Cirrus Whistleblowing Policy
All employees, contractors, consultants, officers, and interims are covered by this policy.
It sets out what you should do if you have reason to believe that something dangerous, unlawful, or unethical is going on at work and it is affecting (or risks affecting) you or other colleagues, or the company.
When you report these kinds of concerns, this is called whistleblowing.
We are committed to operating at all times, and in everything that we do, to the highest standards of integrity.
However, this policy recognises that there may be occasions when the high standards expected are not met.
Please follow the procedure outlined below in this policy to immediately report any concerns requiring that action may be needed as fast as possible.
This policy also covers the actions of third parties such as suppliers, service providers, and clients, as well as our staff. If you are concerned about a third party, please also raise them via this Whistleblowing process before approaching anyone else. The HR or Compliance team will be able to explain how you should proceed.
Cirrus will always take your concerns seriously and they will be thoroughly investigated by appropriate personnel. Most importantly, you should feel confident to follow the below procedure. There will be no reprisals for individuals who bring these concerns to the company’s attention – we value and respect all such reports and those who make them to us. We all play an important role in ensuring that our business and everyone working in and with it acts professionally, lawfully and appropriately.
What activities are typically considered relevant to whistleblowing?
This is not an exhaustive list, but the types of concerns you may want to raise with us by whistleblowing could include:
- Any activity you suspect is criminal
- Any activity you suspect puts health and safety at risk
- Any activity you suspect may damage the environment
- Any activity you suspect breaches our policy on bribery and corruption
- Any failure to comply with legal or regulatory obligations
- Any failure to meet professional requirements
- Any attempt to conceal one or more of these activities
If your complaint is about the behaviour of others towards you, please refer to the grievance policy as guidance on how to proceed. These types of behaviour are not covered by this whistleblowing policy.
Please speak to HR or Compliance if you are unsure whether something that you are concerned about is covered by this policy.
Confidentiality and Anonymity
The company encourages individuals to raise concerns openly this makes it easier to investigate than anonymous reports. By using the whistleblowing email address, your name will only be known to 2 individuals who will ensure your confidentiality is protected. Without this, the company will be unable to ask for further clarification and find evidence to support your allegations and/or reach an informed conclusion. In these circumstances, the company may miss evidence or opportunities to gather important supporting information, or identify helpful witnesses, because we may simply be unaware of their existence.
Nevertheless, if you prefer to keep your identity anonymous, we will do all that we can to ensure that you retain your anonymity, and the confidentiality of your concerns, as far as possible. If we need to disclose your identity to others as part of the investigation, we will always discuss with you beforehand both our desire and our reasons for wishing to identify you.
In all circumstances, the company will ensure there are no reprisals. Please see the rights you have in section 2.4 below.
There are no reprisals for mistakes or if following our investigations, (which we will always conduct thoroughly and conscientiously), we conclude that there has been no breach of law, policy, or unethical conduct. However, the disclosure must, in the reasonable belief of the colleague making the disclosure, show that one or more of the following events has happened, is happening or is likely to happen and that it is in the public interest to make the disclosure:
- A criminal offence
- Failure to comply with any legal obligation
- Miscarriage of justice
- Danger to health & safety of any individual
- Danger to the environment, or,
- Deliberate concealment of any of the above.
If at any time, you do not feel that you have been fairly or properly treated by us in the handling of your whistleblowing concern, you must inform us immediately. You should inform the COO in the first instance; and if you are not satisfied with the outcome of that conversation, you should follow the process set out in our grievance policy.
We also protect whistle-blowers from others, so where a whistle-blower reports to us that they have been treated inappropriately by others, (including having received threats as a result of raising their concerns), we will take disciplinary action against those individuals. The consequences of us taking this action could include dismissal of such individual(s) for gross misconduct. Whistle-blowers may also be entitled to take legal action against those individuals.
If you would like more information about your rights as a whistle-blower and how you are entitled to be protected, you can contact Public Concern at Work, which is an independent charity offering a confidential helpline on 020 7404 6609; www.pcaw.org.uk.
Whistleblowing to others outside of Cirrus
Our policy covers the process for raising, investigating, and resolving wrongdoing within the workplace.
The whistleblowing procedure that we have put in place has been designed to ensure that to the best of our ability, we are able to resolve any concerns raised and to protect you as part of this process.
For these reasons, we anticipate that it would be extremely rare, if ever necessary, for you needing to involve anyone outside of Cirrus as part of this process.
However, we recognise that potentially, in exceptional circumstances, you might wish to involve an external body – an industry regulator, for example – and/or the independent charity Public Concern at Work, who can direct you towards the appropriate regulator for the type of issue you want to raise.
Involving the Press or Media
Involving the media in a whistleblowing matter often has the effect of inflaming the situation, not assisting it. It can significantly hamper evidence gathering and the willingness of other relevant individuals to support the process.
We therefore strongly discourage you from involving the media and remind you of your obligations within your contract of employment in this regard. We expect you to have taken all reasonable steps to deal with the matter internally, or with an external regulator, and to have taken full advice from a lawyer or from Public Concern At Work, before you could justify involving the press.