KILDWICK CE PRIMARY SCHOOL

Learning to Live, Living to Love, Loving to Learn

Whistle Blowing Policy

Date Approved: Autumn 2023

Next Review: Autumn 2024

The Second Report of the Committee on Standards in Public Life: Local Public Spending Bodies published by The Nolan Committee used the term ”whistleblowing” to mean the confidential raising of problems or concerns within an organisation by a member of staff. This is not “leaking” information but refers to matters of impropriety e.g. a breach of law, school procedures or ethics. Nor is whistleblowing the raising of a grievance within the school (which would be dealt with under the staff grievance procedures).

Introduction

The staff and governors of Kildwick CE Primary School seek to run all aspects of school business and activity with full regard for high standards of conduct and integrity. If members of school staff, parents, governors or the school community at large become aware of activities which give cause for concern, Kildwick CE Primary School has this whistleblowing policy; this acts as a framework to allow concerns to be raised confidentially and provides for a thorough and appropriate investigation of the matter to bring it to a satisfactory conclusion, under the school’s disciplinary procedure.

Kildwick CE Primary School is committed to tackling fraud and other forms of malpractice and treats these issues seriously. Kildwick CE Primary School recognises that some concerns may be extremely sensitive and has therefore developed a system, which allows for the confidential raising of concerns within the school environment but also has recourse to an external party outside the management structure of the school.

When might the whistleblowing policy apply?

Individuals are encouraged to come forward in good faith with genuine concerns knowing they will be taken seriously. A whistleblower should ask a few questions before taking action:

  • Is it, or do you believe it to be, illegal?
  • Is it, or do you believe it to be, against codes of practice issued by the school, regulatory authorities or a professional body?
  • Does it contradict what the employee has been taught, or should have been taught?
  • Is it about an individual’s behaviour or is it about general working practices?
  • Has the whistleblower witnessed the incident?

If any individual raises malicious unfounded concerns or attempts to make mischief, this will also be taken seriously and may constitute a disciplinary offence or require some other form of penalty appropriate to the circumstances. All allegations should be capable of being dealt with through the disciplinary procedure and will be considered appropriately. Where the alleged activity or behaviour cannot be dealt with under the scope of other procedures then consideration should be given to using this whistleblowing policy e.g.:

  • manipulation of accounting records and finances
  • inappropriate use of school assets or funds
  • decision-making for personal gain
  • any criminal activity
  • damage to the environment of the school
  • dangerous practices
  • abuse of position
  • fraud and deceit or corrupt practices
  • serious breaches of school procedures which may advantage a particular party (for example tampering with tender documentation, failure to register a personal interest)
  • sexual or physical abuse of pupils or others
  • Other unethical conduct.

Anonymous allegations will only be considered if the issues raised are:

  • Very serious
  • The credibility of the allegation is considered to be high
  • The likelihood of confirming the allegation is high

Procedure

The whistleblowing procedure is similar, in the first instance, to the grievance procedure. Kildwick CE Primary School encourages the whistleblower to raise the matter internally in the first instance with their Headteacher. This will allow the alleged wrongdoer to give an explanation for the behaviour or activity. Alternatively the whistleblower may request a private and confidential meeting in the first instance with the person who is causing concern. A work colleague of their choice may accompany him if they so wish.

All matters will be treated in strict confidence and anonymity will be respected wherever possible. Written, dated and signed supporting evidence and statements should always be taken to any meetings if possible. Alternatively if the whistleblower considers the matter too serious or sensitive to raise within the internal environment of the school, the matter should be directed in the first instance to the Chair of Governors.

How will the matter be progressed?

The individual(s) in receipt of the information or allegation (the investigating officer(s)) will carry out a preliminary investigation. This will seek to establish the facts of the matter and assess whether the concern has foundation and can or should be resolved internally. The initial assessment may identify the need to involve third parties to provide further information, advice or assistance, for example involvement of other members of school staff, the school’s external auditors, legal or personnel advisors, the police or the regulatory bodies.

Records will be kept of work undertaken and actions taken throughout the investigation. The investigating officer(s), possibly in conjunction with the Chairman of Governors or nominee, will consider how best to report the findings and what corrective action needs to be considered. This may include some form of disciplinary action and/or third party referral such as the police.

Depending on the nature of the concern or allegation and whether or not the investigating officer considers there to be a case to answer, the disciplinary procedure may be applied. In such cases any disciplinary action will be considered by the dismissal committee and if appropriate the dismissal appeals committee of the Governing Body. Where a case is proven on the balance of probability the matter will be reported to the full Governing Body, regulatory authorities and, where appropriate, the DCSF and GTC.

If the whistleblower is dissatisfied with the conduct of the investigation or resolution of the matter or has genuine concerns that the matter has not been handled appropriately, the concerns may be raised with the Chair of Governors. If that fails to resolve matters then the employee may seek the assistance of “Chief Internal Auditor” on 01609 760067. For any concerns taken outside of the school this policy will not apply and any employee raising issues on a wider basis, e.g. with the press, without following the procedure in this policy may be liable to disciplinary action.

Respecting confidentiality

Wherever possible Kildwick CE Primary School seeks to respect the confidentiality and anonymity of the whistleblower and will as far as possible to protect him/her from reprisals. Kildwick CE Primary School will not tolerate any attempt to harass or victimise the whistleblower, or attempts to prevent concerns being raised, and will consider any necessary disciplinary or corrective action appropriate to the circumstances.

Conclusion

Existing good practice within Kildwick CE Primary School in terms of its systems of internal control, both financial and non-financial, and the external regulatory environment in which the school operates, ensures that cases of suspected fraud or impropriety rarely occur. This whistleblowing policy is provided as a reference document to establish a framework within which issues can be raised confidentially internally and if necessary outside the management structure of the school. This document is a public commitment that concerns are taken seriously and will be actioned. Any actions arising from allegations/investigation must be in accord with the school’s disciplinary procedure, which should cover all of the potential areas of concern.