The aims of this policy are:
1) 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.
2) To provide staff with guidance as to how to raise those concerns.
3) To reassure staff that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.
This policy covers all employees, officers, consultants, contractors, volunteers, casual workers, and agency workers.
This policy does not form part of any employee's contract of employment, and we may amend it at any time.

What is whistleblowing?
Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. Some
examples of whistleblowing include the exposure of actual or suspected:
1) Criminal activity.
2) Fraud or corruption, for example offering or accepting a bribe.
3) Wilful deception or dishonesty in relation to the delivery of customer services.
4) Breaches of legislation, for example, the Data Protection Act.
5) Abuse of authority (or the Company’s authority) for personal gain or in breach of the Company’s policies and procedures.
6) Health and safety issues, including food hygiene, that put the safety of employees, customers, students, tenants, or visitors at risk.
7) Physical, sexual, or emotional abuse of a colleague, tenant, student or customer (please note that if you personally are the victim of abuse, you should raise the matter immediately using the Company’s grievance procedure).

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 (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 or Bullying and Harassment Policy as appropriate.

If you are uncertain whether something is within the scope of this policy you should seek advice from your line manager or the Human Resources department, whose contact details are at the end of this policy. 

Raising a whistleblowing concern
If you are concerned or wish to complain about a matter which affects you directly and personally, you should use the Company’s grievance procedure rather than the whistle-blowing procedure. In some cases, there may be an overlap between a whistle-blowing concern and a grievance, for example, a health and safety matter where the risk also affects you. Please note however that the whistle-blowing procedure cannot be used to raise a grievance relating to a personal matter which has already been investigated and dealt with under the Company’s grievance procedure.

Normally, as a first step, you should raise your concern with your immediate line manager as soon as you become aware or suspect that something untoward is occurring. However, depending on the potential seriousness of the issue(s) concerned and who is involved it may be appropriate for you to make your disclosure
directly to a Director.

You may raise your concerns either verbally or in writing. You have the right to submit an anonymous concern however we would encourage you to be open about your identity as this makes it much easier to verify the matter and to investigate it.

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. 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.

Confidentiality
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.

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 the Human Resources department (or one of the other contact points at the end of this policy) and appropriate measures can then be taken to preserve confidentiality. If you are in any doubt, you can seek advice from our Employee Assistance Programme (confidential helpline and online resource) or Protect, the independent whistleblowing charity, which offers a confidential helpline - details are at the end of this policy.

Investigation and outcome
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 to provide further information.

The Company will take any disclosure seriously and will investigate the matter thoroughly and objectively before making a final assessment. If we receive an unsupported, anonymous disclosure it may be treated with caution but will be pursued further, at the discretion of the Company, if we believe that there may be some substance to the allegations.

In some cases, we may appoint an investigator or team of investigators including staff with relevant experience of investigations or specialist knowledge of the subject matter. The investigator(s) may make recommendations for change to enable us to minimise the risk of future wrongdoing.

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 from 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.
If we conclude that a whistleblower has made false allegations maliciously, the whistleblower will be subject to disciplinary action.

If you are not satisfied
If you are not satisfied with the outcome of the Company’s investigation you have the right to raise the matter with the appropriate external body or agency, for example, the Police, the Environment Agency or the Health & Safety Executive.

External disclosures
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.

The law recognises that in some circumstances it may be appropriate for you to report your concerns 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.

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 a third party directly. However, we encourage you to report such concerns internally first through your line manager or one of the other individuals set out at the end of this policy.

Protection and support for Whistleblowers
We recognise that it takes great courage and determination to make a disclosure of this nature and the Company is wholly committed to offering long-term and ongoing support to whistleblowers who act in good faith. However, if you fail to report your suspicions you may become implicated in wrongdoing, which will be regarded as a serious matter. We do expect, therefore that if you have a serious concern(s), you will come forward and voice that concern as soon as possible.

If you have a genuine belief in the authenticity of the information being disclosed and you are acting in good faith rather than for personal gain, you will be fully protected, both in law and by the Company’s whistle-blowing policy even if it is later found that you were mistaken. Please note however that this protection does not apply to someone who maliciously raises a concern that they know is untrue. Malicious allegations of this nature will be regarded as a serious disciplinary matter.

If you believe that you are suffering from any form of retribution (including harassment, intimidation, and victimisation) or if you are being treated less favourably in any way as a result of having raised your concerns you should speak with the Human Resources department or a Director straightaway. You also have the right to raise a grievance.