To maintain a work environment in which all employees can raise genuine concerns about poor or unacceptable practices or misconduct without fear of reprisal.
European Law specifically protects a “whistleblowing” employee against dismissal or other sanctions, provided they act in good faith and reasonably believe that one of the following has or is likely to occur:
For Q-Park to achieve, maintain its guiding principles, and to ensure there is a robust procedure to make a disclosure, employees must have the ability to raise concerns internally. Where the internal procedure is not acceptable, a third-party supplier ‘Safecall’ has been contracted to provide an external solution for employees to make a disclosure. This policy is intended to provide employees who believe that they have discovered malpractice or dishonesty within our organisation, such as those listed above, a method to raise these concerns.
Whistleblowing is the disclosure of information by an employee or worker of experience or knowledge of dangerous activity, fraud, illegal or unethical conduct occurring in the workplace.
The Employment Rights Act 1996 as amended by the Public Interest Disclosure Act 1998 governs the disclosure by an employee or worker of unacceptable workplace activities or practices and is intended to protect employees who ‘blow the whistle’ from being subjected to dismissal or any detriment as a result.
i. This policy applies to all employees, suppliers, users, customers, contractors, agency workers and interims personnel of Q-Park UK and Ireland.
ii. Where employees are named below, this will apply to all in point one above, therefore, anyone of any legal link to the Organisation can raise the concerns through our whistleblowing procedures.
iii. All of the aforementioned are responsible for raising genuine concerns.
iv. The Directors of Q-Park UK & Ireland are responsible for ensuring that a procedure is available for genuine concerns to be raised by employees and thoroughly investigated without reprisals or sanctions to the employee raising the issue.
v. Line Managers are responsible for implementing and abiding by this procedure and supporting the promotion of our Whistleblowing policy and procedure and where to go for further help.
vi. Human Resources are responsible for the administration, record-keeping and co-ordination of the whistleblowing procedure and investigating any SafeCall (independent) complaints received.
If one of our employee’s raises a concern, they will not be expected to produce unquestionable evidence to support their claim. This is the responsibility of the individual business units within our organisation and the Investigating Officer once it has been alerted. An employee is only required to have a genuine concern and to raise it in good faith.
If an employee raises a concern, even if that concern proves to be unfounded, they will not be regarded detrimentally, so long as it was a genuine concern at the time and raised in good faith.
Our organisation recognises that an employee may not wish to be identified during the course of an investigation. In such cases, the company will do everything reasonably and lawfully possible to protect the employee’s identity.
If it proves impossible to resolve the matter without revealing an employee’s identity, then the nominated Investigating Officer will discuss with the employee whether and, if appropriate, how an investigation is to proceed. In certain circumstances it may subsequently not be possible to maintain complete confidentiality (for example, if legal proceedings take place) but our organisation will do everything reasonably possible to support and protect the employee concerned.
It is much more difficult for anonymous disclosures to be investigated. Employees are encouraged not to make disclosures anonymously unless it is considered necessary.
If, following completion of any investigation, an employee is not satisfied with the outcome, they can refer the matter to the appropriate Managing or Finance Director.
Our Organisation will not tolerate the victimisation of any employee who raises a genuine concern. Any such occurrences, or failure by all Managers to maintain confidentiality and failure to apply the procedure set out in this document, will be dealt with under disciplinary procedure and is deemed as gross misconduct.
UK law does not provide any protection if an employee commits a criminal offence by disclosing information.
7.1 This policy and procedure do not cover the following, for which separate procedures exist:
7.2 This Policy makes up part of our organisation’s overall policy and commitment towards Corporate Social Responsibility.
7.3 Q-Park UK & Ireland have appointed SafeCall to operate a whistleblower phone line. SafeCall is part of the Law Debenture Corporation and is completely independent to Q-Park.
7.4 The SafeCall whistleblower phone line operates 24hrs a day, 365 days a year, the number is displayed on our induction, our communications, the intranet and on posters at every site. Employees can also register their complaint online through SafeCall.
The following procedures are in place for an employee to make a disclosure:
a) The preferred option is for our employee’s to informally approach their Line Manager for it to be investigated informally and a resolution given back to our employee direct where matters do not arise that are sufficiently serious (as denoted in the introduction section of this policy).
b) Where point ‘a’ cannot be achieved or where it is sufficiently serious, then the employee will be asked to put their complaint in writing to the HR Department. The Line Manager or another appropriate person may take a record of the complaint and email this through to the HR Department where an employee has a disability.
i. investigate the disclosure.
ii. appoint an appropriate person to investigate the disclosure; or
iii. approach the HR Department to investigate and/or appoint the appropriate Investigating Officer.
c) If your disclosure is regarding your immediate Manager employees should approach their Line Manager, who will arrange an appropriate investigation as in a) above.
d) If the disclosure is regarding a member of our organisation and you are not a legal employee, then you should refer your complaint to the HR Department or through the SafeCall confidential reporting line.
e) Alternatively, the employee can take their disclosure direct to the HR Department.
f) If the employee feels unable to follow steps a), b) or c), they can phone our confidential whistleblowing line, SafeCall for advice or to register their disclosure. They can also register their confidential disclosure online through the SafeCall platform.
g) All disclosures will be received from SafeCall in confidence to the Head of HR for UK & Ireland and they will refer either contact the employee to make them aware of receipt, or, in the case of protected disclosures, they will liaise through the SafeCall platform for further investigation and updates to the whistleblower. The Head of HR may delegate this to any Senior Member of the HR team in their absence and will appoint a suitably qualified / experienced investigating officer, whom is independent to all the allegations arising to ensure no conflicts of interests are founded.
h) If the disclosure relates to the Head of HR for UK & Ireland, the disclosure should be made to the Managing Director or Finance Director.
i) Q-Park employees are encouraged, whenever possible, to report using the internal procedures described above.
The Investigation Procedure:
Any of the aforementioned, may make a disclosure as outlined in this policy.
i. Once in receipt of a disclosure, the Designated Officer will send a written acknowledgement of the disclosure to the discloser’s contact details and, as soon as practically possible, arrange an initial interview with the discloser to ascertain the area of concern.
ii. At this stage the Whistleblower will be asked whether they wish for their identity to be disclosed and they will be reassured about protection from possible reprisals or victimisation.
iii. The Whistleblower will also be asked whether or not they wish to make a written or verbal statement. In either case, the Designated Officer will write a brief summary of the interview, which will be agreed by both the employee and the Designated Officer.
iv. The Designated Officer will then appoint an Investigating Officer. It is the responsibility of the Designated Officer to ensure that the Investigating Officer appointed will act in an independent and impartial manner when carrying out his/her investigation into the Disclosure.
v. The investigation may need to be carried out under the terms of strict confidentiality i.e. by not informing the subject of the disclosure until (or if) it becomes necessary to do so. This may be appropriate in cases of suspected fraud.
vi. If there is evidence of criminal activity, the Investigating Officer should notify the Designated Officer who will notify the Appropriate Director. Our Organisation will not take any steps to knowingly hinder any criminal investigation.
vii. The Designated Officer will offer to keep the Whistleblower, who made the disclosure informed about the investigation and its outcome.
viii. If the result of the investigation is that there is a case to be answered by any individual against whom a disclosure has been made, the disciplinary rules and procedure of our Organisation will be used.
ix. Where there is no case to answer, and the Whistleblower making the disclosure had done so based on a genuine concern and was not acting maliciously, the Designated Officer should ensure that the Whistleblower suffers no reprisals.
x. Only where a Whistleblower is proven to act maliciously or makes false allegations, will it be considered appropriate to take action against the employee who made the Disclosure under the terms of the disciplinary rules and procedure of our Organisation.
xi. Due to the varied nature of investigations and prospective outcomes, it is not possible to lay down strict time scales but all investigations will be carried out by the Investigating Officer as quickly as reasonably possible.