AJA is committed to the highest standards of transparency, probity, integrity and accountability and this Whistleblowing Policy sets out the framework for dealing with allegations of malpractice.

1. Purpose
   • This policy is intended to provide a means for AJA employees, members, candidates, affiliates to raise genuine concerns about malpractice in the workplace (if they believe it is in the public interest to do so). It is defined in a way that will ensure confidentiality, protecting those making such allegations to do so free from reprisals, in the knowledge they will be protected from being victimised, discriminated against, or disadvantaged in any way.
   • Further, this procedure is intended to ensure that AJA complies with its duty under the Public Interest Disclosure Act 1998.

2. Scope
   • This policy applies to everyone associated with employees, members, candidates, affiliates supporting the work of AJA.
   • This policy does not replace other policies such as the Complaints, Grievance, and Ethics and Practice Policies. Neither does it replace other specifically laid down reporting procedures such as the Health and Safety Policy.
   • This policy covers the release of information relating to alleged wrongdoing in the public interest. It does not cover personal grievances. The AJA grievance policy continues to be the appropriate way to raise personal issues relating to the specific job or employment.  If it’s a personal problem only it will not be covered by whistleblowing. You might be able to resolve the problem another way. Qualifying disclosures can include: a criminal offence, the breach of a legal obligation by an organisation, a miscarriage of justice, someone’s health and safety being in danger, or damage to the environment. You can whistle blow about anyone trying to cover up information about such matters.
   • If you have a genuine concern and reasonable belief it is in the public interest, even if it is later discovered that you are mistaken, under this policy you will not be at risk of losing your job or from suffering any form of retribution as a result.
   • Protection will not be extended to an individual who maliciously raises a matter they know to be untrue; or who is anyway involved in the malpractice. Those found to be making false allegations maliciously will be subject to disciplinary action. This may result in action up to (and including) dismissal.
   • This policy does not form part of an employee’s terms and conditions of employment and may be subject to change at the discretion of management.
   • Malpractice includes (but is not limited to) the issues listed below:

• Committing a criminal offence (both local and international)
• Sexual misconduct, including sexual abuse, harassment, or exploitation (see AJA safeguarding policy).
• Abuse or exploitation of beneficiaries, children, and vulnerable adults (see AJA safeguarding policy).
• Breach of AJA’s Ethics and Practice Policy.
• Financial wrongdoing, including theft, bribery, fraud, money laundering and aid diversion.
• A failure to comply with any legal obligations.
• Danger to the health and safety of individuals, or damage to the environment.
• Abuse of position, improper conduct, or unethical behaviour.
• Any activity which would bring the organisation into serious disrepute.
• The deliberate concealment of information relating to any of the matters listed above.

3. Process
   • You should in the first instance report your concerns to a member of the Ethics and Professional committee who will deal with the matter in confidence.
   • Alternatively, if you feel uncomfortable with reporting in this manner, then you can raise your allegation in confidence to any member of the AJA Council.
   • At the point of raising a concern it would be useful for you to share information describing (Appendix 1):

• Whether anyone is at immediate risk of harm
• What has actually happened? Provide notes of dates, times, people and places.
• Who is involved?
• How do you know about it?
• When were you first concerned about it?
• Have you told anyone about it?
• Was any action taken?
  • At this point, the EPC or AJA Council member should:
• Decide on whether it is appropriate to handle such complaints under this policy.
• Report issues of malpractice to the Chair, who will initiate an investigation.
• the contact point will instigate the critical incident procedure, if sufficiently serious malpractice (safeguarding, etc) is alleged.
• Inform the complainant promptly of any action taken.
  • You (the complainant) will be notified once the matter has been resolved, but outcomes are subject to confidentiality and may not be communicated.
  • If you remain dissatisfied with the explanation or reason given to you, you may raise the matter with any member of the AJA Council or an AJA Trustee.
  • However, if you do not wish to raise your concerns with anyone within the organisation, you may take them directly to an appropriate organisation or body, e.g. The Charity Commission, the Police, the Environment Agency, Health and Safety Executive or Social Services Department.
  • The Chair will report annually to the AJA AGM on the operation of the procedure and on any allegations made during the period covered. The report will be in a form which retains the anonymity of complainants.

4. Frequently asked questions

What if a member of the EPC/ AJA Council is involved in the alleged malpractice?

Matters should be raised with the AJA Chair or an AJA trustee, an external body, or via the external hotline.

Can the disclosure be made anonymously?

You are strongly encouraged not to make anonymous disclosures as details cannot be checked with you. This may seriously limit the ability of investigators to pursue your concerns. Nonetheless, all disclosures, made anonymously or otherwise, will be reviewed.

Who will conduct the investigation?

Normally an independent person from within AJA will be appointed. On rare occasions, or for complex cases (safeguarding, etc), external investigation support may be sought.

What if the matter involves a criminal offence?

The issue must also be reported to the police if a criminal offence, such as fraud or theft, or sexual assault has been committed.

What if the matter is a complaint about the performance/behaviour of a manager/member/candidate/associate/contractor or affiliate against me?

Such complaints will be directed for action to the appropriate AJA policy unless the concerns relate to a form of malpractice listed in this policy.

Appendix 1

Malpractice – Initial report form

April 2024
updated 2025