We value the reputation of ESGright in all our business activities. As such, we are committed to ensuring our staff and clients consistently maintain the highest standards of honesty and integrity. We believe in an environment of openness and transparency to encourage the reporting of any wrongdoing, internal or external to our business activities, including bribery, corruption, fraud or criminal offences, as soon as possible. This will enable ESGright to maintain our high ethical standards and act promptly on these concerns.
Scope
This policy applies to all shareholders, directors, management, and staff of ESGright, including full time, part time, seconded staff, agency staff, agents, interns, and any other persons who perform services on behalf of ESGright. The policy guidance also covers external dealings with clients, suppliers, government bodies and other businesses and organisations. The policy aims to encourage employees and members of the public to communicate and disclose any improper conduct within ESGright. The policy provides a framework which enables individuals to inform us of any improper conduct. The policy also highlights the need for all staff to conduct themselves with the highest levels of integrity and ensures that whistle blowers will be protected from any detrimental actions such as reprisals, intimidation or harassment. ESGright will ensure that all disclosures are investigated promptly and consistently.
What is whistleblowing?
Whistleblowing refers to the deliberate and voluntary disclosure of improper conduct in relation to our business activities by a person who has access to information about actual, suspected or anticipated disciplinary breaches or criminal offences.
Reporting concerns
Disclosures should first be highlighted to your immediate superior informally. This is to ensure that only valid concerns are documented for further investigation. After discussion with your superior, a formal disclosure should be made in writing to the Principal Consultant. The disclosure should contain details of who is involved, timing and location of the incident, the nature of the improper conduct, the reason for the incident and any witnesses or documentary evidence. You should also include details of any informal steps taken to resolve the issue.
Employees could also raise a concern anonymously by send an email with supporting evidence. The email can be sent to “Whistleblower@ESGright.com“. Anonymous concerns must be supported with evidence for any investigation to commence.
Confidentiality and protection
Provided that the whistle blower has acted confidentially and in good faith, without any personal interest or gain, ESGright will endeavour to keep the whistle blowers’ identity secret, only to be shared with those involved in the investigation.
We aim to encourage openness and transparency and will support whistleblowers who have acted in good faith. Whistleblowers must not suffer detrimental treatment because of a genuine disclosure. In the event a whistleblower believes they (or those related to them) have been subjected to detrimental treatment in retaliation because of a genuine disclosure, they must inform the Principal Consultant immediately.
For certain disclosures, it may be necessary to report externally to a regulator. Protection for the whistleblower is provided by the Whistleblower Protection Act 2010. The protection covers protection from detrimental actions, disclosure of confidential information and immunity from civil and criminal actions.
Investigating the disclosure
Prompt action will be taken by an independent person or team to investigate all internal and external disclosures. A time will be set by the team for feedback to ESGright and the whistleblower.
If the disclosure relates to an employee, the employee will not be part of the investigation team.
Once the investigation concludes, the team will inform the whistleblower of the outcome, whether there is no case to answer or if further action will be taken. All investigation matters, decisions and outcomes must be fully documented and managed in accordance with the Personal Data Protection Act 2010.
At no time can the whistleblower contact the suspected parties or discuss the case with other parties.
For certain improper conduct disclosures referral to the authorities may be required. Referral can be made without the individual whistleblower’s consent.
Failure to follow this policy
The following failures to follow this policy may result in disciplinary action and/or dismissal from ESGright. For external businesses and organisation, failure to comply with this policy may result in the termination of business relationships and engagements.
- Disclosing improper conduct publicly without following the process outlined in this policy
- Making a false, malicious or vexatious disclosure for personal gain
- Retaliating against a whistleblower (or a related person) in the event you are under investigation due to a genuine disclosure
