Whistleblowing Policy

• Everyone should be aware of the importance of preventing and eliminating wrongdoing at work. Employees should be watchful for illegal or unethical conduct and report anything of that nature that they become aware of.
• Any matter raised under this procedure will be investigated thoroughly, promptly and confidentially, and the outcome of the investigation reported back to the employee who raised the issue.
• No employee will be victimised for raising a matter under this procedure. This means that the continued employment and opportunities for future promotion or training of the employee will not be prejudiced because he/she has raised a legitimate concern.
• Victimisation of an employee for raising a qualified disclosure will be a disciplinary offence.
• If misconduct is discovered as a result of any investigation under this procedure the Cathedral's disciplinary procedure will be used, in addition to any appropriate external measures.
• Maliciously making a false allegation is a disciplinary offence.
• An instruction to cover up wrongdoing is itself a disciplinary offence. If told not to raise or pursue any concern, even by a person in authority such as a manager, employees should not agree to remain silent. They should report the matter to the Communar / Executive Director or a non-executive member of Chapter or, if a member of Chapter is not available, to the appropriate external authority.

This policy applies to everyone who works for and in or volunteers in the cathedral. This means employees, workers, office holders, volunteers, interns and contractors.

‘Whistleblowing’ refers to the internal or external disclosure of malpractice and serious suspected wrongdoing as well as illegal acts, or omissions, at work. It covers, for example, how we raise funds, how we commission work or make payments and where there has been a breach of a legal, statutory or regulatory requirement or unethical behaviour.

To use this whistleblowing policy and be legally protected under the Act, you must make a disclosure about a serious concern. This is known under the Act as a ‘qualifying disclosure’. This means you have information and reasonably believe that one or more of the following matters is happening, has taken place, or is likely to happen in the future:

1. a criminal offence (including fraudulent and corrupt behaviour, e.g., theft, fraud or malpractice)
2. a miscarriage of justice
3. an act creating risk to health and safety 
4. an act causing damage to the environment 
5. a breach of any other legal obligation,
6. Unethical behaviour
7. concealment of any of the above

You do not need to have proof that such an act is being, has been, or is likely to be, committed. You do, however, need to hold a reasonable belief of such an action having been, being or likely to be carried out.

This whistleblowing policy does not apply to:

Complaints: A complaint that is an expression of your dissatisfaction which calls for a response. If you want to make a complaint about the cathedral you should use our complaints policy.

Safeguarding concerns: For safeguarding concerns please contact safeguarding@chichestercathedral.org.uk

Concerns about other organisation: If you have concerns about the behaviour of another Church of England organisation, you should raise them through that organisation, following any whistleblowing procedures it has.

Employment related concerns: This policy does not deal with any complaints employees may have about their own employment position, which should be addressed through the Cathedral’s Grievance Procedure. (Bullying, harassment and discrimination are only covered by the whistleblowing policy when your particular case is in the public interest.)

How to raise a concern

You should raise your whistleblowing concern as soon as possible. This will make it easier to act and to enable any problems to be resolved or reported quickly. 

You can make your disclosure orally, but written disclosures are preferable as these will make the process more efficient and effective. In your disclosure, you should:

1. provide any relevant context and background, including relevant dates, venues, names etc
2. state clearly the reason why the situation causes for concern.

[You may find it useful to consider the following questions. What do I think is happening? What (if any) evidence do I have? Who is doing it? Why might it be wrong? What clear explanations may there be? May others be aware of the issue(s)? Who may I report this to?]

You must say that you are raising your concern using the whistleblowing policy and whether you wish your identity to be kept confidential. While we will make every effort to deal with your case confidentially, depending on the circumstances of the case this may not always be possible (e.g. if the police are involved). Where this is the case, you will be informed of this and the reasons why it was not possible. We prefer non-anonymous disclosures, as anonymity often makes it difficult to properly investigate concerns, protect employees or give feedback on outcomes.

c) The Head of Human Resources is designated to handle whistleblowing concerns in the Cathedral and is the Cathedral’s Whistleblowing Officer.

d) You should report your concern in the first instance to your line manager/volunteer co-ordinator where appropriate, or to the Whistleblowing Officer. If the matter concerns the Whistleblowing Officer, it should be raised with the Communar or the Dean. You may also report concerns directly to any non-executive member of Chapter (i.e. lay members or clergy, excluding the Dean, Chancellor, Precentor or Treasurer.)

e) If you are unsure whether to use this procedure, or you want independent advice at any stage, you should contact your trade union or an independent organisation such as Protect.

f) If you feel unable to whistle blow internally (especially if your concern lies with the Cathedral’s senior leadership, including members of Chapter) the matter may be reported directly to the Bishop, the Rt Revd Dr Martin Warner and/or the Diocesan Secretary, Ms Gabrielle Higgins. You may also contact the relevant regulator, such as the Charity Commission or Church Commissioners.

If you raise a concern which you believe to be true, the Chapter will take appropriate action to protect you from any harassment, victimisation or bullying. Employees and workers who raise a genuine concern under this policy will not be at risk of losing their job, nor will it influence any unrelated disciplinary action or redundancy procedures.

The matter will be treated confidentially but if the concern cannot be resolved without revealing your identity, the Whistleblowing Officer (or other person managing the process, where the complaint involves the Whistleblowing Officer) will make every effortto discuss with you whether and how to proceed.

You should note that they will not be protected from the consequences of making a disclosure if, by doing so, you commit a criminal offence.

How the concern will be dealt with, will depend on what it involves. It is likely that further enquiries and/or investigation will be necessary. The concern may be investigated by the Whistleblowing Officer, through the disciplinary process or it may be referred to the police, Diocesan Safeguarding Adviser, a regulator, other agencies, an external auditor or an independent investigator.

Typically, the matters raised may result in one or more of the following:

1. no action required
2. action being taken under another policy or procedure
3. an internal investigation under this policy
4. a referral to the police or other relevant statutory body
5. referral to the Church Commissioners
6. a referral to cathedral’s external auditors
7. a Serious Incident Report being made to the Charity Commission
8. an independent enquiry.

It may be necessary for you to give evidence in criminal or disciplinary proceedings.

The Whistleblowing Officer will give you feedback on the progress and outcome of any investigation, wherever possible. Your complaint will be acknowledged immediately and you will receive a response within five working days. If there is likely to be a delay you will receive an email explaining why.

If it is found that you have knowingly or maliciously makes an untrue allegation or you are involved in any way in the malpractice, wrongdoing or illegal acts or omissions, the Chapter will take appropriate action in accordance with the appropriate policy.

If the suspicions are not confirmed by an investigation, the matter will be closed and a record retained. Any person raising a concern under this policy will not suffer any detriment for raising the concern unless they are found to have made a malicious allegation.