Definition
We encourage workers to raise genuine concerns about malpractice at the earliest possible stage in the right way.
Scope
All Carillion employees, consultants, temporary and agency workers, and anyone on a contract for services.
Objectives
- To support the current legal requirements of the Public Interest Disclosure Act 1998.
- To support the Carillion values.
- To ensure employees can raise concerns without fear of suffering retribution.
- To provide a clear and confidential procedure.
Principles
- Any concerns raised will be treated fairly and properly.
- We will not tolerate the harassment or victimisation of anyone raising a genuine concern.
- Any individual making a disclosure will retain their anonymity unless they agree otherwise.
- We will ensure that the individual raising the concern is aware of who is handling the matter.
- We will ensure no one will be at risk of suffering some form of retribution as a result of raising a concern even if they are mistaken. We do not however extend this assurance to someone who maliciously raises a matter they know is untrue.
The types of matters regarded as malpractice for the purposes of this policy are:
- Fraud or financial malpractice
- Corruption, bribery or blackmail
- Criminal offences
- Failure to comply with a legal or regulatory obligation
- Miscarriage of justice
- Endangering the health and safety of an individual
- Endangering the environment
- Concealment of any of the above.
For personal grievances please use the Grievance Procedure.
- If you have a concern about malpractice the issue should first be raised with your line manager either orally or in writing.
- If you feel unable to raise the matter with your manager, for whatever reason, please raise the matter with your Human Resources Director.
- If you would prefer to speak to an independent third party, in confidence, please raise the matter with:
Whistle Blowing Hotline 0800 716017 (Code 70812).
This is provided through the independent party First Assist who provide the Employee Care counselling and legal advice service. Your concerns will be reported to the Company without revealing your identity.
If these channels have been followed and you still have concerns, or if you feel the matter is so serious that you cannot discuss it with any of the above, please contact:
Non-Executive Director (plc) - Roger Dickens on 0121 503 8401
If you have raised your concern internally you will be informed on who is handling the matter, how you can make contact with them and if there is any further assistance required from you.
We will give as much feedback as we can without any infringement on a duty of confidence owed by us to someone else.
We will not disclose your identity without your consent. If the situation arises where we are not able to resolve the concern without revealing your identity (e.g. if your evidence is required in court), we will discuss with you whether and how we can proceed.
If you are unsure whether to use the procedure or you want independent advice at any stage, you may contact the independent charity Public Concern At Work on 0207 404 6609. Their lawyers can give you free confidential advice at any stage about how to raise a concern about serious malpractice at work. (http://www.pcaw.co.uk/).
There may be circumstances where you can report matters to outside bodies such as regulators or the police. Public Concern at Work will be able to advise you on such an option and in the circumstances in which it is appropriate for you to contact an outside body.
