Whistleblowing Policy

Policy Statement

World of Textiles UK LTD is committed to the highest standards of honesty, openness, and accountability. We encourage employees and others who have serious concerns about any aspect of our work to come forward and voice those concerns without fear of reprisal.

This Whistleblowing Policy (also known as “Public Interest Disclosure Policy”) provides a confidential process for raising concerns about potential wrongdoing, enabling the organization to investigate and address issues before they escalate.

Purpose and Scope

Who This Policy Applies To

This policy is for:

• All employees (permanent, temporary, part-time, full-time)
• Contractors and agency workers
• Consultants and advisors
• Suppliers and business partners
• Former employees (in relation to matters during employment)

What This Policy Covers

This policy is for reporting serious concerns about:

Financial Matters:

• Fraud, theft, or financial irregularities
• Misuse of company funds or assets
• False accounting or fraudulent financial reporting
• Money laundering

Legal and Regulatory Violations:

• Breach of legal obligations
• Criminal offenses
• Failure to comply with regulatory requirements
• Miscarriage of justice

Health, Safety, and Environment:

• Dangers to health and safety
• Environmental damage or risks
• Unsafe working conditions or practices

Bribery and Corruption:

• Bribery or corruption
• Conflicts of interest not properly declared
• Inappropriate gifts or hospitality
• Facilitation payments

Employee Welfare:

• Bullying or harassment
• Discrimination
• Modern slavery or human trafficking
• Safeguarding concerns

Professional Conduct:

• Unethical behavior
• Abuse of authority
• Gross mismanagement
• Breach of company policies

Data and Information:

• Data protection breaches
• Unauthorized disclosure of confidential information
• Cybersecurity incidents
• Information security failures

Concealment:

• Cover-ups of wrongdoing
• Deliberate suppression of concerns
• Obstruction of investigations

Legal Protection

Under the Public Interest Disclosure Act 1998 (PIDA), workers who make qualifying disclosures about wrongdoing are protected from detrimental treatment or dismissal, provided they:

• Have a reasonable belief that the disclosure is in the public interest
• Have a reasonable belief that the disclosure is substantially true
• Make the disclosure to an appropriate person or body

This policy is designed to ensure disclosures are made appropriately and qualify for legal protection.

When to Use This Policy

Whistleblowing vs. Personal Grievances

Use the Whistleblowing Policy for concerns about:

• Wrongdoing that affects others or the public interest
• Serious matters that could harm the organization, employees, or stakeholders
• Situations where normal reporting channels are inappropriate

Use the Grievance Procedure for concerns about:

• Your own employment situation (pay, working conditions, treatment)
• Personal disputes with colleagues
• Routine operational matters

If in doubt, raise your concern and we will direct you to the appropriate procedure.

How to Raise a Concern

Step 1: Consider the Issues

Before raising a concern, consider:

• What is the specific wrongdoing or malpractice?
• Do you have evidence or a reasonable belief?
• Has it already occurred, is it ongoing, or likely to occur?
• Who is involved or affected?
• Have you witnessed it directly or heard about it?
• Is there an immediate danger requiring urgent action?

Step 2: Decide How to Report

You can raise concerns through several channels:

Option 1: Your Line Manager

• Appropriate if the concern doesn’t involve your manager
• Quickest route for many issues

Option 2: Senior Management

• If the concern involves your line manager
• For more serious matters
• Contact any member of senior management

Option 3: Confidential Email

• Email: info@worldoftextiles.com marked “Confidential - Whistleblowing”
• Provides written record
• Can be anonymous if necessary

Option 4: Written Report

• Write to: Senior Management Team, World of Textiles UK LTD, 960 Capability Green, Luton, Bedfordshire, LU1 3PE
• Mark envelope “Private & Confidential - Whistleblowing”

Option 5: Telephone

• Call +44 1234 567 890 and ask to speak confidentially about a serious concern
• Can be anonymous if you wish

Option 6: External Bodies (see below)

Step 3: Provide Information

When raising a concern, provide:

• Background and context
• Names, dates, and locations where possible
• Specific details of the wrongdoing
• Evidence you have (documents, emails, etc.)
• How you became aware of the issue
• Whether others know about it
• Your contact details (unless reporting anonymously)

You do not need to prove the allegations - you only need a reasonable belief based on the information available to you.

Anonymous Reports

You can raise concerns anonymously, though this may limit our ability to:

• Seek further information
• Provide feedback on the outcome
• Offer support during the process

Where possible, we encourage you to provide your name in confidence.

How We Will Respond

Initial Assessment

Within 5 working days of receiving a disclosure, we will:

• Acknowledge receipt (if contact details provided)
• Assess the seriousness and credibility
• Determine the appropriate course of action
• Appoint an investigator if necessary

Investigation Process

The investigation will typically involve:

1. Planning - Defining scope, appointing investigators, setting timeline
2. Evidence Gathering - Interviews, document review, site visits
3. Analysis - Evaluating evidence objectively
4. Findings - Determining whether concerns are substantiated
5. Recommendations - Proposing corrective actions
6. Implementation - Taking appropriate action
7. Follow-up - Monitoring effectiveness of actions

Timeline

• Minor matters: Typically resolved within 4-6 weeks
• Complex matters: May take several months
• Regular updates will be provided where contact details are available

Possible Outcomes

Depending on findings, we may:

• Disciplinary Action - Warnings, suspension, dismissal
• Process Improvements - Policy changes, new controls
• Training - Additional training for staff
• Referral to Authorities - Police, regulators, professional bodies
• Civil Action - Recovery of losses, contract termination
• No Action - If concerns are unfounded

Feedback

If you provided contact details:

• We will keep you informed of progress
• You will be told whether your concern was substantiated
• You may not receive details of disciplinary actions (due to confidentiality)
• You can request updates on the status of the investigation

Confidentiality and Anonymity

Confidentiality

We will:

• Treat all disclosures in strict confidence
• Only share information on a need-to-know basis
• Protect your identity wherever possible
• Only reveal your identity with your consent, or if legally required

Anonymity

You may report anonymously, but:

• We cannot confirm receipt or provide updates
• Investigation may be more difficult without follow-up questions
• Protection under PIDA may not apply
• We encourage confidential (not anonymous) reporting where possible

Limits to Confidentiality

We may need to disclose your identity:

• If required by law or court order
• To police or regulatory authorities
• During disciplinary or legal proceedings
• If you agree to be a witness

We will discuss this with you before disclosing your identity.

Protection from Retaliation

Non-Retaliation Policy

We will not tolerate any form of retaliation against anyone who:

• Raises a genuine concern in good faith
• Provides information during an investigation
• Refuses to participate in wrongdoing

What is Retaliation?

Retaliation includes:

• Dismissal or disciplinary action
• Demotion or denial of promotion
• Reduction in pay or benefits
• Exclusion from training or opportunities
• Bullying, harassment, or intimidation
• Negative performance reviews
• Social exclusion or ostracism

Reporting Retaliation

If you experience retaliation:

• Report it immediately to senior management
• It will be investigated as a serious matter
• Those responsible will face disciplinary action
• You may have legal remedies under PIDA

False Allegations

This policy is for genuine concerns raised in good faith. Making deliberately false or malicious allegations will:

• Not be protected under this policy
• May result in disciplinary action
• Could lead to legal action for defamation

However, if your concern is not substantiated after investigation, you will not face any penalty if you raised it in good faith.

Support for Whistleblowers

We recognize that raising concerns can be stressful. Support available includes:

• Confidential discussions with HR or senior management
• Employee Assistance Programme - Counseling and support services
• Legal information - Guidance on your rights
• Flexible working - If needed during investigation
• Witness support - If you participate in proceedings

External Reporting

In some circumstances, you may report concerns to external bodies:

Prescribed Regulators

Depending on the concern, you may contact:

• Health and Safety Executive (HSE): Health and safety matters
• Environment Agency: Environmental concerns
• Financial Conduct Authority (FCA): Financial services misconduct
• Information Commissioner’s Office (ICO): Data protection breaches
• Equality and Human Rights Commission: Discrimination issues
• Companies House: Company law breaches

Legal Advisors

You can seek advice from:

• Solicitor or barrister
• Citizens Advice Bureau
• Trade union representative
• Professional body or association

Serious Matters

For serious concerns, you may contact:

• Police: Criminal matters
• Serious Fraud Office: Fraud and corruption
• National Crime Agency: Organized crime, human trafficking
• HM Revenue & Customs: Tax fraud

Independent Charity

• Protect (formerly Public Concern at Work): Independent whistleblowing charity
• Free and confidential advice line: 020 3117 2520
• Website: www.protect-advice.org.uk

Media and MPs

Reporting to media or MPs is only protected in very limited circumstances when:

• You have already reported internally or to a regulator
• You reasonably believe you will be victimized
• You reasonably believe evidence will be concealed or destroyed
• The matter is exceptionally serious
• The disclosure is reasonable in all circumstances

Seek legal advice before making public disclosures to ensure you remain protected.

Responsibilities

Senior Management

• Create a culture where concerns can be raised safely
• Ensure this policy is communicated and accessible
• Treat all disclosures seriously and investigate thoroughly
• Protect whistleblowers from retaliation
• Take appropriate action based on findings

Managers

• Be approachable and listen to concerns
• Escalate serious matters appropriately
• Support employees who raise concerns
• Never retaliate or allow retaliation
• Maintain confidentiality

All Employees

• Raise concerns about wrongdoing
• Cooperate with investigations
• Maintain confidentiality
• Support colleagues who raise concerns
• Report any retaliation

Record Keeping

We maintain records of:

• All whistleblowing disclosures received
• Investigation processes and findings
• Actions taken
• Outcomes and lessons learned
• Retaliation allegations and responses

Records are kept confidentially and securely for at least 6 years.

Training and Awareness

We provide:

• Induction training explaining this policy
• Manager training on handling disclosures
• Regular reminders about whistleblowing procedures
• Updates when policy changes

Monitoring and Review

We will:

• Monitor the number and nature of disclosures
• Review handling of cases for lessons learned
• Assess effectiveness of protections
• Report anonymized statistics to senior management
• Review this policy annually

Contact Information

To raise a concern or seek advice:

• Email: info@worldoftextiles.com (mark “Confidential - Whistleblowing”)
• Telephone: +44 1234 567 890
• Write to: Senior Management Team, World of Textiles UK LTD

External support:

• Protect (Whistleblowing Charity): 020 3117 2520
• ACAS Helpline: 0300 123 1100
• Citizens Advice: www.citizensadvice.org.uk

Commitment

We are committed to:

• Maintaining the highest ethical standards
• Encouraging a culture of openness
• Investigating concerns thoroughly and fairly
• Protecting those who raise legitimate concerns
• Taking appropriate action on substantiated issues
• Learning and improving from disclosures

Speak up. We’ll listen. We’ll act.

Approved by: Board of Directors Policy Owner: Senior Management Next Review Date: December 2026