RNS Chartered Accountants are committed to dealing responsibly, openly and professionally with concerns about possible illegal or negligent behaviour within the firm.
Introduction
Our values provide the foundation for what we believe will build long term sustainable success for the firm. We want to work in a way that promotes our values and ensures that we provide the best possible service for our clients, and best possible environment for our staff.
The firm is committed to dealing responsibly, openly and professionally with concerns anyone may have about possible malpractice within the firm. This whistleblowing policy provides a mechanism for team members and for third parties to raise genuine concerns, whilst offering protection from victimisation, harassment or disciplinary proceedings for those who do so.
Who does this policy apply to?
The policy applies to all Partners and staff, including those on permanent contracts, consultants and to those on work experience and to third parties who have a relationship with the firm or come into contact with its team members
What concerns are covered by this policy?
This policy covers situations where an individual raises a concern about illegal or negligent behaviour or wrongdoing that affects others such as clients, staff, the firm, suppliers or the public interest. Examples of the types of concerns to be raised under this policy are:
- Danger to health and safety
- Danger to the environment
- Breach of a legal obligation
- Negligence on the part of the firm
- Financial misconduct of the firm or any of its employees
- Wrongdoing by a client
- Poor work by a member or student of the ICAEW or other professional body
- Bribery and corruption
- Any attempt to cover up any of the above
What types of concerns are not covered by this policy?
This policy does not cover concerns or complaints about an employee’s own personal employment position. Generally speaking, a whistleblowing issue is one that affects others, e.g. clients or the firm, whereas a personal complaint is one where you believe you personally have been unfairly treated. If you are a team member raising a concern in relation to money laundering, please follow the firm’s Money Laundering Procedures or contact the firms Money Laundering Reporting Officer, John Heeney for guidance.
Clients who are dissatisfied with the service received from RNS are asked to follow the complaints procedure set out in their engagement letter.
Protection under this policy
You are not required to prove any matters raised under this policy. An honest and reasonable suspicion that malpractice has been or is likely to be committed is sufficient.
If you raise a genuine concern under this policy, you will not be at risk of losing your job or suffering any form of detriment as a result. Provided you are acting honestly and reasonably, it does not matter if you are mistaken about your concern.
Public Interest Disclosure Act 1998 (‘PIDA’)
Some disclosures will be “protected disclosures” under the PIDA if the individual raising the issue reasonably believes that the disclosure is made in the public interest and fits into the categories set out in the legislation. A whistleblower making a “protected disclosure” is given statutory protection and, providing certain conditions are satisfied, they have the legal right not to suffer a detriment as a result of their whistleblowing.
Please note the Public Interest Disclosure Act 1998 does not cover all matters you may be concerned with (please refer to the “What types of concerns” paragraph above).
Personal Liability
The firm will not tolerate the victimisation or harassment of team members who have raised a concern under this policy. All allegations of such treatment will be taken seriously and if well founded will usually be investigated under the firm’s disciplinary procedure as potential gross misconduct.
Anyone found to have treated a colleague in this way may be dismissed without notice or pay in lieu of notice.
Maliciously making a false allegation under this policy will constitute gross misconduct and will be investigated under the firm’s disciplinary procedure. Anyone found to have maliciously made a false allegation may be dismissed without pay or pay in lieu of notice.
What to do if you have a concern
RNS staff and partners: If you have any concerns about malpractice that you would like to raise, please speak to any partner in the first instance. You can do this orally or in writing. If, for any reason, you feel unable to raise the matter with a partner, you should refer the matter to another senior member of staff. When raising your concern, please make sure the person you raise the matter with knows you are raising it under this procedure.
Third parties: Please contact our Ethics Partner, Rob Smith.