- Private: BRE Way
- Ethics Decision Tree
- Raising Issues of Concern
- Equal Opportunity
- Health, Safety & Wellbeing
- Responsible Sourcing
- Honesty and Integrity
- Bribery and Corruption
- Conflicts of Interest
- Data Protection and Information Security
- External Activities and Communications
- Financial Controls, Records and Reporting
- Gifts and Hospitality
- Media and Stakeholder Communications
- Open and Fair Competition
- Proper Use of Company Property and Resources
- Using Company Computer Systems
- Environmental Impact
Reporting an Ethical Issue
If you believe that you (or others) are being asked to act or behave in a way that seems illegal, improper or unethical, you should raise this with your Line Manager, another manager, or the Legal or Compliance teams. If you feel uncomfortable doing so, you can send an anonymous note in the post.
Examples of such concerns include:
- Suspected unlawful or criminal offences – e.g. fraud, corruption, bribery or blackmail.
- Improper conduct or unethical behaviour – e.g. persistent lateness, unauthorised absence from work, failure to fulfil duties, taking credit for others’ work, intentionally misleading customers or providing inaccurate information.
- Abusive behaviour – e.g. bullying, harassment, discrimination.
- Unauthorised use of company property and resources – e.g. conducting personal business on company time.
- Endangering the environment.
- Concealing information relating to any of the above.
The routes for raising issues of concern – DON’T BE AFRAID TO SPEAK UP!
In the first instance, you should report your concern to your Line Manager orally or in writing (written concerns can help to ensure that all the details are correctly understood). If you think that raising such matters with your Line Manager may not be appropriate, you may contact any of the following:
- Another more senior manager
- Any member of the HR team
- Any member of the Compliance team
- Any member of the Legal team
- Any Director of any Group Company
- Any member of the BRE Group Board
- The BRE Group Chief Executive
Alternatively, should you wish not to raise the issue with a BRE group employee you may approach, in confidence, any BRE Group Board Non-Executive Director, each of whom is independent of BRE.
If the matter pertains to BRE Global, you may raise your concern with the Chairman of the BRE Global Governing Body, or another member, all of whom are non-executives. Contact details may be found on the BRE Group intranet, on the website or from BRE Customer Services.
Any such person will deal with your concern in confidence, sharing it on a strictly need-to-know basis, and will not disclose your identity.
If you have any concerns about integrity, independence, conflicts of interest or impartiality you should raise these issues with a member of the Compliance team or e-mail firstname.lastname@example.org
Raising concerns in the public interest
You might have public interest concerns that are eligible for reporting to regulators or other public bodies, should you wish not to report these to BRE or you feel that BRE is not acting on your concerns.
A full list of prescribed people and bodies you can report to is held by the Department for Business, Innovation & Skills and can be accessed here. This list includes the Health and Safety Executive, Commissioners for Her Majesty’s Revenue & Customs (HMRC) and The Environment Agency, among others.
Our commitment to non-retaliation
We recognise that reporting a concern can be a difficult, not least because of the fear of reprisal. The purpose of encourage reporting is not to apportion blame, but to understand and forestall any issues that might arise. We will not tolerate acts of retaliation of any kind against anyone who has reported in good faith a concern about a digression from the BRE Way. Furthermore, you may be protected by law for reporting certain concerns such as those relating to health and safety, the environment, or fraud and other illegal activities.
Refer to our Whistleblowing Policy in the BRE staff area of this site.
Q: Two months ago I accompanied my manager to visit a customer in Latin America. Our hosts upgraded my manager’s hotel room to a penthouse and gave him expensive gifts. I felt it was inappropriate for him to accept these and shared my concern with another manager when I returned. Since then my manager has stopped speaking to me almost entirely apart from being overly critical of everything I now do. I am afraid that he has found out that I reported him and is now getting back at me.
What Can I Do?
A: You should contact a member of the HR, Compliance, or Legal team, any Director or BRE Group Board Member. You could even contact a non-executive Board Member or BRE Global Governing Body member, should you feel uncomfortable raising it with a BRE employee. A thorough investigation will follow. BRE will not tolerate anybody’s career or reputation being adversely affected because they’ve had the courage to report a concern. BRE will protect and support you. If the investigation agrees you are a victim of retaliation, appropriate action will be taken.
Dealing with external feedback
BRE views all feedback as an opportunity to learn and improve. If you receive a compliment or recommendation you should record it and report it to the Customer Services team. If a response has been requested, Customer Services will forward the feedback to the relevant business area to respond.
Similarly, if you receive a complaint, you should record it and report it to Customer Services. At the discretion of Customer Services, the complaint will then be looked into either by the business area Manager/Director or their elected delegate, or by the Quality & Compliance team.