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Whistleblowing Policy

Purpose of the Policy

We encourage informants to use this policy if there are any concerns about any wrong doing at Skills for Security Limited. However, if the policy has been invoked for malicious reasons or in pursuit of a personal grudge, then an employee /informant will be liable to immediate termination of employment or such lesser disciplinary sanction as may be appropriate in the circumstances.

Aims of the Policy

The Policy is designed to ensure that you can raise your concerns about wrongdoing or malpractice within Skills for Security without fear of victimisation, subsequent discrimination, disadvantage or dismissal.

It is also intended to encourage and enable you to raise serious concerns within Skills for Security rather than ignoring a problem or ‘blowing the whistle’ outside.

This Policy aims to:

  • encourage you to feel confident in raising serious concerns at the earliest opportunity and to question and act upon concerns about practice
  • provide avenues for you to raise those concerns and receive feedback on any action taken
  • ensure that you receive a response to your concerns and that you are aware of how to pursue them if you are not satisfied
  • reassure you that you will be protected from possible reprisals or victimisation if you have made any disclosure in good faith.

Scope of the Policy

This Policy is intended to enable those who become aware of wrongdoing in Skills for Security affecting some other person or service, to report their concerns at the earliest opportunity so that they can be properly investigated.

The Whistle Blowing Policy is not intended to replace existing procedures:

  • If your concern relates to your own treatment as an employee, you should raise it under the existing grievance or harassment procedures
  • If a client has a concern about services provided to him/her, it should be raised as a complaint to the Head of Quality

Complaints of misconduct by Skills for Security are dealt with under a separate procedure (for further information please contact the Head of HR & Business Support).

Qualifying Disclosures

 Certain disclosures are prescribed by law as “qualifying disclosures”. A qualifying disclosure means a disclosure of information that the employee / informant genuinely and reasonably believes is in the public interest and shows that the company has committed a “relevant failure” by:

  • committing a criminal offence;
  • failing to comply with a legal obligation;
  • a miscarriage of justice;
  • endangering the health and safety of an individual;
  • environmental damage; or
  • concealing any information relating to the above.

These acts can be in the past, present or future, so that, for example, a disclosure qualifies if it relates to environmental damage that has happened, is happening, or is likely to happen. Skills for Security will take any concerns that are raised relating to the above matters very seriously.

Procedure

  • If you are concerned about one of the areas listed above, you should, in the first instance, report this to your line manager. If your concerns are about your line manager, you should contact the Head of HR & Business Support or any manager with whom you feel comfortable discussing the issue.
  • You should reasonably believe that malpractice is happening. However, you don’t have to provide hard evidence – we would prefer you to come forward so we can investigate before things go seriously wrong.
  • This policy applies to disclosing matters of public interest. If you are concerned about something that is happening to you personally (such as a breach of your own terms and conditions that does not affect other people), you should follow our grievance procedure.
  • We will take all reasonable steps to maintain your confidentiality if you request this. If the manager dealing with your concerns will not be able to investigate while maintaining your confidentiality, they will inform you of this.
  • You are entitled to raise your concerns anonymously. However, we will not be able to deal with them as effectively or give you as much feedback if we cannot talk to you in person. It will also be harder to establish if the allegations are credible.
  • The manager will tell you what action they propose to take and by when. This is likely to include investigating the issue and sharing the concerns with other managers.
  • The manager will keep you informed of progress as far as is possible. However, we will need to protect sensitive business information and the confidentiality of other members of staff. In particular, we will not usually be able to tell you about any disciplinary action being taken against a colleague.
  • If you are not satisfied with the response that you receive from the organisation, then you are entitled to contact a relevant external body to share your concern. A relevant external body will be one that has expertise in the area of concern, such as the ESFA or Ofsted.
  • The media is not a relevant external body. You should not contact the media to raise a concern.

Your Rights and Duties

  • We will not subject you to any detrimental treatment for coming forward with genuine concerns, even if the disclosure turns out to be groundless. If you believe anyone is victimising, bullying or harassing you or treating you unfairly because you have raised concerns, you should notify your line manager or HR, who will investigate.
  • If you subject a whistleblower to any sort of detrimental treatment, we will treat this as a serious disciplinary matter. We may also launch our disciplinary procedure if we believe you have maliciously made a false whistleblowing disclosure or intentionally deceived us.
  • We will brief all staff and managers so you understand your rights, obligations and what actions to take under this policy.
  • If you need further advice on your rights, you can call the whistleblowing charity Protect on its helpline (020 3117 2520).
  • If you leave the organisation and have signed a confidentiality agreement, this does not prevent you from making a disclosure that is in the public interest.

Treatment by Others 

Bullying, harassment or any other detrimental treatment afforded to a colleague who has made a qualifying disclosure is unacceptable. Anyone found to have acted in such a manner will be subject to disciplinary action or dismissal. 

Whistleblowing is the disclosure by an individual of wrongdoing that is happening in the organisation. You are protected from reprisals for blowing the whistle, even if your fears turn out to be mistaken.

We encourage everyone whom we engage (including full-time and part-time employees, casual and agency workers, contractors, directors and non-executive directors, volunteers and secondees) to report concerns about any of the following:

  • A criminal offence.
  • A failure to comply with a legal obligation.
  • A miscarriage of justice.
  • A practice that puts health, safety in danger.
  • Damage to the environment.
  • [Consider adding any other matters relevant to your organisation, such as: bribery, financial misconduct, modern slavery, unethical conduct.]
  • An attempt to cover up one of the above.

This list is not exhaustive.

We will treat all such concerns fairly and consistently.

This policy is non-contractual and we may amend it at any time.

Last Review Date: April 2024 

Next Review Date: April 2025

Position in Organisation: HR

Signed: B Brougham