The Seetec Group is one of the UK and Ireland’s leading public and business services providers. Our core purpose is to improve people’s lives through the services we provide. We’re a for-profit employee owned trust company that embeds social value into everything we do. Through people, technology and assets we help public, private and third sector organisations transform their business in a diverse range of sectors including skills, employment, justice, health and wellbeing. Putting customers and service users at the heart of what we do, we enable individuals, communities and businesses to thrive. We support and empower people to achieve in a variety of ways, from apprenticeships, training and employment, to making lifestyle changes or choosing a crime-free life. Collaborating with a diverse range of partners, and through investment in our people, we deliver long-term value for money that achieve outcomes for organisations, and the people we serve.
This policy is applicable to Seetec in its entirety, which includes all Corporate Service functions and business streams including all Seetec legal and trading entities.
The Seetec Group Whistleblowing Policy and associated procedures apply to all parts of Seetec Group and includes all European Social Fund contracts. Please see Appendix B
2.0 Policy Aims
Key Definitions (as defined by The Department for Business Innovation and Skills):
“Whistleblowing” means; the term used when a worker passes on information concerning wrongdoing: “making a disclosure” or “blowing the whistle”. The wrongdoing will typically (although not necessarily) be something they have witnessed at work.
“Whistleblower” means: An individual who makes a Whistleblowing disclosure.
Whistleblowing is viewed by Seetec as a positive act that can make a valuable contribution to Seetec’s business. It is important that our staff feel able to raise concerns. Seetec is committed to achieving the highest possible standards of service and the highest possible ethical standards in all of its’ practices.
It is important to Seetec that individuals can raise concerns about wrongdoing or malpractice within our group of companies without fear of victimisation, subsequent discrimination or any form of disadvantage.
This Whistleblowing Policy provides a framework of protection for individuals who disclose information to expose risk, misconduct, malpractice, wrongdoing and matters of similar concern. In short it protects Whistleblowers from victimisation and dismissal.
Therefore, this Policy aims to:
- encourage individuals to feel confident in raising serious concerns at the earliest opportunity and to question and act upon concerns about practice
- provide avenues for individuals to raise concerns and receive feedback on any action taken
- ensure that such individuals receive a response to their concerns and that they are made aware of how to pursue them if they are not satisfied
- reassure individuals that they will be protected from possible reprisals or victimisation if they have made any disclosure in good faith.
3.0 Principles of the Policy
This Policy is intended to enable those individuals connected with Seetec, who become aware of a potential wrongdoing to report their concerns in confidential and supported manner so that any such matter can be objectively and confidentially investigated.
The Whistleblowing Policy sits alongside other Seetec policies and is not intended to replace other existing policies or procedures.
If a concern relates to an individual’s own treatment as a colleague, it should be raised in accordance with the Seetec Group Grievance Policy and Procedure.
If a Seetec client (those who receive the services of Seetec) has a concern about the services provided to them, then any such concerns or issues should be raised in accordance with the Seetec Group Compliments and Complaints Policy.
Any disclosure made by an individual in relation to this Whistleblowing Policy should be made under the process set out in Appendix A.
A Whistleblower is protected by the law via the Public Interest Disclosure Act 1998 and the Republic of Ireland’s Protected Disclosures Act 2014. These laws provide protection for those who voice genuine and legitimate concerns and provide protection for Seetec’s colleagues and others against false, vexatious and malicious accusations. Any Whistleblower will not be treated unfairly or be disadvantaged in any way if they make a disclosure.
Under the above Disclosure Acts, a worker who makes a disclosure must reasonably believe two things;
- That they are acting in the public interest.
- That a worker must reasonably believe that the disclosure tends to show past, present or likely future wrongdoing.
The categories of wrongdoing referenced above can include (but are not limited to):
- A criminal offence that has been committed or is likely to be committed
- Non-compliance with company policies which could result in loss to the company
- Undue favor being granted to another party with whom Seetec does business
- A failure to comply with legal / regulatory obligations
- A miscarriage of justice
- Actions which endanger health and safety
- Actions which could cause damage to the environment
- Actions which are fraudulent, corrupt or involve potential or suspected bribery (see Anti-Bribery, Corruption and Fraud Policy)
- Bullying of an individual or a bullying culture across a team (or across the organisation) which an individual feels unable to be raise through other channels
- Concerns about a member of staff’s conduct towards vulnerable people (for example, a child or an adult with care and support needs), whist carrying out their work
- Information that suggests a colleague, sub-contractor, agency worker or volunteer is unsuitable to work with children or vulnerable adults
- Belief that senior managers and the designated safeguarding lead have failed to take appropriate action in response to safeguarding concerns
- An attempt to cover up any of the above
The process for making a disclosure / whistleblowing is attached at Appendix A to this Policy.
All Seetec Group colleagues; Adherence to this policy and law
Line Managers; Ensuring awareness and compliance of colleagues with this policy
Seetec Group Executive Board: Responsible for overall management / conduct against this policy, review, dissemination and approval of policy.
Appendix A: Whistleblowing Process
1. Principles of Confidential Reporting
1.1 We know that it is never easy to report a concern, particularly one that may relate to fraud, bribery or corruption. However, it is of vital importance to our business that any individual can come forward with any concerns at an early stage and before problems have a chance to become serious. In certain parts of the business, an individual may also have a professional duty to report a concern.
1.2 An individual may invite a work colleague, or trade union representative, to be present during any meeting(s) or interviews in connection with the concerns raised.
1.3 We will support all colleagues who have a legitimate concern and protect them from reprisals or victimisation. If an individual comes forward with a concern, they can be confident that this will not affect their career or enjoyment of their job.
1.4 We will take all reasonable steps to respect and protect an individuals’ confidentiality. Any individual can raise concerns anonymously. There may be instances were allegations are made relating to the conduct of a colleague, sub-contractor, agency worker or volunteer, in connection with a child, young person or an adult with care and support needs, where it is assessed as necessary that Seetec notify the designated Safeguarding Officer of the allegations.
1.5 If anyone tries to discourage an individual from coming forward to express a legitimate concern, this will treat this as a disciplinary offence. Should anyone criticise or victimise an individual after a concern has been expressed, this will also be dealt with this under our disciplinary procedure.
2. Disclosure Process:
2.1 Internal Disclosures
2.1.1 If a disclosure is to be made, the individual should, if appropriate, approach their line manager and explain what is causing their concern for the public interest. It is important that (when raising any such disclosure) that an individual should try to capture their concerns in as objective a manner as possible with clear examples of evidence so that the issue can be addressed as efficiently and effectively as possible. If you believe that your line manager or more senior members of staff are the subject of the disclosure, then 2.1.2 should be followed.
2.1.2 In the event that any disclosure by an individual relates to the line manager or senior members of staff, then the disclosure should be made to Executive Director for Commercial and Corporate Governance (acting as the Designated Officer for Seetec Group) in order to begin the process of investigation. Alternatively, should your concern relate to that person, then the Group HR Director can be contacted, and they will manage any investigation.
2.1.3 Whilst we would always encourage you to report any concerns internally in the first instance, in addition, or alternatively, in the UK you can also approach Protect, an independent organisation, for confidential and independent advice at: Protect, https://protect-advice.org.uk/ 020 3117 2520, The Green House, 244-254 Cambridge Heath Road, London E2 9DA.
There is no equivalent body in the Republic of Ireland.
Where a disclosure is received by a colleague from an external source, details should be reported immediately to the Executive Director for Commercial and Corporate Governance and / or the Executive Director of the business to which the disclosure relates.
3. Seetec’s Response
3.1 If a colleague makes a disclosure, Seetec will investigate it carefully and thoroughly. Only those with a need to know will be notified of the disclosure. However, a high-level report may be produced at the Seetec Group Executive Board level which highlights the areas any disclosure concerns and actions to be taken but not disclosing the details of the discloser unless it is necessary as part of any investigation / action to be taken. We have to be fair to our colleagues, but also to any others involved; If an individual is potentially being accused of misconduct, we have to understand their side of the story as well, without disclosing a disclosers details / identity. In any investigation, we will take into account and respect any concerns the disclosing party may express regarding their safety or career.
3.2 A referral of a concern will be acknowledged within seven business days, with an indication of how Seetec proposes to proceed with the matter and an indicative timescale.
3.3 If it is not possible to complete the initial enquiries within seven business days, then Seetec will explain why and what the next steps are.
3.4 If a decision is made not to investigate, then clear reasons will be stated and given to the disclosing party for such.
3.5 If the disclosing party requests it, Seetec will, if reasonably possible, let the disclosing party know the results of the investigation and any action that is proposed to be taken by Seetec. However, in doing this, Seetec must respect the confidentiality of other colleagues as well and ensure that any feedback provided does not breach any law in the jurisdiction the disclosure and investigation regards.
3.6 The action that will be taken by Seetec will depend on the nature of the concern and will be dealt with through the Seetec disciplinary process.
3.7 Should the investigation concern the actions of a third party related to Seetec such as a subcontractor or supply chain partner, then any actions to be taken will be governed by the legal remedies available under their contract and the applicable law in their jurisdiction.
3.8 Where the disclosure requires the engagement of a recognised third party such as the police, then Seetec will fully co-operate with their enquiries.
3.9 Concerns or allegations raised, which fall within the scope of established policies or procedures, will be referred for consideration under such.
Any individual who makes a disclosure will be given feedback on the outcome of any investigation conducted, subject to the constraints of Seetec’s duty of confidentiality to service users and colleagues or any other legal constraints.