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Policy

Corporate Governance Framework

Our corporate governance framework sets out the necessary responsibilities and procedures that guarantee we operate properly.

Published
29 October 2021

Last updated
27 November 2025 - Changes

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  1. Contents
  2. Appendix 4 – Speak Up (Whistleblowing) policy
  3. Policy Statement

Policy Statement

    2.0
    1. This Policy describes the Gambling Commission’s approach to the Public Interest Disclosure Act (1998) (PIDA) (opens in new tab), which protects workers from detrimental treatment or victimisation from their employer if, in the public interest, they blow the whistle on wrongdoing.

    2. As defined by the PIDA, disclosures made in the public interest are to do with wrongdoing which tends to show one or more of the following:

      1. a criminal offence has been committed, is being committed, or is likely to be committed
      2. that a person has failed, is failing or is likely to fail to comply with any legal obligation to which he is subject
      3. that a miscarriage of justice has occurred, is occurring, or is likely to occur
      4. that the health or safety of any individual has been, is being, or is likely to be endangered
      5. that the environment has been, is being, or is likely to be damaged
      6. that information tending to show any matter falling within any one of the preceding paragraphs has been, is being or is likely to be deliberately concealed.
    3. You can raise a concern at any time and speak up about conduct or an incident that happened in the past, is happening now, or you believe will happen.

    4. Whilst this policy is focused on concerns that are of ‘public interest’, and not ‘private concerns’ relating to your own personal treatment, speaking up about any issue is encouraged. If you are unsure if the matter you want to raise falls under this policy, do not worry. When you raise your concern, advice will be available and if the matter you are speaking up about might be best considered under a different policy or process, the person who you raise your concern with will discuss this with you.

    5. You do not need proof of any wrongdoing. The Commission will take responsibility for investigating any matters raised. As long as you are not acting maliciously but are acting in the reasonable belief that your concern is in the public interest, it does not matter if it turns out you were mistaken.

    6. Concerns raised under this policy are protected disclosures which means there is a legal right not to be subjected to detrimental treatment. The Commission will not tolerate the detrimental treatment of anyone because they have raised a concern under this policy. If anyone tries to prevent you from speaking up or victimises you for doing so, this will be taken seriously and looked into. If someone has victimised you for raising a concern or discloses your identity without authority, they may be subject to disciplinary action.

    7. We recognise that there may be circumstances when you would prefer to speak to someone confidentially. This means that the person you speak to will take steps to keep your identity secret from others. If this is the case, please say so at the outset.

    8. If you ask us not to disclose your identity, we will not do so without your consent unless necessary or required by law.

    9. You should understand that there may be times when we are 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 the matter can best proceed.

    10. PIDA does not contain any specific provisions for confidentiality in relation to protected disclosures. The Commission will seek to handle all disclosures with sensitivity. If you request confidentiality, the Commission will do everything it reasonably can to prevent the disclosure of any information that could identify you. However, it is important to note that there are limits to confidentiality. To resolve a concern, revealing your identity might be necessary or required by law. In addition, there may be instances where your identity becomes apparent without you having been specifically identified.

    11. We understand that you might be concerned about how information you disclose (such as emails or evidence) will be stored and who will have access to it. Internal guidance is available on how to respond to a concern and this sets out how information is managed to ensure it is not accessible by anyone who is not investigating your concern.

    12. Anonymous disclosures will be investigated to the fullest extent possible, but the full protection of this policy cannot be given to those who do not identify themselves. If you do not tell us who you are, it is much more difficult to:

      • look into the matter fairly, when further questions cannot be asked
      • protect your position, if you subsequently experience any victimisation
      • provide any feedback on the outcome of the disclosure.
    13. When you raise a concern, you will be asked how you think the matter should be resolved. The Head of Governance will usually be informed that a disclosure has been made to ensure it can be recorded and the appropriate response identified. There may be circumstances where this is not deemed appropriate, for instance if the investigation would not be sufficiently independent. In those circumstances, the Executive Director of People Services or an alternative Executive Director, or the Commissioner who chairs the Audit and Risk Committee (ARC) will be notified instead. Advice will usually then be sought from relevant Commission teams where appropriate, for instance, People Services, Finance, Governance or Legal on the appropriate action to take.

    14. The Chair of ARC will be notified of the nature of all concerns raised.

    15. As much feedback as possible will be provided on the process to review the concern you raised. However, we may not be able to share the precise action or provide full details of the investigation where this would infringe on a duty of confidence owed by us to someone else or undermine our regulatory or legal functions.

    16. On notification of the outcome of any investigation, you are encouraged to provide feedback to either the Head of Governance or the lead investigator on your experience of speaking up. Any learning from your experience will be noted by the Head of Governance and best practice and possible improvements to the ‘Speak Up (Whistleblowing)’ arrangements identified.

    17. If you are dissatisfied with the outcome of the investigation, you are encouraged to raise your concern within 10 working days after we tell you what action has been taken. This is not an appeal process, since the action taken will not be about you or your circumstances (concerns relating to your own personal treatment are likely to be dealt with under a different policy), but it is a point of escalation to check the matter has been dealt with appropriately and with sufficient rigour and honesty.

    18. To escalate your concern, you should write to someone more senior than the person who initially investigated. This could be a member of the Executive Team, the Chief Executive, the Senior Independent Director, the Chair of Commissioners or the Chair of ARC. If you want the matter to remain confidential, please say so in your message. The person you write to will respond, confirming how the matter will be taken forward and the expected timeline for response. The outcome will be confirmed to you in writing. While we cannot guarantee that we will respond to all concerns in the way you might wish, we will ensure that we handle the matter fairly and properly.
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