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Whistleblowing Procedure

Whistleblowing Procedure for Suppliers, their Employees and Contractors

Objective

This procedure is designed to enable Suppliers, contractors and Suppliers’ employees to report any suspicions about potential wrongdoing or malpractice on the part of West Brom staff.

The West Brom’s Statement

The West Brom confirms that no contractor or Supplier shall suffer as a consequence of bringing to WBBS’s attention, in good faith, a suspected or latent breach of this procedure. Furthermore, the West Brom confirms that Suppliers and contractors will suffer no contract withdrawal or loss of business for abiding by this procedure.

Scope

This procedure covers reporting of suspected malpractice, harassment or bullying perpetrated by staff, contractors and any appointed representatives of the West Brom.

Examples of Reporting

The list below serves to provide examples of concern that are relevant to this procedure:

  • A criminal offence or failure to comply with a legal obligation
  • A danger to the health and safety of an individual
  • Bribery and Corruption
  • Inappropriate relationships with suppliers
  • False accounting or reporting irregularities
  • A deliberate concealment of any of the above

Where Suppliers, contractors or Suppliers’ employees reasonably believe any of the above have, may have or will take place, the West Brom encourages these concerns to be raised immediately

Procedure

In the first instance Suppliers can raise their concerns by telephoning the West Brom’s Fraud Hotline on 0121 796 7444. It is a 24-hour hotline and information can be given anonymously. Suppliers wishing to be contacted by the Society to discuss the matter further can leave their details.

Alternatively, Suppliers may prefer to report their concerns externally by contacting any of the following bodies:

Financial Conduct Authority
Telephone: 020 7066 9200
E-mail: whistle@fca.org
Website: www.fca.org.uk/whistleblowing

Action Fraud
Telephone: 0300 123 2040
Online reporting tool: http://www.actionfraud.police.uk/report_fraud

Prudential Regulation Authority
Telephone: 0203 461 8703
E-mail: PRAwhistleblowing@bankofengland.co.uk
Website: http://www.bankofengland.co.uk/pra/Pages/contactpra/whistleblowing.aspx

Modern Slavery and Human Trafficking

The Society is committed to ensure that there is no modern day slavery or human trafficking in any part of our business and supply chain. In addition to the Society’s supply chain risk mapping to identify suppliers who, directly or through their subcontractors may present a slavery risk to the society, we encourage suppliers to report any concerns or suspicions they may have of any inappropriate modern slavery or trafficking activity on their third parties. Any reporting will be investigated and treated in confidence. Concerns should be directed in the first instance to Legal & Regulatory Services (Supplier Management).

Procedure Guidance – Investigation and Feedback

Following an initial assessment to determine the scope of any investigation, a decision will be made whether to investigate further. Where possible, the West Brom will advise the discloser of the outcome of any investigations. Please note that concerns raised anonymously may be more difficult to investigate.

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