Whistleblowing - An Introduction

Hello, I'm welcome. Two days have been a whistle blowing. My name's Katie Jackson and I will be talking to you today about the concept of supply, what we mean by whistle blowing. Some of the guidance says around out there moments on their legal position. I'm not going to be giving legal bonds in Lebanon because that's what we do. But I am gonna be thinking about if you develop policy. New organization. Andi. If you will know what it means for you to be thinking about supporting the kinds of issues you might come up against in those terms, we'll also be thinking about whether advice and I didn't see what one can think about. And in addition to that thinking about other organizations that your staff might be upto, which, if it kind of has a whistle blowing, concerned what you might do in respect of that, where else they might be up to get that box and kind of be comfortable dealing with position yourself. So again, thinking about song pricing, I was blown conveyed extremes is is she. Hand is about miscarriages of justice. Sometimes it could be about life and death type scenarios on answer something that sometimes I ever be feel comfortable dealing with. That needs to be dealt with appropriately, thoroughly, properly, in order to ensure that you know you're staying in the what side of the law that you're getting feedback in your organization. If there are shoes and concerns that where people's lives may be in danger, for example, that you're acting, stop acting for in addition to them, just also they control. Do you think about the boy? Did she is a public interest as well. They were involved in Mr Blowing in terms of days that may be so. Might be quite scared and upset Kiss. These are and sometimes can be. Look at some examples from extreme consumes concerns, and so it is important for you to think about how you have that type of situation on. That's one of the things will think about attempts you whistle might be the other law firm. You're thinking you're whistleblower policy. He's there as advice and guidance in terms off, making sure that your stuff on December is making sure that you're compliant with your obligations in terms of whistleblowing. But the really saying to people that this is an extremely same position. It's not something that should be taken lightly on that stuff involved in whistleblowing would be treated in a particular way. It's a kind of thing, a bit like emergency testing for intellectuals. Continue In such a situation, you might be in a position Teoh assist and advise clients, particularly this morning. He might command with whistleblowing concerns, but larger ones like be in a position to do so on, according the whistleblower stance might very for their smaller firms watching his weapon. I might be something you're thinking about as a kind of worst place tsunami on your staff members. You wouldn't necessarily want to be assisting clients that you might have some post if you could. For example, so what's my? Well, I'm a consultant into compliance consultant. I don't give legal boys on So Theobald point tonight about this, but we're not, is that it isn't legal. Reports on the UN describing a position as presented by various other public sector organizations are not giving me good advice as to what position is on DSO really thinking about your privacy? You might be saying visiting ourselves on the big stuff and have to think about so they think about what we mean by whistleblower who might be a cast defines whistleblowing as a person who speaks up about doing the organization along in terms of thinking about babies. So that's a department for business innovation and skills, which is a government identifying this person who's making disclosure about balding within an organisation. And that is different when you're talking about making a disclosure that is a particular term. Okay, I will talk about disclosure actually means in a minute. There's more information about that, surely on. So it's really about saying that that person is making a discussion about wrongdoing in an organization that open dissension might be, for example, your North. So if there's a situation which arises, I will talk about some of the categories about disclosure is, but there's a situation advises that has very serious concerns on is extremely serious then, in a situation where somebody might need to speak up about her and to think about what that means in terms of their own advice, guidance that they need to think about what needs to be reported, and why should it be imported on what to say. Okay, so there were criteria. Making disclosures to protect those who make on the idea is to protect those people from the toleration. So if you make a public interest exclusion, Dennis, good faith, then you just look for the right reasons and is a public interest dysplasia. Then in that situation, you are protected from retaliation. So talked about disclosures A until this point and what that kind of that there's more meaning to that. We're going to touch on that little bit more, but it really is about making a good faith and also about making sure that they are in the public interest. We'll talk more about that in a minute, but if you do go down the road, there are measures and thanks to protect people from retaliation. So talk that people this could be extremely serious concerns on that. People can feel scared about those things. This is half way going toe frame some of that conversation in the future. So this is how we need to think that's the seriousness of the concern that could be placed on one way might be talking about whistle. If you're dealing with whistle public concern work, that's a charity that set up Teoh support. What's going to help people understand what whistleblowing say? That whistleblowing should be interested in terms? It's not often for personal gain. It is Yuzhin somebody saying something because they want to do so for the right reasons on its for the people to take those steps under dress that I'm not particularly so the public interest discos are on the enterprise recollected fall all the items of legislation, which, given the situation regarding whistle blowing, as well as the Employment Rights Act of 1996. So these three pieces of legislation set out position regarding whistle blowing. The Improvement Lights Act deals with issues around reporting on employer retaliation. The Public Interest Disclosure Act set up the current system regarding whistle blowing. And that's where kind of all the modern system that place moment started that that was in 1998 on the Enterprise Awake electric format made changes that widened its going in 2013. So there have been some changes there, So that's one of the reasons why I'm not gonna cover the legal position in this weapon on. It can be quite complicated, and it would probably went into that level of detail. Get into providing boss, which injected then as part of these webinars, well, we are gonna do instead is what it says about the legal position, which should give you a fair idea where it is a moment of what it looks like on in addition to that, the kinds of things that you can have in your whistle blowing policy. So the best guidance on legal position is work with links. Disclosure must reasonably believe two things. But if they do, then this could be a protected discussion. So disclosure that's protected from retaliation and then maybe recourse to legal action if there is retaliation. So the important waas protected on the 1st 1 is that they are acting in the public interest so they can't come up something with any personal grievances. We'll talk about this in a minute, but it can't be a personal agreement system for sure. If you've got a grievance work, then that's different to having a public interest disclosure. So a grievance is something completely different century person. She has happened in employment. Michael Bullying, for example, might be some issues with the important terms with contract. There might be something there way. A grievance procedure market. More appropriate protective disclosure. Most billy in the wider public interest to be made. OK, the second point is working reasonably believed that disclosure tends to show past, present or likely future will do. Falling Mito one more following categories. The 1st 1 It's criminal offenses and this might, for example, types of financial impropriety such as fraud. 2nd 1 is ready to comply with any obligations. No, the 3rd 1 is a miscarriage of justice. The 4th 1 is endangering someone's health safety. 5th 1 is damage to the environment on the final One is covering up any wrongdoing in any of the above categories, So the Employment Rights Act 1996 provides Watch an employment tribunal for those who blame them so you can make a claim if you play the whistle on your handsome Italian national has been some issue that Andi compensation can be reduced if that is not made for the box. So let's other think about what might be in your whistle blowing policies, important public policy within your organization to think about. If something happened within your organization that preventable categories that we talked about four staff would need to understand where to go and have to deal with that situation on. They'd also need to understand. You could have, for example, clients that came through the door. It can be a position where it's coming to have legal boss about little all say something to you. They could fall into the category, often sublime, would, you know, have designed based on your property if they fell into one of those categories. So thinking in that sort percent need to make your stuff a wet and have a policy in place in order to deal with that. If you're not prepared to accept clients who are going on dealing with these types of situations, do you know somebody else who is marked some details with informant, for example, it might be their organizations that might be that this is it might be better prepared to deal with this type of situation and what that looks like. So it's important. Trouble was a blow policy place. The important thing to think about is that you need to think about the time from the top within the organization, and this is about saying to the board level contacts you got in place, what other named contacts people could go to. And if you don't have a board, do you have partners? Is there somebody you might be, for example, a part time partner? That's not them all the time. People feel comfortable talking to this, like outside of the normal executive life off the organization, that decision making process that might be up to by the side of independent colonel safety somebody is perfect to approach in terms of whistleblowing is anybody that's providing openside. Maybe retired for partner would have the authority on the respective partners to step in and deal with that situation. If no issue really with senior partner or they need to be aware that there should be somebody else who's like removed in case there is a problem with Nazi Party was well on the scene, Partner should have no difficulty. That's not necessarily saying somebody is better than another person. It's about providing independent oversight in a different wine on independent boys back into the organization. To be able to raise concerns by somebody is going to treat that person with respect and the decision making about the organization will treat that person with respect, respect that consents been investigated properly. So really about providing that confidence to stuff that that's going to be done in that particular way on that tone from the top. So in terms of the organizational culture, about allowing people to be able about dealing with it in that way is extremely important. A lot of NHS enquiries So there's been a number of these mammals are playing with people's lives have been abreast through various energy scandals. Thean quarries of fans subsequently that people have a brain because they were scared of retaliation. Benson. And it's about saying, If you raised concern with somebody who was maybe partner, well, maybe that's already in court with Would that stuff remember, be scared that somebody would come back by? Some workers are valuable eyes and ends. There is information out there that could save lives, So it's important to be thinking about different ways. How is this being communicated to stop? What does that look like in terms off saying, Um, you know, can you breathe this in a different way? That doesn't seem us a scariest whistle blowing. That could be a little bit more relaxed in terms off the way in which is presented so to say to people, actually, we do support people coming forward with their concerns particularly. We think there's miscarriages of justice but could save those kinds of things. If there's anything in that type of situation or what should be able to voice their concerns without being afraid of any continuation tool on, you can use that advice, guidance and information in order to progress him after appropriately and also to provide that people within the organization to ensure it doesn't happen again. All provide additional train. Your staff said they're being supported appropriately on that might be if somebody comes in on their let's get current you what, for example, have mental health difficulties of extremely distressed? A new place on a member of stuff is concerned about their welfare well being. Do you want to provide extra advice and support to my staff member intend to deal with out today? Need to speak to somebody about what they've seen, but so can you support that stuff over by saying welcome to any future meetings, reviewing my sport plant in a different way by getting other organizations involved off my sign posting them talk and organizations on what does that look like within our organizations so they can be different ways. If somebody's got concerned about such a thing happen, we support that person so it can be important. Okay, after an export systems in place to implement training, mentoring advice on other support systems in during that pump responses can improve confidence on the draw of the disclosures are made so it can be important. Have training support of students in place and to think carefully about how you're dealing with stuff. Members who need that additional support on who might be whistleblowing, but also for people who are listening positions you nominated within your policy to make provisioning policy for training, support and to transfer that caused your learning development plan on your competent statement requirements to ensure that that's being addressed, employees should have times going within the whistleblower policy, usually in which they will hear back from people. However, you can't save within that the because of the nature of whistle blowing. Some of the information that they're providing to you would be beautiful upon for the organization or for the senior staff well, wealth for them to be kept in board there should be treated for potentially before so they might make it displeasure. T. You might be able to deal with that situation, but then, in addition to that, you think carefully about how that information might have communicated back to them. You might be appropriate within your whistleblower policy to say something benign. If you've blown a whistle in the organization or about something else, you mind or here for information back because that information like confidential. However, if you're in that situation, prompt acknowledgement of some of these concerns can make somebody feel quite a lot better. So if you're going back to say that you can't buy everything because your breasts informant in respect of this. But I have promptly acknowledged your concern, we will look into the further and act on them then that enable somebody to feel better about. However, if you can give feedback can help that person available more in respect of those concerns they raise. So as we previously said, there is an issue that to distinguish between grievance policy on door, so whistleblower policy within your organization might want to think about that. So to say to people, actually, this is a different policy on within your whistle by proxy, to write in that site, you know? Actually, no, we're not going. Teoh, you know, allow personal grievances to be counters of whistle blowing. If you've got personal grievance, this is the page number looking to see and provide a definition of what is a personal briefing, somewhat to start marking her child tones. It's not the same as saying that's a whistle blowing himself, so I'm station to have a very between. Doing your office manual should make it easier for people to see. And if somebody comes to a HR department, it's important that have their awareness as well as to what my counters agreement versus what might be going on. You might want to sign post them stuff within the organization to different places where they can find out more about grievances and also whistle glances. They're getting that right within the organization. In addition to that, we do have people making course for seniors stuff, overs after whistleblower report. Keep a record of those Let's say stuff. Members are making a lot of whistleblowing reports when it's not necessary, naturally, their personal grievances. Instead, that kind of feedback, training and support into stop purpose is gonna be useful for them. So they're getting that correct message in that providing that correct support back out to people as well. Some other organizations can provide devices guidance, for example, a cancel pocket concern work. If staff members have those concerns and you might want to highlight those things, any whistleblower policy as well. In addition to that I commitment to treat all disclosures consistently and fairly is going to be important. I'm really this back to the beginning to say what we think about that tone from the top, you know, stuff. Members should be treated better than anyone should be treated in this. In a way, I can't take it more seriously than that, because I got a different job time total because they I have more popularity within the organization, for example, those kinds of things it has to be consistent. A bear approached pounds exposures are treated and setting out the steps that you take and help that person as well. So, for example, you marbled have the facility to make up for what happens next. Does that need to be independently investigating. You want us to know continually asking the firm, for example, if they would be prepared to look for any supplying allegations. Or like I said, biggest retired partners through these partners of you still trust and have a relationship with could be a group here. It might be something waiting to get other organizations over. The authorities involved the police, for example, and want me to make import to the regulators. There can be different organizations that need to be told. Getting involved in dealing with that situation is important. If you're thinking about making that I'm designing that process. You also think about how you're going to treat persons. We've talked about whether they're going to be kept informed, but she also being position, wing of thinking about are they are they not going to be treated confidentially on and where possible? I think that should be the case of confidentiality should be respected. That person who's made a ticket, they're scared of retaliation. If they're making report that could impact their colleagues, for example, that could be a potential issue. So in that situation somebody might feel very uncomfortable about that. being disclosed there on what their colleagues might have to say about they might know, but equally there should be some issued at around and so concerned that you know some support for that person to say It's okay to make that level of report on this what we're going to do. It's important to say that you can't put into again in clause when it comes to a public interest disclosure. Something is that serious. There cannot be any means of preventing an employee from making those disclosures. This is something that's been highlighted in similar cases that go with BSL rain descending around issues of sexual misconduct on disclosure. So you're you're dealing with those kinds of issues. You have to think about that professional conduct it doesn't prevent about being disclosed. The regulator, it might know on it shouldn't prevent an issue being disclosed in the public interest because we talked about issues on how Siris on this can be for people who are making whistleblower report. We need to think about how that person, what really put ourselves in their shoes and have that level of empathy for somebody on to take that step back and think about how they want to be treated in that situation. If you were in that position, you need to think about how your employees what between if they're being pressurised by their colleagues. If the big fresh wars by the alarm one just because of particulars and are aware that's occurred, they might be feeling what stress as a result about so because of the serious nature to concerns and the possibility of return mention. But Whistleblowers Company Extreme stressed in situation They might feel that pressure than what? Going to pressure from the manages depression. But stuff members a model concerned that they've seen someone else. And you can also see this situation with clients that, well, if it falls into one of those categories, might sign posting else back. Or they might come to see a solicitor deliberately in order to obtain regular bonds about whistle, they might not be aware of how to use a sinister or what time it is going to see in that kind of success that you what you so you might have to have some organizations you convert people, some other local people that you can say actually, this bone will be better for you to go talk to in this kind of tsunami. You see this type of thing. What do you think it market even not if you stay within a case, but what protected discussion that needs to be so These are the kinds of Sonam use where you might have to think and be empathetic. Put yourself into the person shoes about what they would be feeding a person who is under a little pressure not to say they can start their anything strange. They want to get it out. Their system on this might be that they use unusual means of attracting attention. You can be, for example, in the villages. It might be somebody you decided they're gonna go to the press. It might be somebody who behaved in strange brains to try to give you a message in a different way, one that you might not necessarily be expecting unless can all be signs of somebody who is trying to blow the whistle on bad things that happen within a particular organization. There might be lots of different ways that they go about trying to attract attention. It's not required to have evidence in order to look at somebody's concern. So if you are in that situation where somebody's way sounds consent for you, it's not for you to insist on having that evidence before you know protect, because this can be stopping that process of whistleblowing taking place. You should be in that position where it's serious, and you should look at it potentially. Regardless of the however, that will depend on the nature of the concerns. It can't be appropriate to just bear in mind that the person you're dealing with talking to have been bullied. They might have been victim owns. It might have been pressurized in a particular way, and stuff should be trained. Counselling support advice exception should potentially be included. As a result, you might want to think about support advice You can offer to stuff in those kinds of circumstances by the morning to have contact with cancelling organizations in the you know, the where. Occurrence that those constant things occur. What you might do, that finding that scenarios that have some kind of plan in that kind of arena, that level of support and advice being if a worker feels unable to base their concerns or if they've been dismissed within their own organisation, the next approaches go to prescribe building on. This is a list of external public organizations that are qualified to deal with this type of situation on can deal with second chances around that. So to say, I'm trying to raise this within my own organization. However, those calls anti have been listened to have been displaced or they felt otherwise unable to because of the circumstances if they're being bullied, victimized or pressure in a particular way on within the training notes that provided with this weapon are there's a list of proscribed organizations, but they include a lot of regulate two bodies on also HMRC service ward off this the FC A on the National Audit Office. Um, on that is there you know those organizations that they're ready to allow him to go blow the whistle about the situation. If you feel it's important to do so, however, workers really should be trying to raise those concerns within their organization. First on, this is part where the importance of that little glowing policy comes in that tone from the top and having that potential independence there within your structure in order to raise it with somebody potentially outside of that normal day to day system. So somebody feels a little bit more comfortable on being open to that level, constructive insight and criticism within your organization to allow that was going to take thanks for smaller firms. That's going to be a little more difficult. It might not necessarily be appropriate. There might not be that level of importance in terms of, you know, the kinds of things that could happen with the work. However, where you got that way, large organizations that they risk then starts to increase with the different types of work that you might take on. I knew Martin to think about different ways in which that committee on how you're going to communicate that to people. So let's think about some examples of whistle blowing. The National Audit Office report into government Whistle blowing provides Bird with mission about some of these examples. If you want to have a look at that, there was a scandal involving mixed up share, and it just a few years ago that somebody had reported because people died. What turned out was prior to that there was a blood on. They had reported that people were forced by records and it was faulty equipment, and they're concerned about people's lives being put. A risk is a result of that that being picked up and taken forward. But those concerns were interacted on, so that's an example of where whistleblowing incident could have been. Better humbled. So making stuff away training the whistleblower policy really burst up, perhaps, is part of the induction or sign posted people to that office manual is going to be important. You do that, making Siemian step aware of that as well. On how to deal with that type of situation can be very reported. These things that saying could potentially be prevented people acted on. So other advice and information is available for organizations such as Public Concern of Work, which is an excellent has lots of information on examples about whistleblowing on other devices. They suggest you that you should have a think about your staff from perhaps point, then there, and also if you get any clients as well that come in now concerned about it, this is a chance that boy to be advice and guidance to people about black on. Just so. Telephone e's got lots of information on the website as well to give further information about a whistleblower that COPD can help in support with HR issues and think about how you're going to deal with any of those child accuses. You have unorganized initiative in your organization around members of stuff on a cats as well can also help. I can help about songs that negotiating process. I've also added within your training notes, they're linked to department for business innovation skills on also linked to the National Audit Office Report on Public Whistleblower, which provides a list of good practice around what should be in a whistleblower policy. And they did it on order it off or different types of whistle blowing policies. And you know those big practice within that. So that's an interesting report week if you want further information, background reading about whistleblowing and also some of the ideas that commands around what should be a policy. Okay, so what's the difference between making protected disclosure in a report to the solicitous regulation authority? Well, in some contexts and two things might not necessarily be two different, you might have to be a list of regulation authority or if you reconnected by one of the other regulators and legal services market, you won't have to say something to them as well. However, the quality via are quite different. Um, the important thing to think that he's doing away with council awesome convinces whether or not what we're dealing with is sufficient to want to discourage them under their Hamburg call. Wider rules. Andi, Let's ever think about what that means in terms of the solicitor's regulation. Well, a natural code of conduct, the current outcomes. And I'm just going to be this to you now. Going outcomes are outcome 10. Quick way, you know to buy the company of any material changes. 20 12 information about you, including serious financial difficulty action taken against you, buying the regulator and serious, but it's confinement. Go achieved the principles bulls outcomes on any other requirements of the handbook. So sometimes we're still blowing can be about financial trading for failing to deal with finance your management correctly simply from mismanagement. And so in this situation, it's important to think about how you're dealing with that aspect of whistle. Do you also need to make a report to the S always. So you get that have a handbook to make sure you think about whether it's something to report. In addition to that out content full, you report to the it'll probably serious misconduct by any person or authorized by the employee manager or owner of any such taking it can, where necessary, your duty of confidentiality to find there are further provisions for corpses. Coffers in the organization was. These are about material breaches, and there are similar provisions with council license commences. Well, I'm potentially with the regulators, which we're talking about, where people have to make a report to connect instead, consider Second, in addition to that, if the concern If you're concerned about corruption, for example, or money laundering, you may need to report the matter. Or, in addition to police partner agencies, sponsored. There's also considerations about crime agency. Were there any reports me to be back, but much needs to be reported to the places, so let's have a think about him. In addition, point around thinking back policies and procedures. If you're dealing with international whistleblowing, an international requirements, if you've got a hold international organization or if you equate in different countries have clients that greater seats as well. Some of those issues big. You got a question about what different countries. How can you, as a multi national organization, working a great within a whistleblower, stripped, but they'll obviously be different legal requirements in different jurisdictions. In this, Webinar doesn't go into that level of detail. But what is important to note is that there are distinctions about how people view whistleblowing, what people might necessarily say about what constitutes whistleblowing on how they feel about how you going to explain to people. So Deloitte found in one of their reports that companies have considered using more terms, such as ethics policy example, while whistleblowing closing to illustrate the kinds of things that people should be reported to their superiors. So it's really about saying how people understand this in the more distant terms. What is going to translate across a number of different languages for people to understand using one particular 11 particularly made on the system really help people to understand that looks so Doing that in different ways can help individuals from different countries with different understandings of language. To understand what it is, and it's not appropriate to be some organizations. However, taking a different tack cam on George quite hard line in terms of making sure that reports are not wasting time on booth. Quality report should be should be good for within where they would expect within which to that I'm imposing kind of sanctions for folks reporting. There are difficulties doing that. A lot of positions in countries are similar in terms of people can be protected from Reprisals on again. Thinking about that in the way that you're naming and describing what somebody should be doing in terms of whistle blowing can be quite difficult. It's a balancing act between making sure the ethically your lights on not necessarily sent people anything that's going to put the Mach from making so awful. To increase their fear of Reprisals, Eastern reports research by her Freshfields found that internationally people were afraid almost half of respondents preserving dated where I'm afraid of Reprisals. People need that additional reassurance and support. There may be additional values to reporting your legacies on these can include way will have to report to you got everything into a centralized place, for example, so If you're a large organization, you think about what? I've got some stepping in a country. Got some stuff you speak different language can ensure that they have access to the correct support in order to make those with reports that I need to be real time score. Do you need to have a dedicated telephone system like you could have that real time support for, you know, availability around the clock? Did they need to be able to go to their superiors in those countries are going to a central point to report What does that look like? I could be additional challenges that way. See transparency international producers before they produce their corruption index, which is about corruption and bribery. And the perception of corruption and anti Barbary around the world is basically. And this can also be a cultural issue, with different cultural norms around what is accepted in certain situations and what was accepted reporting the lords of that country as well. So that would be different requirements, Which is why thinking about in four times and in different ways, according to local businesses, located what stuff can be very helpful thinking about on if you look at the notes that provided with this. It is clear that people have concerns to those have been around because it was about the difficulty of being able to be taken seriously. Those saying she's unlikely. I'm thinking about pointing this a wide context and even if you're an organization, is based in this country. But with offices split further in different locations and further away from each other, that kind of itself present challenges about making sure the countries where you want it to be as an organization and what you and how does that translate according to what people expect? Are you leading from the top? What does the culture on? How is that reinforced within different offices? And this can be different offices around the world. It could be different offices within the same city. It How does that translate? Tonight they're visible presidents. The company is not always there something elsewhere along breaking people, people that actually gets forward and speak. Some of the reports on a reference around the international multinational think about large organisations in particular. One of the things that comes up in that is the commercial decision making can overtake what is a little blurry ethic kind of report there balancing act to be a balance between paving ethically and also maintaining business continuity. That's one issue, but also putting profit before of an organization, campo serious difficulty compliance. So against that doesn't give legal. But it is that that that's an issue that was raised. These reports is something that comes up in that kind of situation. You might want to think that placing responsibility for whistleblowing, whether it needs to get with in order committee, for example, in order for it to be truly effective. If you're a large organization, you have, as previously suggested, for example, nominated somebody not seeing your partner to be delivering this kind of information. Then during the investigation, approximately, he's been time. What organization before did they need to have a 40 structure? And how does that work with organizations and to that extent to be doing well? What happens without money bordering on the requirements in winning Goldring regulations? 2017 tell nothing about an extra for your It might be something you want to be an external partner organization to help investigate awarded to see how well whistleblowing concerns within the organization of being down and never before, which is loyal, so that what they felt was that it should be a nepotism, two way communication. We've had a discussion about the difficulties with that confidentiality and raise perhaps a distinction between how that might be beauty. There is an emphasis, perhaps in this country on the terms of confidentiality in terms of what this apartment for business skills and innovations produced. Deloitte in their reported to be saying things like, Different in terms off. They suggest calling if you've got a telephone system that people can use to report that consent, according help lines, I love that outlines in orderto and emphasize that there should be two way communication, some of these particular concern and reported their superior or somebody else with organization that considered to be taken seriously. It may be that family resulting quickly with the help while being necessary 50 resulting a full whistleblower types regardless of with your multinational company or a local business. Maybe if Yorks is just one off its, you're likely to have lots of different people supply. So if you're comparing, for example, in my search, providers have state aging, some of these monthly national, You're going to have a lighted different people, either end of the process like that. What help move is people that help people move into houses? You might be referring clients different. Sexist with parts of your organization, you might have a much larger provide to leave senses much more sophisticated systems of supply chains. How received work. Do you know? Do you understand how they work? Do you know? I understand that there's any aspect about that root cause a whistle blower type event? Is there anything in there that put, for example, cause concern and Barbara Corruption? Is there anything in there that could cause concern that they haven't been reporting? Is there anything in there that could harm your reputation dealing with that particular person? So there are situations that needs to be thought about examined in his ways. If there was a concern that was raised, intend to one of your supply chain. So if there was a concern that his ways something you did business with and they had to stop trading or some other action that happened, would you have to cope with that? What other reputation management issues are being those types of situations, and I'm prepared for that talking Teoh People supply change What they record can also be telling well, so make sure you understand within a certain radius of like of what Whoever you're vertically integrate holds on to integrate with whoever you want. But by spot where they supply work to you, whoever operated you is that going to impact your reputation could be very happens. That could cause issues for you or your business. Thinking about those, Alice and I said, in a situation where the tunnel walks the dog, that could be a lot of work involved in keeping up with this kind of thing to try to work, whether they're business related issues around, you need to be aware of in order to make sure that your policy succeeds. There's a guarantee, however, if you are reading that type of situation where you are happening, dependent on, said people within yourself, making sure the auditing, I think he But not having those discussions can prove very valuable in case the worst should have happened. So you think you got your BENDIS and supporting in business terms can also promote great to A when most well, said the standards for what you expect in terms of daily. Can I please have a copy off your and I understand on, Have some insurance from you if you're particularly keep their business. So think about what the requirements are in terms of people doing business with. You know, you tend to work exactly. Start a relationship with any supplier. If your supply starts moving in a particular direction, it may be for them to think about what was going on to think that human reducing human How can you demonstrate up to those so think about your nose Can Actually business benefits well, could have to be complying. Selling point for you to send me detail. These will you. So this can be a means to so business toe your supply chain to think about how you work with your business partners in a different way to promote ethics and compliance. Approach cost across your business. You might just want to keep a sort of going alongside anything else that I picked up when you keep in the Court of Grievance days when we're thinking about material breaches and reports regulator. If you make reports the National Crime Agency. There's anything else that happens within the organisation. For example, Safety chief, the's camp all you know, kept safely alongside whistle support. Have you received any? What do they look like? What kind of investigations coming up? Have you learned anything from the investigation? And this could be really simple record for the smaller business. It might need to be more detail for those international companies, but it just needs to start out with a very simple way of recording this. In order to say that pattern in relation to these whistleblowing reports. Are you getting anything in on a regular basis? Were you investigating appointing? It's true, but actually keeps occurring. I would suggest maybe you need to do more investigation. Maybe need to look into the issues is more carefully. Maybe you need to think about these things. There are lots of different ways in which there are issues. Teoh Deal. Think about explore Teoh in order to promote continues improvement and backs practice within your organization. This can all be linked back into the system. All continues in order to decide. This is how we thought about this is how does situation this is have a balanced, various responsibilities involved in a situation on we have. Also potentially thinking about training staff is important. So I think that kinds of situations they may be faced with their superiors of their work help. Like if you're digging with multinational situations where the stuff need to be trained about what happens overseas and what requirements are overseas for different types of displeasure, are there different types of rooms like these are different wars and example divide with corruption that need to be taken into account the different courts? Are you setting that help? What does that look like within your organization? And how can you leave that cultural turn top in your between? Sure, you get the most out of your way. All of these things will be considered to me, communicated to stuff as part of that leading culture. So your training notes there is an example there called can keep just a simple table to think about if you want, Teoh recalled. What that looks in addition to that was the number references at the end of this the end of this training nights like this, one of the things all different senses that have come with this. But in addition to that, I think about some of the international elements. There must really interesting pieces there on supply concerns. Well, focus on different challenges that you can place now. Also easily translatable back into what it is that you need to think about policy and have a look. But that's even if you're not involved in international because they can't really interesting on Davies thinking about how to get the best out on the wider context off digging on your staff within whistleblowing organisation. Because everybody has different backgrounds, people are not necessarily not to put the same spirit 779 which you won't have different people within your organization where it supported diversity to think about how that situation that they know what that means to them. But what can I use in which demonstrate aboard understanding O two way communication, making sure the organization recognizes them directly on you? Deal with them. Put me with consent that that crazy. So I think this webinar has been useful for you. The next steps be able to have a read of those training notes that company this on, then have a go at some of the questions that there for you as well. So I've got some questions of the enter sort of Test your knowledge on Teoh. Welcome evidence that you completed for your that CP game. Thanks. Thanks very much, Kuljit.