Whistleblowing Policy

What is whistleblowing?

Whistleblowing is the term used when a person passes on information concerning wrongdoing. In this guidance, we call that “whistleblowing reports” or “raising concerns”.

Our Policy

Whitwam Ltd wants to encourage a trusting and supportive environment for all our members, employees, clients, suppliers and wider stakeholders. Whitwam Ltd takes malpractice or misconduct seriously and is committed to a culture of openness, trust, and respect in which every stakeholder can report legitimate concerns and be assured of protection against victimisation.

Any person that raises concerns under this policy can be assured that any matter raised will be investigated thoroughly, promptly and confidentially, and the outcome of the investigation reported back to the person who raised the concern.

The Whitwam Ltd Code of Governance states that:

“There should be a documented whistleblowing procedure for the members, workforce, and stakeholders to raise concerns in confidence and – if they wish – anonymously. The board should routinely review the procedure and any concerns raised and ensure a policy is in place to ensure proportionate and independent investigation and follow up.”

We will listen to whistleblowing reports, treat them seriously, and try to resolve them as quickly as possible and learn from them so that we can continuously improve.

The purpose of this policy is:

  • To enable Whitwam Ltd to act quickly against any potential malpractice to ensure it conducts its business with the highest standards of integrity and honesty at all times;
  • To identify risks that Whitwam Ltd may not know about;
  • To remind members, employees, clients, suppliers, wider stakeholders and the public to speak out in confidence if they have concerns and to be assured that they do not need to provide evidence for their concerns to be raised; and
  • To raise awareness of the importance of preventing and eliminating wrongdoing at work. Members, [employees], [clients], [suppliers] and wider stakeholders should be watchful for illegal or unethical conduct and report anything of that nature that they become aware of.
  • To reassure any person raising concerns will be protected from possible reprisals or victimisation having made a disclosure in good faith;
  • To highlight that there are other routes to raise concerns if a person feels that they cannot speak up

This policy and procedure sets out how Whitwam Ltd will deal with whistleblowing contacts from its members, employees, clients, suppliers wider stakeholders and the general public.

What types of concerns are covered?

  • Conduct which is an offence or a breach of law, including but not limited to corruption, fraud or bribery
  • A miscarriage of justice
  • An act creating risk to health and safety
  • An act causing damage to the environment
  • The unauthorised use of public funds or other financial irregularities
  • Sexual or physical abuse
  • Other unethical conduct
  • Concealment of any of the above

This Policy cannot be used to question financial, or business decisions taken by Whitwam Ltd, and nor should it be used to reconsider any personal grievances such as bullying, harassment and discrimination which are not covered by whistleblowing legislation. In such cases our Whitwam Ltd.’s Grievance Policy should be consulted instead. If you are unclear which policy, you should use please speak to your line manager or the Managing Director.

If you are unsure about whether or how to raise a concern or want confidential advice about raising concerns about serious malpractice at work, you can contact the independent charity ‘Protect’, see here for contact details.


Whitwam Ltd will ensure that all concerns raised will be treated in confidence and every effort will be made not to reveal your identity if you so wish. At the appropriate time, however, we may ask you to come forward as a witness. This policy encourages you however to provide your name and contact details on your concern whenever possible, if you do not do so we are unable to go back to you for further information, which can make investigating the concerns that were raised difficult.

Please note that you:

  • Must disclose the information in good faith
  • Must believe it to be substantially true
  • Must not act maliciously or make false allegations
  • Must not seek any personal gain.
  • Whitwam Ltd recognises there may be matters that cannot be dealt with internally and external authorities will need to become involved. Where this is necessary we reserve the right to make such a referral without an individual’s consent.

Protection From Detriment

Wrongdoing reported by an employee will typically, (although not necessarily), be something they have witnessed at work.

With regards to employees, Whitwam Ltd will ensure the Public Interest Disclosure Act 1998 is applied in all cases. This policy does not form part of an employee’s contract of employment and may be amended or withdrawn at any time.

Whitwam Ltd commits that no individual who makes a report under this policy will be subjected to any detriment as a result, in accordance with the Employments Rights Act 1996.

  • In the event that a person believes they are being subjected to a detriment by any other person within [ Whitwam Ltd] as a result of their decision to disclose, they must inform the Whistleblowing Officer or contact the whistleblowing hotline on [insert telephone number] and appropriate action will be taken to protect them from any reprisals.
  • If any person tries to discourage another employee from coming forward to express a concern, or criticises or victimises them after a concern has been raised, he or she may be subject to formal disciplinary action
  • We will do everything possible to maintain confidentiality. However, there may be circumstances where the information may need to be discussed or disclosed to third parties, including other employees of Whitwam Ltd, in order that the information may be properly investigated or as part of any disciplinary or criminal proceedings
  • Individuals qualify for whistleblower protection provided the disclosures made have a connection to the wider public interest.

Untrue Allegations

If an individual makes an allegation or raises concerns in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. In making a disclosure the individual should exercise due care to ensure the accuracy of the information. If, however, an individual makes malicious or vexatious allegations, and particularly if they persist with making them, action may be taken against that individual.

Resolving concerns and complaints 

As with many other organisations, most concerns that are raised can be quickly resolved through either a telephone call or email to one of the Whitwam Ltd team. We prefer to receive complaints in writing so if you make a complaint in person or over the phone you may be asked to follow this up in an email.

We keep a record of all correspondence relating to whistleblowing and the final outcome. We may report instances of whistleblowing to our Board of Directors and members but will never provide details of the content of the complaint or the complainant.

Any person raising concerns under this policy can expect to be treated with courtesy, respect and fairness at all times. We expect that you will also treat our staff dealing with your concern with the same courtesy, respect and fairness. We will deal with your concern promptly and will not treat you less favourably than anyone else because of your sex or legal marital or same-sex partnership status: this includes family status, responsibility for dependants, and gender (including gender reassignment, whether proposed, commenced or completed); sexual orientation; colour or race (this includes ethnic or national origin or nationality); disability; religious or political beliefs, or trade union affiliation or any other unjustifiable factors, for example language difficulties, age, pregnancy and maternity.

If you feel your complaint has not been resolved to your satisfaction, you will be provided with an opportunity to escalate the complaint within a reasonable timeframe. The process for escalation is provided in the Complaints Procedure below.

Policy Owner

The current owner of this policy is the Managing Director, Buz Ross, who is responsible for reviewing the policy at every three years from date of last approved version.

A confidential log of all concerns raised will be kept by the managing Director and anyone involved in any concern raised will retain all relevant correspondence until after the completion of an investigation and all escalation routes have been exhausted, and the outcome of any investigation has been reported to the person who raised the concern.

Whistleblowing Procedure

If it is not possible to resolve your concerns informally or if you consider the matter is too serious to be handled informally, you can follow the formal procedure.

You should email your concerns to Buz.Ross@Whitwam.ltd.uk with ‘WHISTLEBLOWING’ included in the email title or complete the Whistleblowing form here. Buz Ross will contact you to acknowledge receipt of your concerns

To help ensure your concerns are addressed as soon as possible please provide as much information as possible as missing or inaccurate information can lead to a delay. For your concerns to be reviewed, it is important the following information is supplied:

  • Your full name and department
  • Date that the concern is raised
  • A summary of your concerns
  • Details of any witnesses or supporting evidence
  • Details of steps you have taken to resolve this matter informally.

What happens next 

In normal circumstances, you can expect your contact to be acknowledged within 48 hours of receipt and to receive a response to it within 5 working days.

Dependent upon the nature of the concerns raised, your concerns may be escalated by the Managing Director or another member of the Whitwam Ltd Leadership team.

The Managing Director will arrange an investigation into the concern raised and will appoint an appropriate person to undertake the investigation. This may be any member of the Leadership Team – they will be named the Investigating Officer.

The investigation may involve the employee, member or stakeholder and any other individuals involved giving a written statement. Any investigation will be carried out in accordance with the Policy set out above. The statement of the person raising concerns will be considered, and they will be asked to comment on any additional evidence obtained. The Investigating Officer will then report to the Management Team, which will take any necessary action, including reporting the matter to any appropriate government department or regulatory agency.

If disciplinary action is required, the Investigating Officer will report the matter to the relevant line manager and start the disciplinary procedure.

On conclusion of any investigation, the person who raised concerns will be told the outcome of the investigation and what Whitwam Ltd has done, or proposes to do, about it. If no action is to be taken, the reason for this will be explained.