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Medway Council is committed to tackling acts of fraud,
corruption, unethical conduct and malpractice, regardless of who
commits them or where in the council they are committed. This way,
councillors, staff and the people of Medway can be sure that the
services the council provides are used in the best interests of the
The council wants its staff to feel confident about raising a
concern about any such conduct or action and that this will be
properly dealt with at the earliest opportunity and not overlooked
To encourage and enable them to do this, the council ensures
that anyone who uses its whistleblowing policy to raise a concern
will be protected from any form of detriment, harassment or
victimisation regardless of:
- its content
- the person with whom it is raised
- the outcome of raising the concern.
There are several individuals or specialist teams within the
council with whom staff can raise a concern. The whistleblowing
policy provides an opportunity for their concerns to be dealt with
internally. Many of the solutions will be found within the council
but they may also be dealt with through an agreed external
Although staff may be tempted to take a concern directly to the
media, airing a concern through the media does not always mean that
the issues raised are appropriately addressed and often fails to
protect innocent parties. Council staff have a duty of confidence
to their employer and unauthorised disclosure of information may be
a disciplinary offence. They should therefore not contact the media
unless they have exhausted all the options available to them
through the policy. Instead, they should seek the advice of their
line manager or one of the specialist Whistleblowing Teams.
Council's Whistleblowing Policy (pdf 123KB).
Who can raise a concern?
If you undertake work for the council, whether you are an
employee, a contractor or a paid or unpaid volunteer, you can use
this procedure to raise a concern.
Who can concerns be raised about?
The people listed above can raise a concern about the practice
of anyone who works for or on behalf of the council. This includes
employees of the council, contractors, councillors or
In a school, staff would normally raise a concern with their
direct line manager. If this is inappropriate, their headteacher or
chair of governors should be contacted, who may involve the
nominated whistleblowing officer.
Is there anything that should not be raised through the
The policy should not be used to raise a concern about terms and
conditions of employment which would be covered by the council's
grievance procedure or matters that can be dealt with through
another procedure. It is also possible that after raising a
concern, an employee might be advised about other agreed council
policies or procedures which are more appropriate to the nature of
the concern. If in any doubt, however, this policy can be used as a
starting point for staff concerns.
Misuse of the whistleblowing policy
Raising a concern unreasonably, with malicious intent or for
personal gain or the gain of others is not acceptable and may lead
to disciplinary action under the council’s disciplinary policy.
The council accepts that, wherever possible, the confidentiality
of anyone wishing to raise a concern will be protected. There
might, however, be occasions where confidentiality cannot be
protected, for example where the police need to be involved. If
there is any possibility that someone's confidentiality cannot be
protected, they will be told why this is the case and will be
offered appropriate advice and support.
Concerns raised anonymously
Concerns expressed anonymously will be investigated. An
investigation may be hampered by the inability to gain further
information, however, so the council encourages staff who raise
concerns to provide some method of contacting them in case further
information is needed.
The scope of the policy
A concern can relate to any unethical or unprofessional conduct
within the council. The policy not only covers acts that have
actually occurred but also conduct which is potentially unethical
or unprofessional . Below are some examples but please remember,
this list is by no means exhaustive:
- an actual or potential breach of the law
- possible or actual miscarriages of justice
- the actual or possible abuse (sexual or physical) of clients in
the council’s care
- potential or actual acts causing damage to the environment
- acts or potential acts of fraud and corruption or the misuse of
- acts that could have a detrimental affect on the health and
safety of employees and/or the public
- actual or potential acts of harassment or bullying of or by
someone working for the council
- actual or potential acts of racial or sexual
- any unethical conduct that causes concern or brings the
reputation of the council into disrepute
- the deliberate concealment of information that would indicate
any of the things above.
If staff are in any doubt as to whether or not to raise a
concern, they can seek confidential advice from the council's Human
Resources Services or their trade union representative.
What to consider when expressing a concern
To enable concerns to be dealt with in a proper and effective
manner, staff have some guidelines to consider:
- Be as clear as possible about what the concern is and who and
what it relates to. You may also want to discuss the concern with
others to see if it is shared
- Be as clear as possible about who maybe involved, when and
where actions may have taken place etc. Make sure the facts are
recorded, for example, record the dates and times of events in a
diary. This way you can be clear about what has actually been heard
or seen and when, rather than relying on memory or hearsay
- Make sure you ask for your concerns to be dealt with under this
How to raise a concern
No matter whom staff raise their concern with, it will be dealt
with under this procedure. If the person with whom an employee
raises the concern feels it necessary, they may want to refer the
concern on to either a specialist team or a more senior council
officer, whichever is appropriate. If this is the case, the person
who raised it will be contacted first and have the opportunity to
discuss any further issues they may have.
The first point of contact
A concern would normally be raised initially with an employee's
line manager or supervisor. The nature of the concern and the
people involved may mean that this is not possible, however.
- If an employee feels unable to raise the matter with their line
manager or supervisor, they may wish to contact their director of
service or the director of the service to which their concern
relates, if it is different
- The employee may wish to refer their concern directly to one of
the council’s specialist whistleblowing teams:
Financial and Audit
Fraud, corruption or misappropriation of council assets or
The care and welfare of adults and community issues, for example
issues concerning the conduct of care staff, housing managers and
The care and welfare of children. If someone suspects that a
child is being neglected or abused by a member of staff, they
should contact the Local Authority Designated Officer
The conduct of employees in general and specific issues of
discrimination, harassment etc
The misuse of information technology, such as email and the
Regeneration and Development
Environmental issues, for example building control, planning
All the teams and the service directors have received specialist
training in dealing with concerns and will follow the procedure set
The procedure to be followed
To ensure that all concerns raised are taken seriously and are
fully investigated, the council has agreed a procedure to be
followed in all cases.
If, at any stage of the procedure, you are asked or wish to meet
with someone addressing the concerns you have raised, you have the
option to be accompanied by a work place colleague, trade union
representative or representative from a professional body.
When you first raise a concern:
However you wish to express your concern, by telephone or in
person, you will receive an acknowledgement of your concerns from
the person to whom you have expressed them. This will be sent to
you within five working days of being notified of your concern and
if you wish, can be sent to your home address.
The person to whom you have reported your concern will then
decide how to progress. This may mean undertaking an investigation.
This does not mean that the concern is either true or untrue but
will help to assess the gravity of the complaint and establish the
facts. It could be possible that the concern may be the result of a
misunderstanding or an authorised change in practice.
Within 10 working days of making your concern known you will
- have a confidential meeting with the relevant person to further
discuss your concern or
- have received, in writing, an outline of how the relevant
person intends to deal with the concern raised.
Depending on the nature of the concern, you may have subsequent
meetings with the relevant investigating persons. These can be held
off-site if desired.
The outcome of your concern
Having raised the concern, the council recognises that you will
need to be assured that the issues have been dealt with. You will
be kept informed on a regular basis of what actions are being taken
and the final results of any investigations.
In some situations, such as referrals to external bodies, it may
not be appropriate (or legally possible) to supply you with the
full information discovered. The reasons for this will be explained
at that time, however.
Taking your concern further
If you have gone through all these channels and you still have a
concern or feel that the issues have not been fully or
appropriately addressed, you can contact the Chief Executive or
have him contacted on your behalf, to discuss your concern in
You should not refer the matter outside the organisation,
however, without first ensuring that all other possible avenues
have been exhausted.
If you have a concern about the conduct of the council or the
actions of anyone who provides work for the council, whether they
be employees, councillors, contractors or volunteers, Medway
Council wants you to feel confident that you can bring it to the
attention of others.
Only when people are prepared and feel able to report such
concerns without the fear of reprisals can we all have confidence
in the integrity and honesty of the council.