South London Theatre (SLT), Building Preservation Trust (BPT) & Members’ Club (MC) Committees

1. Policy Statement

South London Theatre (SLT), the SLT Members’ Club (MC) and the SLT Building Preservation Trust (BPT) are committed to creating a safe and supportive environment for all its staff, volunteers, and users of the building.

This means giving individuals the space to speak up if they wish to give feedback or have a concern and responding appropriately when they do. We hope that everyone feels empowered to do so and confident in the knowledge that this is the right thing to do.

We recognise that the decision to speak up can be a challenging one. Anyone thinking of doing so should be assured that they will be heard and that their concern will be dealt with in confidence.

We encourage an open and transparent culture and seek the highest standards of ethical conduct and integrity. We therefore welcome reports of any concerns. This allows us to reflect on and improve our practices, and investigate and address any issues.

2. Definitions

‘‘Feedback” for the purpose of this policy is defined as an expression of a view or opinion on our procedures and ways of working. Feedback, highlighting great practice, or when we get things wrong, or could make improvements is really important to us in making SLT, BPT and MC responsive to and reflective of our members, visitors and building users.

A “complaint”, for the purpose of this policy, is an expression of dissatisfaction about how we are working. It is a criticism that expects a reply and would like things to be changed. A complaint must be about an action for which we are responsible or is within our sphere of influence.

“Whistleblowing” is the reporting of suspected wrongdoing or dangers in relation to the organisation’s activities. This includes bribery, facilitation of tax evasion, fraud or other criminal activity, witnessing the mistreatment of others, health and safety risks, safeguarding incidents or concerns, damage to the environment, unethical behaviour and breach of legal or professional obligations.

3. Giving Feedback or Raising a Complaint

Anyone wishing to give feedback or raise a concern is encouraged to do so to the Chair or Secretary of the relevant committee. We hope that most issues will be able to be resolved informally and members are encouraged to speak to the relevant parties in the first instance. Where an informal resolution is not possible or the concern is sufficiently serious the following processes should be followed.

We encourage people to contact us openly to help us to investigate the concerns raised, which may be hampered by contacting us anonymously. We will always respect your confidentiality, though there may be rare occasions when we may be required to disclose your identity by law.

If you wish to raise a formal complaint, it is helpful to include the following details (in writing):

- The nature and key elements of the concern
- Where and when any event happened
- The name/s of anyone involved
- The outcome you are hoping for
- How best to contact you

Everyone who gives feedback or raises a complaint will be treated with courtesy and respect. In return we expect people who make a complaint to communicate their concerns fairly and appropriately.

It is the responsibility of all involved in the process to provide a safe environment for the complainant, treat the concern seriously, deal with it promptly and fairly and maintain confidentiality, as appropriate. Others will only be involved on a need-to-know basis.

We will try to resolve any concerns as quickly as possible, whilst ensuring they are given due consideration. Please note, if the complaint or concern is very detailed it may take longer to respond.

If you are not satisfied with a response we will consider any further points you wish to raise, but reserve the right to draw the matter to a conclusion.

All our committee roles are undertaken by volunteers, who will do their best to learn from feedback and address reasonable complaints. We reserve the right to close an issue where no further progress can be made, or where a complaint has become unreasonably persistent; this will be communicated to the person or people raising the issue by the Chair of the relevant committee.

4. External Support

If you are not satisfied with our internal response, you can contact the Charity Commission on 0845 300 0218 or visit www.charitycommision.gov.uk for advice.

If your complaint relates to how we collect and use your personal data you have the right to report your concerns to the Information Commissioner’s Office www.ico.org.uk.

If your complaint relates to our fundraising practices these can be escalated to the Fundraising Regulator on 0300 999 3407 or via their website www.fundraisingregulator.org.uk.

5. Whistleblowing

A ‘whistleblower’ is someone who has a reasonable belief that wrongdoing has or is currently taking place, or that it is likely to take place in the future. Legal protections for Whistleblowing are enshrined in the Public Interest Disclosure Act which protects workers from detrimental treatment or victimisation from their employer if, in the public interest, they blow the whistle on wrongdoing. The Charity Commission is the regulatory body to whom workers can make appropriate disclosures on matters relating to ‘the proper administration of charities and funds given, or held, for charitable purposes’.

Whilst we hope that such concerns will be extremely rare, it is important our members know how to safely raise such issues.

Individuals with legitimate concerns are encouraged to, as far as possible, raise them in line with the internal reporting routes laid out earlier in this policy.

Where appropriate, an investigator will be appointed, who will be someone independent from the concern raised. Our regulator (the Charity Commission) and others may also be informed. Where appropriate, actions will be agreed and implemented to improve our systems and to try to prevent any recurrence of the circumstances giving rise to the concern.

Where appropriate, the outcome of the investigation will be shared with the individual raising the concern, even if this is a decision not to progress the investigation. This may not be appropriate in all cases, for example for confidentiality reasons. In such circumstances, where the whistleblower has asked to be kept informed, the whistleblower should still be updated and provided with reassurance that their concern has been (or is being) properly dealt with.

6.1 Objective Support

If you are unsure about how best to proceed, or what information to share, you may seek independent advice from organisations such as ‘Protect’ which is an independent whistleblowing charity. It also operates a free, confidential advice line for those who have a concern.

6.2 External Agencies

Where a crime has been, or is being, committed this should be reported to the responsible agencies. In the UK, relevant bodies include the police, HMRC (for tax fraud) and Action Fraud (for other fraud and cybercrime).
If a concern relates to any serious wrongdoing at SLT, MC or BPT (and if you do not have confidence in their response) this may also be reported to the Charity Commission for England and Wales:
You should only report to the Charity Commission issues that could seriously harm:
- The people a charity helps
- The charity’s staff or volunteers
- Services the charity provides
- The charity’s assets
- The charity’s reputation

Examples of serious harm include:
- If someone’s health or safety is in danger, for example if a charity does not use its safeguarding policy
- A criminal offence, for example theft, fraud or financial mismanagement
- If a charity uses its activities as a platform for extremist views or materials
- Loss of charity funds, for example when a charity loses more than 20% of its income or more than
£25,000
- If the charity does not meet its legal obligations, for example if someone uses a charity for
significant personal advantage

Email: whistleblowing@charitycommission.gov.uk

Guidance: Report serious wrongdoing at a charity as a worker or volunteer

Please do not report any concerns to the media (including disclosing on social media). If you do, this may affect the legal protection you may otherwise have as a whistleblower under the Public Interest Disclosure Act 1998.

7. Contacts

Chair, South London Theatre
chairman@southlondontheatre.co.uk

General Secretary, South London Theatre
generalsecretary@southlondontheatre.co.uk

Chair, Building Preservation Trust
charlotte@southlondontheatre.co.uk

Chair, Members’ Club
barcomchair@southlondontheatre.co.uk

Secretary, Members’ Club
mcsecretary@southlondontheatre.co.uk

Written correspondence marked for one of the above and marked ‘confidential’ may be sent to:

South London Theatre,
The Old Fire Station,
2a Norwood High Street,
London SE27 9NS

Policy Approved:

9 August 2023

Review Due:

August 2023