Surface Matter Whistleblowing policy

Whistleblowing policy

Surface Matter is committed to being open, honest and accountable and complying with its legal obligations. We want a free and open culture in the Board, Management and the rest of the team.

It is important that any concerns a team member has about any part of Surface Matter, the way the business is run or potential fraud, misconduct or wrongdoing has taken place, is reported and properly managed quickly.

All team members, including temporary staff and contractors or suppliers should raise any real concerns about wrongdoings within the business with confidence they will be taken seriously and fully investigated without having to worry about being victimised, discriminated or disadvantaged as a result.

This whistleblowing policy covers concerns that fall outside the scope of our Grievance policy, which allows team members to raise issues about their own employment concerns including but not limited to unfair treatment, injustice, discrimination, harassment and bullying. Any concerns about wrongdoing that qualifies under the Public Interest Disclosure Act (PIDA) should be raised. PIDA provides legal protection against dismissal or penalty from publicly disclosing serious concerns.

These concerns may include:

  • Conduct likely to harm Surface Matter
  • Breaches of company policies
  • Violating criminal or civil laws, rules or regulations
  • Endangering anyone’s health and safety
  • Improper conduct or unethical behaviour
  • Environmental damage
  • The deliberate concealment of any malpractice

If a team member has a genuine and reasonable belief of malpractice within Surface Matter currently, previously, or likely to happen in the future, they must raise their concern.

Confidentiality and protection

Surface Matter will protect team members who disclose a concern provided that the concern is made reasonably and in good faith that any allegations or information disclosed are true.

Surface Matter will protect the whistleblower’s identity as far as is possible. During the investigation process Surface Matter may be required to reveal identities under a legal obligation, which may be to the police or external body, like solicitors, to get advice. Any identity disclosure will be conducted strictly confidentially, and all disclosures will be taken seriously and treated fairly.

Disciplinary action will be taken against any team member deliberately raising false and malicious allegations.

If a team member has a genuine and reasonable concern they should inform their Manager immediately. If the concern is about the actions of their Manager, they should raise the matter directly with a Director.

Team members are encouraged to raise their concerns in writing where possible, setting out the background and history of their concerns (giving names, dates and places where possible) and indicating the reasons for their concerns. They must state that they are using the Whistleblowing Policy and specify if they want to keep their identity confidential.

The relevant Manager or Director will consider the disclosure and will report the matter to the Board member if necessary. Action taken by Surface Matter will depend on the seriousness of the allegation and:

  • Where appropriate, Surface Matter will conduct a proper investigation and make an objective assessment of the concern.
  • The team member will be kept informed of progress.
  • Surface Matter will ensure that necessary action is taken (i.e. referral to the police or to funded partners)


A director will determine if an investigation is appropriate for any allegations, and they may need more information from the whistleblower for this. Whistleblowers will be informed when initial queries have been made and whether further investigation will take place, or a reason why no action is taken.

Investigations will be conducted by an appropriate Director and their findings will be reported to the Board who will make the final decision. During the investigation, it may be needed to follow the procedures from other policies such as the disciplinary, grievance, bullying and harassment policies. Where these procedures are referred to, the person who has had an allegation made about them will be informed of the name of the person who made the complaint and the nature of the allegation(s).

If you continue to have serious concerns after the investigation has been completed and feel that you need to contact an external agency, you can.

There is a list of prescribed companies disclosures can be made to (Public Interest Disclosure Act 1998, as amended by the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2003

You can seek advice before raising a concern by contacting Public Concerns at Work, a registered charity that advises on serious malpractice within the workplace

Protecting the individual raising the concern

When a team member raises a concern in good faith, Surface Matter will take action to protect them from any harassment, victimisation or bullying. Individuals who raise a genuine concern under this policy will not be at risk of losing their job, or any unrelated disciplinary action.

If a team member believes they are being subjected to any disadvantage within the workplace because they’ve raised concerns under this procedure, they should inform their Manager or a Director immediately. Team members who victimise or retaliate against whistleblowers under this policy may be subject to disciplinary action. We will try to treat the matter confidentially where possible if the individual requests it and their name or position will not be revealed without permission unless required by law. If the concern cannot be resolved without revealing identity, a Director will discuss how to proceed. Depending on the nature of the complaint, the police or an external authority may need to be notified or involved during or after our investigation.

Disclosures made under this policy may involve highly confidential and sensitive matters and team members may prefer to make an anonymous disclosure. However we cannot guarantee all anonymous allegations will be investigated as this could be without further information, feedback or confirmation of good faith. It is better for whistleblowers to reveal their identity and measures will be taken to keep confidentiality where possible.

If an investigation finds that a disclosure was made maliciously, in bad faith or for personal gain, the whistleblower will not be protected by this procedure and Surface Matter will take appropriate disciplinary action against them. This may constitute gross misconduct and could lead to summary dismissal. Whistleblowers will not be protected from making a disclosure if, by doing so, they commit a criminal offence. Those making disclosures anonymously or without following this policy will not be protected by this procedure.