Disclosure Procedure

Procedure

If an employee is concerned about any form of wrongdoing, malpractice or danger and they want to discuss the concern or raise it in writing with someone that they can identify and confide in they should normally first raise the issue with their Line Manager. There is no special procedure for doing this: they can tell that person about the problem or put it in writing if they prefer.

If they feel they cannot tell their Line Manager, for whatever reason, they should raise the issue with a Company Director.

After an employee has raised a concern, the Company will decide how to respond in a responsible and appropriate manner under this policy. Typically, this will involve making internal enquiries first, but it may be necessary to carry out a formal or informal investigation depending on the nature of the concern raised. 

External investigators may be brought in where necessary. The Company will endeavour to complete investigations within a reasonable time.

The Company will keep the employee informed of the progress of the investigation carried out and when it is completed. The Company will not be able to inform them of any matters which would infringe the duty of confidentiality owed to others.

Raising your concern externally (exceptional cases) 

The main purpose of this policy is to give the employee the opportunity and protection they need to raise concerns internally. The Company would expect that in almost all cases raising concerns internally would be the most appropriate action for them to take.

However, if for whatever reason, they feel they cannot raise their concerns internally and they reasonably believe the information and any allegations are substantially true, they can consider raising the matter with the appropriate regulator. A list of the bodies currently listed as regulators for this purpose and the areas they are responsible for is available from Protect (see below). 

If an employee has good reasons for not using the internal or regulatory disclosure procedures described above, they may consider making wider disclosure by reporting the matter to the police or to the media, for example. However, employees who make wider disclosures of this type will only be protected (from dismissal or suffering detrimental treatment) in certain circumstances. The Company recommends that employees take legal advice before following this course of action since we believe it will be in employees’ own interests to do so.

Protect is a leading independent charity whose main objectives are to promote compliance with the law and good practice in the public, private and voluntary sectors. They are a source of further information and advice at www.protect-advice.org.uk.

Those using the procedure outlined in this policy to raise a concern are assured that they will not suffer any form of punishment or detrimental treatment. Any person who victimises a bona fide whistleblower (e.g. by subjecting them to any form of detrimental treatment) will be liable to disciplinary action. Such a person is also liable to an employment tribunal claim (which may include liability for unlimited damages) brought by the whistleblower against them personally. To ensure the protection of all our employees, those who maliciously make an allegation they do not reasonably believe to be true and/or not made in the public interest will also be liable to disciplinary action.

If you have any questions about the application of this policy, please contact your Line Manager.