Whistleblowing Policy & Procedure

All employees have a legal duty to act in good faith.

An important element in achieving and maintaining these qualities is a mechanism for enabling employees to raise concerns they may have about potential malpractice or wrongdoing, without fear of reprisals.

This policy sets out a framework to facilitate the reporting of concerns involving malpractice or impropriety, in confidence, which must be raised in good faith. It applies to all employees and also to any other individuals who work within Securitas including temporary staff, consultants and contractors. The policy extends to give legal protection to employees against being dismissed or penalised as a result of publicly disclosing concerns such as:

• Criminal activity, such as fraud, bribery, dishonesty, theft or embezzlement;
• Failures to comply with legal or statutory obligations;
• Miscarriages of justice;
• Endangering an individual’s health and safety;
• Environmental damage or pollution;
• Other improper conduct or unethical behaviour;
• Attempts to conceal any of the above.

It should be emphasised that this policy is intended to assist individuals who believe they have discovered malpractice or impropriety. It is not designed to question financial or business decisions taken by the Company nor does it substitute or replace the grievance procedures; nor is the policy a channel for employees to raise matters in relation to their terms and conditions of employment.

All concerns must be raised in good faith. Anyone who abuses the policy (for example by maliciously raising a concern they know to be untrue) will be subject to disciplinary action.

This policy will protect those who disclose malpractice or impropriety in good faith and will allow employees to have such concerns treated as confidential.

Employee Assurance

Employees who raise a genuine concern will not be at risk of damaging their employment position or working arrangements as a result. Provided you act in good faith, in the reasonable belief that there may be malpractice or impropriety, it does not matter whether or not your concern proves to be well founded.

You will not be penalised or victimisation for raising a genuine concern and anyone responsible for such conduct will be subject to disciplinary action.

Employees may decide that they want to raise a concern in confidence and ask for their identity to be protected. If that is the case, their details will not be disclosed without prior consent. If a situation arises where it is not possible to deal with the issues raised without revealing the individuals identity (for instance because the evidence is needed in court), there will be a discussion with the individual in advance of any steps taken.

This policy does not cover the situation where information about malpractice is received anonymously, but discretion will be used in the investigation of such information.

Responsibilities

• Employee

If an employee has concerns about malpractice or impropriety they are responsible for reporting this through the appropriate channels.

• Employer

Ensure that employees who raise concerns under this policy in good faith are not penalised or subject to any less favourable treatment as a result of raising their concerns.

Once a concern has been reported, Securitas will undertake an initial investigation and establish what action should be taken and how best to resolve matters. If the issues are better dealt with via another Securitas policy, this along with the process to be applied with be discussed with the employee.

Securitas will instigate appropriate enquiries and/or investigations, and will:

• Confirm who is handling the issues and how they can be contacted;
• Confirm if further assistance from the reporting individual is needed;
• Write confirming the concerns raised and outline how it is proposed to handle matters.

Reporting process

• Internal Notification

Employees can raise concerns with their Line Manager or the Area HR Business Partner in the first instance. If this is inappropriate (for example, the concern directly involves them), they can report the matter to the Director responsible for the business operation in which they work.

Through the available above channels, notifications may be made orally or in writing and must state the facts as clearly as possible, giving full details for those believed to be involved and the precise nature of the malpractice or impropriety. If the reporting employee has a direct personal interest in the matter, this must be declared at this stage.

When raising concerns, the employee must make it clear if they want to raise the matter in confidence so that appropriate steps can be taken.

On receipt of a complaint of malpractice or impropriety, the member of staff who receives the complaint must pass the information on to the HR Director as soon as reasonably possible.

• External Notification

If the employee believes none of the above notification channels are appropriate to report their concern or the allegation is of a serious or sensitive nature, or if a complaint is not resolved, it should be reported through one of the following channels of the Securitas Integrity Line:

• Website: www.securitasintegrity.com
• Telephone number: 0800 032 8483

The notification must state the facts as clearly as possible, giving full details for those believed to be involved and the precise nature of the malpractice or impropriety.

The Securitas Integrity Line is managed by an external company on behalf of Securitas.

A complaint outside of the Securitas Integrity Line may also be submitted to the Corporate Social Responsibility Manager for Securitas worldwide:

Email: integrity@securitas.com

In writing: Cecilia Alenius, Securitas Group CSR Officer, P.O. Box 12307, S- 102 28 Stockholm, Sweden.

Independent advice

Individuals who feel unsure about raising a concern or want confidential advice can contact the following organisations:

GMB Trade Union

They offer support and advice to Member’s free from any influence or recognition agreement they have with Securitas. GMB can be contacted on www.gmb.org.uk or on telephone number 0207 391 6700.

Public Concern at Work

This is an independent charity their lawyers can give free confidential advice on how to raise a concern.

They are not available as a conduit for reporting matters.

They can be contacted on 020 7404 6609 or e-mail on helpline@pcaw.co.uk 

Advice, Conciliation and Arbitration Service (ACAS)

Government supported advice and assistance provider who can provide free information may be contacted on 08457 474747.