This document is only applicable to employees of Blue Ring Digital Services Limited.
"Whistle-blowing Policy" refers to this Whistle-blowing Policy.
"You", "Your" refers to You the employee of Blue Ring Digital Services Limited.
"We", "Us", "Our", "Blue Ring Digital Services Limited" refers to Blue Ring Digital Services Limited.
We will try to keep everything in this document as straightforward as possible, but if there’s anything You don’t understand, please get in touch with Us.
The headings in this Whistle-blowing Policy are for convenience only and shall not affect their interpretation.
The masculine shall include the feminine and the neuter and the singular the plural and vice versa.
If any provision or part of any provision of this Whistle-blowing Policy is found by a court or other competent authority to be void or unenforceable, such provision or part of a provision shall be deleted from these Whistle-blowing Policy and the remaining provisions or parts of the provision shall continue to be in full force and effect.
We are committed to dealing with any concerns about the company openly, responsibly and confidentially. If You have any genuine concerns about something to do with the company – for example, You believe mismanagement or malpractice has occurred, or may occur in the future – We naturally want to know about this as soon as possible. This Whistle-blowing Policy sets out Our procedure for raising concerns about incidents of malpractice or mismanagement in the workplace, and how We will deal with those concerns. This could relate to any practice, procedure or policy carried out by any officer or employee of the company – for example, a breach of rules, irregularity, a danger to Our employees or Our customers, financial malpractice, breach of legal obligations, or something that may damage the environment.
The Public Interest Disclosures Act 1998 encourages staff to raise their concerns internally about wrong doing in the workplace. This includes concerns about:-
- someone having committed, or being likely to commit, a criminal offence;
- a failure to comply with any legal or regulatory obligation;
- a miscarriage of justice;
- something which endangers the health and safety of an individual;
- damage to the environment;
- fraud or financial irregularity;
- blackmail, corruption or bribery;
- deliberate concealment relating to any of the above.
Wrong doing is anything that it is illegal, improper or unethical, and may impact Our image and/ or profits.
Misconduct and malpractice can happen in any company and can go undetected and unpunished if those who know about it are afraid to speak out. You are therefore encouraged to come forward with any information if You feel it is appropriate to do so. Any disclosure made that is thought to be true, even if it turns out that You are mistaken, will be protected by this policy if You have a reasonable suspicion that malpractice has occurred, is occurring or is likely to occur. We do, however, ask that You do not carry out investigations of You own accord, as this could cause issues with any future investigation or alert individuals and result in the destruction of evidence.
How to report a concern
Our primary aim is to prevent workplace malpractice from occurring in the first place. If it happens, We want to prevent it from recurring. If appropriate, We will make every effort to resolve the situation promptly. If that isn’t possible, We will then take further action to investigate the matter fully, and take appropriate action.
If You have a concern about workplace malpractice, You should first discuss it with Your line manager. They will attempt to resolve the matter as promptly as possible. There may be circumstances where You feel unable to approach Your line manager. If so, You can raise Your concerns directly with the Senior Management Team.
How will We investigate?
We will carry out an internal investigation and, if necessary, will also call in external support or report the matter to the Police if required. However, any employee reporting a wrong doing can be assured that the We will deal with the matter sensitively and confidentiality will always remain a priority.
The investigation will be carried out as quickly as possible. It is not possible to lay down precise timescales for the investigation as this very much depends on the nature of the allegation, and We will wish to carry out suitable enquiries.
We will write to the individual who has notified Us of the alleged wrong doing, to acknowledge the complaint, and the employee will be kept informed on the progress of the investigation and, once concluded, the outcome.
Any individual alleged to have carried out wrong doing will be dealt with in accordance with Our Ethics and Code of Conduct Policy, the formal Disciplinary and Grievance Policy and if necessary, the law. They will be notified of the allegation made against them as soon as is practically possible.
So far as possible, We will not disclose Your identity, if known, at any time, unless it’s necessary to do so for the purposes of Our investigations, to obtain legal advice, or to comply with a legal or regulatory obligation. This applies provided you:-
- raise any genuine concerns and not out of malice;
- have reasonable grounds for believing Your concerns to be true;
- have complied in full with the spirit of the policy and the process set out above.
While We will take every effort to ensure Your confidentiality, if it becomes necessary to identify You for the reasons stated above, We will not do this without discussion with You.
We are committed to ensuring that You are not subjected to any harassment, victimisation or disciplinary action as a result of raising Your concerns. And, as far as possible, any supporting evidence relating to Your disclosure will be kept secure at all times.
If You make an allegation that is not confirmed by subsequent investigation, no action will be taken against You. However, malicious allegations may result in disciplinary action against You.
Changes to Whistle-blowing Policy
This Whistle-blowing Policy replaces all previous versions. We reserve the right to change the Whistle-blowing Policy at any time.