VM MARINE INTERNATIONAL LIMITED
Whistleblowing Policy
- Purpose
- Scope
- Policy/Statement
- in accordance with the procedures laid down
- in good faith, and
- in the reasonable belief of the individual making the disclosure that it tends to show malpractice.
- Associated Comments
- Responsibilities
VM Marine is committed to the highest standards of openness, probity and accountability, and expects its employees to report any knowledge or genuine suspicion of any impropriety within the Group.
This policy sets out arrangements for individuals to raise serious concerns about malpractice or wrongdoing in ways which will protect them from reprisal. Similarly, this policy would become relevant if concerns raised with management are not satisfactorily resolved.
This statement applies to VM Marine Group and all of its subsidiaries.
It is intended to cover concerns which are in the public interest. These might include:
- Breach of Company’s Code of Business Principles and Policies.
- Financial malpractice or fraud.
- Failure to comply with a legal obligation.
- Dangers to health and safety or the environment.
- Criminal activity.
- Miscarriage of justice.
- Improper conduct or unethical behaviour.
- Attempts to conceal any of the above.
This is not intended to be a comprehensive list and any matters raised under this policy will be considered seriously.
Normally any such concern about a workplace situation should be raised with the employee's immediate manager or some more senior level of management. However, it is recognised that because of the seriousness and sensitivity of some issues, together with the knowledge of who the employee thinks may be involved in wrongdoing, this may be difficult or even impossible.
This policy sets out arrangements for individuals to raise serious concerns about malpractice or wrongdoing in ways which will protect them from reprisal. Similarly, this policy would become relevant if concerns raised with management are not satisfactorily resolved.
Protection
This policy is designed to offer protection to those employees who disclose such concerns provided the disclosure is made:
Confidentiality
The Company will treat all such disclosures in a sensitive manner. The identity of the individual making the allegation may be kept confidential so long as it does not hinder or frustrate 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 the evidence required.
Anonymous Allegations
This policy encourages individuals to put their name to any disclosures they make because appropriate follow-up questions and investigation may not be possible unless the source of information is identified. Concerns expressed anonymously are much less powerful, but they will not be ignored particularly where they have credibility, raise serious issues and can be confirmed from reliable alternative 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. If, however, the investigation shows that an individual has made malicious or vexatious allegations, and particularly if he or she persists with making them, disciplinary action may be taken against the individual concerned.
Procedures for Making a Disclosure
The disclosure may be made to any of the Head of Departments, the Directors or the Audit Committee members.
It is the responsibility of the VM Marine employees at each business location to ensure compliance with this statement.
Promulgated on 21 Apr 2013