Guidance

Speak Up Policy

Published 27 October 2026

Policy Statement

The NDA group has a shared commitment to delivering the mission ethically; this includes creating an environment where everyone is valued, respected, included, and feels comfortable raising concerns and speaking up. In line with this, all NDA Group Operating Companies have a consistent approach on Speak Up. 

The aim of the NWS policy is to ensure all concerns raised are captured, considered, and dealt with appropriately. It will also help us to learn from the matters that are raised so that we can improve how the NDA Group operates as part of our vision to create great places to work. It is not contractual; we will review it regularly and may change it. 

The policy applies to all permanent NWS employees, agency workers and consultants contracted to NWS.

NWS commits to:	We will achieve this by:
Creating an environment in which anyone working for NWS can raise a concern.	Not tolerating anyone being prevented or deterred from speaking up or being mistreated because they have spoken up. Any suggestion of retaliation against individuals who speak up will be taken very seriously. It’s important we all feel safe and confident to speak up and that we take the time to really listen
Ensuring anyone working for NWS knows how to raise a concern.	Facilitating a number of ways to raise concerns or issues at NWS: For example, there is OSHENS for health, safety and security observations or incidents; a dedicated cyber security reporting system for cyber matters; HR processes in relation to employment matters; and you can always speak to a member of the management team. However, if for any reason you do not want to use these routes, then this policy provides an alternative route.
Promoting Safecall, an impartial service for individuals who wish to report any matter of concern they feel cannot be reported by using an internal method for whatever reasons.	You can contact Safecall by telephone on 0800 915 1571, or via the Safecall website. www.safecall.co.uk
Ensuring strong governance and continuous improvement in the oversight of speak up.	Providing updates to the NWS Audit, Risk & Assurance Committee (ARAC) on speak up activity. This oversight helps the ARAC assess the effectiveness of the Speak Up culture and ensures that leadership is held accountable for maintaining a safe, transparent, and responsive environment. The ARAC’s active engagement reinforces our commitment to ethical conduct and supports a culture were speaking up is valued and protected.

Definition of Speaking Up

Speaking up is about raising concerns about things you think aren’t right or are worried about, without fear that you will be mistreated because you have spoken up. By being open and doing the right thing we will create a more positive, ethical working culture for everyone. Taking a personal responsibility for speaking up is part of what we expect from everyone, and leaders have a particular responsibility to promote speaking up and create an environment where it is safe for everyone to do so.  

Here at Nuclear Waste Services Ltd (NWS) we want you to feel safe to speak up and want to hear about any concerns you have. Your speaking up helps us to identify opportunities to put things right or for improvement that we might not otherwise know about and make working here better for you and our colleagues.

Who is this policy for?

This policy is particularly for everyone who works here, including permanent employees, Agency Supplied Workers, consultants, secondees and graduates. It explains how you can raise concerns and what happens if you do.  

If you work for one of our suppliers, you can also report concerns in accordance with this policy. You can always access Safecall – our independent, confidential platform for raising concerns, using the details below. Home - Safecall Ltd Whistleblowing service provider, vendor, solutions

What can I speak up about?

You can speak up about anything that gets in the way of delivering our purpose, anything that affects your working life or any situation where you are concerned, we haven’t done the right thing or gone about it in the right way. That could be something which simply doesn’t feel right to you.  

Some examples that may fall under this policy include: 

• You suspect that there has been a breach of the law, e.g., bribery, corruption, fraud, or the facilitation of tax evasion which is not being addressed. 

• You are worried that a person’s personal interests have conflicted with their professional duties, e.g., where a contract has been awarded to an organisation which a person involved in the process has a personal connection to, and you are concerned this might not have been properly disclosed and considered.  

• You are concerned that someone has falsified (i.e., deliberately changed or left out) important information in a document. 

• You see something happening or become aware of a practice that you are concerned may become dangerous or put the organisation at risk (if there is an immediate threat to life, safety or property, please use the emergency response route). 

• You witness inappropriate behaviour such as bullying, harassment or discrimination towards a colleague (if it is you experiencing these behaviours, please use the processes set out at Table 1 below). 

Some issues may be most appropriately considered under other policies or processes for example the grievance or respect at work policy. If you raise something as a speak up that is better dealt with under another policy or process, we will help redirect it. You should believe what you’re saying is true, even if you’re not completely sure. 

This is not the right policy to use for: 

• Concerns about immediate threats to life, safety or property. 

• Concerns about treatment you have personally experienced in the course of your employment.

Who can I speak up to?

Within NWS

Lots of speaking up happens informally through conversations with supervisors and line managers where questions, suggestions and challenges are raised and resolved quickly, and help is sought where needed. We strive for this to be a normal, everyday practice and encourage you to explore this option – it may well be the simplest and easiest way of resolving matters.

However, you have other options in terms of who you can speak up to depending on what feels most appropriate to you and the type of matter it is, and we’d encourage you to use one of these options to give us the best chance to take action and resolve matters.

Issue	Method
Health, safety, security observations or incidents	OSHENs. Trade Union Safety Reps. Line Managers
Employment matters	HR and Trade Union Reps
Cyber	Cyber reporting line
Whistleblowing	See separate Speak Up/Whistleblowing Guidance document, NWS reporting channels (see Response 11 of the Guidance Document) for further details on this, Safecall or a relevant external agency or regulatory body as specified in the whistleblowing legislation (Public Interest Disclosure Act 1998). The Office for Nuclear Regulation (ONR)
Ethics & Compliance matter	NWS Ethics and Compliance Lead
Any matter you feel cannot be raised using an internal method, for whatever reason	Safecall

Within the NDA Group

If you feel you cannot speak up within NWS, you may do so to via the NDA Ethics & Compliance Team HR@nuclearwasteservices.uk or use Safecall and indicate you wish the concern to be raised as an NDA matter. They will then oversee the resolution of your matter, involving NWS as appropriate.

Safecall (independent concerns hotline provider)

The NDA Group uses Safecall, an impartial service for individuals who wish to report any matter of concern they feel cannot be reported using another internal method for whatever reason. Safecall will then notify the NWS Ethics & Compliance lead of your concerns – they do not investigate them. It is possible to remain anonymous if you use this route. Individuals who choose to report anonymously are provided with a unique email address and are required to set up a password on the Safecall website. They are encouraged to periodically log in to the site to check for updates, respond to any follow-up questions, and receive information about the progress or outcome of their concern. 

You can contact Safecall by telephone on 0800 915 1571, or via the Safecall website www.safecall.co.uk. Please note Safecall do not investigate the matter.

Externally

We would always encourage you to use internal options above, at least in the first instance. 

However, there may be exceptional times when you feel it’s most appropriate to raise an issue externally to a regulator or relevant professional body.

How should I Speak up?

You can speak up to any of the people or organisations in the table above in person by phone or in writing (including email). In all circumstances, please be ready to explain as fully as you can the information and circumstances that prompted you to speak up.

What happens when I Speak up?

Every concern is considered, and a decision is made about whether an investigation is needed, another policy or process is more appropriate to deal with the issue, or whether another method of resolving the concern is more appropriate. What you can expect to happen after speaking up is shown in the ‘Communicating with you’ and ‘How we learn from speak up’ sections of this policy and in the Speak Up/Whistleblowing Guidance document. The ‘Confidentiality’ section of the policy below explains our commitment to treating concerns with a high standard of confidentiality. 

Where an investigation is needed, this will be objective and conducted by someone who is suitably impartial (this will typically be someone from within our organisation, but it might be someone from a different part of the NDA Group or, when required, someone external) with appropriate training. The type of investigation and length of time to resolve will very much depend on the issue raised but will normally be completed within 12 weeks or in line with the NWS Grievance Policy. After receiving an acknowledgement of your concern, you will receive updates as appropriate.

Training and Awareness

All employees will receive an overview of the NWS Speak Up policy as part of their induction process to ensure early awareness of how to raise concerns safely and appropriately. In addition, employees are expected to complete relevant training on speaking up, which is available through the NWS Learning Management System. This training should be undertaken within the first three months of joining the organisation and refreshed every 3 years to support a consistent understanding of the policy and promote a culture of openness from the outset.

Non-retaliation

We will protect any person who reports a concern which they believe to be genuine, or assists with an investigation, from retaliation for having done so. We set clear expectations through training and communications that retaliation of any kind will not be tolerated. We are committed to addressing retaliation and we strongly encourage individuals to speak up if they experience or witness such behaviour. Any reported instances will be taken seriously and investigated, with disciplinary action taken where appropriate. Managers are expected to actively foster a safe environment and remain alert to any signs of mistreatment, ensuring that those who do the right thing by speaking up are supported.

Confidentiality

We understand you may have concerns about who will know that you have spoken up, and this information will always be treated on a strictly need to know basis. If you do not wish to be identified, we will take steps to protect your identity as the person who has spoken up, (although in limited circumstances it may not always be possible). More information can be found in the Speak Up/ Whistleblowing Guidance document. 

The only way you can retain anonymity is to use Safecall. If you identify yourself to us, it makes it much more likely that we will be able to get to the bottom of your concern, as we are able to ask you for clarifications, and further information and also provide you with help and support. We’ll also be able to provide some feedback on the outcome.  

The persons managing your concern will take steps to ensure that your concern will only be shared with others, on a strictly need-to-know basis.  

If you are concerned about how your data will be used and processed, please refer to the NWS data privacy notice.

Communicating with you

We will always treat you with respect and will thank you for speaking up.  

Exactly how and to what extent we communicate with you or involve you in the process to consider the issue you have raised will depend on what the issue is and how it is taken forward, but we’ll let you know what to expect.  

Feedback Mechanism: To support transparency and trust in the Speak Up process, a structured feedback loop is in place. Once a concern is raised, the individual will receive an initial acknowledgement, typically within five working days. Where appropriate, updates on the progress of the matter will be provided at key stages, such as when an investigation begins or concludes.

While confidentiality may limit the level of detail shared, individuals will be informed when their concern has been reviewed and whether any action has been taken as a result. Those who report anonymously via Safecall are encouraged to log in periodically to check for updates or respond to follow-up questions.

How we learn from Speaking up

Making sure we learn from the matters our people have spoken up about is critical to help us make improvements to what we do and the environment we work in. Where improvements that can be made are identified, we will ensure necessary changes are made and are working effectively. If it’s appropriate and we can do so without breaking confidentiality, we’ll share what we’ve learned. 

We will seek feedback from you about your experiences of speaking up. We will review the effectiveness of this policy and our local process every three years, with the outcome published by NDA and changes made as appropriate.