BTC Code of Conduct and Ethics Booklet V5.0 Page 31 of 33 Dec 2023 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 BTC nor should it be used to reconsider any matters which have already been addressed under harassment, complaint, disciplinary or other procedures. Once the "whistleblowing” procedures are in place, it is reasonable to expect staff to use them rather than air their complaints outside BTC. 2. SCOPE This policy is designed to enable employees of BTC to raise concerns internally and at a high level and to disclose information which the individual believes shows malpractice or impropriety. 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 statutes • Dangers to Health & Safety or the environment • Criminal activity • Improper conduct or unethical behaviour • Attempts to conceal any of these 3. SAFEGUARDS 3.1 Protection This policy is designed to offer protection to those employees of BTC 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. 3.2 Confidentiality BTC 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 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. 3.3 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:
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