Whistleblowing policy

We take our responsibilities to our employees and to the wider community very seriously. However, as in any business, we recognise that there’s always a risk of illegal or unethical malpractice taking place that we are unaware of. If something like this ever happens, we want to hear about it as quickly as possible so that we can put it right. If you have reason to believe that malpractice is taking place, please raise it in accordance with this policy.

What is whistleblowing?

Whistleblowing means to ‘speak up’ or raise a concern about suspected misconduct or illegal acts happening within our company or supply chain. The wrongdoing you disclose must be in the public interest, which means that it affects others. It could relate to any of the following:

  • Criminal offences
  • Danger to the health and safety of any individual
  • Damage to the environment
  • Miscarriages of justice
  • The company is breaking the law
  • You believe someone is covering up a wrongdoing relating to any of the above

For example, you could be reporting a concern about fraud, bribery, modern slavery, data protection breaches or the facilitation of tax evasion. It may be something that happened in the past, is happening now or that you believe will happen in the near future.

Personal grievances cannot be raised under our whistleblowing policy. If your concern relates to the way you are being treated as an individual, you should follow the grievance procedure in your employee handbook.

How to raise a concern

Please email blowthewhistle@key.co.com and explain your concerns – this mailbox can only be accessed by our Company Directors. Make it clear in your email that you are following our whistleblowing policy. Alternatively, please speak to the most senior member of staff that you feel comfortable approaching. All of our employees are expected to follow up on any issues of this nature that are raised to them and should escalate it to a more senior colleague without delay.

Provide all the information that you have, but remember it is not your job to investigate. To whistleblow, you simply need to have a reasonable belief that you are right about the concern you are raising. The most important thing is to report it quickly so that the company can take action as soon as possible.

You can report anonymously if you want, but we’d urge you not to do so. If we know who you are, we can protect you, ask you follow up questions to help with our investigation and keep you informed. If we don’t have all the information we need, in some cases we may be unable to investigate at all. Alternatively, you can give your name but still request confidentiality. You must clearly state if you don’t want anyone else to know it was you who raised the concern.

Your report and any personal data that you provide alongside it will be treated sensitively and handled in line with our privacy policy.

External support

If you would like external support, Protect can help. They are a charity that provides confidential advice for individuals who have witnessed wrongdoing in their workplace but are unsure how to raise their concerns. Citizens Advice and gov.uk also have more information on whistleblowing.

Instead of coming directly to us, you may choose to report your concerns to a prescribed body who deals with the issue you’re raising. You may also decide to get legal advice from a lawyer. Aside from this, in most cases you should not find it necessary to report your concerns to anyone else externally. We urge you to seek advice before doing so. Reporting to an external party e.g. the media will often mean that you lose the rights and protections that are provided for whistleblowers by law.

What will happen after I report?

We will listen to your concern carefully and decide what, if any, action is needed. This may involve an investigation and interviews with you and anyone who is suspected of being involved in the malpractice. Any investigation will be carried out in a manner that is as fair and proportionate as possible. We will contact you if we need any more information from you at any stage.

We will try to keep you informed, although we may be limited in how much information we can share.

If you requested that we keep your identity confidential, we will take all reasonable steps to do so. Your confidentiality would only be broken if it was necessary in order to allow for a thorough investigation or to deal with the malpractice. We will do our best to alert you before this happens.

If we discover that malpractice has taken place, anyone involved or responsible will be dealt with in accordance with our disciplinary policy. We will take whatever measures we deem necessary to stop the malpractice from occurring, prevent it from happening again and remedy any harm that has already been caused.

Protection for whistleblowers

We view whistleblowing as a positive act that helps us to uphold the highest ethical standards. We will welcome your report because it alerts us to potential wrongdoing that we would otherwise be unaware of and provides us with an opportunity to prevent further harm.

In addition, as a whistleblower and our employee, you are protected by the Public Interest Disclosure Act 1998. This law means that you won’t be treated unfairly or lose your job because you’ve blown the whistle.

You can expect other staff not to retaliate or react negatively against you in any way. Should they do so, this behaviour would be dealt with in line with our disciplinary policy.