This policy aims to provide guidance of what constitutes whistleblowing and how to raise those concerns.
This policy aims to encourage Workers who have whistleblowing concerns to share such concerns as soon as possible. The policy also provides guidance of what constitutes whistleblowing and how to raise those concerns.
This policy applies to all society employees (permanent or temporary), trustees, consultants, contractors, volunteers, casual workers or agency workers acting on behalf of the society.
The British Psychological Society (the “society”/ “we”) aims to conduct its activities with honesty and integrity and we expect our Workers to maintain the same high standards.
We recognise, however, that there may be occasions when we – or our people - do not get this right.
A culture of openness and accountability is essential in order to prevent such situations occurring and to address them when they do occur. We aim to provide an open, transparent and safe working environment where Workers feel able to speak up if they have serious concerns.
Who this policy applies to
This policy applies to everyone who works for the society and volunteers with the society.
This means employees of the society, trustees, consultants, contractors, volunteers, casual or agency workers acting on behalf of the society and the reference to the capitalised term “Workers” shall refer to such individuals either collectively or individually in accordance with the context of this policy.
Nothing in this policy is intended to change, or shall be interpreted as changing, the legal status of any individual, whether as employee, worker, volunteer or otherwise, in relation to the society.
The aims of this policy are to:
(a) Encourage Workers who have whistleblowing concerns of the type set out in section 2 below, to share such concerns 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) Provide Workers with guidance of what constitutes whistleblowing and how to raise those concerns.
(c) Reassure Workers that if they raise genuine concerns under this policy they will not under any circumstances be subjected to any form of detriment or disadvantage as a result of having raised their concerns even if they turn out to be mistaken.
This policy does not form part of any employee's contract of employment and we may amend it at any time following a review of the policy.
This policy will apply in cases where a Worker genuinely believes that one of the following set of circumstances is occurring, has occurred or may occur within the society and that it is in the public interest for the Worker to disclose it.
The matters which may be disclosed in this way (“whistleblowing concerns”) fall into one or more of the six categories of wrongdoing set out below.
A disclosure relating to any of these will be a “protected disclosure”.
(1) A criminal offence (including fraudulent and corrupt behaviour e.g. fraud or malpractice)
(2) a failure to comply with any legal obligation
(3) a miscarriage of justice;
(4) an act (or omission) creating risk to health and safety
(5) an act causing damage to the environment;
(6) the deliberate concealment of any of the above matters.
It is not necessary for a Worker to have proof that such an act is being, has been or is likely to be committed.
A Worker does, however, need to hold a reasonable belief of such action having been, being or likely to be carried out.
The society encourages Workers to raise concerns in accordance with this policy.
The society reserves the right to investigate whether Workers are properly raising concerns in accordance with this policy.
If, following investigation of the concerns raised, it is concluded that the allegations were made maliciously or with a view to personal benefit, disciplinary action may be instigated against the person making the allegations.
This policy is only to be used in the circumstances as outlined in section 2 above.
There are a number of society policies that will be relevant in other circumstances.
In particular, this policy should not be used for complaints relating to an employee’s own personal circumstances, such as the way they have been treated at work and in these instances the grievance procedure may be more appropriate.
Matters related to bullying and harassment are addressed by the society’s Dignity at Work Policy.
If Workers are in doubt about the procedure to follow Workers may wish to contact the Head of Legal and Governance, the Human Resources department or the Advisory, Conciliation and Arbitration Service (ACAS) for guidance.
4.1 Raising a concern
If a Worker wishes to raise a whistleblowing concern, the earlier it is done the better.
A Worker may raise a whistleblowing concerns by telephone, in person or in writing.
Every incident will be treated sensitively and will be fully investigated.
In the first instance, a Worker should contact their line manager or if a volunteer providing services to the society, the departmental director with overall responsibility for the services, either by approaching them in person or putting their concerns in writing.
It may be possible to agree a way of resolving concerns quickly and effectively.
However where an Worker’s concern relates to actions of
- Their line manager, they should contact their department director.
- The Worker’s department director, they should contact the Chief Executive.
- The Chief Executive, they should contact the Chair of the Board of Trustees.
- A trustee or the Board of Trustees collectively, they should contact the Head of Legal and Governance who will refer the matter appropriately for consideration externally
We will arrange a meeting with the Worker as soon as possible to discuss the concern.
The Worker may bring a colleague or union representative to any meetings under this policy.
The companion must respect the confidentiality of their disclosure and any subsequent investigation.
We will take down a written summary of the Worker’s concern and provide them with a copy after the meeting.
We will also aim to give the Worker an indication of how we propose to deal with the matter.
4.2 Investigation and Outcome
Once a Worker has raised a concern, we will carry out an initial assessment to determine the scope of any investigation.
We will inform them of the outcome of our assessment.
A Worker may be required to attend additional meetings in order to provide further information.
In some cases we may appoint an investigator or team of investigators including individuals with relevant experience of investigations or specialist knowledge of the subject matter.
The investigator(s) may make recommendations for change to enable us to minimise the risk of future wrongdoing.
Appropriate steps will be taken to ensure that a Worker’s working relationships are not prejudiced by the fact of disclosure of whistleblowing concerns.
We will aim to keep the Worker informed of the progress of the investigation and its likely timescale.
However, sometimes the need for confidentiality may prevent us giving specific details of the investigation or any disciplinary action or other action taken as a result.
Workers should treat any information shared with them about the investigation as strictly confidential.
If the concerns raised relate to the actions of a trustee or the Board of Trustees, we would normally appoint an independent external investigator to consider the concerns which have been raised.
4.3 Confidentiality and disclosure
We hope Workers will feel able to voice whistleblowing concerns openly under this policy.
However, if a Worker wants to raise their concerns confidentially, we will make every effort to retain their anonymity.
If it is necessary for anyone investigating a concern to know the identity of a Worker, we will discuss this with them first.
We do not encourage Workers to make disclosures anonymously.
Proper investigation may be more difficult or impossible if we cannot obtain further information from a Worker.
It is also more difficult to establish whether any allegations are credible.
If a Worker is concerned about possible reprisals if their identity is revealed they should raise this when they report their concerns or as soon as possible thereafter.
4.4 If Workers are not satisfied
Whilst we cannot always guarantee the outcome Workers are seeking, we will try to deal with concerns expressed under this policy fairly and in an appropriate way.
By using this policy, Workers can help us to achieve this.
If a Worker is not happy with the way in which the Employee’s concern has been handled, Workers can raise their concern in writing to the Chief Executive or if they are implicated in a Worker’s concerns, with the Chair of the Board of Trustees who will refer the matter appropriately for review.
4.5 External Disclosures
The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the society.
In most cases a Worker should not find it necessary to alert anyone externally and we strongly encourage Workers to exhaust the internal processes set out about in the first instances.
In exceptional or urgent circumstances, however, or where, having made a disclosure, a Worker is unhappy with the outcome, the Worker may make a disclosure to prescribed bodies such as a regulator.
It will very rarely, if ever be appropriate, to alert the media.
Prescribed bodies include but are not limited to:
- The Charity Commission
- HM Revenue & Customs
- The Health and Safety Executive
- The Financial Services Authority
- Institute for Apprenticeships and Technical Education
We strongly encourage Workers to seek advice before reporting a concern to anyone external to the society.
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:
Advice Line: 02074046609 or 02031172550
Email: [email protected]
Whistleblowing concerns usually relate to the conduct of our Workers, 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 a Worker if the Worker raises the matter with the third party directly.
However, we encourage Workers to report such concerns internally first in accordance with this Policy.
4.6 Protection and support for whistleblowers
It is understandable that whistleblowers are sometimes worried about possible repercussions.
We aim to encourage openness and will support Workers who raise genuine whistleblowing concerns in good faith under this policy, even if they turn out to be mistaken.
The law expressly states that employees or workers (persons who have an agreement with the society to do work or perform services for payment) will not suffer any detrimental treatment or disadvantage as a result of raising a concern.
Detrimental treatment includes dismissal, disciplinary action, threats, ceasing to use the services of the whistleblower or other unfavourable treatment connected with raising a concern.
If an employee or worker believes that they have suffered any such treatment, they should raise it with their line manager, departmental director or a senior manager as appropriate.
If an employee believes they have suffered any such treatment and their concerns are not resolved they may raise these formally using our grievance procedure.
Employees or workers must not threaten or retaliate against whistleblowers in any way.
If employees or worker are involved in such conduct they may be subject to disciplinary action (if they are an employee) or the cessation of their services (if they are a worker).
In some cases the whistleblower may also have a right to sue individuals personally for compensation in an employment tribunal.
Please note that this protection is only available to employees or workers and does not apply to Workers unless they are an employee or worker, as defined in employment legislation.
4.7 Procedure for recording Whistleblowing Concerns
A central record of whistleblowing concerns will be maintained by the Legal and Governance department.
The record will include the areas of society business that have been affected, a summary of action taken, the outcome, any follow-up and feedback provided.
We will reflect upon the outcomes from any disclosures which are made under this policy even if they are not upheld and we will look at how we can improve our ways of working to ensure that we improve the transparency and safety of our working environment going forwards.
Board of Trustees
Date of last review
5 November 2021
Next review due
5 November 2024