CAIRNGORMS NATION­AL PARK AUTHORITY

WHIS­TLEBLOW­ING POLICY

INTRO­DUC­TION

1. All of us, at one time or anoth­er, have con­cerns about what is hap­pen­ing at work. Usu­ally these con­cerns are eas­ily resolved. How­ever, when they are about unlaw­ful con­duct or fin­an­cial mal­prac­tice it can be dif­fi­cult to know what to do. You may be wor­ried about rais­ing such issues or may want to keep the con­cerns to your­self, per­haps feel­ing it’s none of your busi­ness or that it’s only a sus­pi­cion. You may feel that rais­ing the mat­ter would be dis­loy­al to col­leagues, man­agers or to the organ­isa­tion. You may decide to say some­thing but find that you have spoken to the wrong per­son or raised the issue in the wrong way and are not sure what to do next.

2. The CNPA has intro­duced this pro­ced­ure to enable you to raise your con­cerns about such issues at an early stage and in the right way. We would rather that you raised the mat­ter when it is just a con­cern rather than wait for proof. If some­thing is troub­ling you, which you think we should know about, or look into, please use this procedure.

OUR ASSUR­ANCES TO YOU

1. The Board are com­mit­ted to this policy. If you raise a genu­ine con­cern under this policy, you will not be at risk of los­ing your job or suf­fer­ing any form of retri­bu­tion as a res­ult. Provided you are act­ing in good faith, it does not mat­ter if you are mis­taken. Of course we do not extend this assur­ance to someone who mali­ciously raises a mat­ter they know is untrue.

2. We will not tol­er­ate the har­ass­ment or vic­tim­isa­tion of any­one rais­ing a genu­ine con­cern. How­ever, we recog­nise that you may non­ethe­less want to raise a con­cern in con­fid­ence under this policy. If you ask us to pro­tect your iden­tity by keep­ing your con­fid­ence, we will not dis­close it without your con­sent. If the situ­ation arises where we are not able to resolve the con­cern without reveal­ing your iden­tity (for instance because your evid­ence is needed in court), we will dis­cuss with you wheth­er and how we can proceed.

HOW CNPA WILL HANDLE THE MATTER

1. Once you have told us of your con­cern, we will look into it to assess ini­tially what action should be taken. This may involve an intern­al inquiry or a more form­al invest­ig­a­tion. We will tell you who is hand­ling the mat­ter, how you can con­tact him/​her and wheth­er your fur­ther assist­ance may be needed. If you request, we will write to you sum­mar­ising your con­cern and set­ting out how we pro­pose to handle it.

2. While the pur­pose of this policy is to enable us to invest­ig­ate pos­sible mal­prac­tice and take appro­pri­ate steps to deal with it, we will give you as much feed­back as we prop­erly can.

3. If reques­ted, we will con­firm our response to you in writ­ing. Please note, how­ever, that we may not be able to tell you the pre­cise action we take where this would infringe a duty of con­fid­ence owed by us to someone else.

HOW TO RAISE A CON­CERN INTERNALLY

Step one

1. If you believe that you are being required to act in a way, or believe that any oth­er mem­ber of staff is act­ing in a way which:

   • Is illeg­al, improp­er, or unethical;
   • Is in breach of a pro­fes­sion­al code;
   • May involve pos­sible mal-admin­is­tra­tion; and,
   • Is oth­er­wise incon­sist­ent with the CNPA work­ing practices

2. you should report the mat­ter to your imme­di­ate line man­ager. If you feel unable to raise the mat­ter with your man­ager, you should approach the HR Man­ager. Please make it clear if you want to raise the mat­ter in confidence.

Step Two

1. If this does not resolve the mat­ter, you should then approach the next per­son in the line man­age­ment chain, up to and includ­ing the Chief Exec­ut­ive. If the situ­ation remains unre­solved the mat­ter should then be repor­ted to the Con­ven­or, who will invest­ig­ate your con­cerns and let you know what action should be taken.

Step Three

1. If these chan­nels have been fol­lowed and you still have con­cerns, or if you feel that the mat­ter is so ser­i­ous that you can­not dis­cuss it with any of the above or you believe that the response from the Con­ven­or does not rep­res­ent a reas­on­able response to your con­cern you may then report the mat­ter to the Scot­tish Exec­ut­ive (Sec­ret­ary SERAD).

Note

1. If your con­cern relates to a Board mem­ber then you should report the mat­ter to the Chief Exec­ut­ive, who will raise it with the Con­ven­or and agree a course of action to be taken. If your con­cern relates to the Con­ven­or or Deputy Con­ven­or you should report the mat­ter to the Chief Exec­ut­ive, who will raise it with the Scot­tish Gov­ern­ment. If you have any con­cerns that you would like to dis­cuss about crises of con­science or the pro­ced­ures you should con­tact the HR Manager.

INDE­PEND­ENT ADVICE

1. If you are unsure wheth­er to use this pro­ced­ure or you want inde­pend­ent advice at any stage, you may contact:
   • If applic­able, your union;
   • The inde­pend­ent char­ity Pub­lic Con­cern at Work on 0141 550 7572. Their law­yers can give you free con­fid­en­tial advice at any stage about how to raise a con­cern about ser­i­ous mal­prac­tice at work.