Whistleblowing is the disclosure of information that you reasonably believe is in the public interest and shows suspected or anticipated wrongdoing or dangers relating to our activities.
This can include issues such as fraud, bribery, health and safety risks, environmental damage, breaches of legal or professional obligations, or attempts to deliberately conceal wrongdoing.
Our policy
We are committed to high standards of openness, integrity and accountability, and we encourage all colleagues to raise concerns without fear of reprisal.
Our whistleblowing policy ensures that you:
- Feel confident raising genuine concerns about suspected or anticipated wrongdoing
- Know the appropriate routes for raising concerns and receiving feedback
- Receive a response and understand how to escalate your concern if you are not satisfied with the outcome
- Are protected from detrimental treatment if you raise a genuine concern in the public interest
This policy applies to all colleagues—including employees, contractors, consultants, agency workers, interns, secondees—as well as suppliers and members of the public.
Our principles
- You don’t need proof. If you genuinely and reasonably believe information shows wrongdoing or risk, you can raise it.
- You don’t have to investigate. It is our responsibility to investigate.
- Concerns may relate to something that has already happened, is happening now, or is likely to happen in the future.
- Concerns can relate to matters inside or outside the UK.
- False or malicious allegations are a serious matter and may lead to disciplinary action.
The reporting process
- As a first step, you can raise the issue with the Director of Compliance
- If you're unhappy with the outcome, or don't want to raise it with either the Director of Compliance you can go to the Chief People Officer, Chief Governance Risk and Legal Officer, Chair of Risk and Audit Committee or the Senior Independent Non-Executive Director.
- If you still aren't happy, you can raise the issue with the National Audit Office.
- In exceptional circumstances, where the issue is very serious, you can raise it outside the organisation to another body.
- Outside bodies include the Financial Conduct Authority, the Pensions Regulator, H&S Executive and the Serious Fraud Office.
Investigation
An appropriate investigator—usually supported by the Compliance team—will carry out a thorough and confidential investigation. You may be invited to a meeting to discuss your concern and can bring a colleague or union representative.
You’ll be kept informed of progress and given feedback on the outcome. Some details may need to remain confidential.
If misconduct is identified, disciplinary or external actions may be taken. If you are dissatisfied with the outcome, you may escalate your concern internally as set out in the policy.
Monitoring
The Chief People Officer will provide high level stats to the Risk and Audit Committee detailing the numbers of concerns raised under the Whistleblowing Policy. No other information will be shared.