Whistle Blowing Policy

ABOUT THIS POLICY

1. We are committed to conducting our business with honesty and integrity and we
   expect all staff to maintain high standards. Any suspected wrongdoing should be
   reported as soon as possible.
2. This policy covers all employees, officers, consultants, contractors, volunteers,
   interns, casual workers and agency workers.
3. This policy does not form part of any employee’s contract of employment,
   however, we expect that its principles and procedures should be followed by all workers
   within its scope. We reserve the right to amend the content of this policy, as necessary,
   from time-to-time.
4. A disclosure under this policy can relate to any wrongdoing anywhere in the
   world; it is not restricted to matters purely arising just in the UK or US.

WHAT IS WHISTLE BLOWING?

Whistle blowing is the reporting of suspected wrongdoing or dangers in relation to our
activities. This includes bribery, fraud or other criminal activity, miscarriages of justice,
health and safety risks, damage to the environment and any breach of legal, ethical or
professional obligations. It also includes the following non-exhaustive list of matters
which may be specific to this workplace:

• Malpractice or ill treatment of a patient/client/customer by a member of staff
• Breach of standing financial instructions
• Showing undue favour over a contractual matter or to a job applicant
• Breach of any relevant code of conduct
• Attempts to conceal any of the above

HOW TO RAISE A CONCERN

1. We hope that in many cases you will be able to raise any concerns with your
   manager. However, where you prefer not to raise it with your manager for any reason,
   you should contact the Head of Human Resources or the Chief Executive Officer. Contact details are at the end of this policy.
2. We will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague or union representative to any meetings under this
   policy. Your companion must respect the confidentiality of your disclosure and any
   subsequent investigation.

CONFIDENTIALITY

We hope that employees, volunteers and others will feel able to voice whistle blowing
concerns openly under this policy. Completely anonymous disclosures are difficult to
investigate. If you want to raise your concern confidentially, we will make every effort to
keep your identity secret and only reveal it where necessary to those involved in
investigating your concern.

EXTERNAL DISCLOSURES

1. The aim of this policy is to provide an internal mechanism for reporting,
   investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally.
2. In some circumstances it may be appropriate for you to report your concerns to
   an external body such as a regulator. We strongly encourage you to seek advice before
   reporting a concern to anyone external.

PROTECTION AND SUPPORT FOR WHISTLEBLOWERS

1. We aim to encourage openness and will support whistleblowers who raise
   genuine concerns under this policy, even if they turn out to be mistaken.
2. Whistleblowers must not suffer any detrimental treatment as a result of raising a
   genuine concern. If you believe that you have suffered any such treatment, you should
   inform the Head of Human Resources or the Chief Executive Officer immediately.
3. You must not threaten or retaliate against whistleblowers in any way. If you are
   involved in such conduct you may be subject to disciplinary action.
4. However, if we conclude that a whistleblower has made false allegations
   maliciously or with a view to personal gain, the whistleblower may be subject to
   disciplinary action.

CONTACTS

Whistle blowing Officer – Head of Human Resources

whistleblowing@eltonjohnaidsfoundation.org

020 7603 9996