Wild Circle Dynamics LTD is committed to the highest standards of honesty, integrity, accountability and ethical behaviour. Our Speak Up Policy explains how employees, contractors, suppliers, customers and other stakeholders can raise concerns about wrongdoing, malpractice or unethical conduct in confidence and without fear of retaliation. This policy is designed to comply with the Public Interest Disclosure Act 1998, the Employment Rights Act 1996 and related UK whistleblowing law.
1. Purpose
The purpose of this policy is to:
- create a safe environment where concerns can be raised promptly;
- encourage early identification and resolution of wrongdoing or risk;
- protect individuals who raise concerns in good faith from retaliation, victimisation or discrimination;
- demonstrate our commitment to ethical conduct, legal compliance and continuous improvement;
- ensure that serious issues are escalated and investigated appropriately.
2. Scope
This policy applies to anyone who has a concern about conduct at Wild Circle Dynamics LTD, including:
- employees and directors;
- contractors, consultants, agency workers and freelancers;
- suppliers, vendors and business partners;
- customers and users of our services;
- members of the public who become aware of a concern.
3. What to report
You may report any concern that you reasonably believe is in the public interest. Examples include, but are not limited to:
- fraud, theft, bribery, corruption or financial misconduct;
- money laundering, terrorist financing or sanctions breaches;
- modern slavery, forced labour or human trafficking;
- breaches of data protection, privacy or information security;
- unauthorised access to systems, hacking or cyber security incidents;
- harassment, bullying, discrimination or victimisation;
- health and safety risks or failures;
- environmental damage or breaches of environmental law;
- serious breaches of our Terms & Conditions, Supplier Code of Conduct or other policies;
- miscarriages of justice, miscounting or false reporting;
- cover-ups of any of the above;
- any other illegal, unethical or unsafe conduct.
You do not need to be certain that wrongdoing has occurred. If you have a reasonable suspicion, you should raise it. Concerns raised maliciously or knowingly falsely may be dealt with under our disciplinary or contractual procedures.
4. How to report
Concerns should be raised as soon as possible after the relevant events come to your attention. You can report a concern by emailinginfo@wildcircledynamicsltd.com with the subject line "Speak Up". Please provide as much detail as possible, including:
- your name and contact details (unless you wish to remain anonymous);
- the nature of the concern and the individuals or departments involved;
- dates, times, locations and any relevant evidence or documents;
- any witnesses or other people who may have relevant information;
- whether you have raised the concern elsewhere and, if so, what happened.
If you are an employee, you may also raise the matter with your line manager or a director in the first instance. However, if you are not comfortable doing so, or if the concern involves senior management, you should use the Speak Up email channel.
5. Anonymous reporting
We understand that some individuals may prefer to remain anonymous. You may report concerns without providing your name or contact details. However, anonymous reports can be more difficult to investigate because we cannot ask follow-up questions or verify information. If you choose to remain anonymous, please provide as much detail and evidence as possible to allow us to assess the concern.
6. Confidentiality
We will treat all reports confidentially to the extent permitted by law. We will only share information with those who need to know in order to investigate and address the concern. This may include internal investigators, managers, legal advisers, human resources personnel and external regulators or law enforcement where necessary.
If you disclose your identity to us, we will not reveal it without your consent unless we are required to do so by law or it is necessary for the purposes of the investigation. In some circumstances, legal proceedings or regulatory investigations may make it impossible to maintain confidentiality.
7. No retaliation
Wild Circle Dynamics LTD prohibits retaliation, victimisation, harassment or discrimination against anyone who raises a concern in good faith, participates in an investigation, or supports another person in raising a concern. Retaliation is a serious matter and may result in disciplinary action, termination of contracts or legal action.
If you believe you have been subjected to retaliation as a result of raising a concern, please report this immediately using the same Speak Up channel.
8. Investigation process
All reports will be taken seriously and assessed promptly. The nominated officer or a designated investigator will:
- acknowledge receipt of the report within 5 business days where contact details are provided;
- assess whether the concern falls within the scope of this policy and whether it is appropriate to investigate;
- determine the appropriate investigation method, which may be internal, external or conducted by legal advisers;
- conduct the investigation fairly, impartially and confidentially;
- keep the person who raised the concern informed of progress where appropriate and where confidentiality allows;
- take corrective action where wrongdoing is found;
- provide feedback to the person who raised the concern, where possible.
The outcome will depend on the nature of the concern and the evidence available. Possible outcomes include dismissal of the concern without further action, informal resolution, disciplinary or contractual action, referral to law enforcement or regulators, or changes to policies and procedures.
9. Malicious or false reports
We recognise that raising a concern can be difficult and that not every concern will be substantiated. You will not face retaliation for raising a concern that is not upheld, provided it was made in good faith. However, if an investigation concludes that a report was made maliciously, knowingly falsely or with the intention of causing harm, we may take disciplinary or legal action against the person who made the report.
10. External reporting
We encourage you to raise concerns with us first so that we have the opportunity to investigate and resolve them. However, UK whistleblowing law protects workers who make disclosures to prescribed persons or bodies where certain conditions are met.
Depending on the nature of the concern, you may also report to external bodies such as:
- the police or Action Fraud for criminal matters;
- the Information Commissioner's Office (ICO) for data protection breaches;
- HM Revenue & Customs (HMRC) for tax or money laundering concerns;
- the National Crime Agency (NCA) for serious and organised crime;
- the Health and Safety Executive (HSE) for workplace safety concerns;
- the Competition and Markets Authority (CMA) for competition law issues;
- the Gangmasters and Labour Abuse Authority (GLAA) for labour exploitation;
- the Financial Conduct Authority (FCA) for regulated financial conduct matters.
In some circumstances, disclosures may also be protected if made to the media or Members of Parliament, but the legal tests for such disclosures are stricter.
11. Record keeping
We will keep records of Speak Up reports and investigations in accordance with our data retention policies and applicable law. Records will be stored securely and accessed only by those with a legitimate need to do so.
12. Monitoring and review
This policy will be reviewed at least annually and whenever there are significant changes in our business, legal obligations or risk environment. We will monitor the number and nature of reports received and use the information to identify trends, improve controls and update training.
13. Contact
If you have any questions about this Speak Up Policy or wish to raise a concern, please contact us:
Wild Circle Dynamics LTD
71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Company number: 17371923
Email: info@wildcircledynamicsltd.com