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Whistleblowing Policy

Approved By

Full Council

Author

Dan Gwalter

Confidentiality
Public
Date Published
November 4, 2025
Document Reference

WES-POL-0024

Notes

Owner (Role)
Secretary
Policy Group
Governance and Conduct
Review Date
November 4, 2027
Status
Published
Version

1.0

Visible on Website
  • 1. Purpose
  • 2. Scope
  • 3. Definitions
  • 4. Policy Statement
  • 5. Roles and Responsibilities
  • 6. Policy Detail and Procedures
  • 6.1 Raising a Concern
  • 6.2 Initial Review
  • 6.3 Investigation
  • 6.4 Protection of the Whistleblower
  • 6.5 False or Malicious Allegations
  • 7. Related Policies and References
  • 8. Compliance and Breach Handling
  • 9. Review and Version Control
  • 10. Approval Record

1. Purpose

This policy provides a secure and confidential route for individuals to raise serious concerns about wrongdoing within the Western Equestrian Society (WES), without fear of reprisal. WES encourages openness, honesty, and accountability. Whistleblowing plays a vital role in protecting the integrity of our governance, safeguarding our members, and maintaining trust.

2. Scope

This policy applies to Council members and Officers; WES Professionals; Area Representatives; volunteers and contractors; and general members with legitimate governance concerns. It applies to concerns involving: criminal activity; breaches of legal or regulatory duty; gross misconduct or serious policy breaches; misuse of WES funds or resources; deliberate cover-ups; and behaviour posing serious risk to members or the public. It does not apply to personal complaints (see Complaints Procedure), disciplinary issues raised about someone (see Disciplinary Procedure), or minor disagreements or grievances.

3. Definitions

  • Whistleblowing: Reporting a serious concern in the public or organisational interest
  • Whistleblower: A person raising such a concern, who may do so confidentially
  • Malpractice: Dishonest, unlawful, dangerous, or unethical activity
  • Retaliation: Any negative treatment of a whistleblower for speaking up

4. Policy Statement

WES will treat all whistleblowing reports seriously. Where a concern is raised in good faith, the individual will be protected - even if the concern proves to be mistaken. Concerns may be raised confidentially or anonymously. WES will investigate promptly, proportionately, and fairly. Whistleblowers must not be treated less favourably or excluded for having spoken up.

5. Roles and Responsibilities

Role
Responsibility
Secretary
Receives whistleblowing concerns; coordinates initial review
Chairperson
Escalation and oversight for serious or high-risk cases
Council
Ensures independence of investigation and upholds policy commitments
Whistleblower
Raises concern in good faith with as much supporting detail as possible

6. Policy Detail and Procedures

6.1 Raising a Concern

  • Concerns should be submitted to the Secretary or Chairperson by email, letter, WhatsApp message, or other written means
  • If the concern involves one of those roles, send it to the other
  • Anonymous reports are accepted but must be detailed and credible to be acted on

The whistleblower should include: what has happened; when and where; who was involved; any supporting evidence or witnesses; and whether the concern has been raised previously.

6.2 Initial Review

  • The Secretary (or Chair) will acknowledge the concern within 7 days

A triage review will determine: whether the concern falls under this policy; whether further investigation is warranted; and whether to refer it to Council, an external advisor, or other relevant body. This review will normally be completed within 14 days.

6.3 Investigation

  • If warranted, an Investigating Officer will be appointed (must be impartial and unrelated to the concern)
  • The investigation may involve document review, interviews, or consultation with external bodies (e.g. police, regulators)
  • Findings will be reported back to the Secretary or Chair, and a decision made on any action required
  • The whistleblower will be informed of the outcome where appropriate (subject to confidentiality)

6.4 Protection of the Whistleblower

  • WES will not tolerate retaliation, discrimination, or exclusion of any whistleblower acting in good faith
  • Retaliatory behaviour may itself result in disciplinary action
  • Whistleblowers do not need to prove the concern is true - only that it was raised honestly and with reason

6.5 False or Malicious Allegations

  • Deliberately false, malicious, or vexatious reports will not be protected under this policy
  • These may lead to action under the Disciplinary Procedure

7. Related Policies and References

  • Complaints Procedure (WES-POL-0005)
  • Disciplinary Procedure (WES-POL-0021)
  • Code of Conduct
  • Data Protection Policy (WES-POL-0014)
  • Whistleblowing Form (Templates and Tools folder)

8. Compliance and Breach Handling

Failure to act appropriately on a whistleblowing concern, or retaliating against someone who raises one, may be treated as a governance breach and result in sanctions against the offending individual(s). All confirmed concerns and investigations will be logged securely by the Secretary and retained for six years.

9. Review and Version Control

Version
Date
Author
Changes Made
0.1
18/07/2025
DG
Initial policy draft
0.5
08/10/2025
DG
Changes following Chairman's review
1.0
04/11/2025
DG
Published

10. Approval Record

Approved By
Date
Notes
Full Council
04/11/2025
Approved for immediate use