6 Sutton Park Road, Sutton, SM1 2GD
Whistleblowing Policy
Policy Statement
The School is committed to fostering a culture of openness, integrity, and accountability. Our Whistleblowing Policy ensures that all members of the School community, including staff, students, contractors, and vendors, can raise concerns about malpractice, wrongdoing, or risks in confidence and without fear of retaliation. All genuine concerns will be taken seriously and investigated promptly and appropriately.
Principles
- Integrity: Promoting an organisational culture of honesty and integrity.
- Protection: Providing protection from retaliation for whistleblowers.
- Confidentiality: Ensuring the confidentiality of the individual raising the concern.
- Clarity: Providing a clear and accessible procedure for raising concerns.
- Accountability: Holding all levels of the organisation accountable for their actions.
- Transparency: Encouraging transparency in addressing wrongdoing.
- Responsiveness: Committing to a prompt and thorough investigation of concerns.
- Support: Offering support and guidance to whistleblowers.
- Fairness: Assuring fair treatment for all parties involved in the whistleblowing process.
- Prevention: Aiming to prevent malpractice and address it early when it occurs.
- Awareness: Raising awareness of the whistleblowing procedures among all stakeholders.
- Monitoring: Regularly reviewing the effectiveness of the whistleblowing policy and procedures.
Regulatory Context
This Policy has been developed in line with the applicable laws, regulations, regulatory advice, and sector best practices, including the following:
Encouraging Open Communication on Workplace Concerns
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Definition
Encouraging Reporting of Concerns Whistleblowing is defined as reporting serious concerns, including fraud, discrimination, harassment, and health and safety violations. Employees are encouraged to raise concerns about malpractice, wrongdoing, or welfare issues at work as early as possible. Concerns should be raised internally; if this is not suitable, staff may report to an external body listed in the policy or seek advice from the Protect advice line. All reports will be treated confidentially, with identities disclosed only with prior consent. Employees will not face penalties for disclosures made in good faith. This policy aligns with the Public Interest Disclosure Act 1998 and the Employment Rights Act 1996, which protect workers who report alleged wrongdoing. The Board of Governors promotes a culture of openness, urging employees to voice concerns promptly to prevent escalation. This policy reassures staff that raising concerns reflects loyalty to the organisation and provides legal protection for disclosures made in the public interest. Clearly defining whistleblowing and providing examples helps employees recognise serious concerns, encouraging proactive reporting and fostering a culture of transparency and accountability. |
Who Does this Policy Apply To
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Advice
Scope of Policy Application This policy applies to all employees, contractors, and associated personnel working at the School, including:
Defining the scope ensures that everyone associated with the School, whether directly or indirectly, understands their obligations and responsibilities under this policy, fostering a culture of compliance and accountability. |
School Assurances
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Rule
Protection and Confidentiality in Raising Concerns The Board of Governors is committed to ensuring all staff are aware of this policy through induction and regular reminders. Raising a genuine concern will not put your job at risk or expose you to retaliation. If you act in good faith, you will be protected, even if mistaken. However, deliberate false or malicious allegations may lead to disciplinary action. All reports will be treated confidentially to protect your identity and encourage openness. We will not disclose your identity without consent unless legally required. If you prefer confidentiality, please inform us at the outset. Anonymous reports are harder to investigate, and we cannot provide protection or feedback without your identity. For independent advice, contact the whistleblowing charity, Protect. Support services, including counselling and legal advice, are also available. This section emphasises the importance of confidentiality and protection from retaliation, reassuring employees that their concerns will be handled seriously. By providing information on support services, the policy fosters an environment where staff feel safe to raise issues, ultimately enhancing workplace transparency and trust. |
What Kind of Concerns May be Raised
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Definition
Scope of Whistleblowing Policy This policy applies to serious concerns regarding service provision, conduct of employees, the Board of Governors, or others acting on their behalf. It includes issues that:
Concerns covered by this policy include:
Concerns that do not qualify as whistleblowing include personal grievances such as bullying or harassment. Issues affecting individuals or related to employment contracts should follow the staff grievance procedures. For guidance on whether a concern is a whistleblowing issue or a grievance, contact Protect (formerly Public Concern at Work), which offers:
This rule defines the scope of the whistleblowing policy, clarifying the types of concerns it covers and distinguishing them from personal grievances. It provides clear guidance on when to use the whistleblowing policy and where to seek further advice, ensuring proper procedures are followed and promoting accountability. |
How is a Concern or Disclosure Raised
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Advice
Named Contacts for Reporting Concerns The Board of Governors has appointed the following contacts for reporting concerns:
When raising a concern, you should provide as much background and context as possible. You are not required to prove the allegation beyond doubt, but you must act in good faith and reasonably believe that the information and any allegations are substantially true. Reports made to any other staff member must be promptly forwarded to one of the named contacts. This rule clarifies the designated contacts for reporting concerns, ensuring all disclosures are directed to the appropriate individuals. It establishes the requirement for good faith in reporting, which is essential for the protection of all parties involved and for maintaining the integrity of the process. |
How the Board of Governors will Respond
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Rule
Procedure for Handling Disclosures The following steps will be taken to address concerns raised under this policy:
This rule ensures a clear and systematic approach to handling concerns, protecting all individuals involved. It establishes timeframes for acknowledging and addressing concerns, provides support for individuals, and maintains confidentiality, while also aiming to keep individuals informed of outcomes. This process is essential for upholding transparency and fairness within the institution. |
Governance and Reporting
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Rule
Oversight and Reporting of Whistleblowing Concerns To ensure consistent handling of whistleblowing concerns, the President will oversee operational management and maintain central records in the Automated Governance System (AGS). An annual report will be submitted to the Board of Governors, including an anonymised summary of the concerns raised, the departments or services involved, relevant posts (if not confidential), and any lessons learned. The institution is committed to raising awareness of the whistleblowing policy and providing training for staff and students on their rights and responsibilities. Regular monitoring of the policy’s effectiveness will take place, with a commitment to review and update it as necessary. This systematic approach promotes transparency, accountability, and continuous improvement while protecting confidentiality and providing insights for enhancing organisational practices. Incorporating awareness and training, along with regular monitoring and review, strengthens the effectiveness of the whistleblowing policy. By ensuring all staff and students are informed of their rights and responsibilities, the institution fosters a culture of transparency and trust, encouraging individuals to raise concerns confidently and facilitating ongoing improvement in practices. |
Metrics and KPIs
The following metrics will be measured and regularly reviewed as key performance indicators for the School to ensure the effectiveness of this policy and associated operations.
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Average Time to Investigate Reports
Measure the average duration, in days, to complete investigations from report receipt to resolution. This KPI assesses the efficiency of the investigation process and helps ensure that concerns are resolved promptly. |
Number of Reports by Category
Categorise and count the number of reports by type (e.g., fraud, misconduct, safety). Understanding the types of concerns raised helps target improvements and allocate resources effectively. |
Number of Whistleblowing Reports Received
Track the total number of whistleblowing reports received annually. This KPI measures the level of engagement with the policy and helps assess whether staff and students are aware of and willing to use the reporting mechanisms. |
Percentage of Reports Acknowledged Within 5 Working Days
Monitor the percentage of whistleblowing reports acknowledged within 5 working days of receipt. Timely acknowledgment shows responsiveness and reassures reporters that their concerns are being taken seriously. |