Whistleblowing Policy

Last review date: 16th February 2026

Next review date: 16th February 2028

1. Introduction

At Raise the Bar, we are committed to conducting our business with integrity, transparency, and accountability. Whistleblowing is an important assurance mechanism that enables individuals to raise genuine concerns about suspected wrongdoing or malpractice connected with Raise the Bar, where they feel unable to raise such concerns through normal channels.

Raise the Bar encourages a culture of openness and aims to ensure that concerns are raised and addressed appropriately, without fear of retaliation.

1. Scope

This policy applies to all individuals connected with Raise the Bar, including:
• Employees (permanent, temporary, and fixed-term)
• Learners and apprentices
• Contractors, consultants, and agency workers
• Members of the public, including clients and partners

All disclosures made under this policy will be taken seriously and handled fairly, sensitively, and in line with applicable legal and regulatory requirements, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

3. What is Whistleblowing?

Whistleblowing is the reporting of suspected wrongdoing that is in the public interest and relates to Raise the Bar’s activities. Such concerns may initially be investigated under this policy but may subsequently lead to other procedures being invoked where appropriate, including disciplinary, safeguarding, or regulatory processes.

4. Examples of Wrongdoing

Concerns that may be raised under this policy include, but are not limited to:

• Financial malpractice, impropriety, or fraud
• Tax evasion
• Failure to comply with legal obligations or statutory requirements
• Dangers to health and safety or the environment
• Criminal activity
• Improper conduct or unethical behaviour
• Fraudulent activity relating to government funding, including DfE-funded apprenticeships
• Fraudulent activity relating to accredited qualifications
• Safeguarding concerns involving learners, apprentices, or vulnerable individuals
• Attempts to conceal any of the above

5. Anonymous Reporting

Raise the Bar recognises that some individuals may wish to raise concerns anonymously. Anonymous disclosures will be considered and investigated as far as reasonably practicable, based on the information provided. However, individuals are encouraged to provide contact details where possible to support a more effective investigation.

6. Reporting Procedure

Individuals who have a serious concern about suspected wrongdoing connected with Raise the Bar should raise the matter as soon as possible. Where it is not appropriate or comfortable to raise the concern through normal channels, disclosures may be made in confidence by email to: whistleblowing@raisethebar.co.uk

Or, if preferred, by letter marked Private & Confidential to: Raise the Bar, 13A Tiger Court, Kings Business Park, L34 1PJ

7. Investigation Process

• Depending upon the nature of the concern, an appropriate and impartial investigator will be appointed. This will usually be a member of the Senior Leadership Team however an external investigator may be engaged where necessary.
• Where the whistleblower is not anonymous, an acknowledgment will be issued within 15 working days of receipt.
• Updates will be provided where appropriate and possible.
• A final outcome will be communicated within 40 working days of submission, where reasonably practicable and subject to confidentiality constraints.
• If the individual remains dissatisfied with the outcome, they may escalate the concern to an appropriate external body.

8. Legal Protections and Safeguards

8.1 Employees

Employees are protected under the Public Interest Disclosure Act 1998 from suffering detriment or dismissal as a result of making a protected disclosure. Raise the Bar takes its obligations under this legislation seriously.

8.2 Learners, Contractors, and Members of the Public

While statutory whistleblowing protections apply specifically to employees, Raise the Bar will not tolerate retaliation or disadvantage against any individual who raises a concern in good faith under this policy.

8.3 Good Faith Disclosures

Where a concern is raised in good faith but is not substantiated following investigation, no action will be taken against the individual.

Where it is determined that a disclosure has been made maliciously or in bad faith, Raise the Bar may take appropriate action in line with relevant policies, contracts, or agreements.

9. External Reporting Channels

Where concerns are not resolved internally, or where individuals believe it is appropriate to do so, concerns may be raised with external bodies, including:

• Department for Education (DfE) (see section 10)
• Safeguarding authorities: Local Authority Designated Officer (LADO) and/or the Disclosure and Barring Service (DBS)
• Health and Safety: Health and Safety Executive (HSE)
• Criminal matters: The Police (via 101 or Police.uk)

10. Department for Education (DfE) Whistleblowing Disclosures

In addition to Raise the Bar’s internal whistleblowing arrangements, individuals may raise concerns directly with the Department for Education (DfE) where the disclosure relates to education or training provision, safeguarding, or the use of public funding.

Raise the Bar recognises and supports the DfE whistleblowing process and acknowledges the importance of transparency and accountability in matters relating to DfE-funded activity, including apprenticeships.

Raise the Bar encourages individuals to raise concerns internally in the first instance wherever possible. However, this policy does not prevent anyone from making a disclosure directly to the DfE or another appropriate external body at any time.

The DfE defines whistleblowing as the disclosure of information which, in the reasonable belief of the individual making the disclosure, is made in the public interest and tends to show one or more of the following:

• Criminal activity
• A breach of legal obligations
• A miscarriage of justice
• Danger to the health or safety of individuals
• Damage to the environment
• Deliberate concealment of information relating to any of the above

Concerns may relate to the actions of an organisation, its staff, or others involved in the delivery of education or training. Individuals can make a whistleblowing disclosure to the Department for Education by following the guidance available at: How DfE handles whistleblowing disclosures – GOV.UK

11. Governance, Review, and Approval

This policy has been approved by the Executive Board of Raise the Bar Ltd.

The policy will be reviewed bi-annually, or sooner where required, to ensure continued effectiveness, compliance with legislation, and alignment with regulatory expectations.