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Whistleblowing Policy: 1 Scope

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5 November 2020 www.ltsi.co.uk.

WHISTLEBLOWING POLICY
NIRAS-LTS International (hereafter NIRAS-LTS) is committed to ensuring the
highest standards of conduct in the delivery of services. Allegations on non-
compliance with NIRAS-LTS Policies, and thus also with internationally accepted
integrity standards, can be made internally in LTS by LTS staff or externally by
outsiders who claim to have a suspicion or a proved case.
NIRAS-LTS is committed to creating and maintaining a culture of openness within
our organisation so that individuals feel encouraged and confident to raise any
concerns relating to suspected misconduct at an early stage. All NIRAS-LTS staff,
permanent as well as project staff, are obliged to report any real or suspected
incidents of corruption.
We also recognise the negative effect which malpractice can have on the
organisation, and therefore encourage you to raise genuine concerns, or any
suspicions you may have concerning misconduct.

1 Scope
This Policy is intended to cover concerns that are made in the public interest. If
the matter is of an individual or personal nature it should be pursued through the
grievance procedure outlined in the Employee Handbook or within your contract.
This Policy applies to employees, and sub-contractors.
This Policy is non-contractual and may be amended by us at any time.

2 Responsibility
Responsibility for implementing this policy lies with the whistle-blower’s Line
Manager or Project Manager, and ultimately the Managing Director.
All of our workers will receive an appropriate briefing to ensure that they are fully
aware of their rights and responsibilities under this Policy. This Policy is made
available to all employees and sub-contractors.
All managers will be fully briefed as to their role in supporting this Policy and the
appropriate action to take in the event of any disclosure being made to them.

3 Principles
We appreciate that those reporting concerns may be apprehensive. We want to
reassure you that you will suffer no detrimental treatment as a result of voicing
your concerns.
We will not tolerate victimisation, harassment, bullying or any other detrimental
treatment of any worker who has made a disclosure under this Policy. Complaints
about such behaviour will be dealt with under the Disciplinary Procedure.
Should you feel you have been subjected to any detriment as a result of raising a
concern under this Policy you should notify your Line Manager for employees or
your Project Manager for sub-contractors.
You can make a disclosure under this Policy if you have genuine concerns relating
to any of the following areas of malpractice, or suspected malpractice:
• Criminal activity;
• Miscarriages of justice;
• Practices endangering health and safety;
• Practices damaging the environment;
• Failure to comply with a legal obligation;
• Abuse of vulnerable children or adults;
• Illegal labour practice constituting modern slavery;
• Bribery;
• Financial malpractice, impropriety or fraud;

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5 November 2020 www.ltsi.co.uk.

• Attempts to conceal any of the above.

The malpractice can be past, present or prospective. It may have occurred inside
or outside the United Kingdom.
You are encouraged to report suspected wrongdoing as soon as possible. No action
will be taken against you if you raise genuine concerns even if the concern you
raised is not confirmed by any subsequent investigation.

3.1 Confidentiality and anonymity


Any disclosure you make under this Policy will be treated as far as reasonably
practicable in a confidential and sensitive manner. If confidentiality is not
reasonably practicable, for instance, because of the nature of the information, this
will be explained to you.
We hope you will feel comfortable to voice any concerns openly, however, you
may make a disclosure anonymously. However, concerns expressed anonymously
cannot be dealt with as effectively as open disclosures as they are often more
difficult to investigate.

4 Process
Allegations should be made directly to Kimberly-Kerr@ltsi.co.uk.

4.1 Investigation
Once a concern has been raised, we will investigate this. If you have not made
the complaint anonymously, you will be asked to attend a meeting as part of this
investigation.
We will keep you informed as to the progress of the investigation, as far as is
possible and appropriate bearing in mind, in particular, any confidentiality
obligations that apply. Please note that you will not be given details of any
disciplinary action taken unless we consider this appropriate.

4.2 UK Aid Direct Whistleblowing Hotline


For UK AID-funded projects, there is a UK Aid Direct whistleblowing hotline (+44
(0) 1355 843 747) which facilitates the reporting of possible illegal, unethical, or
improper conduct when the normal channels of communication have proven
ineffective or difficult. The hotline is available to be used by all DFID employees,
as well as clients, Business Partners and others in a business relationship with UK
Aid Direct. Please use this hotline to report corruption, fraud, human trafficking,
slavery, safeguarding children and young people concerns, terrorism funding, and
other violations related to UK Aid Direct, DFID staff and consultants, and
programmes.
UK Aid Direct, consultants, contractors, suppliers, and associated person(s)
involved in DFID funded business should immediately report any suspicions or
allegations of aid diversion, money laundering or counter terrorism finance to the
Counter Fraud and Whistleblowing Unit at reportingconcerns@dfid.gov.uk or +44
(0) 1355 843 747.

4.3 Dissatisfaction with the outcome of the process


If you are dissatisfied with the outcome of the investigation, you should raise this
with the Managing Director, giving the reasons for your dissatisfaction. He will
respond in writing notifying you of his acceptance or rejection of the need for
further investigation and the reasons for this.

4.4 Breach of this Policy


We may invoke the Disciplinary Procedure if you are found to have subjected a
whistle-blower to any form of detrimental treatment. It may also be invoked if
you have intentionally misled us in respect of any matter, breached this Policy in

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5 November 2020 www.ltsi.co.uk.

any other way and/or if we believe that you have made a false allegation
maliciously.

Patrick Abbot

Managing Director, NIRAS-LTS International

5th November 2020

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