Last Reviewed:

7 July 2022


22 June 2022

Scheduled review date

All policies are reviewed annually or as required


  • Whistleblowing is the reporting of suspected malpractice, wrongdoing or dangers in relation to activities that the Group undertakes. The main purpose of this policy is to give all our staff the opportunity and protection they need to raise concerns internally and in the manner provided for under the whistleblowing legislation, without fear of retribution or detrimental treatment.
  • The Group wishes to assure all staff that it is safe and acceptable to speak up about any concerns they may have. This policy is designed to enable staff to raise any concern at an early stage. We would far rather you raise a matter when it is still only a concern rather than waiting for proof. As long as you raise the matter in good faith, it matters not if you are mistaken or if there is an innocent explanation for your concerns.
  • This procedure is non-contractual and does not form part of your contract of employment. We reserve the right to vary it from time to time.


  • This procedure applies to all staff including agency workers and staff on zero hours contracts.


When to use this policy

  • Whistleblowing occurs when an individual provides information which has a public interest aspect to it and tends to show: 

    • that a criminal offence has been committed, is being committed or is likely to be committed,
    • that a person has failed, is failing or is likely to fail to comply with any legal obligation,
    • that a miscarriage of justice has occurred, is occurring or is likely to occur,
    • that the health or safety of any individual has been, is being or is likely to be endangered,
    • that the environment has been, is being or is likely to be damaged, or
    • that information regarding the above has been, is being or is likely to be deliberately concealed.

  • If your complaint relates to your own employment position or personal circumstances at work or we consider it may be more appropriately or better handled under our grievance policy (or any other) then we will let you know.


Raising a concern

  • If you have a concern about any form of malpractice covered by this policy, you should normally raise the issue with your line manager. If you feel you cannot tell your line manager, for whatever reason, you should raise the issue with your line manager’s, line manager. If you feel you cannot tell this person either, or you have exhausted these channels and you still have concerns, then you should raise the issue with our Group Head of Compliance & Clinical Governance and/or our the Head of Legal. Contact details are at the end of this policy.

  • You should raise your concern in writing. Although you are not expected to prove the truth of your disclosure, you must reasonably believe the disclosure is made in the public interest and that the information provided tends to show the malpractice described. We will therefore generally need sufficient details to enable us to investigate it.

  • You should seek to provide us with the following information:
    1. Your name;
    2. Information on the malpractice/concern such as what was said or done; and
    3. the background and history of the concern (giving relevant dates, places and departments and people involved, where possible).
    4. If you have any personal interest in the matter, we do ask that you tell us at the outset.
  • Although information may be provided anonymously, we encourage you to give your name when reporting your concern whenever possible. This is because anonymous disclosures are difficult to investigate. We nonetheless have a dedicated Ethics Reporting Channel, Navex, to where anonymous reports may be made. Further details are below.

  • The Group would expect you in almost all cases to seek to raise your concerns internally as the most appropriate first course of action. We encourage you to always seek to raise your concerns internally wherever possible but we appreciate that this may not always be possible. We strongly encourage you to seek advice before reporting a concern to any outside agency or body of the Group. Sources of advice, support and further information are available at the end of this policy.

Responding to concerns

  • In the first instance, we will assess your concern and consider any appropriate action. This may involve an informal review, an internal inquiry or a more formal investigation. We will always seek to acknowledge your concerns and where appropriate, advise you of how we propose to handle the matter, as soon as possible.

  • We may ask you for further information about the concern either at a meeting or by other means.

  • Whenever possible, we will give you feedback on the outcome of any investigation. We will also, if possible seek to give you an indication of timings for any actions or next steps. We cannot however inform you of any matters which would infringe any duty of confidentiality owed to others therefore we might not be able to advise you of the full action we have taken, only that any necessary steps have been

  • All concerns raised will be treated in confidence and every effort will be made not to reveal your identity unless it is required to investigate your concern.

Protection and support for those raising concerns

  • If staff use this policy in good faith to raise a concern the Group gives them its assurance that they will not suffer any form of retribution, victimisation or detrimental treatment because of any such disclosure. Anyone found to be involved in such conduct may be subject to disciplinary action which could result in their immediate dismissal. However, if we conclude that a whistleblower has maliciously made false allegations maliciously, then that person may be subject to disciplinary action of their own. 

Further information and contacts

For Legal, Anti-bribery, Corruption, Data Protection and Information Security & Integrity:

Head of Legal

Luisa Wengraf

West Wing, 17th Floor, Chiswick Tower, Chiswick High Road, London W4 4AJ




For Health, Safety and Welfare:

Head Quality, Safety, Health & Environment

Marc Christian




For Safeguarding & Delivery of Care:

Head of Clinical Governance & Compliance

Ursula Holt



Ethics Reporting Channel, Navex 

Tel: 0800 048 5851 or as otherwise set out using the above link


The Whistleblowing Helpline

Offers free advice to workers in social care


Telephone helpline: 0800 072 4725