Whistle Blowing Policy
Policy for reporting of malpractices, fraud or corruption

Introduction

  • All of us at one time or another has concerns about what is happening at work. Usually these concerns are easily resolved. However, when they are about unlawful conduct, financial malpractice, fraud, corruption or serious failures of standards at work that put people or property at risk (this is not intended to be an exhaustive list), it can be difficult to know what to do.

You may be worried about raising such issues or may want to keep the concerns to yourself, perhaps feeling it’s none of your business or that it’s only a suspicion.You may feel that raising the matter would be disloyal to colleagues, managers or to the organization. You may even feel that your job will be at risk if you do raise a concern. You may decide to say something but find that you have spoken to the wrong person or raised the issue in the wrong way and are not sure what to do next.

  • This policy is introduced to enable you to raise your concerns about such malpractice at an early stage and in the right way. We would rather that you raised the matter when you have a genuine concern rather than wait for the proof. The Company would welcome the opportunity to inquire into your concerns first.
  • This policy is primarily for concerns where the interests of others or of the organization itself are at risk. It does not absolve employees from their duty of confidentiality and care in the course of their work nor is it a route for taking up a grievance about a personal situation.
  • This policy is for people employed by the Company. For the purposes of this policy,this is someone who is:
  • Employed on a substantive contract:
  • On secondment
  • On a temporary contract or employed through an agency to work for the Company
  • As an independent consultant:
  • Contractors and suppliers of services to the Company

The Company’s assurances to you:

  • The Company is committed to ensuring that its culture will continue to be one of honesty and opposition to fraud, theft and corruption. Employees are encouraged to raise concerns about fraud, theft and corruption with their managers. The whistle blowing policy provides re-assurance to the whistle-blowers that they will not be victimized if they act in good faith. As such, the Company will not extend this assurance to someone who maliciously raises a matter they know is untrue.
  •  The Company will not tolerate the harassment or victimization of anyone raising a genuine concern. However, the Company recognizes that you may nonetheless want to raise a concern in confidence under this policy. If you ask us to protect your identity, your details will not be disclosed without your consent. If the situation arises where the matter cannot be resolved without revealing your identity (for instance because your evidence is needed in court), the person investigating the matter will discuss with you how to proceed.
  • The Company will consider, as far as it’s reasonably practicable, concerns raised anonymously. If you do not reveal who you are, the person investigating the matter will be unable to respond to you. It will also make the task of investigating the allegation more difficult. Because of this, this policy is not appropriate for concerns raised anonymously.

What the Company will do if you raise a concern

  • Allegations and suspicious of fraud, theft and corruption will be investigated by the Internal Audit Manager or such other person as the Company CEO may appoint. The Investigating Officer will:
  • Conduct an internal inquiry or a more formal investigation
  • Record all evidence received
  • Ensure that evidence is sound and adequately supported as far as possible
  • Ensure security of all evidence collected
  • Contact and liaise with other agencies where appropriate
  • Notify the Company’s insurers where appropriate
  • In the case of internal matters, liaise with the Personnel Manager
  • Notify the Chairman and Vice-Chairman of the Audit Committee
  •     In the interim, the issue you raise will be acknowledged within 5 working days you will be told:
  • Who is handling the matter
  • How you can contact him/her
  • Whether your further assistance may be needed
  • When you raise your concerns, you may be asked how you think the matter might best be resolved. If you do have any personal interest in the matter, please say so at the outset.
  • The person handling the matter will then write to you within 10 working days summarizing your concerns and setting out what is likely to happen next. Once the investigation is completed, you will be advised of the outcome in writing. Please note that it may not be possible to tell you the precise action taken where this would infringe a duty of confidence owed to someone else.
  • The Company can be expected to deal swiftly and thoroughly with any employee guilty of fraud, theft or corruption and to report appropriate cases to the police.

How to raise your concerns:

  • If you have a concern about malpractice, please raise it with your supervising manager first. This may be orally or in writing
  • If for whatever reason, you feel unable to raise the matter with your supervising manager, please raise your concerns in writing with the CEO and/or the Internal Audit Manager.