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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Whistleblowing (Speaking Up) Policy

1. Purpose

The purpose of this policy is to provide clear guidance on how staff at {{org_field_name}} can raise concerns about wrongdoing, misconduct, or regulatory breaches in a safe and confidential manner. Whistleblowing is an essential part of safeguarding and maintaining high standards of care, and this policy supports staff in voicing concerns without fear of retaliation.

The policy is in accordance with:

• The Public Interest Disclosure Act 1998, which protects whistleblowers from victimisation and detriment where a qualifying disclosure is made.
• The Regulation and Inspection of Social Care (Wales) Act 2016.
• The Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017 (as amended), including:
  • Regulation 65 (Whistleblowing): the duty to have effective arrangements in place so people working at the service can raise concerns that may adversely affect individuals’ health, safety or well-being, and to ensure those concerns are appropriately investigated and acted upon.
  • Regulation 82 (Support for staff raising concerns): the duty for the Responsible Individual to ensure the whistleblowing policy is complied with and that arrangements to enable and support staff and volunteers to raise concerns are operated effectively, including promoting zero tolerance for poor care or failure to safeguard.
• CIW’s regulatory expectations regarding openness, safeguarding and effective governance.

2. Scope

This policy applies to all employees, agency staff, volunteers, and contractors at {{org_field_name}}. It covers concerns related to:

• Poor care practices that compromise the safety or dignity of service users.
• Safeguarding concerns, including abuse, neglect, or exploitation​.
• Financial misconduct, such as fraud or misuse of resources.
• Breaches of health and safety regulations, including unsafe working conditions.
• Legal and regulatory breaches, including non-compliance with CIW regulations​.
• Discrimination or harassment of staff or service users.

Personal grievances such as bullying, disciplinary issues, or employment disputes should be addressed through the Disciplinary and Grievance Policy, unless they also involve wrongdoing affecting service users or organisational integrity.

3. Principles of Whistleblowing

3.1. Creating a Culture of Openness and Transparency

At {{org_field_name}}, we actively promote a culture where staff feel confident and supported when raising concerns. Managers and senior leaders are trained to respond to concerns without bias or defensiveness, ensuring that all reports are taken seriously. Whistleblowing is not seen as disloyalty but as an essential safeguarding mechanism that protects service users, staff, and the organisation.

To encourage openness, staff are regularly reminded of their duty to report concerns as part of their professional responsibilities. This is reinforced in induction training, staff meetings, and supervision sessions.

3.2. Duty of candour and openness

{{org_field_name}} promotes an open and transparent culture when things go wrong. Where a whistleblowing concern relates to harm, service failure, or poor care, we will ensure the appropriate processes are followed to be open and honest with individuals receiving care and support and/or their representatives, including providing appropriate information about what happened and the outcome of investigations, and offering an apology where appropriate.

3.3. Confidentiality and Protection from Retaliation

Confidentiality is a key component of this policy. Staff members can raise concerns anonymously, and their identity will not be disclosed without their consent unless required by law (e.g., in safeguarding investigations). Where a concern is raised anonymously, we will still assess and investigate it as far as reasonably possible. However, anonymity may limit our ability to obtain further information, provide feedback, and/or offer ongoing support to the person raising the concern. Staff are therefore encouraged to raise concerns confidentially (rather than anonymously) wherever possible, so we can act promptly and keep them appropriately updated.

Retaliation against whistleblowers is strictly prohibited. Any form of victimisation, harassment, or intimidation against a whistleblower will be treated as gross misconduct under the Disciplinary and Grievance Policy and could result in dismissal or legal action.

If a staff member believes they have suffered retaliation after raising a concern, they should report this to {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}} or, if necessary, escalate the issue to CIW or an external whistleblowing authority.

3.4. How to Raise a Concern

Staff are encouraged to raise concerns as early as possible, either verbally or in writing. The following options are available:

1. Speaking to a Line Manager – The first point of contact for most concerns should be the staff member’s immediate supervisor or manager.
2. Contacting the Registered Manager – If the concern involves a line manager or is of a serious nature, staff should report directly to {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}} at {{org_field_registered_manager_email}}.
3. Reporting to the Safeguarding Lead – If the concern relates to abuse or neglect, staff should report to {{org_field_safeguarding_lead_name}}.
4. Escalating to alternative internal or external routes (including CIW): If staff believe their concern is not being addressed appropriately, if the concern involves the Registered Manager/senior staff, or if staff feel unable to raise the matter internally, they may raise the concern with:
5. the Responsible Individual (RI) (where appointed) or the service provider’s senior leadership; and/or
6. Care Inspectorate Wales (CIW) as the service regulator; and/or
7. the relevant Local Authority safeguarding team (and/or Police) where the concern indicates abuse, neglect, improper treatment or immediate risk; and/or
8. Protect (formerly Public Concern at Work) for independent whistleblowing advice and support.

Staff may also seek independent support/advocacy (for example via trade union representation or relevant advocacy services) before or during the whistleblowing process.

A whistleblowing report should include:

• A clear description of the concern.
• Dates, times, locations, and any supporting evidence.
• Names of any people involved (if known).

3.5. How Concerns Are Investigated

All reports will be reviewed and investigated immediately in line with our risk management and safeguarding policies. The investigation process will follow these steps:

1. Initial Acknowledgment – A whistleblower will receive written confirmation that their report has been received within 5 working days.
2. Preliminary Assessment – A senior manager or the designated safeguarding officer will conduct an initial risk assessment to determine the severity of the concern.
3. Formal Investigation – If required, an independent investigation team will be assigned. This may include external safeguarding professionals or regulatory bodies such as CIW.
4. Outcome and Feedback – The whistleblower will be informed of the general outcome of the investigation within 28 days, while respecting confidentiality and legal constraints.

If a concern is found to be substantiated, immediate corrective actions will be taken, including staff retraining, disciplinary measures, or regulatory reporting. If the concern is found to be unsubstantiated, but raised in good faith, the whistleblower will not face any negative consequences.

All whistleblowing concerns will be recorded in a secure whistleblowing log and handled in line with data protection and confidentiality requirements. Records will include the concern raised, immediate actions taken, the investigation process, findings, outcomes, and learning/actions, and will be retained in accordance with our records management arrangements.

Where the concern indicates abuse, neglect, improper treatment, criminal behaviour, or immediate risk, we will make the appropriate referrals without delay (for example to the Local Authority safeguarding team and/or Police) and we will liaise with CIW where required. We will also consider whether any related regulatory notifications or professional referrals are required.

3.6. Preventing and Addressing Malicious Reports

Whistleblowing must be responsible and evidence-based. False or malicious reports—made with the intent to harm colleagues or the organisation—will be taken seriously and may result in disciplinary action. However, staff will never be penalised for raising genuine concerns, even if investigations do not confirm wrongdoing.

4. Managing Whistleblowing Efficiently

4.1. Training and Awareness

• All staff receive whistleblowing training during induction and annual refresher courses.
• Clear guidance on whistleblowing is included in staff handbooks, posters in communal areas, and digital resources.

4.2. Support for Whistleblowers

• Staff raising concerns are offered confidential support, including access to external advocacy services.
• The Registered Manager and Safeguarding Lead ensure that whistleblowers feel safe and valued.

4.3. Monitoring and Continuous Improvement

• Incident trends are analysed to identify recurring risks or areas for improvement.
• Annual policy reviews ensure alignment with the latest CIW guidance and legal standards.

4.4 Governance, Responsible Individual Oversight and Organisational Learning

The service provider and Responsible Individual (where appointed) will ensure the whistleblowing arrangements are operated effectively and that staff and volunteers are encouraged and supported to raise concerns, with zero tolerance for poor care or failure to safeguard individuals.

Whistleblowing information (themes, numbers, outcomes, timeframes, and actions taken) will be reviewed through the service’s governance systems and will be:

• escalated to the Responsible Individual for oversight (including where concerns indicate potential systemic risk or repeated themes);
• included in periodic quality and safety monitoring and review, alongside complaints, incidents and safeguarding; and
• used to identify learning, training needs, and service improvements, which will be shared with staff in an appropriate and timely way.

5. Related Policies

This policy is supported by:

• CHW13 – Safeguarding Adults from Abuse and Improper Treatment Policy
• CHW16 – Health and Safety at Work Policy
• CHW26 – Recruitment, Selection, and Retention Policy
• CHW27 – Staff Supervision, Training, and Development Policy
• CHW31 – Disciplinary and Grievance Policy

6. Policy Review

This policy is reviewed at least annually and sooner where required by changes to legislation, statutory guidance (including Welsh Government guidance for regulated services), CIW requirements, or changes to relevant professional standards (including Social Care Wales Codes of Professional Practice). Any updates will be communicated to all staff, and additional training will be provided where necessary.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
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