This document is the policy of Priavo Maritime Security Incorporated (hereafter the “Company”) on dealing with whistleblowing complaints.
This policy aims to provide guidance to all Directors, managers, employees and personnel providing services on behalf of the company on a contract basis if they should need to raise genuine and legitimate concerns that an instance of wrongdoing has occurred or is occurring in the practice. This is known as whistle-blowing or, more formally, as making a disclosure in the public interest.
We want to foster a culture of openness and a work environment where an individual can feel confident about raising a concern without fear of reprisal. We will safeguard an individual who makes a whistle-blowing complaint in good faith and with a genuine belief of wrongdoing, in accordance with the Public Interest Disclosure Act 1988 (PIDA).
Policy scope and principles
This policy applies to all Directors, managers, employees and personnel providing services on behalf of the company of the company (collectively referred to as ‘staff members’ in this policy), where their actions qualify for protection under PIDA.
PIDA makes it unlawful to dismiss, discipline or victimise a worker who ‘blows the whistle’ on criminal behaviour or malpractice providing the worker has a reasonably held belief that the information is substantially true and makes the disclosure in good faith.
A qualifying disclosure is a disclosure of information where the staff member reasonably believes one of the following is happening, has taken place or is likely to happen in the future:
A criminal offence (such as money laundering, fraud or financial irregularities
Breach of a legal obligation
A miscarriage of justice
Endangering the health and safety of any individual
Damage to the environment
Deliberate concealment of any of the above
The company’s approach to whistleblowing is underpinned by the belief that if a staff member is genuinely concerned that wrongdoing has been or is being committed, they should not ignore it. If a staff member feels they need independent advice, they can contact Public Concern at Work (www.pcaw.co.uk) on 00 (44) 207 404 6609. PCAW provides free and confidential advice on whistle-blowing matters but it is the staff member’s responsibility not to disclose any confidential information relating to the company to this third party.
You can make a complaint either in person or in writing, by specifically referring to your complaint as a whistle-blowing matter, through any of the following channels:
· To your Manager/ Team Leader
· To the General Counsel
· To any of the Directors
· Emailing [email protected]
Whichever way you choose to raise your complaint, it will be acknowledged in writing within 48 hours.
The company will then appoint a senior member of the company’s management team who has not been involved in the matter to investigate the issues raised in the complaint. The investigator will decide how to investigate the complaint, along with likely timescales, to ensure that the complaint is fully, fairly and speedily investigated and may appoint others to assist him/her with the investigation. The investigator will endeavour to resolve the issues as quickly as possible and will communicate progress and outcomes to the whistle-blower and to others impacted by the complaint.
Your identity will not be revealed to people outside the investigation and management teams except:
Where we are legally obliged to do so
Where the information is already in the public domain
To the police as a potential criminal offence
If there are any other circumstances in which we are required to reveal your identity outside those identified above, the investigator or other senior managers will discuss this with you first.
The complaint will be investigated on a confidential basis. A fact-finding meeting will be arranged with you as soon as possible and you can choose to appoint a representative to address the meeting and make representations on your behalf, but such representative may not answer questions for you. This representative may be a colleague or a trade union representative.
Any staff member(s) or other contractors who may be implicated in the complaint will be told that a complaint has been made and what its nature is. They will have an opportunity to respond either in writing or in a fact-finding meeting. They will also have the option to be accompanied by a representative.
In order to assist with the investigation, the investigator may be accompanied by another member of the investigation team and/or management team at the fact-finding meeting(s).
The investigator will communicate the findings of the investigation to:
You, as the person who raised the complaint
The individual(s) under investigation
Members of the company’s management
External authorities who may need to consider whether action should be taken on the basis of the findings, if appropriate
The outcome will be provided as promptly as possible and the complainant will be advised on the timescales throughout the investigation.
Note: If you choose to raise a concern with an outside body, the company requests that you should only do so if you remain dissatisfied with the internal process has been exhausted.
The company will keep formal records of the complaint and outcome. Such records are confidential and are retained in accordance with the Data Protection Act.
This policy will be updated in line with statutory amendments and will be reviewed annually.
Priavo Maritime Security Incorporated
Review Date: 25/02/2019