If you’re a whistleblower, you shouldn’t be treated unfairly or lose your job because you reported the problem. The Compliance Officer of the Südzucker AG only processes personal data which are objectively essen- tial in order to examine, confirm or eliminate grounds for suspicion. No sensitive personal details such as ethnic origin, political views, religious persuasion, membership in a trade union or details about the health or sexuality of the person are ever processed.

Only breaches in relation to stakeholder schemes, or other personal pension schemes where a direct payment arrangement exists, will be of material significance to the Pensions Regulator. The new regulations introduce one exception to the discretionary approach to taking action over reported breaches of the law described in paragraph 71 of this code of practice. They introduce a number of new governance standards that trustees must report against in an annual statement signed by the chair of trustees. Trustees who do not produce this chair’s statement will be fined between £500 and £2,000. If you are thinking of raising a whistleblowing concern under this Policy but feel you need advice before speaking to anyone, you may wish to take independent legal advice from a lawyer. Under the Public Interest Disclosure Act 1998, an employee can report to the FRC concerns in relation to matters which are within the scope of the FRC’s regulatory duties, and such disclosures will be protected if certain criteria are fulfilled.

The Requirement To Report Breaches

Any failure to comply with whistleblowing requirements may give rise to Employment Tribunal claims from a whistleblower who suffers a detriment and/or dismissal resulting from reporting concerns. The FCA rules on whistleblowing are primarily contained in the FCA Handbook under the ‘Systems and Controls’ section, which contains a chapter on whistleblowing (SYSC 18). These rules apply to a broad range of financial services firms, including banks, building societies, credit unions, insurers, investment firms, mortgage lenders, and consumer credit firms.

For example, the Pensions Act 2004 is an enactment as are regulations made under that Act. meldesystem-whistleblower of criminal law, such as an offence of dishonesty under the Theft Act, would also come within the term enactment. In all cases, the Pensions Regulator expects reporters to act conscientiously and honestly, and to take account of expert or professional advice where appropriate. We will not encourage you to proactively obtain any further information from any source, whatever the circumstances, but we may ask you to clarify the information you have already provided. The University is committed to conducting its affairs in a responsible way, taking into account the requirements of funding bodies as well as our principles of academic freedom.

Thus, any serious concern that a member of staff has about any aspect of service provision, the conduct of officers, members of the Council or others acting on behalf of the Council can and should be reported under this policy. Your concerns may relate to something which is happening, has already happened or is likely to happen in the future. When an individual blows the whistle, they are raising a concern about a danger or illegality that affects others (for example customers, members of the public, or their employer). The person blowing the whistle is usually not directly, personally affected by the danger or illegality. Consequently, the whistleblower rarely has a personal interest in the outcome of any investigation into their concern, they are simply trying to alert others. All reporters should establish a procedure for evaluating matters to determine whether a breach has occurred and, if it has, whether it is likely to be of material significance to the Pensions Regulator.

Deletion Of Registered Data

All firms regulated or authorised under the Financial Services and Markets Act 2000 are subject to the Senior Management and Certification Regime (‘SM&CR’). Implemented by the FCA, the SM&CR is a regulatory framework aimed at promoting a culture of responsibility and accountability within financial firms. If you want to blow the whistle you can either use the procedures where you work or contact the PSR via the FCA’s Intelligence Department. Reports must be investigated within three months, extendable for an additional three months.

This facility can be used by anyone affected by CBM Global’s work, including partner organisations, programme participants and community members. WhistleB provides a user-friendly whistleblowing system that employees and external stakeholders can use to report suspected ethical and compliance-related misconduct. The Assistant Director (SWAP) will provide an annual report to the Council’s Audit and Governance Committee which has responsibilities for overseeing the effectiveness of the Council’s governance arrangements as well as the Standards Committee. All reporting will be anonymised and will only identify common themes, numbers of disclosures year on year and will highlight actions taken to improve systems and policies. Initial concerns may be raised orally or in writing, although normally it is preferable to put the concern in writing, and there may be occasions when it will be necessary to go back to the whistleblower to confirm the complaint in writing. The whistleblower is invited to set out the background and history of the concern, giving names, dates and places where possible, and the reason why this is of particular concern.

Whistleblowers who submit information in good faith – confidentially and/or anonymously – shall not suffer any adverse consequences. The ‘Südzucker Compliance Line’ is an electronic communication platform with certified data protec- tion credentials. It exists to receive and to process notifications of compliance violations in a secure and confidential manner.

We have experience reviewing existing whistleblower systems and implementing whistleblower systems “from scratch”. Our holistic consulting approach takes into account not only the requirements of the HinSchG, but also the labour law and data protection requirements that apply in this context, which should not be underestimated. The internal reporting point can be staffed by an employee of the company or a work unit consisting of several employees. However, a third party (e.g., an external lawyer) can also assume this function for the company. According to the explanatory memorandum to the Act, the establishment of a central reporting point within a group of companies is also permissible. When setting up a whistleblower system, it must be ensured that the procedure meets the requirements of the GDPR in terms of data security.

Information should be submitted by named individuals because many investigations can be car- ried out faster and more effectively if the name of the source is known. Südzucker assures strict confidentiality of the identity of the whistleblower at all times (see Point 3.3). Complying with statutory regulations and internal rules is top priority at Volkswagen Financial Services UK (VWFS) and we are committed to the highest standards of openness, propriety and accountability. In line with that commitment we encourage our employees to come forward with any serious regulatory concerns on the basis of having reasonable suspicion. Grievances are concerns, problems or complaints raised by a staff member with management. Anybody may at some time have problems with their working conditions or relationships with colleagues that they may wish to raise.