Whistleblowing Policy

We are committed to conducting our business with honesty and integrity and we expect everyone who works for us to maintain these standards. Any suspected wrongdoing should be reported as soon as possible.

What is whistleblowing?

Whistleblowing is the reporting of suspected wrongdoing or danger. This may include bribery, fraud or other criminal activity, a miscarriage of justice, a serious health and safety risk, damage to the environment or a breach of legal or professional obligations.

How to raise a concern

We hope that in most cases you will be able to raise your concern with your Line Manager or Head of Department. However, if for any reason you prefer not to do so, you should raise it with our Head of HR or Chief Executive.

We will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague to the meeting. Your colleague must respect the confidentiality of your disclosure and any subsequent investigation, and failure to do so may constitute misconduct.

Confidentiality

We hope that our employees will feel able to voice concerns openly under this policy. Completely anonymous disclosures are difficult to investigate. If you want to raise your concern confidentially, you should do so to our Head of HR. We will make every effort to keep your identity secret and reveal it only, where necessary, to those involved in investigating your concern.

External disclosures

The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally.

However, in some circumstances, it may be appropriate for you to report your concerns to an external body such as a regulator. We strongly encourage you to seek advice before reporting a concern to anyone external. Public Concern at Work operates a confidential helpline. Their contact details are at the end of this policy.

Protection and support for whistleblowers

We aim to encourage openness and will support whistleblowers who raise genuine concerns under this policy, even if they turn out to be mistaken.

Whistleblowers must not suffer any detrimental treatment as a result of raising a genuine concern. If you believe that you have suffered any such treatment, you should inform our Head of HR immediately. If the matter is not remedied, you should raise it formally using our Grievance Procedure.

You must not threaten or retaliate against whistleblowers in any way. If you are involved in such conduct, you may be subject to disciplinary action under our Disciplinary Procedure. However, if we conclude that a whistleblower has made false allegations maliciously, in bad faith or with a view to personal gain, the whistleblower may be subject to disciplinary action.

Public Concern at Work operates a confidential helpline. Their contact details are:

Helpline: (020) 7404 6609 E-mail: whistle@pcaw.co.uk Website: www.pcaw.co.uk

If you have a question about any aspect of our Whistleblower Policy please contact our Head of HR.

Last updated: 07/03/19