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Whistle Blowing Policy
Whistle Blowing Policy
Whistle Blowing Policy
360 Recruitment – Whistle Blowing Policy
360Rec-15 | 2024-2025
The term ‘Whistle Blowing’ in this policy refers to the disclosure internally or externally by staff of malpractice, as well as illegal acts or omissions at work
Policy statement
360 Recruitment Ltd is committed to achieving the highest possible standards of service and the highest possible ethical standards in public life and in all its practices. To achieve these ends, it encourages freedom of speech. It also encourages employees and learners to use internal mechanisms for reporting any malpractice or illegal acts or omissions by its employees, ex-employees, learners or ex learners.
Other policies and procedures
360 Recruitment Ltd has a range of policies and procedures, which deal with standards of behaviour at work; they cover Discipline, Grievance, Recruitment and selection. Employees are encouraged to use the provisions of these procedures when appropriate.
There may be times, however when the matter is not about your personal employment position and needs to be handled in a different way.
Bad practice or abuse by a member of staff
A criminal offence has been committed, is being committed or is likely to be committed
Suspected fraud
Disregard for legislation, particularly in relation to health & safety at work
The environment has been, or is likely to be damaged
Breach of standing financial instructions
Showing undue favour over a contractual matter or to a job applicant
A breach of a code of conduct or practice
Information on any of the above has been, is being or is likely to be concealed.
This list is not exhaustive.
360 Recruitment Ltd will not tolerate any harassment or victimisation of a whistle-blower (including informal pressures), and will treat this as a serious disciplinary offence, which will be dealt with under the Disciplinary rules and procedure.
Designated Officer
The following person has been nominated and agreed by 360 Recruitment Ltd as the designated officer for concerns under this procedure and will have direct access to the most senior person in the organisation.
Greg Tyler – Director
Tel: 0115 923 3366
Email: greg@360rec.co.uk
Post: 360 Recruitment Ltd, The Lookout, Bull Close Road, Nottingham. NG7 2UL.
Role of the designated Officer
Where concerns are not raised with the line manager, the designated officer will be the point of contact for employees and learners who wish to raise concerns under the provisions of this policy. Where concerns are raised with him/her, he/she will arrange an initial interview, which will if requested be confidential, to ascertain the area of concern. At his stage, the whistle-blower will be asked whether he/she wishes his/her identity to be disclosed and will be reassured about protection from possible reprisals or victimisation. He/she will also be asked whether or not he/she wishes to make a written or verbal statement. In either case, the designated officer will write a brief summary of the interview, which will be agreed by both parties.
Role of the most senior person in the organisation
The designated officer will report to the most senior person in the organisation, who will be responsible for the commission of any further investigation.
Complaints about the most senior person in the organisation
If exceptionally the concern is about the most senior person in 360 Recruitment Ltd this should be made to the Head of Business Support who will decide on how the business investigation will proceed. This may include and external investigation.
The Investigation
The investigation may need to be carried out under the terms of strict confidentially i.e. by not informing the subject of the complaint until (or if) it becomes necessary to do so. This may be appropriate in case of suspected fraud. In certain cases, however such as allegations of abuse, suspension from work may have to be considered immediately.
The designated officer will offer to keep the whistle-blower informed about the investigation and its outcome.
If results of the Investigation is that there is a case to be answered by any individual, the Disciplinary rules and procedures will be used.
Where there is no case to answer, but the employee held a genuine concern and was not acting maliciously. The designated officer should ensure that the employee suffers no reprisals
Only where false allegations are made maliciously, will it be considered appropriate to act against the whistle-blower, under the terms of the Disciplinary rules and procedure.
If the concern raised is very serious or complex, an inquiry may be held.
The most senior person in 360 Recruitment Ltd will brief the designated officer as to the outcome of the investigation. The designated officer will then arrange a meeting with the whistle-blower to give feedback on any action taken. (This will not include details of any disciplinary action, which will remain confidential to the individual concerned). The feedback will be provided within the time limits (to be specified).
If the whistle blower is not satisfied with the outcome of the investigation, 360 Recruitment Ltd recognises the lawful rights of employees and ex-employees to make disclosures to prescribed persons (such as the Health & Safety Executive, the Audit Commission or the utility regulators or where justified elsewhere).
The Law
This policy and procedure have been written to take account of the Public Interest Disclosure Act 1998, which protects workers making disclosures about certain matters of concern, where those disclosures are made in accordance with the Act’s provisions. The Act is incorporated into the employment Rights Act 1966, which also already protects employees who take action over, or raise concerns about, health at safety at work.
Prescribed Persons
Disclosures of information may be made to the following persons who have been prescribed by the Government.
Gangmasters and Labour Abuse Authority - http://www.gla.gov.uk/ Stronger Together - http://stronger2gether.org/
Data Protection Registrar - https://ico.org.uk/
Health & Safety risks
HSE and local authority
Environmental issues: The Environment Agency
Utilities: OFTEL, OFFER, OFWAT, OFGAS, Rail Regulator
Financial Services & the City: Financial Services Authority (and pending its full operation, its predecessor bodies); HM Treasury (insurance)
Fraud & fiscal irregularities: Serious Fraud office, Inland Revenue, Customs & Excise
Public Sector finance: NAO, Audit commission, Accounts, Commission for Scotland
Company Law: Department of Trade & Industry
Consumer Law: Office of Fair Trading and local authority
Others: Certification officer (Trade Unions)
Civil Aviation Authority
Charity commission
Criminal Cases Review Commission
Occupational Pensions
Regulatory authority
360 Recruitment – Whistle Blowing Policy
360Rec-15 | 2024-2025
The term ‘Whistle Blowing’ in this policy refers to the disclosure internally or externally by staff of malpractice, as well as illegal acts or omissions at work
Policy statement
360 Recruitment Ltd is committed to achieving the highest possible standards of service and the highest possible ethical standards in public life and in all its practices. To achieve these ends, it encourages freedom of speech. It also encourages employees and learners to use internal mechanisms for reporting any malpractice or illegal acts or omissions by its employees, ex-employees, learners or ex learners.
Other policies and procedures
360 Recruitment Ltd has a range of policies and procedures, which deal with standards of behaviour at work; they cover Discipline, Grievance, Recruitment and selection. Employees are encouraged to use the provisions of these procedures when appropriate.
There may be times, however when the matter is not about your personal employment position and needs to be handled in a different way.
Bad practice or abuse by a member of staff
A criminal offence has been committed, is being committed or is likely to be committed
Suspected fraud
Disregard for legislation, particularly in relation to health & safety at work
The environment has been, or is likely to be damaged
Breach of standing financial instructions
Showing undue favour over a contractual matter or to a job applicant
A breach of a code of conduct or practice
Information on any of the above has been, is being or is likely to be concealed.
This list is not exhaustive.
360 Recruitment Ltd will not tolerate any harassment or victimisation of a whistle-blower (including informal pressures), and will treat this as a serious disciplinary offence, which will be dealt with under the Disciplinary rules and procedure.
Designated Officer
The following person has been nominated and agreed by 360 Recruitment Ltd as the designated officer for concerns under this procedure and will have direct access to the most senior person in the organisation.
Greg Tyler – Director
Tel: 0115 923 3366
Email: greg@360rec.co.uk
Post: 360 Recruitment Ltd, The Lookout, Bull Close Road, Nottingham. NG7 2UL.
Role of the designated Officer
Where concerns are not raised with the line manager, the designated officer will be the point of contact for employees and learners who wish to raise concerns under the provisions of this policy. Where concerns are raised with him/her, he/she will arrange an initial interview, which will if requested be confidential, to ascertain the area of concern. At his stage, the whistle-blower will be asked whether he/she wishes his/her identity to be disclosed and will be reassured about protection from possible reprisals or victimisation. He/she will also be asked whether or not he/she wishes to make a written or verbal statement. In either case, the designated officer will write a brief summary of the interview, which will be agreed by both parties.
Role of the most senior person in the organisation
The designated officer will report to the most senior person in the organisation, who will be responsible for the commission of any further investigation.
Complaints about the most senior person in the organisation
If exceptionally the concern is about the most senior person in 360 Recruitment Ltd this should be made to the Head of Business Support who will decide on how the business investigation will proceed. This may include and external investigation.
The Investigation
The investigation may need to be carried out under the terms of strict confidentially i.e. by not informing the subject of the complaint until (or if) it becomes necessary to do so. This may be appropriate in case of suspected fraud. In certain cases, however such as allegations of abuse, suspension from work may have to be considered immediately.
The designated officer will offer to keep the whistle-blower informed about the investigation and its outcome.
If results of the Investigation is that there is a case to be answered by any individual, the Disciplinary rules and procedures will be used.
Where there is no case to answer, but the employee held a genuine concern and was not acting maliciously. The designated officer should ensure that the employee suffers no reprisals
Only where false allegations are made maliciously, will it be considered appropriate to act against the whistle-blower, under the terms of the Disciplinary rules and procedure.
If the concern raised is very serious or complex, an inquiry may be held.
The most senior person in 360 Recruitment Ltd will brief the designated officer as to the outcome of the investigation. The designated officer will then arrange a meeting with the whistle-blower to give feedback on any action taken. (This will not include details of any disciplinary action, which will remain confidential to the individual concerned). The feedback will be provided within the time limits (to be specified).
If the whistle blower is not satisfied with the outcome of the investigation, 360 Recruitment Ltd recognises the lawful rights of employees and ex-employees to make disclosures to prescribed persons (such as the Health & Safety Executive, the Audit Commission or the utility regulators or where justified elsewhere).
The Law
This policy and procedure have been written to take account of the Public Interest Disclosure Act 1998, which protects workers making disclosures about certain matters of concern, where those disclosures are made in accordance with the Act’s provisions. The Act is incorporated into the employment Rights Act 1966, which also already protects employees who take action over, or raise concerns about, health at safety at work.
Prescribed Persons
Disclosures of information may be made to the following persons who have been prescribed by the Government.
Gangmasters and Labour Abuse Authority - http://www.gla.gov.uk/ Stronger Together - http://stronger2gether.org/
Data Protection Registrar - https://ico.org.uk/
Health & Safety risks
HSE and local authority
Environmental issues: The Environment Agency
Utilities: OFTEL, OFFER, OFWAT, OFGAS, Rail Regulator
Financial Services & the City: Financial Services Authority (and pending its full operation, its predecessor bodies); HM Treasury (insurance)
Fraud & fiscal irregularities: Serious Fraud office, Inland Revenue, Customs & Excise
Public Sector finance: NAO, Audit commission, Accounts, Commission for Scotland
Company Law: Department of Trade & Industry
Consumer Law: Office of Fair Trading and local authority
Others: Certification officer (Trade Unions)
Civil Aviation Authority
Charity commission
Criminal Cases Review Commission
Occupational Pensions
Regulatory authority
