Group Speak Up Policy

1. What is Speak Up?

Speak Up is the name of the CFO Centre’s Whistleblowing Programme.

2. Purpose of this Speak Up Policy

The guiding principles of this Policy are (a) to encourage you to report suspected or potential unlawful, unethical or otherwise improper conduct that could be harmful to the CFO Centre and its stakeholders, and (b) to reassure you that you can raise genuine concerns without fear of reprisals.

This Policy does not form part of or vary any contract of employment or agreement to provide services and we may amend it at any time. For the avoidance of doubt, this Policy is not intended to vary the independent status of any Principal, Regional Partner or Country Leader.

3. Who can Speak Up?

This Policy covers all CFO Centre staff and business partners, including: employees; officers; consultants; contractors; casual workers; agency workers; interns; volunteers; students; suppliers; visitors to any CFO Centre site and third parties who provide services for and on behalf of the CFO Centre (including Principals, Regional Partners and Country Leaders).

4. When you should Speak Up

You should Speak Up when you see, hear, or become aware of any behaviour or business practice, related to CFO Centre’s business, that is illegal, unethical, dangerous or amounts to malpractice.

Examples of when to Speak Up could include:

• Danger to health and safety
• Breach of internal policy
• Fraud
• Data and Privacy violations
• Miscarriages of justice
• Money Laundering
• Facilitating Tax evasion
• Bribery or corruption
• Bullying and/or Harassment
• Damage to the environment

Note that there is a difference between whistleblowing (Speak Up) and raising a grievance:

• whistleblowing is where an individual has a concern about a danger or illegality that has a public interest aspect to it, for example because it threatens customers, third parties or the public generally; but
• a grievance is a complaint that generally relates to an individual’s own employment position or personal circumstances at work.

This Policy does not set out the procedure that applies to general grievances. If you have a complaint about your own personal circumstances, then you should use the CFO Centre’s Grievance Procedure.

5. When not to use this Speak Up procedure

FDs/CFOs performing services to CFO Centre clients may encounter illegal or unethical business practices within a client. This might include suspected bribery, money laundering or tax evasion. In these instances, you must contact the Group’s CFO, Nevil Durrant ([email protected]) as in some jurisdictions (including the UK), local laws require us to make reports where there is a suspicion of tax evasion or money laundering.

6. How can you Speak Up?

Internal Reporting Channels

CFO Centre Group staff concerned about any form of malpractice covered by this Policy, should raise Speak Up issues with their Functional Lead. Principals, Regional Partners and Country Leaders should raise any issues with either the UK CEO (for UK matters) or the Group CEO (for ROW matters).

Alternatively, Speak Up issues can be emailed to [email protected]. This email address is administered by the Group CFO Nevil Durrant ([email protected]), and the Head of Legal, Toby Parkes ([email protected]).

If either the Group CFO or Group Head of Legal are implicated or otherwise involved in the subject matter of the Speak Up report, you should send your Speak Up report to the UK CEO, Jamie Mills ([email protected]) (for UK matters) or the Group CEO, Sara Daw ([email protected]) (for ROW matters).

External Reporting Channels

If, due to exceptional circumstances, you feel you cannot raise your concerns internally and you reasonably believe the information and any allegations are substantially true, the law may recognise that it would be appropriate for you to raise the matter with another prescribed person, such as a regulatory authority, law enforcement agency, or other external body, in accordance with any relevant law or regulation applicable in your jurisdiction. In The UK for example, the relevant regulator is the ICEAW, whose details can be found at paragraph 10 of this Policy.

All concerns that are reported through any of the Speak Up channels are protected under this Policy. However, if you report externally, only certain reports will qualify for protection under local law or regulation. If your report qualifies as a matter of public interest, you will gain the protections afforded under the local public interest disclosure laws. Those protections include confidentiality, and immunity from criminal and civil liability or disciplinary action. You will also receive protection from detrimental action in reprisal for making a disclosure to the appropriate authorities.

We strongly encourage any individual to seek appropriate advice before reporting a concern to anyone external.

7. What happens after your Speak Up?

We are committed to ensuring that all disclosures raised will be dealt with appropriately, consistently, fairly and professionally. We will arrange a meeting as soon possible to discuss the concern raised. You may bring a colleague to any meeting that takes place. The companion must respect the confidentiality of the disclosure and any subsequent investigation. We may ask you for further information about the concern raised, either at this meeting or at a later stage.

After the meeting, we will decide how to respond. Usually this will involve making internal enquiries first, but it may be necessary to carry out an investigation at a later stage which may be formal or informal depending on the nature of the concern raised. External investigators may be brought in where necessary. We will endeavour to complete investigations within a reasonable time.

We will keep you informed of the progress of the investigation carried out and when it is completed, and give you an indication of timings for any actions or next steps that we will take, but we cannot inform you of any matters which would infringe any duty of confidentiality owed to others.

8. Confidentiality, anonymity and non-retaliation

Confidentiality

All concerns raised will be treated in confidence and every effort will be made not to reveal your identity if that is your wish. If disciplinary or other proceedings follow the investigation, it may not be possible to take action as a result of a disclosure without your help, so you may be asked to come forward as a witness. If you agree to this, you will be offered advice and support.

Anonymity

Although a concern may be raised anonymously, we encourage you give your name when reporting your concern whenever possible. If this is not done, it will be much more difficult for us to protect your position or to give feedback on the outcome of investigations. Concerns that are expressed completely anonymously are also much less powerful and are difficult to investigate.

Non retaliation

CFO Centre operate a non-retaliation Policy when a genuine concern has been reported in good faith. No action will be taken against you if you report concerns, even it is found that there was no wrongdoing or unlawful conduct. In many countries in which we operate, the local law may protect you if you raise certain serious concerns through a process like Speak Up.

9. Responsibilities of the Functional Lead

If you are a Functional Lead or have staff reporting directly to you, it is your responsibility to become familiar with this Policy and facilitate the reporting of any Speak Up concerns raised by members of your team. You are not expected or advised to raise complaints for or on behalf of your direct reports, but instead should encourage and facilitate the individual to Speak Up using the appropriate Speak Up channels set out in this Policy. You must make your direct reports aware of this Policy.

10. Further information and contacts

If you have any queries about the application of this Policy, please contact the Group Head of Legal ([email protected]) or Group CFO ([email protected]) in the first instance.

Relevant regulators may include:
ICAEW The Business Centre Chartered Accountants’ Hall One Moorgate Place London EC2R 6EA
Helpline: +44 (0)1908 248 250 Email: [email protected]