Request 101004023262

I am writing to request the following information under Freedom of Information legislation:

1. How many incidences of whistleblowing has Moray Council recorded in each of the last five financial years (please break down by year, 2021/22, 2022/23, 2023/24, 2024/25, 2025/26)?

2. Does your whistleblowing policy encourage or direct whistleblowers to raise concerns with a "prescribed person" (as defined under the Public Interest Disclosure Act 1998)? If so, please specify which prescribed person(s) are referenced.

3. Does your whistleblowing policy or process guarantee anonymity to individuals who raise a concern? If so, please provide a copy of the relevant section of the policy addressing this.

4. Does your whistleblowing policy include a non-recrimination or non-retaliation provision, protecting whistleblowers from detriment or reprisal as a result of raising a concern? If so, please provide a copy of the relevant section of the policy addressing this.

5. Has your internal whistleblowing policy been subject to any external review, audit, or assessment (by an external body, auditor, regulator, or independent consultant) within the last five years? If so, please provide:

a) the name of the body/organisation that conducted the review;

b) the date of the review; and

c) a copy of any resulting report or summary of findings, subject to any applicable exemptions.

Response 28-07-2026

1. Across all the years in question, the number is less than 5. Low numbers of 5 or less may lead to the identification of individuals. This information is therefore exempt under Section 38(1)(b) of the Freedom of Information (Scotland) Act 2002 - Personal Information.

2. Yes - Head of People, Change and Community Strategy, as Confidential Reporting Officer

3. Yes. Moray Council’s procedure states – “Confidentiality - All concerns will be treated in confidence, and every effort will be made not to reveal the employee’s identity if they so wish. At the appropriate time, however, the employee’s identity may have to be revealed (e.g. employees may need to come forward as a witness). Should this situation arise, employees will be contacted in advance. The nature and detail of the concerns may be disclosed to relevant parties to facilitate an investigation.”

4. Yes. Moray Council’s procedure states – “The Council will not tolerate any harassment or victimisation of individuals reporting concerns (including informal pressures) and will take appropriate action to protect them when they raise a concern in good faith either during or after the investigation. In addition, employees will not be at a detriment in terms of opportunities for promotion, transfer or training due to whistleblowing details are contained within the Public Interest Disclosure Act 1998 which provides strong protection for workers who raise a genuine concern about malpractice.”

5. Moray Council’s procedure was reviewed earlier this year by the internal policy team. No external reviews of this procedure have been commissioned as of yet. Please find the Policy here.