Complaints and Whistleblowing Policy

Street Lights Collective CIC is committed to operating with honesty, transparency, accountability and care. The Organisation exists to serve young people, families and communities through the values of Presence. Power. Purpose. This means that concerns, complaints and disclosures must be taken seriously, handled fairly and used to strengthen practice.

The Organisation recognises that people may sometimes feel dissatisfied, unsafe, unheard or concerned about conduct, decision making, safeguarding, delivery quality, discrimination, financial handling, governance or organisational culture. Street Lights Collective CIC welcomes concerns being raised early so that issues can be addressed, harm can be prevented and trust can be protected.

This policy sets out how complaints and whistleblowing concerns will be received, recorded, assessed, investigated, resolved and reviewed. It also explains the difference between a complaint, a grievance, a safeguarding concern and a whistleblowing disclosure.

• To provide a clear process for raising complaints about Street Lights Collective CIC.
• To provide a safe process for raising whistleblowing concerns about serious wrongdoing or risk.
• To protect children, young people, families, staff, volunteers, practitioners, partners and the public.
• To make sure concerns are responded to fairly, consistently and without unnecessary delay.
• To ensure safeguarding concerns are escalated immediately to the Designated Safeguarding Lead.
• To ensure whistleblowers are not treated unfairly for raising genuine concerns in the public interest.
• To support organisational learning, accountability and improvement.

This policy applies to all Street Lights Collective CIC activities, including community programmes, school based programmes, mentoring, TIPS, the Street Lights Ambassador Programme, the NEET Futures Initiative, Hood Lessons, the Unity Tour, events, outreach, online activity, partnerships, training, consultancy and internal organisational activity.

This policy applies to concerns raised by:

• young people;
• parents, carers and family members;
• community members;
• directors and advisors;
• staff, sessional workers and volunteers;
• trauma informed practitioners;
• partners, schools, local authorities, funders and commissioners;
• members of the public.

It is important that concerns are handled through the correct route. Some matters may need more than one route. For example, a complaint about a staff member may also raise a safeguarding concern.

A whistleblowing concern should normally be raised with one of the following:

• a Director of Street Lights Collective CIC;
• Phillip Chackochen, Designated Safeguarding Lead, where the concern relates to safeguarding;
• Marisa Ferguson, Finance and Compliance Lead, where the concern relates to finance or compliance;
• another suitable director, advisor or senior person if the concern involves the usual reporting person.

The concern may be raised verbally or in writing. It should include as much detail as possible, including what happened, who was involved, dates, locations, evidence, witnesses and why the person believes there is serious wrongdoing or risk.

Street Lights Collective CIC will respond to whistleblowing concerns by:

• Acknowledging the concern where contact details are available.
• Assessing immediate risk, including safeguarding, financial, legal and reputational risk.
• Taking urgent action where needed to protect children, young people, adults, staff, volunteers or the public.
• Appointing a suitable person to review or investigate the concern.
• Keeping information confidential as far as possible.
• Recording decisions, actions and reasons.
• Reporting to external agencies where required.
• Providing feedback where possible, while respecting confidentiality and legal limits.
• Identifying learning and improvement actions.

Because Street Lights Collective CIC works with young people, families and communities affected by trauma, serious youth violence, exploitation, online harm and community risk, safeguarding must be considered in every complaint and whistleblowing concern.

Contextual safeguarding recognises that harm can occur beyond the home, including in peer groups, schools, parks, estates, transport routes, online platforms, events, community spaces and areas affected by postcode conflict.

Complaints or disclosures must be escalated to the DSL immediately if they include or suggest:

• abuse, neglect or exploitation;
• criminal exploitation or county lines;
• sexual exploitation or harmful sexual behaviour;
• serious youth violence, threats, retaliation or weapon carrying;
• online grooming, harmful content, threats or coercion;
• unsafe adult conduct or boundary concerns;
• domestic abuse or family violence;
• a young person missing, at risk or unsafe;
• a failure to report or respond to safeguarding concerns.

The DSL for Street Lights Collective CIC is Phillip Chackochen.

Any allegation against a director, advisor, staff member, volunteer, practitioner, partner or any adult representing Street Lights Collective CIC must be taken seriously.

This includes concerns that an adult may have:

• harmed a child, young person or vulnerable adult;
• behaved in a way that indicates they may pose a risk of harm;
• breached professional boundaries;
• used their position to intimidate, exploit, manipulate or control;
• failed to report safeguarding concerns;
• acted in a way that undermines trust or safety.

Such concerns must be referred to the DSL and handled in line with safeguarding procedures. Where required, the Organisation will contact the relevant local authority safeguarding partners, Local Authority Designated Officer, police, DBS, funder, commissioner or regulator.

All complaints and whistleblowing concerns must be recorded securely. Records should include:

• date received;
• name and contact details of the person raising the concern, where available;
• summary of concern;
• people involved;
• risk assessment;
• actions taken;
• decisions made;
• external referrals;
• outcome;
• learning points;
• date closed.

Records must be stored securely and shared only with those who need to know. Safeguarding records must be kept separately and securely in line with the Organisation’s safeguarding and data protection policies.

Street Lights Collective CIC will report concerns to external agencies where required or appropriate. This may include:

• children’s social care;
• adult safeguarding services;
• police;
• Local Authority Designated Officer;
• Disclosure and Barring Service;
• funders or commissioners;
• insurers;
• CIC Regulator or Companies House where relevant;
• Charity Commission where relevant to a partner charity or if required in a specific context;
• Information Commissioner’s Office for serious data breaches where required.

Where Street Lights Collective CIC is working under contract, grant agreement or partnership arrangement, the Organisation will also comply with relevant reporting requirements in that agreement.

Street Lights Collective CIC will treat concerns seriously. However, the Organisation may take proportionate steps where a complaint is deliberately false, malicious, abusive, threatening, discriminatory, repeatedly unreasonable or intended to harass staff, volunteers or participants.

This does not mean that difficult, emotional or strongly worded complaints will be dismissed. Many people raise concerns while distressed. The Organisation must distinguish between distress and deliberate abuse.

Where behaviour becomes abusive or unsafe, the Organisation may set communication boundaries, appoint a single point of contact, pause non urgent communication, seek external advice or take action to protect people.

The Board will review complaint and whistleblowing themes at least annually, or sooner where serious concerns arise. Reviews should consider:

• patterns in complaints;
• safeguarding themes;
• equality, diversity and inclusion issues;
• staff or volunteer training needs;
• partnership risks;
• communication improvements;
• policy gaps;
• programme quality;
• community trust and accountability.

Learning must lead to action where improvement is needed.

This policy should be read alongside:

• Safeguarding and Child Protection Policy;
• Data Protection Policy;
• Website Privacy Notice;
• Equality, Diversity and Inclusion Policy;
• Health and Safety Policy;
• Code of Conduct;
• Volunteer Policy;
• Safer Recruitment Policy;
• Finance Policy;
• Social Media Policy;
• Risk Management Policy.

This policy will be reviewed annually by the Board of Directors, or sooner if there is a serious complaint, whistleblowing disclosure, safeguarding incident, change in law, regulator expectation, funder requirement or significant organisational change.

This Complaints and Whistleblowing Policy was approved by the Board of Directors of Street Lights Collective CIC.

Date approved: __________________________________________

Review date: ____________________________________________

Signed on behalf of the Board: ____________________________

Name: _________________________________________________

Role: _________________________________________________

Appendix 1: Complaint Form

Appendix 2: Whistleblowing Disclosure Form