
Whistleblowing Policy
Last updated: 23/04/2025
Policy Statement
Thurstan Hoskin Solicitors LLP is committed to the highest standards of openness, integrity and accountability. As part of that commitment, we encourage staff and third parties to speak up if they have concerns about wrongdoing, risk, or malpractice within the firm. This policy sets out how individuals can raise concerns confidentially and without fear of retaliation.
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Purpose
The purpose of this policy is to:
Enable and encourage staff and external parties to raise serious concerns internally
Outline how concerns will be investigated and addressed
Protect whistleblowers from reprisals or victimisation
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Scope
This policy applies to:
All employees (permanent, temporary, and contract)
Partners and consultants
Trainees, agency workers, volunteers, and interns
Third parties including clients, suppliers, and contractors
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What is Whistleblowing?
Whistleblowing is the disclosure of information about suspected wrongdoing or dangers in relation to our firm’s activities. Examples include:
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Criminal offences (e.g. fraud, bribery)
Breaches of legal or regulatory obligations
Risk to health and safety or the environment
Miscarriages of justice
Deliberate concealment of any of the above
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Personal grievances (e.g. bullying, harassment) should be raised under our grievance procedures.
Raising a Concern
Concerns should be raised as soon as possible, ideally in writing, with:
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Your line manager or supervising partner
Our Compliance Partner (or MLRO if financial crime is suspected)
Alternatively, concerns can be reported anonymously via the Solicitors Regulation Authority (SRA): https://www.sra.org.uk/consumers/problems/report-solicitor/whistleblowing-to-sra/
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Handling of Disclosures
All concerns will be taken seriously and investigated promptly. Investigations will be conducted fairly and sensitively. Confidentiality will be maintained as far as possible, but information may need to be disclosed to others on a need-to-know basis to investigate effectively.
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We will:
Acknowledge concerns within 5 working days
Commence investigation within 10 working days
Provide a response or update within 30 working days (or explain any delays)
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Protection for Whistleblowers
We are committed to ensuring that whistleblowers are not subjected to any detrimental treatment as a result of raising a genuine concern. Any retaliation or victimisation will be treated as a disciplinary offence.
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False or malicious disclosures made deliberately to harm individuals or the firm may lead to disciplinary action. However, no action will be taken against anyone who raises a concern in good faith, even if it is later found to be unfounded.
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External Disclosures
In rare circumstances, and if internal channels have been exhausted or are inappropriate, concerns may be raised externally with regulators such as:
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The Solicitors Regulation Authority (SRA)
The Legal Ombudsman
HMRC (for financial crime)
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Roles and Responsibilities
Compliance Partner: Overall responsibility for whistleblowing matters
MLRO:Â Point of contact for financial crime concerns
HR Lead: Ensures whistleblowers are supported and protected
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Record-Keeping and Oversight
All whistleblowing reports will be recorded in a secure register by the Compliance Partner. Periodic reviews will be carried out to identify trends, ensure consistent handling, and report findings (where appropriate) to the Partners.
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Training and Culture
Whistleblowing awareness is included in staff induction and refreshed through annual compliance training. The firm is committed to fostering a culture where staff feel confident to raise concerns without fear.
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Monitoring and Review
The effectiveness of this policy will be reviewed annually by the Compliance Partner. Any improvements or changes will be communicated to all staff. Feedback from staff on how the policy operates in practice is welcome.
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Approval
This policy was approved by the Partners of Thurstan Hoskin Solicitors LLP on 24/04/2025 and is reviewed annually.
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