Registration Number: {{org_field_registration_no}}

Whistleblowing (Speaking Up) Policy

1. Introduction

At {{org_field_name}}, we are committed to creating an open and honest workplace where employees and workers feel safe and supported when raising concerns about wrongdoing, misconduct, unsafe practice or other matters affecting the public interest.

We recognise that speaking up is essential for maintaining high standards of care, safeguarding service users and staff, identifying risks and ensuring compliance with legal and regulatory requirements.

This policy supports compliance with:

Employment Rights Act 1996, including Part IVA concerning protected disclosures.
Public Interest Disclosure Act 1998, which established the principal statutory whistleblowing protections within the Employment Rights Act 1996.
Employment Rights Act 2025, including the amendment in force from 6 April 2026 expressly recognising sexual harassment as a category of wrongdoing capable of forming the subject of a protected whistleblowing disclosure.
Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, including Regulation 17 – Good governance.
CQC’s current assessment framework, including the Well-led – Freedom to Speak Up quality statement.

This policy establishes clear and confidential routes for raising concerns and confirms {{org_field_name}}’s commitment to ensuring that workers who make protected disclosures are not subjected to unlawful detriment or dismissal because they have spoken up.

{{org_field_name}} is registered with the Care Quality Commission to carry out the regulated activity of {{org_field_regulated_activity}} for {{org_field_service_users_bands}} in their own homes.

2. Purpose and Scope

The purpose of this policy is to ensure that everyone working for or on behalf of {{org_field_name}} understands:

Their right to raise concerns about wrongdoing.
How to raise a concern.
When a disclosure may qualify for statutory whistleblowing protection.
The protection available to workers who make protected disclosures.
The internal and external routes available for speaking up.

This policy applies to employees and workers, including bank and agency staff, apprentices, trainees and other individuals who fall within the statutory whistleblowing provisions.

While statutory whistleblowing protection does not generally extend to volunteers or most external job applicants, other than where specific statutory provisions apply, {{org_field_name}} extends its organisational commitment to speaking up without retaliation to volunteers, students and placement learners.

What Counts as a Protected Disclosure

For a disclosure to qualify for statutory whistleblowing protection, the worker must reasonably believe that the disclosure is made in the public interest and that the information disclosed tends to show that one or more of the following has occurred, is occurring or is likely to occur:

A criminal offence.
A failure to comply with a legal obligation.
A miscarriage of justice.
A danger to the health or safety of any individual.
Sexual harassment.
Damage to the environment.
Deliberate concealment of information tending to show any of the above.

For the purposes of whistleblowing legislation, sexual harassment means unwanted conduct of a sexual nature within the meaning of Section 26(2) of the Equality Act 2010.

A qualifying whistleblowing disclosure concerning sexual harassment may relate to sexual harassment that:

Has already occurred.
Is currently occurring.
Is likely to occur.

The normal statutory whistleblowing requirements continue to apply. In particular, the worker must reasonably believe that making the disclosure is in the public interest.

A disclosure may be made verbally or in writing. A worker does not need to have complete proof before raising a concern. However, statutory whistleblowing protection depends on the legal conditions applying to the particular disclosure and the route through which it is made.

Examples of Concerns

Concerns that may potentially fall within this policy include:

Unsafe or poor care practices.
Abuse or neglect of service users.
Serious safeguarding failures.
Criminal activity.
Fraud or financial wrongdoing.
Failure to comply with CQC regulations or other legal obligations.
Unsafe staffing or working practices.
Risks to health or safety.
Deliberate concealment of incidents or regulatory failures.
Environmental wrongdoing.
Sexual harassment where the statutory whistleblowing conditions are met.

Whistleblowing and Personal Grievances

Whistleblowing concerns wrongdoing that the worker reasonably believes is in the public interest.

A matter that relates solely to an individual’s own employment circumstances, such as pay, working hours, interpersonal disagreements or an individual employment complaint, will normally be addressed through the appropriate grievance or other employment procedure.

However, a matter should not automatically be treated solely as a grievance merely because it personally affects the worker.

For example, a disclosure concerning sexual harassment may qualify as whistleblowing where the worker reasonably believes that the disclosure is in the public interest and the other statutory requirements for a protected disclosure are satisfied.

Where there is uncertainty about whether a concern should be considered under the Whistleblowing Policy, Grievance Policy, Harassment Policy, Safeguarding Policy or another procedure, {{org_field_name}} will consider the nature of the information raised and ensure that the concern is directed through the appropriate process without discouraging the individual from speaking up.

3. Encouraging a Culture of Speaking Up

At {{org_field_name}}, we actively encourage staff to voice concerns as soon as possible. We recognise that employees may feel hesitant about raising issues due to fear of reprisal or uncertainty about whether their concerns are valid. To create a culture where speaking up is valued, we:

Ensure that all employees are aware of their right to report concerns without suffering negative consequences.
Provide clear, confidential channels for raising concerns.
Offer reassurance that reports will be taken seriously and investigated promptly.
Commit to protecting whistleblowers from victimisation or retaliation.
We recognise and proactively guard against closed cultures by listening to early warning signs, analysing trends from concerns, and sharing learning openly.
We will nominate a Speak Up Lead/Champion (and, where appropriate, a Freedom to Speak Up Guardian-equivalent) who is independent of line management, visible to staff, and trained to receive concerns.
Any victimisation or detriment against someone who speaks up (or who helps someone to speak up) will be treated as gross misconduct.

Employees who raise concerns in good faith will never be treated unfairly, dismissed, or subjected to any form of detriment for doing so.

4. How to Raise a Concern

If anyone is at immediate risk of harm, call emergency services and/or the Local Authority Safeguarding Team without delay, then inform the Registered Manager as soon as it is safe to do so.

Employees who witness wrongdoing or have concerns should report them as soon as possible. Concerns can be raised in several ways, depending on the employee’s comfort level and the nature of the issue.

Where to report:

1) Verbally to the Registered Manager or Safeguarding Lead

2) Inform the Registered Manager by email: {{org_field_registered_manager_email}}

3) Call the office and inform the Registered Manager or Safeguarding Lead: {{org_field_phone_no}}

4) Out of hours phone number: {{org_field_out_of_hours}}

5) Online via our website: {{org_field_website}}

You can raise a concern with {{org_field_name}} or with a prescribed person (such as the CQC) at any time—you do not have to raise it internally first to be legally protected.

Outside organisations:

• Care Quality Commission (CQC): 03000 616161 (you may report as a worker at any time).
• Local Authority Adult Safeguarding: {{org_field_local_authority_authority_name}} — {{org_field_local_authority_information_link}}.
• NSPCC Whistleblowing Advice Line (for concerns about risks to children): 0800 028 0285 or help@nspcc.org.uk.
• Protect (independent whistleblowing charity): 020 3117 2520 or whistle@protect-advice.org.uk for confidential advice.
• Acas (employment rights advice and early conciliation): 0300 123 1100.
• Equality and Human Rights Commission (serious equality/human rights concerns): 0808 800 0082.

4.1. Informal Resolution

In some cases, issues may be resolved informally by speaking directly to a line manager or supervisor. If an employee feels comfortable doing so, they are encouraged to discuss their concerns with their immediate superior, who will take appropriate action.

Informal discussion is optional; if you prefer, you may raise your concern formally or with a prescribed person at any stage.

4.2. Formal Reporting

If the concern is serious or the employee feels unable to report it informally, they should raise it formally through one of the following channels:

Line Manager or Supervisor: If the issue cannot be resolved informally, employees can report their concerns in writing or in a confidential meeting.
Whistleblowing Officer (Designated Lead): We have appointed a senior staff member to act as the Whistleblowing Officer. This individual is responsible for handling reports confidentially, initiating investigations, and ensuring appropriate action is taken.
Senior Management or Director: If the employee feels their concern has not been addressed at a lower level, they may escalate it to senior management.

Anonymous reporting: You may raise concerns anonymously through any of the channels above. We will review and act on anonymous concerns where possible, but anonymity can limit our ability to investigate and to update you.

4.3. External Reporting

If an employee believes that their concern has not been properly addressed internally, or if they fear a conflict of interest, they may report their concern to an external authority. This includes:

Care Quality Commission (CQC): Employees can report concerns about unsafe care or regulatory breaches directly to the CQC.
Local Authority Safeguarding Team: If the concern relates to abuse or neglect, it may be appropriate to report it to the local safeguarding authority.
Police or NHS England: For concerns involving criminal activity or patient safety.
Public Concern at Work (Protect): An independent charity providing legal advice to whistleblowers.

Employees should only escalate concerns externally if they have attempted to resolve them internally first, unless the matter is urgent and reporting externally is necessary to prevent immediate harm.

5. Handling Whistleblowing Reports

When a concern is raised, {{org_field_name}} follows a structured process to ensure that it is handled fairly and effectively.

5.1 Acknowledgement and initial risk assessment

We acknowledge all reports within five working days. A trained investigator (or the Whistleblowing Officer) will complete an initial risk assessment to decide immediate safety actions, safeguarding referrals, and whether statutory notifications to external bodies (including the CQC) are required.

5.2. Investigation Process

Where investigation is warranted, we will set clear terms of reference, identify an investigator with appropriate seniority and independence, and gather relevant evidence sensitively and confidentially. We will give the reporter an indicative timescale and provide periodic updates while protecting confidentiality.

Employees who raise concerns will be kept informed of the progress of the investigation, where appropriate, while maintaining confidentiality. Investigations should typically conclude within 28 days; where more time is needed, we will explain why and give a revised timescale.

5.3. Outcome and Action

Once the investigation is complete, appropriate action is taken based on the findings. This may include:

Implementing corrective measures to resolve the issue.
Disciplinary action against individuals found guilty of wrongdoing.
Reporting findings to external authorities if required.
Share learning and changes with staff (“you said, we did”) and feed themes into governance and quality improvement.
Where allegations are not upheld, consider whether system improvements or further training are still warranted.

Whistleblowers will be informed of the outcome, subject to confidentiality considerations, and any further steps that may be taken to address the issue.

6. Protection and Support for Whistleblowers

We recognise that employees who report concerns may feel vulnerable. {{org_field_name}} strictly prohibits retaliation against whistleblowers and will take disciplinary action against anyone found to be victimising or harassing an individual for speaking up.

Whistleblowers who believe they are experiencing retaliation should report it immediately to the Whistleblowing Officer or senior management. We offer additional support, including:

Confidential counselling services for employees who experience distress as a result of reporting concerns.
Alternative work arrangements where necessary to protect whistleblowers from harassment.
Mediation services to address any conflict that arises following a report.
Detriment includes dismissal, disciplinary action, unjustified negative appraisals, denial of training or opportunities, bullying/harassment, or threats.
Allegations of victimisation will be investigated swiftly; substantiated cases may result in disciplinary action up to and including dismissal.
Reasonable adjustments and alternative reporting routes will be offered to ensure people with different backgrounds and protected characteristics can speak up safely.

7. Confidentiality and Anonymity

All whistleblowing reports are treated with the highest level of confidentiality. Employees may choose to report concerns anonymously; however, anonymity may limit the organisation’s ability to fully investigate and address the issue.

We will keep your identity confidential and will not share it beyond those who need to know without your consent, unless we are legally required to do so—for example, where a vulnerable adult or child may be at risk, a serious crime may have been committed, or another authority must act to ensure safety. Any information shared will be limited to what is necessary.

Records of concerns will be stored securely, with access restricted on a need-to-know basis and retained in line with our data protection and retention policies.

8. Compliance and Policy Review

This policy will be reviewed at least annually and after any significant legal or regulatory change. The Registered Manager (and Speak Up Lead/Champion) is responsible for implementation and effectiveness.

We will:

• maintain a secure Speak Up log to track concerns, actions and learning;

• analyse themes and report them through governance/quality meetings;

• ensure all staff (including agency/bank staff and volunteers) receive induction and periodic refresher training on speaking up;

• test the effectiveness of our speaking up culture (for example, via surveys or forums) and act on feedback.

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}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.

DC29-Whistleblowing (Speaking Up) Policy