WHISTLE-BLOWING POLICY

1. Introduction

1.1 BFD is one of NGOs aid agencies committed to fighting poverty through its programme principles.  These principles and aims are delivered through integrity, this means being honest and transparent in what we do and say, and accepting responsibility for our individual and collective actions.  It is expected that those working for, and representing BFD shall act with integrity.  BFD shall be an organization that acts with integrity and honesty.

1.2 In order for stakeholders of BFD to have confidence in our honesty and integrity, this policy aims to provide a supportive process that encourages and enables employees or workers to raise concerns about misconduct within BFD without repercussion and will give them confidence that their concerns will be properly investigated and resolved in a timely manner.

2. Legal and Policy Impact

2.1 This policy considers the following legislation:

•   Human Rights Act (1998).

•   Public Interest Disclosure Act (1998).

•   Employment Rights Act (1996) sections 44 and 100.

2.2  Where an employee has a concern about their terms and conditions of work, their working relationship with BFD, or how a concern they raised was addressed, they are encouraged to use BFD grievance procedure.

2.3  In the event that an employee feels they are being bullied or harassed in the workplace for either blowing the whistle, or for any other reason they are encouraged to refer to BFD PSEA Policy.

2.4  The BFD website is reasonable evidence that Whistle-Blower are not being followed.

3. Scope of the policy

3.1 This policy applies to all employees, contractors/consultants and agency workers, trustees, interns, volunteers or those on work-placement working on behalf of building Foundation for Development.  Throughout the document, the term “worker” will apply to collectively define these groups.

4. BFD's policy on Whistle-blowing

4.1 BFD's policy on whistle-blowing has the following objectives:

•   To provide direction to all BFD workers on what is unacceptable practice within BFD, and to provide a safe and secure environment to blow the whistle on unacceptable practice.

•   To protect workers who raise a concern in good faith and who have a reasonable suspicion that the alleged malpractice has occurred, is occurring, or is likely to occur.

•   To provide reassurance to those workers who raise concerns in good faith and with reasonable suspicion that they will not experience any repercussions for doing so.

4.2  This policy aims to make workers aware of their rights and responsibilities with regard to up-holding the values and standards of practice at BFD and how to raise concerns when these standards of practice are not up-held.

4.3  Whilst this is not an exhaustive list, malpractice would include the following:

•            A criminal offence, including theft, fraud or corruption.

•            A failure to comply with a legal obligation, (including but not limited to those under the BFD or its financial regulations).

•            A miscarriage of justice.

•            Accepting gifts which are intended to influence decision making.

•            The endangering of an individual’s health and safety, and well-being:  this would include towards staff member, worker or visitor to BFD.

•            Damage to the environment or conduct which conflicts with Building Foundation for development interests.

•            Deliberate disregard or serious breach of BFD principles and values, including bullying and harassment, and discrimination.

•            Deliberate concealment of information to any of the above.

5. Responsibilities

5.1 Executive Director is accountable for ensuring the effective implementation of this policy throughout BFD and representing BFD's interests/concerns in the event of publicity or litigation resulting from a whistle-blowing allegation.

5.2 Line managers are responsible for ensuring that the principles of this policy are communicated and understood throughout their teams. 

6. How to raise a concern

6.1 In the event that they suspect malpractice, workers at BFD have a responsibility to inform someone who is able to do something about the problem.  They must provide details about the malpractice immediately they become aware.  All attempts should be made to raise the concern internally in the first instance.  Please refer to Appendix A for more details.

APPENDIX A

Worker Guidance on whistle-blowing.

1. Determining whether to use the Whistle-blowing Policy or not

1.1 This quick question section may help you to determine whether you should use the whistle blowing procedure.

1.2 Does the malpractice fall under one of the following?

•   A criminal offence, including theft, fraud or corruption.

•   A failure to comply with a legal obligation, namely those under the BFD or its financial regulations.

•   A miscarriage of justice.

•   The endangering of an individual’s health and safety, and well-being:  this would include towards staff member, worker or visitor to BFD.

•   Damage to the environment or conduct, which conflicts with Building foundation For Development interests.

•   Deliberate disregard or serious breach of BFD principles and values, including bullying and harassment, and discrimination.

•   Deliberate concealment of information to any of the above.

1.3     Do you have a genuine reason to believe that malpractice occurred either in the past, recently, or is likely to occur in the near future?

1.4     What details do you have?  Check that the details are not judgements or assumptions, but based on fact.

1.5     Do you feel vulnerable or at risk?

2. Letting someone know

2.1 It is recommended that as soon as you become aware of, or have good reason to believe that, malpractice either has occurred, is occurring or likely to occur by an employee, volunteer or contractor within BFD, raise your concern with an appropriate member of staff within BFD. In the first instance, this would normally be your immediate line manager.  You can make a report either orally or in writing.

2.2 If the malpractice concerns your line manager, then raise your concern with their line manager.

2.3  If the malpractice is regarding health and safety, raise your concern with the Facilities Manager, who has delegated responsibility for health and safety matters within BFD.  It is also advisable to inform your line manager at this point.

2.4 In any case, CEO/ Executive director should be notified with the concern through submitting it to ethics@bfdyemen.org.  Executive director is responsible for investigating instances of fraud or other malpractice reported to him.   

3. Providing details about your concern 

3.1         As soon as you become aware of or suspect malpractice, you have a duty to inform an appropriate person of your concern.  If it is later found that you were aware of malpractice and had withheld information, this may have serious consequences for you.

3.2          When you discover or suspect any malpractice the following steps  should be taken:-

·       Immediately report your findings or suspicions to ethics@bfdyemen.org as mentioned above.

·       Or you can report anonymously and without disclosing the identity by visting the follwing link  https://www.bfdyemen.org/ethics-center/ . In which foramt should be filled and submitted especiatlly when the concern realted to high senior management as the bord of trustees (Chairman) will dirctly receive the raised concen .

·       Rememebr to provide as much evidence as possible