Company Name: Connect2Luton

Date: July 2020



Luton & Kent Commercial Services LLP (LKCS LLP) is committed to the highest possible standards of openness, probity and accountability and we encourage employees and others working with us to raise any concerns about any aspect of our work to come forward and voice those concerns.

In some instances, concerns may need to be expressed on a confidential basis. This procedure encourages employees to raise serious concerns, without fear of reprisal or victimisation, internally within LKCS LLP rather than over-looking a problem or raising the matter externally.

LKCS LLP has established independent channels through which whistleblowing concerns can be properly considered. You can therefore be confident that if you wish to raise a whistleblowing concern it will be dealt with fairly and appropriately. If you feel it appropriate to take this issue beyond the company, section 13 outlines the alternative channels that may be used.

It applies to all employees, agency workers and those contractors working on LKCS LLP premises for example cleaners, builders and drivers. It also covers suppliers and those providing services under a contract with LKCS LLP in their own premises.


Aim and Scope

This procedure aims to ensure individuals are:

  • Encouraged to feel confident in raising serious concerns and to question and act upon concerns about practice.
  • Provided with avenues to raise concerns and receive feedback on any action taken.
  • Given a response to their concerns and are aware of how to pursue them if not satisfied.
  • Reassured that they will be protected from reprisals or victimisation if they have a reasonable belief any disclosure has been made in good faith.


There are existing procedures in place to enable individuals to lodge a grievance relating to their own employment including issues relating to harassment and bullying. This procedure is intended to cover concerns that fall outside the scope of other procedures.

These include:

  • Conduct which is has been or is likely to be an offence or breach of law.
  • Conduct that has occurred is occurring or is likely to occur the result of which LKCS LLP fails to comply with a legal obligation. For example unauthorised use of public funds, possible fraud and corruption, sexual or physical abuse of clients, or other unethical conduct discrimination of any kind and waste/frivolous expenditure.
  • Disclosures related to past, current or likely miscarriages of justice.
  • Past, current or likely health and safety risks, including risks to the public as well as other employees (see below).
  • Past, current or likely damage to the environment.
  • Past or current activities to cover up a wrongdoing.


Concerns about any aspect of service provision or the conduct of employees or others acting on behalf of LKCS LLP can be reported under the Whistleblowing Procedure. This may be about something that you:

  • Feel uncomfortable about in terms of known standards, your experience or the standards you believe LKCS LLP subscribes to: or
  • Is against the LKCS LLP’s policies; or
  • Falls below established standards of practice; or
  • Amounts to improper conduct.


What is Whistleblowing?

Whistleblowing is a process whereby an employee or worker provides certain types of information, usually to the employer or a regulator, which has come to their attention through work. The disclosure may be about the alleged wrongful conduct of the employer, or about the conduct of a fellow employee, client or any third party. Whistleblowing is therefore ‘making a disclosure in the public interest’.


Other Complaints Procedures

This procedure is separate from LKCS LLP’s Complaints Procedures and other statutory reporting procedures applying to some divisions. It is also separate to the Grievance Procedure which is available to members of staff.

Any investigation into allegations of potential malpractice under this procedure will not influence or be influenced by any disciplinary or redundancy procedures that already affect an individual.



All concerns raised will be treated in confidence and every effort will be made not to reveal your identity if this is your wish. However, in certain cases, it may not be possible to maintain confidentiality if you are required to come forward as a witness. If we must reveal your identify we will discuss this with you in advance of any disclosure.


Anonymous Allegations

Whenever possible you should put your name to your allegation as concerns expressed anonymously are much less powerful that those that are attributed to a named individual. Anonymous allegations will however be considered and investigated at LKCS LLP’s discretion.

In exercising the discretion, the factors to be taken into account would include:

  • The seriousness of the issues raised
  • The credibility of the concern; and
  • The likelihood of confirming the allegation from attributable sources.


Untrue Allegations

If you make an allegation in good faith that is not subsequently confirmed by an investigation, no action will be taken. However, false, malicious or vexatious disclosures will be addressed in accordance with LKCS LLP’s Disciplinary Policy and Procedures.


Bribery Act 2010

LKCS LLP has a zero tolerance approach to acts of bribery and corruption. Any instances of suspected bribery and corruption must be reported to the LKCS LLP Executive Board. If you do not feel able to report your concerns to the LKCS LLP Executive Board or your line manager, the Whistleblowing policy can be used to confidentially raise your concerns. See the Anti-Bribery Policy for further guidance.

How to Raise a Concern


Concerns can be raised verbally or in writing. A concern raised in writing should:

  • Set out the background and history of the concern, giving names, dates and places where possible.
  • Give the reason why you are particularly concerned about the situation.


The earlier a concern is raised the easier it is to take action. Although you are not expected to provide proof that your concerns are warranted, you should be confident there are sufficient grounds for your concern. Further investigation may be hampered if there is only limited evidence to support the concern raised.

A trade union or professional association may raise a matter on behalf of an employee.

Step One – Raising a Concern

Whenever possible you should raise your concern with your immediate manager or his/her manager. If this is not appropriate, you should approach a member of the LKCS LLP Executive Board.

Suspected fraud, theft, bribery, money laundering or similar criminal offence must be reported to the LKCS LLP Executive Board who will then inform the LKCS LLP Board.

Step Two - How LKCS LLP will respond

The action LKCS LLP takes will depend on the nature of the concern. The matters raised may:

  • Be investigated internally by management, or through the disciplinary or other internal process;
  • Be referred to the Police;
  • Be referred to the LLP’s Internal or External Auditor;
  • Form the subject of an independent inquiry.


In order to protect individuals and LKCS LLP, initial enquiries will be made to decide whether an investigation is appropriate and, if so, what form it should take. Concerns or allegations which fall within the scope of specific procedures (e.g. child protection or discrimination issues) will normally be referred for consideration under those procedures.

Some concerns may be resolved by agreed action without the need for investigation. If urgent action is required this will be taken before any investigation is conducted.

Where contact details have been provided, you will be written to within ten working days:

  • Acknowledging that the concern has been received;
  • Indicating how LKCS LLP proposes to deal with the matter;
  • Giving an estimate of how long it will take to provide a final response;
  • Informing you if any initial enquiries have been made;
  • Whether further investigations will take place and, if not, why not.


Recording Concerns

A central record of whistleblowing concerns is maintained and forms part of the assurance reporting to the LKCS Executive Board. The record will include the areas of business that have been affected, a summary of action taken and the resulting outcome, follow up and feedback. Managers that receive Whistleblowing concerns must report the matter to the LKCS Executive Board for inclusion on the central record.



The amount of contact between the person considering the issues and you will depend on the nature of the matters raised, the potential difficulties involved and the clarity of the information provided. If necessary, further information will be sought.


Attending Meetings

When any meeting is arranged you have the right to be accompanied by a trade union representative where applicable or a workplace colleague who is not involved in the area of work to which the concern relates.



LKCS LLP will take steps to minimise any difficulties you may experience as a result of raising a concern. For instance, if you are required to give evidence in criminal or disciplinary proceedings, LKCS LLP will advise or arrange for you to have advice about the procedure.


Protection from Reprisals and Victimisation

LKCS LLP does not tolerate reprisals, victimisation or harassment and will take all reasonable action to protect you if you raise a concern via the Whistleblowing Policy and Procedure. LKCS LLP will treat any reprisals, victimisation or harassment as a serious matter and if this involves a LKCS LLP employee it will be investigated in accordance with the Disciplinary Procedure. In the event of a disciplinary case being found, this could potentially result in the person’s dismissal.

LKCS LLP accepts that you need to be assured that concerns will be properly addressed and, subject to legal constraints, will provide information about the outcomes of any investigations.


How the matter can be taken further

This procedure is intended to provide individuals with an avenue to raise concerns within LKCS LLP. If you are not satisfied, and feel it is right to take the matter further, the following are possible contact points:

  • Head of Human Resources Commercial Services Kent Ltd for and on behalf of the Executive Board - 01622 236914
  • Public Concern at Work - 020 7404 6609
  • Relevant professional bodies or regulatory organisations
  • A Solicitor
  • The Police


If a matter is taken outside LKCS LLP, you must take all reasonable steps to ensure that confidential or privileged information is not disclosed. If in doubt, check with the named LKCS LLP contacts.


Public Interest Disclosure

Public Interest Disclosure Act 1998 gives employees two safeguards in respect of disclosures of information.

  • An employee is entitled not be subjected to any

detriment by virtue of having made a protected disclosure.

  • The dismissal of any LKCS LLP employee directly due to the individual having made such a disclosure will automatically be unfair.


Policy Review

This policy and whistleblowing arrangements shall be reviewed by the LKCS LLP Board every two years or sooner if required to ensure its suitability, adequacy and effectiveness and improvements shall be made as appropriate.