Whistle Blowing

1. Introduction
1.1. This policy applies to the GBWR group (GBWR), presently Great Britain Wheelchair Rugby Limited and its subsidiary GBWR Trading Limited; the policy will also apply equally to any additional subsidiary(ies) which may form part of the GBWR group from time to time.
1.2. Directors, employees, consultants, and volunteers (collectively ‘Workers’), are often the first to realise that there may be something seriously wrong within an organisation. However, they may not express their concerns because they feel that speaking up would be disloyal to their colleagues or to the organisation. They may also fear harassment or victimisation. In these circumstances, Worker may decide it is preferable to ignore the concern rather than report what may be a suspicion of malpractice. This policy is implemented to address concerns which may inhibit speaking up.
1.3. Please note that this whistle-blowing policy is designed for use where there are concerns about serious malpractice, impropriety, or cover-up. For other matters, there are existing grievance policy and associated procedures in place to enable staff to lodge a grievance relating to employment matters and there are existing complaints policy and procedures for volunteers, members, contractors, and the public to raise any general complaints with GBWR.
1.4. GBWR is committed to the highest possible standards of openness, probity, and accountability. In line with that commitment GBWR expects all who have contact with the organisation and who have serious concerns about any aspect of its work, to come forward and voice those concerns. Cases will proceed on a confidential basis where so practical, however confidentiality may be waived where maintaining confidentiality proves to be a hindrance to the investigation (see section 5.).
1.5. The provisions of the Public Interest Disclosure Act 1998 (as it may be amended from time to time) protect most Workers from suffering any detriment or dismissal as a result of raising a genuine concern. This whistle-blowing policy provides guidance as to how to raise concerns and makes it clear that an individual may report any concern without fear of victimisation, subsequent discrimination, or disadvantage.
1.6. GBWR also encourages all others who have contact with the organisation, such as members, to also use the process set out in this policy to raise any serious concerns within GBWR rather than overlooking a problem or airing their concerns outside the charity.

2. Aims of policy
2.1. This whistle-blowing policy is designed to enable anyone to raise concerns internally and at a high level and to disclose information which the individual believes shows malpractice or impropriety. In particular, the policy aims to:
• encourage individuals to feel confident in raising serious concerns and to question and act upon concerns about practice;
• provide avenues to raise concerns and receive feedback on any action taken;
• ensure that the individual receives a response to any concern and that they are aware of how to pursue them if not satisfied with such a response; and
• re-assure individuals that they will be protected from possible reprisals or victimisation providing there is reasonable belief that there is a concern and the disclosure of that concern is made in the public interest.

3. Scope of policy
3.1. This policy is intended to cover concerns which are in the public interest and may at least initially be investigated separately, but then might lead to the invocation of other procedures, eg disciplinary.
3.2. Such concerns may include:
• Criminal activity
• Failure to comply with a legal obligation
• Dangers to health and safety
• Damage to the environment
• Miscarriages of justice
• Financial malpractice, impropriety, bribery, or fraud
• Improper or unethical behaviour
• Failure to comply with GBWR policies and procedures
Or attempts to deliberately conceal any of these matters
3.3. A concern may be raised in relation to something which has already happened, is currently happening, or is likely to happen.

4. Safeguards
4.1. GBWR is committed to good practice and high standards and aims to be supportive of all who are involved with the organisation. The policy is designed to offer protection to all who disclose concerns, provided any disclosure is made:
• in the public interest;
• in the reasonable belief of the individual making the disclosure that it tends to show conduct that falls within points at paragraphs 2 and 3 above; and
• to an appropriate person (please see below).
4.2. The Public Interest Disclosure Act 1998 (as it may be amended from time to time) protects most Workers from victimisation, discipline, or dismissal where they raise genuine concerns of misconduct or malpractice.
4.3. GBWR will not tolerate any harassment or victimisation (including informal pressures) and will take appropriate action to protect all who raise a concern through the internal whistle-blowing procedure.
4.4. Any investigation into allegations of potential malpractice will not influence or be influenced by any disciplinary or redundancy procedures that may already affect a Worker.

5. Confidentiality and anonymous allegations
5.1. This policy strongly encourages individuals to put their name to any whistle-blowing disclosures they make so that they can be contacted for further details or to check information during the investigation. While putting a name to the disclosure is strongly encouraged, disclosures made anonymously will be considered, although GBWR’s ability to investigate anonymous disclosures may be more limited.
5.2. GBWR will treat all such disclosures in a confidential and sensitive manner. The identity of the individual making the allegation may be kept confidential so long as it does not hinder or frustrate any investigation. However, the investigation process may reveal the source of the information and the individual making the disclosure may need to provide a statement as part of the evidence required.

6. Untrue allegations
6.1. In making any whistle-blowing disclosure, an individual needs to exercise due care to ensure the accuracy of the information, but the individual should not undertake his or her own investigation to confirm the accuracy of information or take any steps to gather further evidence to support their disclosure. If an individual makes an allegation in the reasonable belief it is in the public interest, which is not confirmed by subsequent investigation, then no action will be taken against that individual.
6.2. If, however, an individual makes any frivolous, malicious, or vexatious allegations, or makes an allegation with a view to personal gain or where he or she does not have a reasonable belief that the disclosure is made in the public interest (and even more so if they persist in making them), GBWR may take disciplinary or other action against that individual as an allegation without genuine concern does not afford Workers protections under the Public Interest Disclosure Act 1998.

7. How to report a concern and relevant timescales
7.1. In reporting a concern, one should not attempt to deal with any whistle-blowing allegation or suspicion themselves, nor mention the concerns to anyone else outside of the reporting line set out in this policy.
7.2. Workers should report any whistle-blowing concerns they have to their line manager. All others should report any such concerns to the CEO (who acts as the monitoring officer for whistle-blowing concerns).
7.3. The reporting route depends, however, on the seriousness and sensitivity of the issues involved and on who is suspected of the malpractice. (For example, if the allegation is about a member of the senior leadership team, then concerns should be directed to the CEO; if the concern relates to the CEO, then the whistle-blower should report it to the chair, who may assign another board member to lead on the investigation, usually the senior independent director; in any case where the chair is the subject of the whistle-blowing concerns, then concerns should be raised to the senior independent director.)
7.4. Concerns may be raised verbally or in writing. In either case, the following should be provided:
• Background and history of the concern (giving relevant dates)
• Reason for the concerns
• Brief outline of the evidence offered to support the concerns
7.5. Anyone reporting a whistle-blowing concern should do so at the earliest opportunity so that appropriate action can be taken.
7.6. If GBWR is alerted to concerns via a ‘tip off’ (eg from a member of the public) then the person receiving the ‘tip off’ should attempt to obtain the following information from the informant:
• Name, address, and telephone number
• Names of individual and/or bodies involved
• A brief outline of the concerns
• How the informant became aware of the concerns
• Whether the informant is willing and able to submit evidence
• Whether the informant requests that GBWR maintains their anonymity so far as reasonably practical, as per section 5
and then follow the reporting procedures above.

8. Actions that GBWR will take and investigating procedure

8.1. GBWR is committed to investigating whistle-blowing disclosures fully, fairly, quickly, and confidentially, as circumstances permit.
8.2. The CEO (or chair/other designated board member in any case where the CEO is the subject of the whistle-blowing concerns, or senior independent director in any case where the chair is the subject of the whistle-blowing concerns) will act as investigating officer and will usually follow the below steps. These steps assume that the individual who has raised the concern has disclosed their name when making the disclosure. Some of these steps may not be appropriate in the case of anonymous disclosures.
• Obtain full details and clarifications of the whistle-blowing concerns
• In order to protect individuals and those accused of misdeeds or possible malpractice, make initial enquiries to decide whether an investigation is appropriate and, if so, what form it should take
• Within ten days, acknowledge to the whistle-blower that the concern has been received; indicate how it is proposed to deal with the matter; and inform them whether further investigations will take place and if not, the reason for not doing so
• If, in the judgement of the investigating officer, a full investigation of the whistle-blowing concern is warranted, then inform and consult with the chair
• Inform the individual against whom the whistle-blowing allegation is made, as soon as is practically possible; a Worker will be informed of their right to be accompanied by a trade union representative, colleague, or friend other than a family member at any future interview or hearing held under the provision of these procedures
• The investigating officer may, where appropriate, call on the assistance of other individuals and/or bodies. For example, in cases of possible fraud, the investigating officer may consider the involvement of the auditor and will inform the police; and in other cases of possible criminal activity, the investigating officer will inform the police. GBWR will ensure that any internal investigation does not hinder a formal police investigation
• Once the investigation is complete, the investigating officer will make a judgement concerning the validity, or otherwise, of the whistle-blowing concerns. This judgement will be detailed in a written report containing the findings of the investigation and reasons for the judgement. The report will be passed to the CEO or chair, as appropriate
• The CEO or any board member designated as the investigating officer will consult with the chair and they will decide what action to take. If the concerns raised by the whistle-blowing have been shown to be justified, then they will invoke the disciplinary or other appropriate GBWR procedures
• If appropriate, a copy of the outcomes will be passed to GBWR’s auditor to enable a review of relevant procedures.
• The investigating officer should keep the whistle-blower informed of the progress of the investigation and, if appropriate, of the final outcome; all responses to the whistle-blower should be in writing
• If the whistle-blower is not satisfied that their concerns have been properly dealt with by the investigating officer, then the whistle-blower has the right to raise this, in confidence, with the chair (or where the concern relates to the chair, then a member of the board, usually the senior independent director); the aim of this whistle-blowing policy is to provide an internal mechanism for reporting, investigating, and remedying any GBWR workplace wrongdoing – it is therefore hoped that it will not be necessary for a whistle-blower to alert external organisations, however, in very serious circumstances (or if all internal GBWR procedures have been exhausted but the whistle-blower considers the outcome of the investigations has not satisfactorily address the concerns) then GBWR recognises that it may be appropriate for an individual to report their concerns to an external body such as a regulator; the government has a prescribed list of external bodies which includes the police, HM Revenue and Customs, and the Health and Safety Executive – a full list (and an advice line) is available from an independent charity called Protect

9. Timescales
9.1. Owing to the varied nature of concerns raised by whistle-blowing, which may involve internal investigators and/or the police, it is not possible to lay down precise timescales for such investigations. The investigating officer should ensure that the investigations are undertaken as quickly as possible, without affecting the quality and depth of those investigations.

10. Responsible officer
10.1. The CEO acts as the whistle-blowing concerns monitoring officer and has overall responsibility for the maintenance and operation of this policy. The CEO will maintain a record of concerns raised and the outcome (but in a form which does not endanger confidentiality) and will report as necessary to the board.
10.2. This role is delegated to the chair/other designated board member in any case where the CEO is the subject of the whistle-blowing concerns, or senior independent director in any case where the chair is the subject of the whistle-blowing concerns.

V014 approved by the GBWR Board of Trustees at the meeting held March 2025
To be reviewed by the GBWR Board of Trustees March 2027