1.1 This policy applies to all employees, freelancers, agents, talent, agency workers, sub-contractors, suppliers, subsidiaries and fixers, or any other person or company engaged by the Company (collectively known as “staff”).
1.2 This policy does not form part of any employee’s contract of employment and we may amend it at any time.
2 POLICY STATEMENT
2.1 We are committed to conducting our business with honesty and integrity and we expect all staff to maintain high standards. We encourage staff to report suspected wrongdoing as soon as possible.
3 WHAT IS WHISTLEBLOWING?
Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our activities. This includes bribery, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment and any breach of legal or professional obligations.
4 HOW TO RAISE A CONCERN
4.1 We hope that in many cases any concerns can be raised with the staff member’s line manager. However, where this is not possible or appropriate, then the staff member should contact a Director.
4.2 We will arrange a meeting with the staff member as soon as possible to discuss the concern. The member of staff may bring a colleague or union representative to any meetings under this policy. The companion must respect the confidentiality of the disclosure and any subsequent investigation.
We hope that staff will feel able to voice whistleblowing concerns openly under this policy. Completely anonymous disclosures are difficult to investigate. If a staff member wants to raise a concern confidentially, we will make every effort to keep the staff member’s identity secret and only reveal it where necessary to those involved in investigating the concern.
6 EXTERNAL DISCLOSURES
6.1 The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases staff members should not find it necessary to alert anyone externally.
6.2 The law recognises that in some circumstances it may be appropriate for staff members to report concerns to an external body such as a regulator. We strongly encourage staff to seek advice before reporting a concern to anyone external. Public Concern at Work operates a confidential helpline. Their contact details are at the end of this policy.
7 PROTECTION AND SUPPORT FOR WHISTLEBLOWERS
7.1 We aim to encourage openness and will support staff who raise genuine concerns under this policy, even if they turn out to be mistaken.
7.2 Staff must not suffer any detrimental treatment as a result of raising a genuine concern. If staff believe that they have suffered any such treatment, they should inform the Whistleblowing Officer immediately.
7.3 Staff must not threaten or retaliate against whistleblowers in any way. If employees are involved in such conduct they may be subject to disciplinary action. If non-employees are involved in such conduct their contracts may be summarily terminated.
7.4 If we conclude that a whistleblower has made false allegations maliciously or with a view to personal gain, the whistleblower may be subject to disciplinary action, or summary termination as appropriate.
7.5 Public Concern at Work operates a confidential helpline. Their contact details are at the end of this policy.