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Whistleblowing Policy

1. Purpose

1.1 This policy is designed to provide a clear process for reporting concerns about wrongdoing or misconduct within the Agena Group. The Agena Group are committed to the highest standards of honesty and integrity, and we encourage all individuals – both inside and outside our organization – to report any genuine concerns they may have.

2. Scope

2.1 The policy applies to everyone who carries out work for the company, including employees, non-executive Directors, Contractors, and Agency employees.

3. What is Whistleblowing?

3.1 Whistleblowing is the reporting of a concern that is in the public interest. A concern qualifies if you reasonably believe it relates to serious wrongdoing, such as:

– Breaking the law,
– Not following legal rules,
– Causing a serious injustice,
– Putting someone’s health or safety at risk,
– Harming the environment, or
– Hiding any of the above.

3.2 These problems could have happened in the past, be happening now, or might happen in the future. The company will take any such concerns you raise seriously.

3.3 Personal grievances (e.g., bullying, harassment, or disputes with colleagues) should be raised through the Grievance Policy. If you raise a concern that does not meet the legal definition by mistake, a Manager will explain that it will be handled under this process instead.

4. Protection for Whistleblowers

4.1 The Employment Rights Act 1996 provides protection for workers who ‘blow the whistle’ where they reasonably believe that some form of illegality, injustice, or breach of health and safety has occurred or is likely to occur. The disclosure has to be “in the public interest”. We encourage you to use the procedure to raise any such concerns.

4.2 Concerns raised in good faith will never result in disciplinary action, even if the concern turns out to be incorrect. However, malicious or knowingly false allegations may lead to disciplinary action.

5. Procedure

5.1 All concerns may be raised via the following [LINK](#) with the option to remain anonymous.

5.2 We will acknowledge receipt within 5 working days, and an appropriate Manager will review the concern. We aim to complete the investigation and provide feedback (where appropriate) within 28 working days. We may involve external parties if required by law or best practice. Confidentiality will be maintained as far as possible during and after the investigation.

5.3 If you are not satisfied with the resolution, you can refer your complaint to the People Services department or a more senior employee.

5.4 External support is also available if you are not satisfied with how your complaint has been dealt with through the Advisory, Conciliation and Arbitration Service (Acas), the whistleblowing charity Protect.

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