What is Whistleblowing?
Whistleblowing occurs when a worker raises a concern or discloses information
which relates to wrongdoing, illegal practices or unethical conduct which has come to his/her attention through work.
Our whistle-blowing policy is intended to encourage and enable workers to raise
concerns within our workplace rather than overlooking a problem or “blowing the
whistle” externally. Under this policy a worker is entitled to raise concerns or disclose
information without fear of penalisation or threat of less favourable treatment,
discrimination or disadvantage.
Our Commitment
DPD is committed to maintaining an open culture with the highest standards of
honesty and accountability where our workers can report any concerns in confidence.
Who does the policy apply to
This policy applies to all employees and persons engaged by, or who interface with
DPD Ireland, without exception, including contractors, sub-contractors, ODF’s,
agency staff and customers.
It is important to note that should you have a concern in relation to your own
employment or personal circumstances in the workplace it should be dealt with by
way of our Grievance Procedure. Likewise concerns arising in regard to workplace
relationships should generally be dealt with through our Dignity at Work policy.
It is also important to note that this policy does not replace any legal reporting or
disclosure requirements. Where statutory reporting requirements and procedures
exist, these must be complied with fully.
Aims of the Policy
● To encourage you to feel confident and safe in raising concerns and disclosing information
● To provide avenues for you to raise concerns in confidence and receive feedback on any action taken
● To ensure that you receive a response where possible to your concerns and information disclosed
● To reassure you that you will be protected from penalisation or any threat of penalisation
What types of concerns can be raised?
A concern or disclosure should relate to a relevant wrongdoing such as possible
fraud, crime, danger or failure to comply with any legal obligation which has come to
your attention in connection with your employment and about which you have a
reasonable belief of wrongdoing.
What types of concerns should not be raised under this Procedure?
A personal concern, for example a grievance around your own contract of
employment would not be regarded as a whistleblowing concern and would be more
appropriately processed through our Grievance Procedure.
Safeguards and Penalisation
A worker who makes a disclosure and has a reasonable belief of wrongdoing will not
be penalised by this organisation, even if the concerns or disclosure turn out to be
unfounded.
Penalisation includes suspension/dismissal, disciplinary action, demotion,
discrimination, threats or other unfavourable treatment arising from raising a concern
or making a disclosure on the basis of reasonable belief for doing so. If you believe
that you are being subjected to penalisation as a result of making a disclosure under
this procedure, you should inform the Ethics Officer immediately.
Workers who penalise or retaliate against those who have raised concerns under
this policy will be subject to disciplinary action.
Workers are not expected to prove the truth of an allegation. However, they must
have a reasonable belief that there are grounds for their concern. It should be noted
that appropriate disciplinary action may be taken against any worker who is found to
have raised a concern or raised a disclosure with malicious intent.
Confidentiality
DPD is committed to protecting the identity of the worker raising a concern and
ensures that relevant disclosures are treated in confidence. The focus will be on the
wrongdoing rather than the person making the disclosure.
However, there are circumstances, as outlined in the Act, where confidentiality
cannot be maintained particularly in a situation where the worker is participating in
an investigation into the matter being disclosed. Should such a situation arise, we
will make every effort to inform the worker that his/her identity may be disclosed.
Procedure - Raising a Concern
Who should you raise your concern with?
As a first step, appropriate concerns should be raised with your immediate
manager or their superior. However, should you not wish to use this route, for
example given the seriousness and sensitivity of the issues involved, you should
approach senior management.
Alternatively, if you feel it is not appropriate to raise your concerns with Senior
Management, you can contact Safecall, an independent provider of outsourced
Whistleblowing Services. The service can be reached free of charge and is available 24 hours a day, 365 days a year. Concerns can be reported by Telephone on 1800
812 740 or via a dedicated portal www.safecall.co.uk/report.
How to raise a concern?
Concerns may be raised verbally or in writing to your supervisor, manager, Senior
Management and/ or Safecall as is appropriate in the circumstances. Should you
raise a concern verbally we will keep a written record of our conversation and
provide you with a copy after the meeting. Should you raise a concern in writing we
would ask you to give the background and history of the concern, giving relevant
details, insofar as is possible, such as dates, sequence of events and description of
circumstances.
If you wish to raise your concern anonymously you should inform supervisor,
manager, Senior Management and/ or Safecall of this when making the disclosure. In
such cases every care will be taken to ensure that your identity is protected and all
potential meetings or contact made with you regarding your disclosure will take this
into consideration.
The earlier you express the concern the easier it will be for us to deal with the matter
quickly.
Having raised your concern with us, we will arrange a meeting to discuss the matter
with you on a strictly confidential basis. We will need to clarify at this point if the
concern is appropriate to this procedure or is a matter more appropriate to our other
procedures, for example our Grievance or Dignity in the Workplace procedures. You
can choose whether or not you want to be accompanied by a colleague or a trade
union representative.
In regard to confidentiality, it is important that there should be an awareness of
respecting sensitive company information, which while unrelated to the disclosure,
may be disclosed in the course of a consultation or investigation process.
Support for Whistle-blowers
Once a disclosure has been made, you will be contacted by the COO (or duly
appointed persons by the COO) who will be your main contact and update you on
matters relating to the disclosure.
If you feel you have been subjected to victimisation or detrimental treatment
regarding a disclosure you have made, contact the COO (or persons duly appointed
by the COO) immediately. Anyone who victimises or retaliates against those who
have raised concerns will be subject to investigation and any appropriate action
taken.
How we will deal with your disclosure
Having met with you in regard to your concern and clarified that the matter is in fact
appropriate to this procedure, we will carry out an initial assessment to examine what
actions we need to take to deal with the matter. This may involve simply clarifying certain matters, clearing up misunderstandings or resolving the matter by agreed
action without the need for an investigation.
If, on foot of the initial assessment, we conclude that there are grounds for concern
that cannot be dealt with at this point, we will conduct an investigation which will be
carried out fairly and objectively. The form and scope of the investigation will depend
on the subject matter of the disclosure.
Disclosures may, in the light of the seriousness of the matters raised, be referred
immediately to the appropriate authorities. Likewise, if urgent action is required (for
example to remove a health and safety hazard), this action will be taken.
It is important to us that you feel assured that a disclosure made by you under this
policy is taken seriously and that you are kept informed of steps being taken by us in
response to your disclosure. In this regard we undertake to communicate with you as
follows:
We will acknowledge receipt of your disclosure and arrange to meet with you as
outlined above;
We will inform you of how we propose to investigate the matter and keep you
informed of actions, where possible, in that regard including the outcome of any
investigation, and, should it be the case, why no further investigation will take place.
However, it is important to note that sometimes the need for confidentiality and legal
considerations may prevent us from giving you specific details of an investigation.
We will inform you of the likely time scales in regard to each of the steps being taken
but in any event we commit to dealing with the matter as quickly as practicable.
It is possible that in the course of an investigation you may be asked to clarify certain
matters. To maximise confidentiality such a meeting can take place off site and you
can choose whether or not to be accompanied by a colleague or trade union
representative.
Where a concern is raised or a disclosure is made in accordance with this policy, but
the allegation is subsequently not upheld by an investigation, no action will be taken
against the worker making the disclosure and the worker will be protected against
any penalisation. It is important to note that if an unfounded allegation is found to
have been with malicious intent, then disciplinary action may be taken.
How the matter can be taken further
The aim of this Policy is to provide an avenue within this workplace to deal with
concerns or disclosures in regard to wrongdoing. We are confident that issues can
be dealt with “in house” and we strongly encourage workers to report such concerns
internally.
We acknowledge that there may be circumstances where an employee wants to
make a disclosure externally, and the legislation governing disclosures — The
Protected Disclosures Act 2014 — provides for a number of avenues in this
regard.
It is important to note however that while you need only have a reasonable belief as
to wrong doing to make a disclosure internally, if you are considering an external
disclosure, different and potentially more onerous obligations apply depending on to
whom the disclosure is made.
Communication, Monitoring and Review
This policy will be communicated as appropriate and will be subject to regular
monitoring and review in consultation with our workforce and their representative.
CG Doc No. 1 Issue 3.0
Issue date: 28th February 2025
Revision date: 15th January 2028
Documented by: Steven Thacker
Approved: Patricia Lennon