Whistleblowing Policy

Introduction

This Whistleblowing Procedure provides a mechanism for any person to alert CTHS on an anonymous basis of any conduct that may relate to manipulation of STAR MI Submissions by participants or STAR Accreditation Award administered by CTHS (STAR).

About CTHS

CT Holdings & Services Ltd (‘CTHS‘) is a joint venture between TISA Exchange (TeX) and Criterion Tec as a not-for-profit organisation to deliver STAR for the industry. This will include agreeing Service Level Definitions for completing a transfer and measuring performance against those targets through the accreditation of STAR participants and the STAR Accreditation Awards.

Making a Whistleblowing Disclosure

If you wish to make a disclosure to CTHS, the contact details are respectively in sections 5 and 6 below. You may make a disclosure on an anonymous basis, however this may make the disclosure more difficult to investigate, or in some cases impossible. Nonetheless anonymous disclosures will be investigated if possible to do so.

You should consider making a disclosure if you have reasonable belief that the information you would disclose indicates manipulation of the data or resultant STAR Accreditation Award administered by CTHS – whether manipulation has potentially or actually occurred, is occurring or is likely to occur.

You should also consider making a disclosure if you have reasonable belief that information submitted by another STAR participating organisation indicates manipulation of the data or resultant STAR Accreditation Award administered by CTHS – whether manipulation has potentially or actually occurred, is occurring or is likely to occur.

If the disclosure would be in relation to your current employer, you should consider making a disclosure under your employer´s whistleblowing policy where one exists. You should still consider reporting your concerns to your employer even if they do not have a whistleblowing policy.

You may wish to seek advice from the whistleblowing charity Protect, which aims to protect society by encouraging workplace whistleblowing. If you are in the UK, Protect’s free and confidential Protect Advice Line can be contacted on +44 (0)20 3117 2520 or by email to whistle@protect-advice.org.uk. If you live outside the UK, Protect suggests that you contact your trade union, a lawyer or, if there is one in your country, an organisation that specialises in advising Whistleblowers. Protect’s website contains contact details for other Whistleblower organisations.

Treatment of Disclosures by CTHS

On receipt of your whistleblowing disclosure, we will first check whether the disclosure relates to information that manipulation, or attempted manipulation, of a STAR Accreditation Award administered by CTHS has occurred, is occurring or is likely to occur.

If we consider that the information does not relate to potential manipulation of a STAR Accreditation Award administered by CTHS, we will advise you accordingly if your identity and contact details are known to us.

Where the information does relate to potential manipulation of a STAR Accreditation Award administered by CTHS, we will acknowledge the disclosure if your identity and contact details are known to CTHS.

CTHS will then seek to investigate whether the whistleblowing information can be substantiated.

If you have requested anonymity but your identity and contact details are known to CTHS, we will take reasonable steps to keep your identity confidential. However, there are circumstances in which, because of the nature of the investigation or disclosure, it will be necessary to disclose a person’s identity – for example, in connection with associated legal or regulatory investigations or proceedings. If in CTHS’s view such circumstances exist, we will seek to inform you that your identity is likely to be disclosed. We will not disclose your identity unless we are required to do by the FCA or otherwise by the operation of law.

Where we concur that manipulation has potentially or actually occurred, is occurring or is likely to occur, CTHS will refer the allegation to the STAR Accreditation Committee and we will generally provide to the STAR Accreditation Committee the results of our investigatory work on the matter.

If you make a whistleblowing disclosure to CTHS, we expect you to respect confidentiality and to refrain from making the information known to persons who do not have a legal or regulatory role relating to the disclosure.

CTHS will take all reasonable steps to protect you if you make a disclosure from any detriment including victimisation or criticism.

Please note that disclosures cannot be withdrawn once received by CTHS.

The Board of Directors of CTHS and the STAR Steering Group receive an anonymised summary at least yearly of any whistleblowing disclosures made to CTHS, together with an analysis of whether the information in a disclosure was substantiated. All disclosures included in the summary will be fully anonymised.

We will retain all whistleblowing records for at least seven years.

Contacts at CTHS

CT Holdings & Services Limited registered office is at Regent’s Court, Princess Street, Hull, HU2 8BA

Email: whistleblowing@star-transfers.co.uk

Whistleblowing to the FCA

You may wish to raise your concerns with the FCA as the regulator prescribed in respect of financial services and markets matters under the Public Interest Disclosure Act 1998 (PIDA).

The FCA would encourage you first to use the whistleblowing procedures in your workplace.

The PIDA is available at http://www.legislation.gov.uk.

You can telephone the FCA on +44 (0)20 7066 9200 during office hours or leave a message on voicemail and, if you wish, they will ring you back.

The FCA’s other contact details for whistleblowing are:

Enforcement and Financial Crime Division (ref PIDA)
Financial Conduct Authority
12 Endeavour Square
London E20 1JN
Email: whistle@fca.org.uk.

Review

This Whistleblowing Procedure is reviewed at least annually by the CTHS Board.