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We are committed to the highest standards of openness, accountability and integrity. This policy enables individuals to raise concerns about wrongdoing and ensures these are handled appropriately and without fear of reprisals.
Whistleblowing is the disclosure of information relating to suspected wrongdoing that is in the public interest.
This policy applies to all trustees, other volunteers, employees, contractors, and third-party representatives of the charity. Its requirements should be reflected in other policies and procedures, agreements and contracts, as necessary.
A whistleblowing concern relates to matters such as:
Whistleblowing differs from a personal grievance. Personal employment concerns should normally be raised under the grievance procedure unless they are also in the public interest.
We will:
Workers who make qualifying disclosures are legally protected from unfair treatment and dismissal. Trustees and volunteers may not have the same statutory protection under employment law, but the charity will apply equivalent standards of protection and fair treatment in practice.
Concerns should normally be raised internally in the first instance.
Reports can be made to:
Trustees raising concerns should normally do so through the Chair or another independent trustee, particularly where the concern relates to senior management or governance.
Where appropriate, concerns may be raised:
Individuals do not need proof of wrongdoing but must reasonably believe the information disclosed is true and in the public interest.
If a concern is not addressed internally, or it is not appropriate to report internally, individuals (including trustees) may raise concerns with an appropriate external body.
Trustees should consider their duties and the best interests of the charity when deciding whether to escalate externally, but are not prevented from doing so where appropriate.
We will:
Where concerns are raised by a trustee or relate to governance, investigations will be handled independently of those involved and, where necessary, escalated to the Board.
We will make every effort to keep the identity of the individual raising the concern confidential where requested. However, this may not always be possible if disclosure is required by law or necessary for a proper investigation.
We will not tolerate:
as a result of raising a genuine concern.
This applies to all individuals covered by this policy, including trustees.
Although trustees may not have statutory whistleblowing protection in all cases, the charity will treat any detriment arising from a disclosure as a serious matter and respond accordingly.
If a concern is raised in good faith but is not confirmed by investigation, no action will be taken.
However, deliberately false or malicious allegations may result in disciplinary or governance action.
We recognise that raising a concern can be difficult. Support may include:
The charity recognises that trustees have a duty to identify and act on wrongdoing but may face specific challenges, including potential conflicts of interest and lack of formal employment status.
Accordingly, the charity will:
Staff, volunteers and trustees may report serious wrongdoing directly to our Charity or another appropriate regulator where:
The Charity Commission deals with concerns that could cause serious harm to:
Examples include fraud, financial mismanagement, safeguarding risks, or significant breaches of legal obligations.
Individuals should normally raise concerns internally first where it is safe and appropriate to do so. However, they may report directly to a regulator if they believe this is necessary.
You can find details on how to contact the Charity Commission about whistleblowing on this web page.
UK Government – Whistleblowing guidance for employers.
Charity Commission for England and Wales – Report serious wrongdoing at a charity as a worker or volunteer.
Charity Commission for England and Wales – Whistleblowing disclosures made to the Charity Commission E&W 2024 to 2025.
Health and Safety Executive (HSE) – Whistleblowers – Contact HSE.
ACAS – Whistleblowing at work.
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This document may be used by non-profits and may not be used on a commercial basis, without our prior written approval. Copyright and all other intellectual property rights of this and any derivatives of this document are retained by Alumna to the fullest extent possible in law.
We are neither lawyers nor accountants, so are unable to offer professional advice. Even if we were, we could not offer advice that would adequately cover all charities or all circumstances. This draft policy is an example only and not intended to be taken into use as is. If you have a regulator other than the Charity Commission, there may be other requirements that are not necessarily included in this example policy.
In using this draft policy, you are accepting that you will take all necessary steps, including seeking professional advice, to ensure the policy approved meets fully your charity’s needs and complies with all regulatory and legal guidance, keep it under regular review and ensure it is up-to-date and that we have no responsibility whatsoever for any loss or detriment that may arise from using it. I have included links to regulatory guidance, and you can find pro bono support using the Charity Excellence Help Finder.
Ethics note: AI was partially used in researching this guide.
If internal reporting is not appropriate or concerns are not being addressed, you can report serious wrongdoing directly to the Charity Commission. This includes risks to beneficiaries, misuse of funds, safeguarding failures, or legal breaches. The Charity Commission provides guidance on how to raise concerns and what information to include when reporting. You can find full details and reporting routes here: Report serious wrongdoing at a charity as a worker or volunteer. Using the official process helps ensure concerns are recorded and assessed properly.
A whistleblowing policy is a document that explains how staff, trustees, volunteers and others can report serious wrongdoing safely and in the public interest. It covers issues such as fraud, safeguarding risks, legal breaches, or misuse of funds. A clear policy helps charities identify problems early, protect beneficiaries, and demonstrate strong governance. The Charity Excellence template provides a practical starting point that can be adapted to suit your organisation’s size, structure, and risk profile.
Whistleblowing covers serious concerns that affect others or the charity itself, rather than personal complaints. This includes fraud, financial mismanagement, safeguarding failures, legal breaches, health and safety risks, environmental damage, and attempts to cover up wrongdoing. The key test is whether the issue is in the public interest. Clear definitions in your policy help staff and volunteers understand what should be reported and reduce confusion with grievance procedures.
A grievance is usually a personal workplace issue, such as pay disputes or interpersonal conflict, while whistleblowing relates to wider wrongdoing affecting others or the organisation. If a concern involves both, it may still qualify as whistleblowing if it is in the public interest. A well-drafted policy should clearly distinguish between the two to ensure concerns are handled through the correct process and escalated appropriately when necessary.
Employees and workers are protected under UK law from unfair treatment or dismissal if they make a qualifying disclosure. Trustees and volunteers may not have the same statutory protection, but good practice is for charities to offer equivalent protection in their policies. This means ensuring no one suffers disadvantage for raising a concern in good faith and treating any retaliation as a serious matter requiring action.
A strong policy should include a clear definition of whistleblowing, examples of reportable concerns, reporting routes, confidentiality arrangements, protections against detriment, investigation processes, and guidance on external reporting. It should also cover trustees explicitly and explain governance oversight. Charity Excellence provides free, practical templates that include these core elements and align with UK regulatory expectations.
