Whistleblowing policy
Summary
We are committed to conducting our business with honesty and integrity, and we expect all staff to maintain high standards. However, all organisations face the risk of things going wrong from time to time, or of unknowingly harbouring illegal or unethical conduct. This policy is intended to support a culture of openness and accountability, which is essential in order to prevent such situations occurring and to address them when they do occur.
| Control information | Control detail |
|---|---|
| Owner | Director of Governance and University Secretary, University Secretary’s Office |
| Author | General Counsel and Director of Legal Services, Legal Services |
| Sponsor | Director of Governance and University Secretary, University Secretary’s Office |
| Consulted |
|
| Approved by | Audit and Risk Committee |
| Responsible area | University Secretary’s Office |
| Version | Version 1 under this Policy Framework |
| Approval date | 02 March 2026 |
| Effective date | 02 March 2026 |
| Interim review effective date | Not applicable |
| Full review period | 3 years |
| Date of next full review | 02 March 2029 |
| EIA completion date | 28 October 2025 |
| DPIA completion date | 03 October 2025 |
| SIA completion date | Not applicable |
| Reporting requirements | Whistleblowing Officer to report verbally to each ARC meeting with a full written report annually |
| Applicable statutory, legal or best practice requirements |
|
| Keywords | confidential, conduct, culture, disclosure, investigation, protection, public interest, whistleblowing, whistleblowing officer |
On this page
1. Updates to this policy
1.1. The University has had a Whistleblowing policy since the Public Interest Disclosure Act 1998 came into force.
1.2. This policy has been reviewed and updated periodically since that date and has been updated to align to the new University of Bristol policy management framework. The version this policy replaces was approved by the Audit and Risk Committee on 27 June 2022.
1.3. This policy has been implemented following relevant consultation. This policy is non-contractual and it may be amended by the University at any time.
2. Introduction
2.1. The University of Bristol (we/our/us) is committed to conducting our business with honesty and integrity, and we expect all staff to maintain high standards. However, all organisations face the risk of things going wrong from time to time, or of unknowingly harbouring illegal or unethical conduct. A culture of openness and accountability is essential in order to prevent such situations occurring and to address them when they do occur.
3. Scope
3.1. This policy covers our staff (including employees, officers such as members of the Board of Trustees, consultants, contractors, paid interns, casual workers, agency workers and those with Honorary contracts) and students.
3.2. The aims of this policy are:
- to encourage staff and students 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 and students with guidance as to how to raise those concerns; and
- to reassure staff and students that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.
4. Definitions
4.1. BoT: Board of Trustees.
4.2. COO: Chief Operating Officer.
4.3. DVC: Deputy Vice Chancellor.
4.4. Nominated Representative: A member of a University-recognised Trade Union who has been nominated by the Audit and Risk Committee to receive disclosures of Whistleblowing Concerns under this policy.
4.5. WBO: The Whistleblowing Officer, the person nominated by the BoT to operate this policy.
4.6. Whistleblower: The person raising a Whistleblowing Concern under this policy.
4.7. Whistleblowing Concern: A disclosure of the type of information set out in What is Whistleblowing, section 6.
5. Responsibilities
5.1. The BoT has overall responsibility for this policy, and for reviewing its effectiveness.
5.2. The WBO has day to day operational responsibility for this policy.
5.3. Our WBO is the University Secretary, or nominee, the contact details can be found in Appendix 1.
5.4. If the WBO is unavailable or absent, or would have a conflict of interest in managing a particular Whistleblowing Concern, then one of the following may act as WBO:
- the COO;
- the DVC; and
- the Nominated Representative.
5.5. If none of the officers listed in paragraph 5.4 is available for any reason then the Chair of the Audit and Risk Committee may appoint an alternative senior member of the University to act as WBO.
5.6. The WBO, in conjunction with the BoT (through the Audit and Risk Committee) shall review this policy from time to time.
5.7. The WBO will report annually to the BoT (through the Audit and Risk Committee) on the operation of the policy and (subject to section 8, Confidentiality and anonymity) whether any disclosures have been made.
5.8. All staff and students are responsible for the success of this policy and are encouraged to use this policy to raise any Whistleblowing Concerns. Staff and students are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the WBO at university.secretary@bristol.ac.uk.
5.9. Managers and other staff who may deal with Whistleblowing Concerns or investigations may seek advice from Legal Services who may, on behalf of the WBO also issue guidance from time to time and may provide training.
6. What is Whistleblowing?
6.1. For the purposes of this policy a Whistleblower is a person who discloses information which in their genuine and reasonable belief is in the public interest and which tends to show one or more of the following:
- criminal activity;
- failure to comply with any legal obligation;
- miscarriage of justice;
- danger to health and safety;
- damage to the environment; and
- the deliberate concealment of any of the above.
6.2. Examples of issues which might be Whistleblowing Concerns include :
- bribery (under our Anti-bribery policy);
- financial fraud or mismanagement or impropriety;
- significant breach of a legal or regulatory obligation;
- unauthorised disclosure of confidential information;
- unauthorised use of data;
- academic or professional malpractice (including research misconduct);
- breach of any legal obligations imposed by research grants or funders; and
- the deliberate concealment of any of the above matters.
6.3. This policy should not be used for complaints relating to your own personal circumstances, such as the way you believe that you have been treated at work or, if you are a student, a complaint about any aspect of student life or an academic appeal. In those cases you should use the Staff Grievance Procedure, Student Complaints Procedure or Examination Regulations as appropriate. This policy may not be used to re-open or review a matter already decided in such procedures or to question or reconsider any financial or business decisions.
6.4. If you are uncertain whether something is within the scope of this policy you should seek advice from the WBO or from the University’s General Counsel. Contact details are in Appendix 1.
7. Raising a Whistleblowing Concern
7.1. In many cases you will be able to raise any Whistleblowing Concern with your line manager or if you are a student with your Senior Tutor, Supervisor or Head of School (together referred to below as Supervisor). If you hold Academic Honorary or Visiting Academic status, you may raise any Whistleblowing Concern with your Sponsor. You may tell them in person or put the matter in writing if you prefer. We would hope that they would be able to find a way to resolve your concern quickly and effectively. In some cases your line manager or Supervisor may feel that your concern should be referred to the WBO; if so, they will discuss this with you before making the referral.
7.2. However, where the matter is more serious, or you feel that your line manager or Supervisor has not addressed your concern, or you prefer not to raise it with them for any reason, you should contact one of the following:
- the WBO;
- the COO;
- the DVC; and
- The Nominated Representative (even if you are not a member of a Trade Union).
Their contact details are in Appendix 1. The person to whom the concern is reported will acknowledge its receipt within 5 working days.
7.3. As soon as possible after receiving your Whistleblowing Concern you will be invited to an initial meeting with the WBO (or the COO, DVC or the Nominated Representative as appropriate). If your meeting is with anybody other than the WBO they will report to the WBO (except where the WBO has a conflict of interest in the subject matter of the Whistleblowing Concern; in such a case the COO, DVC or Nominated Representative will act as WBO).
7.4. We recognise that you may wish to be accompanied to any meeting under this policy by someone who can support you (such as a Trade Union representative or Supervisor). If you wish to bring a companion, you should confirm who you would like to accompany you and we will consider whether their attendance is appropriate. We would not normally allow legal representatives to accompany you. Subject to any applicable law, you and your companion are expected to maintain the confidentiality of the Whistleblowing Concern and any subsequent investigation, recommendation or action.
7.5. After your initial meeting with the WBO (or COO, DVC or the Nominated Representative) an initial assessment will be carried out to determine:
- whether the Whistleblowing Concern falls within this policy or whether it should be considered under a different internal policy; and
- if this policy applies, the scope of any investigation.
7.6. You will be given a written summary of your Whistleblowing Concern and an indication of how we propose to deal with the matter.
8. Confidentiality and anonymity
8.1. We hope that you will feel able to raise Whistleblowing Concerns openly under this policy and we would hope that you do not feel the need to raise your concern on an anonymous basis. However, you may, if you wish, raise your concern in confidence.
8.2. We do not encourage you to make disclosures anonymously because proper investigation can be more difficult or impossible if we cannot obtain further information from you. It is also more difficult to establish whether any allegations are credible.
8.3. Whistleblowing Concerns which are expressed anonymously will be considered at our discretion according to:
- the seriousness of the issues raised; and/or
- the likelihood of confirming the allegation from alternative credible sources.
8.4. We recognise that you may wish to keep your identity confidential when raising a Whistleblowing Concern.
8.5. In the event that we consider it necessary to reveal your identity as part of investigating and dealing with your concerns (whether under this whistleblowing process or another internal process) we will let you know and discuss this with you before we do so. We will endeavour to ensure that you suffer no detriment for raising Whistleblowing Concerns in accordance with this policy.
8.6. If you are concerned about possible reprisals if your identity is revealed you should raise this with the WBO or the person with whom you raise your concern.
8.7. Malicious or vexatious allegations, or concerns raised in bad faith or with a view to personal gain, may lead to disciplinary action being taken against you.
9. Investigation and outcome
9.1. As explained above, the form of the investigation will depend on the nature of the matter raised and the WBO (or COO, DVC or the Nominated Representative, as appropriate) will determine initially whether the matter should be investigated and if so:
- whether that investigation should take place under an existing internal procedure (e.g. if the allegation relates to potential fraud then the investigation will take place under the Counter fraud policy); or
- whether it is necessary to set up an investigation separate from existing processes.
9.2. The WBO (or COO, DVC or the Nominated Representative, as appropriate) will also consider at this initial stage (and on an ongoing basis) whether any external body needs to be notified (such as the police, the Office for Students or a funder).
Another internal procedure
9.3. If the WBO considers that a concern should be dealt with under another internal procedure, they will notify you of that decision. That internal procedure will take place in the normal way and in accordance with any relevant Ordinances, Regulations and policies. Your involvement (including applicable confidentiality issues) will depend on the relevant procedure. The outcome of any investigation under an internal procedure will be reported to the WBO so that they may decide whether any further action should be taken to minimise future wrongdoing. Depending on the applicable procedure you may or may not be informed of the outcome of the internal procedure (including any actions taken by us under it).
Whistleblowing investigation
9.4. Investigations will not normally be undertaken by the WBO. The WBO will appoint an investigator or team of investigators which might include staff with relevant experience or specialist knowledge of the subject matter. The investigator(s) may contact you for any further information. They may make recommendations for change to enable us to minimise the risk of future wrongdoing. However, it is for the WBO to decide what action we should take as a result of any whistleblowing investigation.
9.5. The WBO will aim to keep you informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent us giving you specific details of the investigation or any action taken as a result.
10. If you are not satisfied
10.1. While we cannot guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way. By using this policy, you can help us to achieve this.
10.2. If you are not happy with the way in which your concern has been handled, you can raise it with one of the other key contacts in paragraph 5.4 of Responsibilities. Alternatively, you may contact the chair of Audit and Risk Committee. Contact details are set out in Appendix 1.
11. External disclosures
11.1. The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally.
11.2. The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body like the Office for Students. It will rarely be appropriate to alert the media. We strongly encourage you to seek advice before reporting a concern to anyone external. The independent whistleblowing charity, Public Concern at Work, operates a confidential helpline. They also have a list of prescribed regulators for reporting certain types of concern. Their contact details are Appendix 1.
12. Protection and support for Whistleblowers
12.1. It is understandable that Whistleblowers are sometimes worried about possible repercussions. We aim to encourage openness and will support staff and students who raise genuine concerns under this policy, even if they turn out to be mistaken.
12.2. 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 (such as bullying and harassment) connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the WBO immediately.
12.3. We will not tolerate such conduct which is likely to result in disciplinary procedures being commenced.
12.4. In addition, individuals may be personally liable if they subject a person to any kind of detriment because they raised Whistleblowing Concerns.
12.5. Certain members of staff may also be protected by the Public Interest Disclosure Act 1988 (PIDA). We believe that this policy incorporates the provisions of PIDA, but to the extent that it does not, the provisions of PIDA will apply.
12.6. A confidential support and counselling hotline is available to Whistleblowers who raise concerns under this policy. Their contact details are set out in Appendix 1.
Request this policy in an alternative format
If you need this policy in a different format, email uob-policymanager@bristol.ac.uk. In your message, include the format you need, for example: plain text, braille, BSL, large print or audio.