1.1 The Public Interest Disclosure Act 1998 protects workers who speak out in the public interest about fraudulent, criminal or dangerous activities, wrong doings or malpractice at work.
1.2 Employees are often the first to realise that there may be something seriously wrong within an organisation. However, they may not express their concerns because they fear harassment or victimisation. They may also feel that speaking up would be disloyal to their colleagues or to the organisation. In these circumstances, it may be easier to ignore the concern rather than report what may just be a suspicion of malpractice.
1.3 The School is committed to the highest possible standards of openness, probity and accountability. In line with that commitment, we expect employees, and others that we deal with, who have serious concerns about any aspect of the School’s work to come forward and voice those concerns. It is recognised that most cases will have to proceed on a confidential basis.
1.4 This Code makes it clear that you can do so without fear of victimisation, subsequent discrimination or disadvantage. This Confidential Reporting Code is intended to encourage and enable employees to raise serious concerns within the School rather than overlooking a problem or “blowing the whistle” outside. It is also designed to protect employees from malicious allegations.
1.5 The Code applies to all employees and those contractors working for the School on School premises, for example, agency staff, builders.
2.1 This Code aims to:
• encourage you to feel confident in raising serious concerns and to question and act upon concerns about practice
• provide an avenue for you to raise those concerns and receive feedback on any action taken
• make sure that you receive a response to your concerns and that you are aware of how to pursue them if you are not satisfied
• reassure you that you will be protected from possible reprisals or victimisation if you have a reasonable belief that you have made any disclosure in good faith.
2.2 The Confidential Reporting Code is intended to cover major concerns that fall outside the scope of other procedures and can include:
• safeguarding and promoting the welfare of children
• conduct which is an offence or a breach of law
• disclosures related to miscarriages of justice
• health and safety risks, including risks to the public as well as other employees
• damage to the environment
• the unauthorised use of school funds
• possible fraud and corruption
• unethical conduct.
2.3 Therefore, you can report any serious concerns that you have about any aspect of the school or the conduct of its employees or others acting on behalf of the School under the Confidential Reporting Code. This may be about something that:
• makes you feel uncomfortable in terms of known standards you experience or the standards you believe the School subscribes to; or
• is against the School’s policies; or
• falls below established standards of practice; or
• amounts to improper conduct.
4 All concerns will be treated in confidence and we will make every effort not to reveal your identity if you so wish. At the appropriate time, however, you may need to come forward as a witness.
5.1 This Code encourages you to put your name to your allegation whenever possible.
5.2 Concerns expressed anonymously are much less powerful but may be considered at the discretion of the School.
5.3 In exercising this discretion, the factors to be taken into account would include the:
• seriousness of the issues raised
• credibility of the concern
• likelihood of confirming the allegation from attributable sources.
6.1 If you voice suspicion in good faith but it is not confirmed by the investigation, no action will be taken against you.
6.2 If the investigation concludes that you have fabricated the allegations, disciplinary action will be taken against you.
7.1 As a first step, you should normally raise concerns with the Head Teacher. This depends however on the seriousness and sensitivity of the issues involved and who is suspected of the malpractice. For example, if you believe that the Head Teacher is involved, you should approach the Chair of Governors.
7.3 Concerns may be raised orally or in writing. If you wish to make a written report you should use the following format:
• the background and history of the concern (giving relevant dates if possible)
• the reason why you are particularly concerned about the situation.
7.4 The earlier you express the concern, the easier it is to take action.
7.5 Although you are not expected to prove beyond doubt the truth of an allegation, you will need to demonstrate to the person contacted that there are reasonable grounds for your concern.
7.8 You may invite your trade union, professional association representative or a friend to be present during any meetings or interviews in connection with the concerns you have raised.
8.1 The School will respond to your concerns. Do not forget that testing out your concerns is not the same as either accepting or rejecting them.
8.2 Where appropriate, the matters raised may:
• be investigated by management, internal audit, or through the disciplinary process
• be referred to the Police
• be referred to the external auditor
• form the subject of an independent inquiry
8.3 In order to protect individuals and those accused of misdeeds or possible malpractice, initial enquiries will be made to decide whether an investigation is appropriate and, if so, what form it should take. The overriding principle which the School will have in mind is the public interest. Concerns or allegations which fall within the scope of specific procedures, such as child protection or discrimination issues, will normally be referred for consideration under those procedures.
8.4 Some concerns may be resolved by agreed action without the need for investigation. If urgent action is required, this will be taken before any investigation is conducted.
8.5 Within ten working days of a concern being raised, the Head Teacher will write to you:
• acknowledging that the concern has been received
• indicating how he proposes to deal with the matter
• giving an estimate of how long it will take to provide a final response
• telling you whether any initial enquiries have been made
• supplying you with information on staff support mechanisms
• telling you whether further investigations will take place and, if not, why not.
8.8 The School will take all practical steps to minimise any difficulties which you may experience either at the time, or in the future as a result of raising a concern. For instance, if you are required to give evidence in criminal or disciplinary proceedings, the School will arrange for you to receive advice about the procedure and will arrange for someone to attend for support if you have not arranged your own support.
8.9 The School accepts that you need to be assured that the matter has been properly addressed. Thus, subject to legal constraints, we will inform you of the outcome of any investigation.