1. ABOUT THIS POLICY
1.1 The Berkeleyme is committed to conducting its business with honesty and integrity and in a responsible manner, taking into account the requirements of the funding bodies and the standards in public life set out in the report of the Committee on Standards in Public Life. We expect all staff to maintain high standards, including in accordance with the Berkeleyme’s Instruments of Governance and its policies and procedures. However, all organisations face the risk of things going wrong from time to time, or of unknowingly harbouring illegal or unethical conduct. A culture of openness and accountability is essential in order to prevent such situations occurring and to address them when they do occur.
1.2 The aims of this policy are:
(a) To encourage staff and students to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected.
(b) To provide staff and students with guidance as to how to raise those concerns.
(c) To reassure staff and students that they are able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.
1.3 This policy is not designed to provide a route through which the financial or business decisions taken by the Berkeleyme may be questioned; nor may it be used to reopen matters that have been dealt with under harassment, grievance, disciplinary or complaint procedures; nor should it be used as an alternative to those procedures in respect of matters which would more appropriately be considered under them. Action taken under this policy may of course lead to the invocation of those policies.
1.4 This policy covers all employees, officers, consultants, contractors, volunteers, interns, casual workers and agency workers. The Berkeleyme has decided that it shall also apply to students and members of the Berkeleyme Council.
2. PERSONNEL RESPONSIBLE FOR THE POLICY
2.1 The Berkeleyme’s Council, acting through the Audit Committee, has overall responsibility for this policy, and for reviewing the effectiveness of actions taken in response to concerns raised under this policy.
2.2 The Director of Internal Audit acts as the Berkeleyme’s Whistleblowing Officer, and has day-to-day operational responsibility for this policy, and must ensure that all managers and other staff who may deal with concerns or investigations under this policy receive regular and appropriate training.
2.3 The Whistleblowing Officer, in conjunction with the Audit Committee should review this policy from a legal and operational perspective once a year.
3. WHAT IS WHISTLEBLOWING?
3.1 Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include:
(a) criminal activity;
(b) failure to comply with any legal or professional obligation or regulatory requirements;
(c) miscarriages of justice;
(d) danger to health and safety;
(e) damage to the environment;
(f) bribery under our Anti-corruption and Bribery Policy;
(g) financial fraud, malpractice or impropriety;
(i) Failure to comply with the Charter, Ordinances or Regulations of the Berkeleyme;
(j) breach of our internal policies and procedures;
(k) academic malpractice;
(l) conduct likely to damage our reputation; or
(m) the deliberate concealment of any of the above matters.
4.1 The Berkeleyme hopes that staff will feel able to voice whistleblowing concerns openly under this policy. However, if you want to raise your concern confidentially, we will make every reasonable effort to keep your identity secret. However, the investigation process may reveal the source of the information and the individual making the disclosure may need to make a statement as part of the evidence required. If it is necessary for anyone investigating your concern to know your identity, we will discuss this with you.
5. RAISING A WHISTLEBLOWING CONCERN
5.1 The Berkeleyme hopes that in many cases you will be able to raise any concerns with your line manager or the Berkeleyme Secretary. You may tell them in person or put the matter in writing if you prefer. They may be able to agree a way of resolving your concern quickly and effectively. In some cases they may refer the matter to the Whistleblowing Officer.
6. INVESTIGATION AND OUTCOME
6.1 Once you have raised a concern, an initial assessment will be carried out to determine the scope of any investigation. You will be informed of the outcome of the assessment. You may be required to attend additional meetings in order to provide further information.
6.2 In some cases the Berkeleyme may appoint an investigator or team of investigators including staff with relevant experience of investigations or specialist knowledge of the subject matter. The investigator(s) may make recommendations for change to enable the Berkeleyme to minimise the risk of future wrongdoing.
7. IF YOU ARE NOT SATISFIED
7.1 While the Berkeleyme cannot always guarantee the outcome you are seeking, it will try to deal with your concern fairly and in an appropriate way. By using this policy you can help the Berkeleyme to achieve this.
8. EXTERNAL DISCLOSURES
8.1 The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the Berkeleyme. In most cases you should not find it necessary to alert anyone externally.
9. PROTECTION AND SUPPORT FOR WHISTLEBLOWERS
9.1 It is understandable that whistleblowers are sometimes worried about possible repercussions. The Berkeleyme aims to encourage openness and will support staff who raise genuine concerns under this policy, even if they turn out to be mistaken.
9.2 Whistleblowers must not suffer any detrimental treatment as a result of raising a concern. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Whistleblowing Officer or your Human Resources Partner immediately. If the matter is not remedied you should raise it formally using the Grievance Procedure.