Whistleblowing Policy

1. Introduction

Delta Force Group Ltd is committed to conducting all aspects of its business with honesty, integrity, transparency and the highest ethical standards.

We encourage all employees, agency workers, contractors, suppliers and other stakeholders to report any genuine concerns regarding suspected wrongdoing, misconduct, illegal activity or unethical behaviour that could adversely affect our employees, clients, business or the wider public.

This policy is developed in accordance with the Public Interest Disclosure Act 1998 (PIDA), as amended by the Enterprise and Regulatory Reform Act 2013, which provides legal protection for workers who make protected disclosures in the public interest. Delta Force Group Ltd will treat all whistleblowing disclosures seriously and investigate concerns fairly, confidentially and without prejudice.

2. Purpose

This policy is designed to:

• Encourage individuals to raise concerns at the earliest opportunity
• Promote a culture of openness, honesty and accountability
• Provide a safe and confidential reporting process
• Protect individuals from victimisation or retaliation when concerns are raised in good faith
• Ensure concerns are investigated fairly and appropriately
• Support continual improvement across our business

3. Scope

This policy applies to:

• Employees
• Directors
• Agency workers
• Contractors
• Consultants
• Temporary workers
• Volunteers
• Apprentices
• Suppliers
• Business partners

4. What Should Be Reported?

Concerns may include, but are not limited to:

• Criminal activity: theft, fraud, bribery, corruption, financial misconduct, money laundering
• Legal or regulatory breaches: breach of legislation, contractual obligations or regulatory non-compliance
• Health & safety: unsafe working practices, serious risks, dangerous acts or omissions
• Security industry concerns: SIA licence fraud, falsification of records or timesheets, sleeping on duty, misuse of client property or systems
• Safeguarding: abuse, neglect, exploitation, failure to protect vulnerable people
• Employment concerns: harassment, bullying, victimisation, discrimination
• Environmental issues: pollution, environmental damage, breaches of environmental legislation
• Information security: data breaches, cyber security incidents, unauthorised disclosure of confidential information
• Modern slavery: forced labour, human trafficking, labour exploitation, unethical recruitment practices
• Concealment: any deliberate attempt to conceal or destroy evidence relating to any of the above

5. Matters Not Covered

This policy is not intended to deal with personal employment grievances such as pay disputes, holiday requests, performance concerns, disciplinary matters or personal disagreements. These matters should be addressed through the company's Grievance or HR procedures.

6. Speaking Up

Delta Force Group Ltd encourages everyone to raise concerns as soon as possible. Raising concerns helps us protect employees, protect clients, prevent financial loss, improve standards, maintain our reputation and meet our legal obligations. No individual will be criticised for reporting genuine concerns made honestly and in good faith.

7. How to Raise a Concern

Concerns may be raised verbally, in writing, by email or in confidence. Reports may be made to your line manager, operations manager, HR manager, business director, company director, compliance department or another appropriate senior manager.

Where an individual believes it is inappropriate to report internally, concerns may also be reported to an appropriate external regulator. Independent confidential advice is available from:

8. Information to Include

Where possible, reports should include:

• A description of the concern
• Dates and times
• Location
• Individuals involved
• Supporting evidence
• Witnesses, if known

Individuals are not expected to prove wrongdoing before reporting a concern.

9. Investigation Process

Every concern will be treated seriously. The investigation process normally includes:

• Stage 1 – Acknowledgement: the concern will normally be acknowledged within two working days
• Stage 2 – Initial Assessment: a senior manager will review the information and determine the most appropriate course of action
• Stage 3 – Investigation: where appropriate, an independent investigation will be undertaken, which may include interviews, document review, system audits, CCTV review, client consultation and evidence gathering
• Stage 4 – Outcome: appropriate action will be taken, which may include corrective actions, disciplinary action, process improvements, training or referral to external authorities where required. Feedback will be provided where appropriate

10. Confidentiality

Delta Force Group Ltd will make every reasonable effort to protect the identity of anyone raising a concern. Information will only be shared where necessary for investigation or where required by law. All records will be handled in accordance with UK GDPR, the Data Protection Act 2018 and the company Privacy Policy.

11. Anonymous Reports

Anonymous reports will be considered. However, providing contact details may assist the investigation and enable clarification of information where necessary.

12. Protection from Retaliation

Delta Force Group Ltd has a zero-tolerance approach to retaliation. Any individual raising a genuine concern in good faith will not suffer dismissal, harassment, victimisation, discrimination, bullying, loss of opportunity or unfair treatment. Any employee found to have retaliated against a whistle-blower may face disciplinary action up to and including dismissal.

13. False or Malicious Allegations

Individuals are encouraged to report genuine concerns. Knowingly making false, malicious or vexatious allegations may result in disciplinary action. A concern raised honestly and in good faith will not result in disciplinary action simply because it is not substantiated.

14. Responsibilities

• Employees are responsible for reporting concerns promptly, acting honestly and in good faith, cooperating with investigations and maintaining confidentiality.
• Managers are responsible for taking concerns seriously, escalating reports promptly, protecting confidentiality, preventing retaliation and supporting investigations.
• Directors are responsible for ensuring investigations are impartial, reviewing trends, monitoring policy effectiveness, promoting an open reporting culture and ensuring legal compliance.

15. Related Policies

This policy should be read alongside:

• Code of Business Conduct
• Anti-Bribery & Corruption Policy
• Modern Slavery Statement
• Equality, Diversity & Inclusion Policy
• Health & Safety Policy
• Privacy Policy
• Information Security Policy
• Grievance Policy
• Disciplinary Policy
• Safeguarding Policy

16. Monitoring and Review

The Business Director – Fire Safety & Compliance is responsible for monitoring the effectiveness of this policy. The policy will be reviewed annually or sooner where legislation changes, business or client requirements change, following significant incidents or following audit recommendations.