China Fleet Trust
China Fleet
Trust
China Fleet Country Club
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China Fleet Trust

Complaints & Whistleblowing

1. Introduction

The Public Interest Disclosure Act 1998 (PIDA), which amended the Employment Rights Act 1996, provides a legal framework for whistleblowing across the private, public, and voluntary sectors. Under this legislation, individuals are protected from victimisation when they make a protected disclosureabout malpractice or wrongdoing in the workplace.

The China Fleet Trust (CFT)is recognised as a ‘prescribed person’under the Act. This means that individuals do not need to be employed by the CFT to raise genuine concerns. This protection extends to Trustees, employees, and third parties, including those associated with our wholly owned trading subsidiary, China Fleet Country Club plc(“the Company”).

CFT is committed to fostering a safe and transparent environment where concerns can be raised without fear of reprisal. This includes concerns about:

  • Activities or conduct by the China Fleet Trust, or
  • Activities or conduct by the China Fleet Country Club plc

Anyone raising a genuine concern will be protected under the Act, including employees of external organisations who report concerns to CFT as an independent body.This policy outlines the procedures for reporting and handling concerns related to malpractice or wrongdoing by either the Trust or the Company. It incorporates guidance from the Charity Commissionand references the Company’s internal Whistleblowing Policy.

1.1 Purpose of This Guidance

Charities are independent organisations governed by Trustees. They play a vital role in society, supported by volunteers, donors, and service users. Occasionally, concerns may arise regarding a charity’s conduct. This guidance aims to direct individuals to appropriate internal contacts or to the Charity Commission where necessary.

1.2 Role of the Charity Commission

The Charity Commission is the independent regulator of charities in England and Wales. Its role is to ensure that charities are:

  • Accountable
  • Well-managed
  • Compliant with legal obligations

The Commission provides guidance, uses legal powers to support charity administration, and intervenes where there is a serious risk of harm, abuse, or mismanagement. It does notact as a general complaints service and may decline to investigate issues that do not meet its threshold for regulatory concern or public interest.

1.3 Scope of This Guidance

This guidance applies to complaints or concerns regarding:

  • The China Fleet Trust, and
  • Its wholly owned trading subsidiary, the China Fleet Country Club plc

1.4 How to Use This Guidance

Each section of this policy is organised by topic and includes key questions and summary answers. For further detail, individuals are encouraged to consult the Charity Commission’s website.

1.5 Additional Sources of Support

The Commission encourages charities to resolve issues internally and to seek support from relevant organisations. Trustees are advised to use all available resources to manage their charities effectively and to seek external advice where appropriate.

1.6 Legal and Best Practice Standards

In this guidance:

  • ‘Must’ indicates a legal or regulatory requirement
  • ‘Should’ indicates best practice expected by the Commission

Failure to follow best practice may result in a breach of legal duties. Trustees are expected to:

Legal Duty

Best Practice

Act in the charity’s best interests

Manage conflicts of interest

Manage resources responsibly

Implement financial controls and manage risks

Act with reasonable care and skill

Seek appropriate advice when needed (e.g., property transactions, investments)

Legal Duty

Act in the charity’s best interests

Manage resources responsibly

Act with reasonable care and skill

Best Practice

Manage conflicts of interest

Implement financial controls and manage risks

Seek appropriate advice when needed (e.g., property transactions, investments)

Trustees who breach their duties may be held accountable for any resulting harm or loss. The Commission may intervene where there is evidence of misconduct, mismanagement, or undue risk to the charity, its assets, or beneficiaries

2. Complaints –What You Need to Know and Do

2.1 How to Raise a Complaint About the China Fleet Trust

In most cases, concerns should be raised directly with the China Fleet Trust before contacting external bodies. This allows the Trust an opportunity to address the issue, clarify any misunderstandings, or take corrective action where necessary.

Initial Contact:

  • Email: Trust@china-fleet.co.uk
  • Telephone: 01752 854630

If your concern relates specifically to the Chief Executive Officer (CEO), you may bypass the CEO and contact the Trust Chair. This can be done by requesting the Chair’s contact details via the Company Managing Director: Telephone: 01752 854652

Examples of issues appropriate for internal resolution include:

  • Decisions made by Trustees within their legal powers
  • Concerns about service quality
  • Employment-related matters (e.g. unfair dismissal)
  • Contractual or internal disputes involving properly appointed Trustees
  • Governance or policy-related matters

For guidance on internal charity disputes, refer to the Charity Commission’s publication: Conflicts in a Charity: Statement of Approach.

2.2 Serious Concerns and the Role of the Charity Commission

Some issues may be serious enough to warrant direct reporting to the Charity Commission, especially if they pose a significant risk to the charity’s beneficiaries, assets, services, or reputation. Examples include:

  • Criminal activity
  • Fraud or financial misconduct
  • Abuse or safeguarding concerns
  • Terrorist-related activity

For further information, refer to the Commission’s guidance: Risk Framework: Charity Commission.

2.3 Reporting to the Charity Commission

Serious concerns should be reported using the Charity Commission’s online reporting form, which enables faster and more efficient handling. If you initially contact the Commission by phone or letter, you may still be asked to complete the online form. Before submitting, ensure you have all relevant information ready to support your report.

2.4 Reporting to Other Authorities

In certain cases, you may need to report concerns to other agencies

  • Police: For suspected criminal activity. If already reported, provide the Commission with the crime reference number and contact details of the investigating officer.
  • Action Fraud: For suspected fraud. Website: Action Fraud Phone: 0300 123 2040
  • Anti-Terrorist Hotline: For concerns about terrorist activity. Phone: 0800 789 321

2.5 Confidentiality and Anonymity

The Charity Commission will respect confidentiality as far as possible and will consider your rights under data protection, freedom of information, and human rights legislation. However, in some cases, your identity may be disclosed or become apparent during the investigation process.Further guidance is available via the Charity Commission’s website via the link.

3. Reports from charity workers and volunteers

If you are a staff member or volunteer working with the China Fleet Trust, you have the right to raise concerns about serious wrong doing within the charity. This includes reporting issues that may affect the Trust’s integrity, operations, beneficiaries, or reputation.

What Can Be Reported?

You may report concerns such as:

  • Financial misconduct or fraud
  • Criminal behaviour
  • Safeguarding breaches
  • Serious breaches of charity law or governance
  • Abuse of position or authority
  • Activities that pose a risk to public trust in the charity

How to Report

Reports can be made directly to the Charity Commission if the issue is serious and cannot be appropriately addressed within the Trust. The Commission provides guidance specifically for charity workers and volunteers on how to report wrongdoing. For more information and to submit a report, visit the Charity Commission’s website:

All reports will be treated with appropriate confidentiality, and whistleblowers are protected under UK law from unfair treatment or dismissal for raising genuine concerns.

4. Reports from auditors and independent examiners, this includes the Trust’s accountant

4.1 Purpose of This Section

Auditors and independent examiners of the China Fleet Trust have specific legal responsibilities under the Charities Act 2011. This section outlines their duty to report certain matters to the Charity Commission when identified during the examination or audit of the Trust’s accounts. Under the Charities Act 2011, auditors and independent examiners must report issues of material significance that may affect the Commission’s ability to exercise its powers under:

  • Section 46–to institute inquiries
  • Section 76–to act for the protection of charities

4.2 What Are Matters of Material Significance?

Matters of material significance typically involve:

  • Serious criminal or unlawful activity
  • Financial irregularities or fraud
  • Governance failures
  • Incidents that could harm the charity’s beneficiaries, assets, or reputation

Further detailed guidance on identifying and reporting such matters is available from the Charity Commission.

4.3 Additional Guidance for Auditors

Auditors should refer to the following professional standards and guidance when considering whether to report concerns:

  • International Standards on Auditing (ISAs)–as adopted by the Financial Reporting Council (FRC)
  • Practice Note 11: The Audit of Charities–which includes specific guidance on reporting duties and public interest disclosures

This guidance has been developed in consultation with the Charity Commission and is available via the FRC website.

5. Other information

5.1 Independent advice

If you are uncertain about whether to raise a concern under this policy, or if you would like independent guidance at any stage, you can contact Protect, the UK’s leading whistleblowing charity. Protect offers free, confidential advice to individuals concerned about wrongdoing in the workplace, including within charities. They can help you understand your options and advise on how to raise concerns safely, including when and how to contact external bodies.

Contact Protect:

Protects support is available to staff, volunteers, trustees, and others connected to the charity who may be considering whistleblowing.

6. The Responsible Officer and Assurance Arrangements

The Chief Executive Officer (CEO)of the China Fleet Trust holds overall responsibility for maintaining, implementing, and reviewing this Whistleblowing and Complaints Policy. The CEO will report to the China Fleet Trust Board as necessary on matters arising under this policy, including any complaints received and actions taken. In the event that a concern or complaint is raised about the CEO, responsibility for overseeing the policy and managing the response will transfer to the Trust Chair to ensure impartiality and appropriate governance. This arrangement ensures that all concerns are handled with integrity, transparency, and accountability, regardless of the individuals involved.

7. China Fleet Trust Fundraising Activity

As part of the China Fleet Trust’s commitment to transparency and accountability in all fundraising activities, a dedicated whistleblowing and complaints procedure has been established.

7.1 Routine Enquiries

Enquiries of a non-serious or routine nature should be addressed in accordance with the general complaints procedure outlined in Section 2.1of this policy.

7.2 Serious Concerns and the Fundraising Regulator

China Fleet Trust is registered with and adheres to the standards set by the Fundraising Regulator. Individuals who have serious concerns about the Trust’s fundraising practices are encouraged to report them directly to the Fundraising Regulator using one of the following methods:

All concerns will be treated with confidentiality and seriousness, and the Trust will cooperate fully with any investigation undertaken by the Regulator.

Date of Review–30 September 2025
Next review Date–30 September 2027
Signed on Original Gordon C Hannah
ChinaFleet Trust CEO