Whistle Blowing Policy

Process owner: Tom Reaney, January 2023

HR Business partner: MHA Monahans

Policy Statement

If any employee becomes aware of any criminal offence or other wrongdoing in the workplace, they should report it immediately. If the wrongdoing gives rise to a personal grievance, staff may raise the matter in accordance with the Grievance policy

Employees may simply wish to disclose a wrongdoing without raising a personal grievance, they may do so by following this whistle blowing procedure. This procedure is not legally binding and does not form part of any Integrity contracts of employment.

Whistle Blowing Principles

In accordance with the Public Interest Disclosure Act 1998, Integrity has instituted a system for reporting information which in their reasonable belief points to a wrongdoing at work. A wrongdoing is any of the following:

  • A criminal offence has been or is likely to be committed.
  • A person has failed, is failing or is likely to fail to comply with a legal obligation.
  • A miscarriage of justice has happened, is happening or is likely to happen.
  • The health and safety of an individual has been, is being or is likely to be damaged.
  • Damage to the environment has occurred, is occurring or is likely to occur; or
  • Information showing any of the above has been, is being, or is likely to be deliberately concealed.

Integrity wishes to ensure that any such wrongdoings are reported and dealt with.

If a member of staff becomes aware of a wrongdoing at work, follow the procedure below immediately. If they believe that a Integrity manager may be involved in the wrongdoing, then directly advise the Finance department, who will report the matter to the assigned HR Business partner.

Whistle Blowing Procedure

If any member of staff becomes aware of a wrongdoing, they should raise concerns immediately with their manager. The manager will carry out a prompt and thorough investigation of the matter and will report their findings to a HR Business Partner. The HR Business Partner will take any necessary action including if appropriate reporting the matter to the relevant external authority.

Should any third party or supplier encounter any activity or behaviour that would constitute criminal activity or pose significant threat to customers or the public, whistleblowing could be undertaken by contacting a HR Business Partner, stating the time, location, organisation, and colleague in question, along with a description of the activity for which they are “Whistleblowing”.

Where possible, it would be requested they provide contact details should Integrity require further information as part of an investigation.

If the member of staff is not satisfied that their disclosure has been dealt with properly or they believe that the manager or any other manager in the business are involved in the wrongdoing, they should raise their concerns directly with an HR Business Partner. The HR Business Partner or an authorised deputy will arrange for an investigation or further investigation to be carried out.

The HR Business Partner will take any necessary action including if appropriate reporting the matter to the relevant external authority. Where, as a result of the disclosure it is necessary to take disciplinary action against a member of staff, this will be done in accordance with Disciplinary Policy. Employees will be informed of the outcome of the investigation and any actions taken as a result.


Integrity will not tolerate the victimisation of any person who discloses a wrongdoing under this policy. Any such victimisation will be treated as a disciplinary offence.