Whistleblowing Policy

1. Whistleblowing Policy

1.1 We are committed to conducting our business with honesty and integrity, and we expect

all staff to maintain high standards in accordance with our Code of Conduct. However,

all organisations face the risk of things going wrong from time to time, or of unknowingly

harbouring illegal or unethical conduct.


1.2 A culture of openness and accountability is essential in order to prevent such situations

occurring or to address them when they do occur.


1.3 The aims of this policy are:

(a) To encourage staff to report suspected wrongdoing as soon as possible, in 

the knowledge that their concerns will be taken seriously and investigated as

appropriate, and that their confidentiality will be respected.

(b) To provide staff with guidance as to how to raise those concerns.

(c) To reassure staff that they should be able to raise genuine concerns in good faith

without fear of reprisals, even if they turn out to be mistaken.



2.1 Whistleblowing is the disclosure of information which relates to suspected wrongdoing

or dangers at work. This may include:

(a) criminal activity;

(b) miscarriages of justice;

(c) danger to health and safety;

(d) damage to the environment;

(e) failure to comply with any legal [or professional] obligation or regulatory


(f) financial fraud or mismanagement;

(g) negligence;

(h) conduct likely to damage our reputation;

(i) unauthorised disclosure of confidential information;

(j) the deliberate concealment of any of the above matters.


2.2  A whistleblower is a person who raises a genuine concern in good faith relating to any

of the above. If you have any genuine concerns related to suspected wrongdoing or

danger affecting any of our activities (a whistleblowing concern) you should report it

under this policy.


2.3 This policy should not be used for complaints relating to your own personal

circumstances, such as the way you have been treated at work. In those cases, you should

use the Grievance Procedure or Anti-harassment and Bullying Policy as appropriate.


2.4 If you are uncertain whether something is within the scope of this policy you should seek

advice from your director, whose contact details are at the end of this policy.



3.1 We hope that in many cases you will be able to raise any concerns with your line

manager. You may tell them in person or put the matter in writing if you prefer. They may

be able to agree on a way of resolving your concern quickly and effectively. In some cases,

they may refer the matter to the director.


3.2 However, where the matter is more serious, or you feel that your line manager has not

addressed your concern, or you prefer not to raise it with them for any reason, you

should contact one of the following:

(a) Altin Biba

(b) HR Manager

(c) Alternatively through our dedicated inbox: speakout@promedical.co.uk


3.3 A meeting with you as soon as possible to discuss your concern. You may bring a

colleague or union representative to any meetings under this policy. Your companion

must respect the confidentiality of your disclosure and any subsequent investigation.


3.4 We will take down a written summary of your concern and provide you with a copy after

the meeting. We will also aim to give you an indication of how we propose to deal with

the matter.


4.1 We hope that staff will feel able to voice whistleblowing concerns openly under this

policy. However, if you want to raise your concern confidentially, we will make every

effort to keep your identity secret. If it is necessary for anyone investigating your

concern to know your identity, we will discuss this with you.


4.2 We do not encourage staff to make disclosures anonymously. Proper investigation may

be more difficult or impossible if we cannot obtain further information from you. It is also

more difficult to establish whether any allegations are credible and have been made in

good faith.


4.3 Whistleblowers who are concerned about possible reprisals if their identity is revealed

should come forward to your director or one of the other contact points listed in

paragraph 3.2 and appropriate measures can then be taken to preserve confidentiality.


5.1 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.


5.2 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. The law allows you to raise a concern in good faith with a third party, where

you reasonably believe it relates mainly to their actions or something that is legally their

responsibility. However, we encourage you to report such concerns internally first. You

should contact your line manager or one of the other individuals set out in paragraph 3.2

for guidance.


6.1 Once you have raised a concern, we will carry out an initial assessment to determine the

scope of any investigation. We will inform you of the outcome of our assessment. You

may be required to attend additional meetings in order to provide further information.


6.2 In some cases we may appoint an investigator or team of investigators including staff

with relevant experience of investigations or specialist knowledge of the subject matter.

The investigator(s) may make recommendations for change to enable us to minimise the

risk of future wrongdoing.


6.3 We will aim to keep you informed of the progress of the investigation and its likely

timescale. However, sometimes the need for confidentiality may prevent us from giving you

specific details of the investigation or any disciplinary action taken as a result. You

should treat any information about the investigation as confidential.


6.4 If we conclude that a whistleblower has made false allegations maliciously, in bad faith

or with a view to personal gain, the whistleblower will be subject to disciplinary action.



7.1 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.


7.2 If you are not happy with the way in which your concern has been handled, you can raise

it with one of the other key contacts listed above.



8.1 It is understandable that whistleblowers are sometimes worried about possible

repercussions. We aim to encourage openness and will support staff who raise genuine

concerns in good faith under this policy, even if they turn out to be mistaken.


8.2 Staff must not suffer any detrimental treatment as a result of raising a concern in good

faith. Detrimental treatment includes dismissal, disciplinary action, threats or other

unfavourable treatment connected with raising a concern. If you believe that you have

suffered any such treatment, you should inform your director immediately. If the matter

is not remedied you should raise it formally using our Grievance Procedure.


8.3 Staff must not threaten or retaliate against whistleblowers in any way. Anyone involved

in such conduct will be subject to disciplinary action.


Date Reviewed: January 2020