Whistleblowing Policy

Making a Disclosure in the Public Interest

Introduction

Seven Steps Support Limited is committed to the highest standards of openness, probity and accountability. This policy aims to enable staff and other members of the Company to voice concerns in a responsible and effective manner. If an individual discovers information that shows serious malpractice or wrongdoing within the organization, this information should be disclosed internally without fear of reprisal. The policy is designed to cover concerns which are in the public interest and may at least initially be investigated separately but might then lead to the invocation of other procedures (e.g., disciplinary).

Scope of Policy

This policy covers concerns such as financial malpractice or impropriety, failure to comply with legal obligation or Statutes, dangers to Health & Safety or the environment, criminal activity, improper conduct, or unethical behavior. It is not designed to question financial or business decisions taken by the Company nor should it be used to reconsider any matters that have already been addressed under harassment, complaint, disciplinary or other procedures.

Safeguards

Protection

This policy offers protection to employees who disclose concerns provided the disclosure is made in good faith, in the reasonable belief of the individual making the disclosure that it tends to show malpractice or impropriety, and if they make the disclosure to an appropriate person.

Confidentiality

The Company will treat all such disclosures in a confidential and sensitive manner. The identity of the individual making the allegation may be kept confidential so long as it does not hinder or frustrate any investigation.

Anonymous Allegations

This policy encourages individuals to put their name to any disclosures they make. Concerns expressed anonymously are much less credible, but they may be considered at the discretion of the Company.

Untrue Allegations

If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. If, however, an individual makes malicious or vexatious allegations, and particularly if he or she persists with making them, disciplinary action may be taken against that individual.

Procedures for Making a Disclosure

On receipt of a complaint of malpractice, the member of staff who receives and takes note of the complaint must pass this information as soon as is reasonably possible to the appropriate designated investigating officer. If there is evidence of criminal activity, then the investigating officer should inform the police.

Timescales

Due to the varied nature of these sorts of complaints, which may involve internal investigators and/or the police, it is not possible to lay down precise timescales for such investigations.

Investigating Procedure

The investigating officer should follow these steps:

1. Obtain full details and clarifications of the complaint.
2. Inform the member of staff against whom the complaint is made as soon as is practically possible.
3. Consider the involvement of the Company auditors and the Police at this stage and should consult with the Manager.
4. Fully investigate the allegations with the assistance where appropriate, of other individuals/bodies.
5. Make a judgement concerning the complaint and validity of the complaint in a written report containing the findings of the investigations and reasons for the judgement.
6. The Manager will decide what action to take. If the complaint is shown to be justified, then they will invoke the disciplinary or other appropriate Company procedures.
7. Keep the complainant informed of the progress of the investigations and, if appropriate, of the final outcome.

If the complainant is not satisfied that their concern is being properly dealt with by the investigating officer, they have the right to raise it in confidence with the Manager or one of the designated persons described above.

Responsibilities

All employees have a responsibility to voice concerns about malpractice or impropriety within the Company. However, those individuals in management positions have an additional responsibility to ensure that such concerns are investigated properly and as quickly as possible.

Training and Awareness

This policy will be brought to the attention of all new employees and made available to all existing employees via the Company Intranet. Training will be provided to ensure that those who are involved in the operation of this policy understand the importance of their role and the procedures to be followed.

Monitoring

The Company will monitor the effectiveness of this policy and will amend it as necessary to reflect changing circumstances. An annual report will be made to the Board of Directors in respect of the number and nature of concerns raised under this policy.

Conclusion

This policy is intended to encourage and enable employees to raise serious concerns within the Company rather than overlooking a problem or raising them outside. Employees can do so in the knowledge that they will be protected from victimisation or reprisal, provided they are raising genuine concerns.