Healing Process policy suite

Freedom to Speak Up and Whistleblowing Policy

1. Purpose

To enable workers and relevant partners to raise patient-safety, legal, ethical, financial, data, security or workplace concerns in good faith without fear of retaliation.

2. Scope and status

This policy applies to current and former employees, workers, contractors, trainees, suppliers and others covered by applicable whistleblowing arrangements. Patient complaints and individual employment grievances may use separate routes but will be redirected safely where they reveal wider wrongdoing.

Core supplier and product policy

3. Policy principles

• A person does not need proof before raising a genuine concern; they should describe what they reasonably believe and any immediate risk.
• Retaliation, victimisation, obstruction, evidence destruction or pressure to remain silent is prohibited.
• Confidentiality will be protected as far as practicable, but anonymity may limit investigation and cannot be guaranteed where disclosure is legally required.
• Concerns are assessed on substance, not the seniority or status of the person involved.

4. Mandatory requirements

• Provide more than one reporting route, including a manager, specialist lead and Board-level or independent route for concerns about leadership.
• Publicise emergency escalation for immediate patient or information risk and preserve the right to approach appropriate external bodies under law.
• Acknowledge concerns, assess conflict and urgency, appoint an appropriate investigator and agree communication expectations.
• Protect the reporter’s identity and employment position, restrict records and monitor for retaliation.
• Separate good-faith concerns that are not substantiated from knowingly false or malicious allegations; an unproven concern is not misconduct.
• Track investigation findings and corrective action and provide feedback to the reporter as far as confidentiality permits.
• Analyse themes and near misses and report them to governance without suppressing uncomfortable findings.
• Train managers to receive concerns calmly, avoid promises they cannot keep and escalate rather than investigate informally.

5. Procedure and escalation

• A concern is logged securely and triaged for immediate safety, safeguarding, crime, fraud, data, regulatory or HR action.
• Where the concern involves the normal recipient, it is routed to the Board sponsor or an independent adviser.
• Retaliation allegations are investigated separately and may lead to disciplinary or contractual action.
• Closure records findings, uncertainty, action and feedback, with an appeal or review route where appropriate.

6. Roles and responsibilities

Board Sponsor

provides independent oversight and receives trend reports.

Compliance/People leads

maintain routes, protection and investigation quality.

Managers

listen, protect, record and escalate.

All workers

raise serious concerns promptly and cooperate honestly.

Investigators

act fairly, confidentially and without conflict.

7. Records, confidentiality and retention

Keep restricted concern records, triage, conflicts, investigation, communications, protection measures, decisions, actions and retaliation monitoring according to legal and organisational requirements.

Records created under this policy must be accurate, attributable, access-controlled and linked to the applicable retention schedule. Where a provider is the controller or authoritative record holder, its documented instructions and legal duties apply.

8. Monitoring, assurance and review

Review annually and after material case or legal change. Report volumes, themes, response, overdue investigations, action closure and retaliation concerns while protecting identity.

Material non-compliance is reported through the relevant clinical-safety, patient-safety, data, security, safeguarding, HR, contractual or whistleblowing route. Corrective actions receive an owner, target date and effectiveness check.

9. Training and communication

The policy owner identifies which roles require awareness, operational or specialist training. Training is accessible, version-controlled, role-specific and refreshed after material change or evidence that understanding is inadequate. Providers communicate local procedures and contact routes before users are granted access.

10. Related documents

• Patient Safety Incident Policy
• Ethical Business Policy
• Safeguarding Policy

11. Approval record