Whistle-blowing, Complaints and Reports procedures

Members and associates are required to bring to the attention of the Committee any potential incident, abuse or concern that they witness, are made aware of, or suspect which appears to breach the Standards contained in this Code of Conduct. Such concerns shall be protected by a policy of absolute confidentiality being afforded to whistleblowers.

Any complaints or concerns relating to a breach of this Code should be reported immediately to the Secretary.  If not felt appropriate to report to the Secretary (for example concerns that the report will not be taken seriously, or that the Secretary is implicated in the concern) then they may be reported to any other appropriate member of the Committee.

Members receiving reports or concerns are obliged to report the matter without delay to the appropriate authorities or to the Secretary who will ensure that the matter is referred onwards. Where such matters may suggest that a child or vulnerable person may be a risk of harm or that an offence has been committed, the matter must be referred to the police without delay.

Investigation of complaints

Any complaints about the conduct of a member or associate shall be investigated by an impartial and independent party (“the investigator”) appointed by the Committee.

The investigator shall act in accordance with the principles of natural justice and fairness. The investigation will be inquisitorial in character. The investigators task is to establish the facts of the case and to report these, along with his/her conclusions as to whether or not there has been a breach of the Code of Conduct. Any complaint must also be supported by evidence sufficient to establish a prima facie case that the Code has been breached.

The investigator shall report his/her findings in the following form:

  • summary of the initial complaint and of the relevant elements of the Code of Conduct;
  • brief account of the key facts in the case, with references to evidence as appropriate and with any contested points of fact highlighted;
  • his findings with reasons as to whether or not the Code has been breached; 
  • any evidence, written and oral; and
  • a recommendation as to what action, if any, should be taken.

Members or associates are expected to co-operate with any investigation into their conduct. They should supply written evidence as requested. They can be accompanied to any meeting by a colleague, friend or legal adviser, but every effort should be made to keep proceedings informal. If they choose to bring a colleague, friend or adviser they are free to consult him or her off the record, but will be expected to answer in person any questions put to them.