Whistleblowing Policy

1.0 Purpose

The purpose of this policy is to set out the guidelines when it comes to whistleblowing and the processes in place to ensure a fair and compliant outcome, as well as:

  • supporting our values;
  • ensuring employees can raise concerns without fear of suffering retribution; and
  • providing a transparent and confidential process for dealing with concerns

This policy covers all employees of the Danbro Group.

2.0 What is Whistleblowing

Whistleblowing is the disclosure of information in connection to the wrongful, unlawful or dishonest activities of your employer or work colleagues to your employer or a third party and which is in the public interest.

Under the Public Interest Disclosure Act 1998, you have a statutory right to disclose concerns relating to the Company without fear of victimisation or detriment. Workers are entitled not to suffer any detriment or be dismissed as a result of a protected disclosure.

3.0 Protected Disclosures

In order to qualify for statutory protection the disclosure must consist of information in relation to one or more of the following events that are within the public interest and must not be deemed to be mere allegations:

  • fraud;
  • corruption, bribery or blackmail;
  • criminal offences;
  • failure to comply with a legal or regulatory obligation;
  • miscarriage of justice;
  • endangering the health and safety of an individual; and

deliberate concealment of any of the above

In making a disclosure, you must reasonably believe the event has happened, is happening or is likely to happen in the near future. Whether or not your disclosure gains the protection of whistleblowing legislation depends on the specific circumstances and nature of the disclosure made. However, to ensure no employee is discouraged from raising genuine concerns we confirm that no employee will be subject to any detrimental treatment or dismissed because they have come to us to share their concerns, either under this policy or the Grievance Procedure.

Please note however that where your concern relates to an internal procedure or act which affects your employment only, rather than being of public interest, such concerns should be raised through the Company’s Grievance Procedure.

If you make a disclosure outside the scope of this policy (e.g. in bad faith) or in breach of this policy, you may not be protected and may be subject to disciplinary action under the Company’s disciplinary procedure (up to and including dismissal). In the event that you make a disclosure in bad faith but in the public interest you may still be protected under law from being subject to dismissal or any detriment but it may impact on any remedy you may seek through the courts.

4.0 How to make a disclosure

In order to assist the Company in investigating the issue, we recommend that all disclosures are made in writing and contain as much sufficient information and evidence as possible. The disclosure should be sent to whistleblowing@danbro.co.uk for consideration. This inbox will be monitored by the Head of Group Compliance and Information.

In the event that you have good reason to reasonably conclude that there is no one internally to whom you can make a disclosure to, you should consider whether it is appropriate to make a disclosure to any regulating or statutory body e.g. HSE or VOSA.

Save in exceptional circumstances, you should not disclose your concerns outside the Company unless you have first provided the Company with the opportunity to address the problem.

5.0 Investigating Disclosures

On receipt of a protected disclosure you may, depending on the circumstances, be invited to

attend an investigation meeting. You are entitled to be accompanied by a work colleague or trade union representative at any such investigatory meeting.

The Company will endeavour to maintain confidentiality where possible however this is not always possible. We would ask that you keep the details of your disclosures confidential and not disclose these to anyone outside of the Company until we have had an opportunity to first address the problem.

Whilst we encourage open disclosures, we appreciate that some employees may wish to raise concerns anonymously however where this occurs, it may be impossible for the Company to investigate or take further action.

6.0 Monitoring and Review

The Group Finance Director is responsible for this policy and all employees should be aware of it and adhere to it. Failure to comply with this policy or other related policies and procedures may result in disciplinary action.

This policy will be reviewed at least annually or with any significant change to process.

Last Updated: 14/01/22 Version 1