Whistleblowing policy
Introduction
We are committed to maintaining the highest level of ethical standards of probity. We have adopted specific policies to achieve this, including an Anti Bribery, Anti-Fraud and Corruption and Counter-Money Laundering Policy, a Code of Conduct in our Colleague Handbook, and the NHF Code of Conduct for Board Members.
Who this policy applies to and what it covers
This policy applies to all Board Members and colleagues whether permanent, part-time, fixed term, casual or volunteers of the organisation.
Our whistleblowing policy
The policy specifically covers our approach to whistleblowing. A ‘whistleblower’ is a worker who becomes aware of a serious problem and raises the matter so that it can be investigated.
Government guidance states that whistleblowing needs to be in the public interest and should not be used for personal grievances, these should be reported through our grievance process.
The Whistleblowing Policy is one way in which we seek to comply with the Public Interest Disclosure Act 1998. This Act is intended to protect workers from dismissal or victimisation if they raise legitimate concerns to do with their work or employer in the following categories:
- Criminal offences, actual or potential.
- Failure to comply with a legal obligation.
- Miscarriages of justice, actual or potential.
- Damage to the environment, actual or potential.
- Health and safety issues.
- Any concerns that any of the above issues may be deliberately concealed.
We will encourage workers to contact any of the following to raise legitimate concerns to do with their work or us:
- Their manager.
- Any other manager or director.
- Our internal auditors.
- Another organisation such as the police, Regulator of Social Housing, or the Health and Safety Executive.
We will support and protect any whistleblower who has volunteered information under this policy from reprisals or victimisation.
If any discrimination or harassment takes place as a result of whistleblowing, we will take appropriate action under our grievance or managing behaviour procedures.
We will do everything possible to protect an individual’s identity when a concern is raised and where the individual does not want their name disclosed. However, if legal action is necessary, an individual’s identity may need to be disclosed (e.g. to the police). We will encourage workers who have such concerns to seek independent advice from Protect the UK’s leading whistleblowing charity) or other sources.
We will ensure that all whistleblowing reports are investigated and appropriate action taken to rectify issues identified.
No action will be taken against the whistleblower if the claims are not subsequently substantiated, unless the whistleblower raises deliberately false or malicious concerns. In which case this will be taken seriously and the individual dealt with under our managing behaviour procedure.
Responsibilities
The Head of Governance, Legal and Risk is responsible for ensuring that the Whistleblowing Policy is adhered to.
Management is responsible for ensuring concerns are reported and investigated. All colleagues are responsible for raising concerns.
The Chief Executive is responsible for co-ordinating whistleblowing investigations.
Annual reports will be made to the Executive Board and Risk and Audit Committee by our appointed internal auditors identifying whistleblowing cases and the action taken.
The Regulator of Social Housing will also be notified of whistleblowing cases depending on the severity and individual circumstances. The decision to disclose will be agreed with the Strategic Board.
This policy will be considered and approved every three years.