Whistleblower Policy

1.1 We are committed to conducting our business with honesty and integrity, and we expect  all staff to maintain high standards. However, all organisations face the risk of things going wrong from time to time. A culture of openness and accountability is essential in order to prevent wrongdoing occurring and to address it if it does occur.

1.2 The aims of this policy are: 

• 1.2.1 to encourage staff to report suspected 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 respected; 
• 1.2.2 to provide staff with guidance as to how to raise those concerns; 
• 1.2.3 to reassure staff that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.

1.3 This policy does not form part of any employee's contract of employment and it may be amended at any time.

This policy applies to all individuals working at all levels of the organisation, including senior managers, officers, directors, employees, freelancers, consultants, contractors, homeworkers, part-time and fixed-term workers, casual and agency staff (collectively referred to as staff in this policy).

3.1 Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include: criminal activity; miscarriages of justice; danger to health and safety; damage to the environment; failure to comply with any legal obligation; bribery; negligence; breach of our internal policies and procedures, for example any form of discrimination or bullying; or the deliberate concealment of any of these matters. 

3.2 A whistleblower is a person who raises a genuine concern relating to any of the above. If you have any genuine concerns related to suspected wrongdoing or negligence affecting any of our activities you should report it under this policy.

3.3 This policy should not be used for complaints relating to your personal circumstances, such as the way you have been treated at work. In those cases, please contact Human Resources. 

3.4 If you are uncertain whether something is within the scope of this policy you should seek advice from the Whistleblowing Officer, whose contact details are at the end of this policy.

4.1 We hope that in many cases you will be able to raise any concerns with your line manager or your Human Resources department. 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. In some cases they may refer the matter to the Whistleblowing Officer. 

4.2 However, where the matter is more serious, or you feel that your line manager or the Human Resources department has not addressed your concern, or you prefer not to raise it with them for any reason, you should contact Mary Basterfield (mary@S4Capital.com), Tel: +44 7714 986175 in the first instance, or, if you feel unable to contact Mary, Rupert Faure Walker, Senior Independent Director and Whistleblowing Officer (rupertfaurewalker@hotmail.com, Tel: +44 (0)7831 620163).

5.1 We hope that staff will feel able 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. If it is necessary for anyone investigating your concern to know your identity, we will discuss with you. 

5.2 We do not encourage staff to make disclosures anonymously. Proper investigation may be more difficult or impossible if we cannot obtain further information from you. Whistleblowers who are concerned about possible reprisals if their identity is revealed  should come forward to the Whistleblowing Officer or one of the other contact points  listed in paragraph 4 and appropriate measures can then be taken to preserve confidentiality. If you are in any doubt you can seek advice from Protect, the independent whistleblowing charity, who offer a confidential helpline.

6.1 The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally. 

6.2 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. It will very rarely if ever be appropriate to alert the media. We strongly encourage you to seek advice before reporting a concern to anyone external. The independent whistleblowing charity, protect, operates a confidential helpline. They also have a list of prescribed regulators for reporting certain types of concern. Their contact details are at the end of this policy. 

6.3 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 or supplier or service provider. The law allows you to raise a concern with a third party, where you reasonably believe it relates mainly to their actions or something that is legally their responsibility.  However, we encourage you to report such concerns internally first. You should contact your line manager or the Human Resources department or one of the other individuals set out in paragraph 4 for guidance.

7.1 We will arrange a meeting, whether in person or by video or audio conference (as appropriate in the context of the nature and significance of your concern) with you as soon as possible to discuss your concern. You may bring a colleague to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation. 

7.2 Following this meeting, 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 further information. 

7.3 In some cases we may appoint an investigator or team of investigators including staff with relevant experience of investigations or specialist knowledge of the subject matter.  The investigator(s) may make recommendations for change to enable us to minimise the risk of future wrongdoing. 

7.4 We will aim to keep you informed of the progress of the investigation and its likely timescale. 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. 

7.5 If we conclude that a whistleblower has deliberately made false allegations, the whistleblower will be subject to disciplinary action.

8.1 While we cannot always guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way. By using this policy you can help us to  achieve this. 

8.2 If you are not happy with the way in which your concern has been handled, you can raise it with one of the other key contacts in paragraph 4. Contact details are set out at the end of this policy.

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

9.2 Staff must not suffer any detrimental treatment as a result of raising 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 Whistleblowing Officer immediately.  If the matter is not remedied you should raise it formally using our Grievance Procedure. 

9.3 Staff must not threaten or retaliate against whistleblowers in any way. Anyone involved in such conduct will be subject to disciplinary action.

10.1 The Board has overall responsibility for this policy, and for reviewing the effectiveness of actions taken in response to concerns raised under this policy. 

10.2 Under the oversight of the Whistleblowing Officer, Mary Rademaker, the Group CFO, has day-to-day operational responsibility for this policy, and must ensure that all managers and other staff who may deal with concerns or investigations under this policy receive regular and appropriate training. 

10.3 The Whistleblowing Officer, in conjunction with the Board should review this policy from a legal and operational perspective at least once a year. 

10.4 All staff are responsible for the success of this policy and should ensure that they use it to disclose any suspected 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 Group CFO and/or the Whistleblowing Officer.