Whistleblowing Policy

This policy provides a framework for raising concerns about suspected wrongdoing, malpractice, misconduct or risks affecting Model Britain, its activities or those connected with the organisation.

Its purpose is to encourage concerns to be raised responsibly, provide an appropriate route for considering them and support a culture in which people can speak up without fear of improper treatment for doing so.

This policy should be read in the context of applicable UK whistleblowing legislation, including the Public Interest Disclosure Act 1998.

Model Britain encourages genuine concerns to be raised by people working with or connected to the organisation, including:

• Employees and workers.
• Directors and members of governance bodies.
• Contractors, consultants and professional advisers.
• Suppliers and service providers.
• Volunteers, where applicable.
• Partners and other project stakeholders.

Members of the public may also bring serious concerns to Model Britain's attention. However, whether a disclosure receives statutory whistleblowing protection depends upon the circumstances and applicable law.

A whistleblowing concern will generally involve suspected wrongdoing that affects others or has a wider public-interest dimension rather than simply a personal disagreement.

Examples may include reasonable concerns relating to:

• Fraud, theft, bribery, corruption or other financial misconduct.
• Criminal activity or suspected breaches of law.
• Failure to comply with a legal or regulatory obligation.
• Serious health and safety risks.
• Serious environmental damage or risk.
• Misuse of company, investor, sponsorship or public funds.
• Serious misconduct, abuse or unethical behaviour.
• Deliberate concealment of suspected wrongdoing.

Whistleblowing is different from raising a personal grievance or complaint about an individual's own employment, contractual relationship or treatment.

Matters such as an individual employment dispute, disagreement over working arrangements or other personal grievance will normally be dealt with through the appropriate grievance, HR, contractual or complaints process rather than this policy.

Concerns should be raised as soon as reasonably practicable. Please provide enough information for the matter to be understood and assessed.

Helpful information may include what happened, when and where it occurred, the people or organisations involved, why you believe there may be wrongdoing and any supporting information or documentation available to you.

Reports may be made anonymously. However, anonymity can sometimes make it more difficult to investigate a concern, obtain further information or provide feedback.

The action taken will depend upon the nature, seriousness and circumstances of the concern. Where appropriate, Model Britain may take the following steps:

It may not always be possible to provide detailed information about an investigation, its findings or action taken because of confidentiality, privacy, legal or other legitimate considerations.

Model Britain will seek to handle whistleblowing concerns sensitively and confidentially so far as reasonably practicable.

Information may nevertheless need to be shared with individuals involved in assessing or investigating the matter, professional advisers, regulators, law-enforcement bodies or other appropriate parties where this is necessary or legally required.

Where someone asks for their identity to remain confidential, we will seek to respect that request so far as reasonably practicable, although absolute confidentiality cannot be guaranteed in every circumstance.

Model Britain does not tolerate victimisation, retaliation or other improper detrimental treatment of a person because they have raised a genuine concern in accordance with this policy.

Workers who make a qualifying protected disclosure may also have statutory protections under UK whistleblowing law.

Anyone who believes they have experienced retaliation or detrimental treatment after raising a concern should report this promptly.

A person raising a concern is not expected to prove that wrongdoing has occurred before speaking up. Concerns raised honestly and on reasonable grounds will be considered appropriately even if they ultimately prove to be mistaken.

Knowingly making a false allegation, deliberately providing false information or acting maliciously is different from raising a genuine concern that turns out to be unfounded. Deliberately false or malicious allegations may be dealt with through appropriate contractual, disciplinary or legal processes where applicable.

Nothing in this policy prevents an individual from seeking independent advice or making a disclosure to an appropriate prescribed person, regulator, law-enforcement body or other authority where permitted by law.

Useful independent sources include:

Personal information received in connection with a whistleblowing concern will be handled in accordance with applicable data protection law and Model Britain's Privacy Policy .

Information will be limited, accessed, retained and disclosed as appropriate to the nature of the concern, any investigation and applicable legal or regulatory requirements.

Model Britain will review this policy periodically and may amend it as the organisation, project, governance arrangements or applicable legal and regulatory requirements develop.

The current published version of this policy will be made available through the Model Britain website.