1. Purpose of policy

Speak up – we will listen. Speaking up about any concern you have at work is really important. You may feel worried about raising a concern, and we understand this. But please don’t be put off. The aims of this policy are:

(a) To encourage staff to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate and that their confidentiality will be respected.

(b) To provide staff with guidance as to how to raise those concerns.

(c) To reassure staff that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.

2. Who Can Raise Concerns?

This policy applies to all workers of eEnergy, wherever they are doing business. This includes anyone who works with eEnergy. This includes temporary, fixed term or permanent employees, consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, apprentices, and work experience placements.

3. What is Whistleblowing?

Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include (but is not exhaustive):

  • Health and Safety
  • Bribery
  • Corruption
  • Fraud
  • Criminal wrongdoing
  • Contravention of environmental regulations
  • Breach of internal policies and procedures (including our Code of Conduct)
  • Racial harassment or discrimination
  • Sexual harassment or discrimination
  • Bullying
  • Drugs and/or alcohol in the workplace, and
  • Conduct likely to damage our reputation

If you have any genuine concerns related to suspected wrongdoing or danger affecting any of your activities, you should report it under this policy. This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work. In those cases, you should use the Grievance Policy or Equality, Inclusion and Diversity policy – both set out in the handbook as appropriate.

4. Feel Safe to Raise Your Concerns

If you raise a genuine concern under this policy, you will not be at risk of losing your job or suffering any form of reprisal as a result. We will not tolerate the harassment or victimisation of anyone raising a concern. Nor will we tolerate any attempt to bully you into not raising any such concern. Any such behaviour is a breach of our values as an organisation and, if upheld following investigation, could result in disciplinary action. Provided that you are acting honestly, it does not matter if you are mistaken or if there is an innocent explanation for your concerns.

5. Confidentiality

We hope you will feel comfortable raising your concerns openly, but we also appreciate that you may want to raise it confidentially. This means that while you are willing for your identity to be known to the person you report your concern to, you do not want anyone else to know your identity. We will make every effort to keep your identity secret. If it is necessary for anyone investigating your concern to know your identity, we will discuss this with you. You can choose to raise your concern anonymously, without giving anyone your name, although we do not encourage this, as it may make it more difficult to investigate thoroughly and give you feedback on the outcome.

6. Our Approach

We hope that in many cases, you will be able to raise any concerns with your line manager. They may be able to agree a way of resolving your concern quickly and effectively. However, where the matter is more serious, or you feel that your line manager has not addressed your concern, or you prefer not to raise it with them for any reason, you should contact one of the following:

(a) Our HR Manager

(b) Our Chief People Officer (CPO)

(c) Protect Whistleblowing Advice Line.

Contact details are set out at the end of this policy.

7. Investigation and Outcome

You can raise your concerns with any of the people listed above in person, by phone or in writing (including email). Whichever route you choose, please be ready to explain as fully as you can the information and circumstances that gave rise to your concern.

Whilst investigating the matter, you may be required to provide further information. Your co-operation after you have raised a matter is essential for the proper investigation of your concern. You may be required to attend an investigatory meeting as a witness. You may bring a colleague with you to help you explain the situation more clearly if you wish.

If a matter is raised anonymously, it will be investigated as far as it can be in accordance with this procedure. In some cases, we may appoint an investigator including staff with relevant experience of investigations or specialist knowledge of the subject matter. The investigator may make recommendations for change to enable us to minimise the risk of future wrongdoing.

We will aim to keep you informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent us giving you specific details of the investigation or any disciplinary action taken as a result. You should treat any information about the investigation as confidential.

If we conclude that a whistle-blower has made false allegations maliciously or with a view to personal gain, the whistle-blower will be subject to disciplinary action.

8. Appeals

If you are dissatisfied with the outcome of this procedure, you may raise the matter with the Chief Executive Officer, Harvey Sinclair. If you remain dissatisfied with the outcome you have the right to express your concerns to the relevant Prescribed Person designated by the Public Interest Disclosure (Prescribed Persons) Order 2014, or any statute or statutory instrument which subsequently supersedes this legislation.

9. Contact

[email protected]

You may make a disclosure to Protect (formerly Public Concern at Work), the leading authority on public interest whistleblowing if you consider that it has an interest in the matter and, despite the best efforts of the Company, you believe that disclosure within the Company is inappropriate or as noted previously has been unsuccessful. Disclosures made to legal advisors in the course of obtaining legal advice will be protected.