The MCG Group is committed to conducting its business with honesty and integrity and aims to achieve the highest possible standards of service and ethical standards in all of its practices.
We expect all staff to maintain the same high standards however, all organisations face the risk of things going wrong and sometimes malpractice and wrongdoing can take place. We take malpractice and wrongdoing very seriously and aim to prevent and eliminate any wrongdoing or malpractice within the organisation.
We therefore encourage all staff to raise any concerns they may have about malpractice or wrongdoing within the organisation freely and without fear of suffering a detriment or dismissal to enable us to eliminate and prevent wrongdoing or malpractice within the organisation.
We will treat any concerns raised seriously and will protect and support any individual who makes a disclosure in line with this policy. MCG predominantly operates within the UK and subject to the UK legislation pertaining to Whistleblowing.
However, following the departure from the EU the introduction of the EU directive for Whistleblowing may also be applicable to our global businesses under the RPI group so we will operate a consistent approach across the global company and apply the best practices under the EU directive. This policy does not form part of any contract and we reserve the right to amend this policy at any time without prior notice.
Who Can Raise a Concern Under this Policy
This policy applies to all current and former employees, workers, officers, consultants, contractors of our business, including home workers, trainees, apprentices, agency workers, casual workers and limited company contractors.
No qualifying length of service is required in order to raise a concern under this policy.
When to Use this Policy
This policy should be used to report concerns of malpractice or wrongdoing in relation to our organisation’s activities where you have information which you reasonably believe tends to show one or more of the following:
It doesn’t matter if you are mistaken about your concern but you must have information that tends to show some malpractice or wrongdoing rather than an opinion or a feeling.
Disclosures That Are Not Covered by This Policy
You will not qualify for protection under this policy if you commit an offence in making the disclosure, or if you disclose a matter that is subject to legal, professional privilege (for example, correspondence between the MCG Group and our lawyers regarding a specific case).
If your concern relates to your own treatment as an employee of the MCGGroup, including personal circumstances at work, you should raise it under our grievance procedure instead, unless you reasonably believe that the matter is in the public interest.
If your concern relates to your own treatment or personal circumstances at work but you are not an employee of the MCG Group, you should use our complaints procedure instead of the grievance procedure.
Our complaints policy is available on request or on MCG Central for MCG Group employees.
If you wish to raise a concern of suspected malpractice or wrongdoing in relation to a client’s activities you may need to raise the concern directly with the client instead.
Any other concerns about our services generally which are not related to the types of wrongdoing or malpractice covered by this policy should be raised using our complaints policy instead.
How to Raise a Concern
Under the new EU directive, as the MCG Group has more than 50 employees there is need to have a formal internal reporting channel.
If you have any concerns of the types of malpractice or wrongdoing covered by this policy, you should in the first instance either
All concerns raised will be acknowledged within 7 days and feedback will also be provided within a reasonable timescale not exceeding 3 months.
If, for any reason, you feel that you cannot tell your immediate superior, or in the case of an agency worker the consultant responsible for managing your assignment, you should raise the issue with the MCG Group HR Department.
Doc No: POL19 Date: Jan 2024 Version No: 4 Page No: 4 Owner: HR Uncontrolled when printed If you have made a disclosure and are still concerned, or the matter is so serious that you feel you cannot discuss it with the person named above, you should raise the matter with the following member of management:
The MCG Group CEO.
You are not expected to prove the truth of your concern beyond reasonable doubt or provide any evidence; however, you will generally need to provide the following information as a minimum:
Any concerns you raise in line with this policy will be recorded
You can raise any concerns anonymously; however, we encourage you to give your name when reporting your concern wherever possible because it may be more difficult for us to protect your position or give you feedback on the outcome of investigations if you choose to remain anonymous.
You may wish to consider discussing your concern with a colleague before raising it formally under this policy. You can also choose to raise a concern under this policy alone or with a colleague; however, it is in the interests of all parties to maintain confidentiality once you have raised a formal concern.
How We Respond to Concerns Raised Under This Policy
We are committed to ensuring that all disclosures raised in accordance with this policy will be dealt with objectively, consistently, fairly and professionally.
In the interests of full transparency, matters will be investigated at Group level by Group resources such as CEO, COO, HR Director and Legal & Compliance Director even if the matter is reported with a Group Company.
All responses will be communicated from the Group Company in which the matter is raised. Whistleblowers must be notified as such as must approve this We will take the time to listen to any issues raised and arrange a meeting as soon possible to discuss your concern
You may bring a colleague (or trade union representative) to any meeting that takes place. The companion must respect the confidentiality of the disclosure and any subsequent investigation.
After the meeting, we will decide how to respond. This will usually involve making internal enquiries in the first instance, 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. We will endeavour to complete investigations within a reasonable time but will provide feedback within 3 months of raising the report.
We will keep you informed of the progress of the investigation as it is carried out and when it is completed, and give you an indication of the timescale for any actions or next steps that we may take. We cannot inform you of any matters that would breach any duty of confidentiality owed to others.
Doc No: POL19 Date: Jan 2024 Version No: 4 Page No: 5 Owner: HR Uncontrolled when printed We will consider any concerns raised anonymously at our discretion, taking into account factors such as the seriousness of the issue raised, the credibility of the concern and the likelihood of confirming the allegation from other sources. However, concerns that are expressed completely anonymously are much less powerful and are difficult to investigate. It may also be difficult for us to provide you with feedback if you cannot be contacted.
All concerns raised will be treated as confidential and every effort will be made not to reveal the identity of any individual who raises a concern. Unless the law requires otherwise, we will only make disclosures to third parties or other staff with your consent.
Raising Your Concern Externally (Exceptional Cases)
The main purpose of this policy is to give all our staff the opportunity and protection they need to raise concerns internally. We would expect that in almost all cases raising concerns internally would be the most appropriate course of action in order to resolve the issue.
GOV.UK website via the following link:
We strongly encourage individuals to seek appropriate advice before reporting a concern to an external person. Public Concern at Work is a leading independent charity whose main objective is to promote compliance with the law and good practice in the public, private and voluntary sectors. They are a source of further information and advice and operate a confidential helpline. ACAS also operate a free confidential helpline that you can contact for advice. The contact details for both organisations are set out in the information and contacts section below.
Protection and Support For This, Raising Concerns
We hope that all staff will feel able to voice their concerns freely under this policy.
The MCG Group is committed to good practice and high standards and to being supportive of staff who raise genuine concerns under this policy, even if they turn out to be mistaken.
Any individual raising a genuine concern must not suffer any detriment as a result of doing so. If you believe that you have suffered such treatment, you should inform The MCG Group HR department immediately.
The MCG Group will not tolerate any harassment or victimisation of individuals who raise concerns about wrongdoing or malpractice in the workplace. No member of staff may threaten or retaliate against an individual who has raised a concern. Any person involved in such conduct may be subject to disciplinary action and in some cases, will be liable to a claim for compensation brought against them personally.
To ensure the protection of all our staff and the integrity of our business, those who raise a concern frivolously, maliciously and/or for personal gain and/or make an allegation they do not reasonably believe to be true and/or
Further Information and Contracts
If you have any queries about the application of this policy, please contact the MCG Group Legal & Compliance department in the first instance or raise a ticket on email@example.com.
Public Concern at Work is a source of further information and advice. It also provides a free helpline offering confidential advice on 020 7404 6609.
Further information is available on their website at www.pcaw.co.uk.
If you are a member of a recognised trade union, you can also seek information and advice from your trade union representative.