All representatives of the charity have an individual responsibility to protect and safeguard the charity’s assets, ensure safeguarding of beneficiaries and ensure compliance with this policy. The charity encourages all representatives of the charity and third parties to raise any concerns immediately in an open and transparent manner. All concerns will be treated seriously and confidentially. Anonymity will be maintained upon request. The charity’s whistleblowing policy and contact address will be published on its website.
Any concerns regarding the protection and safeguarding of the charity’s assets, safeguarding of beneficiaries or fundraising practice should be flagged to the Chief Executive. If the Chief Executive is implicated, then the concern should be flagged to a trustee.
The Chief Executive (or trustee) should:
- Acknowledge the concern in writing within 5 working days of receipt.
- Complete an investigation to establish the facts and circumstances relating to the concern within 30 working days, or as soon as is reasonably practicable. Specialist support may be sought.
- Report back in writing to the individual who raised the concern within 45 working days, or as soon as is reasonably practicable, explaining the outcome of the investigation, conclusions reached, and actions to be taken.
The Chief Executive (or trustee) may, at his/her discretion, seek input from the Chair of the Board of Trustees at any point during this process who may, at his/her discretion, recommend discussion by the full Board before proceeding. If the Chair is implicated, then another trustee.
When the cause for concern is found to be valid the charity must take appropriate action. Specific actions will depend on the facts and circumstances. Examples may include, but are not limited to:
- Issuing a verbal or written warning.
- Taking immediate steps to dissociate the charity from the activity, individual or organisation.
- Making changes to the charity’s policies and procedures.
- Taking legal action.
- Developing an internal and external communications strategy.
- Reporting to the Charity Commission under the Reporting Serious Incidents regime.
- Advising professional advisors, for example insurers, external auditors / independent examiners and banks.
- Contacting the Anti-Terrorist Hotline on +44(0)800 789 321.
- Calling the DFID confidential hotline on +44 (0)1355 843747
- Reporting to Action Fraud
Without exception, any evidence of criminal activity including actual or suspected incidents of bribery, fraud, theft, money laundering, terrorist financing or other financial crime will be reported to the police and to the Charity Commission.
Any inappropriate fundraising activity will be reported to the fundraising regulator’s complaints mechanism https://www.fundraisingregulator.org.uk/