Whistleblowing Policy

Al-Waris Foundation is committed to operating lawfully, ethically, transparently and in accordance with its charitable purposes.

People involved with the charity should be able to raise genuine concerns about serious wrongdoing without fear of inappropriate retaliation.

Al-Waris Foundation will:

Whistleblowing must not be suppressed merely because a concern could cause embarrassment or reputational damage to the charity.

This policy provides a framework for raising concerns about suspected serious wrongdoing connected with Al-Waris Foundation.

Its purposes are to:

This policy may be used by:

Other people, including beneficiaries, donors and members of the public, may normally use the Complaints Policy unless the nature of their information makes another reporting route more appropriate.

Whistleblowing generally involves raising information about suspected wrongdoing that affects others or the wider public interest rather than solely a personal grievance.

Concerns may relate to conduct that has:

A person does not need absolute proof before raising a genuine concern.

They should have an honest and reasonable basis for raising it.

Concerns may include suspected:

This list is not exhaustive.

Whistleblowing is different from an ordinary personal complaint.

For example:

However, a personal complaint may also reveal wider wrongdoing.

The charity should consider the substance of the concern rather than rejecting it merely because it was initially submitted through the wrong procedure.

Where information suggests that a child or adult may be at immediate or significant risk of harm, safeguarding procedures must take priority.

The concern should be reported promptly through the relevant safeguarding route.

Whistleblowing procedures must not delay:

See:

Where there is an immediate danger to life or serious safety risk, appropriate emergency services should be contacted without waiting for the internal whistleblowing process.

Internal reporting should follow as soon as reasonably practicable.

A whistleblowing concern should normally be raised with an appropriate authorised person.

Depending on the circumstances, this may be:

The charity should ensure that there is always an alternative route where the concern involves the person who would ordinarily receive it.

Where a concern relates to:

the concern should be raised directly with another unconflicted trustee.

The Chair must not control the investigation into allegations concerning their own conduct.

Where necessary, the unconflicted trustee may seek:

Where a concern concerns another trustee, it should be raised with:

The trustee who is the subject of the concern must not determine the outcome of the investigation.

Where the concern involves:

the person raising the concern may need to approach an appropriate external body.

Depending on the subject matter, this could include:

A concern may normally be raised:

Written reports are preferable for significant matters because they provide a clear record.

However, a concern must not be ignored simply because it was raised verbally.

Where possible, the person raising the concern should provide:

A person should not delay reporting merely because they cannot provide every detail.

Whistleblowers are not expected to conduct their own full investigation.

They should not:

Relevant evidence already legitimately available to the person may be provided with the report.

Anonymous whistleblowing concerns may be considered.

The charity should assess:

Anonymous reporting may make investigation more difficult because follow-up questions cannot easily be asked.

However, credible anonymous safeguarding, fraud or serious-governance concerns must not automatically be dismissed.

The identity of a whistleblower should be protected as far as reasonably practicable.

Information should normally be disclosed only to people who need it for:

Absolute confidentiality cannot be guaranteed.

Disclosure may be necessary where:

Where reasonably possible, the whistleblower should be informed before their identity is disclosed.

Al-Waris Foundation will not tolerate retaliation against a person because they have raised a genuine concern.

Retaliation may include:

A retaliation allegation should itself be investigated.

Certain workers who make qualifying disclosures may have statutory protection under whistleblowing law.

Whether statutory protection applies depends on:

This policy does not attempt to restrict or replace statutory rights.

A person may obtain independent legal advice where they are uncertain about their rights.

Some people involved with Al-Waris Foundation, including volunteers or trustees, may not have the same statutory employment-law whistleblowing protections as qualifying workers.

Al-Waris Foundation nevertheless applies the anti-retaliation principles of this policy to trustees, volunteers and other people within its governance and operational framework.

This is an organisational commitment and does not create employment status where none otherwise exists.

A person will not be penalised merely because a genuinely raised concern turns out to be mistaken.

Whistleblowers are not required to prove wrongdoing before reporting it.

The key distinction is between:

Knowingly making a deliberately false allegation for the purpose of harming another person may result in appropriate action.

However:

do not by themselves establish that an allegation was malicious.

The charity must avoid using allegations of "malice" to discourage legitimate reporting.

When a concern is received, the authorised recipient should assess:

Immediate protective action may be taken before the full investigation begins.

Where contact details are available, Al-Waris Foundation should normally acknowledge a whistleblowing concern within 5 working days.

The acknowledgement should avoid making premature conclusions.

It may explain:

Where an investigation is appropriate, it should be:

The investigator should not have a material conflict of interest.

An external investigator or adviser should be considered where:

A person accused of wrongdoing should normally be treated fairly.

Where appropriate, they should have an opportunity to respond to allegations.

However, disclosure may need to be delayed where necessary to:

An allegation is not proof of misconduct.

Appropriate records should be maintained, which may include:

Access should be restricted.

Where serious wrongdoing is suspected, reasonable steps should be taken to preserve relevant evidence.

This may include:

Records must not be deliberately destroyed, altered or concealed.

While a concern is investigated, temporary measures may be necessary.

These may include:

Interim measures are precautionary and do not necessarily mean misconduct has been established.

Suspected:

must be assessed under the Anti-Fraud, Bribery and Corruption Policy.

The charity should consider:

A safeguarding whistleblower may raise concerns about:

Safeguarding action must not wait for the completion of an internal governance investigation.

Concerns involving:

should also be considered under:

The Information Commissioner's Office may need to be notified where applicable.

Whistleblowing concerns may arise from overseas projects.

Examples include:

Overseas concerns should be investigated proportionately while considering:

Anyone who becomes aware that project evidence may have been:

should report the concern.

Photographs, videos, invoices and beneficiary information must not be knowingly falsified to satisfy donors or internal monitoring requirements.

AI-generated material must not be knowingly presented as genuine evidence of charitable activity.

A concern should be raised if AI-generated or manipulated content is being deliberately represented as:

Legitimate illustrative AI content is distinct from fraudulent project evidence where it is clearly used and represented appropriately.

Concerns should be raised where there is suspected deliberate misrepresentation of:

Fundraising must not knowingly mislead donors.

A person should raise a concern where they reasonably believe restricted donations are being deliberately used for an unrelated purpose without lawful authority.

The concern should distinguish between:

Concealment of a significant conflict of interest may constitute whistleblowing where it creates serious governance or financial risk.

Examples include undisclosed:

There may be circumstances where a concern should be reported outside Al-Waris Foundation.

The appropriate recipient depends on the subject.

Possible external bodies include:

The charity should not require internal reporting first where doing so would be inappropriate, unsafe or contrary to law.

Serious concerns about charity governance or administration may fall within the Charity Commission's regulatory remit.

Examples may include:

Not every disagreement or minor procedural issue requires Charity Commission involvement.

A whistleblowing disclosure may reveal a reportable serious incident.

The charity must assess this separately under the Serious Incident Reporting Policy.

A matter must not be withheld from the Charity Commission merely because an internal investigation is continuing where reporting is otherwise required.

Where information suggests serious criminal conduct, the charity should consider whether law-enforcement involvement is necessary.

Immediate threats to life or safety should be reported through emergency services.

An internal investigation must not obstruct a police investigation.

Where the concern involves serious misuse of personal information or data-protection failures, the charity should assess whether notification or other engagement with the Information Commissioner's Office is required.

Where appropriate and lawful, the person raising the concern should receive an update.

The charity may be able to explain:

The charity may be unable to disclose:

The whistleblower does not automatically have a right to the full investigation report.

Whistleblowing investigations vary significantly in complexity.

Al-Waris Foundation will seek to deal with concerns without unreasonable delay.

Where possible, the whistleblower should receive an indication of progress if the investigation is prolonged.

The need for a thorough and fair investigation takes priority over an artificial deadline.

Possible outcomes include:

More than one outcome may apply.

Where wrongdoing or control failures are identified, Al-Waris Foundation should consider corrective action including:

Where serious misconduct by a trustee is established, the Board should consider appropriate action in accordance with:

This may include considering:

Anyone involved in assessing or investigating a concern must declare relevant conflicts.

A conflicted person should not:

where doing so would compromise independence.

See the Conflict of Interest Policy.

A person considering whistleblowing may seek independent advice.

Depending on their circumstances, sources may include:

The charity will not require someone to waive statutory rights as a condition of raising a concern.

No agreement entered into by Al-Waris Foundation should knowingly be used to prevent a person from making a legally protected disclosure or reporting matters to a competent regulator or law-enforcement authority where the law permits such reporting.

Public or media disclosure may have different legal consequences from disclosure to the charity or an appropriate prescribed person.

Anyone considering public disclosure should consider obtaining independent advice.

This policy does not encourage unnecessary disclosure of:

Whistleblowing records should be retained in accordance with the Records Retention and Disposal Policy.

Retention should reflect:

Records should not be retained indefinitely without justification.

Personal data processed during whistleblowing must be handled in accordance with:

Access should be restricted according to legitimate need.

Information must not be unnecessarily disclosed merely because an allegation has been made.

The Board should receive proportionate information concerning significant whistleblowing matters.

Where possible, reporting should be anonymised.

Board oversight may include:

The Board does not require unnecessary identifiable case details to exercise oversight.

The Board of Trustees retains overall responsibility for ensuring Al-Waris Foundation maintains an effective whistleblowing framework.

Operational responsibility may be delegated.

The Board must ensure there is an alternative reporting route where a concern involves the Chair or another person ordinarily responsible for receiving concerns.

Relevant trustees, volunteers, staff and other representatives should be informed that:

This policy should be read alongside:

This policy will be reviewed:

Version: 2.0 Status: Approved Approved by: Board of Trustees Approval date: 25/08/2026 Next scheduled review: 24/08/2027