Whistle Blowing Policy
All staff of companies in the Phoenix Group are encouraged to raise genuine concerns at the earliest opportunity and in an appropriate way about possible improprieties in the conduct of our business, whether in matters of financial reporting or other malpractices.
This policy is designed to:
- Support our values
- Ensure staff can raise concerns without fear of retribution
- Ensure staff can raise concerns anonymously if they wish
- Provide a transparent and confidential process for dealing with concerns
This policy not only covers possible improprieties in matters of financial reporting, but also other suspected malpractices which may be illegal and / or damage the reputation of the Group, including:
- Corruption, bribery, blackmail
- Other criminal offences
- Failure to comply with legal or regulatory obligations
- Miscarriages of justice
- Endangering the health and safety of an individual
- Concealment of any of the above
- All concerns raised will be treated fairly and properly.
- We will not tolerate the harassment or victimisation of anyone raising a concern.
- Any individual making a disclosure will retain their anonymity unless they agree otherwise.
- Unless the concern has been raised anonymously, we will ensure that any individual raising any issue is aware of who is handling the matter.
- We will ensure no one will be at risk of suffering any 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 to be untrue.
If any member of staff reasonably believes in good faith that a malpractice exists in the workplace, then they should report this immediately to their own line manager if it is appropriate in the circumstances to do so. If for any reason they feel it is not appropriate to report the matter to their own line manager, then they can report their concerns to either:
- The Group Company Secretary, or
- The HR manager of their business area
If these channels have been followed and employees still have concerns, or if any member of staff feels that the matter should be brought to the attention of the Non-Executive Directors (who are independent of the day to day running of the Group), they should contact any of the Non-Executive Directors. They can be contacted either by email, or by letter as follows:
- Senior Non Executive Director - Brian Sellwood email@example.com
- Senior Independent Director - David Garman firstname.lastname@example.org
- Non-Executive Director - David Warnock email@example.com
Alternatively members of staff can write to any of the above:
C/O The Group Company Secretary
Hunsbury Hill Avenue
Correspondence marked 'Personal - Addressee Only' will be passed unopened to the relevant person.
Members of staff who have raised concerns and who have chosen not to remain anonymous will be informed of who is handling the matter, how they can make contact with that person and if there is any further assistance required. We will give as much feedback as we can without any infringement of any duty of confidentiality owed by us to someone else. The identity of any member of staff raising a concern under this policy will not be disclosed without their prior consent. Where concerns cannot be resolved without revealing the identity of the person raising the concern (for example if evidence is required in a court), we will enter into a dialogue with the member of staff concerned as to whether and how we can proceed.
Public Interests Disclosure Act
All UK members of staff are protected under the Public Interest Disclosure Act 1998, where they make a protected disclosure. These are disclosures of information, which in the reasonable belief of the person making the disclosure, involve one or more of the following:
- a criminal offence has been, is being, or is likely to be, committed;
- a person has failed, is failing, or is likely to have failed to comply with any legal obligation to which they are subject;
- a miscarriage of justice has occurred, is occurring, or is likely to occur;
- health and safety of an individual has been, is being, or is likely to be endangered;
- the environment has been, is being, or is likely to be damaged;
- information relating to any of the above is being deliberately concealed.
- Members of staff in other territories outside the UK will be treated by the Company as if such legislation applied to them.