1.0 Introduction

1.1 We as Low Carbon Contracts Company Limited (LCCC) and Electricity Settlement Company Limited (ESC) (together referred to as “we” or the “Company”) are committed to conducting our business with integrity, honesty and with high standards of professional behaviour. This is central to our culture and ethos and lies at the heart of everything we do. We expect all our staff to maintain high standards and to report any suspected wrongdoing as soon as possible.

1.2 This policy covers all employees, officers, consultants, and contractors. It does not form part of any employee's contract of employment and we may amend it at any time.

1.3 If you have any questions that are not addressed by this policy, please contact your line manager or the Head of Assurance and Risk. If neither is available and/or the matter is complex or urgent, please speak to Legal.

2.0 Objective of the Policy

2.1 The aim of this policy is to encourage staff to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and appropriately investigated, and that their confidentiality will be respected.

2.2 The policy is also intended to reassure staff that they can raise genuine concerns without fear of repercussion, even if they turn out to be mistaken. It provides staff with guidance as to how to raise their concerns.

3.0 What is Whistleblowing

3.1 “Whistleblowing” refers to the disclosure of information relating to suspected wrongdoing or dangers at work. This may include disclosure of information in relation to:

  • bribery or other criminal activity;
  • financial fraud or mismanagement;
  • danger to health and safety;
  • damage to the environment;
  • breaches of professional or legal obligations;
  • breach of our internal policies and procedures, including our Code of Conduct; and
  • miscarriages of justice.

3.2 Whistleblowing is important to safeguard the effective delivery of services, foster a healthy work culture and encourage efficiencies.

4.0 How to Raise a Concern

4.1 We hope that in many cases you will feel comfortable to raise any concerns with your line manager. However, where you feel the matter might be very serious and/or you prefer not to raise it with your line manager for any reason, you should contact the Head of Assurance and Risk (who is the Whistleblowing Officer). Contact details are as follows - Email: Kevyn.connelly@lowcarboncontracts.uk; and Mobile: 07721 723216

4.2 If you prefer, you can use our ethics and compliance hotline and web-reporting service which is supplied by an external third party and is available twenty four (24) hours a day, seven (7) days a week. The service can be used by all staff and our stakeholders to confidentially report fraud, corruption, unethical behaviour or any other matters of concern. We also publish the details of the hotline on our website.

4.3 You can report using the hotline:

  • by telephone - dial the free phone number 0800 046 5683 and then listen to the easy-to-follow instructions. You will then be transferred to a trained whistleblowing call handler to tell them your raise your concerns.
  • via the website - send a confidential report by logging onto lowcarboncontracts.ethicspoint.com and selecting Make a Report on the left hand side. You will then be able leave a message by typing the details into the secure message box.

5.0 Investigation of Your Concern

5.1 All concerns will be investigated by the Company, and will be dealt with appropriately, consistently, fairly, and professionally. The Head of Assurance and Risk will lead the investigation, unless a more appropriate staff member has been identified.

5.2 The investigation procedure and timeline will be issued to the staff and stakeholders who are required to be involved in the investigation. If a staff member makes a disclosure, you can expect that we will arrange a meeting with you as soon as possible and within two (2) business days to discuss your concern. You may bring a colleague or union representative to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation.

5.3 The timeline for concluding the investigation will be determined on a case by case basis, depending on the nature and scale of the concern. Subject to any legal restrictions, the Company will give feedback to you regarding your concern in accordance with the timelines set.

5.4 After a concern has been disclosed the Company may offer services, such as mediation or counselling, to help rebuild trust and relationships in the workplace.

6.0 Confidentiality

6.1 We hope that staff will feel able to voice whistleblowing concerns openly under this policy. If you want to raise your concern confidentially, we will make every effort to keep your identity secret and only reveal it where necessary to those involved in investigating your concern.

6.2 We will ensure that any personal data is handled in accordance with LCCC/ESC’s privacy and data retention policies (available on the intranet for staff, and online for external parties via LCCC/ESC’s website Low Carbon Contracts - Data Protection Policy.pdf - All Documents (sharepoint.com)

7.0 If You Are Not Satisfied

7.1 While we cannot always guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way. By using this policy, you can help us to achieve this.

7.2 If you are not happy with the way in which your concern has been handled, you can raise it with the Chief Executive or the General Counsel and Company Secretary. Alternatively, you may contact the chair of the Audit, Risk and Assurance Committee, whose details will be provided on request.

8.0 External Disclosures

8.1 The aim of this policy is to provide an internal mechanism for reporting, investigating, and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert external persons.

8.2 The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. We strongly encourage you to seek advice before reporting a concern to anyone external. Protect, is an independent whistleblowing charity that operates a confidential helpline. Helpline: 0203 117 2520, Email: whistle@protect-advice.org.uk, Website: www.protect-advice.org.uk

9.0 Protection & Support for Whistleblowers

9.1 We aim to encourage openness and will support whistleblowers who raise genuine concerns under this policy, even if they turn out to be mistaken.

9.2 Whistleblowers will not suffer any detrimental treatment as a result of raising a genuine concern. If you believe that you have suffered any such treatment, you should inform Head of Assurance and Risk immediately. If the matter is not remedied, you should raise it formally through our Grievance Procedure.

9.3 You must not threaten or retaliate against someone you believe to be a whistleblower. If you are involved in such conduct you may be subject to disciplinary action. In some cases, the whistleblower could have a legal remedy against you personally.

9.4 However, if we conclude that a whistleblower has made false allegations maliciously or with a view to personal gain, the whistleblower may be subject to disciplinary action.