Whistleblowing

Our commitment

FE fundinfo is committed to maintaining the highest standards of conduct and strives to operate within a culture of ethical and appropriate corporate behaviour in all business activities. This includes ensuring that we act with integrity, honesty, and in accordance with good governance principles.

Summary of FE fundinfo's whistleblowing policy

FE fundinfo's whistleblowing policy aims to encourage and facilitate the reporting of any suspected wrongdoing within the company or by its staff, in line with the company's commitment to ethical and appropriate corporate behaviour.

What is whistleblowing and when to raise a concern

Whistleblowing is the disclosure of information or raising of concerns about illegal or unethical conduct that may harm the reputation, financial well-being, or legal obligations of the company or its staff. In this context wrongdoing refers to illegal or unethical conduct within the FE fundinfo Group which may include, but is not limited to:

1. unethical conduct such as serious conflicts of interest, serious improper conduct or misuse of sensitive or confidential information;
2. breach of FEfi Group's policies and/or procedures;
3. behaviour that harms or is likely to harm the reputation and/or financial well-being of one or more FE fundinfo Group entities;
4. a criminal offence or regulatory breach;
5. a miscarriage of justice;
6. bribery;
7. fraud;
8. slavery, servitude and/or forced or compulsory labour;
9. financial mismanagement;
10. negligence;
11. putting the health or safety of an individual in danger;
12. damage to the environment; or
13. concealment of any of the above.

Who can raise a concern 

Any current or former staff member, director, officer, shareholder, manager, or applicant of the company can raise a concern, as long as they have reasonable grounds to suspect the issue or behaviour falls within the scope of the policy.

How to raise a concern

A concern can be raised through the usual supervisory or reporting channel, by contacting the team at [email protected], by contacting another FE fundinfo entity, or by using the Safecall system, which is an independent and confidential service available 24/7. A concern can be raised in writing or verbally, and can be anonymous if preferred. As much information as possible should be provided to assist the investigation. See the following link for Safecall’s international freephone numbers https://www.safecall.co.uk/en/file-a-report/telephone-numbers, alternatively Safecall can be contacted via the web https://www.safecall.co.uk/report/. 

Next steps

The relevant team that receives a concern will acknowledge the receipt of the concern within seven days, verify its validity, and decide whether to conduct an investigation. The whistleblower will be provided with a status update or response within three months, unless prohibited by law. The investigation will be carried out in a fair and impartial manner, and may involve appointing an external person or entity or referring the matter to an external authority.

Confidentiality

The identity of the whistleblower and any individuals mentioned in the concern will be protected as far as possible, unless disclosure is required by law or necessary for the investigation. Anyone involved in the process should respect the confidentiality of the information.

Whistleblower protection

The company will take steps to ensure that whistleblowers do not suffer any detriment or victimisation as a result of raising a concern. Anyone responsible for such conduct may face disciplinary action. Whistleblowers may also access counselling services through the Employee Assistance Program.

Consequences of malicious or false reporting

Whistleblowers should act in the public or the company's interest and have reasonable grounds to believe that the information they report is true. Whistleblowers who make false or malicious reports may lose the protection of the Whistleblowing policy.

External disclosure

Whistleblowers are encouraged to use the internal mechanism provided by the policy, but may also report their concerns to an external body such as a regulator or other reporting body established by law, subject to certain conditions and limitations. Whistleblowers should seek advice before making an external disclosure.