Whistleblowing Policy

Policy Statement:

Altar of Earth is deeply committed to fostering an open, honest, and accountable environment where integrity and ethical conduct are paramount. We recognise that individuals may, from time to time, become aware of serious concerns regarding malpractice, wrongdoing, or risks that could affect our participants, staff, volunteers, the public, or the reputation of Altar of Earth. This Whistleblowing Policy (also known as a "Speak Up" policy) provides a safe, confidential, and clear mechanism for all individuals to raise such concerns without fear of reprisal, adhering to the legal protections and best practices in both the United Kingdom (UK) and the United States (US).

Our mission to connect to ancestral ties and nature for mental well-being requires a foundation of trust. We believe that empowering individuals to speak up about genuine concerns is vital for safeguarding our community, maintaining high standards, and upholding our values. This policy ensures that serious issues are brought to light and addressed promptly and appropriately, promoting transparency and accountability across all our operations.

1. Scope

This policy applies to all individuals associated with Altar of Earth, including:

  • Employees (paid and unpaid)

  • Volunteers

  • Contractors and Consultants

  • Board Members

  • Any other individual acting on behalf of Altar of Earth.

It covers concerns relating to any aspect of Altar of Earth's operations, conduct, or practices, wherever they occur (online or in person).

2. Guiding Principles

Our Whistleblowing Policy is founded on the following core principles:

  • Openness and Transparency: We encourage individuals to raise genuine concerns openly.

  • Protection from Retaliation: Individuals who raise concerns in good faith will be protected from any form of detriment, victimisation, or unfair treatment.

  • Confidentiality: Every effort will be made to protect the identity of the whistleblower, where requested, consistent with the need to conduct a thorough investigation.

  • Fairness and Impartiality: All reported concerns will be investigated fairly, objectively, and promptly.

  • Accountability: Individuals found to have engaged in wrongdoing will be held accountable, and necessary corrective actions will be taken.

  • Learning and Improvement: We will learn from any issues raised through whistleblowing to continuously improve our practices and governance.

3. What is Whistleblowing / Types of Concerns Covered

Whistleblowing, or "making a protected disclosure," involves raising a genuine concern about a serious wrongdoing or risk. This policy covers concerns relating to:

  • Criminal Offences: e.g., fraud, theft, bribery, other illegal activities.

  • Failure to comply with Legal Obligations: e.g., breaches of health and safety law, data protection law, safeguarding regulations, or environmental regulations.

  • Miscarriages of Justice.

  • Risk to Health and Safety: e.g., unsafe practices or environments, particularly in our nature-based activities.

  • Damage to the Environment.

  • Safeguarding Concerns: Any abuse, neglect, or harm (or risk of harm) to children or vulnerable adults.

  • Malpractice or Unethical Conduct: e.g., unethical financial practices, conflicts of interest, serious breaches of our Code of Conduct.

  • Attempts to Conceal any of the above.

This policy is not for raising personal grievances (e.g., relating to individual terms and conditions or interpersonal disputes). Such matters should be addressed through the Complaints and Grievance Policy.

4. Procedure for Raising a Concern

4.1. Preferred Method: Internal Reporting

We strongly encourage individuals to raise concerns internally in the first instance, as this allows Altar of Earth to address issues quickly and effectively.

Step 1: Contact the Designated Lead

Concerns should be reported to Altar of Earth's Designated Lead for Whistleblowing, who also holds safeguarding responsibilities:

  • Melissa Main (Founder)

  • Email: contact@altarofearth.org

  • If the concern directly involves Melissa Main, the report should be made to a member of the Board of Directors not involved in the alleged wrongdoing.

Step 2: How to Raise a Concern

Concerns should ideally be put in writing (e.g., via email), including:

  • Your name and contact details (though anonymous reports will be considered – see Section 8).

  • The nature of the concern, including specific details (what, when, where, who).

  • Any supporting evidence or documentation you may have.

  • The individuals involved, if known.

  • What action you believe should be taken.

We understand that raising a concern can be daunting. You do not need to have absolute proof; a reasonable belief that wrongdoing has occurred or is likely to occur is sufficient.

4.2. Acknowledgment

Upon receipt of a formal whistleblowing concern, the Designated Lead will acknowledge it in writing within [e.g., 5 business days].

5. Investigation Process

All reported concerns will be treated seriously and investigated thoroughly, fairly, and impartially.

  • Initial Assessment: The Designated Lead will assess the concern to determine if it falls within the scope of this policy and requires investigation.

  • Investigator Appointment: A suitable, impartial investigator (who may be the Designated Lead, another appointed individual, or an external third party for very serious or complex matters) will be assigned. This person will not be directly implicated in the concern.

  • Gathering Information: The investigator will gather all relevant information, which may include interviewing the whistleblower (if their identity is known and they are willing), the person(s) against whom the concern is raised, and any witnesses.

  • Timelines: Investigations will be conducted promptly. The Designated Lead will aim to provide an update within [e.g., 20 business days] on the steps taken or proposed. Complex cases may require more time, and the whistleblower will be kept informed of progress.

  • Confidentiality during Investigation: All parties involved in the investigation will be asked to maintain strict confidentiality.

  • Safeguarding Referrals: If the concern relates to safeguarding children or vulnerable adults, immediate action will be taken in accordance with Altar of Earth's Safeguarding and Vulnerable Adults Policies, which includes reporting to external statutory authorities where necessary.

6. Outcome and Feedback

  • Once the investigation is complete, the Designated Lead will inform the whistleblower (where their identity is known) of the outcome of the investigation and any actions taken, without disclosing confidential details about other individuals.

  • Possible outcomes may include:

    • The concern is upheld, and appropriate corrective and/or disciplinary action is taken.

    • The concern is not upheld due to insufficient evidence.

    • The concern is referred to another internal policy (e.g., Complaints and Grievance Policy) or an external agency.

    • Lessons learned are identified, and improvements to policies or procedures are implemented.

7. Protection for Whistleblowers / No Retaliation

Altar of Earth has a strict zero-tolerance policy against retaliation towards anyone who raises a concern in good faith.

  • UK (Public Interest Disclosure Act 1998 - PIDA): Individuals making "protected disclosures" (disclosures about specific types of wrongdoing, made in the public interest, to appropriate persons or bodies) are legally protected from detriment or dismissal.

  • US (Various Federal and State Whistleblower Laws): Various laws protect whistleblowers from retaliation (e.g., adverse employment actions) for reporting certain types of wrongdoing.

  • Altar of Earth's Commitment:

    • No employee, volunteer, or contractor will suffer any detrimental treatment (e.g., dismissal, disciplinary action, demotion, harassment, or disadvantage) as a result of raising a genuine concern under this policy.

    • Any individual found to be retaliating against a whistleblower will face disciplinary action, up to and including termination of employment or volunteer status.

    • If a whistleblower believes they have suffered retaliation, they should report it immediately to the Designated Lead or, if the Designated Lead is implicated, to a member of the Board of Directors.

8. Confidentiality and Anonymous Reporting

  • Confidentiality: We will protect the identity of the whistleblower, where requested, as far as legally and practicably possible, consistent with conducting a proper investigation. However, absolute confidentiality cannot be guaranteed if the identity is necessary for the investigation, or if disclosure is required by law.

  • Anonymous Reporting: While we encourage individuals to provide their name to facilitate communication and investigation, we will consider anonymous reports. However, investigating anonymous concerns can be more challenging due to the inability to seek clarification or provide updates.

9. External Reporting (Last Resort)

We encourage internal reporting first, as it generally allows for the quickest and most effective resolution. However, we recognise that in some circumstances, or if internal channels are exhausted and unsatisfactory, individuals may feel the need to report externally.

  • UK: Under PIDA, disclosures can be made to prescribed persons/bodies (e.g., relevant regulators, ombudsmen) or, in very limited circumstances, to others (e.g., media), provided specific conditions are met.

  • US: Depending on the nature of the concern, external reporting might be to federal agencies (e.g., OSHA, SEC), state agencies, or law enforcement.

  • Altar of Earth does not encourage premature external reporting without allowing internal processes to work, but we will not victimise anyone who has a genuine and reasonable belief that they need to report externally.

10. Malicious False Allegations

While this policy protects individuals who raise concerns in good faith, it does not protect those who make false allegations maliciously or for personal gain. If an investigation concludes that a false allegation was made maliciously, disciplinary action, up to and including termination of employment or volunteer status, may be taken.

11. Policy Review

This Whistleblowing Policy will be reviewed regularly, at least annually, or sooner if there are changes in legislation, best practices, or organisational circumstances. All individuals covered by this policy will be made aware of any updates.

Disclaimer: This Whistleblowing Policy provides a comprehensive framework based on general principles and common legal requirements in the UK (specifically PIDA) and the US (a general approach to federal and state whistleblower protections). However, specific laws and regulations concerning whistleblowing vary significantly by sector and jurisdiction within the US, and guidance can evolve in the UK. This document should be considered a robust template and must be reviewed, adapted, and approved by qualified legal counsel in the specific UK region and relevant US states where Altar of Earth operates to ensure full compliance with all applicable local laws and regulations concerning whistleblower protections.