Whistleblowing

ASG group is committed to conducting our business with honesty and integrity and we expect all employees to maintain high standards. A culture of openness and accountability is essential in order to prevent such situations from occurring or to address them when they do occur.

1. Scope

The Whistleblowing policy covers an employee’s right to raise a concern, known as a ‘disclosure’, of any suspected wrongdoing or dangers at work.

This policy should not be used for complaints relating to personal circumstances, as the Company’s Grievance Policy is intended to address concerns in this area.

Procedure

1. Reporting and Investigation

In the event that there is reason to believe that an act within the scope of the policy is taking place, this should be reported to the Group  HR Manager, specifying that the report is being made under the terms of the Whistleblowing Policy.

Details must be provided of the reasons for the concern. It is not always necessary to have absolute proof that such an act is being, has been, or is likely to be committed, evidence that highlights a reasonable belief will often be sufficient.

An investigation will be conducted into the complaint with support from the Group HR Manager. Investigation meetings will be held with all relevant parties.

2. Timescales

We will aim to keep all concerned informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent us giving specific details of the investigation or any disciplinary action taken as a result.

3. Outcomes

Whilst we cannot always guarantee the outcome an individual may be seeking; we will deal with all concerns fairly and in an appropriate way. If an individual is unhappy with the way their concern has been dealt with, the matter can be raised with Public Concern at Work (Independent whistleblowing charity – 0207 404 6609).

4. Confidentiality

The company will keep the identity of individuals confidential as far as possible. However, in certain circumstances, e.g., if a criminal investigation is required, individuals may be needed as a witness and as such they will be informed of any impact on confidentiality at the earliest opportunity.

We do not encourage individuals to make disclosures anonymously. Proper investigation may be more difficult or impossible if we cannot obtain further information from employees making the report. It is also more difficult to establish whether any allegations are credible and have ben made in good faith. Whistle-blowers who are concerned about possible reprisals if their identity is revealed should come forward to the Group HR Manager and appropriate measures can then be taken to preserve confidentiality. 

If you are in any doubt, you can seek advice from HR or Public Concern for Work; the independent whistleblowing charity, who offer a confidential helpline.

5. External disclosures

The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace and we would encourage all concerns to be reported internally in the first instance. In most cases, it should not find it necessary to alert anyone externally.

The law recognises that in some circumstances it may be appropriate for concerns to be reported to an external body such as a regulator. It will very rarely, if ever, be appropriate to alert media. We strongly encourage individuals to seek advice before reporting a concern to anyone external.

Whistleblowing concerns usually relate to the conduct of our employees, but they may sometimes relate to the actions of a third party, such as a customer, supplier or service provider. The law allows concerns to be raised in good faith with a third party where there is reasonable belief that the concern relates mainly to their actions or something that is legally their responsibility. However, we encourage such concerns to be reported internally first.

Revised October 2022