Policies / Whistleblowing
A safe route for raising serious concerns.
This policy explains how people connected with HEADTURNED Foundation can raise serious concerns about wrongdoing, risk, misconduct, or serious failure, and how those concerns should be handled.
Purpose and scope
This policy is for serious concerns that go beyond routine complaints.
HEADTURNED Foundation encourages people to speak up if they become aware of serious wrongdoing, serious risk, misconduct, concealment, or failure connected with the Foundation’s work.
This policy provides a route for those concerns to be raised, considered, escalated, and addressed appropriately.
It does not replace the Complaints Policy for everyday feedback, dissatisfaction, service issues, or routine concerns.
Related documents
Whistleblowing sits alongside the wider trust, safeguarding, complaints, and governance framework.
Policies Overview
Brings together the trust, compliance, and governance policies that support the Foundation website.
Complaints
Explains how everyday concerns, complaints, and formal issues may be raised and handled.
Safeguarding
Explains how safeguarding responsibilities, welfare concerns, and protective principles are approached.
Governance
Explains how the Foundation approaches stewardship, oversight, and responsible decision-making.
Who this policy is for
This policy applies to people with a connection to the Foundation.
This policy is for people who have, or have had, a connection with the Foundation, including trustees, staff, volunteers, contractors, advisers, partners, applicants, suppliers, and others who become aware of a serious issue connected with the Foundation’s work.
In some jurisdictions, people who raise concerns in good faith may have specific legal protections as whistleblowers. While the detail may vary, the Foundation will not treat someone unfairly for raising a serious concern honestly and responsibly.
Serious concerns
Whistleblowing is intended for serious wrongdoing, serious risk, or serious misconduct.
Serious concerns may include:
- suspected fraud, theft, bribery, or misuse of funds;
- serious safeguarding, welfare, health and safety, or animal welfare concerns;
- serious breaches of law, regulation, governance duties, financial controls, or compliance requirements;
- serious conflicts of interest or governance failures that put the Foundation, its mission, people, animals, land, or public trust at risk;
- deliberate concealment, cover-up, falsification, or destruction of relevant information;
- serious misuse of personal information, confidential information, systems, resources, or authority; or
- retaliation or unfair treatment connected with someone raising a serious concern.
If you are unsure whether something is a complaint, safeguarding matter, whistleblowing matter, or another type of concern, you can still raise it. We will aim to route it to the most appropriate process.
Principles
Serious concerns should be handled with safety, fairness, confidentiality, and proportionate action.
- Safety: people should be able to raise serious concerns without fear of unfair treatment.
- Respect: concerns raised in good faith should be listened to and taken seriously.
- Fairness: reviews and investigations should be proportionate and respectful to everyone involved.
- Confidentiality: information should be shared only with those who reasonably need to know in order to handle the concern.
- Action: serious risks should be assessed promptly and escalated where necessary.
How to raise a concern
Serious concerns should be raised clearly and with as much relevant detail as possible.
Where possible, concerns should be raised using the contact routes published on the website and clearly marked as a serious concern or whistleblowing matter.
It is helpful to explain:
- what you have seen, heard, or become aware of;
- who may be involved, where this is known;
- when and where the issue happened or is happening;
- whether there is any immediate risk to people, animals, land, systems, funds, evidence, or the Foundation;
- any steps already taken; and
- any documents, messages, screenshots, records, or other information that may help us understand the concern.
In some cases, it may be more appropriate to raise the concern with a trusted person, safeguarding lead, trustee, adviser, or other responsible contact.
Anonymous concerns
Anonymous concerns will be considered, but they can be harder to investigate.
Anonymous concerns will be reviewed where possible. However, anonymity may limit our ability to ask clarifying questions, assess evidence, take follow-up steps, or provide updates.
Providing contact details can help us handle the matter more effectively, but we recognise that there may be situations where someone does not feel able to identify themselves.
How concerns are handled
The response will depend on the nature, seriousness, urgency, and evidence available.
Where appropriate, we aim to:
- acknowledge receipt within a reasonable time where contact details are provided;
- assess the information and decide whether the matter is a whistleblowing concern, safeguarding concern, complaint, governance issue, or another type of matter;
- take prompt action where there appears to be immediate risk;
- involve relevant people only on a need-to-know basis;
- seek specialist, legal, safeguarding, technical, or professional advice where appropriate;
- carry out a proportionate review or investigation; and
- record the concern, decisions made, actions taken, and any learning identified.
Where possible and appropriate, we may provide updates to the person who raised the concern. There may be limits on what can be shared, especially where confidentiality, safeguarding, legal duties, employment matters, or investigation integrity apply.
Protection from retaliation
Unfair treatment for raising a serious concern in good faith will not be tolerated.
The Foundation will not tolerate detrimental treatment of anyone because they have raised a serious concern in good faith, even if the concern is not ultimately upheld.
Detrimental treatment may include dismissal, demotion, exclusion, intimidation, harassment, pressure, threats, loss of opportunity, reputational harm, or other negative consequences connected with raising a concern.
Allegations of retaliation may themselves be treated as serious concerns.
External routes and records
Some concerns may also involve external regulators, authorities, or specialist bodies.
Depending on the nature of the concern and where you live, there may be external routes for raising issues with regulators, law enforcement, oversight bodies, safeguarding authorities, data protection regulators, health and safety bodies, or other competent authorities.
We will keep proportionate records of serious concerns raised, how they were handled, decisions made, and any actions taken, in line with our Privacy Policy.
Where appropriate, anonymised learning from serious concerns may be used to improve policies, training, risk controls, governance arrangements, safeguarding practices, or operational processes.
Review and updates
This policy will be reviewed as the Foundation’s structure, activities, and responsibilities develop.
This policy will be reviewed periodically and updated where necessary to reflect changes in law, guidance, Foundation structure, reporting routes, safeguarding arrangements, governance responsibilities, or operational activity.
The version published on this page is the version currently in force.