This policy applies to all employees, consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors or any other person associated with us, no matter where they are located.
We believe in honest, open and transparent conversations and that most issues can be resolved
this way. This policy sets out how you can raise a whistleblowing concern and the protection and
support that will be available for you.
We recognise that raising a whistleblowing concern can be daunting. However, we encourage you
to raise your concerns internally as soon as possible if you suspect some wrongdoing. We’re here
to listen and will take all concerns that you raise seriously.
Whistleblowing concerns to which this policy relates
Whistleblowing is the act of reporting suspected wrongdoing or risk of wrongdoing relating to:
• A criminal offence;
• A failure to comply with a legal obligation;
• A miscarriage of justice;
• A risk to the health and safety of an individual;
• Damage to the environment; or
• An attempt to cover up any of the above.
It is not necessary for you to prove the wrongdoing. However, to be protected by whistleblowing
laws against detrimental treatment or dismissal, you must reasonably believe that wrongdoing
(related to one of the categories above) is being, has been or is likely to be committed and that
your disclosure is in the public interest.
Step 1 – raising a whistleblowing concern
If you have a genuine concern relating to any type of wrongdoing covered by this policy, there are
a couple of options available to you to raise it;-
i) Raise it internally with your Line Manager or a member of our HR team.
ii) Raise it using the ethicspoint reporting system genphoenix.ethicspoint.com
Internally, your concern can be raised verbally or in writing and should cover:
• Details of the suspected wrongdoing;
• Names of any individuals involved; and
• What action (if any) you are seeking.
In some cases, it may be necessary to ask you to attend a meeting with your Line Manager and a
member of the HR team to clarify the nature of your concern. This will be arranged as soon as
possible and you may, if you wish, bring a colleague or trade union rep with you.
Step 2 – responding to your whistleblowing concern
If you used the ethics-point reporting system you will receive a reply by the same system and will
be able to log on to review progress with your case.
If you raised the concern internally, the Manager that you initially raise your concern with will
decide if an investigation is required and, if it is, who is the most appropriate person to conduct it.
We will then write to you confirming that we are conducting an investigation and giving you some
indication of timescales. The level of investigation and the time it will take will vary depending on
the nature of the suspected wrongdoing.
Following the investigation, we will write to you to confirm its completion, the outcome and any
next steps or action that will be taken. While we will try to provide you with comprehensive
feedback, this may not always be possible where data protection rules apply or where there are
sensitive issues that need to remain confidential.
Stage 3 – appeal
If you are not satisfied with how your concern has been dealt with, you should appeal to the HR
team in writing, setting out the grounds of your appeal. We will arrange a meeting with you,
another manager and a member of the HR team. Once the appeal manager has considered the
grounds for your appeal, you will be informed of the outcome.
Our commitment to you
You have the right not to be subjected to any detrimental treatment because you have raised a
whistleblowing concern. If you raise a whistleblowing concern in line with this policy, we will
ensure you are treated with respect and provided with adequate support.
If you are told not to raise or pursue a whistleblowing concern, or you believe that you have been
subjected to detrimental treatment because you have raised a concern, please talk to the HR team
or raise it under our grievance policy.
Any such behaviour will not be tolerated and it will be treated as a disciplinary offence.
If we find that an individual has knowingly raised false allegations, this will also be treated as a
disciplinary offence.