Whistleblowing Policy


This Policy applies to all employees of Thatcham Research or Gamston Aviation Limited (“Colleagues”). For the purposes of this policy, references to “Company” include Thatcham Research and/or Gamston Aviation Limited. Other individuals performing functions in relation to the organisation, such as agency workers and contractors, are encouraged to use it.

It is important to the business that any fraud, misconduct or wrongdoing by company employees, managers, and directors, is reported and properly dealt with. The organisation therefore encourages all individuals to raise any concerns that they may have about the conduct of others in the business or the way in which the business is run. This policy sets out the way in which individuals may raise any concerns that they have and how those concerns will be dealt with.

 2. Background

The law provides protection for employees who raise legitimate concerns about specified matters. These are called “qualifying disclosures”. A qualifying disclosure is one made in the public interest by an employee who has a reasonable belief that:

  • a criminal offence;
  • a miscarriage of justice;
  • an act creating risk to health and safety;
  • an act causing damage to the environment;
  • a breach of any other legal obligation; or
  • concealment of any of the above;

is being, has been, or is likely to be, committed. It is not necessary for the employee to have proof that such an act is being, has been, or is likely to be, committed – a reasonable belief is sufficient. The employee has no responsibility for investigating the matter – it is the organisation’s responsibility to ensure that an investigation takes place.

An employee who makes such a protected disclosure has the right not to be dismissed, subjected to any other detriment, or victimised, because he/she has made a disclosure.

The organisation encourages employees to raise their concerns under this procedure in the first instance. If an employee is not sure whether to raise a concern, he/she should discuss the issue with his/her line manager or the HR department.


  • Everyone should be aware of the importance of preventing and eliminating wrongdoing at work. Individuals should be watchful for illegal or unethical conduct and report anything of that nature that they become aware of.
  • Any matter raised under this procedure will be investigated thoroughly, promptly and confidentially, and the outcome of the investigation reported back to the individual who raised the issue.
  • No individual will be victimised for raising a matter under this procedure. This means that the continued employment and opportunities for future promotion or training will not be prejudiced because he/she has raised a legitimate concern.
  • Victimisation of an employee for raising a qualified disclosure will be a disciplinary offence.
  • If misconduct is discovered because of any investigation under this procedure the organisation’s disciplinary procedure will be used, in addition to any appropriate external measures.
  • Maliciously making a false allegation is a disciplinary offence.
  • An instruction to cover up wrongdoing is itself a disciplinary offence. If told not to raise or pursue any concern, even by a person in authority such as a manager, employees should not agree to remain silent. They should report the matter to a director.

This procedure is for disclosures about matters other than a breach of an employee’s own contract of employment. If an employee is concerned that his/her own contract has been, or is likely to be, broken, he/she should use the organisation’s grievance procedure.

4. Procedure

4.1 Stage 1

In the first instance, any concerns should be raised with the employee’s line manager. If the employee reasonably believes the line manager to be involved in the wrongdoing or if for any other reason does not wish to approach the line manager, then he/she should proceed straight to Stage 3.

4.2 Stage 2

The line manager will arrange an investigation into the matter (either by investigating the matter him/herself or immediately passing the issue to someone in a more senior position). The investigation may involve the employee and other individuals involved giving a written statement. Any investigation will be carried out in accordance with the principles set out above. The employee’s statement will be considered, and he/she will be asked to comment on any additional evidence obtained. The line manager (or the person who carried out the investigation) will then report to the Thatcham Management Board (TMB), which will take any necessary action, including reporting the matter to any appropriate government department or regulatory agency. If disciplinary action is required, the line manager (or the person who carried out the investigation) will report the matter to HR, and start the disciplinary procedure. On conclusion of any investigation, the employee will be told the outcome of the investigation and what the TMB has done, or proposes to do. If no action is to be taken or if only limited information as to the outcome and/or next steps can be shared, the reason for this will be explained.

4.3 Stage 3

If the employee is concerned that his/her line manager is involved in the wrongdoing, has failed to make a proper investigation or has failed to report the outcome of the investigations to the TMB, he/she should inform a member of the TMB who will arrange for another manager to review the investigation carried out, make any necessary enquiries and make his/her own report to the TMB as in stage 2 above. Any approach to the TMB will be treated with the strictest confidence and the employee’s identity will not be disclosed without his/her prior consent.

4.4 stage 4

If on conclusion of Stages 1, 2 and 3 the employee reasonably believes that the appropriate action has not been taken, he/she should report the matter to the proper authority. The legislation sets out several bodies to which qualifying disclosures may be made. These include:

  • HM Revenue & Customs; 
  • The Environment Agency; 
  • The Financial Services Authority; 
  • The Director of Public Prosecutions;   
  • The Office of Fair Trading; 
  • The Serious Fraud Office. 
  • The Health and Safety Executive;
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