For a confidential and secure whistleblowing channel submit via this form. 

1. Purpose

1.1 We aim always to conduct our business with the highest standards of integrity and honesty. We expect all our employees and workers to maintain the same standards in everything they do. We therefore encourage anyone to report any perceived wrongdoing by the business or its employees, workers, contractors or agents that falls short of these business principles.

1.2 The policy aims to assist us in the early detection of any inappropriate behaviour or practices within our business and to provide all Workers, with the relevant information so that they understand the procedure to follow when raising concerns about any malpractice which they believe has occurred or is likely to occur within hour business. For the purposes of this policy a “Worker” or “Workers” shall include employees, self-employed contractors, shareholders, management, volunteers, trainees, job applicants and ex-employees. Any person making a disclosure under the policy is defined as a “Reporting Person”. This policy complies with the Public Interest Disclosure Act 1998 and the European Whistleblowing Directive.

1.3 We wish to create an atmosphere of openness in which employees and workers feel confident that they can raise any reasonable concern about our business activities with us in the knowledge that it will be taken seriously, treated as confidential and that no action will be taken against them for raising the matter.

1.4 Employees and workers are encouraged to use the procedure set out below if they have any concerns at all about wrongdoing at work, including any criminal offence, a failure to comply with legal obligations, a miscarriage of justice, a health and safety danger, an environmental risk, breach of food safety and/or hygiene, breach of equal opportunity, not acting professionally or honestly in meeting the needs of our customers/clients, consumers and suppliers or a concealment of any of these.

1.5 This policy is not contractual but sets out the way in which we plan to manage such issues.

2. Scope

2.1 This policy and procedure applies to all employees and Workers as listed above, including those on fixed-term contracts, any casual workers or agency workers. It aims to protect those who make a 'protected disclosure' either during their employment (or duration of the contract/agreement in the case of workers) and also after this has ended, and also enables them to take action in respect of any victimisation.

2.2 For a disclosure to be protected it must reasonably appear to the employee or worker that it is in the ’public interest‘.

2.3 Note that the scope of this policy does not cover any potential breaches of an individual's employment contract: these should be raised under our grievance procedure. Nor is this policy intended to be used to question financial or business decisions taken by us, nor as a means of reconsidering any matters that have already been addressed under our bullying and harassment, grievance, disciplinary or other procedures.

2.4 The policy covers any malpractice within our business and may include :

a criminal offence

• the breach of a legal obligation or any statutory Code of Practice
• a miscarriage of justice
• a danger to the health and safety of any individual
•  an environmental risk
• any attempt to conceal any of the above.

2.5 The list below is not exhaustive but gives examples of the types of concerns that should be raised:

• misuse of assets (including stores, equipment, vehicles, buildings, computer hardware and software)
• failure to comply with appropriate professional standards
• bribery, corruption or fraud, including the receiving or giving of gifts or hospitality in breach of our procedures
• falsifying records
• failure to take reasonable steps to report and rectify any situation which is likely to give rise to a significant avoidable cost, or loss of income to our business or would otherwise seriously prejudice it
• using the power and authority of our business for any unauthorised or ulterior purpose
• causing damage to the environment

2.6 Employees are encouraged to ‘blow the whistle’ on malpractice. By being alerted to any potential malpractice at an early stage we can take the necessary steps to safeguard the interests of all employees and protect our business. The employee or worker does not have to be able to prove the allegations but should have a reasonable and genuine belief that the information being disclosed is true: some allegations may prove to be unfounded, but we would prefer the issue or concern to be raised, rather than run the risk of not detecting a problem early on.

1.7 Any disclosure made under this policy is confidential and the identity of the Reporting Person will be protected, as far as is possible.

3. Responsibility

3.1 The overall responsibility for implementing and monitoring the effectiveness of this policy rests with the CEO. All managers and supervisors/team leaders have a crucial role to play in encouraging employees and workers under their supervision to report any concerns they may have.

3.2 Any employee or worker who has knowledge of, or reasonably suspects, any fraud, theft or other suspicious or unlawful act taking place within our business should report this to their manager, or if they do not feel able to report such matters to their line manager should use the procedure set out below. 

3.3 All employees and workers, irrespective of their job or seniority, are required not to subject any other employee or worker to any detrimental treatment nor harass or bully such an individual on the basis that they have raised a concern under this policy. They are also required not to encourage others to do so nor to tolerate such behaviour. Disciplinary action, including dismissal, may be taken against any employee found guilty of such behaviour. In addition, an employee or worker who has victimised a colleague may be personally liable for any victimisation.

4. Procedure

4.1 An employee who is concerned about any form of malpractice can, in the first instance, raise the issue with their manager. This can be done either verbally or in writing. 

4.2  The disclosure may be anonymous, although openness is encouraged so that the appropriate investigations may be carried out.

4.3 If the Reporting Person feels they cannot raise the alleged malpractice with their manager, for whatever reason, the issue should be raised via the Whistleblowing process via the form.

4.4  Upon receipt of a report, we will acknowledge receipt within 7 days. It may be necessary to carry out an investigation which may be formal or informal, depending on the nature of the concern raised. We will respond to the Reporting Person within three months and will continue to provide updates until a conclusion is provided.

4.5  A Reporting Person may request a confidential in-person meeting and the employee or Worker may ask a work colleague to act as a companion.

4.6  As far as possible, the Reporting Party will be kept informed of the outcome of any enquiries and investigations we conduct and what action, if any, has been taken. Individuals will not be informed of any matter which would infringe on the duty of confidentiality to others.

4.7  Employees or Workers are encouraged to raise any concerns internally using this process. However, there may be exceptional or urgent circumstances where it might be appropriate to refer a concern to an external agency. This is at the sole discretion of the Reporting Party.

Examples of external agencies may include:

- The Local Data Regulator (eg. ICO in UK)

– FSA (For Financial Reports)

- The Local Competition Regulator (e.g. the Competition and Markets Authority in the UK)

4.8  We also reserve the right to make such a referral without the whistleblower’s consent.

4.9 If an employee has a complaint about their own personal circumstances, the normal employee grievance policy should be used.

5. Protection

5.1  We undertake that no employee who makes a bone fide report under this procedure will be subjected to any detriment as a result and we will not condone any form of victimisation, bullying or other detrimental treatment of anyone who has raised a concern under this policy.

5.2  If any individual believes that they are being subjected to any detrimental treatment, bullying or harassment by any person within our business (including by their work colleagues and co-workers) as a result of their decision to invoke this procedure, they must inform their manager immediately (or escalate this matter through the Whistleblowing email address) and appropriate action will be taken to protect them from any reprisals.

5.3  Any victimisation, bullying or detrimental treatment will be dealt with under our disciplinary policy.

6. False Claims

6.1 If it should become clear that the procedure has not been invoked in good faith, for example for malicious reasons or to pursue a personal grudge against another employee, this will constitute misconduct and will be dealt with under our disciplinary policy.

6.2  Under the Public Interest Disclosure Act 1998, disclosures to persons outside our business should only be made if the individual honestly and reasonably believes the allegation to be true. The making of malicious allegations relating to our activities to external persons, including media or Social Media platforms, will constitute gross misconduct and disciplinary action (up to and including dismissal) and/or legal action may be taken against the individual.

7. External Advice

7.1 If a Reporting Person wishes to seek external advice regarding whether to raise an issue under this policy they can do so via the relevant local agency or another professional adviser.

Examples of Agencies/Advisors may include:

-      Protect - a charity in the UK promoting compliance with the law and good practice.

-      The appointed Trust person or the relevant CLA Partner (FNV Horecabond or CNV Vakmensen) in the Netherlands.

-      The Inspection due Travail in France.

8. Related Policies and Documents

• Business ethics and integrity policy
• General Data protection policy
• Disciplinary policy
• Equal opportunity policy
• Grievance policy
• Health and safety policy

The above list is not exhaustive.

9. Further Information

Any queries or comments about this policy should be addressed to your manager in the first instance.

10. Policy owner

This policy is owned and maintained jointly by the Head of HR and Head of Legal.

11. Policy review date

Date last reviewed: February 2024