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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Whistleblowing Policy

1. Purpose

The purpose of this policy is to provide clear guidance to all employees, agency workers, and contractors on how to raise concerns about wrongdoing or malpractice within {{org_field_name}}. This policy aims to encourage a culture of openness, accountability, and integrity, ensuring that concerns are raised in a responsible and protected manner.

2. Scope

This policy applies to all individuals working for or on behalf of {{org_field_name}}, including employees, workers, agency workers supplied by us or engaged through us, contractors, consultants, volunteers, and directors. It also applies to concerns raised by former workers where the concern relates to their engagement with {{org_field_name}}.

This policy covers concerns about wrongdoing connected with our business activities, our recruitment and staffing services, our workers, our clients/hirers, suppliers, and any third parties where the concern affects or may affect {{org_field_name}}’s operations, legal compliance, or the safety and wellbeing of workers, candidates, clients, service users or members of the public.

3. Definition of Whistleblowing

Whistleblowing is the disclosure of information that relates to suspected wrongdoing or dangers in the workplace. For a disclosure to be protected in law, it must usually be a “qualifying disclosure” (i.e., information which the individual reasonably believes shows one of the types of wrongdoing listed below) and the individual must reasonably believe the disclosure is made in the public interest (not solely a personal employment dispute).

This can include:

• A criminal offence (e.g., fraud or abuse)
• Failure to comply with legal or regulatory obligations
• Sexual harassment or other unlawful harassment, or a failure to prevent or address it, where this amounts to a breach of legal obligations
• A miscarriage of justice
• Endangering the health and safety of an individual
• Damage to the environment
• Deliberate concealment of any of the above

4. Reporting Procedures

Employees or workers who wish to raise a concern should follow these steps:

Step 1: Internal Reporting
Concerns should be raised with the Registered Manager:

• Name: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
• Email: {{org_field_registered_manager_email}}
• Phone: {{org_field_registered_manager_phone}}

If the concern involves the Registered Manager, the issue should be raised with a senior director or an external reporting authority.

Step 2: External Reporting

In some circumstances, it may be appropriate to report concerns externally (for example, where you reasonably believe the matter will be covered up, you fear retaliation, evidence may be destroyed, or you have already raised the concern internally and it has not been addressed).

The law provides additional protections where disclosures are made to certain “prescribed persons” (regulators and public bodies). The list of prescribed persons changes over time. The current list is published by GOV.UK and should be used to identify the correct body for your concern (e.g., Health and Safety Executive for health and safety issues, HMRC for National Minimum Wage concerns, Information Commissioner’s Office for data protection concerns).

Examples of external bodies that may be relevant to a temporary staffing agency include (depending on the issue):

• Health and Safety Executive (HSE) – workplace health and safety.
• HM Revenue & Customs (HMRC) – National Minimum Wage / unlawful deductions and certain tax issues.
• Employment Agency Standards Inspectorate (EAS) – agency conduct and some agency business compliance issues (where within its remit).
• Gangmasters and Labour Abuse Authority (GLAA) – labour exploitation (where applicable).
• Information Commissioner’s Office (ICO) – data protection / information security concerns.
• Local Authority Safeguarding – safeguarding concerns (where a worker/candidate or service user is at risk).

Where you are unsure, you can seek independent advice before reporting externally.

5. Confidentiality and Protection

{{org_field_name}} will treat whistleblowing disclosures sensitively and will take reasonable steps to protect the whistleblower’s identity where requested. However, confidentiality cannot be guaranteed in all circumstances (for example, where disclosure is required by law, where there is an overriding public interest, or where it is necessary to investigate the concern fairly).

Individuals who make a protected whistleblowing disclosure are protected in law (under the Public Interest Disclosure Act 1998 and the relevant provisions of the Employment Rights Act 1996) from:

• detrimental treatment because they have made (or are believed to have made) a protected disclosure; and/or
• dismissal (for employees) where the reason or principal reason is that they made a protected disclosure.

A disclosure does not have to be made “in good faith” to qualify for legal protection; however, compensation may be reduced by an employment tribunal where a disclosure is found not to have been made in good faith.

Anonymous disclosures will be considered, but anonymity can make investigation and feedback more difficult.

Whistleblowing records will be handled in line with UK GDPR / Data Protection Act 2018 requirements, including access controls and appropriate retention periods.

6. False or Malicious Allegations

{{org_field_name}} will not take action against anyone who raises a concern honestly and reasonably, even if the concern later proves to be mistaken or cannot be substantiated.

However, if an individual is found to have knowingly made a false disclosure or acted maliciously, this may result in disciplinary action (or other appropriate action for non-employees).

7. What happens after a concern is raised

• Acknowledgement: We will normally acknowledge receipt within 5 working days, unless the report is anonymous.
• Initial assessment: We will assess the concern to determine whether it should be handled under this whistleblowing policy or another process (e.g., grievance, safeguarding, disciplinary, or health & safety procedures).
• Investigation: Where appropriate, an investigator will be appointed who is independent of the allegations as far as reasonably possible.
• Updates and outcome: We will provide reasonable updates and, where appropriate, information about the outcome. We may be limited in what we can share due to confidentiality, data protection, and legal constraints.
• Escalation: If you believe your concern has not been handled appropriately, you may escalate to a Director or consider external reporting.

8. Investigations and Outcomes

• Once a report is received, an initial assessment will determine the appropriate course of action.
• An internal investigation may be conducted, and findings will be communicated where appropriate.
• If necessary, external authorities will be involved.

9. Support for Whistleblowers

• Employees who experience any form of retaliation for whistleblowing should report it immediately.
• Support will be provided, including access to confidential counselling services if required.

10. Related Policies

• Safeguarding Policy
• Health and Safety Policy
• Grievance and Disciplinary Policy
• Anti-Fraud and Corruption Policy

11. Policy Review

This policy will be reviewed annually or sooner if there are significant changes in legislation or business operations. Any amendments will be communicated to all staff.

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