Introduction

‍Whistleblowing is the term used when you report something you see or have found out about that you consider to be wrong. In most cases this can be reported to your line manager. If you cannot or do not wish to do this for any reason, then you should follow the procedure set out below.

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Policy Statement

CES Medical Ltd is committed to ensuring an open culture with the highest standards of honesty and accountability. This policy is designed to allow staff to disclose information that they believe constitutes a wrongdoing without being penalised in any way in doing so.

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Scope

‍This policy and the procedures applies to all directors, managers, staff members, apprentices, workers and anyone else who has a contract to carry out work for us personally. It does not apply to genuinely self-employed contractors who run a profession or business on their own account.

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Procedures

‍CES Medical Ltd recognises that raising concerns about wrongdoings can be one of the most difficult and challenging things to do in a work environment. Under this policy you may come forward with legitimate concerns without fear of being blamed or of any reprisal. You will not be disadvantaged for raising what you consider to be a legitimate concern.

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What wrongdoings should be raised?

‍If you genuinely believe that we, or any of our staff have taken, are intending to take or have failed to take action that you reasonably believe could lead or amount to:
• A failure to comply with any legal obligations
• A criminal offence that has been, is being, or is likely to be committed
• Unauthorised or inappropriate disclosure, misuse or loss of confidential, personal and/or sensitive information
• A miscarriage of justice• Bribery or financial fraud
• Risk or damage to the environment
• A danger to the health and safety of employees or others
• Attempts to supress or hide information or evidence relating to a wrongdoing in any of the areas above

The Public Interest Disclosure Act 1998 provides protection for workers who reasonably believe that they are acting in the public interest, where the concern (disclosure) is covered under one of the areas above.

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The concern can be about an incident that happened in the recent past, is happening now, or that you believe is likely to happen in the near future.

Concerns over personal issues such as a complaint against another staff member should be raised using the appropriate company procedure, likely to be either the grievance policy, bullying and harassment policy or the code of business conduct, as such complaints are not in the public interest.

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Can I raise a concern anonymously?

‍Anonymous reporting is discouraged as it may prevent us obtaining further information in relation to the concern raised and prevent a full investigation from taking place. You can make a protected disclosure where we will assure you of confidentiality unless we are required to disclose your identity by law.

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How do I raise a concern?

‍If possible, you should raise your concern internally. This can be reported verbally or in writing to any manager senior manager or director within the Company if you feel unable to discuss with your line manager. You should provide as much detail as possible including anything you have witnessed, any evidence you have obtained and dates and times of incidents occurring as appropriate. If you attend a meeting you can bring a companion with you if you wish for moral support.

If you really feel you are unable to raise your concern internally you may make a disclosure to a relevant regulatory authority. This information will be advised publicly on all Company noticeboards and the intranet.

The matter will be fully investigated with you and with other people that you believe are involved with or connected to the suspected wrongdoing by an appointed independent investigating officer who may be internal or external to the Company.

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What will happen next?
The person you have raised the concern with will listen to you and consider the concern(s) you have raised and decide what, or if, further action is needed. You will be informed who else may need to be spoken to. The Director will need to be informed and they will consider any actions to be taken.

Where possible you will be kept informed about the actions which are proposed or are being taken. This may not always be possible where we are under a duty to protect the confidentiality of other people that are involved.

If you do not feel your concern has been dealt with appropriately you may address the concerns you have about the way the matter has been dealt with or, if you disagree with the outcome, with the Director.

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Giving you support

‍It is understandable that staff may feel that they will be ‘singled out’ for making a disclosure which they believe to be in the public interest. We will take every step to ensure that if you raise a legitimate concern you will be protected and supported.

We may take appropriate action against any person found to be:

• victimising another person for using this procedure (please tell a member of the management team if you think you have been victimised, or raise it formally under the grievance procedure if the matter is not remedied); or

• deterring any person from reporting genuine concerns under this procedure. If you think you have been deterred, you can raise the matter formally under the grievance procedure (if the matter is not remedied).

If we find that people have done either of the above we may take disciplinary action against them, which may result in their dismissal.

If we find that you have raised a concern in a frivolous or vexatious manner then our investigation may potentially result in us taking disciplinary action against you, which may lead to your dismissal.