Group Whistleblowing policy
Last updated 12/06/2019
We are committed to doing business in accordance with the law, our Code of Business Conduct (our Code) and our Values. We encourage whistleblowing as it plays an important role in achieving this commitment and is part of an open, honest and Values-based culture.
This policy sets out how colleagues can report concerns and explains the protection and support that will be given to those who speak up. It also sets out the minimum requirements of each business unit in managing an effective whistleblowing procedure.
This policy applies to all Tesco colleagues including consultants, contractors and agency colleagues in relation to their work for Tesco. It applies to all companies that are either majority-owned by Tesco or operated by Tesco management. Companies in which Tesco does not hold a majority stake will be expected to implement an equivalent framework.
It is our policy to encourage colleagues to speak up if they have any concerns about wrongdoing. Any colleague who raises their concerns in good faith will be supported for doing so and will be protected from retaliation.
Raising your concerns
You can report concerns about any conduct that you think might be a breach of the law, our Code or our Values. The whistleblowing process is not for reporting minor grievances or HR issues. For those issues, you should speak with your line manager or contact your People Partner.
If you cannot talk directly to the person whose conduct is causing concern, you are encouraged to raise the matter with your line manager first. If you are unable to raise your concern with your line manager or they take no action, you must raise your concern using any of the following channels:
Speak directly with a member of your Legal, People, Security or Audit teams;
Contact your Director, a member of your business unit’s Leadership Team, the Group Executive team or the Tesco PLC Board, or
Report your concern through Protector Line. Protector Line is our confidential whistleblowing hotline run by an independent third party in each business unit. You can contact Protector Line anonymously if you prefer.
Investigation of concerns
All concerns raised at Tesco are taken seriously. Prompt steps will be taken to consider your concern and, where appropriate, investigate the allegations in line with Group Standard for the conduct of internal investigations. Your concern will be managed confidentially. That means that all information on the matter, including the identity of individuals involved, will only be shared where necessary with relevant individuals. Any Personal Data (as defined in the Data Protection Act 1998 and its foreign law equivalents) that you provide in connection with a whistleblowing report will be processed in accordance all applicable data protection laws.
We do not tolerate retaliation in any form against individuals who raise concerns and we are committed to ensuring that colleagues who raise concerns are not victimised.
If you raise a genuine concern in good faith, you will not face any adverse consequences for speaking up, even if you were mistaken about your concern. If you believe that you are being retaliated against, you should report it immediately. Any individuals found to be deliberately retaliating against a whistleblower will be investigated in accordance with the company disciplinary policy and their action may result in action up to and including dismissal.
Alongside this commitment, whistleblowers also have statutory protection under the UK Public Interest Disclosure Act 1998 (and its foreign law equivalents) which protects the confidentiality of complaints and ensures you are legally protected from victimisation and will not be at risk of any form of retribution.
Business unit requirements
Each business unit is accountable for implementing an effective local whistleblowing programme that adheres to the Risk, Controls and Assurance (RCA) framework:
Clear governance: Leadership show clear tone from the top and lead by example;
Policies: The Whistleblowing Policy is adopted locally and easily accessible to colleagues;
Procedures & guidance: Business units must operate five formal whistleblowing channels and implement procedures to ensure complaints received via any of these channels are investigated in accordance with the Group standards on investigations. The formal channels are:
Complaints brought to the attention of control functions or auditors in their professional capacity (eg People teams, Legal, Security, Audit, Finance).
Members of the Group Executive team or Tesco Plc Board;
An independent whistleblowing hotline (Protector Line) for both suppliers and colleagues;
Code of Business Conduct annual declarations; and
Communications & training: Appropriate training and communications take place throughout the year to ensure colleagues know how to raise and handle concerns.
Investigations & sanction: Complaints are investigated and appropriate sanctions taken where necessary.
Monitoring & auditing: Data is regularly reported to the local Compliance Committee.
This policy is supported by the Code of Business Conduct