Whistle blowing policy

The Devonshire Group are committed to carrying out business in a safe, honest and ethical way.  Part of that is creating an open and supportive working environment where colleagues feel able to speak up about any suspected wrongdoing. 

This policy details our process for dealing with whistleblowing.  This policy applies to all colleagues and anyone working with us.

If you are concerned that any of the issues below are happening, have happened or are likely to happen, we encourage you to raise this as soon as possible:

    • Any bribery, fraud or other criminal offence
    • A miscarriage of justice
    • An act creating risk to health and safety
    • A risk or actual damage to the environment
    • A breach of any other legal or professional obligation; or
    • Concealment of any of the above.

It is not necessary for you to have any proof that any of these acts are happening.  As long as you have a reasonable belief, you should report your concerns and we encourage you to do so under this procedure in the first instance. 

If you’ve made a disclosure under this policy you will not suffer any detrimental treatment as a result of raising a genuine concern.  If you believe that you have suffered any such treatment, you should inform your manager or a member of the People team immediately.

Equally you must not threaten or retaliate against a colleague who has raised matters of concern under this policy.  If we think you might have acted in such a manner we’ll need to investigate and it may mean disciplinary action against you.  You might also be at risk of being found personally liable for your behaviour.

Principles

    • Everyone should be aware of the importance of preventing and eliminating wrongdoing at work. Colleagues should be watchful for illegal or unethical conduct and report anything of that nature that they become aware of.

    • Any matter raised under this procedure will be investigated thoroughly, promptly and confidentially, and the outcome of the investigation reported back to the colleague who raised the issue.

    • No colleague will be victimised for raising a matter under this procedure. This means that the continued employment and opportunities for future promotion or training of the colleague will not be prejudiced because he/she has raised a legitimate concern.

    • Victimisation of a colleague for raising a qualified disclosure will be a disciplinary offence.

    • If misconduct is discovered as a result of any investigation under this procedure the Company’s disciplinary procedure will be used, in addition to any appropriate external measures.

    • Maliciously making a false allegation is a disciplinary offence.

    • An instruction to cover up wrongdoing is itself a disciplinary offence. If told not to raise or pursue any concern, even by a person in authority such as a manager, colleagues should not agree to remain silent. They should report the matter to a member of the SET.

Procedure

If you need to raise a concern, here’s how you can go about doing it.  Remember, if you have a personal complaint or concern, for example, how you are being treated at work, this isn’t a whistleblowing matter.  It would be covered under the grievance process or the bullying and harassment policy depending on the type of complaint you have. 

1) You can raise the issue with your line manager.  But if you believe your manager to be involved in the wrongdoing you have concerns about, or you don’t feel able to speak to them, talk to another manager instead or the People team.  You may be asked to confirm any verbal concerns in writing.

2) The line manager will arrange an investigation of the matter (either by investigating the matter themselves or immediately passing the issue to someone in a more senior positon).  An investigation meeting will be held with the individual making the disclosure.  The purpose of this meeting is to gather as much information as possible regarding their concerns, including whether they have any supporting evidence or can identify any witnesses. Any investigation will be carried out in accordance with the principles set out above. 

3) After this meeting, the investigating manager will commence a full investigation into the concerns raised.  The investigation will aim to gather all relevant information including relevant documentary evidence or witness statements.

4) Once the investigation is complete, the investigating manager will report their findings to the Senior Executive Team, which will take any necessary action, including reporting the matter to the appropriate organisation or regulatory body with authority for that area.  If disciplinary action is required, the investigating manager will report the matter to the People team and start the disciplinary procedure.  On conclusion of any investigation, the investigating manager will write to the individual confirming the outcome.

5) If on conclusion, you are not satisfied with the explanation or outcome, you may rise the matter with the appropriate official organisation or regulatory body.  Alternatively, you may raise a formal complaint under the Company’s grievance policy.