SGA Whistle Blowing Policy


1. Staff is often the first to realise that there may be something seriously wrong within the organisation. However, they may not express their concerns because they feel that speaking up would be disloyal to their colleagues or to the organisation. They may also fear harassment or victimisation. In these circumstances it may be easier to ignore the concern rather than report what may be a suspicion of malpractice.

2. SGA is committed to the highest possible standards of corporate governance. In line with this commitment, SGA encourages employees and others with serious concerns about any aspect of SGA to come forward and voice those concerns. This process is commonly referred to as “whistle blowing” and this policy gives detailed advice on how to go about it.

3. It is recognised that certain cases will have to proceed on a confidential basis. This policy makes it clear that staff can make reports without fear of reprisals. This is intended to encourage and enable staff to raise serious concerns within the Secretariat, Executive Board or Governing Council rather than overlooking problems or raising them outside.


4. This policy aims to provide avenues for staff to raise concerns and receive feedback on any action taken. It:

  • allows staff to take the matter further if they are dissatisfied with initial response to the concerns expressed, and
  •  reassures staff that they will be protected from possible reprisals or victimisation.

5. Any serious concern that a member of staff has about any aspect of service provision or the conduct of officers or members of SGA or others acting on behalf of SGA can and should be reported under this policy.

6. This concern may be about something that is:

  • unlawful; or
  • against SGA’s policies; or
  • against established standards of practice; or
  • improper conduct.


7. Concerns should normally be raised with the General Manager, Chairman of the Audit Committee, President of the SGA Executive Board, Chairman of the SGA Governing Council or any other members. The most appropriate person to contact will depend on the seriousness and sensitivity of the issues involved and who is suspected of the malpractice.

8. Concerns may be raised orally or in writing. Employees who wish to make a written report should use the following format:

  • background and history of the concern (giving relevant dates);
  • reason why the employee is particularly concerned about the situation.

9. It should be noted that often the earlier a concern is expressed the easier it is to take appropriate action.

10. Although employees are not expected to prove the truth of an allegation that is made, it will be necessary to demonstrate to the person contacted that there are sufficient grounds for concern.

11. The action taken by management will depend on the nature of the concern. Allegations should be passed to the General Manager in the first instance. Where appropriate, the matters raised may be initially investigated by the Secretariat to decide whether a full investigation by the Audit Committee is necessary.

12. On receipt of any allegation of fraud or corruption, the GM will report the matter to the President who will arrange for the Audit Committee to lead the investigation.

13. Within ten working days of a concern being raised, the person raising the concern will be informed:

  • acknowledging that the concern has been received;
  • indicating how it proposes to deal with the matter; and
  • giving an estimate of how long it will take to provide a final response.

14. If it is impossible for initial inquiries to be completed within ten working days, the situation will be explained in the letter of acknowledgement. Where a decision is made that no investigation will take place, the reasons for this will be provided.

15. The amount of contact between the officers considering the issues and the employee raising the concern will depend on the nature of the matters raised, the potential difficulties involved and the clarity of the information provided. If necessary, further information may be sought from the person raising the concern.


16. Harassment or Victimisation It is recognised that the decision to report a concern can be a difficult one to make, not least because of the fear of reprisals from those who may be guilty of malpractice. SGA will not tolerate any harassment or victimisation (including informal pressures) and will take appropriate action in order to protect a person who raises a concern in good faith.

17. Confidentiality As far as possible, SGA will protect the identity of any employee who raises a concern and does not want his/her name to be disclosed. However, the investigation process may reveal the source of the information and a statement by the person reporting the concern may be required as part of the evidence.

18. Anonymity Concerns expressed anonymously will be considered at the discretion of SGA as far as it is appropriate and depending on the nature of complaint and evidence provided.

19. False and Malicious Allegations SGA will protect itself and its employees from false and malicious expressions of concern by taking disciplinary action where appropriate. In addition, a concern which is genuinely believed may prove to be unfounded on investigation. SGA will try to ensure that the negative impact of either a malicious or unfounded allegation about any person is minimised. However, it acknowledges that it will not be possible to prevent all of the repercussions potentially involved.

1 Aug 11