Our commitment is underpinned by our Whistleblowing Policy to:
- Encourage colleagues to raise genuine concerns about suspected wrongdoing at the earliest practical stage, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected
- Provide colleagues with guidance as to how to raise those concerns
- Reassure colleagues they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.
All managers are expected to operate an ‘open door’ policy and should therefore make themselves available, either personally or by telephone or email, to resolve issues or concerns.
The Board of Directors has overall responsibility for ensuring the policy is applied.
The Audit Committee is responsible for ensuring all whistleblowing instances are investigated.
The Executive Committee is responsible for ensuring all colleagues understand and comply.
All colleagues are responsible for understanding the principles outlined in this policy and for reporting appropriate concerns using the methods outlined in the policy.
Monitoring and review
When a whistleblower raises a concern, we carry out an initial assessment to determine the scope of the any investigation. This initial assessment is conducted by the Global Director of Risk and Compliance or the Chief People Officer.
All matters raised under this policy will be reported to the NCC Group Audit Committee for review. The whistleblower will be informed of the progress of any investigation into the issue they have raised. Complaints about the way concerns have been handled can be raised using the same contacts and process.
Training and communication
Details on how to access the whistleblowing independent and confidential helpline are prominently displayed on all digital media channels as well as in our physical locations. Links to the Whistleblowing Policy and process also feature in our Compliance onboarding and annual refresher training.