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Whistleblowing policy

We always aim to conduct ourselves ethically and with honesty and integrity. We expect the same high standards from all of our people – employees, contractors, trustees and directors. We do, however, recognise that there may be occasions when we – or our people – do not get this right. In these instances, you may need to raise certain concerns through this whistleblowing policy.

There may also be times when our clients might not get things right. Although external concerns may need to be handled differently, how to raise external concerns is explained within this policy and can be used as a guide in these cases.

This section of the playbook covers what you can do to report any wrongdoing.

What is whistleblowing? #

Whistleblowing is the reporting of suspected wrongdoing at your workplace that can affect others. Legally, this is known as ‘making a disclosure in the public interest’.

The Public Interest Disclosure Act 1998 provides protection for individuals who raise legitimate concerns about the specified matters outlined below.

These are called qualifying disclosures. A qualifying disclosure is one made in good faith by an individual who has a reasonable belief that:

This policy is only to be used in specific circumstances outlined above. 

If your concern is related to anything other than a disclosure in public interest, please refer to dxw’s grievance procedure.

How to raise a concern #

If you see, or hear, something that you think falls under the above reasons for whistleblowing, it’s important that you raise your concern swiftly.

While you have the option to express your concern verbally, we do ask that wherever possible, you also submit it in writing, in your own words. This will help to facilitate the investigation and ensure you receive a proper response. 

In most cases, we hope that you will feel comfortable to raise any concerns with your line manager.  If you feel unable to raise your concern with your line manager, you can speak to your Head of, or Director. Alternatively, you can contact the Head of People directly.

There may be circumstances where you do not feel comfortable with your identity being known when reporting a concern. In these instances, you can use this anonymous form to report your concern. This form is managed by the People team, and they will receive the responses submitted through this form. The People team will then review the concern and pass the information across to an appropriate person.

When reporting a concern in this way, please ensure that you include as much detail and evidence as possible, as we will not be able to contact you for further details. The investigation may be affected if we do not have all of the relevant information. 

Please be aware that when raising a concern anonymously, you will not receive any further communication following the reporting of your concern, as we will be unable to identify you.

When raising a concern where you are not anonymous, please make sure that you cc the People team into any emails to ensure that your concern is recorded, and to ensure the team can support you, and anyone else involved in the process appropriately. You should clearly state what your whistleblowing concern is. You should keep to the facts, provide any evidence and avoid language that may be insulting or abusive.

Investigating your concern #

You can usually expect a written response to your concern within 7 calendar days. This response will outline the next steps for investigation and typically involves a detailed discussion in a meeting with you. You may bring a colleague or union representative to any meetings related to whistleblowing.

Someone appropriate, according to the nature of the concern, will be appointed to investigate. This would normally be a Director who has had no prior involvement in the event that has been raised.

Estimating the duration of an investigation is challenging, as it depends on the nature of the raised concern. There may be some instances where it is necessary to refer the matter to an external advisor. The person appointed to investigate your concern will provide regular updates on progress where possible. Following the conclusion of the investigation, and where possible, you will be informed of the outcome. There is no formal right to appeal the outcome.

Confidentiality #

Discussions and investigations about whistleblowing will be kept private. If you report a concern, it’s important that you do not discuss this with others unless it is with people directly involved in the investigation process. This helps keep the investigation fair, protects everyone’s privacy, and avoids any unwanted interference. Confidentiality is key to making sure it’s safe for people to speak up about their concerns.

Protection and support for whistleblowers #

We encourage openness under this policy and want anyone raising a concern to be assured it will be taken seriously and investigated thoroughly, even if it turns out to be unfounded. The Public Interest Disclosure Act 1998, protects whistleblowers from detrimental treatment as a result of making a protected disclosure. Raising a protected disclosure should not have a negative impact on your treatment at work. This includes, but is not limited to, career progression and dismissal.  

We will not tolerate anyone facing negative consequences for making a disclosure in good faith. If you believe you have received any such treatment, you should contact the Head of People immediately.

Malicious disclosure #

If it’s discovered that you deliberately brought up an issue that you know is false, or if you’re somehow connected to the misconduct, wrongdoing, or illegal actions, your conduct will be dealt with according to dxw’s disciplinary procedure.

External concerns #

For any external concerns, generally, we advise raising them with your line manager or Director and referring to the client’s or government area’s own whistleblowing policy. If the external concern involves us directly, i.e. our operations or ethics, then this becomes an internal matter and will need to be raised using the guidance in this policy.

Last updated: 23 February 2024 (history)