Reporting a Suspected Malpractice (Whistle Blowing) Policy
It is the duty of every member of staff and volunteer to speak up about genuine concerns in
relation to criminal activity, breach of a legal obligation (including negligence, breach of contract,
breach of administrative law), miscarriage of justice, danger to health and safety or the
environment, and the cover up of any of these in the workplace. It applies whether or not the
information is confidential.

Steel Bones Is committed to ensuring that any concerns of this nature will be taken seriously
and investigated. A disclosure to Steel Bones will be protected if the member of staff has an
honest and reasonable suspicion that the malpractice has occurred, is occurring, or is likely to
occur. Staff and volunteers who raise concerns reasonably and responsibly will not be penalised
in any way.

Who this policy is for?
This policy is for people employed by or volunteering with the Steel Bones For the purposes of
this policy only, this is someone who is:
• Employed on a permanent or fixed term contract of employment;
• On secondment to Steel Bones;
• On a temporary contract or employed through an agency to work for Steel Bones;
• An independent consultant for Steel Bones
• A volunteer with Steel Bones
• Contractors and suppliers of services to Steel Bones

Procedures
Any individual who has reasonable suspicions of malpractice should initially take their concerns
to their line manager. If they do not feel that this is the appropriate person, they should
approach the Chair, or if their concern is related to the Chair, they should contact a Trustee. It is
recognised that for some individuals, raising a concern under this procedure may be a daunting
and difficult experience. An individual may choose to be accompanied or represented by their
trade union representative or colleague at any stage of this procedure. All reported incidents will
be investigated. All reports will be dealt with in confidence, with only staff who need to know,
being informed.

The Chair or Trustee will establish and record the basis of the concerns that have been raised
and establish what further actions are required. The individual raising the concern will be
advised of the outcome of the investigation as soon as possible, normally within two weeks of
the date of their disclosure. Where a longer period is needed for investigation, the member of
staff will be informed in writing.

The Chair will be informed of all reported disclosures and the actions being taken. In the case of
disclosures on alleged fraud and corruption, Steel Bones Finance Officer/ Advisor and Steel
Bones auditors will be informed by the Chair.
If an individual is not satisfied with the response received and any subsequent action taken,
they should put their concerns in writing to another appropriate trustee who will arrange any
further investigation as he/she thinks appropriate. The Chair will send a written response to the
individual concerned.

Guiding principles
To ensure that this policy is adhered to, and to assure staff that the concern will be taken
seriously, Steel Bones will:
Not allow the person raising the concern to be victimised for doing so;
Treat victimisation of whistleblowers as a serious matter that may lead to disciplinary action that
may include dismissal;
Not attempt to conceal evidence of poor or unacceptable practice;
Take disciplinary action if an employee destroys or conceals evidence of poor or unacceptable
practice or misconduct;
Ensure confidentiality clauses in employment contracts do not restrict, forbid or penalise whistle
blowing;
Liaise with the other organisations (see section below) to whom staff report malpractice.
Independent advice and further reading
Further Information for charitable organisations can be found on the Charity Commission’s
website on:
http://www.charity-commission.gov.uk/Our_regulatory_activity/Reporting_issues/Trustee_emplo
yee_and_volunteer_guidance_index.aspx

Employees/Volunteers who feel unsure about whether or how to raise a concern or want
confidential advice can contact the independent charity Public Concern at Work
(http://www.pcaw.org.uk) on 020 7404 6609 or email helpline@pcaw.co.uk. Their lawyers can
give free confidential advice on how to raise a concern about serious malpractice at work.
Free information and advice can also be obtained from the Advice, Conciliation and Arbitration
Service (ACAS) – Telephone: 08457 47 47 47.

You may feel that it is more appropriate to report a matter to another organisation. Other
organisations concerned with standards in the voluntary sector include:
The Charity Commission – 0845 300 0218
Audit Commission for local authorities and the National Health Service in England and Wales –
0844 798 3131
Health & Safety Executive – contact on-line; http://www.hse.gov.uk/contact/index.htm or in
emergency 0845 300 9923
NHS Fraud & Corruption Reporting Line – 0800 028 40 60
Public Concern at Work and ACAS can advise on the circumstances when it is more appropriate
to contact an outside body.

Originally Adopted February 2018
Next Review Date: January 2019

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