April 2024
Deptford Housing Cooperative
Whistleblowing Policy
1.0
What is Whistleblowing?
Whistleblowing is the term used when a person reports wrongdoing. In this
guidance, we call that “whistleblowing reports” or “raising concerns”.
2.0
Our Policy
Deptford Housing Cooperative (DHC) encourages a trusting and supportive
environment for our members, employees, customers, suppliers and
stakeholders. DHC takes malpractice or misconduct seriously and is
committed to a culture of openness, trust and respect in which every
stakeholder can report legitimate concerns and be assured of protection
against victimisation.
2.1
Any person that raises concerns under this policy can be assured that any
matter raised will be investigated thoroughly, promptly and confidentially, and
the outcome of the investigation reported back to the person who raised the
concern.
2.1.1
The Co-operative Code of Governance states that:
“There should be a documented whistle-blowing procedure for the
members, workforce and stakeholders to raise concerns in confidence
and – if they wish – anonymously. The board should routinely review the
procedure and any concerns raised and ensure a policy is in place to
ensure proportionate and independent investigation and follow up.”
2.2
We will listen to whistleblowing reports, treat them seriously, and try to resolve
them as quickly as possible and learn from them so that we can continuously
improve.
2.3
The purpose of this policy is:
2.3.1
To enable Deptford Housing Cooperative to act quickly against any
potential malpractice to ensure it conducts its business with the
highest standards of integrity and honesty at all times.
2.3.2
To identify risks that Deptford Housing Cooperative may not know
about.
2.3.3
To remind members, employees, customers, suppliers, wider
stakeholders and the public to speak out in confidence if they have
concerns and to be assured that they do not need to provide evidence
for their concerns to be raised.
2.3.4
To raise awareness of the importance of preventing and eliminating
wrongdoing at work. Members, employees, customers, suppliers and
wider stakeholders should be watchful for illegal or unethical conduct
and report anything of that nature that they become aware of.
2.3.5
To reassure any person raising concerns will be protected from
possible reprisals or victimisation having made a disclosure in good
faith.
2.3.6
To highlight that there are other routes to raise concerns if a person
feels that they cannot speak up.
2.4
This policy and procedure sets out how DHC will deal with whistleblowing from
its members, employees, customers, suppliers wider stakeholders and the
general public.
3.0
What types of Concerns are Covered?
3.1.1
Conduct which is an offence or a breach of law, including but not
limited to corruption, fraud or bribery.
3.1.2
A miscarriage of justice.
3.1.3
An act creating risk to health and safety.
3.1.4
An act causing damage to the environment.
3.1.5
The unauthorised use of public funds or other financial irregularities.
3.1.6
Sexual or physical abuse.
3.1.7
Other unethical conduct.
3.1.8
Concealment of any of the above
3.2
This Policy cannot be used to question financial or business decisions taken
by DHC, and nor should it be used to reconsider any personal grievances such
as bullying, harassment and discrimination which are not covered by
whistleblowing legislation. In such cases DHC’s Complaints or Grievance
policies should be consulted instead. If you are unclear which policy you
should use please speak to the Housing Manager or the Chair of DHC.
3.3
If you are unsure about whether or how to raise a concern or want confidential
advice about raising concerns about serious malpractice at work, you can
contact the independent charity ‘Protect’ – https://protect-advice.org.uk
for
contact details.
4.0
Confidentiality
DHC will ensure that all concerns raised will be treated in confidence and
every effort will be made not to reveal your identity if you wish. At the
appropriate time, however, we may ask you to come forward as a witness.
This policy encourages you however to provide your name and contact details
on your concern whenever possible, if you do not do so we are unable to go
back to you for further information, which can make investigating the concerns
that were raised difficult.
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4.1
Please note that you:
4.1.1
You must disclose the information in good faith.
4.1.2
You must believe it to be substantially true.
4.1.3
You must not act maliciously or make false allegations.
4.1.4
You must not seek any personal gain.
4.2
DHC recognises there may be matters that cannot be dealt with internally and
external authorities will need to become involved. Where this is necessary, we
reserve the right to make such a referral without an individual’s consent.
5.0
Protection from Detriment
5.1
Wrongdoing reported by a member, employee, customer, supplier, wider
stakeholder and the public will usually (although not necessarily) be something
they have witnessed on DHC’s estate.
5.2
With regards to employees, DHC will ensure the Public Interest Disclosure Act
1998 is applied in all cases. This policy does not form part of an employee’s
contract of employment and may be amended or withdrawn at any time.
5.3
DHC commits that no individual who makes a report under this policy will be
subjected to any detriment as a result, in accordance with the Employments
Rights Act 1996.
5.3.1
5.3.2
5.3.3
5.3.4
In the event that a person believes they are being subjected to a
detriment by any other person within Deptford Housing Cooperative as
a result of their decision to disclose, they must inform the Chair and
appropriate action will be taken to protect them from any reprisals.
If any person tries to discourage another member, employee,
customer, supplier, wider stakeholder or a member of the public from
coming forward to express a concern, or criticises or victimises them
after a concern has been raised, he or she may be subject to formal
disciplinary action.
we will do everything possible to maintain confidentiality. However,
there may be circumstances where the information may need to be
discussed or disclosed to third parties, including other employees of
Deptford Housing Cooperative in order that the information may be
properly investigated or as part of any disciplinary or criminal
proceedings.
individuals qualify for whistleblower protection provided the disclosures
made have a connection to the wider public interest.
6.0
Untrue Allegations
6.1
If an individual makes an allegation or raises concerns in good faith, which is
not confirmed by subsequent investigation, no action will be taken against that
individual. In making a disclosure the individual should exercise due care to
ensure the accuracy of the information.
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6.2
If, however, an individual makes malicious or vexatious allegations, and
particularly if they persist with making them, action may be taken against that
individual.
7.0
Resolving Concerns and Complaints
7.1
As with many other organisations, most concerns that are raised can be
quickly resolved through either a phone call or email to the Housing Manager.
We prefer to receive complaints in writing so if you make a complaint in person
or over the phone, you may be asked to follow this up in an email.
7.2
We keep a record of all correspondence relating to whistleblowing and the final
outcome. We may report instances of whistleblowing to our Management
Committee and members but will never provide details of the content of the
complaint or the complainant.
7.3
Any person raising concerns under this policy can expect to be treated with
courtesy, respect and fairness at all times. We expect that you will also treat
our staff dealing with your concern with the same courtesy, respect and
fairness. We will deal with your concern promptly and will not treat you less
favourably than anyone else because of your sex or legal marital or same-sex
partnership status: this includes family status, responsibility for dependants,
and gender (including gender reassignment, whether proposed, commenced
or completed); sexual orientation; colour or race (this includes ethnic or
national origin or nationality); disability; religious or political beliefs, or trade
union affiliation or any other unjustifiable factors, for example language
difficulties, age, pregnancy and maternity.
7.4
If you feel your complaint has not been resolved to your satisfaction you will be
provided with an opportunity to escalate the complaint within a reasonable
timeframe. The process for escalation is provided in the Complaints Procedure
below.
8.0
Reporting Procedure
8.1
Consider raising your concern informally. If it is not possible to resolve your
concern informally or if you consider the matter is too serious to be handled
informally, you should follow this formal procedure.
8.2
Email your concerns to chair@deptfordhousing.coop with
WHISTLEBLOWING’ included in the email title. The Chair of the Management
Committee will contact you to acknowledge receipt of your concerns and give
guidance on next steps.
8.2
A confidential log of all concerns raised will be kept by the Chair and anyone
involved in any whistleblowing concern raised. The Chair will retain all relevant
correspondence until after the completion of an investigation and all escalation
routes have been exhausted, and the outcome of any investigation has been
reported to the person who raised the concern.
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8.4
To help ensure your concerns are addressed as soon as possible please
provide as much information as possible as missing or inaccurate information
can lead to a delay. For your concerns to be reviewed, it is important the
following information is supplied:
8.4.1
Your full name and whether you are a member, employee, customer,
supplier, wider stakeholder or member of the public.
8.4.2
The date the concern is raised.
8.4.3
A summary of your concerns.
8.4.4
Details of any witnesses or supporting evidence.
8.4.5
Details of steps you have taken to resolve this matter informally.
9.0
What Happens Next
9.1
Your concern will be acknowledged within five working days of receipt. You will
receive a response within 20 working days.
9.2
Dependent upon the nature of the concern/s raised, it may be escalated by the
Chair to another member of the DHC Management Committee.
9.3
The Chair will arrange an investigation into the concern and will appoint an
appropriate person to undertake the investigation. This may be a senior staff
member or another member of the DHC Management Committee.
– they will be named the Investigating Officer.
9.4
The investigation may involve the employee, member or stakeholder and any
other individuals involved giving a written statement. Any investigation will be
carried out in accordance with the Policy set out above. The statement of the
person raising concerns will be taken into account, and they will be asked to
comment on any additional evidence obtained. The Investigating Officer will
then report to the Management Committee, which will take any necessary
action, including reporting the matter to any appropriate government
department or regulatory agency.
9.5
If disciplinary action is required, the Investigating Officer will report the matter
to the relevant line manager and start the disciplinary procedure.
9.6
On conclusion of any investigation, the person who raised concerns will be told
the outcome of the investigation and what DHC has done, or proposes to do
about it. If no action is to be taken, the reason for this will be explained.
10.0
Review
The management committee is responsible for ensuring that this policy is reviewed
annually to ensure continued relevance and good practice. Updates and
amendments may be proposed, considered and approved via an SGM.
Last updated: April 2024
Date of next review: April 2025
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