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Whistleblowing Procedure

Whistleblowing (Open Door Reporting) Procedure for Suppliers, Contractors and Supplier Employees.

Objective

This procedure enables Suppliers, Contractors and Supplier Employees to report concerns regarding actual or suspected wrongdoing, malpractice or unethical conduct involving The West Brom, its employees, contractors, representatives or suppliers.

The West Brom is committed to operating with integrity and encourages anyone with genuine concerns to raise them as soon as possible.

The West Brom's Commitment

The West Brom will treat concerns raised in good faith seriously and, where possible, confidentially. No Supplier, Contractor or Supplier Employee will suffer loss of business, contract termination, retaliation or other adverse treatment solely as a result of raising a genuine concern. Reports may be made anonymously.

Examples of Concerns

The following examples are not exhaustive but may be reported under this procedure:

  • Criminal activity, fraud or financial crime.
  • Bribery, corruption or improper inducements.
  • Conflicts of interest.
  • Breaches of legal or regulatory obligations.
  • Breaches of FCA or PRA requirements.
  • Deliberate breaches of West Brom policies or procedures.
  • False accounting or reporting irregularities.
  • Inappropriate relationships with suppliers.
  • Misuse of confidential information or personal data.
  • Bullying, harassment, discrimination or other non-financial misconduct.
  • Risks to the health, safety or wellbeing of any individual.
  • Environmental damage.
  • Modern slavery, forced labour or human trafficking.
  • Deliberate concealment of any of the above.

Where an individual reasonably believes any of the above has occurred, is occurring or is likely to occur, The West Brom encourages the concern to be raised immediately.

How to Raise a Concern

West Brom Whistleblowing Hotline
0121 796 7444

The hotline operates 24 hours a day and reports may be made anonymously. Individuals wishing to discuss concerns further may leave their contact details.

External Reporting

Whilst The West Brom encourages concerns to be raised through its internal reporting arrangements, individuals may report concerns directly to an appropriate regulator or authority where they believe this is appropriate. Reporting externally is not conditional on first using West Brom's internal arrangements.

Financial Conduct Authority (FCA)
Email: whistle@fca.org.uk
Website: www.fca.org.uk/whistleblowing

Prudential Regulation Authority (PRA)
Email: PRAwhistleblowing@bankofengland.co.uk
Website: www.bankofengland.co.uk/prudential-regulation

Action Fraud
Website: www.reportfraud.police.uk

Modern Slavery

The West Brom is committed to preventing modern slavery and human trafficking within its business and supply chain. Suppliers are encouraged to report any concerns or suspicions relating to modern slavery, forced labour or human trafficking connected to their organisation, subcontractors or supply chain. Any concerns will be investigated and treated appropriately.

Malicious Reports

Any individual who raises a concern in good faith will be protected under this procedure, even where an investigation does not substantiate the concern. However, deliberately false or malicious allegations may result in action being taken.