Whistleblowing Policy

The Ashfield Mill Group is committed to maintaining the highest standards of ethical conduct, integrity, openness and accountability in all aspects of its business operations. The Group encourages a culture in which employees, workers, suppliers, contractors and other stakeholders feel confident in raising genuine concerns about wrongdoing, unethical behaviour or suspected breaches of legal, regulatory or the Group’s requirements.

The Group is committed to conducting business responsibly and to protecting and promoting the human rights, dignity and wellbeing of all individuals connected with its operations and supply chain. This includes a commitment to preventing modern slavery, human trafficking, forced labour, child labour, bribery, corruption and any other form of unlawful or unethical conduct.

The purpose of this Whistleblowing Policy is to provide a safe and confidential mechanism for reporting concerns in good faith, without fear of retaliation, victimisation or adverse treatment. The Group will take all concerns seriously and, where appropriate, investigate them fairly, objectively and confidentially.

While this policy cannot cover every possible circumstance, all employees and associated persons are expected to act in accordance with its principles and to support a culture of honesty, integrity and responsible business practice throughout the organisation.

This policy applies to employees, temporary workers, contractors, agency staff, raw material suppliers, commissioned partners and external stakeholders.

Whistleblowing concerns generally relate to wrongdoing, unlawful activity, risks to individuals, the organisation, or the public interest. Personal employment concerns affecting an individual, such as pay, contractual terms, or interpersonal disputes, should normally be raised through the Group’s Grievance Procedure.

The types of complaints that can be raised, but are not limited to, include:

  • Fraud, bribery, or corruption
  • Financial misconduct
  • Health and safety breaches
  • Environmental violations
  • Modern slavery or child labour
  • Human rights abuses
  • Discrimination, harassment, or bullying
  • Breaches of Group’s policies
  • Criminal activity
  • Regulatory non-compliance
  • Concealment of any wrongdoing

Reporting Channels

The Group encourages all employees and stakeholders to raise genuine concerns regarding suspected wrongdoing. Any complaint of this nature can be reported to your line manager if you are comfortable doing so, or to senior management if you are not comfortable reporting to your line manager. Concerns may also be raised with the HR function, for which responsibility currently sits with the Group’s Accounts and Payroll Manager. Further to this, you can make an anonymous or confidential complaint by giving your name and requesting confidentiality. Although the Group are not required to do so, we will make every effort, where possible, to protect your identity. However, there may be circumstances where disclosure is required by law or where disclosure is necessary for a fair and thorough investigation. Despite this, Individuals raising concerns in good faith will be protected from retaliation, and all reports will be treated confidentially and investigated appropriately.

Dedicated whistleblowing postal address:

John Spencer Textiles,
Ashfield Mill, Active Way
Burnley, BB11 1BS

You may be able to report wrongdoing to a prescribed person anonymously, but it’s possible they won’t be able to take the issue further if you have not provided all the information they need. 

Other external channels that can be utilised for further information include Citizens’ Advice, the whistleblowing charity Protect and/or your trade union.

Protection from Retaliation and Investigation

Despite how or where you choose to report, the Group will ensure that there is no victimisation, harassment, dismissal, or disciplinary action for raising concerns in good faith. This protection will apply even if the concern is not ultimately substantiated.

Reports will be acknowledged within 2-5 working days from the date the complaint has been raised, followed by a further acknowledgement and communication on the initial assessment of the complaint, which can take up to 10 working days. The investigation process will then be conducted and normally completed within 4-8 weeks of the report being raised, although complex investigations may take longer. During the investigation, relevant evidence may be collected and reviewed, including but not limited to CCTV footage, photographs, audio recordings, policies, procedures, risk assessments, financial records, witness statements, emails and other relevant documentation. Investigations will normally be led by the Managing Director or another suitably independent manager. Where the concerns involve senior management, directors or potential conflicts of interest, an independent investigator or external specialist may be appointed. This will ultimately result in the investigation conclusion providing an outcome and corrective action plan. Where appropriate and lawful to do so, the whistleblower will be informed of the outcome of the investigation and any actions taken.

This corrective action may be, but is not limited to:

  • Disciplinary action
  • Process improvements
  • Supplier corrective action plans
  • Referral to regulators or law enforcement
  • Additional training

All whistleblowing reports will be appropriately documented and managed confidentially, with personal data processed, retained, and disposed of in accordance with applicable data protection legislation and the Group’s record retention requirements. The Group will monitor whistleblowing reports and investigation outcomes to identify trends, inform continuous improvement, and support periodic reporting to senior management where appropriate.

The Group encourages all stakeholders to raise genuine concerns in good faith and recognises that whistleblowing reports may be made even where the concerns are ultimately unsubstantiated. Individuals raising concerns are not expected to have proof of wrongdoing. Concerns should be raised where there is a reasonable belief that wrongdoing may have occurred, is occurring, or is likely to occur. However, any individual found to have knowingly made a false, malicious, or misleading allegation may be subject to disciplinary action in accordance with the Group’s disciplinary procedures.

The Quality and Compliance Manager will be responsible for reviewing and maintaining the Whistleblowing policy at the end of each financial year, alongside the Group’s Modern Slavery Statement. This will monitor any regional and global legislative changes, the effectiveness of the procedure and any trend that may be established from claims. Any changes will be approved by the Group’s Managing Director.