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. WHAT IS WHISTLEBLOWING?
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;
(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. RAISING A WHISTLEBLOWING CONCERN
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: email@example.com
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
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
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. EXTERNAL DISCLOSURES
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
6. INVESTIGATION AND OUTCOME
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. IF YOU ARE NOT SATISFIED
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
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. PROTECTION AND SUPPORT FOR WHISTLEBLOWERS
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