Vault UK Group provides the means of reporting by employees of suspected misconduct, illegal acts or failure to act within the Group
The aim of this Statement is to encourage employees and others who have serious concerns about any aspect of the Group’s or any of its subsidiaries work to come forward and voice those concerns.
Employees are often the first to realise that there may be something seriously wrong internally. ‘Whistleblowing’ is viewed by Vault UK Group as a positive act that can make a valuable contribution to Vault UK Group's efficiency and long-term success. It is not disloyal to colleagues to speak up. Vault UK Group is committed to achieving the highest possible standards of service and the highest possible ethical standards in all of its practices. To help achieve these standards it encourages freedom of speech.
If you are considering raising a concern you should read this Statement first. It explains:
the type of issues that can be raised
how the person raising a concern will be protected from victimisation and harassment
how to raise a concern, and
what Vault UK Group will do.
2. What is the aim of the Statement and when does it apply?
2.1. Aims of the Statement
This Statement is designed to ensure that you can raise your concerns about wrongdoing or malpractice within Vault UK Group without fear of victimisation, subsequent discrimination, disadvantage or dismissal.
It is also intended to encourage and enable you to raise serious concerns within Vault UK Group rather than ignoring a problem or 'blowing the whistle' outside.
This Statement aims to:
encourage you to feel confident in raising serious concerns at the earliest opportunity and to question and act upon concerns about practice
provide avenues for you to raise those concerns and receive feedback on any action taken
ensure that you receive a response to your concerns and that you are aware of how to pursue them if you are not satisfied
reassure you that you will be protected from possible reprisals or victimisation if you have made any disclosure in good faith.
2.2. Scope of this Statement
This Statement is intended to enable those who become aware of wrongdoing in Vault UK Group and/or its subsidiaries affecting some other person or service, to report their concerns at the earliest opportunity so that they can be properly investigated.
The Whistleblowing process is not intended to replace existing procedures:
If your concern relates to your own treatment as an employee, you should raise it under the existing grievance or harassment procedures
If a client has a concern about services provided to him/her, it should be raised as a complaint to Vault UK Group
2.3. Who can raise a concern?
The Statement applies to all:
employees of Vault UK Group Ltd or any of its subsidiaries
employees of contractors working for Vault UK Group, for example, agency staff
employees of suppliers
those providing services under a contract or other agreement with Vault UK Group
2.4. What should be reported?
Any serious concerns that you have about service provision or the conduct of personnel or others acting on behalf of Vault UK Group that:
make you feel uncomfortable in terms of known standards;
are not in keeping with Vault UK Group policies;
fall below established standards of practice; or
are improper behaviour.
These might relate to:
conduct which is an offence or a breach of the law (a criminal offence has been committed or failing to comply with any other legal obligation)
disclosures related to miscarriages of justice
racial, sexual, disability or other discrimination
health and safety of the public and/or other employees
damage to the environment
unauthorised use of public funds or other assets
possible fraud and corruption
neglect or abuse of clients, or
other unethical conduct.
This list is not exhaustive.
3. Protecting the Whistleblower
3.1. Your legal rights
This policy has been written to take account of the Public Interest Disclosure Act 1998 which protects workers making disclosures about certain matters of concern, when those disclosures are made in accordance with the Act’s provisions and in the public interest.
The Act makes it unlawful for Vault UK Group to dismiss anyone or allow them to be victimised on the basis that they have made an appropriate lawful disclosure in accordance with the Act.
Rarely, a case might arise where it is the employee that has participated in the action causing concern. In such a case it is in the employee’s interest to come into the open as soon as possible. Vault UK Group cannot promise not to act against such an employee, but the fact that they came forward may be taken into account.
3.2. Harassment or Victimisation
Vault UK Group is committed to good practice and high standards and to being supportive of you as an employee.
Vault UK Group recognises that the decision to report a concern can be a difficult one to make. If you honestly and reasonably believe what you are saying is true, you should have nothing to fear because you will be doing your duty to your employer, your colleagues and those for whom you are providing a service.
Vault UK Group will not tolerate any harassment or victimisation of a whistleblower (including informal pressures) and will take appropriate action to protect you when you raise a concern in good faith and will treat this as a serious disciplinary offence which will be dealt with under the disciplinary rules and procedure.
3.3. Support to you
Throughout this process:
you will be given full support from senior management
your concerns will be taken seriously, and
Vault UK Group will do all it can to help you throughout the investigation
If appropriate, Vault UK Group will consider temporarily re-deploying you for the period of the investigation.
For those who are not Vault UK Group employees, Vault UK Group will endeavour to provide appropriate advice and support wherever possible.
All concerns will be treated in confidence and every effort will be made not to reveal your identity if that is your wish. If disciplinary or other proceedings follow the investigation, it may not be possible to take action as a result of your disclosure without your help, so you may be asked to come forward as a witness. If you agree to this, you will be offered advice and support.
3.5. Anonymous Allegations
This Statement encourages you to put your name to your allegation whenever possible. If you do not tell us who you are it will be much more difficult for us to protect your position or to give you feedback. This Statement is not ideally suited to concerns raised anonymously.
Concerns expressed anonymously are much less powerful but they may be considered at the discretion of Vault UK Group. In exercising this discretion the factors to be taken into account would include:
the seriousness of the issue raised
the credibility of the concern, and
the likelihood of confirming the allegation from other sources
3.6. Untrue Allegations
If you make an allegation in good faith and reasonably believing it to be true, but it is not confirmed by the investigation, Vault UK Group will recognise your concern and you have nothing to fear. If however, you make an allegation frivolously, maliciously or for personal gain, appropriate action that could include disciplinary action, may be taken.
4. Raising a Concern
4.1. Who should you raise your concern with?
This will depend on the seriousness and sensitivity of the issues involved and who is suspected of the wrongdoing. You should normally raise concerns with:
Your Line Manager
Your Departmental Head
The Compliance Manager
The Chief Executive Officer
The address for correspondence is Vault UK Group Ltd, 15 Queen Square, Leeds, LS2 8AJ.
If, exceptionally, the concern is about the Chief Executive Officer, your concern should be raised with Chairperson who will decide how the investigation will proceed. This may include external investigation.
If you are unsure who to contact, the independent charity Protect can advise you. They offer a free and confidential helpline on 020 3117 2520.
4.2. How to raise a concern
You may raise your concern by telephone, in person or in writing. The earlier you express your concern, the easier it is to take action. You will need to provide the following information:
the nature of your concern and why you believe it to be true
the background and history of the concern (giving relevant dates)
Although you are not expected to prove beyond doubt the truth of your suspicion, you will need to demonstrate to the person contacted that you have a genuine concern relating to suspected wrongdoing or malpractice within Vault UK Group or any of its subsidiaries and there are reasonable grounds for your concern.
You may wish to consider discussing your concern with a colleague first and you may find it easier to raise the matter if there are two (or more) of you who have had the same experience or concerns.
You may invite your professional association representative or a friend to be present for support during any meetings or interviews in connection with the concerns you have raised.
5. What the Group will do
Vault UK Group will respond to your concerns as quickly as possible. Do not forget that testing your concerns is not the same as either accepting or rejecting them.
The overriding principle for Vault UK Group will be fairness and transparency. In order to be fair to all employees, including those who may be wrongly or mistakenly accused, initial enquiries will be made to decide whether an investigation is appropriate and, if so, what form it should take.
The investigation may need to be carried out under terms of strict confidentiality, i.e. by not informing the subject of the complaint until (or if) it becomes necessary to do so. In certain cases however, such as allegations of ill treatment of others, suspension from work may have to be considered immediately. Protection of others is paramount in all cases.
Where appropriate, the matters raised may:
be investigated by management, internal audit, or through the disciplinary/grievance process
be referred to the police
be referred to the external auditor
be referred and put through established child protection/abuse procedures
form the subject of an independent inquiry
Within ten working days of a concern being raised, the person investigating your concern will write to you:
acknowledging that the concern has been received
indicating how Vault UK Group proposes to deal with the matter
supplying you with information on staff support mechanisms
telling you whether further investigations will take place and if not, why not.
The amount of contact between you and the colleagues considering the issues will depend on the nature of the matters raised, the potential difficulties involved and the clarity of your information. It is likely that you will be interviewed to ensure that your disclosure is fully understood.
Any meeting can be arranged away from your workplace, if you wish, a professional association representative or a friend may accompany you in support.
Vault UK Group will do what it can to minimise any difficulties that you may experience as a result of raising a concern. For instance, if you are asked to give evidence in criminal or disciplinary proceedings, Vault UK Group will arrange for you to receive appropriate advice and support.
You need to be assured that your disclosure has been properly addressed. Unless there are any legal reasons why this cannot be done, you will be kept informed of the progress and outcome of any investigation.
6. The Responsible Officer
The Compliance Manager has overall responsibility for the maintenance and operation of this Statement.
7. How the Matter can be Taken Further
This Statement is intended to provide you with an avenue within Vault UK Group to raise concerns. Vault UK Group hopes you will be satisfied with any action taken. If you are not, and you feel it is right to take the matter outside Vault UK Group the following are the suggested legal contacts:
the External Auditor: Grant Thornton UK LLP
The Colmore Building, 20 Colmore Circus, Birmingham, West Midlands, B4 6AT
0121 212 4000
other relevant bodies prescribed by legislation
If you raise concerns outside Vault UK Group you should ensure that it is to one of these prescribed contacts.
You should not disclose information that is confidential to Vault UK Group or to anyone else, such as a client or contractor of Vault UK Group or its subsidiaries except to those included in the list of prescribed contacts.
This Statement does not prevent you from taking your own legal advice.
Approved By: CEO, Vault UK Group Ltd
Last Reviewed Date: 02 October 2023