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Whistle-blowing Policy

1. Toybox Policy

Toybox believes that all those involved with the organisation should conduct themselves with honesty and integrity. This includes, staff, board members, partners, volunteers and consultants. And as such, any activity not in accordance with the organisation’s values should be reported.

If anyone becomes aware of any unethical behaviour, they should speak with their line manager. However, if such an action were to cause a potential conflict of interest or risk to their own person, Toybox has this Whistle-blowing Policy in place.

All employees are encouraged to raise their concerns about any unacceptable behaviour and wrong-doing in the conduct of our business; this could be financial irregularities, inappropriate behaviour, or any other issue that relates to the organisation’s Core Value and ethical behaviours.

2. Potential Issues

Whistle-blowing covers any wrongdoing or negligence, which must be in the public interest and may involve one or more of the following:

  1. An offence or breach of regulations or laws, i.e. fraud, bribery, corruption, the use of favoured contractors to provide them with rewards, a criminal act, failure to comply with a legal obligation, questionable accounting or auditing.
  2. Inappropriate or unethical conduct.
  3. Possible malpractice, i.e. theft or misuse of funds, assets or public money.
  4. Failure to comply with legal obligations, tax or customs infringements.
  5. Safeguarding issues.
  6. Danger to health and safety, i.e. known failures of any system used in the maintenance of a building or equipment which would place staff and/or members of the public in danger.
  7. Damage to the environment, i.e. careless disposal of rubbish or chemical products.
  8. Any attempt to cover up an act of negligence or ignore it, failure to deal with the issue, a lack of concern, or involvement with other individuals in the negligent act.

This list is not exhaustive and the negligent act could be occurring now, has occurred in the past or there is a concern that something may occur in the future.

3. Procedure

If anyone is concerned that a person involved on Toybox business (a Toybox employee, partner, consultant, volunteer or trustee) is engaged in any of these activities, the issue must be raised formally and without delay with the person who is responsible for that role (normally the line manager) or with the director if the problem relates to the line manager. If the director is the subject of the complaint, the complaint should be raised with the CEO and if the CEO is the subject of the complaint, the issue should be raised with the Chair of the Board.

Once a complaint has been received the following process will be followed:

  1. The complainant will be notified that a complaint has been received, they will also be informed as to who will investigate the complaint and how long this process will take
  2. The person against whom the complaint has been made will also be notified and advised who will be investigating the complaint and how long this process will take
  3. Post the investigation a written summary will be given to both parties however, if the individual making the report has a personal interest, this should be declared from the outset. However, it should be noted that the person dealing with the Whistle-blowing report may not be able to inform the complainant of the precise measures to be taken, since this would infringe a duty of confidentiality that must be upheld. The process will be as open as possible, subject to these restrictions.

4. Guarantees

If an employee raises a genuine issue, they shall not run the risk of reprisals as a result. Toybox shall not tolerate the bullying or abuse of anyone who raises a genuine issue. Toybox recognises that such a problem may need to be raised in confidence and the employee may request that their identity be protected and confidentiality maintained. However, if the problem cannot be resolved without revealing the identity of the employee, for example because their evidence is needed in court, Toybox will discuss this with employee to see if the process can continue. The name of the employee will not be disclosed without their consent. Anonymous complaints are much more challenging to deal with and investigate, and make protection of the complainant’s position and any provision of feedback to them more difficult.

Just as Toybox will strive to protect those who raise problems in good faith, so they will aim to protect those against whom complaints are made which turn out to be without sufficient foundation. A problem raised in good faith may have no basis in reality and both parties will be protected equally.

However, Toybox will take disciplinary measures against any employee who, with malicious intent, raises an issue that they know to be false or for which there are no reasonable grounds for believing the information supplied is accurate, or who is found to be bullying another employee or volunteer for using the procedure, or dissuading them from raising genuine problems under said procedure.

5. Connection with the Grievance Policy and Procedures

The Whistle-blowing Policy relates to the disclosure of information, namely, whether it will be in the public interest to do so. It is not meant to replace the complaints procedure which is in place so that any member of staff can raise a personal problem or express dissatisfaction over a management decision.

6. Contacts

Internal Contact include:

The contacts details for the Toybox CEO are: [email protected]

The contact details for the Toybox Chair of the Board are: [email protected]

If an employee has exhausted all internal procedures but does not consider the response from their own management team, or the Toybox Board to be reasonable, they can report the matter in writing to one of various external legal institutions.

  1. Charity Commission whistle-blower advice line – 08000 557214
  2. The registered charity Public Concern at Work (0207 404 6609) has more information on which of these would be most appropriate for special cases.
  3. The Charity Fraud division of Crimestoppers- 08000 232 101 to report any suspicious activity regarding fraud within Toybox.

7. Comments for Partners Partners are recommended to follow their own Whistle-blowing Policy and procedures. However, if the issue relates to a Toybox funded project and they feel that the issue is still not sufficiently resolved they can contact the Toybox CEO (via the contact information above). This is to be seen as a final option and should not replace a partner’s complaints procedure or be a way for a member of staff to express dissatisfaction over a management decision.