WHISTLEBLOWING POLICY AND PROCEDURES

1. Policy Statement

Corallia is committed to creating a safe and supportive environment for all staff, volunteers, partners, and the people and companies we support. This commitment includes providing a platform for individuals to voice their concerns and ensuring that each concern is addressed appropriately and thoroughly.

We aim to empower everyone to speak up, confident that it is the right thing to do. We understand that making the decision to raise a concern can be difficult. Therefore, anyone considering doing so should be assured that they will be heard and that their concern will be handled with the utmost confidentiality.

We promote an open and transparent culture, striving for the highest standards of ethical conduct and integrity. We welcome the reporting of any concerns, as it allows us to investigate and address issues, learn valuable lessons, and continuously improve as an organization.

1. Scope

All Corallia staff and representatives must adhere to this policy in both their professional and personal lives, without exception. This includes:

• All Corallia staff, including employees as well as personnel under direct contracts
• Volunteers and interns
• Staff and representatives of partner agencies, or any other individuals, groups, or organizations with a formal/contractual relationship with Corallia that brings them into contact with young people

Additionally, donors, supporters, journalists, ambassadors, and others who may encounter young people through their involvement with Corallia or its partners must comply with this policy while visiting programs or offices or participating in campaigns or events.

1. Framework

All employees, volunteers, or representatives of Corallia are expected to promote its values and principles and protect its reputation by:

• Exhibiting zero tolerance for nepotism, corruption, and bribery in any of Corallia’s activities.
• Respecting the basic rights of others by acting fairly, honestly, and sensitively, and treating everyone with dignity and respect.
• Tackling bureaucracy and avoiding dogmatism and excessive opinionation.
• Challenging or preventing harassment, intimidation, or discrimination.
• Maintaining high standards of personal and professional conduct.
• Notifying managers of any potential conflicts of interest.
• Ensuring the safety and well-being of themselves and others, and actively protecting young people by complying with Corallia’s Safeguarding Policy.
• Protecting the organization’s assets and resources.
• Collaborating with Corallia’s partners to ensure equivalent standards of safeguarding, dignity, and respect.
• Reporting any matters that violate the standards contained in this Code.
• Taking complaints seriously and ensuring they are properly investigated.

Corallia is committed to adhering το laws and guidance that protect and promote the safety and well-being of young people including:

• The Greek Constitution (articles 4-25)
• The Greek Civil Code (code 65)
• The Greek Criminal Code
• The Greek statutory legislation (Law 3064/2002 as amended, and Presidential Decree 233/2005).

1. Types of Concern

‘Whistleblowing’ refers to the reporting of suspected wrongdoing or dangers related to the organization’s activities. This includes bribery, facilitation of tax evasion, fraud, or other criminal activities, mistreatment of others, health and safety risks, safeguarding incidents or concerns, environmental damage, unethical behavior, and breaches of legal or professional obligations.

A ‘whistleblower’ is someone who has a reasonable belief that wrongdoing has occurred, is currently occurring, or is likely to occur in the future.

Whistleblowing differs from complaints or grievances in that it concerns issues with a broader impact than just the individual. For instance, if an employee raises a complaint about personal bullying, it should be handled under the staff grievance policy and procedures. However, if the investigation uncovers concerns about a broader culture of bullying, those ‘public interest’ concerns should be addressed under this whistleblowing policy and procedures.

Therefore, this policy should not be used by employees to report individual concerns or issues such as grievances or complaints related to management decisions or terms of employment. Such issues should be initially discussed with your line manager and then escalated according to the relevant policy, e.g., to HR.

1. Protection for Whistleblowers

We recognize that the decision to speak up can be difficult. We will always support individuals who have a reasonable belief or concern about wrongdoing and will take their interests into account throughout any investigation.

We do not tolerate bullying, harassment, or victimization of anyone who raises a concern. For Corallia staff, this means that your future employment, progression, or opportunities will not be negatively impacted. Any instances of bullying, victimization, or attempts to identify the whistleblower will be taken very seriously and may result in disciplinary action.

If a report originates from outside Corallia, such as from a partner organization, we will discuss the concerns with the individual and conduct the investigation accordingly.

1. Confidentiality

We will always respect the privacy of whistleblowers. If it becomes necessary to identify you to resolve an issue, we will discuss this with you first. We will be judicious in disclosing your identity to other investigators and will only do so when necessary or otherwise appropriate. For example, within the small team at Corallia responsible for considering and investigating concerns, we will omit your name in reports and other documents where it is not necessary.

In cases where the concern involves a contractor or another organization with which we work, we will discuss with you what information is appropriate to share, including whether to reveal your identity and the details of your concern. It may be most appropriate for those parties to conduct their own investigation.

If disciplinary or other proceedings against those involved in wrongdoing are necessary, your evidence as a witness may be needed. We will advise and support you if your testimony is required.

If you have any concerns about confidentiality, please let us know.

We do not encourage whistleblowers to contact us anonymously, as this can complicate the investigation and assessment of the concern’s credibility. While we will still consider anonymous concerns, we may be limited in our ability to take action without sufficient information. The best way to raise a concern is to do so openly, as this allows us to investigate and address the issue more effectively and promptly.

1. Links to other Policies

Corallia has several other policies in place with links to this policy. This policy is not a substitute for other policies, and individuals are encouraged to report in line with the appropriate policy or route wherever possible. Concerns reported under this policy may be investigated under the relevant policy, for example:

• Corallia Safeguarding Children and Adults Policy
• Corallia Code of Conduct

* These are currently policies of Corallia, which should be followed as applicable. Where such a policy is replaced the current version of the Corallia policy should be followed.

Please report any matter in line with the most appropriate policy or route. However, if you are unsure, what is most important is that you promptly tell us about it. We will then deal with your concern under the most appropriate policy and procedures.

We would also expect others with whom we deal to have their own internal policies under which concerns can be dealt with.

1. Reporting Concerns

We hope that all staff, representatives, and other individuals covered by this policy feel confident in raising concerns to their line manager or to their Corallia point of contact in the first instance. If you feel unable to do so, you may raise your concerns with a more senior Corallia manager whom you trust or in one of the following ways:

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

Where a crime has been, or is being, committed this should be reported to the responsible agencies in the country. Relevant bodies include the police, Cybercrime Prosecution Directorate Cybercrime Prosecution (for cases of cyber bullying and racism) and The Greek Ombudsman (for monitoring and promoting the implementation of the principle of equal treatment in the private, public, and wider public sectors).

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.

If you are unsure about how best to proceed, or what information to share, you may seek independent advice from organisations such as discussed above. However, this policy is designed to protect whistleblowers and to ensure that any matters are properly and promptly investigated and dealt with. We therefore strongly encourage anyone with a genuine concern immediately to contact one of the people at Corallia mentioned above so that we can start addressing that concern.

WHISTLEBLOWING PROCEDURES

1. Raising a Concern:

Anyone wishing to raise a concern is encouraged to do so through the relevant existing policy (as listed in item 6 on page 2 of the Whistleblowing Policy), their line manager, or their Corallia point of contact. If an individual does not feel comfortable doing so – for example, if they have previously raised a concern and feel it was not addressed appropriately – they should use the channels outlined in item 7 of the Whistleblowing Policy.

1. Providing Information:

There is no mandatory form to complete. However, when raising a concern, it is helpful to include:

• The nature and key elements of the concern.
• When any wrongdoing occurred (or started if ongoing) and/or when you became aware of it.
• Who was/is involved.
• Any other relevant background information (e.g., where any wrongdoing has taken place).
• Who else (if anyone) has been notified, when, and what response was received.
• How best to contact you.

1. Reporting the Concern:

If a whistleblower contacts a Corallia staff member, the staff member should report this immediately to the Nominated Person or Trustee. They will then involve others as appropriate. If the concern is a criminal matter, it may be reported to the police.

1. Ensuring a Safe Environment:

All involved in the process must provide a safe environment for the whistleblower, treat the concern seriously, handle it promptly and fairly, preserve evidence, and maintain confidentiality as appropriate.

1. Acknowledgment:

The Corallia staff member receiving the concern, or another appropriate person, should acknowledge receipt within one working day.

1. Initial Response:

Within five working days, the whistleblower should be informed of the proposed approach to address the concern. Additional information may be sought to aid the investigation. If it is decided not to investigate the matter or to take no further action, the whistleblower should be informed of the reasons for this decision and the level at which the decision was made.

1. Concerns Involving Third Parties:

If the concern involves another party, such as a contractor, it may be most appropriate for that party to conduct the investigation. In such cases, we will discuss with the whistleblower what information is appropriate to share. It is crucial that whistleblowers trust Corallia to respect their wishes, especially regarding confidentiality, even if this may limit the investigation.

1. Investigation:

Where appropriate, an independent investigator or investigation team (either internal or external) will be appointed. The investigator will report to the CEO, the Risk and Audit Committee, and/or the Board of Trustees as appropriate. Our regulator (the Charity Commission), funders, and others may also be informed. Actions will be agreed upon and implemented to improve Corallia’s systems and prevent recurrence of the issue.

1. Sharing Outcomes:

Where appropriate, the outcome of the investigation will be shared with the whistleblower, even if it is a decision not to progress the investigation. This may not always be possible, for confidentiality reasons. If the whistleblower has asked to be kept informed, they should still receive updates and reassurance that their concern has been properly addressed.

APPENDIX

Useful contacts:

Colour Youth Community LGBTQ of Athens

Recording cases of homophobic, transphobic, amphiphobic violence and discrimination, psychological empowerment groups for LGBTQI + people, psychosocial support, and advocacy.

Website: www.colouryouth.gr

E-mail: info@colouryouth.gr

Τ.: (+30) 694 5583 395

Rainbow Families

Recording cases of homophobic, transphobic, amphiphobic violence, psychosocial support for families and minors, human rights advocacy.

Website: www.ouraniotoksofamilies.blogspot.gr

E-mail: ouraniotoksofamilies@gmail.com

HUMAN RIGHTS 360

Providing legal support, defending human rights.

Website: www.humanrights360.org

E-mail: contact@humanrights360.org

PRAKSIS – Development, Social Support and Medical Cooperation Programs

Provision of medical care, psychosocial support and / or temporary accommodation, legal counseling. Website: www.praksis.gr

Amnesty International – Hellenic Section

Providing legal support, defending human rights

Website: www.amnesty.gr

E-mail: athens@amnesty.org.gr

Τ.: (+30) 210 3600 628

National Center for Social Solidarity

Psychological and / or social support for members of vulnerable population groups going through crisis and emergency situations.

Website: www.ekka.org.gr

Prefecture of Attica: T.: 197 (Hotline for Immediate Social Assistance)

Nationwide: T.: 1107 (National Child Protection Line)

This information was updated on 01.09.2023.