Whistle blowing policy
The Croda Group has an established Code of Ethics which sets out the standards of conduct expected in the management of its business. All employees are expected to carry out their duties in a manner that is consistent with the Code. If employees become aware of circumstances which are not in compliance with the Code then they should communicate their suspicions using the “whistle blowing” policy explained below.
Whistle blowing – what is it?
The term “whistle blowing” is most commonly used to describe when an employee (or ex employee) discloses wrong doing within an organisation. Such wrong doing can include unlawful conduct, financial malpractice or dangers to the public or the environment. Public disclosure of confidential information about an organisation could clearly be a breach of an employee’s contract, therefore special arrangements are needed to protect both the employee and the organisation. It is important that the employee’s concerns about illegal or unethical activities can be raised without fear of victimisation and that the organisation is alerted to malpractice early so that it can be stopped and the perpetrators dealt with.
A whistle blowing procedure allows employees to raise concerns with management about the conduct of others which they consider to be in some way damaging to the organisation or others within it.
What types of issues are covered?
Wrongdoing can include:
Commission of a crime
Failure to comply with any legal obligation
A miscarriage of justice
A danger to health and safety
Damage to the environment
The deliberate concealment of information tending to show one of the above is occurring or likely to occur
It can also include:
Fraud and financial irregularities
Deliberate improper business conduct
But would not extend to mismanagement which may arise from error or incompetence. Nor does it include a personal grievance which should be pursued through your line managers in accordance with your local grievance procedure.
What do you do if you have a concern about wrongdoing?
Wherever possible concerns should be raised through line managers. Where it is believed that the line manager is the source of the malpractice or that a group of managers are colluding in the malpractice, then the concerns should be raised with a Divisional Director. In circumstances where Divisional Directors are implicated then the issue should be raised at group level. This would usually be to the President of the business sector of which your division forms part, but if you wish to raise the matter with someone independent of line management, contact can be made with either the Company Secretary or the Group Personnel Manager of Croda International Plc at Cowick Hall, Snaith, Goole, East Yorkshire DN14 9AA, telephone number 01405 860551.
What will happen to me if I raise a concern?
If you ask us to protect your identity by keeping your confidence, we will not disclose it without your consent. We will write down all the information you give so that you can agree that we have understood your concerns correctly. All legitimate concerns will be respected and investigated. You will receive feedback on the progress of investigations. However, given the fact that the investigation of concerns will vary depending upon their nature, no specific time scale can be set.
If you raise a genuine concern in good faith you will not be at risk of suffering any form of retribution as a result. Provided you are acting in good faith, it does not matter if you find you are mistaken.
What if I raise the concern anonymously?
It is very difficult to assess whether or not an anonymous letter is genuine or malicious. Consequently, whilst we will consider an anonymous report we will not start an investigation.