Overview and contacts
If you have a concern about the council’s services please read this policy. We can give confidential advice about concerns you may have regarding the council and its services.
We encourage people to raise their concerns under this procedure in the first instance. If you are not sure whether to raise a concern, you can discuss the issue and/or policy with:
Teresa Sharman, Head of Internal Audit
Tel. 01603 430138
email: teresa.sharman@southnorfolkandbroadland.gov.uk
Kerry Eldridge, Director of People and Organisational Culture
Tel. 01603 987682
email: kerryeldridge@norwich.gov.uk
Jan Robinson, Head of Legal and Governance (Monitoring Officer)
Tel. 01603 989434
email: janrobinson@norwich.gov.uk
Louise Rawsthorne, Chief Executive
Tel. 01603 987754
email: louiserawsthorne@norwich.gov.uk
Guidance is also available on the Government website, which has links to the Advisory, Conciliation and Arbitration Service (ACAS) for help and advice on resolving a workplace disputes.
All concerns will be treated in confidence and every effort will be made not to reveal the identity of the person highlighting the concern.
1. Introduction
1.1 This policy seeks to provide a process that gives anyone with a concern about the council the confidence to bring that concern to our attention.
1.2 Norwich City Council operates within legal requirements and regulations and expects its employees to co-operate in this by adhering to all laws, regulations, policies and procedures. Any employee becoming aware of inappropriate conduct is obliged and encouraged to report this activity. This policy also applies to other individuals performing functions in relation to the council such as contractors, consultants, partners and agency workers and other stakeholders including councillors.
1.3 Employees are often the first to realise that there may be something seriously wrong within the council. However, they may not express their concerns because they feel that speaking up would be disloyal to their colleagues or to the council. Councillors, customers and stakeholders are also in a position to identify concerns that affect council services and need to be addressed.
1.4 The law provides protection for workers who raise legitimate concerns about specified matters. These are called ‘qualifying disclosures’. A qualifying disclosure is one made in the public interest by a worker who has a reasonable belief that the following is being committed or is likely to be committed:
- a criminal offence
- a miscarriage of justice
- an act creating risk to health and safety
- an act causing damage to the environment
- a breach of any other legal obligation
- concealment of any of the above
1.5 It is not necessary for the worker to have proof that such an act has been, or is likely to be committed – a reasonable belief is sufficient. The worker has no responsibility for investigating the matter.
1.6 Individuals with a concern may fear that they will be victimised or harassed if they raise the concern. In these circumstances it may feel easier to ignore the concern rather than report what may be a suspicion of malpractice. A worker who makes a protected disclosure has the right not to be dismissed, subjected to any other detriment, or victimised, because they have made a disclosure.
1.7 The council is committed to the highest possible standards of openness, probity and accountability. In line with that commitment the council encourages employees, customers, contractors, employees of subsidiaries, stakeholders or any other person with serious concerns about any aspect of the council’s work to come forward and voice those concerns.
1.8 It is recognised that certain cases will have to proceed on a confidential basis but in accordance with the Freedom of Information Act this policy seeks to provide a transparent method for dealing with concerns. Whistle-blowers can have confidence through this policy that they have the fullest protections afforded by the Public Interest Disclosures Act.
1.9 Specifically this policy makes it clear that employees and others can make reports without fear of reprisals and sets out what protections are in place under this policy. It is intended to encourage and enable concerns to be raised within the council so that they can be addressed, rather than overlooking problems or raising them outside the council.
1.10 All officers, councillors and partners have a responsibility to protect the council’s interests through the proper adherence to this policy.
1.11 The council is committed to maintaining high ethical standards and taking your concerns seriously.
2. Aims and scope of this policy
2.1 This policy aims to:
- encourage and enable any person to feel confident in raising serious concerns and to question and act upon concerns
- provide avenues for any person to raise concerns and receive feedback on any action taken
- ensure everyone making a referral receives a response to their concerns
- describe how to take the matter further if dissatisfied with the council’s response
- reassure anyone making a referral that they will be protected from reprisals or victimisation
2.2 For the avoidance of doubt if you have concerns that any person may be being mistreated / abused you can discuss your concerns in confidence with your manager or those listed on the front cover of this policy.
2.3 There are existing procedures in place to enable employees to lodge a grievance relating to their own employment, customers to complain about the service they receive, and report if councillors have breached the Member Code of Conduct. This policy should not be used for such concerns; however, advice can be obtained from the contacts on the front cover of this policy if you have any doubts.
2.4 The whistleblowing policy is intended to cover concerns listed below. A concern may be about:
- sexual, physical or emotional abuse of clients or other individuals
- conduct which is an offence or a breach of law
- disclosures related to miscarriages of justice
- health and safety risks, including risks to the public as well as employees
- damage to the environment
- unauthorised use of public funds
- action that is contrary to the council’s financial procedures or contract regulations
- possible fraud, corruption or financial irregularity
- action that is against the council’s financial regulations and policies
- practice that falls below established standards or practice
- other improper or unethical conduct.
2.5 The concern may be something that makes a person feel uncomfortable in terms of known standards, their experience or the standards to which they believe the council subscribes. If in doubt please contact either a named contact on the front cover of this policy or Protect to have a confidential discussion.
2.6 This policy applies to all employees, councillors, contractors, consultants, and agency workers and other stakeholders who are acting on behalf of, or in partnership with, the council.
2.7 Any disclosure of information that, in the reasonable belief of the worker, is made in the public interest shall be deemed a qualifying disclosure.
2.8 This policy incorporates the provisions that are required from the Public Interest Disclosure Act.
3. 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 Monitoring Officer (see paragraph 3.11), 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 Given the possible contractual issues annex A of this policy gives specific guidance to contractors and partners of the council in raising such concerns.
3.5 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.
3.6 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.
3.7 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.
3.8 It should be noted that often the earlier a concern is expressed the easier it is to take appropriate action.
3.9 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.
3.10 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.
3.11 Advice and guidance on how specific matters of concern may be pursued can be obtained from the council’s Monitoring Officer janrobinson@norwich.gov.uk
3.12 The officer nominated to lead on whistleblowing is Jan Robinson, Head of Legal and Governance who can be contacted by email on janrobinson@norwich.gov.uk. Alternatively, employees may wish to get confidential advice from their trade union or professional association.
3.13 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.
4. Supporting the individual to raise a concern harassment or victimisation
4.1 The council recognises that the decision to raise a concern can be difficult, not least because of the fear of reprisals.
4.2 The council will not tolerate harassment or victimisation and will take action to protect individuals who raise concerns. This does not mean that if the individual raising the concern is the subject of informal or formal, procedures, that those procedures will be halted as a result of raising a concern under this policy.
4.3 Officers should not release information which identifies whistle-blowers without their permission, unless there is a requirement to do so (e.g. a court order).
4.4 Any person applying pressure upon such officers to identify whistleblowers shall be subject to the same provisions as outlined in 4.6 below.
4.5 Where a whistle-blower alleges they are / have been victimised / harassed as a result of raising a concern that matter shall be referred to an appropriate officer to deal with and investigate. Appropriate officers will include the s151 officer (chief finance officer), monitoring officer, head of HR. Where the investigations may identify the whistle-blower, either indirectly or directly, the way forward shall be discussed with the whistle-blower and any resultant action confidentially reported to the chair of the audit committee where appropriate.
4.6 Each case will be considered on its merits. If anyone is found to have victimised or harassed someone, who has made a referral under this policy, it would normally be considered:
- a matter of gross misconduct if carried out by an employee of the council
- a matter for the council to consider termination of a contract, if it is carried out by or at the request of a contractor. If there are concerns that a contractor is victimising, or has victimised, a whistle-blower an independent review may be requested
- a matter that would be referred to the standards committee, if it relates to member conduct
- a matter that could affect service provision, if it relates to a customer
Confidentiality
4.7 All concerns will be treated in confidence and every effort will be made not to reveal the identity of the person highlighting the concern if that is the wish of the individual.
4.8 Information may be shared with officers to help progress any relevant investigation, but in a form which does not endanger confidentiality.
4.9 It must be appreciated that the investigation process may reveal the source of the information and a statement by the individual raising the concern may be required as part of the evidence.
4.10 Referrals will be recorded so that summary information can be reported to the council’s audit committee to illustrate trends.
Anonymity
4.11 Individuals are encouraged to put their name to any allegation. The council will do its best to protect the individual’s identity when they do not want their name disclosed.
4.12 Concerns expressed anonymously are much less powerful but will be considered at the discretion of the council. In exercising this discretion, the factors to be taken into account would include:
- seriousness of the issue
- credibility of the concern
- likelihood of being able to obtain the necessary information
Untrue allegations
4.13 Any individual who makes an allegation which is not subsequently confirmed by the investigation, will have no action taken against them and will continue to have protection under this policy from victimisation or harassment.
4.14 If, however, an individual makes malicious or vexatious allegations, action may be taken against them. Maliciously making a false allegation is a disciplinary offence.
5. How the council will respond
5.1 The council offers various routes for concerns to be raised. To ensure that they are processed appropriately, and to help direct a prompt response, referrals will be reviewed by the head of internal audit, the monitoring officer and the head of human resources and learning at the earliest opportunity to agree the best approach.
5.2 The action taken by the council will depend on the nature of the concern. Where appropriate, the matters raised may:
- be investigated by management, internal audit, or other appropriate person
- be referred to the external auditor
- be referred to the police
- form the subject of an independent inquiry.
5.3 In order to protect individuals and the council, an initial investigation will be carried out to decide whether a full investigation is appropriate and, if so, what form it should take. Concerns or allegations, which fall within the scope of specific procedures, for example, safeguarding or discrimination issues, will normally be referred for consideration under those procedures.
5.4 It should be noted that some concerns may be resolved by agreed action without the need for investigation. Equally some issues may be investigated without the need for initial enquiries. If urgent action were required, this would be taken before any investigation is conducted.
5.5 The council will write to the person raising the concern within seven working days (i.e. the individual or representative with whom the report was lodged) to:
- acknowledge that the concern has been received
- indicate how it proposes to deal with the matter
- give an indication of when a final response or update will be provided
- inform the person whether any initial enquiries have been made
- supply the person with information on employee support mechanisms, and
- inform the person whether further investigations will take place and, if not, why not
5.6 Every effort will be made to resolve the matters raised as soon as possible, in the interests of the council, the person raising the concern and the person(s) being investigated.
5.7 The amount of contact between the officers considering the issues and the person raising the concern will depend on the nature of the matters raised, the potential difficulties involved and the clarity of the information provided. If necessary, further information may be sought from the person raising the concern.
5.8 Where any meeting is arranged, employees have the right, if they so wish, to be accompanied by someone, such as a trade union representative or a work colleague, who is not involved in the area of work to which the concern relates.
5.9 The council will take appropriate steps to minimise any difficulties, which a person may experience as a result of raising a concern and provide advice and support should they be required to give evidence, e.g. at a disciplinary hearing.
5.10 The council accepts that the person raising a concern needs to be assured that the matter has been properly addressed. Thus, subject to legal constraints, the person raising the concern will be kept informed as the investigation progresses unless they have requested otherwise. At the very least they should receive an update on the investigation by the date implied by the estimated response time given in section 5.4.
6. How the matter can be taken further
6.1 This policy is intended to provide an avenue to raise concerns within the council. The council hopes that those using this process will be satisfied with the way their concerns are treated and any investigations that may be carried out. However, if they are not satisfied and feel it right to take the matter outside the council, the matter can be raised with:
- a solicitor
- relevant professional bodies or regulatory organisations, such as:
o HM Revenues and Customs
o Financial Conduct Authority
o Competition and Markets Authority
o Health and Safety Executive
o Environment Agency
o Independent Police Complaints Commission
o Serious Fraud Office
6.2 In taking advice from sources outside the council a person must ensure that, so far as possible, it is raised without confidential information being divulged. Also a person would, other than in exceptional circumstances, be expected to have exhausted the internal routes available first.
6.3 Any individual has the right and responsibility to refer a concern to the police if they suspect a criminal act.
7. Roles and responsibilities framework
7.1 The responsibility for the operation of this policy rests with the corporate leadership team to ensure all employees are fully aware of its provisions.
7.2 Audit committee is responsible for assuring the council that the risks across the council are being identified and managed. It is therefore responsible for ensuring that this policy is robust in identifying concerns and that the identified risks are addressed. It is also responsible for ensuring that the principles within this policy are upheld.
Investigations
7.3 Investigations should be undertaken by appropriate officers with relevant expertise, and may be someone independent of the person receiving the referral. Internal audit (IA) and human resources (HR) will jointly ensure that investigations are swift and effective and undertaken by someone with relevant skills and experience. IA and HR will act as the corporate services who maintain records of all referrals and subsequent investigations received by the council. Additionally:
7.4 IA will lead on all financial referrals, including those where there are significant financial implications to an allegation, whilst not explicit within the referrals. The audit team will ensure that concerns raised through the informal process are logged and trends identified.
7.5 HR will lead on allegations regarding serious misconduct of council employees. The HR team will advise and support employees involved in the investigation process to ensure that such processes are fair and supportive to all those involved.
7.6 The monitoring officer will lead on allegations regarding misconduct of councillors.
Line managers
7.7 Line managers must create an open and fair culture within their area of responsibility and ensure that employee concerns are listened to and action taken where necessary.
7.8 They are responsible for ensuring that there is a safe environment for employees to raise their concerns and that there is no retribution as a result of someone raising their concerns.
Employees
7.9 In all contracts of employment there is an implied understanding of mutual trust and confidence between the employer and employee. All employees, therefore, have a responsibility to raise concerns about work and they may do so in the manner described in this policy.
8. How the policy will be monitored and reviewed monitoring
8.1 The council has a responsibility for registering the nature of all concerns raised and to record the outcome. The council’s internal audit service will produce an annual report, which will identify any patterns of concern and assess the effectiveness of the policy.
8.2 This policy will be publicised via the council’s website and specifically:
- every new employee will be provided a copy of the policy when joining the council
- every contract will require the contractor to communicate the policy to their employees and adopt its provisions when working for the council
- every employee of a joint venture or company owned by the council will be provided a copy of the policy when joining the JV or company, together with training on the whistleblowing procedures of their organisation and the circumstances where each policy will apply
- all newly elected members should be provided a copy of the policy.
Review
8.3 This procedure will be kept under review and any amendments will be subject to consultation with employee representatives.
9. Annex A
Procedure for contractors / partners, employees of subsidiaries
9.1 As a first step contractors should normally raise concerns with their manager, who will then inform the lead council officer who is dealing with that particular contract. If contractors do not have a manager, they should raise their concerns direct with the lead council officer. This depends on the seriousness and sensitivity of the issues involved and who is suspected of the malpractice. For example, if contractors believe that their manager or lead council officer is involved, they should approach the head of internal audit at the council directly. Otherwise, the lead council officer receiving notification of concerns under this policy will inform the head of internal audit that a confidential report has been received and provide a copy.
9.2 If the concern relates to financial irregularities or failures of financial controls the lead council officer receiving the report will also immediately notify the head of internal audit.
9.3 Concerns may be raised verbally or in writing. Individuals who wish to make a written report are invited to use the following format:
- the background and history of the concern, giving relevant dates if possible
- the reason why the individual is particularly concerned about the situation.
9.4 It should be noted that often the earlier a concern is expressed the easier it is to take appropriate action.
9.5 Advice and guidance on how specific matters of concern may be pursued can be obtained internally from the internal audit service. Alternatively contractors may wish to get confidential advice from their trade union or professional association.
9.6 Contractors 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 you who have had the same experience or concerns.
9.7 Contractors 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.
June 2026
If you need this information by email for use with the read-aloud function or in an alternative format, please contact us on 0344 980 3333 or visit norwich.gov.uk/intran
