The objective of this policy is to implement a well-defined procedure for employees who wish to report valid concerns about malpractice or impropriety in the workplace and are unable to do so through established procedures or communications channels. This policy should not be regarded as a means to circumvent established procedures or communications channels.
If in doubt – raise it! This applies to you whether you are a permanent employee, an agency or temporary staff member, an intern or a volunteer.
SCOPE OF POLICY
- This policy covers raising concerns about wrongdoing in the workplace by managers, employees, contractors, agency staff, interns, volunteers and anyone else engaged to work at ALBAIT.
- The policy covers raising concerns about alleged wrongdoing in the workplace and in any work-related setting outside the workplace e.g. business trips and work-related social events.
1- Reportable Conduct The following list, which is not exhaustive, gives examples of reportable malpractice or impropriety:
- Malpractice of care.
- Poor quality care/negligence.
- Fraudulent completion of claim forms, records, medical notes, performance monitoring data.
- Forgery or alteration of any cheque, bank draft or any other financial or other document belonging or relating to ALBAIT.
- Misappropriation of funds, supplies, or other assets.
- Impropriety in the handling or reporting of money or financial transactions.
- Profiteering as a result of insider knowledge of ALBAIT activities.
- Disclosing confidential or proprietary information to outside parties.
- Accepting or seeking anything of material value from contractors, vendors or persons providing services/materials to ALBAIT.
- Destruction, removal or inappropriate use of records, furniture, fixtures, and equipment.
- Any other financial malpractice, impropriety or fraud.
- Failure to comply with laws and regulations.
- Criminal activity.
- Improper conduct or unethical behaviour.
- Breach of contract.
- Danger to health and safety.
- Damage to the environment.
- Unofficial approach to the Media.
- Attempts to conceal any of the above.
- The employee acknowledges that in the course of the Appointment, he/she will have access to Confidential Information.
- The employee shall not (except in the proper course of the Employee’s duties), either during the Appointment or at any time after its termination (howsoever arising), use or disclose to any person, company or other organization whatsoever (and shall use best endeavours to prevent the publication or disclosure of) any Confidential Information. This shall not apply to:
– any use or disclosure authorized by the Company or required by law; or
– any information which is already in, or comes into, the public domain other than through the Employee’s unauthorized disclosure.
3- Protection of the Whistle-blower
- ALBAIT shall maintain the confidentiality of the person making the report to the fullest extent reasonably practicable within the legitimate needs of law and any ensuing evaluation or investigation.
- The identity of the Employee making the allegation will be kept confidential and confined to the Investigating Committee so long as it does not hinder or frustrate any investigation.
- The investigation process may reveal the source of the information to persons involved in the investigation or resolution of the investigation report. The Employee making the report may need to provide a statement as part of the evidence required.
1- Reporting Procedure
- It is essential that the subject of any such message be shown as ‘Whistle Blowing’. The report should include the reporting employee’s name.
- Employees who make a report shall do so only:
a) In good faith;
b) In the reasonable belief that the reportable issue tends to show malpractice; or impropriety; and
c) After having acquired appropriate, though not necessarily complete, supporting detail and evidence.
d) Employees who make a report must not:
- Contact the suspected individual in an effort to determine facts or demand restitution; or
- Discuss the case, facts, suspicions or allegations with anyone except the Investigating Committee or unless specifically asked to do so by it.
2- Investigation Procedure
- The Investigation Committee will be appointed by the CEO or, in a case where the CEO is the subject of the report, the Chairman of the Board. The Investigating Committee will consider the information made available to them and decide on:
– The person who will lead the investigation;
– The procedure(s) to be followed; and
– The scope of the concluding report.
- Any investigation will be conducted as sensitively and speedily as possible. The investigation will include but not be limited to the following steps:
– Full details of the allegation will be obtained;
– The allegation will be fully investigated; and
– The person who made the report will be informed of the outcome of the investigation, in due course and as appropriate, of any action taken.
- At the appropriate time (subject to the progress and status of the investigation) the person against whom a report is made will be informed of it. He will be allowed to comment and make a rebuttal to the findings before the Investigating Committee before any investigation is concluded.
- In some instances it may be necessary to refer the matter to an external authority for further investigation, particularly in cases alleging misuse of funds.
This Whistle Blowing Policy is designed to maintain the high standards of integrity and reputation of ALBAIT and has been implemented to assure employees who, acting in accordance with this policy, make reports in good faith of malpractice or impropriety in the workplace that they will not be dismissed, victimized or discriminated against as a result of the making of such report.