IGD aims to develop a culture of openness. As part of this it is fundamental that any concerns you may have about suspected malpractice within IGD, are raised. It is in everyone’s interest to ensure that malpractice does not occur, by anyone, to anyone or in any practice. The following policy and procedure explains what is meant by malpractice and how genuine concerns should be raised. Anyone who feels they need to raise a concern under this policy should note that IGD will take seriously any concerns raised and take all possible steps to ensure the person raising the concern is treated fairly, with dignity and respect.
This policy applies to all volunteers of IGD.
What is whistleblowing?
Whistleblowing is the disclosure of information which relates to suspected wronging or danger at work. This may include:
- criminal activity;
- miscarriages of justice;
- creating a risk to health and safety;
- damage to the environment;
- failure to comply with any legal obligation or regulatory requirement;
- financial fraud or mismanagement
- conduct likely to damage our reputation
- unauthorised disclosure of confidential information
- the deliberate concealment of any of the above;
A whistleblower is a person who raises a genuine concern in good faith relating to any to the above. If a volunteer has a genuine concern related to suspected wrongdoing or danger affecting any of our activities a report should be made under this policy.
This policy should not be used for complaints relating to the administration or carrying out of IGD’s charity activities, where there is no genuine concern in relation to wrongdoing or danger. In these cases a report should be made using the Complaints Policy.
Any queries as to the correct procedure to use should be raised with the Company Secretary.
Raising a whistleblowing concern
A volunteer should raise their concerns to the IGD staff member they liaise with on a regular basis, preferably in a face to face meeting. If the volunteer finds it difficult the initial contact can be made by email. The IGD staff member will arrange a meeting with the volunteer to discuss the concern raised as soon as is practically possible.
If the volunteer believes the IGD staff member to be involved, or for any reason does not wish to approach the IGD staff member, then they should report their concerns to the Company Secretary.
A meeting will be arranged with the volunteer as soon as possible to discuss the concerns raised. The individual may be accompanied by a trade union representative or a colleague to any meeting under this policy. The companion must respect the confidentiality of the disclosure and any subsequent investigation.
After the meeting a written summary of the concerns will be made and a copy provided for the volunteer. Where possible IGD will aim to give an indication of how we propose to deal with the matter at this stage. A volunteer who makes such a protected disclosure has the right not to be dismissed, or subjected to victimisation, because he/she has made the disclosure.
IGD hopes that volunteers will feel able to voice whistleblowing concerns under this policy. However, if a volunteer wishes to raise a concern confidentially every effort will be made to keep their identity secret. If it is necessary for anyone investigating the concern to know the whistleblower’s identity this will be discussed with the individual.
IGD does not encourage volunteers to make disclosures anonymously. Proper investigation may be more difficult or impossible if we cannot obtain further information. It is also difficult to establish whether any allegations are credible and made in good faith. Whistleblowers who are concerned about possible reprisals if their identity is revealed should speak with the Company Secretary.
The aim of this policy is to provide a mechanism for reporting, investigating and remedying any wrongdoing. In most cases it should not be necessary to alert anyone externally. The law recognises that in some circumstances it may be appropriate to report concerns to an external body such as a regulator. We recommend that advice is sought before reporting a concern externally.
Whistleblowing concerns usually relate to the conduct of our staff but they may sometimes relate to the actions of a third party such as a customer, supplier or service provider. The law allows an individual to raise a concern in good faith with a third party, where you reasonably believe it relates mainly to their actions or something that is legally their responsibility. However, IGD encourages volunteers to report such concerns to IGD first to either to their contact at IGD or IGD’s Company Secretary.
Investigation and outcome
Once a concern has been raised an initial assessment will be carried out to determine the scope of any investigation.
The whistleblower will be informed of the outcome of the assessment and may be required to attend additional meetings in order to provide further information. In some cases we may appoint an investigator or team of investigators including staff with relevant experience of investigation or specialist knowledge of the subject matter.
IGD aims to keep the whistleblower informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent us giving specific details of the investigation or any disciplinary action taken as a result. The whistleblower should treat any information about the investigation as confidential.
If IGD concludes that a whistleblower has made false allegations maliciously, in bad faith or with a view to personal gain, further action will be taken, including possible termination of the volunteer’s role.
Where the whistleblower is not happy with the way in which their concerns have been handled they will be advised of the contact details of the relevant person to speak with. Normally this would be the Chairman of the Board of Trustees.
Volunteers are encouraged to follow this procedure for reporting but in the event that this procedure is exhausted and the volunteer finds the handling of the concern unsatisfactory, there is the option of contacting the Charity Commission via email: [email protected] Further information may also be found at https://www.gov.uk/guidance/report-serious-wrongdoing-at-a-charity-as-a-worker-or-volunteer
Protection and support for whistleblowing
It is understandable that whistleblowers are sometimes concerned about possible repercussions. IGD aims to encourage openness and will support workers who raise genuine concerns in good faith under this policy.
Volunteers must not suffer any detrimental treatment as a result of raising a concern in good faith. Detrimental treatment includes termination of your volunteering role, threats or other unfavourable treatment connected with raising a concern. If the whistleblower believes that they have suffered any such treatment, the matter should be reported to the Company Secretary.
Staff and other volunteers must not threaten or retaliate against whistleblowers in any way. Anyone involved in such conduct will be subject to disciplinary action.
Responsibility for the policy
The Board of Trustees has overall responsibility for this policy and for reviewing the effectiveness of actions taken in response to concerns raised under the policy.
The Company Secretary has day to day operational responsibility for this policy and must ensure that all managers and other staff who may deal with concerns or investigations under this policy receive regular training.
The Company Secretary should review this policy from a legal and operational perspective at least once a year.
All volunteers are responsible for the success of this policy and should ensure that they use it to disclose any suspected danger or wrongdoing.
Chairman of the Board at https://www.igd.com/about-us/how-we-are-governed
Company Secretary at [email protected]
This policy does not cover:
- complaints from staff, who should use IGD’s Whistleblowing Policy where appropriate
- complaints from staff which are personal, where the member of staff should use IGD’s grievance procedure
- complaints from volunteers who are dissatisfied about IGD’s work and where there is no suspected wrongdoing or danger, where you should use the Complaints Policy or the Whistleblowing Policy, as appropriate, at http://igd.com/policies
The Charity may alter or adapt this Policy, and any components of it, at any time.
Approval and review
This policy was approved by the Board of Trustees on 28th November 2019.