Whistleblower policy

Articulate is committed to operating in an ethical way and we expect our employees and other stakeholders to do the same. This policy explains how you can report things that are wrong, illegal or dishonest.

 

Introduction

Articulate Marketing is committed to operating ethically and transparently. We expect our employees and all other stakeholders to do the same.

This policy provides all stakeholders (including employees, contractors, suppliers, customers, community members, and business partners) with a clear framework for reporting serious issues such as misconduct, illegal activities, and/or violations of company policies, ensuring their protection from retaliation.

Objective

This policy explains how you can report serious issues that are wrong, illegal or dishonest. A serious issue constitutes any act or omission that could:

  • Violate of laws or regulations
  • Endanger public health, safety or the environment
  • Involve fraud, theft, bribery or corruption
  • Constitute harassment, discrimination, or bullying
  • Breaches of company policies, including ethical and financial conduct
  • Any other major unethical behaviour with implications for the environment or society

Anonymous reports will be considered based on

  • The seriousness of the issue raised
  • The credibility of the report
  • The ability to verify the report from other sources

Do not use the policy for:

  • Personal grievances.
  • False allegations.

Abuse of the policy may be grounds for disciplinary action.

Scope

This policy applies to all stakeholders both internal and external, including:

  • Internal: employees (including workers, agency staff, trainees and managers
  • External: suppliers, business partners, customers, community members

Separate mechanisms are provided for internal and external stakeholders to ensure tailored approaches to reporting and addressing concerns.

How to blow the whistle

For internal stakeholders

Internal reporting: concerns can be reported to the CEO, the CFO or the Head of People via email, a Slack private message, or telephone.

Anonymous reporting: submit a report via this link.

Please note that it is a condition of working for Articulate that you do not speak or write to representatives of the press, TV, radio, or to any other third party about concerns and issues without the express and prior authority of the CEO. Care must be taken to ensure that nothing is done that could give rise to legal action (e.g. for slander or libel) or damage Articulate’s reputation.

For external stakeholders

Anonymous reporting: Use this grievance form.

Direct reporting: email grievances@articulatemarketing.com

External reporting: if internal mechanisms are not feasible or safe, external stakeholders can report to external bodies such as regulatory authorities or seek guidance from independent third-party whistleblower protection organisations.

Before making your complaint either as an internal or external stakeholder, you may find it helpful to note the following:

  • The nature of your concern (eg theft, bullying).
  • Why you think it should be reported.
  • Who was involved. Do not approach or accuse anyone directly.
  • When and where it happened
  • Times and dates when it may have happened.
  • Details of any evidence.
  • Has any action already been taken by anyone?
  • Details of any witnesses.

We will investigate your concerns. We may get help, if required, from other people.

We encourage you to raise your concerns internally in the first instance as we provide a safe, independent route within Articulate. As a last resort, if you feel you need outside advice, you may consider contacting the following external agencies which are able to provide support:

  • Everyone in Articulate, including the CEO, is subject to the same standards. If you have concerns or issues relating to the CEO, you can speak to our Head of People, or the CFO.
  • Public Concern at Work is a charity that provides a free and strictly confidential legal helpline to anyone in the UK concerned about malpractice which threatens the public interest.
  • You may also raise suspicions of criminal wrongdoing directly with the police or any prescribed person.

If you seek advice outside Articulate, you are reminded that you must ensure that you do not disclose confidential information or that your disclosure is protected by privilege. You can check with Public Concern at Work, which will also advise on ways to proceed.

Anonymity

We encourage you to identify yourself. Anonymity means that we can’t give you any feedback and it also makes investigating a problem more difficult. We will, however, consider anonymous reports according to:

  • The seriousness of the issues raised.
  • The credibility of the report.
  • Our ability to confirm the report from attributable sources.

Who is covered by this? Workers, agency staff, trainees and employees.

Privacy

We will respect your privacy if you raise a concern in good faith. There may be instances where it becomes necessary to reveal the source of information and a statement may be required as part of the evidence (for example, for disciplinary proceedings or to mount a prosecution). In such an event we will support you throughout the process.

We will not tolerate harassment or victimisation and will take action to protect you when you raise a concern in good faith.

Investigations process

  1. Acknowledgement: all reports will be acknowledged within 3 business days of receipt
  2. Preliminary review: reports will be assessed to determine their validity and whether they constitute a serious issue as defined in this policy
  3. Investigation: A thorough and impartial investigation will be conducted. This may involve interviews, review of evidence and collaboration with legal or regulatory experts
  4. Resolution: The investigation's outcomes will be communicated to the whistleblower, where possible, within 30 business days.
  5. Follow up: measures will be taken to address any identified issues, and disciplinary action will be enforced where necessary.

Mechanisms to ensure Whistleblower protection

To safeguard good faith whistleblowers, Articulate commits to the following:

  • Confidentiality: Information shared will remain confidential to the extent possible except where disclosure is required by law or to conduct an investigation.
  • Consent: whistleblowers will be informed of who needs to be involved and their consent will be sought before sharing information with additional parties.
  • Support: the company may offer whistleblowers appropriate support, including legal or counselling services.
  • Independent oversight: an independent third party may be engaged to assess risks and ensure the fairness of the process.
  • Monitoring and feedback: whistleblowers will be updated on the status of their report and any outcomes whilst maintaining confidentiality.

Employees who ‘whistle blow’ are protected by the Public Interest Disclosure Act 1998. If you know, or suspect, that some wrongdoing is occurring within the Company, you should raise the matter immediately with the CEO, CFO or HR.

Consequences for retaliation

If retaliation against a whistleblower is identified:

  1. Immediate disciplinary action will be taken against the individuals responsible
  2. The whistleblower will be provided with additional support and protections to prevent further harm

Training and awareness

  1. All employees and managers will receive regular training on whistleblower protections, anti-retaliation policies and the grievance process.
  2. Awareness campaigns will be conducted to ensure stakeholders understand their rights and the mechanisms available to raise concerns.

Policy update

We will review this policy at least once a year and it may be updated at any time.