Whistleblowing policy

Why we have the policy

At Prostate Cancer UK, we’re committed to maintaining the highest standards of governance and enabling open and accountable management. Everyone has the right to raise genuine concerns, no matter who they are or what their circumstances are.

As a charity, we take pride in having an open culture guided by our values and behaviours. Our code of conduct is also important to us and we expect our people (everyone who works here, including employees, trustees, agency workers, volunteers, consultants and contractors) to follow it.

We’re here to listen and take all concerns raised by our people seriously and, as far as possible, treat them confidentially. We recognise that raising a whistleblowing concern can be daunting but encourage everyone to report concerns as soon as possible if you suspect wrongdoing, improper or illegal conduct is happening at work.

This policy explains how and when you should raise a concern, as well as the support and protection available to you when we do. It reflects the legal protection given to workers under the Public Interest Disclosure Act 1998. We place high importance on ensuring every person’s wellbeing is supported and protected, and that we’re all treated with the utmost dignity and respect.

Individuals reporting genuine concerns in good faith, will not suffer any detriment, unfair treatment or discrimination. We won’t tolerate any form of victimisation or harassment against a ‘whistleblower’ for raising concerns.

If you have a concern and it relates to:

• a personal grievance that is not in the public interest (for example, an allegation of bullying or harassment or an allegation that a contract of employment has been breached) you should raise this under our separate Grievance Procedure.
• someone being exposed to harm through abuse, exploitation or neglect, you should raise this under our Safeguarding Procedure.

If you’re unsure about which policy can best deal with your concern, you can speak to a member of the People Team.

Who it’s for

This policy applies to all colleagues whatever your role, seniority or length of service. Other individuals, including our contractors, subcontractors, suppliers and volunteers are also encouraged to follow the approach set out in this policy. We may update the policy from time to time.

Key definitions

Whistleblowing is the act of disclosing mismanagement, corruption, illegality, unethical practices or some other wrongdoing. Officially this is called ‘making a disclosure in the public interest’.

Examples of concerns may include:

• a criminal offence, for example, fraud
• someone’s health and safety is being put in danger or at risk
• risk or actual damage to the environment
• a miscarriage of justice
• unethical conduct
• the company is breaking the law or not complying with legal or regulatory obligations, for example, doesn’t have the right liability insurance
• a belief that someone is covering up any of the above

You can make a disclosure at any time; it can be about an incident that happened in the past, is happening now, or that we believe will happen in the near future.

It’s not necessary to prove the wrongdoing. However, to be protected by whistleblowing laws against detrimental treatment or dismissal, you must reasonably believe that wrongdoing (related to one of the categories listed above) is being, has been, or is likely to be committed and that your disclosure is in the public interest at the time you report it.

Personal grievances (for example bullying, harassment, discrimination) aren’t covered by whistleblowing law, unless a case is in the public interest. You should report these in accordance with our Grievance Policy or if you’d prefer to take a less formal approach you can use our Speaking Up form

A whistleblower is a worker who reports wrongdoing by making a disclosure in the public interest. They must reasonably believe that the wrongdoing is being, has been, or is likely to be committed to be protected by law for making the disclosure.

Public interest means the matter being disclosed must affect others such as the general public or colleagues.

Our commitment

At Prostate Cancer UK, we’re committed to enabling the reporting of concerns and ensuring that anyone who raises a concern is treated with respect and provided with support and protection.

Any colleague who raises a genuine concern, in good faith, will not be subjected to any detriment, unfair treatment, discrimination or be discouraged from raising concerns. If this does occur, the matter should be reported to a member of the People Team and/or a Leadership Team member in the first instance. As an alternative, matters can also be raised under our Grievance Procedure by the individual impacted.

If a colleague is subjected to mistreatment, discouraged from reporting concerns or a concern hasn’t been addressed satisfactorily, after following all the steps outlined in this procedure, you should contact one of the individuals below:

Director of People & Culture
Sharon Pavitt
[email protected]
020 3310 7024

Chief Executive
Laura Kerby
[email protected]
020 3310 7215

Chair of the Finance, Risk and Audit Committee
Caroline Artis
Caroline [email protected]

Chair of the Board of Trustees
Doris Olulode
[email protected]

Individual responsibilities

We all have a responsibility to report any genuine concerns or wrongdoing in line with this policy and encourage and enable others to do so, following the procedures set out here.

Discouraging an individual from raising or pursuing a legitimate whistleblowing concern will be treated as a disciplinary offence. If we find that an individual has knowingly raised false allegations this will also be treated as a disciplinary offence.

People manager responsibilities

People managers must:

• Safeguard and support team members and be responsible for listening to concerns and escalating them promptly and appropriately.
• Be familiar with relevant policies and proactively speak to the People Team for guidance where needed and as soon as possible where there are any significant issues.

Raising a whistleblowing concern

If you have a genuine concern relating to any type of wrongdoing that is covered under this policy, you should raise it with your line manager. If your concern relates to your line manager, or for any reason you don’t wish to approach your line manager, you should raise your concern with your Head of Department, a member of the Leadership Team, the People Team or one of the individuals listed in this policy.

We encourage you to be as open as possible about any issues however minor, so we can ensure that these are addressed appropriately, and we’re all supported. You should raise any issues with your manager or complete the Speaking Up form if you’d prefer to informally raise a concern in writing.

You can raise an initial concern verbally, but you should then follow it up in writing, setting out clearly the following information:

• the details of the suspected wrongdoing.
• the names of any individuals involved.
• what action (if any) you are seeking.

In some cases, you may be asked to attend a meeting to clarify the nature of the concern and provide further details. This will be arranged as soon as possible. You can bring along a colleague to this meeting if you wish. Where it is considered appropriate, a member of the People Team or other appropriate colleagues may also be present.

Confidentiality and anonymity

We want everyone to feel comfortable about raising a whistleblowing concern openly and actively encourage everyone to do so. When a concern is raised, confidentiality will be maintained as far as is possible. If we do need to reveal your identity to anyone, we will notify you beforehand. Equally, as individuals, we should not discuss concerns widely but only with those involved in supporting us or investigating the matter.

It is possible to raise a whistleblowing concern anonymously. This can be done via Tell Jane. We encourage anonymous reporting over remaining silent. Although we will investigate any concern that is reported anonymously as best we can, an anonymous report is likely to be more difficult for us to investigate and we will not be able to provide direct feedback.

Responding to a whistleblowing concern

The manager to whom a concern is raised, in collaboration with a member of the People Team and/or Leadership Team, will decide if an investigation is required and who the most appropriate person to conduct it is. Where possible, we’ll inform the person who has raised the initial concern, of the next steps and timeframe for this process.

If an investigation is required, we’ll respond in writing to confirm that we’re conducting an investigation, the next steps and the timescale for completion. The level of investigation and time this will take will vary depending on the nature of the suspected wrongdoing.

Following consideration of a concern, we’ll inform the individual promptly, in writing of the outcome of the process (along with any next steps or action that will be taken). Possible outcomes of the investigation may include, but are not limited to, no further action, internal formal action or further investigation by an external authority.

We aim to provide comprehensive feedback but this may not always be possible. Information regarding the conclusion of the matter or any resulting sanctions may be limited if the individual involved is a current employee, there are any data protection rules to apply, or there are sensitive issues that need to remain confidential.

Appeal

If an individual is not satisfied with how a concern has been dealt with, an appeal can be made in writing. The appeal should clearly set out the grounds of the appeal, ie. the basis on which the original concern is considered not to have been satisfactorily dealt with. The appeal process is not for adding additional allegations, these should be raised separately.

Details of who an appeal should be addressed to will be included in the outcome letter from the original concern (or can be addressed to one of the individuals named in this policy).

A relevant senior manager will consider the grounds for appeal and review the way the original whistleblowing concern was handled. If a meeting is needed, this will be arranged as soon as reasonably practical. The individual raising the appeal may bring a colleague if they wish. Where it is considered appropriate, a member of the People Team may also be present. The outcome from an appeal will be communicated promptly in writing.

Raising whistleblowing concerns externally

Aside from exceptional circumstances, we should raise whistleblowing concerns initially internally to enable us to reach a resolution without the need for third party involvement. If having followed the procedures, including an appeal, an individual feels that appropriate action has not been taken, this can be reported to the correct prescribed body or person (see list on GOV.UK).

Alerting the media to a concern, particularly before or during an internal investigation, is almost never justified or appropriate in any situation. We strongly discourage anyone from doing so and will treat any contact with the press as a serious disciplinary issue unless exceptional circumstances exist. Where the press is involved, this should be done with advice from a lawyer (or suitable external sources of information) as protection under whistleblowing laws continue only if certain conditions are met.

Sources of support and information

Employee Assistance Programme
Help and support is available to all colleagues through our employee assistance programme (EAP), Spectrum Life. We can speak to an independent adviser on a confidential basis about any issue that is troubling us. They provide friendly, impartial advice on a wide range of work and non-work-related matters 24 hours a day, 365 days a year.

Tell Jane
A safe place where we can report anything happening at work that we feel may be unfair or wrong, such as bullying, harassment or discrimination. It’s completely anonymous (if you want it to be) and they’re there to help us with guidance, advice and seeking a resolution.

Contact them via their chat function on their website, using the their contact form or call their free Hotline on 0800 689 0802

Other external sources of information:
Protect: speak up, stop harm (Independent whistleblowing charity)
Helpline: 020 3117 2520

Charity Commission
Telephone: 0300 066 9197
Email: [email protected]

Citizens Advice
Adviceline (England): 0800 144 8848