Purpose:
ENVY is committed to high standards of ethical corporate behaviour towards our colleagues, stakeholders, and wider clients. This Policy sets out our commitments to encouraging and facilitating the raising of concerns relating to malpractice or misconduct within, or involving ENVY, or any of its related companies and third parties. The Policy sets out the channels via which you can raise concerns responsibly and effectively. ENVY is committed to addressing any reported concerns promptly, fairly, and confidentially.
How it is applied at ENVY:
This Policy applies not only to employees of ENVY, but also to individuals on work experience, freelancers, shareholders, external clients and to any others acting on behalf of or working with ENVY such as suppliers. References in this Policy to individuals raising a grievance in certain circumstances apply to ENVY employees only.
However, if you are a freelancer working on behalf of ENVY, please follow the procedures detailed in your contract regarding your complaint’s procedure.
Why should you raise a concern:
Whistleblowing is all about prevention and that is our priority. As such, if something is troubling you here at ENVY and you think we should be made aware or require us to investigate, we would strongly encourage you to raise it at the earliest opportunity. If we don’t know about it, we can’t fix it, and this is something we would like to avoid. Please remember that although you need to have a reasonable belief that malpractice has been, is being or is likely to be committed, you do not need to have firm evidence of malpractice to raise a concern.
Examples of whistleblowing:
This is a non-exhaustive list:
- Malpractice, fraud, bribery, or corruption
- Duty of care concerns
- Failure to comply with a legal, compliance or regulatory obligation
- Other criminal offences or illegal acts (including fraud)
- Miscarriage of justice
- Serious misuse or abuse of authority
- Concerns regarding widespread racism, discrimination, or sexual harassment, potentially affecting multiple individuals
- Improper conduct or unethical behaviour or behaviours which are not in accordance with our values
- Safeguarding or modern slavery
- Accounting, auditing matters or financial reporting practices
- Breach of the Company policies
- Concealment of information relating to any of the above
How to raise a concern:
If you feel able to raise your concern openly with your line manager, then this is the best course of action. However, if you feel unable to raise the matter with your line manager, or you think they have not properly addressed your concern, please speak directly to HR. In addition, any addressed concerns can be raised confidentially and anonymously.
How a concern will be handled:
Once you have raised your concern, ENVY will assess this; particularly, which internal team should handle it; and what action is appropriate. This may involve an informal review, an internal enquiry, or a more formal investigation. We aim to acknowledge your concern within seven days of receipt. Either at that time, or shortly thereafter. From this, you will be told who will be handling your concern, how you can contact them, and what further assistance may be needed from you.
Please note, if you ask, we will write to you summarising your concern and setting out how we propose to handle it. We may not be able to tell you how long any investigation will take, but we will try to ensure that you are kept up date.
When you raise the concern, it will be helpful to know how you think the matter might be resolved. If you have a personal interest in the matter, but we do ask that you tell us this at the outset. If we think your concern falls more properly within other ENVY procedures, we will tell you.
Where possible ENVY will give you feedback on the outcome of any investigation. Please note that we will not be able to tell you about disciplinary, or other action, when it would infringe a duty of confidence ENVY owes to another person.
Whilst ENVY cannot guarantee that we will respond to all matters in the way that you might wish, we will try to handle any such concern fairly and appropriately, considering our responsibilities to the individual who raised the concern and any individuals against whom a concern is raised.
ENVY ensures:
Confidentiality: Your identity will be kept confidential. Your identity will not be disclosed to anyone beyond the team responsible for assessing and/or investigating the matter without your consent unless we are required to do so by law or to meet our regulatory or professional obligations.
Non-retaliation: ENVY will not tolerate retaliation of any sort (including threats of retaliation) against an individual for raising a concern, making a report, or assisting in an (internal or external) investigation. Anyone who knowingly conceals wrongdoing, or attempts to victimise, harass, or deter a person raising a concern, will face appropriate disciplinary action by ENVY.
Fair Assessment: Once you have raised your concern, ENVY will assess it and consider what action is appropriate. This may involve an informal review, an internal enquiry, or a more formal investigation. However, in some cases, it may not be appropriate or possible for ENVY to investigate itself, in which case alternative guidance may be given. Wherever possible, once the review, enquiry or investigation has been completed, feedback will be provided to the individual who raised the concern.
Anonymity: As set out in this policy, it is your choice whether you wish to close your identity, therefore, we will not do so without your consent, unless required by law.
Training:
At ENVY we offer training to all staff on the key arrangements of the policy. However, more specifically to our line-managers we provide training on their whistleblowing responsibilities, such as providing guidance confidently to workers and ensuring they are committed to creating an open culture where disclosures are welcome.
Non-Whistleblowing Agreements:
You should not use this following policy if:
- Report events presenting an immediate threat to life or property. Please use your local emergency procedures instead.
- Report any grievances or personal employment issues you may have in relation to your personal terms of employment; these should be escalated within the company you work for. This includes disputes about pay, hours or conditions in the workplace, which you should raise with your employer through their own internal procedures.
- Settle personal or legal disputes.
- Make accusations which you know are false. Doing so may lead to disciplinary measures.
Available resources:
ENVY is committed to good governance and fully endorses the principle of accountability. Although you do not need to raise your concerns with ENVY before contacting an external party, we would however encourage any concerns to be raised with us first.
Nevertheless, if a concern about malpractice cannot be resolved within ENVY, there are the following available resources to you:
- EAP Service – short-term counselling and referral services for employees. Find more information here.
- The Film & TV Charity – these specialise in providing support to people with two or more years’ experience working in film and television, covering a wide range of issues, including bullying and harassment, legal advice, and debt. More information can be found at their website here.
- The Equality & Human Rights Commission – this is an independent statutory body with the responsibility to encourage equality and diversity, eliminate unlawful discrimination, and protect and promote the human rights of everyone in the UK. You can find guidance on discrimination and human rights on their website here.
- Ofcom – UK whistleblowing legislation related to and regulates the media sector. Further information can be found on their website here.
How whistleblowing is communicated at ENVY:
At ENVY our policies are documented on our internal website for all our employees to view and the information is also shared with any new joiners in our induction process.
Changes to this policy:
ENVY ensures that their policies are up to date. As such, this Policy may change from time to time with or without notice. The latest version of this Policy will be available to you if you may require it.
It is your responsibility as an employee to read and keep up to date with the requirements, procedures and other matters always set out in the latest version of this Policy.