Whistle Blowing Policy
1. Policy Intent
The Forward Institute is committed to the highest standards of transparency, integrity and accountability. It is important that our own business practises uphold our responsible business ethos, and we encourage all team members to speak up if you believe that any of our practises are not in accordance with our principles of responsible business. We aim to have a culture whereby all team members feel comfortable and able to raise any concerns with any relevant individual in the team.
Where such concerns are of a more serious nature, the Whistleblowing Policy sets out a framework for making and dealing with serious allegations of illegal and improper conduct, whilst ensuring confidentiality and protection for the individual who has made the allegation.
This policy applies to all Forward Institute employees, including our contractors. This procedure applies to, but is not limited to, allegations about any of the following:
Conduct which is an offence or breach of the law
Alleged miscarriage of justice
Serious Health and Safety risks
The unauthorised use of public funds
Possible fraud and corruption
Sexual, physical or verbal abuse, or bullying or intimidation of employees, customers or service users
Abuse of authority
Other unethical conduct
All allegations will be treated in confidence and the Forward Institute will not, without the whistle-blower’s consent, disclose the identity of a whistle-blower to anyone other than a person involved in the investigation/allegation.
4. Anonymous Allegations
We encourage whistle-blowers to put their name to an allegation wherever possible as anonymous allegations may often be difficult to prove. Allegations made anonymously are much less powerful but will be considered at the discretion of the CEO/Board. In exercising discretion to accept an anonymous allegation the factors to be taken into account are:
The seriousness of the issue raised
The credibility of the allegation; and
Whether the allegation can realistically be investigated from factors or sources other than the complainant
5. Untrue Allegations
No disciplinary or other action will be taken against someone who makes an allegation in the reasonable belief that it is in the public interest to do so even if the allegation is not substantiated by an investigation. However, disciplinary action may be taken against a whistle-blower who makes an allegation without reasonable belief that it is true or in the public interest to do so (e.g. making an allegation frivolously, maliciously or for personal gain where there is no element of public interest).
6. Procedure for making an allegation
If deemed appropriate, it is preferable for allegations to be made to your line manager. However, if felt more appropriate, the employee should speak to the Head of Operations and Finance (Jess Dennis), CEO (Adam Grodecki) or, for exceptionally serious and sensitive allegations, to the Chair of the People Committee (Bill Castell ([email protected])).
Whether a written or verbal report is made it is important that relevant information is provided including:
The name of the person making the allegation and a contact point.
The context of the allegation (giving relevant dates, names and positions of those involved);
The specific reason for the allegation. Although whistle-blowers will not be expected to prove the truth of any allegations, they will need to provide information to establish that that there are reasonable grounds for the allegation.
The whistle-blower may be accompanied by another person of their choice during any meetings or interviews regarding the allegation.
8. Action on receipt of allegation
The person to whom the allegation has been reported will record details of the allegation within 5 working days of receipt of the allegation, gathering as much information as possible, including:
The record of the allegation:
The acknowledgement of the allegation;
Any documents supplied by the whistle-blower
They should ask the whistle-blower for their preferred means of communication and contact details and use these for all communications with the whistle-blower in order to preserve confidentiality.
Depending on the allegation, the person to whom the allegation has been made will inform the relevant Senior members of the team and/ or Board in order to determine whether the allegation should be investigated and the method of investigation. Unless deemed necessary to the investigation, the investigating team/ Board members will not be told the name of the whistle-blower. If, in order to investigate the allegation, it is deemed necessary to name the whistle-blower, or if it is felt that it will become obvious who the whistle-blower is, the whistle-blower will be informed of this and may decide to not proceed with their allegation.
If the allegation relates to fraud, potential fraud or other financial irregularity the Head of Finance and Operations (Jess Dennis) and CEO (Adam Grodecki) will be informed within 5 working days of receipt of the allegation.
If the allegation discloses evidence of a criminal offence it will immediately be reported to the Board and a decision will be made as to whether to inform the Police. If the allegation concerns suspected harm to children, the appropriate authorities will be informed immediately.
Timeline: The allegation will be acknowledged in writing within 10 working days with;
An indication of how the Forward Institute proposes to deal with the matter
An estimate of how long it will take to provide a final response
An indication of whether any initial enquiries have been made
Information on whistle-blower support mechanisms
Indication whether further investigations will take place and if not, why not
Where the allegation has been made anonymously, the Forward Institute will be unable to communicate what action has been taken.
The Forward Institute will take steps to minimise any difficulties which may be experienced as a result of making an allegation. For instance, if a whistle-blower is required to give evidence in criminal or disciplinary proceedings the Forward Institute will arrange for them to receive advice about the procedure and advise on the support mechanisms that are available.
The Forward Institute accepts that whistle-blowers need to be assured that the matter has been properly addressed. Thus, subject to legal constraints, we will inform those making allegations of the outcome of any investigation.
10. Responsibility for the procedure
The CEO and the Board will have overall responsibility for the operation of this Procedure and for determining the administrative processes to be followed and the format of the records to be kept.
A Register will be held by the Company Secretary (Head of Finance and Operations) and will record the following details:
The name and status (e.g. employee) of the whistle-blower
The date on which the allegation was received
The nature of the allegation
Details of the person who received the allegation
Whether the allegation is to be investigated and, if yes, by whom
The outcome of the investigation
Any other relevant details
The Register will be confidential and only available for inspection by the Board.
The CEO will report annually to the People Committee on the operation of the procedure and on the whistleblowing, allegations made during the period covered by the report. The report will be in a form which does not identify whistle-blowers.