1. Policy Statement

Black London Advisory Service (BLAS) is committed to maintaining the highest standards of integrity, transparency, accountability, and ethical conduct.

BLAS recognises that employees, volunteers, trustees, contractors, and partners are often best placed to identify concerns about wrongdoing, risks, or unsafe practices.

This Whistleblowing Policy provides a safe and confidential mechanism for individuals to raise genuine concerns without fear of retaliation, victimisation, or disadvantage.

BLAS encourages a culture where speaking up is valued and where concerns are investigated fairly, promptly, and appropriately.

 

2. Purpose

The purpose of this policy is to:

• Encourage individuals to raise genuine concerns.

• Protect whistleblowers from retaliation.

• Provide clear reporting procedures.

• Ensure concerns are investigated appropriately.

• Promote accountability and good governance.

• Prevent misconduct, fraud, abuse, and harm.

 

3. Scope

This policy applies to:

• Board Directors and Trustees

• Employees

• Volunteers

• Advisors

• Consultants

• Contractors

• Temporary workers

• Agency workers

• Interns

• Partner organisations

It applies to concerns relating to BLAS activities, including:

• Governance

• Financial management

• Service delivery

• Client safety

• Legal compliance

• Employment practices

• Safeguarding

• Data protection

• Ethical conduct

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4. What is Whistleblowing?

Whistleblowing occurs when an individual raises a genuine concern about wrongdoing, malpractice, or risks affecting others or the organisation.

A whistleblower is someone who reports concerns in good faith.

Whistleblowing is different from:

• Personal grievances.

• Workplace disputes.

• Complaints about individual employment matters.

Employment-related concerns should normally be raised through the Grievance Procedure.

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5. Types of Concerns Covered

Examples of concerns that may be raised under this policy include:

Fraud and Financial Misconduct

Including:

• Theft.

• Financial abuse.

• False accounting.

• Misuse of organisational funds.

• Fraudulent claims.

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Corruption and Bribery

Including:

• Offering or accepting improper payments.

• Conflicts of interest being concealed.

• Abuse of authority.

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Safeguarding Failures

Including:

• Failure to protect children or vulnerable adults.

• Ignoring safeguarding concerns.

• Unsafe practices.

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Discrimination and Harassment

Including:

• Racism.

• Bullying.

• Harassment.

• Unequal treatment.

• Failure to address discrimination.

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Legal or Regulatory Breaches

Including:

• Breaches of legislation.

• Regulatory non-compliance.

• Serious policy failures.

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Data Protection and Cyber Security Concerns

Including:

• Unauthorised access to information.

• Data breaches.

• Misuse of confidential information.

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Health and Safety Risks

Including:

• Unsafe working conditions.

• Failure to manage risks.

• Serious hazards.

 

Abuse of Position

Including:

• Misuse of authority.

• Exploitation of clients.

• Personal benefit from BLAS activities.

 

6. Whistleblowing Principles

BLAS is committed to the following principles:

Protection

Individuals raising genuine concerns will be protected from retaliation.

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Confidentiality

Information will be shared only with those who need to know.

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Fairness

All concerns will be considered objectively.

 

Independence

Where appropriate, investigations will be conducted by someone independent of the concern.

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Accountability

BLAS will take appropriate action where wrongdoing is identified.

 

7. Protection for Whistleblowers

BLAS will not tolerate:

• Victimisation.

• Bullying.

• Harassment.

• Dismissal.

• Unfair treatment.

• Negative consequences because someone raised a genuine concern.

Any retaliation against a whistleblower may result in disciplinary action.

 

8. False or Malicious Reports

BLAS encourages genuine reporting.

However, knowingly making false, malicious, or deliberately misleading allegations may result in action under:

• Disciplinary procedures.

• Volunteer procedures.

• Contractual arrangements.

A concern raised honestly will not be penalised simply because it is not proven.

 

9. Confidentiality

BLAS will make every effort to protect the identity of whistleblowers.

Information may only be shared where:

• Investigation requires disclosure.

• Legal obligations apply.

• Safeguarding concerns exist.

• Authorities require information.

Individuals should avoid discussing investigations with unauthorised persons.

 

10. Anonymous Reports

BLAS accepts anonymous concerns.

However, anonymous reporting may limit:

• Ability to ask follow-up questions.

• Investigation options.

• Ability to provide feedback.

Individuals are encouraged to provide contact details where possible.

 

11. Reporting a Concern

Concerns may be raised through:

First Point of Contact

Normally:

• Line Manager.

• Chief Executive Officer.

• Designated Safeguarding Lead (where relevant).

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Serious Concerns

Concerns may be raised directly with:

• Chair of Trustees.

• Board Governance Committee.

Examples:

• Concerns involving senior leadership.

• Financial misconduct.

• Serious governance failures.

 

12. How to Raise a Concern

Individuals should provide:

• Nature of the concern.

• Background information.

• Dates and locations.

• Individuals involved.

• Evidence available.

• Any immediate risks.

Individuals are not expected to prove wrongdoing; they only need reasonable grounds for concern.

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13. Initial Assessment

The person receiving the concern will:

• Record the concern.

• Assess urgency and risk.

• Determine appropriate action.

• Confirm next steps where possible.

The concern may be:

• Investigated internally.

• Referred to another policy process.

• Referred externally where required.

 

14. Investigation Process

Investigations will:

• Be conducted fairly.

• Gather relevant evidence.

• Maintain confidentiality.

• Allow relevant parties to respond.

• Produce documented findings.

Investigations may involve:

• Interviews.

• Document reviews.

• Financial reviews.

• Policy reviews.

• External advice.

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15. Investigation Outcomes

Possible outcomes include:

• No action required.

• Recommendations for improvement.

• Additional training.

• Policy changes.

• Disciplinary action.

• Referral to external authorities.

Where appropriate, the whistleblower will be informed that action has been taken, while respecting confidentiality.

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16. External Reporting

Individuals may raise concerns externally where appropriate.

External organisations may include:

• Information Commissioner's Office (ICO).

• Health and Safety Executive (HSE).

• Charity Commission.

• Police.

• Local safeguarding authorities.

• Relevant regulators.

BLAS encourages individuals to raise concerns internally first where safe and appropriate.

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17. Safeguarding Concerns

Where concerns relate to:

• Child protection.

• Vulnerable adults.

• Abuse.

• Exploitation.

The matter will be handled under the Safeguarding Policy.

Immediate risks may require referral to statutory authorities.

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18. Financial Concerns

Concerns involving:

• Fraud.

• Financial abuse.

• Theft.

• Misuse of funds.

will be reported to the appropriate financial governance authority within BLAS.

The Treasurer and Board may be involved where necessary.

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19. Data Protection

Whistleblowing records will be handled in accordance with:

• UK GDPR.

• Data Protection Act 2018.

• BLAS Data Protection Policy.

Records will be:

• Securely stored.

• Access restricted.

• Retained appropriately.

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20. Responsibilities

Board of Directors/Trustees

The Board will:

• Promote a speak-up culture.

• Ensure whistleblowing arrangements exist.

• Review significant concerns.

• Ensure independence where required.

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Chair of Trustees

The Chair will:

• Receive concerns involving senior leadership.

• Ensure appropriate investigations.

• Report significant matters to the Board.

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Chief Executive Officer

The CEO will:

• Promote awareness.

• Support implementation.

• Ensure appropriate responses.

• Prevent retaliation.

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Managers

Managers will:

• Take concerns seriously.

• Escalate appropriately.

• Protect confidentiality.

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Employees and Volunteers

Everyone must:

• Report serious concerns.

• Cooperate with investigations.

• Maintain confidentiality.

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21. Training and Awareness

BLAS will ensure relevant individuals understand:

• What whistleblowing means.

• How to raise concerns.

• Protection available.

• Responsibilities under this policy.

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22. Monitoring and Reporting

BLAS will monitor:

• Number of whistleblowing concerns.

• Types of concerns raised.

• Outcomes.

• Lessons learned.

Significant issues will be reported to the Board.

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23. Review of Policy

This policy will be reviewed annually or sooner where:

• Legislation changes.

• Organisational structures change.

• Lessons are identified.

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24. Relevant Legislation and Guidance

This policy reflects:

• Public Interest Disclosure Act 1998

• Employment Rights Act 1996

• Enterprise and Regulatory Reform Act 2013

• Equality Act 2010

• UK GDPR

• Data Protection Act 2018

• Charity Governance Code principles

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25. Related BLAS Policies

This policy should be read alongside:

• Constitution & Governance Framework

• Code of Conduct Policy

• Complaints Policy

• Equality, Diversity & Inclusion Policy

• Anti-Racism Policy

• Safeguarding Policy

• Data Protection & GDPR Policy

• Financial Management Policy

• Fraud Prevention Policy

• Conflict of Interest Policy