Whistleblowing

Hastoe Group is committed to fostering a culture of openness, probity and accountability, and to taking all reasonable steps to deter malpractice - including fraud, bribery, money laundering and misconduct. To help achieve this, the Group will promote awareness of this policy and the accompanying procedure, at least annually, supported by e-learning every two years. Anyone raising a legitimate concern about malpractice that has happened, is happening or is likely to happen, will not be at risk of losing their job or being subjected to detrimental treatment by Hastoe Group or its colleagues.

Purpose

The aims of the policy are to:

• Encourage and enable employees, contractors, suppliers, and other stakeholders to raise genuine and serious concerns about actual or suspected malpractice as early as possible, in relation to specific issues which are in the public interest.
• Provide a confidential mechanism for doing so.
• Reassure individuals they will be protected by law from any form of reprisal such as victimisation, harassment, discrimination, dismissal or any other detrimental treatment, by either Hastoe Group or their colleagues.

Scope

This policy applies to all employees, workers, Board members, and those providing services to the Hastoe Group. This includes temporary agency workers, contractors and consultants. This policy is open, fair, and inclusive offering protection to both internal and external parties who suspect malpractice related to Hastoe Group’s activities.

What Is Whistle Blowing?

Whistle blowing is the reporting of suspected wrongdoing, malpractice or risk in relation to Hastoe’s activities. This is informally referred to as “blowing the whistle” or more formally as “making a disclosure in the public interest”.

Individuals are protected by law as long as they report the right type of concern – a “qualifying disclosure” – to the right person and in the right way. A qualifying disclosure is defined in the Public Interest Disclosure Act 1998 and the Employment Rights Act 1996. It is a serious concern about malpractice which affects the well-being of residents, other customers, employees, Hastoe Group, the public or the environment.

A qualifying disclosure is made when the person making the disclosure reasonably believes (and it is in the public interest) that one or more of the following has been committed, is being committed, or is likely to be committed.

A criminal offence, for example:

• Fraud, including bribery and money laundering, involving the conversion of the Group’s funds for personal gain.
• False accounting, e.g. deliberate misstatement of statutory financial statements.
• Theft or misappropriation of the Group’s, tenants’ or other staff’s cash or property.
• Malicious damage to Group property.
• Deliberate actions which leave the Group liable to legal action.

A failure to comply with a legal obligation, for example:

• Staff involvement or collusion in the illegal occupation or letting of Group residential properties (“key selling”), or those other properties managed by the Group.
• Corruption and/or collusion with contractors or other third parties to obtain personal financial or other gain.
• Seeking or accepting payment of financial or any other bribes.
• Falsifying performance data.
• Abuse or neglect of vulnerable people.

A miscarriage of justice, for example: tampering with evidence to attempt to pervert a court decision.

There is a danger to the health and safety of any individual, for example: the coercion of staff, contractors or suppliers to carry out unsafe or illegal work practices.

Damage to the environment, for example: the unsafe or illegal disposal of toxic materials, e.g. arising from building works, renovations or other processes.

There is a deliberate attempt to conceal any of the above. These examples are not exhaustive and other instances may arise.

Whistle Blowing Principles

Individuals must only raise concerns under this policy about a suspected risk, malpractice or wrongdoing that affects others such as clients, suppliers, colleagues, customers, the Company or the public interest. Concerns may also be raised in relation to an act of wrongdoing which may negatively impact the environment.

Concerns relating to a personal grievance or dispute will be dealt using the Group’s Grievance Procedure.

Concerns or allegations, including those which may be considered gross misconduct offences, will be dealt with under the Group’s Disciplinary Policy and Procedure.

This policy is not intended as a means to re-open matters that have already been addressed under the grievance or disciplinary policies and procedures, or to question legitimate financial or business decisions taken by the Group.

Abuse of this policy and procedure by maliciously or mischievously raising unfounded allegations, either internally or externally, will be regarded as a serious disciplinary offence and may result in disciplinary action, including dismissal.

Where an allegation is made, the people involved will normally be informed of the allegation and the evidence supporting it, and will be allowed to comment and provide relevant information before the investigation is completed.

Any allegation of malpractice or wrongdoing will be treated in the strictest confidence and investigated in accordance with the Whistleblowing Procedure. The identity of the person raising the concern will not be disclosed to the alleged offender(s) without their prior approval, unless this is incompatible with a fair investigation. In such circumstances, Hastoe will consult with the individual concerned.

If an individual makes an allegation they must have a reasonable belief the allegation is true and it must not be made for personal gain.

Reporting Requirements

Concerns can be raised using the whistleblowing form available on Hastoe’s website, which directs submissions to a confidential email address: whistleblowing@hastoe.com. This ensures accessibility for all stakeholders, including contractors and third parties.

Alternative reporting routes are in place to ensure impartiality. If concerns involve a senior officer responsible for whistleblowing oversight, another officer will handle the case.

Individuals can choose to remain anonymous when reporting concerns, though doing so may limit the ability to fully investigate the issue.

Responsibilities

All employees, workers, Board members and service providers should:

• Remain vigilant and, where they have a reasonable belief, report any actual or suspected malpractice they come across in the Group, to eliminate fraud, bribery, money laundering and misconduct using the accompanying Whistle Blowing Procedure.
• Report any actual or suspected cases of bullying, harassment, victimisation or any other type of detrimental treatment of an employee or worker on the grounds that they have made a protected disclosure.
• Not cover up or remain silent about someone else’s actual or suspected malpractice, even if a manager or other person of authority instructs them to do so.
• Not make malicious or false disclosures (see 6.5 above).

The Governance and Compliance Team will:

• Record all whistle blowing incidents in the Fraud Register.
• Report all allegations along with the outcome of investigations to the Audit and Risk Committee.

A designated Whistleblowing Officer will oversee investigations. An alternative officer will be assigned if concerns involve this individual.

Any person implicated by reports of malpractice or improper activity must co-operate fully with the investigation.

Related Hastoe Group Policies and Procedures and UK Legislation

There are links to the following Group policies and procedures:

• Anti-Fraud Policy
• Health, Safety and Wellbeing Policy
• Anti-Money Laundering Procedure
• Maintaining Standards of Probity Policy
• Code of Conduct
• Procurement Policy
• Complaints Procedure
• Standing Orders
• Data Protection Policy
• System Regulations

The legislation relevant to this policy is:

• Employment Rights Act 1996
• Enterprise and Regulatory Reform Act 2013
• Public Interest Disclosure Act 1998