1. Document Control
Policy Owner: Principal / Director (or Designated Compliance Lead)
Responsible Committee: Management Committee (with reporting to Academic Board where academic matters arise)
Approval Authority: Principal / Director
Effective From: 25/12/2025
Version: 1.0
Applies To: All employees, contractors, associates, visiting lecturers, volunteers, students and third parties who work with or engage with Equra College London.
2. Purpose
Equra College London is committed to the highest standards of integrity, transparency and accountability. This policy sets out how individuals can raise concerns about wrongdoing or serious risks in a safe and responsible way, and how the College will respond. It aims to:
a. Encourage early reporting of genuine concerns in the public interest.
b. Provide clear, safe reporting routes including confidential escalation options.
c. Protect whistleblowers from retaliation and victimisation.
d. Ensure concerns are assessed, investigated and addressed fairly and proportionately.
e. Support a culture where speaking up is treated as a responsible act.
3. Scope
This policy applies to concerns that relate to wrongdoing or risk connected to Equra College London, including activity occurring:
a. On College premises or at College events.
b. In delivery settings including partner sites where the College has involvement.
c. Online learning environments.
d. In contracted or outsourced services connected to the College.
This policy can be used by staff, students and external parties. It does not replace normal grievance or complaint routes for personal issues, but it may apply where the concern involves serious wrongdoing or risk affecting others.
4. Definitions
Whistleblowing: Reporting a concern in the public interest about wrongdoing, risk or malpractice connected to the College.
Public interest: The concern affects others or the wider public, not solely a personal employment or academic dispute.
Whistleblower: A person who raises a concern under this policy.
Retaliation: Any disadvantage, threat, harassment, dismissal, penalty or negative treatment because a person raised a concern.
5. What Can Be Reported Under This Policy
Concerns may include, but are not limited to:
a. Criminal activity, fraud, theft or financial misconduct.
b. Bribery, corruption or improper influence.
c. Safeguarding failures or risks to children or vulnerable adults.
d. Health and safety risks, unsafe practices or serious hazards.
e. Discrimination, harassment or serious misconduct affecting others.
f. Academic integrity failures, serious assessment malpractice or manipulation of outcomes.
g. Data protection breaches or unlawful processing of personal data.
h. Misuse of College funds, assets or systems.
i. Serious breaches of College policy that create risk to students, staff or the public.
j. Attempts to conceal wrongdoing.
6. What This Policy Is Not For
This policy is not the primary route for:
a. Student dissatisfaction with academic outcomes, which should use appeals or complaints routes.
b. Personal employment grievances that only affect the individual, which should use internal management or grievance routes.
c. Routine customer service issues, which should use general complaints routes.
However, if a matter appears to involve significant wrongdoing, risk or public interest, the College may treat it as a whistleblowing concern even if it overlaps with another route.
7. Commitment to Non-Retaliation
Equra College London will not tolerate retaliation against anyone who raises a genuine concern in good faith. Retaliation may be treated as misconduct and may lead to disciplinary action.
Protection applies where the concern is raised honestly, even if it is not ultimately proven, provided it was not made maliciously or knowingly false.
8. Confidentiality and Anonymity
8.1 Confidential reporting
Whistleblowers may request confidentiality. The College will take reasonable steps to protect identity, subject to legal requirements and fair investigation needs.
8.2 Anonymous reporting
Anonymous reports will be considered and assessed, but anonymity can limit the ability to investigate fully. Whistleblowers are encouraged to provide contact details where possible.
8.3 Data protection
All information will be handled in line with the Data Protection Policy and records management requirements.
9. Reporting Routes
Concerns may be raised through one of the following routes, depending on seriousness and comfort level:
9.1 Primary reporting route
Report to the Principal / Director or Designated Compliance Lead.
9.2 Alternative reporting route
If the concern relates to the Principal / Director, or the whistleblower feels unable to raise it via the primary route, the concern may be raised with:
a. The Chair of the Academic Board (for academic governance concerns), or
b. A designated independent senior person appointed by the College for whistleblowing matters.
9.3 Safeguarding urgent route
Where the concern involves safeguarding risk, it must be raised immediately via the Safeguarding reporting route in the Safeguarding Policy and Procedure.
9.4 Health and safety urgent route
Where the concern involves immediate risk to health and safety, it must be raised immediately via the Health and Safety reporting route, and emergency services should be contacted where appropriate.
10. How to Raise a Concern
Whistleblowers should provide as much detail as possible, including:
a. What happened, when and where.
b. Who was involved or affected.
c. What policy or legal issue is believed to be breached, if known.
d. Any evidence available (documents, emails, screenshots, dates, names of witnesses).
e. Whether the concern has been raised before and what response was given.
Concerns may be raised verbally or in writing. Written reporting is encouraged where possible to support accurate handling.
11. Initial Assessment and Response
11.1 Acknowledgement
The College will acknowledge receipt of the concern within a reasonable timeframe.
11.2 Initial assessment
The College will assess:
a. Whether the matter falls under whistleblowing.
b. The seriousness and urgency of the risk.
c. Whether immediate safeguards are required.
d. Whether another policy route is more appropriate.
e. The appropriate investigator and investigation approach.
11.3 Safeguarding and urgent risk action
Where there is immediate risk, safeguarding action or urgent health and safety action will be prioritised before full investigation.
12. Investigation Process
12.1 Proportionate investigation
The College will investigate concerns fairly and proportionately. This may involve:
a. Reviewing documents and records.
b. Interviewing relevant individuals.
c. Liaising with partner organisations where relevant.
d. Consulting specialist advice where needed (for example safeguarding, legal, or data protection advice).
12.2 Fairness to all parties
Investigations will be conducted fairly and without assumptions. Individuals named in allegations will be given an appropriate opportunity to respond.
12.3 Timeframes
Investigation timeframes will depend on complexity. The College will provide updates where reasonable and appropriate.
13. Outcome and Actions
13.1 Outcome communication
The College will aim to inform the whistleblower of whether the concern has been substantiated and whether action has been taken. The level of detail shared may be limited by confidentiality, data protection and employment or student privacy considerations.
13.2 Corrective and preventive action
Where wrongdoing is identified, the College may take action such as:
a. Process or policy changes.
b. Additional training.
c. Disciplinary action where appropriate.
d. Safeguarding actions.
e. Data breach actions and reporting where required.
f. Referral to external authorities where legally required.
14. Malicious or Bad Faith Allegations
If a concern is found to be knowingly false or made maliciously, the College may take appropriate action. This does not affect protection for whistleblowers who raise concerns honestly and in good faith.
15. Record Keeping
The College will keep appropriate records of:
a. The concern raised and initial assessment.
b. Investigation steps and evidence considered.
c. Findings and decisions.
d. Actions taken and follow-up monitoring.
Records will be maintained securely in line with the Data Retention and Records Management Policy.
16. Monitoring and Review
The College will monitor whistleblowing concerns and outcomes to identify systemic risks and improvements. This policy will be reviewed annually or sooner if regulatory or operational changes require updates.
17. Related Policies and Documents
This policy should be read alongside:
a. Safeguarding Policy and Procedure
b. Health and Safety Policy
c. Incident and Accident Reporting Procedure
d. Risk Assessment Policy and Template
e. Equality, Diversity and Inclusion (EDI) Policy
f. Anti-Bullying and Harassment Policy and Procedure
g. Academic Governance and Quality Assurance Policy
h. Academic Misconduct Procedure
i. Data Protection Policy
j. Data Breach Incident Response Procedure
k. Data Retention and Records Management Policy
l. Student Complaints Procedure
m. Staff Conduct, Recruitment and Professional Standards Policy