Hostlink UK

HostlinkUK Whistle Blowing Policy

Introduction
1. Hostlink UK is committed to the highest standards of openness, probity and accountability. An important aspect of accountability and transparency is a mechanism to enable staff and other members of the Company to voice concerns in a responsible and effective manner. Where an individual discovers information which they believe shows serious malpractice or wrongdoing within the organisation then this information should be disclosed internally without fear of reprisal, and there should be arrangements to enable this to be done independently of line management (although in relatively minor instances the line manager would be the appropriate person to be told).

2. The Public Interest Disclosure Act, gives legal protection to employees against being dismissed or penalised by their employers as a result of publicly disclosing certain serious concerns. The Company has endorsed the provisions set out below to ensure that no members of staff should feel at a disadvantage in raising legitimate concerns. This policy is intended to cover concerns which are in the public interest and may at least initially be investigated separately but might then lead to the invocation of other procedures e.g. disciplinary. These concerns could include: Dangers to Health & Safety or the environment. Criminal activity. Improper conduct or unethical behaviour

Safeguards
3. Protection - this policy is designed to offer protection to those employees of Hostlink UK who disclose such concerns provided the disclosure is made:
In good faith.
In the reasonable belief of the individual making the disclosure that it tends to show malpractice or impropriety and if they make the disclosure to an appropriate person (see below). It is important to note that no protection from internal disciplinary procedures is offered to those who choose not to use the procedure.
In an extreme case, malicious or wild allegations could give rise to legal action on the part of the persons complained about.

4. Confidentiality – Hostlink UK will treat all such disclosures in a confidential and sensitive manner. The identity of the individual making the allegation may be kept confidential so long as it does not hinder or frustrate any investigation. However, the investigation process may reveal the source of the information and the individual making the disclosure may need to provide a statement as part of the evidence required.

5. Anonymous Allegations - this policy encourages individuals to put their name to any disclosures they make. Concerns expressed anonymously are much less credible, but they may be considered at the discretion of the Company. In exercising this discretion, the factors to be taken into account will include: 
The seriousness of the issues raised.  
The credibility of the concern. 
The likelihood of confirming the allegation from attributable sources.

6. Untrue Allegations - If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. In making a disclosure the individual should exercise due care to ensure the accuracy of the information. If, however, an individual makes malicious or vexatious allegations, and particularly if he or she persists with making them, disciplinary action may be taken against that individual.

Procedures for Making a Disclosure
7. On receipt of a complaint of malpractice, the member of staff who receives and takes note of the complaint, must pass this information as soon as is reasonably possible, to the appropriate designated investigating officer as follows:
In the case of a complaint, which is any way connected with but not against the Business Owner.
The Business Owner will nominate a Senior Manager or external party to act as the alternative investigating officer.

8. If there is evidence of criminal activity then the investigating officer should inform the police. The Company will ensure that any internal investigation does not hinder a formal police investigation.

Timescale
9. Due to the varied nature of these sorts of complaints, which may involve internal / external investigators and / or the police, it is not possible to lay down precise timescales for suc investigations. The investigating officer should ensure that the investigations are undertaken as quickly as possible without affecting the quality and depth of those investigations.

Investigating Procedure
10. The investigating officer should follow these steps:
Full details and clarifications of the complaint should be obtained.
The investigating officer should inform the member of staff against whom the complaint is made as soon as is practically possible. At the discretion of the investigating officer and dependant on the circumstances of the complaint an alternative representative may be allowed e.g. the individual’s legal representative.
The allegations should be fully investigated by the investigating officer with the assistance where appropriate, of other individuals / bodies.
The Business Owner/ Senior Manager will decide what action to take. If the complaint is shown to be justified, then they will invoke the disciplinary or other appropriate Company procedures.
The complainant should be kept informed of the progress of the investigations and, if appropriate, of the final outcome.
If appropriate, a copy of the outcomes will be used to enable a review of Company procedures.

11. If the investigation finds the allegations unsubstantiated and all internal procedures have been exhausted, but the complainant is not satisfied with the outcome of the investigation, HostlinkUKrecognises the lawful rights of employees and ex-employees to make disclosures to prescribed persons or body (e.g. the Health and Safety Executive). A full list of prescribed people and bodies can be found on the Government Website (www.gov.uk).

Last updated September 2022
Next review September 2023