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Standard #1: Whistleblowing

General Statement:

  • Any employee who suspects wrongdoing at work is strongly encouraged to raise his concern in confidence through the internal whistleblowing procedure.

Elaboration of Standard:

  • Anyone who raises a genuinely held concern in good faith concerning a matter which he reasonably believes to be true will not suffer any form of reprisal or retribution as a result. This will be the case even where the individual raising the concern is mistaken and there is no case to answer.

  • Harassment or victimization, including informal pressure, of anyone raising a genuine concern will not be tolerated, and any such conduct will itself constitute a breach of the Standards of Business Conduct and will be treated as a serious disciplinary matter.

  • While no one who comes forward in good faith has anything to fear, false allegations raised maliciously will be treated as misconduct and dealt with in accordance with the Disciplinary Procedure.

  • An individual who is concerned about actual or suspected wrongdoing and who wishes to report the matter formally for investigation should raise it with his line manager. The line manager should immediately refer the matter to a Designated Officer for investigation but must otherwise keep all details confidential.

  • Where an individual feels unable to raise his concern with his line manager, for whatever reason, it should be raised directly with a Designated Officer or with an HR manager, who will then refer it to a Designated Officer. Concerns raised in this way will be investigated fully and the identity of the person raising the concern will be kept confidential.

  • When the investigation has been completed, the person who raised the concern will be informed of the outcome by the Designated Officer.

  • Examples of suspected wrongdoing that should be raised in this way include:

    • the commission of a criminal offence;
    • a failure to comply with any legal obligation or any other unlawful act or omission
    • an act or omission which will, or is likely to, unlawfully endanger the health or safety of an individual or unlawfully damage the environment
    • a breach of human rights;
    • accounting malpractice or falsification of documents;
    • any other breach of the Standards of Business Conduct or any other applicable Group Policy;
    • a miscarriage of justice; and
    • concealment of any of the above.
  • This list is not exhaustive. A concern should be raised irrespective of whether the suspected wrongdoing has occurred, is occurring or is likely to occur.

  • While concerns may be raised anonymously, you are strongly encouraged to report matters in confidence rather than anonymously. A full investigation of your concern may not be possible without your cooperation, and proper feedback cannot be provided to those who remain anonymous.

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