Employees, agency workers, self-employed contractors, and trainees on vocational or work experience schemes are encouraged to raise genuine concerns about possible malpractice within Evri at the earliest practicable stage rather than to wait for proof.
This policy does not form part of your terms and conditions of employment, and can at any time be reviewed and changed at the organisations request.
This document supersedes all prior Public interest & Disclosure policies.
Evri believes that it is good business practice to ensure that everyone is aware of what constitutes malpractice under the terms of the Public Interest Disclosure Act, 1998, and what action they can take to disclose alleged instances of malpractice. Individual employees may often be the first to realise when either a colleague or Evri is doing something that is illegal, improper, or fraudulent.
The aim of this policy is to provide a rapid mechanism under which genuine concerns can be raised internally, and if necessary externally, without fear of adverse repercussions. It is also intended to promote throughout Evri a culture of openness and a shared sense of integrity by inviting all employees to act responsibly in order to uphold the reputation of Evri and maintain public confidence.
Sometimes employees may not report their concerns for a number of reasons:
In such circumstances, individuals may believe that it is easier to ignore the concern rather than to report what may prove to be just a suspicion of malpractice. The procedure detailed below is intended to provide safeguards and reassurances to enable employees to raise concerns about malpractice in connection with the business.
The procedure also aims to balance the need to provide safeguards for individual employees who raise concerns in good faith about malpractice, against the need to protect other employees and Evri against malicious or vexatious allegations that can cause serious damage to innocent individuals.
The Security department has set up a free phone telephone service – “Speak up Line” – for individuals to report information relating to allegations or suspicions of malpractice. This is a confidential line, where information can be left anonymously if preferred. All information is treated as confidential. The “Speak Up Line” number is 0844 543 7010
Some examples of the types of matters regarded as malpractice for the purposes of this policy are:
The individual should, as soon as reasonably practicable, disclose in confidence the grounds for their belief of malpractice to a manager or HR Business Partner, providing as much supporting written evidence as possible about the reasons for their concern about wrongdoing.
The manager/HR Business Partner, will interview the individual in confidence as soon as practicable after the initial disclosure.
The employee can request that their identity be kept confidential. Evri will make every effort to respect this request, but cannot guarantee it in all circumstances. Where this may not be possible – for instance, if the issue becomes a matter for the police – Evri will discuss this with the individual as soon as possible.
As soon as practicable, the manager/HR Business Partner will recommend the further stages to be taken. Such recommendations may (without limitation) include one or more of the following:
Any recommendations for action will follow an investigation. Recommendations may be made by a manager, HR Business Partner or an appropriate senior level manager, providing that none of them are alleged to be involved in the malpractice and will be made to the HR Director or Chief Executive.
In any case, the recommendation will be made without revealing the identity of the individual, save as provided for in the section headed “Safeguards” below. The recipient of the recommendation will take all steps within their power to ensure that such safeguards are implemented, except to the extent that in the view of the recipient there are good reasons for not doing so.
A recommendation of no further action may be made if the manager/HR Business Partner:
A recommendation of no further action may also be made if:
Where possible, the individual will be informed of the relevant actions to be taken, or if there is no further action deemed necessary.
If, having followed the above procedure, the individual is not satisfied with the action taken; they may raise the matter directly with the Police or other relevant Public Authority / Government department. However, the individual should inform Evri of this intention before approaching an external body so that the reasons for their dissatisfaction can be examined and, hopefully, resolved.
The individual may disclose the matter on a confidential basis to a professionally qualified lawyer for the purpose of taking legal advice. Evri is not responsible for reimbursing the individual for any expenditure as a result of them taking this action.
Whenever possible, the individual will not be identified unless they give their consent in writing, or there are grounds to believe that the individual has acted maliciously. In the absence of such consent or grounds, the individual will only be identified in circumstances where:
Any documentation (including computer files) kept in relation to the matter will be kept secure. As far as practicable, any documentation prepared by the manager/HR Business Partner will not reveal the identity of the individual as the discloser of information under this procedure. If a union representative or work colleague is involved in this procedure, they will required to keep the matter strictly confidential, save as required by law or until such time as it comes into the public domain.
Evri encourages individuals to report their concerns rather than to keep them to themselves. The individual will not be penalised in any way as a result of raising the issue, unless the action is not raised in good faith. Where there are grounds to believe that a disclosure has been made maliciously, or where an external disclosure is made without first advising Evri and without reasonable grounds, Evri may take action against the individual. This could include disciplinary action for employees, or possible civil action for non-employees.
This policy should be read in conjunction with the Equality and Diversity policy, Grievance policy and guidelines where appropriate.
This document will be reviewed annually. If there are any changes prompted by legislation or case law it will be reviewed to ensure compliance.
This policy is owned by Human Resources.