Feedback, Complaints & Whistleblowing Policy

Purpose 

This policy sets out the principles and processes for sharing feedback, raising complaints and/or whistleblowing, how to escalate them, and the procedure for the responsible Project MAMA staff and/or trustees to respond to them.

Definitions

Project MAMA Stakeholders - Project MAMA Stakeholders are all Project MAMA employees, self-employed contractors, agency workers, volunteers, trustees, Mamas and partner organisations.

Feedback - Feedback is information communicated to anyone working or volunteering at ProjectMAMA, positive or constructive, about our organisation, services and/or stakeholders that can be used to reflect, adjust and improve current and future systems and behaviours.

Complaints - Complaints are defined as all statements that highlight something is unsatisfactory or unacceptable whether made formally or informally if the complainant either states that they are making a complaint or confirms that they would like the matter to be dealt with as a complaint when asked.

Whistleblowing- Whistle blowing is reporting a serious concern that presents a risk to Mamas, colleagues, partner organisations or the organisation itself. It includes concerns about actual wrongdoing and wrongdoing that is anticipated or may happen in the future. Examples include: abuse or Neglect; bullying or victimisation; dangers to health and safety; financial malpractice or impropriety or fraud; failure to comply with a legal, compliance or regulatory obligation; criminal activity; breach of the Organisation’s Code of Conduct; anything else that presents a risk to others; attempts to conceal any of the above. This is a non-exhaustive list. If you suspect your concern falls within the scope of this definition please report according to the procedures set out. 

Principles

  • Project MAMA is committed to reflective practice and will actively seek feedback about services and the organisation whether positive or negative. 

  • This policy (and subsequent versions) will be published publicly on our website.

  • Notices will be displayed at MAMAhub seeking members’ views (See Appendix A) and clearly explained within the MAMAhub New Attendees & Equality and Diversity Monitoring Form (See Appendix B) and Support Folder for Mamas supported through the Mother Companion (MC) Project (See Appendix C).

  • Project MAMA understands that complaints or concerns may arise about some aspect of the setting, an individual volunteer, trustee or member of staff or the way in which the organisation is run.

  • Project MAMA is aware of the importance of listening to and taking account for any impacts or risks resulting from our services or how the organisation is run. 

  • All complaints or whistleblowing will be taken seriously  and investigated thoroughly, promptly and confidentially upon request, following the appropriate procedures below. The outcome of the investigation will be reported back to the person who raised the issue.

  • If misconduct is discovered as a result of any investigation under this procedure, our disciplinary procedure will be used, in addition to any appropriate external measures.

  • All feedback, complaints or whistleblowing can be made verbally or in written form. If a person is unable to communicate or record the matter they are raising in a particular way, such as using the English language or in writing, it will not prevent the complaint from being considered and the means to communicate it will be supported equitably through provisions of interpretation or support to record in a written form. 

  • No person will suffer any reprisal or be victimised for raising a matter under this procedure. This means that no person will be prejudiced because they have raised a concern.

  • Victimisation of an individual for raising a legitimate complaint or whistleblowing would lead to disciplinary action in line with Project MAMAs Disciplinary Procedure.

Scope

This policy applies to all Project MAMA stakeholders and any other organisations or members of the public reporting feedback or concerns relating to any Project MAMA stakeholders.

If you want to bring a complaint or grievance in relation to your own position or contract of employment, please use the Grievance policies.

Sharing Feedback 

If you have feedback you would like to share, positive or constructive please share your feedback directly with those involved if you feel comfortable to. You can also contact the office team over the phone 0117 941 5320 or in writing to hello@projectmama.org to speak with a member of  the team.

Misunderstandings can arise through a simple breakdown in communication, and if we do not know of concerns we can do nothing to resolve them. A straightforward informal discussion between those involved may be all that is needed to set things right. This is likely to be dealt with by the member of staff or volunteer this is shared with. Staff and volunteers are encouraged to share any such positive or constructive feedback with the team.

Raising a Complaint or Whistleblowing Concern - Escalation Pathway

Please remember that you do not need to have firm evidence of malpractice to raise a concern or complaint. You will be asked if you wish to raise the concern or complaint confidentially (ie. your identity is not disclosed as part of any investigation) at the outset. 

Those raising complaints or concerns will be asked to share their experience and how you think the matter might be resolved. 

We request that formal complaints or whistleblowing concerns are summarised in a written form. Support to do so can be requested.

Upon request, we will write to you summarising your concern and setting out how Project MAMA proposes to handle it. 

We may not be able to tell you how long any investigation will take, but we will try to ensure that you are kept updated throughout. Wherever possible, we will give you feedback on the outcome of any investigation. Please note that we will not be able to tell you about disciplinary or other action, when it would infringe a duty of confidence Project MAMA owes to another person. 

If we think your concern falls more properly within the Grievance procedures, we will tell you. 

Step One - If you do not feel happy with the outcome of informally sharing your feedback or do not feel comfortable to speak directly with those involved, please report your complaint or concern openly to the Service Manager, Radmila Faleyeva-Munns, radmila@projectmama.org 07719 873 107 or your line manager.

Step Two - If you feel unable to raise the matter with the Service Manager or your line manager or you think they have not properly addressed the concern at Step One, please raise it with the CEO, Emily Carter, emily@projectmama.org 07376 350 274.

Step Three - If you have followed the steps above but believe that the malpractice is continuing, or if you feel that either of the steps above are not appropriate because of the seriousness of the concerns, or because of the involvement of either your line manager, Service Manager or the CEO, then please raise it with our nominated Whistleblowing Contact on the Board of Trustees, chairoftrustees@projectmama.org

Step Four - If on conclusion of Steps One, Two and Three, you reasonably believe that appropriate action has not been taken, you should report the matter to the relevant external body. For a full list of prescribed people/bodies see: Whistleblowing: list of prescribed people and bodies - GOV.UK (www.gov.uk)

If your concern relates to behaviour of people who work or volunteer with children and due to the nature of your concern you feel unable to raise it with anyone at Project MAMA please refer to the Local Authority Designated Officer (LADO) - Concerns about Professionals on pg 8.

Seek Confidential External Advice

If you are unsure whether or how to raise a concern, or you want confidential advice, you can contact the independent whistleblowing charity Protect on 0203 117 2520. For more information see the website: https://protect-advice.org.uk/advice-line/  

Please note that Protect are not able to raise a concern on your behalf or investigate concerns raised.

Our Assurances to You

Your safety - Project MAMA assures you that it will not take or tolerate reprisal against anyone who raises a concern confidentially under this policy. Provided that you are acting honestly in raising your concern, it will not matter if your concern proves to be mistaken. 

However disciplinary action may be taken if you maliciously raise a matter you know to be untrue. 

The Public Interest Disclosure Act 1998 protects employees against detrimental treatment or dismissal as a result of any disclosure of normally confidential information in the interests of the public.

If you feel that as a result of raising a whistleblowing concern you have suffered detrimental treatment, you should submit a formal complaint under the Grievance Policy detailing what has happened or contact Project MAMA’s nominated Whistleblowing Contact on the Board of Trustees, chairoftrustees@projectmama.org   

Anonymity - We would advise against raising concerns anonymously (i.e. when you do not give your name at all). This is because we are unable to protect you from reprisal, give you any feedback about action taken and also because it is much harder to investigate an anonymous concern raised. As such, whilst Project MAMA will consider concerns raised anonymously, we cannot provide the same assurances we offer to those who raise concerns confidentially. 

Confidentiality - If you ask us not to disclose your identity (ie. you raise your concern confidentially), we will not do so without your consent, unless required by law. You should understand that there may be times when Project MAMA is unable to resolve a concern without revealing your identity, for example where your personal evidence is essential. In such cases, we will discuss with you whether and how best to proceed.

If in doubt, please raise it.

Training on Feedback, Complaints and Whistleblowing

Project MAMA is committed to ensuring that all staff, volunteers, and trustees understand how to respond appropriately to feedback, complaints, and whistleblowing concerns. We:

  • Provide all new staff, volunteers, and trustees with an induction briefing on this policy, which includes the opportunity to ask questions.

  • Make this policy publicly available on Project MAMA’s website to ensure transparency and accessibility.

Handling Procedure

Receiving Feedback 

All members of staff and volunteers may receive feedback, positive or constructive and are responsible for responding according to this policy. 

All staff and volunteers will keep written records of significant positive feedback and share this with the team. All significant positive feedback will be added to the relevant project tab of the M&E database under “Other Feedback Shared” as appropriate by staff or line managers of volunteers. This will be used to inform and encourage our staff and trustees and to provide positive publicity for the work of Project MAMA. 

Anyone sharing constructive feedback will be asked to share their experience and what they would like to happen to remedy this. 

Once discussed the individual sharing constructive feedback will be asked whether they feel this incident is resolved.

All constructive feedback should be reported to your line manager, who will ensure it is accurately recorded and engaged with so that the appropriate actions and learning can be taken if necessary.

If the situation or feedback is not resolved this should be escalated to a complaint and support of how to do this in line with the escalation pathway offered.

Receiving Complaints or a Whistleblowing Concern

Within this section the “responsible individual” is the term used for the person who received the feedback, complaints and/or whistleblowing concern as per the escalation pathway.

The responsible individual is expected to handle any Complaints or Whistleblowing Concern following this procedure:

  1. Ask those raising a complaint or concern to share their experience and how they think the matter might be resolved. 

  2. Make a clear and accurate record of what has been raised and stored in a confidential space. Where necessary, the person wishing to make a Complaint or raise a Whistleblowing Concern should receive support from the responsible individual to record the complaint in a written form. 

  3. Inform the person raising the complaint or concern of who will be handling the matter, how the responsible individual can be contacted and whether further assistance may be needed from them. Include in this communication a summary of their concern and set out how Project MAMA proposes to handle it. 

  4. If we think the concern falls more properly within the Grievance procedures, notify the complainant of this and offer equitable support in accessing these.

  5. Inform your line manager if appropriate and you need support, or to escalate. Refer to the escalation pathway if it would not be appropriate to involve your line manager.

  6. Assess the complaint or concern and consider what action is appropriate. This may involve an informal review or a more formal investigation. Keep the person raising the complaint or concern updated throughout this period. 

    1. Where a formal investigation of a situation is required, notify the complainant that the investigator will gather evidence about the events raised in the complaint. This may include:

      1. telephoning or visiting the person raising the complaint or concern;

      2. interviewing, by telephone or in person, the staff involved, or any other relevant witnesses for further information;

      3. a site visit, if relevant, to see the situation for themselves;

      4. researching relevant laws, policies, procedures and guidelines; and,

      5. looking at relevant papers and records involved in the support if relevant for further information.

  7. Wherever possible, Project MAMA will provide feedback to the person raising the complaint or concern on the outcome and subsequent actions taken, of any investigation. Please note it would not be appropriate to share information around disciplinary or other action, when it would infringe a duty of confidence Project MAMA owes to another person. 

  8. Record reflections and lessons learnt from this complaint/concern and create recommendations to stop it from happening again. Share this with your line manager to establish an action plan and strategy to embed this into our work going forward. Share a summary of this with the person who raised the complaint or concern if appropriate.

Local Authority Designated Officer (LADO) - Concerns about Professionals

LADO is where you report concerns and allegations against people who work or volunteer with children. The LADO must be contacted within one working day in respect of all cases in which it is alleged that a person who works with children has:

  • behaved in a way that has harmed, or may have harmed a child;

  • possibly committed a criminal offence against or related to a child; or

  • behaved towards a child or children in a way that indicates they may pose a risk of harm to children

The role of the LADO is set out in Section 11 of the Children's Act 2004 and in the HM Government guidance Working Together to Safeguard Children (2018).

Bristol LADO: 0117 903 7795 LADO@bristol.gov.uk 

https://bristolsafeguarding.org/children/lado-concerns-about-professionals/If a concern pertains to safeguarding children, please also refer to Project MAMA’s Safeguarding Children Policy and Procedures

Report to Charity Commission 

If a serious incident takes place within or relating to Project MAMA, it is important that there is prompt, full and frank disclosure to the Charity Commission. 

Responsibility to report serious incidents to The Charity Commission sits with the Chair of Trustees and where involving them the board of Trustees as a whole. This may be delegated to someone else within the charity, such as an employee or the charity’s professional advisers whoever the responsibility to do so and ensure the reporting is completed sits with the board of trustees.

  • Actual or alleged incidents should be reported promptly. This means as soon as is reasonably possible after it happens, or immediately after your charity becomes aware of it.

  • The following table should be referred to by charity trustees to identify serious incidents and decide what to report.

  • This guidance on how to report serious incidents. 

  • This is the online form which must be used to report a serious incident on behalf of the trustee body. 

Relevant Contact Details