This policy aims to inform and direct any person to report evidence of malpractices and allegations of misconduct in a confidential manner. It allows any person to raise concerns they feel unable to direct to their line manager and to report them in a confidential or anonymous manner without fear of retaliation and in the knowledge that it will be taken seriously and investigated.
This policy is for any person working with or for World Vision UK, this includes; - employees, consultants, contractors, partners, volunteers, interns, trustees. Additionally, this policy is available as a reporting mechanism to all beneficiaries, donors, sponsors, visitors, contractors and partners of WVUK. It encourages disclosures to be made in the public interest without restriction or repercussion.
Misconduct – conduct that constitutes a criminal offence, failure to comply with legal and regulatory obligations, miscarriage of justice, health and safety danger, environmental risk or a concealment of any of these. Failure to comply with a WVUK policy or breaches of the WVUK Code of Conduct or Behavioural Protocols may also constitute misconduct.
4. Cross References
The Public Interest Disclosure Act 1998 (PIDA) governs whistleblowing. PIDA came into force on 2 July 1999. It amends the Employment Rights Act 1996 and protects workers against dismissal or other penalties because of making a 'protected disclosure'.
Confidentiality and Data privacy will be maintained in accordance with GDPR Data Protection Act 2018.
This policy is intended to address matters of a serious nature relating to misconduct by WVUK or its employees and associates. WVUK provides and promotes the Integrity and Protection Hotline operated by a third-party vendor with multilingual support, for anyone to access by email or phone twenty-four hours of the day, as the mechanism to use for reporting any allegations of misconduct. An allegation must be made in good faith and not from personal motives. All allegations will be rigorously investigated. WVUK will take appropriate action where claims of unlawful or unethical behaviour are substantiated. Confidentiality with respect to the identity of the Whistleblower and the information revealed will be maintained as is fully practicable, but subject to overriding legal requirements. WVUK gives its assurance that no whistleblower who makes a bona fide report under this Policy will be subjected to any detriment by WVUK as a result.
5.1 Allegations covered; -
- Dishonesty, fraud or corruption;
- Instances of bribery or suspected terrorist engagement or involvement;
- Illegal acts ( e.g. theft, drug sale or use, violence, harassment, criminal damage to property or other breaches of law);
- Unethical actions ( e.g. dishonestly altering company records, engaging in questionable accounting practices or wilfully breaching the organisation’s Code of Conduct or Ethical Policy ) ;
- Actions that are potentially damaging to the organisation or dangerous to individuals connected with it ( e.g. unsafe work practices, substantial wasting of resources );
- Actions likely to cause financial loss or damage to the reputation or be otherwise detrimental to organisational interests;
- Any other kind of serious impropriety.
To report an allegation by phone or online, you should visit the website www.worldvision.ethicspoint.com or phone UK freephone 0800 890011 then dial 8778975384.
An allegation should contain as much information as possible; - the name of persons involved, dates, times, locations, facts relevant to urgency, documentation, witnesses and any supporting evidence.
5.2 Investigation; - all allegations of misconduct will be promptly acknowledged and recorded by the independent third party. This will generate an electronic report which will be received by WVUK’s Safeguarding Manager and Director of People & Culture. Allegations will be consistently and fairly investigated. The Director of People & Culture will appoint an appropriate individual to undertake the investigation. Any individual who has been implicated will be informed, as appropriate, of the investigation and given the opportunity to provide evidence. All investigations will be confidentially documented and shared as appropriate with WVUK Senior Leadership and Trustees, so that the necessary corrective action can be taken. Upon conclusion of the investigation the reporter will be informed that the process has been followed and completed. Should the matter concern the Director of People & Culture it should be directly reported to a Trustee whose contact details can be obtained from the Governance Manager by e-mail, Laura.email@example.com.
5.3 Allegations of misconduct: - matters of discrimination, bullying or harassment, perceived unfair treatment by a line manager, complaints about the work environment, issues concerning pay or benefits. These will be handled by the Grievance or Dignity at work policies and should be referred to the People & Culture department. Only if a person does not believe these allegations have been fully investigated should they then be submitted through the Whistleblowing procedure.
5.4 Training & Awareness: - all employees will receive information and training that will inform and direct them to this policy and how to access the Integrity and Protection Hotline. External partners, contractors, consultants, supporters and beneficiaries can access this via our website.
Appropriate disciplinary action will be taken against any employee who violates this policy e.g. by violating a whistle-blower’s anonymity or engaging in retaliation against a whistle-blower or where a disclosure was made in bad faith.
If it should become clear that the procedure has not been invoked in good faith, for example for malicious reasons or to pursue a personal grudge against another person, this will constitute misconduct and will be dealt with in accordance with the terms of WVUK’s Disciplinary Policy.
7. Reporting and Monitoring
The investigation report will contain a clear description of the alleged incident or issues, corrective action already taken or advised, an assessment of potential risk to the organisation and proposed mitigation, a conclusion and further implications or reporting to statutory authorities.
Where it is believed that a “Serious Incident”, as defined by the UK Charity Commission, may have taken place the matter will be escalated according to WVUK’s Serious Incident Reporting policy.
Confidentiality with respect to the identity of the whistle-blower, the information revealed, and all evidence supplied will be maintained fully practicable within the parameters of the General Data Protection Regulation 2018.
The number of whistleblowing cases will be reported by the Director of People & Culture to the Board.
WVUK would expect that in almost all cases, raising concerns internally would be the most appropriate action. However, further recourse can be sought from the Charity Commission by contacting them on firstname.lastname@example.org.