Whistleblowing policy
1. About this policy
1.1 – We are committed to conducting our business with honesty and integrity and we expect all staff to maintain high standards. We encourage concerns to be raised as soon as possible by anyone connected with our business who reasonably believes wrongdoing, misconduct, or a serious risk has occurred, is occurring, or is likely to occur.
1.2 – This policy covers all employees, officers, consultants, contractors, volunteers, interns, casual workers and agency workers, former workers, job applicants, clients, suppliers, freelancers, and other external stakeholders who may be affected by or become aware of wrongdoing connected with StudioLR’s activities.
1.3 – StudioLR may accept concerns under this policy from a wider range of people than those protected by whistleblowing law. Nothing in this policy is intended to expand or reduce any legal rights.
1.4 – This policy is intended for concerns about wrongdoing, misconduct, or serious risks in the public interest. It is not normally intended for personal employment grievances or routine customer/service complaints, which should be raised under the relevant grievance or complaints procedure unless they also involve wider wrongdoing or a serious public-interest concern.
1.5 – This policy does not form part of any employee's contract of employment and we may amend it at any time.
1.6 – The process for handling disclosures under this policy, including investigation steps, updates and indicative timescales, is set out in the relevant Grievance Procedure.
2. What is whistleblowing?
2.1 – Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our activities. This includes sexual harassment, bribery, facilitation of tax evasion, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment, any breach of legal or professional obligations, and any deliberate concealment or attempted cover-up of any of the above.
3. How to raise a concern
Employees
3.1 – We hope that in many cases you will be able to raise any concerns with your manager. However, where you prefer not to raise it with your manager for any reason, you should contact our Directors.
3.2 – We will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation.
All other stakeholders
3.3 – Concerns can be raised in the following ways:
emailing concerns@studiolr.com
completing the form at www.studiolr.com/concerns
sending a letter to the following address, marked FAO The Company Directors: StudioLR, 25 The Bond Building, Breadalbane Street, Edinburgh EH6 5JW
4. Confidentiality
4.1 – We hope that you will feel able to voice whistleblowing concerns openly under this policy. Completely anonymous disclosures are difficult to investigate. If you want to raise your concern confidentially, we will make every effort to keep your identity secret and only reveal it where necessary to those involved in investigating your concern.
5. Anonymity
5.1 – If you would prefer to raise a concern anonymously, you may do so by completing the form at www.studiolr.com/concerns. While a space for a name and email address is provided, it is not mandatory to provide either when completing this form. Submissions will not be published on our website.
5.2 – You may also send a letter to us at the following address: StudioLR, 25 The Bond Building, Breadalbane Street, Edinburgh EH6 5JW
5.3 – If a concern is raised anonymously, we may be unable to ask follow-up questions, provide updates, or investigate as fully as we otherwise could.
6. External disclosures
6.1 – The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in connection with our activities. We encourage concerns to be raised internally first where appropriate, as this often allows issues to be addressed quickly and effectively. However, nothing in this policy prevents you from seeking independent advice or, where the law allows, reporting a concern to a regulator, prescribed person, or other appropriate external body.
6.2 – The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. We strongly encourage you to seek advice before reporting a concern to anyone external. Protect operates a confidential helpline. Their contact details are at the end of this policy.
7. Protection and support for whistleblowers
7.1 – We aim to encourage openness and will support whistleblowers who raise genuine concerns under this policy, even if they turn out to be mistaken.
7.2 – When a concern is raised (whether openly or confidentially), we will consider whether the whistleblower may be at risk of detriment or retaliation and agree proportionate steps to protect them. This may include agreeing a safe contact method and times, limiting who they need to speak to, and (where relevant) taking practical steps to reduce risk in the workplace.
7.3 – We will take proportionate steps to preserve confidentiality, including: keeping records securely; limiting access to information to those who need to know to investigate and/or resolve the concern; and, where possible, anonymising or minimising identifying details in any documentation. We will only disclose a whistleblower’s identity where necessary for a fair investigation, to comply with law, or to protect someone from serious harm, and we will seek to discuss this with the whistleblower in advance where reasonably practicable.
7.4 – If the concern relates to a Director, or the whistleblower reasonably believes the Directors should not handle the matter, the concern should be marked “For independent review”. StudioLR will appoint an independent third party (for example, an external HR or legal adviser) to handle the matter.
7.5 – Whistleblowers must not suffer any detrimental treatment as a result of raising a genuine concern. For external stakeholders, this includes unjustified termination of contracts, refusal of services, exclusion from opportunities, or other disadvantage because a concern was raised. If you believe that you have suffered any such treatment, you should inform our Directors immediately, or use the route in 7.4 where appropriate. If the matter is not remedied you should raise it formally using the External Stakeholders Grievance Procedure. Employees may also raise the matter under the Employee Grievance Procedure where relevant.
7.6 – StudioLR employees must not threaten or retaliate against whistleblowers in any way. If you are involved in such conduct you may be subject to disciplinary action. In some cases the whistleblower could have a right to sue you personally for compensation in an employment tribunal.
7.7 – However, if we conclude that a concern was raised maliciously and/or with knowledge that it was false, StudioLR may take appropriate action. In the case of employees, this may include disciplinary action. A concern that is not upheld, by itself, does not mean it was raised maliciously.
7.8 – Protect operates a confidential helpline. Their contact details are at the end of this policy.
8. Contacts
Protect (Independent whistleblowing charity)
Helpline: 0203 117 2520
Website: Protect - Speak up stop harm - Whistleblowing Homepage