Charity Whistleblowing Policy: Guide and Template

A whistleblowing policy tells the people who work or volunteer for your charity how to raise serious concerns — about fraud, safeguarding failures, or other wrongdoing — and reassures them that they can do so safely. For charities with employees in particular, a clear policy is increasingly expected by funders and is a practical part of good governance. This guide explains what whistleblowing means in the charity context, the legal protection available, when concerns can go to the Charity Commission, and gives you a template to adapt.

What is whistleblowing?

Whistleblowing is when someone reports certain types of wrongdoing they have seen at work. The Charity Commission's guidance puts it simply:

"If you're a charity worker and report certain types of wrongdoing, this is known as 'whistleblowing'."

It is distinct from a personal grievance or a complaint about service. Whistleblowing concerns matters in the public interest — for example, a criminal offence, a risk to someone's health and safety, a failure to comply with a legal obligation, or the deliberate concealment of any of these.

Is a whistleblowing policy a legal requirement?

For most charities, having a written whistleblowing policy is strongly recommended good practice rather than a strict legal requirement. This is consistent with our guide on what policies are required by law for UK charities: the underlying legal protection exists regardless of whether a charity has a policy, but a policy is the practical mechanism that makes the protection usable.

A policy matters most for charities with employees, but even small volunteer-run charities benefit from having a clear route for raising concerns. Many funders now expect to see one.

The legal protection: PIDA 1998

The Public Interest Disclosure Act 1998 (PIDA) protects workers who "blow the whistle" on wrongdoing. The protection applies regardless of the size of the employer — there is no minimum-headcount threshold below which it stops applying. A worker who makes a "qualifying disclosure" in the right way is protected from being dismissed or treated unfairly because of it.

A whistleblowing policy does not create this protection — the law does — but it helps the charity meet the spirit of it by giving people a safe, clear internal route to raise concerns before they feel they have to go elsewhere.

Reporting to the Charity Commission

If a concern cannot be resolved internally, or relates to the charity's own leadership, it can be reported externally. The Charity Commission for England and Wales is a prescribed person for whistleblowing, which means workers and volunteers can report certain matters to it directly and still be protected.

The prescribed-persons list describes the Commission's remit as:

"the proper administration of charities in England and Wales and of funds given or held for charitable purposes in England and Wales."

The Commission explains how it uses such reports:

"Your information helps us determine if a charity is at risk, and how serious it is. We will make a record of your concern, and investigate those that pose the highest risk."

A good internal policy should name the Charity Commission (and, where relevant, other regulators such as the police or the Fundraising Regulator) as external routes if internal channels are not appropriate.

What to include in a whistleblowing policy

A practical whistleblowing policy for a small charity should cover:

1. Purpose and scope — what the policy is for, and who it covers (employees, volunteers, and often contractors).

2. What can be reported — the kinds of serious concern the policy covers, and how this differs from a personal grievance or service complaint.

3. How to raise a concern — who to tell first (usually a line manager or a named trustee), and an alternative if that person is part of the concern.

4. Confidentiality and protection — an assurance that the charity will not tolerate anyone being penalised for raising a genuine concern, and how confidentiality will be handled.

5. External reporting — that concerns can be taken to the Charity Commission or another regulator if they cannot be addressed internally.

6. How concerns are handled — what the charity will do after a concern is raised, and what feedback the person can expect.

Template

Here is a template you can adapt:

Whistleblowing Policy — [Charity Name]

Approved by trustees: [Date] Review date: [Date — typically 12 to 24 months later]

1. Purpose. This policy enables employees, volunteers, and others working for [Charity Name] to raise serious concerns about wrongdoing safely and in confidence.

2. What this policy covers. Concerns about, for example: criminal activity, financial malpractice or fraud, danger to health and safety, safeguarding failures, failure to comply with a legal obligation, or the deliberate concealment of any of these. It does not replace our complaints or grievance procedures, which deal with other matters.

3. How to raise a concern. Concerns should normally be raised with [named person / role, e.g. the Chair of Trustees]. If that person is involved in the concern, or you are not comfortable raising it with them, contact [alternative named person / role].

4. Protection. No one who raises a genuine concern in good faith will be penalised for doing so. We will protect the identity of anyone raising a concern as far as we reasonably can.

5. External reporting. If a concern cannot be raised or resolved internally, you can report it to the Charity Commission for England and Wales or another relevant regulator. Doing so does not remove your legal protections.

6. What happens next. We will acknowledge your concern, decide how to look into it, and give you feedback on the outcome where we are able to.

7. Review. This policy is reviewed by the trustees at least every two years.

Common mistakes

Confusing whistleblowing with complaints. A whistleblowing policy is for serious, public-interest concerns. Keep it distinct from your complaints policy, which handles dissatisfaction with the charity's services.

No alternative contact. If the only route is "tell your manager," a concern about that manager has nowhere to go. Always name an alternative.

Forgetting the external route. A policy that does not mention the Charity Commission leaves people unsure whether they can go outside the charity — which is exactly when they most need reassurance.

For the wider set of policies your charity should hold, see our charity compliance checklist or generate a personalised list with our free compliance checklist generator.

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This guide applies to charities registered in England and Wales. This is general guidance, not legal advice.

Sources

• Report serious wrongdoing at a charity as a worker or volunteer — GOV.UK
• Whistleblowing: list of prescribed people and bodies — GOV.UK
• Public Interest Disclosure Act 1998 — legislation.gov.uk