WHISTLEBLOWING POLICY
1. Objective The company encourages employees to raise any concerns that they may have about any wrongdoing at any level within the business and ensure this is acted on and investigated accordingly.
2. Responsibility Managing Director
Operations Manager
Heads of Departments
3. Related Documents Food Safety and Quality Manual
BRCGS Global Standard for Food Safety
Good Manufacturing Guidelines
4. Scope Warehouse / Factory
5. Procedure
5.1 This policy is designed to enable employees, suppliers or customers of the Company to raise concerns at a high level and to disclose information which the individual believes shows malpractice or wrongdoing. 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:
• Financial malpractice or impropriety or fraud
• Failure to comply with a legal obligation or Statutes
• Dangers to Health & Safety or the environment
• Criminal activity
• Improper conduct or unethical behaviour
• Attempts to conceal any of these
• Product safety, integrity, quality & legality
5.2 This policy is designed to offer victim protection to those employees of the Company who disclose such concerns provided the disclosure is made. When implementing remediation measures, the safety, welfare and best interests of the affected persons shall always come first. To the extent possible the identity of the persons making the complaint will remain confidential:
• in good faith
• in the reasonable belief of the individual making the disclosure that it tends to show malpractice or wrongdoing 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 allegation could give rise to legal action on the part of the persons complained about.
5.3 The Company 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.
5.4 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
5.5 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 aggravating allegations, and particularly if he or she persists with making them, disciplinary action may be taken against that individual.
5.6 Procedures for Making a Disclosure
Employees can raise any concerns at any time with any Manager or Supervisor. Alternatively, there is confidential reporting box located in the overall room or you can call 07760162866.
• Complaints of malpractice or wrongdoing will be investigated by the Quality Assurance Manager, unless the complaint is in any way related to the actions of the Quality Assurance Manager. In such cases, the complaint should be passed to the Operations Manager for referral;
• Complaints against the Managing Director should be passed to the Operations Manager who will nominate an appropriate investigating officer;
• The complainant has the right to bypass the line management structure and take their complaint direct to the Operations Manager. The Operations Manager has the right to refer the complaint back to management if they feel that the management without any conflict of interest can more appropriately investigate the complaint.
Should none of the above routes be suitable or acceptable to the complainant, then the complainant may approach one of the following individuals who have been designated and trained as independent points of contact under this procedure. They can advise the complainant on the implications of the legislation and the possible internal and external avenues of complaint open to them:
If there is evidence of criminal activity then the investigating manager should inform the police. The Company will ensure that any internal investigation does not hinder a formal police investigation.
5.7 Due to the varied nature of these sorts of complaints, which may involve internal managers and / or the police, it is not possible to lay down precise timescales for such investigations. The investigating manager should ensure that the investigations are undertaken as quickly as possible without affecting the quality and depth of those investigations.
The investigating manager, should as soon as practically possible, send a written acknowledgement of the concern to the complainant and thereafter report back to them in writing the outcome of the investigation and on the action that is proposed. If the investigation is a prolonged one, the investigating officer should keep the complainant informed, in writing, as to the progress of the investigation and as to when it is likely to be concluded.
All responses to the complainant should be in writing and sent to their home address or if applicable displayed on notice boards.
5.8 The investigating manager should follow these steps:
• Full details and clarifications of the complaint should be obtained;
• The investigating manager should inform the member of staff against whom the complaint is made as soon as is practically possible. The member of staff will be informed of their right to be accompanied by a representative at any future interview or hearing held under the provision of these procedures;
• The investigating manager should consider the involvement of the Operation manager and the Police at this stage. consult with the Managing Directors;
• The allegations should be fully investigated by the investigating officer with the assistance where appropriate, of other individuals / bodies;
• A judgement concerning the complaint and validity of the complaint will be made by the investigating manager. This judgement will be detailed in a written report containing the findings of the investigations and reasons for the judgement. The report will be passed to the operations manager as appropriate;
• The operations 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 passed to the Company Auditors to enable a review of the procedures.
If the complainant is not satisfied that their concern is being properly dealt with by the investigating manager, they have the right to appeal it in confidence with the Managing Director, or another manager.
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, the Company recognises the lawful rights of employees and ex-employees to make disclosures to prescribed persons (such as the Health and Safety Executive, the Auditing Body), or, where justified, elsewhere.
This policy is available in different laguages upon request.
