Policy & Implementation

Whistleblowing

1. Introduction

International Power (IPR) is committed to the highest standards of quality, honesty, openness and accountability.
As part of that commitment, IPR encourages employees or others with serious concerns about any aspect of work to come forward and express those concerns. We recognise that employees will need to come forward on a confidential basis. We want to make it clear that they can do so without fear of reprisal or victimisation.
This statement to our employees is intended to underline our commitment, and our support to those who come forward to express their concerns. Employees are often the first people who realise that there may be something seriously wrong within the organisation, but may not express their concerns. This could be for a number of reasons; because speaking up might be regarded as disloyal by colleagues or the organisation, because of fear that they may be victimised, doubts about reporting what might only be a suspicion, or because it might seem easier to ignore it and not get involved.
‘Whistleblowing’ is often understood as reporting a concern outside the organisation because, for various reasons, the employee does not wish or feel able to raise the matter internally. This Whistleblowing Policy aims to encourage and enable employees to raise serious concerns by ‘blowing the whistle’ within the company, rather than overlooking a problem or raising the issue outside.
When we find a problem, we will always deal with it seriously. We know that we cannot expect you to practise higher standards than those we apply.

2. Confidential Reporting

We know that it is never easy to report a concern, particularly one which may relate to fraud or corruption. We urge you to come forward with any concerns at an early stage, and before problems have a chance to become serious.
If you prefer, we are happy for you to come forward with another colleague, a friend, trades union representative or other advisor to report a concern.
We will support concerned employees and protect them from reprisals or victimisation. If you come forward with a concern, you can be confident that this will not affect your career, or your enjoyment of your job. This applies equally if you come forward in good faith with a concern which turns out later not to be justified.
We will do anything we can to respect your confidentially, if you have requested this.
If anyone tries to discourage you from coming forward to express a concern or suppresses information you have given them, we will treat this as a disciplinary offence. In the same way, we will deal with anyone who criticises or victimises you after a concern has been expressed.
The Company requires that you do not disclose confidential, false or misleading information. Whilst you should be aware of your duty of confidentiality, when taking a concern outside the Company it is recognised that, on occasion, it may be difficult to comply with.
The Public Interest Disclosure Act 1998 (which came into force in July 1999) gives legal protection to whistleblowers who honestly and reasonably believe that the information they disclose or the allegations they make are substantially true. The Act extends protection given to Health and Safety representatives to individuals who raise genuine concerns about health and safety or environmental risks.

3. Whom to Contact

In most cases, you should be able to raise your concerns with your immediate manager or his/her supervisor. If for some reason this is not possible, you should speak to Internal Audit, the head of Human Resources, the Company Secretary or an Executive Director and if necessary, you should ask for a confidential meeting. All such contacts should be treated in confidence.

4. The Company’s Response

If you come to us with a concern, we will look into it carefully and thoroughly. We have to be fair to you, but also to any other involved. If someone is potentially being accused of misconduct, we have to find out their side of the story as well. In our investigation, we will respect any concerns you have expressed about your own safety or career.
If you request, we will try to let you know the results of our investigation and about any action that is proposed. However, in doing this, we have to respect the confidentiality of other employees as well.
The action that will be taken by IPR will depend on the nature of the concern. The matters raised may be investigated by management, by internal enquiry or through the disciplinary process. Alternatively, they may be subject to independent enquiry. Relevant matters may also be subject to investigation by the police. However, in order to safeguard both IPR and individuals, initial enquiries will be made to determine whether the commitment of resources to any form of investigation would be appropriate. These initial enquiries would also assist in determining the most appropriate process for the consideration of the concern. Any necessary action that is required urgently would be carried out ahead of any assessment / investigation process.
Concerns or allegations raised which fall within the scope of established procedures will be referred for consideration under those procedures.
A referral of a concern will be acknowledged within 7 days, with an indication of how the Company proposes to deal with the matter and likely timescale. If it is not possible to complete the initial enquiries within the seven days, the letter of acknowledgement will explain. If a decision is made not to investigate, the reasons will be given.
Some matters may be investigated without the need for initial enquiries to be made. Similarly, some concerns may be capable of resolution by agreed action without the need for investigation.
The level of contact between you and whoever is considering the issues will depend on the nature of the matters raised, the potential difficulties involved as well as the clarity of the information provided. Further information may be sought from you.
The Company will take appropriate steps to minimise any difficulties that you may experience as a result of using the whistleblowing policy.
You will be given as much information as possible on the outcomes of the investigation, subject to the constraints of our duty of confidentiality to staff or Board members or any other legal constraint. The objective of the various responses would be to assure you that the matter has been addressed.
Abuse of the confidential reporting process, for instance by maliciously raising unfounded allegations, will be treated as a disciplinary matter. But no-one who comes forward in good faith has anything to fear.

5. Monitoring the Policy

Confidential records will be kept of all matters raised through the Whistleblowing Policy and the Board will receive reports with an assessment of the effectiveness of the policy and any emerging patterns.

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