1: Introduction

1.1 Policy Overview
Redcone Recruitment Limited is committed to conducting business with integrity, transparency, and the highest ethical standards. This Whistleblowing Policy has been designed to provide a framework for employees, contractors, and other stakeholders to raise concerns about any wrongdoing within the organisation without fear of retaliation. This policy applies to issues related to unlawful conduct, unethical behaviour, malpractice, safety violations, or any actions that may harm the interests of Redcone Recruitment Limited, its employees, clients, or the wider public. The policy reflects compliance with the Public Interest Disclosure Act 1998 (PIDA), which protects whistleblowers in the UK, and ensures adherence to relevant ISO standards such as ISO 37001 (Anti-Bribery Management) and ISO 45001 (Occupational Health and Safety).

1.2 Policy Objectives
The primary objectives of this Whistleblowing Policy are to:

• Encourage employees and stakeholders to report any concerns or suspicions of wrongdoing.
• Protect whistleblowers from retaliation or victimisation.
• Ensure that all reported concerns are treated seriously, investigated thoroughly, and resolved appropriately.
• Foster a culture of openness and accountability within the organisation.
• Comply with legal and regulatory obligations, including the Public Interest Disclosure Act 1998.

2: Purpose

2.1 Scope of the Policy
This policy covers the reporting of any improper or illegal conduct within Redcone Recruitment Limited. Whistleblowing concerns may include, but are not limited to:

• Criminal offences (e.g., fraud, theft, bribery, or corruption).
• Violations of legal obligations or regulatory requirements.
• Health and safety breaches that endanger employees, contractors, or the public.
• Environmental violations or incidents of pollution.
• Unethical behaviour, including harassment, discrimination, or malpractice.
• Any attempt to conceal or cover up wrongdoing.

2.2 Legal and Ethical Compliance
This policy ensures that Redcone Recruitment Limited meets its legal obligations under the Public Interest Disclosure Act 1998, the Bribery Act 2010, and other relevant laws, including those related to health and safety, environmental protection, and employment practices. The policy also aligns with ISO 37001 (Anti-Bribery) and ISO 45001 (Health and Safety), supporting the company’s commitment to ethical conduct, transparency, and employee welfare.

3: Scope

3.1 Who Can Raise a Concern?
This policy is applicable to all employees, contractors, temporary workers, suppliers, and other stakeholders associated with Redcone Recruitment Limited. Concerns can be raised by:

• Full-time and part-time employees.
• Temporary staff and labour supplied to clients.
• Contractors and subcontractors.
• Suppliers or service providers working with Redcone Recruitment Limited.
• Any third-party stakeholder impacted by the company’s operations.

3.2 Types of Concerns to Report
The whistleblowing policy covers concerns that are in the public interest. These may include:

• Health and Safety Violations: Unsafe working practices, failure to comply with traffic management regulations, or unsafe working conditions.
• Environmental Concerns: Improper disposal of waste, environmental hazards, or breaches of ISO 14001 environmental standards.
• Unlawful Activities: Fraud, theft, corruption, or any illegal conduct.
• Ethical Violations: Bullying, discrimination, harassment, or unethical recruitment practices.
• Misuse of Resources: Misappropriation of company funds, equipment, or resources for personal gain.

4: Reporting Procedure

4.1 How to Raise a Concern
Redcone Recruitment Limited encourages individuals to report concerns as soon as they become aware of any wrongdoing. The company provides multiple channels for whistleblowing:

• Direct Reporting: Concerns can be reported to an employee’s immediate supervisor or manager.
• Confidential Reporting: If the whistleblower is uncomfortable reporting directly, they can contact the Health and Safety Manager or a designated whistleblowing officer.
• Anonymous Reporting: While it is encouraged that whistleblowers provide their contact details, anonymous reports will also be accepted. However, anonymity may limit the scope of the investigation.
• External Reporting: If internal reporting mechanisms are inadequate or unavailable, concerns can be raised with relevant external bodies, such as the Health and Safety Executive (HSE), the Environment Agency, or the Information Commissioner’s Office (ICO), depending on the nature of the concern.

4.2 Information to Provide
When raising a concern, the whistleblower should provide as much detailed information as possible, including:

• A clear description of the concern or incident.
• Dates, times, and locations of the events.
• Names of individuals involved or witnesses to the incident.
• Any supporting evidence (e.g., documents, emails, or photos).
• Information on any previous efforts to address the issue.

4.3 Confidentiality
Redcone Recruitment Limited is committed to maintaining the confidentiality of whistleblowers. All concerns will be treated with the highest level of discretion. The identity of the whistleblower will not be disclosed without their consent, unless required by law.

4.4 Protection from Retaliation
In accordance with the Public Interest Disclosure Act 1998, Redcone Recruitment Limited prohibits retaliation against any employee or individual who raises a concern in good faith. This includes protection from dismissal, demotion, disciplinary action, or any form of harassment or victimisation. Any employee found to have retaliated against a whistleblower will face disciplinary action, up to and including dismissal.

5: Investigation and Follow-Up

5.1 Initial Assessment
Once a concern has been raised, the designated whistleblowing officer or manager will conduct an initial assessment to determine whether the concern falls within the scope of this policy. If the concern is outside the scope of whistleblowing, it may be referred to another appropriate channel (e.g., grievance procedures for personal employment issues).

5.2 Investigation Process
If the concern is deemed valid, an investigation will be initiated. The investigation process will include:

• Appointing an independent investigator or investigation team, if necessary.
• Collecting relevant evidence, including statements from witnesses and reviewing any relevant documentation.
• Ensuring that the investigation is conducted fairly, thoroughly, and without bias.
• Maintaining confidentiality throughout the process.

5.3 Outcome and Resolution
Upon completion of the investigation:

• A report will be prepared outlining the findings, conclusions, and any recommended actions.
• The whistleblower will be informed of the outcome, unless anonymity has been requested.
• Corrective actions will be implemented, if necessary, to address any identified wrongdoing or policy violations.
• The outcome will be documented, and any lessons learned will be applied to improve company policies and procedures.

5.4 Escalation of Concerns
If the whistleblower is dissatisfied with the handling or outcome of their concern, they have the right to escalate the issue. This may include:

• Requesting a review of the investigation by senior management.
• Reporting the matter to an external regulatory authority if the concern has not been adequately addressed.

6: Responsibilities

6.1 Employee Responsibilities
All employees, contractors, and stakeholders of Redcone Recruitment Limited are responsible for:

• Reporting any concerns of illegal, unethical, or unsafe conduct in good faith.
• Cooperating with any investigations that arise as a result of a whistleblowing report.
• Maintaining confidentiality regarding the whistleblowing process and investigation.

6.2 Management Responsibilities
Managers and supervisors have a responsibility to:

• Actively promote a culture of openness and integrity where concerns can be raised without fear of retaliation.
• Take all whistleblowing reports seriously and ensure they are addressed promptly.
• Ensure that employees who raise concerns are protected from retaliation.

6.3 Whistleblowing Officer Responsibilities
The Whistleblowing Officer is responsible for:

• Receiving and assessing all whistleblowing reports.
• Ensuring that investigations are conducted thoroughly and fairly.
• Safeguarding the confidentiality of whistleblowers.
• Providing whistleblowers with updates on the progress of investigations.
• Reporting the outcomes of investigations to senior management and ensuring that corrective actions are implemented.

7: Policy Review and Updates

7.1 Regular Review
This Whistleblowing Policy will be reviewed annually or in response to significant legislative changes or organisational developments. The purpose of these reviews is to ensure that the policy remains effective, relevant, and compliant with current laws and best practices.

7.2 Continuous Communication
Redcone Recruitment Limited is committed to ensuring that all employees and stakeholders are aware of this Whistleblowing Policy. Regular communication and training will be provided to ensure that individuals understand their rights, responsibilities, and the process for raising concerns.

8: Relevant Legal and ISO Compliance

8.1 Legal Considerations
This policy has been developed to comply with the following legal frameworks:

• Public Interest Disclosure Act 1998 (PIDA)
• Bribery Act 2010
• Health and Safety at Work Act 1974
• Employment Rights Act 1996
• Equality Act 2010

8.2 ISO Standards
The Whistleblowing Policy is designed to align with and support compliance with relevant ISO standards, including:

• ISO 37001: Anti-Bribery Management Systems
• ISO 45001: Occupational Health and Safety Management Systems
• ISO 9001: Quality Management Systems

By implementing this Whistleblowing Policy, Redcone Recruitment Limited ensures that concerns about wrongdoing can be raised and addressed promptly, fostering a culture of transparency, integrity, and continuous improvement across the organisation.