Whistleblowing policy

It is important to the Company that any fraud, misconduct or wrongdoing is reported and properly dealt with. The Company therefore encourages all individuals to raise any concerns that they may have about the conduct of others in the business or the way in which the business is run.

This policy sets out the way in which individuals may raise any concerns that they have and how those concerns will be dealt with. It applies to all employees of the Company, full time and part-time employees on fixed-term contracts and others performing functions in relation to the organisation, such as agency workers and contractors, are encouraged to use it. It is also available to use by any external third party or counterparty.

This policy and procedure are not contractual and the Company reserves the right to amend it should it, in its sole discretion, elect to do so.
 

Principles

• Everyone should be aware of the importance of preventing and eliminating wrongdoing at work. Individuals should be watchful for illegal or unethical conduct and report anything of that nature that they become aware of.
• Any matter raised under this procedure will be investigated thoroughly, promptly and confidentially, and the outcome of the investigation reported back to the worker who raised the issue. 
• No individual will be victimised for raising a matter under this policy. This means that the continued employment and opportunities for future promotion or training of the individual will not be prejudiced because he/she has raised a legitimate concern.
• Victimisation of a worker for raising a qualified disclosure will be a disciplinary offence.
• If misconduct is discovered as a result of any investigation under this procedure the organisation's disciplinary procedure will be used, in addition to any appropriate external measures.
• Maliciously making a false allegation is a disciplinary offence.
• An instruction to cover up wrongdoing is itself a disciplinary offence. If told not to raise or pursue any concern, even by a person in authority such as a manager, individuals should not agree to remain silent.
   

This procedure is for disclosures about matters other than a breach of an employee's own contract of employment. If an employee is concerned that his/her own contract has been, or is likely to be, broken, he/she should use the organisation's grievance procedure.