Whistle blowing policy 

The Capita Group is committed to applying a whistleblowing policy because it is in the interests of its employees, customers, shareholders and industry regulators. This document sets out what the whistleblowing policy is intended to achieve and how the mechanism should and should not be used in accordance with industry best practice.

What is whistleblowing?
Whistleblowing refers to the disclosure by an employee of serious, potentially criminal matters that have taken place or are taking place within an organisation to a line manager, independent manager or external body.

Examples of such matters include:

• all suspected fraudulent activity/serious management malpractices or unlawful behaviour (eg, theft, misrepresentation, insider dealing)
• failures to comply with applicable regulations eg, health and safety guidance
• failures to comply with Group policy
• reckless conduct in the workplace.

What is PIDA?
PIDA stands for the Public Interest Disclosure Act 1998. PIDA gives protection in law to employees who make a ‘qualifying disclosure’. If there are no established channels for making qualifying disclosures within an organisation, or in cases where those that are the subject of the disclosure are at very senior level in the organisation, then PIDA will protect an employee who makes a qualifying disclosure to a regulator. For the financial services industry, which is of relevance to parts of Capita, the regulator is the Financial Services Authority (FSA).

The PIDA requires that, where organisations have established their own appropriate channels, qualifying disclosures should wherever possible be made in accordance with those procedures. This policy establishes and explains the relevant procedures within Capita for this purpose.

What is a qualifying disclosure?
A qualifying disclosure is any disclosure of information which the employee making the disclosure believes indicates that one or more of the following has been committed, is being committed, or is likely to be committed:

• criminal offence
• failure to comply with legislation
• miscarriage of justice
• the health and safety of any individual endangered
• damage to the environment
• intentional misreporting of performance data
• deliberate concealment of information relating to any of the above.

What is Capita’s policy on whistleblowing?
Capita must be made aware of matters of malpractice covered by the above definition of a qualifying disclosure.

The details of any concern should be reported honestly, accurately and without malice.

Capita takes malpractice seriously. Practical examples of possible malpractice include for example fraud, insider dealing, money laundering, financial misrepresentation, drug or alcohol abuse and withholding evidence from an internal or external enquiry.

We will respect the wishes of staff raising concerns if they ask for confidentiality, but Capita may need to act to protect its employees, clients and business. Capita may also have a duty to pass information to the FSA or another regulatory/enforcing authority.

What should I do if I suspect malpractice?
It is preferable that whistleblowing concerns are raised as soon as you have a reasonable suspicion, you are not expected to investigate your concerns to prove its validity.

In the first instance, you should raise any concerns you have with your line manager, director in charge or any other senior person within Capita with whom you feel comfortable. They will either act on the information that you give them, or pass it to the relevant person who can deal with it.

In regulated businesses, they will inform the compliance team if the matter has potential regulatory impact. If you suspect that fraud may have occurred, please refer to the Group Fraud Policy for details of how to escalate the matter.

If the matter is not dealt with in a manner you feel is appropriate, or it is not possible to discuss the matter with your line manager for any reason, the matter should be reported to the Group Head of Risk Management, Group Compliance Director or the Group HR Director in accordance with the procedure below.

If the matter is connected with a Group Executive or main Board Director, the matter should also be reported to the Group Non-Executive Chairman.You may call or email these individuals when it is convenient for you. They will either speak to you or arrange to meet you, on or off Capita’s premises and outside office hours if necessary.

What are the consequences for me of blowing the whistle?
You should satisfy yourself that in making your disclosure you are acting in good faith and that you genuinely believe that the information and allegations are substantially true.

Capita will not divulge your identity to the subjects of the disclosure, unless it is absolutely necessary to do so.

You will not in any way be liable to disciplinary action or loss of benefits, rights or prospects as a result of your action.

We may also take advantage of the full range of disciplinary sanctions against any employee who acts or attempts to act in a way prejudicial to you as a result of you making a qualifying disclosure, which may ultimately result in reporting their actions to the appropriate regulatory/enforcing body.

Capita reserves the right to treat malicious or false allegations under the Group’s disciplinary procedure, without reference to the whistleblowing policy.

What does whistleblowing NOT apply to?
The most obvious situation is an employment matter. Employment matters should be dealt with in accordance with the Capita Grievance Procedure as set out in the employee handbook. The whistleblowing policy will not apply in these circumstances.

The Capita Group Plc