Forest of Dean Pink Elephant Project C.I.C.

Whistleblowing Policy

Contents

  1. Purpose and scope
  2. Principles
  3. Procedure
  4. Safeguard for employees raising a qualifying disclosure
  5. Contacts

1 Purpose and scope

The Forest of Dean Pink Elephant Project C.I.C. (Fod-PEP) (the Company) is committed to conducting its business with honesty and integrity and expect all employees to maintain high standards in accordance with the Anti-Bribery and Corruption Policy. It is important to the business that any fraud, misconduct or wrongdoing is reported and dealt with promptly. A culture of openness and accountability is essential to prevent such situations occurring or to address them if they do occur.

This policy applies to all employees but can also be used by other associated person who perform duties or tasks in relation to, on behalf of, the Company, such as volunteers, consultants and contractors. The purpose of this policy is to provide guidance on how to report suspected wrongdoing, in the knowledge that the concern will be taken seriously and investigated as appropriate.

Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work, this is known as a qualifying disclosure. A qualifying disclosure is one that is made in the public’s interest and there is a reasonable belief that one of the following is being, has been, or is likely to be, committed. It is not necessary to have proof that such an act is being, has been, or is likely to be, committed.

  • A criminal offence.
  • A miscarriage of justice.
  • An act creating risk to health and safety.
  • An act causing damage to the environment.
  • A breach of any other legal obligation.
  • Concealment of any of the above.

This policy does not apply to personal grievance unless it is in the public’s interest. Personal grievances should be raised through the Grievance Procedure.

2 Principles

  • Everyone should be aware of the importance of preventing and eliminating wrongdoing at work. They are encouraged to raise genuine concerns of suspected wrongdoing or danger affecting any of the Company’s activities under this policy.
  • Concerns raised under this policy will be investigated thoroughly, promptly and confidentially and the outcome of the investigation will be reported back to the employee who raised the concern.
  • In making a qualifying disclosure, the employee has the right not to be dismissed, subject to any other determinant, or victimisation because they have made a disclosure, regardless of the outcome of any investigation.
  • Victimisation of an employee who has raised a concern is a disciplinary offence.
  • If misconduct is discovered as a result of any investigation under this policy, the Disciplinary Procedure will be used, in additional to any appropriate external measures.
  • Any concern made maliciously is a disciplinary offence.
  • An instruction to cover up any wrongdoing is a disciplinary offence.

3 Procedure

In the first instance, employees should raise any concerns with their line manager. If they cannot raise their concern with their line manager, they should raise it with the Whistleblowing Officer. Should a situation arise where the employee is unable to approach a manager within the Company, they can report their concern to the local police force, either online or by telephone.

The line manager (or the Whistleblowing Officer) will arrange for the concern to be investigated. They will investigate or request for a senior manager to conduct the investigation, depending on the nature of the concern. As part of the investigation, a meeting will be arranged with the employee to discuss the concern. The employee may be accompanied by a work colleague or a trade union representative to any formal meetings under this policy. The companion must respect the confidentiality of the disclosure and any subsequent investigation.

The investigator will report the concern, along with any actions or recommendations including reporting the concern to the relevant regulatory body (if required), to the General Management Board.

The employee will be kept informed of the investigation’s progress and on conclusion will be informed of the outcome. Specific details of the investigation or outcome may not be given to the employee if sensitive or confidential. Any information regarding the investigation and outcome which is given should be kept confidential.

If it is concluded that a malicious allegation has been made, the employee will be subject to disciplinary action.

If the employee is not happy with the way in which their concern was handled or the outcome of the investigation, they should raise this with HR.

4 Safeguard for employees raising a qualifying disclosure

Raising a concern can be difficult, especially if worried about possible repercussions. Openness is encouraged and support will be given to those who raise genuine concerns under this policy, even if they turn out to be mistaken.

Employees must not suffer any detrimental treatment because of raising a concern. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If an employee believes that they have suffered any such treatment, they should inform HR immediately.

Employees must not threaten or retaliate against those who have raised concerns. Anyone involved in such conduct will be subject to disciplinary action.

If an employee raises a concern which is not confirmed during the investigation, no action will be taken against them for raising the concern in the first place.

5 Contacts

Whistleblowing Officer: John Richards Tel. 07861 685080

Whistleblowing Policy v1.0 17/10/2024

Skip to content