Whistleblowing Policy

Our Commitment

We are committed to:

1. Open Culture — Encouraging everyone to raise genuine concerns
2. Protection — Protecting those who report concerns in good faith from retaliation
3. Confidentiality — Maintaining confidentiality wherever possible
4. Thorough Investigation — Taking all concerns seriously and investigating appropriately
5. Fair Treatment — Treating all parties fairly throughout the process
6. No Tolerance for Retaliation — Taking action against anyone who victimises a whistleblower
7. Learning and Improvement — Using concerns raised to improve our practices

What is Whistleblowing?

Whistleblowing is the disclosure of information about wrongdoing or malpractice in the workplace. It is different from a personal grievance or complaint about your own employment situation.

Whistleblowing Covers

Concerns about wrongdoing that affects others or the organisation, including:

• Criminal offences or unlawful activity
• Fraud, theft, or financial irregularities
• Bribery or corruption
• Health and safety dangers
• Environmental damage or risks
• Failure to comply with legal obligations
• Breach of company policies
• Miscarriage of justice
• Deliberate concealment of any of the above

Whistleblowing Does Not Cover

Personal grievances or complaints, including:

• Disputes about your own employment terms
• Complaints about your manager or colleagues
• Bullying or harassment directed at you personally
• Disagreements about performance management

These matters should be raised through our Grievance Procedure or other relevant policies.

Legal Protection

Whistleblowers are protected by law under the Public Interest Disclosure Act 1998 (PIDA).

Protected Disclosures

A disclosure is protected if:

• It is made in good faith
• The person making it reasonably believes the information is true
• The person reasonably believes they are making the disclosure in the public interest
• It relates to one of the qualifying categories of wrongdoing

Qualifying Categories

The law protects disclosures about:

• Criminal offences
• Breach of legal obligations
• Miscarriages of justice
• Danger to health and safety
• Environmental damage
• Deliberate concealment of any of these

Protection from Detriment

Workers who make protected disclosures are protected from:

• Dismissal
• Disciplinary action
• Demotion
• Reduction in pay
• Denial of training or promotion
• Bullying or harassment
• Any other detrimental treatment

How to Raise a Concern

We provide multiple channels for raising concerns. You can choose the route most appropriate to your situation.

Step 1 — Consider Your Options

Think about the nature of your concern and who is best placed to address it:

• Is it something your line manager can resolve?
• Does it involve your line manager?
• Is it serious enough to require senior management involvement?
• Does it involve potential criminal activity?

Step 2 — Raise Your Concern

Option A — Line Manager

For most concerns, your line manager is the first point of contact. They can:

• Listen to your concern
• Investigate or escalate as appropriate
• Keep you informed of progress
• Maintain confidentiality

Option B — Senior Management

If your concern involves your line manager, or you feel uncomfortable raising it with them, contact:

• Operations Director
• Managing Director
• Any member of the senior management team

Option C — Compliance Manager

For concerns about compliance, ethics, or governance:

Compliance Manager Email: compliance@allservices4u.co.uk Phone: [Phone number]

Option D — Human Resources

For concerns with an employment dimension:

HR Manager Email: hr@allservices4u.co.uk Phone: [Phone number]

Option E — Confidential Whistleblowing Hotline

For confidential or anonymous reporting:

Whistleblowing Hotline Phone: [Hotline number] Email: whistleblowing@allservices4u.co.uk

This channel is monitored independently and your identity will be protected.

Option F — Written Disclosure

You can submit a written disclosure to:

Whistleblowing Officer All Services 4U [Address]

Mark your envelope “Private and Confidential — Whistleblowing”

Step 3 — Provide Information

When raising a concern, provide as much information as possible:

• What happened or is happening
• When it happened (dates and times)
• Where it happened
• Who was involved
• Any witnesses
• Any documentary evidence
• Why you believe it is wrong
• Any previous attempts to raise the concern

You do not need to have proof of wrongdoing — a genuine belief based on reasonable grounds is sufficient.

Anonymous Reporting

You may raise concerns anonymously if you wish. However, we encourage you to identify yourself because:

• It is easier to investigate when we can ask follow-up questions
• We can keep you informed of progress
• We can provide you with support and protection
• Anonymous allegations can be harder to substantiate

If you do report anonymously:

• We will still investigate where possible
• We cannot provide you with feedback
• We cannot provide the same level of protection

Confidentiality

We will maintain confidentiality as far as possible.

Our Commitment

• Your identity will only be disclosed on a need-to-know basis
• We will not disclose your identity without your consent unless required by law
• All records will be kept confidentially and securely
• Anyone involved in an investigation will be required to maintain confidentiality

Limitations

In some circumstances, we may need to disclose your identity:

• If required by law or court order
• If disclosure is necessary for investigation or legal proceedings
• If there is an imminent risk to health and safety
• With your consent

We will inform you if we need to disclose your identity and explain why.

What Happens Next

Acknowledgement

We will acknowledge receipt of your concern within:

• 2 working days for written disclosures
• Immediately for verbal disclosures

Initial Assessment

We will assess your concern to determine:

• Whether it falls within this policy
• The seriousness and urgency of the matter
• The most appropriate way to investigate
• Who should conduct the investigation

Investigation

An appropriate person will be appointed to investigate. This may be:

• A senior manager not involved in the matter
• The Compliance Manager
• Human Resources
• An external investigator for serious matters

The investigation will:

• Be conducted fairly and objectively
• Gather relevant evidence
• Interview relevant witnesses
• Allow those accused to respond
• Be completed as quickly as reasonably possible

Outcome

At the conclusion of the investigation:

• Findings will be reported to appropriate management
• Appropriate action will be taken
• You will be informed of the outcome (subject to confidentiality)
• Any necessary improvements will be implemented

Timescales

Stage	Timescale
Acknowledgement	Within 2 working days
Initial assessment	Within 5 working days
Investigation	Depends on complexity
Progress updates	At least every 2 weeks
Outcome notification	Within 5 working days of conclusion

Complex investigations may take longer. We will keep you informed of progress.

Protection from Retaliation

We will not tolerate any retaliation against anyone who raises a concern in good faith.

What is Retaliation?

Retaliation includes any detrimental treatment as a result of raising a concern:

• Dismissal or threat of dismissal
• Disciplinary action
• Demotion or denial of promotion
• Reduction in pay or benefits
• Change in duties or working conditions
• Bullying, harassment, or intimidation
• Exclusion or isolation
• Damage to reputation
• Any other unfavourable treatment

Our Commitment

• Anyone who retaliates will face disciplinary action, up to and including dismissal
• Retaliation by third parties (suppliers, subcontractors) may result in termination of contract
• We will take steps to protect you from retaliation
• You can raise concerns about retaliation through this policy

If You Experience Retaliation

If you believe you are being subjected to retaliation:

• Report it immediately through any of the channels listed above
• Keep records of any incidents
• We will investigate and take appropriate action

Malicious or Vexatious Allegations

This policy is designed to protect genuine whistleblowers. It does not protect those who make allegations maliciously or in bad faith.

Good Faith

A disclosure is made in good faith if you genuinely believe that the information is true, even if it later turns out to be mistaken.

Malicious Allegations

Malicious allegations are those made:

• Knowing them to be false
• With intent to cause harm to another person
• For personal gain
• To pursue a personal vendetta

Anyone who makes a malicious allegation may face disciplinary action.

Not Malicious

The following are not malicious:

• Genuine concerns that turn out to be unfounded
• Concerns based on reasonable belief even if mistaken
• Concerns that cannot be substantiated due to lack of evidence

You will not be penalised for raising a genuine concern, even if the investigation does not substantiate it.

Support for Whistleblowers

We provide support to those who raise concerns.

Internal Support

• Access to HR for advice and support
• Regular updates on investigation progress
• Protection from retaliation
• Counselling through our Employee Assistance Programme
• Reasonable adjustments to working arrangements if needed

External Support

You may also seek external advice from:

Protect (formerly Public Concern at Work) Independent whistleblowing charity Phone: 020 3117 2520 Website: www.protect-advice.org.uk

ACAS Advisory, Conciliation and Arbitration Service Phone: 0300 123 1100 Website: www.acas.org.uk

Trade Union If you are a member of a trade union, your representative can provide advice and support.

External Disclosures

In most cases, concerns should be raised internally first. However, in some circumstances you may make a disclosure to an external body.

Prescribed Persons

You may make a disclosure to a “prescribed person” (regulator) if:

• You reasonably believe the information is substantially true
• You reasonably believe the matter falls within the regulator’s remit
• You are not acting for personal gain

Relevant prescribed persons include:

Regulator	Matters Covered
Health and Safety Executive	Health and safety at work
Environment Agency	Environmental protection
Financial Conduct Authority	Financial services
Information Commissioner	Data protection
Serious Fraud Office	Serious or complex fraud
HM Revenue & Customs	Tax fraud
Local Authority	Various regulatory functions
Gas Safe Register	Gas safety

Wider Disclosures

Disclosures to the media or other external parties are only protected in very limited circumstances. You should seek legal advice before making such disclosures.

Record Keeping

We maintain records of all whistleblowing disclosures.

What We Record

• Date and nature of the disclosure
• How the disclosure was made
• Summary of the concern raised
• Actions taken and outcome
• Feedback provided to the whistleblower
• Any lessons learned

Confidentiality of Records

• Records are kept securely with restricted access
• Only those with a legitimate need can access records
• Records are retained in accordance with our retention policy
• Personal data is processed in accordance with data protection law

Retention Period

Whistleblowing records are retained for 6 years from the date of resolution, or longer if:

• Legal proceedings are ongoing or anticipated
• The matter relates to potential criminal activity
• Required by law or regulation

Responsibilities

Board of Directors

• Overall accountability for whistleblowing arrangements
• Setting the tone from the top
• Ensuring adequate resources and procedures
• Receiving reports on whistleblowing activity

Managing Director

• Leadership commitment to open culture
• Ensuring policy implementation
• Reviewing significant disclosures
• Taking action on findings

Whistleblowing Officer / Compliance Manager

• Receiving and logging disclosures
• Coordinating investigations
• Maintaining confidentiality
• Reporting to senior management
• Ensuring protection of whistleblowers

Human Resources

• Providing support to whistleblowers
• Advising on employment implications
• Handling any disciplinary matters arising
• Monitoring for retaliation

Managers

• Creating an open environment for raising concerns
• Receiving and escalating disclosures appropriately
• Maintaining confidentiality
• Protecting team members who raise concerns

All Employees

• Raising genuine concerns about wrongdoing
• Cooperating with investigations
• Maintaining confidentiality
• Not retaliating against whistleblowers

Monitoring and Review

We monitor the effectiveness of this policy.

Monitoring

• Number of disclosures received
• Nature of concerns raised
• Time taken to investigate and resolve
• Outcomes of investigations
• Feedback from whistleblowers
• Any allegations of retaliation

Reporting

The Board receives an annual report on whistleblowing activity, including:

• Summary of disclosures received
• Types of concerns raised
• Outcomes and actions taken
• Trends and patterns
• Recommendations for improvement

Review

This policy is reviewed annually and updated as necessary to reflect:

• Changes in legislation
• Best practice developments
• Feedback and lessons learned
• Audit recommendations

Frequently Asked Questions

What if I’m not sure whether to raise a concern?

If in doubt, raise it. We would rather receive concerns that turn out to be unfounded than miss genuine wrongdoing. You will not be penalised for raising a genuine concern.

Can I raise a concern on behalf of someone else?

Yes. You can raise a concern if you become aware of wrongdoing affecting others, even if it does not directly affect you.

What if my concern involves senior management?

Use the confidential whistleblowing hotline or contact the Board directly. You can also report to an external regulator if appropriate.

Will I be told the outcome?

We will tell you as much as we can, subject to confidentiality obligations. In some cases, we may not be able to share details about disciplinary action taken against others.

What if I’m worried about raising a concern?

Speak to HR, the Compliance Manager, or use the confidential hotline. We will support you through the process and protect you from retaliation.

Can I refuse to participate in an investigation?

We encourage cooperation, but you will not be penalised for declining to participate. However, investigations may be harder to conclude without witness cooperation.

What if my concern is about something outside work?

This policy covers wrongdoing connected to our business. Concerns about matters outside work may be better addressed through other channels.

Related Policies

This policy should be read in conjunction with:

• Anti-Bribery and Corruption Policy
• Code of Conduct
• Grievance Procedure
• Disciplinary Procedure
• Data Protection Policy
• Health and Safety Policy

Approval

This Whistleblowing Policy has been approved by the Board of Directors and is communicated to all employees, subcontractors, and relevant stakeholders.

Date: [Date]

Review Date: [Date + 1 year]

Contact

Confidential Whistleblowing Hotline Phone: [Hotline number] Email: whistleblowing@allservices4u.co.uk

Compliance Manager Email: compliance@allservices4u.co.uk Phone: [Phone number]

HR Manager Email: hr@allservices4u.co.uk Phone: [Phone number]

External Advice — Protect Phone: 020 3117 2520 Website: www.protect-advice.org.uk

Quick Reference

When to Use This Policy

✓ You suspect fraud, theft, or financial irregularities
✓ You are aware of bribery or corruption
✓ You have concerns about health and safety risks
✓ You believe there is environmental damage
✓ You know of breaches of law or regulations
✓ You suspect deliberate concealment of wrongdoing

How to Raise a Concern

1. Speak to your line manager, OR
2. Contact senior management, OR
3. Email compliance@allservices4u.co.uk, OR
4. Call the confidential hotline, OR
5. Write to the Whistleblowing Officer

Our Promise to You

✓ We will take your concern seriously
✓ We will investigate appropriately
✓ We will protect your confidentiality
✓ We will not tolerate retaliation
✓ We will keep you informed
✓ We will not penalise genuine concerns

All Services 4U encourages a culture of openness where concerns can be raised without fear. This policy is available to all interested parties on request.