Whistleblowing Policy

23rd February


Policy Owner

Human Resources

Policy Author

General Counsel/Club Secretary

Effective date

September 2020

Review date

September 2021

Revision History



Comments/reason for amendments

Amended by






Review History

Name and Job Title

Date of review


Michelle Slimm



  • This policy is designed to enable employees, causal staff and contractors to raise concerns internally and at a senior level and to disclose information regarding suspected wrongdoing or impropriety within the Company. The aim of the policy is to encourage staff to report suspected wrongdoing or impropriety as soon as possible in the knowledge that their concerns will be taken very seriously and will be dealt with confidentially.


Examples of acts of wrongdoing or impropriety which may fall under this policy include, but are not limited to the following:

  • Criminal activity
  • Safeguarding of Children and Vulnerable Adults
  • Dangers to Health and Safety
  • Bribery or Fraud
  • Slavery / Human Trafficking
  • Failure to comply with any legal, professional obligations or regulatory requirements
  • Discrimination
  • Bullying and/or harassment
  • Conduct likely to damage the reputation of the Company
  • The deliberate release of confidential information


  • This Policy offers protection for those individuals who disclose their concerns provided that such concerns are made in good faith and in the reasonable belief that there is wrongdoing or impropriety.


  • The Company will treat all such disclosures in a confidential and sensitive manner. The identity of the individual making the allegation will be kept confidential. However, the Company may need to reveal the source of the information to further the investigation. In these circumstances the individual making the allegation will be consulted before any disclosure is made.


  • The Company will investigate anonymous allegations at its discretion. However, anonymous allegations are much less credible and therefore individuals are encouraged to put their names to any disclosure.


  • If an individual makes an allegation in good faith, which is not confirmed by a subsequent investigation, no action will be taken against that individual. If, however, an individual makes a malicious or vexatious allegation, and particularly if he or she persists with making them, disciplinary action may be taken against that individual.


  1. Complaints and disclosures should be made to the Senior Legal Counsel / Club Secretary unless the complaint is about the Senior legal Counsel / Club Secretary, in which case it should be reported to the Director of Football Administration / Chief Executive. The Senior Legal Counsel / Club Secretary may investigate the matter or, if appropriate, may appoint a Director or senior manager to investigate the complaint (whoever it is will be the “Investigating Officer”).
  2. Any investigation will be undertaken as quickly as possible without affecting the quality and depth of the investigation. The Senior Legal Counsel / Club Secretary will provide the individual who is making the claim with a written acknowledgement of the complaint and will keep them updates as the investigation progress.
  3. The Investigation will proceed as follows:
    1. The Investigating Officer will obtain full details of the complaint and seek clarification of any issues.
    2. The Investigating Officer shall notify the member of staff against whom the complaint is made as soon as is reasonably practicable. The individual shall be entitled to be accompanied by representative at any future hearing or interview.
    3. The Investigating Officer will investigate the complaint and if necessary shall conduct interviews and obtain statements with other members of staff. Where applicable, the Investigation Officer may use individual or external agencies to assist in the investigation.
    4. The Investigating Officer will keep the Company’s Board informed of the investigation and shall consult with the Company’s Board as appropriate.
    5. The outcome of the investigation will be communicated in writing to the complainant and the employee subject to the complaint. Depending on the outcome of the report the Company may invoke other procedures including but not limited to disciplinary procedures.
    6. If the complainant is not satisfied that the complaint has been dealt with properly by the Investigating Officer then they have the right to raise it in confidence with the Chief Executive (or, in the case where the complaint is against the Senior Legal Counsel/ Club Secretary and the Chief Executive is the investigating officer, then another member of the Company’s Board).
  4. Key Contacts

The Head of Safeguarding at the Football Club is Chris Elliott and can be contacted on 07976 660 0953 or Chris.elliott@wbafc.co.uk.

           The Child and adult at risk policy can be found here

Particular consideration must be given to guidance within the Sexual Offences Act 2003 in relation to staff in positions of trust (POT).