The College is committed to conducting its business with honesty and integrity and we expect all employees to maintain high standards. Any behaviour or actions that do not meet these standards or any suspected wrongdoing should be reported as soon as possible.
This policy applies to all persons working for the College or on our behalf in any capacity, including employees at all levels, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with the College, wherever located.
Students at City Lit are also encouraged to raise genuine concerns about suspected wrongdoing by making a complaint to the Whistleblowing Officer.
This policy does not form part of any employee’s contract of employment, and we may amend it at any time.
This policy should be read alongside the Anti-Corruption and Bribery Policy and the Anti-Fraud Policy.
What is whistleblowing?
Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our activities. This includes bribery, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment and any breach of legal or professional obligations.
A whistle-blower is a person who raises a genuine concern relating to any of the above. If an employee has a genuine concern related to suspected wrongdoing or danger affecting any of the College's activities, they should report it under this policy.
This policy should not be used for complaints relating to an employee's own personal circumstances, such as the way an employee has been treated at work. In these cases, the employee should use the Grievance Procedure as appropriate.
If an employee is uncertain whether something is within the scope of this policy, they should seek advice from the Whistleblowing Officer. Contact details are at the end of this policy.
How to raise a concern
We hope that in many cases employees will be able to raise any concerns with their line manager. However, where they prefer not to raise it with their manager for any reason, they should contact the Whistleblowing Officer.
When you report your concern, please state the background history of the concern (giving relevant dates) and the reason why you are particularly concerned about the situation. A meeting will be raised as soon as possible with the employee to discuss their concern/s. The employee may bring a colleague or union representative to any meetings under this policy. The companion must respect the confidentiality of the disclosure and any subsequent investigation. The college will take down a written summary of the employee's concern and provide them with a copy after the meeting. The College will also aim to give the employee an indication of how it proposes to deal with the matter.
We hope that employees will feel able to voice whistleblowing concerns openly under this policy. Completely anonymous disclosures are difficult to investigate. If an employee wants to raise their concerns confidentially, we will make every effort to keep their identity secret and only reveal it where necessary to ensure a proper investigation is carried out.
The College does not encourage employees to make disclosures anonymously. Proper investigation may be more difficult or impossible if the College cannot obtain further information from the employee. It is also more difficult to establish whether any allegations are credible. Whistleblowers who are concerned about reprisal if their identity is revealed should come forward to the Whistleblowing Officer and appropriate measures can then be taken. The College will not make efforts to identity staff who make disclosures before, and outside, of the formal investigations process.
All documents created as part of an investigation will be held securely and access restricted to a need-to-know basis. Documents will be held for as long as necessary. The retention period will be determined by factors such as whether the concern is upheld or not and what recommendations are made.
Investigation and outcome
Once an employee has raised a concern, the College will carry out an initial assessment to determine the scope of any investigation. The College will inform the employee of the outcome of its assessment. The employee may be required to attend additional meetings in order to provide further information.
In some cases, the College may appoint an investigator or team of investigators including staff with relevant experience of investigations or specialist knowledge of that subject matter. The investigator(s) may make recommendations for change to enable the College to minimise the risk of future wrongdoing. The College will take all steps within their power to ensure the recommendations are implemented within a reasonable timescale unless there are good reasons for not doing so.
The College will aim to keep the employee informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent the College giving the employee specific details of the investigation or any disciplinary action taken as a result. The employee should treat any information about the investigation as confidential.
If the College concludes that a whistle-blower has made false allegations maliciously or with a view to personal gain, the whistle-blower will be subject to disciplinary action.
If the employee is not satisfied
While the College cannot always guarantee the outcome the employee is seeking, the College will try to deal with an employee’s concern fairly and in the appropriate way. By using this policy, the employee can help the College to achieve this.
If an employee is not happy with the way in which their concern has been handled, they can appeal against the outcome by raising the issue with the Principal within one week from the date of the outcome. The Principal or a member of the Executive team not previously involved will make a final decision on action to be taken and notify the employee who made the disclosure.
If the issue involves the Principal, an employee can raise their concerns with the Clerk to the Governors. In the event that the issue relates to the Clerk to the Governors, an employee can raise their concerns with the Chair of the Governing Body.
The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases an employee should not find it necessary to alert anyone externally.
The law recognises that in some circumstances it may be appropriate for an employee to report their concerns to an external body such as a regulator. We strongly encourage employees to seek advice before reporting a concern to anyone external. Protect (Public Concern at Work) operates a confidential helpline. Their contact details are at the end of this policy.
Safeguards: Protection and support for whistle-blowers
The College aims to encourage openness and will support whistle-blowers who raise genuine concerns under this policy, even if they turn out to be mistaken.
Whistle-blowers must not suffer any detrimental treatment as a result of raising a genuine concern. If employees believe that they have suffered any such treatment, they should inform the Whistleblowing Officer immediately.
Staff must not threaten or retaliate against whistle-blowers in any way. Employees who are involved in such conduct may be subject to disciplinary action.
However, if the College conclude that a whistle-blower has made false allegations maliciously or with a view to personal gain, the whistle-blower may be subject to disciplinary action.
Graham Jennings, Head of Data Compliance & Business Planning
Alternate contact independent of management structure:
Katrina O’Sullivan, Clerk to Governors
Employees can also contact the charity Protect (previously known as Public Concern at Work) for confidential advice on whistleblowing issues
Address: The Green House 244-254 Cambridge Heath Road London E2 9DA
Protect Advice Line: 020 3117 2520
Protect Advice line: firstname.lastname@example.org
Approved by Governing Body March 2022