Whistleblowing is where a worker reports a wrongdoing in the public interest to their employer or a relevant organisation. This is commonly referred to as ‘blowing the whistle.’
Whistleblowing policy and procedure
Last updated: April 2021
- Why do we need this policy?
- Who needs to follow the policy and procedure outlined in this document and why?
- What’s our policy and how will we implement it?
- Data protection, equality and diversity
Why do we need this policy?
We are committed to high standards of integrity, honesty and professionalism in all that we do. We all have a right and responsibility to speak up if there are any concerns or if we notice any behaviour that contravenes our values.
Who needs to follow the policy and procedure outlined in this document and why?
All board members, employees and partners.
What’s our policy and how will we implement it?
You do not need to wait for proof when reporting wrongdoing: you only need to have a reasonable concern. It is not for you to investigate or prove that your concerns are justified, that is our responsibility.
Whistleblowing is the term used when an employee passes on information concerning wrongdoing. It can be referred to as ‘making a disclosure’ or ‘blowing the whistle.’
You should ‘blow the whistle’ if you have a concern, that you reasonably believe is of public interest, about the conduct of others in the organisation or the way in which the organisation is run.
You’re protected by law if you reasonably believe that the disclosure tends to show past, present or likely future wrongdoing falling into one or more of the following categories:
- A criminal offence, for example fraud
- Someone’s health and safety is in danger
- Risk or actual damage to the environment
- A miscarriage of justice
- A breach of a legal obligation
- You believe someone is covering up wrongdoing
If you ‘blow the whistle’ or raise a concern, you will not be treated unfairly or lose your job.
This policy and procedure sets out how to raise a concern and the process this will follow.
Raising a concern
To raise a concern around perceived wrongdoing, that you reasonably believe is of public interest, in the first instance you should raise a concern with your manager.
If you feel that you cannot speak to your manager, talk to another manager or discuss your concern with an executive director.
If you do not feel that you can raise your concern with anyone up to and including executive director or you feel the response is inadequate, you can escalate your concern to the CEO. If you are unable to do this or have an inadequate response then you should discuss your concern with the chair of the board or the chair of the audit and risk assurance committee.
If you do not wish to raise your concern with anyone in the business, or your response from the business has been inadequate, you can contact the head of sponsor team in the Department for Education ([email protected]). If you cannot do this or need to escalate your concern this should be addressed with the senior sponsor in the Department of Education ([email protected]).
Anonymous whistleblowing process
We encourage you to raise your concern in your own name wherever possible. It is easier for us to investigate, and we can keep you updated on the issues or concerns you have raised.
If you need to, you can still raise a concern anonymously. This is better than saying nothing about a serious wrongdoing. If you want to raise your concern anonymously and do not want other people to know about it, we will respect this as far as possible, and restrict information to a ‘need to know’ basis. In such cases, we will inform you about the proposed use of your personal information and discuss potential safeguards that may be taken to protect you from identification.
However, it is important to note that there may be occasions when we are unable to resolve a concern without revealing a whistleblower’s identity.
In instances where the whistle-blower does not provide their contact details, we are unable to enter into any communication with them. Additionally, anonymous reporting may also create challenges relating to an investigation as the organisation or investigator are unable to contact them to obtain further information or clarifications.
Once a concern has been raised, the person receiving the complaint will investigate the matter themselves or immediately pass the issue to someone in a more appropriate position.
A meeting with the whistleblower (who may be accompanied by a colleague who is not involved in the area of work to which the concern relates) will be arranged to gather all the information needed to understand the situation.
In some situations, the matter may be concluded informally with satisfactory explanations. It is important to note that if the matter is concluded in this way and the disclosure was found to be untrue, it does not automatically mean that it was raised maliciously.
If necessary, a formal investigation will be carried out. If there are any other individuals involved they will be invited to an investigation meeting to discuss the matter and to gather facts.
Once all relevant information has been gathered, the line manager or person who carried out the investigation, will then prepare a written report for the CEO, or if the CEO has investigated then this will be given to the chair of the board.
All the information will be reviewed and decision made regarding outcomes, including reporting the matter to any appropriate government department or regulatory agency.
On conclusion of any investigation, the outcome will be shared with the whistleblower together with confirmation of what has been done or is proposed to be done about it. If no action is to be taken, the reason for this will be explained.
If disciplinary action is required, the line manager (or the person who carried out the investigation) will refer the matter to the HR department who will make arrangements to start the disciplinary procedure ensuring that the person carrying out the disciplinary has not been involved in the matter and is ideally a manager of a higher level than the line manager.
If the whistleblower is concerned that either the person investigating their disclosure is involved in the wrongdoing, has failed to make a proper investigation or has failed to report the outcome of the investigations, they should inform the head of people and development, who will arrange for another manager to review the investigation carried out, make any necessary enquiries and make their own report as above.
The HR team will document any decisions or action taken after a concern has been raised. They will record the date and number of whistleblowing disclosures that are received, their nature and the action taken, if any, along with content of the feedback provided to the whistleblower.
You can also contact Protect for free advice and guidance via their website at www.protect-advice.org.uk
If this policy isn’t followed, the most appropriate course of action will be agreed by the head of people and development and executive director – people and business support, dependent on the circumstances.
Data protection, equality and diversity
A data protection impact assessment (DPIA) and equality impact assessment (EIA) have been completed for this policy.
If you have a query about this document, please contact Jane Marr, Head of People and Development.
Last reviewed: April 2021
Next review date: April 2022
Policy owner: Tracy Watterson, Assistant Director – People and Business Support
Policy reference: POL_HR21
If you require a PDF version of this policy, please contact us.