Whistleblowing Policy

Updated November 2025

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Purpose of this Policy

Highlands Innovation CIC is committed to operating with integrity, transparency and accountability. This Whistleblowing Policy provides a clear framework for raising serious concerns about wrongdoing, misconduct or risks within or connected to our organisation, without fear of victimisation or detriment.

What is Whistleblowing?

Whistleblowing is when a person raises a concern about suspected wrongdoing or dangers in relation to our activities, projects, governance or conduct. This may include issues that:

• are unlawful, dishonest or fraudulent;
• breach legal, regulatory or safeguarding duties;
• pose a risk to the safety or wellbeing of individuals or the wider community;
• involve serious misuse of funds or resources;
• attempt to conceal or cover up wrongdoing.

Whistleblowing is different from a personal complaint or grievance, which is usually about an individual’s own situation and is handled under other procedures.

Our Commitment to Whistleblowers

We encourage people to speak up if they have genuine concerns. We will:

• take concerns raised under this Policy seriously and consider them fairly;
• treat whistleblowers with respect and, where possible, handle concerns confidentially;
• not tolerate victimisation, retaliation or unfair treatment of anyone who raises a concern in good faith;
• seek to address issues promptly and proportionately.

Who Can Raise a Concern?

This Policy applies to:

• staff, volunteers, trustees and contractors working with or on behalf of Highlands Innovation CIC;
• partners, suppliers or collaborators who become aware of serious concerns relating to our activities;
• others who have a credible reason to believe there is significant wrongdoing connected to our work.

Examples of Concerns

Concerns that may be raised under this Policy include, but are not limited to:

• fraud, financial irregularity or misuse of funds;
• serious breaches of safeguarding duties;
• criminal activity or failure to comply with legal obligations;
• serious health and safety risks;
• deliberate concealment of wrongdoing;
• serious breaches of our Ethical Conduct Policy.

How Concerns Are Handled

Concerns raised under this Policy will be reviewed by an appropriate senior person or governance lead within Highlands Innovation CIC. Depending on the nature of the concern, this may involve:

• gathering further information and clarifying the issue;
• conducting an internal review or investigation;
• seeking external professional or legal advice;
• referring matters to relevant external bodies or authorities where required.

Where appropriate and lawful, we will aim to keep the whistleblower informed of the progress and outcome of the matter.

Confidentiality

We will treat whistleblowing concerns as sensitively and confidentially as possible. Information will be shared only with those who need to know in order to consider or investigate the concern. In some circumstances, it may not be possible to maintain complete confidentiality if legal or safeguarding duties require disclosure.

Malicious or Vexatious Allegations

Concerns raised in good faith will be supported, even if they are not upheld. However, deliberately false, malicious or vexatious allegations may be considered a serious matter and dealt with under appropriate procedures.

Review of this Policy

We will review this Whistleblowing Policy periodically to ensure it remains effective, proportionate and aligned with good governance practice. Updates will be indicated by the “Updated” date at the top of this page.