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Whistleblowing Policy

Depending on your start date this policy may be contractual.

Latest review: April 2024

Policy statement

Our objective at HALO is to uphold the highest standards of conduct and ethics in all areas of our work and to comply with local legislation. In line with this commitment, we ensure that anyone who has a serious concern of wrongdoing is encouraged to come forward to raise those concerns following the proper channels.

Every employee (past or present) has the right to raise an issue in the full knowledge that they will be taken seriously and can do so without fear of reprisal or adverse treatment. It is important that we uphold our values and as such, we adhere to the following statements and principles regarding this policy: -

  • Every employee is able to confidentially highlight or raise a wrongdoing, made in good faith, even if they turn out to be mistaken.
  • The Director of HR has overall responsibility for the Whistleblowing Policy and undertakes periodic reviews of the policy and updates this document to reflect organisational changes, best practice, operational experience and/or legislative updates that may be required from time to time.
  • The Whistleblowing Policy does not form part of anyone鈥檚 contract of employment and is not intended to replace any other statutory reporting procedures operated by HALO.
  • In order to ensure we are continuously seeking ways to improve; we will keep records of whistleblowing activity so that we can determine any patterns or work procedures that require addressing.
  • All disclosures will be handled timeously and will be conducted through proportionate assessments or investigations.
  • We encourage early resolution where appropriate, but where this is not possible, we will aim to conclude matters within an agreed timeframe.
  • We offer support and protection to all those who legitimately raise a concern or who are directly involved in a concern that has been raised.
  • The people who conduct investigations will have appropriate skills, experience, and knowledge and, be impartial / independent to the investigation in order to avoid any conflict of interest.
  • We will meet timescales whenever possible and ensure that action points are implemented swiftly.
Scope

This Policy applies to all to all employees (past and present) including, contracted staff, trainees and those on apprenticeships as well as agency workers.

This policy is a practical document and therefore might be changed or added to from time to time, to take account of lessons learned and any updated government legislation.

It is our intention to adhere to all relevant laws and regulations. The support of all employees is also necessary to achieve compliance with these laws and regulations.

Procedure

If any employee reasonably believes that a policy, practice, or activity of HALO is in violation of an applicable law or regulation, or if they believe that someone has behaved in a manner that breaches our Code of Conduct or other polices, they have a duty to report this, using one of HALO鈥檚 reporting channels.

Complaints are either dealt with by the Director of HR (lisa.davidson@halotrust.org), or if they are of a safeguarding nature will be overseen by the Global Safeguarding Lead, (xara.church@halotrust.org).

Under UK legislation, complaints of a whistleblowing nature refer to any of the following matters:

  • A criminal offence, including but not limited to;
    • Financial wrongdoing
    • Sexual exploitation, abuse, sexual harassment or child abuse
    • Bullying or harassment
    • Modern slavery
    • Radicalisation or extremism.
  • A miscarriage of justice;
  • An act creating such risk to health and safety which is not subject to reasonable controls measures;
  • An act causing unnecessary or illegal damage to the environment A breach of any other legal obligation;
  • Fraudulent reporting or misreporting of performance data; or
  • Concealment of any of the above
Whistleblowing options

If an employee suspects that HALO or any of its employees are in breach of the above points, there are a number of Whistleblowing options available to them within and external to HALO:

If the matter can be quickly resolved through HALO鈥檚 early resolution process (see below), then the Line Manager will communicate as such to all parties concerned.

Should the early resolution process not be applicable, then the matter or concern must be directed to HALOs Director of HR, the Global Safeguarding Lead or alternatively through Safecall or to the HALO Trustees.

Any employee who raises a concern in good faith based on the above, will be protected from disciplinary action, even if the concern turns out to be a mistake or untrue.

It is the duty of every HALO employee who believes there has been a failure to comply with an applicable law, regulation, or clearly established HALO policy to bring this to the attention of HALO鈥檚 Management Team, so that we will have a reasonable opportunity to investigate and correct the matter as appropriate.

For the avoidance of doubt, this policy will not apply in the event of any employee who has not followed this policy and who makes an unauthorised disclosure, discussion or contact with the press in relation to any HALO matter whatsoever.

All Disclosures will be assessed on receipt by an independent Investigation Team or person appointed by HALO who will make an initial determination as to whether the Disclosure merits a further formal investigation or can be resolved quickly and correctly through the early resolution process.

Early resolution

Where possible and appropriate the Director of HR and/or the appointed HALO Investigations Team will seek to resolve concerns raised by way of early resolution. The early resolution process is intended for simple and straightforward issues raised that can be dealt with effectively within 20 working days.

Formal investigation process

On matters that require extensive assessments and/or investigations, the whistleblowing concern will be conducted predominantly internally by an independent investigations team wherever possible unless on rare occasions where it is appropriate to appoint an external service to conduct such an investigation. A Standard Operating Procedure will guide this process.

Those appointed to investigate the whistleblowing concern raised, will have the appropriate skills and experience to carry out the investigation and produce a report with appropriate due care and diligence

Depending on the nature of the Disclosure, it may not be possible to share much, if any, information. This may particularly be the case where a Disclosure investigation uncovers other matters which also require investigation.

However, wherever is possible, updates on any process directly related to the raised concern will be communicated where appropriate to all parties concerned.

In some instances, to ensure an effective investigation, the employee who raised the concern may asked to attend a meeting in order for the investigations team to gain further insight into the Disclosure. However, participation in such a meeting is subject to the nature of the Disclosure and will not take precedence over the well-being of the individual concerned.

All individuals called upon to participate as a witness in an investigation are required to co-operate fully with the Investigation Team as far as is possible and will be given a reasonable timeframe in order to respond to such a request. Their engagement with the investigation process will include an on-going risk assessment to ensure their safety and well-being.

Witnesses and anyone who supports a witness during an interview must observe the confidentiality requirements of this policy and not divulge or discuss any information relating to the investigation with anyone other than each other. Any breaches of confidentiality will be subject to separate disciplinary processes.

HALO encourages early resolution where possible and where this is not possible, timescales relating to formal investigations will be subject to the recommendations as put forth by the Investigations Team.

It is important that Whistleblowers do not start to investigate a concern they are raising, this could place people at risk of harm. They are required to report what they know, in good faith.

Read more HALO policies