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1. Scope 
This Policy applies without exception to all those working under Camira’s control. Those raising concerns about malpractice, as defined below, should use this Policy and Procedure.

This Policy and Procedure is not Camira’s normal Grievance Procedure. Those raising concerns about personal circumstances should use the Disciplinary, Grievance and Appeals Policy.

2. Introduction
Camira is committed to maintaining its reputation for ethical behaviour by embracing an open, transparent and safe working environment where workers feel able to speak and ensuring that its business is conducted with integrity.

Camira requires that all those working on its behalf and associated with it to conduct themselves professionally and fairly with openness and honesty to the highest legal and ethical standards. 

Camira adopts a zero-tolerance stance on the victimisation of those who ‘blow the whistle’ and is committed to upholding all applicable compliance and related requirements.

Camira is committed to protecting those that ‘blow the whistle’ and to the protection of public interest through the consistent and fair enforcement of this Policy and associated procedures. Insofar as permitted by law,  Camira will take all reasonable steps to protect the confidentiality of those making protected disclosure.

3. Purpose
The purpose of this Policy and Procedure is to prevent malpractice by Camira, including its employees,  agents and partners and is designed to help people raise concerns around malpractice.

This Policy and Procedure explains how concerns may be raised with Camira management and/or, if necessary, with other parties and also the protections available under the current Public Interest Disclosure Act (‘PIDA’).

Camira is committed to this Policy and Procedure.

4. Responsibilities
All those working under Camira’s control are responsible for complying with this Policy and Procedure and for the prevention, detection and reporting of malpractice.

Managers are responsible for encouraging vigilance and the reporting of malpractice, for responding to concerns in accordance with this Policy and Procedure, for assisting investigations into such concerns and taking appropriate actions to prevent detect, discourage and deter malpractice.

5. Definitions
‘Whistleblowing’: Workers who make public disclosures, generally to the media about wrongdoings in the workplace, are commonly referred to as “whistle-blowers”. In the past, these workers were often dismissed or victimised by their employers, which discouraged many workers from ‘whistleblowing’. With the introduction of legislation, ‘whistle-blowers’ are now protected under certain circumstances.

‘Malpractice’: in this context refers to actions which may be: illegal, improper, or unethical; in breach of a professional code; possible maladministration, fraud or misuse of public funds; or acts which are otherwise inconsistent with Camira’s Policies; and may for example refer to any of the following: failure to comply with a legal obligation; unprofessional acts; misuse or inappropriate use of funds or resources; a criminal offence; a miscarriage of justice; the endangering health & safety; damage to the environment; deliberate concealment of information relating to any of the above.

‘Fraud’: in this context refers to undertaking, or intention to undertake, actions in order to obtain gain, and/or cause loss to other, and/or expose others to risk of loss. The term ‘fraud’ encompasses: fraud by false representation; fraud by failing to disclose information; and fraud by abuse of position. Descriptions of the above can be found within the current Fraud Act.

‘Corruption’: in this context refers to giving or obtaining advantage through means which are illegitimate, 
immoral, and/or inconsistent with duty and/or the rights of others. Examples include accepting bribes or incentives during procurement processes or seeking to unduly influence others.

6. Policy Statement 
All organisations including Camira risk things going wrong or unknowingly harbouring malpractice. 

Camira is committed to identifying and taking measures to prevent and remedy malpractice, particularly in relation to issues around fraud and corruption. Camira aims to prevent malpractice before it happens by encouraging a culture of openness and encouragement in the raising of concerns.

Those raising concerns are likely to have additional concerns about doing so, for example potential exposure to victimisation, detriment and/or risks to job security. The intention of this Policy and 
Procedure is to encourage the raising of concerns and to provide information about the protections afforded under the PIDA as well as the process by which those concerns should be raised.

By identifying malpractice early, necessary steps can be taken to safeguard interests, protect our organisation and prevent fraud and corruption.

Those using this Policy and Procedure to raise concerns in good faith are assured that they will be treated consistently and fairly and that they will not suffer any form of retribution, victimisation or detriment because of their actions. In addition, the PIDA may provide legal protection in relation to disclosures made in relation to raised concerns in accordance with the Act.

Concerns raised in accordance with this Policy and Procedure will be treated seriously and actions taken will be in accordance with this Policy and Procedure.

Concerns raised in confidence will be treated in confidence however it is not possible to guarantee confidentiality. If confidentiality cannot be maintained then this will be discussed first with those raising the concerns.

Feedback will be given on any investigation and will be sensitive to concerns as a result of any steps taken under this procedure.

In some circumstances Camira may decide that it ought to reveal the identity of those raising concerns in 
order to assist with investigations, in which case those raising the concerns will be advised beforehand.

While disclosures can be made using Camira 24/7 ANON freephone whistleblowing helpline, it is likely to be much more difficult to look into matters raised anonymously, to protect the position of those raising the concerns and to give feedback. It is advised that, where possible, if you use our ANON whistleblowing helpline, that you provide contact details to the operator in order to maintain traceability. These contact details will not be passed on to Camira unless you give explicit consent.

Whistle-blowers receive protection under the PIDA. Further information about the protection afforded 
under the PIDA can be found using the resources listed at the end of this Policy and Procedure.

7. Procedures

7.1. Tell your line manager

• Concerns about any form of malpractice should normally be first raised with your line manager.
• There is no special procedure for telling your line manager other than simply telling them about the concerns or put it in writing if you prefer.
• At whatever level the issue is raised, if you have any personal interest in the issue then this should be raised at the outset.
• The line manager will advise if the concern falls more properly within the grievance procedure
  
  

7.2. If you feel unable to tell your line manager
 

• If you feel you cannot tell your line manager, for whatever reason, you should raise the issue with 
  the next tier of management or, if the issue is related to financial issues, the Finance Director.
• If you feel that you cannot disclose to the next tier of management and/or the Finance Director because you believe that the individual may be implicated in the malpractice, you should raise the matter in confidence with an another Board Director.
• The Board of Directors are entrusted with the duty of investigating staff concerns about illegal, improper or unethical behaviour.
• You should also approach one of the Board of Directors to draw attention to cases where there is evidence of irregular or improper behaviour elsewhere in the organisation, but where you have not been personally involved, or if you are required to act in a way which, for you, raises a fundamental issue of conscience.
  
  

7.3. If you still have concerns

• If you have reported a matter as described in the above paragraph and believe that the response does not represent a reasonable response to the issues you have raised, you may report the matter directly to the Chief Executive Officer (CEO).
  
  

7.4. If you feel unable to raise the matter within Camira

• If you feel that the people whom you would normally raise the issue are parties to, or supportive of, the behaviour causing concern, you may report the matter to our external 24/7 freephone ANON Whistleblowing Helpline by telephoning 0800 160 1787. ANON will report the matter to our Human Resources team for a response.
  
  

7.5. Responding to whistleblowing

• We will decide how to respond to concerns raised in a responsible and appropriate manner, which 
  will normally involve making internal enquiries first, however it may be necessary to carry out an 
  investigation at a later stage which may be formal or informal depending on the nature of the concern.
• If you have raised a concern we will, as far as possible, keep you informed of the decisions taken and the outcome of any enquiries and investigations carried out, however we will not be able to inform you of any matters which would infringe our duty of confidentiality to others.
  
  

7.6. Raising your concern with authorities (exceptional cases only)

• In all but the most exceptional of circumstances concerns about malpractice should be raised internally.
• The purpose of this Policy and Procedure is to provide the opportunity and protection needed to raise concerns internally without reporting the concern to external bodies.
• It is, therefore, expected that raising concerns internally will be the most appropriate action to be taken in almost all cases and those raising concerns must make every effort to do so.
• If, however, those raising concerns fell that it is not possible to do so internally then the PIDA may afford you protection in relation to your disclosure but only if you are acting in good faith and if you honestly and reasonably believe that your allegations are true.
• In such circumstances, you may raise concerns with the Police and/or with the appropriate regulator, for example the Health & Safety Executive, the Environmental Agency, the Information Commissioner’s Office or the Environmental Health Agency.
• If you raise concerns externally, you may be required to demonstrate why you felt that the normal internal procedure was not appropriate. In these circumstances you are strongly recommended to seek advice (see section Sources of advice below) before following this course of action, as the PIDA only affords protection to whistleblowers in certain circumstances.
  
  

7.7. Wider whistleblowing disclosures 

• If you have good reason for not using the internal or regulatory disclosure procedures described above, you might consider making wider disclosure by reporting the matter to the media and/or making a posting on the internet.
• Note that if you have not followed internal procedures, whistleblowing disclosures to the media or by other public disclosure will generally be considered to be an unreasonable course of action.
• Reporting concerns for public circulation, even if done in good faith, before raising them in accordance 
  with these procedures may result in disciplinary proceedings which could lead to your dismissal.
• You are recommended to seek advice before following this course of action, as the PIDA only affords protection to whistleblowers in certain circumstances. In particular, no protection is given if the disclosure is made for personal gain.
• It is important to note that a disclosure will not be protected under the PIDA where you are committing 
  an offence by making that disclosure, for example by breaching the current Data Protection Act.
  
  

7.8. Sources of advice

• It is recommended to that you seek advice about whistleblowing and the PIDA at an early stage if you intend to report malpractice. This is important so that you know the extent of the protection which will be provided to you under the PIDA.
• If you are a member of a trade union, you may wish to seek advice about raising an issue from a trade 
  union representative. You may also wish to seek advice from ‘Protect’ (formally ‘Public Concern at Work’) which is in independent charity set up to provide advice and guidance about whistleblowing issues.
  
  

7.9. Malicious whistleblowing

• If you are found to have made allegations falsely, maliciously and/or not in good faith, a disciplinary process may be instigated against you which may result in your dismissal.
• It is important to note that, as long as you have raised a concern in good faith, you will not be 
  subject to disciplinary action even if the investigation finds your allegations to be unproven.
  
  Issued: January 2025