Whistleblowing Policy

1. 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 individuals the space to speak up if they have a concern and responding appropriately and thoroughly when they do. We hope that everyone feels empowered to do so and confident in the knowledge that this is the right thing to do.

We recognise that the decision to speak up can be a challenging one. Anyone thinking of doing so should be assured that they will be heard and that their 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.

2. 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.

3. 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 Procedures. 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.

Consequently, this policy should not be used to report individual concerns or issues such as grievances or complaints relating to a management decision or terms of employment. Instead, such issues should be discussed with your line manager in the first instance and then escalated in line with the route set out in the individual relevant policy, e.g. to the People and Learning team.

4. Protection for Whistleblowers

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

We never tolerate bullying, harassment or victimisation of an individual. For KTI workers, this means your future employment, progression or opportunities will not be negatively affected if you raise a genuine concern. Any instances of bullying or victimisation or attempts to identify a whistleblower will be treated very seriously and may result in disciplinary action.

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.

5. Confidentiality

We will always respect the privacy of whistleblowers. Where it is necessary to identify you in order to resolve an issue, we will discuss this with you first. We will also be judicious in disclosing your identity to other investigators and only disclose your identity where this is necessary or otherwise appropriate (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).

This includes instances where the concern is in respect of a delivery partner, contractor or another organisation with which we work. In such circumstances, 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 those parties then to be asked to investigate.

It may be considered appropriate to commence disciplinary or other proceedings against those involved in any wrongdoing; and, in such circumstances, your evidence as a witness may be needed. 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.

We do not encourage whistleblowers to contact us anonymously. This can make it much harder to investigate or to establish whether the concern is credible. While we will still consider the concern, we may not be able to take any action if we do not have everything we need to proceed. 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.

6. 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 Children and 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
• Grievance Policy and Procedures
• 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.

7. 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:

7.1 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)

7.2 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.