Oxford Instruments (“the Company”) is committed to conducting all business with integrity and in a responsible manner. In line with our values, processes and procedures, it is important that all employees feel confident that they can freely voice genuine concerns and/or disclose information relating to possible malpractice about the Company’s or a colleague’s business activities. This is often referred to as “Whistleblowing” and anyone should feel they are able to use this process to speak up, however small the issue might be. Whistleblowing is a positive act, when motivated by a genuine concern about an action or behaviour that is not consistent with the Company’s ethical standards and just doesn’t feel right. It helps us to understand issues that could potentially challenge our ethical standards and identify opportunities for improvement.
The procedure below has been created to ensure that any matters raised about a business malpractice are dealt with fairly and promptly. It might be that one of our other processes, e.g. the grievance procedure, is a better option. But if you are not sure, it is best to speak up using either process and we can go from there.
Our principle
It is important that all employees are able to freely voice any genuine concerns they have about work practices that don't feel right and/or disclose information relating to a possible malpractice.
This procedure applies to all Workers (this means employees, whether permanent, contract, or employees of other individuals who are working on our premises or on behalf of the Company).
It is your duty to perform your role in a responsible and trustworthy manner. Anyone involved in business malpractice may be subject to disciplinary action (which could result in dismissal) and where appropriate, legal action may also be taken against individuals that are to blame.
It is the responsibility of all managers to ensure that this policy is actively supported and that any Workers for whom they are responsible understand and support the principles contained within it.
The Board of Directors has overall responsibility for effective operation of this policy and for reviewing the effectiveness of actions taken in response to concerns raised under this policy.
A business malpractice is any activity undertaken by a Worker, individually or on behalf of the Company, which is conducted illegally or without due care to their or the Company’s responsibility to shareholders, customers, workers or local environment. The list below, whilst not exhaustive, gives some examples of such activities:
A whistleblower is a person who raises a genuine concern relating to any of the above. If you have any genuine concerns related to a suspected wrongdoing or danger affecting our activities (a “whistleblowing concern”) you should report it under this policy. If you are not sure, it is better to speak up than to say nothing.
The Company will protect any Worker who raises a genuine whistleblowing concern. This includes any disclosure of information that, in the reasonable belief of the Worker, is made in the public interest. This can be taking place now, have happened or likely to be committed, with a reasonable belief being sufficient to raise the issue.
You should use the procedure set out in this policy if you genuinely believe the Company, or any Worker of the Company, has taken, intends to take, or has failed to take action which you reasonably believe amounts to (or may amount to) business malpractice. This procedure is not a mechanism for raising individual grievances or complaints relating to contracts of employment.
Depending on the nature of the concern and the need to undertake investigations and/or involve the police or a regulatory body, it may not be possible to confirm specific timescales for your concerns to be investigated and concluded. However, action undertaken will be carried out as quickly as practicably possible without affecting the quality of the investigation.
Records
Throughout any necessary investigation, records will be kept detailing the nature of the disclosure and the outcome of each stage of the investigation. These records will be kept in accordance with any prevailing data protection requirements and will remain confidential.
Protection and support
To ensure you feel comfortable raising any issues, the Company will try where possible and appropriate to:
a) formally acknowledge your disclosure;
b) respect your confidentiality;
c) provide you with appropriate support;
d) investigate your concerns thoroughly;
e) update you on any investigation as it proceeds; and
f) advise you of the outcome of any investigation where appropriate, particularly in circumstances where it is felt that this may be sensitive to you.
Whistleblowers who make a protected disclosure must not suffer any detrimental treatment because of the disclosure. Detrimental treatment includes dismissal, disciplinary actions, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment as a result of raising a concern, you should inform your line manager, your local HR team or a member of the Head Office Compliance team (email: compliance@oxinst.com) immediately. If the matter is not remedied, you should raise it formally using an applicable local grievance procedure.
At any point during an investigation into a matter raised, the investigating officer may require further information from you. They may also require any Worker implicated either directly or indirectly in the matter to be suspended from their work.
The conclusion of an investigation may result in the dismissal of a Worker or Workers. Where this happens dismissal will normally be carried out only after consultation with a Managing Director/President/Executive Director/Chairman or Non-Executive Board Director, depending on the level of the Worker affected.
Action other than dismissal for any Worker involved in a business malpractice will also normally be managed in accordance with the appropriate procedure for managing misconduct.
If you have a whistleblowing concern, your manager may be able to help resolve the issue. However, if you do not feel it is appropriate to discuss with your concerns with your manager and you would like advice and guidance on the matter, contact your local HR team or the Head Office Compliance team (email: compliance@oxinst.com).
Safecall is an independent reporting service, and you may prefer to report your concern directly to them. Safecall provides a confidential worldwide service for all our employees, customers, suppliers, agents, representatives and partners. You can report your concern in English or in your local language, anonymously if necessary.
Following a call, Safecall will provide a full, written report to the Company to allow the matter to be fully investigated and appropriate action taken.
Safecall can be contacted in the following ways:
Via email: report@safecall.co.uk
Via the Safecall website: https://www.safecall.co.uk/en/clients/oxinst/
By telephone: https://www.safecall.co.uk/file-a-report/telephone-numbers/
Our Senior Independent Director
One of the non-executive directors of the Oxford Instruments plc Board acts as Senior Independent Director with particular responsibility to make sure we uphold our ethical standards and behaviour.
If, in exceptional circumstances, a serious issue arises that you feel cannot be raised through the other routes, you can contact the Senior Independent Director at: seniorindependentdirector@oxinst.com The Senior Independent Director has authority to direct an investigation into reports made.
The aim of this policy is to provide a mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases alerting the Company or our independent reporting service, Safecall, will be sufficient.
However, there may be some circumstances where it may be appropriate for you to report your concerns to an external body such as a regulator. It will very rarely, if ever, be appropriate to alert the media. We strongly encourage you to seek advice before reporting a concern to an external regulator.
An investigating officer will investigate all issues relating to the concern reported. This may require them to be provided with copies of documents or formally interview individuals in support of evidence relating to the concern.
On completion of an investigation, and ordinarily in conjunction with another senior member of management, the investigating officer will agree an appropriate course of action. If appropriate, you may be advised of the outcome in writing. However, the Company may not be able to inform you of any matters which could infringe the duty of confidentiality owed to others.
In addition, the Company may pass on a summary of the investigation and outcome to the Company’s auditors and legal advisors to enable a review of, and improvement to, procedures.
Whilst we cannot guarantee the outcome of an investigation you are seeking; we will try to deal with your concern fairly and in an appropriate way. By using this policy, you can help us to achieve this.
If you are dissatisfied with the outcome of the investigation into the concerns you raised or believe it may impact you or your role directly, you are encouraged to raise this using the relevant grievance or complaints procedure in place within your business or region. If you feel that this cannot be raised through this route, you can contact the Senior Independent Director at: seniorindependentdirector@oxinst.com.
This policy is non-contractual and may be varied and withdrawn by the Company without notice.
© Oxford Instruments 2024