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Millom Town Council
Millom Town Council was formed in 1974 when the parish boundaries changed from Cumberland.

Whistleblowing Policy

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Whistleblowing Policy

Adopted: September 2025
Review Date: September 2028

Policy

It is important that any fraud, misconduct or wrongdoing by staff or others working on behalf of Millom Town Council are reported and properly dealt with. We, therefore, require that all individuals raise any concerns that they may have about the conduct of others in Millom Town Council. This policy sets out the way in which individuals may raise any concerns that they have and how those concerns will be dealt with.

Background

The Public Interest Disclosure Act 1998 amended the Employment Rights Act 1996 to provide protection for workers who raise legitimate concerns about specified matters in the public interest. These are called “qualifying disclosures”. A qualifying disclosure is one made by an employee who has a reasonable belief that:

  • a criminal offence;
  • a miscarriage of justice;
  • an act creating risk to health and safety;
  • an act causing damage to the environment;
  • a breach of any other legal obligation; or
  • concealment of any of the above;

is being, has been, or is likely to be, committed. It is not necessary for you to have proof that such an act is being, has been, or is likely to be, committed – a reasonable belief is sufficient. You have no responsibility for investigating the matter – it is Millom Town Council’s responsibility to ensure that an investigation takes place.

If you make a protected disclosure, you have the right not to be dismissed, subjected to any other detriment, or victimised, because you have made a disclosure. We encourage you to raise your concerns under this procedure in the first instance.

Principles

  • Everyone should be aware of the importance of preventing and eliminating wrongdoing at work. Staff, councillors and others working on behalf of Millom Town Council should be watchful for illegal or unethical conduct and report anything of that nature that they become aware of.
  • Any matter raised under this procedure will be investigated thoroughly, promptly and confidentially, and the outcome of the investigation reported back to the person who raised the issue.
  • No employee/councillor or other person working on behalf of Millom Town Council will be victimised for raising a matter under this procedure. This means that the continued employment and opportunities for future promotion or training of the worker/councillor will not be prejudiced because they have raised a legitimate concern.
  • Victimisation of an individual for raising a qualified disclosure will be a disciplinary offence.
  • If misconduct is discovered as a result of any investigation under this procedure, our disciplinary procedure will be used, in addition to any appropriate external measures.
  • Maliciously making a false allegation is a disciplinary offence.
  • An instruction to cover up wrongdoing is itself a disciplinary offence. If told not to raise or pursue any concern, even by a person in authority such as a manager, you should not agree to remain silent. You should report the matter to the Town Clerk or Chair of Council and General Purposes.

Procedure

Concerns relating to an alleged breach of the Councillors Code of Conduct will be referred to the Monitoring Officer for investigation.

This procedure is for disclosures about matters other than a breach of your own contract of employment, which should be raised via the Grievance Policy.

Stage 1

In the first instance, any concerns should be raised with the Clerk, who will arrange an investigation into the matter. The investigation may involve you and other individuals involved giving a written statement. Any investigation will be carried out in accordance with the principles set out above. Your statement will be taken into account, and you will be asked to comment on any additional evidence obtained.

The Clerk (or delegated person) will take any necessary action, including reporting the matter to the Council, or any appropriate government department or regulatory authority. The Clerk (or delegated officer) will also invoke any disciplinary action if required. On conclusion of any investigation, insofar as confidentiality allows, you will be told the outcome and what the council has done, or proposes to do, about it. If no action is to be taken, the reason for this will be explained.

Stage 2

If you are concerned that the Clerk is involved in the wrongdoing, has failed to make a proper investigation or has failed to report the outcome of the investigations to the relevant person you should escalate the matter to the Chair of Council and General Purposes. The Chair will then arrange for a review of the investigation to be carried out and make any necessary enquiries.

Stage 3

If on conclusion of Stages 1 & 2 you reasonably believe that the appropriate action has not been taken, you should then report the matter to the relevant body, this includes:

  • HM Revenue and Customs
  • The Health and Safety Executive
  • The Environment Agency
  • The Serious Fraud Office
  • The Charity Commission
  • The Pensions Regulator
  • The Information Commissioner
  • The Financial Conduct Authority

You can get the full list in The Public Interest Disclosure (Prescribed Persons) Order 2014:
www.gov.uk/government/uploads/system/uploads/attachment_data/file/496899/BIS-16-79-blowing-the-whistle-to-a-prescribed-person.pdf

Data Protection

When an individual makes a disclosure, we will process any personal data collected in accordance with the data protection policy. Data collected from the point at which the individual makes the report is held securely and accessed by, and disclosed to, individuals only for the purpose of dealing with the disclosure.

This is a non-contractual procedure which will be reviewed from time to time.

Signed: ……………………. Chair of Council
Adopted, approved and Dated: 24th September 2025

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Millom Town Council was formed in 1974 when the parish boundaries changed from Cumberland.
01229 772340 theclerk@millomtowncouncil.co.uk 6 Newton St, Millom, LA18 4DR
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Upcoming Meeting Dates

2025

APRIL 30TH: Methodist Church meeting room
MAY 28TH: Methodist Church meeting room
JUNE 25TH: Methodist Church meeting room
JULY 30TH: Methodist Church meeting room

All meetings will commence at 07.00pm unless otherwise stated on
the agenda.