The C3 Church

The C3 Church has a whistleblowing policy to ensure that any concerns about wrongdoing, misconduct, or illegal activities within the church can be reported safely and confidentially. This policy protects whistleblowers from retaliation and ensures that all reports are properly investigated and addressed in line with our ethical and legal responsibilities.

Please read this policy to know whether your concern is best addressed by the Whistleblowing Policy. Otherwise, you may need to use one of our other avenues to raise a concern.

Whistleblowing policy

Version Updated March 2025

1. Scope

We are committed to conducting our work and service with openness, honesty, integrity and accountability. We actively encourage a free and open culture in all dealings between members of the congregation, volunteers, staff, Trustees and workers.

Tackling problems is vitally important to maintaining a healthy culture within the C3 Church; in maintaining and living out our values and beliefs; and in achieving our charitable objectives and aims. Any suspected wrongdoing should therefore be reported as soon as possible.

This policy aims to help cover all employees, volunteers, Trustees, interns, Academy students, and workers to raise any serious concerns they may have about colleagues or anything taking place in the C3 Church with confidence and without having to worry about being victimised, discriminated against or disadvantaged in any way as a result.

This policy does not form part of any employee's contract of employment and we may amend it at any time.

This policy does not cover safeguarding concerns or allegations about staff or volunteers, which are addressed in our Safeguarding Policy. If a concern does not fall under the specific parameters of this policy, it should be addressed under our Complaints Policy. Complaints by staff in relation to their employment or role should be addressed through our Grievance Procedure, Complaints by volunteers in relation to their role or area of service should be addressed through our Problem Solving Procedures.

2. What is whistleblowing?

Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our activities.

Examples include, but are not limited to:

bribery
facilitation of tax evasion
fraud or other criminal activity
miscarriages of justice
health and safety risks
damage to the environment
any breach of legal or professional obligations
sexual, physical, or verbal abuse, or bullying or intimidation of employees, customers or service users
abuse of authority
spiritual abuse
other unethical conduct
concealment of any of the above

You do not need 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 of being, having been, or likely to be carried out.

3. How to raise a concern

We hope that in many cases you will be able to raise any concerns with your line manager, or team leader, or someone representing the C3 Church in a leadership role. Once you have raised your concerns, you may be advised to follow a different procedure, such as our Grievance Procedure, our Safeguarding Policy, or our Anti-Harassment and Bullying Policy. Alternatively, you may be advised to make your concerns more formal and to follow the procedure outlined below.

If you have a reasonable belief that an act is being, has been, or is likely to be, committed you should report your allegation to the Whistleblowing Officer. You should do this by completing the online Whistleblowing Form. If you are unable to access this online Form you should email whistleblowing@theC3.uk and assistance will be provided to complete the Form.

The Form asks you to provide as much detail in your report as possible including

Your name and suitable contact details.
What is your role at the C3 Church? If you no longer work for the C3 Church, please tell us when you left.
Are you an employee or a volunteer within the C3 Church?
What is alleged to have happened and when/where?
Who has been affected by the case, or incident and how have they been affected?
Who else witnessed the event, who is aware and what has been done about it?
Who else knows that you have reported the matter?
What are your wishes concerning anonymity?

We recognise that the decision to make an allegation can be a difﬁcult one to make. However, whistleblowers who make serious allegations in the reasonable belief that it is in the public interest to do so should have nothing to fear because they are doing their duty either to the Church and/or to those for whom the Church or they are providing a service.

4. Confidentiality

We hope that individuals will feel able to voice whistleblowing concerns openly under this policy. Completely anonymous disclosures are difficult to investigate. However, if you want to raise your concern confidentially, we will make every effort to keep your identity secret and only reveal it where necessary to those involved in investigating your concern.

5. Procedure

Once an allegation has been raised to the Whistleblowing Officer, discussions will be held with appropriate individuals in either the Senior Leadership Team, including the Senior Pastors, or, where relevant, amongst the Trustees. The purpose of the discussions will be to identify the most appropriate course of action depending on the nature of the allegations and those implicated by the allegations. We will at all times maintain appropriate levels of confidentiality during these discussions

In all cases where an allegation is considered to be serious, the Trustees will be notified. The Trustees may determine to handle the concern themselves; may delegate the investigation and management of the concern to appropriate individuals within the Senior Leadership Team; or they may appoint an external party to assist in handling the concern/allegation.

It is likely that most allegations will require an investigation to be carried out. This investigation may involve the individual making the allegation attending an initial investigative meeting to understand and learn more about the nature and details of the allegation. That individual may be accompanied to the meeting for support, but it is important to ensure that companion also respects the confidentiality of the allegation or disclosure and any subsequent investigation.

The investigation may follow further meetings, or for an outcome to be confirmed in a written report. We accept that whistleblowers need to be assured that the matter has been properly addressed and therefore, subject to legal constraints, we will endeavour to keep updated those making allegations of the procedure that is being followed, and where appropriate, the outcome of any investigation.

6. Outcomes

Typically, the matters raised may result in one or more of the following outcomes:

no action required
action being taken under another policy or procedure
an internal investigation under this policy
a referral to the police or other relevant statutory body
referral to the Trustees
a referral to the C3 Church’s external auditors
a Serious Incident Report being made to the Charity Commission
an independent enquiry
It may be necessary for the whistleblower to give evidence in criminal or disciplinary proceedings

7. External disclosures

The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing within the C3 Church. In most cases you should not find it necessary to alert anyone externally.

The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. We strongly encourage you to seek advice before reporting a concern to anyone external. Protect operates a confidential helpline. You may also make contact with the Charity Commission. Their contact details are at the end of this policy.

8. Protection and support for whistleblowers

We aim to encourage openness and will support whistleblowers who raise genuine concerns under this policy, even if they turn out to be mistaken.

Pastoral support, advice and guidance will be given to whistleblowers as appropriate.

Whistleblowers must not suffer any detrimental treatment as a result of raising a genuine concern. If you believe that you have suffered any such treatment, you should inform the Senior Pastors immediately, or where such a concern relates to them, to a Trustee. You will be advised of the most appropriate procedure to follow in relation to your concern and what this will involve.

No individual must threaten or retaliate against whistleblowers in any way. If we believe you are involved in such conduct you may be subject to disciplinary action. For employees, this will involve our Disciplinary Procedure, and for others, including members of the congregation or volunteers, this could involve in serious cases you being asked to leave the Church.

Equally, if we conclude that a whistleblower has made false allegations maliciously or vexatiously, the whistleblower may be subject to disciplinary action and/or in serious cases asked to leave the Church.

9. Monitoring and reviewing

All formal complaints and responses made to The C3 Church will be recorded and filed in a secure place in accordance with our Data Protection Policy.

This Policy will be reviewed annually to ensure it is up to date and continues to be fit for purpose.

10. Useful Contact Details

The C3 Church

whistleblowing@thec3.uk

Protect

Independent whistleblowing charity

Helpline:  020 3117 2520

Website: https://protect-advice.org.uk/contact-protect-advice-line/

Charity Commission

whistleblowing@charitycommission.gov.uk

The C3 Church Whistleblowing Policy