- Purpose
Clever Centre Ltd is committed to conducting its business with honesty, integrity, and accountability. This Whistleblowing Policy is designed to prevent malpractice within the organisation, its employees, contractors, associates, and partners by enabling individuals to raise concerns in a safe and responsible way.
The policy ensures that all staff and stakeholders can report suspected wrongdoing without fear of victimisation, retaliation, or disadvantage.
- Scope
This policy applies to:
- All employees of Clever Centre Ltd (permanent, temporary, and agency staff)
- Contractors, consultants, and associates working on behalf of Clever Centre Ltd
- Third parties and partners engaged with the organisation
Concerns may relate to any aspect of Clever Centre Ltd’s operations, including work with young people, vulnerable adults, and businesses.
- Definition of Whistleblowing
Whistleblowing occurs when a person reports suspected wrongdoing or malpractice within an organisation. This may include, but is not limited to:
- Criminal activity (e.g., fraud, theft, corruption, bribery, or offences under the Bribery Act 2010)
- Failure to comply with legal or regulatory obligations
- Endangering the health or safety of an individual, particularly young people and vulnerable adults
- Environmental damage
- Deliberate concealment of wrongdoing
- Misuse of company funds or assets
- Breach of company policies or procedures
- Our Commitment
Clever Centre Ltd encourages a culture of openness and accountability. We believe that by knowing about potential malpractice at an early stage, we can:
- Take swift and effective action
- Protect our staff and stakeholders
- Safeguard the reputation and integrity of the organisation
- Prevent harm to vulnerable groups
- Stop fraud, corruption, and other misconduct before it escalates
- How to Raise a Concern
If you have a genuine concern about malpractice, you should raise it as soon as possible. Concerns can be reported in the following ways:
- To your line manager or supervisor
- To a member of the Senior Leadership Team
- Directly to the Whistleblowing Officer (confidential contact details will be provided internally)
Concerns may be raised verbally or in writing. Whistleblowers are encouraged to provide as much detail as possible, including dates, individuals involved, and any supporting evidence.
- Confidentiality and Protection
- All whistleblowing disclosures will be treated in strict confidence.
- Whistleblowers will be protected from harassment, victimisation, or dismissal as a result of raising a concern in good faith.
- Anonymous disclosures will be considered, although they may limit the ability to investigate effectively.
- Investigation and Outcome
- All concerns raised will be assessed promptly and, where appropriate, investigated.
- Investigations will be conducted fairly, thoroughly, and without bias.
- Where wrongdoing is identified, corrective action will be taken, which may include disciplinary action, reporting to external authorities, or improvements to internal controls.
- Whistleblowers will be informed, where possible, of the outcome, subject to confidentiality and data protection requirements.
- Malicious or Vexatious Allegations
Deliberately false or malicious allegations will not be tolerated and may result in disciplinary action. However, no action will be taken against anyone who raises a concern in good faith, even if it is later found to be unfounded. - Review of Policy
This policy will be reviewed annually to ensure it remains fit for purpose, complies with relevant legislation, and supports Clever Centre Ltd’s commitment to integrity and accountability.
Updated: September 2025