Whistleblowing Policy (Public Interest Disclosure)


The aims of this policy are to:

  • Encourage staff to report suspected wrongdoing, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected.
  • Provide guidance as to how to raise those concerns.
  • Reassure staff that they can raise genuine concerns without fears of reprisals, even if they turn out to be mistaken.

This policy is not designed to replace the normal procedures whereby a Manager is informed when there are concerns about an individual’s behaviour. For instance, if it is felt by colleagues that an individual is bullying another member of staff then this should be reported immediately to the appropriate Manager. If a member of staff is worried about their own personal circumstances, such as the way they have been treated at work then they should use the grievance procedure or Anti Bullying and Harassment Policy as appropriate to raise their complaint. The purpose of this policy is to provide an internal mechanism for reporting, where there are concerns of possible serious business malpractice, which the employee reasonably believes it is in the public interest to disclose.

The normal procedure to be followed is set out at the end of this policy. The procedure has been drawn up to provide safeguards to enable individuals to raise genuine concerns of possible malpractice within the Group whilst balancing this against the need to protect members of staff against uninformed, vexatious or malicious allegations.

If an employee of the Group becomes aware of any of the following matters (or any similar matter of concern) he/she should report such matter to the Group in accordance with this policy:

  • that a criminal offence has been committed, is being committed, or is likely to be committed;
  • that a person has failed, is failing or is likely to fail to comply with any legal obligation to which that person is subject;
  • that a miscarriage of justice has occurred, is occurring or is likely to occur;
  • that the health or safety of any individual has been, is being or is likely to be endangered;
  • that the environment has been, is being or is likely to be damaged; or
  • that information tending to show that any of the above is being, or is likely to be concealed.

This policy should also be used to report any concerns that you have about any suspicion of bribery, corruption or other potential breach of the Company’s Anti-Corruption and Bribery Policy or Gifts and Hospitality Policy.

An individual who believes that one of the matters above (or similar matter) has occurred should approach his or her line manager who will then approach the Group HR Department (“HR”) in confidence in accordance with the procedure set out below.

Any individual who reports any matter under this policy shall not be victimised or subjected to detriment by the Group as a result of their actions.

Any other employee of the Group who threatens or retaliates against whistleblowers 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.

However, the Group may also take disciplinary action against an individual where there are grounds to believe that the matter raised has been made maliciously, vexatiously or for personal gain, or where the individual has, without good reason, failed to follow the appropriate procedural steps.


This procedure applies to all individuals who work within the Group, including all contract and freelance staff.

The procedure is a formal one and is designed to protect the identity of the individual raising the concern (“the Discloser”) wherever possible.

The Company does not encourage staff to make disclosures anonymously. Proper investigation may be more difficult or impossible if we cannot obtain further information from the Discloser. It is also more difficult to establish whether any allegations are credible. Individuals who are concerned about possible reprisals if their identity is revealed should come forward to HR and appropriate measures can then be taken to preserve confidentiality. If you are in any doubt you can seek advice from Public Concern at Work, the independent whistleblowing charity, who offer a confidential helpline. Their contact details are set out at the end of this policy.

The Discloser should, as soon as practicable, disclose in confidence the grounds for the belief of malpractice to his or her line manager who should, in turn, report the alleged malpractice to HR.

In the event that the Discloser is concerned that his or her line manager is involved in the

malpractice complained of, then they should approach HR directly.

In the event that the Discloser is concerned that HR is involved in the malpractice complained of, then he/she should approach the Group COO and, in those circumstances, references in this policy to HR shall be deemed to be references to the COO.

Any assertion of malpractice under this policy should, wherever possible, be in writing, but, if this is not practicable, any such disclosure may be verbal and, in either event, the grounds for the belief of malpractice should be stated, as well as the identity of those accused of malpractice (if known).

On receipt of the disclosure, the line manager (if appropriate) and HR should interview the Discloser in confidence. Such interview will take place as soon as practicable after the initial disclosure, but normally within 10 working days of the disclosure being received or communicated.

The Discloser may be accompanied at the interview by a work colleague or local trade union representative if he/she wishes. The Discloser’s companion must respect the confidentiality of the disclosure and any subsequent investigation. Any notes or other written material made at the meeting shall not identify the name of the Discloser without his/her permission.

As soon as practicable after the interview, HR will recommend what further steps should be taken. Such recommendations should be made to the appropriate officer of the Group and may include one or more of the following:

  • that the matter be reported to the police or to the appropriate public authority;
  • that the matter should be further investigated either internally within the Group or by external auditors or investigators appointed by the Group;
  • that a worker should be given the opportunity to seek redress through the Group’s grievance procedure, if appropriate.

Unless the Discloser has otherwise consented in writing, HR’s recommendations will be made without revealing the identity of the Discloser as far as practicable. The recipient of the recommendations will take steps to ensure that the recommendations are implemented except if, in the view of the recipient, there are good reasons for not doing so.

Once HR has decided what further steps (if any) should be taken, it will inform the Discloser and the Discloser’s line manager of the decision. If no further steps by the Group are proposed, HR will give the reasons for this in writing. The Discloser should treat any information received during the investigation process as confidential.

The Discloser will not be required by the Group, without his/her consent, to participate in an enquiry or investigation into the matter established by the Group unless there are grounds to believe that the Discloser’s participation is necessary on an open rather than confidential basis to establish the facts of the matter, although as far as practicable the identity of the individual as the original Discloser of the information under this procedure will remain confidential.

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.

The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. It will very rarely, if ever, be appropriate to alert the media. We strongly encourage you to seek advice before reporting a concern to anyone external. The independent whistleblowing charity, Public Concern at Work, operates a confidential helpline, their contact details are: (020) 7404 6609: whistle@pcaw.co.uk: www.pcaw.co.uk.