Whistleblowing Policy

Version Number	001
Status	Approved June 2026
Publication Date
Policy Owner/Author	Headteacher
Review Date	September 2026
Approved/Ratified by	Interim Executive Board (IEB)

Introduction

We are committed to maintaining a culture of openness, accountability, and integrity, seeking to ensure that employees and workers feel secure in disclosing concerns about any activity which may harm individuals or undermine our school. We have therefore adopted this Whistleblowing Policy to provide clear guidance to those who may need to raise concerns in accordance with the Public Interest Disclosure Act 1998 (PIDA) and Department for Education (DfE) guidance for schools.

We recognise that our staff may be in the best position to realise that something could be seriously wrong within our school. However, in some cases they may not express their concerns because they feel that speaking up would be disloyal. They may also fear harassment or victimisation.

We therefore feel it is crucial that we, as the Governing Body, promote a culture that expects the highest possible standards of openness, integrity, and accountability. In line with that commitment, we openly encourage staff within the scope of this policy, who have serious concerns about any aspect of the school’s work, to come forward and disclose those concerns.

We recognise that they may wish to seek advice and be supported by a trade union representative when raising a concern and we would acknowledge and encourage such actions, recognising the important role trade union representatives can play. Trade union representatives acting in accordance with this policy and procedure will not suffer detriment in their employment with our school.

Purpose and Aims

The purpose of this policy is to encourage staff to report (and importantly how to report) suspected wrongdoing within school, with the knowledge that their concerns will be taken seriously and investigated as appropriate, and their confidentiality will be protected wherever possible.

This policy therefore aims to:

• encourage staff to feel confident in raising serious concerns and to question and act upon these concerns;

• provide avenues for staff to raise those concerns and receive feedback on any action taken where appropriate and relevant;

• ensure that staff receive a response to their concerns and are aware of how to pursue them if they are not satisfied;

• reassure staff that they will be protected from possible reprisals or victimisation if they have a reasonable belief that they have made a disclosure in the public interest.

Scope

This Policy and Procedure will apply to all staff working in school and is intended to cover those concerns that fall outside the normal scope of other school policies and procedures, dealing with serious wrongdoing or malpractice.

A disclosure protected under this policy may include (please note that this is not an exhaustive list):

• a criminal offence and/or activities;

• bribery, corruption, or blackmail;

• financial malpractice or irregularity;

• improper use of authority;

• failure to comply with any legal obligations or regulatory requirements;

• miscarriage of justice;

• there is a threat to an individual’s health and safety;

• damage to the environment;

• covering up wrongdoing in respect of any of the above;

• any act of harassment, sexual harassment, or victimisation;

• conduct likely to damage the school’s reputation;

• breaches to the school’s internal policies and procedures;

• deliberate concealment regarding information about known malpractices (financial or otherwise);

• fraud or theft against the school or suppliers;

• negligence.

In addition, staff making a disclosure must also have a reasonable belief that the disclosure is in the public interest.

It should be emphasised that this policy and procedure is not designed to question financial or business decisions taken by our school, nor may it be used to reconsider any matters that have already been addressed under other procedures. Members of staff who make disclosures outside the arrangements set out here will not be protected under this policy.

Protection

We recognise that it can be difficult to make the decision to report a concern. However, if a concern is raised in good faith and based on reasonable belief, there should be nothing to fear. We would therefore remind employees considering raising concerns that, when covered by the Public Interest Disclosure Act 1998, they will be protected from dismissal or other detriment as long as they follow this policy and procedure.

We will not tolerate any harassment, sexual harassment, or victimisation of any kind. Harassment or bullying of a whistleblower constitutes a disciplinary offence and we will take appropriate action, including disciplinary action, if necessary, to protect staff when they raise a concern.

Any investigation into allegations of potential malpractice will not influence or be influenced by other procedures such as investigations and hearings under the disciplinary, health and wellbeing, capability, redundancy, or any other dismissal procedures that already affect members of staff or may affect them in the future.

Where a concern is not confirmed by a subsequent investigation, no action will be taken against those reporting the matter. If, however, it is determined through an investigation that a member of staff made an allegation frivolously, maliciously, or for personal gain, disciplinary action may be taken against them.

Confidentiality

All concerns will be treated in confidence, and every effort will be made not to reveal the member of staff’s identity if they so wish. At the appropriate time, however, the member of staff may need to come forward as a witness. If we are not able to resolve the concern without revealing their identity, it will be discussed with them beforehand to determine next steps.

Anonymous Concerns’ Reporting

Whilst staff can remain anonymous if they choose, we do not encourage anonymous reporting. Proper investigation may be more difficult or impossible if further information from the person raising a concern cannot be obtained; it is also more difficult to establish whether any such allegations are credible and have been made in the public interest.

People who are concerned about possible reprisals if their identity is revealed are assured that we will not tolerate any victimisation or detrimental treatment of anyone who raises a concern in good faith in the Public Interest. Concerns expressed anonymously are much less powerful but may still be considered, having taken into account:

• the seriousness of the issues raised;

• the credibility of the concern; and

• the likelihood of confirming the allegation from attributable sources.

The Headteacher in conjunction with the Chair of Governors will decide in each case whether a complaint made anonymously should be investigated.

Untrue Allegations

If a member of staff reports a concern in good faith, but it is not confirmed by the investigation, no action will be taken against that employee. If, however, an employee makes an allegation frivolously, maliciously, or for personal gain, disciplinary action may be taken against them.

How to Raise a Disclosure

As a first step, concerns should initially be disclosed to the Headteacher in writing. Wherever possible, concerns should be made in writing using the template at Appendix 1. However, the Headteacher may meet with the member of staff as soon as practicable to discuss their concern, recording sufficient details as outlined in Appendix 1 to enable the matter to be thoroughly investigated, providing a copy to the member of staff.

We recognise that in some cases disclosing a concern to the Headteacher may not be appropriate and in these circumstances:

• where the concern relates to the Headteacher or member(s) of the Governing Body, then it should be raised directly with the Chair of Governors;

• where the concern relates to the Chair of Governors or full Governing Body, then concerns should be raised with the Clerk to Governors who will consider the most appropriate course of action.

Where disclosing a concern, the member of staff will need to provide the following information:

• the nature of the concern and why they believe it to be true;

• the background and history of the concern (giving relevant dates where appropriate);

• that they are exercising their right to raise this concern under the whistleblowing policy.

Although they are not expected to prove beyond doubt the truth of the suspicion, they will need to demonstrate to the person contacted that they have a genuine concern and there are reasonable grounds for the concern relating to suspected wrongdoing or malpractice within the school.

The member of staff may invite their trade union representative or a work colleague to be present during any meetings or interviews in connection with the concerns raised.

Investigating a Disclosure

Once a member of staff has raised a concern as outlined above, the Headteacher within 10 working days will carry out an initial assessment and inform the member of staff of the scope of any investigation and timescale (if known) for completion. This may include the member of staff being required to attend additional meetings to provide further information as part of any investigation.

The Headteacher may consider it appropriate to refer the concern to an external agency for consideration in advance of any internal investigation. This may be appropriate where concerns about child safeguarding, potential criminal activity, or unsafe working practices are raised. Where this is deemed appropriate, no further internal investigation should be undertaken until clearance is given by the relevant agency concerned and the matter is referred back to the school.

Where necessary, the school may appoint an investigator or team of investigators, including those with relevant experience of investigations or specialist knowledge of the subject matter. The investigator(s) may make recommendations for change to enable the school to minimise the risk of future wrongdoing.

The school accepts that staff concerned need to be assured that the matter has been properly addressed, therefore the Headteacher will aim to keep the member of staff appropriately informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent the school from providing specific details of the investigation or any outcomes or disciplinary action taken as a result. All persons involved in this process should treat any information about the investigation as confidential.

Outcome of Disclosure

Whilst it cannot always be guaranteed that the outcome will be in line with the member of staff’s expectation, concerns will always be dealt with fairly and in an appropriate way.

Where the Headteacher (or Chair of Governors) has investigated the matter, they will produce a written report into the concerns raised, outlining conclusions and any necessary actions to be taken. The member of staff raising the concerns will be notified of any outcomes and these, together with a copy of the report (anonymised), will be made available to all Governors.

Where an external investigator has been appointed, their written report will be submitted to the Headteacher (or Chair of Governors) who must act on any recommendations made within the report. The member of staff raising the concerns will be notified of any outcomes and these, together with a copy of the report (anonymised), will be made available to all Governors.

There is no right of appeal against any decisions taken under this policy and procedure.

External Disclosure

Staff who are not satisfied with how concerns disclosed to the school have been dealt with may choose to report them externally to an appropriate body, details of which are shown below:

• the Local Authority;

• the Police – for concerns of criminal behaviour;

• any Prescribed Person or Body (e.g., Ofsted, Ofqual, the Children’s Commissioner, or the NSPCC) – a full list can be found via the official government whistleblowing registry.

Independent Support and Advice

If the member of staff is unsure and wishes to seek support, they may wish to speak to their trade union. In addition, independent information and advice for employees/workers is also available from the charity Protect via their dedicated advice line or official support portal.

Report to Governing Body

The Headteacher will report to governors the outcome of whistleblowing investigations, anonymising the detail, but confirming the outcome and any actions arising from the investigation.

APPENDIX 1: Raising A Concern Form

Section	Input / Field Area
Section 1: Details	(Where anonymity is required, please leave section 1 blank)
Name of person raising concern:	(May be anonymous)
Job title:
Contact address / Tel / Email:
Relationship with subject:	(For example manager, colleague, none, etc.)
Section 2: Outline	(Please outline the nature of concern providing details of suspected wrongdoing including name(s), job title(s), date(s), timescale(s), place, and other relevant information. Please use additional sheets if necessary).
Section 3: Declaration	(Leave signature blank if anonymous)
Section 4: Management Action	(To be completed by the manager to whom the concern was raised)
Manager Name / Job Title / Work Place:
Relationship with subject:	(For example manager, colleague, none, etc.)
Additional Info / Summary:	Additional information obtained from the person raising the concern to help clarify the nature of the concern, if applicable.
Signature / Print Name / Date:	(Of person to whom complaint is raised)

DOCUMENT CONTROL – RECORD OF CHANGES

Version Number:	Publication Date:	Nature of, and Reason for, Change(s)
001		Original Framework Draft