1. Introduction

1.1. We are committed to the highest possible standards of openness, probity and accountability. In line with that commitment, the aim of this policy is to encourage you to assist us in tackling fraud, corruption and other malpractice within the organisation and in setting standards of ethical conduct. These are very serious issues and we are committed to tackling them within the organisation at all levels. Our aim is to provide a way for you to  report any concerns about malpractice to us, which you reasonably believe are in the public interest.

1.2. The types of malpractice that we are concerned about include:

1.2.1. Any fraud including tenancy fraud, financial mismanagement or corruption;

1.2.2. Any irregularities involving accounting or other financial procedures;

1.2.3. The commission of any criminal offence;

1.2.4. Any conduct which is or maybe in conflict with our interest, such as involvement with a business competitor;

1.2.5. Any dishonesty or other irregularities in dealing with customers and suppliers;

1.2.6. Conduct which endangers the health and safety of employees and others working for us;

1.2.7. Failure to comply with any legal or professional obligation or regulatory requirements;

1.2.8. Bribery under our Anti-fraud and corruption Policy;

1.2.9. Breach of our internal policies and procedures including our Code of Conduct;

1.2.10. Unauthorised disclosure of confidential information;

1.2.11. Negligence;

1.2.12. Damage to the environment; and

1.2.13. The deliberate concealment of any of the above matters.

1.3. It is not possible to come up with an exhaustive definition of what we mean by malpractice, and there may well be other issues of concern which we have not listed here but would nevertheless be considered as malpractice. You are encouraged to speak up if you have any concerns.

2. Policy Statement

2.1. This policy is not meant to apply to employees who have a complaint about their employment, which should be addressed under the Grievance Policy. The Confidential Reporting Policy applies to all employees, agency and casual workers, consultants and also to our board, residents, contractors, suppliers and other people and organisations with which we work (our Stakeholders).

2.2. This policy should be used where there are concerns about suspected danger or wrongdoing, and where you reasonably believe that disclosure of your concern is in the public interest. This policy does not apply to concerns relating exclusively to an individual's personal situation, as these issues should be raised under our policies dealing with grievances, harassment or bullying as appropriate. This policy also does not apply to concerns or issues relating to any personal or contractual dispute a stakeholder may have with us.

2.3. This policy does not form part of any employee's contract of employment and we may amend it at any time.

2.4. All employees and managers of Fairhive, under the guidance of the Chief Executive for matters raised internally, or the Company Secretary for matters raised by stakeholders, are responsible for the implementation of the Confidential Reporting (Whistleblowing) Policy.

3. Your Responsibilities

3.1. Reporting

3.1.1. If you are aware of or suspect that there may be any sort of malpractice occurring within the organisation, we strongly encourage you to let the relevant person know about it.

3.1.2. We hope that in many cases you will be able to raise any concerns with your line manager. You may tell them in person or put the matter in writing if you prefer. They may be able to agree a way of resolving your concern quickly and effectively.

3.1.3. However, where the matter is more serious, or your concern has not been addressed by your line manager and / or you prefer not to raise it with your line manager for any reason, you should contact one of the following individuals using the confidential reporting email account, or contact the individual directly:

  • Company Secretary;
  • Chief Executive;
  • Chair of the Audit Committee; or
  • Chair of the Board.

3.2. This confidential email address, Confidential.Reporting@fairhive.co.uk, is for all confidential reporting concerns. Any email sent to this address will be received by members of the HR team and the Company Secretary. This email account is available for both internal and external concerns – please could you specify on your email who you would like your concern to be referred to.

3.3. If you are an employee, it would not normally be appropriate to disclose your concerns outside of Fairhive, or to a third party unless you have followed the procedures in this policy first. If you disregard these procedures, any disclosure to a third party may be in breach of your obligations or confidentiality which form part of your employment relationship with us, and you may not qualify for statutory protection under the Employment Rights Act 1996 (ERA 1996). (The Act). In specified circumstances, the Act gives protection to workers who raise concerns about malpractice. If you would like more information about the Act, please contact the Human Resources Team.

3.4. If you are a stakeholder or individual outside of Fairhive, you should raise your concerns with the Company Secretary in the first instance.

3.5. If you are uncertain whether something is within the scope of this policy you should seek advice from the Head of People Engagement.

3.6. We will investigate all concerns that are raised, even if they are raised anonymously. However, we would encourage you to give us detailed information about your concerns including your name, your position and details of the malpractice, including comments as to how you have been able to find out about it.

3.7. The more information that you can give us, the easier it is for us to progress our investigations. We will ensure that if you give your name, the person conducting the investigation will consider putting in place procedures to protect your identity. If you raise a concern on an anonymous basis, you should be aware that this may make it impossible for us to fully investigate your concerns.

4. Investigation

4.1. The person that you contact will investigate the concern that you have raised with them. In appropriate cases, the person you contact may appoint others, for example the police, to investigate your concern.  The nature of the investigation will depend on the nature of the problem you have raised, but in each case we will do the following:

  1. Take a detailed note of your concern and, if possible, talk to you if more details are needed.
  2. Investigate your concern in conjunction with any other department relevant to the subject matter of your complaint. 
  3. Respect your confidentiality as far as possible. If you do raise a concern, the person that you contact will take all reasonable steps to keep your identity confidential. However, in order to ensure that we can fully investigate your concern, it may not be possible to guarantee absolute confidentiality.
  4. Give you feedback at the conclusion of the investigation and, where possible, tell you what action, if any, has been taken.

4.2. To enable us to minimise the risk of future wrongdoing, the investigator may make recommendations for change including, but not limited to:

  1.  A review of internal policies and procedures;
  2. The provision of additional support and training for employees;
  3. Carrying out additional risk assessments;
  4. Re-structuring of departments or directorates; and/or
  5. Disciplinary action.

4.3. We will aim to keep you informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent us giving you specific details of the investigation or any disciplinary action taken as a result. You should treat any information about the investigation as confidential.

5. Protection

5.1. It is understandable that individuals are sometimes worried about possible repercussions. We aim to encourage openness and will support employees who raise genuine concerns under this policy, even if they turn out to be mistaken.

5.2. Individuals who raise concerns under this policy must not suffer any detrimental treatment as a result of raising a concern. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Head of People Engagement immediately. If the matter is not remedied, you should raise it formally using our Grievance Procedure.

5.3. You must not threaten or retaliate against an individual who has raised concerns under this policy in any way. If you are involved in such conduct you may be subject to disciplinary action.

5.4. If you genuinely believe that there is some form of malpractice occurring within Fairhive, and that your disclosure is in the public interest, and you raise a concern in accordance with this policy, we will ensure that you do not suffer any disadvantage in the workplace as a result of speaking out about your concerns.

5.5. It may be that a concern that you have raised turns out to be unfounded when investigated. This does not mean that you should not have raised your concern in the first place and therefore will not affect our policy to ensure that you do not suffer a disadvantage as a result of raising your concern.

5.6. In certain circumstances, you may also be protected under the Employment Rights Act 1996. The link to this Act is: http://www.legislation.gov.uk/ukpga/1996/18/contents

5.7. If you raise a concern which you know to be false and/or raise a concern solely out of malice, then disciplinary action may be taken against you in accordance the procedures set out in our Disciplinary Policy. This disciplinary action may result in dismissal or termination of your relationship with us.

5.8. While we cannot always guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way. By using this policy you can help us to achieve this.

5.9. If you are not happy with the way in which your concern has been handled, you can raise it with the Company Secretary or Chief Executive or the Chair of the Audit Committee or the Chair of the Board.

6. External Disclosures

6.1. The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally.

6.2. The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. It will very rarely, if ever, be appropriate to alert the media. We strongly encourage you to seek advice before reporting a concern to anyone external. The independent whistleblowing charity, Public Concern at Work, operates a confidential helpline. They also have a list of prescribed regulators for reporting certain types of concern.

6.3. Concerns might relate to the conduct of our employees, but they may sometimes relate to the actions of a third party, such as a customer, supplier or service provider. In some circumstances the law will protect you if you raise the matter with the third party directly. However, we encourage you to report such concerns internally first. You should contact your line manager or the Company Secretary or Chief Executive or the Chair of the Audit Committee or the Chair of the Board.

7. Monitoring

The HR department is responsible for monitoring this policy and to provide regular reports to the Head of People Engagement and by exception to the Executive Management Team. This policy will be reviewed at least every three years to ensure that it remains relevant to the business and fit for purpose.

8. Impacts

Resident/Employee Implications - 

This policy applies to all employees, agency and casual workers, consultants and also to our board, residents, contractors, suppliers and other people and organisations with which we work (our Stakeholders).

Equality, Diversity & Inclusion - 

This policy is applied to all employees in a fair and consistent manner, and conforms to the requirements of the Equality Act 2010.

Value for Money - 

Policies that support legitimate concerns being raised help to ensure effective service delivery and, in turn, value for money.

We depend on motivated, safe and engaged employees to deliver our strategic objectives.

Data Protection - 

All HR data is stored in line with Fairhive’s Data Retention Policy.

Accountability - 

There is a risk of malpractice not being addressed if employees feel unable to safely raise concerns.

This policy provides a safe reporting mechanism to ensure our policies and practices are being followed. This supports the continuation of effective service delivery.

Quality - 

N/A

When things go wrong - 

N/A

9. Related legislation, regulation, procedures and other documents:

Equality Act 2010
Disciplinary Policy
Grievance Policy
Employment Rights Act 1996

Policy author details
Author Lauren Bright
Job title HR Business Partner
Date approved May 2023
Review Due Date May 2026

                      together with tenants                  disability confident leader                          HQN DLO contractor logo                          HDN logo                   ASCP logo