Whistleblower Policy

At Influencer, we are committed to doing the right thing, and that includes creating a culture where concerns can be raised safely and with confidence. We want all employees to feel empowered to speak up about any potential wrongdoing, and to know that they’ll be supported if they do.

This policy sets out how to raise a concern, what happens next, and the protections available to anyone who ‘blows the whistle’.

What is Whistleblowing:

Whistleblowing is when you report something you’ve seen or heard at work that you reasonably believe is wrongdoing and in the public interest. This could include:

• Criminal activity
• Breach of legal obligations
• A miscarriage of justice
• Endangering someone’s health and safety
• Environmental damage or
• Deliberate cover-up of any of the above

It can relate to something that has happened, is happening, or is likely to happen in the future.

Whistleblowing is different from raising a personal complaint or concern about your own treatment, for example, bullying or harassment. These should be raised under our Grievance Policy, unless the issue affects others and is in the public interest. “In the public interest” means it has to also affect others. For example other workers, customers or the general public.

Who is protected:

If you raise a qualifying concern in good faith, you are protected by law under the Public Interest Disclosure Act 1998, even if the concern turns out to be unfounded.

This protection applies if you are an employee, worker, agency worker, or apprentice, even if you have since left the organisation. However, it does not apply if:

• You’re self-employed or a volunteer
• You commit a criminal offence while making the disclosure (e.g. hacking)
• The disclosure breaches legal professional privilege (e.g. solicitors sharing client
  information)

How to raise a concern:

We encourage you to speak up as soon as you reasonably believe there is a concern.

In the first instance, you can raise your concern with your line manager. If it is not appropriate to do so (for example, if the concern involves them), you can speak directly to the People Team by emailing people.inbox@influencer.com.

You’re encouraged to put your concern in writing. This helps create a clear record. When raising a concern, try to include:

• A description of the issue
• Any relevant facts, dates, or names
• Whether you’ve spoken to anyone else about it
• Any supporting documents, if available

In order to raise a concern, you do not have to have evidence of the malpractice, but must have a reasonable belief that the malpractice has occurred.

What happens next:

Once your concern is received, it is the responsibility of Influencer to investigate the issue. This will include discussions with you and then assessing what further action or investigation is required.

All concerns raised under this procedure, regardless of their nature, will be treated seriously and sensitively. Where practicable, immediate steps will be taken to remedy the situation. However, depending on the nature of the issue that has been raised, it may take a period of time to fully investigate the matter.

After the investigation is complete, we’ll share the outcome with you (where appropriate), though in some cases we may be limited by confidentiality.

Where no action is taken, a full explanation will be given. The Company will also consider future action to minimise the risk of reoccurrence wherever possible.

Employee protection:

The company will not tolerate harassment or victimisation of anyone who raises a concern under this procedure, regardless of whether or not the concern proves to be well founded.

Employees should not be discouraged from raising concerns due to actual or possible pressure from other work colleagues, employees or management. Discouraging another to come forward with a concern is a disciplinary offence and will be dealt with under the Disciplinary Procedure.

Employees are further protected under legislation against being dismissed or being subject to
some other detriment because they have raised a concern about possible malpractice.

Raising concerns externally:

We always encourage concerns to be raised internally first, but we understand that in some cases you may feel more comfortable speaking to an independent organisation.

You can contact Protect, the UK’s leading whistleblowing charity, for free and confidential advice.

Protect – Independent Whistleblowing Advice
Contact number - 020 3117 2520
www.protect-advice.org.uk

Please speak with a member of the People Team should you have any questions about this policy.