Whistleblowing Policy

Walsall Community Active Projects CIC

Company number 17051741

Whistleblowing Policy

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1. Statement of Intent

Walsall Community Active Projects CIC is committed to working honestly and openly. We expect everyone associated with us to maintain high standards in all that we do. If something is going wrong, we want to know about it so we can put it right.

This policy explains how staff, volunteers, trustees, partners, participants and members of the public can raise serious concerns about wrongdoing in our organisation, and how those concerns will be handled.

2. What is Whistleblowing?

Whistleblowing is when a person raises a concern about wrongdoing or risk that affects others. It is different from a personal complaint or a grievance about your own treatment, which are dealt with through our Complaints Procedure or Grievance Procedure.

Whistleblowing is protected under the Public Interest Disclosure Act 1998 (PIDA). A person who raises a genuine concern in the public interest is legally protected from being treated unfairly as a result.

3. What You Can Raise as a Whistleblowing Concern

Examples include:

• Fraud, theft or financial irregularity
• Misuse of funds, assets or resources
• Safeguarding concerns that are not being properly handled
• Serious breaches of health and safety
• Bullying, harassment or discrimination by people in positions of trust
• Criminal offences, past, present or planned
• Failure to comply with legal duties
• Damage to the environment
• Serious breaches of data protection
• Deliberate concealment of any of the above

4. Our Promise

If you raise a genuine concern, we will:

• Take it seriously
• Treat it confidentially as far as possible
• Investigate it fairly
• Keep you informed of progress and outcomes, within the limits of confidentiality
• Protect you from any unfair treatment, victimisation or dismissal
• Treat any retaliation against a whistleblower as a serious disciplinary matter

5. Confidentiality and Anonymous Concerns

We will try to keep your identity confidential if you ask, although in some cases we may need to share information to investigate properly or because the law requires it. We will discuss this with you first wherever possible.

We accept anonymous concerns, but they are harder to investigate, and we may not be able to give you feedback. We strongly encourage you to give your name.

6. Good Faith and Malicious Concerns

We protect anyone who raises a concern they reasonably believe to be true, even if it turns out to be mistaken. We do not protect concerns raised maliciously, dishonestly or for personal gain. False or malicious whistleblowing may be treated as a serious disciplinary matter.

7. How to Raise a Concern Internally

In most cases, concerns should be raised first with the Founder. If the concern involves the Founder, you should raise it with the Chair of the Board or another trustee.

You can raise a concern:

• In person
• By phone
• By email
• In writing

It helps if you can give:

• A clear description of the concern
• Dates, times and places
• Names of anyone involved or who may have witnessed it
• Any supporting evidence

You can bring a trusted friend, colleague, family member or union representative for support.

8. How Concerns Are Handled

On receiving a concern, we will:

• Acknowledge it in writing within 5 working days
• Carry out an initial assessment within 10 working days
• Decide on appropriate next steps, which may include an internal investigation, referral to a regulator or referral to the police
• Keep the whistleblower informed of progress
• Complete most investigations within 8 to 12 weeks, depending on complexity
• Share findings and actions, as far as confidentiality allows

9. Raising a Concern Externally

If you do not feel able to raise a concern internally, or if you have raised it internally and you do not believe it has been addressed properly, you can go directly to a 'prescribed person' under PIDA. These include:

• The CIC Regulator (for governance concerns about a CIC)
• The Information Commissioner's Office (data protection)
• The Health and Safety Executive
• HMRC (tax and payroll fraud)
• Action Fraud and the police
• Local authority designated officers (safeguarding)
• Charity Commission (charity partnerships)
• Funders (concerns about misuse of grant funds)

For free, confidential advice, you can contact the whistleblowing charity Protect on 020 3117 2520 or at protect-advice.org.uk.

10. Support During and After

Raising a concern can be stressful. We will:

• Offer regular check-ins with a trusted contact
• Signpost you to confidential support where helpful
• Take swift action if you experience any form of retaliation
• Treat the person who is the subject of the concern fairly too, with support where appropriate

11. Roles and Responsibilities

Board of Directors

• Promotes the policy and a culture of openness
• Receives anonymised reports on whistleblowing activity
• Reviews this policy annually

Founder / Whistleblowing Officer

• Receives and handles whistleblowing concerns
• Decides on investigation routes and external referrals
• Reports to the Board

All Staff and Volunteers

• Speak up if they see or suspect wrongdoing
• Cooperate with any investigation
• Treat the process and those involved with respect

12. Records and Data Protection

We will keep records of all whistleblowing concerns securely, separately from personnel files, in line with our Data Protection Policy. Records will be retained for at least 6 years, longer where the matter is serious.

13. Training and Promotion

All staff, volunteers and trustees will be made aware of this policy at induction. Refresher training will be provided every two years. The policy will be available on our website and in our staff handbook.

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Policy Review

This policy was adopted on 14 February 2026 and will be reviewed annually, with the next scheduled review in February 2027. It will also be reviewed earlier if there are significant changes in legislation, guidance, or our activities.

All staff, volunteers and trustees will be made aware of any updates and asked to confirm they have read and understood the revised version.

Signed on behalf of the Board