1. Policy Statement
Livewell Corporate Ltd is committed to maintaining the highest standards of integrity, professionalism, accountability and ethical conduct across all areas of the business.
We encourage all employees, contractors, self-employed practitioners, agency workers, suppliers and other stakeholders to raise genuine concerns where they believe wrongdoing, misconduct, unlawful activity or unsafe practice may be taking place.
This policy exists to provide a clear and confidential route for reporting concerns, ensuring that individuals who raise concerns in good faith are protected from retaliation or detrimental treatment.
This policy is intended to support compliance with the Public Interest Disclosure Act 1998 (PIDA), relevant employment legislation, safeguarding responsibilities and good corporate governance.
2. Scope
This policy applies to:
- Employees
- Directors
- Self-employed practitioners
- Associate therapists
- Contractors
- Temporary workers
- Agency staff
- Consultants
- Volunteers
- Suppliers
- Business partners
- Third-party service providers
This policy applies across all Livewell Corporate Ltd operations including:
- Clinics
- Mobile healthcare services
- Corporate wellbeing services
- Health screening and assessments
- Event recovery services
- Administrative functions
- Training and education services
- Supplier and subcontractor relationships
3. What is Whistleblowing?
Whistleblowing is the reporting of information where an individual reasonably believes wrongdoing, risk or unlawful activity is occurring, has occurred or may occur.
This may include concerns relating to:
- Criminal activity
- Fraud or financial misconduct
- Bribery or corruption
- Theft
- Health and safety breaches
- Unsafe clinical practice
- Safeguarding concerns
- Abuse or neglect
- Data protection breaches
- Confidentiality breaches
- Regulatory non-compliance
- Modern slavery or exploitation
- Discrimination or serious misconduct
- Harassment or bullying
- Environmental harm
- Deliberate concealment of wrongdoing
This list is not exhaustive.
4. Matters Covered by Other Procedures
This policy is intended for concerns raised in the public interest.
It is not generally intended for personal employment grievances such as:
- pay disputes
- holiday disagreements
- interpersonal conflicts
- contract disputes
- dissatisfaction with management decisions
These matters should usually be addressed through the appropriate grievance or management procedures unless wider wrongdoing is involved.
5. Protection for Whistleblowers
Livewell Corporate Ltd will not tolerate retaliation against any individual who raises a genuine concern in good faith.
This includes protection from:
- dismissal
- contract termination
- disciplinary action
- intimidation
- threats
- victimisation
- unfair treatment
- discrimination
- loss of work opportunities
A person does not need to prove wrongdoing has occurred, only that they reasonably believe the concern is genuine and raised honestly.
Malicious or knowingly false allegations may however result in appropriate action.
6. Confidentiality
Livewell Corporate Ltd will treat whistleblowing concerns seriously and, where possible, confidentially.
Information will only be shared on a need-to-know basis to allow appropriate investigation, safeguarding action or legal compliance.
Whilst confidentiality will be respected wherever possible, complete anonymity cannot always be guaranteed where formal investigation or legal proceedings are required.
Anonymous disclosures will be considered, although investigation may be more limited where insufficient information is provided.
7. How to Raise a Concern
Concerns should be raised as soon as possible.
Where possible, individuals should provide:
- details of the concern
- dates, times or locations if relevant
- names of individuals involved where known
- supporting evidence where available
- explanation of why the concern is believed to be serious
Reports can be made verbally or in writing.
Concerns should normally be reported to:
Managing Director
Steven Hartill
Livewell Corporate Ltd
43 Emmanuel Road
Sutton Coldfield
B73 5LY
Email: info@livewellhealth.co.uk
Telephone: 0330 043 2501
If the concern relates to senior management, the concern should be raised to an alternative director or relevant external authority.
8. External Reporting
Where appropriate, concerns may also be raised externally with:
- Police
- Health and Safety Executive (HSE)
- Information Commissioner’s Office (ICO)
- Care Quality Commission (where relevant)
- Safeguarding authorities
- HMRC
- Professional regulatory bodies
- Modern Slavery Helpline
- Legal advisers
Emergency safeguarding or safety concerns should be reported immediately to 999 where urgent action is required.
9. Investigation Process
Once a concern is raised, Livewell Corporate Ltd may:
- acknowledge receipt
- conduct an initial review
- gather relevant information
- interview relevant individuals
- escalate to safeguarding or regulators if required
- seek legal or specialist advice
- take interim protective action where necessary
The exact process will depend on the nature and seriousness of the concern.
Not all concerns will result in formal investigation, but all genuine concerns will be considered appropriately.
10. Outcomes
Depending on findings, outcomes may include:
- no further action
- management intervention
- additional monitoring
- process improvements
- disciplinary action
- suspension
- contract termination
- safeguarding referral
- police involvement
- regulatory notification
- legal action
Where appropriate and lawful, feedback may be provided to the individual raising the concern.
11. Record Keeping
Livewell Corporate Ltd may maintain confidential records of whistleblowing concerns including:
- date raised
- nature of concern
- actions taken
- investigation outcomes
- lessons learned
Records will be handled in accordance with applicable confidentiality and data protection obligations.
12. Training & Awareness
Relevant personnel may receive awareness regarding:
- how to identify reportable concerns
- safeguarding escalation
- health and safety reporting
- ethical business conduct
- confidentiality expectations
13. Policy Monitoring & Review
This policy will be reviewed periodically to ensure continued legal compliance, effectiveness and alignment with organisational risk.
Approval
Steven Hartill
Managing Director
Livewell Corporate Ltd