Whistleblowing policy

The British Psychological Society (the "society"/ "we") aims to conduct its activities with honesty and integrity and we expect all individuals to maintain the same high standards. 

We recognise, however, that there may be occasions when we – or our people - do not get this right.  A culture of openness and accountability is essential in order to prevent such situations occurring and to address them when they do occur.

We aim to provide an open, transparent and safe working environment where individuals feel able to speak up if they have serious concerns.   

This policy will apply in cases where an individual genuinely believes that one of the following set of circumstances is occurring, has occurred or may occur within the society and that it is in the public interest for the individual to disclose it.

The matters which may be disclosed in this way ("whistleblowing concerns") fall into one or more of the six categories of wrongdoing set out below.

A disclosure relating to any of these will be a "protected disclosure". 

1. A criminal offence (including fraudulent and corrupt behaviour e.g. fraud or malpractice)
2. a failure to comply with any legal obligation 
3. a miscarriage of justice; 
4. an act (or omission) creating risk to health and safety 
5. an act causing damage to the environment; 
6. the deliberate concealment of any of the above matters. 

It is not necessary for an individual to have proof that such an act is being, has been or is likely to be committed. An individual does, however, need to hold a reasonable belief of such action having been, being or likely to be carried out.

If, however, following investigation of the concerns raised, it is concluded that the allegations were made maliciously or with a view to personal gain, disciplinary action may be instigated against the person making the allegations. 

This policy is only to be used in the circumstances as outlined in section 2 above.

There are a number of society policies that will be relevant in other circumstances.

In particular, this policy should not be used for complaints relating to an employee's own personal circumstances, such as the way they have been treated at work and in these instances the grievance procedure may be more appropriate.

Matters related to bullying and harassment are addressed by the society's Dignity at Work Policy.

If individuals are in doubt about the procedure to follow, they may wish to contact the Head of Legal and Governance, the Human Resources department or the Advisory, Conciliation and Arbitration Service (ACAS) for guidance. 

4.1 Raising a concern 

If an individual wishes to raise a whistleblowing concern, the earlier it is done the better. An individual may raise a whistleblowing concern by telephone, in person or in writing. Every incident will be treated sensitively and will be fully investigated. 

In the first instance, an individual should contact their line manager or if a volunteer providing services to the society, the departmental director with overall responsibility for the services, either by approaching them in person or putting their concerns in writing.

The Board of Trustees have overall collective responsibility for the running of the society.  A trustee who may wish to raise a concern should first raise the matter with other trustees.  It may be possible to agree a way of resolving concerns quickly and effectively. 

However, where an individual's concern relates to actions of:

• Their line manager - they should contact their department director. 
• The individual's department director - they should contact the Chief Executive. 
• The Chief Executive - they should contact the Chair of the Board of Trustees. 
• A trustee or the Board of Trustees collectively - they should contact the Head of Legal and Governance who will refer the matter appropriately for consideration externally 

We will arrange a meeting with the individual as soon as possible to discuss the concern.

The individual may bring a colleague or union representative to any meetings under this policy.

The companion must respect the confidentiality of their disclosure and any subsequent investigation. 

We will take down a written summary of the individual's concern and provide them with a copy after the meeting.

We will also aim to give the individual an indication of how we propose to deal with the matter. 

4.2 Investigation and Outcome

Once an individual has raised a concern, we will carry out an initial assessment to determine the scope of any investigation. We will inform them of the outcome of our assessment.

An individual may be required to attend additional meetings in order to provide further information. 

In some cases we may appoint an investigator or team of investigators including individuals with relevant experience of investigations or specialist knowledge of the subject matter.

The investigator(s) may make recommendations for change to enable us to minimise the risk of future wrongdoing. 

Appropriate steps will be taken to ensure that an individual's working relationships are not prejudiced by the fact of disclosure of whistleblowing concerns. 

We will aim to keep the individual informed of the progress of the investigation and its likely timescale.

However, sometimes the need for confidentiality may prevent us giving specific details of the investigation or any disciplinary action or other action taken as a result.

Individuals should treat any information shared with them about the investigation as strictly confidential.

If the concerns raised relate to the actions of a trustee or the Board of Trustees, we would normally appoint an independent external investigator to consider the concerns which have been raised.

4.3 Confidentiality and disclosure 

We hope individuals will feel able to voice whistleblowing concerns openly under this policy.

However, if an individual wants to raise their concerns confidentially, we will make every effort to retain their anonymity.

If it is necessary for anyone investigating a concern to know the identity of an individual, we will discuss this with them first. 

We do not encourage individuals to make disclosures anonymously.

Proper investigation may be more difficult or impossible if we cannot obtain further information from an individual.

It is also more difficult to establish whether any allegations are credible.

If an individual is concerned about possible reprisals if their identity is revealed they should raise this when they report their concerns or as soon as possible thereafter.   

4.4 If individuals are not satisfied

Whilst we cannot always guarantee the outcome individuals are seeking, we will try to deal with concerns expressed under this policy fairly and in an appropriate way. By using this policy, individuals can help us to achieve this. 

If an individual is not happy with the way in which their concern has been handled, the individual can raise their concern in writing to the Chief Executive or if they are implicated in an individual's concerns, with the Chair of the Board of Trustees who will refer the matter appropriately for review 

4.5 External Disclosures

The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the society.

In most cases an individual should not find it necessary to alert anyone externally and we strongly encourage individuals to exhaust the internal processes set out above in the first instance. 

In exceptional or urgent circumstances, however, or where, having made a disclosure, an individual is unhappy with the outcome, the individual may make a disclosure to prescribed bodies such as a regulator. It will very rarely, if ever, be appropriate, to alert the media. 

Prescribed bodies include but are not limited to:

• The Charity Commission
• HM Revenue & Customs
• The Health and Safety Executive
• The Financial Conduct Authority
• Institute for Apprenticeships and Technical Education

We strongly encourage individuals to seek advice before reporting a concern to anyone external to the society.

The independent whistleblowing charity, Protect, operates a confidential helpline. They also have a list of prescribed regulators for reporting certain types of concern.

Their contact details are:

• Advice Line: 02074046609 or 02031172550
• Website: https://www.pcaw.co.uk
• Email: [email protected]

Whistleblowing concerns usually relate to the conduct of individuals, but they may sometimes relate to the actions of a third party, such as a customer, supplier or service provider.

In some circumstances the law will protect an individual if the individual raises the matter with the third party directly. However, we encourage individuals to report such concerns internally first in accordance with this policy. 

4.6 Protection and support for whistleblowers 

It is understandable that whistleblowers are sometimes worried about possible repercussions.

We aim to encourage openness and will support individuals who raise genuine whistleblowing concerns in good faith under this policy, even if they turn out to be mistaken. 

The law expressly states that employees or workers (persons who have an agreement with the society to do work or perform services for payment) will not suffer any detrimental treatment or disadvantage as a result of raising a concern.

Detrimental treatment includes dismissal, disciplinary action, threats, ceasing to use the services of the whistleblower or other unfavourable treatment connected with raising a concern. 

If an employee or worker believes that they have suffered any such treatment, they should raise it with their line manager, departmental director or a senior manager as appropriate.

If an employee believes they have suffered any such treatment and their concerns are not resolved they may raise these formally using our grievance procedure. 

Employees or workers must not threaten or retaliate against whistleblowers in any way.

If employees or workers are involved in such conduct they may be subject to disciplinary action (if they are an employee) or the cessation of their services (if they are a worker). 

In some cases the whistleblower may also have a right to sue individuals personally for compensation in an employment tribunal. 

4.7 Procedure for recording Whistleblowing Concerns 

A central record of whistleblowing concerns will be maintained by the Legal and Governance department.

The record will include the areas of society business that have been affected, a summary of action taken, the outcome, any follow-up and feedback provided.

We will reflect upon the outcomes from any disclosures which are made under this policy even if they are not upheld and we will look at how we can improve our ways of working to ensure that we improve the transparency and safety of our working environment going forwards.