Whistleblowing policy

Whistleblowing

What does this policy cover and who is covered?

This policy covers all employees, volunteers, consultants and others associated with Global Canopy (GC).

It sets out what they should do if they have reason to believe that something dangerous, unlawful or unethical is going on at GC and it is affecting (or risks affecting) them, colleagues or the public. When you report these kinds of concerns, this is called whistleblowing.

Global Canopy is committed to operating at all times to the highest standards of integrity and openness. We pay special attention to creating an environment and culture where concerns can be easily raised and will be addressed. However, all organisations could be affected by conduct that is dangerous, against the law or breaches ethical or professional codes.

Please follow the procedure outlined below to report any concerns that you have about this kind of conduct, so that we can take the necessary action to address these concerns as quickly as possible.

This policy also covers the actions of third parties such as partners, suppliers and service providers, as well as our staff. If you are concerned about a third party, please also raise this with us before approaching anyone else.

We will always take your concerns seriously and they will be thoroughly investigated by appropriate personnel. Most importantly, you should feel confident to follow the procedure below. There will be no reprisals for individuals who bring these concerns to our attention – we value and respect all such reports and those who make them to us. We all play an important role in ensuring that our organisation and everyone working in and with it acts professionally, lawfully and appropriately.

What sorts of activities are typically considered relevant to whistleblowing?

This is not an exhaustive list, but the types of concerns you may want to raise with us by whistleblowing could include:

• An activity you suspect is criminal, puts health & safety at risk, might damage the environment or breaches bribery/corruption policies.
• A failure to comply with legal/regulatory obligations, professional requirements.
• An attempt to conceal one or more of these.

Protect – a charity that advises on whistleblowing

If you are concerned about a whistleblowing issue then it may be helpful to know about Protect. They operate a free, independent advice line for individuals who have concerns about whistleblowing.

Bullying or harassment

If your complaint is about the behaviour of others towards you, our bullying and harassment policy or grievance policy contain the relevant guidance on how to proceed. These types of behaviour are not covered by this whistleblowing policy.

Confidentiality and anonymity

You are encouraged to raise concerns openly, and we actively discourage anonymous whistleblowing. This is because it is not always easy to manage and to investigate anonymous reports, especially if we are unable to ask you for clarification of further details, we may struggle to find evidence to support your allegations and/or reach an informed conclusion. In these circumstances, we risk missing evidence or opportunities to gather important supporting information, or identify helpful witnesses, because we may be unaware of their existence, in spite of our best efforts to uncover them.

If you prefer to keep your identity anonymous, we will do all that we can to ensure that you retain your anonymity, and the confidentiality of your concerns, as far as possible. If we need to disclose your identity to others as part of the investigation, we will always discuss with you beforehand both our desire and our reasons for wishing to identify you.

We will protect you from reprisals.  You can read more about how we do this and what rights you have below.

Protection for whistleblowers

There are no reprisals for mistakes or if following our investigations, (which we will always conduct thoroughly and conscientiously), we conclude that there has been no breach of law, policy or unethical conduct.

When making a disclosure, you have legal protection from reprisal if, in your reasonable belief, one or more of the following events has, is or is likely to happen and that it is in the public interest to make the disclosure:

• A criminal offence
• Failure to comply with any legal obligation
• Miscarriage of justice
• Danger to health & safety of any individual
• Danger to the environment, or
• Deliberate concealment of any of the above.

If at any time, you do not feel that you have been fairly or properly treated by us in the handling of your whistleblowing concern, you must inform us immediately by contacting the HR team ([email protected]) in the first instance.

We also protect whistleblowers from others, so where a whistleblower reports to us that they have been treated inappropriately by others, (including having received threats as a result of raising their concerns), we will take disciplinary action against those individuals. The consequences of us taking this action could include dismissal of such individual(s) for gross misconduct. Whistleblowers may also be entitled to take legal action against those individuals.

Whistleblowing to others outside Global Canopy

Our policy covers the process for raising, investigating and resolving wrongdoing within GC’s work. We hope that these procedures ensure that, we are able to resolve any concerns raised and to protect you as part of this process. For these reasons, we anticipate that it would be rare, for you to involve anyone outside GC as part of this process.

However, we recognise that potentially, in exceptional circumstances, you might wish to involve an external body – an industry regulator, for example – and/or the independent charity Protect, who can direct you towards the appropriate regulator for the type of issue you want to raise.

Involving the press/media

Involving the media in a whistleblowing matter often has the effect of inflaming the situation, not assisting it. It can significantly hamper evidence gathering and the willingness of other relevant individuals to support the process.

We therefore strongly discourage you from involving the media. We reserve the right to treat any contact with the press as a serious disciplinary issue justifying dismissal unless exceptional circumstances exist. For example, we would generally expect you to have taken all reasonable steps to deal with the matter internally, or with an external regulator, and to have taken full advice from a lawyer or from Protect, before you could justify involving the press.

Our procedure for raising and dealing with a whistleblowing concern

Raising the concern and potential escalation

If you feel you have a whistleblowing concern, then the procedure to follow is:

1. First consider if other policies / procedures are more appropriate – grievance, capability, disciplinary, health and safety.
2. A good starting point is often to raise the concern with your line manager.
3. If the circumstances mean it’s not appropriate to raise a concern with your line manager, or they have not responded to escalate further – to a director, then the Executive Director – and also to the Chair of the board.
4. If you have exhausted these options and the issue remains unresolved, then a protected disclosure can be made to another relevant public body including: HM Revenue & Customs, the Financial Conduct Authority, the Competition and Markets Authority, the Health and Safety Executive, the Environment Agency, the Independent Police Complaints Commission and the Serious Fraud Office.

You may also find it helpful to speak to Protect – who can advise on whistle blowing situations.

Dealing with concerns

Once you have told us of your concern at whatever stage of this procedure, GC will look into it, and assess initially what action should be taken.

This may involve an internal enquiry or a more formal investigation. The organisation will inform you who is handling the matter, how they can be contacted and whether any further assistance may be needed from you. If you request it, GC will write to you summarising your concerns and setting out how we propose to resolve the situation, and confirming that you will be protected if the disclosure falls within the ‘qualifying disclosures’ covered in this policy.

While the purpose of this policy is to enable us to investigate possible malpractice and take appropriate steps to deal with it, GC will give you as much feedback as possible. If requested, GC will confirm our response in writing. Please note that it may not be possible to tell whistleblowers the precise action taken where this would break a duty of confidence owed by us to someone else.

Key points

If a concern later turns out not to be justified, but it was raised in good faith and without malice, the whistleblower can still expect support.

GC will ensure that the employment, promotion and development opportunities of staff, volunteers or consultants who raise concerns will not be affected.

Any member of staff who raises a concern that later turns out to be malicious or brought in bad faith may be disciplined under the Disciplinary Procedures.

Any colleague who tries to discourage another person from coming forward, or criticises or victimises them after voicing a concern, will be dealt with under the Disciplinary Procedures.

All parties involved in the disclosure will be protected from victimisation or retaliation, which in itself is a disciplinary offence.

Changes to our whistleblowing policy

We keep this whistleblowing policy under review and will place any updates on our website. This policy was last reviewed in March 2024.