Democracy Spraffa

9 - Whistleblowing Policy

Renfrewshire Council · 9 February 2023
Back to Finance, Resources and Customer Services Policy Board — 9 February 2023 and its agenda

Text extracted from the council's PDF. Layout and reading order may differ from the original.

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___________________________________________________________________
To: Finance, Resources and Customer Services Policy Board
On: 09 February 2023
___________________________________________________________________
Report by: Director of Finance and Resources
___________________________________________________________________
Heading: HR & OD Policies (Revised Whistleblowing Policy)
___________________________________________________________________
1. Summary 
1.1 The Council is committed to conducting its business with honesty and 
integrity, and it expects all employees to maintain high standards in 
accordance with the Council’s Code of Conduct for Employees.  Therefore, the
purpose of this report is to provide Elected Members with the revised HR&OD
Whistleblowing Policy attached in Appendix 1 for approval. 
1.2 The revised policy, which replaces the current ‘Expressing Concerns Out with
Line Management Policy’ is part of the Council’s ongoing programme to review
of HR&OD Policies and provides a mechanism for a concern about any
wrongdoing or malpractice within the Council to be reported and investigated.   
1.3  The policy is applicable to Local Government Employees, teachers, workers, 
officers, consultants, contractors, volunteers, casual workers and agency 
workers.  Consultation has taken place with the Trade Unions and feedback
where  applicable has informed the development of this policy. The policy has 
been modernised and updated in line with best practice, legislation and 
embeds our Council values. 
1.4  Following approval from Members, the policy will be communicated to all
managers and employees within the Council via the normal channels. 
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2. Recommendations
2.1  Members are asked to approve the revised Whistleblowing Policy attached at
Appendix 1.
___________________________________________________________________
3.  Background
3.1  The Council strives to create an open and inclusive working environment which
enables employees to carry out their roles in a safe and supportive  way.  This
is important to maintaining health and wellbeing which remains our top priority. 
3.2 The revised policy aims to encourage the reporting of any suspected 
wrongdoing or malpractice in a confidential and secure environment, without 
fear of reprisal, and sets out a clear process for all to follow. 
3.3 Whistleblowing is a right under the Employment Rights Act 1996, the Public 
Interest Disclosure Act 1998 and the Enterprise and Regulatory Reform Act 
2013 that enables anyone who is conducting business for or on behalf of the 
Council to raise concerns over any matter of malpractice, wrongdoing, or 
dangerous activity at work.    
3.4 Once approved, training will be made available for all Council employees on the
procedures for submitting and dealing with concerns through designated
officers. This will support the fair, inclusive and consistent implementation of
this policy.
___________________________________________________________________
Implications of the Report
1.  Financial - None.
2.  HR & Organisational Development - HR & OD and Internal Audit will provide
advice and guidance to managers and employees on the interpretation and
application of this policy. 
3.  Community Planning - None
4.  Legal - The Council will meet its legislative and best practice requirements.
5.  Property/Assets - None
6.  Information Technology – None
7.  Equality & Human Rights 
The Recommendations contained within this report have been assessed in 
relation to their impact on equalities and human rights.

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No negative impacts on equality groups or potential for infringement of
individuals’ human rights have been identified arising from the
recommendations contained in the report.  If required following implementation,
the actual impact of the  recommendations and the mitigating actions will be
reviewed and monitored, and the results of the assessment will be published
on the Council’s website. 
8.  Health & Safety - None
9.  Procurement – None
10.  Risk - None
11.  Privacy Impact – PIA Carried Out – No negative impact.
12. Climate Risk - None
13.  Cosla Policy Position - not applicable.
_________________________________________________________
List of Background Papers
Not applicable
___________________________________________________________________
Author: Raymond Cree, Organisational Development & Workforce Planning Manager
Email: raymond.cree@renfrewshire.gov.uk.  Tele:  01414870803

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Issue Number: 2                            
Issue Date: 2/23
Review Date:  2/25    
Whistleblowing Policy
For all council employees. 
This document is
available in alternative
formats on request.

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CONTENTS
1.  Introduction ............................................................................................................................ 2 
2.  Purpose and Aims ................................................................................................................. 2 
3.  Scope of policy ...................................................................................................................... 2 
4.  What is whistleblowing? ......................................................................................................... 2 
5.  Procedure for Raising a Whistleblowing Concern ................................................................. 3 
6.  Raising a Whistleblowing Concern to Elected Members ....................................................... 4 
7.  Confidentiality and Anonymity ............................................................................................... 5 
8.  External disclosures ............................................................................................................... 5 
9.  Protection and Support for Whistleblowers ............................................................................ 6 
10.  False Reporting ..................................................................................................................... 6 
11.  Responsibility and Training .................................................................................................... 6 
12.  Monitoring and Review .......................................................................................................... 7 
13.  Contacts ................................................................................................................................. 7 
VERSION CONTROL
Version  Date Details of Review/Revisals made Next Review date
1 January
2023
Drafting of new policy to reflect current
legislative requirements 
[February 2025]

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1. Introduction 
1.1 The Council is committed to conducting its business with honesty and integrity,
and it expects all employees to maintain high standards in accordance with the
Council’s Employee Code of Conduct. Part of that is creating an open and
supportive working environment where employees feel able to speak up about
any suspected wrongdoing. This policy details our process for dealing with
Whistleblowing. 
1.2 This policy has been agreed and implemented following consultation with the
recognised Trade Unions. 
2. Purpose and Aims 
2.1 The purpose of this policy is to provide a mechanism for employees of the
Council, and other workers within the Council as detailed in section 3.1 of the
policy, to report a concern which they have about serious wrongdoing or
malpractice within the Council. It draws on the rights and obligations contained
within the Employment Rights Act 1996, the Public Interest Disclosure Act 1998
and the Enterprise and Regulatory Reform Act 2013. 
2.2 The aims of this policy are:
(a) To encourage employees and other workers within the Council 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 employees and other workers with guidance as to how to
raise those concerns.
(c) To reassure employees and other workers that they should be able to
raise genuine concerns without fear of reprisals, even if they turn out to
be mistaken. 
3. Scope of policy 
3.1 This policy covers all Council’s employees, workers, officers, consultants,
contractors, volunteers, casual workers, and agency workers. 
4. What is whistleblowing? 
4.1 Whistleblowing is the disclosure of information which relates to suspected
malpractice, wrongdoing or dangers at work. This may include:
 Criminal activity;
 Failure to comply with any legal or professional obligation or regulatory
requirements;
 Miscarriages of justice;

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 Danger to health and safety;
 Damage to the environment; 
 Information tending to show any matter falling within any one of the
preceding paragraphs has been, is being or is likely to be deliberately
concealed. 
4.2 A “whistleblower” is a person who raises a genuine concern relating to any of
the above. If you have any genuine concerns related to suspected malpractice,
wrongdoing or danger affecting any of the Council’s activities (a whistleblowing
concern) you should report it under this policy. 
4.3 Whistleblowing does not cover less serious matters; such matters should be
raised by an employee to their line manager. An employee’s concerns about their
own employment which should be addressed in accordance with the relevant HR
policy, for example the Council’s Grievance Procedure or Respect at Work
Policy, as appropriate. 
4.4 If an employee or other worker is uncertain whether something is within the
scope of this policy they should seek advice from the Whistleblowing Officer,
whose contact details are at the end of this policy. 
5. Procedure for Raising a Whistleblowing Concern 
5.1 An employee or other worker wishing to raise a matter that is covered by the
categories covered in this policy should:
(a) Contact the appropriate designated officer in the employing Service in the
Council. The Designated Officers are those identified in Annex 1 to this
policy. The concern should be raised, preferably, in writing and to avoid
any doubt, should be preferably described as a “Whistleblowing
Concern”.    
(b) Call the Confidential Whistleblowing Hotline.
(c) Completing the online form at www.renfrewshire.gov.uk, search for
‘Whistleblowing Policy’. 
5.2 Employees within the Renfrewshire Health and Social Care Partnership can
access the National Whistleblowing Standards in relation to NHS Services.
Further information can be obtained from the Chief Officer and accessed here. 
5.3 Where a whistleblowing concern is made directly to a line manager, the line
manager should immediately forward details of the concern to the Designated
Officer. 
5.4 Any whistleblowing concern received in accordance with paragraph 5.1 above,
will be sent to the Designated Officer (set out in Annex 1 of this policy). If a
whistleblowing concern is made which alleges wrongdoing by a Designated
Officer, then that concern should be made directly to the Chief Executive. In the

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event the whistleblowing concern relates to the Chief Executive then that concern
should be made directly to the Council’s Monitoring Officer. 
5.5 Once a whistleblowing concern has been submitted the Designated Officer (or
nominated officer in their absence) will acknowledge receipt as soon as possible
and within a maximum of 5 working days.   
5.6 At this stage of the process, it is important that confidentiality is maintained by
both parties where that is required to ensure that the matter can be dealt with in
the appropriate way, avoid prejudice and protect individual rights. 
5.7 The whistleblowing concern will then be considered, and a decision taken as to
whether, and in what way, the matter should proceed. 
5.8 Should the Designated Officer decide not to take any action you will be notified
and given the reason(s) for this decision.  
5.9 If the Designated Officer decides that further action is required based on your
whistleblowing concern, then you will be notified of this decision and the likely
timescale. 
5.10 Once the matter has been concluded and the appropriate action taken in
response to your concern, you will be informed subject to confidentiality being
maintained, as required. 
5.11 Under the terms of this policy, you may seek a progress update from the
Designated Officer regarding the status of your concern, although it has to be
understood that the response may have to be qualified in order to protect other
interests.  
5.12 Whilst the Council cannot guarantee the outcome you are seeking, the Council
will try to deal with your concern fairly and in an appropriate way.  By using this
policy, you can help the Council achieve this.    
5.13 If you are not satisfied with the way your whistleblowing concern has been dealt
with, you can raise this with the Chief Executive. 
6. Raising a Whistleblowing Concern to Elected Members 
6.1 Where an Elected Member is approached by an employee or other worker as set
out in section 3 above in connection with a whistleblowing concern covered
under this policy, the Elected Member should encourage that individual to raise
their concern in accordance with this policy.

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6.2 In cases where an Elected Member receives a whistleblowing concern, they shall
send it directly to the Whistleblowing Officer who will then process it in line with
this policy. 
6.3 Elected Members must not investigate any whistleblowing concerns themselves. 
7. Confidentiality and Anonymity 
7.1 The Council hopes that all employees and other workers will be able to raise
whistleblowing concerns openly under this policy. However, if an employee or
other worker wishes to raise their concern confidentially, the Council will try to
ensure that their identity remains anonymous. If it is necessary for anyone
investigating the employee or other worker’s concern to know their identity, then
this will be discussed directly with them. 
7.2 The Council does not encourage employees or other workers to raise concerns
anonymously. Proper investigation may be more difficult or impossible if the
Council cannot obtain further information. It is also more difficult to establish
whether any allegations are credible. Employees or other workers who are
concerned about possible consequences if their identity is revealed should raise
this with the Designated Officer and appropriate measures may be taken to
preserve confidentiality. An employee or other worker can seek advice from the
Council’s whistleblowing hotline or Protect, the independent whistleblowing
charity, who offer a confidential helpline (details are set out below). 
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 workplace. It is expected that
the internal mechanisms outlined in this policy will be used and with confidence.
If, however, there is genuine cause to believe that an internal disclosure to one of
the identified officers would not be appropriate for particular reasons, it is
accepted that a disclosure to an external regulator may be protected. It will very
rarely, if ever, be appropriate to alert the media and employees and other
workers are strongly encouraged to report concerns through this policy and its
internal mechanisms. 
8.2 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 at the end of this policy. 
8.3 Whistleblowing concerns usually relate to the conduct of the Council’s
employees, 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 you if you raise the matter with the third party directly. However, the
Council encourages its employees and other workers to report such concerns

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internally first. An employee or other worker should contact the Whistleblowing
Officer for guidance regarding this. 
9. Protection and Support for Whistleblowers 
9.1 It is understandable that whistleblowers are sometimes worried about possible
repercussions. The Council encourages openness and transparency and will
support employees and other workers who raise genuine concerns under this
policy, even if they turn out to be mistaken. Employees and other workers raising
concerns under this policy will be protected, provided that the concern is made in
the reasonable belief that it is in the public interest. 
9.2 Employees and other workers raising a concern under this policy must not suffer
any detrimental treatment as a result of raising the concern. Detrimental
treatment includes dismissal, disciplinary action, harassment, victimisation 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 immediately. If the matter is not remedied, you should raise it formally
using the Council’s Grievance Procedures or Respect at Work Policy.  
9.3 An employee or other worker must not threaten or retaliate in any way against
another individual raising a whistleblowing concern. Any employee or other
worker involved in such conduct may be subject to disciplinary action under the
Council’s Disciplinary Procedures. In addition, where an employee or other
worker has been subjected to a detriment by another employee, they could be
personally liable for their own conduct. 
10. False Reporting 
10.1 There may be instances when a concern is submitted, based on reasonable
belief by an employee or other worker that something is wrong at a particular
time, which is subsequently demonstrated to be false or inaccurate. In such
circumstances, employees or other workers will be informed of the discrepancy
between their concern and the facts at hand. Provided that the Council is
satisfied that the employee or other worker had a reasonable belief that such a
situation should be reported, no further action will be taken. 
10.2 If an employee or other worker has deliberately raised a concern that they know
to be untrue or unfounded this may lead to a disciplinary investigation and
disciplinary action against the employee being taken. 
11. Responsibility and Training 
11.1 Internal Audit has overall responsibility for this policy and for reviewing the
effectiveness of actions taken in response to concerns raised under this policy.
The Whistleblowing Officer will maintain a register of concerns raised and the

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outcomes, as required. The Whistleblowing Officer (or other delegated officer)
will present an annual report to the Audit, Risk and Scrutiny Board detailing the
number of whistleblowing complaints received and actions taken by the Council.
This annual report will be anonymised to protect confidentiality. 
11.2 The Designated Officers must provide information regarding any concerns
received to the Whistleblowing Officer. Regular updates and information about
outcomes of any investigations must be provided to the Whistleblowing Officer to
allow them to maintain the register of concerns. 
11.3 The Designated Officers must ensure that all managers and other staff who may
deal with concerns or investigations under this policy receive regular and
appropriate training. 
12. Monitoring and Review 
12.1 This Policy will be reviewed regularly and in line with any legislative and/or
organisational changes. The recognised trade unions will be consulted on any
future changes to this policy.
13. Contacts
Whistleblowing Officer Chief Auditor (or delegated officer)
whistleblowingofficer@renfrewshire.gov.uk
Monitoring Officer Head of Corporate Governance  
mark.conaghan@renfrewshire.gov.uk
Renfrewshire Council’s external
auditors
[Gary Devlin, Partner Azets]
[01415674500]
[gary.devlin@azets.co.uk]
Whistleblowing hotline
Available Monday-Thursday from 9am to
4.45pm and Friday 9am to 3.55pm
[0300 300 1314]
[whistleblowingofficer@renfrewshire.gov.uk]
Protect
(Independent whistleblowing charity)
The Green House 
244-254 Cambridge Heath Road
London
E2 9DA
Telephone: 020 3117 2520 
Email: whistle@protect-advice.org.uk 
Website: www.protect-advice.org.uk

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Annex 1 
DESIGNATED OFFICERS TO WHOM WHISTLEBLOWING CONCERNS MAY BE
REPORTED 
Gordon McNeil – Director of Environment and Infrastructure
Alastair MacArthur – Director of Finance and Resources (to whom any concerns regarding the
Chief Executive’s Service should also be directed)
Steven Quinn – Director of Children’s Services
Christine Laverty – Chief Officer of the Renfrewshire Health and Social Care Partnership
Mary Crearie - Director of Communities and Housing