Speak Up & Listen Up Policy

Introduction

The Speak Up & Listen Up Policy (the Policy) sets out the framework for dealing with concerns of illegal and improper conduct.

The Charity is committed to the highest standards of transparency, probity, integrity and accountability.

This Policy is intended to provide a means of raising concerns about standards, conduct, financial irregularity or possible unlawful action, in a way that will ensure confidentiality and protect those raising such concerns in the reasonable belief that it is in the public interest to do so from being victimised, discriminated against or disadvantaged.

This Policy is intended to ensure that the Charity complies with its duty under the Public Interest Disclosure Act 1998.

Public Interest Disclosure, or "Whistleblowing" is the reporting of suspected wrongdoing or risks that are in the public interest. This is legally known as making a protected disclosure under the Public Interest Disclosure Act 1998. Whistleblowing concerns are different from personal grievances, which relate to an individual’s own employment situation.

The Public Interest Disclosure Act 1998 protects individuals who raise concerns about wrongdoing in the public interest. This means that a person who speaks up in good faith should not suffer dismissal, victimisation, or unfair treatment because they have raised a genuine concern.

Scope

This policy applies to the Trustees as well as any other person associated with the Charity. This Policy applies to, but is not limited to, concerns about any of the following:

  • Conduct which is an offence or breach of the law
  • Alleged miscarriage of justice
  • Serious Health and Safety risks
  • The unauthorised use of public funds
  • Possible fraud and corruption
  • Sexual, physical or verbal abuse, or bullying, or harassment, or intimidation of employees, or customers or service users
  • Abuse of authority
  • Other unethical conduct
  • The concealment of any of the above

This Policy should be read in conjunction with any other applicable operational policies, which may be adopted by the Charity from time to time.

The Charity’s policies are located centrally by the Charity.

Reporting

Contact Details for Reporting (in writing):
Nick Swales (Chairperson) or Debbie Clarke (*Designated Safeguarding Lead)
Amelia House,
Crescent Road,
Worthing,
United Kingdom,
BN11 1RL

Or by email: concern@CISIFutureFoundation.onmicrosoft.com

The Charity recognises that the decision to raise a concern can be difficult. However, those who speak up in the reasonable belief that it is in the public interest to do without fear of victimisation or discrimination because they are doing their duty either to the Charity and/or to those for whom the Charity are providing a service for.

The Charity will take appropriate action to protect anyone who speaks up in the reasonable belief that it is in the public interest to do so from any reprisals, harassment or victimisation.If an individual feels unable to raise a concern internally, or believes it has not been properly addressed, they may raise the matter with an appropriate external body such as the Charity Commission, the Police, or another relevant regulator.

Confidentiality

All concerns will be treated in confidence, and every effort will be made not to reveal the identity of the individual who raised the concern unless the individual requests otherwise. However, this may not always be possible if the matter is subsequently dealt with through other Charity policies.

Similarly, if the concern results in court proceedings, then the individual may have to give evidence in open court if the case is to be successful.

The Charity will not, without the individual’s consent, disclose the identity of said individual to anyone other than a person involved in the investigation/concern.

Anonymous Concerns

This Policy encourages those who speak up to put their name to a concern wherever possible as anonymous concerns may often be difficult to substantiate/prove. Concerns made anonymously are much less powerful but anonymous concerns will be considered at the discretion of the Charity Chairperson / Board of Trustees.

In exercising discretion to accept an anonymous concern the factors to be taken into account:

  • The seriousness of the issue raised
  • The credibility of the concern; and

Whether the concern can realistically be investigated from factors or sources other than the complainant

Untrue Concerns

No action will be taken against an individual who speaks up and raises a concern in the reasonable belief that it is in the public interest to do so even if the concern is not substantiated by an investigation.

However, action may be taken against an individual who speaks up and raises a concern without reasonable belief that it is in the public interest to do so (e.g. raising a concern frivolously, maliciously or for personal gain where there is no element of public interest).

Procedure for Raising a Concern

It is preferable for concerns to be made to the Charity Chairperson. However, this may depend on the seriousness and sensitivity of the issues involved and who is suspected of the malpractice. For example, if the individual who speaks up believes that the Chairperson is involved it would be inappropriate to raise it directly with them. The individual may then raise the concern directly with the Designated Safeguarding Lead (DSL).

If either of the above are notified of a concern, they will consider the concern and may discuss it with the other Trustees. The Chairperson (or either/or both) of the above, af ter consideration, will discuss the concern with the individual who spoke up to determine if they wish to proceed with the concern and an investigation.

Concerns

Whether a written or oral report is made it is important that relevant information is provided including:

  • The name of the person raising the concern and a contact point (if not anonymous).
  • The background and history of the concern (giving relevant dates and names and positions of those who may be in a position to have contributed to the concern);
  • The specific reason for the concern. Although someone raising a concern will not be expected to prove the truth of any concerns, they will need to provide information to the person they have reported to, to establish that there are reasonable grounds for the concern.

Someone raising a concern may be accompanied by another person of their choosing during any meetings or interviews in connection with the concern. However, if the matter is subsequently dealt with through another policy, the right to be accompanied will at that stage be in accordance with the relevant policy.

Action on receipt of a concern

The Chairperson and/or the DSL will record details of the concern, gathering as much information as possible (within 5 working days of receipt of the concern) including:

  • The record of the concern:
  • The acknowledgement of the concern;
  • Any documents supplied by the individual speaking up

The Chairperson and/or the DSL will ask the individual speaking up for their preferred means of communication and contact details and use these for all communications with the individual in order to preserve confidentiality.

If the concern relates to fraud, potential fraud or other financial irregularity the Chairperson and/or the DSL will be informed within 5 working days of receipt of the concern. The Chairperson and/or the DSL will determine whether the concern should be investigated and the method of investigation.

If the concern discloses evidence of a suspected criminal offence, it will immediately be reported to the Board of Trustees and a decision will be made as to whether to inform the Police. If the concern involves suspected harm to children and/or vulnerable adults, the Safeguarding Policy should be ref erred to.

The Charity reserves the right to appoint an independent external person to carry out an investigation of a complaint where required.

Timetable

An acknowledgement of the concern in writing within 10 working days with:

  • An indication of how the Charity propose to deal with the matter
  • An estimate of how long it will take to provide a final response
  • An indication of whether any initial enquiries have been made
  • Information on support mechanisms for the individual speaking up
    Indication whether further investigations will take place and if not, why not

The Chairperson and/or the DSL will aim to keep the individual speaking up informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent them giving specific details of the investigation or any action taken as a result.

Where the concern has been made anonymously the Charity will be unable to communicate what action has been taken.

Support

The Charity will take steps to minimise any difficulties which may be experienced as a result of raising a concern. For instance, if the individual speaking up is required to give evidence in criminal or disciplinary proceedings the Charity will arrange for them to receive advice about the procedure and advise on the support mechanisms that are available.

The Charity accepts that those speaking up need to be assured that the matter has been properly addressed. Thus, subject to legal and/or confidentiality constraints, we will inform those raising concerns of the outcome of any investigation.

Responsibility for the Policy

The DSL has overall responsibility for the operation of this Policy and together with the support of the board for determining the administrative processes to be followed and the format of the records to be kept.

Monitoring

A Register will record the following details:

  • The name and status (e.g. supplier) of the individual speaking up
  • The date on which the concern was received
  • The nature of the concern
  • Details of the person who received the concern
  • Whether the concern is to be investigated and, if yes, by whom
  • The outcome of the investigation
  • Any other relevant details

The Register will be confidential and only available for inspection by the Board of Trustees.

The DSL will report annually to the Board of Trustees on the operation of the Policy and on any concerns raised during the period covered by the report. The report will be in a form which does not identify those speaking up.

*Designated Safeguarding Lead: Responsible for the implementation of the Safeguarding and Speak Up & Listen Up policies and reviewing the policies on a tri-annual basis

Last reviewed by the Board: 16/02/2026

Next review due: 16/02/2029