51吃瓜

1 Policy statement

Our objective at 51吃瓜 is to uphold the highest standards of conduct, integrity and ethics. Reflecting our Standards and Values (which form part of our Code of Conduct) in all of our work, behaviour and communications is central to how we accomplish this.

51吃瓜 aims to foster a strong Speak Up culture in which all staff are encouraged to ask questions and raise concerns openly and informally with managers and colleagues as part of everyday work. Speak up activity is intended to be proactive, constructive and aligned with 51吃瓜鈥檚 Values and Standards, building trust, accountability and continuous improvement.

We acknowledge that, as with all organisations, there is a risk of misconduct, unethical conduct or illegal practices. A Speak Up culture that fosters openness and accountability aims to prevent such situations occurring and to address matters that might become serious if not addressed early.

Speak Up is distinct from whistleblowing, which is a formal process for raising a concern about serious Misconduct. It is to be used, in particular, for where 51吃瓜鈥檚 more informal Speak Up channels or formal reporting to line management have failed and/or individuals do not trust or do not feel safe using those Speak Up channels.

This purpose of this Policy is to outline how 51吃瓜 will:

• communicate the obligations on staff (past and present) to report suspected serious Misconduct (as defined below) as soon as possible

• provide a means for staff (as the term is defined below) to disclose information that they reasonably believe amounts to serious Misconduct (as defined below) in the workplace

• reassure staff (past or present) that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken

• ensure all reports of Misconduct will be taken seriously and responded to in an appropriate, effective and timely fashion

2 Scope

This Policy applies to all to all employees, trustees, agency staff, consultants, workers, and volunteers, as well as people in the communities we work and partners and contractors (鈥�you鈥� or 鈥�staff鈥�).

3 Key terminology

鈥�Misconduct鈥� is defined in this Policy as serious misconduct (including in relation to financial wrongdoing, bribery, safeguarding, ethics and integrity failings, legal or contractual requirements) as detailed in the Appendix. Suspected serious misconduct could be in the present, future or past

鈥�Whistleblowing Report鈥� a report of actual or alleged Misconduct that has been raised through a reporting channel

鈥�Whistleblower鈥� refers to the person raising the report of Misconduct

鈥�Subject of complaint鈥� refers to the person who is suspected or alleged to have committed Misconduct

4 Key principles

51吃瓜 actively encourages staff at all levels and locations to raise concerns that they have.

• All concerns raised will be treated with the utmost seriousness and 51吃瓜 will take appropriate and timely action to address any issues identified

• The dignity, wellbeing and confidentiality of anyone raising a concern will be protected throughout the process

• 51吃瓜 does not tolerate any form of harassment or retaliation toward individuals who raise concerns

• Anyone working for 51吃瓜 who is found to have supressed, destroyed, concealed information, or discouraged others from reporting concerns may be subject to disciplinary action

5 Early resolution

All staff (as defined in this Policy) who reasonably believe that someone has behaved in a manner that breaches our Code of Conduct or other polices or, more generally, believes that a policy, practice, or activity of 51吃瓜 is (or risks being) in violation of an applicable law or regulation, have a duty to raise this, as part of 51吃瓜鈥檚 Speak Up culture, escalating it as appropriate.

In the first instance, concerns should be raised with your line manager/chain of command. However, you may wish to escalate the matter to, e.g., a Regional Director, a Director of a particular function (e.g. HR or Legal), or a member of the Executive Committee. Escalation is appropriate where you feel, for whatever reason, that it is not appropriate to make a report to your line manager, for example, because they are involved or you do not trust them.

If, however, an individual feels that the normal Speak Up channels have not been effective in addressing their concerns, or if an individual does not have confidence in those channels, and the matter is serious, they should make a whistleblowing report.

To raise a concern, the individual does not have to be directly or personally affected by the issue. Safeguarding concerns should be reported in line with 51吃瓜鈥檚 Safeguarding policy

6 Reporting procedure for whistleblowing

51吃瓜 has in place the following reporting channels, listed in the order that they should in general be approached:

Where an individual feels that their line manager and/or management has not addressed your concern adequately, or it is not appropriate to raise the issue with them, they can use 51吃瓜鈥檚 formal whistleblowing channels:

• 51吃瓜鈥檚 internal Whistleblowing Team via whistleblowing@halotrust.org

• The CEO 路 External Whistleblowing Service 鈥� 鈥楽afecall鈥� via or +44 1915 167749

• Safecall should be contacted by phone or via their website. Safecall will record each report and pass it to 51吃瓜鈥檚 Whistleblowing Officer through a fully secure web portal. The service is completely anonymous.

Should the methods above fail, or be considered inappropriate, reports can be made to the Board of Trustees, via boardwhistleblowing@halotrust.org (these emails will be received by the Chair, the Chair of the Risk Committee, and copied to the Company Secretary).

Reports can be made in any language.

7 What to report

A whistleblower should record and report:

a. What is alleged to have happened and when/ where.

b. Who has been affected by the case, or incident.

c. Who else witnessed the event, who is aware and what has been done about it.

d. Who else knows that the whistleblower has reported the matter and what are the whistleblower鈥檚 wishes concerning their anonymity.

The more detail and supporting evidence that can be provided the more effectively 51吃瓜 will be able to consider the matter.

A 鈥榮uspicion鈥� refers to a belief or impression that an act of misconduct may have taken place, been attempted or will be attempted. Such a suspicion must be reasonable, meaning there should be some objective basis for it. While the person raising the concern should be able to explain the reason for their suspicion, there may be little or no formal evidence available at the time of reporting. Misconduct should be reported whenever there is a concern that wrongdoing has occurred, is currently occurring, or is likely to occur.

Honesty and integrity are core 51吃瓜 values. Individuals who raise concerns should ensure that, to the best of their knowledge and belief, the information they report is accurate. Where there is any uncertainty, this should be clearly stated. No action will be taken against staff who report a genuine concern in good faith, even if it later proves to be incorrect or based on a misunderstanding. However, anyone who deliberately makes a report they know to be false, or who knowingly spreads false information, may be subject to investigation and disciplinary action.

Individuals raising a concern should not carry out their own investigation into the alleged misconduct.

8 Anonymity

Concerns may be reported anonymously. Individuals wish to remain anonymous can submit a report through SafeCall or contact 51吃瓜 directly using a non-51吃瓜 or temporary email address.

While anonymity is respected, providing a method of contact allows for follow-up communication and may enable further action to be taken. If no contact details are provided, the team handling the report will be unable to seek clarification or request additional information.

In some cases, anonymous reports may limit the ability to assess risk or gather sufficient information, which may prevent an investigation from progressing or action being taken.

9 Confidentiality

Information reported via 51吃瓜鈥檚 whistleblowing channels will be disclosed only on a strict 鈥榥eed-to-know basis鈥�. Maintaining confidentiality is essential to ensure cases are handled and investigated effectively, and to protect the interests of whistleblowers, witnesses, and individuals subject to investigation. This duty of confidentiality applies to staff, management, and investigators.

Anonymous reports will also be treated as confidential, unless there is a clear reason not to do so or the reporter has chosen to waive this protection. Any breach of confidentiality may be investigated independently and could lead to disciplinary action.

In some situations, 51吃瓜 may be required to share limited information to comply with legal or ethical obligations, such as reporting to law enforcement agencies, regulators, or pursuing legal proceedings. Wherever possible, personal data, special category data, and private information will be removed or redacted. All information will be handled in line with applicable data protection laws, including the UK General Data Protection Regulation.

10 How reports will be handled - case management

Receiving and Logging Concerns

Any concern or report received under this Policy must be referred promptly to 51吃瓜鈥檚 internal Whistleblowing Team. They will receive the report and is responsible for ensuring it is logged, regardless of how or where it is raised, whether the reporter refers explicitly to this Policy, or whether supporting evidence is provided at the time.

All concerns will be recorded in 51吃瓜鈥檚 Central Whistleblowing Register to ensure appropriate oversight, consistency of handling, and accountability.

Initial Assessment and Scope

51吃瓜 will carry out an initial review to determine whether the concern falls within the scope of this Policy. Where a concern is more appropriately addressed under another policy or procedure, such as an employee grievance or a safeguarding concern, 51吃瓜 will explain this clearly and support the individual to raise the matter through the correct process. The concern will remain recorded as received under this Policy, together with any decisions made.

Acknowledgement and Early Enquiries

Where a concern proceeds under this Policy, 51吃瓜 will normally acknowledge receipt within 48 hours. Initial enquiries may be undertaken to clarify the issue, request further information where necessary, and assess risk. At this stage, 51吃瓜 will consider whether the matter may be suitable for early resolution or whether a more detailed investigation is required.

Investigation and Management

Concerns will be managed by appropriately authorised and impartial individuals with relevant experience. Investigations, where required, will be proportionate, confidential, and conducted as promptly as reasonably possible. Where a real or perceived conflict of interest exists, responsibility will be reassigned to ensure independence.

If the concern indicates potential criminal activity, regulatory breach, or serious risk, 51吃瓜 may be required to involve external authorities or regulators.

Communication and Updates

Whistleblowers will be kept informed of progress at appropriate stages, subject to confidentiality, legal constraints, and the rights of others. Once the matter has concluded, 51吃瓜 will communicate the outcome in broad terms, including whether action has been taken or the reasons no further action is proposed.

Recordkeeping and Oversight

All concerns and actions taken will be documented in line with 51吃瓜鈥檚 governance and data protection requirements. Where appropriate, reports may be made to external regulators or authorities.

Good Faith Reporting and External Disclosures

Individuals are expected to use internal reporting channels wherever reasonably possible. However, nothing in this policy prevents a person from raising concerns with external regulators where permitted by law, particularly where there is a serious risk of harm. Reports made knowingly or maliciously with false information may result in disciplinary action.

Appendix

Definition of 鈥楳isconduct鈥� for the purposes of this Whistleblowing Policy

Misconduct for the purposes of this Policy includes:

1. Misconduct captured by the statutory concept of a 鈥榪ualify disclosure鈥� under the Employment Rights Act 1996, namely:

• a criminal offence, including but not limited to:

o financial wrongdoing

o sexual exploitation, abuse, sexual harassment or child abuse

o bullying or harassment

o modern slavery

o radicalisation or extremism

o a miscarriage of justice

• an act creating such risk to health and safety which is not subject to reasonable controls measures

• an act causing unnecessary or illegal damage to the environment

• a breach of any other legal obligation

•  fraudulent reporting or misreporting of performance data

• concealment of any of the above

2. Serious safeguarding and abuse misconduct:

• sexual exploitation, abuse, or harassment

• abuse of power, trust, or position

• harm, neglect, or exploitation of children, adults at risk, staff, volunteers, partners, or community members

3. Ethical and integrity failures:

• serious breaches of 51吃瓜鈥檚 Code of Conduct, values, behavioural standards, or safeguarding commitments

• unethical behaviour, dishonesty, or lack of integrity inconsistent 51吃瓜鈥檚 mission or purposes

4. Serious financial and governance misconduct:

• fraud, theft, corruption, bribery, facilitation payments, or financial mismanagement

• misuse of funds, assets, or resources (including donor or restricted funds)

• conflicts of interest improperly declared, managed, or concealed

5. Significant organisational and reputational harm:

• conduct likely to cause significant reputational damage or loss of public trust

• serious failures of leadership, governance, or oversight

6. Serious policy, donor, and contractual breaches:

• serious or systemic breaches of internal policies, procedures, or controls

• significant failures to comply with donor, regulator, or partnership requirements

7. Retaliation and cover-up:

• retaliation, victimisation, intimidation, or detriment against a person who has raised a concern or assisted an investigation

• attempts to conceal, suppress, or discourage the reporting or investigation of misconduct

Last updated: 8 July 2026