91¶¶Òõ

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Whistleblowing Policy

At 91¶¶Òõ we expect College members to conduct themselves professionally and with honesty and integrity. However, all organisations face the risk of things going wrong from time to time and unknowingly harbouring illegal or unethical conduct.

Review Date: Lent Term 2027 by Governance Committee

The College encourages open communication from all those who work for us and we want everyone to feel secure about raising concerns. 

This policy applies to all staff and members of the College.  For clarity, the term staff means anyone working in any context for the College at any level or grade (whether permanent, fixed term or temporary) and includes employees, workers, visiting Fellows, trainees, interns, seconded staff, agency staff, agents, volunteers, and external members of College committees. The term member includes senior members (Fellows in any class of fellowship) and junior members (students and alumnae) of the College. For the purposes of this policy, both members and staff will be referred to collectively as staff

The purpose of this policy is to assist individuals who believe they have discovered wrongdoing, malpractice or impropriety.  It does not form part of any employee's contract of employment. 

 

  1. Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work.  This may include:
    a) criminal activity;
    b) miscarriages of justice;
    c) danger to health and safety;
    d) damage to the environment; 
    e) failure to comply with any legal or professional obligation or regulatory requirements;
    f) sexual harassment; 
    g) bribery; or
    h) the deliberate concealment of any of the above matters.
  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 wrongdoing or danger affecting any of our activities (a whistleblowing concern) you should report it under this policy.
  3. This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work. In those cases you should use the College's Grievance Procedure.  In addition, this policy should also not be used:
    a) To reconsider any matters which have already been addressed under a grievance or disciplinary or other internal process; or
    b) To investigate an academic dispute between a student and the College (complaints of this nature should be addressed to the Senior Tutor).
  4. If you are uncertain whether something is within the scope of this policy you should seek advice from the Head of HR/Bursar or President, whose contact details are at the end of this policy.
     
  1. The College hopes that in many cases you will be able to raise any concerns informally in the first instance.  Non-academic staff should raise any concerns with their head of department.  Academic staff and students may wish to raise concerns with the Senior Tutor.  
  2. In either case, if the individual raising concerns reasonably believes any of these individuals are involved in the wrongdoing, then any concerns can be raised directly with a member of Council.  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 Council.
  3. Where the matter is more serious, or you feel your concern has not been adequately addressed, you should contact the Bursar or any other member of Council.
  4. Where concerns have been referred to the Bursar or another member of Council, they will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague or union representative to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation. 
  5. The Bursar or other member of Council will take down a written summary of your concern and provide you with a copy after the meeting. They will also aim to give you an indication of how they propose to deal with the matter.  If an investigation is required, this will be carried out in accordance with the principles set out below. 
     
  1. The College hopes that staff will feel able to voice whistleblowing concerns openly under this policy. It will be more difficult to investigate your concern properly if we are unable to obtain further information from you.  However, if you want to raise your concern confidentially, we will endeavour to keep your identity confidential. If it is necessary for anyone investigating your concern to know your identity, we will discuss this with you. We will also inform you before we confirm your identity to any other person.
  2. Whistleblowers who are concerned about possible reprisals if their identity is revealed should come forward to the Bursar or one of the other members of Council and measures can then be taken to preserve confidentiality where appropriate. If you are in any doubt you can seek advice from Public Concern at Work, the independent whistleblowing charity, who offer a confidential helpline. Their contact details are at the end of this policy.
  1. The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally. 
  2. The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. It will very rarely if ever be appropriate to alert the media. The College strongly encourages you to seek advice before reporting a concern to anyone external. The independent whistleblowing charity, Public Concern at Work, 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.
  1. Once you have raised a concern, this will usually be referred to the Bursar who will carry out an assessment.  At this stage you may be asked to provide further information so the Bursar can assess whether the issue falls within the scope of this Whistleblowing Policy and whether an investigation is required. If it is determined that the matter is better addressed under another policy, you will be informed of this and advised which policy applies.
  2. If an investigation is required, the Bursar will decide whether to investigate the matter themselves, or whether to pass it to someone else who they feel is appropriate to investigate.  In some cases we may appoint an investigator or team of investigators including staff with relevant experience of investigations or specialist knowledge of the subject matter. 
  3. The investigation may involve you or other individuals providing a written statement. You may also be required to attend additional meetings in order to provide further information to assist the investigation.
  4. The College will aim to keep you informed of the progress of the investigation and its likely timescale. 
  5. The person who carried out the investigation will then report to the Council, which will decide whether further action should be taken, including reporting the matter to any appropriate government department or regulatory agency.  If disciplinary action is required, the Bursar will report the matter to Human Resources and/or the Council as appropriate and the disciplinary process may be invoked. The investigator may make recommendations for change to enable the College to minimise the risk of future wrongdoing.
  6. On conclusion of the investigation, the individual will be informed of the outcome and any action the College acting through either the Council or if the Council decides to refer the matter to Governing Body, the Governing Body has decided to take to resolve it. If no action is to be taken, the reason will be stated.  However, sometimes the need for confidentiality may prevent the College from giving you specific details of the investigation or any disciplinary action taken as a result. You should treat any information about the investigation as confidential.
  7. If the College concludes that a whistleblower has made false allegations maliciously or with a view to personal gain, the whistleblower will be subject to disciplinary action. 
     
  1. While the College cannot always guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way. By using this policy you can help us to achieve this.
  2. If you are not happy with the way in which your concern has been handled, you can raise it with another member of Council. Alternatively, you may contact the President as appropriate, who will inform Council that a matter has been raised and will arrange for another senior member of the College to review the investigation carried out, make any necessary enquiries and make their own report to the Council. 
  3. If your concerns relate to the actions of the Bursar you should contact the President who will arrange to investigate the matter in line with the procedure set out in this policy. 
  4. If your concerns relate to the actions of the President then you should raise your concerns with the Vice President who will discuss this matter with the Chair of the Committee constituted under the Fellowship Statute XXXVII, and take such action as they believe is appropriate consistent with the Statutes of the College and employment law.
  5. If, once you have exhausted all available options under this policy, and you reasonably believe the appropriate action has not been taken, then you may wish to raise the matter externally. The College encourages staff in this situation to seek guidance from the Whistleblowing Charity, Public Concern at Work, whose contact details are at the end of this policy.  
     
  1. It is understandable that whistleblowers are sometimes worried about possible repercussions. The College aims to encourage openness and will support staff who raise genuine concerns under this policy, even if they turn out to be mistaken.
  2. Staff 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. 
  3. The College will not tolerate retaliation of any kind.  Any staff involved in such conduct may be subjected to disciplinary action up to and including dismissal.  In some cases, the whistleblower could take legal action against staff personally for compensation in an employment tribunal.  
  4. If you believe that you have suffered any such treatment, you should inform the Bursar immediately. If the matter is not remedied you should raise it formally using our Grievance Procedure. 
     
  1. The Council has overall responsibility for this policy, for reviewing the effectiveness of actions taken in response to concerns raised under this policy and ensuring it stays up to date with current Charity Commission guidance and regulation.
  2. The Bursar, through the Head of HR as appropriate, has day-to-day operational responsibility for this policy.  The Head of HR will ensure that all staff within the College community are aware of their obligations under this policy, and that any staff who may deal with concerns or investigations under this policy receive regular and appropriate training. 
  3. This policy should be reviewed from a legal and operational perspective at least once a year or in line with regulatory changes (whichever is sooner).
  4. All staff are responsible for the success of this policy and should ensure that they use it to disclose any suspected danger or wrongdoing. Staff are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Bursar.

Bursar: bursar@murrayedwards.cam.ac.uk

Acting President: president@murrayedwards.cam.ac.uk

Head of HR: hr@murrayedwards.cam.ac.uk

 

Public Concern at Work 
(Independent whistleblowing charity)

Helpline: (020) 7404 6609
E-mail: whistle@pcaw.co.uk
Website: