Whistleblowing Policy

1.1 CasinoReviews.com is committed to the highest standards of openness, probity and accountability. To achieve these standards requires that there are clear mechanisms in place to allow staff a safe space to raise concerns about potential wrongdoing, breaches or failures within the company in a secure manner that ensures that their diligence is supported and concerns are appropriately investigated.

1.2 This policy provides a procedure for staff or other relevant parties (including contractors, agency workers, shareholders, board members, volunteers, unpaid workers, trainees, interns, sub-contractors, suppliers, applicants or previous employees) to raise concerns about a perceived wrongdoing openly, confidentially or anonymously, where there is a public interest element. It aims to help people who believe they have discovered malpractice or impropriety and to protect them from victimisation and reprisal should they raise concern in the public interest.

1.3 The protections offered by this policy may, in qualifying circumstances, apply to facilitators, colleagues or relatives of the reporting person who are also hold a work-related connection with CasinoReviews.com, or to legal entities that the reporting person owns, works for or is otherwise connected with in a work-related context.

1.4 This is often known as ‘whistleblowing’, which is the reporting of information which relates to suspected wrongdoing at work, including possible unlawful conduct, fraud, risks to the public or malpractice. This is not the same as a grievance, which relates to a dispute about an employee’s own employment position, or their interactions with other team members, and has no additional public interest dimension. Grievances are handled under the separate Grievance Procedure.

1.5 Where any of the parties detailed in term 1.2 have a concern, they should ordinarily report any the issue to their line manager. Where this is not possible, the matter should be raised with either a member of the Senior Leadership Team or our People and Talent Team. This is referred to as “open whistleblowing”, which refers to any report made internally without anonymity.

1.6 If you do not feel that this is possible or appropriate in the circumstances of your concern to either report the matter to the relevant team member internally, or you wish to remain anonymous when reporting, you may use the following procedure and be reassured that you can expose wrongdoing without risk to yourself.

1.7 For the sake of clarity, given the nature of the work undertaken by CasinoReviews.com, our Whistleblowing Policy is not an appropriate system to manage consumer complaints relating to the complaint management process or outcome of any complaint managed by this service.

2.1  CasinoReviews.com is committed to good governance and is dedicated to fostering a positive and open working environment where staff have a clear understanding of their responsibilities and Management are accountable for the decisions that are made.

2.2  We recognise that our staff are one of our most valuable assets when it comes to identifying potentially problematic practices within the business. This policy is put in place to ensure that there are clear and easily accessed channels to raise reasonable concerns at the earliest stages. This is known as whistleblowing.

2.3  The aims of this policy are:

2.4  The policy does not form part of any employee’s contract of employment and it may be amended at any time.

3.1  The Board of Directors has overall responsibility for approving the policy, and the Senior Leadership Team has responsibility for overseeing and reviewing the effectiveness of actions taken in response to concerns raised under the policy and to provide assurance to the Board.

3.2  A recipient of a whistleblowing disclosure as set out in this policy (at section 4) will, within seven days, report the content of the complaint and the proposed investigation procedure to the Chief Operating Officer. If a disclosure has been made confidentially, the name of the worker will not be included in this report without the worker’s prior consent.

3.3  CasinoReviews.com’s Chief Operating Officer is the designated Whistleblowing Officer and has day-to-day operational responsibility for the policy and must ensure that anyone who deals with matters under this policy is suitably experienced or trained. Where the Chief Operating Officer has a conflict of interest in dealing with any particular disclosure raised, the designated officer will be the Director who may act as designated officer or appoint another person.

3.4  Staff, Board Members and everyone working on behalf of CasinoReviews.com are responsible for the success of the policy and are encouraged to suggest ways in which it might be improved by sending these to the Chief Operating Officer.

4.1  A ‘whistleblowing disclosure’ is a report of information which an individual reasonably believes suggests that one of the following has occurred or may do so:

a. a criminal offence, for example fraud, financial irregularity, improper or unauthorised use of public funds, bribery or corruption etc;

b. someone’s health and safety is put in danger;

c. damage to the environment;

d. a miscarriage of justice;

e. breaking the law;

f. covering up wrong doing described in a-e above.

4.2. Workers who have information about suspected wrongdoing or danger in relation to our activities should report it under this policy. Workers should have a reasonable belief that raising the concern is in the public interest and should not raise malicious or vexatious matters that are not in the public interest.

4.3  The policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work where these do not have a wider public interest. In such circumstances, you should use relevant Grievance policies which the People and Talent team can provide.

4.4  If you are unsure about whether anything is within the scope of this policy you should seek advice from the Chief Operating Officer.

5.1 Disclosures can be made in person, over phone or video call, or in writing through a line manager, any other member of the Senior Leadership Team, or the Chief Operating Officer, who is the designated ’Whistleblowing Officer’. Our company policy is to facilitate as much remote work as possible, however where required in person meetings may be arranged to facilitate whistleblowing reports. Where you fee that an in person meeting is required, you should make a request to the Chief Operating Officer.

5.2 If the disclosure relates to the Chief Operating Officer, you should raise the complaint with the Director.

5.3 When making a disclosure under this policy, you should try to provide the following information:

5.4 Where you raise a concern, you should be open and transparent about any interest you hold in the outcome of the matter.

6.1  CasinoReviews.com will ensure that any disclosures made under this policy will be treated as entirely confidential. Only team members that are essential to actioning any actions required to rectify a confirmed issue, or required to fully investigate the issue will be informed of any information provided during a disclosure.

6.2  It is far easier to fully investigate disclosures that are open. Where you choose to make an anonymous disclosure, it becomes far more challenging for us to gather full supporting evidence, conduct a robust investigation, or confidently report back any actions that have been take as a result of our investigation.

Disclosures made anonymously will be reviewed, but whether an investigation proceeds will be at the discretion of the reviewing officer. Factors that may influence whether an investigation is undertaken include but are not restricted to:

6.3  When making a submission, you can include your name but request that it be kept confidential. This will allow us to revert to you with further questions and report back on any findings from the resultant investigation. Every effort will be made to protect the identity of any individual who requests that their disclosure be kept confidential.

7.1  Following receipt of a disclosure, the person contacted must report the matter to the Chief Operating Officer who will make a decision on how to proceed. If the Chief Operating Officer is subject to a conflict of interest or if the disclosure relates to the Chief Operating Officer, the report should be made to the Director.

7.2  If, upon review, the managing officer (the Chief Operating Officer or the Director) determines that the disclosure is more accurately categorised as a grievance the managing officer will bring the matter to the attention of the Head of People and Talent and the case will be handled under the Grievance Policy. Otherwise the following provisions will apply:

7.3  The Chief Operating Officer (or Director) will lead the investigation or appoint an investigation manager and/or team of investigators that may including staff with relevant experience of investigations or specialist knowledge of the subject matter including external investigators. The investigation will be conducted thoroughly and impartially.

7.4  The investigation manager will be responsible for:

7.5  Usually you will be offered a video call in confidence as soon as possible after the initial disclosure in order for an initial assessment to be carried out. You can request that another team member accompanies you for support at the interview.

7.6  You may be invited to attend additional meetings in order to provide further information.

7.7  To facilitate a detailed and thorough investigation of any whistleblowing report, and to ensure compliance with the legal standards that as a responsible stakeholder CasinoReviews.com is required to meet, detailed records of all interactions relating to any whistleblowing report. This includes recording any calls or videocalls.

7.8  Confidentiality may prevent us giving you specific details of the investigation or any disciplinary action taken as a result. Any information shared with you in the final report on the investigation should be treated as confidential.

8.1  The investigator(s) may make recommendations in the report to the Chief Operating Officer (or the Director) for change to enable us to minimise the risk of future wrongdoing and may also recommend disciplinary action or a wider investigation.

8.2  The Chief Operating Officer will submit the report and recommendations of the investigator to the Director/Board of Directors, who will consider the investigator’s report and may accept the recommendations in whole or in part and arrange for the Chief Operating Officer to put arrangements in place to implement the recommendations.

8.3  If you are dissatisfied with the outcome, you may raise your concern with the Director, if you are further dissatisfied you may this with the appropriate with the agencies depending on the subject matter of the disclosure.

8.4  If you need further help or advice you can obtain this from:

- UK: the charity Protect (formerly Public Concern at Work) which has a confidential helpline and website offering guidance on whistleblowing. [https://protect-advice.org.uk/]

- Malta: the Maltese Ministry of Justice provides detailed information on the rights and processes involved in the whistleblowing process. [https://justiceministry.gov.mt/en/justice/whistleblower/Pages/Questions-and-Answers.aspx#:~:text=For%20guidance%20on%20how%20to,.helpmail%40gov.mt.]

- Portugal: Transparency.org provide free and confidential legal advice supporting witnesses of corruption. [https://www.transparency.org/en/alacs]

8.5  CasinoReviews.com understands that in rare circumstances, it may not be possible to whistleblow internally with a reasonable expectation that the concern will be managed impartially. As such we recognise and support the rights of people to make disclosures to appropriate external agencies.

A full list of these prescribed bodies that can be found on the following websites:

UK - www.gov.uk 

Malta - https://www.gov.mt/mt/Pages/home.aspx

Portugal - https://www.portugal.gov.pt/

Spain - https://www.lamoncloa.gob.es/

9.1  Whistleblowing disclosures can leave the reporting party concerned about potential negative consequences for themselves. Legally, all businesses are required to ensure that reporting parties are shielded from any form of retributory action. Beyond our legal obligations our aim is to foster a supportive and open working culture where our team feel safe to raise reasonable concerns, secure in the knowledge that even if the investigation does not validate their concerns, they will face not detrimental consequences.

9.2  Anyone making a disclosure must not suffer any detrimental treatment as a result of making a disclosure. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with making a disclosure. If you believe that you have suffered any such treatment, you should inform the Whistleblowing Officer, the Chief Operating Officer, immediately. If the matter is not remedied you should raise it formally using our Grievance Procedure.

9.3  CasinoReviews.com has a zero tolerance policy with regard to victimisation or harassment of any person who raises any concern relating to our practices or activities that are in the public interests. No team member should engage in any conduct that could be reasonably considered to be threatening against anyone raising a whistleblowing concern. If you are found to have been involved in such conduct you may be subject to disciplinary action.

9.4 Wherever possible all disclosures will be treated as confidential and every effort will be made to shield employees or other persons cited within the disclosure. On these grounds, we may take the following actions:

9.5  All records relating to disclosures, subsequent investigation and actions taken will be managed in compliance with the GDPR, the UK GDPR, and CasinoReviews.com’s Retention and Disposal Policy.

9.6  You can also obtain confidential advice from Protect (formerly Public Concern at Work). This is an independent charity and is a leading authority on public interest whistle blowing. Reporting Outcomes

9.7  The Chief Operating Officer will consider whether any form of public reporting through its Board is appropriate.

10.1  CasinoReviews.com’s Chief Operating Officer:

10.2  CasinoReviews.com’s Director:

11.1 Can I raise a concern confidentially?

Yes. Simply make clear in your report that you would like your report to remain confidential.

11.2 Can I make a disclosure anonymously?

It is best to identify yourself, whether openly or in confidence, as this makes it easier to investigate a report and take appropriate action. It may not be possible to protect or reassure a person making a report if we do not know who you are. There are various organisations detailed in term 8.4 that can support you if you want to take advice on whether to include your name in your report.

11.3 What information should I provide?

It is helpful to provide supporting evidence such as dates, times and names although this is not required under the legislation and we encourage concerns to be raised as soon as possible.

11.4 Is a complaint or grievance different from whistleblowing?

A grievance generally will relate to a matter that you have a personal interest in, or where the potential outcomes could affect you directly. A complaint about how you have been treated at work should normally be raised as a grievance under the relevant HR policy and not under the whistleblowing policy.

Whistleblowing concerns tend to relate to larger scope issues that impact the public interest. Examples of potential whistleblowing issues would be illegal dumping of waste, or the distribution of dangerous products.

11.5 Can a whistleblowing concern relate to my own employment terms?

In July 2013, the whistleblowing legislation was changed to require a worker making a disclosure to have a reasonable belief that the disclosure was made “in the public interest”. Therefore it cannot be about an individual’s own employment contract and their personal situation. Any personal concerns should be raised with your line manager and we will look at them under CasinoReviews.com’s HR policies.

Whistleblowing disclosure must relate to a wider interest, for the organisation or a number of workers. This does not mean there is an actual public interest but whether the person raising a concern reasonably believes them to be in the public interest