Whistle blowing policy

Whistle blowing policy

We’re committed to the highest possible standards of openness, probity and accountability, and constantly strive to safeguard and act in the interest of the public and our colleagues. It’s important to us that any fraud, misconduct or wrongdoing, by colleagues or other agents, is reported and properly addressed. We encourage any colleagues or third parties we work with who have concerns about any aspect of our work to come forward. This policy makes it clear that individuals can act without fear of reprisals.

Colleague responsibilities

As part of their employment, all of our colleagues are required to complete a Whistleblowing module assigned to them on our Learning Management System (LMS).

They’re also encouraged to bring to our attention any practice or action that they reasonably believe is a:

  • criminal offence
  • failure to comply with any legal obligation
  • miscarriage of justice
  • danger to the health and safety of any individual.

They’re also encouraged to flag any suspected attempts to conceal information on the above.

Any individual raising legitimate concerns won’t be subject to any detriment, either during or after employment.  We’ll ensure the individual is protected from any intimidation or harassment by other parties.

Investigation and resolution

Some concerns may be resolved by agreed action without the need for investigation or further information.

Within ten working days of a concern being received, we’ll write to the individual who raised the concern:

  • acknowledging that the concern has been received
  • indicating how we propose to deal with the matter
  • giving an estimated timeframe for a final response
  • advising whether any initial enquiries have been made, whether further investigations will take place, and if not, why not.
Escalating concerns

If, after escalating any concerns internally to our Head of HR and/or CEO, it’s felt the appropriate remedial action hasn’t been taken, concerns should be reported to the relevant authority, such as:

  • HM Revenue & Customs
  • The Health and Safety Executive
  • The Environment Agency or Scottish Environmental Protection Agency
  • The Information Commissioner

This list isn’t exhaustive. Advice on the most appropriate authority can be sought from Public Concern at Work which is an independent Whistleblowing Charity.

Individuals shouldn’t disclose to a non-relevant third party any details of any concern raised in accordance with this process, and mustn’t, in any circumstances, publicise concerns in any way.


We’ll look to protect the identity of anyone who raises a concern and doesn’t want their name to be disclosed. However, it must be appreciated that the investigation process may reveal the source of the information and a statement may be required as part of the evidence.

Anonymous Allegations

You will be encouraged to put your name to your allegation. Concerns expressed anonymously are much less powerful, but they will be considered at our discretion.

Untrue allegations

If an individual makes an allegation in good faith, but it isn’t confirmed by the investigation, no action will be taken against them. If, however, they make allegations that are malicious or simply to cause anger, irritation or distress, remedial action may be taken.

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