Common Purpose (the "Organization")
All employees are encouraged to raise genuine concerns about possible improprieties in matters of financial reporting and other malpractices at the earliest opportunity, and in an appropriate way.
This Whistleblower Policy of the Organization:
This policy not only covers possible improprieties in matters of financial reporting, but also:
1. Encouragement of Reporting
The Organization encourages complaints, reports or inquiries about illegal practices or serious and substantial violations of the Organization's policies, including illegal or improper conduct by the Organization itself, by its leadership or by others on its behalf.
2. Protection from Retaliation
The Organization prohibits retaliation by or on behalf of the Organization against staff or volunteers for making good faith complaints, reports or inquiries under this policy or for participating in a review or investigation under this policy. This protection extends to those whose allegations are made in good faith but prove to be mistaken. The Organization reserves the right to discipline persons who make bad faith, knowingly false or vexatious complaints, reports or inquiries, or who otherwise abuse this policy.
3. Where to Report
Complaints, reports or inquiries may be made under this policy on a confidential or anonymous basis. They should describe in detail the specific facts demonstrating the bases for the complaints, reports or inquiries.
They should be directed to the People & Operations Director; if they are implicated in the complaint, report or inquiry, it should be directed to the Group CEO. The Organization will
conduct a prompt, discreet and objective review or investigation. Staff or volunteers must recognize that the Organization may be unable to fully evaluate a vague or general complaint, report or inquiry that is made anonymously.
If these channels have been followed and employees still have concerns, or if employees feel the matter is so serious that it cannot be discussed with any of the above, they should contact the Chair of the Board of Trustees.
Employees, who have raised concerns internally, will be informed of who is handling the matter, how they can make contact with them and if there is any further assistance required. We will give as much feedback as we can without any infringement on a duty of confidence owed by us to someone else.
Employees' identities will not be disclosed without prior consent. Where concerns are unable to be resolved without revealing the identity of the employee raising the concern, (e.g. if their evidence is required in court), we will enter in to a dialogue with the employee concerned as to whether and how we can proceed.
Public Interest Disclosure Act
All UK employees will be protected under the Public Interest Disclosure Act 1998, where they make a protected disclosure. These are disclosures of information, which in the reasonable belief of the employee making the disclosure, cover the following employer activities:
Employees in other territories will be treated by the Organization as if such legislation applied to them.
Responsibility for reviewing and updating the Whistleblowing Policy lies with the People & Operations Director and nominated Trustee. This document will be reviewed and updated every 12 months.
Last reviewed: 01 March 2021
Common Purpose Charitable Trust
38 Artillery Lane,
London E1 7LS