Approved by Raymond Cullen, Managing Director — next review January 2027
How anyone working for Cullen Utilities Ltd can raise concerns about suspected wrongdoing, and the protections in place for doing so.
Cullen Utilities Ltd is committed to conducting business with honesty and integrity, and expects all staff to maintain high standards. We recognise that things can go wrong, and that a culture of openness and accountability is essential to prevent or address such situations. This policy applies to everyone who works for the firm in the UK, including partners, employees, contractors and subcontractors, agency staff, consultants, and work-experience or other trainees.
Whistleblowing is the disclosure of information relating to suspected wrongdoing — generally a breach of a legal, statutory or regulatory requirement, or unethical behaviour. This may include a violation of a legal requirement such as health and safety obligations, general malpractice, gross misconduct, or a potential breach of the Pensions Act 2004, Proceeds of Crime Act 2002 or Bribery Act 2010.
An individual making a protected disclosure is given statutory protection from victimisation under the Public Interest Disclosure Act 1998 (PIDA), provided the disclosure is in the public interest. A protected disclosure is one that, in the reasonable belief of the person making it, tends to show a criminal offence, a failure to comply with a legal obligation, a miscarriage of justice, a danger to someone's health or safety, damage to the environment, or the deliberate concealment of any of these.
All whistleblowing disclosures are treated as confidential. To report a concern, contact the company director, Raymond Cullen, directly in person or by email, and make clear you are raising it under this policy so we can investigate and protect your identity. We will keep you informed of progress and its likely timescale, though the need for confidentiality may limit the specific details we can share.
We hope staff feel able to voice concerns openly, but where you wish to raise a concern confidentially we will make every effort to keep your identity secret and will discuss it with you if it needs to be revealed. We do not encourage anonymous concerns, as proper investigation is harder, but they will still be taken seriously. We support staff who raise genuine concerns, even if they turn out to be mistaken.
This policy provides an internal route for reporting and remedying wrongdoing, and in most cases you should not need to alert anyone externally. In some circumstances it may be appropriate to report to an external regulator, such as the Health and Safety Executive; it will rarely if ever be necessary to alert the media. The independent whistleblowing charity Protect offers free, confidential advice on its UK helpline (020 3117 2520) and Scottish helpline (0141 550 7572).