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2. If the employee chooses the whistleblowing policy as the most
appropriate mechanism for his/her concern (or the more informal
procedures have been tried and the result has proved unsatisfactory in
the eyes of the employee) before proceeding with approaching the
Supervising Member (see paragraph 5 below) the employee may, if
he/she wishes, raise the matter in confidence with his/her line manager
in the first instance. If, for whatever reason, he/she does not wish to
consult his/her line manager but nonetheless wants a second opinion,
a member of the relevant senior management team may be consulted
in confidence.
3. If the line manager or member of the relevant senior management
team (‘Senior Colleague’) is alerted under the policy, that Senior
Colleague should advise the employee in question in no more than five
working days whether he/she also considers the suspicion reasonable
and, also, that the use of the policy is appropriate in the circumstances.
The employee may still alert the Supervising Member even if his/her
Senior Colleague does not concur with his/her suspicion and/or feels
that invoking the policy will be inappropriate, provided he/she still
believes there are reasonable grounds for suspicion.
4. Whether or not the employee informs a Senior Colleague, a person
considering blowing the whistle must not prevaricate, make obvious
investigations or set any traps. It may prove detrimental to any further
investigations if the person believed to be involved in the wrongful
activity is approached.
Stage 2: Raising the suspicion and initial investigation
5. Once the employee (and any Senior Colleague consulted) believes
there are reasonable grounds for suspecting an activity falling within
the policy and that the use of the policy is appropriate, the employee
should alert one of the Supervising Members (‘SMs’). A number of
members of the NCI audit committees are available to be a Supervising
Member in a case of whistleblowing (details in the FAQs). They can be
contacted about an issue in any NCI (not just about the NCI on whose
audit committee they serve). The SM will take the basic details of the
concern and the whistleblower’s contact details. The SM will then
decide how the initial evaluation should be conducted (usually by
commissioning relevant staff or professional assistance), consider the
outcome and recommendations, and be briefed on the progress of any
subsequent investigation (challenging where necessary its adequacy
and conclusions). Usually at this point the relevant Chief Officer and
director / head of department will be informed that a whistleblowing
issue has arisen, but their involvement in the investigation may be
limited to being informed (this reflects the delicacy of the nature of a
whistleblowing investigation. More information will later be provided to
enable the introduction of new, stricter controls).