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Whistleblowing policy

How to raise a concern

3.1  When an individual wishes to raise a concern, he or she will need to identify the issues carefully. They must be clear about the standards against which they are judging practice. Whilst not exhaustive they should consider the following:

  • Is it illegal?
  • Does it contravene professional codes of practice?
  • Is it against government guidelines?
  • Is it against the council’s guidelines?
  • Is it about one individual’s behaviour or is it about general working practices?
  • Does it contradict what the employee has been taught?
  • Has the individual witnessed the incident?
  • Did anyone else witness the incident at the same time?

3.2  Concerns from employees should normally be raised with their immediate manager. Similarly, non-employees (e.g. agency workers or contractors) should raise a concern with their contact within the council, usually the person to whom they directly report.
3.3  In some cases, the nature or sensitivity of the concern means that this may not always be appropriate. If a person feels they cannot raise their concern with their immediate manager they are able to go directly to the interim internal audit manager (see paragraph 3.12), or the named contacts at the beginning of this policy. They may also do so if, having raised a concern with the immediate manager/contact, they feel there has not been an appropriate response.
3.4  Others wishing to raise a concern should consider using the council’s complaints procedures by emailing ways for raising concerns can be found on the council’s website, or by ringing 0344 980 3333.
3.5  Given the possible contractual issues annex A of this policy gives specific guidance to contractors and partners of the council in raising such concerns.
3.6  Concerns may be raised verbally or in writing. Anyone who wishes to make a written report should give the background and history of the concern, giving relevant dates if possible, and the reason why they are particularly concerned about the situation.
3.7  If the individual wishes, they may ask for a private meeting with the person to whom they wish to make the complaint and can be accompanied if they wish. An employee may invite someone, such as their trade union or a work colleague, to be present during any meetings or interviews in connection with the concerns they have raised.
3.8  When making a complaint verbally, the individual should write down any relevant information and date it. They should keep copies of all correspondence and relevant information.
3.9  It should be noted that often the earlier a concern is expressed the easier it is to take appropriate action.
3.10  The individual should ask the person to whom they are making the complaint what the next steps will be and if anything more is expected from them.
3.11  Although a person is not expected to prove the truth of an allegation that is made, it will be necessary to demonstrate that there are sufficient grounds for concern. It is not necessary for any person to undertake investigations into their concern prior to contacting the council as this may undermine any ultimate action needing to be taken. 
3.12  Advice and guidance on how specific matters of concern may be pursued can be obtained from the council’s internal audit service. The officer nominated to lead on whistleblowing is Teresa Sharman, head of internal audit who can be contacted by email on
3.13  Alternatively employees may wish to get confidential advice from their trade union or professional association
3.14  Employees may wish to consider discussing their concerns with a colleague first and may find it easier to raise the matter if there are two (or more) of them who have had the same experience or concerns.
3.15  Where a person feels that they cannot approach anyone in the council, they may wish to report their concerns through the external independent reporting scheme called Protect. Protect are an independent charity providing a legal advice service designated by the Bar Council and information provided to Protect is protected under the Public Interest Disclosures Act. Their lawyers provide confidential advice free of charge and their contact details are:

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