The Briggs Group is committed to always acting in a manner which is ethical, fair, even-handed and in compliance with all laws, regulations, and obligations. However, all organisations are at risk of accidentally developing practices which are illegal, unfair, and unethical if there is not sufficient accountability. This Policy aims to encourage our employees with serious concerns about any aspect of our business to come forward and voice those concerns, so that they can be investigated effectively.
‘Whistleblowing’ is the term used in respect of disclosing information in the public interest and has a specific legal definition under the Public Interest Disclosure Act 1998, i.e., a disclosure of information which, in the reasonable belief of the person making the disclosure is made in the public interest and tends to show serious wrongdoing or danger (‘a protected disclosure’). Any ‘worker’ of our Company, for example, agency staff, contractors, consultants, and employees fall within this Policy.
The Policy covers disclosures of serious wrongdoing or danger made by our workers. It is the responsibility of The Board of Directors to ensure that the Whistleblowing Policy has been adopted by The Briggs Group and that all staff are aware of it and can access it easily.
The Public Interest Disclosure Act 1998 (the “Act”) gives legal protection from dismissal, disciplinary action, penalisation, or adverse treatment where someone discloses serious concerns, provided that the disclosure is made in accordance with the Act.
Purpose of this Policy and Relationship to Grievance Procedure
The purpose of this Policy is to allow workers to raise concerns about serious malpractice or noncompliance within The Company. It should not be used lightly or frivolously, or as an initial means for dealing with personal grievances. Personal grievances should be raised through The Company’s normal grievance procedure.
Examples of serious wrongdoing or dangers under the Act and this Policy are:
Breach of a legal or professional obligation
Any criminal activity, including incitement to commit a criminal act
Bribery, corruption, or fraud
A miscarriage of justice
A danger to the health or safety of any individual or damage to the environment
Abuse of power or authority
How to Raise Concerns
Workers should raise any concerns under this Whistleblowing Policy directly with their line manager (or if their line manager is the subject of their concerns, their immediate superior) or The Human Resource Department at firstname.lastname@example.org.
Where someone has tried all other channels or is unable to raise concerns with any of the above, then they should address their concerns to a Director of The Briggs Group Board.
How the Company Will Deal with Concerns
The Briggs Group will deal with any concerns raised under this policy by launching an investigation to determine if any further action is necessary. This will usually begin by making informal enquiries and inspecting and auditing records and procedures but may result in a formal investigation at a later stage.
The person raising a concern may be asked to attend a meeting to discuss those concerns and a colleague or union representative may accompany them to any meeting under this policy. The companion must respect the confidentiality of the disclosure and any subsequent investigation.
The Company will inform the person who raised the concerns who is investigating the matter and will keep them informed of any developments or decisions so long as these are not confidential.
Raising Concerns Externally
In exceptional circumstances it may be necessary for someone to raise concerns externally to certain prescribed persons (such as a regulator). This should only be done in cases where it is not possible for the person to raise concerns internally, or where this has been done but the concerns have been dismissed.
Concerns should only be raised with an external regulator or authority where the person reasonably believes that the allegations are substantially true, and we would encourage anyone to seek independent advice before taking this step.
A list of external persons can be found in the schedule to the Public Interest Disclosure Act 1998 which can be viewed online at www.legislation.gov.uk.