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Joanne Leach comments on the new laws cracking down on bosses exploiting foreign workers in Personnel Today

Posted on: November 29th, 2024 by Natasha Cox

Senior Associate and employment law specialist Joanne Leach comments on the new laws just introduced that will ban bosses who fail to pay their staff the minimum wage from hiring workers from abroad for up to two years.

Joanne’s comments were published in Personnel Today, 28 November 2024, and can be found here.

“Tougher rules to prevent companies exploiting cheap foreign labour are certain to be welcomed. Workforces are strengthened by the diversity brought to organisations by migrant workers and those individuals deserve not to be exploited.

“However, extending the power of Home Office officials to withdraw a company’s sponsorship licence if they breach employment laws could have potentially catastrophic consequences for businesses which rely on an overseas workforce. This announcement should therefore serve as a wake-up call to all employers that they must comply with employment laws as well as immigration rules.

“The government’s intention to expand the circumstances in which sanctions can be issued to include employment law breaches and extend the penalty from being banned from hiring overseas workers from one year to two will shift the compliance landscape considerably. However, it seems that the proposed expansion only applies to companies. It may be more effective to increase the sanctions on individuals who facilitate these breaches – perhaps further changes are to come before the draft legislation reaches parliament.

“It is uncertain when we can expect this law to come into effect. Companies effectively have a grace period to get their house in order. To do so, they should be taking an active approach to ensure compliance in all areas. Employers should review their policies and procedures to ensure they are up to date and meet minimum standards.

“It is hoped the government also consults early as to how this change can be implemented. It is unclear how a company will be judged to be in breach of employment laws – will this finding derive from a successful employment tribunal claim or will a new regulatory body be tasked with assessing failure to comply with minimum standards?”

If you would like some advice on how these new regulations might impact you as an employer, please contact our Employment team.

Employment law insight: New obligations regarding the fair distribution of tips

Posted on: October 1st, 2024 by Hugh Dineen-Lees

October 2024

The Employment (Allocation of Tips) Act 2023 (“the Act”), supplemented by a statutory code of practice and associated non-statutory guidance, comes into force today, 1 October 2024.

The Act significantly impacts the hospitality industry by introducing new rules governing how employers must deal with tips paid by customers, and it is estimated it will lead to an additional £200m being taken home by millions of workers in the UK.

The new requirements

The new legislation affects all retail and hospitality businesses including restaurants, cafes, hotels, hairdressers and taxi firms.

Businesses must now ‘fairly allocate’ all tips received. In addition, tips must be paid straight to workers and cannot be retained by the employer for any reason, including for business expenses.

“Tips” includes gratuities and service charges. However, it does not include cash tips if those are received by a worker and not declared to the employer. It does not matter if the tip is made by card, cash, or via an app.

In addition, employers must not make any deductions from tips except for tax, and where appropriate, National Insurance.

Tips must be paid to the worker/employee no later than the end of the month following the month in which it was paid by the customer.

What does fairly allocating tips mean?

The statutory code states that allocating and distributing tips fairly does not necessarily require employers to allocate the same proportion of tips to all workers, providing there are legitimate reasons why different workers are allocated different proportions.

The code provides examples of the criteria that employers may consider when allocating tips, such as:

  • the number of hours worked in the period the tips were collected;
  • individual and team performance;
  • level of responsibility and/or seniority;
  • customer intention;
  • length of service;
  • type of role (e.g., front of house or back of house); and
  • rate of basic pay.

The code prevents employers from pooling tips from multiple sites and all individuals who are involved in providing a direct service to customers should be considered as part of the distribution, including agency workers.

What do employers need to do?

Unless employers only receive tips on a very occasional or exceptional basis, they will need a written policy in place relating to the collection and distribution of tips.

They will also need to decide on their chosen method of tip distribution. How employers distribute is up to them, as long as it is fair. Some employers may choose to allow each individual worker to retain 100% of their tips received, whereas some employers may choose to implement a tronc system. However, using a tronc does not absolve employers of their responsibilities, so they will need to be careful to ensure the use of a tronc system is appropriate and that it is properly and fairly implemented. Employers should consider whether it is appropriate to seek the agreement of their staff as to which system of allocation will be used.

Employers must keep records of the qualifying tips received and how these are distributed. These records must be kept for three years from the date the tip was received and staff may request copies.

It is recommended that regular checks are made to ensure tips are being distributed in line with policies. It is also recommended that policies are regularly reviewed in line with business changes, such as restructurings or redundancies.

Connected obligations

Employers should be mindful of their data protection obligations when sharing records of tips. Employers should not provide details of the specific amounts paid to other workers, nor other people’s personal data, such as their bank details. Instead they should provide the total amount of qualifying tips received and the amount paid to the worker making the request.

Tips do not form any part of the National Minimum Wage. Employers must ensure that workers are paid in line with the National Minimum Wage and National Living Wage requirements regardless of any tips the worker may receive. 

How should an employer deal with complaints relating to tips?

The code of practice states that parties should attempt to resolve issues relating to tips between themselves. It is therefore imperative that any complaints are investigated and dealt with properly, either informally (if appropriate) or under a suitable grievance procedure.  

If the matter cannot be resolved internally, a member of staff may make a claim in the employment tribunal and they may be awarded up to £5,000 to compensate them for any financial losses relating to their employer’s failure(s).

If you have any questions on the fair distribution of tips or need assistance regarding your compliance with the new legislation, please contact a member of our Employment team.

Emma Cocker comments on ageism in the private wealth sector in eprivateclient

Posted on: October 1st, 2024 by Hugh Dineen-Lees

Senior Associate in the Employment team Emma Cocker comments on ageism in the private wealth sector, and how firms should be proactive in tackling this form of discrimination, in eprivateclient.

Emma’s comments were published in eprivateclient, 27 September 2024, and can be found here

“Employing older workers brings tangible benefits. These individuals often possess a depth of experience that younger workers may not, as well as an ability to connect with older clients. This is particularly important as statistics show that older individuals hold the bulk of private wealth within the UK. As such, workplace ageism ought not to be a problem in the private wealth sector, but this is unfortunately not the case. 

“The Equality Act 2010 protects against age discrimination in all aspects of employment including recruitment, terms and conditions, promotions, training and dismissals. Treating a worker less favourably simply because of their age, or in any way connected to their age, is (with very limited exceptions) illegal and should be avoided. Employment Tribunals are quick to root out issues of age discrimination, even in cases where employers attempt to dress up ageism as a legitimate reason for less favourable treatment. Compensation can be high, and cases attract adverse publicity.

“Leaving aside the risks of litigation, firms should be proactive in tackling age discrimination because of the noted benefits of employing older staff. This starts with the recruitment process where “blind recruitment” should be used to eradicate bias based on an applicant’s personal characteristics, including their age. Firms should also use initiatives such as discrimination and diversity training, as well as ensuring workplace policies do not discriminate on the grounds of age. Employee rewards ought to be based on performance and not length of service, and assumptions regarding “slowing down”, or older people being more likely to accept redundancies, should also be avoided.”

Employment law insight: Mohammed Al Fayed allegations and an employer’s duty to prevent sexual harassment at work

Posted on: September 20th, 2024 by Hugh Dineen-Lees

A recent BBC article highlighted that more than 20 female former employees have come forward to report their experience of sexual assault (and in five cases, rape) whilst working at Harrods.

This is unfortunately the latest in a series of high-profile sexual harassment cases in the workplace. The effect of such behaviour is extremely damaging, not least because of the risk of costly employment tribunal claims against employers, but also because the significant reputational damage inflicted affects the ability of organisations to attract and retain staff, as well as potentially losing them valuable customers. Cases of sexual misconduct undoubtedly affect businesses’ “bottom line”.

What is the law on preventing sexual harassment in the workplace?

While these latest allegations relate to cases of sexual assault and rape, these cases are thankfully rare. What is much less rare is allegations of sexual harassment at work.

Sexual harassment is unwanted conduct of a sexual nature which has the purpose or effect of either violating the person’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment.

The scope is broad and includes a wide range of behaviours. As the effect of sexual harassment is viewed subjectively (i.e. through the eyes of the victim) it is not uncommon for accused individuals to claim their behaviour was “banter” or, “a compliment” when it was, in fact, sexual harassment.

As well as the accused individual’s responsibility for sexual harassment, employers may also be responsible (or “vicariously liable”) for the conduct of their employees (and in some cases, other third parties such as customers). This can be the case even where they did not condone, or even know, the conduct had occurred.

Legislation will shortly come into force which increases the burden on employers to prevent sexual harassment in the workplace, making it even more important that employers are aware of, and acting in line with, their duties.   

The new duty

The Worker Protection (Amendment of Equality Act 2010) Act 2023 is due to come into force on the 26 October 2024 and creates an anticipatory duty on the employer to take reasonable steps to actively prevent the sexual harassment of their employees; not just to investigate them if they arise.

This is a law which was passed by the last government, but the current government is considering further extending this duty to require employers to take ‘all’ reasonable steps, rather than the reasonable steps that will be required from 26 October 2024.

What should employers do to comply with their new duties?

Having clear sexual harassment policies and procedures, providing anti-sexual harassment training and encouraging a “speak-up” culture are all critical steps for employers. Taking time to consider where the risks lie in a specific working environment, as well as the sector in which the organisation operates will help determine what further action needs to be taken. All of the above should be regularly reviewed and monitored.

Supporting HR managers in dealing with sexual harassment claims is also crucial. They are likely to be the first employee in a senior leadership position to whom such claims are reported and they must be well equipped to deal with allegations appropriately to avoid further potential damage to the organisation.  

What should a business do if a claim of sexual harassment is raised at work?

Any allegations should be properly investigated under an anti-harassment policy or grievance policy and appropriate action should be taken, based on the conduct identified.

Employers that are regulated, such as financial services organisations regulated by the FCA and/or PRA must remember that a failure to investigate and resolve such allegations could lead to regulatory investigations, as well as possible enforcement action.

The behaviour did not take place at their place of work – does this matter?

No. Employers may be liable for sexual harassment committed by their employees ‘in the course of employment’, meaning any place the employee is working, not just their regular place of work. Liability can also attach to acts committed when employees are not working but they are somewhere connected with work. This could include, for example, social drinks after work and Christmas parties.

Creating a culture of acceptable behaviour

It is important that employers create a workplace culture that minimises the risk of sexual harassment. Sometimes sexual harassment can stem from other inappropriate behaviours not being properly investigated and addressed. Turning a blind eye to these behaviours can fail to set the tone as to what is appropriate and inappropriate in the workplace, leading to costly claims against employers.  

If you have any questions on the new duty to prevent sexual harassment, or how to investigate allegations of sexual harassment, or if you require workplace training, please contact a member of our employment team.

Tesco loses its Supreme Court ‘fire and rehire’ fight

Posted on: September 19th, 2024 by Hugh Dineen-Lees

The practice of terminating an individual’s employment to re-employ them on new terms (known as ‘fire and re-hire’) has always been controversial. This is because it is typically used to implement unfavourable changes to employees’ contracts.

The Government is tightening up on such practices, and in July, issued a fire and re-hire code of practice which made it clear fire and re-hire should only be used in very limited circumstances. Now, the Supreme Court has granted an injunction to prevent Tesco from firing and re-engaging employees on lower compensation.

In 2007, Tesco inserted a clause into its contracts which provided for retention payment awards as an incentive for employees to relocate to other sites following the closure of distribution centres. In 2021, Tesco attempted to remove this clause and threatened anyone who did not agree with the termination of their employment. Consequently, the Union of Shop, Distributive and Allied Workers (USDAW) brought action against Tesco seeking an injunction to prevent the termination of the contracts, arguing the 2007 change was intended to be permanent. USDAW won an injunction in 2022 which stopped Tesco from carrying out its plans, but Tesco got that ruling overturned on appeal.

On 12 September 2024, the Supreme Court reversed that decision. Commenting that the individuals had been induced to make significant and permanent changes to their lives by relocating, the Judges made it clear that any limitation to the change should have been negotiated in 2007.

Employers may be concerned that this decision significantly narrows when fire and re-hire can be used. They may also be concerned that it sets a precedent for injunctive relief to be granted to protect employees from dismissal, which is rare. However, cases like these are fact-specific: the injunction was granted in a case where the affected individuals made a life-changing move in return for compensation during the performance of the contract – and it was not specified at the relevant time that the additional compensation could be taken away.

The Government has previously indicated that it intends to ban fire and re-hire, and following this judgment, the Department for Business and Trade has stated that new legislation shall be brought in soon. In the meantime, there are occasions where the use of fire and re-hire could still be appropriate, particularly if the alternatives are for employees to be retained on terms which significantly damage the business, or risks mass redundancies, or even for a business to cease trading entirely. The Tesco matter was different and was a situation which was said to be “unrealistic” and “flouting industrial common sense”.  However, it does highlight how careful employers must be when agreeing contractual variations, and, in particular, how employers ought to carefully consider the duration of any proposed changes.

If you have any question about the drafting or varying of employment terms and any related issues, please contact a member of our Employment team.

Becci Collins comments on Labour’s ‘Plan to Make Work Pay’ in People Management

Posted on: September 12th, 2024 by Hugh Dineen-Lees

Solicitor Becci Collins comments on the government’s proposed reforms surrounding ‘fire and rehire’ practices, redundancy rights and TUPE considerations, in People Management magazine.

Becci’s comments were published in People Management, 11 September 2024, and can be found here.

“The government has not implemented a complete ban on fire and rehire, as it originally pledged to do. Instead, it has made it clear that terminating employment before re-engaging an individual on different terms is the last resort. This requires an employer to ensure that it has taken all reasonable alternatives and reached an agreed outcome with affected individuals.

“A failure to comply with this requirement could provide grounds for unfair dismissal claims, which may cause reputational damage as well as adverse implications on employee relations. A further extension to a complete ban would put employers in a very uncomfortable position should the business get into financial difficulty. Instead of being able to retain its workforce on different terms, the business would be forced to consider redundancy in order to ensure its survival.

“Whilst the government has stated that it intends to strengthen TUPE protections, further detail has yet to be provided. The previous Conservative government confirmed that only employees are protected by the TUPE provision in response to case law which cast doubt on this. The current Labour government has indicated that it will take the opposite approach and extend the protection to those currently classed as workers by creating a single worker status, encompassing the current status of employee and worker.

“Extending the number of individuals protected by TUPE would increase the amount of work – and therefore time and costs – for employers, which may act as a deterrent. It may also increase the responsibilities a business assumes through the TUPE process, as any liabilities (potentially including litigation), may be transferred, although contractual indemnities could prevent this.

“The Labour government has proposed extending the requirement on when a collection consultation is required in redundancy to instances where 20 people will be impacted across the business, not just one workplace. This proposal would widen the number of individuals entitled to collective consultation.

“Further, earlier in the year, redundancy protection was expanded for those returning from maternity or adoption leave. They are to be offered suitable alternative employment ahead of other individuals at risk. However, where shared parental leave is taken, individuals are only protected for the period of their maternity or adoption leave. We may see the new government extend protections to cover this additional period of leave.

“Employers will need to ensure that their policies reflect these extended protections and be aware that failure to account for the expansion may result in a costly unfair dismissal and/or discrimination claim.”

Emma Cocker comments on Employment Tribunals and the Employment Bill in City A.M.

Posted on: August 29th, 2024 by Hugh Dineen-Lees

With the upcoming Employment Bill on the horizon, Senior Associate in the Employment team Emma Cocker comments on whether current Employment Tribunals will be fit for purpose, in City A.M.

Emma’s comments were published in City A.M., 28 August 2024, and can be found here.

“The government’s intention to significantly expand employment rights will have a monumental effect on employment tribunals. We already know that tribunal claims are up by around 7% compared with 2022/23 with over 650,000 open cases. Giving employees protection against unfair dismissal from day one of their employment along with the extension of time limits for bringing claims from three to six months is likely to significantly effect the Tribunal’s ability to deal with cases in a timely manner. 

“Worryingly, parties are already experiencing significant delays, with some cases taking over 18 months to reach a final hearing. Complex discrimination claims face the longest waits, with Tribunals struggling to find capacity for hearings that are often listed for a minimum of seven days.  

“The former Conservative government had consulted on the reintroduction of Tribunal fees; however these were nominal and would be unlikely to make any difference in combating delays. The current government’s main solution appears to be the digitisation of claims, but it is unclear what further improvements are proposed beyond the existing online platform for submitting claims and liaising with the Tribunal. 

“Employment Tribunals could become overwhelmed with increased claims on top of already long delays, meaning both employers and employees may face longer waits to resolve workplace disputes.”

If you would like any advice on the upcoming Employment Bill or Employment Tribunals, please contact a member of our employment team.

Regulatory update on the use of non-disclosure agreements

Posted on: August 23rd, 2024 by Hugh Dineen-Lees

On 6 August 2024, the Solicitors Regulation Authority (SRA) updated its warning notice to solicitors on the use of non-disclosure agreements (NDAs).  In essence, an NDA is any agreement/contract or clause within a wider agreement/contract under which is it agreed that certain information will be kept confidential between the parties.

In the employment law context, NDAs are typically found in settlement agreements. These are used by employers to settle employment tribunal claims, either after proceedings have been initiated, or as a way of securing the employee’s agreement not to bring claims in the future.

The SRA first published the warning notice in March 2018, following concerns arising from the #MeToo movement that settlement agreements containing NDAs were being used to prevent the reporting of misconduct to the relevant criminal and/or regulatory authorities, in particular, sexual misconduct.

The warning notice was revised in November 2020 to make clear that inserting other types of clauses which discouraged the reporting of incidents could also amount to a breach of the SRA’s regulatory Principles and Code of Conduct. Now the SRA has further updated the warning notice, which although aimed at solicitors, is useful for employers to be aware of when they are thinking of offering an individual a settlement agreement containing an NDA.

In particular, employers ought to consider:

Is an NDA required? The SRA states NDAs “should not be used routinely” and ACAS guidance highlights that careful consideration should be given to the need for NDAs on a case-by-case basis. Only use NDAs when they are genuinely needed. Be especially careful in cases where the employee has raised complaints that could constitute criminal conduct, or conduct warranting regulatory investigation and/or action. Template or ‘off the shelf’  agreements are not likely to be appropriate, so take specific advice in each and every case.

Time limits: Solicitors should challenge unreasonable time limits proposed by the opponent to ensure the individual’s solicitor has sufficient time to take instructions, advise and respond. Be wary, as an employer, of setting unreasonable deadlines and always ensure the individual has enough time to take proper legal advice.

Funding: Consider whether the typical contribution of £500 plus towards the employee’s legal fees is fair and reasonable in the circumstances, particularly if the employee has raised serious allegations that could constitute criminal conduct, or conduct warranting regulatory investigation and/or action.

Please contact our specialist employment team if you need further guidance on employment tribunal claims or settlement agreements and non-disclosure agreements.

 

 

Joanne Leach comments on the ‘right to disconnect’ in City A.M.

Posted on: August 21st, 2024 by Hugh Dineen-Lees

Joanne Leach, Senior Associate in the Employment team, comments on the government’s plan to give workers the ‘right to disconnect’ outside of their work day, in City A.M.

Joanne’s comments were published in City A.M., 21 August 2024, and can be found here.

“The implementation of the “right to disconnect” will require employers to carefully weigh up the competing interests of various employees. One individual’s “right to switch off” might curtail the right of another to work flexibly. This would impact others who require flexibility.

“To manage this risk, employers should suggest practical measures such as requiring any staff working outside core office hours to delay the sending of internal emails until the next working day. This is likely to be more effective in managing any conflicts as opposed to mandating all employees to switch off when it does not suit them.

“It remains to be seen whether employers can implement such practices and benefit from the increased productivity that the policy aims to deliver without opening themselves up to the chance of claims brought by staff who feel that their right to work flexibly has been curtailed by a government order to disconnect.”

If you would like some advice on how to support your staff in relation to flexible working and wellbeing, please contact a member of our Employment team.

Emma Cocker discusses menstruation in the workplace in People Management

Posted on: August 12th, 2024 by Hugh Dineen-Lees

Emma Cocker, Senior Associate in the Employment team, explores how employers can best support staff who are menstruating or experiencing the menopause in People Management.

Emma’s article was published in People Management, 9 August 2024, and can be found here.

There are around 15 million people of menstruating age in the UK, with roughly the same number ‘in work’. It is likely that a significant proportion of those 15 million people will either be menstruating or in menopause. Given these figures, you might think menstruation would be a hot topic in the workplace. However, the evidence suggests otherwise, with only 12 per cent of organisations providing support for menstruation and menstrual health.  

A recent study by Heriot-Watt University revealed that individuals who menstruate are still facing significant challenges at work, including poor access to toilets and washing facilities, pain and mental health symptoms, and the need to conceal menstrual blood due to stigma. This study focused on the experiences of menstruating people working in research and innovation roles, but the findings are equally applicable to all work environments. 

It is estimated that up to one in three people who menstruate will experience abnormal menstruation at some point in their reproductive lives, most commonly when starting their periods and before menopause. Menstruation and menopause, therefore, are a significant health and wellbeing concern for employers.

The importance of creating a positive and open environment around menstruation cannot be overstated and employers should prioritise educating line managers, regardless of their sex. It is often felt that people who do not menstruate have no understanding of the all-encompassing physical and mental effects of menstruation beyond age-old stereotypes around premenstrual tension. If employees know that all line managers have received appropriate training, they are likely to feel more comfortable about raising concerns with their employer. This will lead to increased confidence and higher productivity and staff retention rates, with a lower chance of stress, anxiety and depression. 

Although not specifically a part of this study, menopause is another issue facing people who menstruate. Menopause is thought of as the simple ceasing of menstruation, however this does not account for perimenopause – the often prolonged and challenging build-up to menopause. Perimenopause can manifest itself in a multitude of physical and mental health symptoms such as unpredictable changes in body temperature (hot flushes), extremely heavy menstrual bleeding (flooding), and problems with memory or concentration (brain fog). In extreme cases, perimenopause may even push individuals to stop working altogether.

Ensuring access to appropriate toilet and washing facilities is also important and employers may also wish to provide hygiene products in all toilet spaces; as well as the practical benefits, this helps to reduce the taboo around menstruation.  

Making provisions for regular comfort breaks is also vital in occupations such as caring and hospitality, where it may be more difficult to take breaks exactly when or as often as needed. In workplaces such as schools, a buddy system can be helpful to ensure that staff can access facilities quickly without having to worry about arranging cover while they are away from the classroom. 

Employers should also consult with staff on uniform requirements. While a light-coloured uniform may be considered visually appealing, it may cause anxiety for those who menstruate because of the fear of leaking or unexpected bleeding. 

Also, a lack of workplace policies could be costing businesses over £6bn per year due to lower productivity. Policies including enhanced sick pay or flexible working could improve such issues and employers should also consider reviewing other relevant policies such as well-being, EDI and performance management to consider menstruation and menopause. This will also help to ensure employers are compliant with the relevant provisions of the Equality Act 2010.

Joanne Leach comments on minimum service levels and industrial action in City A.M.

Posted on: August 8th, 2024 by Natasha Cox

Joanne Leach, Senior Associate in the Employment team, comments on the news that the UK government will repeal controversial laws enforcing minimum service levels during industrial action, in City A.M.

Joanne’s comments were published in City A.M., 7 August 2024, and can be found here.

“With the proposed plans to ignore minimum services levels legislation, the government can secure an easy early win in terms of following through on the employment commitments of their election manifesto.

“Repealing this controversial and ineffective legislation, which had already been subject to challenge via judicial review, will take up minimal legislative time in contrast to the scrutiny that will inevitably be required of the implementation of the rest of its New Deal for Working People. A direction to ignore its provisions in advance of that repeal will effect an even more immediate impact – the strengthening of the fundamental right of any worker to withdraw their services to protect their contractual terms.”

If you would like further advice on these legislative changes and the impact they may have on you, please contact a member of the Employment team.

Joanne Leach comments on anti-bullying policies in People Management

Posted on: August 6th, 2024 by Natasha Cox

Joanne Leach, Senior Associate in the Employment team, comments on a recent study which found that more than half of UK employees do not think that shouting at work counts as bullying and discusses how employers can address workplace bullying.

Joanne’s comments were published in People Management, 5 August 2024, and can be found here.

“Adopting an anti-bullying and anti-harassment policy is merely the first step an employer must take towards addressing workplace bullying. To ensure it is effective, employers must also train the whole workforce on what is required of them regarding their interaction with colleagues.

“What constitutes ‘acceptable conduct’ has shifted significantly in recent years, and behaviour that used to be tolerated can now lead to significant liabilities for an individual and their employer.

“When an incident of bullying occurs, employers are more likely to minimise liability with clear grievance and whistleblowing policies in place which employees can access and managers can understand.

“Policies that address workplace culture, such as a clear diversity, equity and inclusion policy and training on unconscious bias and allyship, also empower employees to support their colleagues and call out wrongdoing if they witness unacceptable conduct.”

If you would like any assistance in developing whistleblowing, workplace culture or diversity, equality and inclusion policies, please contact a member of our Employment team.