Care Clarity Support & Advocacy

Whistleblowing Policy

Whistleblowing Policy

Organisation: Care Clarity Support & Advocacy Ltd
Reference: CC-POL-WHISTLE-001
Issue date: 02 May 2026
Version: Status: Live policy

This Raising Concerns, Freedom to Speak Up and Whistleblowing policy and procedure details the process in use at Care Clarity Support & Advocacy Ltd. It has been reviewed with Section updated to explain governance roles. For these changes to reflect in the policy, the system details questionnaire will need to be updated. The references have also been checked and Further Reading added.

  • The Care Act 2014
  • Employment rights Act 1996
  • Public Interest Disclosure Act 1998
  • The Health and Social Care Act 2008 (Regulated Activities) (Amendment) Regulations
  • The criminal Justice and Courts Act 2015
  • The Enterprise and Regulatory Reform Act 2013
  • Employment rights Act 2025
  • Author: Government, (2025), Employment rights Act 2025

https://www.legislation.gov.uk/ukpga/2025/36/contents

  • Author: The Care Quality Commission (CQC), (2025), Regulation 20: Duty of Candour

Available from: https://www.cqc.org.uk/guidance-providers/all-services/ regulation-20-duty-candour

  • Author: Nursing and Midwifery Council, (2024), Whistleblowing to the NMC

Available from: https://www.nmc.org.uk/ guidance-for-nurses-and-midwives/whistleblowing/

  • Author: The Care Quality Commission (CQC), (2023), Report a Concern if you are a

Member of Staff Available from: https://www.cqc.org.uk/ concern/report-concern-if-you-are-member-staff

  • Author: NHS Business Services Authority, (2023), Freedom to Speak Up – Raising

Concerns (Whistleblowing) Available from: https://www.nhsbsa.nhs.uk/ policies/freedom-speak-raising-concerns- whistleblowing#:~:text=You%20can%20raise%20a%20concern,unsafe%20working%20conditio

The company aims to

*Offer skilled care to enable people supported by us to achieve their optimum state of health and well-being. *Treat all people supported by us and all people who work here with respect at all times. *Uphold the human and citizenship rights of all who work and visit here and of all Clients. *Support individual choice and personal decision-making as the right of all Clients. *Respect and encourage the right of independence of all Clients. *Recognise the individual uniqueness of Clients, staff and visitors, and treat them with dignity and respect at all times. *Respect individual requirement for privacy at all times and treat all information relating to individuals in a confidential manner. *Recognise the individual need for personal fulfilment and offer individualised programmes of meaningful activity to satisfy that need of Clients and staff. This policy ensures that the duty of candour is upheld, promoting transparency and openness in all aspects of care and support, especially when things go wrong. Clients and their families are informed of any incidents affecting their care and support, and appropriate actions are taken to rectify and learn from such events. To ensure that all staff working at Care Clarity Support & Advocacy Ltd understand the importance of raising a concern, sometimes also referred to as ‘speaking up’ or ‘whistleblowing’. This policy covers all employees, ocers, consultants, contractors, volunteers, interns, casual workers and agency workers. This policy does not form part of any employee’s contract of employment and Care Clarity Support & Advocacy Ltd may amend it at any time.
The purpose of this policy is to

  • Encourage staff to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected
  • To provide staff with guidance as to how to raise those concerns
  • To reassure staff that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken This policy and procedure does not apply if a member of the workforce is aggrieved about their personal position. They must use the Grievances Policy and Procedure. To support Care Clarity Support & Advocacy Ltd in meeting the following Quality Statements:

Relevant Legislation

  • The Care Act 2014
  • Employment rights Act 1996
  • Public Interest Disclosure Act 1998
  • The Health and Social Care Act 2008 (Regulated Activities) (Amendment) Regulations
  • The criminal Justice and Courts Act 2015
  • The Enterprise and Regulatory Reform Act 2013
  • Employment rights Act 2025

Roles Affected

  • all Staff
  • NHS staff
  • Persons working on training courses
  • Temporary Agency Staff

People Affected

  • Clients

Stakeholders Affected

  • Commissioners
  • Local Authority
  • Care Quality Commission

all staff have a duty to ensure standards of quality care by raising concerns regarding wrongdoing or malpractice. This policy will provide the means of ensuring that staff can confidentially raise genuine concerns of malpractice and/or misconduct through appropriate means at the earliest point without fear of reprisal.

Where required, Care Clarity Support & Advocacy Ltd will be registered with the CQC for regulated activities, service types and service user bands as defined in the CQC Statement of Purpose. This will ensure that Care Clarity Support & Advocacy Ltd provides services that are safe, effective, caring, responsive and well-led in line with the CQC’s published quality statements, regulatory framework and associated best practice guidance. Domiciliary care service, personal Care The Registered Manager, and nominated individual of Care Clarity Support & Advocacy Ltd, have overall management responsibility for this policy and procedure and for ensuring the proper governance of Care Clarity Support & Advocacy Ltd. The Registered Manager role is held by: Linda Akli The nominated individual role is held by: Linda Akli

  • The organisation is managed and governed appropriately
  • Suitable systems are in place to effectively assess, monitor and improve the service
  • Records are completed accurately and stored safely and securely
  • That the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act

2018 are met

  • Care and support delivered is consistent, safe and of high-quality

Care Clarity Support & Advocacy Ltd is commifitted to a high standard of care, to honesty, openness and decency in all its activities and in line with the requirements of duty of candour. It is recognised that Client safety must come first at all times and, whilst it can be difficult for staff to raise concerns about the practice of others, including managers, the implications of not raising those concerns are potentially very serious for Care Clarity Support & Advocacy Ltd, its employees and most importantly for those receiving its services.

Care Clarity Support & Advocacy Ltd encourages a free and open culture in its dealings with its employees and all people with whom it engages in business and legal relations. In particular, Care Clarity Support & Advocacy Ltd recognises that effective and honest communication is essential if any wrongdoing or malpractice is to be effectively dealt with and the organisation’s success ensured. Care Clarity Support & Advocacy Ltd recognises that staff members are likely to be the first to realise that there may be something seriously wrong within the organisation but may feel that speaking up would be disloyal to colleagues or their employer who may, under certain circumstances, face criminal charges. They may also fear harassment or victimisation and fear for a loss of job or a reduction in work hours. Care Clarity Support & Advocacy Ltd will not tolerate the ill treatment, including any bullying or harassment, of anyone raising a concern. It will ensure that any individual who raises a concern, can do so confidentially in line with the Public Interest Disclosure Act 1998 (PIDA). Care Clarity Support & Advocacy Ltd will ensure that any individual who raises a genuine concern under this policy will not be at risk of termination of their employment or suffer any form of reprisal which includes, but is not limited to, loss or reduction of hours or changes to regular working patterns because of it. Care Clarity Support & Advocacy Ltd will ensure that it follows not only the law on whistleblowing, but also best practice and guidance from the NHS and regulatory bodies including the Care Quality Commission. Care Clarity Support & Advocacy Ltd understands that some Clients may take in and retain information in different ways. To support full understanding and engagement, this policy is available in accessible formats. The accessibility tools tool has various ways of making this policy accessible by providing this policy in:

  • Audio
  • Large print
  • Multiple languages

This policy can also be made available in

  • Easy-read versions
  • Simple-policy view to reduce navigation and complexity

These options are in place to help Clients to understand and engage with this policy more easily.

all staff have a duty to raise concerns regarding inappropriate behaviour, unlawful conduct, poor practice or behaviour to ensure standards of quality care. Staff at Care Clarity Support & Advocacy Ltd are encouraged to speak up about anything that gets in the way of doing a great job. Care Clarity Support & Advocacy Ltd will have a Freedom to Speak Up Guardian who supports staff to speak up when they feel that they are unable to in other ways. The Freedom to Speak Up Guardian for Care Clarity Support & Advocacy Ltd is Linda Akli.

Their contact details are

0333 335 5869 Staff at Care Clarity Support & Advocacy Ltd can report certain types of wrongdoing, usually something seen at work – though not always. The wrongdoing disclosed must be in the public interest. This means it must affect others, for example the general public.

This procedure is intended to provide a safeguard to enable members of staff to raise concerns about one or more of the following that has occurred, is occurring, or is likely to occur. These qualifying disclosures (see denition) mean that staff can raise a concern about risk, malpractice or wrongdoing that they think is harming the services, might harm or has harmed in the past any aspect of the services that Care Clarity Support & Advocacy Ltd delivers. A few examples of this might include (but are by no means restricted to):

  • Unsafe care
  • Unsafe working conditions
  • Inadequate induction or training for staff
  • Lack of, or poor, response to a reported Client safety incident
  • Suspicions of fraud (which can also be reported to the local counter-fraud team)
  • Damaging the environment – e.g. disposing of materials or waste incorrectly, for example, ushing medicines or syringes down the toilet or sink
  • A bullying culture (across a team or organisation rather than individual instances of bullying)
  • Incidents of unsafe staffing, falsication of timesheets, Client records or other clinical or care records
  • Failure to investigate claims of physical or sexual assault
  • Physical, verbal or sexual abuse of any Client, colleague or other person on the premises of Care Clarity Support & Advocacy Ltd
  • Sexual harassment
  • Breaching the Data Protection Act

This policy should not be used for complaints relating to a member of staff’s own personal circumstances, such as the way they have been treated at work. In those cases, the individual should use the Grievances Policy and Procedure, Anti-bullying Policy and Procedure, Harassment Policy and Procedure or Sexual Harassment Policy and Procedure.

  • If a member of staff has a genuine concern about a risk, malpractice or wrongdoing at work, it is hoped that they feel they will be able to raise it first with their line manager
  • This may be done verbally or in writing
  • It is better to raise a concern as soon as it arises
  • Where possible, unless, for example, where the concern relates to a safeguarding matter,

the concerns raised will be treated confidentially

  • The member of staff’s line manager will inform them if they cannot keep the concern confidential
  • The Registered Manager has overall responsibility for concerns raised and the member of staff’s line manager may need to share the concern with the Registered Manager who will have access to Care Clarity Support & Advocacy Ltd.
  • A member of staff can raise a concern anonymously if they wish to do so. Any anonymous concerns will be taken seriously and investigated as far as possible based on the information provided. however, Care Clarity Support & Advocacy Ltd may not be able to respond directly to the individual or investigate further with the individual given that their identity will not be known
  • If a member of staff does not feel they can raise the concern with their line manager or the concern relates to or involves the line manager (or they have raised it with the line manager and no action has been taken) the member of staff should then escalate their concerns to the Registered Manager and Care Clarity Support & Advocacy Ltd. to deal with appropriately
  • If the member of staff does not feel that the Registered Manager or Care Clarity Support & Advocacy Ltd. will appropriately handle their concerns, the member of staff may report their concerns directly to Linda Akli, the Freedom to Speak Up Guardian at Care Clarity Support & Advocacy Ltd, whose contact details are: 0333 335 5869 If the member of staff does not feel that the Registered Manager, Care Clarity Support & Advocacy Ltd. or Freedom to Speak Up Guardian will appropriately handle their concerns, the member of staff may report their concerns directly to the Care Quality Commission on 03000 616161 or through its website
  • The CQC will not disclose the member of staff’s identity without their consent unless there are legal reasons requiring the CQC to do so, e.g. where the information is about a child or vulnerable adult who is at risk

It is understandable that whistleblowers are sometimes worried about possible repercussions. Care Clarity Support & Advocacy Ltd aims to encourage openness and will support staff who raise genuine concerns under this policy, even if they turn out to be mistaken. Whistleblowers must not suffer any detrimental treatment as a result of raising a concern. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If an individual believes that they have suffered any such treatment, they should inform the Registered Manager immediately. If the matter is not remedied, the individual should raise it formally using the grievance procedure at The Care Clarity Support & Advocacy Ltd. Anyone who threatens or retaliates against whistleblowers in any way may be subject to disciplinary action. Prior to raising a concern, the member of staff may want to get free, independent and confidential advice from:

  • The Whistleblowing Helpline for NHS and Social Care (Speak Up):
  • 0300 311 22 33
  • [email protected]

Or

  • Protect (Formerly Public Concern at Work) – A whistleblowing charity:
  • 020 3117 2520
  • [email protected]
  • www.protect-advice.org.uk

The Registered Manager may arrange a meeting to discuss the concern. If so, the individual may bring a colleague or union representative to any meetings under this policy. The individual’s companion must respect the confidentiality of the disclosure and any subsequent investigation. The Registered Manager, in consultation with Care Clarity Support & Advocacy Ltd., shall have discretion over the nature of the investigation into concerns raised, including, where it is considered appropriate, the involvement of others such as Adult Social Services or auditors. If there is evidence of criminal activity, the Police will be informed. Care Clarity Support & Advocacy Ltd cannot always guarantee the outcome the individual is seeking. however, Care Clarity Support & Advocacy Ltd will try to deal with the individual’s concern in a fair and appropriate way. If the individual is not happy with the way in which the concern has been handled, they can raise it with one of the contacts listed at paragraphs to .

  • Responsibility for dealing with any concerns reported will lie with the Registered

Manager who will have access to Care Clarity Support & Advocacy Ltd.

  • If the concerns relate to the Registered Manager, concerns should be escalated to the Care Clarity Support & Advocacy Ltd. Ifthe concerns involve both the Registered Manager and Care Clarity
  • LTD. or if an individual is fulfilling both roles, the member of staff can contact the CQC
  • Where a safeguarding concern is received by a member of staff, Rutland County Council safeguarding policies and procedures will be followed
  • Where a safeguarding concern is received by a member of staff and refers to the actions of the Manager or Deputy Manager, then the referral must in the first instance be made to the Social Services Adult Protection Team
  • The Adult Protection Team will take the responsibility of informing other agencies. the contact details for the local Social Services for Care Clarity Support & Advocacy Ltd are as follows: Adult Duty. Rutland County Council. Catmose Road. Oakham. Rutland. LE15 6HP. 01572 722577

The individual with whom the concern is raised will acknowledge the concern within locally agreed timescales and in line with best practice. The investigating officer will be confirmed to the member of staff along with any further information required including contact information and an estimate of the likely timescales involved. Where possible, the responsible manager will feed back to the member of staff who raised the concern on the outcome of any investigation, although this may not always be possible in full due to the nature of the disclosure. A record of the information provided and details of the proceedings will be kept in line with best practice. all whistleblowing concerns will be investigated. however, if a member of staff is found to have made allegations maliciously and/or not in good faith, disciplinary action may be taken. A member of staff will never be disciplined for raising a concern, so long as they follow the whistleblowing procedure or make disclosures in accordance with the Public Interest Disclosure Act 1998 (PIDA). Unless an employer has taken reasonable steps to prevent this type of victimisation by co- workers, it will be deemed liable for the acts of its staff. It is therefore no longer enough to deal with incidents of bullying or harassment as and when they arise, on a case by case basis. The only basis upon which an employer will now be able to defend itself against liability for the actions of its staff will be by proactive steps. In order to demonstrate a “reasonable steps” defence, an employer will need to anticipate conduct such as bullying and harassment. To avoid incidents of bullying or harassment occurring, Care Clarity Support & Advocacy Ltd will take the following steps:

  • Adhere to the Whistleblowing Policy
  • Embed a culture of openness and transparency
  • Communicate the policy
  • Offer any necessary training to ensure that it is put into effect
  • Take action if any worker bullies or harasses a whistleblower

The PIDA protects Whistleblowers from being restricted to bring claims of whistleblowing. The Care Clarity Support & Advocacy Ltd will seek legal or Human Resource advice to ensure that (where relevant) any agreements between Care Clarity Support & Advocacy Ltd and the employee/worker does not prevent them from issuing a whistleblowing claim. Care Clarity Support & Advocacy Ltd strives through its good governance and Quality Assurance policies and procedures to ensure that as an organisation it has a clear audit and review process in place that seeks to foster a culture of continuous improvement and learning. Care Clarity Support & Advocacy Ltd invites and actively seeks feedback, especially from those who may be faced with particular barriers to speaking up and raising concerns. The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases it should not be necessary to alert anyone externally. The law recognises that in some circumstances it may be appropriate for individuals to report their concerns to an external body such as a regulator. It will very rarely, if ever, be appropriate to alert the media. Care Clarity Support & Advocacy Ltd strongly encourages staff members to seek advice before reporting a concern to anyone external. Whistleblowing concerns usually relate to the conduct of staff, but they may sometimes relate to the actions of a third party, such as a supplier or service provider. In some circumstances, the law will protect an individual if they raise the matter with the third party directly. however, Care Clarity Support & Advocacy Ltd encourages staff to report such concerns interfinally first, in line with this policy.

Care Clarity Support & Advocacy Ltd provides care and support to Clients with a range of needs in a person-centred, safe, and lawful way. all staff must follow the guidance within this policy and the Client’s Care Plan, ensuring that assessed needs, reasonable adjustments and individual preferences are met.

  • Every Client is treated equally and with dignity and respect
  • Care and support are tailored to individual needs, preferences and desired outcomes
  • Staff follow legal, regulatory, and professional guidance at all times
  • Person-centred approaches are used to promote independence, choice, and wellbeing

To support this approach, staff will also follow the policies and procedures below where applicable:

  • Person-Centred Care and Supporting Planning
  • Raising Concerns, Freedom to Speak Up and Whistleblowing
  • Mental Capacity Act (MCA) 2005
  • Deprivation Of Liberty in Community Settings
  • Equality, Diversity and Human rights
  • Overarching Medicines Management
  • Positive Behaviour Support Including challenging Behaviour
  • Restrictive Practices Including Restraint and Physical Interventions
  • Sex, Sexuality and Relationships

This list is not exhaustive and there will be additional policies and procedures in place to support specific Client needs. Staff must seek clarification from their line manager or the Registered Manager, Linda Akli, if there is any uncertainty. Staff supporting any specialist area of need will receive appropriate induction and training. They will complete competency assessments, where required, to meet the needs of Clients as outlined in the Training Policy and Procedure at Care Clarity Support & Advocacy Ltd. To ensure Clients receive person-centred care and support from Care Clarity Support & Advocacy Ltd, staff must adhere to the following:

  • The term ‘whistleblower’ is used to describe people who make a ‘qualifying disclosure’

about a genuine concern at work. Where a worker suffers a detriment or is dismissed as a result, then they may have certain employment protections under the Employment rights Act 1996 (as amended by the Public Interest Disclosure Act 1998, often referred to as ‘PIDA’)

  • Qualifying disclosures are disclosures of information where the worker reasonably believes (and it is in the public interest) that one or more of the following matters is either happening, has taken place, or is likely to happen in the future:
  • A criminal offence
  • The breach of a legal obligation
  • A miscarriage of justice
  • A danger to the health and safety of any individual
  • Damage to the environment
  • Sexual harassment
  • Deliberate attempt to conceal any of the above
  • A disclosure made in the interest of the public, i.e. not relating to an individual such as in a grievance case
  • A dispute about the employee’s own employment position without a public interest aspect
  • Public Interest Disclosure Act 1998 – Legislation which provides protection to workers who make disclosures in the public interest
  • PIDA refers to ‘workers’. This policy has used the term employee/staff/colleagues to reflect the relevant persons that this policy relates to. The NHS integrated Policy (2016) ‘Freedom to Speak Up: Whistleblowing Policy for the NHS’ refers to volunteers being included. however, PIDA does not specifically include volunteers as they are not paid employees and therefore cannot be compensated financially for ill treatment or unfair dismissal
  • Legislation which lays out the offences involving ill-treatment or wilful neglect by a

person providing health or social care

  • Made or done by someone whose name is not known or made public
  • Vicarious liability refers to a situation where someone is held responsible for the actions or omissions of another person. In a workplace context, an employer can be liable for the acts or omissions of its employees, provided it can be shown that they took place in the course of their employment
  • The disclosure of information which relates to suspected wrongdoing or dangers at work. This may include (but is not limited to):
  • criminal activity
  • Failure to comply with any legal (or professional) obligation or regulatory requirements
  • Miscarriages of justice
  • Danger to health and safety
  • Damage to the environment
  • Bribery
  • Facilitating tax evasion
  • financial fraud or mismanagement
  • Breach of internal policies and procedures
  • Conduct likely to damage the reputation or financial wellbeing of the organisation
  • Unauthorised disclosure of confidential information
  • Negligence
  • The deliberate concealment of any of the above matters
  • all staff have a duty to ensure standards of quality care by raising concerns regarding inappropriate behaviour, unlawful conduct, poor practice or behaviour and will be protected and supported to do so

Care Clarity Support & Advocacy Ltd is commifitted to the Raising Concerns, Freedom toSpeak Up and Raising Concerns, Freedom to Speak Up and Whistleblowing Policy and Procedure and will act on information given in line with it

Care Clarity Support & Advocacy Ltd will monitor the effectiveness of the whistleblowingprocedures and will review every concern raised to identify and address any themes or trends

  • On induction, staff will be trained on the whistleblowing procedures of Care Clarity Support & Advocacy Ltd. Information on how to report concerns will be visible at The
  • all whistleblowers will be treated in a fair way and will not be victimised or prejudiced as a result of a genuine concern
  • If you have concerns that you are at risk of harm or abuse, you can contact Louise

Hewitt-will. Care Clarity Support & Advocacy Ltd has a safeguarding policy and your

Service User Guide provides information on who you can talk to

https://protect-advice.org.uk/ https://www.england.nhs.uk/wp-content/uploads/2016/11/whistleblowing-guidance… https://www.england.nhs.uk/publication/the-national-speak-up-policy/ https://www.acas.org.uk/whistleblowing-at-work https://assets.publishing.service.gov.uk/ whistleblowing-guidance-for-employers-and-code-of-practice.pdf https://www.legislation.gov.uk/ukpga/2025/36/contents harassment/

  • Grievances Policy and Procedure
  • Duty of Candour Policy and Procedure
  • Complaints, Suggestions and Compliments Policy and Procedure
  • Anti-bullying Policy and Procedure
  • Data Protection and confidentiality Policy and Procedure
  • Sexual Harassment Policy and Procedure
  • The Employment rights Act 2025 – Whistleblowing and Sexual Harassment
  • Employment rights Act 2025

Staff report that Care Clarity Support & Advocacy Ltd is extremely open, transparent andactively supports and encourages whistleblowing
The following forms are included as part of this policy

  • Whistleblowing flow Chart – PM11

To outline the process for whistleblowing