KCC is committed to the highest possible standards of openness,
probity and accountability and we encourage employees and others
working with us to raise any concerns about any aspect of our work
to come forward and voice those concerns. In some instances,
concerns may need to be expressed on a confidential basis.
This procedure encourages employees to raise serious concerns,
without fear of reprisal or victimisation, internally within KCC
rather than over-looking a problem or raising the matter
It applies to all employees, agency workers and those
contractors working on KCC premises, for example, cleaners,
builders and drivers. It also covers suppliers and those providing
services under a contract with KCC in their own premises.
If you require this policy in another format please go the end
of this document for details.
Other Complaints Procedures
This procedure is separate from KCC’s Complaints Procedures and other statutory
reporting procedures applying to some directorates. Managers are
responsible for making service users aware of these procedures.
Any investigation into allegations of potential malpractice
under this procedure will not influence or be influenced by any
disciplinary or redundancy procedures that already affects an
Aim & Scope
This procedure aims to ensure individuals are:
- encouraged to feel confident in raising serious concerns and to
question and act upon concerns about practice
- provided with avenues to raise concerns and receive feedback on
any action taken
- given a response to their concerns and are aware of how to
pursue them if not satisfied.
- reassured that they will be protected from reprisals or
victimisation if they have a reasonable belief any disclosure has
been made in good faith.
There are existing procedures in place to enable individuals to
lodge a grievance relating to their own employment including issues
relating to harassment and bullying. This procedure is intended to
cover concerns that fall outside the scope of other procedures.
Employment Policy Team
- conduct which is, has been or is likely to be an offence or
breach of law
- conduct that has occurred, is occurring or is likely to occur
the result of which KCC fails to comply with a legal obligation.
For example unauthorised use of public funds, possible fraud and
corruption, sexual or physical abuse of clients, or other unethical
conduct discrimination of any kind and waste/frivolous
- disclosures related to past, current or likely miscarriages of
- past, current or likely health and safety risks, including
risks to the public as well as other employees (see below)
- past, current or likely damage to the environment
Concerns about any aspect of service provision or the conduct of
officers or KCC Members or others acting on behalf of the KCC, can
be reported under the Whistleblowing Procedure.
This may be about something that you:
- feel uncomfortable about in terms of known standards, your
experience or the standards you believe KCC subscribes to: or
- is against the KCC’s Standing Orders and policies; or
- falls below established standards of practice; or
- amounts to improper conduct .
KCC’s Safety Complaints Procedure should be used to raise any
issues, concerns or complaints of a health and safety nature and
which are not confidential.
All concerns raised will be treated in confidence and every
effort will be made not to reveal your identity if this is your
wish. However, in certain cases, it may not be possible to maintain
confidentiality if you are required to come forward as a
Whenever possible you should put your name to your allegation as
concerns expressed anonymously are much less powerful that those
that are attributed to a named individual. However anonymous
allegations will be considered and investigated at KCC’s
In exercising the discretion, the factors to be taken into account
- the seriousness of the issues raised
- the credibility of the concern; and
- the likelihood of confirming the allegation from attributable
If you make an allegation in good faith that is not subsequently
confirmed by an investigation, no action will be taken.
Disciplinary action will only be taken against individuals who
knowingly make false, malicious or vexatious allegations.
How to Raise a Concern
Concerns can be raised verbally or in writing. A concern raised
in writing should:
- set out the background and history of the concern, giving
names, dates and places where possible
- give the reason why you are particularly concerned about the
The earlier a concern is raised the easier it is to take action.
Although you are not expected to prove beyond doubt the truth of an
allegation, you need to demonstrate to the person contacted that
there are sufficient grounds for your concern.
A trade union or professional association may raise a matter on
behalf of an employee.
Step One – Raising a Concern
Whenever possible you should raise your concern with your
immediate manager or his/her manager. If this is not appropriate,
you should approach the following according to the nature of the
Business Strategy & Support
Enterprise & Environment
Education, Learning & Skills
Families & Social Care
Customer & Communities
Senior Management contact points
David Cockburn (Head of Paid Service)
Janet Armstrong (Senior Auditor Manager)
Public concern at work
020 7040 6609
KCC has an Anti Fraud and Corruption Policy Statement and all
financial irregularities must be reported to the Chief Internal
Step Two - How KCC will respond
The action KCC takes will depend on the nature of the concern.
The matters raised may:
- be investigated internally by management, Internal Audit or
through the disciplinary or other internal process
- be referred to the Police
- be referred to the External Auditor
- form the subject of an independent inquiry.
In order to protect individuals and KCC, initial enquiries will
be made to decide whether an investigation is appropriate and, if
so, what form it should take. Concerns or allegations
which fall within the scope of specific procedures (e.g. child
protection or discrimination issues) will normally be referred for
consideration under those procedures.
Some concerns may be resolved by agreed action without the need
for investigation. If urgent action is required this will be taken
before any investigation is conducted.
You will be written to within ten working days:
- acknowledging that the concern has been received
- indicating how KCC proposes to deal with the matter
- giving an estimate of how long it will take to provide a final
- informing you if any initial enquiries have been made
- whether further investigations will take place and, if not, why
The amount of contact between the officers considering the
issues and you will depend on the nature of the matters raised, the
potential difficulties involved and the clarity of the information
provided. If necessary, further information will be sought.
When any meeting is arranged you have the right to be
accompanied by a trade union representative or a workplace
colleague who is not involved in the area of work to which the
KCC will take steps to minimise any difficulties you may
experience as a result of raising a concern. For instance, if you
are required to give evidence in criminal or disciplinary
proceedings, KCC will advise or arrange for you to have advice
about the procedure.
KCC will not tolerate harassment or victimisation (including
informal pressures) and will take action to protect individuals who
raise a concern in good faith.
KCC accepts that you need to be assured that concerns will be
properly addressed and, subject to legal constraints, will provide
information about the outcomes of any investigations.
How The Matter Can Be Taken Further
This procedure is intended to provide individuals with an avenue
to raise concerns within KCC. If you are not satisfied, and feel it
is right to take the matter further, the following are possible
- Public Concern at Work 020 7404 6609
- Audit Commission 020 7630 1019
- local Kent County Council member
- relevant professional bodies or regulatory organisations
- a solicitor
- the Police
If a matter is taken outside KCC, you must take all reasonable
steps to ensure that confidential or privileged information is not
disclosed. If in doubt, check with the named KCC contacts.
Public Interest Disclosure
Public Interest Disclosure Act 1998 gives employees two
safeguards in respect of disclosures of information.
- An employee is entitled not be subjected to any detriment by
virtue of having made a protected disclosure.
- The dismissal of any KCC employee directly due to the
individual having made such a disclosure will automatically be
This document is available in other formats and languages call
01622 694778 or email Employment Policy Queries for further
For alternative languages call 08458 247 247 this service can
help you get information about KCC services or publications in your
language. An English-speaking operator will take details of your
requirements and arrange a translation or interpreting service. You
may need an English-speaking friend or a family member to help you
For Texttalk please call 08458 247905.