How to use this template
Some parts of this template are intended to be changed and updated by you to align with your business. However, we’ve aimed to make this as easy as possible for you to use. Here’s how to get started:
Disclaimer: This template is made with the purpose to be used as a starting point for a policy intended for your business. It should be edited, and personalised to suit the needs of your business. We do not recommend that you implement any of these policies without seeking legal advice.
Last reviewed: [Date of last review/publication]
[Your Company] strives to create an open and transparent workplace culture where concerns can be raised with management, and where staff who raise concerns are supported and treated fairly.
This policy aims to enable and encourage staff to raise concerns within [Your Company]. It recognises a worker’s legal rights to make a protected disclosure to certain prescribed persons or bodies under the Public Interest Disclosure Act 1998 and any subsequent legislation, as incorporated into the Employment Rights Act 1996.
1.1. [Your Company] is committed to creating a safe, open and transparent workplace culture, where employees are encouraged to raise concerns at the earliest opportunity. [Your Company] recognises that employees are often the first to realise that there may be something seriously wrong within an organisation.
1.2. It is important to [Your Company] that any fraud, misconduct or wrongdoing by workers or officers of the organisation is reported and properly dealt with. [Your Company] is committed to tackle malpractice and wrongdoing. Everyone should be aware of the importance of preventing and eliminating wrongdoing at work. If any cases of wrongdoing are upheld they will be seriously dealt with.
1.3. [Your Company] encourages staff to use internal mechanisms for reporting malpractice or illegal acts or omissions by employees or ex-employees. Employees will be listened to and serious concerns will be investigated.
1.4. [Your Company] will provide regular refresher training to all managers enabling them to deal with concerns that are raised and is committed to treating all disclosures consistently and fairly.
1.5. [Your Company] will ensure that all new employees, supervisors and managers will receive induction on the policy and will provide refresher training to all members of staff so that they are aware of whistleblowing law and know how to use this policy.
1.6. Adequate resources will be made available to fulfil the aims of this policy. The policy will be widely promoted on [where the policy will be available, e.g. your intranet], and an introduction to this policy (and others), will be covered in the first week of onboarding new team members.
1.7. This policy allows staff to take the matter further if they are dissatisfied with the management response and aims to reassure staff that they will be protected from harassment or victimisation from co-workers or from [Your Company] for raising concerns.
2.1. This policy applies to all staff including temporary, casual and agency staff, work experience, trainees and apprentices. Other individuals who work or have worked within the organisation, such as former staff, volunteers, the self-employed and contractors, are also encouraged to use it.
2.2. For the purpose of this policy, [Your Company] recognises that whistleblowing is the passing on of information about wrongdoing at work. The whistleblower must reasonably believe that they are acting in the public interest.
2.3. The statutory categories for wrongdoing are:
2.4. Examples of wrongdoing might include (but are not restricted to) :
2.5. It is not necessary for the member of staff to have proof that wrongdoing is being, has been, or is likely to be committed. A reasonable belief is sufficient to disclose the concern. The member of staff has no responsibility for investigating the wrongdoing. It is the organisation's responsibility to ensure that an investigation takes place.
2.6. A member of staff who makes such a protected disclosure has the right not to be dismissed, subjected to any other detriment, or victimised, because they have made a disclosure.
2.7. [Your Company] recognises that any so-called ‘gagging’ or confidentiality clauses in settlement agreements or non-disclosure agreements with individuals do not prevent members of staff from making disclosures in the public interest and are void in such circumstances.
2.8. If the wrongdoing that the staff member wants to disclose is not included in the list above, advice may be sought from the designated officers (see section 4 below) or from a trade union representative on the use of the appropriate policy.
3.1 The senior management team is responsible and accountable for this Whistleblowing Policy and Procedure. They will:
3.2. All staff have a duty to report wrongdoing (whistleblow) under the circumstances set out in section 2 of this policy.
3.3. Line managers are responsible for:
3.4. Designated officer (see below) has lead responsibility for the whistleblowing procedure and for dealing with issues raised. They will:
3a. The following person has been nominated and agreed by [Your Company] as the designated officer for concerns under this procedure: [Full name of your agreed Designated Officer].
In [Full name of your agreed Designated Officer]’s absence, [Full name of a secondary Designated Officer] will take over as designated officer.
3b. These designated officers will act as an independent and impartial source of advice to staff at any stage of raising a concern, and are accessible to anyone in the organisation.
3c. These people have been given special responsibility and training in dealing with whistleblowing concerns and will give you information about where you can go for more support. They will:
4.1. In many circumstances, the easiest way a member of staff can get their concern resolved will be to raise it formally or informally with their line manager who should report it to the designated officer.
4.2. If this is not appropriate as the concern relates to the line manager, or if the member of staff does not feel able to raise it with them or if raising it with their line manager does not resolve matters, the member of staff can approach a designated officer directly. The designated officer will then confirm how the matter will be investigated.
4.3. Any member of staff who wants to raise a concern that is potentially of public interest, is encouraged to get legal advice where appropriate such as through their trade union or through the charity Protect (see section 9.’More information and support’ below).
4.4. If, for any reason, the member of staff does not feel comfortable raising their concern internally, they can raise concerns externally with ‘prescribed bodies’ (see section 8 below) if they feel this is necessary and in the public interest.
4.5. Concerns should be raised in writing (including email). The letter should set out the background and history of the concerns, giving names, dates and places where possible, and the reason why the member of staff is making the disclosure. If the individual does not feel able to make the disclosure in writing, an interview will be arranged.
4.6. When any meetings are arranged with an individual who is making or has made a protected disclosure, they have a right to be accompanied by a trade union representative. The meeting can be off site if requested.
4.7. The employee raising concerns does not have to prove the allegation but they must demonstrate that there are sufficient grounds for concern.
4.8. If the member of staff wants to raise the matter in confidence, they should please say at the outset so that appropriate arrangements can be made.
4.9. Confidentiality will be maintained as far as is possible. It is guaranteed at the point of making a protected disclosure and will be maintained throughout the investigation and hearings, other than when a disclosure of identity is needed due to cross examination of the staff member as a witness to any subsequent procedure, or is required by law.
4.10. It is best to raise a concern openly, because that makes it easier for [Your Company] to follow it up. [Your Company] ****will not disclose the whistleblower’s identity without their consent unless there are legal reasons that require them to do so. This might be, for example, where their information is about a child or vulnerable adult who is at risk, or where there is a possible criminal offence. If this is the case, [Your Company] may have to tell the police or another official body, or if required to do so by a court. [Your Company] will let the individual know if it has to do this and that this will identify them to another body.
4.11. Staff may, if they wish, disclose information anonymously. However, it should be noted that in such circumstances, [Your Company] will not be able to contact staff to discuss their concern or ask them for further information, nor will they normally be able to give any feedback about any action it takes, although anonymous whistleblowers may seek feedback through a telephone appointment or by using an anonymised email address.
5.1. Any concern raised under this policy will be investigated thoroughly, promptly and confidentially.
5.2. Any approach to line managers and designated officers will be treated with the strictest confidence and the member of staff’s identity will not be disclosed without their prior consent. All members of staff will be treated with respect at all times and the person raising the concern will be thanked.
5.3. There may be a meeting with the member of staff raising the concern to ensure [Your Company] understands exactly the particular worry.
5.4. When any meetings are arranged with an employee who has made a protected disclosure, they have a right to be accompanied by a trade union representative. The meeting can be off site if requested.
5.5. When an individual makes a disclosure, the organisation will process any personal data collected as part of the investigation in line with [Your Company] data protection policy which can also be found on the staff Notion page ensuring the data is stored securely and only accessed by those individuals essential for dealing with the disclosure.
5.6. Within five working days of a concern being raised, the line manager or designated officer who received the disclosure will write to the member of staff setting out the following:
5.7. The member of staff who raises the concern will be told how long to expect the investigation to take and will be kept up to date with its progress.
5.8. The matters raised may be investigated internally. Where it has not been possible to resolve the matter quickly (usually within a few days) with the line manager, someone suitably independent (such as a designated officer) and properly trained will carry out an investigation.
5.9. The investigation will be objective and evidence-based, and will produce a report that focuses on identifying and rectifying any issues, and learning lessons to prevent problems recurring. The investigator may decide that the concern would be better looked at under another process, such as the grievance procedure or dignity at work procedure. If so, this will be discussed with the member of staff.
5.10. In the event that misconduct is discovered as a result of any investigation under this policy, the disciplinary policy and procedure will be invoked in addition to any external measures.
5.11. At the conclusion of any investigation, the member of staff will be told the outcome of the investigation and what [Your Company] has done, or proposes to do, about it. Wherever possible, [Your Company] will share the full investigation report with the member of staff who raised the concern (while respecting the confidentiality of others). If no action is to be taken, the reason for this will be explained.
5.12. If an individual is not satisfied with the response received and any subsequent action taken, they should put their concerns in writing to [Full name of board Chairman] who will arrange any further investigation as [he/she/they] thinks appropriate. [Full name of board Chairman] will send a written response to the individual concerned.
5.13. More serious disclosures may be referred to an external prescribed person or body and may form the subject of an independent inquiry.
5.14. In the event of an inquiry, where possible the trade union representatives will be consulted on the drawing up of terms of reference for any inquiry panel, as well as being involved in the implementation of any inquiry recommendations.
6.1. [Your Company] ****understands that raising a concern can be difficult for staff, especially if they fear reprisal from those responsible for the malpractice. [Your Company] will not tolerate harassment and victimisation of anyone raising a concern, and there should be no impact on the continued employment and opportunities for future promotion or training of anyone raising a concern. Any such behaviour is a serious breach of our values as an organisation and, if upheld following investigation, could result in disciplinary action potentially leading to dismissal.
6.2. Nor will [Your Company] tolerate any attempt to bully anyone into not raising any such concern. Any such behaviour is a breach of our values as an organisation and, if upheld following investigation, could result in disciplinary action potentially leading to dismissal.
6.3. This policy encourages members of staff to put their name to their concerns. Concerns expressed anonymously are harder to follow up and have an effective outcome.
6.4. If a member of staff makes an allegation in good faith, but the allegation is not confirmed by the investigation, no action will be taken against that member of staff. They will not be at risk of losing their job or suffering any form of reprisal as a result. Provided the member of staff is acting honestly, it does not matter if they are mistaken or if there is an innocent explanation for their concerns.
This policy is intended to provide a route by which members of staff can raise concerns internally. However, if an employee is unhappy with the outcome of an investigation or if, for any reason they do not feel comfortable raising their concern internally, they are free to take the matter outside of the organisation to a prescribed person or body or to their Member of Parliament (MP).
7.1. The full list of prescribed persons and bodies can be found on the UK government website at: www.gov.uk/government/publications/blowing-the-whistle-list-of-prescribed-people-and-bodies--2/whistleblowing-list-of-prescribed-people-and-bodies
They include:
9.1. Protect is the UK’s whistleblowing charity that aims to stop harm by encouraging safe whistleblowing. They provide a legal advice service offering free expert and confidential advice on how best to raise a concern and protection as whistleblower.
Protect Advice Line: whistle@protect-advice.org.uk
Protect Advice Line: 020 3117 2520 (* option 1)
9.2. UK government advice on ‘Whistleblowing for employees’ www.gov.uk/whistleblowing]
9.3. ACAS guidance on ‘Whistle-blowing – Public Interest Disclosure’
https://archive.acas.org.uk/index.aspx?articleid=1919
