Whistleblowing Policy

POLICY STATEMENT 

The King’s Trust International (“KTI”) is committed to creating a safe and supportive environment for all its staff, volunteers and partners, as well as the children and young people it supports. 

This means giving everyone the space to speak up if they have a concern and responding thoroughly and appropriately when they do. We hope that everyone feels empowered to do so. 

We recognise that the decision to speak up can be a challenging one. If you are thinking of doing so please be assured that you will be heard and that your concern will be dealt with in the strictest confidence possible.  

We encourage an open and transparent culture and believe in applying strong morals, high standards and ethical principles to our work. We therefore welcome reports of any concerns. This allows us to investigate and address any issues, learn lessons and improve as an organisation.  

Training on this policy will form part of the induction process for all individuals who work for us, and regular training will be provided as necessary. 

 

SCOPE 

We want everyone to have the confidence to speak up. This policy therefore seeks to reassure not just KTI’s staff / workers, but also others including volunteers, those at our delivery partners & contractors and young people supported through our programmes. If you have any concerns about KTI or its activities, we want to hear from you. This can be done under this policy, our feedback and complaints policy or through the contact us page on our website. We will then deal with your concern under the most appropriate policy and procedures.  

The Board of Trustees is ultimately responsible for this policy and reviews this as appropriate with the support of the Risk, Audit and Finance Committee. 

 

TYPES OF CONCERN  

‘Whistleblowing’ is the reporting of suspected wrongdoing or dangers in relation to the organisation’s activities. For the purposes of this policy, this includes bribery, facilitation of tax evasion, fraud or other criminal activity, witnessing the mistreatment of others, health and safety risks, safeguarding incidents or concerns, damage to the environment, unethical behaviour and breach of legal or professional obligations.  

A ‘whistleblower’ is someone who has a reasonable belief that wrongdoing has or is currently taking place, or that it is likely to take place in the future. 

Whistleblowing differs from complaints or grievances in that it is about concerns which have a wider impact than just the individual. For example, if an employee raises a complaint about bullying faced by them this should be dealt with under our grievance policy and procedure. However, if the investigations raise concerns about a bullying culture then those wider ‘public interest’ concerns should be investigated and dealt with under this policy. 

You should not use this policy to report individual concerns or issues such as grievances or complaints relating to a management decision or terms of employment. Instead, you should discuss these with your line manager in the first instance and then escalate them in line with the route set out in the individual relevant policy, e.g. to the People and Learning team. 

 

PROTECTION FOR WHISTLEBLOWERS  

We recognise that the decision to speak up can be a difficult one. If you have a reasonable belief or concern about wrongdoing, we will always support you and do all we can to consider your interests throughout any investigation. 

If you are a KTI employee, your future employment, progression or opportunities will not be negatively affected if you raise a genuine concern. We never tolerate bullying, harassment or victimisation of an individual. Any instances of bullying or victimisation or attempts to identify a whistleblower will be treated very seriously and may result in disciplinary action. If you believe that you have suffered any such treatment, you should inform the People Partner or the Nominated Whistleblowing Person (Tracy Fountain, Head of Safeguarding) immediately. If the matter is not remedied you should raise it formally under our grievance policy and procedure. 

Those who are not workers of KTI do not have the legal protection provided by The Public Interest Disclosure Act. However, we will still take the same care to try and ensure that your interests are protected, and you are not exposed to any retaliation for speaking up.  

 

CONFIDENTIALITY  

We respect the privacy of whistleblowers and we will be careful not to disclose your identity.  If we think identifying you will be helpful in resolving an issue, we will discuss with you first why we think this is so and whom it would be appropriate to inform (e.g. within the small team at KTI responsible for considering and/or investigating such concerns, omitting your name in reports and other documents where this is not necessary).   

Where you raise a concern in respect of a delivery partner, contractor or another organisation with which we work we will consider with you what information it would be appropriate for us to pass on to such parties (including whether to reveal your identity and/or details of your concern). It may be most appropriate for us then to ask those parties to investigate.  

Where it may be appropriate to commence disciplinary or other proceedings against those involved in any wrongdoing, your evidence as a witness may be needed. If so, we will advise and support you if we do need you to give evidence as a witness. 

If you have any worries about confidentiality, please let us know.  

It is harder to investigate or to establish whether a concern is credible if you contact us anonymously. We do not therefore encourage whistleblowers to contact us anonymously. The best way to raise a concern is to do so openly as this makes it easier for us properly and promptly to investigate the concern and take appropriate action to deal with this.  

 

LINKS TO OTHER POLICIES 

KTI has several other policies in place with links to this policy.  

This policy is not a substitute for other policies. Where relevant, concerns reported under this policy may therefore be investigated under a different policy. For example:  

• Safeguarding young people policy 
• Prevention of sexual exploitation, abuse and harassment (PSEAH) policy 
• Feedback and complaints policy 
• Health, safety and security policy 
• Data protection policy  
• Anti-money laundering and counter-terrorism policy 
• Fraud and theft policy 
• Anti-corruption and bribery policy (including gifts and hospitality) 
• Grievance policy and procedure 
• Conflict of interest policy  

Please report any matter in line with the most appropriate policy or route. However, if you are unsure, what is most important is that you promptly tell us about it. We will then deal with your concern under the most appropriate policy and procedures.  

We also expect delivery partners and others with whom we deal to have their own internal policies under which concerns can be dealt with. If a matter relates to such parties, it is usually better to report it first to them as they are in the best position to respond. However, if you do not have confidence in their response or likely response, you may report it to us. 

 

REPORTING CONCERNS  

We hope that all staff, representatives, delivery partner employees and other individuals covered by this policy feel confident in raising concerns to their line manager or to their KTI point of contact in the first instance.  

If you feel unable to do so, you may raise your concerns with a more senior KTI manager who you trust or in one of the following ways: 

KTI Nominated Whistleblowing Person:	Tracy Fountain, Head of Safeguarding
KTI Safeguarding / Whistleblowing phone number:	+44 (0)20 3222 5911 (UK office hours)
KTI Whistleblowing e-mail address:	KTIwhistleblowing@kingstrustinternational.org
KTI Nominated Whistleblowing Trustee:	Michael Nartey, Trustee and Chair of the Risk, Audit and Finance Committee
KTI Whistleblowing e-mail address:	KTIwhistleblowing@kingstrustinternational.org

 

Please note that calls to the phone number will usually be answered by Tracy Fountain (Head of Safeguarding) or Sana Sud (International Safeguarding Adviser). E-mails sent to the KTI Whistleblowing e-mail address will be received into a secure mailbox which may be accessed by Michael Nartey (Trustee and Chair of the Risk, Audit and Finance Committee), Jo Parsons (Director of Delivery and Impact), Ann Newman (Deputy Director of Global Delivery) and Tracy Fountain (Head of Safeguarding). With the exception of the IT Department, no one else is able to access this mailbox. 

 

SUPPORT  

We will support you. However, if you want independent support then ‘Protect’ is an independent whistleblowing charity that provides support to individuals and organisations with whistleblowing. It operates a free, confidential advice line for those who have a concern. 

Advice Line: 020 3117 2520 

Website: Protect – Speak up stop harm | The Whistleblowing Charity (protect-advice.org.uk) 

 

EXTERNAL  

Individuals with legitimate concerns are encouraged, as far as possible, to raise them in line with the internal reporting routes laid out in this policy.  

Where a crime has been, or is being, committed this should be reported to the responsible agencies in the relevant country. In the UK, relevant bodies include the police, HMRC (for tax fraud) and Action Fraud (for other fraud and cybercrime).   

If a concern relates to any serious wrongdoing at KTI (and if you do not have confidence in KTI’s response) this may also be reported to the Charity Commission for England and Wales: 

Email: whistleblowing@charitycommission.gov.uk 

Guidance: Report serious wrongdoing at a charity as a worker or volunteer 

Other prescribed persons and bodies are listed in Government guidance. 

Please do not report any concerns to the media (including disclosing on social media). If you do, this may affect the legal protection you may otherwise have as a whistleblower under the Public interest Disclosure Act. 

If you are unsure about how best to proceed, or what information to share, you may seek independent advice from organisations such as Protect (as discussed above). However, this policy is designed to protect whistleblowers and to ensure that any matters are properly and promptly investigated and dealt with. We therefore strongly encourage anyone with a genuine concern immediately to contact one of the people at KTI mentioned above so that we can start addressing that concern. 

 

Whistleblowing procedures 

1. We encourage you to raise any concerns either under the existing relevant policy (as listed in the whistleblowing policy), to your line manager or to your KTI point of contact. If you do not feel able to do so – for example because you have done so before and feel it was not addressed appropriately – you should raise your concern using one of the options under Reporting Concerns.  

2. We do not have any form which must be completed. However, where possible, information about the concern should include the following details: 

• the nature and key elements of the concern; 
• when any wrongdoing, etc. occurred (or started if ongoing) and/or when you became aware of it;  
• who was / is involved;  
• any other relevant background information (e.g. where any wrongdoing has taken place); 
• who else (if anyone) has been notified, when and what response has been received; and 
• how best to contact you. 

3. In the event a whistleblower contacts a KTI employee, the employee should report this immediately to the Nominated Person or Trustee. They will then involve others as appropriate. If the concern is a criminal matter, this may be reported to the police.  

4. It is the responsibility of all involved in the process to provide a safe environment for the whistleblower, treat the concern seriously, deal with it promptly and fairly, preserve evidence and maintain confidentiality as appropriate. 

 5. The KTI employee receiving details of the concern or another appropriate person should acknowledge receipt within one working day.  

 6. Within five working days, the whistleblower should be advised how it is proposed to deal with the matter. Additional information may be sought to help with our investigations. In the event it is decided not to investigate a matter or to take any further action in relation to this, the whistleblower should be advised of the reasons for this decision and the level at which this decision has been taken. 

 7. Where appropriate, an investigator / investigation team (either internal or external) will be appointed. This will be someone independent from the concern raised. The investigator will report to the CEO, the Risk, Audit and Finance Committee and/or the full Board of trustees as appropriate. Our regulator (the Charity Commission), funders and others may also be informed. Where appropriate, actions will be agreed and implemented to improve KTI’s systems and to try to prevent any re-occurrence of the circumstances giving rise to the concern. 

 8. Where appropriate, the outcome of the investigation will be shared with the individual raising the concern, even if this is a decision not to progress the investigation. This may not be appropriate in all cases, for example for confidentiality reasons. In such circumstances, where the whistleblower has asked to be kept informed, the whistleblower should still be updated and provided with reassurance that their concern has been (or is being) properly dealt with.