Whistleblowing Policy

Whistleblowing Policy

INTRODUCTION

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:

  • To provide a safe and confidential mechanism for individuals to report concerns about potential misconduct or wrongdoing within Wild Thang Limited;
  • To protect whistleblowers from retaliation or adverse consequences for raising genuine concerns;
  • To ensure that reported concerns are properly investigated and addressed in a timely and appropriate manner;
  • To promote a culture of transparency, accountability, and ethical conduct within Wild Thang Limited.

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.

SCOPE OF POLICY

This Whistleblower Policy and Procedure applies to the following individuals:

  • All current employees of Wild Thang Limited, including full-time, part-time, and temporary employees, regardless of their level or position within Wild Thang Limited.
  • Contractors, consultants, or agency workers who provide services to Wild Thang Limited.
  • Former employees and workers of Wild Thang Limited.

The Policy covers concerns or potential misconduct related to Wild Thang Limited's activities, employees, or stakeholders, including but not limited to:

  • Financial irregularities, fraud, or misappropriation of assets.
  • Violations of health and safety regulations or practices.
  • Environmental issues or breaches of environmental laws and regulations.
  • Breaches of legal or regulatory requirements.
  • Violations of Wild Thang Limited's policies, procedures, or code of conduct.
  • Unethical or improper conduct, including conflicts of interest.

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.

WHISTLEBLOWING PRINCIPLES

  • Wild Thang Limited is committed to conducting its business with the highest standards of ethics, integrity, and transparency. Wild Thang Limited encourages a culture of openness and accountability within the organization, where employees and workers feel empowered to raise genuine concerns about potential misconduct or wrongdoing without fear of retaliation.
  • Wild Thang Limited recognizes the vital role of whistleblowing in identifying and addressing potential misconduct or wrongdoing and acknowledges that whistleblowing is a valuable tool for promoting good governance and protecting Wild Thang Limited's interests.
  • Wild Thang Limited is committed to protecting whistleblowers from retaliation, discrimination, or adverse consequences for raising genuine concerns in accordance with this Policy. Whistleblowers are afforded legal protections under the Public Interest Disclosure Act 1998 (PIDA) and the Employment Rights Act 1996.
  • Wild Thang Limited is committed to maintaining the confidentiality of whistleblowers' identities and the information provided, to the extent possible and permitted by law. Whistleblowers have the right to report concerns anonymously, if desired.
  • Wild Thang Limited encourages whistleblowers to report concerns in good faith, based on reasonable belief and without malicious intent. This Policy does not protect individuals who make intentionally false or misleading reports.
  • All reported concerns will be thoroughly and impartially investigated by designated personnel or an independent third party. Wild Thang Limited is

committed to taking appropriate corrective actions based on the findings of the investigation.

  • Wild Thang Limited explicitly prohibits any form of retaliation, harassment, or adverse treatment against whistleblowers for raising genuine concerns under this Policy. Individuals found to have engaged in retaliation may be subject to disciplinary action, up to and including termination of employment or contract.
  • Wild Thang Limited is committed to regularly reviewing and improving this Whistleblower Policy and Procedure to ensure its effectiveness and alignment with best practices in whistleblower protection and corporate governance.

REPORTABLE CONCERNS

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:

  • Criminal offenses, such as fraud, bribery, corruption, or money laundering;
  • Breaches of legal or regulatory requirements;
  • Violations of Wild Thang Limited's policies, procedures, or code of conduct;
  • Miscarriages of justice;
  • Dangers to health and safety or the environment;
  • Unethical or improper conduct;
  • Attempts to conceal any of the above.

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.

REPORTING PROCEDURES

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:

  • Whistleblowing Officer – Leigh McLaughlin
  • Dedicated Whistleblowing Hotline: 07944953330
  • Dedicated Whistleblowing Email Address: management@wildthang.co.uk

Individuals are encouraged to provide as much detail as possible when making a whistleblowing report, including:

  • A clear description of the concern or potential misconduct;
  • Relevant dates, times, and locations;
  • Names of individuals involved or witnesses;
  • Supporting documentation or evidence, if available.

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.

CONFIDENTIALITY AND ANONYMITY

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.

INVESTIGATION PROCESS

Initiation of Investigation

  • Upon receiving a whistleblowing report or concern, the Designated Whistleblowing Officer/Committee shall promptly initiate an investigation into the reported matter.
  • The Designated Whistleblowing Officer/Committee shall be responsible for overseeing and coordinating the investigation process.

Confidentiality and Anonymity

  • Wild Thang Limited shall make every reasonable effort to maintain the confidentiality of the whistleblower's identity and the reported information, subject to legal and regulatory requirements.
  • The whistleblower's identity may need to be disclosed in certain circumstances, such as legal proceedings or regulatory investigations, but only to the extent necessary and permitted by law.
  • Anonymous reports will be accepted and investigated to the extent possible, considering the limitations associated with the lack of ability to follow up or gather additional information from the whistleblower.

Investigation Procedures

  • The investigation shall be conducted by individuals with appropriate qualifications, independence, and expertise, who shall gather and review relevant evidence, conduct interviews, and analyse all pertinent information related to the reported concern.
  • Wild Thang Limited may engage external investigators or subject matter experts, as necessary, to ensure a thorough and impartial investigation.
  • The investigation shall be conducted in a fair and objective manner, ensuring due process and the protection of the rights and interests of all parties involved.

Fair Treatment and Due Process

  • Wild Thang Limited shall ensure fair treatment and due process for all parties involved in the investigation, including individuals who are the subject of the reported concerns.
  • Individuals who are the subject of the reported concerns shall be informed of the allegations against them and provided with an opportunity to respond and present their perspective during the investigation.
  • Wild Thang Limited shall take appropriate measures to protect the rights and interests of all parties during the investigation, including the implementation of confidentiality measures and the prevention of retaliation or adverse consequences.

Timelines and Reporting

  • The investigation shall be conducted in a timely manner, with an estimated timeline for completion based on the complexity and nature of the reported concerns.
  • The whistleblower (if known) and other relevant parties shall be provided with periodic updates and progress reports on the investigation, subject to confidentiality and legal requirements.
  • Upon completion of the investigation, the Designated Whistleblowing Officer/Committee shall report the findings and recommendations to the appropriate authorities or governing bodies within Wild Thang Limited.

Corrective and Disciplinary Actions

  • If the investigation findings substantiate the reported concerns, Wild Thang Limited shall take appropriate corrective actions and implement disciplinary measures, in accordance with its policies and procedures, and applicable laws and regulations.
  • Individuals found to have engaged in misconduct or wrongdoing shall be subject to disciplinary action, which may include termination of employment or other appropriate consequences.
  • Wild Thang Limited shall take prompt and appropriate action to address any instances of retaliation or adverse consequences against the whistleblower, in accordance with its policies and applicable laws and regulations.

Record-Keeping and Documentation

  • Wild Thang Limited shall maintain accurate and comprehensive records of the investigation process, findings, and actions taken, in compliance with legal and regulatory requirements.
  • All investigation-related documents and records shall be securely stored and retained in accordance with Wild Thang Limited's document retention policies and applicable laws and regulations.

Review and Continuous Improvement

  • Wild Thang Limited shall regularly review and evaluate the effectiveness of the investigation process and procedures, incorporating feedback and lessons learned to improve the whistleblowing policy and investigation processes.
  • Wild Thang Limited shall make necessary updates and revisions to the whistleblowing policy and investigation procedures to ensure compliance with evolving legal and regulatory requirements, as well as best practices in whistleblower protection and corporate governance.

PROTECTION FROM RETALIATION

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:

  • Maintaining confidentiality and anonymity (if requested) to the extent possible, subject to legal requirements and the need to conduct a thorough investigation.
  • Providing support and assistance, such as counselling or legal advice, to Whistleblowers who experience or fear retaliation.
  • Implementing disciplinary action, up to and including termination of employment or contract, against individuals found to have engaged in retaliation against a Whistleblower.
  • Offering alternative work arrangements or temporary reassignment, if necessary, to protect the Whistleblower from potential retaliation.

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.

DISCIPLINARY ACTION

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.

RECORD-KEEPING AND REPORTING

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:

  • The nature and details of the concern or misconduct reported;
  • The identities of the individuals involved, subject to confidentiality and anonymity requirements;
  • The investigation process, including the steps taken and the evidence gathered;
  • The final outcome of the investigation and any actions taken as a result.

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:

  • Implementing appropriate technical and organizational measures to protect the confidentiality and security of personal data;
  • Limiting access to records and personal data to authorized individuals on a need-to-know basis.

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:

  • The number of whistleblowing reports received;
  • The nature and types of concerns raised;
  • The outcomes of investigations and any actions taken;
  • Identified trends or patterns in whistleblowing reports;
  • Recommendations for improving the whistleblowing process.
  • Reports shall be submitted to the designated Whistleblower Officer – Leigh McLaughlin on management@wildthang.co.uk.

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.

TRAINING AND AWARENESS

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:

  • Ensuring that all employees and workers understand the purpose and importance of the Whistleblower Policy and Procedure.
  • Educating employees and workers on what constitutes a protected disclosure or reportable concern under this Policy.
  • Providing clear guidance on the reporting procedures and channels available for raising concerns.
  • Emphasizing the protections and safeguards in place for whistleblowers, including confidentiality and protection from retaliation.
  • Promoting a culture of transparency, accountability, and ethical conduct within the organization.

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:

  • In-person sessions.
  • Online modules.
  • Workshops.
  • A combination of the above methods.

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:

  • Presentations.
  • Handouts.
  • Case studies.
  • Scenario-based exercises.

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.

POLICY REVIEW AND UPDATES

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:

  • Evaluate the effectiveness of the Policy in achieving its objectives, including the number and nature of reports received, the handling of investigations, and the protection of whistleblowers from retaliation.
  • Assess compliance with applicable laws and regulations, such as the Public Interest Disclosure Act 1998 (PIDA) and the Employment Rights Act 1996, as well as any relevant updates or amendments.
  • Consider feedback and input from stakeholders, including employees, whistleblowers, and relevant authorities, regarding the Policy's implementation and potential areas for improvement.
  • Review any reported incidents or cases handled under the Policy to identify potential gaps or areas for enhancement.

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.