Whistleblowing Policy
Introduction
We operate a confidential reporting procedure. It is available to everyone irrespective of employment status, length of service or position.
Our procedure provides access to a safe and effective means of reporting matters of genuine concern. This may relate to something inappropriate in the way our organisation operates or the behaviour of another employee. Concerns may involve perceived misconduct or other wrongdoing.
This procedure is not intended for personal matters relating to your own employment. Such issues must be dealt with through our grievance procedure.
We acknowledge that it is never easy to report a concern, especially when serious misconduct or unlawful acts are observed. However, we urge you to raise matters at the earliest opportunity. This allows us to respond speedily and effectively before problems worsen. As far as we are able, we will deal with reports promptly and confidentially. To ensure this, it is important you follow our procedure.
Guiding Principles
We must all be watchful for unlawful or unethical conduct at work. Preventing and eliminating workplace wrongdoing is important, and we all have a duty to report inappropriate behaviour or activity.
We will consider matters raised under this procedure confidentially and will investigate them promptly and thoroughly. We will always deal with your concerns appropriately, consistently, fairly and professionally.
Where we need to meet with you to discuss matters, we recognise that these conversations can be stressful. You may therefore be supported by a work colleague or trade union representative during such discussions.
We will seek to protect your identity unless required by law to reveal it. We will offer appropriate support throughout the process.
You may report concerns anonymously. However, this may prevent us from informing you of the outcome and may affect our ability to provide whistle-blower protections.
You will not be victimised or penalised for raising a reasonable belief under this procedure, even if the concern later proves unfounded.
You cannot be instructed to cover up wrongdoing or told not to report genuine concerns. Any attempt to do so is itself a serious disciplinary offence.
If anyone intimidates, bullies, harasses or victimises you for reporting something through this procedure, you must inform us. Such behaviour is a serious disciplinary offence.
Misconduct or wrongdoing uncovered during an investigation under this procedure will be treated as a disciplinary matter and may also be reported externally to a statutory agency.
Our Procedure
Initially, you should report concerns to your line manager. If unsure whether to raise the matter, you may discuss it confidentially with them. If you believe your manager may be involved, contact a more senior Manager or Director.
Your line manager will either investigate the allegation personally or refer it to someone more appropriate. You will be advised if the matter is referred elsewhere.
Where possible, we will provide an indication of expected steps and timescales. On conclusion of the investigation, we will advise you of the outcome, what action will be taken, or why no action is planned.
If you do not receive an acknowledgement of your concerns within seven days, please contact a more senior Manager/Director. This also applies if you believe an investigation has been insufficient.
Should you believe your concerns have not been considered at a sufficiently senior level, contact a more senior Manager/Director. It is important that you have complete confidence in this procedure.
Public Interest Disclosures
The law provides special protections for workers who make “public interest disclosures”, also known as whistleblowing. These are qualifying disclosures made under current public interest disclosure legislation. They apply only where you reasonably believe the matter concerns:
- A criminal offence
- A miscarriage of justice
- An act creating risk to health and safety
- An act causing damage to the environment
- A breach of any other legal obligation we may have
- Our concealment of any of the above
You are not expected to provide proof of wrongdoing, but you must reasonably believe that wrongdoing is occurring, has occurred or is likely to occur. Provided you follow the above procedure, we will investigate urgently. We do not expect you to undertake investigative work yourself.
Our investigation may not fully satisfy all concerns. In cases involving protected disclosures, you may be able to refer the matter to a statutory agency. These include HM Revenue and Customs, The Serious Fraud Office, The Office of Fair Trading, The Health and Safety Executive and The Environment Agency.
Making Malicious Allegations
This procedure is intended to enable the reporting of genuine concerns. We focus on the substance of a disclosure, not your motives for raising it. We encourage you to come forward even where issues later prove unfounded, provided your belief was reasonable.
However, if you deliberately make or support false or malicious allegations—for example, those made out of spite or for personal gain—this will be a disciplinary matter. Following investigation, such conduct may amount to serious or gross misconduct and could result in summary dismissal.
Approaching External Organisations
You must not approach a commercial organisation such as a media outlet instead of following this procedure. You must also refrain from publishing or promoting your concerns on social media, networking sites or blogs. Doing so jeopardises our ability to investigate properly and undermines our promise of confidentiality.
Failure to follow this procedure may also limit the protections available to you.
If exceptional circumstances prevent you from utilising this procedure to make a public interest disclosure, you should contact the appropriate statutory agency.
Deliberate violations or breaches of this procedure may constitute serious misconduct. Following investigation, gross misconduct may result in summary dismissal.