Rayner Group Whistleblowing Policy

POLICY STATEMENT

1.1 We are committed to conducting our business with honesty and integrity, and we expect all our employees to maintain high standards. All organisations, however, face the risk of something going wrong from time to time, or of unknowingly harbouring illegal or unethical conduct. A culture of openness and accountability is essential in order to prevent such situations occurring or to address them when they do occur.

1.2 The aims of this policy are:

(a) To encourage you to report suspected wrongdoing as soon as possible, in the knowledge that your concerns will be taken seriously and investigated as appropriate, and that your confidentiality will be respected.

(b) To provide you with guidance on to how to raise those concerns.

(c) To reassure you that all Rayner employees should be able to raise genuine concerns in good faith without fear of reprisals, even if they turn out to be mistaken.

1.3 This policy does not form part of any employee’s contract of employment and it may be amended at any time.

1.4 Queries regarding this policy should be referred to the Legal Director.

2. WHAT IS WHISTLEBLOWING?

2.1 Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include:

  • criminal activity;
  • miscarriages of justice;
  • dangers to health and safety;
  • damage to the environment;
  • failure to comply with any legal or professional obligation or regulatory requirements;
  • bribery;
  • financial fraud or mismanagement;
  • serious negligence;
  • breach of our internal policies and procedures;
  • conduct likely to damage our reputation;
  • unauthorised disclosure of confidential information;
  • the deliberate concealment of any of the above matters.

2.1 A whistleblower is a person who raises a genuine concern in good faith relating to any of the above. If you have any genuine concerns related to suspected wrongdoing or danger affecting any of our activities (a whistleblowing concern) you should report it under this policy.

2.2 This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work. In those cases you should use the Grievance Procedure.

3. RAISING A WHISTLEBLOWING CONCERN

3.1 We hope that in most cases you will be able to raise any concerns you have with your Manager. You may tell them in person or put the matter in writing if you prefer. They may be able to agree a way of resolving your concern quickly and effectively. In some cases they may need to refer the matter to the Legal Department.

3.2 Where the matter is more serious however, or you feel that your Manager has not addressed your concern, or you prefer not to raise it with your Manager for any reason, you should contact the Legal Director.

3.3 A meeting will be arranged with you as soon as possible to discuss your concern. You may bring a colleague or union representative to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation.

3.4 A written summary of your concern will be taken at the meeting and we will provide you with a copy after the meeting. We will also aim to give you an indication of how we propose to deal with the concern you have raised.

4. CONFIDENTIALITY

4.1 We hope that all our staff feel able to voice whistleblowing concerns openly under this policy. If you wish to raise your concern confidentially, however, we will make every effort to keep your identity secret. If it is necessary for anyone investigating your concern to know your identity, we will discuss this with you.

4.2 We do not encourage you to make disclosures anonymously. Proper investigation may be more difficult or impossible if we cannot obtain further information from you. It is also more difficult to establish whether any allegations are credible and have been made in good faith. Whistleblowers who are concerned about possible reprisals if their identity is revealed should come forward to the Legal Director and appropriate measures can then be taken to preserve confidentiality.

5 EXTERNAL DISCLOSURES

5.1 The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally. 5.2 The law recognises however, that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. We strongly encourage you to seek advice before reporting a concern to anyone external. The independent whistleblowing charity, Public Concern at Work, operates a confidential helpline. Contact details are: (020) 7404 6609. E-mail: whistle@pcaw.co.uk Website: www.pcaw.co.uk

5.3 Whistleblowing concerns will usually relate to the conduct of our employees but they may sometimes relate to the actions of a third party, such as a customer, supplier or service provider. The law allows you to raise a concern in good faith with a third party, where you reasonably believe it relates mainly to their actions or something that is legally their responsibility. We encourage you however, to report any such concerns internally first. You should contact your Manager or the Legal Department for guidance.

6 INVESTIGATION AND OUTCOME

6.1 Once you have raised a concern, we will carry out an initial assessment to determine the scope of any investigation. We will inform you of the outcome of our assessment. You may be required to attend additional meetings in order to provide further information.

6.2 In some cases we may appoint an investigator or team of investigators including staff with relevant experience of investigations or specialist knowledge of the subject matter. The investigator(s) may make recommendations for change to enable us to minimise the risk of future wrongdoing.

6.3 We will aim to keep you informed of the progress of the investigation and its likely timescale. Sometimes the need for confidentiality may prevent us however, giving you specific details of the investigation or any disciplinary action taken as a result. You should treat any information about the investigation as confidential.

6.4 If we conclude that a whistleblower has made false allegations maliciously, in bad faith or with a view to personal gain, the whistleblower will be subject to disciplinary action.

7. IF YOU ARE NOT SATISFIED

7.1 While we cannot always guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way. By using this policy you can help us to achieve this.

7.2 If you are not happy with the way in which your concern has been handled, you can raise this with the Legal Director.

8. PROTECTION AND SUPPORT FOR WHISTLEBLOWERS

8.1 It is understandable that whistleblowers are sometimes worried about possible repercussions. We aim to encourage openness and will support any employee who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

8.2 Staff must not suffer any detrimental treatment as a result of raising a concern in good faith. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Legal Director immediately. If the matter is not remedied you should raise it formally using our Grievance Procedure.

8.3 Staff must not threaten or retaliate against whistleblowers in any way. Anyone involved in such conduct will be subject to disciplinary action.

9. WHO IS RESPONSIBLE FOR THE POLICY?

9.1 The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations.

9.2 The Legal Department has primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness and dealing with any queries on its interpretation. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy.