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WHISTLEBLOWING POLICY

1. Purpose

The purpose of this Whistleblowing Policy is to establish procedures for colleagues and others, to report any concerns about unethical, illegal, or improper conduct with-in the organization, without fear of retaliation.

Whistleblowing is one of the most effective ways of preventing and eliminating wrongdoing at work.

We recognise that raising a whistleblowing concern can be daunting. However, we encourage you to report concerns internally as soon as possible where you suspect wrongdoing. We are here to listen and will take all concerns that you raise seriously.

This policy sets out the procedure for raising a whistleblowing concern and the sup-port and protection that is available to you when you do so.

If your concern relates to a personal grievance that is not in the public interest (for ex-ample, an allegation of bullying or harassment, or an allegation that your contract of employment has been breached), you should raise it under our separate grievance procedure.

This policy does not form part of your contract of employment, and we reserve the right to amend or withdraw it at any time.

2. Scope

This policy applies to all colleagues, contractors, consultants, suppliers, and stakeholders of EGOTM

3. Reporting Procedure

Whistleblowing is the act of reporting suspected wrongdoing or risk of wrongdoing relating to:

  • a criminal offence.
  • a failure to comply with a legal obligation.
  • a miscarriage of justice.
  • a risk to the health and safety of an individual.
  • damage to the environment; or
  • an attempt to cover up any of the above.

You do not need to prove the wrongdoing. However, to be protected by whistleblowing laws against detrimental treatment or dismissal, you must believe that wrongdoing (related to one of the categories listed above) is being, has been, or is likely to be committed and that your disclosure is in the public interest.

Concerns can be reported through multiple channels, including:

  • Direct reporting to line managers or supervisors
  • Contacting the Human Resources Department
  • Utilising the anonymous reporting hotline or online platform provided by the company www.eg-otm.integrityline.com

Reports should include as much detail as possible, such as dates, times, locations, individuals involved, and any supporting evidence.

4. Confidentiality

The identity of whistleblowers who choose not to report anonymously will be kept confidential to the extent possible, consistent with applicable laws and the need to conduct a thorough investigation.

Only individuals directly involved in the investigation will have access to the whistleblower's identity.

5. Non-Retaliation

Retaliation against individuals who report concerns in good faith is prohibited and will result in disciplinary action, up to and including dismissal.

Any employee found to have engaged in retaliation against a whistleblower will be subject to disciplinary measures.

6. Investigation Process

Upon receiving a report, the company will conduct a prompt and impartial investigation.

Whistleblowers will be informed of the progress and outcome of the investigation to the extent possible without compromising confidentiality or privacy rights.

The company will take appropriate corrective actions if wrongdoing is substantiated.

7. False Reporting

Reports made in bad faith, with malicious intent, or with knowledge of their falsity will be subject to disciplinary action.

False reporting may result in termination of employment or other appropriate sanctions.

8. Legal Protections

This policy is designed to comply with all relevant UK legislation, including the Public Interest Disclosure Act 1998 and the Employment Rights Act 1996.

Whistleblowers are protected by law from detrimental treatment or dismissal because of making a protected disclosure.

9. Review & Communication

This policy will be periodically reviewed and updated as necessary to ensure compliance with legal requirements and best practices.

Contact Information: For questions or concerns regarding this Whistleblowing Policy, colleagues may contact the Human Resources Team.

EGOTM is committed to fostering a culture of transparency, integrity, and accountability, and encourages all colleagues to speak up about any concerns they may have.