Public Interest disclosure

This was posted by on November 14th, 2016

Introduction

Trust Insurance at all times conducts its business with the highest standards of integrity and honesty. It expects all employees to maintain the same standards in everything they do. Employees are therefore encouraged to report any wrongdoing by the company or its employees that falls short of these business principles. (This also applies to staff of key contractors, if applicable.)

The Public Interest Disclosure Act (PIDA) 1998 protects employees who report wrongdoing within the workplace but it is the aim of this policy to ensure that as far as possible our employees are able to tell us about any wrongdoing at work which they believe has occurred or is likely to occur.

We recognise that employees may not always feel comfortable about discussing their concerns internally, especially if they believe that the company itself is responsible for the wrongdoing. The aim of this policy is to ensure that employees are confident that they can raise a matter with the company that concerns them in the knowledge that it will be taken seriously and treated as confidential.

The company undertakes that no employee who makes a bona fide report under this procedure will be subject to any detriment as a result, in accordance with section 47B of the Employment Rights Act 1996. The company will take all steps possible to ensure that no one (under our control) engages in victimisation as a result. In the event that you believe you are being subjected to detriment by any person within the company as a result of your decision to invoke the procedure you must inform Geoffrey Parrish and appropriate action will be taken to protect you from any reprisals.

If it should become clear that the procedure has not been invoked in good faith, the allegations are false and/or malicious, (for example to pursue a personal grudge against another employee), this will constitute misconduct and will be dealt with in accordance with the terms of the company’s disciplinary procedure.

What does this include under the PIDA?

A qualifying disclosure tends to show that a ‘failure’ has taken place, is taking place or is likely to take place. A failure includes:
• A criminal offence
• A failure to comply with any legal obligation
• A miscarriage of justice
• The putting of health and safety of any individual in danger
• Damage to the environment
• Deliberate concealment relating to any of the above

The company takes these failures very seriously,

Procedure

If appropriate, discuss the matter with your manager in the first instance.
• An informal approach to your manager will be treated as completely confidential (and will not result in any report to anyone within the company unless you agree).
• If the matter requires further investigation this will be carried out by your manager and you will be informed of the outcome and what, if any, action has been taken.

If you would prefer, you may raise concerns to a different manager, or any other senior person within the organisation (including the Principal/Director).

If you remain unhappy about the speed or conduct of the investigation or the way in which the matter has been resolved, you should refer the matter to Geoffrey Parrish. When they have investigated your complaint they will tell you the result of the investigation and what, if any, action has been taken.

External referral

The company is keen to hear of any concerns that employees may have about wrongdoing at work and encourages them to use the procedure described above wherever possible.

The company recognises there may be matters that cannot be dealt with internally and external authorities will need to become involved. Where necessary the company reserves the right to make such a referral without your consent.

From 14 January 2005, the FSA are the regulator prescribed in respect of financial services and marketing matters under the PIDA .On the 1st of April 2013 the regulator became the Financial Conduct Authority (FCA) and further information is available via their website.

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