Donate

Whistleblowing Policy

CCJ Whistleblowing Policy 

‘Whistleblowing’ Procedure

Reporting Illegal and Improper Conduct

Procedure and Guidance for Staff

 

 

The Council of Christians and Jews (CCJ) is committed to being open, honest and accountable. It encourages a free and open culture in its dealings between the Trustees and those working with the charity, both employees and volunteers.    

This policy aims to help the Trustees and employees/volunteers to raise any serious concerns they may have about colleagues or their employer with confidence and without having to worry about being victimised, discriminated against or disadvantaged in any way as a result.    

It is written in the context of the Public Interest Disclosure Act 1998 which protects employees who ‘blow the whistle’ on malpractices within their organisation. 

 

 

BACKGROUND: What is whistleblowing? 

The legal definition of whistleblowing is a disclosure of information that, in the reasonable belief of the whistleblower, is made in the public interest and tends to show that: 

  • A criminal offence has, is or is likely to be committed; 

  • A person has, is or is likely to fail to comply with any legal obligation; 

  • A miscarriage of justice has, is, or is likely to occur; 

  • The health or safety of any individual but in particular; children, vulnerable adults or the elderly has, is, or is likely to be endangered; 

  • The environment has, is, or is likely to be damaged; or 

  • Information falling within any of the above paragraphs has or is likely to be deliberately concealed. 

A disclosure can be made to various people, including the employer, the Charity Commission, other regulators and potentially the press. 

It is not necessary for individuals who raise the concern to prove the wrongdoing that is alleged to have occurred or is likely to occur. 

However, if an individual knowingly or maliciously makes an untrue allegation (e.g.: in order to cause disruption to The Charity), The Charity (CCJ) will take appropriate disciplinary action against them.  This may constitute gross misconduct. 

Individuals should note that they will not be protected from the consequences of making a disclosure if, by doing so, they commit a criminal offence. 

This policy does not deal with any complaints staff may have about their employment.   This should be dealt with through the charity’s Grievance Procedure. 

The charity’s Anti-Bullying and Harassment policy offers protection to workers against harassment, bullying and discrimination. 

Volunteers (or members) should make complaints or raise concerns through the Volunteer Complaints Procedure. 

 

 

1. INTRODUCTION 

1.1 CCJ (The Council of Christians and Jews) expects the highest standards of conduct from all employees and will treat seriously any concern that an employee may have about illegal or improper conduct. 

1.2 Employees will be expected, through agreed procedures and without fear of recrimination, to bring to the attention of the co-Directors any serious impropriety or breach of procedure. 

1.3 This procedure is based on the model policy drawn up by Yavneh College and Hertfordshire Local Authority which was produced in consultation with the trade unions and professional associations. 

 

2. WHAT IS THE PURPOSE OF THE PROCEDURE? 

2.1 The procedure is designed to enable employees to notify the Co-Directors of any reasonable suspicion of illegal or improper conduct. The procedure requires all employees to act responsibly to uphold the reputation of the charity and to help maintain public confidence. 

2.2 It is a procedure in which the Co-Directors will be expected to act swiftly and constructively in the investigation of any concerns in accordance with the charity’s disciplinary procedure. 

2.3 Concern about a colleague’s professional capability should not be dealt with using this procedure. 

 

3. WHEN SHOULD IT BE USED? 

3.1 This procedure is not designed to replace or be used as an alternative to the charity’s grievance procedure, which should be used where an employee is only aggrieved about his/her own situation. Employees who are worried about wrongdoing at work do not necessarily have a personal grievance. 

3.2 Employees must act in good faith and must have reasonable grounds for believing the information to be accurate. 

3.3 No employee who uses this procedure in good faith will be penalised for doing so. The charity will not tolerate harassment and/or victimisation of any employee raising concerns. 

3.4 An employee who is not sure whether the conduct he/she is concerned about does constitute illegal or improper conduct or is unsure about how to proceed can contact any of the names listed in section 7 for advice. 

3.5 Financial regulations require any employee who suspects fraud, corruption or other financial irregularity to ensure this is reported to the Chair of the Finance Committee for possible investigation. Normally you must first report any suspicion of such an irregularity to the Co-Directors, who will in turn report it to the Chair of the Finance Committee. 

3.6 If a concern is regarding the Chair of the Finance committee this should be raised with the Chair of the Trustee Board.  

 

4. MECHANISM FOR RAISING CONCERNS 

4.1 Where the issue concerns a co-Director or having made your report, you believe they have failed to take appropriate action, then you should bring it to the attention of the Chair of Trustees. 

4.2 Where an issue concerns the Chair of Trustees this should be brought to the attention of the Vice Chairs or the Chair of the Finance Committee.  

4.2 Employees who feel unable to follow this route, for whatever reason, have the option of contacting one of the names listed in section 7. 

4.3 Depending on the nature of the concern the complainant will be asked to justify and support their claim. Normally the complainant will be asked to do this in writing. It will therefore be helpful to note down any facts and dates as they happen. 

4.4 Employees who want to use the procedure but feel uneasy about it may wish to consult their trade union initially and bring a friend or trade union representative along to any discussions, so long as the third party is independent of the issue. 

4.5 Where anonymity is requested efforts will be made to meet the request where appropriate but that might not always be possible. The earlier and more open the expression of concern the easier it will be to take appropriate action. 

4.6 Each case will be investigated thoroughly with the aim of informing the complainant of the outcome of any investigation as quickly as possible. 

4.7 The matter be referred to the police, other agencies such as Social Services, an external auditor or an independent investigator. 

4.8 It may be necessary for the individual to give evidence in criminal or disciplinary proceedings. 

4.9 The charity will give the individual feedback on the progress and outcome of any investigation wherever possible. If the suspicions are not confirmed by an investigation, the matter will be closed.  Staff will not be treated or regarded any differently for raising the concern, and their confidentiality will continue to be protected. 

 

5. WHAT SHOULD BE DONE IF AN ISSUE IS RAISED WITH A SENIOR MEMBER OF STAFF? 

5.1 If a senior member of staff (other than a co-Director) is approached by a colleague on a matter of concern as defined in this document, they should be advised to take the matter to the Co-Directors. 

 

6. EXAMPLES OF ILLEGAL AND/OR IMPROPER CONDUCT 

  • fraudulent or improper use of the charity’s money or assets 

  • abuse of employees or volunteers 

  • dangerous practices at work 

  • corruptly receiving any gift or advantage 

  • allowing private interests and those of the charity to conflict. 

 

7. NAMES TO CONTACT (see 3.4 and 4.2) 

Or any of the following professional association representatives or your trade union: 

Protect (Whistleblowing Advice) Limited 

This charity is an independent authority on public interest and whistleblowing.   It promotes compliance with the law and good practice.   They also aim to influence public policy and legislation. 
https://protect-advice.org.uk/  

 

ACAS 

The Arbitration Conciliation & Advisory Service website provides guidance on whistleblowing for both employers and employees 
www.acas.org.uk/index.aspx?articleid=1919 

 

Direct.Gov 

Information on whistleblowing can be accessed through the government websites. 
www.gov.uk/whistleblowing/overview  

 

The Chartered Institute of Personnel and Development (CIPD) 

CIPD is the professional body for those involved in the management and development of people. They have a factsheet on whistleblowing. 
      www.cipd.co.uk/subjects/empreltns/whistleblw/whistle.htm 

  

______________________________________________________________________________ 

POLICY APPROVED:  31st August 2023 

POLICY DUE FOR REVIEW: August 2025 or should any legislative change come about before this date.