Solution Chapel International
Whistleblowing Policy
Version | 001 | | Approved By | Board of Trustees
Dated | 25th June 2024 | | Next Review Due On | June 2025
Key Points
The Whistleblowing Procedure sets out the framework for dealing with allegations of illegal and
improper conduct.
Solution Chapel International is committed to the highest standards of transparency, probity,
integrity, and accountability.
This procedure is intended to provide a means of making serious allegations about standards,
conduct, financial irregularity, or possible unlawful action in a way that will ensure confidentiality
and protect those making such allegations in the reasonable belief that it is in the public interest to
do so from being victimized, discriminated against, or disadvantaged.
This procedure does not replace other policies and procedures such as the complaints procedure,
the Grievance and Harassment and Bullying Policies and other specifically laid down statutory
reporting procedures.
This procedure is intended to ensure that the Solution Chapel International complies with its duty
under the Public Interest Disclosure Act 1998.
Scope
This procedure applies to all Solution Chapel International members, employees, including
Associates and contractors.
This procedure does not replace other Solution Chapel International policies or procedures. For
example, if an employee or volunteer has a grievance about their working conditions, they should
use the Solution Chapel International Grievance Policy or, if they felt that their manager or a
colleague was treating them unfavorably, they should use the Solution Chapel International
Harassment and Bullying Policy. Similarly if an employee or volunteer has a concern about the
conduct of a fellow employee or volunteer in the working environment (e.g. that they are not
treating colleagues with respect) they should raise these with their line manager, or if that is not
possible, with the Founder & Senior Pastor, Treasurer of Trustees inf@solutionchapel.or or through
the Charity Commission’s whistle blowing policy whistleblowing@charitycommission.gsi.gov.uk
This procedure applies to, but is not limited to, allegations about any of the following:
• Conduct which is an offence or breach of the law
• Alleged miscarriage of justice
• Serious Health and Safety risks
• The unauthorized use of public funds
• Possible fraud and corruption • Sexual, physical or verbal abuse, or bullying or intimidation
of employees, customers or service users
• Abuse of authority
• Other unethical conduct
Reporting
Contact Details for Reporting: (in writing) xxx
Solution Chapel International recognizes that the decision to make an allegation can be a difficult
one to make. However, whistleblowers who make serious allegations in the reasonable belief that it
is in the public interest to do so have nothing to fear because they are doing their duty either to
Solution Chapel International and/or to those for whom Solution Chapel International are providing
a service.
Solution Chapel International will take appropriate action to protect a whistleblower who makes a
serious allegation in the reasonable belief that it is in the public interest to do so from any reprisals,
harassment or victimization.
Confidentiality
All allegations will be treated in confidence and every effort will be made not to reveal a
whistleblower’s identity unless the whistleblower otherwise requests. However, if the matter is
subsequently dealt with through other Solution Chapel International procedures such as the
Disciplinary Procedure.
Similarly, if the allegation results in court proceedings, then the whistleblower may have to give
evidence in open court if the case is to be successful.
Solution Chapel International will not, without the whistleblower’s consent, disclose the identity of a
whistleblower to anyone other than a person involved in the investigation/allegation.
Anonymous Allegations
This procedure encourages whistleblowers to put their name to an allegation wherever possible as
anonymous allegations may often be difficult to substantiate/prove. Allegations made anonymously
are much less powerful but anonymous allegations will be considered at the discretion of the Senior
Pastor/Treasurer Trustee.
In exercising discretion to accept an anonymous allegation the factors to be taken into account:
• The seriousness of the issue raised
• The credibility of the allegation; and
• Whether the allegation can realistically be investigated from factors or sources other than
the complainant
Untrue Allegations
No disciplinary or other action will be taken against a whistleblower who makes an allegation in the
reasonable belief that it is in the public interest to do so even if the allegation is not substantiated by
an investigation. However, disciplinary action may be taken against a whistleblower who makes an
allegation without reasonable belief that it is in the public interest to do so (e.g. making an allegation
frivolously, maliciously or for personal gain where there is no element of public interest).
Procedure for Making an Allegation
It is preferable for allegations to be made to an employee’s immediate manager to whom they
report. However, this may depend on the seriousness and sensitivity of the issues involved and who
is suspected of the malpractice. For example, if the whistleblower believes that management is
involved it would be inappropriate to raise it directly with them. The whistleblower may then make
an allegation direct to any of the following:
• The Founder & Senior Pastor
• Treasurer Trustee
If either of the above receive an allegation he/she will consider the allegation and may discuss with
either the Founder & Senior Pastor or other Trustees. The line manager (or either/or both) of the
above, after consideration, will discuss with the whistleblower and if they wish to proceed with the
allegation will be investigated.
Allegation
including:
Whether a written or oral report is made it is important that relevant information is provided
• The name of the person making the allegation and a contact point.
• The background and history of the allegation (giving relevant dates and names and positions
of those who may be in a position to have contributed to the allegation);
• The specific reason for the allegation. Although someone making an allegation will not be
expected to prove the truth of any allegations, they will need to provide information to the
person they have reported to, to establish that that there are reasonable grounds for the
allegation.
Someone making an allegation may be accompanied by another person of their choosing during any
meetings or interviews in connection with the allegation. However, if the matter is subsequently
dealt with through another procedure the right to be accompanied will at that stage be in
accordance with the relevant procedure.
Action on receipt of an Allegation
The line manager will record details of the allegation gathering as much information as possible,
(within 5 working days of receipt of the allegation) including:
• The record of the allegation:
• The acknowledgement of the allegation.
• Any documents supplied by the whistleblower
The investigator will ask the whistleblower for his/her preferred means of communication and
contact details and use these for all communications with the whistleblower in order to preserve
confidentiality.
If the allegation relates to fraud, potential fraud or other financial irregularity the Treasurer will be
informed within 5 working days of receipt of the allegation. The Treasurer will determine whether
the allegation should be investigated and the method of investigation.
If the allegation discloses evidence of a criminal offence, it will immediately be reported to the Board
of Trustees and a decision will be made as to whether to inform the Police. If the allegation concerns
suspected harm to children, the appropriate authorities will be informed immediately.
If the issue is around suspected harm to vulnerable adults, the Vulnerable Adults policy, the Mental
Capacity Act Policy and the Deprivation of Liberty and Safeguarding Policies should be referred to.
Timetable
• Acknowledge the allegation in writing within 10 working days with
o An indication of how the Solution Chapel International propose to deal with the
matter
o An estimate of how long it will take to provide a final response
o An indication of whether any initial enquiries have been made
o Information on whistleblower support mechanisms
o Indication whether further investigations will take place and if not, why not
Where the allegation has been made internally and anonymously, obviously Solution Chapel
International will be unable to communicate what action has been taken.
Support
Solution Chapel International will take steps to minimize any difficulties which may be experienced
as a result of making an allegation. For instance, if a whistleblower is required to give evidence in
criminal or disciplinary proceedings Solution Chapel International will arrange for them to receive
advice about the procedure and advise on the support mechanisms that are available.
Solution Chapel International accepts that whistleblowers need to be assured that the matter has
been properly addressed. Thus, subject to legal constraints, we will inform those making allegations
of the outcome of any investigation.
Responsibility for the Procedures Monitoring
The Founder & Senior Pastor and Treasure of Trustees have overall responsibility for the operation
of this Procedure and for determining the administrative processes to be followed and the format of
the records to be kept.
Monitoring
A Register will record the following details:
• The name and status (e.g. employee) of the whistleblower
• The date on which the allegation was received
• The nature of the allegation
• Details of the person who received the allegation
• Whether the allegation is to be investigated and, if yes, by whom
• The outcome of the investigation
• Any other relevant details
The Register will be confidential and only available for inspection by the Board of Trustees.
The Founder & Senior Pastor will report annually to the Board of Trustees on the operation of the
Procedure and on the whistleblowing, allegations made during the period covered by the report.
The report will be in a form which does not identify whistleblowers.