Whistleblowing Policy and Procedures

Version:	Review date:	Approved by:	Comments:
1.0	September 2021	Dr Maryam Abubakar	Next Review: September 2022
2.0	September 2022	Dr Maryam Abubakar	Next Review: September 2023
2.0	September 2023	Dr Maryam Abubakar	Next Review: September 2024
2.0	September 2024	Dr Maryam Abubakar	Next Review: September 2025
2.0	June 2025	Dr Maryam Abubakar	Next Review: June 2026

Introduction

Whistleblowing is the term used when you report something you see or have found out about that you consider to be wrong. In most cases this can be reported to your line manager. If you cannot or do not wish to do this for any reason, then you should follow the procedure set out below.

Policy Statement

Camford Medicals is committed to ensuring an open culture with the highest standards of honesty and accountability. This policy is designed to allow employees to disclose information that they believe constitutes a wrongdoing, without being penalised in any way for doing so.

Scope

This policy and the procedures apply to all directors, managers, employees, apprentices, workers and anyone else who has a contract to carry out work for us personally. It does not apply to genuinely self-employed contractors who run a profession or business on their own account.

Procedures

Camford Medicals recognises that raising concerns about wrongdoings can be one of the most difficult and challenging things to do in a work environment. Under this policy you may come forward with legitimate concerns without fear of being blamed or of any reprisal. You will not be disadvantaged for raising what you consider to be a legitimate concern.

What wrongdoings should be raised?

If you genuinely believe that we, or any of our employees have taken, are intending to take or have failed to take action that you reasonably believe could lead or amount to:

a failure to comply with any legal obligations
a criminal offence that has been, is being or is likely to be committed
unauthorised or inappropriate disclosure, misuse or loss of confidential, personal and/or sensitive information
a miscarriage of justice
bribery or financial fraud
risk or damage to the environment
a danger to the health and safety of employees or others
attempts to supress or hide information or evidence relating to a wrongdoing in any of the areas above.

The Public Interest Disclosure Act 1998 provides protection for workers who reasonably believe that they are acting in the public interest, where the concern (disclosure) is covered under one of the areas above. The concern can be about an incident that happened in the recent past, is happening now or that you believe is likely to happen in the near future. Concerns over personal issues such as a complaint against another employee should be raised using the appropriate company procedure, likely to be either the Grievance Policy, Bullying and Harassment Policy or the Code of Business Conduct, as such, complaints are not in the public interest.

Can I raise a concern anonymously?

Anonymous reporting is discouraged as it may prevent us obtaining further information in relation to the concern raised and prevent a full investigation from taking place. You can make a protected disclosure where we will assure you of confidentiality unless we are required to disclose your identity by law.

How do I raise a concern?

If possible, you should raise your concern internally. This can be reported verbally or in writing to any manager, senior manager or director within Camford Medicals, if you feel unable to discuss the concern with your line manager. You should provide as much detail as possible, including anything you have witnessed, any evidence you have obtained and the dates and times of incidents occurring, as appropriate. If you attend a meeting you can bring a companion with you, if you wish, for moral support.

If you really feel you are unable to raise your concern internally you may make a disclosure to a relevant regulatory authority. This information will be available publicly from Camford Medicals. The matter will be fully investigated with you, and with other people that you believe are involved with or connected to the suspected wrongdoing, by an appointed independent investigating officer who may be internal or external to Camford Medicals.

What will happen next?

The person you have raised the concern with will listen to you and consider the concern(s) you have raised and decide what, or if, further action is needed. You will be informed who else may need to be spoken to. Generally, the Registered Manager will need to be informed and they will consider any actions to be taken.

Where possible you will be kept informed about the actions which are proposed or are being taken. This may not always be possible where we are under a duty to protect the confidentiality of any other people that are involved.

If you do not feel your concern has been dealt with appropriately you may address any concerns you have about the way the matter has been dealt with or, if you disagree with the outcome, with the Managing Director.

Giving you support

It is understandable that employees may feel that they will be ‘singled out’ for making a disclosure that they believe to be in public interest. We will take every step to ensure that if you raise a legitimate concern you will be protected and supported. We may take appropriate action against any person found to be:

victimising another person for using this procedure (please tell a member of the management team if you think you have been victimised, or raise it formally under the grievance procedure if the matter is not remedied)
deterring any person from reporting genuine concerns under this procedure. If you think you have been deterred, you can raise the matter formally under the grievance procedure (if the matter is not remedied).

If we find that people have done either of the above, we may take disciplinary action against them, which may result in their dismissal. If we find that you have made a disclosure of false or misleading information under this Policy maliciously, for personal gain, or otherwise in bad faith then our investigation may potentially result in us taking disciplinary action against you, which may lead to your dismissal

Additional support

If you need more support, you can contact the Protect advice line either online or via telephone. This is a charity which offers free expert advice to whistleblowers. Their telephone number is: 020 3117 2520 (Lines open Mon, Tue, Thurs: 9:30am – 1pm, 2pm – 5:30pm; Wed, Fri: 9:30am – 1pm) Alternatively an online contact form can be completed via their website https://protect-advice.org.uk/

Status of this policy

This policy does not give contractual rights to any employees. Camford Medicals reserves the right to make amendments to or change the content of the policy at any time. Any changes will be communicated to all workers.

Monitoring

Monitoring of incidents raised under this policy will be via a Whistleblowing Incident Log. This will be reviewed on a monthly basis.

Related policies and procedures

Bullying and Harassment Policy and Procedures

Complaints and Compliments Policy and Procedures

Confidentiality Policy and Procedures

Duty of Candour Policy and Procedures

Grievance Policy and Procedures

Safeguarding Policy and Procedures

Legislation and Guidance

Public Interest Disclosure Act 1998

From the Government website: https://www.gov.uk/government/publications/whistleblowing-guidance-and-code-of-practice-for-employers

Compliance

Safe	S2: How are risks to individuals and the service managed so that people are protected and their freedom is supported and respected.
Well-led	W1: How does the service promote a positive culture that is person-centred, open, inclusive and empowering.