You are here: Amoria Bond Home > Whistle-blowing Policy
This procedure outlines the process to follow for a Discloser when reporting a perceived wrongdoing within Amoria Bond Limited Group of Companies, including something they believe goes against the core values of PROFES and the Amoria Bond Group of Companies Code of Conduct. These include the principles of; integrity, objectivity, accountability, openness, honesty, leadership and impartiality.
Amoria Bond is committed to creating a work environment with the highest possible standards of openness, probity and accountability. In view of this commitment, we encourage Disclosers with serious concerns about the work of Amoria Bond to come forward and voice their concerns without fear of reprisal. Disclosers should note that where the concern is one that might fall under Amoria Bond’s staff or work force policies on equality and diversity or harassment and bullying or other staff policies, they should consider using the reporting mechanisms for those other policies first. If a member of the public or third party believes that their complaint fits the description of a ‘attributable concern’, they may report their concerns through the whistleblowing policy procedure.
Amoria Bond acknowledges that Disclosers may often be the first people to realise that there may be something seriously wrong within the organisation.
This policy aims to:
What is an attributable concern?
If a Discloser is asked to do something, or is aware of the actions of another, which they consider to be wrongdoing, they can raise it using this procedure. The Discloser must have a reasonable belief that raising the concern is in the public interest.
A Discloser may decide to raise a concern under the whistle-blowing policy if they are aware of a situation that they feel:
• is against Amoria Bond’s procedures and protocols as set out in its code of conduct;
• falls below established standards of practice Amoria Bond subscribes to;
• amounts to improper conduct; or
• is an abuse of power for personal gain.
The types of matters regarded as a attributable concern for the purpose of this procedure include, but are not limited to, the following:
• Fraud or financial irregularity;
• Corruption, bribery or blackmail;
• Other Criminal offences;
• Failure to comply with a legal or regulatory duty or obligation;
• Miscarriage of justice;
• Endangering the health or safety of any individual;
• Endangering the environment;
• Improper use of authority; and
• Concealment of any of the above.
Disclosers should not raise malicious or vexatious concerns, nor should they raise knowingly untrue concerns. In addition, this procedure should not be used to raise concerns of a HR/personal nature, such as, complaints relating to a management decision or terms and conditions of employment. These matters should be dealt with using the relevant alternative procedure, equally, this policy would not apply to matters of individual conscience where there is no suggestion of wrongdoing by Amoria Bond but, for example, an employee or Amoria Bond Board Member is required to act in a way which conflicts with a deeply held personal belief.
The Public Interest Disclosure Act (1999) gives legal protection to employees against being dismissed or penalised by their employers as a result of publicly disclosing certain serious concerns. Amoria Bond believes that no member of staff should be at a disadvantage because they raise a legitimate concern. Amoria Bond will not tolerate harassment or victimisation and will take action to protect Disclosers when they raise a concern in the public interest.
Raising a concern
If a Discloser experiences something in the workplace which they consider an attributable concern, it is important that the concern is raised as early as possible. Proof is not required at this point – it is for Amoria Bond to investigate. The Discloser must, however, have a reasonable belief that disclosing the information is in the public interest before raising a concern.
All concerns will be treated in confidence and every effort will be made to protect the Discloser’s identity if they wish to remain anonymous. However, at the appropriate time, it is possible that the Discloser will need to come forward as a witness for the matter to progress.
It is important to follow the correct procedure when raising a whistle-blowing concern. The following steps should be adhered to:
a. It is important that the concern is raised with the person best placed to deal with the matter, in most cases this will be the Designated Officer. However, the Discloser may want to raise the concern with someone they know and trust, such as their line manager who can raise it with the Designated Officer on their behalf.
b. If it is suspected that the concern may implicate the line manager in some way, then it could be raised with a more senior manager in the line management chain.
c. If the Discloser is unable to raise an attributable concern with a line manager or a senior manager or feel that it has not been adequately addressed, it should be raised directly with the Designated Officer.
d. Ultimately, the Discloser can raise their concern with Amoria Bond’s Group Managing Director.
Information needed to raise a concern
When raising a concern under the procedure, the Discloser should try to provide the following information:
• The background and reason behind the concern;
• Whether they have already raised a concern with anyone and the response; and
• Any relevant dates when actions related to the concern took place.
This information should demonstrate that there are reasonable grounds for the concern to be acted upon. It is important that matters are not investigated by the Discloser themselves. If applicable, personal interests must be declared from the outset.
How the concern will be handled
All investigations will be conducted sensitively and as quickly as possible. While Amoria Bond cannot guarantee that the outcome will be as the Discloser may wish, it will handle the matter fairly and in accordance with this procedure. Once a concern has been raised with either the line manager or Designated Officer, Senior Manager or Group Managing Director, a meeting may be arranged with them to determine how the concern should be taken forward.
Amoria Bond may decide to take the matter forward by a number of methods, including:
• An internal inquiry or other formal investigation;
• An internal or external audit;
• Referring the matter to the police;
• Referring the matter to another relevant authority for investigation.
Before a final decision is taken on how to proceed, or as part of the investigation, the Discloser may be asked to meet with those investigating their allegation. If a meeting is arranged, the Discloser may wish to be accompanied by a trade union representative, colleague or friend. The person who accompanies the Discloser should not be involved or have a direct interest in the area of work to which the concern relates. The meeting can be conducted over the telephone rather than face to face.
Within 10 clear working days of a concern being raised, Amoria Bond’s Designated Officer will write to the Discloser to:
• Acknowledge that the concern has been received;
• Indicate how they propose to deal with the matter;
• Give an estimate of how long it will take to provide a final response;
• Tell the Discloser whether any initial investigation or enquiry has been made;
• Tell the Discloser whether further investigation will be made, and if not, why not;
• Tell the Discloser how frequently Amoria Bond will keep them up to date on progress of the investigation.
The amount of contact between Amoria Bond and the Discloser concerned will vary depending on the concern raised, any difficult issues and any further clarity required. If necessary, Amoria Bond will seek further information from the Discloser.
Amoria Bond will confirm when the matter is concluded and, if appropriate, the outcome of the investigation, maintaining security and confidentiality for all parties as far as possible.
Throughout any investigation, the Discloser will still be expected to continue their duties/role as normal unless deemed inappropriate.
Confidentiality and anonymity
Amoria Bond always encourages potential Disclosers to speak up about potential serious wrongdoing in a way that they feel comfortable. The best way to raise a concern is to do so openly, as this makes it easier for Amoria Bond to investigate and provide feedback.
Amoria Bond will respect any request for confidentiality as far as possible, restricting it to a ‘need to know’ basis. However, if the situation arises where it is not possible to resolve the concern without revealing the Discloser (for example in matters of criminal law), Amoria Bond will advise them before proceeding. The same considerations of confidentiality should be afforded to the recipient(s) at the centre of the concern, as far as appropriate.
Disclosers may choose to raise concerns anonymously, i.e. without providing their name at all. If this is the case, the investigation itself may serve to reveal the source of information. Disclosers are therefore encouraged, where possible to put their names to concerns raised. When anonymous concerns are raised, they will be treated as credible and investigated so far as possible.
If a concern is raised in the reasonable belief that it is in the public interest and procedures have been followed correctly, the Discloser raising the concern will be protected by the terms of this policy and, where applicable, by whistle-blowing legislation (see www.gov.uk for more information on who is covered by whistle-blowing legislation). Where a Discloser has been victimised for raising a concern, Amoria Bond concerned will take appropriate action against those responsible, in line with Amoria Bond’s disciplinary policy and procedures.
If a Discloser makes an allegation but it is not confirmed by the investigation, no action will be taken against them. However, if a malicious or vexatious allegation is made without good reason to: cause trouble; for personal gain; or to discredit Amoria Bond an investigation may take place. Where the Discloser is an employee or an Amoria Bond Board Member or a contractor this may result in disciplinary or other action if they have broken the terms of their employment, acted against Amoria Bond Code of Conduct or broken a clause in a contract.
In addition, if you are either unable to raise the matter with Amoria Bond or you are dissatisfied with the action taken you may consider raising it with:
• The police;
• The relevant regulatory body or professional body;
• Your Trade Union;
• Your solicitor;
• Your Citizens Advice Bureau.
Further information and signposting for potential Disclosers is available on www.gov.uk.
If a Discloser does take the matter outside Amoria Bond, to an external body, they should ensure they do not disclose information that is confidential, for example, if you are an employee your contract of employment may set out expectations of your regarding what is confidential.
This policy will be communicated to all employees across the Group, as well as to our suppliers, contractors and business partners and wider stakeholders. Employees are encouraged to raise concerns about any instance of malpractice at the earliest possible stage through the procedures set out in this “Whistle Blowing Policy”.
+31 (0) 20 80 80 888
1016 EV Amsterdam,
+49 (0) 221 845 6110
+44 (0) 161 448 8881
14 Egerton House,
Towers Business Park,
Manchester M20 2DX,
+65 6672 9400
One George Street, #16-01,