Policy Date Policy Owner Name Policy Owner Title Review Date January 2026 Gill Green Director of Operations January 2027 View as a PDF Policy Scope Forever Manchester is Greater Manchester’s Community Foundation, the only charity that raises money to fund and support community activity across Greater Manchester. This policy is applicable to all our employees, trustees, those providing or receiving a service to/from the Foundation. Policy Statement Employees are often the first to realise that there may be something wrong within the organisation. However you may not express your concerns because you feel that speaking up would be disloyal to your colleagues or to Forever Manchester. You may also fear harassment or victimisation. In these circumstances it may be easier to ignore the concern rather than report what may be just a suspicion of malpractice. Forever Manchester encourages its members of staff to raise genuine concerns about malpractice at the earliest practicable stage rather than wait for proof. Malpractice within Forever Manchester is taken very seriously. This procedure is to provide safeguards to enable you to raise concerns about malpractice in connection with Forever Manchester. The aim is to provide a rapid mechanism under which genuine concerns can be raised internally without fear of repercussions to the individual. The procedure also seeks to balance the need to provide safeguards for employees who raise genuine concerns about malpractice against the need to protect other members of staff and Forever Manchester against uninformed or vexatious allegations which can cause serious difficulties for innocent individuals. Malpractice The following are examples of malpractice: fraud or financial irregularity; corruption bribery or blackmail; criminal offences; failure to comply with a legal or regulatory obligation; miscarriage of justice; endangering the health and safety of an individual; endangering the environment; improper use of authority; serious financial maladministration arising from the deliberate commission of improper conduct; concealment of any of the above. Procedure If you want to raise a concern about any of the above, please use the procedure set out below. Please note that there are existing procedures to enable you to raise grievances concerning your employment. The procedure applies to disclosure by an individual (described in this procedure as “the Discloser”) who is an employee or agency contract worker employed or engaged by Forever Manchester and who has grounds to believe that malpractice has occurred, is occurring or is likely to occur in Forever Manchester (whether on the part of another employee or any other person or persons). The Discloser shall as soon as practicable disclose in confidence the grounds for belief of malpractice to the Chief Executive who has been designated by Forever Manchester as a member of staff with appropriate experience and standing to handle such disclosures. For the purposes of this procedure the above-named person is described hereafter as the “Designated Officer”. Any disclosure shall be in writing and the Discloser should provide as much supporting evidence as possible about the disclosure and the grounds for the belief of malpractice. On receipt of the disclosure the Designated Officer will offer to interview the Discloser in confidence, such interview to take place as soon as practicable after the initial disclosure. The Discloser may be accompanied by a local trade union representative or work colleague at the interview. Further steps As soon as practicable the Designated Officer will recommend what further steps are to be taken. Such recommendations may (without limitation) include one or more of the following: (a) the matter be reported to the police (b) the matter be investigated further internally by Forever Manchester or by external auditors or investigators appointed by Forever Manchester (c) that the Discloser be given the opportunity to seek redress through the grievance or disciplinary procedure. A recommendation of no further action may be made if the Designated Officer is: (a) satisfied after investigation that the malpractice has not occurred or is not likely to occur (b) aware that the matter is already subject to legal proceedings, or has already been referred to the police or other public authority (c) aware that the matter is already (or has already been the subject of proceedings) under one of the Forever Manchester’s other procedures (d) satisfied that the Discloser does not have a reasonable belief that malpractice within the meaning of this procedure has occurred, is occurring or is likely to occur (e) satisfied that the Discloser is not acting in good faith Any recommendations under this procedure will be made by the Designated Officer to the Board of Trustees. In any event the allegations will be made without identifying the Discloser save as outlined below. The recipient of the recommendations shall implement the recommendations except to the extent that in the view of the recipient there are good reasons for not doing so. The Discloser will be informed of the steps taken or if no steps are taken the reason for this. External disclosure If having followed the procedure the Discloser is not satisfied with the steps taken the Discloser may raise the matter confidentially with the police or relevant public authority or Member of Parliament. The Discloser may at any time disclose the matter to a professionally qualified lawyer for the purpose of taking legal advice. If an employee has a concern and is unsure whether this is the appropriate procedure for raising it, or is unhappy about the final outcome of an investigation, he or she can contact the independent charity, Public Concern at Work, on 0207 404 6609 for independent advice. Safeguards The Discloser will not, where practicable, be identified unless the Discloser consents in writing or there are grounds to believe that the Discloser acted maliciously. In the absence of consent or grounds the Discloser will only be identified if: this is a legal obligation the information is in the public domain to a professionally qualified lawyer for the purposes of obtaining legal advice or where it is necessary as part of a proper investigation However, whilst all practical steps will be taken to avoid the identity of the Discloser becoming public knowledge, the Discloser must accept that in some circumstances it may inevitably be possible to deduce his identity as the Discloser of the information. Confidentiality of the Discloser’s identity cannot therefore be guaranteed. Any documentation (including computer files and disks) kept in relation to the matter will be kept secure. This will ensure that as far as practicable, any documentation prepared will not reveal the identity of the individual as the Discloser of information under this procedure. Where the Discloser involves a local trade union representative or work colleague, the Discloser will be under an obligation to use all reasonable endeavours to ensure that the representative or work colleague keeps this matter strictly confidential save, as permitted under this procedure, as required by law or until such time as it comes into the public domain. Protection against detriment for making a disclosure No detriment will be imposed and no disciplinary action will be taken against the Discloser because of disclosure made in accordance with this procedure. This will not, however, prevent Forever Manchester from bringing disciplinary action in cases where there are grounds to believe that a disclosure has been made maliciously or vexatiously or where external disclosure is made in breach of this procedure without reasonable grounds or otherwise than to an appropriate public authority.
