EQUALITY AND DIVERSITY POLICY

Whistleblowing policy 

Making a disclosure in the public interest 

Introduction 

Murray McIntosh expects everyone working for the business to act honestly and responsibly. Anyone who becomes aware of suspected wrongdoing should feel able to raise it. This policy explains who to contact and how we will deal with concerns relating to our business and recruitment services. 

Concerns should be raised as soon as possible. No one should be dismissed, threatened, bullied or treated unfairly for making a protected disclosure. The legal protections are set out in the Employment Rights Act 1996, as amended by the Public Interest Disclosure Act 1998 and later legislation. This policy does not limit those rights or prevent lawful reporting outside Murray McIntosh. 

Scope of the policy 

This policy applies to employees, agency workers, temporary workers and contractors working for Murray McIntosh. Candidates, clients, suppliers and other parties may also raise concerns under this policy. Statutory whistleblowing protection depends on the individual’s legal status and the circumstances of the disclosure. Whistleblowing means reporting information that you reasonably believe shows wrongdoing and that it is in the public interest to report. The wrongdoing may have happened already, be happening now or be likely to happen. 

Examples include: 

·  Criminal offences, fraud, bribery or financial malpractice. 

·  Failure to comply with a legal obligation, including unlawful recruitment practices, illegal working, exploitation or misuse of candidate and client information. 

·   A miscarriage of justice. 

·   Danger to health and safety or damage to the environment. 

·   Deliberate concealment of any of the above. 

Personal employment complaints should normally be raised through the grievance procedure. A concern may nevertheless qualify as whistleblowing where it also meets the public interest test. Concerns must not be rejected merely because they overlap with a grievance or another company procedure.   

Protection and confidentiality

You do not need to prove that wrongdoing has occurred before reporting it. If you reasonably believe there is a problem, you should raise it. You will not be penalised simply because the investigation does not support your concern. A protected disclosure does not lose its protection just because you did not follow this procedure. 

Knowingly providing false information may lead to disciplinary action following a fair investigation. An unsubstantiated concern, disagreement with findings or repeated reporting does not by itself establish that a report was knowingly false. 

We will handle concerns discreetly and share information only with those who need it to investigate or deal with the matter, or where the law requires it. We will try to protect your identity, although this cannot always be guaranteed. Where possible, we will speak to you before your identity needs to be disclosed. 

Anonymous concerns 

You can raise a concern anonymously. We will consider how serious it is, what evidence is available and whether the information can be checked. Giving your name and a safe way to contact you will usually help us investigate and keep you informed. We will not dismiss a concern just because it is anonymous. 

How to raise a concern 

Tell your line manager or a Director, either verbally or in writing. If you do not feel comfortable speaking to your line manager, go directly to a Director. Explain what has happened, when it happened and who was involved. Provide any information you already have, but do not obtain evidence unlawfully or put anyone at risk. 

If your concern involves the person you would normally report to, speak to another Director who is not involved. If there is no suitable person within the business, or you do not feel able to report internally, you can seek independent advice or use an appropriate lawful external reporting route. The person receiving the disclosure must pass it promptly and confidentially to a Director who is not implicated. That Director will appoint an investigating officer with no conflict of interest. An independent investigator may be appointed where necessary. 

External reporting and advice 

Internal reporting is encouraged, but is not a precondition for every protected external disclosure. Workers may obtain legal advice or report to an appropriate prescribed person or body, subject to the applicable legal conditions. The correct recipient depends on the concern, for example the Health and Safety Executive, Information Commissioner’s Office or Environment Agency where the matter falls within their remit. 

The current list is available at www.gov.uk/government/publications/blowing-the-whistle-list-of-prescribed-people-and-bodies--2. Independent confidential advice is available from Protect at protect-advice.org.uk. Wider disclosures, including to the media, are subject to stricter legal conditions; seek advice before taking that route.

Acknowledgement and timescales 

The person handling the investigation will acknowledge your concern as soon as reasonably practicable and explain the next steps. The time needed will depend on the issue. We will deal with it promptly while allowing enough time for a fair and thorough investigation. 

We will agree a safe way to contact you and keep you informed of progress. Where possible, we will tell you when we expect to finish. We will explain the outcome and any action taken as far as we can, while respecting other people’s confidentiality and data protection rights. Investigation procedure 

·   Obtain and record the details of the concern and clarify any missing information. Assess any immediate risks and take necessary protective action. 

·   Check for conflicts of interest, preserve relevant records and decide who should investigate. Consider whether external specialists, auditors, regulators or the police should be involved. 

·   Gather evidence fairly and give relevant people an opportunity to respond. Inform the person concerned when appropriate, provided this does not compromise evidence, safety or an external investigation. 

·   Where disciplinary proceedings follow, use the relevant company procedure and applicable rights to be accompanied. 

·   Prepare a written report setting out evidence, findings, reasons and recommended actions. Submit it to a Director who is not implicated. 

·   The responsible Director will decide and record appropriate corrective, disciplinary or other action, including changes to recruitment processes and controls where needed. 

·   Provide appropriate feedback, check for retaliation and monitor completion of actions. 

Where there is evidence of criminal activity, the responsible Director will consider reporting to the police and obtain advice where necessary. Internal enquiries must not obstruct a police or regulatory investigation. 

If the person remains concerned

If you believe your concern has not been properly dealt with, you can ask another Director who has not been involved to review it, where one is available. You can also seek independent advice. You do not have to use every internal reporting route before making a lawful external disclosure. 

Records and policy review

Records of concerns, investigations and actions must be kept securely and accessed only by authorised people. They must be retained in line with the company’s data protection and retention arrangements. Directors will review this policy periodically and when changes in the law or issues within the business make a review necessary.   

Approved by: Adam Cave        Position: Director         Date: 07/07/2026                     Review: 07/07/27