Whistleblowing

We recognise that children cannot be expected to raise concerns in an environment where adults fail to do so. All adults involved in Study Links provision of care should be aware of their duty to raise concerns, where they exist, about the management of child protection, which may include the attitude or actions of other adults. The Whistleblowing policy can be found in the handbook.

Public Interest Disclosure (‘Whistleblowing’)

What this policy covers

This policy applies to employees, workers and contractors, and volunteers including homestays.

The Company constantly strives to safeguard and act in the interest of the public and its staff. It is important to the Company that any fraud, misconduct or wrongdoing, by employees, homestays or other agents, is reported and properly addressed.

This policy applies to all employees, homestays and all other agents of the Company, who are encouraged to raise concerns in a responsible manner. The Company prefers that a concern is raised and dealt with properly, rather than kept quiet.

Your responsibilities

You are encouraged to bring to the attention of the Company any practice or action of the Company, its employees, homestays or other agents that you reasonably believe is against the public interest, in that the practice or action is:

• a criminal offence
• a failure to comply with any legal obligation
• a miscarriage of justice
• a danger to the health and safety of any individual
• an attempt to conceal information on any of the above

Any individual raising legitimate concerns will not be subject to any detriment, either during or after employment. The Company will also endeavour to ensure that the individual is protected from any intimidation or harassment by any other parties.

This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work, which should be raised under the Company’s Grievance Procedure.

Procedure

In the first instance, you should raise any concerns you have with your manager or Study Links representative. If you believe your manager or the Study Links representative to be involved, or if, for any reason, you do not wish to approach them, then you should raise it with a more senior person in the Company.

Any matter raised under this policy will be investigated promptly and confidentially. The outcome of the investigation, as well as any necessary remedial action to be taken, will be confirmed to you. If no action is to be taken, the reason for this will be explained to you.

Allegations regarding potential breaches of this policy will be treated in confidence and investigated thoroughly. If you raise any concerns under this policy, the Company is committed to ensuring that you are protected from victimisation, harassment or less favourable treatment. Any such incidents will be dealt with under the Company’s Disciplinary Procedures.

Escalating your concern

If you are dissatisfied with this response, you should raise your concerns in writing directly with a more senior person in the Company.

If, after escalating your concerns, you believe that the appropriate remedial action has not been taken, you should then report the matter to the proper authority. These authorities include

• HM Revenue & Customs
• the Financial Conduct Authority
• the Health and Safety Executive
• the Environment Agency or Scottish Environmental Protection Agency
• the Information Commissioner

This list is not intended to be exhaustive, and you must take care to ensure you contact the proper authority in relation to the particular concerns you have.

If you are unsure as to the appropriate authority, advice can be sought from Protect (formerly known as “Public Concern at Work”) which is an independent Whistleblowing Charity or the NSPCC who offer an advice line. Their contact details are at the end of this policy.

If you raise a false allegation and you are found to be culpable, or in any way involved in the wrongdoing, or if you raise a concern maliciously or in a manner not prescribed in this policy, then you may be subject to disciplinary action up to and including dismissal without notice for gross misconduct or a termination of any contract with Study Links.

You should not disclose to a non-relevant third party any details of any concern raised in accordance with this policy, and you must not, in any circumstances, publicise your concerns in any way.

Independent advice

Independent advice and support can be obtained from Protect (formerly known as “Public Concern at Work”) (Independent Whistleblowing Charity) and the NSPCC:

Review

This policy is reviewed annually taking into account any changes in legislation, practice or roles concerned throughout the year.