Whistleblowing Policy

Policy​ ​Last​ ​Updated​ ​on: February 2022

Policy​ ​Last​ ​Updated​ ​by: Matt Pattison

Next​ ​Review​ ​Date: February 2023

This procedure applies to everyone who works for Elite holiday Clubs, whether on a paid or voluntary basis.

Aims and purpose of this procedure

The aim of this procedure is to provide a clear and transparent way for anyone who works for Elite to raise concerns about acts of wrongdoing or malpractice in the workplace. It also aims to ensure that any concerns are dealt with effectively and in a timely fashion.

This procedure provides managers with steps to deal with allegations, ensuring that staff and volunteers are not penalised for raising genuine concerns, even if those concerns prove to be unfounded. It also provides the means for taking disciplinary action against any employee who is found to have raised false concerns with malicious intent.

The procedure does not apply to child protection concerns or allegations of possible risk of abuse by a member of staff or volunteer. Concerns or allegations of this nature should be dealt with following the relevant procedure of child safety.

Aims and purpose of this procedure

  • Speak to your supervisor, manager, or another colleague (preferably someone you work with closely). If your concern relates to your supervisor/manager, you should speak to that person’s manager. If you choose to speak to a colleague, he/she may nominate another responsible manager to handle your concern.
  • Your manager, or the responsible manager, will arrange to meet with you as soon as possible to discuss your concern. This meeting can take place away from the workplace if necessary.
  • You will be told at the meeting, or as soon as possible afterwards, what action will be taken to address your concern. It may not be possible to tell you the full details of the outcome, as this could relate to the confidential third party information. If no action is to be taken in relation to your concern, you will also be informed of this fact and given the reasons why.
  • If you do not want the person you have concerns about to know your identity, you should make this clear to the responsible manager at the earliest opportunity. Every effort will be made to respect your wishes, but it cannot be guaranteed that your identity will not be disclosed. If this is the case you will be informed and any issues you may have about this will be discussed with you.
  • If you need support in raising your concern, you may bring a work colleague or trades union representative with you to the meeting with the responsible manager.



What to do if someone raises a concern with you about malpractice

If someone tells you they are concerned about the actions of another staff member or volunteer, you should arrange to meet him/her as soon as possible. If you are not the person’s supervisor/manager, you should establish why he/she has chosen to discuss the concern with you. You may suggest that the person speaks to another responsible manager if you wish, but should not refuse to hear what the person has to say.

You should approach the situation sensitively, recognising the discomfort that the person may feel. Offer to meet him/her away from the office if he/she wishes, and allow him/her to bring a work colleague or trades union representative to the meeting. You should also remind the person with the concern about other sources of support available to him/her. Some are listed at the end of this document.

If the person reporting the concern wants his/her identity to be kept confidential, you should explain that this will be done if possible, but that it may not be achievable.

Make notes of your discussions with the individual, and check the accuracy of your notes with him/her.

Deciding what action to take

Once you have established the nature of the concern, it may be of a relatively minor nature and you may decide to resolve it informally.

If the concern appears more serious, you must consider first whether any immediate action is needed to protect children or a vulnerable adult. If so, you should check the child protection/ safeguarding procedures to consider what action to take.

You should also consider whether there is any need to involve the police and/or other statutory services (Eg. Health). If so, you should contact Matthew Charles Pattison to discuss the matter further.

If you are not the manager of the person who is subject of the concern, you should refer the matter to the person’s manager, who will decide what action to take.

Conducting an investigation.

Unless the matter is relatively minor and can be dealt with informally, the responsible manager should arrange for an investigation to be completed as swiftly as possible. The investigation should also be demonstrably thorough and impartial.

The scope of the investigation will be determined by the nature of the concern. Witnesses may need to be interviewed and records may need to be scrutinised. It is also possible that advice may be needed from someone with specialist knowledge in human resources.

Once the investigation is completed, a report should be produced summarising the nature of the concern, the investigation process and the outcome, including specific recommendations. The organization should take measures to preserve the anonymity of the person who raised the concern, if this has been his/her wish. If the concerns are not upheld, this should also be made clear.

If the concern is upheld and the person at the centre of it is found to have been culpable or remiss in some way, the report’s recommendations should be carried out using a clear plan of action. The plan may include the use of disciplinary action, training, coaching, counselling, the implementation of the policies and procedures for the whole workforce, or a referral to the Disclosure and Barring Services (DBS).

If it becomes apparent during the course of the investigation that a criminal offense may have been committed, the police should be informed. The organisation’s own investigation may have to be suspended on police advice, if the police decide that they may need to become involved.

The person who raised the concern should be informed of the outcome, but not the details of any disciplinary action. It may be appropriate for the person who raised the concern to be offered support or counselling.

If the concern is unfounded and the person who raised it is found, through the process of investigation, to have acted maliciously or out of desire for personal gain, it may be appropriate to consider disciplinary action against him/her.

Recording Concerns

The responsible manager should make accurate notes of each stage of the process, including the discussions during meetings, regardless of whether the concern is dealt with formally or informally.

Copies of these notes should be given to the person who is the subject of the concern. The person who raised the concern should also be given copies of notes from his/her discussion.

Notes made during the investigation and the report of the investigation, together with any notes relating to the outcome, should be kept on file of the person at the centre of the concern. If it was requested, these notes should not reveal the identity of the person who reported the concerns.

Further information and advice

The following details may also be useful:

Charity Commission: 0845 300 0218

Public Concern at work: 020 7404 6609