Whistleblowing Policy

Last Reviewed: 15/09/2026

Next Review Date: 15/09/2027, or earlier if required by legislation or statutory guidance

1. Purpose

HDS encourages employees and workers to raise genuine concerns about wrongdoing at work.

Whistleblowing is the disclosure of information where a worker reasonably believes both that making the disclosure is in the public interest and that the information tends to show one or more types of wrongdoing listed in section 2. This includes wrongdoing that has happened, is happening or is likely to happen. A reasonable belief can be mistaken; workers do not need to prove the wrongdoing.

This policy does not form part of any contract of employment.

2. What Can Be Reported

 A whistleblowing concern may relate to suspected:

• criminal activity;

• failure to comply with a legal obligation;

• miscarriage of justice;

• danger to health and safety;

• damage to the environment;

• sexual harassment;

• deliberate concealment of any of the above.

 Sexual harassment became an express qualifying category for whistleblowing purposes from 6 April 2026.

 A concern which is solely about an individual’s personal employment situation, without a public-interest element, will normally be dealt with under the Grievance Policy or, where relevant, the Anti-Bullying, Harassment and Sexual Harassment Policy. However, a personal grievance may also contain a protected disclosure. HDS will consider the substance of the concern and any whistleblowing protection that may apply, regardless of which policy the person uses to raise it.

3. Raising a Concern

Concerns should normally be raised with the employee's Line Manager.

Where this is not appropriate, including where the concern involves the Line Manager, it may be raised with another manager or a Director.

Where a concern involves a Director, it may be raised with an uninvolved senior manager. HDS will arrange impartial handling and obtain independent external support where necessary. The manager handling the concern remains responsible for action and follow-up.

Concerns may be raised verbally or in writing, although providing the relevant facts in writing may assist HDS in considering the matter.

Anonymous concerns will be considered where possible, although anonymity may make investigation and feedback more difficult.

Employees do not need to prove the wrongdoing before raising a genuine concern.

4. How HDS Will Respond

HDS will keep a secure record of the concern, action taken and outcome, sharing information only where necessary. Where contact details are available, the person raising the concern will receive appropriate progress updates and feedback, subject to confidentiality. The manager handling the matter will follow up agreed actions and check for retaliation or ongoing support needs.

HDS will consider concerns promptly, fairly and as confidentially as reasonably practicable.

 Depending on the circumstances, HDS may:

• make initial enquiries;

• carry out an investigation;

• take appropriate corrective or disciplinary action;

• refer the matter to an appropriate external body; and/or

• obtain advice from FSB Legal/HR Advice or another appropriate external HR/legal adviser.

 The person raising the concern will normally be told, where appropriate, how HDS intends to deal with it, although confidential information about other individuals may not be disclosed.

 5. Protection

 HDS will not tolerate retaliation, victimisation or detrimental treatment against anyone because they have made a protected disclosure.

 Employees must not retaliate against someone who raises or supports a whistleblowing concern.

 Any such conduct may be dealt with under the Disciplinary Policy and Procedure.

 Workers who make a protected disclosure may have statutory protection from detriment and, where applicable, dismissal.

 6. External Disclosures

 HDS encourages concerns to be raised internally where appropriate so that they can be addressed promptly.

 However, nothing in this policy prevents a worker from making a protected disclosure to an appropriate prescribed person or regulator where the legal requirements are met.

Workers are not required to report internally first or complete HDS’s internal procedure before making an external disclosure that meets the legal requirements for protection. Protection may also apply to disclosures to a legal adviser when obtaining legal advice, or through other routes permitted by law. Different legal conditions apply depending on the recipient.

No confidentiality clause, agreement or HDS policy prevents a worker from making a protected disclosure.

Employees may obtain independent advice from Acas, Protect, or an appropriate legal adviser. GOV.UK specifically recognises these as sources of further whistleblowing guidance.

7. Deliberately False Allegations

A concern will not result in disciplinary action merely because it is not ultimately substantiated.

Knowingly providing false information or fabricating evidence may be dealt with under the Disciplinary Policy and Procedure. A concern will not be treated as deliberately false merely because it is not substantiated or because the person raising it has a personal disagreement with someone involved.

8. Review

This policy will be reviewed at least annually and sooner where legislation or statutory guidance changes.