Whistle blowing policy

Whistle Blowing Policies and Procedures 

1. Policy Statement 

The Group recognises that generally, incidents of workplace fraud or mismanagement are on the increase and it is committed to ensuring that any such malpractice is immediately dealt with if it should arise. Employees are often the first to realise that something is wrong in the workplace but they may feel that they cannot express their concerns because it  would be disloyal to their colleagues or to the company, or that they would be subjected to harassment or victimisation. 

The Group encourages employees to raise their concerns about any malpractice at the earliest possible stage and this policy and procedure sets out the correct method for raising such concerns. Because circumstances differ this policy and procedure sets out general principles as to how matters should be dealt with but confers to no contractual rights. Provided they follow the steps laid out in this policy and procedure, employees will be able to raise genuine concerns about malpractice within the Group without fear of harassment or victimisation. 

2. Scope 

This policy and procedures document covers Synergy Health plc and Group companies and is applicable to all employees. 

3. Definition 

For the purposes of this policy, the Group considers the following matters to be malpractice: 

3.1. The commission of a criminal offence; 

3.2. Contravention of the Bribery Act 2010; 

3.3. Failure to comply with a legal obligation; 

3.4. The occurrence of a miscarriage of justice; 

3.5. The endangerment of an individual’s or group of individual’s health and safety; 

3.6. The endangerment of the environment; 

3.7. The concealment of any information pointing to any of the above matters. 

4. Appropriate Representatives for Disclosure 

4.1. Employees should initially discuss any concerns with their immediate manager or supervisor who 

will attempt to resolve the matter as promptly as reasonably practicable. 

4.2. If this is not appropriate or if the employee reasonably considers that the manager/supervisor has 

not dealt with the concern sufficiently or at all, the employee may then raise the concern with the 

next highest level of management. 

4.3. If the employee is still dissatisfied with the decision or action taken, they should contact the Group 

Company Secretary.  He can be contacted by telephone 01332 386821 or by e-mail 

Whistle.Blowing@synergyhealthplc.com, who will either deal with the matter himself or designate an 

appropriate management representative. Whistle Blowing Policies and Procedures 

4.4. Any concerns will so far as reasonably practicable be dealt with in the strictest confidence at all 

times, although it must be recognized that in certain circumstances it will be difficult for the company 

to pursue a complaint or to tackle an alleged wrongdoer without the complainant’s identity becoming 

known or to refrain from pursuing an issue raised by a complainant in order merely to respect his or 

her request for confidentiality. 

5. Disclosure 

The person hearing the complaint will arrange a confidential interview with the employee and may 

require the employee to detail the concern in writing beforehand. The concern will then be discussed in 

full at the interview and the person hearing the complaint will decide if any further action needs to be 

taken and if so, what. This may include requiring the employee to attend a further interview with a higher 

level of management and to provide any further evidence deemed necessary. A note of the decision will 

be provided to the employee and any such note is to be treated as strictly confidential by the employee.

6. Further Steps 

6.1. If the concern raised is found to be valid and is not already the subject of an internal investigation or 

legal proceedings, a decision will be taken by the Group as to how to proceed which may include 

referral of the matter: 

  • ƒ to the Board of Directors with a view to internal investigation 
  • ƒ to an appropriate external regulatory body for investigation 
  • ƒ to the police 
  • ƒ of the employee to the grievance procedure 

6.2. The employee will be informed of any decision taken and the employee is required to keep this 

decision strictly confidential. 

7. External Disclosure 

7.1. If the employee has followed this procedure and is genuinely and reasonably dissatisfied with the 

outcome, the employee may raise the concern confidentially with any appropriate regulatory 

authority, the police or a Member of Parliament. The employee must inform the original 

manager/supervisor/next highest level of management before taking this action. 

7.2. The employee may also take this action if they have reasonable grounds for belief that all of the management consulted are or were involved in the malpractice which they have alleged or that they 

will be subjected to a detriment if they raise the matter internally. 

7.3. The rules covering external disclosure do not  apply for the purpose of taking confidential legal 

advice from a professionally qualified lawyer. 

8. Protection from Victimisation 

The Company confirms that, provided the employee raises the concern about malpractice in accordance 

with the terms of this policy, in good faith and not out of any malice or with a view to personal gain and 

has reasonable grounds for the belief in the concern: 

8.1. so far as reasonably practicable, the employee’s identity will not be disclosed at any time, unless 

necessary for the purposes of the investigation or to comply with a legal obligation; 

8.2. the employee will not be subjected to any harassment, victimisation or disciplinary action as a result 

of raising the concern, provided he/she has complied in full with this policy; Whistle Blowing Policies and Procedures 

8.3. so far as reasonably practicable any supporting evidence relating to the concern will be kept secure 

at all times. 

If at any time it is discovered that the employee has raised a concern maliciously, not in good faith or with a view to personal gain or that he/she has breached the terms of this policy, the employee will lose the protection under this policy and will be subject to disciplinary action under the Group’s disciplinary procedure. 



You are contacting:

Synergy Health Americas Home Office

Synergy Health Americas
12425 Race Track Road
Tampa FL 33626

Telephone:+1 (813) 891-9550


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