Version: 2.7
Date last reviewed: March 2025
Next review date: March 2026
Policy owned and maintained by: Human Resources
Policy approved by: Executive Leadership Team
1. Purpose
Unipart Group of Companies Limited, its subsidiaries and associated companies (in each case, the “Company”) is committed to conducting our business lawfully and with honesty and integrity.
It is important to the Company that any suspected wrongdoing (fraud, corruption or malpractice) which has occurred or may occur, is brought to our attention so it can be investigated and dealt with as appropriate. The Company therefore encourages all individuals to raise any concerns they may have regarding the conduct of Unipart people or the way in which the business is run.
The purpose of this policy is to guide individuals on how to bring to the attention of the Company any concerns they may have relating to actual or potential wrongdoing at work (known as “whistleblowing”), the legal protections they are afforded in doing so, and how those concerns will be dealt with.
2. Scope
This Policy applies to all Unipart People and is also available for use by any external third party or counterparty.
For the purpose of this policy’ Unipart People’ are defined as:
(i) all established and fixed term employees who work under a contract of employment; and
(ii) any other person engaged to work on the Company’s behalf, including any persons engaged as a consultant, third party service provider, worker or agent whether through third parties or directly.
References to an “individual” are to be construed accordingly.
This Policy does not form part of any employee’s contract of employment and it may be amended at any time.
3. Definitions
3.1 Whistleblowing
Whistleblowing is the act of disclosing information about wrongdoing in the workplace (often described as making a ‘qualifying disclosure’).
The Whistleblower does not need to have proof that such an act is being, has been, or is likely to be, committed – a reasonable belief is sufficient.
The Whistleblower bears no responsibility for investigating the matter – it is the Company’s responsibility to ensure that the matter(s) raised are investigated.
3.2 Qualifying disclosure
A qualifying disclosure is one made in the public interest by an individual (‘Whistleblower’) who has reasonable belief that:
- a criminal offence;
- a miscarriage of justice;
- an act creating risk to health and safety;
- financial fraud or mismanagement;
- an act causing damage to the environment;
- bribery or corruption;
- breaches of competition law or anti-competitive practices;
- a breach of any other legal obligation;
- conduct likely to damage the Company’s reputation;
- concealment of any of the above;
is being, has been, or is likely to be, committed.
3.3 Protected disclosure
The term ‘protected disclosure’ describes a qualifying disclosure made to an appropriate party.
A protected disclosure may be made to one of five types of recipients, these are:
- a worker’s employer
- a legal adviser
- a Minister of the Crown (in certain circumstances)
- a regulatory body (e.g. Health and Safety Executive or Information Commissioner)
- a third party (e.g. the media)
Further information about protected disclosures can be found on the ‘Protect’ website.
3.4 Fraud
‘Fraud’: for the purpose of this policy refers to where an individual has undertaken, or intends to undertake, actions in order to obtain gain for him/herself or another, or cause loss to another, or expose another to risk of loss.
The term ‘fraud’ encompasses:
i) Fraud by false representation;
ii) Fraud by failing to disclose information; and
iii) Fraud by abuse of position.
Descriptions of the above can be found within the Fraud Act 2006.
3.5 Corruption
‘Corruption’ for the purpose of this policy refers to an individual who has given or obtained advantage through means which are illegitimate, immoral, and/or inconsistent with their duty to the Company or the rights of others, for example accepting or offering bribes or incentives during a procurement process.
3.6 Malpractice
‘Malpractice’ for the purpose of this policy refers to actions which may be:
i) illegal, improper, or unethical;
ii) in breach of a professional code;
iii) possible maladministration, fraud or misuse of public funds; or
iv) acts which are otherwise inconsistent with the standards of conduct described in ‘Conducting Business the Unipart Way’.
4. Principles
Everyone associated with the Company should be aware of the importance of the prevention and elimination of wrongdoing in the workplace and should be watchful for illegal or unethical conduct and report anything of that nature they become aware of.
The Company never requires, expects or condones fraud, corruption or malpractice in any area or at any level of its business and by promoting a culture of honesty and openness we believe we can prevent wrongdoing before it happens.
In all but exceptional circumstances, concerns about wrongdoing should be raised internally either directly through line management or via Safecall – our independent confidential reporting partner (see section 7.2.2 for contact details).
Any matter or concern raised under this policy will be investigated thoroughly, confidentiality and in a timely manner, and the outcome reported back to the Unipart Person who raised the issue (unless prevented by anonymity).
No Unipart Person will be victimised or suffer any detriment for raising a concern in good faith under this policy.
5. Protection of Whistleblowers
The Public Interest Disclosure Act 1998 provides legal protection for individuals who raise their legitimate concerns by making a ‘protected disclosure’.
If you have raised a genuine concern through this Policy, the Company will ensure that you suffer no detriment as a result, even if the investigation is unable to substantiate your allegations.
Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment which is connected with raising a concern.
If you believe that you have suffered any such treatment, you should inform your line manager or one of the contacts listed in Appendix 1. If the matter is not remedied you should raise it formally using our Grievance Procedure.
Prompt action will be taken against those who victimise somebody because they have spoken out. The harassment or victimisation of a fellow employee for raising a concern about suspected fraud, corruption or malpractice under this policy will not be tolerated and will be regarded by the Company as a serious disciplinary offence.
Equally however, the Company cannot allow abuse of this Policy. If it becomes clear that you have made allegations maliciously and/or not in good faith then you will be subject to disciplinary proceedings which may result in your dismissal.
Further detail on who is protected and for what type of disclosure is available on the Government’s website.
6. Grievances
It should be noted that this policy is not a substitute for our normal grievance procedure and is not the correct policy for Unipart people to use to raise complaints about their own personal circumstances at work.
Unipart people who wish to lodge a formal complaint or concern about their own personal circumstances at work should refer to the Unipart Group Grievance Policy.
7. Reporting procedure
Reporting suspected malpractice at work can be difficult, especially where it involves colleagues or managers. We recognise this, however, the Company still needs and wants to hear about fraud, corruption or malpractice as the consequences of such behaviour can have a significant impact on the on-going reputation and financial exposure of the business and its employees.
The Company will do its best to help you through this process if you genuinely believe that malpractice has occurred, is planned, or is on-going. Please see appendix 2 of this policy for a flowchart to guide you through the process.
Whistleblowing concerns usually relate to the conduct of staff, but they may sometimes relate to the actions of a third party, such as a customer, supplier or service provider. The law allows you to raise a concern in good faith with a third party, where you reasonably believe it relates mainly to the actions of that third party or something that is legally their responsibility. However, we encourage you to report such concerns internally first.
7.1 Tell your line manager
In the first instance, and unless you have reason to believe your Line Manager is involved in wrongdoing or have some other reason to not wish to approach them, any concerns should be raised with your line manager.
Where it is possible, it is almost always best to initially raise your concerns in this way, as your manager may well be able to satisfy your concerns and/or resolve the matter informally and locally.
7.2 If you feel unable to tell your line manager
If, for any reason, you don’t wish to raise your concerns with your line manager or you believe they have failed to resolve the matter satisfactorily, you should do one of the following:
7.2.1 Raise the matter with one of the Company’s specialist professionals listed in Appendix 1 of this Policy;
7.2.2 Raise the matter with your divisional HR department or HR manager/director; or 6.2.3 Raise the matter via our external, confidential Whistleblowing partner – Safecall.
There are 2 ways to do this:
- i) Via the confidential web portal https://www.safecall.co.uk/file-a-report/
- ii) Via the confidential Whistleblowing hotline.
From the UK: 0800 915 1571
For a list of international numbers please follow this link: Whistleblowing hotline numbers
Safecall provides an independent confidential reporting line and website where you can raise your concerns and be assured they will be fully addressed. If you choose to use the hotline rather than the web portal, calls are handled by skilled staff and will be treated in complete confidence.
A report of the concern raised will be sent to the Group Legal Director and HR Director, Corporate Responsibility & Policy who will arrange for an appropriate investigation and report the result back via Safecall.
Safecall will not disclose your name to the Company if you wish to remain anonymous.
Safecall is an international service so colleagues are able to raise concerns in their first language.
7.3 Anonymity
You may choose to reveal your name or remain anonymous when voicing your concerns. You should be aware however that, should you choose to remain anonymous, it may be more difficult for the Company to look into the matter effectively and if you choose to raise your concerns via options 7.2.1 or 7.2.2 above it will not be possible to provide feedback on investigations if you are anonymous.
If you use the Whistleblowing Hotline you may choose to reveal your name and contact details to the Hotline service providers and ask that they keep your details confidential from the Company. Under these circumstances it may still impact the Company’s ability to fully investigate your allegations, however the Company will provide the Hotline Service provider with feedback on our investigations which they can pass on to you.
It may also be the case, on occasion, that an investigation will reveal the identity of a whistle-blower; in such cases we will continue to protect the individual’s anonymity to the extent that we are able to do so.
8. Investigation procedure
8.1 If you have openly raised your concern internally, or have used Safecall and have agreed for your name to be disclosed to us
Under these circumstances we will determine if your concern falls within the scope of this Policy, and give you an indication of how we propose to deal with the matter and how feedback will be provided.
Please note, the Company will not be able to share some details about progress with you in the event this would infringe a duty of confidentiality owed to somebody else. In any event, you should treat any information about the investigation as confidential.
If your concern does fall within the scope of this Policy, the person to whom you have reported the issue will initially assess what action should be taken and advise you accordingly.
The Company cannot guarantee that it will respond to all matters in the way that you would like, but every effort will be made to handle the matter fairly and properly and to advise of the outcome (either verbally or in writing depending on the nature and severity of the issue) and the reasons for it.
If, following an investigation, wrongdoing is identified the Company will take the appropriate action (which may involve the Company reporting the matter to relevant external authorities, including the police, or taking appropriate disciplinary action).
If you believe a suitable investigation has not been undertaken in accordance with this Policy, you may escalate the matter to a senior director (as listed in Appendix 1).
8.2 If you have raised a concern on an anonymous basis either internally or via Safecall.
Under these circumstances the Company will investigate based on the information available.
Where Safecall has been used, the Company will provide written feedback via the reporting web portal or via the Safecall team.
9. Confidentiality
This Policy aims to provide you with the reassurance you may need when raising any suspected wrongdoing concerns with an internal manager.
While we would prefer you to raise your concern openly and without confidentiality requirements, you are fully entitled to request that your disclosure is raised in confidence under this policy.
Where confidentiality is requested, we will make every effort to resolve the concern without revealing your identity. If the situation arises where we are not able to resolve the concern without revealing your identity, we will discuss this with you and explain the options that are available.
10. Record keeping
While all records relating to malpractice investigations will be kept confidential in accordance with current Data Protection Regulations, it should be noted that there may be occasions when the Company is required by law to refer the information to an external body, e.g. the Health and Safety Executive, or in response to a Court Order.
11. Raising concerns with external bodies
It is recognised that there may be exceptional circumstances where Unipart People feel that they need to report matters to external bodies.
A full list of persons/bodies can be found in The Public Interest Disclosure (Prescribed Persons) Order 1999.
If a Unipart person is considering making a wider disclosure (for example to the media) the Company strongly advises them to seek specialist guidance on whether their disclosure meets the necessary threshold to afford them legal protection under the Public Interest Disclosure Act 1998 before doing so.
If you are unsure whether or how to use this procedure, or if you want independent advice at any stage, you can contact Protect via their website. This is an independent charity, whose lawyers can give you free confidential advice at any stage about raising a concern about malpractice at work.
12. Review and maintenance of this policy
All those persons referred to within the scope of this policy are required to adhere to its terms and conditions.
Individual managers are responsible for ensuring that this policy is adhered to.
Any queries on the application or interpretation of this policy must be discussed with the Human Resources Department prior to any action being taken.
The Human Resources Leadership Team has the responsibility for ensuring the maintenance, regular review and updating of this policy.
This policy will be reviewed annually. Any material amendments will be subject to the approval of the Executive Leadership Team
13. Version history
| Version no. | Version Date: | Amended by: | Summary of changes |
| 2.7 | March 2025 | Deb Astles | ● Policy format amended to reflect current template
● Addition of this version history table ● No material change. |
APPENDIX 1
If you feel unable to raise your concern with a manager from your own area, you can directly contact any of the managers/directors listed below to obtain advice or register a concern.
These internal contacts can be reached through the Unipart House switchboard on 01865 778966.
Alternatively, you may choose to use our external confidential Whistleblowing reporting service – Safecall via their online reporting portal or by phone (Whistleblowing hotline numbers); or you can contact Protect via their website.
| Type of Concern | Internal Contacts |
| Fraud, theft or other financial irregularities | Head of Security
Finance Director Chief Financial Officer Company Secretary Chief People Officer HR Director Legal Director |
| Bribery, corruption or any other criminal matters | Head of Security
Chief People Officer Chief Financial Officer Company Secretary Legal Director |
| Breaches of contract, anti-competitive practices or other legal non-compliance | Legal Director
Chief People Officer Group Company Secretary |
| Improper treatment of individuals (including bullying, discrimination or victimisation) | HR Director
Chief People Officer Company Secretary Legal Director |
| Misuse of confidential/sensitive information, or conflicts of interest | HR Director
Chief People Officer Company Secretary Legal Director |
| Misuse of IT equipment or systems, breaches of data protection requirements or internet abuse | IT Director
HR Director Chief People Officer IT Security Manager Data Protection Officer |
| Breaches of Unipart’s Code of Conduct, company policies and control procedures, and delegated authority limits. | HR Director
Chief People Officer HR Director, Policy and Compliance Company Secretary/Legal Director |
| Health and Safety issues, unsafe working practices or environmental issues | Health and Safety Director
Chief Sustainability Officer HR Director Chief People Officer Company Secretary/Legal Director |
If you are uncertain or uncomfortable about contacting individuals in the above list you can email the HR Director, Policy and Compliance (Deborah.astles@unipart.com) or the Group Legal Director (Ben.Thornton@unipart.com).