Whistleblowing Policy

Organisation: Think Cre8tive Group CIC

Date Adopted: 1 October 2025

Review Date: 1 October 2026

Responsible Officer: Chair of the Board / Designated Whistleblowing Lead

1. Policy Statement

Think Cre8tive Group CIC is committed to the highest standards of openness, honesty, and accountability. We encourage staff, volunteers, and stakeholders to raise concerns about wrongdoing, risk, or malpractice at the earliest opportunity, without fear of reprisal.

This policy outlines how concerns can be raised, how they will be investigated, and the protection available to whistleblowers.

2. Purpose

This policy ensures:

  • Concerns about wrongdoing can be raised safely and confidentially.
  • All reports are treated seriously and investigated fairly.
  • Individuals are protected from victimisation or retaliation when acting in good faith.
  • Think Cre8tive Group CIC complies with the Public Interest Disclosure Act 1998 (PIDA).

3. Scope

This policy applies to:

  • All employees, directors, and sessional staff.
  • Volunteers and facilitators.
  • Contractors, partners, or suppliers with a relationship to Think Cre8tive Group CIC.

4. What is Whistleblowing?

Whistleblowing is the disclosure of information about malpractice, illegal acts, or dangers at work. Examples include:

  • Fraud, corruption, or financial irregularity.
  • Criminal activity or breaches of law.
  • Safeguarding risks or neglect of participants.
  • Health and safety dangers.
  • Discrimination, harassment, or unethical behaviour.
  • Deliberate concealment of wrongdoing.

This policy is not for personal grievances (which should be raised via the Complaints or Grievance Policy).

5. Principles

  • Concerns can be raised without fear of dismissal, victimisation, or disadvantage.
  • Whistleblowers’ identities will be kept confidential wherever possible.
  • Concerns will be taken seriously, investigated promptly, and addressed fairly.
  • Malicious or knowingly false allegations may lead to disciplinary action.

6. How to Raise a Concern

Concerns should be raised as soon as possible, either verbally or in writing. Routes include:

  1. Line Manager / CEO – for staff and volunteers.
  2. Designated Whistleblowing Lead (Chair of the Board) – if the concern involves management or is particularly serious.
  3. External reporting – where internal reporting is not appropriate, concerns can be raised with:
    • Regulator (CIC Regulator, Charity Commission if relevant).
    • Local Authority Safeguarding Team.
    • Whistleblowing helplines (e.g. Protect).

7. Procedure

  1. Concern is raised verbally or in writing.
  2. Acknowledgement is given within 5 working days.
  3. The concern will be assessed and, if appropriate, a formal investigation will be launched.
  4. An outcome will normally be communicated within 30 days (or longer if complex, with updates provided).
  5. If the whistleblower is unsatisfied, they may escalate to the Board or an external regulator.

8. Protection for Whistleblowers

  • No individual will be penalised for raising a concern in good faith.
  • Retaliation or harassment of whistleblowers is strictly prohibited and will result in disciplinary action.
  • Support will be offered where needed, including access to external advice services.

9. Roles & Responsibilities

  • Board of Directors: Oversight of policy and investigations.
  • Chair / Designated Lead: Point of contact for concerns, ensures investigations are fair and independent.
  • Managers: Promote a safe culture where concerns can be raised.
  • All Staff & Volunteers: Duty to raise concerns where they believe wrongdoing may be taking place.

10. Monitoring & Review

  • The Board will monitor whistleblowing reports and outcomes annually.
  • This policy will be reviewed every 12 months, or sooner if legal changes occur.
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