Employee Handbook

Conflict of interest

Public interest disclosure (whistle blowing) We encourage an open culture in all our dealings with employees, managers, and everyone with whom we come into contact. Effective and honest communication is essential if malpractice is to be effectively dealt with. Genuine concerns should be raised through our Speak Out channel; every incident will be dealt with in confidence, and you will not be at risk of damaging your position as a result. If you ask for your identity to be protected, it will not be disclosed without your agreement. If a situation arises where it is not possible to deal with the concern anonymously (for instance because your evidence is needed in court or a disciplinary hearing), there will be a discussion as to whether and how we can proceed. Provided you are acting in the public interest, it does not matter whether your concern proves to be well founded. However, this assurance does not extend to anyone who acts on an improper motive and raises a matter they know to be untrue. Stage 1: Internal line management If you have a concern about malpractice, raise it in writing with your line manager or a more senior manager, stating the facts of the matter clearly. You can outline how you would like it to be investigated and you should tell us at this stage if you have a direct or personal interest in the matter. Stage 2: Alternative contacts If you feel unable to raise the matter with your line management you should raise your concern via FM Conway’s SpeakOut App or telephone helpline 0808 169 1521 . Once you have reported your concern, FM Conway will initially assess what action should be taken. If your concern falls more appropriately within other policies, we will tell you. Your disclosure will be taken seriously and promptly investigated. You will be interviewed and asked to provide a written statement. Once FM Conway has finalised the investigation, any necessary action will be taken. We will give you as much feedback on the action to be taken as we can. If requested, we will confirm our response to you in writing. Please note, however, that we may not be able to tell you the precise action we take where this would infringe our duty of confidentiality to someone else. How to raise a concern

A conflict of interest may take many forms. Most commonly, we ask that:

• You do not allow your outside activities to interfere with work or allow any conflict between your duties and your private interests to affect your ability to carry out your duties effectively • You will not make use of or exploit FM Conway or brand names associated with FM Conway, your connection with FM Conway, or information obtained in the course of your duties, to further your own private interests or those of any outside organisation, to the detriment of FM Conway • You will not act in a manner likely to bring FM Conway or its shareholders/ Directors into disrepute or to affect its reputation and integrity Bribery FM Conway is committed to ensuring that all our commercial dealings meet the highest professional standards. It is never acceptable to accept or offer bribes in any business transaction. Bribes may come in a variety of forms such as corporate hospitality, charitable donations, and personal gifts, as well as money. Any employee being offered any of these must report this to their line manager, HR and Legal, who will advise how to manage the situation. Breaches of this rule will result in disciplinary action, which may result in dismissal. Purchasing and commissioning FM Conway is involved in commissioning work and in tenders for contracts with other organisations. All dealings with current and potential suppliers and clients must be properly handled through the approved official channels using the application of high standards of objectivity, integrity, and fairness. If you are dissatisfied We ask that matters are reported to FM Conway in the first instance, but if you are unhappy with our response, you may then go to an external authority. While we cannot guarantee that we will respond to all matters in the way that you might wish, all matters will be handled fairly and properly. By using this policy, you will help us to achieve this. For more information please see the Bribery Policy on the IMS.

For more information, please see the Whistle Blowing Policy on the IMS.

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