Whistleblowing

Policy 

Mosaic LGBT+ Young Persons’ Trust, Charity Number 1166676

 

Policy Owner: FL Committee

Review Cycle: 48 Months

Next Review Date: March 2030 (Updated and re-approved March 2026)

 

M Mindful

O Open

S Safe

A Agile

I Inclusive

C Community

""

Whistleblowing Contacts:

 

Ken Batty – Chair of Trustees: Ken.Batty@mosaictrust.org.uk

Madison Pollard-Shore – Vice Chair: madison.pollard@mosaictrust.org.uk

Gemma Benton  – Designated Safeguarding Trustee: gemma.benton@mosaictrust.org.uk

Jo Wittams – Finance Committee Chair: jo.wittams@mosaictrust.org.uk

 

1. Scope

 

This Policy applies to Mosaic LGBT+ Young Persons’ Trust (“Mosaic”, “the Trust”) staff (employees and workers), volunteers, mentors, Trustees, sessional workers and contractors. Mosaic also welcomes concerns raised by young persons and their carers, and members of the public; however, legal whistleblowing protections under the Public Interest Disclosure Act 1998 apply specifically to workers (including employees).

 

2. Opening Statement and Commitment

 

Mosaic recognises that trust, openness and accountability are central to our work with young LGBT+ persons. We want everyone connected to Mosaic to feel confident speaking up if something feels unsafe, unlawful, improper, or seriously concerning.

 

We actively encourage disclosures to Mosaic at the earliest opportunity. We would always rather hear about a concern and address it promptly than risk harm to young persons, colleagues, volunteers, the wider community, or to Mosaic’s reputation and legal compliance.

 

3. Definitions: 

 

What is Whistleblowing, and how does it differ from a Grievance:

 

The legal definition of whistleblowing is a disclosure of information that, in the reasonable belief of the whistleblower, is made in the public interest and tends to show that one or more of the following has happened, is happening, or is likely to happen:

 

  • a criminal offence;
  • a failure to comply with a legal obligation;
  • a miscarriage of justice;
  • a danger to the health or safety of any individual;
  • damage to the environment; or
  • the deliberate concealment of any of the above.

 

Whistleblowers (workers) are protected by law under the Public Interest Disclosure Act 1998 (PIDA). Under this law, workers must not be dismissed or subjected to detriment for raising a qualifying protected disclosure.

 

Whistleblowing is different from a grievance. A grievance is usually a personal workplace complaint about an individual’s employment (for example, pay, duties, relationships at work, or how they have been treated). Whistleblowing is about raising a public-interest concern about wrongdoing, risk, or misconduct that affects others or the organisation.

 

Sometimes a matter can be both a grievance and a whistleblowing disclosure. Mosaic will handle such cases fairly and may run processes in parallel or sequence them, as appropriate.

 

Useful guidance is available from ACAS:

https://www.acas.org.uk/grievances

https://www.acas.org.uk/whistleblowing-at-work

 

4. No Detriment, Victimisation or Retaliation

 

Mosaic will not tolerate any form of victimisation, retaliation, intimidation, harassment or other detriment towards a person because they raised a whistleblowing concern (or assisted with an investigation) in line with this policy. This includes direct and indirect detriment.

 

Any person who believes they have suffered detriment for raising a concern should report it immediately to the Chair of Trustees or the Vice Chair. Allegations of retaliation will be treated seriously and may result in disciplinary action.

 

5. How Whistleblowing Can Affect Employees and Managers

 

Raising a concern can be stressful, and Mosaic recognises it may affect wellbeing. Mosaic will aim to handle disclosures sensitively, fairly and promptly.

 

For managers and Trustees, whistleblowing matters can involve difficult judgments and require confidentiality and impartiality. Managers and Trustees must avoid any action or language that could be perceived as discouraging disclosures or causing detriment to the whistleblower or to anyone involved.

 

Where concerns relate to safeguarding, Mosaic’s safeguarding duties take priority, and information will be shared in line with the Safeguarding Policy and Confidentiality & Information Sharing approach.

 

6. Who to Contact (Points of Contact for Whistleblowing Queries)

 

Mosaic encourages disclosures to be raised internally in the first instance, where appropriate. Concerns may be raised to any Trustee, but the following contacts are the most relevant:

 

Ken Batty – Chair of Trustees: Ken.Batty@mosaictrust.org.uk

Madison Pollard-Shore – Vice Chair: madison.pollard@mosaictrust.org.uk

Gemma Benton  – Designated Safeguarding Trustee: gemma.benton@mosaictrust.org.uk

Jo Wittams – Finance Committee Chair: jo.wittams@mosaictrust.org.uk

 

If the concern relates to the Chair of Trustees, disclosures should be made to the Vice Chair. If the concern relates to the Vice Chair, disclosures should be made to the Chair or another Trustee.

 

External reporting: In some circumstances, it may be appropriate to raise concerns with an external regulator (a “prescribed person or body”), the Charity Commission, or other relevant authorities. The UK Government list of prescribed persons is available here:

https://www.gov.uk/government/publications/blowing-the-whistle-list-of-prescribed-people-and-bodies--2/whistleblowing-list-of-prescribed-people-and-bodies

 

7. How to Raise a Whistleblowing Disclosure

 

Concerns can be raised verbally or in writing. Where possible, Mosaic encourages disclosures in writing (including by email) to help ensure clarity and an accurate record.

 

A disclosure should include, as far as possible:

  • what happened (or what you believe is happening);
  • when and where it happened;
  • who is involved;
  • any evidence or supporting information you have; and
  • whether you believe anyone is at immediate risk (particularly safeguarding).

 

Anonymous reporting: Mosaic offers an option to submit concerns anonymously via a Google Form : http://tiny.cc/mosaiccomplaints. Responses to this form will be sent to Lukasz Konieczka, Executive Director and Madison Pollard, Vice-Chair. 

 

Mosaic will consider anonymous disclosures and investigate based on the information provided, although anonymity may limit the ability to gather evidence and provide feedback.

 

8. Anonymity and Confidentiality

 

Wherever possible, Mosaic encourages whistleblowers to share their identity so that Mosaic can fully investigate the concern and provide appropriate support.

 

However, Mosaic recognises that individuals may fear repercussions, particularly in small charities.

 

Mosaic will respect requests for anonymity and confidentiality to the extent reasonably practicable. However, Mosaic cannot guarantee anonymity or complete confidentiality if doing so would prevent a fair investigation, if disclosure is required by law, or if safeguarding actions require information-sharing.

 

It is unlawful to prevent someone from whistleblowing by using confidentiality provisions. For example, Mosaic will not use employment contracts, volunteer agreements or settlement agreements to stop lawful protected disclosures.

 

9. Support for Whistleblowers

 

Mosaic recognises that raising a concern can be difficult. We are committed to supporting whistleblowers throughout the process. Support may include: wellbeing check-ins; an internal support contact (where appropriate); adjustments to working arrangements where feasible; and signposting to external specialist support.

 

External support includes Protect and WhistleblowersUK. Whistleblowing support is also available at www.wbuk.org.

 

ACAS guidance on responding to disclosures: https://www.acas.org.uk/whistleblowing-at-work/responding-to-a-whistleblowing-disclosure

 

10. How Mosaic Will Investigate and Respond

 

Mosaic will handle disclosures promptly, fairly and proportionately. The Trust will not dismiss concerns due to uncertainty at the outset about whether the matter technically constitutes whistleblowing; Mosaic will consider the substance and risk.

 

Acknowledgement and updates: Mosaic will aim to acknowledge receipt within 5 working days (where contact details are provided) and will provide reasonable updates where appropriate. The timeframe for investigation will depend on complexity; Mosaic will seek to agree a realistic timeframe with the whistleblower where possible.

 

Assignment: The Trustee receiving the disclosure will discuss it with the Chair of Trustees, who will assign an investigator. Where the Chair is the subject of the disclosure, the matter will be passed to the Vice Chair for allocation.

 

Impartiality: Wherever possible, investigations will be conducted by someone independent of the issues raised and without a conflict of interest. Mosaic may obtain external support where needed.

 

The investigator will:

 

  • consider whether the disclosure may constitute whistleblowing, a grievance, a safeguarding concern, or a combination;
  • gather relevant evidence (including speaking with the whistleblower where possible and others as necessary);
  • keep accurate records and handle information on a strict need-to-know basis;
  • consider appropriate remedial action, including referral to safeguarding procedures, disciplinary action, policy change, training, or reporting to regulators; and
  • agree on what feedback can be provided to the whistleblower, taking account of confidentiality and data protection obligations.

 

Mosaic will confirm the outcome in writing where appropriate (and where contact details are provided), including what action has been taken or is planned, subject to confidentiality and data protection constraints.

 

11. Knowingly False or Malicious Allegations

 

Mosaic encourages concerns raised in good faith and based on a reasonable belief. Under the whistleblowing law, there is no requirement that a disclosure be made “in good faith” to qualify for protection; however, if Mosaic concludes that a disclosure is knowingly false or malicious, It may take appropriate action. For workers, this may include disciplinary action. This does not affect Mosaic’s commitment to investigate concerns and manage risk appropriately.

 

12. Record Keeping, GDPR and Data Protection

 

Mosaic will keep a secure record of whistleblowing disclosures, investigations, decisions and actions taken. Records will be stored securely and accessed only by authorised individuals on a need-to-know basis.

 

Mosaic processes personal data in accordance with the Data Protection Act 2018 and UK GDPR. Information will be retained only as long as necessary for safeguarding, legal, regulatory, and governance purposes, and will be disposed of securely. Where a personal data breach is suspected, Mosaic will follow its data breach procedure and, where required, report to the Information Commissioner’s Office (ICO).

 

13. Relationship to Other Policies and Procedures

 

This Whistleblowing Policy should be read alongside, and may operate in parallel with, the Trust’s Safeguarding Policy, Complaints Procedures, Disciplinary and Grievance Policy (per ACAS guidelines), Equality/EDI policy, Health and Safety Policy, and Confidentiality & Information Sharing and Data Protection policies.

 

If a Trustee is informed of a whistleblowing allegation, the Trustee should consider whether the matter intersects with another policy area (for example, safeguarding) and ensure the appropriate lead is involved without delay.