ETC of PWD Whistle Blowing Policy

ETC of PWD Whistle Blowing Policy

Definition: Whistle Blowing is the term used when a worker, volunteer or other stakeholder passes on information concerning wrongdoing. The wrongdoing disclosed must be in the public interest. This means it must affect others. A whistle blower can raise a concern at any time about an incident that happened in the past, is happening now, or believes will happen in the near future.

Context: ETC of PWD is a small organisation,  it is not expected that will change. The ability for any of the trustees to raise concerns about others is implicit. The ability for any employees, volunteers and others formally associated with the charity (other stakeholders) to raise concerns is equally important. We must also bear in mind the constitution of a Charitable Incorporated Organisation under the Charities Commission:


If a dispute arises between members of the CIO about the validity or

propriety of anything done by the members under this constitution, and

the dispute cannot be resolved by agreement, the parties to the dispute

must first try in good faith to settle the dispute by mediation before

resorting to litigation.”

Advice: If a Whistle Blower wants external advice, as a registered charity there is CC guidance that any complainant of serious harm can follow

or email:

Any of the ETC of PWD trustees, employees, volunteers or other stakeholders associated with the charity wishing to make a complaint against the charity might also consult Protect, a specialist Whistle Blowing charity, which can help explain: what types of wrongdoing you can report; legal rights; next steps if you decide to report something

Protect’s free and confidential advice line: Telephone: 0800 055 7214

They can also get advice from Citizens Advice.

Requirements: It is important that any fraud, misconduct or wrongdoing by other trustees, volunteers, employees, stakeholders or by delivery partners is reported and properly dealt with. The ETC of PWD Whistle Blowing policy requires all concerned to raise any concerns that they may have about the conduct of others in the charity or the way in which the organisation is run. The range of examples of serious harm that would support whistleblowing might include:

  • if someone’s health or safety is in danger, for example if a charity does not use its safeguarding policy
  • a criminal offence, for example theft, fraud or financial mismanagement
  • if a charity uses its activities as a platform for extremist views or materials
  • loss of charity funds, for example when a charity loses more than 20% of its income or more than £25,000
  • if the charity does not meet its legal obligations, for example if someone uses a charity for significant personal advantage.

The ETC of PWD Whistle blowing policy also allows for employees, volunteers or other stakeholders, such as beneficiaries of projects supported by the charity, to raise any concerns that they might have about the conduct of others in the charity or the way in which the organisation is run.

ETC of PWD Whistle Blowing Report: Procedure

It is not necessary for the complainant to have firm evidence that wrongdoing has taken place, reasonable belief is sufficient. It is the role of the charity to make the investigation as follows.

Stage 1

Unless the concern is an urgent Safeguarding one, in which case the Whistle Blower should contact the Charity Commission and Police quickly, the first step of a Whistle Blower is to raise their concern in writing with the Safeguarding Manager,

Either at


Higher Week



EX19 8SJ

Or by email

who will arrange an investigation of the matter.

Any investigation will be carried out in accordance with these principles and processes:

  • Within as short a timeframe as possible
  • Transparent, accountable and within the UK legal framework
  • A thorough investigation of the evidence and the implications of the evidence with a panel of trustees. The investigator/s must consider: what the issue is; what impact that issue has on the people the charity helps; the impact on the charity’s assets and services; the impact on the charity’s staff, volunteers and other stakeholders; the impact on the charity’s reputation or on public trust and confidence in the charity sector; who reported the issue and the supporting evidence.
  • The complainant/s to be kept informed of progress at each stage.

Stage 2

  • An interim decision should be reached at which stage the subject of the allegations must be allowed to appeal the final decision. Any subsequent statements made by the complainant/s will be taken into account and he/ she/ they will be asked to comment on any additional evidence obtained.
  • The remaining trustees will take any necessary action, including reporting the matter to any Grant Manager, Donor, any external agency (eg the Police), the Charity Commission.
  • The trustees will also invoke any disciplinary action required under the ETC of PWD Disciplinary Policy.
  • On conclusion of any investigation, the complainant/s will be told the outcome formally and in writing and what the charity has done, or proposes to do, about it. If no action is to be taken, the reason for this will be explained.



Stage 3

If on conclusion of stages 1 and 2 the complainant/s reasonably believe that the appropriate action has not been taken, they should report the matter to the relevant body. This includes:

  • HM Revenue & Customs
  • the Health and Safety Executive
  • the Environment Agency
  • the Serious Fraud Office
  • the Charity Commission
  • the Pensions Regulator
  • the Information Commissioner
  • the Financial Conduct Authority.


Stage 1 should happen within 1 week

Stage 2 should happen within the following week

Stage 3 is at the discretion of the complainant

Unless the matter is of significant complexity and involves referring back and forth internationally, in which case all involved will understand that the timeframe might have to expand to fit.