Whistleblowing Policy

1. Introduction

New Meaning Training (NMT) is committed to the highest possible standards of service provision and to full accountability for those services. In line with that commitment, employees are encouraged to come forward and voice any concerns they may have about NMT work. This policy document makes it clear that employees can do so without fear of reprisals and is intended to encourage and enable them to raise serious concerns within NMT rather than overlooking a problem or “blowing the whistle” outside.
The policy applies to all employees.

Public Interest Disclosure Act 1998

This act protects workers who make protected disclosures about wrongdoing. It makes provision about the kind of disclosures which may be protected; the circumstances in which the disclosures are protected; and the persons who may be protected.

Provide routes for staff to raise concerns and receive feedback on any action taken.
Reassure staff that they will be protected from possible reprisals or victimisation.
- This policy does not replace the NMT Complaints procedure. There are also existing procedures in place relating to Discipline, Grievance, Capability director/confidential reporting/policy document etc. The NMT Whistleblowing Policy is intended to cover concerns that fall outside the scope of these procedures, such as malpractice or wrongdoing.
- Thus, any concern that you may have regarding a suspicion of malpractice or wrongdoing in any aspect of the NMT provision, or the conduct of staff within NMT, or others acting on behalf of NMT, can and should be reported under this policy. Employees are expected to report malpractice and wrongdoing and may be liable to disciplinary action if they knowingly or deliberately do not disclose information relating to malpractice or wrongdoing.

- - The responsibility for the effectiveness and efficiency of this policy rests with the Board of Directors.

Certain disclosures are prescribed by law as “qualifying disclosures”. A “qualifying disclosure” means a disclosure of information that the employee genuinely and reasonably believes is in the public interest and shows that NMT has committed a “relevant failure” by:

Criminal offences including fraud, bribery and corruption, money laundering etc.;
Theft, whether petty or serious;
Breach of statutory regulations, health / safety regulations which may result in danger of the health and safety of our employees;
Breach of the organisation’s rules and regulations or unethical practice in financial reporting, accounting controls;
Dishonesty;
Miscarriage of justice;
Any attempts to cover up or the concealment of any of the above.
- Employees must reasonably believe that the disclosure is “in the public interest”. We encourage you to use this policy to raise any such concerns.
- Should the concern not meet the requirement to be a qualifying disclosure, you should raise this under the NMT Grievance Policy. Where a concern is raised under the Whistleblowing Policy where it is not appropriate to do so, ie it relates to a personal grievance, the receiving manager will confirm that the matter will be addressed under the NMT Grievance Policy.
- If an individual is not sure whether to raise a concern, they should discuss the issue with their Line Manager or the Peoples Manager.
- However, if we conclude that a whistle-blower has made false allegations, maliciously, the whistle-blower may be subject to disciplinary action.

Staff are protected in law by the Public Interest Disclosure Act, which gives employees protection from detriment and dismissal where they have made a protected disclosure, providing the legal requirements of the Act are satisfied.

Concerns expressed anonymously are much less powerful, but they will be treated with caution and considered at the discretion of NMT. In exercising this discretion, the factors to be considered would include:

The seriousness of the issues raised.
The credibility of the concern; and director/confidential reporting/policy document.
The likelihood of obtaining the necessary information and confirmation of the allegation.

First, raise the concerns with your Area Manager or the Peoples Manager. The most appropriate person to contact will depend on the seriousness and sensitivity of the issues involved and who is thought to be involved in the malpractice. For example, if you believe that the Area Manager is involved in the matter of concern, or the normal channels of communication are inappropriate for some reason, you should approach the Director of NMT or the Chair of the Board.
Although concerns may be raised verbally, they are better put in writing (see Appendix 1). It should set out the background and history of the concern giving relevant names, dates and places where possible, and the reason why the situation is of concern.
The earlier a concern is expressed; the easier it is to take appropriate action.
Advice and guidance on how matters of concern may be pursued can be obtained from the Area Manager or Director of NMT.
NMT will investigate the complaint. Depending upon the circumstances, NMT may (or may not) provide feedback to the complainant.

This policy is intended to provide employees and other persons with an avenue to raise concerns within NMT and it is hoped that this will be the option taken in the first instance. NMT hopes this will be sufficient. While we cannot guarantee that we will respond to all matters in the way that you might wish, we will handle the matter fairly and properly. By using this policy, you will help us to achieve this. If you are unhappy with our response, you can contact Protect on 020 3117 2520 or whistle@protect-advice.org.uk. If needed, Protect will be able to advise you on the circumstances in which you may be able to contact an outside body safely.
Wider disclosures (for example, to the police, media and non-prescribed regulators) may be protected under the Act, but only where certain conditions apply. If you report your concern to the media, in most cases you will lose your whistleblowing law rights. If you are considering a wider disclosure, you should first seek advice about your rights and responsibilities, by contacting Protect.

Whistleblowing Disclosure
Employee name:
Investigating staff member:
Statement

Please confirm why you believe your complaint to fall within the remit of the Whistleblowing Policy.

By signing this form, you confirm that you are making this disclosure in line with our whistleblowing policy and understand that this matter will be dealt with under this procedure.
Employee Signed:
Date:

Investigating staff member signed:
Date: