Whistleblowing Policy

Definition

Whistleblowing is the name given to the act of the disclosure of information to the employer or the relevant authority by an individual who knows, or suspects, that the Company is responsible for or taken part in some wrongdoing. In other words, Whistleblowing is when an employee reports suspected wrongdoing at work. Officially this is called ‘making a disclosure in the public interest’.

Those making qualifying disclosures are protected against dismissal or detriment by The Public Interest Disclosure Act 1998.

Scope

This policy applies to employees, contractors and any person working for or on behalf of Oxford Analytica.

Qualifying Disclosures

Certain disclosures are prescribed by law as ‘qualifying disclosures’. A ‘qualifying disclosure’ means a disclosure of information that the whistle-blower genuinely and reasonably believes is in the public interest and shows that the Company has committed a ‘relevant failure’ by:

  • committing a criminal offence
  • failing to comply with a legal obligation
  • a miscarriage of justice
  • endangering the health and safety of an individual
  • environmental damage or
  • concealing any information relating to the above.

These acts can be in the past, present or future, so that, for example, a disclosure qualifies if it relates to environmental damage that has happened, is happening, or is likely to happen.

Oxford Analytica will take any concerns that you may raise relating to the above matters very seriously.

Employees must reasonably believe that the disclosure is ‘in the public interest’. We encourage you to use the procedure to raise any such concerns.

The Procedure

The company recognises the importance of having a procedure in place so that you can raise any concerns you have. However, it must also ensure that information and matters that are confidential to the company are not necessarily disclosed to the outside world.

You should therefore report any concerns you may have to the Director of Operations, Director of People & Development or the Global Managing Director who will treat the matter with complete confidence.

Where you have a genuine concern, which constitutes a protected disclosure you should not be afraid of bringing it to the attention of someone within the company. If you make such a disclosure you can be assured that the matter will be taken seriously, that it will be investigated thoroughly and as promptly as circumstances will allow.

If there is a reason why you cannot tell the Company directly or if you are not satisfied with the outcome of actions taken by the Company, you should raise the matter with the appropriate official organisation or regulatory body.

Before instigating this procedure, you should first consider whether the matter should more appropriately be dealt with under the Company's grievance or harassment procedures.

Providing that you follow the whistle blowing procedure, you will not be disciplined or suffer any other  detriment. However, if a false accusation is made maliciously this will result in disciplinary action being  taken.

TREATMENT BY OTHERS

Bullying, harassment or any other detrimental treatment afforded to a colleague who has made a qualifying disclosure is unacceptable. Anyone found to have acted in such a manner will be subject to disciplinary action, including potentially summary dismissal

FURTHER INFORMATION

Please review Whistleblowing for Employees UK Government Guidance.

 

Last updated: June 2018