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BMT Global “Raising Concerns” Policy

BMT is committed to creating and maintaining a working environment which exemplifies integrity and accountability and adopts systems that support transparency in decision-making, good governance and ethical behaviour.

BMT Global “Raising Concerns” Policy

(Updated October 2018)

  1. OVERVIEW

BMT is committed to creating and maintaining a working environment which exemplifies integrity and accountability and adopts systems that support transparency in decision-making, good governance and ethical behaviour.

This Policy supports the disclosure by individuals of wrongdoing occurring within BMT so that appropriate action can be taken.  BMT will treat all information disclosed in a confidential manner (so far as circumstances permit), conduct a fair and objective investigation and take appropriate remedial steps or notify relevant authorities.

The purpose of this Policy is to ensure that BMT:

The benefits of encouraging disclosures of wrongdoing and protecting those who make disclosures include:

  1. SCOPE AND APPLICATION

All BMT stakeholders are encouraged to report any wrongdoing in accordance with this Policy.  This Policy operates in conjunction with and does not take away the protection which exists under law.

  1. POLICY PRINCIPLES

Matters which should be reported under this Policy may include, but are not limited to:

  1. HOW TO RAISE A CONCERN

A member of staff or immediate family member may make a disclosure to:

The preferred route is via the ExpoLink Hotline – details below.

A stakeholder who is not a member of staff may make a disclosure to:

BMT has implemented a hotline (provided by ExpoLink) so that concerns can be raised confidentially and, if preferred, anonymously. 

The hotline contact details are displayed on posters and cards within each operating unit and all employees should familiarize themselves with the details.   When a concern is raised through the hotline, the details are passed to Centre HR Director, General Counsel and Head of Risk and Internal Audit, who will then allocate the investigation to a single individual to manage.

Concerns raised directly to a director, Company Secretary, senior manager of the Operating Unit or Partnership MD should be elevated to the Centre HR Director, General Counsel or Head of Risk and Internal Audit as appropriate.

  1. INVESTIGATION OF DISCLOSURES
  1. INVESTIGATION REPORTS
  1. CONFIDENTIALITY

As far as possible, and subject to the need to conduct proper investigations and take any consequential disciplinary steps, BMT is committed to preserving the confidentiality of:

Information must remain confidential where reasonably possible.

  1. PROTECTION OF THOSE RAISING CONCERNS
  1. DELIBERATE AND FALSE DISCLOSURES

A person who knowingly makes a deliberate and false accusation

  1. ROLE OF THE GLOBAL ETHICS COMMITTEE

The ethics committee meets every six months and will review, giving due regard to confidentiality:

  1. DOCUMENT MANAGEMENT

All information, documents, records and reports relating to the investigation of reported misconduct will be confidentially stored and retained in a secure manner.

The policy will be reviewed annually by the Global Ethics Committee for continuing suitability.

Download our Global “Raising Concerns” Policy »