At Project Access (PA), we aim to conduct ourselves ethically, and with honesty and integrity. We expect the same high standards from all our people: volunteer team members, mentors, and mentees. We do, however, recognise that there may be occasions when we do not get this right. In these instances, you may feel that you need to raise your genuine and serious concerns through this whistleblowing policy.

‘Whistleblowing’ refers to the internal or external disclosure of malpractice as well as illegal acts, or omissions, at work. It covers, for example, how we raise funds, how we commission work, make payments, and allocate funding.

Goals and Scope

The aims of this policy are to:

1. Provide an effective way for you to raise serious concerns,
2. Ensure that you receive feedback on any action undertaken by us as a result of you raising serious concerns,
3. Ensure that you will be supported and protected from reprisals or victimisation for having raised your concern in good faith,
4. Signpost you to further options available to you if you are dissatisfied with our response, or if internal investigation is not appropriate,
5. Allow Project Access to take action against any volunteer who makes allegations in bad faith and/or publicly discloses information when it is unreasonable for them to do so.

This policy applies to anyone who volunteers for PA (Project Access International and any of its subsidiary organisations) as a mentor or team member, or anyone who is otherwise affiliated with PA, including mentees.

What Is a Disclosure?

Under the law, volunteers are not afforded the same whistleblowing protection that is afforded to employees. However, at PA we want to promote and encourage an open and honest environment in which concerns can be freely raised. We will therefore, in so far as is possible, aim to treat all individuals making a disclosure in the spirit of the law governing employees, specifically the Public Interest Disclosure Act 1998.

The Public Interest Disclosure Act 1998 amended the Employment Rights Act 1996. These laws provide protection for individuals who raise legitimate concerns about specified matters, called qualifying disclosures. A qualifying disclosure is a disclosure made in good faith by an individual who has a reasonable belief that any of the following have occurred:

1. A criminal offence (including fraudulent and corrupt behaviour, theft, fraud or malpractice);
2. A miscarriage of justice;
3. An act creating risk to health and safety;
4. An act causing damage to the environment;
5. A breach of any other legal obligation; or
6. Concealment of any of the above.

It is not necessary for you to have proof that such an act is being, has been, or is likely to be, committed. You do, however, need to hold a reasonable belief of such an action having been, being or likely to be carried out.

If you make a protected disclosure, you have the right not to be dismissed, subjected to any other detriment, or victimised. This is true even if you were genuinely mistaken. We will not tolerate any individual being disadvantaged because they made a disclosure in good faith.

Malicious Disclosures

If it is found that you have maliciously raised a matter you know to be untrue, or you are involved in wrongdoing (including cover-ups), this policy will not apply and your conduct may be dealt with under other PA procedures.

Non-Whistleblowing Concerns

This policy is only for the qualifying disclosures above. Other concerns should follow relevant PA policies such as:

• Safeguarding Policy
• Privacy Policy
• Slack Codes of Conduct

Raising a Concern Internally

How Should I Raise It?

You should raise your concern as soon as possible. Written disclosures are preferable. In your disclosure, please:

1. Provide relevant background (dates, names, where the concern arose, etc.);
2. State clearly why the situation causes concern;
3. Include your preferred method of communication;
4. Say that you are raising the concern under the whistleblowing policy and whether you want your identity kept confidential.

We consider anonymous disclosures, but do not encourage them because they can hinder investigation and feedback.

Who Should I Raise It With?

PA team members – raise the matter with your immediate leader (Global Director, Country Team Lead, DSL, or CEO as appropriate). If the concern involves that person, choose another senior leader.

Mentors & mentees – email support@projectaccess.org. If the concern involves a PA team member, email the CEO, Lukas Popp, at lukas.popp@projectaccess.org.

What Happens After I Raise a Concern?

Your disclosure will be acknowledged promptly and investigated. The investigator may request your consent to share details with others as needed. You will be informed of the outcome or next steps. If you disagree with the decision, you may object within 14 days by emailing support@projectaccess.org.

Outcomes may include: no action, action under another policy, internal investigation, or referral to police or regulators.

Raising a Concern Externally

Please exhaust internal processes first. In exceptional cases you may disclose to an external body (e.g., the Charity Commission). If you do, notify PA at support@projectaccess.org.

Making a Disclosure to the Press / Social Media

Public or social-media disclosures that are defamatory, malicious, or bypass internal procedure may be treated as misconduct and could lead to disciplinary action.

Related Policies and Procedures

• Privacy Policy: Data Collection, Sharing, Processing, Retention, Security, Your Rights
• Safeguarding Policy: Definitions, Roles, Responding to Concerns, DBS Referrals

Policy Updates and Responsibility

PA may update this policy at any time; the latest version will appear on the PA website. All mentors, mentees, and team members are responsible for reviewing updates.

Contact Details

• Designated Safeguarding Lead: Katie Na — dsl@projectaccess.org
• PA Country Teams: see Appendix addendums — support@projectaccess.org
• Chief Executive Officer: Lukas Popp — lukas.popp@projectaccess.org
• NSPCC Helpline: +44 808 800 5000