Scope – Who This Policy Applies To
This policy applies to all employees, workers, contractors, agency staff, consultants, suppliers, clients, and any other external stakeholders who become aware of concerns relating to the Company’s activities.
External stakeholders are encouraged to raise any concerns in good faith where they reasonably believe wrongdoing, unsafe practices, unethical behaviour, or breaches of law or Company policy may have occurred.
The Company will treat all disclosures seriously and will ensure that concerns raised by both internal and external parties are handled confidentially, fairly, and without retaliation.
Responsibilities
Lodestone always aims to conduct ourselves with the highest standards of integrity and honesty at all times. Lodestone expects all workers to maintain the same standards in everything they do. This policy is not contractual but sets out the way in which we plan to manage such issues. All those who work for us are therefore strongly encouraged to report any perceived wrongdoing by the Company or its employees or contractors or agents that falls short of these principles.
The Public Interest Disclosure Act 1998 protects workers who report wrongdoing within the workplace. It is the aim of this policy to ensure that as far as possible employees are able to tell the Company about any wrongdoing at work which they believe has occurred or is likely to occur.
The Company recognise that employees may not always feel comfortable about discussing their concerns internally, especially if they believe that the business itself is responsible for the wrongdoing. The aim of this policy is to ensure that employees are confident that they can raise any concerns about the Company activities in the knowledge that it will be taken seriously, and that no action will be taken against them.
All of the employees are encouraged to use the procedure set out below if they have a concern about any of the following:
- Wrong doing at work, including any criminal offence.
- A failure to comply with legal obligations.
- A miscarriage of justice.
- A health and safety danger.
- An environmental risk; or
- A concealment of any of these.
Employees do not have to be able to prove the allegations, but should have a reasonable and genuine belief that the information being disclosed is true: some allegations may prove to be unfounded, but we would prefer the issue or concern to be raised, rather than run the risk of not detecting a problem early on.
If appropriate, the employee should discuss the matter with his/her Line Manager in the first instance. If the matter requires further investigation, this will be carried out and they will be informed of the outcome and what action, if any, has been taken.
At that point if they remain unhappy about the speed or conduct of the investigation or the way in which the matter has been resolved, they should refer the matter to Senior Management.
Following further investigation of the complaint, they will be informed of the result and what, if any, action has been taken. If they are unhappy with the Company's handling or the outcome of the investigation they may raise their concerns in writing under the Company's grievance procedure.
Lodestone undertakes that no employee who makes a bona fide report under this procedure will be subjected to any detriment as a result, in accordance with section 47B of the Employment Rights Act 1996.
Process, Timelines and Communication of Outcomes
All whistleblowing disclosures will be acknowledged within five working days of receipt.
An initial assessment will be conducted within ten working days to determine whether a formal investigation is required and to confirm next steps.
Where an investigation is initiated, the Company will aim to complete this within 30 working days, although complex matters may take longer. If additional time is required, the individual raising the concern will be informed of the revised timeline.
The individual will be kept informed at key stages of the process, including:
• Confirmation that the concern has been received
• Whether an investigation will proceed
• When the investigation has concluded
While full details of outcomes may not always be shared due to confidentiality or data protection obligations, the Company will confirm whether appropriate action has been taken.
All disclosures will be handled sensitively, and reasonable steps will be taken to protect the identity of the individual raising the concern where requested and legally possible.