How we will respond
Our response will depend on the nature of the concern raised and may be:
- advice only
- resolved by agreed action without the need for investigation
- investigated internally (by management, counter fraud and investigations team or other independent investigators)
- referred to the relevant safeguarding team (child protection or vulnerable adults)
- referred to the Police, if a criminal matter
- referred to the external auditor
- the subject of an independent inquiry
The officer receiving the whistleblowing allegation (if a major issue) will immediately notify the investigations team within corporate audit to include the disclosure on a central register.
We may carry out initial enquiries in order to protect individuals or employees and those accused of wrongdoing. We will use the results of these enquiries to decide whether an investigation is needed and if so, what form it should take. If urgent action is required this will be taken before we start any investigation.
The investigations team will follow up concerns of fraud, bribery or corruption. If there are other serious concerns of a potentially criminal nature, they will refer the complaint to our monitoring officer. They will determine whether:
- we should refer the concern to the Police directly or
- advise the complainant to make such a referral
If the monitoring officer decides that we should refer the matter to the Police, we will seek advice from the Police to establish:
- if a simultaneous internal investigation can be conducted
- whether or not they consent for the subject of the complaint to be informed of allegations
Our code of conduct requires employees to notify their line manager immediately of any criminal investigation. Failure to do so could result in disciplinary action being taken.
We will acknowledge your whistleblowing disclosure within five working days. Within the next 10 working days we will explain in writing how we propose to deal with the matter. The whistleblower will be:
- given an estimate of how long it will take to provide a final response
- told if initial enquiries have been made
- told if further investigation is required, and if not, why not (where appropriate)
- given details of support mechanisms
- advised of the investigating officer (where appropriate)
- advised how we will inform you of progress
The amount of contact between you and the officer considering your whistleblowing disclosure will depend on the nature of the concerns raised. For example, if further investigation is required, the investigator may need to seek additional information from you.
If a meeting is necessary, this can be held off site if you prefer. If you are an employee you will have a right to be accompanied by a union representative or work colleague (not involved in the area where the concern exists). If you are not an employee you may wish to bring a friend with you. A neutral venue can be arranged, where required.
We will help with any difficulties you may experience as a result of raising a concern. We will, for example, provide advice if you are required to give evidence for criminal or disciplinary proceedings. Sometimes whistleblowers have counter-allegations made against them. We have a duty to investigate any concerns that we receive and that will apply in these circumstances. However this will not detract from the principles, as set out in this policy, which govern how we will respond to whistleblowers. The over-riding objective will be to establish the truth.
We will retain records of all work carried out and actions taken to address the concerns raised by the whistleblower. This will include the investigator’s case file, where relevant. We will hold all files securely and confidentially, in accordance with our retention of records policy.
At the end of our investigations we will provide feedback to the whistleblower (if known) on actions taken and limited detail on the outcome of investigations. Feedback will be subject to legal constraints. However we recognise the importance of providing you with assurances that the matter has been dealt with properly.