Whistleblowing

(Non-contractual policy. Your rights under the Public Interest Disclosure Act 1998 (as incorporated into the Employment Rights Act 1996) are statutory and cannot be overridden.)

What Is Whistleblowing?

Whistleblowing means reporting a genuine concern about wrongdoing or malpractice within the organisation that is in the public interest. This is different from a personal grievance (which should be raised under the grievance procedure).

Protected disclosures cover concerns about:

• Criminal offences (including fraud and corruption).
• Failure to comply with a legal obligation.
• Miscarriages of justice.
• Danger to the health and safety of any person.
• Damage to the environment.
• Deliberate concealment of any of the above.

How to Raise a Concern

If you believe that wrongdoing is occurring, has occurred, or is likely to occur, raise it with Mike Wood in the first instance. You may do this verbally or in writing.

If your concern involves Mike Wood, or if you feel unable to raise it internally, you may raise it with a prescribed person or body — for example:

• Health and Safety Executive (HSE) for health and safety matters.
• Information Commissioner’s Office (ICO) for data protection matters.
• HM Revenue & Customs for tax matters.
• Environment Agency for environmental matters.

A full list of prescribed persons is published by the government.

Protection

The company will not tolerate any retaliation, victimisation, or detriment against an employee who raises a genuine concern in good faith under this policy. Employees who subject a whistleblower to detriment will face disciplinary action.

You are protected by law if you make a qualifying disclosure, even if your concern turns out to be unfounded, provided you reasonably believed it to be true and in the public interest at the time.

Investigation

All concerns raised under this policy will be taken seriously. The company will investigate promptly and, where possible, keep you informed of progress and outcome. Confidentiality will be maintained as far as reasonably possible, but it may be necessary to disclose your identity if the matter proceeds to a formal investigation or legal proceedings.