Whistleblower policy

Introduction

Dynaudio is committed to the highest standards of openness, probity and accountability.

An important aspect of accountability and transparency is a mechanism to enable staff, other members of the Company or an external partner to voice concerns in a responsible and effective manner. It is a fundamental term of every contract of employment and external partnership that an employee or an external partner will faithfully serve his or her employer or partner and not disclose confidential information about the employer’s or partner’s affairs.

Nevertheless, where an individual discovers information which they believe shows serious malpractice or wrongdoing within the organisation, then this information should be disclosed internally without fear of reprisal, and there should be arrangements to enable this to be done independently of line management (although in relatively minor instances the line manager would be the appropriate person to be told).

It should be emphasised that this policy is intended to assist individuals who believe they have discovered malpractice or impropriety. It is not designed to question financial or business decisions taken by the Company nor should it be used to reconsider any matters, which have already been addressed under harassment, complaint, disciplinary or other procedures.

Scope of Policy

The purpose of this Policy is to provide Dynaudio employees and external stakeholders with communication channels that will allow them to raise concerns in confidence, and anonymously if desired, without fear of reprisals or retaliation of any kind. Employees or external stakeholders who believe improper practices or questionable acts have or will occur in connection with Dynaudio are encouraged to report them.

This policy is intended to cover concerns, which are in the public interest and may at least initially be investigated separately but might then lead to the invocation of other procedures e.g. disciplinary. These concerns could include:

  • Financial malpractice or impropriety or fraud.
  • Failure to comply with a legal obligation or Local Legislation.
  • Dangers to Health & Safety or the environment.
  • Criminal activity.
  • Improper conduct or unethical behaviour, e.g. harassment, violence, and threats.
  • Attempts to conceal any of these.

Safeguards

Protection
This policy is designed to offer protection to those employees of Dynaudio or external stakeholders who disclose such concerns provided the disclosure is made:

  • in good faith.
  • in the reasonable belief of the individual making the disclosure that it tends to show malpractice or impropriety and if they make the disclosure to an appropriate person (see below). It is important to note that no protection from internal disciplinary procedures is offered to those who choose not to use the procedure. In an extreme case, malicious or wild allegations could give rise to legal action on the part of the persons complained about.

Confidentiality
Dynaudio will treat all such disclosures in a confidential and sensitive manner. The identity of the individual making the allegation may be kept confidential so long as it does not hinder any investigation. However, the investigation process may reveal the source of the information and the individual making the disclosure may need to provide a statement as part of possible legal actions.

Anonymous Allegations
This policy encourages individuals to put their name to any disclosures they make. Concerns expressed anonymously are much less credible, but they may be considered at the discretion of the Company. In exercising this discretion, the factors to be taken into account will include:

  • the seriousness of the issues raised.
  • the credibility of the concern.
  • the likelihood of confirming the allegation from attributable sources.

Untrue Allegations
If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. In making a disclosure the individual should exercise due care to ensure the accuracy of the information. If, however, an individual makes malicious allegations as part of harassment, and particularly if he or she persists with making them, disciplinary action may be taken against that individual.

Procedures for Making a Disclosure

Dynaudio employees and external stakeholders can ‘whistle-blow’ by using the confidential form on our website www.dynaudio.com/whistleblower or by contacting HR at HQ in person.

The primary Whistleblower-caretaker and Investigating Officer is Director of HR.

On receipt of a complaint of malpractice, the person who receives and takes note of the complaint, must pass this information as soon as is reasonably possible, to the appropriate designated Investigating Officer.

Please note the following about HR handling whistleblowing:

  • Complaints of malpractice will be investigated by the Director of HR unless the complaint is against the Director of HR or is in any way related to the actions of the Director of HR. In such cases, the complaint will be passed to the CEO for referral.
  • In the case of a complaint, which is in any way connected to but not against the Director of HR, the CEO will nominate a Senior Manager or an external party to investigate the allegations.
  • If there is evidence of criminal activity then the Director of HR should inform the CEO and the police. The Company will ensure that any internal investigation does not hinder a formal police investigation.

Timescales

Due to the varied nature of these sorts of complaints, which may involve internal / external investigators and / or the police, it is not possible to lay down precise timescales for such investigations. The investigating officer should ensure that the investigations are undertaken as quickly as possible without affecting the quality and depth of those investigations.

The investigating officer, should as soon as practically possible, send a written acknowledgement of the concern to the complainant and thereafter report back to them the outcome of the investigation and on the action that is proposed.

Investigating Procedure

The Investigating Officer should follow these steps in reporting a complaint:

  • Obtain full details and clarifications of the complaint.
  • Inform the member of staff against whom the complaint is made as soon as is practically possible. The member of staff will be informed of their right to be accompanied by a shop steward or work colleague at any future interview held under the provision of these procedures. At the discretion of the investigating officer and dependant on the circumstances of the complaint, an alternative representative may be allowed e.g. the individual’s legal representative.
  • Investigate the allegations fully - with the assistance where appropriate of other individuals/bodies.
  • Make a judgement concerning the complaint and validity of the complaint. This judgement will be detailed in a written report containing the findings of the investigations and reasons for the judgement. The report will be passed to the Chief Executive Officer as appropriate.

The Chief Executive Officer will then decide what action to take. If the complaint is shown to be justified, then the Company will invoke the disciplinary or other appropriate Company procedures.

The complainant should be kept informed of the progress of the investigations and, if appropriate, of the final outcome.

If appropriate, a copy of the outcomes will be used to enable a review of Company procedures.

If the complainant is not satisfied that their concern is being properly dealt with by our Director of HR, the complainant has the right to raise it in confidence with the Chief Executive Officer, or any other member of the Corporate Management Team.