1.Introduction

At JNP Legal, we are committed to maintaining a culture of openness, accountability, and integrity. We recognise that whistleblowing is an essential part of ensuring high ethical standards within the firm and the legal profession. This policy is designed to enable employees, contractors, and stakeholders to raise concerns about wrongdoing or misconduct without fear of reprisal, and in compliance with the Welsh Government's Code of Practice for whistleblowing.

 

2.Purpose of the Policy

The purpose of this policy is to:

• Encourage individuals to report any wrongdoing, unethical behaviour, or illegal activities within JNP Legal.
• Ensure that concerns raised are dealt with promptly, seriously, and confidentially.
• Provide protection to individuals who raise genuine concerns from victimisation or any detrimental treatment.

 

3.Scope of the Policy

This policy applies to:

• All employees (permanent, temporary, and part-time).
• Contractors and consultants.
• Third parties who have a relationship with JNP Legal.

Whistleblowing relates to concerns over:

• Criminal offences, including fraud and corruption.
• Breaches of legal obligations or professional regulations.
• Miscarriages of justice.
• Danger to health and safety.
• Environmental damage.
• Attempts to cover up any of the above.

 

4.Legal Framework

This policy is guided by:

• The Public Interest Disclosure Act 1998 (PIDA).
• The Welsh Government Code of Practice for Whistleblowing.
• Employment Rights Act 1996.

In line with the Welsh Government's standards, JNP Legal ensures that all whistleblowing concerns are handled responsibly and in good faith.

 

5.Confidentiality and Anonymity

JNP Legal recognises the importance of confidentiality for individuals raising concerns. We will, wherever possible, protect the identity of whistle-blowers and ensure that their disclosures are handled sensitively and in confidence.

If you wish to remain anonymous, you may do so. However, anonymity may limit our ability to conduct a full investigation into the allegations.

 

6.Procedure for Raising a Concern

6.1 Informal Approach

Employees are encouraged to raise concerns internally in the first instance. If you feel comfortable, raise the matter with your Head of Department (HOD), who will listen to your concerns and provide advice on how to proceed.

6.2 Formal Whistleblowing Procedure

If the concern is serious, or if you feel unable to raise the issue informally, the formal whistleblowing procedure can be used:

• Report the concern in writing, verbally, or via email to the appointed Whistleblowing Officer:
  • Name: Sam Hoyland
  • Email: SamH@jnplegal.org
  • Phone: 01685 350421
• Provide details of the nature of the concern, including any relevant facts, dates, and names of individuals involved.
• Investigation: The Whistleblowing Officer will acknowledge the report within five working days and arrange an investigation into the matter. The whistle-blower may be contacted for further information during this process.
• Outcome: Upon completion of the investigation, the Whistleblowing Officer will provide feedback on the outcome and any actions taken, provided this does not breach any legal obligations regarding confidentiality.

 

7.Protection for Whistle-blowers

JNP Legal is committed to protecting individuals who raise concerns under this policy. We will not tolerate any form of harassment, discrimination, or victimisation of a whistle-blower. If an individual feels they have been subjected to any detrimental treatment because of raising a concern, they should report this immediately to the Whistleblowing Officer.

Any individual found retaliating against a whistle-blower may face disciplinary action, up to and including dismissal.

 

8.Malicious Allegations

While we encourage concerns to be raised, any allegations made maliciously or with the intention of causing harm to others may result in disciplinary action.

Whistleblowing should be done in good faith, and those who deliberately make false accusations will not be protected under this policy.

 

9.Reporting to External Authorities

In certain situations, employees may feel it is necessary to raise concerns with external authorities, such as regulators or law enforcement. This step should only be taken after the internal process has been followed, unless there is a serious and immediate threat to safety or serious criminal conduct involved.

Relevant external bodies include:

• The Solicitors Regulation Authority (SRA)
• The Health and Safety Executive (HSE)
• The Information Commissioner’s Office (ICO)
• Police or other law enforcement agencies

Whistle-blowers who raise concerns externally should ensure that their disclosure is appropriate and lawful under the Public Interest Disclosure Act 1998.

 

10.Monitoring and Review

This policy will be reviewed annually, or when there are significant changes to legislation or the Welsh Government’s Code of Practice, to ensure its continued relevance and effectiveness. Employees are encouraged to provide feedback on this policy to ensure it remains practical and fit for purpose.