Whistleblowing

Whistleblowing is the process of raising concerns about wrongdoing, misconduct, risk or malpractice within an organisation. In Scottish third sector organisations, concerns are commonly raised by employees, volunteers, trustees, contractors or others connected with the organisation. Whistleblowing is generally regarded as an important part of good governance, safeguarding and organisational accountability.

Examples of whistleblowing

Concerns raised may include:

• fraud or financial irregularity
• criminal activity
• safeguarding failures or abuse
• breaches of legal obligations
• health and safety risks
• corruption or misuse of charitable assets
• discrimination or unethical behaviour
• attempts to conceal wrongdoing

Within the third sector, whistleblowing is often described as a mechanism that allows people to “speak up” when something appears seriously wrong within an organisation. The aim is usually to identify and address concerns at an early stage before harm escalates or public trust is damaged.

Whistleblowing policy

Whistleblowing policies are an important element of organisational governance and volunteer management. It is good practice for organisations to have whistleblowing arrangements in place so that employees and volunteers can report concerns about unethical, illegal or unsafe practices without fear of retaliation.

A whistleblowing policy explains how concerns can be raised and how the organisation will respond. It is distinct from a complaints or grievance policy because it focuses on concerns raised in the wider public interest rather than solely on personal dissatisfaction or employment disputes.

A typical whistleblowing policy will normally include:

• a statement encouraging people to report concerns
• examples of the kinds of issues covered
• who concerns should be reported to
• options for confidential reporting
• assurances that concerns will be taken seriously
• protections against victimisation or retaliation
• investigation procedures and expected timescales
• guidance on confidentiality and record keeping
• circumstances in which external reporting may be appropriate
• links to related policies such as safeguarding, complaints, disciplinary and grievance procedures

Legal background

Whistleblowing in the UK is commonly associated with the Public Interest Disclosure Act 1998 (PIDA). In practice, Scottish third sector guidance usually refers to PIDA in the context of protecting workers who raise concerns in good faith and in the public interest. Policy materials should present whistleblowing not simply as a legal obligation, but as part of creating a transparent and accountable organisational culture.

Within charities, whistleblowing is closely connected to trustee duties. OSCR emphasises that trustees must act with care and diligence, protect charitable assets and respond appropriately to serious concerns about misconduct or governance failures. OSCR provides a route for concerns involving Scottish charities, particularly where there may be misconduct, mismanagement or risks to charitable property or beneficiaries.

Effective whistleblowing arrangements are generally intended to strengthen organisational culture as much as regulatory compliance. Clear procedures can help build trust, encourage early reporting of serious concerns and demonstrate that organisations are committed to openness, accountability and responsible governance.

Further resources and links

Voluntary Sector Gateway West Lothian - Whistleblowing Policy

UK Government - Whistleblowing for employees

Lindsays Solicitors - Whistleblowing and Charity Trustees

OSCR - Whistleblowing Guidance

Skills Development Scotland - Whistleblowing Policy Example