Whistle Blowing Policy
Document No: PHDHR40 Revision: 4 Issue Date: 28/10/2025
This policy applies to all employees, workers, contractors, and agency personnel.
PHD Electrical Contractors Ltd is committed to maintaining the highest standards of transparency, accountability, and integrity across the organisation. This policy enables workers to raise serious concerns internally rather than overlooking problems or raising them externally.
The Company encourages all individuals to report concerns about unlawful acts, misconduct or wrongdoing. This includes improper behaviour by employees, officers, suppliers, or others associated with the business. This revised version incorporates new legal requirements under the Employment Rights Act 2025, including expanded whistleblowing protections, particularly for sexual harassment disclosures.
Background
Under UK law, workers are legally protected when making qualifying disclosures in the public interest. Such disclosures include a reasonable belief that:
- criminal offences or unlawful acts
- breaches of legal or regulatory obligations
- miscarriages of justice
- health and safety risks
- environmental damage
- financial malpractice or fraud
- deliberate concealment of wrongdoing
are being, have been, or are likely to be committed.
Workers do not need proof, only a reasonable belief that wrongdoing has occurred or may occur.
From 6 April 2026, disclosures relating to sexual harassment are explicitly recognised as protected disclosures under whistleblowing law.
Encouragement to Report
Employees are strongly encouraged to raise concerns early. Speaking up protects the business, colleagues, and the wider public. If a worker is unsure whether to raise a concern, they should speak with their line manager or HR.
The Company guarantees that all concerns raised in good faith will be taken seriously and handled confidentially.
Reporting Procedure
Concerns can be raised through the following channels:
- Directly to a line manager or supervisor
- Via the designated Whistle Blowing Officer – Jody Bourne
- Through a confidential email address: info@phdelectricalcontractors.co.uk
- Anonymously via Post, or WhatsApp
Workers are not responsible for investigating concerns; the Company will conduct all investigations promptly and objectively.
Stage 1 – Line Manager
Unless the worker believes the line manager is involved or inappropriate, concerns should first be raised with them.
The manager will:
- acknowledge the concern
- initiate an investigation or escalate to a senior manager
- obtain necessary statements
- compile a report for the Board
Stage 2 – Investigation and Outcome
The investigator will review all relevant information and report findings to the Board. The worker will be informed of:
- the outcome
- action taken
- reasons if no action is taken
Stage 3 – Escalation to the Managing Director
If the worker believes:
- their manager is involved,
- the investigation was improper, or
- the matter has not been escalated appropriately,
they should contact the Managing Director directly. Identity will not be disclosed without consent unless legally required.
Stage 4 – Reporting Externally
If internal procedures are exhausted or inadequate, workers may raise concerns with prescribed authorities, including:
Serious Fraud Office
- HMRC
- Financial Conduct Authority
- Competition and Markets Authority
- Health and Safety Executive
- Environment Agency
- Independent Office for Police Conduct
Protection from Victimisation
Employees who raise concerns in good faith under this policy will be protected from any form of retaliation, harassment, victimisation or detriment. Any attempt to penalise a whistleblower will be treated as a serious disciplinary matter.
A worker who makes such a protected disclosure has the right not to be dismissed, subjected to any other detriment, or victimised, because they have made a disclosure.
Principles
- Wrongdoing must be prevented wherever possible
- Concerns will be investigated promptly, confidentially, and fairly
- Workers will not be penalised for raising genuine concerns
- Deliberate false allegations constitute misconduct
- Covering up wrongdoing is a disciplinary offence
- If instructed not to report an issue, workers must ignore such instructions and escalate immediately
Policy Review
This policy will be reviewed annually by the Managing Director and updated to reflect any future stages of ERA 2025 implementation.
Confidentiality
All concerns will be handled in strict confidence. Workers’ identities will not be disclosed without consent unless legally necessary.
Data protection
Any personal data collected during disclosures will be processed in line with data protection legislation and internal privacy policies. Access will be restricted to those involved in investigating or acting on the disclosure.
Oliver Parry 28th October 2025
