Terms, Policies and Statements



The Company is committed to maintain the high standards of honesty, openness and responsibility. Therefore, the Company treats unprofessional conduct very seriously, whether it is committed by managers, employees, suppliers or contractors.


Policy Aim


The Company recognises that an employee may find it difficult to raise concerns of malpractice and misconduct. This policy will provide a means to raise concerns so that they can be investigated properly, sensitively and in confidence. The Company also recognises the need to ensure any employee using this system is protected from receiving or suffering any disadvantage as a result of raising a concern in good faith




Whistle Blowing


Is a term used when someone who works in or for an organisation raises a concern about a possible fraud, crime, danger or other serious risk that could threaten customers, colleagues, shareholders, the public or the organisation’s own reputation. If any employee brings information about a wrongdoing to the attention of their employers or a relevant organisation, they are protected in certain ways under the Public Interest Disclosure Act 1998, so people are encouraged to speak out if they find malpractice in an organisation.


Public Interest Disclosure


Blowing the whistle is more formally known as ‘making a disclosure in the public interest.’

Disclosure of information is information, which, in the reasonable belief of the employee making the disclosure, tends to show one or more of the following:


  • 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 he 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.
  • That information tending to show any matter falling within any one of the preceding paragraphs has been, is being, or, is likely to be deliberately concealed.





The Company will make available a reporting procedure to any employee who genuinely believes that the Company or any employee of the Company has taken or failed to take action that they reasonably believe will lead to, or amount to, any of the following:


  • A failure to comply with any legal obligations
  • A criminal offence
  • A miscarriage of justice
  • Danger to the health and safety of an individual
  • Damage to the environment
  • The deliberate concealment of information tending to show any of the above.

Any employee who has a concern regarding malpractice and misconduct within the Company, should raise that concern internally, rather than externally, wherever possible, using the policy.


This policy is not intended to replace the Company’s Grievance Procedure that remains the proper method of dealing with issues of a personal nature relating to matters of employment.


Matters can be raised either verbally or in writing. Any employee wishing to use this policy should contact their manager who will immediately agree an appropriate course of action. Should the malpractice report concern the manager or the employee considers that it is not appropriate to raise the matter with a manager; the matter can be disclosed to any member of the senior management:


  • Disclosures should be provided with full details and, where possible, supporting evidence.
  • Any disclosure made under this policy will be treated in the strictest of confidence.
  • Any origin of an allegation will be kept confidential wherever possible.
  • Anonymous disclosures may be made, however this type of disclosures can make investigations difficult.
  • Anyone reporting allegations will be given appropriate advice and support during the process.
  • Where possible the Company will inform of the outcome of the investigation.

Employees will not be punished or subject to detrimental action as a result of making a disclosure in accordance with this policy. Any harassment, victimisation or less favourable treatment of any persons will be treated as a disciplinary offence, under the Harassment, Victimisation and Bullying Policy.



Should any employee make a disingenuous disclosure i.e. in order to cause disruption to the Company or without reasonable belief, or accuracy, disciplinary action may be taken.

Use of this policy will not affect any duty of confidentiality an employee may owe the Company. Under the duty of confidentiality employees may not disclose confidential information about the Company without authorisation.


Non Compliance


All employees have a role to play in enforcing the policy and are required to deal with any observed or reported breaches. Should employees feel apprehensive about their own safety in regard to addressing any breach, they should seek senior management support.

Failure to comply with this policy may lead to a lack of clarity over job role, learning needs or expected standards of performance, resulting in reduced effectiveness or efficiency, underperformance and putting service delivery at risk.

Any member of staff refusing to observe the policy will be liable to disciplinary action in accordance with the Company’s Disciplinary Policy up to and including dismissal.


Implementation of the Policy


Overall responsibility for policy implementation and review rests with the Company senior management. However, all employees are required to adhere to and support the implementation of the policy. The Company will inform all existing employees about this policy and their role in the implementation of the policy. They will also give all new employees notice of the policy on induction to the Company.

This policy will be implemented through the development and maintenance of procedures for appraisals and one-to-one meetings, using template forms, and guidance given to both managers and employees on the process.


Monitoring Policy


The policy will be monitored on an on-going basis, monitoring of the policy is essential to assess how effective the Company has been.


Reviewing Policy


This policy will be reviewed and, if necessary, revised in the light of legislative or codes of practice and organisational changes. Improvements will be made to the management by learning from experience and the use of established reviews.


Policy Amendments


Should any amendments, revisions, or updates be made to this policy it is the responsibility of the Company senior management to see that all relevant employees receive notice. Written notice and/or training will be considered.


Additional Information


If you require any additional information or clarification regarding this policy, please contact your manager. In the unlikely event where you are unhappy with any decision made, you should use the Company’s formal Grievance Procedure.

To the extent that the requirements of this policy reflect statutory provisions, they will alter automatically when and if those requirements are changed.