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Whistleblowing Policy

How We Deal With Reports of Wrongdoing

Whistleblowing Policy

The purpose of this policy statement is:

  • To 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.

  • To provide staff with guidance as to how to raise those concerns.

  • To reassure staff that they should be able to raise genuine concerns in good faith without fear of reprisals, even if they turn out to be mistaken.

  • Create a culture of openness and accountability is essential to prevent such situations occurring or to address them when they do occur.

NB. This policy does not form part of any employee's contract of employment, and it may be amended at any time

Who does this apply to:

This policy applies to all individuals working at all levels of the organisation, including senior managers, officers, directors, employees, consultants, contractors, trainees, homeworkers, part-time and fixed-term workers, casual and agency staff (collectively referred to as staff in this policy)

What does it cover:

Whistleblowing - the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include, but is not limited to:

  • criminal activity

  • miscarriages of justice

  • danger to health and safety

  • damage to the environment

  • failure to comply with any legal or professional obligation or regulatory requirements

  • bribery

  • financial fraud or mismanagement

  • negligence

  • breach of our internal policies and procedures

  • conduct likely to damage our reputation

  • unauthorised disclosure of confidential information

  • the deliberate concealment of any of the above matters

Protection and Support for Whistle-blowers:

  • This policy has been written to take account of the Public Interest Disclosure Act 1998 which protects workers making disclosures about certain matters of concern, when those disclosures are made in accordance with the Act’s provisions and in the public interest.

  • We aim to encourage openness and will support staff who raise genuine concerns in the public interest under this policy, even if they turn out to be mistaken. If you believe that you have suffered any detrimental treatment as a result of raising a concern you should inform Duncan Holmes immediately.

  • Anyone found to have subjected a whistle-blower to harassment or victimisation will be subject to disciplinary action.

  • You will be given full support throughout the process and your concerns will be taken seriously.

  • All concerns will be treated in confidence and every effort will be made not to reveal your identity if that is your wish. If disciplinary or other proceedings follow the investigation it may not be possible to take action as a result of your disclosure without your help, so you may be asked to come forward as a witness. If you agree to this, you will be offered advice and support.

  • We hope that staff will feel able to voice whistleblowing concerns openly under this policy.

  • Concerns expressed anonymously will be considered at the discretion of the organisation, taking into account the following considerations:

    •  the seriousness of the issue raised

    •  the credibility of the concern, and

    •  the likelihood of confirming the allegation from other sources



Raising Concern:

  • Concerns should be raised with your line manger and/or Duncan Holmes

  • If you have any genuine concerns related to suspected wrongdoing or danger affecting any of our activities (a whistleblowing concern) you should report it under this policy.

  • This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work. In those cases you should use the Grievance Procedure as set out in the Staff Handbook.

  • If you are uncertain whether something is within the scope of this policy you should seek advice from Duncan Holmes

What will Happen:

We will respond to your concerns as quickly as possible. Initial enquiries will be made to decide whether an investigation is appropriate, and if so, what form it should take. The investigation may need to be carried out under terms of strict confidentiality, i.e. by not informing the subject of the complaint until (or if) it becomes necessary to do so. However, protection of others is paramount in all cases.

Where appropriate, the concerns raised may be:

  •  investigated by management or through the grievance/ disciplinary process

  •  referred to the police

  • subject to an independent investigation

  • Within ten working days of a concern being raised, the person investigating your concern will write to you

    • acknowledging that the concern has been raised

    • indicating how the organisation proposes to deal with the matter

    • providing signposting to the Employee Assistance Programme

    • telling you whether further investigations will take place and if not, why not.

An interview may be arranged to ensure that your disclosure is fully understood. You will be able to bring a friend or union representative to any interviews or meetings held in connection with the concerns you have raised.

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 and hold any information about the investigation as confidential.

External Discourses

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. However, the law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body.

We strongly encourage you to seek advice before reporting a concern externally. The independent whistleblowing charity, Protect, operates a free confidential helpline( Tel: 020 3117 2520.)

The Government list of prescribed regulators for reporting certain types of concern is available at Blowing the whistle to a prescribed person: list of prescribed persons and bodies (

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