Whistleblowing - Severn Trent Services by shitingting


									‘Speak-Up’ –
Whistleblowing Policy

Human Resources
Severn Trent
Policy Status:   Approved
Issue Date:      July 2011
Version:         7.0
Policy Owner:    Human Resources
Contact:         mailto:rachel.dodsworth@severntrent.co.uk
Review Date:     January 2012

A message from our Chief Executive
We believe in openness and honesty. If you are worried about wrongdoing
affecting the company, colleagues or customers then please use whatever
means to let us know. Doing the right thing and speaking out about things we feel
are wrong is essential. Maintaining high ethical standards is crucial to the
success of our business. Normally the concerns we all have from time to time
about what is happening at work are easily resolved, but if they involve unlawful
or unethical conduct, financial wrong doing or dangers to health and safety or the
environment it can be difficult to know what to do.
You may be worried about raising such issues or feel that it’s none of your
business or that it’s only a suspicion. You may feel you are being disloyal to
colleagues or managers. However, raising a concern is the right thing to do,
whatever your position in the company; it is in all our best interests to prevent
This policy is to help you raise your concern at an early stage and in the right
The following are some examples of wrong doing concerning business,
customers and regulatory risks:
        Breaches of “Doing the right thing, the Severn Trent Way” and our
         internal Policies
        Fraud/theft (against the company, its customers or its suppliers)
        Corruption, bribery or blackmail
        Criminal offences
        Negligence/ intentional disregard of duties and responsibilities
        Conduct likely to damage the company’s reputation
        Failure to comply with a legal or regulatory obligation
        Endangering the health and safety of any individual
        Endangering the environment
        Improper use of authority
        Providing data which is known to be inaccurate or misleading
        Other unethical conduct
        Hiding information about wrong doing
This list cannot cover all possible situations, so if you are worried let us know.
The Severn Trent Plc Board and I are totally committed to this policy. We want
you to have confidence that your concerns will be taken seriously and handled
sensitively and fairly. Please help us to ensure we live up to our stated

Tony Wray
Group Chief Executive
Whistleblowing Policy
1.    Scope

     This policy applies to anybody who is employed by, or carries out work on
     behalf of, any Severn Trent group company including managers, officers,
     directors, contractors, consultants, trainees, part-time and fixed-term
     workers, homeworkers, temporary staff, agency workers and volunteers.

2.   Definition of Whistleblowing

     Someone blows the whistle when, in good faith, they tell their employer or
     an authorized third party about a genuine concern they have about
     unethical, dangerous or illegal activity that they are aware of or suspect is
     going on at work.

     Whistleblowing can inform those who need to know about health and
     safety risks, potential environmental problems, bribery, fraud, corruption,
     cover- ups and many other problems. Often it is only through
     whistleblowing that this information comes to light and can be addressed
     before real damage is done. Whistleblowing should be seen as an
     invaluable warning system which can save lives, jobs, money and

     This policy does not relate to complaints relating to your personal
     circumstances, such as the way you have been treated at work. In those
     cases you should use the appropriate HR Policy.

     If you are uncertain whether something is within the scope of this policy
     you should seek advice from your Line Manager, a Senior Executive or
     Safecall (see Section 6) or Public Concern at Work, the independent
     whistleblowing organization, who offer a confidential helpline:-

     Helpline: (0044) 7404 6609
     E-mail: whistle@pcaw.co.uk
     Website: www.pcaw.co.uk

3.   Ethical Behavior at Severn Trent

     “Doing the right thing, the Severn Trent Way” expresses the values and
     standards of behavior       which we all need to abide by in our day to day
     business. Anyone who        works for the company either directly or
     indirectly should be made aware of “Doing the right thing, the Severn
     Trent Way”.
       “Doing the right thing, the Severn Trent Way” is available on Streamline or
       by calling the HR Advice Line on 150 (internal) or 02476 478202
       (external) or by e-mailing hradviceline@severntrent.co.uk.

4.     Your Safety

       If you raise a genuine concern under this policy, you will not be at risk
       of losing your job or suffering any form of retribution as a result.
       Providing you are acting with good intentions it does not matter if you
       are mistaken. Of course Severn Trent does not give this assurance to
       someone who raises a false allegation maliciously.

      If you believe that you have suffered any such treatment you should inform
      one of the contact points listed in section 6 immediately. If the matter is not
      remedied you should raise it formally using our grievance procedure or
      seek advice from Public Concern at Work.

      Staff must not threaten or retaliate against whistleblowers in any way.
      Anyone involved in such conduct may be subject to disciplinary action.

5.     Your Confidentiality

        We hope that this policy reassures you that you can safely raise a
        concern openly. If you feel that you cannot, you can ask for your
        identity to be kept confidential but you need to make this very clear when
you raise your concern. If you ask us to protect your identity we      will       not
disclose it without your consent, unless we are required to do         so legally. If
the situation arises where we are not able to resolve the       concern       without
revealing your identity, we will discuss with you        whether and how we can

       While we will consider anonymous reports, this policy is not designed to
       deal with concerns raised anonymously. Remember that if you do not tell
       us who you are, it will be much more difficult for us to look into the matter,
       to protect your position, or to give you feedback. It is also more difficult to
       establish whether the allegations are credible and have been made in
       good faith.

      Whistleblowers who are concerned about possible reprisals if their identity
      is revealed should come forward to one of the contact points listed in
      paragraph 6 and appropriate measures can be taken to preserve
      confidentiality. If you are in doubt you can seek advice from one of the
      contacts in section 6 or Public Concern at Work.
6.    How to report your concern

      The most important thing is that you raise your concern with someone.
      There are a number of ways you can raise a concern and these are
      listed below:

      Option 1 - Line Manager

      If you have a concern we hope that you will feel able to raise it first with
      your Line Manager. You can do this face to face or in writing.

     In most cases, your Line Manager will be the most appropriate person
     to talk to about your concern. However, if you can’t raise the issue with
     your manager, or no action has resulted from you doing this, talk to your
manager’s manager.

      Option 2 - Senior Executives

      Alternatively, you can raise a concern with one of the following senior

      Tony Wray                         Alec Richmond
      Group Chief Executive             Director of Internal Audit
      Severn Trent Plc                  Severn Trent Plc
      Severn Trent Centre               Severn Trent Centre
      PO Box 5309                       PO Box 5309
      Coventry, CV3 9FH                 Coventry, CV3 9FH
      02477 715600                      02477 715603
      tony.wray@severntrent.co.uk       alec.richmond@severntrent.co.uk

      Evelyn Dickey
      Human Resources Director
      Severn Trent Plc
      Severn Trent Centre
      PO Box 5309
      Coventry, CV3 9FH
      02477 715615

      Option 3 - Safecall

      You can also call our confidential reporting line on 0800 915 1571. This
      confidential reporting line is operated by Safecall - an independent
     company that specializes in handing concerns at work. Safecall will take
     details of your concern and send a report through to Severn Trent to
     investigate. You can ask Safecall to keep your identity confidential. A
     description of how Safecall will handle your call is attached in the
     Supporting Information (Section 10).

7.   Reporting your concern in other ways

     We hope that if you need to raise a concern you will feel able to follow the
     procedure outlined above before considering raising a concern in other
     ways (e.g. to OFWAT or the Health and Safety Executive), but providing
     you are acting in good faith and you have evidence to back up your
     concern, we would rather you raised the matter with an appropriate
     outside body than stay silent.

8.   Dealing with your Concern

     We will normally discuss your concern with you. This will normally involve
     a meeting, at which you can choose whether or not you want to be
     accompanied by a colleague or trade union representative, (we cannot
     guarantee your confidentiality if you are accompanied). You may be asked
     how you think the matter might best be resolved. If you do have any
     personal interest in the matter, we ask that you tell us at the outset. If
     another policy or procedure is more appropriate for handling your concern
     we will tell you.

     We will take down a written summary of your concerns and provide you
     with a copy after the meeting. We will also aim to give you an indication of
     how we propose to deal with the matter.

     Following these discussions we will look into your concern and initially
     assess what action should be taken. This may involve an internal inquiry
     or a more formal investigation – when fraudulent activity is suspected the
     Anti Bribery & Anti Fraud Response Plan will be used to investigate the
     matter. We will ensure that the investigation is carried out in a way which
     is fair and equitable to the individual raising the concern and the person(s)
     against whom the allegation is made.

     We will tell you who is dealing with the matter, how you can contact them
     and whether your further assistance may be needed. If you request it, we
     will write to you summarizing your concern and setting out how we
     propose to handle it.

     Once your concern has been fully investigated we will confirm this and
     let you know what we can about the actions we have taken.
9.   Responsibilities

     As an employee you are responsible for:-

        Understanding the standards of ethical behavior expected at Severn
         Trent, as outlined in “Doing the right thing, the Severn Trent Way”.
        Raising any genuine concern you may have as quickly as possible
         using one of the methods listed in section 6.

     Managers and Directors are responsible for:-

        Ensuring that all employees, agency workers, temporary staff,
         volunteers and contractors working in their department are made
         aware of this policy and “Doing the right thing, the Severn Trent Way”.
        Creating an environment in which it is easy to discuss a concern about
         unethical behavior.
        Taking seriously any concern that is raised.
        Dealing sensitively with anyone who raises a concern.
        Logging all concerns raised with Human Resources.
        Notifying Group General Counsel or Internal Audit at the earliest
         opportunity if the concern involves possible fraudulent activity. This will
         enable them to assess whether the matter is serious enough to warrant
         an investigation under the Anti Bribery & Anti Fraud Response Plan.
        Investigating concerns thoroughly and making an objective
         assessment of the concern (where the matter is not handled under the
         Anti Bribery & Anti Fraud Response Plan).
        Seeking advice when necessary.
        Keeping the employee advised of progress, as appropriate.
        Completing an Investigation Summary Report.

     Human Resources are responsible for:

        Providing advice to employees and managers on the application of the
         Whistleblowing policy.
        Monitoring the effectiveness of the Whistleblowing policy and process.
        Maintaining a restricted access whistleblowing register and associated
        Providing regular updates to the Corporate Responsibility Committee,
         which reports into the Severn Trent Plc Board.
        Supporting managers to ensure his/her obligations in this Policy
        Conducting a review of this policy from a legal and operational
         perspective once a year.
10.   Supporting Information

         “Doing the right thing, the Severn Trent Way” Anti Bribery & Anti Fraud
         Anti Bribery & Anti Fraud Response Plan – not published but owned by
          General Counsel
         Safecall Process Map
         Safecall Question & Answers
         Managers guidelines on handling whistleblowing concerns
         Format for the Investigation Summary Report
         Grievance
         Bullying & Harassment

11.   Document Change History

      Date     Version Change                                 Author
      01/04/00 1.0     - Whistleblowing/ disclosure           Divya Odedra
                         policy introduced
      01/03/03 2.0     - Policy updated to                    Divya Odedra
                         incorporate group-wide
                         disclosure statement
      01/12/05 3.0     - Replaced with group-wide             Sue Barker
                         policy called Promoting
                         Ethical Behavior at Work
      16/06/08 4.0     - Confidential reporting line          Jennie
                         introduced.                          Ferguson
                       - Policy renamed
      08/03/10 5.0     - Reviewed an updated as               Rachel
                         per policy review process            Dodsworth
      14/01/11 6.0     - Updated to reflect changes           Rachel
                         to Section 6 – How to report         Dodsworth
                         your concern
      15/07/11 7.0     - Reviewed and updated to              Rachel
                         provide further clarity in           Dodsworth
                         relation to the Policy and to
                         reflect the Bribery Act 2011

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