Whistleblowing Policy

HAE Group is committed to conduct our business with honesty and integrity, and we expect all staff to maintain high standards.

A supportive, open and honest culture is essential in order to prevent the risk of wrongdoing, illegal or unethical conduct, which may damage the company’s reputation and/or performance, and could even save people from harm. Employees should feel comfortable to make a disclosure and the following policy sets out the process for making a disclosure.

This policy covers all HAE Group companies, employees, officers, consultants, contractors, casual workers and agency workers.

Clarification of Terms

Whistleblowing or Disclosure is the term used when an employee passes on information concerning wrongdoing.

Whistleblower

A whistleblower is an employee who reports a genuine concern relating to certain types of wrongdoing.

A prescribed person

Is an individual or organization that usually has an authoritative relationship over organizations, industries, or individual workers.
Can include regulators, professional bodies, commissioners, auditors, and government authorities.

Disclosure or grievance?

This policy should not be used for complaints relating to personal circumstances, such as the way you have been treated at work. In those cases, you should use the Grievance Procedure outlined in our Employee Handbook and our Human Rights Policy.

If you are uncertain whether something is within the scope of this policy you should seek advice from your line manager, or if not appropriate, the CEO or a member of the Board, and they will assist you in raising your concern in line with the relevant policy.

A concern can be raised at any time about an incident or wrongdoing that happened in the past, is happening now, or it is believed it will happen in the near future and falls into one or more of the following categories:

Criminal offences (this may include, for example, types of financial impropriety such as fraud)
Failure to comply with an obligation set out in law;
Miscarriages of justice;
Damage to the environment;
Endangering of someone’s health and safety;
Bribery under our Anti-corruption and Bribery policy;
Breach of our internal policies and procedures;
Conduct likely to damage our reputation or financial wellbeing;
Negligence; or
Covering up wrongdoing in the above categories.

Policy Aims

To encourage our employees to report wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be protected.
To provide our employees with guidance on how to raise their concerns.
To assure our employees that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.

Personnel Responsible for the Policy

The Board of Directors has overall responsibility for this policy, and for reviewing the effectiveness of actions taken in response to concerns raised under this policy. The Board must ensure that Senior Management Team, managers and other staff who may deal with concerns or investigations under this policy receive regular and appropriate training.

All staff are responsible for the success of this policy and should ensure that they use it to disclose any suspected danger or wrongdoing. Staff are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Board of Directors.

Raising a Whistleblowing Concern

It is anticipated that in many cases you will be able to raise any concerns with your line 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.

However, where the matter is more serious, or you feel that your line manager has not addressed your concern, or you prefer not to raise it with them for any reason, you should contact the CEO or any other member of the Board.

The CEO or any other member of the Board will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague or union representative to any meeting under this policy. Your companion must respect confidentiality of your disclosure and any subsequent investigation.

Your concern will be documented in writing and you will receive a copy after the meeting. We will also aim to give you an indication of how we propose to deal with the matter.

Whistleblowers can make disclosures to prescribed persons if they feel unable to raise concerns within their own organization.

Confidentiality

It is our intention that our employees will feel confident and protected to voice whistleblowing concerns openly under this policy. However, if you want to raise your concern confidentially, we will make every effort to keep your identity secret. You will be advised if it is necessary for anyone investigating your concern to know your identity.

However, we do not encourage our employees 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 allegations are credible.

Whistleblowers, who are concerned about possible reprisals if their identity is revealed should come forward to the CEO or the prescribed person. You can request confidentiality and appropriate measures will be taken. If you are in any doubt you can seek advice from the independent whistleblowing charity, who offer a confidential helpline. The contact details are at the end of this policy.

Note: It will rarely ever be appropriate for you to report your concern to the media, and this can impact the protection available to you. We strongly encourage you to seek advice and report your concern internally before reporting a concern to anyone external.

Investigation and Outcome

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 information.

In some cases, we may appoint an investigator or team of investigators including staff with relevant experience and specialist knowledge of the subject matter. The team can then make recommendations for change to enable us to minimise the risks of future wrongdoing.

We will aim to keep you informed of the progress and its likely timeline. However, sometimes the need for confidentiality may prevent us 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.

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

If You Are Not Satisfied

While we cannot always guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way.

If you are not happy with the way in which your concern has been handled, you can raise it directly with the CEO or any member of the Board. If you still remain unsatisfied, you may seek advice and guidance from the whistleblowing charity or trade union in your country. Contact details of both the members of the Board and charities are included at the end of this policy.

External Disclosures

The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator or the prescribed person. It will very rarely, if ever, be appropriate to alert the media. We strongly encourage our employees to seek advice before reporting a concern to anyone external.

The independent whistleblowing charities operate in most of the countries of our operations. Contact details are at the end of this policy.

Whistleblowing concerns usually relate to the conduct of our staff, but they may sometimes relate to the actions of a third party, such as a customer, supplier or service provider. In some circumstances the law is protective if you raise the matter with the third party directly. However, we encourage you to report such concerns internally first, to your line manager, the CEO or a member of the Board.

Protection and Support for Whistleblowers

It is understandable that whistleblowers are sometimes worried about possible repercussions. We aim to encourage openness and will support our employees who raise genuine concerns under this policy, even if they turn out to be mistaken.

Whistleblowers must not suffer any detrimental treatment as a result of raising a concern. 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 CEO immediately or raise it formally using our Grievance Procedure.

Employees who threaten or retaliate against whistleblowers in any way will face disciplinary action. In some cases, the whistleblower is entitled to sue such employees personally for compensation in an employment tribunal.

Our company will provide confidential support and counselling to whistleblowers who raise concerns under this policy.

Contacts

Contact the members of the Board to raise any concerns

Neville Karai, CEO
Ian Hutchinson, CCO
Richard Thackeray, COO

List of prescribed people and bodies you can report malpractice to, other than your employer

Protect, UK's leading whistleblowing charity: Protect - Speak up stop harm - Whistleblowing Homepage
Call: 020 3117 2520

Whistleblowers Ireland
Contact Whistleblowers Ireland in the strictest confidence
Tel: 087 919 9113 (7am-11pm)
Email: contact@whistleblowersireland.com

Whistleblower Aid (USA)
About Us - Whistleblower Aid
PO Box 33562, Washington, D.C. 20033