Speak Up Policy and Procedure
Purpose
At Rapport, we are committed to operating with honesty, integrity and accountability. We encourage our people to “speak up” if they have questions or concerns about potentially unethical, unsafe or even illegal conduct.
We value the importance of speaking openly with your line manager about any concerns you may have. However, if for any reason you do not feel comfortable raising a concern with your line manager, you can do so using this policy and procedure.
You may see “speaking up” referred to elsewhere as “whistleblowing”.
Scope
Anyone carrying out some form of work for Rapport can “speak up” under this policy, including employees (full or part-time, temporary or permanent), contractors and interns. These people are referred to as “individuals” throughout this policy and procedure. As such, when we refer to “your line manager” throughout this procedure, this means your Rapport line manager / supervisor / primary contact.
Non-employees who do not carry out work for Rapport (including Board members, investors, job applicants, customers, visitors, office building staff and members of the public) are not protected by the Public Interest Disclosure Act 1998, unlike the people mentioned in 2.1. However, you may still wish to "speak up" about actual or potential wrongdoing using our External Speak Up Form on our website, which is found in paragraph 5.4.
“Speaking up” under this policy and procedure relates to reporting your concerns about actual or potential wrongdoing (be this illegal, unsafe or unethical) at Rapport which you believe has happened, is happening, or is likely to happen. You will typically be reporting these concerns because they could affect a number of other people as well as - or instead of - you personally.
Should you wish to make a complaint about something which directly affects you, you should instead refer to one of the following two methods:
For employees, the Grievance Procedure (e.g., to raise a grievance due to disrespectful treatment by a fellow employee).
For non-employees, i.e., Board members, contractors, interns, job applicants, suppliers, customers, visitors and office building staff (e.g., office security and cleaners), the Third Party Complaints Procedure.
Links to these two procedures can be found in section 9.
Examples of wrongdoing which could form the basis of speaking up include - but are not limited to - the following:
unlawful practices,
criminal offences,
financial malpractice, impropriety or fraud,
acts of bribery,
breaches of legal, regulatory or professional obligations,
miscarriages of justice,
serious health, safety and wellbeing risks to any individual(s),
environmental damage, or
deliberately suppressing or concealing information relating to the above.
Principles
All concerns raised under this policy in good faith (i.e., not malicious or vexatious as defined in section 4) will be treated seriously and acted on wherever possible, and no one will experience adverse treatment as a consequence of having spoken up under this policy, in accordance with the Public Interest Disclosure Act 1998. Legislative differences in other Rapport locations are detailed in Appendix 1.
All information will be treated as confidential unless its disclosure is absolutely necessary, in which case the individual(s) who raised the concern will be made aware.
In some circumstances, the individual(s) who have raised concerns may be asked to be a witness for the purposes of investigating the concerns. Where this is the case, we will ensure those who speak up are provided with the appropriate support and guidance.
Anyone will be able to speak up anonymously if they wish. With this being said, we encourage individuals to identify themselves when speaking up wherever possible, because this makes investigating, addressing and feeding back on concerns significantly easier. We will nevertheless give the same consideration to anonymous concerns, taking account of factors such as seriousness, credibility and likelihood of being able to confirm the concern from other sources.
We appreciate that alleged organisational wrongdoing can be very complex, so we are committed to investigating any concerns fully before taking action.
We will always seek the fairest resolution, including the involvement of law enforcement and other regulatory bodies where necessary.
Concerns which are not suitable to be handled under this policy will be progressed through the route deemed most appropriate, be this the Grievance, Disciplinary, Third Party Complaints or other procedures.
We will pursue strict disciplinary - and legal where appropriate - consequences for anyone found to have partaken in unethical, unsafe or illegal conduct under this policy.
Malicious and vexatious concerns
All concerns raised under this policy will be taken seriously. Concerns might be considered malicious or vexatious if an investigation finds:
you have made deliberately false allegations,
you have a continued pattern of unfounded allegations against the same person(s), or
you have generally reported concerns or given information in bad faith.
Such situations might result in Disciplinary action being taken against you.
PROCEDURE
Raising concerns with us
If you have a concern covered by this policy which you wish to speak up about, you should raise this - either verbally or in writing - with your line manager. Your line manager should then seek guidance by raising the issue with the People Team or Head of Operations as appropriate.
However, if for some reason you feel it would not be appropriate to raise the issue with your line manager, or if you have told them but remain concerned that the issue has not been addressed, you can raise the issue directly on our Internal Reporting Channel, which is submitted to the People Team.
You can speak up anonymously via the internal reporting channel, if you would prefer not to be identified when speaking up. We would nonetheless encourage you to identify yourself because this makes it much easier for us to investigate and provide feedback on your concerns.
Non-employees who do not carry out work for Rapport (including Board members, investors, job applicants, customers, visitors, office building staff and members of the public) can submit concerns to our People Team using our confidential External Reporting Channel. Any submissions will be anonymous unless you choose to provide your name and contact details. We would nonetheless encourage you to identify yourself because this makes it much easier for us to investigate and provide feedback on your concerns.
While you may wish to discuss your concerns with a close colleague before raising them, you should avoid discussing these once you have raised the concerns in the interests of maintaining confidentiality.
Line managers might be notified of concerns of the type covered by this policy. In these situations, line managers have a responsibility to recognise when such information needs to be progressed down the appropriate route, be this the Speak Up Procedure, Grievance Procedure or otherwise.
Responding to concerns
We are committed to ensuring that all concerns reported under this policy are handled fairly, consistently and in a timely manner, and aim to acknowledge receipt of the concern within five working days.
When responding to the initial concern, we will typically arrange a private meeting between the individual and a member of the People Team or the Head of Operations. This meeting will provide the opportunity for an initial discussion, to clarify what the concern is and to gather more information. You may bring a work colleague or, if relevant, a trade union representative, as a companion to this meeting if you prefer, although they must maintain the confidentiality of the meeting and any subsequent investigation.
The People Team member or Head of Operations will decide on the most appropriate next steps, including whether to initiate an investigation and any other important steps in the process. Where an investigation is required, the People Team member or Head of Operations will appoint an Investigating Officer who is suitably capable, aware of the subject matter and nonetheless independent from the concerns and process up to that point. Where appropriate to do so, the company may decide to appoint an independent external Investigating Officer and share relevant data, that may include personal data with them. The People Team member or Head of Operations will oversee the investigation and notify the individual(s) of the steps planned for the process. During the investigation itself, the Investigating Officer will update you on its progress and expected timescales, although it should be noted sometimes information may be limited in the interests of confidentiality.
Investigations might involve external subject experts and/or legal advice as required, whose point of contact will be the Investigating Officer. This should always be confirmed with the People Team or Head of Operations in advance.
Upon completion of any investigation, the Investigating Officer will submit a report with findings, proposed next steps and any recommendations (both individual and organisational) to the relevant member of the Executive Team. The recipient will consider the findings and decide on the outcome (i.e., that the allegations are upheld, partly upheld, or not upheld) as well as any next steps. This might involve liaising with relevant experts, the Executive Team and the Chair of the Board as deemed appropriate. An investigation might culminate in a recommendation that disciplinary action be considered, which would fall under the Disciplinary Policy and Procedure and be led by the People Team.
The individual who received the investigation report will decide the findings of the outcome of the matter and inform the individual(s), including - if appropriate and confidentiality allows - any action taken and next steps. We aim to provide this feedback within three months of the concerns being raised.
If you do not consider your concerns to have been adequately addressed, you can raise the issue with the People Team or another member of the Executive Team, provided they have not been involved in the process up to that point.
The People Team will keep a record of any concerns raised under this policy and will provide a summary report to the Executive Team, containing the concerns, action taken, and any thematic issues to address.
Where concerns have been raised anonymously, the same process as above will be followed, acknowledging that some steps (such as investigation) may be more difficult to carry out in practice due to the need to maintain anonymity.
Raising concerns with external authorities
In most cases, raising concerns directly with us will be the most appropriate course of action for you to take. However, the main purpose of this policy is to ensure you feel comfortable and safe to speak up, and we recognise in some circumstances you may feel unable to raise your concerns directly with us. In this situation, the law allows for you to raise the matter with another “prescribed person”. You can find a list for prescribed people and bodies (and their areas of responsibility) here.
Depending on the nature of the concern, relevant authorities may include those below or in the above paragraph:
We strongly encourage you to seek the appropriate advice before reporting a concern with an external authority. Protect (formerly known as Public Concern at Work) is a leading independent charity which aims to promote good practice and legal compliance within the public, private and voluntary sectors. This should be a helpful source of advice and further information if you are considering raising a concern externally. The Protect free confidential helpline is available on 020 3117 2520.
Please note that the media is not a relevant external body. Should you contact the media to raise allegations about the organisation, this could be subject to disciplinary action up to and including dismissal.
Support and protection when raising concerns
If you use this policy to speak up and raise concerns, you will not suffer any form of retribution or detrimental treatment regardless of whether your concern turns out to be mistaken. The Public Interest Disclosure Act 1998 protects individuals from any detrimental treatment in relation to speaking up, including harassment or victimisation by the organisation or colleagues. If you believe you have suffered such treatment, you should inform the People Team immediately, who will take action to resolve the issue. This might involve directing you to the Grievance Procedure.
No one working for Rapport may seek to prevent a concern being raised, threaten or retaliate against anyone who has raised a concern or been involved in an investigation under this policy, regardless of whether the concern turns out to be mistaken. Retaliation can take many forms, be this obvious or subtle behaviour including (but not limited to):
suspension,
dismissal,
negative performance reviews,
intimidation,
unequal treatment,
non-renewal of a fixed term contract,
damage to reputation,
bullying,
etc.
Refer to the Dignity and Respect at Work Policy for more information, examples and guidance in the event of others disrespecting you or violating your dignity at work, including when you have assisted someone who raised a concern rather than raising one yourself. A link to this policy can be found in section 9.
Threats, retaliation or any other attempts to prevent a concern being raised or investigated will be handled under the Disciplinary Policy and Procedure and may amount to gross misconduct.
Note, however, that if you do not follow the procedure set out above, which encompasses the requirements of The Public Interest Disclosure Act 1998, the protection against detriment may not apply.
Employee Assistance Programme (EAP)
Our EAP is free and confidential for all employees to use. You can access the EAP for employees here.
Related documents
The following documentation may be used in conjunction with this policy:
Additional information
This policy does not form part of your contract and we may choose to alter it at any time.
Overall responsibility for policy implementation and review rests with the policy owner as specified in the table below.
Should you have any questions or feedback regarding this policy, please contact the People Team.
Version | 1.0 |
Policy owner | People Team |
Last reviewed | July 2025 by Scott McCrory-Irving |
Review frequency | Every year |
Next review | July 2026 |
Appendix 1 - Regional variations
Hungary
3.1 Employees (and other people who carry out work of some form, including Board members) in Hungary are protected by the Whistleblower Protection Act 2023, which implements the EU Whistleblowing Directive 2019.
More information on the protections of this legislation (which is very similar to the UK) can be found here. Note that we are too small an organisation to have a legal obligation to set up a reporting channel.
EU Countries
3.1 The Whistleblowing Directive 2019 affords protections to employees (and others who carry out work of some form, including Board members) which are detailed here.
Singapore
3.1 There is no specific protection legislation related to whistleblowing in Singapore, although there are specific protections related to disclosures surrounding corruption and drug misuse within the Prevention of Corruption Act 1960 and the Misuse of Drugs Act 1973 respectively.
USA
3.1 There is a variety of protective legislation in relation to whistleblowing in the USA which can be found here.
Regardless of the protective legislation in the country you are based, we will abide by our principles laid out in this policy that no one who speaks up in good faith will experience adverse treatment as a consequence.
Note for all of the above that the relevant legislation for you will depend on your relationship with the Company. If in doubt, either contact the People Team or Protect charity (link available at paragraph 6.3 above).