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Whistleblowing is raising a genuine concern about certain types of wrongdoing within an organisation.
A Whistleblower is a person who raises a genuine concern about certain types of wrongdoing in the workplace. Wild Thang Limited is committed to the highest standards of openness, probity, and accountability. We therefore view it as extremely important to have a mechanism in place to enable current, former employees and wider stakeholders to voice concerns in a responsible and effective manner.
The objectives of this policy are:
Wild Thang Limited is committed to regularly reviewing and updating this Policy to ensure its effectiveness and compliance with evolving legal and regulatory requirements, as well as best practices in whistleblower protection and corporate governance.
This Whistleblower Policy and Procedure applies to the following individuals:
The Policy covers concerns or potential misconduct related to Wild Thang Limited's activities, employees, or stakeholders, including but not limited to:
The policy is not designed to question financial or business decisions taken by Wild Thang Limited. Neither should the policy be used for complaints relating to the employee's own personal circumstances, such as the way the employee has been treated at work. The Grievance Procedure should be used in these cases.
The Policy does not apply to personal grievances or complaints related to employment terms and conditions, which are covered by separate policies and procedures.
The Policy applies to Wild Thang Limited's operations and activities within England, Wales and Ireland, as well as the United States.
Covered Individuals may report concerns through the following channels:
The Policy may also apply to third parties, such as suppliers, customers, or stakeholders, to the extent that they become aware of potential misconduct or concerns related to Wild Thang Limited's activities.
committed to taking appropriate corrective actions based on the findings of the investigation.
This Policy is designed to enable employees, workers, and other individuals associated with Wild Thang Limited to raise genuine concerns about potential misconduct or wrongdoing within Wild Thang Limited, without fear of retaliation or adverse consequences.
A reportable concern under this Policy includes, but is not limited to, any suspected or actual:
Reportable concerns may relate to past, present, or potential future misconduct, and may involve employees, workers, or third parties acting on behalf of Wild Thang Limited.
Disclosures must be made in good faith and based on a reasonable belief or suspicion of potential misconduct. Disclosures made for personal gain or with malicious intent may not be protected under this Policy or relevant laws.
This Policy does not cover personal grievances or complaints related to employment terms and conditions, which should be addressed through Wild Thang Limited's grievance procedures.
Wild Thang Limited will make every effort to protect the confidentiality of whistleblowers and their disclosures, subject to legal requirements or the need to conduct a proper investigation.
Anonymous disclosures may be accepted, but whistleblowers are encouraged to identify themselves to facilitate effective investigation and communication.
Whistleblowers who raise genuine concerns in good faith will be protected from retaliation, such as dismissal, disciplinary action, or other forms of detriment. Retaliation against whistleblowers is a serious offense and may result in disciplinary action.
Concerns should be reported through the designated channels or personnel, such as the Whistleblowing Officer/Committee, whistleblowing hotline, or email address provided in this Policy.
If the whistleblower believes that it is not appropriate or possible to report the concern internally, they may consider reporting to external authorities or agencies, as permitted by relevant laws and regulations.
Wild Thang Limited has established multiple channels for individuals to report concerns or potential misconduct under this Policy. Whistleblowing reports can be made through the following designated channels:
Individuals are encouraged to provide as much detail as possible when making a whistleblowing report, including:
Whistleblowing reports can be made in writing, verbally, or anonymously. However, Wild Thang Limited encourages individuals to identify themselves when making a report to facilitate effective communication and investigation.
Upon receipt of a whistleblowing report, Wild Thang Limited will acknowledge receipt within 5 business days and provide an estimated timeline for initiating an investigation.
Wild Thang Limited will maintain strict confidentiality regarding the identity of the whistleblower and the details of the report, subject to legal requirements and the need to conduct a thorough investigation.
If necessary, Wild Thang Limited may contact the whistleblower for additional information or clarification during the investigation process, while maintaining confidentiality.
If the whistleblower has concerns about reporting internally or believes that the matter has not been properly addressed, they may report the concern to relevant external authorities or regulators, such as:
Wild Thang Limited will maintain accurate and confidential records of all whistleblowing reports and investigations, in accordance with applicable data protection laws and regulations.
Wild Thang Limited will provide regular training and awareness programs to ensure that all employees and workers are familiar with the whistleblowing policy and reporting procedures.
Wild Thang Limited will make every reasonable effort to keep the identity of the whistleblower confidential, subject to legal requirements. Disclosure of the whistleblower's identity will only be made on a need-to-know basis and with the whistleblower's consent, unless required by law.
Wild Thang Limited will accept anonymous reports of concerns or misconduct. Anonymous reports will be investigated to the extent possible based on the information provided. However, whistleblowers are encouraged to identify themselves to facilitate a more effective investigation and follow-up.
All information and documentation related to the whistleblowing report will be treated as confidential. Access to confidential information will be restricted to authorized personnel involved in the investigation process.
Wild Thang Limited will implement appropriate data protection measures to safeguard confidential information in compliance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.
Wild Thang Limited may be required to disclose the whistleblower's identity in certain circumstances, such as legal proceedings or court orders. In such cases, the whistleblower will be notified in advance, unless prohibited by law.
Whistleblowers are expected to maintain confidentiality and not disclose information related to the reported concern or investigation to unauthorized parties. Failure to maintain confidentiality may result in disciplinary action or legal consequences.
Any unauthorized disclosure of a whistleblower's identity or confidential information related to a report may result in disciplinary action, up to and including termination of employment or contract. Wild Thang Limited may also pursue legal remedies for breaches of confidentiality, as appropriate.
Initiation of Investigation
Confidentiality and Anonymity
Investigation Procedures
Fair Treatment and Due Process
Timelines and Reporting
Corrective and Disciplinary Actions
Record-Keeping and Documentation
Review and Continuous Improvement
Wild Thang Limited strictly prohibits any form of retaliation, victimization, or adverse treatment against a Whistleblower who raises a genuine concern or participates in an investigation in good faith under this Policy. Retaliation is a serious offense and will not be tolerated under any circumstances.
For the purposes of this Policy, "retaliation" includes, but is not limited to, dismissal, demotion, suspension, harassment, discrimination, or any other unfavourable action taken against a Whistleblower as a result of raising a concern or participating in an investigation.
Wild Thang Limited will take all reasonable measures to protect Whistleblowers from retaliation, including:
Any instances of retaliation or perceived retaliation against a Whistleblower should be reported immediately to the Designated Whistleblowing Officer/Committee or through the designated reporting channels outlined in this Policy.
All reports of retaliation will be promptly and thoroughly investigated, and appropriate remedial action will be taken if retaliation is found to have occurred.
Whistleblowers are legally protected from dismissal or detriment under the Public Interest Disclosure Act 1998 (PIDA) and the Employment Rights Act 1996 for making a protected disclosure. If a Whistleblower experiences retaliation or detriment, they may seek legal recourse through the appropriate channels.
Wild Thang Limited is committed to creating a culture of transparency and accountability, where Whistleblowers can raise concerns without fear of retaliation. Wild Thang Limited has a zero-tolerance policy towards retaliation and is dedicated to protecting Whistleblowers who report concerns in good faith.
Wild Thang Limited will take appropriate disciplinary action against any individual found to have engaged in misconduct or wrongdoing reported through the whistleblowing process. Disciplinary action may include, but is not limited to, verbal or written warnings, suspension, demotion, or termination of employment, depending on the severity of the misconduct. The disciplinary process will be conducted in accordance with Wild Thang Limited's disciplinary policy and applicable employment laws.
Wild Thang Limited strictly prohibits retaliation against whistleblowers who raise genuine concerns in good faith. Retaliation may include, but is not limited to, dismissal, demotion, harassment, discrimination, or any other adverse action taken against the whistleblower. Individuals found to have engaged in retaliation against whistleblowers will be subject to disciplinary action, up to and including termination of employment or contract.
Making malicious or intentionally false reports under the whistleblowing policy may be considered a disciplinary offense and may result in disciplinary action, including potential termination of employment or contract. However, genuine concerns raised in good faith, even if they turn out to be unfounded, will not result in disciplinary action.
Any disciplinary action taken under the whistleblowing policy will be fair, impartial, and follow due process. Individuals subject to disciplinary action will have the right to respond to allegations and present their case. The disciplinary process will be conducted in accordance with the principles of natural justice and applicable employment laws.
Wild Thang Limited is committed to maintaining confidentiality and protecting the personal data of individuals involved in the whistleblowing process, including those subject to disciplinary action. Any personal data collected or processed during the disciplinary process will be handled in accordance with data protection laws and Wild Thang Limited's data protection policies.
Wild Thang Limited will maintain records of disciplinary actions taken under the whistleblowing policy. These records may be used for monitoring, reporting, and continuous improvement purposes, while ensuring appropriate confidentiality and data protection measures.
Wild Thang Limited shall maintain accurate and confidential records of all whistleblowing reports, investigations, and outcomes in accordance with this Policy and applicable laws and regulations.
Records shall be kept securely and in compliance with data protection laws, including the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).
The types of information to be recorded shall include, but are not limited to, the following:
Records shall be retained for a period of 5 years, or as required by applicable laws and regulations, whichever is longer.
All records and personal data related to whistleblowing reports shall be handled in accordance with data protection laws and principles, including:
Wild Thang Limited shall establish procedures for regular reporting on the implementation and effectiveness of this Policy and Procedure.
Reporting shall be conducted annually and shall include, but not be limited to, the following information:
Reporting shall be conducted in a manner that maintains the confidentiality of whistleblowers and other individuals involved, in accordance with this Policy and applicable laws and regulations.
Wild Thang Limited shall use the information gathered from record-keeping and reporting to identify areas for improvement in this Policy and Procedure and shall implement measures to address any identified weaknesses or gaps.
Wild Thang Limited shall regularly review and update this Policy and Procedure based on feedback, lessons learned, and changes in legal or regulatory requirements, to ensure its continued effectiveness and compliance.
Wild Thang Limited is committed to providing regular training and awareness programs to ensure that all employees, workers, and relevant stakeholders are aware of this Whistleblower Policy and Procedure, understand their rights and responsibilities, and know how to report concerns or potential misconduct.
The objectives of the training and awareness programs shall include:
Wild Thang Limited shall conduct training sessions on the Whistleblower Policy and Procedure at regular intervals, which shall be no less than annually.
The training sessions may be delivered through various methods, including but not limited to:
The training content and materials shall be comprehensive and tailored to different roles, responsibilities, and levels within the organization.
The training materials shall include, but not be limited to:
The training materials shall incorporate real-life examples and case studies to illustrate the application of the policy and the potential consequences of non-compliance.
The training shall provide guidance on identifying and reporting different types of concerns or misconduct covered by this Policy.
Attendance at the training sessions shall be mandatory for all employees and workers, including provisions for new hires or those who missed previous sessions.
Wild Thang Limited shall maintain accurate records of training attendance and completion and implement a system for tracking and monitoring training compliance.
Wild Thang Limited shall develop and implement an ongoing awareness campaign to reinforce the key principles and procedures of the Whistleblower Policy and Procedure, utilizing various communication channels such as intranet, newsletters, posters, and email reminders.
Wild Thang Limited shall encourage open dialogue and discussions about ethical conduct, transparency, and the reporting of concerns.
Wild Thang Limited shall regularly evaluate the effectiveness of the training and awareness programs through feedback surveys, assessments, or other methods, and incorporate feedback and lessons learned to continuously improve the training content, delivery methods, and overall effectiveness.
Wild Thang Limited shall ensure that the training and awareness programs remain up-to-date and aligned with any changes in relevant laws, regulations, or best practices.
Wild Thang Limited shall review this Policy and its implementation on a regular basis, at least annually, to ensure its continued effectiveness, compliance with applicable laws and regulations, and alignment with industry best practices.
The review process shall be overseen by the designated Whistleblower Officer, who shall:
Based on the review, the Designated Whistleblowing Officer shall propose any necessary updates or amendments to the Policy, which shall be subject to approval by the Board of Directors.
Upon approval, the updated Policy shall be communicated to all employees and relevant stakeholders through appropriate channels, such as internal communications, training programs, and awareness campaigns.
Wild Thang Limited shall maintain records of Policy reviews, updates, and the rationale for any changes made, in compliance with applicable data protection and record-keeping requirements.
Wild Thang Limited may seek external advice or consultation from legal experts, regulatory bodies, or industry associations to ensure alignment with best practices and compliance with evolving legal requirements, as deemed necessary.
Wild Thang Limited is committed to continuously improving the Whistleblower Policy and Procedure based on feedback, experience, and evolving best practices, to promote a culture of transparency, accountability, and ethical conduct within the organization.