About this policy
The aim of this policy is to encourage individuals who may have concerns regarding instances of malpractice and improper conduct to contact SEAI. This invitation applies equally to members of the public, homeowners, beneficiaries, applicants, grantees, nominated project contacts or applicant representatives, project co-ordinators, contractors or any other competent person, BER Assessors, special advisors or independent consultants, stakeholders, or anyone otherwise involved in or familiar with a programme delivered by SEAI.
The successful delivery of all programmes managed and administered by SEAI relies upon the honest and reasonable participation of all parties involved.
All registered contractors, installers, BER assessors or any other competent persons, special advisors or independent consultants and any other parties involved in a programme have an absolute responsibility to undertake their duties in a competent, professional and honest manner.
SEAI welcomes disclosures concerning suspected instances of malpractice or improper conduct. You may from time to time have concerns about possible improprieties by individuals involved in these programmes.
What is a concern / disclosure?
- Examples of concerns that may warrant disclosure include, but are not limited to, suspected instances of: Unlawful or improper use of funds, and/or resources of a public body or any other financial malpractice, impropriety or suspected fraud;
- Improper conduct or unethical behaviour;
- Failure to comply with or breach of the operating rules and/or guidelines of a programme or any attempt to encourage a breach of same or a breach of the terms of contractor / assessor registration;
- Failure to comply with any legal obligations or statutes;
- Danger to the health and safety of an individual;
- Damage to the environment;
- Criminal activity or the commission or committing of an offence; and
- Attempts to deliberately conceal any of the above matters or attempts to induce others to facilitate such actions.
A disclosure or concern may be received under the Disclosures Policy or in another way, for example, a concern may be raised by an individual by contacting their usual contact within SEAI. This is also dealt with as a disclosure.
What happens when a disclosure is made?
Our actions may include:
- Consideration of all disclosures which fall within our remit;
- Thorough investigation of your disclosure in as much as the information provided/available allows;
- Fully or partially withholding grant payments;
- Imposing sanctions in accordance with our programme rules; and
- Referring a matter to An Garda Síochána in appropriate circumstances.
You will be asked to provide as much detail as possible including the details of names and addresses of all persons and/or properties involved and specifics of the allegations of malpractice or impropriety.
SEAI will take steps appropriate to the circumstances to investigate any suspected improper conduct, for example, concerns about the quality of work carried out by a contractor will be investigated by the Inspections Unit. SEAI will provide appropriate training to staff to ensure disclosures are addressed in accordance with this policy.
Note: Where an SEAI employee raises a concern or discloses information regarding potential relevant wrongdoing within SEAI that has come to their attention through their work, they may refer to the SEAI Protected Disclosures (Whistle-blowing) Policy and associated Procedure for further guidance.
This Disclosures Policy does not apply to SEAI investigations of complaints or appeals. If you have a complaint or appeal, please refer to the SEAI Customer Charter for the SEAI Complaints and Appeals Policy.
Raising a concern
If you wish to raise a concern relevant to this Policy, please contact SEAI directly by:
- Writing to us at Disclosures, SEAI, 3 Park Place, Hatch Street Upper, Dublin 2;
- Calling us at 018082100 or
- Emailing us at firstname.lastname@example.org
In certain circumstances, if deemed appropriate by the individual, an individual may contact the Chief Executive Officer of SEAI to report any matters outlined above.
SEAI recognises that the decision to report a concern of suspected instances of malpractice or improper conduct may be difficult. All concerns raised will be treated confidentially, investigated thoroughly and managed fairly. SEAI will make all reasonable efforts to keep the identity of a disclosing individual confidential.
- To facilitate tracking, when a disclosure or concern is received, staff members are requested to forward such correspondence or send details of a concern raised with them to email@example.com.
- Details of the disclosure or concern are reviewed by the Information Compliance Officer and assigned to the appropriate team within SEAI for investigation in accordance with their normal procedures.
- The actions taken by SEAI will be appropriate to the circumstances, however, SEAI will endeavour to ensure that the following steps are followed and documented in a file in any investigation by SEAI:
- Establish credibility of the disclosure / concern;
- Identify specifically the conduct that is allegedly or actually contrary to law, SEAI’s rules or terms and conditions or any applicable code of practice or regulation or any other binding rules;
- If the disclosure / concern is credible and improper conduct is identified, seek a response on same from the third party in question; and
- SEAI will consider the third party’s response, if any, together with the file of information collated, and determine the appropriateness of imposing sanctions or penalties on the third party or reporting the matter to the appropriate enforcement agency.
SEAI disclosures log
Disclosures and concerns are tracked on the SEAI Register of Disclosures. Disclosures log will be maintained by the Information Compliance Officer.
SEAI Records relating to disclosures
The Information Compliance team will create a folder and provide access to the appropriate team within SEAI assigned to investigate the disclosure. The investigating team will keep a copy of all records relevant to their investigation in this folder.
Internal Access to SEAI Records relating to disclosures
Access to disclosure folder(s) will be managed by the Information Compliance Officer and shall only be provided upon receipt of a written access request from a member of SEAI’s Senior Management Team.
SEAI reserves the right to withdraw or amend this policy at any time.
 In circumstances of suspected criminal activity or where obliged by law or otherwise to do so, SEAI may forgo seeking a response from the third party in question and report the matter directly to An Garda Síochána and/or other Regulatory Bodies.