Employee Concern Policy

(Protected Disclosures)

Document Classification Document Ref Dated Document Owner
Internal & External Use HR-DOC-A07-06 06/12/2023 Lucy Dodd

Revision History

Version Date Revision Author Summary of Changes
1 2019/08/26 Debs Danbury Document Creation


Name Title
All Employees All Employees
Contracted Stakeholders Contractors, sub contractors, apprentices, non-exec members, volunteers and other 3rd party individuals contracted to Zenitech
Zenitech Website External parties to Zenitech


Name Position Email Approval Date
Christopher Lacy-Hulbert Director 12 December 2023


Here at Zenitech, we are committed to the highest standards of ethical and business conduct. Raising an employee concern is one of the most effective ways of preventing and eliminating wrongdoing in the workplace.

We recognise that raising a concern can be daunting. However, we encourage you to report concerns internally as soon as possible where you suspect wrongdoing. We are here to listen and will take all concerns that you raise seriously.

This policy sets out the procedure for raising an employee concern, how we will handle any reports received and the support and protection that is available to you when you do so.

This policy does not form part of your contract of employment and we reserve the right to amend or withdraw it at any time in part or in full.


This policy applies to:

  • all employees and workers employed by us, or previously employed by us
  • any natural person working as, or under the direction or supervision of, a contractor or sub-contractor engaged under contract with us, or previously engaged by us
  • any apprentice, intern, paid or unpaid trainee, volunteer, private entrepreneur or those whoare self-employed engaged under contract with us, or previously engaged by us
  • any person who has entered into a pre-contractual relationship with us
  • those who hold an ownership interest in any of our group companies, including our investors and non-executive members

It relates to any concern in the public interest, meaning the wrongdoing has to affect other people, such as co-workers, customers, suppliers or the general public. It covers a wide range of values and principles relating to the public good, or what is in the best interests of society (up to and including material or serious violations of legal activity).

If your concern relates to a personal grievance that is not in the public interest (for example, an allegation of bullying or harassment, or an allegation that your contract of employment has been breached or not fulfilled, or a breach of any other internal policy that is not in the public interest), you should raise it under your local regions’ separate grievance procedure.

If you are unsure about whether your concerns are best dealt with under the employee concern policy or grievance procedure, please speak to your local People Team for further advice.

Legislation which regulates this policy

Individuals are protected from suffering any detriment for reporting a concern in the public interest as follows:

  • In the UK, protection is afforded by the Employment Rights Act 1996 (as amended by the Public Interest Disclosure Act 1998)
  • In Lithuania, Hungary and Romania member states have adopted the protections provided in the scope of the European Union Whistleblower Directive (2019/1937)

Employee concerns to which this policy relates

Raising an employee concern under this policy is the reporting of suspected wrongdoing or risk of wrongdoing relating to (not an exhaustive list):

  • a criminal offence – eg, offering a bribe or other fraudulent activity
  • a failure to comply with a legal obligation – eg, neglecting a duty of care
  • a miscarriage of justice – eg, terminating an employee unfairly for raising a concern
  • a risk to the health and safety of an individual or the public – eg, serving contaminated food
  • damage to the environment – eg, a company polluting a local river
  • obstruction or improperly attempting to influence the investigations of any authority (eg, police, courts)
  • financing illegal activities – eg, illegal or non-transparent use of public funds/assets
  • other suspected activities which may constitute illegal or serious misconduct
  • concealing or attempting to cover up any of the above.

It is not necessary for you to prove the wrongdoing. However, to be protected by the laws against detrimental treatment or dismissal, you must reasonably believe that wrongdoing is being, has been, or is likely to be committed and that your disclosure is in the public interest.

Any knowingly false or vexatious allegations made by an employee with the intent of doing harm to another person or the company’s reputation will be grounds for disciplinary action, up to and including dismissal by the company.

Stage 1 - Raising a concern

If you have a genuine concern relating to any type of wrongdoing that is covered under this policy, you should raise your concern with your regional Head of People in confidence.

You can raise your concern orally, or in writing. We recommend that you use our Form to raise an employee concern and then email your concern in confidence to your regional Head of People (their details can be found on our People Platform, HiBob).

If you are not an employee, you may use the same form in order to raise your concern. You can either email this to the local Head of People, or post a copy to the address below.

Whilst we would encourage you to provide your contact details, you may of course raise your concern anonymously, you would need to do this in writing and post it to our Group Head Office in the UK at Zenitech Limited, 4th Floor, 18 St Cross Street, London EC1N 8UN addressed to the Chief People Officer.

It is important that you set out clearly:

  • the details of the suspected wrongdoing;
  • the names of any individuals involved; and
  • and what action (if any) you are seeking.

In some cases, it may be necessary to ask you to attend a meeting to clarify the nature of your concern. This will be arranged as soon as possible. You may, if you wish, bring a colleague or where applicable, a trade union representative with you to the meeting. Where it is considered appropriate, a member of the People Team may also be present and also a note-taker.

If such a meeting is necessary, we will take complete and accurate minutes and ensure that personal data is processed confidentially and in accordance with any data protection rules that apply.

Please note: If you are raising your concern in Hungary, we acknowledge the extended provisions for external persons in Hungarian Law under the Complaints Act.

Please click here for an additional Schedule to this policy.

Stage 2 - Responding to your employee concern

We will acknowledge any concern raised under this policy within 7 working days of receipt.

The regional Head of People will decide if an investigation is required and, if it is, the most appropriate person to conduct it. This will be the investigating manager.

If no investigation is required, we will put the reasons why we feel no action is needed to you in writing within 10 working days.

Stage 3 - Investigation

The investigating manager will write to you confirming that they are conducting an investigation and the timescale for completion.

The purpose of the investigation is to establish whether the suspected wrongdoing actually took place. The nature of the wrongdoing may require the investigating manager to involve external parties (legal advisors, auditors or other forms of consultant) but only to the extent necessary for the investigation.

We aim to complete all investigations within a maximum of 30 days of acknowledgement, however the level of investigation, and time this will take, will vary depending on the nature of the suspected wrongdoing.

Depending on the nature of the suspected wrongdoing, we may also at this stage need to inform the Executive Board.

Stage 4 - Decision

After consideration of the evidence from the investigation, the investigating manager will inform you in writing of the outcome and any next steps or action that will be taken within 7 working days. While we aim to provide you with comprehensive feedback, in some cases this may not be possible, for example where data protection rules apply or there are sensitive issues that need to remain confidential.

Our decision may include one or more of the following actions:

  • reporting the suspected wrongdoing to the relevant external authorities (eg. police, environmental agencies, courts etc)
  • taking appropriate disciplinary action with the person suspected of the wrongdoing internally
  • discontinuing the investigation if insufficient evidence of the suspected wrongdoing can be established
  • discontinuing the investigation if it is determined the wrongdoing is not covered by this policy

Stage 5 - Consequences and sanctions

Based on the results of the investigation and decision taken, we will determine any sanctions or corrective actions that need to be taken as a consequence of the wrongdoing.

Any employee who is responsible, in part or in full, for the wrongdoing may face disciplinary action up to and including dismissal for gross misconduct. Depending on the nature of the wrongdoing, the individual may also be subject to legal or civil penalties.

For other persons, the sanction will depend on the nature of the connection between our company and that person at the time of the wrongdoing, and the severity of the wrongdoing.

In the unlikely event that you do not receive any reply from the company, or the company has not taken any action in response to information about suspected wrongdoing, you have the right to apply directly to the relevant authority in your region (see below).

Stage 6 - Appeal

If you are not satisfied with how your concern has been dealt with, you should appeal to your Regional Director or the Global Head of People Operations. It must not be the same person who handled the original concern.

Your appeal must be made in writing. It is important that you set out clearly the grounds of your appeal, i.e. the basis on which you consider that your original concern has not been satisfactorily dealt with.

In some cases, it may be necessary to ask you to attend a meeting to clarify the nature of your appeal. This will be arranged as soon as possible. You may, if you wish, bring a colleague or where applicable, a trade union representative with you to the meeting. Where it is considered appropriate, a member of the People Team may also be present.

We will consider the grounds for your appeal and review the way your original disclosure was handled. You will be informed in writing of the outcome as quickly as possible, but no later than 30 days from when you submitted your appeal.

Confidentiality and anonymity

We want you to feel comfortable about raising an employee concern openly and actively encourage you to do so.

Where you raise an employee concern, we will maintain your confidentiality and anonymity as far as possible. If we need to identify you to anyone, we will notify you beforehand.

Any report or subsequent investigation are considered strictly confidential and will be handled as such by any person involved in dealing with your concern. We will maintain your anonymity as far as possible and if we need to identify you to anyone for a legitimate reason, we will notify you beforehand.

Personal Data

In relation to this policy, we may receive information on both the individual raising the concern and on other persons involved in the suspected wrongdoing, including sensitive data.

All information received according to this policy will be handled in accordance with data protection regulations applicable to the location of the suspected wrongdoing and in any event with Article 27 of the General Data Protection Regulation (EU/GDPR) 2016/679 of the European Parliament and Data Protection Act (2018) in the UK.

Our commitment to you

You have the right in law not to be subjected to any detrimental treatment (including being unfairly penalised, disciplined or dismissed) because you have raised an employee concern.

If you raise an employee concern in accordance with this policy, we will ensure that you are treated with respect and provided with adequate support and protection.

If you are told not to raise or pursue an employee concern, or you believe that you have been subjected to detrimental treatment because you have raised an employee concern, you should report the matter to your local Head of People. Alternatively, you can raise it under our grievance procedure.

Any behaviour that subjects an employee to detrimental treatment for raising a concern will not be tolerated and will be dealt with under our disciplinary procedure.

If we find that an individual has knowingly raised false allegations, this will also be treated as a disciplinary offence and will be dealt with under our disciplinary procedure.

Raising your employee concerns concerns externally

We encourage you to raise your employee concerns internally in the first instance. However, if you feel that appropriate action has not been taken, you should report the matter to the correct prescribed body or person.

UK – information on how to raise a protected disclosure is on GOV.UK

Hungary – Act XVV of the 2023 Complaints, Notifications of Public Interest and Rules for Reporting Abuse, known as the ‘Complaints Act’

Lithuania – Public Prosecutor’s Office of the Republic of Lithuania (Clause 4.4.4 of the Law on Protection of Whistleblowers)

Romania – Chapter IV, articles 12-17 from Law 361/2022 on the protection of whistleblowers in the public interest

The list of prescribed bodies or persons in your region is the best starting point to identify a regulator to disclose your concerns to. Prescribed bodies or persons are the regulators that the government has designated as responsible for hearing and dealing with whistleblowing concerns in their respective sectors.

It is easier to gain protection under whistleblowing laws if you raise your concerns to a prescribed body or persons, rather than to other external bodies such as the media. Only in very rare and exceptional circumstances will contacting the media be an appropriate way to resolve your concern.

The policy is updated and reviewed yearly as part of the continual improvement process.