Date for review: 01 Jan 2024
Reference: ICYE UK – Whistleblowing Policy
Introduction and Aim
Policy Purpose The purpose of this policy is to:
- Encourage you to feel confident to make a disclosure of concerns about issues that fall under this policy.
- Provide avenues for you to raise those concerns.
- Reassure you that you will be protected when you raise a concern.
- Provide a framework in which individuals can raise concerns about malpractice in a supportive atmosphere.
- Help ICYE members (active alumni), staff and trustees ensure the good governance of the organisation.
ICYE-UK aims to maintain the highest standards of openness, decency, integrity and accountability in its work. ICYE believes in:
- Attaining the highest quality standards in all our activities;
- Nurturing a culture of mutual trust, support and encouragement.
Everyone who works with or for ICYE-UK must be vigilant for signs of wrongdoing or criminal activity by individuals or organisations working with or for ICYE-UK and are encouraged to report such behaviour using this policy.
Who does this Policy apply to?
This Policy applies to all ICYE-UK people, i.e. trustees, employees, volunteers, consultants, suppliers, temporary staff, contractors and other people in the ICYE Federation worldwide. In addition, this policy applies to anyone who wants to raise a concern about ICYE-UK, including those who use ICYE-UK services or take part in ICYE-UK activities, as well as other stakeholders and the public.
Whistle-blowing can be defined as the disclosure of information, a perceived wrongdoing in an organisation, or the risk thereof, to individuals or entities believed to be able to effect action. Whistle-blowing is a term used to describe a situation in which an employee, trustee, volunteer or any other individual linked or associated with ICYE-UK raises a concern about possible malpractice, fraud, crime, danger, safeguarding or any other serious risk that could threaten primary actors, colleagues (staff members and volunteers), donors, the public or ICYE-UK’s integrity and reputation. The difference between a whistle-blowing issue and an employee grievance is that in the case of whistle-blowing, the concern is about a danger or illegality that has a public interest to it; a grievance or private complaint, by contrast, is a dispute about the employee’s own employment position and has no additional public interest dimension.
What kind of concerns should I disclose under this policy?
Any serious concerns you may have about any aspect of the activities of ICYE-UK or those who work within ICYE-UK can be reported under this policy. Examples of malpractice which you should report include, but are not limited to, the following:
- Corruption, bribery or blackmail;
- Fraud and financial irregularity;
- Failure to comply with legal or regulatory obligations;
- Breach of ICYE-UK internal policies and procedures
- Abuse of position at ICYE-UK to obtain personal benefits;
- Showing undue favour over a contractual matter or to a job applicant;
- Endangering the health and safety of any individual;
- Endangering or abusing (either physically or mentally) children or vulnerable adults with whom ICYE-UK is working;
- Incidences of bullying, harassment or discrimination;
- Unauthorised disclosure of confidential information;
Concerns should be raised as early as possible. Concerns may be raised verbally or, preferably, in writing or by email, giving any background and history, including relevant dates.
Who should blow the whistle?
Any individual who becomes aware of malpractice in any part of ICYE-UK has an obligation to report that conduct, and should do so as described using the procedure below. Anyone can report conduct under this policy: primary actors, staff members, trustees, volunteers, partner organisations and their employees or anyone else who is concerned, including members of the general public.
What is confidential whistle-blowing?
A whistle-blower may choose to reveal his or her identity when a report or disclosure is made. In this case, ICYE-UK will respect and protect the confidentiality of the whistle-blower, and gives an assurance that it will not reveal the identity of the whistle-blower to any third-party insofar as it is possible to do so (sometimes it is not possible to achieve this; for example, if something is being investigated by the police, or the court orders disclosure). An advantage for ICYE-UK of a confidential (as opposed to anonymous) report is that it is easier to investigate the report. Importantly, the ICYE-UK assurance of confidentiality can only be effective if the whistle-blower also maintains confidentiality.
What is anonymous whistle-blowing?
As an alternative to confidential reporting, a whistle-blower may choose not to reveal his or her identity. Although the whistle-blower is then sure about anonymity, this does make it harder for ICYE-UK 4 to investigate fully. ICYE-UK does not encourage staff or volunteers to make disclosures anonymously. An anonymous whistle-blower should be careful not to reveal his or her identity to a third party.
Protecting a Whistle-Blower
ICYE-UK’s systems to protect confidentiality and offer anonymity aim to keep a whistle-blower safe. To ensure the safety of whistle-blowers, ICYE-UK undertakes to treat all whistle-blowing reports as either confidential or anonymous. The choice between confidential or anonymous whistle-blowing is entirely that of the whistle-blower. Providing a matter of concern is raised in good faith (see the definition below), no action will be taken against the whistle-blower even if the concern turns out to be unfounded. It will be assumed that the report was made in good faith unless it can be clearly and demonstrably shown otherwise. However, reports which are malicious, knowingly untrue or made for personal gain are viewed as serious matters. An employee or volunteer who makes a report in respect of which bad faith is proven, is liable to disciplinary action, which may include dismissal. To be protected, reports must be made in good faith. Essentially, this means that the report must be made honestly for the purpose of allowing the concern to be addressed.
In addition, advice can also be obtained from outside ICYE-UK through the whistleblowing organisation, Protect. This organisation is UK based, but can provide advice on whistle-blowing from other countries: Telephone +44 (0)20 3117 2520 Email email@example.com
Whistle-blowing Procedure /How to report a concern
There will always be disagreements about the best way of doing something, and challenges will often be made to practices and decisions in working life. In order to assess if a matter should be reported under the whistle-blowing policy it may be helpful to go through the following questions:
- Does this feel right to me?
- Does it appear reasonable?
- Would I feel comfortable justifying this to public scrutiny?
If you answer ‘no’ to these questions, you should report the concerns. If you become aware, directly or indirectly, of a practice or incident which causes concern, there are two options available:
- Report through normal lines of management to the office manager for staff and to the volunteer co-ordinator for volunteers; or
- If this has already been done and no action has been taken, or if you feel unable to talk to your line manager, you may contact the trustee responsible for risk management (currently Keith Donnelly firstname.lastname@example.org ).
- If the concern is about a member of the Board of Trustees, contact the Office Manager. If the concern is about the Office Manager, contact the Chair of the Board of Trustees (currently Araceli Higueras email@example.com );
For concerns regarding safeguarding, it is not the responsibility of employees to decide whether or not abuse has taken place, however, concerns should be reported to the designated safeguarding officer/trustee (chair) who will initiate the procedure for dealing with suspected or actual incidents of abuse.
On receiving a report, an appropriate investigator will be appointed. The identity of the investigator will usually depend on the nature of the reported malpractice. For example, a financial irregularity might be investigated by the office manager, Treasurer or Risk Manager Trustee. Designated Safeguarding Officers will ensure that the appropriate reporting procedure is followed so that suspected or actual cases of abuse are responded to appropriately and consistently, referred to the relevant law enforcement agency and statutory authority and that support is given to the vulnerable individual. The person reporting the malpractice will be told the name of the investigator, how to make contact with him or her, and whether further help will be needed.
After investigating all the facts, the investigator will inform the whistle-blower of their decision on what action will be taken, which may be to do nothing or to follow the full disciplinary procedure. However, sometimes the need for confidentiality may prevent ICYE-UK giving them specific details of the investigation or any disciplinary action taken as a result. The whistle-blower should treat any information regarding the investigation as confidential. If the whistle-blower has reason to believe that their suspicion has not been properly investigated, or that some material facts have not been taken into consideration in the investigation, they should raise their concerns with the trustee responsible for risk management (currently Keith Donnelly firstname.lastname@example.org )
The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing at ICYE-UK. In most cases, a whistle-blower should not find it necessary to alert anyone outside ICYE-UK. The law recognises, however, that in some circumstances it may be appropriate for the whistle-blower to report concerns to an external body such as a regulator. However, ICYE-UK encourages individuals to report such concerns internally first.
If the whistle-blower believes that their concerns with the Board of Trustees have not been investigated properly or addressed they should report the problem to the charity commissioners – see: https://www.gov.uk/guidance/report-serious-wrongdoing-at-a-charity-as-a-worker-or-volunteer
The Global Whistle Blowing Policy will be reviewed every three years and updated when required, and the availability of updated versions will be communicated to staff and volunteers. It is the individual member’s responsibility to ensure they are complying with the most current version of the policy.