Whistleblowing

The whistleblowing policy is underpinned by the principles that the highest standards of honesty and integrity are fundamental in all areas of Brickability Group plc. This means being honest and transparent in what we do and what we say and accepting responsibility for our individual and collective actions. Any fraud, misconduct or wrongdoing by either the Company or its employees should be reported. We believe that it is essential to create an environment in which employees feel able to raise concerns internally without fear of disciplinary action being taken against them as a result of any disclosure and be assured that an investigation will take place.

This policy details the supportive process that encourages and enables employees or workers to raise concerns about misconduct within Brickability Group without repercussion and will give them confidence that their concerns will be properly investigated and resolved in a timely manner.

This procedure applies to all employees and those retained on a contract basis. The same standards apply to all.

• To ensure that the policy is applied consistently across the business.
• To ensure that the policy supports a culture of openness and accountability.
• To encourage individuals to raise concerns as soon as possible.
• To ensure policy is updated in line with legislation.
• To provide appropriate guidance to managers and individuals.
• To ensure that all line managers are fully trained in the management of whistleblowing.
• To ensure that all employees are dealt with sensitively and respectfully in all matters and no-one is victimised for raising a matter under this procedure.

• To always conduct business with honesty and integrity and support this whistleblowing process.
• To take personal responsibility for the business area that they are responsible for.
• To create a workplace where employees are able to raise issues.
• To encourage individuals to raise issues as soon as possible.
• To act speedily and effectively to inform the People Team to enable appropriate appointment of responsible person to undertake the investigation.

• To raise issues as soon as possible.
• To follow the internal processes before referring the matter externally.
• Not to accept any practices that are unacceptable.

The Public Interest Disclosure Act 1998 protects employees from dismissal or other disciplinary action when they report wrongdoing by their employers for specified issues. These specified issues are called ‘qualifying disclosures’.

The act aims to promote greater openness between employers and employees in the workplace. We strongly believe that those who report wrongdoing should not be victimised.

Examples of ‘Qualifying disclosures' include:

• A criminal act
• Failure to comply with a legal obligation
• A miscarriage of justice
• Health & Safety breaches
• Damage to the environment
• Concealment of any of the above
• Any suspected fraudulent activity

• Everyone should be aware of the importance of preventing and eliminating wrongdoing at work. You should be watchful for illegal or unethical conduct and report anything of this nature that you 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 whoever raised the issue
• No one will be victimised for raising a matter under this procedure. This means that the continued employment and opportunities for your future promotion or training will not be prejudiced because you have raised a legitimate concern
• Victimisation of an employee 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, you should not agree to remain silent and should report the matter to a Director

Where you wish to make a disclosure concerning one or more of these examples of wrongdoing, you can:

• Discuss the concern with their line manager. We have a responsibility to listen and respond to any matter that is of concern to any employee.
• If the complaint is in any way connected with the employee’s line manager then the complaint should be referred to a Senior Manager or a Director.
• Another option would be to raise your concerns via the Company’s grievance procedure; this process would not however give you the protection of the Public Interest Disclosure Act. You must make clear you are following the grievance procedure in this instance.

If the above are not appropriate or the issue is not satisfactorily resolved, you should put your concerns in writing to the Divisional Director who will arrange for an independent review of the case which will include a full and fair investigation taking place with a view to reaching a sensible and fair resolution of the issue. There may be matters that cannot be dealt with internally and external authorities will need to become involved. Where this is necessary, the Company reserves the right to make a referral on your behalf without your consent.

If on conclusion of the above stages, you reasonably believe that the appropriate action has not been taken, you should consider reporting the matter to the proper authority. The legislation sets out a number of bodies to which qualifying disclosures may be made.

These include:

• HM Revenue & Customs
• the Financial Services Authority
• the Office of Fair Trading
• the Health and Safety Executive
• the Environment Agency

The company recognises that there may be some cases where no wrongdoing is found through internal procedures. In such cases, if the disclosure is reasonable, made in good faith and the information believed to be true, protection will be given, and no disciplinary action will be taken.

The person appointed to undertake the investigation should follow these steps:

• Full details and clarifications of the complaint should be obtained.
• 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 trade union or other representative at any future interview or hearing held under the provision of these procedures.
• Consideration should be made as to whether the Auditors or Police should be informed at this stage and should consult with the CFO or CEO.
• The allegations will be fully investigated with the assistance of the People team and where appropriate, of other individuals / bodies. We may appoint an externally appointed person to conduct the investigation.
• A judgement concerning the complaint and validity of the complaint will be made by the investigating officer. 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 CEO.

The CEO 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 will 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 Brickability 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 officer, they have the right to raise it in confidence with the CEO.

If the investigation finds the allegations unsubstantiated and all internal procedures have been exhausted, but the complainant is not satisfied with the outcome, the complainant is not satisfied with the outcome of the investigation, Brickability Group recognises the lawful rights of employees and ex-employees to make disclosures to prescribed persons (such as the Health and Safety Executive, the Audit Commission, or the Utility regulators), or, where justified, elsewhere.

Last updated: July 2024