Whistleblowing Policy

PIVT. recognises that our people are talented, professional and respectful, and that the majority will conduct themselves to the high standards expected in line with our values and shared behaviours. In the event that an employee becomes aware of wrongdoing, malpractice, or risks to others, we want to ensure they have a safe and trusted way to raise concerns.

This policy provides a procedure to raise such concerns without fear of repercussion and with the reassurance that disclosures will be handled sensitively, fairly, and in line with legislation.

Our commitments are to:

• Create an environment where all employees and workers feel safe to raise genuine concerns.
• Ensure all disclosures are investigated promptly and fairly.
• Protect whistleblowers from victimisation or retaliation.
• Take appropriate action where malpractice or wrongdoing is identified.

What is covered under this policy?

This policy sets out the process to be used for reporting serious concerns that are in the public interest, including where an employee reasonably believes that:

• A criminal offence has been, is being, or is likely to be committed.
• A failure to comply with a legal obligation has occurred, is occurring, or is likely to occur.
• The health or safety of an individual has been, is being, or is likely to be endangered.
• The environment has been, is being, or is likely to be damaged.
• There is deliberate concealment of information relating to any of the above.

This policy applies to all staff including agency workers and self-employed contractors.

This policy is not designed for personal grievances (e.g., about terms and conditions, relationships, or treatment at work). Those should be raised under the Grievance Policy.

Any queries regarding the policy should be discussed with your line manager. Please note that where the term “line manager” is used it refers to the person you directly report to.

Employees are asked to:

• Read this policy and comply with the guidance and their obligations detailed within it.
• Report concerns honestly and in good faith.
• Use the reporting channels outlined in this policy.
• Maintain confidentiality of the matter raised.

Line Managers are asked to:

• Listen seriously and sensitively to concerns raised.
• Act promptly and escalate disclosures in line with this policy.
• Protect employees from retaliation or victimisation.

Whistleblowing Officer/HR will:

• Act as the designated point of contact for whistleblowing concerns.
• Ensure that all concerns are recorded and investigated appropriately.
• Provide advice and support to both the whistleblower and any employees subject to investigation.
• Ensure compliance with legislation and internal procedures.

How can I raise a concern?

Concerns can be raised:

• By speaking directly, in confidence, with the Whistleblowing Officer/member of HR.
• If the concern involves senior management and you feel unable to raise it internally, you may raise it with an appropriate external body (e.g., prescribed person under law).

Can I raise concerns anonymously?

Yes, anonymous reports will be considered. However, anonymity may make it more difficult to investigate or provide feedback. Employees are encouraged to identify themselves where possible, but confidentiality will be respected at all times.

All concerns raised will be acknowledged within 5 working days.

The Whistleblowing Officer (or nominee) will carry out an initial assessment and decide whether further investigation is required.

Where an investigation is required, this will be conducted promptly, fairly, and sensitively, with regard to confidentiality.

The whistleblower will be informed of the outcome wherever possible, subject to legal and confidentiality restrictions.

Employees raising genuine concerns will not suffer dismissal, disciplinary action, or other detriment as a result of doing so.

Any retaliation against a whistleblower will be treated as a disciplinary matter.

Confidentiality will be maintained to the fullest extent possible. Information will only be shared with those who need to know in order to investigate or address the concern.

While all concerns are taken seriously, if an investigation finds that a disclosure was made maliciously or knowingly false, disciplinary action may be taken.

PIVT. recognises that raising concerns or being the subject of an investigation can be challenging. If you require any support through this process, including any potential temporary adjustments whilst the process is concluded, please reach out to your Line Manager or HR.