Public Interest Disclosure (Whistleblowing)

The University of Sheffield is committed to the highest standards of ethics, transparency, probity and accountability. It seeks to conduct its affairs in a responsible manner taking into account the requirements of its funding bodies for the proper use of public funds and of the standards required in public life.

The aim of this policy, in line with the Public Interest Disclosure Act (PIDA) 1998, (as amended by the Enterprise & Regulatory Reform Act 2013) is to enable and encourage individuals to raise matters of concern that are in the public interest (often referred to as whistleblowing), such as: malpractice, impropriety or wrongdoing, at a high level within the University, without fear of reprisal, so that they may be investigated and where appropriate acted upon.

Such disclosures may be about the alleged wrongful conduct of the University, or about the conduct of a fellow employee, service user, or any third party. The individual making a disclosure is usually not directly, personally affected by the danger or illegality, although they may be.

Scope:

This policy, for making an internal disclosure, applies to all: employees and workers, including for example: those with honorary contracts; apprentices; interns; atypical workers; and agency workers. As well as students, and members of University bodies (e.g. University Committees), though not covered by the PIDA. (Please see paragraph 2.5 of the procedure in relation to the protections afforded under the PIDA).

Key Principles:

1. Everyone should be aware of the importance of preventing and eliminating wrongdoing at work. All members of the University should be watchful for illegal or unethical conduct and are encouraged to report anything of that nature that they become aware of.

2. All concerns raised by an individual will be treated fairly and properly.

3. Where there are grounds for proceeding, any matter raised under this policy will be investigated thoroughly, promptly, and confidentially.

4. Individuals making a protected ‘qualified disclosure’ in line with this Policy will not be penalised for doing so. (See Section 2 of the procedure for the definition of a “Qualifying Disclosure”).

5. All complaints of victimisation of an individual for raising a qualified disclosure will be treated seriously and may provide grounds for disciplinary or other appropriate action.

6. If misconduct is discovered as a result of any investigation under this procedure the University’s disciplinary procedure will apply, in addition to any appropriate external measures.

7. Maliciously making a false allegation is a disciplinary offence.

This policy cannot be used by individuals to challenge financial and business decisions properly taken by the University of Sheffield or seek reconsideration of any matter already addressed under other internal procedures for example complaints, disciplinary and grievance procedures.

How the University supports the ability to address concerns

This policy is supported by a detailed Public Interest Disclosure (Whistleblowing) Procedure.

It is recognised and expected that the majority of concerns will be raised openly with managers (or for students their Head of Department and/or Supervisor) as part of day to day practice and this policy does not seek to undermine this.

As any qualified disclosure needs to be in the ‘public interest’ the policy cannot be used to raise purely private matters (e.g. in relation to a member’s individual contract) or in relation to a grievance which seeks to redress a wrong done to oneself. There are however a number of other appropriate policies and procedures available to staff and students through which individuals may raise and attempt to resolve such specific concerns, e.g. relating to a grievance, disciplinary, research misconduct, or harassment matters.

The University also has in place a set of Financial Regulations covering a wide range of areas including the delegation of financial authorities, purchasing, fraud, and general systems of audit and internal financial control. In the case of concerns regarding financial irregularities/concerns these may be addressed under the University’s Fraud Response Plan. Further information in relation to this is provided within the Public Interest Disclosure (Whistleblowing) Procedure, and the Financial Regulations.

Staff with concerns in relation to student conduct may wish to seek advice in relation to how this may be addressed from the Student Conduct and Appeals Office within Student Service.

Approved on behalf of Council by Human Resources Committee 24th October 2013.

Document Control
Last Update: 11/16
Date of Next Review: 11/18