Whistle Blower Policy

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Whistleblowing Policy at IIFC UK

What Is Whistleblowing?

Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our activities. We want to ensure that our employees have an effective route to raise such genuine concerns and one which encourages and enables employees to raise serious concerns within IIFC UK rather than overlooking a problem. The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying wrongdoing in the workplace and in most cases you should not find it necessary to alert any one externally (although see further below).

IIFC UKs Commitments

IIFC UK is committed to the highest possible standards of openness, probity and accountability. In line with that commitment we expect employees, and others that we deal with, who have genuine/serious concerns about any aspect of IIFC UKs work to come forward and voice those concerns. IIFC UK is happy to discuss your concerns and will also advise you as to what is regarded as failure with reference to Qualifying Disclosures. We encourage all line managers to be open to concerns of the employees.

Who Does The Policy Apply To?

The policy applies to all employees, (including those designated as casual hours, temporary, agency, authorised volunteers or work experience), and those contractors working for IIFC UK on the premises, for example, agency staff, builders, drivers. It also covers suppliers and those providing services under a contract with IIFC UK.

Policy Aims and Safeguards

IIFC UK recognises that the decision to report a concern can be a difficult one to make. If what you are saying is true, you should have nothing to fear because you will be doing your duty to your employer and those for whom you provide a service.

IIFC UK is committed to;

  • provide avenues for you to raise concerns in confidence and receive feedback on any action taken.
  • ensure that you receive a response to your concerns and that you are aware of how to pursue them if you are not satisfied.
  • reassure you that you will be protected from possible reprisals or victimisation if you have a reasonable belief that you have made a disclosure in good faith.
  • apply our policies such that you have reasonable support to make use of them.

The Policy covers “Qualifying Disclosures*

A “qualifying disclosure” is one which, in your reasonable belief, suggests that one or more of the following has been, is being, or is likely to be committed:

  • a) A criminal offence;
  • b) A failure to comply with any legal obligation;
  • c) A miscarriage of justice;
  • d) The putting of the health and safety of any individual in danger;
  • e) Damage to the environment; or
  • f) Unauthorised use of public funds &other unethical conduct; and
  • g) Deliberate concealment relating to any of the above.
  1. In each of the cases from ‘a’ to ‘g’ irrespective of whether the action, inaction or failure occurred in the United Kingdom or elsewhere.
  2. All Qualifying Disclosures are protected by The Public Interest Disclosure Act 1998.
  3. Other procedures are available to employee e.g. the grievance procedure which relates to complaints about your own employment. This policy does not replace other complaints procedures which are for public use.

Confidentiality

All concerns will be treated in confidence and every effort will be made not to reveal your identity if you so wish. At the appropriate time, however, you may need to come forward as a witness.

This policy encourages you however to put your name to your concern whenever possible. Please note that you:

  • must disclose the information in good faith.
  • must believe it to be substantially true.

• must not act maliciously or make false allegations.

How to Raise Your Concern including external approach

We encourage you to carry out five checks if wishing to Whistleblow or speaking up.

  1. See:

The first step is seeing something you believe needs to be raised. Consider the questions;

  • What can you see occurring?
  • Have you seen wrongdoing?
  • Do you anticipate wrongdoing?
  1. Prepare:

The next step is to thoroughly prepare.

It is advisable to make sure you are aware of the IIFC UK Whistleblowing procedure and whom to contact. Seek advice from your Line Manager/HR/Compliance Officer, as appropriate, and keep a full record of notes and emails.

  1. Evaluate:

Using the evidence you have gathered, and the advice you have sought, you should evaluate what is taking place in order to fully understand the situation.

  1. Act:

After evaluating the situation and if you feel it is necessary, you should then act.

Report the issue to the appropriate person and use the IIFC UK procedure described herein below.

  1. Keep Trying: 1) Informal Disclosure

Having followed the earlier steps, if you feel your concerns are not being addressed, you should pursue them at a higher level.

Re-evaluation of the situation, and, if necessary, further preparation, are important every time you raise the reporting level.

You can blow the whistle or “speak up” by following four steps described herein below:

In the first instance, employees are encouraged to consider whether raising the matter informally might resolve the concern and to discuss with their Line Manager and/or HR how this might be undertaken.

2) Formal Disclosure

3) Disclose to a Regulator

  • Telephone: +44 (0)20 7066 9200
  • Email: – whistle@fca.org.uk

Should you decide that a formal disclosure is appropriate please contact your Line Manager and HR.

If the issue is against your respective Line Manager, you are strongly encouraged to contact the Senior Manager/Compliance Officer. In the absence of the Compliance Officer and where you wish to speak up with the Senior Management you can directly approach the MD of IIFC UK.

Upon receipt of such disclosure the Line Manager/HR Manager will immediately contact the Compliance Officer and or Managing Director for further action connected with such disclosure.

The responsibility for the primary relationship with the FCA and /or other regulatory bodies lies with the Board of Directors and in particular the Managing Director and the Manager/Compliance Officer. As such, you should, in the first instance, contact the Manager/ Compliance Officer to raise any issues of regulatory concern.

You have the right to make protected disclosures to the Whistleblowing Champion and the Compliance Officer. The law recognises that in some circumstances it may be appropriate for you to report your concerns to a regulator. It is not a legal requirement that you contact us internally before doing so but we encourage you to consider using our internal processes first.

Direct contact with the regulator might be considered (see below) if you are unable to address the subject matter of the formal disclosure internally including via the Board of Directors the Managing Director and the Whistleblowing Champion.

Details of Whistleblowing Champion:

Dr Anand Kumar: Non-Executive Director & Chair of the Risk Committee

Email: anand.raghubir@gmail.com

Mobile: 0044 7834359092

Details of external regulator:

(During office hours or leave a message on voicemail)

  • Post: Intelligence Department (Ref PIDA), The Financial Conduct Authority, 12 Endeavour Square, London, E20 1JN
  • You may also fill up online form at;

https://www.fca.org.uk/firms/whistleblowing/where-make-report

Further guidelines on whistleblowing at FCA website:

www.fca.org.uk/firms/whistleblowing

Public Disclosure

As noted above, the law recognises that in some circumstances it may be appropriate for you to report your concerns to a regulator. It will very rarely if ever be appropriate to alert the media. We strongly encourage you to seek advice before deciding whether external contact with the media is relevant and permissible.