Every HALO employee, whether international, or national staff, is expected to report, or ‘blow the whistle’ on anything they witness, which they consider to be inappropriate,
reckless, illegal, or otherwise in contravention of HALO’s Values and Standards1. Those who choose not to report incidents could be considered complicit. The Staff Grievance Procedure and External Complaints Policy.2 are extant, but distinct from HALO’s Whistleblowing Policy.
Whistleblowing is the act of raising a concern about any wrongdoing (including financial impropriety). Sharing information, or talking through any concern, can be the first step
towards helping HALO prevent harm, support victims, investigate failings, discipline offenders and protect our reputation. Examples of wrongdoing which must be reported are:
a. Standing Operational Procedure (SOP) breaches, or shortcuts, which negligently expose individuals (staff, or beneficiaries) to danger.
b. Any act (or serial behaviour) involving the sexual abuse, bullying, or harassment of a member of staff, or beneficiary.
c. Corruption, the financial exploitation of a beneficiary community, or any other financial impropriety.
d. Toxic leadership – leading through fear, cruelty, or any behaviour which runs contrary to HALO’s culture/ ethos, or Values and Standards.
3. WHISTLEBLOWING OPTIONS
Enclosure 1 explains how reports should be made, or escalated, and the three approaches are below. The whistleblower’s privacy, and the confidentiality of their report (or case) will be protected, whatever the approach.
a. The Chain of Command. Wrongdoing of any sort should usually be reported to the chain of command. Leaders in HALO are selected because they have the character and skills to take responsibility, support their subordinates and do the right thing. Whistleblowers should be confident in their chain of command and are routinely expected to use it.
b. Senior Management. Whistleblowers may feel that the severity of the issue they have identified, or witnessed, warrants immediate Director‐level intervention. They might
also lack trust in their immediate superiors. In such circumstances they can and should approach any member of HALO’s Senior Management with the matter they wish to report.
c. HALO Independent Whistleblowing Service: ‘Safecall.’ If the Chain of Command, or Senior Management should not receive a report (if for instance the chain of command is thought to be involved in the wrongdoing), Safecall should be contacted by phone or on the web. The Service should also be used if individuals feel that they want to be completely anonymous to HALO’s chain of command.
d. The Trustees. Should the methods above fail, or be in any way considered inappropriate, employees of HALO also have the freedom to report their concerns direct to
the Chairman, or to other trustees on the Board.3
4. SAFECALL REPORT
Safecall will record each report and pass it to HALO’s Whistleblowing Officer through a fully secure web portal. Director HR is HALO’s Whistleblowing Officer and will be employed as such unless she is accused of the alleged wrongdoing.
All whistleblowing reports will be investigated, with either Director HR, or Head of Safeguarding in the lead, unless the issue is operational, in which case Director of Capability, or Director of Programmes will lead. The whistleblower will be updated on progress and the outcomes. If he/ she used Safecall anonymously, updates will be available through the Whistleblowing Service.
a. Subjects of Whistleblowing Complaints. Anyone who is the subject of a complaint will be told that an allegation has been made against them at an appropriate point in the investigation; the subject’s employment and legal rights will be protected throughout.
b. Results of Investigations and Lessons Learned.
(1) The results of any investigation will be briefed to the CEO, who will determine what action needs to occur. The whistleblower and subject(s) will be kept informed throughout the process, without prejudice to the result.
(2) HALO is a ‘learning organisation’. Lessons (those that can be generally released) will be captured and published for HALO’s internal use once an investigation has concluded; lessons which have Sector‐wide utility will be released through the Charity Commission and/ or the equivalent national bodies (such as the OSCR). SOPs will be amended as necessary to ensure that HALO’s procedures remain agile and consistent with lessons learned.
6. THE WHISTLEBLOWER'S RIGHTS
Employees who whistleblow are absolutely protected under law.4 Where any mistreatment, or reprisal against a whistleblower is proven, disciplinary action will be taken against the perpetrator and a criminal investigation could ensue.
7. REPORTING RESPONSIBILITIES
Honesty and Integrity are key HALO Values. The first duty of a whistleblower is therefore to be certain that, to the best of their knowledge and belief, the report is true; if there is uncertainty it must be explained as such. There will be no penalty if a wrongful allegation is made in good faith, but action will be taken against any member of HALO proven to have made deliberately false, or vexatious claims. A whistleblower should record and report:
a. What is alleged to have happened and when/where.
b. Who has been affected by the case, or incident and what their condition is.
c. Who else witnessed the event, who is aware and what has been done about it.
d. Who else knows that the whistleblower has reported the matter and what are the whistleblower’s wishes concerning their anonymity.
1. The HALO Trust Values and Standards are published as part of HALO’s policy framework.
2. This policy covers the process through which a third party, or member of a beneficiary community, can make a complaint against HALO.
Other trustees who might be approached are: Anthony Bird firstname.lastname@example.org; Jane Davis email@example.com; Paddy Nicoll firstname.lastname@example.org; Paddy Beeley email@example.com; Rupert Younger firstname.lastname@example.org; Nima Elbagir email@example.com; Mark Aedy firstname.lastname@example.org; and Gemma Mortensen email@example.com
4. The legal framework varies from country to country, but many have employment laws, which respect and protect whistleblowers. The UK legislation is the Public Interest Disclosure Act 1998; US legislation comes under the Whistleblower Protection Act 1989.