Westminster Foundation for Democracy (WFD) wishes to establish effective arrangements so that our people, partners, and participants in WFD-supported activities feel safe to speak up if they come across something in their work or interactions with WFD, past present or imminent, that they consider may be a breach of WFD’s Code of Conduct or otherwise wrong, illegal, or endangering the safety or wellbeing of others.

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Policy Principles

WFD’s Reporting Concerns Policy is based on several principles. WFD will:

• As part of its approach to Code of Conduct and Reporting Concerns, follow the four-stage process: (1) prevent harm, particularly sexual exploitation and abuse and sexual harassment, from occurring; (2) encourage all stakeholders to report concerns and listen to those who are affected; (3) respond sensitively but robustly when harm or allegations of harm occur; and (4) learn from every case.
• Lay out appropriate standards of behaviour for staff and all those engaged by WFD via the WFD Code of Conduct.
• Provide a unified mechanism for reporting any concerns in relation to the WFD Code of Conduct and any of WFD’s policies via this Reporting Concerns Policy;
• Ensure that everyone feels able to, and understands their responsibility to, speak up when they see something that doesn’t feel right;
• Listen to those who raise a concern and treat them with respect;
• Handle concerns responsibly, professionally, and in a positive manner;
• Ensure anyone raising a concern does not suffer any unfair or negative treatment; and
• Support those involved.

Definitions

“Code of Conduct” means the WFD Code of Conduct as approved and adopted by the Chief Executive Officer

“Code of Conduct SRO” means the Chief Executive Officer who acts as Senior Responsible Officer for the Code of Conduct

“Code of Conduct Focal Point” means a WFD staff member who can advise and assist individuals, outside the management chain, to raise a Concern

“Concern” means any reasonable, honest believe of an actual, suspected, or threatened breach of the Code of Conduct or any of the policies referred to in the Code. This excludes any issues related to management decisions or processes, or terms and conditions of employment, which relate to an individual employee and should be addressed under the Grievance Policy.

“Nominated Officer” means a WFD staff member who acts as the Senior Responsible Officer for promoting training and standards associated with a policy referred to in the Code of Conduct, receiving and responding to Concerns, and coordinating reviews and learning.

“Protected disclosure” means a Concern that is a “qualifying disclosure” protected by law under the Public Interest Disclosure Act 1998, commonly known as the “whistleblowing legislation”.

Policy Implementation Framework

1. Governance accountability

The Board of Governors of WFD is ultimately accountable for overseeing the proper management of WFD’s arrangements to ensure that Concerns may be reported and responded to appropriately.

As a Board member, the CEO currently acts as the Board-level Safeguarding champion.

2. Management responsibility

The Chief Executive Officer (CEO), as Senior Responsible Officer (SRO) for the Code of Conduct and Accounting Officer, holds senior management responsibility for developing and implementing this Policy.

The CEO shall be assisted by the Director of Operations generally and, as appropriate, the relevant Nominated Officer(s).

3. Scope and application

This Policy applies directly to all WFD Governors and staff including employees, agency workers, self-employed contractors engaged by WFD.

The Policy also applies to any partners, suppliers, and participants in WFD activities.

Line managers should ensure that any new joiners are aware of this Policy.

4. What types of Concerns may be raised under this Policy?

This Policy may be used if, in relation to WFD-supported activities:

• someone is asked to do something, or is aware of the actions of others, which they consider to be a breach of the Code of Conduct or any of WFD’s policies;
• someone witnesses behaviour they consider to be fundamentally wrong, illegal, or has the potential to endanger others or breach WFD’s values;
• there is any incident of fraud, theft, bribery, corruption, or terrorist financing;
• someone is concerned about a failure to comply with legal obligations; and/or
• any safeguarding issue arises.

This list is not exhaustive.

There is no timeframe limit on when a concern can to be raised under this policy. Therefore, if concerns relate to historical incidents, these can be raised via the process set out below and will be handled in accordance with this policy.  

5. How to raise a Concern

If someone is unsure as to whether a Concern can be raised under this Policy, they are encouraged to speak to a Code of Conduct Focal Point, a Nominated Officer, or the Code of Conduct SRO.

There are a number of routes for someone to raise a Concern:

• Talk to a WFD manager;
• Email concerns@wfd.org or telephone the WFD Emergency phone on +44 7920 524264;
• Speak directly to the relevant Nominated Officer or the Code of Conduct SRO; or
• Notify the Foreign, Commonwealth & Development Office, WFD’s sponsor department, via the reporting concerns mailbox and hotline reportingconcerns@fcdo.gov.uk or +44 (0) 1355 843747 for any fraud, bribery, corruption, or safeguarding Concern or the FCO Management Advice Service (managementadviceservice@fco.gov.uk) for any non-financial Concern, where a WFD staff member feels unable to raise any issues to WFD, due to the severity or sensitivity of the complaint; or where there is senior management implicated.

Code of Conduct SRO

Code of Conduct SRO

Anthony Smith

anthony.smith@wfd.org

Nominated Officers

Safeguarding staff, experts, and participants	Jon Spence Cecilia Makonyola	Safeguarding@wfd.org Jon.spence@wfd.org Cecila.makonyola@wfd.org
Safety & security	Natasha Kurzeja	Security@wfd.org
Fraud, theft, bribery, and corruption	Natasha Kurzeja	fraud@wfd.org
Privacy & data protection	Natasha Kurzeja	Dataprotection@wfd.org
Counter Terrorism	Natasha Kurzeja	fraud@wfd.org
Bullying and Harassment	Jon Spence	Jon.spence@wfd.org

Format for raising a Concern  

A Concern may be raised in person, by email, or by telephone. Individuals should try to provide as much information as possible, including:

• Background and reason for the Concern;
• Whether the Concern has already been raised with anyone else and the response;
• Relevant dates;
• How the values and behaviours in the Code of Conduct have been breached.

6. Confidentiality and protection

Individuals should be encouraged and feel able to voice a Concern openly under this policy.

Any Concerns raised under this Policy will be treated in a sensitive manner. Details of individuals will only be shared with those who need to know in order to review, investigate, and progress the matter. This would usually be the Code of Conduct SRO, the relevant Nominated Officer, and any internal or external adviser to the Nominated Officer.

If someone wishes to raise a Concern confidentially on the basis that their name is not revealed without their consent, this will be respected as far as possible. If an investigation may indicate the source of the information, this will be discussed with the individual before proceeding. If a Concern is raised anonymously, this is likely to limit the extent to which WFD can investigate the matter and therefore put others at risk. Raising a Concern openly makes it easier to investigate fully, provide feedback, and take action.

Individuals who raise a genuine Concern in line with this Policy should not suffer any detriment as a result of raising that Concern. This includes cases where a review or investigation confirms that there has been no wrongdoing. Any suggestion of victimisation will be rigorously investigated. If the Concern is a Protected disclosure, this protection is guaranteed by law. In the unlikely case of a false report made in bad faith, this could be treated as a disciplinary matter.

7. Responding to Concerns

WFD will develop Response Procedures which will establish robust guidelines for responding to and investigating any concerns raised under the Reporting Concerns Policy. There will be Non-Compliance Incident Response Procedures and Safeguarding Incident Response Procedures.

In summary, all Concerns should be promptly notified to and review by the relevant Nominated Officer. The review will include a discussion with the individual raising the Concern to ensure that the Nominated Officer has a clear understanding of the matter and to discuss how the matter will be taken forward. Individuals may wish to be accompanied by a trade union representative or a work colleague at this meeting for support. As appropriate, an investigation may be commissioned. Any investigation will be conducted sensitively and as quickly as possible. WFD will assess the need to take immediate steps may be taken to protect any individual or assets that may be at risk.

The Nominated Officer will keep the individual who raised the Concern updated throughout the process.

When the matter is concluded, the Nominated Officer will explain the outcome of the review and/or investigation in as much detail as they are able, whilst maintaining security and confidentiality. This may be face-to-face or over the telephone, but will always be confirmed in writing.

WFD will make every effort to provide the necessary reassurance that the matter has been properly looked into and where appropriate action has been taken to address any Code of Conduct breach or wrongdoing, so that the Concern raised is put to rest.

8. Learning

WFD will develop Review Procedures which will be a process for periodic review and continuous improvement of reporting on and responses to any concerns raised.

Following any reported concern in relation to the Code of Conduct, WFD will review the Code of Conduct and this Reporting Concerns Policy, and all relevant procedures and identify any improvements to be made. The CEO, as SRO for the Code of Conduct, will be responsible for ensuring implementation of any required improvements.

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This policy was last updated on May 23 2024.