WHISTLEBLOWING POLICY

At Earthhaven Healthcare Solutions Ltd., we recognize the critical importance of whistleblowing as a means to maintain the highest standards of safety, integrity, and compliance within our operations. This policy is designed to support our commitment to transparency and accountability, providing clear guidance on how whistleblowing works within our organization. It outlines the processes for raising concerns and the protections offered to whistleblowers, ensuring that all employees understand their role and the support available to them.

Whistleblowing occurs when an individual, typically an employee, exposes information or activities within their workplace that are deemed illegal, unethical, or not correct. The action of whistleblowing involves reporting types of wrongdoing that affect others, such as colleagues, the organization itself, or the general public.

Criteria for Whistleblowing
For a disclosure to be considered whistleblowing:Public Interest: The reported issue must involve matters of public interest, affecting health, safety, or the general welfare of the public or the organization's integrity.
Type of Wrongdoing: Common types of reportable wrongdoing include:
Violations of legal obligations.
Miscarriages of justice.
Dangers to health and safety.
Damage to the environment.
The cover-up of any of these.

Legal Protections for Whistleblowers
By law, whistleblowers are afforded significant protections designed to encourage the reporting of misconduct without fear of retaliation:Protection from Retaliation: Whistleblowers should not face any form of unfair treatment, discrimination, or job loss as a consequence of reporting wrongdoing.
Confidentiality: Efforts should be made to protect the identity of the whistleblower to the extent possible and permissible under the law.

Timing of Disclosures
Historical, Present, and Future Wrongdoing: Concerns can be raised about incidents that occurred in the past, are ongoing, or are believed to be potential future risks or malpractices.

At Earthhaven Healthcare Solutions Ltd., we are committed to fostering an environment of openness and transparency. We understand the crucial role that our employees play in maintaining high standards of care and operational integrity. As such, we actively encourage staff to report any practices or behaviors that deviate from our accepted standards.

Core Principles of Our Whistleblowing Policy
Encouragement of Open Communication:
We strongly encourage all employees to voice concerns about any aspect of our operations that they believe falls short of legal, ethical, or company standards. Recognizing that employees are often the first to know when something is going wrong, we value their input in identifying potential malpractices.
Serious Consideration of Concerns:
Every concern raised by our employees is taken seriously. We ensure that all issues are treated with the utmost seriousness and confidentiality, reflecting our commitment to addressing potential issues promptly and effectively.
Fair and Respectful Treatment:
It is crucial that employees raising concerns are treated fairly and with respect. We are committed to ensuring that no employee is stigmatized or penalized for raising genuine concerns. Our organizational culture supports and protects those who, in good faith, report wrongdoing.
Thorough and Impartial Investigations:
All reported concerns undergo a thorough and impartial investigation. Our process for investigating whistleblowing claims is consistent with our approach to handling complaints from service users or their representatives, ensuring transparency and fairness in addressing all grievances.
Protection from Retaliation:
In accordance with the Public Interest Disclosure Act 1998, we are committed to safeguarding our staff from any form of victimisation or retaliation. Employees who report concerns in good faith can be assured of protection against any adverse consequences as a result of their disclosure.
Legal Compliance:
Our whistleblowing procedures are designed to comply with all relevant laws and regulations. This compliance reinforces our dedication to lawful and ethical conduct across all aspects of our operations.

Implementation and Awareness
Training and Awareness: We provide regular training and awareness sessions to ensure that all employees understand the whistleblowing policy and feel confident in their ability to raise concerns.
Communication Channels: Multiple channels are available for employees to raise concerns confidentially and securely. These channels are clearly communicated to all staff and are easily accessible.

At Earthhaven Healthcare Solutions Ltd. (EHS), our whistleblowing policy and procedures are essential tools for maintaining and enhancing the quality of the services we provide. This policy is designed to ensure that any issues of wrongdoing or malpractice are addressed swiftly and effectively, safeguarding our commitment to operational excellence and ethical conduct.

Objectives of the Whistleblowing Policy
Prompt and Effective Action:
The policy provides a clear framework for taking immediate action when potential wrongdoing or malpractice is reported. This ensures that any issues that could negatively impact our service quality or reputation are managed and rectified promptly.
Clarity of Procedures:
Our whistleblowing policy outlines the specific steps to be taken when a concern is raised. This clarity helps to remove any uncertainty about how concerns should be reported and the subsequent actions that will be taken. It details the channels through which concerns can be raised, the processes for handling these concerns, and the protections in place for those who come forward.
Confidential and Safe Reporting:
We prioritize creating an environment where our employees feel secure in reporting concerns. The policy guarantees confidentiality and ensures that whistleblowers are protected from reprisal, discrimination, or disadvantage. This commitment to safety and security encourages open and honest communication.
Encouragement of Open Communication:
EHS encourages all team members to voice their concerns without hesitation. This policy supports a culture of transparency and continuous improvement, where all employees feel responsible for the integrity and success of our operations.
Universal Applicability:
The whistleblowing policy applies to every member of the Earthhaven Healthcare Solutions team, regardless of their position or role within the organization. This universal scope ensures that everyone is aware of their rights and responsibilities under the policy and is equally protected and obligated to act in accordance with its provisions.

At Earthhaven Healthcare Solutions Ltd. (EHS), the concept of 'Duty of Care' is fundamental to our operational ethos and reflects our commitment to ensuring the safety and well-being of both our service users and colleagues. It underscores the shared responsibility among all team members to act vigilantly against any form of malpractice or misconduct that could compromise the health and safety of individuals within our care.

Definition of Duty of Care
Responsibility for Well-being:
Our duty of care involves a legal and ethical obligation to ensure the safety, health, and well-being of all service users and staff members. This includes taking all reasonable steps to prevent harm by anticipating and mitigating potential risks.
Vigilance against Malpractice:
Staff members are expected to maintain a high level of vigilance and act proactively to prevent, identify, and address any instances of malpractice, abuse, or neglect. This includes understanding the signs of abuse and knowing the correct procedures for reporting and dealing with such issues.

Importance of Whistleblowing in Duty of Care
Empowerment through Policy:
Recognizing the challenges that can arise when raising concerns, EHS has established a robust whistleblowing policy designed to instill confidence and protect those who come forward with concerns about malpractice. This policy is a critical tool in empowering our employees to fulfil their duty of care effectively.
Facilitating Swift Resolutions:
The whistleblowing policy ensures that there is a clear, confidential, and secure process for reporting concerns. This facilitates swift and effective actions to resolve issues, thereby preventing harm and safeguarding the welfare of all involved.
Support and Training:
EHS provides ongoing training and support to all employees to ensure they understand their duty of care and how to execute it properly. This training includes how to identify potential risks, the importance of reporting, and how to use the whistleblowing policy effectively.

At Earthhaven Healthcare Solutions Ltd. (EHS), we are committed to fostering an environment where all team members feel safe and supported in reporting any instances of malpractice. Our whistleblowing policy is designed to ensure that staff understand that reporting wrongdoing is not only supported but encouraged, and it is the appropriate course of action to maintain the integrity and safety of our services.

Purpose of the Whistleblowing Policy
Our whistleblowing policy underpins our commitment to an open, honest, and transparent operational environment. This transparency is crucial not only for safeguarding our clients and staff but also for the continuous improvement of our organization through the adoption of best practices.

Making a Whistleblowing Claim
Reporting Concerns:
When you raise a concern, you can expect it to be taken seriously from the outset. Your report will be carefully listened to, and an initial determination will be made about whether further investigation is required.
Further information may be requested from you as investigations progress, to ensure a comprehensive understanding of the context and specifics of the issue reported.
Anonymity and Confidentiality:
Your choice to remain anonymous or to keep your identity confidential will be respected, depending on the severity and nature of the claim. We strive to protect our whistleblowers to the fullest extent possible while ensuring that investigations are thorough and effective.
Involvement in the Process:
While you will not have a say in the ultimate handling of your concern, we commit to keeping you informed about the actions we are taking in response to your report.
Regular updates will be provided as the investigation progresses, ensuring that you are aware of how your concern is being addressed.
Outcome Transparency:
Please be aware that there might be limitations on the information we can share about the outcomes of investigations. In cases where confidentiality is required to protect the privacy and rights of others involved, specific details may be withheld.
However, we will ensure that you understand the general outcome and that appropriate actions have been taken.

Legal Protection and Considerations
Protection Under Law: It is important for staff to understand that legal protection and rights for whistleblowers can be compromised if they choose to report their concerns to the media or other external parties without following the proper internal channels first.
Internal Reporting First: We strongly encourage all employees to utilize the internal reporting mechanisms provided by EHS before considering external options. This approach ensures that you retain your whistleblower protections and that the matter is handled swiftly and confidentially within the organization.

At Earthhaven Healthcare Solutions Ltd. (EHS), we recognize the importance of protecting the identities of our employees who come forward as whistleblowers. Our commitment to maintaining strict confidentiality and, where requested, anonymity, is paramount. However, it is also critical to balance these protections with our commitment to transparency and the effective handling of whistleblowing cases.

Policy on Anonymity and Confidentiality
Anonymity
Anonymous Reporting:
Whistleblowers have the option to report issues anonymously to any manager within Earthhaven Healthcare Solutions. This can be done through various channels designed to protect the whistleblower’s identity.
It is crucial for whistleblowers to understand that while anonymity can be maintained, the absence of a contactable whistleblower might restrict the ability to gather more detailed information as the investigation progresses. This limitation can potentially affect the thoroughness and depth of the investigation.
Limitations of Anonymity:
When claims are made anonymously, the details provided may be the only information available to initiate and conduct an investigation. If the information is insufficient or lacks specificity, it may hinder our ability to fully address the concern.
Whistleblowers are encouraged to provide as much detailed information as possible to facilitate an effective investigation.

Confidentiality
Confidential Reporting:
Employees may also choose to disclose their identity when making a report but request that their identity be kept confidential. In these instances, every effort will be made to protect the identity of the whistleblower from being disclosed during the investigation process and in any subsequent actions.
The confidentiality of the whistleblower will be safeguarded unless there is a legal obligation to disclose the identity, such as cases escalated to external authorities where specific regulations may require the disclosure of the whistleblower’s identity.
Protection from Reprisals:
EHS is committed to ensuring that no employee who reports wrongdoing, whether anonymously or confidentially, suffers detriment or reprisal as a result of their actions. Protective measures are enforced rigorously to uphold this commitment.

Transparency and Legal Requirements
Balancing Transparency: While we strive to maintain the confidentiality and anonymity of whistleblowers, it is important to note that certain serious cases might require escalation to external authorities. In such instances, anonymity or confidentiality may be overridden by legal obligations.
Informed Whistleblowers: All employees are fully informed of these terms upon making a claim. Clear communication about the potential limits of confidentiality and anonymity is part of our commitment to transparency.

At Earthhaven Healthcare Solutions Ltd. (EHS), we are committed to fostering a culture of confidence and trust. It is crucial that our staff are well-informed about the whistleblowing protocols in place to protect them and fully understand the process. This procedure outlines how whistleblowing is managed within EHS, ensuring that all employees are aware of how to proceed with raising concerns and the protections afforded to them under the law.

Whistleblowing Process
Reporting Concerns
Initial Reporting:
Employees who suspect wrongdoing within any area of EHS’s operations should report their concerns as soon as possible. This can be done through designated channels such as a direct supervisor, the compliance officer, or via our confidential whistleblowing hotline or online platform.
Handling of Reports:
All reports received will be treated with the utmost confidentiality. Initial assessments will be conducted to determine the validity of the concerns and the appropriate course of action.

Criteria for Protected Disclosures
Qualifying Disclosures:
Under the Public Interest Disclosure Act 1998, disclosures qualify for protection if they relate to specific types of wrongdoing which the employee reasonably believes has occurred, is occurring, or is likely to occur. These include:
Criminal offences
Failure to comply with legal obligations
Miscarriages of justice
Health and safety dangers
Environmental damage
Reasonable Belief:
The employee need not have concrete proof but must have reasonable grounds for their belief in the wrongdoing. The belief does not have to be correct in hindsight, but it must be reasonable and genuine at the time of making the disclosure.
Good Faith and Public Interest:
Disclosures must be made in good faith and in the public interest. Employees are encouraged to act honestly, without personal grievances, ensuring that their claims aim to address genuine concerns rather than personal conflicts.

Protections for Whistleblowers
No Retaliation:
No employee who reports a concern in good faith will face dismissal, disciplinary action, or any form of retaliation. EHS is committed to protecting such employees under the Public Interest Disclosure Act 1998.
Confidentiality:
The identity of the whistleblower will be protected unless disclosure is necessary for the investigation or required by law.

Malicious Allegations
Consequences of False Claims:
While EHS encourages transparency and honesty, it is critical that the whistleblowing process is not used for malicious purposes. Any employee found to have knowingly made false allegations with intent to cause harm may face disciplinary actions, including dismissal.

At Earthhaven Healthcare Solutions Ltd. (EHS), we encourage all employees to report any concerns they might have regarding malpractice or misconduct within the organization through internal channels, unless there are valid reasons to bypass these usual routes. This policy details the procedures for handling such internal disclosures to ensure they are managed effectively and transparently.

Internal Reporting Procedures
Making a Disclosure
How to Disclose:
Employees should raise concerns either orally or in writing. It is preferable to make these disclosures to the employee's immediate manager or supervisor.
Whistleblowers are encouraged to provide as much detail as possible to facilitate a thorough investigation. This includes dates, places, people involved, and any other relevant information.
Anonymous Disclosures:
Disclosures from anonymous sources will be considered, but the lack of detailed information may hinder the ability to conduct a full investigation. Therefore, anonymous disclosures might not always be pursued further unless substantial evidence is provided.

Responsibilities of the Recipient of the Disclosure
Initial Assessment:
The recipient of the disclosure must first confirm that the disclosure is made in good faith.
They should assess the seriousness of the information received and decide on the appropriate action, which might include initiating an internal investigation.
Investigation:
A preliminary investigation should be carried out to determine the validity of the allegations.
If necessary, the matter may be referred to external authorities such as the police, external auditors, or the Health & Safety Executive, especially if the issue is beyond the scope of internal resolution or involves legal implications.
Feedback and Communication:
The whistleblower should be kept informed throughout the process. Initial feedback about the actions taken should be provided soon after the disclosure is made.
Upon completion of the investigation, the whistleblower should be informed of the outcome and any actions that have been taken or will be taken.

Timeline for Investigation
Standard Investigation Period:
Investigations should be completed within 28 working days from the date the disclosure was first made.
If the investigation is likely to take longer due to complex issues or external dependencies, the whistleblower should be informed of the extension and the reasons for the delay.

Alternative Reporting Routes
Escalation:
If an employee feels that disclosing a concern to their manager or supervisor is not suitable, perhaps due to involvement or conflict of interest, they are advised to report the matter to the next higher level of management.
Each department will have a designated officer or senior manager who can also receive disclosures, ensuring there is always an alternative avenue available.

At Earthhaven Healthcare Solutions Ltd. (EHS), we are committed to treating all whistleblower reports with the highest degree of seriousness and thoroughness to ensure that our workplace maintains the highest standards of integrity and ethical conduct. While we strongly encourage all employees to report any suspected wrongdoing, it is crucial to emphasize the responsibilities associated with making such reports.

Handling Unjustified ReportsSeriousness of False Claims

Accountability: Making a report that is knowingly false or made in bad faith can have serious consequences for the accused and can undermine the trust and morale within the organization. Therefore, it is important that all employees understand that allegations should be based on facts that the whistleblower genuinely believes to be true.
Investigating Reports
Thorough Investigation: All reports are investigated thoroughly to ascertain the facts. This investigative process is crucial in distinguishing between genuine concerns and reports made in bad faith.
Consequences of False Claims
Disciplinary Actions: If an investigation concludes that a whistleblower has made a false claim knowingly or with malicious intent against colleagues, disciplinary measures will be taken. These measures are necessary to protect the integrity of our reporting process and to prevent misuse of the system that could harm innocent parties and the organization’s atmosphere of trust.
Examples of Disciplinary Actions: Such actions may include formal reprimands, suspension, or even termination of employment, depending on the severity and impact of the false claim.

Support for Good Faith Reporting
Encouragement of Honest Reporting: EHS continues to support and protect employees who report concerns in good faith, even if the investigations do not find evidence to substantiate the allegations. The key is the genuine belief in the truth of the report at the time it is made.
Training and Guidance: We provide ongoing training and guidance to ensure all employees understand what constitutes a valid report and encourage them to approach reporting with sincerity and a sense of responsibility.

At Earthhaven Healthcare Solutions Ltd. (EHS), continuous improvement and adaptability are key principles that guide our operations. To ensure that our whistleblowing policy remains effective and relevant, it undergoes regular monitoring and review. This process helps to align the policy with our organizational goals and the changing legal and ethical landscape.

Monitoring and Review Process
Role of the Company Secretary
Annual Review: The Company Secretary is tasked with ensuring the effectiveness of the whistleblowing policy. This includes conducting an annual review to assess the policy's efficiency, its alignment with best practices, and compliance with applicable laws.
Reporting Findings: The findings from the annual review, along with any recommendations for improvements, are reported to the Board of Directors. This ensures that senior management is directly involved in the enhancement of the policy.
Employee Involvement
Feedback and Suggestions: All employees are encouraged to provide feedback and suggest enhancements to the whistleblowing policy. Employee input is invaluable as it often highlights practical aspects of the policy’s implementation and areas where adjustments may be necessary.
Feedback Channels: Suggestions can be submitted through various channels, such as staff meetings, direct communication with HR, or via an anonymous feedback form available on the company intranet.

Policy Flexibility
Non-Contractual Nature: It is important for all staff to understand that the whistleblowing policy is not a contractual document. This means that it can be revised and updated without altering the terms of employment contracts.
Revisions and Updates: The policy may be revised at any time to respond to new challenges, changes in legislation, or to incorporate feedback from employees and other stakeholders. Any significant changes to the policy are communicated to all employees promptly to ensure that everyone is informed and aligned with the new provisions.