Speak Up Policy

The Institute is committed to ensuring that we always carry out our business in an ethical, honest, fair and respectful manner. However, if you become aware of circumstances in which we are not meeting our standards, we encourage you to speak up and tell us.

CISI has a speak up culture in which employees should feel able to raise any matter of genuine concern internally, without fear of victimisation or discrimination. Employee concerns will be taken seriously, and the matters raised will be investigated appropriately. CISI will not tolerate retaliation against those who speak up. This policy sets out how employees may raise concerns about wrongdoing and our approach if such concerns are raised.

Speaking up is the act of raising concerns internally about wrongdoing related to the business. You are encouraged to speak up about suspected, or actual violations, of CISI’s values, or about any violations of the law. Concerns should be raised when it is in the public interest to do so (i.e. when it is in the benefit of CISI members, customers, stakeholders, fellow employees or the wider public to do so). Here are some examples of the kind of concerns which can be dealt with using the speak up policy:

• Financial malpractice

• Health and Safety concerns

• Breach of policy

• Breach of confidentiality

• Data protection violations

• Bribery and corruption

This policy can be used by any employee who wishes to speak up about wrongdoing related to the business. However, there are certain sorts of wrongdoing may be better dealt with under other policies (e.g. the grievance procedure, disciplinary procedure and harassment procedure). For example, if you have a direct personal interest in matters, it will normally be appropriate to use the grievance procedure.

If you are unsure whether to raise your concern under this policy, you may approach one of the people mentioned below informally and ask for advice on what to do. The most appropriate ourse of action will be decided on a case by case basis.

In any case, when considering concerns which have been raised, consideration will be given as to whether or not there is a more appropriate policy to deal with the matter. If your concern is to be dealt with under a different policy, this will be discussed with you.

 

In the first instance, you should consider raising concerns with your line manager. He/she has a responsibility to listen and respond to any matter that is important to you. Concerns can be raised verbally or in writing. They may be able to agree a way of resolving the matter quickly and effectively.

Senior Manager/HR:

If for any reason you feel as though you cannot speak with your line manager, you should consider raising your concerns with the head of your department or with HR.

You can also raise concerns with the following individuals if you feel that doing so is appropriate, or if you feel your concern was not adequately dealt with at earlier stages:

• any Executive Director;

• the Chief Executive; or

• the Chairman.

If you are not comfortable with the concern being addressed by the Executive Director/Chief Executive, an independent Director, Becky Taylor, has been appointed to look into concerns. Becky Taylor can be contacted by emailing her directly using the following email address: independentdirector@cisi.org

When speaking up, you should state that you are following this policy.

What will happen?

Your line manager or senior manager will take a note of your concern and will try their best to resolve the problem themselves. If this is not possible, your concern may be escalated to HR, who may involve an Executive Director or the Chief Executive.

Who will take charge?

An Executive Director will be allocated to oversee the process and will be your key point of contact.

How will the matter be resolved?

In some cases, the investigation process may be limited, particularly where it appears that the concerns are minor or based on a misunderstanding. In other cases, the investigations will be more wide-ranging. Your point of contact will keep you informed through discussion where possible.

How long will it take?

It is not practicable to set out strict time-limits for investigations. Much will depend upon the particular issues. However, we recognise that it is important that matters are looked into without delay. You will be informed of progress wherever possible throughout the process.

What happens next?

Where possible you will be given feedback about the outcome. However, there may be circumstances where this is not appropriate, for example, where disciplinary proceedings or other action of a confidential nature are taken.

 

If you wish your identity to be kept confidential, let this be known when you initially raise your concern. The CISI will keep the identity of staff members who speak up confidential, unless otherwise required by law.

However, there may be circumstances where preserving confidentiality is not possible. For example, if the information in the report could only come from one source. If this is the case, please be assured that CISI take instances of victimisation as a result of speaking up very seriously. CISI staff members should not face retaliation as a result of speaking up.

The CISI understands that some employees may wish to raise concerns anonymously. Any concerns raised in this way will not be dismissed out of hand, however, there are three things to consider before speaking up anonymously:

• It will be much harder to investigate concerns that are raised anonymously, as it will not be possible to contact the person who raised the concern to ask for more information.

• The CISI cannot effectively protect whistleblowers who raise concerns anonymously, for example by identifying if that person has been subject to victimisation or other problems

• It is not possible to provide feedback to the whistleblower, or let them know what has happened regarding their concern if the initial concern was raised anonymously

CISI supports any employee speaking up about wrongdoing under this policy. If you believe that you are being victimised or disadvantaged as a result of the report, you should immediately tell an Executive Director/ Chief Executive or HR. You will not be victimised or disadvantaged for doing this. The only qualification to this is that, if your allegations are proven to be malicious and untrue, disciplinary proceedings are likely. Furthermore, any employee who obstructs an investigation is likely to be subject to disciplinary proceedings.

The UK’s Public Interest Disclosure Act (PIDA) offers protection for whistleblowers who speak up. If you wish to find out more about PIDA, Protect offer a guide which can be found on their website https://protect-advice.org.uk

The CISI are committed to supporting concerns that are raised internally, and hope you feel able to follow this internal policy rather than reporting to an external body. However, we recognise that there may be circumstances where you may wish to approach an external regulator. If this is the case, we encourage you to contact Protect, an external whistleblowing charity who run an advice line for employees, who will be able to provide advice and guidance. You can visit the website at https://protect-advice.org.uk or call the advice line on +44 (0)20 3117 2520