Cairngorms

Whistleblowing policy

Cairngorms National Park Authority Policy

31st October, 2022

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 raise the matter when it is just a concern rather than wait for proof. If something is troubling you, that you think we should know about, or look into, please use this procedure.

    Our Assurances to you

  3. The Board is 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.
  4. 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

  5. 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 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.
  6. 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.
  7. 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

8.    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

9. 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

10. 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

11. 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

12. 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 on 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 crises of conscience or the procedures you should contact the HR Manager.

Independent advice

13. 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.

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