Whistle-Blowing Policy

Policy statement

The Healing Hubs Charity is committed to conducting its business ethically, legally, and with integrity. This policy provides a safe, confidential route for staff, volunteers, trustees, contractors, and other stakeholders to raise concerns about wrongdoing, abuse, or risks affecting the charity, service users, or public funds. No one will be punished or disadvantaged for raising a genuine concern in good faith.

Scope

Applies to: all employees (including temporary or fixed-term), volunteers, trustees,  contractors, and partner organisations delivering services on behalf of The Healing Hubs Charity.

Covers concerns about wrongdoing, including but not limited to: criminal activity, fraud, safeguarding concerns, mismanagement of resources, unsafe practices, breaches of legal or regulatory obligations, corruption, discrimination, sexual harassment, or any activity putting beneficiaries at risk.

Principles and rights

·  Duty of care: protect beneficiaries, staff, and volunteers from harm.

·  Non-retaliation: individuals raising concerns in good faith will be protected from retaliation, dismissal, or other detrimental treatment.

·  Confidentiality: concerns will be treated confidentially to the extent possible, consistent with legal obligations and the need to investigate.

·  Accessibility: clear, straightforward reporting channels; support available for reporters who need it.

·  Accountability: all concerns will be acknowledged, investigated appropriately, and outcomes reported to the appropriate governance level.

Definitions

·  Whistleblowing: the act of reporting concerns about illegal, unethical, or improper conduct within the charity or its activities.

·  Protected disclosure: a disclosure made in the manner described in this policy and meeting the criteria of a qualifying disclosure (UK whistleblowing protections apply when the disclosure relates to wrongdoing and is in the public interest).

What may be reported

·  Criminal activity or suspected fraud

·  Breaches of law, regulation, or fundraising standards

·  Financial mismanagement or misuse of funds

·  Safeguarding concerns (the safeguarding policy provides a separate route; whistleblowing can be used for reporting concerns about safeguarding failures)

·  Health and safety risks

·  Discrimination, harassment, or bullying

·  Corruption, bribery, or conflict of interest

·  Data protection and misuse of personal information

·  Environmental or safeguarding risks to volunteers or beneficiaries

Reporting channels (the 'whistleblowing route')

Primary route (internal):

Report in the first instance to your line manager or supervisor where possible.
If the concern involves your line manager, or you prefer not to go to them, report to the Designated Safeguarding Lead (DSL) or Chair of Trustees.
Reports can be made verbally or in writing (email or a confidential form) and should include: nature of concern, who is involved, when/where it occurred, and any evidence.

Secondary route (independent/anonymous):

If internal routes are not appropriate or you fear retaliation, use the charity’s whistleblowing contact point: [Whistleblowing Email/Address], or contact the Chair of Trustees directly.
External route (where applicable): you may raise concerns with relevant authorities (e.g., local safeguarding boards, the Charity Commission, or the Financial Conduct Authority) if you believe there is a significant risk or illegality and internal channels have failed or are inappropriate.

In cases of immediate risk or criminal activity, contact emergency services or local police as appropriate.

Receiving and handling disclosures

·  All disclosures received will be treated seriously, acknowledged promptly, and handled confidentially.

·  The person handling the whistleblowing report will be trained to manage investigations in line with this policy.

·  Initial assessment will determine whether a formal investigation is required, what safeguarding actions are necessary, and who will be involved.

Protection from retaliation

·  The charity will not tolerate retaliation or discrimination against anyone who raises concerns in good faith.

·  If retaliation occurs, staff should report it to the DSL, Chair of Trustees, or the independent whistleblowing contact.

·  Remedies may include protective measures, changes to duties, or support as appropriate and proportionate.

Investigation process

·  Purpose: establish facts, assess risk, and determine appropriate corrective action.

·  Timeliness: investigations will be initiated promptly and completed with appropriate urgency; the length of investigation will depend on complexity but will be communicated to the reporter and relevant stakeholders.

·  Scope: may include interviews, document review, and consultation with external regulators if required.

·  Records: all investigations will be recorded, including evidence considered, findings, and actions taken.

·  Outcomes: actions may include policy updates, training, disciplinary action, reporting to external authorities, or other remediation measures.

·  Privacy: individuals involved will be informed of the outcome where appropriate, while respecting confidentiality and data protection requirements.

Data protection and confidentiality

·  Personal data collected under this policy will be processed in line with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

·  Information will be stored securely, accessed only by authorised individuals, and retained for as long as necessary for the purpose of the investigation and legal/regulatory requirements.

·  Anonymised summaries may be used for learning and governance purposes.

Roles and responsibilities

Trustees/Board:

Ensure the whistleblowing policy is implemented, reviewed, and publicly available.
Ensure independence of investigations and oversee governance of the whistleblowing process.

Designated Safeguarding Lead (DSL) and/or Chair of Trustees:

Receive and acknowledge disclosures; oversee investigations arising from whistleblowing.
Coordinate response, including liaison with internal teams and external authorities as required.

Managers and Supervisors:

Handle initial concerns, maintain a safe culture, support reporters, and protect staff from retaliation.
Ensure appropriate action is taken and keep records of concerns raised and actions taken.

All staff, volunteers, and contractors:

Familiarise themselves with the policy, report concerns promptly, and cooperate with investigations.
Maintain professional conduct and support a safe work environment.

Training and awareness

·  All staff, volunteers, and trustees will receive training on whistleblowing policy and procedures as part of induction.

·  Refresher training will be provided at least every 2 years, or sooner if policy is updated or regulatory requirements change.

·  Training will cover what constitutes a qualifying disclosure, how to report, protection against retaliation, and the investigation process.

Records and documentation

·  A centralised, secure log of whistleblowing disclosures (without unnecessary detail) will be maintained by the DSL/Chair of Trustees.

·  Documentation will include dates, channel used, summary of concerns, actions taken, and final outcomes.

·  Records will be kept in line with the charity’s data retention policy and legal requirements.

Public communications and anti-retaliation stance

·  This policy and the grievance/whistleblowing channels will be clearly communicated to beneficiaries, staff, volunteers, and partners.

·  The charity commits to fostering an open culture where concerns can be raised safely without fear of negative consequences.

Monitoring, review, and continual improvement

·  The Board of Trustees will receive an annual whistleblowing report summarising: number of disclosures, types of concerns, outcomes, and trends.

·  The policy will be reviewed at least every two years or sooner if laws or guidance change, or after significant incidents.

·  Feedback from staff, volunteers, and beneficiaries will be sought to improve the process.

Related policies and procedures

·  Safeguarding Adults Policy

·  Complaints Policy

·  Data Protection and GDPR Policy

·  Anti-Bullying/Anti-Harassment Policy

·  Equal Opportunities and Diversity Policy

·  Code of Conduct and Professional Boundaries

Last Reviewed: April 2026