Scripture Union's Whistleblowing policy (April 2022) is as follows…
Scripture Union is committed to maintaining high standards of openness, integrity, accountability and transparency as an organisation.
All organisations face the risk of things going wrong or of unknowingly harbouring malpractice. Scripture Union has a duty to identify and take measures to remedy all malpractice particularly with regard to issues of fraud and corruption.
This policy sets out the way in which individuals may raise a serious concern about wrongdoing or malpractice in the workplace in order to promote good governance and accountability in the public interest and to do so with confidence and without having to worry about being victimised, discriminated against or disadvantaged in any way as a result.
Scope of this policy
This policy applies to all employees and volunteers of Scripture Union England and Wales, including permanent and short-term employees as well as external consultants, contractors and agency staff whilst at Scripture Union.
This policy is concerned with the disclosure of information that is, or may be, in the public interest and is not intended to replace other Scripture Union policies which cover issues such as safeguarding, fraud or standards of behaviour at work. Before raising their concerns under this procedure, individuals should consider whether the matter is covered by another Scripture Union policy, such as the Safeguarding Policy, Anti-Fraud Policy, Complaints Policy or Grievance Policy.
If any individual is unsure whether their concern falls within the scope of the policy, they should contact the Whistleblowing Officer for a decision as to which is the appropriate procedure to apply.
What is whistleblowing?
Scripture Union considers whistleblowing to be the disclosure by a person, usually an employee or volunteer, to the public or those in authority of confidential information that relates to wrongdoing or malpractice in an organisation or workplace. Malpractice could be improper, illegal or negligent behaviour by anyone in the workplace.
A qualifying disclosure is one which, in the reasonable belief of the person making a disclosure, is in the public interest, such as:
- a criminal offence
- a failure to comply with any legal obligation
- abuse or exploitation of a child or adult at risk
- a miscarriage of justice
- a health and safety risk to an individual
- damage to the environment
- unacceptable fundraising practices
- a deliberate attempt to cover up any of the above
Raising a concern in the workplace
Scripture Union wishes to promote a culture of openness and therefore hopes that in most cases an individual will be able to raise any concerns with their line manager/volunteer team leader or the next more senior manager (up to Chair of Trustees) if it concerns the line manager. Wherever possible a written account of the concern should be provided. It is hoped that this will result in finding a quick and effective resolution. If the line manager considers that the concern should be referred to the Whistleblowing Officer, they will discuss this with the whistleblower before making the referral.
Where the matter is more serious or, having raised the matter with the line manager the individual considers that the concern has not been addressed, the individual should contact the Whistleblowing Officer.
It is not necessary for individuals who raise the concern to prove the wrongdoing or malpractice that is alleged to have occurred or is likely to occur. However, if an individual knowingly or maliciously makes an untrue allegation, this may constitute serious misconduct and Scripture Union may take appropriate disciplinary action against them.
Concerns relating to safeguarding
At Scripture Union, keeping children safe is of paramount importance, and the need to provide adequate care for children and young people is at the forefront of any of its activities. All trustees, staff, contractors and volunteers have a duty to report all safeguarding concerns and it is crucial that they do so. Safeguarding concerns should be reported through the safeguarding policies and procedures.
Protecting the individual raising the concern
If an individual raises a concern which they believe to be true or which they reasonably believe is something that requires investigation, Scripture Union will take appropriate action to protect the individual from any harassment, victimisation or bullying. Employees or volunteers who raise a genuine concern under this policy will not be at risk of losing their job/volunteer role, nor will it influence any unrelated disciplinary action or, in the case of employees, redundancy procedures.
The matter will be treated confidentially if the individual requests it and their name or position will not be revealed without their permission unless Scripture Union has to do so by law.
If the suspicions are not confirmed by an investigation, the matter will be closed. Staff and volunteers will not be treated or regarded any differently for raising the concern, and their confidentiality will continue to be protected.
How Scripture Union will deal with the concern
How the concern will be dealt with will depend on the nature of the matter raised. The Whistleblowing Officer (or an authorised nominee in their absence) will determine whether the matter should be:
- investigated and, if so, whether that investigation should take place under an existing procedure, and
- referred to the police, an external auditor or an independent investigator.
The outcome of an investigation under an existing internal procedure will be reported to the Whistleblowing Officer so that they may decide whether any further action should be taken.
The Whistleblowing Officer will carry out an initial assessment to determine the scope of any investigation and who should carry out the investigation.
The investigation will be conducted as sensitively and speedily as possible. The whistleblower will be given an opportunity to expand upon their concern and to address any questions that the person conducting the investigation may have in relation to their knowledge of any relevant events.
The findings of the investigation will be reported to the Whistleblowing Officer who will decide what action should be taken.
The Whistleblowing Officer will aim to keep the whistleblower informed of the progress of any investigation and its likely timescale and will inform the whistleblower of what action, if any, is to be taken, bearing in mind that the need for confidentiality may prevent disclosure of specific details.
When an individual makes a disclosure, Scripture Union will process any personal data collected in accordance with its Data Protection Policy. Data collected from the point at which the individual raises the concern will be held securely and accessed by and disclosed to individuals only for the purposes of dealing with the disclosure.