Public Interest Disclosure (‘Whistleblowing’)

What This Policy Covers

This policy applies to all colleagues, workers, and contractors.

The Company is committed to safeguarding and acting in the interests of the public and its staff. It is important that any fraud, misconduct, or wrongdoing by colleagues or agents is reported and properly addressed.

All colleagues and agents are encouraged to raise concerns in a responsible manner. The Company prefers that issues are raised and dealt with, rather than ignored.

Your Responsibilities

You are encouraged to report any practice or action of the Company, its colleagues, or other agents that you reasonably believe is against the public interest, including if the act is:

  • A criminal offence

  • A failure to comply with a legal obligation

  • A miscarriage of justice

  • A danger to the health or safety of any individual

  • Causing damage to the environment

  • An attempt to conceal information relating to any of the above

Anyone raising legitimate concerns will not face any detriment during or after employment.
The Company will also protect individuals from intimidation or harassment as a result of whistleblowing.

⚠️ Note: This policy is not for complaints about your personal employment circumstances (e.g., treatment at work). Those issues should be raised under the Grievance Procedure.

Procedure

In the first instance, raise any concerns with your manager.

If your manager is involved, or if you prefer not to approach them, raise the issue with a more senior person in the Company.

Any matter raised under this policy will be:

  • Investigated promptly (within 7 working days) and confidentially.

  • The outcome and any remedial actions will be confirmed to you.

  • If no action is taken, the reason will be explained.

All allegations will be treated in confidence and investigated thoroughly.
The Company is committed to protecting anyone who raises concerns from victimisation, harassment, or unfair treatment.
Any such behaviour will be handled under the Disciplinary Procedure.

Escalating Your Concern

If you are not satisfied with the initial response, raise your concerns in writing with a more senior person within the Company.

If, after escalation, you still believe the issue hasn’t been properly addressed, you may report it to the relevant external authority. Appropriate authorities include:

  • HM Revenue & Customs

  • The Financial Conduct Authority

  • The Health and Safety Executive

  • The Environment Agency or Scottish Environmental Protection Agency

  • The Information Commissioner

  • Department for Education (ESFA) – How ESFA handles whistleblowing disclosures

This list is not exhaustive. You must ensure you contact the correct authority for your particular concern.

If you are unsure who to contact, seek advice from Protect (formerly Public Concern at Work), an independent whistleblowing charity — contact details below.

⚠️ If you knowingly make a false or malicious allegation, or if you are found to be involved in the wrongdoing, disciplinary action may be taken — up to and including dismissal without notice for gross misconduct.

You must not share details of any concern with non-relevant third parties, nor should you publicly disclose your concerns.

Independent Advice

Independent advice and support are available from:

Protect (formerly “Public Concern at Work”)
Email: whistle@protect-advice.org.uk
Tel: 0203 117 2520
Website: www.protect-advice.org.uk

Further Information

More information about whistleblowing can be found at:
Whistleblowing for colleagues: What is a whistleblower – GOV.UK

Version Control

Current version: 2
Previous version: 1
Reviewed by: Hannah Wheawall
Changes made: None
Issued: 14/03/25
Next review date: 14/03/26
Signed by: Hannah Wheawall – People & Culture Director