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1. Introduction

This policy applies to all workers of VisitScotland, including off-payroll workers e.g. contractors.

At VisitScotland we are committed to conducting our work with honesty and integrity and we expect all staff to operate in accordance with our values – respectful, accountable, curious, knowledgeable and ambitious.

However, all organisations carry a risk that things may go wrong from time to time and it is important that any fraud, misconduct or wrongdoing by workers of the organisation is reported and properly dealt with.

At VisitScotland we encourage all workers to raise any concerns that they may have about the conduct of others in the business, or the way in which the business is run, as soon as possible. This is known as whistleblowing.

All concerns will be taken seriously and investigated as appropriate. Workers can raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.

This policy sets out the way in which individuals may raise any concerns that they have and how those concerns will be dealt with.

2. Purpose and scope

Workers are defined as:

  • Employees of VisitScotland
  • non-executive Board members
  • Those working under contract (e.g. consultants and self-employed contractors), and agency staff

The policy references "the law". Applicable items of legislation are:

  • The Employment Rights Act 1996 (ERA)
  • The Public Interest Disclosure Act 1998
  • The Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2018 (Statutory Instrument 2018 No.795).
  • The Enterprise and Regulatory Reform Act (ERRA) 2013
  • Worker Protection Act 2024
  • Data Protection Act 2018/UK GDPR

The Employment Rights Act 1996 provides legal protection for workers who raise legitimate concerns about specified matters. These are called "qualifying disclosures".

A qualifying disclosure means disclosure of any information which in the reasonable belief of the worker is made in the public interest and tends to show that one or more of the following has occurred, are occurring or is likely to occur:

  • criminal activity
  • miscarriage of justice
  • danger to health and safety
  • environmental damage
  • a breach of any legal obligation
  • deliberate concealment of any of the above
  • Sexual harassment (to be included as a legal requirement from 1 April 2026)

Whistleblowing may also include disclosure of information which relates to:

  • bribery (under VisitScotland’s Anti-bribery and Corruption Policy)
  • facilitating tax evasion (contrary to VisitScotland’s Anti-Criminal Finance Policy)
  • financial fraud or mismanagement (under VisitScotland’s Fraud Policy)
  • breach of VisitScotland’s internal policies and procedures
  • conduct likely to damage VisitScotland’s reputation or
  • unauthorised disclosure of confidential information.

It is not necessary for the worker to have proof that such an act is being, has been, or is likely to be, committed - a concern is enough. The worker has no responsibility for investigating the matter - it is the organisation's responsibility to ensure that an investigation takes place.

A worker who makes a disclosure has the right not to be dismissed, subjected to any other detriment, or victimised because they have made a disclosure.

A worker has the right to make a disclosure from day one of employment. A worker can also make a disclosure, even if they no longer work for the organisation.

The organisation encourages workers to raise their concerns under this Whistleblowing Policy in the first instance. If a worker is not sure whether to raise a concern, they should discuss the issue with their line manager or contact the Chief People and Culture Officer and/or the Head of Legal.

This policy should not be used for complaints relating to an employee's own personal circumstances, such as the way they have been treated at work. If a worker is concerned that their own contract has been, or is likely to be, broken, they should refer to the VisitScotland Grievance Policy.

​​​​​​​3. Principles

Everyone should be aware of the importance of preventing and eliminating wrongdoing at work. Workers should be watchful for illegal or unethical conduct and report anything of that nature that they become aware of.

Any matter raised under this procedure will be investigated thoroughly and promptly, and the outcome of the investigation reported back to the worker who raised the issue.

No worker will be victimised for raising a matter under this procedure. This means that the continued employment and opportunities for future promotion or training of the worker will not be prejudiced because they have raised a concern.

Victimisation of a worker for raising a qualified disclosure will be a disciplinary offence.

If misconduct is discovered because of any investigation under this procedure the organisation's Disciplinary Policy will be used, in addition to any appropriate external measures.

Maliciously making a false allegation is a disciplinary offence. 

An instruction to cover up wrongdoing is itself a disciplinary offence. If told not to raise or pursue any concern, even by a person in authority such as a manager, workers should not agree to remain silent, they should report it.

If a member of staff has concerns they should speak to a member of the HR team or a member of the PCS union staff group.

4. Confidentiality and anonymity

This policy encourages employees to put their name to their allegation whenever possible. If employees do not tell us who they are it may be more difficult for us to investigate their concern, provide appropriate protection and support to them or to give them feedback.

It is also more difficult to establish whether any allegations are credible. If employees wish to raise a concern confidentially, we will make every effort to keep their identity confidential. If it is necessary for anyone investigating their concern to share their identify with others we will discuss this with them.

We encourage anonymous reporting over remaining silent. Although we will investigate any concern that is reported anonymously as best we can, an anonymous report is likely to be more difficult for us to investigate and we will not be in a position to provide employees with any feedback.

If disciplinary or other proceedings follow the investigation, it may not be possible to act because of their disclosure without their help, so they may be asked to come forward as a witness. If they agree to this, they will be offered advice and support.

Whistleblowers who are concerned about possible reprisals if their identity is revealed should come forward to the Chief People and Culture Officer and appropriate measures can then be taken to preserve confidentiality.

If employees are in any doubt, they can seek advice from Protect, the independent whistleblowing charity, who offer a confidential helpline, www.protect-advice.org.uk, telephone 020 3117 2520. 

5. The process

Who should employees raise a concern with?

In the first instance, and unless the worker reasonably believes their line manager to be involved in the wrongdoing, any concerns should be raised with the worker’s line manager.

If they believe the line manager to be involved, or for any reason do not wish to approach their line manager, then the worker should notify the next most senior member of staff or their head of department.

If exceptionally, the concern is raised about their director then they should raise their concern with the Chief Executive. If exceptionally, the concern is raised about the Chief Executive then the concern should be raised with the Chair.

Any approach will be treated with the strictest confidence and the worker's identity will not be disclosed without their prior consent.

How to raise a concern

Employees may raise a concern by telephone, in person or in writing. The earlier they express a concern, the easier it is to act. Employees should provide the following:

  • The nature of their concern and why they believe it to be true.
  • The background and history of the concern (including any relevant dates).

In advance of raising a concern, they may wish to consider discussing the situation with a work colleague or trade union representative. They can accompany employees to any meetings or be included in any telephone conversations.

What will VisitScotland do?

When a line manager or appropriate manager is notified of potential wrongdoing, the line manager or appropriate manager will write to an employee within seven working days of the concern being raised, to acknowledge the concern has been received.

We will indicate how VisitScotland proposes to deal with the matter and supply employees with any information on support that is available to them.  If an investigation is to take place employees will be informed.

When investigating a concern, the manager appointed as lead investigator may have to speak to employees on one or more than one occasion to gather relevant facts. If this is the case, they will be invited into a meeting to discuss the concern and clarify information about it.

HR will be present at these meetings and workers will be advised that they have the right to be accompanied by a companion (either a trade union representative or a work colleague). This companion must respect the confidentiality of the disclosure and any subsequent investigation.

Depending upon the nature of the concern this meeting can be arranged away from the workplace.

The worker’s statement will be considered, and they will be asked to comment on any additional evidence obtained.

The lead investigator (or the person who carries out the investigation) will then report their findings in writing to the Chief People and Culture Officer and the Director of Corporate Services, who will take any necessary action.

This action may include following anti-bribery or fraud processes, if appropriate, and/or reporting the matter to any appropriate government department or regulatory agency.

If disciplinary action is required, the lead investigator (or the person who carried out the investigation) will take this matter forward with the People and Culture Department and the Disciplinary Policy will be applied.

We will aim to keep employees informed of the progress of the investigation and the expected timescale. However, sometimes the need for confidentiality may prevent us giving their specific details on the investigation or any disciplinary action taken as a result.

On conclusion of any investigation, the worker will receive an outcome letter summarising what the organisation has done, or proposes to do, about it. The worker will receive this outcome letter within three months of the disclosure date.

If no action is to be taken, the reason for this will be explained. Employees should treat any information about the investigation and the outcome letter as confidential.

What happens if I do not feel the matter has been dealt with appropriately?

If the worker is concerned that their line manager or lead investigator has failed to instigate a disclosure or has failed to take the matter seriously, they should inform a senior member of staff or head of department who will arrange for another manager to review the investigation carried out, make any necessary enquiries and compile a report in writing to the Chief People and Culture Officer and the Director of Corporate Services, as outlined above.

If, on conclusion, the worker reasonably believes that the appropriate action has not been taken, they should report the matter to the proper authority. We encourage employees to seek advice before reporting a concern to anyone external. The independent whistleblowing charity, Protect, operates a confidential helpline. They also have a list of prescribed regulators for reporting certain types of concern. These include:

  • Commissioners for HM Revenue and Customs
  • Financial Conduct Authority (formerly the Financial Services Authority)
  • Competition and Markets Authority
  • Health and Safety Executive
  • Environment Agency
  • Serious Fraud Office
  • Audit Scotland

Find further information on prescribed regulators on the UK Government website.

Whistleblowing concerns usually relate to the conduct of our staff, but they may sometimes relate to the actions of a third party, such as a supplier.

In some circumstances the law will protect employees if they raise the matter with the third party directly. However, we encourage employees to report such concerns internally first. They should contact their line manager or Head of Procurement for guidance.

6. Monitoring and review

This policy will be reviewed every three years, or sooner dependent on legislative change.

The Whistleblowing Policy will be sent to the following groups for comment and/or approval.

  1. PCS VisitScotland representative group – for information/comment
  2. VisitScotland Heads of Department – Leadership Group – for consultation
  3. VisitScotland Executive Leadership Group – for recommendation for Board approval
  4. VisitScotland Board – final approval

All VisitScotland policies will be published on the Hub, which ensures they are accessible to all staff.

Training will be provided to senior staff (HODs and Executive Leadership Group) to ensure  they understand their role in responding to, and acting upon, whistleblowing.  Training for all employees, and line managers is available via Virtual College.

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