Whistleblowing policy

1. Introduction

1.1. At Newfoundland Diagnostics Ltd [Newfoundland] we are committed to maintaining the highest standards of integrity, openness, and accountability. This Whistleblowing Policy encourages all employees, contractors, consultants, suppliers, and other relevant parties to raise concerns about any wrongdoing, unethical behaviour, or illegal activities without fear of retaliation. It aligns with the requirements of the Public Interest Disclosure Act (PIDA) 1998 and other UK legislation. This policy applies to all individuals working with Newfoundland regardless of their role or location.

2. Purpose

2.1. The purpose of this policy is to:

2.1.1. Ensure compliance with Public Interest Disclosure Act (PIDA) 1998 by offering protection to whistleblowers.

2.1.2. Promote ethical practices by encouraging the reporting of illegal, unethical, or dangerous activities, including those related to bribery, modern slavery, data protection breaches, and discrimination.

2.1.3. Protect whistleblowers from retaliation or any other negative consequences for reporting concerns in good faith.

3. Scope

3.1. This policy applies to all employees, contractors, consultants, officers,
interns, agency workers, suppliers, and third-party partners. It covers concerns relating to:

3.1.1. Criminal offenses (e.g., fraud, bribery, corruption in
accordance with the Bribery Act 2010)
3.1.2. Non-compliance with legal or regulatory obligations (including data protection laws like GDPR)
3.1.3. Dangers to health and safety
3.1.4. Environmental risks
3.1.5. Human rights violations, including breaches of the Modern Slavery Act 2015
3.1.6. Discrimination or harassment
3.1.7. Financial mismanagement or misconduct
• Any attempt to conceal any wrongdoing

4. Whistleblowing Principles

4.1. Protection: Under PIDA, whistleblowers who raise concerns in good faith
are protected from dismissal or any form of detriment, such as formal warnings or demotions.

4.2. Confidentiality: All concerns will be treated confidentially, and we will
endeavour to keep the identity of the whistleblower anonymous where
possible. However, if the investigation requires disclosure of identity, this
will be discussed with the whistleblower first.

4.3. Anonymous Reporting: Although we prefer that whistleblowers identify
themselves, concerns can be raised anonymously. We will investigate
anonymous reports to the extent possible, though anonymity may limit the
ability to investigate fully.

4.4. No Retaliation: No whistleblower will suffer any form of retaliation for
raising a concern in good faith, even if the investigation does not confirm
the allegation. False or malicious allegations, however, may result in
disciplinary action.

5. How to Raise a Whistleblowing Concern

5.1. You can raise concerns via the following channels:
5.1.1. Manager or Supervisor: In most cases, raise concerns
with your line manager.

5.1.2. Escalation: If the concern is serious or if you feel
uncomfortable reporting to your manager, you may escalate the issue to:
5.1.3. Directors
5.1.4. Designated Whistleblowing Officer

5.2. External Reporting: In cases where internal reporting does not resolve the
concern, or if you believe the issue involves significant wrongdoing, you
may report to external bodies such as:

5.3. Regulators (e.g., Financial Conduct Authority, Health and Safety
Executive)

5.4. Protect (formerly Public Concern at Work), a whistleblowing charity that
can offer guidance on reporting (https://protect-advice.org.uk).

5.5. All reports should include:
5.5.1. Details of the concern
5.5.2. Key facts and dates
5.5.3. Names of individuals involved
5.5.4. Any evidence supporting the concern

6. Investigation Process

6.1. Upon receiving a whistleblowing report:
6.1.1. Acknowledgement: You will receive confirmation that your concern has been received within 5 working days.
6.1.2. Investigation: An impartial investigator will be assigned,
and a thorough, confidential investigation will be conducted.
6.1.3. Feedback: You will be kept informed of the progress of
the investigation, although specific details may remain
confidential.
6.1.4. Outcome: Upon conclusion, you will be informed of the
outcome and any actions taken. If you are unsatisfied with the
outcome, you may escalate the concern to a senior executive or
an external body.

6.2. If misconduct is discovered, appropriate corrective actions will be taken,
including disciplinary action, dismissal, or reporting to external authorities
where required.

7. Data Protection

7.1. All personal data related to whistleblowing reports will be handled in
accordance with the UK GDPR. This includes ensuring that data is:
7.1.1. Processed fairly and lawfully
7.1.2. Kept secure and confidential
7.1.3. Accessed only by individuals involved in the investigation

8. Protection for Whistleblowers

8.1. If you raise a concern in good faith, you will be protected under this policy
and the Public Interest Disclosure Act (PIDA) 1998. Any form of retaliation or detrimental treatment for whistleblowing will be treated as a disciplinary
matter and could result in severe consequences, including dismissal.

9. Anti-Bribery and Corruption

9.1. As part of our compliance with the Bribery Act 2010, all concerns related
to bribery, corruption, or unethical business practices must be reported
immediately. This includes any form of offering, giving, or receiving bribes.
Failure to report such activity could lead to severe disciplinary action or
legal consequences.

10. Modern Slavery Compliance

10.1. In compliance with the Modern Slavery Act 2015, we are committed to ensuring that modern slavery and human trafficking do not take place in our supply chains or any part of our business. Whistleblowers are encouraged to report any concerns relating to exploitation, forced labour, or human rights abuses.

11. Taking Concerns Outside the Business

11.1. In rare cases, whistleblowers may feel it is necessary to take their concerns to an external body, such as a regulator or legal authority. In such cases, the whistleblower is encouraged to seek advice from external organizations such as Protect. While raising concerns internally is preferred, employees are protected under PIDA if they raise legitimate concerns with the appropriate external authorities.

12. Compliance with Government Procurement Regulations

12.1. This whistleblowing policy is part of our broader commitment to ethical
business practices and complies with the Public Contracts Regulations
2015.

13. Policy Review and Monitoring

13.1. This policy will be reviewed annually by the Board to ensure compliance with UK laws and regulations, including changes to the Public Interest Disclosure Act, Bribery Act, Modern Slavery Act, GDPR, and other relevant legislation. Whistleblowing reports will be monitored, and the outcomes will be presented to the Board to ensure continuous improvement and compliance with our legal obligations.

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Frequency of Review: 2 Years
Approved by Freddie Jackson – Head of Operations
Date: 08.08.2024