Good Innovation is committed to maintaining the highest standards of integrity, ethics, and accountability in all aspects of our business, including our relationships with clients and suppliers.
This Whistleblowing Policy provides a framework for employees and others to raise concerns about potential wrongdoing or malpractice, both within Good Innovation and involving our clients and suppliers.
This includes any concerns related to harassment, including sexual harassment. We recognise that reporting sexual harassment can be particularly difficult, and we assure individuals that such reports will be treated with the utmost seriousness and sensitivity.
We value transparency and encourage open communication. This policy ensures that those who report concerns in good faith will be protected from retaliation.
This Whistleblowing Policy is available to all employees, contractors, consultants, and others acting on behalf of Good Innovation. It should be read in conjunction with our Respect at Work Policy, which provides detailed information on what constitutes harassment, including sexual harassment.
This Whistleblowing Policy will be reviewed and updated periodically to ensure its effectiveness and compliance with applicable laws and regulations.
The purpose of this policy is to:
Provide a confidential and accessible process for reporting concerns about potential wrongdoing.
Protect individuals who report concerns from any form of reprisal or victimization.
Ensure that all concerns are investigated thoroughly and fairly.
Promote a culture of openness and accountability within Good Innovation and throughout our business relationships.
Facilitate the reporting of harassment, including sexual harassment, and ensure these reports are addressed appropriately.
This policy applies to all employees, contractors, consultants, and anyone acting on behalf of Good Innovation. It also covers concerns relating to our clients and suppliers. Concerns can be raised about any of the following, including but not limited to:
Illegal activities
Fraud, bribery, or corruption
Financial irregularities
Health and safety violations
Environmental damage
Discrimination or harassment, including sexual harassment
Breaches of our Code of Conduct
Unethical behaviour by clients or suppliers
Any other serious malpractice or wrongdoing
We encourage individuals to raise concerns as soon as possible after becoming aware of them. Concerns should be reported through one of the following channels:
Directly to Andrew Bathgate: This is the preferred initial point of contact. Andrew will provide a safe space to voice concerns and will ensure they are taken seriously.
Alternative Contact Persons: If the concern involves Andrew, or if an individual is uncomfortable reporting to him, they may contact another Partner
Anonymous Reporting: Where permitted by law, reports can be made anonymously. However, it is helpful to provide contact details if possible, to allow for follow-up questions.
External Reporting (if appropriate and permissible): In certain circumstances, and where permitted by law, concerns may be reported to an external regulatory body or authority.
If a reported concern does not qualify as a whistleblowing issue under this policy, Andrew will provide the stakeholder with a formal written rationale explaining why it wasn't accepted and suggest the most appropriate course of action.
All reports will be treated with confidentiality to the extent possible and permissible by law. We will make every effort to protect the identity of individuals who report concerns in good faith, including ensuring data is protected. The investigator will conduct a baseline risk assessment to ensure the reporter's role or standing is safeguarded during the process.
There will be no retaliation or victimisation against anyone who reports a concern, even if the concern turns out to be unsubstantiated. Any form of retaliation will be treated as gross misconduct and will be subject to serious disciplinary action, up to and including summary dismissal.
All reported concerns will be investigated thoroughly, impartially, and in a timely manner. We will acknowledge receipt of a report within 7 business days and aim to complete the initial assessment and communicate next steps within 30 business days
The investigation will be conducted by Andrew Bathgate or another appropriate individual/team, as determined by Good Innovation.
All stages of the investigation, including findings and actions taken, will be documented and retained securely, including interview notes. We aim to resolve all concerns promptly and within a reasonable timeframe as outlined above. However, the complexity of the investigation may impact the exact duration.
If the initial investigation does not lead to a satisfactory resolution, the concern can be escalated to Kevin.
If the concern relates to a client or a supplier, the following process will be followed:
Assessment: Andrew (or the assigned investigator) will assess the nature of the concern and determine the appropriate course of action.
Client's Whistleblowing Route: If the client has a designated whistleblowing procedure, Andrew will guide and support the individual who raised the concern in following that procedure. This may involve helping them understand the client's process, preparing any necessary documentation, or accompanying them to meetings if appropriate.
Raising with the Client (If No Formal Procedure): If the client does not have a clear whistleblowing procedure, Andrew will work with the individual to determine the best way to raise the concern directly with the client. This will be done in a manner that protects the individual's identity and minimizes the risk of retaliation, to the extent possible and permissible by law and the agreement with the client.
Internal Investigation (If Applicable): If the client-related concern also involves internal issues within Good Innovation (e.g., a Good Innovation employee facilitating the client's wrongdoing), an internal investigation will be conducted concurrently.
Reporting and Action: The findings of the investigation, whether internal or related to a client, will be reported to the appropriate level of management. Appropriate action will be taken, which may include disciplinary action, process changes, or reporting to external authorities as necessary.
Andrew will support the individual throughout this process, providing guidance, advice, and a safe space for them to express their concerns and ask questions.
We will provide feedback to the individual who reported the concern, where possible and appropriate, about the outcome of the investigation and any actions taken. However, due to confidentiality reasons, we may not be able to provide full details of the investigation or disciplinary actions taken. While respecting confidentiality, we will communicate status updates at key milestones as well as the general outcomes of investigations to the reporting individual, as appropriate.
While we encourage reporting in good faith, this policy should not be used to make false or malicious allegations. Individuals who make knowingly false or malicious reports may be subject to disciplinary action.