Safeguarding Policy

We will always aim to keep a whistleblower’s identify confidential where asked to do so although we cannot guarantee this, and we may need to disclose your identity should the complaint lead to issues that need to be taken forward by other parties. For example:

  • The police, fraud prevention agencies or other law enforcement agencies (to investigate or prevent crime, including fraud)
  • The courts (in connection with any court proceedings)
  • Other third parties such as the relevant regulatory authority (e.g. Ofqual in England).

The investigator(s) assigned to review the allegation will not reveal the whistleblower’s identity unless the whistleblower agrees or it is absolutely necessary for the purposes of the investigation (as noted above). The investigator(s) will advise the whistleblower if it becomes necessary to reveal their identity against their wishes.

A whistleblower should also recognise that he or she may be identifiable by others due to the nature or circumstances of the disclosure (e.g. the party which the allegation is made against may manage to identify possible sources of disclosure without such details being disclosed to them).

Once a concern has been raised we have a duty to pursue the matter. It will not be possible to prevent the matter being investigated by subsequently withdrawing their concern as we are obliged by the regulators to follow-up and investigate allegations of malpractice or maladministration.

In all cases, we will keep you updated as to how we have progressed the allegation (e.g. we have undertaken an investigation) and the whistle-blower will have the opportunity to raise any concerns about the way the investigation is being conducted with the investigator(s). However, we won’t disclose details of all of the investigation activities and it may not be appropriate for us to disclose full details of the outcomes of the investigation due to confidentiality or legal reasons (e.g. disclose full details on the action that may be taken against the parties concerned). While we cannot guarantee that we will disclose all matters in the way that you might wish, we will strive to handle the matter fairly and properly.

 

Investigations

The paragraphs below explain how an investigation is likely to be handled.

Responsibility for the Investigation

In accordance with regulatory requirements all suspected cases of malpractice and/or maladministration will be examined promptly by The Company to establish if malpractice or maladministration has occurred and we will take all reasonable steps taken to prevent any adverse effect from occurring as defined by the regulators.

All suspected cases of malpractice and maladministration will be passed to our Head of Centre Management and we will acknowledge receipt, as appropriate, to external parties within 48 hours. All high-risk cases of malpractice and/or maladministration will be escalated to the Head of Compliance and Assurance to investigate further.

Our Head of Compliance and Assurance will be responsible for ensuring the investigation is carried out in a prompt and effective manner and in accordance with the procedures in this policy and will allocate a relevant member of staff (e.g. a member of our centre management team/escalated to compliance and assurance) to lead the investigation and establish whether or not the malpractice or maladministration has occurred, and review any supporting evidence received or gathered by The Company.

At all times we will ensure that The Company personnel assigned to the investigation have the appropriate level of training and competence and they have had no previous involvement or personal interest in the matter.

Notifying Relevant Parties

In all cases we will tell the person who made the allegation who will be handling the matter, how they can contact them, what further assistance we may need from them and agree a timetable for feedback (see the above section on ‘Confidentiality and Whistleblowing’ for possible limitations in relation to the feedback, and the section below on ‘Investigation Timelines and Summary Process’ for details of our anticipated response times).