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Purpose

This document is designed to provide advice and guidance to employees and line managers on how to report legitimate concerns they may have about business practices and to disclose information which the individual believes shows malpractice or impropriety in a protected and effective way.

Scope

This policy applies to all staff employed by QAS Copak Limited.

Policy

All employees are encouraged to raise genuine concerns about possible impropriety in the conduct of our business at the earliest opportunity and in an appropriate way, whether in matters of: –

  • Financial Reporting
  • Fraud
  • Corruption, Bribery, or Blackmail
  • Failure to comply with legal or regulatory obligations
  • Miscarriage of Justice
  • Endangering health and safety of an individual
  • Endangering any element of the environment
  • Concealment of any of the above or other malpractices

 
This policy is designed to: –

  • Ensure employees can raise concerns without fear or suffering retribution.
  • Provide a transparent and confidential process for dealing with concerns.

 

Protection and Confidentiality
  • All 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 any individual raising a concern is aware of who is handling the matter.
  • We will ensure that no one will be at risk of suffering any form of retribution because of raising a concern, even if they are mistaken, we do not, however, extend this assurance to those that maliciously raise a matter that is known to be untrue.

 

Procedure

If any employee believes reasonably and in good faith that malpractice exists in the workplace, then the employee should report this immediately to their line manager. However, if for any reason they are reluctant to do so then they should report their concerns to either:

• Their managers manager

• The HR & HS Manager

If these channels have been followed and employees still have concerns, or if employees feel the matter is so serious that it cannot be discussed with any of the above, they should contact the Directors.

Employees who have raised concerns internally will be informed of who is handling the matter, how they can contact that person and if there is any further assistance required. We will give as much feedback as we can without any infringement of the duty of confidence owed by us to someone else. Employees’ identities will not be disclosed without prior consent. Where concerns cannot be resolved without revealing the identity of the employee raising the concern, we will enter into dialogue with the employee concerned as to whether and how we can proceed.

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. The investigating manager will ensure that investigations are undertaken as quickly as possible without affecting their quality and depth.

Appeals process

The decision of the Directors is final and there is no right of appeal.

If you have exhausted the internal process and are still not satisfied, we recognise fully your right to make disclosures to prescribed persons such as The Health and Safety Executive, HMRC and SEDEX. Before doing so you are urged to approach the independent charity Protect (Formally Public Concern at Work) on 020 3117 2520 (Option 1) where lawyers can give you free confidential advice about serious malpractice at work.