Whistleblowing policy
About this policy
We are committed to conducting our business with honesty and integrity and we expect all employees to maintain high standards. Any suspected wrongdoing should be reported as soon as possible. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, partners, directors, officers, agency workers, seconded workers, volunteers, interns, consultants, contractors, and extends to our external agents, consultants, third-party representatives, business partners and suppliers (external partners and suppliers).
This policy sets out the procedure for raising a whistleblowing concern, as well as the protection and support available to individuals who do so. Concerns related to employee grievances should be raised under the grievance policy found in the employee policies and procedures handbook. Any concerns regarding bullying, harassment or sexual harassment should be raised through the firm’s dignity at work and sexual harassment policy, also located in the employee policies and procedures handbook. If you are unsure, please speak to your people manager for guidance.
We reserve the right to amend this policy at any time.
Protection and support for whistleblowers
We aim to encourage openness, and we will support and protect whistleblowers who raise genuine concerns under this policy, even if they turn out to be mistaken.
Whistleblowers must not suffer any detrimental treatment, such as bullying or harassment (including sexual harassment), as a result of raising a genuine concern. If you believe that you have suffered any such treatment, you should inform your people manager immediately.
External business partners and suppliers should inform their PKF Francis Clark contact in the first instance if they believe they have suffered any detrimental treatment as a result of raising a genuine concern or if the matter has not been remedied. Should they feel unable to do this for any reason, then they should contact our whistleblowing officer, using the contact details at the end of this policy.
Whistleblowers must not be threatened or retaliated against in any way. If you are involved in such conduct, you may be subject to disciplinary action in accordance with our disciplinary policy contained in the employee policies and procedure handbook which is located on the firm’s intranet. However, if we conclude that a whistleblower has made false allegations maliciously, the whistleblower may be subject to disciplinary action.
What is Whistleblowing?
Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our
activities. This includes:
- suspected bribery
- facilitation of tax evasion
- fraud or other criminal activity
- miscarriages of justice
- health and safety risks
- damage to the environment
- any breach of legal or professional obligations
- any breach of the firm’s required operational procedures and standards as set out in the practice manual directory and in the service line manuals
- reports of bullying, harassment or sexual harassment
How to raise a concern
For employees, we hope that in many cases you will be able to raise any concerns with your manager. However, where you prefer not to raise it with your manager for any reason, you may contact our whistleblowing officer (the firm’s senior internal legal counsel). You can raise your concern verbally by telephone using the confidential telephone line below. Should you leave a message on the voicemail service, we will respond to you as soon as possible. You can also raise your concern in an email using the contact details at the end of this policy, or by completing the anonymous form found here.
External business partners and suppliers should raise any concerns with their direct point of contact at PKF Francis Clark. Should they feel unable to do this for any reason, then they should contact our whistleblowing officer, using the contact details at the end of this policy.
Responding to your concern
You will be provided with a written response as soon as possible from receiving your concern. If you have raised your concern anonymously the response may take longer. We will arrange a meeting with you as soon as possible to discuss your concern with a view to bringing a satisfactory conclusion to the concerns raised, where applicable. If you are an employee, you may bring a colleague to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation.
The level of investigation and the time taken to complete the investigation will vary depending upon the concern raised. Upon completion of the investigation, you will be informed in writing as quickly as possible the outcome and any further steps that will be taken. We aim to provide comprehensive feedback; however, this may not be possible where data protection rules apply or there is sensitive confidential information.
Appeal
If the concern has not been resolved to your satisfaction, you may appeal orally or in writing to one of the other key contacts listed at the end of this policy. The appeal should be made as soon as possible from the date the outcome was provided to you.
An appeal meeting will be arranged as soon as possible and will be dealt with impartially by someone who has not previously been involved in the initial concern. If you are an employee, you may bring a colleague to the meeting, and they must respect the confidentiality of the disclosure and any further investigation. You will be informed in writing of the outcome of the appeal as quickly as possible.
Confidentiality
We hope that you will feel able to raise whistleblowing concerns openly under this policy. If you wish to raise your concern confidentially, we will make every effort to keep your identity secret and only reveal it where necessary to those involved in investigating your concern. You may decide to raise a whistleblowing concern anonymously and you can do this by using the whistleblowing phone number at the end of this policy. Completely anonymous disclosures are difficult to investigate and whilst we will investigate anonymous concerns the best we can, it may mean we are unable to provide you with any feedback.
External Disclosures
The aim of this policy is to provide a supportive process for reporting, investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to involve external parties. The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. We strongly encourage you to seek advice within the firm before reporting a concern to anyone external. The reason for this is that the firm itself may have statutory or professional obligations to report which need to be observed in the first instance.
Should you wish to obtain confidential advice, “Protect” is an independent whistleblowing charity which operates a confidential helpline. You can contact them
using their details at the end of this policy.
Contacts
Primary Contact:
Whistleblowing officer (senior internal legal counsel)
[email protected]
Confidential whistleblowing telephone number: 01392 351800
Secondary Contact:
Head of people management and development
01392 667000
External Contact:
Protect (independent whistleblowing charity)
Helpline: 020 3117 2520
Website: https://protect-advice.org.uk