Whistleblowing Policy

Last review date: 30th May 2024

Next review date: 30th May 2025

Purpose and objective

The Whistleblowing policy ensures that employees and learners may report incidents of wrongdoing or suspected malpractice without fear of retaliation.

1. Scope

This policy is owned wholly by Raise the Bar. It is the responsibility of line managers and HR to ensure its fair and consistent implementation. Regular checks will be conducted to ensure this policy is adhered to. This policy applies to all permanent staff of Raise the Bar, clients, and learners.

2. Examples

This policy is intended to cover concerns which are in the public interest of Raise the Bar and may, at least initially, be investigated separately but might then lead to the invocation of other procedures, e.g., disciplinary.

These concerns could include:

  • Financial malpractice or impropriety or fraud
  • Tax evasion
  • Failure to comply with a legal obligation or statutes.
  • Dangers to Health & Safety or the Environment
  • Criminal activity
  • Improper conduct or unethical behaviour
  • Fraudulent activities relating to government funding, including ESFA/DfE apprenticeships.
  • Fraudulent activities in relation to accredited qualifications
  • Attempts to conceal any of these.

3. Procedure

If an employee, client, or learner discovers a breach of company policy or indeed has concerns listed above, there is a facility for him/her to report that breach in confidence either via their line manager, if appropriate, or via a letter or email addressed directly to the Managing Director at RTB at 13a Tiger Court, Kings Business Park L34 1PJ or whistleblowing@raisethebar.co.uk

The Managing Director will investigate the alleged breach. If unsatisfied with the outcome, the whistle-blower should raise the matter with the appropriate organization or body, e.g., the Police, the Environment Agency, Health and Safety Executive, Social Services Department, ESFA, or DfE.

ESFA Contact Details:
www.customerhelpportal.education.gov.uk
or www.form.education.gov.uk/service/Contact_the_Department_for_Education

The Public Interest Disclosure Act 1998 prevents employees from suffering a detriment or having their contract terminated for ‘whistleblowing’, and the Company takes very seriously any concerns that employees may raise under this legislation.

The Company encourages individuals to use the procedure if concerned about any wrongdoing at work. However, if the procedure has not been invoked in good faith (e.g., for malicious reasons or in pursuit of a personal grudge), then it may render the employee liable to immediate termination of employment or such lesser disciplinary sanction as may be appropriate in the circumstances and as per the disciplinary policy.

In accordance with ESFA guidance on whistleblowing disclosures, Raise the Bar acknowledges the importance of promptly and appropriately handling any disclosures related to ESFA-funded activities, including apprenticeships. Any concerns specifically related to ESFA-funded programs should be addressed in alignment with ESFA guidelines and may be escalated to ESFA as necessary.
Link to ESFA Guidance:
www.gov.uk/guidance/how-esfa-handleswhistleblowing-disclosures

4. Safeguards

Protection: This policy is designed to offer protection of a Raise the Bar employee, client, or learner who discloses concerns provided the disclosure is made in good faith.
Confidentiality: Raise the Bar will treat all such disclosures confidentially and sensitively.
Untrue Allegations: If an individual makes an allegation, in good faith, which is not confirmed by subsequent investigation, no action will be taken against the individual.

5. Policy Review and Updates

This policy will be reviewed annually to ensure its effectiveness and relevance in addressing emerging circumstances. Updates or amendments may be made as necessary to reflect evolving business needs and regulatory requirements.
Policy Owner: Laura Moore
Version: 1 Initial Draft (March – 2024)

Approval

This Whistleblowing Policy was approved by the Executive Board of Raise the Bar.

Signed: Becs Bridge (Managing Director)

Date: 30.05.24

Monitoring and Review

This policy will be monitored as required to review its effectiveness and will be updated in accordance with necessary changes.