1. OVERVIEW
This policy outlines what you should do if you suspect something happening at work is putting you or others in danger or is illegal or unethical.
The purpose of this policy is to enable us to investigate and deal properly and sensitively with allegations of wrongdoing and does not replace the Grievance Policy contained in our internal Employee Handbook. This policy is intended to assist individuals who believe they have discovered malpractice or impropriety. It is not designed to question financial or business decisions taken by Nations Recruitment nor should it be used to reconsider any matters which have already been addressed under harassment, complaint, disciplinary or other policies.
2. WHAT IS WHISTLEBLOWING?
Our aim is to maintain the highest standards of integrity in everything we do. However, all organisations can occasionally be affected by conduct that is dangerous, against the law or breaches ethical or professional codes.
Should you have any such concerns, we encourage you to report them immediately — this is called ‘whistleblowing’. You can be assured that we will take your concerns seriously, they will be thoroughly investigated, and you can be confident there will be no reprisals.
2.1. The types of concerns you may want to raise with us by whistleblowing might include:
any activity you suspect is criminal
any activity you suspect puts health and safety at risk
any activity you suspect may damage the environment
any activity you suspect breaches our policy on bribery and corruption
any failure to comply with legal or regulatory obligations
any failure to meet professional requirements; and/or
any attempt to conceal one or more of these activities.
you can disclose this information orally or in writing to the HR Manager. If you make such a disclosure, you should provide full details and, where possible, supporting evidence.
Note that if your complaint is about the way people are behaving towards you, then you should refer to our policy on Bullying and Harassment, or to our Grievance Policy, for guidance on how to proceed.
3. Safeguards
It is important that these issues are dealt with sensitively and quickly. Anonymous disclosures are strongly discouraged as they are likely to hinder effective investigation. However, if you disclose information in accordance with this procedure, in so far as it is reasonably practicable, your identity will be kept confidential.
If you reasonably believe that the nature of your concern relates to any of the areas set out above and you disclose this information to the appropriate person under this procedure in good faith no action will be taken against you for making the disclosure.
Nations Recruitment will take appropriate disciplinary action, up to and including summary dismissal, against any worker:
found to be victimising another worker for using this procedure, or deterring any worker from reporting genuine concerns under it, or
making a disclosure/allegation maliciously or veraciously.
4. Procedure
We will promptly investigate your allegation and will take whatever action it considers appropriate. Your assistance may be required during the investigation.
On receipt of a complaint of malpractice, the member of staff who receives and takes note of the complaint, must pass this information as soon as is reasonably possible, to the appropriate designated investigating officer as follows:
Complaints of malpractice will be investigated by the appropriate Director unless the complaint is against the Director or is in any way related to the actions of the Director. In such cases, the complaint should be passed to the Group MD for referral.
In the case of a complaint, which is any way connected with but not against the Director, the Group MD will nominate a Senior Manager to act as the alternative investigating officer.
Complaints against the Group MD should be passed to the Chairman who will nominate an appropriate investigating officer.
The complainant has the right to bypass the line management structure and take their complaint direct to the Chairman. The Chairman has the right to refer the complaint back to management if he/she feels that the management without any conflict of interest can more appropriately investigate the complaint.
If there is evidence of criminal activity then the investigating officer should inform the police. The Company will ensure that any internal investigation does not hinder a formal police investigation.
5. Timescales
Due to the varied nature of these sorts of complaints, the investigating officer should ensure that investigations are undertaken as quickly as possible without affecting the quality and depth. The investigating officer, should as soon as practically possible, send a written acknowledgement of the concern to the complainant and thereafter report back to them in writing the outcome of the investigation and on the action that is proposed. If the investigation is a prolonged one, the investigating officer should keep the complainant informed, in writing, as to the progress of the investigation and as to when it is likely to be concluded.
All responses to the complainant will be in writing and sent to a private address/email.
6. Investigating Procedure
The investigating officer should follow these steps:
Full details and clarifications of the complaint should be obtained.
The investigating officer should inform the member of staff against whom the complaint is made as soon as is practically possible. The member of staff will be informed of their right to be accompanied by a trade union or other representative at any future interview or hearing held under the provision of these procedures.
The investigating officer should consider the involvement of the Company auditors and the Police at this stage and should consult with the Chairman / Group MD.
The allegations should be fully investigated by the investigating officer with the assistance where appropriate, of other individuals / bodies.
A judgement concerning the complaint and validity of the complaint will be made by the investigating officer. This judgement will be detailed in a written report containing the findings of the investigations and reasons for the judgement. T
he report will be passed to the Group MD or Chairman as appropriate.
The Group MD / Chairman will decide what action to take. If the complaint is shown to be justified, then they will invoke the disciplinary or other appropriate Company procedures.
The complainant should be kept informed of the progress of the investigations and, if appropriate, of the final outcome.
If appropriate, a copy of the outcomes will be passed to the Company Auditors to enable a review of the procedures.
If the complainant is not satisfied that their concern is being properly dealt with by the investigating officer, they have the right to raise it in confidence with the Group MD / Chairman, or one of the designated persons described above.
If the investigation finds the allegations unsubstantiated and all internal procedures have been exhausted, but the complainant is not satisfied with the outcome of the investigation, the Company recognises the lawful rights of employees and ex-employees to make disclosures to prescribed persons (such as the Health and Safety Executive, the Audit Commission, or the utility regulators), or, where justified, elsewhere.
7. PROTECTION AND SUPPORT FOR WHISTLEBLOWERS
7.1 We aim to encourage openness and will support whistleblowers who raise genuine concerns under this policy, even if they turn out to be mistaken.
7.2 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 the Managing Director immediately. If the matter is not remedied you should raise it formally using our Grievance Procedure.
7.3 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. In some cases the whistleblower could have a right to sue you personally for compensation in an employment tribunal.
7.4 However, if we conclude that a whistleblower has made false allegations maliciously, the whistleblower may be subject to disciplinary action.
7.5 Public Concern at Work operates a confidential helpline. Their contact details are at the end of this policy.
CONTACTS
Operative Support Team
Helpline: (020) 33045782
Email: info@nationsrecruitment.com