Please note – This policy is specific to BVSC and may not be applicable to your organisation. This
policy has been provided for your information and guidance only. To our knowledge the contents of
this policy are accurate and up to date. We advise all organisations to seek professional or legal
advice when introducing new policy and procedures to your respective organisation.
WHISTLEBLOWING POLICY
1.0
OBJECTIVE
1.1
BVSC aims to achieve its strategic goals through the delivery of high quality
services and activities. We are committed to creating a working environment
in which honesty and accountability are paramount
1.2
This policy and procedure conforms to the guidance in the Public Interest
Disclosure Act 1998 (PIDA).
1.3
We expect employees and others that we deal with, who have serious and
genuine concerns about any aspect of our work to come forward and voice
those concerns with the reassurance that they will be protected from reprisals
or victimisation for whistleblowing in good faith.
1.4
It should be emphasised that this policy is intended to assist individuals who
believe that they have discovered malpractice or impropriety. This policy is
not designed to question financial operational decisions taken by BVSC nor
should it be used to reconsider any matters which have already been
addressed under harassment, complaint, disciplinary and grievance or other
procedures.
1.5
This policy is intended to cover major concerns that fall outside the scope of
other policy and procedure which include:
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conduct which is an offence or a breach of law,
disclosures related to miscarriages of justice,
health and safety risks, including risks to the public as well as other
employees,
damage to the environment,
the unauthorised use of public funds,
possible fraud and corruption,
unethical conduct, or
attempts to conceal any of these.
1.6
The policy does not replace the BVSC Complaints Procedure.
2.0
APPLICATION
2.1
This policy applies to all permanent and short term employees of BVSC. It
also applies to other categories of workers such as volunteers, secondees,
external consultants, contractors and agency staff whilst at BVSC.
Please note – This policy is specific to BVSC and may not be applicable to your organisation. This
policy has been provided for your information and guidance only. To our knowledge the contents of
this policy are accurate and up to date. We advise all organisations to seek professional or legal
advice when introducing new policy and procedures to your respective organisation.
3.0
PRINCIPLES
3.1
You are protected as a whistleblower if you:
 are a worker and
 believe that malpractice in the workplace is happening, has happened in
the past or will happen in the future and
 are revealing information of the right type (a qualifying disclosure) and
 reveal it to the right person, and in the right way (making it a protected
disclosure).
3.2
Qualifying Disclosures
A qualifying disclosure could be disclosure about criminal offences, failure to
comply with a legal obligation, miscarriages of justice, threats to an
individual’s health and safety, damage to the environment or a deliberate
attempt to cover up any of the aforementioned or similar issues.
3.3
You will not be protected from whistleblowing if:
 you break the law when making a disclosure or
 the information is protected under legal professional privilege.
3.4
Protected Disclosures
For your disclosure to be protected you must:
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make the disclosure in good faith (with honest intent and without malice)
and/or
reasonably believe that the information is substantially true and/or
reasonably believe that you are making the disclosure to the right
prescribed person.
3.5
It is BVSC’s responsibility to ensure that an investigation takes place.
3.6
If an individual is not sure whether to raise a concern, he/she should discuss
the issue with his/her line manager or the Human Resources Manager.
3.7
You can contact Public Concern at Work in order to get advice on raising
concerns (see section 5.0 for full details).
3.8
Harassment or Victimisation
BVSC will not tolerate any harassment or victimisation and will take
appropriate action to protect members of staff when a concern is raised in
good faith.
Victimisation of an employee for raising a qualified disclosure will be a
disciplinary offence.
Please note – This policy is specific to BVSC and may not be applicable to your organisation. This
policy has been provided for your information and guidance only. To our knowledge the contents of
this policy are accurate and up to date. We advise all organisations to seek professional or legal
advice when introducing new policy and procedures to your respective organisation.
Any investigation into allegations of potential malpractice will not influence or
be influenced by any disciplinary or redundancy procedures that already affect
you.
3.9
Confidentiality
All concerns will be treated in confidence and every effort will be made not to
reveal your identity if you so wish. However, you may need to come forward
as a witness.
3.10
Anonymous Allegations
We encourage staff to put your name to your allegation. Anonymous
concerns are much less powerful and will be considered at BVSC’s discretion.
In exercising this discretion we will take into consideration the seriousness of
the issue raised, the credibility of the concern and the likelihood of confirming
the allegation from attributable sources.
3.11
Untrue allegations
If the allegation that you have made in good faith is not confirmed following an
investigation, no action will be taken against you.
If it becomes clear that this procedure has not been invoked in good faith (for
malicious reasons) or to pursue a personal grudge against another individual,
this will constitute misconduct and will be dealt with in accordance with the
BVSC Disciplinary Procedure.
4.0
THE PROCEDURE
4.1
Stage 1
In the first instance you should raise your concern with your line manager.
However, if you believe your line manager has any involvement then you
should proceed to Stage 3.
You may raise your concern verbally or in writing. If you produce a written
account, you should provide details of the background and history of your
concern and give relevant dates and provide reasons for why you are
concerned about the situation.
The earlier you express your concern the easier it will be to take action.
At this stage your line manager will provide you with information on staff
support mechanisms.
Please note – This policy is specific to BVSC and may not be applicable to your organisation. This
policy has been provided for your information and guidance only. To our knowledge the contents of
this policy are accurate and up to date. We advise all organisations to seek professional or legal
advice when introducing new policy and procedures to your respective organisation.
4.2
Stage 2
Your line manager will arrange an investigation of your concern. Your line
manager may investigate the matter themselves or may deem it necessary to
pass the matter on to someone in a more senior position.
As part of the investigation you (and other individuals involved) may be asked
to provide written statements (if you have not already done so at stage 1).
You may be invited to attend meetings or interviews in connection with the
issues that you have raised. You will be entitled to invite a trade union
representative or work colleague to accompany you at these meetings.
Following the investigation, you will be provided with a written response within
15 working days.
If your concern is justified the line manager will confirm the action to be taken,
the time scale and the person responsible, this is subject to any legal
constraints. If your concern is not justified you will be informed in writing of
the reasons for this.
A copy of this response should be forwarded to the Human Resources
Manager.
4.3
Stage 3
If you are concerned that your manager is involved in the wrongdoing then
you may proceed to this stage whereby you may communicate your concern
to the next level of management. The investigating manager will follow the
process detailed in Stage 2.
If your concern involves the Chief Executive, you should refer your concern to
the Board of Trustees who will nominate a representative to investigate your
concern and follow the process detailed in Stage 2. Please contact the
Human Resources Manager (on a confidential basis) for the contact details of
the Board of Trustees.
You may also have continuing concerns following the response that has been
given to you at Stage 2, then you must produce a written statement detailing
your concerns. This statement should be forwarded, along with a copy of
your line manager’s written response, to the next level of management.
A copy of all documents should be forwarded to the Human Resources
Manager.
The manager receiving your statement will acknowledge receipt of the
concerns raised and give further consideration, meeting you and other
Please note – This policy is specific to BVSC and may not be applicable to your organisation. This
policy has been provided for your information and guidance only. To our knowledge the contents of
this policy are accurate and up to date. We advise all organisations to seek professional or legal
advice when introducing new policy and procedures to your respective organisation.
individuals involved if necessary. Their decision will be communicated to you,
in writing, within 15 working days.
If your concern is justified the investigating manager will confirm the action to
be taken, the timescale and the person responsible, this is subject to any legal
constraints. If your concern is not found to be justified, you will be informed in
writing of the reasons for this.
5.0
RAISING A CONCERN EXTERNALLY
5.1
The intention of this policy is to provide you with an avenue to raise your
concerns. If you are not satisfied with the action that has been taken and this
procedure has been exhausted you may take the matter outside of BVSC.
5.2
Please note that in order to maintain the protection of the Public Interest
Disclosure Act 1998 (PIDA) disclosure other than to BVSC must be made to
selected bodies or persons, for example, your disclosure will be protected if
made to the Inland Revenue or Health & Safety Executive. Information on
selected bodies can be found at:
http://www.direct.gov.uk/prod_consum_dg/groups/dg_digitalassets/@dg/@en/
@employ/documents/digitalasset/dg_177605.pdf
5.3
Wider external disclosures, for example disclosures made to the police, media
or to MP’s are protected if:
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5.4
The disclosure was made in good faith,
You reasonably believe that the information and/or allegations made are
substantially true,
You reasonably believe that you will be subject to detrimental treatment by
BVSC by making the disclosure,
You reasonably believe that evidence relating to the allegation will be
concealed or destroyed if you make the disclosure to BVSC
Your concern has already been formally raised internally,
Your concern is of an exceptionally serious nature.
You may also seek further advice from:
Public Concern at Work – This is a registered charity who offer their
services free of charge and it strict confidence. They are an independent
authority on public interest and whistleblowing.
http://www.pcaw.co.uk
Directgov – Information on whistleblowing can be accessed through this
government website.
Please note – This policy is specific to BVSC and may not be applicable to your organisation. This
policy has been provided for your information and guidance only. To our knowledge the contents of
this policy are accurate and up to date. We advise all organisations to seek professional or legal
advice when introducing new policy and procedures to your respective organisation.
http://www.direct.gov.uk/en/Employment/ResolvingWorkplaceDisputes/Whistl
eblowingintheworkplace/DG_175821
The Charity Commission – Telephone number for their contact centre on
0845 300 0218. Lines are open from 08:00 to 18:00, Monday to Friday, except
national holidays.
www.charity-commission.gov.uk
The Chartered Institute of Personnel & Development (CIPD) – The CIPD
is a professional body for the management and development of people.
http://www.cipd.co.uk/subjects/empreltns/whistleblw/whistle.html
Trade Union
Citizens Advice Bureau
Professional Bodies or Regulatory Organisations
The Police
5.5
If you do take the matter outside BVSC, you should ensure that you do not
disclose confidential information.