Company number: 12497951
6 Sutton Park Road, Sutton, SM1 2GD

Whistleblowing Policy

Policy Statement

The School is committed to fostering a culture of openness, integrity, and accountability. Our Whistleblowing Policy ensures that all members of the School community, including staff, students, contractors, and vendors, can raise concerns about malpractice, wrongdoing, or risks in confidence and without fear of retaliation. All genuine concerns will be taken seriously and investigated promptly and appropriately.

Principles

Integrity: Promoting an organisational culture of honesty and integrity.
Protection: Providing protection from retaliation for whistleblowers.
Confidentiality: Ensuring the confidentiality of the individual raising the concern.
Clarity: Providing a clear and accessible procedure for raising concerns.
Accountability: Holding all levels of the organisation accountable for their actions.
Transparency: Encouraging transparency in addressing wrongdoing.
Responsiveness: Committing to a prompt and thorough investigation of concerns.
Support: Offering support and guidance to whistleblowers.
Fairness: Assuring fair treatment for all parties involved in the whistleblowing process.
Prevention: Aiming to prevent malpractice and address it early when it occurs.
Awareness: Raising awareness of the whistleblowing procedures among all stakeholders.
Monitoring: Regularly reviewing the effectiveness of the whistleblowing policy and procedures.

Regulatory Context

This Policy has been developed in line with the applicable laws, regulations, regulatory advice, and sector best practices, including the following:

Authority	Name	Url
UK Government	Higher Education and Research Act 2017 (HERA) A UK legislation that reformed the higher education and research sector, particularly by establishing the Office for Students and UK Research and Innovation.
Office for Students (OfS)	Regulatory Notices and Advice Regulatory notices are additional information about OfS' regulatory requirements and are part of the regulatory framework. Regulatory advice helps providers understand and meet OfS requirements.
Quality Assurance Agency (QAA)	The Quality Code This code represents a shared understanding of quality practice across the UK higher education sector, protecting public and student interests and championing the UK's reputation for quality.
Advance HE	Code of Governance for Universities A code of governance that sets out the principles and standards that universities in the UK should follow.
Committee of University Chairs	The Higher Education Code of Governance A code aimed at ensuring the highest levels of governance at higher education institutions.

Authority

Name

Url

UK Government

Higher Education and Research Act 2017 (HERA)
A UK legislation that reformed the higher education and research sector, particularly by establishing the Office for Students and UK Research and Innovation.

Office for Students (OfS)

Regulatory Notices and Advice
Regulatory notices are additional information about OfS' regulatory requirements and are part of the regulatory framework. Regulatory advice helps providers understand and meet OfS requirements.

Quality Assurance Agency (QAA)

The Quality Code
This code represents a shared understanding of quality practice across the UK higher education sector, protecting public and student interests and championing the UK's reputation for quality.

Advance HE

Code of Governance for Universities
A code of governance that sets out the principles and standards that universities in the UK should follow.

Committee of University Chairs

The Higher Education Code of Governance
A code aimed at ensuring the highest levels of governance at higher education institutions.

Encouraging Open Communication on Workplace Concerns

Title
Advice Encouraging Reporting of Concerns Employees are encouraged to raise any concerns about malpractice, wrongdoing, health and safety, or a person's welfare at work as early as possible. Concerns should be raised internally according to this policy. If internal reporting is not suitable, staff may report to an external body listed in the policy or seek advice from the Protect advice line. Concerns will be treated confidentially, and identities will not be disclosed without prior consent. Employees will not face penalties for making a disclosure in good faith. This policy aligns with the Public Interest Disclosure Act 1998 and the Employment Rights Act 1996, which protect workers who disclose information about alleged wrongdoing. To maintain a high standard of openness, the Board of Governors encourages employees to voice concerns promptly, preventing issues from escalating into more severe problems. This policy ensures that concerns are taken seriously and addressed appropriately, fostering a safe and transparent work environment. It also reassures staff that raising concerns demonstrates loyalty and commitment to the organisation, and provides legal protection for disclosures made in the public interest.

Title

Advice
Encouraging Reporting of Concerns

Employees are encouraged to raise any concerns about malpractice, wrongdoing, health and safety, or a person's welfare at work as early as possible. Concerns should be raised internally according to this policy. If internal reporting is not suitable, staff may report to an external body listed in the policy or seek advice from the Protect advice line.

Concerns will be treated confidentially, and identities will not be disclosed without prior consent. Employees will not face penalties for making a disclosure in good faith. This policy aligns with the Public Interest Disclosure Act 1998 and the Employment Rights Act 1996, which protect workers who disclose information about alleged wrongdoing.

To maintain a high standard of openness, the Board of Governors encourages employees to voice concerns promptly, preventing issues from escalating into more severe problems. This policy ensures that concerns are taken seriously and addressed appropriately, fostering a safe and transparent work environment. It also reassures staff that raising concerns demonstrates loyalty and commitment to the organisation, and provides legal protection for disclosures made in the public interest.

How is a Concern or Disclosure Raised

Title
Advice Named Contacts for Reporting Concerns The Board of Governors has appointed the following contacts for reporting concerns: Paymon Khamooshi, President (Email: Paymon.khamooshi@lsi.ac.uk) Somayeh Aghnia, Chairperson (Email: Somayeh.aghnia@lsi.ac.uk) When raising a concern, you should provide as much background and context as possible. You are not required to prove the allegation beyond doubt, but you must act in good faith and reasonably believe that the information and any allegations are substantially true. Reports made to any other staff member must be promptly forwarded to one of the named contacts. This rule clarifies the designated contacts for reporting concerns, ensuring all disclosures are directed to the appropriate individuals. It establishes the requirement for good faith in reporting, which is essential for the protection of all parties involved and for maintaining the integrity of the process.

Title

Advice
Named Contacts for Reporting Concerns

The Board of Governors has appointed the following contacts for reporting concerns:

Paymon Khamooshi, President (Email: Paymon.khamooshi@lsi.ac.uk)
Somayeh Aghnia, Chairperson (Email: Somayeh.aghnia@lsi.ac.uk)

When raising a concern, you should provide as much background and context as possible. You are not required to prove the allegation beyond doubt, but you must act in good faith and reasonably believe that the information and any allegations are substantially true. Reports made to any other staff member must be promptly forwarded to one of the named contacts.

This rule clarifies the designated contacts for reporting concerns, ensuring all disclosures are directed to the appropriate individuals. It establishes the requirement for good faith in reporting, which is essential for the protection of all parties involved and for maintaining the integrity of the process.

Governance and Reporting

Title
Advice Oversight and Reporting of Whistleblowing Concerns To ensure consistent handling of whistleblowing concerns, the President will oversee operational management and maintain central records in the Automated Governance System (AGS). An annual report will be submitted to the Board of Governors, including an anonymised summary of: The concerns raised The departments or services involved The relevant posts (if not confidential) Any lessons learned This rule ensures systematic oversight and transparency in managing whistleblowing concerns. By maintaining central records and providing an annual report, it facilitates consistent practice, accountability, and continuous improvement, while protecting confidentiality and providing valuable insights for enhancing organisational practices.

Title

Advice
Oversight and Reporting of Whistleblowing Concerns

To ensure consistent handling of whistleblowing concerns, the President will oversee operational management and maintain central records in the Automated Governance System (AGS). An annual report will be submitted to the Board of Governors, including an anonymised summary of:

The concerns raised
The departments or services involved
The relevant posts (if not confidential)
Any lessons learned

This rule ensures systematic oversight and transparency in managing whistleblowing concerns. By maintaining central records and providing an annual report, it facilitates consistent practice, accountability, and continuous improvement, while protecting confidentiality and providing valuable insights for enhancing organisational practices.

How the Board of Governors will Respond

Title
Advice Procedure for Handling Disclosures The following steps will be taken to address concerns raised under this policy: Initial enquiries will be made to determine whether an investigation is necessary. Depending on the nature of the concern, it may be: Investigated by a member of the Management Team or the Board of Governors, or through relevant disciplinary procedures Referred to the police or other appropriate agencies Referred to an external auditor Subject to an independent enquiry Resolved by agreed action without further investigation Within 10 working days, the named contact will: Acknowledge receipt of your concern Outline how the matter will be addressed and provide an estimated timeframe Offer information on staff support mechanisms If investigation officers need to meet with you, this can be off-site if preferred, and you may bring a trade union representative or another advisor. All parties must maintain strict confidentiality. The relevant board will take steps to minimise any difficulties you may face as a result of raising a concern and will support you if you need to provide evidence at a criminal or disciplinary hearing. While confidentiality will be upheld, the board will make efforts to inform you of the investigation’s outcome where possible. This rule ensures a clear and systematic approach to handling concerns, protecting all individuals involved. It establishes timeframes for acknowledging and addressing concerns, provides support for individuals, and maintains confidentiality, while also aiming to keep individuals informed of outcomes. This process is essential for upholding transparency and fairness within the institution.

Title

Advice
Procedure for Handling Disclosures

The following steps will be taken to address concerns raised under this policy:

Initial enquiries will be made to determine whether an investigation is necessary. Depending on the nature of the concern, it may be:
- Investigated by a member of the Management Team or the Board of Governors, or through relevant disciplinary procedures
- Referred to the police or other appropriate agencies
- Referred to an external auditor
- Subject to an independent enquiry
- Resolved by agreed action without further investigation
Within 10 working days, the named contact will:
- Acknowledge receipt of your concern
- Outline how the matter will be addressed and provide an estimated timeframe
- Offer information on staff support mechanisms
If investigation officers need to meet with you, this can be off-site if preferred, and you may bring a trade union representative or another advisor. All parties must maintain strict confidentiality.
The relevant board will take steps to minimise any difficulties you may face as a result of raising a concern and will support you if you need to provide evidence at a criminal or disciplinary hearing.
While confidentiality will be upheld, the board will make efforts to inform you of the investigation’s outcome where possible.

This rule ensures a clear and systematic approach to handling concerns, protecting all individuals involved. It establishes timeframes for acknowledging and addressing concerns, provides support for individuals, and maintains confidentiality, while also aiming to keep individuals informed of outcomes. This process is essential for upholding transparency and fairness within the institution.

School Assurances

Title
Advice Protection and Confidentiality in Raising Concerns The Board of Governors is committed to ensuring all staff are aware of this policy through induction and regular reminders. Raising a genuine concern under this policy will not put your job at risk or expose you to retaliation. If you act in good faith, you will be protected, even if mistaken. However, deliberately false or malicious allegations may lead to disciplinary action. We encourage concerns to be raised openly. If you prefer confidentiality, inform us at the outset. We will not disclose your identity without your consent unless legally required. If resolving a concern necessitates revealing your identity, we will discuss it with you and agree on how to proceed. Anonymous reports are more difficult to investigate, and we cannot provide protection or feedback without your identity. For independent advice, contact the whistleblowing charity, Protect.

Title

Advice
Protection and Confidentiality in Raising Concerns

The Board of Governors is committed to ensuring all staff are aware of this policy through induction and regular reminders.

Raising a genuine concern under this policy will not put your job at risk or expose you to retaliation. If you act in good faith, you will be protected, even if mistaken. However, deliberately false or malicious allegations may lead to disciplinary action.
We encourage concerns to be raised openly. If you prefer confidentiality, inform us at the outset. We will not disclose your identity without your consent unless legally required. If resolving a concern necessitates revealing your identity, we will discuss it with you and agree on how to proceed.
Anonymous reports are more difficult to investigate, and we cannot provide protection or feedback without your identity.
For independent advice, contact the whistleblowing charity, Protect.

Who Does this Policy Apply To

Title
Advice Scope of Policy Application This policy applies to all employees, contractors, and associated personnel working at the School, including: Founders Board members Volunteers Agency staff Builders and drivers Providers of works, services, or supplies, including external contractors and those delivering services under contracts with the Local Authority or the School. Defining the scope ensures that everyone associated with the School, whether directly or indirectly, understands their obligations and responsibilities under this policy, fostering a culture of compliance and accountability.

Title

Advice
Scope of Policy Application

This policy applies to all employees, contractors, and associated personnel working at the School, including:

Founders
Board members
Volunteers
Agency staff
Builders and drivers
Providers of works, services, or supplies, including external contractors and those delivering services under contracts with the Local Authority or the School.

Defining the scope ensures that everyone associated with the School, whether directly or indirectly, understands their obligations and responsibilities under this policy, fostering a culture of compliance and accountability.

What Kind of Concerns May be Raised

Title
Advice Scope of Whistleblowing Policy This policy applies to serious concerns regarding service provision, conduct of employees, the Board of Governors, or others acting on their behalf. It includes issues that: Violate established standards or policies Fall below expected practice Constitute improper conduct Concerns covered by this policy include: Criminal offences that have occurred, are occurring, or are likely to occur Non-compliance with legal obligations Disclosures of miscarriages of justice Health and safety risks, including risks to the public Environmental damage Breaches of policies and procedures Concealment of any information relating to the above Concerns that do not qualify as whistleblowing include personal grievances such as bullying or harassment. Issues affecting individuals or related to employment contracts should follow the staff grievance procedures. For guidance on whether a concern is a whistleblowing issue or a grievance, contact Protect (formerly Public Concern at Work), which offers: Clarification on the difference between whistleblowing and grievances A free and confidential advice line This rule defines the scope of the whistleblowing policy, clarifying the types of concerns it covers and distinguishing them from personal grievances. It provides clear guidance on when to use the whistleblowing policy and where to seek further advice, ensuring proper procedures are followed and promoting accountability.

Title

Advice
Scope of Whistleblowing Policy

This policy applies to serious concerns regarding service provision, conduct of employees, the Board of Governors, or others acting on their behalf. It includes issues that:

Violate established standards or policies
Fall below expected practice
Constitute improper conduct

Concerns covered by this policy include:

Criminal offences that have occurred, are occurring, or are likely to occur
Non-compliance with legal obligations
Disclosures of miscarriages of justice
Health and safety risks, including risks to the public
Environmental damage
Breaches of policies and procedures
Concealment of any information relating to the above

Concerns that do not qualify as whistleblowing include personal grievances such as bullying or harassment. Issues affecting individuals or related to employment contracts should follow the staff grievance procedures.

For guidance on whether a concern is a whistleblowing issue or a grievance, contact Protect (formerly Public Concern at Work), which offers:

Clarification on the difference between whistleblowing and grievances
A free and confidential advice line

This rule defines the scope of the whistleblowing policy, clarifying the types of concerns it covers and distinguishing them from personal grievances. It provides clear guidance on when to use the whistleblowing policy and where to seek further advice, ensuring proper procedures are followed and promoting accountability.

Metrics and KPIs

The following metrics will be measured and regularly reviewed as key performance indicators for the School to ensure the effectiveness of this policy and associated operations.

Title
Average Time to Investigate Reports Measure the average duration, in days, to complete investigations from report receipt to resolution. This KPI assesses the efficiency of the investigation process and helps ensure that concerns are resolved promptly.
Number of Reports by Category Categorise and count the number of reports by type (e.g., fraud, misconduct, safety). Understanding the types of concerns raised helps target improvements and allocate resources effectively.
Number of Whistleblowing Reports Received Track the total number of whistleblowing reports received annually. This KPI measures the level of engagement with the policy and helps assess whether staff and students are aware of and willing to use the reporting mechanisms.
Percentage of Reports Acknowledged Within 5 Working Days Monitor the percentage of whistleblowing reports acknowledged within 5 working days of receipt. Timely acknowledgment shows responsiveness and reassures reporters that their concerns are being taken seriously.

Title

Average Time to Investigate Reports
Measure the average duration, in days, to complete investigations from report receipt to resolution.
This KPI assesses the efficiency of the investigation process and helps ensure that concerns are resolved promptly.

Number of Reports by Category
Categorise and count the number of reports by type (e.g., fraud, misconduct, safety).
Understanding the types of concerns raised helps target improvements and allocate resources effectively.

Number of Whistleblowing Reports Received
Track the total number of whistleblowing reports received annually.
This KPI measures the level of engagement with the policy and helps assess whether staff and students are aware of and willing to use the reporting mechanisms.

Percentage of Reports Acknowledged Within 5 Working Days
Monitor the percentage of whistleblowing reports acknowledged within 5 working days of receipt.
Timely acknowledgment shows responsiveness and reassures reporters that their concerns are being taken seriously.