Whistleblowing Policy & Procedure

Policy Statement

In any large organisation, employees may often be the first to realise when there is something seriously wrong. However, they may not express their concerns because they feel that speaking up would be disloyal to their colleagues or to the organisation. They may also fear harassment or victimisation. In these circumstances, it may be easier to ignore the concern rather than report what may just be a suspicion of malpractice.

BHT is committed to the highest possible standards of openness, probity and accountability. In line with that commitment, employees and others with serious concerns about any aspect of BHT's work are encouraged to come forward and voice those concerns. It is recognised that certain cases will have to proceed on a confidential basis. This policy makes it clear that staff can do so without fear of reprisals.

This policy is intended to encourage and enable staff to raise serious concerns, whether related to their role or not, and within BHT or elsewhere, rather than overlooking a problem.

Throughout this policy and procedure, the use of the words ‘employee’ or ‘staff’ refers to paid employees, unpaid volunteers, interns, Board members, and students on placement. The words are used for purposes of economy and do not imply or confer upon Board members, volunteers, interns, or students on placement more general rights of employees nor do they create or infer employee status. Reference to Brighton Housing Trust and BHT includes Sussex Oakleaf which has merged with BHT from 1st April 2020.

Definition and scope

For the purposes of this policy, whistleblowing is defined as “incidents where an employee discloses some alleged wrongdoing within the Trust”.

This policy is concerned with issues about probity, honesty and accountability in the organisation. It is not intended to address grievances relating to individual employment for which a separate policy exists.

Specific attention is drawn to fundraising activities where, without the proper controls, charities have been known to lose money. Therefore, if any employee, member of staff or Board member becomes aware of, or suspects that cash is being misappropriated, then the Chair of the Board or the Chair of the Finance, Audit and Risk Committee should be alerted. Concerns regarding fundraising activities can also be raised with the Fundraising Standards Authority (www.frsb.org.uk/ by email [email protected] or phone 020 4444 2588).

Policy Objective

This policy aims to:

  • provide avenues for staff to raise concerns and receive feedback on any action taken
  • allow staff to take the matter further if they are dissatisfied with the Trust’s response
  • reassure staff that they will be protected from reprisals or victimisation for whistleblowing in good faith

There are existing procedures in place to enable staff to lodge a grievance relating to their own employment. This Whistleblowing Policy is intended to cover issues of probity and honesty that fall outside the scope of other procedures.

Whistleblowing may cover a matter that:

  • is unlawful
  • is against the Trust’s Standing Orders or policies;
  • falls below established standards of practice;
  • amounts to improper conduct.

Policy Standards

Harassment or Victimisation

BHT recognises that the decision to report a concern can be a difficult one to make, not least because of the fear of reprisal from those responsible for the malpractice. BHT will not tolerate harassment or victimisation, and will take action to protect staff when staff raise a concern in good faith. (See also BHT’s Anti Harassment Policy).

This does not mean that, if staff are already the subject of disciplinary or redundancy procedures, those procedures will be halted as a result of their whistle blowing.


BHT will do its best to protect staff identity when they raise a concern and do not want their name to be disclosed. It must be appreciated that the investigation process may reveal the source of the information and a statement by staff may be required as part of evidence required for disciplinary or other proceedings.

Anonymous Allegations

This policy encourages staff to put their name to their allegation. Concerns expressed anonymously are much less powerful, but they will be considered at the discretion of BHT.

In exercising the discretion, the factors to be taken into account would include:

  • the seriousness of the issues raised;
  • the credibility of the concern; and
  • the likelihood of confirming the allegation from attributable sources.

Untrue Allegations

If an individual makes an allegation in good faith, but it is not confirmed by the investigation, no action will be taken against the individual. If, however, staff make malicious or vexatious allegations, disciplinary action may be taken against them, or student, intern and volunteering placements may be ended.


As a first step, staff should normally raise concerns with their immediate manager or their superior. This depends, however, on the seriousness and sensitivity of the issues involved and who is thought to be involved in the malpractice. For example, if staff believe that management is involved, they should approach the Chief Executive or the Director of Finance and Resources.  If they believe that the Chief Executive or the Director of Finance and Resources is involved, staff should approach the Chair of the Board of Management or the Chair of the Finance, Internal Audit and Risk Committee (contact details on the final page of this procedure).

Concerns are better raised in writing. Staff are invited to set out the background and history of the concern, giving names, dates and places where possible, and the reason why staff are particularly concerned about the situation. If staff do not feel able to put their concern in writing, they may telephone or meet the appropriate officer.

The earlier staff express the concern, the easier it is to take action.

Although staff are not expected to prove the truth of an allegation, they will need to demonstrate to the person contacted that there are sufficient grounds for their concern.

Advice and guidance on how matters of concern may be pursued can be obtained from:

  • The Chief Executive
  • The Director of Finance and Resources
  • The Head of Human Resources, Learning & Development
  • The Human Resources Manager

Staff may invite their staff representative or professional association to raise a matter on their behalf.

Staff can also approach Public Concern at Work for confidential and independent advice.  (See last page for details).

Response to concerns raised

The action taken by BHT will depend on the nature of the concern.  The matters raised may:

  • be investigated internally;
  • be referred to the Police or another enforcement agency;
  • form the subject of an independent inquiry, for example, by a regulator.

In order to protect individuals and BHT, initial enquiries will be made to decide whether an investigation is appropriate and, if so, what form it should take.

Some concerns may be resolved by agreed action without the need for investigation.

Within ten working days of a concern being received, BHT will write to the member of staff who raised the concern:

  • acknowledging that the concern has been received;
  • indicating how it proposes to deal with the matter;
  • giving an estimate of how long it will take to provide a final response;
  • telling them whether any initial enquiries have been made; and
  • telling them whether further investigations will take place, and if not, why not.

The amount of contact between the officers considering the issues and the member of staff who raised the issue will depend on the nature of the matters raised, the potential difficulties involved and the clarity of the information provided. If necessary, further information will be sought.

When any meeting is arranged, staff have the right, if they so wish, to be accompanied by a union or professional association representative or a friend who is not involved in the area of work to which the concern relates.

BHT will take steps to minimise any difficulties which staff may experience as a result of raising a concern. For instance, if staff are required to give evidence in criminal or disciplinary proceedings, BHT will advise them about the procedure.

BHT accepts that staff need to be assured that the matter has been properly addressed. Thus, subject to legal constraints, staff will receive information about the outcomes of any investigations.

Further Steps

This policy is intended to provide staff with an avenue to raise concerns within BHT. BHT hopes staff will be satisfied. If they are not, and if they feel it is right to take the matter outside the Trust, the following are possible contact points:

  • BHT’s Internal or External Auditors;
  • relevant professional bodies or regulatory organisations;
  • their solicitor;
  • the Police or another enforcement agency.

If staff do take the matter outside Brighton Housing Trust, they need to ensure that they do not disclose confidential information or that disclosure would be privileged. It is advisable to check with the contact point about that.

The Responsible Officer

For the purposes of this policy, the responsible officer is the Chief Executive. He or she will have overall responsibility for the maintenance and operation of this policy. He/she will maintain a record of concerns raised and the outcomes (but in a form which does not endanger staff confidentiality) and will report as necessary to the Board.

Record Keeping

A record will be kept of each stage of the procedure.  The record will be signed and dated by the Chief Executive.  This will be placed on a Whistleblowing register held by the Chief Executive and will be retained for at least five years.

An annual report on the use of the Whistleblowing Policy will be presented to the Finance, Internal Audit and Risk Committee.

Contact Information

The Chair of the Board is Joan Mortimer ([email protected]). This email address may only be used for whistleblowing purposes.

The Chair of the Audit, Risk and Governance Committee is Peter Freeman ([email protected]). Again, this email address may only be used for whistleblowing purposes.

Public Concern at Work can be contacted from Monday to Friday, 9.00 am to 6.00 pm at:

Address: 3rd Floor, Bank Chambers, 6 – 10 Borough High Street, London SE1 9QQ.

Telephone: 020 7404 6609

Fax: 020 7403 8823

E-mail: [email protected] (UK enquiries), [email protected] (UK helpline), [email protected] (UK services)

Website: www.pcaw.co.uk