This policy applies to all persons working for the Company or on our behalf in any capacity, including employees at all levels, directors, officers, managers, employees, consultants, freelancers, contractors, trainees, volunteers, interns, casual workers and agency workers.
We are committed to conducting our business with honesty and integrity and we expect all staff to maintain high standards. However, all organisations face the risk of things going wrong from time to time, or of unknowingly harbouring illegal or unethical conduct. A culture of openness and accountability is essential in order to prevent such situations occurring and to address them when they do occur. Any suspected wrongdoing should be reported as soon as possible.
The aims of this policy are to:
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, freelancer complaints procedure, the Anti-Harassment and Bullying Policy or the Prevention of Sexual 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, including allegations of sexual harassment, which the individual reasonably believes it is in the public interest to disclose.
The All3Media Group has a confidential whistleblowing support line, run by Protect, an independent whistleblowing charity. Calls to Protect are made under legal privilege, and the detail of the call will be kept confidential, and not disclosed by Protect to All3Media.
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.
Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. If an individual of the Group becomes aware of any of the following matters (or any similar matter of concern) they should report such matter to the Group in accordance with this policy:
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 their manager who will then approach People/HR in confidence in accordance with the procedure set out below.
We aim to encourage openness and will support whistleblowers who raise genuine concerns under this policy, even if they turn out to be mistaken. 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. If you believe that you have suffered any such treatment, you should inform All3Media Group COO immediately. If the matter is not remedied, you should raise it formally using our Grievance Procedure.
Any other individual of the Group who threatens or retaliates against whistleblowers may be subject to disciplinary action up to and including the termination of your employment or in the case of individuals who are not employees, your engagement may be terminated forthwith. 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 up to and including the termination of your employment or in the case of individuals who are not employees, your engagement may be terminated forthwith, 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 policy and the procedure below does not form part of any contract of employment or other contract to provide services, and we may amend it at any time and/or depart from it as we consider necessary.
We hope that in many cases you will be able to raise any concerns with your manager. However, where you prefer not to raise it with your manager for any reason, you should contact the Managing Director, Contact details are at the end of this policy.
The procedure is a formal one and is designed to protect the identity of the individual raising the concern (the “Discloser”) wherever possible.
We hope that staff will feel able to voice whistleblowing concerns openly under this policy. 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 and only reveal your identity where necessary to those involved in investigating your concern. If you are in any doubt, you can seek advice from Protect the independent whistleblowing charity, who run a confidential helpline for the All3Media Group. Details of the Protect whistleblowing line 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 their manager who should, in turn, report the alleged malpractice to HR.
In the event that the Discloser is concerned that their manager is involved in the malpractice complained of, then they should approach HR directly or the All3 Media Group COO.
In the event that the Discloser is concerned that HR is involved in the malpractice complained of, then they should approach the All3 Media 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 Manager (if appropriate) and People/HR should meet with the Discloser in confidence. to discuss the concern. Such meeting will take place as soon as practicable after the initial disclosure.
The Discloser may be accompanied at the meeting by a work colleague or local trade union representative if they wish. 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 their permission.
As soon as practicable after the meeting, 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:
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 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. Sometimes the need for confidentiality may prevent the Discloser from being given specific details of any ongoing investigation or any action taken as a result of confidentiality and/or data protection and/or other restrictions preventing the Company from disclosing the outcome of its investigations to the Discloser.
The Discloser will not be required by the Group, without their 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. The Discloser must also keep any information about the investigation as confidential.
While we cannot always guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way. By using this policy, you can help us to achieve this.
If you are not happy with the way in which your concern has been handled, you may contact the Group COO or where relevant the Group CEO.
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 and to make use of the independent and confidential Protect whistleblowing helpline, whose details are set out at the end of this policy.
Whistleblowing concerns usually relate to the conduct of our staff, but they may sometimes relate to the actions of a third party, such as a customer, supplier or service provider. In some circumstances the law will protect you if you raise the matter with the third party directly.
However, we encourage you to report such concerns internally first, in line with this policy.
The All3Media confidential whistleblowing helpline is run by an independent charity called Protect and provides free, confidential whistleblowing advice.
The helpline will be open Mondays, Tuesdays, Thursdays: 9:30am – 1pm and 2pm – 5:30pm; Wednesdays and Fridays: 9:30am – 1pm, excluding Bank Holidays.
Managing Director John Whittle: jwhittle@limepictures.com
