Handelsbanken Wealth Management and Handelsbanken Asset Management are trading names of Handelsbanken Wealth & Asset Management Limited (HWAM). HWAM is committed to the highest standards of openness, probity and accountability. An important aspect of accountability and transparency is the provision of a mechanism to enable employees, contractors or suppliers to voice their concerns about “qualifying disclosures”, in a responsible and effective manner.
HWAM is committed to the highest standards of openness, probity and accountability. An important aspect of accountability and transparency is the provision of a mechanism to enable employees, contractors or suppliers to voice their concerns about “qualifying disclosures”, in a responsible and effective manner.
HWAM is committed to creating a secure working environment and expects its employees at all times to act within the law, applicable codes of practice, and to apply the highest possible operating/business ethics in all areas of their activities. Nevertheless, where an employee, contractor or supplier discovers information which they believe shows serious malpractice or wrongdoing within HWAM then this information should be disclosed without fear of reprisal. HWAM is committed to the provision of an effective mechanism to enable this to occur.
The Public Interest Disclosure Act 1998 (PIDA) provides guidance for dealing with whistleblowing issues in a safe and constructive way and this policy and procedure is designed to conform to such guidance.
This policy provides protection to those individuals who make a disclosure, provided it is made in good faith and in relation to any event that is reasonably believed to be a qualifying disclosure. A qualifying disclosure is one which, in the reasonable belief of the individual, suggests that one or more of the following has been, is being, or is likely to be committed:
- a criminal offence;
- the putting of the health and safety of any individual in danger;
- a failure to comply with any legal obligation;
- damage to the environment;
- a miscarriage of justice;
- deliberate concealment relating to any of the above;
- a breach of regulatory rules;
- a breach of HWAM/the Bank’s policies and procedures; or
- behaviour that harms or is likely to harm the reputation or financial well-being of HWAM.
Confidentiality
HWAM will treat all such disclosures seriously and in a confidential and sensitive manner. The identity of the individual making the disclosure will, if requested, and as far as reasonably possible, be kept confidential to only those employees involved in investigating the disclosure and to HWAM’s management or any external authorities who need to consider whether action should be taken, and the nature of such action on the basis of the findings. However, it must be understood that there may be circumstances where the investigating officer may be required to reveal the identity of the individual making the allegation, and even where such disclosure is not necessary, it is possible that the investigation process may reveal the source of the information; the individual making the disclosure may also be requested to provide a statement as part of the evidence required. Where it is necessary or desirable to disclose the identity of the individual then the agreement of the individual making the disclosure will be sought, unless prohibited by law, but where such disclosure is considered necessary, consent is not required. In any such event the protection afforded under PIDA will apply.
Anonymous allegations
HWAM encourages individuals to put their name to any disclosures they make in the knowledge that they will be protected under the terms of this policy. However, it is possible to report concerns anonymously using the form at the bottom of this page. Please be aware that anonymous reports may be significantly more difficult to investigate, but will nonetheless be considered.
Unproven allegations
If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. In making a disclosure the individual should exercise due care to ensure the accuracy of the information.
Malicious or vexatious allegations
If an individual makes a malicious or vexatious allegation, disciplinary action will be taken against that individual.
It should be emphasised that this policy is intended to assist individuals who believe they have discovered malpractice or impropriety. It is not designed to question financial or business decisions taken by HWAM, unless any such action is suspected to be criminal - e.g. fraudulent or otherwise falls under the definition of a qualifying disclosure, nor should it be used to raise any matters which have already been addressed under harassment, grievance, disciplinary or other procedures.
With appropriate whistleblowing procedures in place, HWAM encourages individuals to use them rather than to air their concerns directly outside of HWAM. HWAM commits to investigating any matters raised thoroughly and properly.
How to report
Employees of HWAM should follow the steps outlined in the company’s Whistleblowing Procedures.
If you are not an employee of HWAM and you wish to make a qualifying disclosure, you should complete the online form provided below. Your contact details will remain confidential and will not be revealed without your permission, unless there is a legal obligation to do so.
Please provide a phone number and address that can be used to contact you with follow-up questions about the case. Consider providing your home phone number and address if this would make it easier for you to deal with follow-up questions.
If you would prefer to make an anonymous report, please just complete the 'Message' section in the form and leave your contact details blank.
You can also make a qualifying disclosure through the FCA. Should you wish to do so, or if you want to find out more about Whistleblowing, please visit the FCA’s Whistleblowing site: https://www.fca.org.uk/firms/whistleblowing.
If you feel you need to take advice before making a disclosure, you may contact the independent charity, Public Concern at Work (www.pcaw.org.uk) on 020 3117 2520. They provide free, confidential advice for individuals who have witnessed wrongdoing in the workplace but are unsure how to raise their concerns.
Investigation
On receipt of the disclosure, a member of the compliance team (as appropriate) will conduct or instigate a full investigation with the objective of establishing whether malpractice has occurred. The format of the investigation may vary depending upon the circumstances. Compliance will consider the involvement of the internal audit department and/or other individuals/bodies as appropriate in the light of the nature of the allegations.
Timescales
Due to the varied nature of potential disclosures which may involve internal investigation and/or the police or other external bodies, it is not possible to lay down precise timescales for completion of such investigations. The investigating officer will ensure that the investigations are undertaken as quickly as reasonably possible without affecting the quality and depth of those investigations.
Findings
Please be aware that anonymous reports may be significantly more difficult to investigate, but will nonetheless be considered. If you have made an anonymous disclosure, which has been investigated, the findings of the investigation will be communicated to the individual(s) under investigation, and to those members of HWAM’s management or any external authorities who need to consider whether action should be taken and the nature of such action on the basis of the findings.