Whistleblowing Policy
This Whistleblowing Policy provides a structured and secure way for employees, contractors, candidates, clients, suppliers, and other stakeholders to raise concerns about serious misconduct or wrongdoing without fear of reprisal. It supports our compliance with PIDA 1998, UK GDPR, Data Protection Act 2018, EU Whistleblower Protection Directive (2019/1937), and relevant industry regulations.
1. Purpose
Pro Contract Direct Limited is committed to maintaining the highest standards of honesty, integrity, transparency, and accountability in all of its operations, particularly in the provision of contractor recruitment, consultancy, and workforce solutions.
2. Scope
This policy applies to:
- All employees, directors, officers, agency staff, contractors, interns, and volunteers
- Recruitment candidates and placed workers
- Clients, vendors, partners, and service providers
- Any person interacting with the company who wishes to raise a concern
It covers reportable concerns across our operations, including:
- Recruitment Services: Discrimination, bribery, falsified credentials
- Consultancy: Conflicts of interest, misuse of client data, fraudulent practices
- General Business Conduct: Harassment, financial fraud, regulatory violations, health and safety breaches
3. Definitions
- Whistleblower: An individual who reports a concern in good faith.
- Reportable Concern: A reasonable belief that misconduct or a legal/ethical breach has occurred or is likely to occur.
- Retaliation: Any adverse action taken against a whistleblower, such as demotion, termination, or harassment.
4. Examples of Reportable Concerns
- Criminal activity (e.g., theft, bribery, fraud)
- Breaches of legal or regulatory obligations
- Breach of data protection or confidentiality protocols
- Falsification of time records or financial statements
- Health and safety risks or environmental hazards
- Discriminatory practices or abuse in recruitment
- Attempts to conceal wrongdoing
5. Reporting Channels
Primary Internal Channels:
- Whistleblowing Officer
Email: info@procontractdirect.com (mark correspondence “Attn: Whistleblowing Officer”)
Phone: 0203 983 7422
Postal: Suite 310e, East Wing, Sterling House, Langston Road, Loughton, IG10 3TS (mark correspondence “Attn: Whistleblowing Officer”)
Alternative Internal Contacts:
- Line Manager or Department Head
- Human Resources Department
- Data Protection Officer (for data-specific concerns)
External Reporting Options:
6. Investigation Process
- Acknowledgement: Concerns will be acknowledged within 48 hours.
- Initial Review: To determine the credibility and scope of the concern.
- Investigation: Led by an impartial investigator, which may involve:
- Interviews with involved parties
- Examination of documentation, logs, and evidence
- Forensic analysis, if relevant
- Timeline:
- Minor issues resolved within 15 working days
- Complex cases updated every 30 days until closed
- Outcome: A written report summarising findings, corrective action, and lessons learned. All investigations conducted with discretion, professionalism, and confidentiality.
7. Protection from Retaliation
- Retaliation may include: Demotion, dismissal, loss of benefits, harassment, bullying, denial of promotions or training.
- Protection Measures:
- Whistleblower’s identity kept confidential (unless legally required to disclose)
- Access to support resources (e.g., counselling, temporary job reassignment)
- Disciplinary action against those who retaliate
- Whistleblowers who feel victimised should contact HR or the Whistleblowing Officer immediately.
8. Confidentiality and Data Protection
- All whistleblowing reports are treated with the strictest confidentiality.
- Data is stored securely and only accessible by authorised personnel.
- Investigation details disclosed only on a need-to-know basis.
- All records retained in line with our data retention policy under UK GDPR.
