Raising Concerns Without Fear of Detriment
- Whistleblowing Policy
1. Purpose
Spring Together CIC is committed to the highest standards of openness, probity, and accountability. This policy is intended to give staff, volunteers, contractors, and directors the confidence to raise genuine concerns about wrongdoing, malpractice, or ethical breaches without fear of detriment.
2. Scope
This policy applies to all directors, staff, volunteers, and contractors of Spring Together CIC.
3. Legal Framework
This policy is underpinned by the Public Interest Disclosure Act 1998, which provides legal protection to workers who make qualifying disclosures in the public interest.
4. What to Report
A whistleblowing concern may relate to:
- Financial fraud, misappropriation of funds, or accounting irregularities
- Bribery or corruption
- Safeguarding failures or risks to children or vulnerable adults
- Breaches of legal obligations
- Risks to health and safety
- Environmental damage
- A cover-up of any of the above
This policy is not intended to replace or bypass Spring Together CIC's Complaints Policy, which covers personal grievances.
5. How to Raise a Concern
Concerns should be raised in the first instance with a director of Spring Together CIC. Where the concern involves a director, it should be raised with another director or, where appropriate, with the CIC Regulator or an external body. Concerns may be raised verbally or in writing. Written reports are encouraged as they help ensure the concern is clearly understood.
6. Confidentiality
Spring Together CIC will treat all whistleblowing concerns in confidence. The identity of the reporter will not be disclosed without their consent, unless required by law. Anonymous reports will be considered but may be more difficult to investigate.
7. Protection from Detriment
Spring Together CIC will not subject any individual to dismissal, disciplinary action, demotion, harassment, or any other detriment as a result of raising a genuine whistleblowing concern. Any individual who believes they have suffered detriment for whistleblowing should raise this as a matter of urgency with a director or an external body.
8. Investigation
All whistleblowing concerns will be taken seriously and investigated promptly and fairly. The individual raising the concern will be kept informed of the outcome where lawfully possible.
9. Malicious Reports
This policy protects individuals who raise concerns in good faith. Where a report is found to have been made maliciously or in bad faith, disciplinary action may be taken against the reporter.
10. External Reporting
Where internal reporting has not resolved the concern, or where the concern relates to the Board itself, the following external bodies may be contacted:
- The CIC Regulator
- The Information Commissioner's Office (ICO) for data protection concerns
- The police — where criminal activity is suspected
- The Health and Safety Executive (HSE) for health and safety concerns
11. Review
This policy will be reviewed annually by the Board of Directors.