Whistleblowing Policy

APPENDIX 14

Introduction

The Welsh Karate Governing Body Ltd (WKGB) is committed to creating and maintaining the safest possible environment for adults, children and young people to participate in Karate in Wales and recognises its responsibility to promote a safe environment for any concerns to be reported without fear of reprisal.

The Public Interest Disclosure Act 1998 protects those who raise legitimate concerns about specified matters. It makes provisions about the kinds of disclosure that may be protected and the circumstances in which disclosures are protected.

This policy is therefore intended to comply with the Act by encouraging everyone in Welsh Karate to make disclosures about fraud, misconduct or wrongdoing to the sport of Karate and anyone within it, without fear of reprisal, so that problems can be identified, dealt with and resolved quickly.

Principles

Everyone should be aware of the importance of eliminating fraud or wrongdoing and reporting a safeguarding concern if the person doesn’t believe the relevant welfare officer has dealt with the issue appropriately

You should report anything that you become aware of that is illegal.

You will not be victimized or dismissed for raising a legitimate matter under this procedure.

Victimisation of a member for raising a qualifying disclosure under this procedure will be a disciplinary offence and dealt with under WKGB’s disciplinary procedure.

Covering up someone else’s wrongdoing is also a disciplinary offence. Never agree to remain silent about wrongdoing, even if it is told to do so by a person in authority.

You will not be penalised for raising a qualifying disclosure even if it is not upheld unless the complaint was both untrue and made in bad faith.

It is not the responsibility of the person reporting the disclosure to investigate any complaint that responsibility lies with the WKGB.

Confidentiality should be upheld in line with legislation and government guidance and will be maintained during the process to the extent that it is practical and appropriate in the circumstances.

• Finally, maliciously making a false allegation is a disciplinary offence.

Aims and Scope of This Policy

This policy aims to:

• Encourage all employees and members to feel confident in raising serious concerns and to question and act upon concerns.
• Provide avenues for you to raise concerns and receive feedback on any action taken.
• Ensure that you receive a response to your concerns and that you are aware of how to pursue them if you are not satisfied.
• Reassure you that you will be protected from possible reprisals or victimization if you have a reasonable belief that you have made any disclosure in good faith.

Qualifying Disclosures

WKGB would expect any members or employees to report any of the following:

• A criminal offence (including fraud).
• A failure to comply with a legal obligation.
• A miscarriage of justice.
• The endangering of an individual’s health and safety.
• Damage to the environment.
• Deliberate concealment of information relating to any of the above.
• Harassment or victimization.
• Safeguarding concerns.

Where the nature of the disclosure is not included in the above list, it should be made by way of the organisation’s   Grievance Procedure and not under the Whistle-Blowing Procedure.

Your belief must be reasonable, but it need not be correct. It might be discovered subsequently that you were in fact incorrect, you would then be asked to show that you held  the belief in good faith and that it was a reasonable one to hold in the circumstances at the time.

How to Raise a Concern

As a first step, you should normally raise concerns with your Coach / line manager. This depends, however on the seriousness of the issues involved and who is suspected of the malpractice e.g. if you suspect the coach/line manager you should approach the President.

The seriousness and sensitivity of the issues involved and who is suspected of the Concerns should be raised in writing.

• The earlier you express the concern the easier it is to act.

How WKGB Will Respond

WKGB will respond to your concerns. Where appropriate, the matter raised may:

• be investigated through the disciplinary process;
• be referred to police/ social services.

To protect individuals and those accused of possible malpractice, initial enquiries will be made to decide whether an investigation is appropriate and, if so, what form it should take.

Concerns or allegations which fall in the scope of specific procedures, for example, Safeguarding and Protecting Children, will normally be referred for consideration under those specific policies and procedures.

Disclosure Procedure

1. If you wish to make a qualifying disclosure you should in the first instance report the situation to  the appropriate coach/line manager.
2. Such disclosures should be made promptly so that any investigation may proceed and any action taken quickly.
3. Any qualifying disclosure will be reported to the WKGB Disciplinary Officer who will Determine who will investigate the disclosure in accordance with the WKGB Disciplinary procedures.
4. Once an investigation has been conducted and completed, you will be informed in writing of the outcome and WKGB’s conclusions and decision as soon as possible.
5. If you wish to appeal against WKGB's decision, you must do so in writing within five working days of the decision. On receipt of an appeal, the WKGB Disciplinary officer will make arrangements to hear your appeal.
6. Following WKGB hearing your appeal, you will be informed in writing of the outcome and WKGB's conclusions and decision within five working days.
7. Once WKGB's decision has been finalised, any necessary action will be taken. If no action is to be taken, the reasons for this will be explained to you.
8. If at the conclusion of the above stages, you reasonably believe that appropriate action has still not been taken, you may report the matter to the proper authority in good faith.
9. The WKGB always encourages members and staff to raise their concerns directly in the first instance, rather than externally.

Anonymous Allegations

This policy encourages you to put your name to your allegation whenever possible. Concerns expressed anonymously are much less powerful but will be considered at the discretion of the WKGB.

In exercising this discretion, the factors to be considered would include:

• the seriousness of the issues raised;
• the credibility of the concern.