Whistleblowing Policy

This policy was last updated March 2023.

RSS  Group  Limited (the “Company”) seeks to conduct its business honestly and with integrity at all times. However, we acknowledge that all organisations face the risk of their activities going wrong from time to time, or of unknowingly harbouring malpractice including corruption, unsafe practices and other misconduct. We have a duty to take appropriate measures to identify such situations and attempt to remedy  them.  By  encouraging  a  culture  of  openness  and  accountability  within  the  organisation,  we believe that we can help prevent such situations occurring. 

We expect all employees to maintain high standards and to report any wrongdoing that falls short of these fundamental principles. The aim of this policy is to ensure that our employees are confident that they can raise any matters of genuine concern without fear of reprisals, in the knowledge that they will be taken seriously and that the matters will be investigated appropriately and regarded as confidential.


The policy covers all employees who are working under a contract of service with the Company as well as former and current workers, agents / contractors working on behalf of the Company referred to as "employees", board  members  including  non-executives,  volunteers,  trainees  and  job  applicants.  It applies  when  an  individual  has  reasonable  grounds  to  believe  that  malpractice  has occurred,  is occurring or is likely to occur in connection with the Company and are reporting in accordance with the internal channels.


he purpose of this policy is to provide a rapid mechanism under which genuine concerns can be raised without  fear  of  adverse consequences  for  the individual  and  any  third  party  helping  the  Discloser  to report at work. The individual making a disclosure will be referred to as the Discloser throughout this document.


• The Company is committed to the highest standards of openness, probity and accountability.

• The Company will fully observe the provisions of the Public Interest Disclosure Act 1998 (the “Act”).  This  policy  also  takes  into  account  the  requirements  of  the  European  Union’s Whistleblowing Directive which came into effect in December 2021 • Any  disclosure  about  suspected  malpractice may be  made,  initially,  to  a  member  of  the Standards Committee or the nominated service provider as set out below.

• Any disclosure to a member of the Standards Committee under this procedure should, as far as is practicable, be in writing. • The Discloser should provide as much supporting written or other evidence as possible about the disclosure and the grounds for the belief of malpractice. 

• The Company will treat all disclosures under this Policy in a sensitive and, as far as possible under this Policy, confidential manner.

• The  Company  will  acknowledge  a  disclosure  within  seven  (7)  days  of  receipt  and  feedback within three (3) months of the acknowledgement, where contact details are provided.

• The Discloser may at any time disclose the matter on a confidential basis to a professionally qualified lawyer for the purpose of taking legal advice.

• If an investigation under this procedure concludes that a disclosure has been made maliciously, vexatiously,  in  bad  faith  or  with  a  view  to  personal  gain,  the  Discloser may be  subject  to disciplinary action. • Any  employee  of  the  Company  who  hinders  reporting or  any  investigation, or  takes action against the Discloser as a result of the disclosure, may be subject to disciplinary action by the Company which may include summary dismissal.  All employees are required to fully co-operate with any investigation under this policy.   

• An employee is protected in law against being dismissed or penalised by their employer if they publicly  disclose  information  that  falls  into  one  of  the  categories  known  as  "qualifying disclosures" and that information is disclosed in a manner that is permitted in the Act.

• This policy is distinct from any of the Company's Grievance procedures. If an employee has a complaint relating to their personal circumstances in the workplace, the appropriate grievance procedure should  be used. Additionally, this Policy may not be used to obtain a rehearing of matters that have already been addressed under other Company procedures such as grievance or disciplinary procedures.


Qualifying disclosures are when the Discloser reasonably believes:

• that a criminal offence has been committed, is being committed or is likely to be committed;

• that a person has failed, is failing or is likely to fail to comply with any legal obligation to which they are subject;

• that a miscarriage of justice has occurred, is occurring or is likely to occur;

• that the health or safety of any individual has been, is being or is likely to be endangered;

• that the environment has been, is being or is likely to be damaged; or

• that information tending to show any matter falling within any one of the preceding paragraphs has been, is being or is likely to be deliberately concealed. The belief need not be correct - it might be discovered subsequently that the Discloser was in fact wrong - but the Discloser must show that they held the genuine belief, that it was a reasonable belief in the circumstances at the time of disclosure and that the qualifying disclosure was made in the public interest and in good faith. 


Reporting We  would  always  recommend  that  in  the  first  instance  you  raise  any  concern  with  your  local management  team.      However,  if  you  do  not feel  comfortable  doing  this  you can raise  the  matter in accordance with the reporting procedure which is as follows. Any disclosure may be made to a member of the Standards Committee or by phone to the RSS Group Confidential Disclosure facility provided by an external, independent specialist, SafeCall, on:   

Country Telephone Number Australia 1 800 312928 Ireland 1 800 812 740 New Zealand 00 800 900 44036 UK 0800 915 1571  at any time, 24 hours a day, 7 days a week or via the web at www.safecall.co.uk/report When contacting SafeCall, you will be put in touch with someone who is trained to receive disclosures about  concerns  in  the  workplace.  We  assure  you,  that  calls  received  by  SafeCall  will  be  treated confidentially and will not be tape recorded. Should you wish, SafeCall will maintain your anonymity.

It  is  preferable  for  whistleblowers  to  reveal  their  identity  to  SafeCall,  who  will only  pass  it  on to the Standards Committee should you give their permission for your identity to be disclosed. They will collect all the information you wish to disclose and make the  disclosure on your behalf, taking measures to preserve  confidentiality  if  necessary.  If  appropriate,  SafeCall  will  continue  to  liaise  with  you  and feedback any resolution.

If you do not want to contact Safecall you can report your concern directly to a member of the Standards Committee, who will require similar information to Safecall in order to progress.


We regret that we cannot guarantee to investigate all anonymous allegations.  After receiving the initial 'disclosure', the Standards Committee will, or will nominate a senior member of staff to, investigate the allegation in accordance with the process detailed in the grievance procedure applicable to the Discloser.  An acknowledgement will be provided within seven (7) days of the initial ‘disclosure’ for those Disclosers who are not anonymous. Where  a  grievance  procedure  is  not  applicable  to  the  Disclosure,  the  Standards  Committee  or nominated senior member will hold a confidential interview with the Discloser (the “Investigator”).  The purpose of this interview is to obtain as much information as possible about the grounds that support the believed malpractice and to consult with the Discloser about further steps which could be taken. Proper investigation may prove impossible if the Investigator cannot obtain further information from you, give you feedback, or ascertain whether your disclosure was made in good faith.  

The Discloser will  have  the  right  to  be  accompanied  by  a  work  colleague  at  the  interview.  The companion of the Discloser will be asked to respect the confidentiality of the qualifying disclosure and any subsequent investigation. In addition a note taker may accompany the member of the Standards Committee.

Further interviews with other relevant people, gathering of information or more enquiries may take place in order that the allegation can be properly investigated and assessed by the Investigator.   

If in the opinion of the Standards Committee the matter raised is not a whistleblowing matter within the meaning of the Act, they may either:

(a) notify the Discloser and no further action will be taken and the matter closed;

(b) appoint an Investigator and ask for them to report back to the Standards Committee; or

(c) request the matter is handled outside of this policy and in line with the relevant policies and procedures regarding grievances and/or complaints (as applicable).


After considering the information provided, the Investigator will recommend to the Standards Committee what further steps should be taken, if any. The following list is not exhaustive, but these may include one or more of the following:

• that the matter should be reported to the police or other appropriate public authority;

• that  the  matter  should  be  investigated,  either  internally  by  the  Company  or  by  some  other external Investigator appointed by the Company;

• proposed actions which may need to be taken as a result of the disclosure or outcome of the investigation including amendments to policies and procedures, further training or implementing any “lessons learnt” as a result of the disclosure; 

• that  an  employee  should  be  given  the  opportunity  to  seek  redress  in  connection  with  the disclosure through the Company's Grievance procedures.

The grounds on which the member of the Investigator may recommend that no further action by the Company should be taken are as follows:

• there are no grounds to the complaint;

• that the Discloser has not demonstrated a reasonable basis for alleging that malpractice within the meaning of this procedure has occurred, is occurring or is likely to occur;

• that the Investigator is satisfied that the Discloser has not acted in good faith;

• that  the  matter  concerned  is  already  the  subject  of  legal  proceedings,  or  has  already  been referred to the police or other public authority;

• that the matter is already (or has already been) the subject of proceedings under one of the Company's other procedures relating to staff.

An individual nominated by the Standards Committee, will take all steps necessary to ensure that the decisions  of  the  Standards  Committee are  implemented including  any  internal  actions  or  sharing  of lessons learnt, except in instances when in their opinion there are good reasons for not doing so. In such circumstances that decision, together with the reasons to support it, will be notified in writing to the Company CEO as soon as practicable. 


Once  the  further  steps  (if  any) to be  taken have  been  agreed,  the Discloser  will  be  notified of  the outcome and the reasons behind it within three (3) months from the date of the acknowledgement of the disclosure subject to them having provided contact details.

If, having followed the above procedure, the Discloser is not satisfied with either the decision reached or the associated outcome, they may raise the matter concerned on a confidential basis directly with the Company CEO.


The  Company  will  treat  all  disclosures  under  this  Policy  in  a  confidential  and  sensitive  manner.  Any report or recommendations will not identify the Discloser unless written consent is given or unless there are grounds to believe that the Discloser has acted maliciously.

In the absence of such consent or grounds, the member of the Standards Committee will not reveal the identity of the Discloser, other than to the Investigator, under this procedure unless:

• where the member of the Standards Committee is under a legal obligation to do so; or

• where the information is already in the public domain; or

• on a strictly confidential basis to the member of the Standards Committee's secretary; or

• on a strictly confidential basis to a professionally qualified lawyer for the purpose of obtaining legal advice.


Whenever an allegation is made as part of this procedure against a named individual, that person will be told of the allegation and of the evidence supporting it, and will be allowed to respond before any investigation, or further action, is concluded. The point at which the individual is informed will depend on the nature of the case.


Any  documentation  (including  computer  files  and  discs)  kept  by  the Investigator  or member  of  the Standards  Committee  relating  to  the  matter  will  be  kept  secure.  As  far  as  practicable,  only  the Investigator and members of the Standards Committee and their administrative assistant and any legal adviser shall have access to it.

The Discloser will  not  be  required  by the  Company,  without  his  or  her  consent,  to  participate  in  any further  enquiry  or  investigation  into  the  related  matter.  Participation  at  this  later  stage  will  usually  be required to be on an open rather than a confidential basis, although the obligations under this procedure will remain in relation to the identity of the original Discloser of information. This principle does not apply if there are grounds to believe that the Discloser may have been involved in misconduct or malpractice.

The Company will not (and it will use all reasonable endeavours to ensure that its employees do not) subject  the Discloser to  any  detriment,  on  the  grounds  of  the  disclosure  of  information  under  this procedure.

The individual should report any complaints of such treatment to a member of the Standards Committee. If they request the member of the Standards Committee to take action in relation to such complaints, the Discloser may be asked for written consent to reveal their identity for the purposes of any such action.


The Standards Committee will be notified of all qualifying disclosures promptly and the outcome of any investigation. An  annual  report  on  whistleblowing  activity  will  be  provided  to  the  Standards  Committee  in  the  first quarter of each calendar year.  Where applicable a nil report will be provided.


Standards Committee Members  Group CEO – Chair  Group Chief Financial Officer If members of the Standards Committee are alleged to be involved in a whistleblowing incident then other members of the Board of Directors of RSS Group Limited or it’s parent company may substitute for committee members. If you have any concern regarding this document either speak to your manager or contact RSS Global Legal at legal@rssglobal.com