1. Purpose and scope
The HEADTURNED Foundation (the Foundation) encourages people to speak up if they become aware of serious wrongdoing, risks, or misconduct connected with our work.
This Whistleblowing & Serious Concerns Policy provides a route for people to raise such issues so they can be considered and addressed appropriately.
It is intended for serious concerns and does not replace our Complaints & Feedback Policy for everyday feedback or service complaints.
2. Who this policy is for
This policy is for people who have a connection with the Foundation, such as trustees, staff, volunteers, contractors, partners, and in some cases members of the public who become aware of serious issues.
In some jurisdictions, people who raise concerns in good faith may have specific legal protections as whistleblowers. While the details may vary, the Foundation will not treat anyone unfairly for raising a serious concern honestly and responsibly.
3. What counts as a serious concern?
Serious concerns under this policy may include, for example:
- Suspected fraud, theft, or misuse of funds.
- Serious breaches of safeguarding, health and safety, or animal welfare.
- Serious breaches of law or regulatory requirements connected with the Foundation's activities.
- Serious conflicts of interest or governance failures that put the Foundation or its mission at risk.
- Attempts to conceal or cover up any of the above types of wrongdoing.
If you are unsure whether an issue is a complaint or a whistleblowing matter, you can still raise it; we will route it to the most appropriate process.
4. Principles behind this policy
Our approach to whistleblowing and serious concerns is guided by principles such as:
- Safety – people should feel able to raise concerns without fear of unfair treatment.
- Respect – concerns raised in good faith will be listened to and taken seriously.
- Fairness – investigations will be proportionate and respectful to everyone involved.
- Confidentiality – information will be shared only with those who reasonably need to know in order to handle the concern.
5. How to raise a serious concern
Where possible, concerns should be raised using one of the contact routes published on our website (for example, a dedicated email address or contact form) and clearly marked as a serious concern or whistleblowing issue.
To help us respond effectively, it is helpful to explain:
- What you have seen, heard, or become aware of.
- When and where it happened or is happening.
- Any steps already taken, and any immediate risks you are worried about.
In some cases, you may be able to raise a concern with a specific trusted contact (for example, a safeguarding lead or trustee) if this is more appropriate.
6. Anonymous concerns
Anonymous concerns will still be considered where possible, but they may be harder to investigate or follow up. Providing contact details can help us ask clarifying questions and share relevant updates, but we recognise there may be situations where someone prefers not to identify themselves.
7. How we will handle serious concerns
While the exact steps will depend on the nature of the concern, we aim to:
- Acknowledge receipt of the concern within a reasonable time, where contact details are provided.
- Assess the information provided and decide on appropriate next steps, which may include a preliminary review or a more formal investigation.
- Involve relevant people only on a need-to-know basis, which may include trustees, safeguarding leads, or external specialists where required.
- Take prompt action if there appears to be an immediate risk to people, animals or the Foundation.
Where possible and appropriate, we will provide updates to the person who raised the concern. However, there may be limits on what we can share, particularly where confidentiality or legal constraints apply.
8. Protection from retaliation or unfair treatment
The Foundation will not tolerate detrimental treatment of anyone because they have raised a serious concern in good faith, even if it later turns out that no wrongdoing occurred.
Detrimental treatment can include dismissal, demotion, unfair treatment, or other negative consequences as a result of having raised a concern. Allegations of retaliation may themselves be treated as serious concerns.
9. Relationship with other policies
This policy sits alongside other governance and safeguarding policies, including:
- Our Safeguarding Policy, for concerns about the safety and welfare of children, young people, or adults at risk.
- Our Conflicts of Interest & Decision-Making Policy, where issues relate to conflicts of interest or governance decisions.
- Our Complaints & Feedback Policy, for everyday concerns or dissatisfaction with services.
10. External routes and regulators
Depending on the nature of the concern and where you live, there may be external routes for raising issues with regulators or oversight bodies (for example, in relation to charity regulation, data protection, or health and safety).
Where appropriate, and where we reasonably can, we will signpost to relevant external guidance or bodies if someone wishes to explore those options.
11. Record keeping and learning
The Foundation will keep proportionate records of serious concerns raised, how they were handled, and any actions taken, in line with our Data Protection & Information Governance Policy.
Where appropriate, anonymised learning from serious concerns may be used to improve policies, training, or governance arrangements.
12. Review and updates
This policy will be reviewed periodically and updated where necessary to reflect changes in law, guidance, or the Foundation's structure and activities.
The version published on the HEADTURNED Foundation website is the version currently in force.