Policy Number 3
Area of Operations: Health & Safety
Date implemented November 2020
Date last reviewed March 2022
1.1 Stryx operates within legal requirements and regulations and expects all employees to co-operate in this by adhering to all laws, regulations, policies and procedures. Any employee, studio holder or volunteer becoming aware of another employee, studio holder or volunteer acting inappropriately is obliged and encouraged to report this activity.
1.2 Stryx is committed to the values of accountability, but the determined perpetrator may find a way round systems and procedures. It is therefore necessary for all managers and employees, studio holders and volunteers to be aware of what is required in the event of suspicions. This document sets out the procedure for employees who wish to notify any suspicions and how Stryx should respond.
• To encourage employees, studio holders and volunteers to feel confident in raising serious concerns, to question and act upon their concerns about practice.
• To provide them with a method of raising concerns and receive feedback on how this is being followed up.
• To ensure employees, studio holders and volunteers receive a response to their concerns and they are aware of how to pursue them if they are not satisfied.
• To reassure employees, studio holders and volunteers that they will be protected from possible reprisals or victimisation if they have reasonable belief that they have made any disclosure in good faith.
3.1 Throughout this policy, the term ‘whistleblower’ denotes the person raising the concern or making the complaint. It is not meant in a pejorative sense and is entirely consistent with the terminology used by Lord Nolan as recommended in the Second Report of the Committee on Standards in Public Life: Local Spending Bodies published in May 1996.
4.1 This policy applies to all employees and studio holders and applies equally to those designated as casual, temporary, agency authorised volunteers or work experience, advisors and those contractors working for Stryx on Stryx premises, for example artists, agency staff, builders, drivers.
4.2 It also covers suppliers and those providing services under a contract with Stryx in their own premises.
4.3 The Whistle Blowing Policy is intended to cover major concerns that fall outside the scope of other procedures. These include:
- financial malpractice or fraud
- inappropriate use of Stryx assets or funds
- decision-making for personal gain
- any criminal activity
- disclosures related to miscarriages of justice
- failure to comply with a legal obligation
- abuse of position
- improper conduct or unethical behaviour
- dangerous procedures or practice risking Health and Safety, including risks to the public as well as other employees, studio holders and volunteers
- serious breaches of Stryx procedures which may advantage a particular party (for example tampering with tender documentation, failure to register a personal interest)
- other unethical conduct
- attempts to conceal any of the above
5 Maintaining Good Practice
5.1 Stryx is committed to the highest standards of openness, honesty and accountability. In line with that commitment, we encourage employees, studio holders and volunteers, and others that we deal with, who have serious concerns about any aspect of Stryx work to come forward and voice those concerns. It is recognised that certain cases will have to proceed on a confidential basis.
5.2 Expected standards of conduct and practice derive from a variety of sources including:
• Job descriptions
• Policies, Procedures and Guidelines
• Professional standards
• Legal requirements and guidelines
• Inspection standards and reports
• Codes of Conduct
5.3 The above list is not exhaustive, but indicates the framework within which Stryx operates. Employees, studio holders and volunteers should ensure that they are aware of the standards expected of them. If they are in any doubt they should discuss this with Stryx Directors..
5.4 The system for maintaining good standards is founded on proper induction, supervision and appraisal, team meetings and briefing sessions, training and development and, where necessary, the positive use of the Capability and Disciplinary Procedures
5.5 Stryx recognises that the decision to report a concern can be a difficult one to make. If what employees, studio holders or volunteers are saying is true, they should have nothing to fear because they will be doing their duty to Stryx and those who are providing a service.
5.6 Stryx will not tolerate any form of harassment or victimisation and will take appropriate action to protect employees when they raise a concern in good faith.
5.7 Any investigation into allegations of potential malpractice will not influence or be influenced by any disciplinary or redundancy procedures that already affect them.
6 How to Raise a Concern
6.1 When an employee, studio holder or volunteer considers that they have encountered a possible case of malpractice they will need to identify the issues carefully. An employee must be clear about the standards against which they are judging practice:
• Is it illegal?
• Does it contravene professional codes of practice?
• Is it against government guidelines?
• Is it against LA guidelines?
• Is it about one individual’s behaviour or is it about general working practices?
• Does it contradict what the employee has been taught?
• Has the employee witnessed the incident?
• Did anyone else witness the incident at the same time?
6.2 With whom an employee should raise concerns, depends upon on the seriousness and sensitivity of the issue involved and who is suspected of the malpractice. Once an employee is certain that malpractice exists the following action should be considered:
• Concerns may be raised verbally or in writing. Employees who wish to make a written report should give the background and history of the concern and the reason why they are particularly concerned about the situation. The earlier concerns are expressed the easier it is to take action
• If the employee, studio holder or volunteer wishes he or she may ask for a private confidential meeting with the person to whom he or she wishes to make the complaint
• An employee, studio holder or volunteer may take another person with them as a witness or for support
• The employee, studio holder or volunteer should take to the meeting – if possible - dated and signed written supporting statements from anyone who can confirm the allegations.
• When making the complaint verbally, the employee, studio holder or volunteer should write down any relevant information and date it. Keep copies of all correspondence and relevant information.
• The employee, studio holder or volunteer should ask the person to whom he or she is making the complaint what the next steps will be and if anything more is expected of them.
• Ask to be informed of the outcome of the investigation into the complaint.
6.3 Although employees, studio holders or volunteers are not expected to prove beyond doubt the truth of an allegation, they will need to demonstrate to the person contacted that there are reasonable grounds for their concern.
6.4 An employee, studio holder or volunteer may wish to consider discussing their concern with a colleague first and they may find it easier to raise the matter if there are two people who have had the same experience or concerns.
6.5 Employees, studio holders or volunteers may ask their trade union or professional association representative to advise them, or be present during any meetings or interviews in connection with the concerns they have raised.
6.6 Employees, studio holders or volunteers will not be victimised, disciplined or disadvantaged in any way for raising genuine concerns. All employees have legal protection under the Public Interest Disclosure Act 1998. This Act protects employees from victimisation by their employer as a result of raising genuine concerns both inside and outside their organisation. However, this does not apply where allegations are found to be malicious or deliberately false. Such behaviour will be dealt with under the Disciplinary Procedure.
6.7 Stryx has designated a number of individuals to specifically deal with such matters and the whistleblower is invited to decide which of those individuals would be the most appropriate person to deal with the matter.
Position Name Contact Details
Karolina Korupczynska Director - email@example.com
Anna Domejko Director - firstname.lastname@example.org