Stokers A5 Handbook Policies APR24 with links

WHISTLEBLOWING POLICY & PROCEDURE

INTRODUCTION Stokers is committed to conducting its business with honesty and integrity, and expects all employees to maintain the highest possible standards at work. However, all organisations face the risk of things going wrong from time to time. A culture of openness and accountability is therefore essential in order to prevent such situations from arising and to address them when they do happen. Any suspected workplace wrongdoing should be reported as soon as possible in accordance with this policy. POLICY This policy covers all employees, officers, consultants, contractors, volunteers, interns, casual workers and agency workers. This is a policy document and therefore does not form part of any employee’s contract of employment. Stokers may amend this policy at any time. GENERAL PRINCIPLES Whistleblowing is the reporting of suspected wrongdoing in relation to workplace activities. This includes bribery, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment and any breach of legal or professional obligations. Specific examples of issues covered by this policy include, but are not limited to: • Any unlawful act; • An act creating a risk to health and safety; • Improper conduct or unethical behaviour (including bribery and corruption); • Breach of any of STOKERS’ policies; • Discrimination of any kind; • Recognition of signs of modern slavery activity; • Financial malpractice, impropriety or fraud; • Failure to comply with a legal obligation or statute; • A breach of the FCA rules or any other relevant legislation; and • Attempts to conceal any of the aforementioned. The business hopes that employees will feel able to voice whistleblowing concerns openly under this policy as completely anonymous disclosures are difficult to investigate. If an employee wants to raise their concern confidentially, Stokers will make every effort to keep the whistleblower’s identity secret and only reveal it where necessary to those involved in investigating their concern.

PROCEDURE Whistleblowers should normally raise any concerns about suspected wrongdoing with their manager in the first instance or the HR department if concerns are regarding their manager. Stokers’ response to any whistleblow will depend on the nature of the concern that has been reported. In all instances, Stokers will record the issue raised and consider the appropriate course of action to take (for example, investigating the issue internally or referring the matter to the police or other external body, etc.). Stokers will normally arrange a meeting with a whistleblower as soon as possible to discuss their concerns. The whistleblower may bring a work colleague or trade union representative to any such meeting. Any companion must respect the confidentiality of the investigation. It may be necessary for Stokers to obtain a whistleblower’s consent to other employees being informed of the concerns reported in order that they can be properly investigated. Whistleblowers will be advised of the outcome of any investigation into their concerns in writing. The outcome of any investigation, any report prepared as a result of the investigation, and any disciplinary or other action arising out of the investigation, must be kept confidential. Any failure to do so may lead to disciplinary action being taken against the whistleblower. If a whistleblower is dissatisfied with the outcome of any investigation, they should contact the HR department who will consider whether further action is necessary. Whistleblowers must not suffer any detrimental treatment as a result of raising a genuine concern under this policy. If a whistleblower believes that they have suffered any such treatment, they should inform their manager or the HR department immediately. If the matter is not remedied, the whistleblower should raise it formally using the Grievance Procedure. Employees must not threaten, or retaliate against, whistleblowers in any way. Such conduct will be treated as a misconduct issue and, in the case of employees, may result in disciplinary action under the Disciplinary Policy. If Stokers concludes that a whistleblower has made false allegations maliciously or with a view to personal gain, this will be treated as a misconduct issue. In the case of employees, this may result in disciplinary action being taken under the Disciplinary Policy.

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