Whistleblowing Policy
Introduction
St John’s Church is committed to openness, honesty, integrity and accountability in church life and all involved are expected to maintain the highest standards of service and ethical practice. An important aspect of accountability is a mechanism to enable staff to voice concerns in a responsible and effective manner where they discover information which they believe shows serious malpractice or wrongdoing in the church. This is known as whistleblowing and this policy is intended to assist any staff member to report their concerns internally and at a high level without fear of reprisal and independently of line management. A linked policy, ‘Reporting of Serious Concerns’ relates to all Church members including staff and should be read in conjunction with this policy.
Employed staff are often the first to realise that there may be something seriously wrong within their organisation (in this case the Church) or within the staff team itself. The Church views whistleblowing as a positive act which can make a valuable contribution to the Church as a whole and to the staff team’s efficiency and long-term success. It can also lead to early intervention in a situation or practice which might otherwise endanger the well-being or safety of others.
Scope of this policy
The Whistleblowing Policy is not intended to replace existing procedures:
If your concern relates to your own treatment as an employee you should raise this under existing grievance, disciplinary or harassment procedures as appropriate.
If you have a serious concern about any aspect of St John’s ministry this should be raised with Vicar or Churchwardens.
Safeguarding
St John’s has specific policies for the safeguarding of children and young people, vulnerable adults and domestic violence which are available here or printed copy from the church office.
If you experience, have experienced, observed, been told about or have suspicions about any of the following:
Physical, emotional or sexual abuse or neglect
Incident of domestic violence
Concern about a vulnerable adult
Any behaviour which you believe to be inappropriate
This must be reported to the Vicar or Parish Safeguarding Officers (PSOs) immediately. If you are not sure what to do please contact either of them for advice. Reports made direct to the PSOs will be passed to the Vicar unless the concern is about the Vicar.
What else should be reported?
Any serious concern about the conduct or practice of the clergy, staff, church officers* or members that:
Makes you feel uncomfortable
Is not in keeping with the Church’s ethos and practice
Appears to be breaking the law
These might relate to:
Unauthorised use of church funds or other assets
Possible fraud or corruption
Health & Safety breaches which endanger people or cause damage to the environment
Conduct which is an offence or a breach of the law (a criminal offence has been committed or there is a failure to comply with any other legal obligation)
Any form of discrimination e.g. racial, sexual, disability
Wrongful accusation or defamation of character
Wrongful treatment of any person
Breaches of church law e.g. conducting an illegal marriage, altering building without appropriate permission
Integrity of clergy leadership e.g. breaching a pastoral confidence, manipulative or harsh pastoral advice
Apparent cover up of or failure to address issues of malpractice or impropriety
This list is not exhaustive.
* A "Church Officer" is anyone appointed/elected by or on behalf of the Church to a post or role, whether they are ordained or lay, paid or unpaid.
Procedures for making a disclosure
You may raise your concern in writing, by email, in person or by telephone. Please give brief details or outline the nature of the concern. Please ensure you leave details of how you would like to be contacted. Please report your concern to either the Churchwardens on churchwardens@stjohnsharborne.org or Chair of Human Resources on hr@stjohnsharborne.org.
Protection & support
This policy has been written to take account of the Public Interest Disclosure Act 1998 which protects employees from being dismissed, victimised or disadvantaged in any way on the basis that they have made an appropriate disclosure.
The PCC is committed to good practice and will support and protect any employee who makes a disclosure. The PCC recognises that the decision to report a concern can be a difficult one to make. If you honestly and reasonably believe that your disclosure is true, you have nothing to fear because you will be doing your duty to your employer, colleagues and members of the church.
The PCC will not tolerate any harassment or victimisation of the whistleblower (including informal pressures). Should such action be carried out by a member of staff disciplinary procedures will be invoked as this would be viewed as serious misconduct.
Any employee who knowingly fails to disclose malpractice or impropriety will not be protected from normal disciplinary procedures.
Confidentiality
St John’s will treat all disclosures with discretion and sensitivity. The identity of the member of staff making the disclosure will be kept confidential so long as it does not hinder or frustrate any investigation e.g. you may be required to give a written statement. You will be kept informed of developments and offered advice and support.
Anonymous disclosures
This policy encourages individuals to put their name to any disclosures they make. Concerns that are expressed anonymously are much less credible and difficult to investigate. If you feel that you must have anonymity then you are still encouraged to raise your concern, but any action, if taken, may therefore be limited.
Unproven disclosure
If a member of staff raises a concern in good faith which is not substantiated by subsequent investigation, no action will be taken against the member of staff raising the concern. In making any disclosure a member of staff should exercise due care to ensure the accuracy of the information which they have noted themselves or has been passed to them by another person.
If a member of staff raises a concern maliciously or frivolously disciplinary action may be taken.
What happens following a disclosure
You will receive a written acknowledgement of your disclosure as soon as possible, but certainly within seven days. The person who you contacted will need to meet with you to discuss and clarify details of your concern.
Further action will depend on the nature of the concern you have raised, and further investigation may be appropriate. You will be advised of how the matter will be dealt with, ongoing progress and eventual outcome including any action to be taken from lessons learned.
Due to the varied nature of disclosures it is not possible to give timescales, sometimes an investigation may take considerable time. However, any investigation will not be deliberately protracted, and you will be kept informed of progress and when it is likely to be concluded.
Investigation
The person who you contacted will need to decide who will investigate and what form the investigation will take. They may need to consult with other people. However, any sharing of information will be on a need to know basis.
If there is evidence of criminal activity, then the police will be informed. Other appropriate bodies e.g. auditors, legal advisers will be consulted as necessary.
If the disclosure is related to a member of clergy the matter will be passed to the Archdeacon for ongoing action.
If your disclosure relates to a member of staff, they will be informed as soon as possible and may be suspended whilst the investigation proceeds. A written report will be prepared and if appropriate the disciplinary procedures will be invoked.
The PCC as trustees will be informed of all relevant information.
Public Concern At Work
Further information about whistleblowing is available from www.pcaw.org.uk or telephone 020 7404 6609.