# 17.21 Whistleblowing Policy
## Purpose
This policy provides a framework for employees to raise concerns about wrongdoing, malpractice, or dangers in the workplace in a safe and confidential manner, without fear of retaliation. Little Coffee Bean Co is committed to maintaining the highest standards of honesty, openness, and accountability.
## Scope
This policy applies to all employees, workers, contractors, agency staff, volunteers, and franchisees of Little Coffee Bean Co across all locations (mobile Tuk Tuks and fixed shops).
## Policy Statement
Little Coffee Bean Co encourages employees to speak up about genuine concerns regarding:
– Criminal offences or breaches of legal obligations
– Miscarriages of justice
– Dangers to health and safety
– Damage to the environment
– Financial fraud or mismanagement
– Concealment of any of the above
All disclosures will be treated seriously, investigated appropriately, and handled confidentially. No employee will suffer detriment or dismissal for raising a genuine concern in good faith.
## Procedures
### 17.21.1 What Concerns Can Be Raised
Employees may raise concerns about:
– Fraud, theft, or financial irregularities
– Health and safety violations
– Food safety breaches
– Discrimination or harassment
– Breach of company policies or legal requirements
– Unethical conduct
– Deliberate concealment of information about any of the above
### 17.21.2 How to Raise a Concern
**Step 1: Informal Reporting**
– Raise the concern with your immediate manager or location lead
– If the concern involves your manager, approach the Area Manager or Director
**Step 2: Formal Reporting**
If informal reporting is inappropriate or unsuccessful:
– Submit a written report to Dan Kane (Director) via email or sealed letter
– Include: nature of concern, names/dates/locations, evidence or information, previous actions taken
– Mark correspondence “Confidential – Whistleblowing”
**Step 3: External Reporting**
If internal channels are inappropriate or have failed:
– Contact a prescribed person or body (e.g., HSE, FSA, ICO, local authority)
– Seek advice from Public Concern at Work (independent whistleblowing charity)
– In exceptional cases, report to police or media (legal advice recommended)
### 17.21.3 Investigation Process
– All concerns will be acknowledged within 5 working days
– The Director or appointed investigator will assess the concern and determine appropriate action
– Investigation may include interviews, document review, and site visits
– The whistleblower will be kept informed of progress (subject to confidentiality and legal constraints)
– Investigation will be completed within 30 working days where possible
– Outcome and actions will be communicated to the whistleblower
### 17.21.4 Confidentiality and Anonymity
– The identity of the whistleblower will be kept confidential wherever possible
– Anonymous reports will be accepted and investigated where sufficient detail is provided
– Information will only be shared on a need-to-know basis
– If identity must be disclosed (e.g., legal proceedings), the whistleblower will be informed in advance
### 17.21.5 Protection from Retaliation
– No employee will suffer dismissal, disciplinary action, threats, or disadvantage for raising a genuine concern
– Any retaliation against a whistleblower will be treated as serious misconduct
– Employees who retaliate may face disciplinary action up to and including dismissal
– Whistleblowers who suffer detriment may raise a grievance under the Grievance Procedure
### 17.21.6 False or Malicious Allegations
– Employees who raise concerns in good faith will be protected, even if the concern is not substantiated
– Deliberately false or malicious allegations will be treated as misconduct and may result in disciplinary action
### 17.21.7 Record Keeping
– All whistleblowing reports and investigations will be documented
– Records will be stored securely and confidentially
– Records will be retained in accordance with data protection requirements
– Anonymous reporting statistics will be reviewed annually
## Responsibilities
### All Employees
– Raise genuine concerns about wrongdoing promptly
– Act in good faith when making disclosures
– Cooperate with investigations
– Maintain confidentiality during investigations
– Support colleagues who raise concerns
### Managers and Location Leads
– Receive and escalate whistleblowing concerns appropriately
– Ensure no retaliation against whistleblowers
– Support investigations as required
– Maintain confidentiality
– Foster a culture of openness and transparency
### Director (Dan Kane)
– Oversee the whistleblowing process
– Ensure concerns are investigated appropriately
– Protect whistleblowers from detriment
– Report serious concerns to authorities where required
– Review policy effectiveness annually
– Maintain whistleblowing records
## Compliance and Legal Framework
This policy complies with:
– **Public Interest Disclosure Act 1998 (PIDA)** – legal protection for whistleblowers
– **Employment Rights Act 1996** – protection from detriment and unfair dismissal
– **Enterprise and Regulatory Reform Act 2013** – public interest test for protected disclosures
– **Health and Safety at Work Act 1974** – duty to report safety concerns
– **Food Safety Act 1990** – duty to report food safety issues
– **Data Protection Act 2018 / UK GDPR** – confidentiality and data handling
– **ACAS guidance** – whistleblowing best practice
## Related Documents
– 17.3 Disciplinary Procedure
– 17.4 Grievance Procedure
– 17.6 Anti-Harassment and Bullying Policy
– 17.2 Health and Safety Policy
– 17.5 Data Protection and Privacy Policy
– Staff Handbook
– Code of Conduct
## Review
– **Policy Owner:** Dan Kane (Director)
– **Review Frequency:** Annually
– **Next Review Date:** October 2026
– **Version:** 2.0
– **Last Updated:** October 2025
– **Approved By:** Dan Kane, Director