Whistle Blowing - Policy

1.    POLICY STATEMENT

     1.1   We are committed to conducting our business with honesty and integrity, and we expect all staff to maintain high                                   standards. However, all organisations face the risk of things going wrong from time to time, or of unknowingly harbouring                   illegal or unethical conduct. A culture of openness and accountability is essential in order to prevent such situations                             occurring or to address them when they do occur.
     1.2   The aims of this policy are to:
          a)    encourage staff to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken                        seriously and investigated as appropriate, and that their confidentiality will be respected,
          b)    provide staff with guidance as to how to raise those concerns, and
          c)    reassure staff that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be                           mistaken.
     1.3   This policy does not form part of any employee’s contract of employment and it may be amended at any time. We may also                 vary elements, such as any time limits, as appropriate in any case.

 

2.    WHO IS COVERED BY THIS POLICY?

     2.1    This policy applies to all employees, directors and other officers, workers and agency workers, volunteers and interns
     2.2    We also require in any contracts with self-employed consultants or contractors that they comply with this policy. We will                        ensure they are given access to a copy.
     2.3    All individuals covered in sections 2.1 and 2.2 are referred to as ‘staff’ in this policy.

 

3.    WHO IS RESPONSIBLE FOR THIS POLICY?

     3.1    While we ask all managers to take responsibility for making sure this policy is complied with, its successful operation also                    depends on you. Please take the time to read and understand it and to go back to your manager with any questions you                      may have. References to Directors in this policy mean the most senior people within our organisation. The Directors have                    overall responsibility for reviewing the effectiveness of actions taken in response to concerns raised under this policy.

 
4.    WHAT IS WHISTLEBLOWING?

     4.1    Whistleblowing is the disclosure of information that relates to suspected wrongdoing or dangers at work. This may include:
             a)    criminal activity,
             b)    miscarriages of justice,
             c)    danger to health and safety,
             d)    damage to the environment,
             e)    failure to comply with any legal or professional obligation or regulatory requirements,
             f)    bribery,
             g)    facilitating tax evasion,
             h)    financial fraud or mismanagement,
             i)    negligence,
             j)    unauthorised disclosure or use of confidential information, or
             k)    the deliberate concealment of any of the above matters.
     4.2    A whistleblower is a person who raises a genuine concern relating to any of the above. If you have any genuine concerns                    related to suspected wrongdoing or danger affecting any of our activities that you think could be a matter of public                              interest (a whistleblowing concern) you should report it under this policy.
     4.3    This policy should not be used for complaints relating to your own personal circumstances that are unlikely to be in the                       public interest, such as the way you have been treated at work. In those cases, you should use the Grievance Procedure or                 Anti-harassment and Bullying Policy as appropriate.

 

5.    RAISING A WHISTLEBLOWING CONCERN

       5.1    We hope that in many cases you will be able to raise any concerns with your manager. You may tell them in person or put                  the matter in writing if you prefer. They may be able to agree a way of resolving your concern quickly and effectively. In                        some cases they may refer the matter to a Director or external adviser.
       5.2    However, where the matter is more serious, or you feel that your manager has not addressed your concern, or you prefer                  not to raise it with them for any reason, you should contact a Director.

       5.3    We will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague or union                             representative to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and                   any subsequent investigation.
       5.4    We will take down a written summary of your concern and provide you with a copy after the meeting. We will also aim to                      give you an indication of how we propose to deal with the matter.

 

6.    CONFIDENTIALITY

     6.1    We hope that staff will feel able to voice whistleblowing concerns openly under this policy. However, if you want to raise                       your concern confidentially, we will make every effort to keep your identity secret. If it is necessary for anyone investigating                 your concern to know your identity, we will discuss this with you.
     6.2    We do not encourage staff to make disclosures anonymously. Proper investigation may be more difficult or impossible if                     we cannot obtain further information from you. It is also more difficult to establish whether any allegations are credible.                     Whistleblowers who are concerned about possible reprisals if their identity is revealed should come forward to a Director                    and appropriate measures can then be taken to preserve confidentiality. If you are in any doubt, you can seek advice from                  Protect, the independent whistleblowing charity, who offer a confidential helpline. Their contact details can be found at                       the end of this policy.

 

7.    EXTERNAL DISCLOSURES

      7.1    The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in                       the workplace. In most cases you should not find it necessary to alert anyone externally.
      7.2    The law recognises that in some circumstances it may be appropriate for you to report your concern to an external body                      such as a regulator. It will very rarely, if ever, be appropriate to alert the media. We strongly encourage you to seek advice                    before reporting a concern to anyone external. The independent whistleblowing charity, Protect, operates a confidential                      helpline. They also have a list of prescribed regulators for reporting certain types of concern. Their contact details are at                      the end of this policy.
      7.3    Whistleblowing concerns usually relate to the conduct of our staff, but they may sometimes relate to the actions of a third                  party, such as a customer, supplier or service provider. In some circumstances, the law will protect you if you raise the                          matter with the third party directly. However, we encourage you to report such concerns internally first. You should                              contact  your manager for guidance.

 

8.    INVESTIGATION AND OUTCOME

      8.1    Once you have raised a concern, we will carry out an initial assessment to determine the scope of any investigation. We                        will inform you of the outcome of our assessment. You may be required to attend additional meetings in order to provide                    further information.
      8.2    In some cases, we may appoint an investigator, such as a staff member with relevant experience of investigations or                              specialist knowledge of the subject matter. The investigator may make recommendations for change to enable us to                            minimise the risk of future wrongdoing.
      8.3    We will aim to keep you informed of the progress of the investigation and its likely timescale. However, sometimes the                         need for confidentiality may prevent us giving you specific details of the investigation or any disciplinary action taken as a                   result. You should treat any information about the investigation as confidential.
      8.4    If we conclude that a whistleblower has made false allegations maliciously or with a view to personal gain, the                                        whistleblower may be subject to disciplinary action.

 

9.    IF YOU ARE NOT SATISFIED

      9.1    While we cannot always guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an                            appropriate way. By using this policy, you can help us to achieve this.
      9.2    If you are not happy with the way in which your concern has been handled, you can raise it with a Director. Alternatively,                      you may contact the independent
 
               whistleblowing charity, Protect, for further advice. Contact details are set out at the end of this policy.

 

10.    PROTECTION AND SUPPORT FOR WHISTLEBLOWERS

     10.1    It is understandable that whistleblowers are sometimes worried about possible repercussions. We aim to encourage                             openness and will support staff who raise genuine concerns under this policy, even if they turn out to be mistaken.
     10.2    Staff must not suffer any detrimental treatment as a result of raising a genuine concern. Detrimental treatment includes                     dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that

                 you have suffered any such treatment, you should inform your manager immediately. If the matter is not resolved you                         should raise it formally using our Grievance Procedure.
     10.3    Staff must not threaten or retaliate against whistleblowers in any way. Anyone involved in such conduct may be subject to                   disciplinary action.

 

11.    MONITORING AND REVIEW OF THIS POLICY

     11.1    We will continue to review the effectiveness of this policy to ensure it is achieving its stated objectives.