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WHISTLEBLOWING policy

​Last reviewed: 19th March 2026
Next review: 1 Jan 2027

Policy Owner: Samuel Davies, Managing Director, Atlas Media Limited
Contact: sam@atlas.film
 

1. Purpose

 

Atlas Media Limited is committed to upholding the highest standards of integrity, transparency, and accountability in all areas of its work. We recognise that those working within or alongside the company are often best placed to identify potential wrongdoing.

 

This policy is designed to encourage individuals to raise genuine concerns in confidence and without fear of retaliation, ensuring that issues are addressed appropriately and without delay.

 

It supports, and should be read alongside, other company policies, including our Anti-Bribery & Anti-Corruption Policy and grievance procedures.

 

2. Scope

 

This policy applies to all individuals working for or on behalf of Atlas Media Limited, including directors, employees (permanent, fixed-term, and part-time), freelancers, contractors, and third-party partners.

 

Whistleblowing refers to the reporting of suspected wrongdoing or risks in the workplace. It is distinct from personal grievances, which should be addressed through the appropriate internal procedures.

 

3. Reportable Concerns

 

Individuals are encouraged to report concerns relating to suspected wrongdoing, whether current, past, or potential. These may include:

 

  • Criminal offences or fraudulent activity

  • Bribery or corruption

  • Breaches of legal or regulatory obligations

  • Miscarriages of justice

  • Risks to health and safety

  • Environmental harm

  • Attempts to conceal any of the above

 

This list is not exhaustive. If there is any uncertainty, concerns should still be raised in good faith.

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4. Legal Protection

 

Under the Public Interest Disclosure Act 1998, individuals who make a qualifying disclosure are protected from dismissal or unfair treatment.

 

Atlas Media Limited fully supports these protections and prohibits any form of retaliation against those who raise concerns honestly and in the public interest, even if the concern ultimately proves unfounded.

 

5. How to Raise a Concern

 

Step 1 - Internal Reporting

Concerns should normally be raised with the Managing Director, either verbally or in writing. Individuals are encouraged to provide as much relevant detail as possible, including dates, names, and supporting information.

 

There is no expectation to investigate or prove the concern - reasonable suspicion is sufficient.

 

Contact: Managing Director

Email: sam@atlas.film

 

Step 2 - Alternative Contact

If the concern involves the Managing Director, or if it is not appropriate to raise it with them, concerns should be directed to an alternative contact (such as an external adviser, company accountant or legal advisor).

 

Step 3 - External Reporting

If a concern is not resolved internally, or if it is not appropriate to raise it within the company, individuals may report the matter to a relevant external authority, such as:

 

  • HMRC (tax or wage concerns)

  • Health and Safety Executive (HSE)

  • Environment Agency

  • Financial Conduct Authority (FCA)

  • Information Commissioner’s Office (ICO)

  • Police

 

Independent advice can also be sought from Protect.

 

6. Anonymity and Confidentiality

 

Concerns may be raised anonymously; however, providing contact details can assist with investigation and follow-up.

 

Where identity is disclosed, Atlas Media Limited will take all reasonable steps to maintain confidentiality, sharing information only where necessary or legally required.

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7. Our Response

 

Upon receiving a concern, the appropriate contact will:

 

  • Acknowledge receipt, typically within five working days

  • Assess the nature of the concern and determine next steps

  • Initiate an investigation or refer the matter where appropriate

  • Provide updates where possible, while respecting confidentiality

 

All concerns will be handled seriously, fairly, and as efficiently as circumstances allow.

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8. Protection from Retaliation

 

Atlas Media Limited does not tolerate any form of retaliation, victimisation, or adverse treatment against individuals who raise concerns in good faith.

 

Any such behaviour will be treated as a serious disciplinary matter and may result in termination of employment or engagement.

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9. Misuse of the Policy

 

This policy is intended to support genuine disclosures made in good faith. Deliberately false or malicious allegations may result in disciplinary action.

 

10. Record Keeping

 

A confidential record will be maintained of all concerns raised, including details of investigations and outcomes. Records will be stored securely and handled in accordance with applicable data protection requirements.

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11. Review

 

This policy will be reviewed annually, or earlier if required due to changes in legislation or business operations. Any significant updates will be communicated to all relevant parties.

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