PUBLIC INTEREST DISCLOSURE (WHISTLE – BLOWER) POLICY
- 1. INTRODUCTION
The Public Interest Disclosure Act 1998 and this policy protects employees from being dismissed or penalised for disclosing information in the public interest, (more commonly referred to as ‘Whistle-Blowing’), that they honestly and reasonably suspect exposes:
- A criminal offence, e.g fraud
- The breach of a legal obligation
- Miscarriages of justice
- Dangers to health and safety
- Risks/ damage to the environment
- Cover-ups of any of the above
The act requires that the employee must first raise their concern with their employer and consideration has been given as to how best this can be done within Northern.
This policy applies to all employees at every level in the organisation and reinforces Northern’s commitment to the safety and well being of all staff.
- 2. THE POLICY
Northern positively encourages employees to speak out without fear of retaliation or unfair treatment, and report where they genuinely feel a malpractice is taking place or health and safety standards are being compromised.
- 3. SCOPE
This policy applies to all Northern employees.
This policy supports and integrates with other policies. Northern will not tolerate discrimination, victimisation or harassment of conscientious employees and incidents of this nature, arising from, or revealed as a result of ‘Whistle-Blowing’, will be viewed seriously and dealt with as a potential discipline matter under Procedure Agreement No 4.
- 4. THE DISCLOSURE REPORTING PROCESS
We recognise that employees are often the first to notice that there may be something wrong within the company. Most concerns are of a relatively minor nature that can and should be resolved through normal channels, and this policy does not affect the normal role and responsibilities of Health and Safety Representatives.
Wherever possible, staff should first raise their concern(s) with their direct line manager. However, where their direct line manager, or other members of the management team, may be involved in the alleged malpractice, then it should be reported directly to the appropriate HRBP for the directorate. The HR team may also be contacted to discuss a concern and the most appropriate course of action to be taken.
When reporting a concern, the employee should give their name, location and a contact point. If when reporting they get an answer phone message, they should not leave details, but ask the
manager or HR team member to make contact with them as soon as possible. Any matters raised with either the line manager or HR will be dealt with promptly, properly and in a way to maintain confidentiality
Alternatively employees can contact Internal Audit via email@example.com, or, should employees prefer to speak to someone outside of Northern they can also raise their concerns with Arriva Group via telephone (0800 587 7580) or email (firstname.lastname@example.org).
DB Group facilities are also available to Northern employees, the details of which can be found at www.deutschebahn.com/en/group/compliance/whistleblowing/
An employee reporting a concern will not be expected to prove the truth of their allegation, but
they should be able to demonstrate that there are sufficient grounds to have a reasonable belief that something is wrong. Employees are encouraged to raise their concerns at the earliest possible stage so that timely action may be taken. Anyone raising a concern should provide background information and the reason for the concern, together with names, dates, places, and as much other information as possible.
- 5. DISCLOSURE FEEDBACK AND ANONYMITY
Under normal circumstances, investigations should take no longer than 14 days but would of course depend upon the complexity of the allegation.
Feedback on the outcome will be given to those who report the alleged malpractice. Where an
employee’s concern arises from a misunderstanding the issues will be explained, but the making of false and/or malicious reports will be a potential disciplinary matter under Procedure Agreement No 4.
Northern encourages employees not to make anonymous reports as it can hinder or complicate
investigations and possibly prevent appropriate action from being taken. However, if an employee believes there is no other way to report their concern than to make an anonymous report, then the employee may do so. e.g. under the Ciras or other safety related reporting processes.
Staff who are members of a Trade Union may also seek advice from their union on matters of
concern but must personally report allegations of a malpractice as above. Employees should
avoid any form of external communications regarding any reports unless internal investigations
have been completed and all internal alternatives have been exhausted.