Whistleblowing Policy

Whistle Blowing Policy

About this policy

The Society is committed to conducting its business with honesty and integrity, and we expect all staff to maintain high standards. However, all organisations face the risk of things going wrong from time to time, or of unknowingly harbouring illegal or unethical conduct. A culture of openness and accountability is essential in order to prevent such situations occurring and to address them when they do occur.

The purpose of this policy is:

(a)         To encourage colleagues to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected.

(b)         To provide colleagues with guidance as to how to raise those concerns.

(c)         To reassure colleagues that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.

This policy has been endorsed by USDAW.

This policy does not form part of any contract of employment or other contract to provide services, and we may amend it at any time.

Who does this policy apply to?

This policy applies to all employees, officers, consultants, self-employed contractors, casual workers, agency workers, volunteers and interns.

The Society’s Childcare business has a separate whistleblowing policy and accompanying flowchart given its unique regulatory environment and the importance of reporting childcare safeguarding concerns without delay through the appropriate route. Colleagues in Childcare should refer to the separate whistleblowing policy which is available to them.

Who is responsible for this policy?

The Audit and Risk Committee, acting on behalf of the board of directors (the Board) has overall responsibility for the effective operation of this policy, and for reviewing the effectiveness of actions taken in response to concerns raised under this policy.

The Society Secretary and Head of Governance has day-to-day operational responsibility for this policy and you should refer any questions about this policy to them in the first instance.

This policy will be reviewed at least every other year and amended as and when required. 

What is whistleblowing?

Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work.

This may include:

(a)         criminal activity;

(b)         failure to comply with any legal obligation or regulatory requirements;

(c)         danger to the health and safety of any individual;

(d)         damage to the environment;

(e)         bribery under our Bribery and Fraud Policy;

(f)          facilitating tax evasion contrary to our Anti-facilitation of Tax Evasion Policy;

(g)         serious financial fraud or mismanagement;

(h)         health and safety breaches likely to endanger any individual;

(i)           modern slavery or human trafficking;

(j)           sexual harassment;

(k)         miscarriages of justice; and

(l)           the deliberate concealment of any of the above matters.

A whistleblower is a person who raises a genuine concern relating to any of the above. If you have any genuine concerns related to suspected wrongdoing or danger affecting any of our activities (a whistleblowing concern) you should report it under this policy.

Colleagues may have less serious concerns that do not amount to a whistleblowing concern. The How to Report a concern page LINK sets out the different ways in which colleagues can raise concerns. They are by either:

(a)         discussing it informally with your line manager;

(b)         raising a formal written grievance;

(c)         contacting the external ‘speak in confidence’ website so the concern can be considered by a member of the Senior Leadership Team; or

(d)         raising a whistleblowing concern in accordance with this policy.

4.4            This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work. In those cases you should use our Grievance Policy LINK.

Raising a whistleblowing concern

In many cases you will be able to raise any concerns with your line manager informally. They may be able to agree a way of resolving your concern quickly and effectively. If your concern relates to your line manager, you should raise it with a more senior manager.  Where the concern relates to serious suspected wrongdoing or dangers at work (such as the examples of whistleblowing concerns above), your line manager/more senior manager may refer the matter to the Society Secretary and Head of Governance in accordance with this policy.

However, where the matter is more serious, or you feel that your line manager has not addressed your concern, or you prefer not to raise it with them for any reason, you should raise it with the whistleblowing line, which is monitored by the Society Secretary and Head of Governance. Contact details are set out at the end of this policy.

The Society Secretary and Head of Governance will instigate an investigation into the whistleblowing concern. Depending on the details of the concern, it may be possible to investigate it based on the information provided. Alternatively, it may be necessary to arrange a meeting with you to discuss your concern in more detail. Where a meeting(s) is held, you may bring a colleague or union representative. Your companion must respect the confidentiality of your disclosure and any subsequent investigation.

Where a meeting to obtain further details is necessary, the Society will take down a written summary of your concern and provide you with a copy after the meeting. We will also aim to give you an indication of how we propose to deal with the matter.

A flowchart setting out how to report a whistleblowing concern is set out here.

Confidentiality

We hope that colleagues will feel able to voice whistleblowing concerns openly under this policy. However, if you want to raise your concern confidentially, we will make every effort to keep your identity secret. If it is necessary for anyone investigating your concern to know your identity, we will discuss this with you.

We do not encourage colleagues to make disclosures anonymously, although we will make every effort to investigate anonymous disclosures. You should be aware that proper investigation may be more difficult or impossible if we cannot obtain further information from you. It is also more difficult to establish whether any allegations are credible. Whistleblowers who are concerned about possible reprisals if their identity is revealed should come forward to the Society Secretary and Head of Governance. If you are in any doubt, you can seek advice from Protect, the independent whistleblowing charity, who offer a confidential helpline. Their contact details are at the end of this policy.

Investigation and outcome

Once you have raised a concern, we will carry out an initial assessment to determine the scope of any investigation. We will inform you if we need further information from you, whether by email/phone or a meeting.

In some cases we may appoint an investigator, who may also be a colleague with relevant experience of investigations or specialist knowledge of the subject matter. The investigator may make recommendations for change to enable us to minimise the risk of future wrongdoing.

The Society Secretary or the person appointed to investigate the matter will aim to keep you informed of the progress of the investigation and when it has concluded. However, sometimes the need for confidentiality may prevent us giving you specific details of the investigation, an outcome or any disciplinary action taken as a result. You should treat any information about the investigation as confidential.

If we conclude that a whistleblower has made false allegations maliciously, the whistleblower will be subject to disciplinary action.

If you are not satisfied

While we cannot always guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way. By using this policy, you can help us to achieve this.

If you are not happy with the way in which your concern has been handled, you can raise it again with the Society Secretary and Head of Governance. Alternatively, you may contact the Chair of the Audit and Risk Committee. Contact details are set out at the end of this policy.

External disclosures

The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally.

The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. It will very rarely if ever be appropriate to alert the media. We strongly encourage you to seek advice before reporting a concern to anyone external. The independent whistleblowing charity, Protect, operates a confidential helpline. They also have a list of prescribed regulators for reporting certain types of concern. Their contact details are at the end of this policy. Alternatively you may wish to seek advice from your Trade Union before making any external disclosure.

Whistleblowing concerns usually relate to the conduct of colleagues, but they may sometimes relate to the actions of a third party, such as a customer, supplier or service provider. In some circumstances the law will protect you if you raise the matter with the third party directly. However, we encourage you to report such concerns internally first, in line with this policy. To do so, you should contact your line manager or the Society Secretary and Head of Governance.

Protection and support for whistleblowers

It is understandable that whistleblowers are sometimes worried about possible repercussions. We aim to encourage openness and will support colleagues who raise genuine concerns under this policy, even if they turn out to be mistaken.

Whistleblowers must not suffer any detrimental treatment as a result of raising a concern. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Society Secretary and Head of Governance or your line manager immediately. If the matter is not remedied, you should raise it formally using our Grievance Policy.

You must not threaten or retaliate against whistleblowers in any way. If you are involved in such conduct you may be subject to disciplinary action.

The Society partners with GroceryAid who offer a range of support to colleagues, including a confidential support and counselling hotline, should you need it.  Their contact details are set out at the end of this policy.

Contacts

Whistleblowing hotline (the Society Secretary and Head of Governance)	Edward Parker 0800 458 7809 edward.parker@midcounties.coop
Chair of the Audit and Risk Committee	Paul.mather@midcounties.coop
Speak in Confidence (for concerns where it wouldn’t be appropriate to raise a grievance or contact the whistleblowing hotline)	Website: https://secure.workinconfidence.com/company/en/signin
Protect (Independent whistleblowing charity)	Helpline: 020 3117 2520 Website: https://protect-advice.org.uk
GroceryAid	Telephone: 08088 021 122 Details of services: Colleague Connect Link

 

APPENDIX 1

Policy review dates – log

 

Below is the formal log of the Policy’s review dates at Audit & Risk Committee meetings:

 

Protocol review dates	Comments
6 April 2021	Minor amends
4 April 2022	Minor amends
12 September 2024	Refreshed policy

 

Next review date: By Sept 2026