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Whistleblowing is reporting certain types of wrongdoing such as fraud or malpractice because you believe it is in the public interest to do so.

This could also include things such as suspecting someone’s health and safety is in danger, or malicious compromising of data.

If you raise a concern that is in the public interest, you cannot be victimised, given a formal warning, dismissed or suffer any other detriment just because you have raised the issue.

Our policy

Our whistleblowing policy aims to make sure you:

• feel confident about raising concerns about wrongdoing and about questioning and
  acting upon concerns
• know there are appropriate avenues to raise concerns and receive feedback on
  any action taken
• are given a response to concerns and are aware of how to continue pursuing the
  matter if they aren’t satisfied with that response, and
• feel reassured they will be protected from reprisal or victimisation if it is reasonable for
  them to believe that their concerns are genuine.

This policy covers all colleagues including employees, agency workers, secondees, interns,
contractors and consultants. It also applies to suppliers and members of the public.

Our principles

• You don’t need proof. All you need to do is to raise the issue as a genuine concern.
• You don’t have to investigate. It is our responsibility to do that.
• It may be something that has already happened, or is happening now, or you believe it is likely to happen in the future.
• It does not have to be in UK. You can ‘blow the whistle’ on something happening outside the UK.
• You must act reasonably. Making a deliberately false or malicious allegation is a serious matter and disciplinary action may be taken against you.

The reporting process

  1. As a first step, you can raise the issue with either the Chief Risk Officer or Chief People Officer.
  2. If you're unhappy with the outcome, or don't want to raise it with either the Chief Risk Officer or Chief People Officer you can go to another Executive Director or Chair of the Risk and Audit Committee. 
  3. If you still aren't happy you can raise the issue with the National Audit Office.
  4. In exceptional circumstances, where the issue is very serious, you can raise it outside the organisation to another body.
  5. Outside bodies include the Financial Conduct Authority, the Pensions Regulator and the H&S Executive.


If you raise a concern, you are kept informed of the progress of the investigation and given feedback on the outcome and how to appeal. The investigator may need to maintain confidentiality, so feedback might be general rather than specific.

We’ll act on the investigation’s findings where appropriate. If any misconduct is discovered, our disciplinary procedure and any appropriate external proceedings may be used to address the issue.


The Director of HR and OD will provide a quarterly update to the Chief Risk Officer, who will include in the report to the Risk and Audit Committee all concerns raised under the Whistleblowing Policy, and any action taken.