Trinity Mirrror

Back

Disclosure Policy

Trinity Mirror aims to conduct its business activities not only within the law, but also with fairness and integrity. We wish to create a working environment within which individual employees feel able to bring to the attention of the Company, concerns about particular incidents of wrongdoing, or other suspected malpractice, without fear of criticism or future discrimination. Staff are encouraged to speak out and report any such wrongdoing or malpractice, as outlined in the following policy for staff.

Who does the Policy apply to?

The Policy applies to any permanent employee, temporary employee or contractor, who reports, in good faith, a concern that:

  • A criminal offence has been, is being, or is likely to be committed;
  • There has, is or likely to be a failure to comply with legal obligations;
  • A miscarriage of justice has, is or is likely to take place;
  • The health or safety of an individual has been, is being, or is likely to be endangered;
  • The environment has been, is being or is likely to be damaged;
  • Unethical behaviour, malpractice or wrong doing of any description, including bribery, has been, is being or is likely to take place;
  • Information that proves that any matter falling within the above has been, is being or is likely to be deliberately concealed.

The Policy will also apply to the reporting of any breaches of the Company's policies on discrimination, harassment and or of the persistent and deliberate avoidance of agreed processes or systems.

How can staff make a disclosure of suspected wrongdoing?

If staff wish to raise a concern, the earlier it is done the better. Every incident will be treated seriously and sensitively and will be fully investigated. In the first instance, staff should speak to their line manager. If, for whatever reasons, the individual does not feel comfortable with this, he or she should speak to the manager's manager. Again, if that is not appropriate, he or she should contact one of the following people:

  • Group HR Director
  • Group Security Manager
  • Group Health and Safety Manager
  • Secretary and Group Legal Director

Whoever is approached will take suitable action and give appropriate feedback.

Will employees be protected from reprisals because of making a disclosure?

We recognise the sensitivity of raising such issues and we undertake to treat details of individuals who report matters with the utmost confidence. This means that the individuals identity will not be disclosed unless it is absolutely necessary to do so in connection with the investigation of the disclosure.

Provided that the disclosure is made in good faith, and the employee has genuine cause for concern, no action will be taken against him or her, nor will there be any threat to his or her career prospects. Retaliation or victimisation from any member of the Company because of the disclosure will not be tolerated.

However, making a disclosure will not affect the outcome of any disciplinary proceedings that the individual may already be undergoing for whatever reason.

Who may not be protected?

Any individual who:

  • Does not make a disclosure in good faith;
  • Has made the disclosure principally for the purpose of obtaining payment or personal gain;
  • Does not have reasonable grounds for suspicion and does not take reasonable steps to raise the matter through the designated internal channels before making the disclosure to external parties.

Any attempt by any member of the organisation to deter an individual from making a disclosure, victimising them or making life difficult for them because of a disclosure, perceived or actual, will be a serious disciplinary offence and may lead to dismissal.