Draft for client review
Status: Working draft dated 20 July 2026. This policy has been prepared from current official UK guidance for Bruce Penny to review. It is not yet an approved company policy.
Before approval, confirm that the responsibilities and working arrangements below match current practice. Professional legal or safety advice should be obtained where needed.
1. Purpose and who this covers
Penny Tree Surgery wants workers to speak up about wrongdoing that affects other people or the public interest. This policy applies to employees, workers, trainees, agency workers and others who may qualify for protection under whistleblowing law.
A personal complaint about an individual employment matter will normally be handled as a grievance unless it also raises a wider public-interest concern.
2. Concerns covered
- A criminal offence, fraud, bribery or theft.
- A breach of a legal obligation.
- A danger to health and safety.
- Damage or a serious risk of damage to the environment.
- A miscarriage of justice, sexual harassment or deliberate concealment of wrongdoing.
A worker does not need to prove the concern before raising it. They should have a reasonable belief that the information tends to show wrongdoing and, for statutory protection, that disclosure is in the public interest and made through an appropriate channel.
3. How to raise a concern
Raise the concern with Bruce Penny in person, by telephone on 07415 900239 or by email to bruce@pennytreesurgery.co.uk. Explain what happened or may happen, when and where, who may be involved, and any immediate risk. Supporting evidence is helpful but not required.
Say if you want your identity kept confidential. We will take reasonable steps to protect confidentiality, but it cannot be guaranteed where disclosure is required by law or necessary for a fair investigation. Anonymous concerns will be considered, although anonymity can make investigation and feedback more difficult.
4. What happens next
We will acknowledge a named concern as soon as reasonably practicable, assess immediate safety or preservation-of-evidence needs, decide who should investigate and keep the person who raised it informed where confidentiality and the rights of others allow.
The outcome may include corrective action, changes to working arrangements, disciplinary or contractual action, or referral to a regulator or the police. The person raising the concern will not control the investigation and may not receive confidential details about other people.
5. Protection from retaliation
Victimisation, dismissal, threats or any other detriment because a worker raised a genuine concern are prohibited. Confidentiality clauses do not prevent a worker from making a legally protected disclosure.
Knowingly making a false allegation for personal gain or with malicious intent may be addressed under the relevant conduct process, but an honestly raised concern will not result in action merely because it is not substantiated.
6. External advice or disclosure
If the concern involves Bruce Penny, internal reporting is inappropriate, or the response does not address an ongoing concern, a worker may seek confidential advice from Acas, the whistleblowing charity Protect, a trade union or a legal adviser.
A worker may also report to the relevant prescribed person or body, such as the Health and Safety Executive or Environment Agency, where the issue falls within that body’s remit. Wider disclosure, including to the media or on social media, is protected only in limited circumstances, so independent advice should be sought first.
7. Records and review
Records will be limited to what is necessary, stored securely and shared only with people who need them for assessment, investigation, action or legal compliance. Bruce Penny is responsible for this policy and will review it annually and after any material case or legal change.
8. Official guidance used
Whistleblowing guidance for workers on GOV.UK
Questions or concerns about this whistleblowing policy? Contact Bruce Penny on 07415 900239 or email bruce@pennytreesurgery.co.uk.