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Whistleblowing Policy

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What is Whistleblowing?

Whistleblowing occurs when an employee or worker provides information to their employer or a regulator which has come to their attention in the workplace. They are making a disclosure in the public interest and this would occur when a worker raises a concern about danger or illegality that affects others.

This policy is designed to provide clear guidance and a procedure for Parity employees to raise issues of concern and/or disclose information within Parity or to the relevant authorities which they believe relate to illegal or improper conduct or practise.

This document outlines the Whistleblowing Policy to be used by employees and workers across Parity Group. In addition temporary workers and contractors who perform functions in relation to the Company are encouraged to use it.

It is designed to enable employees of the Company to raise concerns internally and at a high level and to disclose information which the individual believes shows malpractice or impropriety. The policy is intended to cover concerns which are in the public interest which could include:

  • Financial malpractice or impropriety or fraud
  • Failure to comply with a legal obligation
  • Dangers to Health & Safety or the environment
  • Criminal activity
  • Miscarriages of justice
  • Improper conduct or unethical behaviour
  • Attempts to conceal any of these

Certain aspects of the Whistleblowing Policy are determined by current legislation.  Should any changes in the relevant legislation result in the Whistleblowing Policy not meeting these legal requirements, then that aspect of the Whistleblowing Policy will automatically be superseded by the new statutory requirement.

If you have a complaint relating to your personal circumstances in the workplace including matters in relation to your Employment Contract, then you should use the Company’s Grievance Policy.

Principles

Parity encourages a culture of openness and transparency and believes that employees should be comfortable in bringing concerns forward in the knowledge that they will be taken seriously and that there will be no adverse repercussions where they have acted in the public interest.

Whilst Employment Contracts at Parity require employees not to disclose confidential information about the employer’s affairs, where an individual discovers information they believe show serious malpractice or wrongdoing within the organisation then this this information should be disclosed internally in accordance with this policy, and externally if necessary, without fear of reprisal.

Parity would therefore encourage all employees to raise any concerns they may have about the conduct of others in the business or the way in which the business is run under the procedure outlined in this Policy in the first instance. The aim of this Policy is to provide an internal mechanism for reporting, investigating and remedying any workplace wrongdoing. It is therefore the aim that employees will not find it necessary to alert external organisations.

Qualifying Disclosures

The Public Interest Disclosure Act 1998 protects Whistleblowers from suffering detriment in employment. A ‘qualifying disclosure’ under the Act is one that is made in the public interest by an employee who has a reasonable belief that:

  1. A criminal offence has been committed, is being committed, or is likely to be committed. This would include types of financial malpractice such as fraud.
  2. A person has failed, is failing, or is likely to fail to comply with a legal obligation.
  3. A miscarriage of justice has occurred, is occurring, or is likely to occur.
  4. The health and safety of any individual has been, is being or is likely to be endangered.
  5. The environment has been, is being or is likely to be damaged
  6. Information tending to show any matter falling within any one of the above categories has been, is being, or is likely to be deliberately concealed

It is not necessary for an employee to have proof that such an act is being, has been or is likely to be committed – a reasonable belief is sufficient, even if that belief later turns out to be wrong. It is Parity’s responsibility, not the employee’s, to ensure an appropriate investigation takes place.

Protected Disclosures

This policy is designed to offer protection to those employees who disclose such concerns provided the disclosure is made:

  • In the public interest and in the reasonable belief of the individual making the disclosure that it tends to show malpractice or impropriety

  • In accordance with the procedure outlined in this policy.

The following points should be noted:

  • There is no protection for those who choose not to follow the procedure outlined in this Policy.

  • Any employee who mistreats, victimises or retaliates against those who have raised concerns under this Policy may be subject to disciplinary action.

  • If an individual makes a disclosure under this Policy, which is not confirmed by subsequent investigation, no action will be taken against that individual.

  • In making a disclosure the individual should take due care to ensure the accuracy of the information although they are not responsible for conducting an investigation.

Confidentiality

The Company will treat disclosures in a confidential and sensitive manner. However the investigation process may require the individual making the disclosure to provide a statement as part of the evidence required.

Procedures for Making a disclosure

In the event that you wish to report a disclosure under this Policy the procedure is as follows.

  • You should report the situation to your Managing Director or Function Head in the first instance.
  • If the disclosure in any way relates to your Managing Director or Function Head, you should report the situation to the Chief Executive.
  • You should provide any relevant information to support your disclosure where possible.
  • All disclosures will be treated seriously and promptly and fairly investigated. An indication of timing of the investigation will be provided from the outset.
  • Part of the investigation may result in disciplinary action being considered and therefore investigation meetings with individuals may be dealt with under the Company’s Disciplinary Policy
  • Once the investigation has been completed, you will be informed in writing of the outcome together with conclusions and decisions in a timely manner. The need for confidentiality may prevent you receiving full details of the investigation or actions taken.
  • Once conclusions are reached, any necessary further action will be taken.
  • If, upon conclusion of the investigation, you reasonably believe that appropriate action has still not been taken, you may then report the matter to the relevant authority.

Queries

If you have any queries about the Whistleblowing Policy, please contact Sarah Cooke, Head of Human Resources s.cooke@parity.net.