The staff and governors of St Clare’s School seek to run all aspects of school business and activity with full regard for high standard of conduct and integrity. In the event that members of school staff, parents, governors or the school community at large become aware of activities which give cause for concern, St Clare’s School has established the following 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.
Throughout this policy, the term whistleblower denotes the person raising the concern or making the complaint. It is not meant in a pejorative sense and is entirely consistent with the terminology used by Lord Nolan as recommended in the Second Report of the Committee on Standards in Public Life: Local Spending Bodies published in May 1996.
St Clare’s School is committed to tackling fraud and other forms of malpractice and treats these issue seriously. St Clare’s 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.
St Clare’s School is committed to creating a climate of trust and openness so that a person who has a genuine concern or suspicion can raise the matter with full confidence that it can be resolved.
The provisions of this policy apply to matters of suspected fraud and impropriety and not matters of more general grievance which would be dealt with under the St Clare’s School Grievance Procedures.
When might the whistleblowing policy apply?
The type of activity or behaviour which St Clares considers should be dealt with under this policy includes:
- Manipulation of accounting records and finances
- Inappropriate use of school assets or funds
- Decision-making for personal gain
- Any criminal activity
- Abuse of position
- Fraud and deceit
- Serious breaches of school procedures which may advantage a particular party (for example tampering with tender documentation, failure to register a personal interest)
What action should the whistleblower take?
St Clare’s School encourages the whistleblower to raise the matter internally in the first instance to allow those school staff and governors in positions of responsibility and authority the opportunity to right the wrong and give an explanation for the behaviour or activity.
St Clare’s School has designated a number of individuals to specifically deal with such matters and the whistleblower is invited to decide which of those individuals would be the most appropriate person to deal with the matter.
Name & Position Contact details (investigating officers)
Head Teacher: Megan Stratton
Assistant Heads: Jody Specht, Colin Marshall
Chair of Governors: Laraine Tuplin
The whistleblower may prefer to raise the matter in person, by telephone or in written form marked private and confidential and addressed to one of the above named individuals. All matters will be treated in strict confidence and anonymity will be respected wherever 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 Council’s Head of Audit.
The Council has its own procedures for dealing with such matters and will ensure every effort to respect the confidentiality of the whistleblower. The Council will ensure relevant officers of the Department of Education and Employment are informed as appropriate.
In addition information and advice can be obtained from the charity Public Concern at Work. This charity offers free legal advice in certain circumstances to people concerned about serious malpractice at work. Their literature states that matters are handled in strict confidence and without obligation. Contact details for the charity are as follows:-
Public Concern at Work
16 Baldwins Gardens
Tel number 020 7404 6609
The National Society for the Prevention of Cruelty to Children (NSPCC) also have a Whistle Blowing helpline number 0800 028 0285
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 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, legal or personnel advisors, the Police, the Department for Education and Employment, the Council.
Records will be kept of work undertaken and actions taken throughout the investigation. The investigation officer(s), possibly in conjunction with the Governing Body, will consider how best to report the findings and what corrective action needs to be taken. This may include some form of disciplinary action or third party referral such as the Police.
The whistleblower will be informed of the results of the investigation and the action taken to address the matter. Depending on the nature of the concern or allegation and whether or not it has been substantiated, the matter will be reported to the Governing Body and the Council.
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 should be raised with the investigation officer(s), the Governing Body and/or directed to the Council.
Wherever possible St Clare’s School seeks to respect the confidentiality and anonymity of the whistleblower and will as far as possible protect him/her from reprisals. St Clares School will not tolerate any attempt to victimise the whistleblower or attempts to prevent concerns being raised and will consider any necessary disciplinary or corrective action appropriate to the circumstances.
Raising unfounded malicious concerns
Individuals are encouraged to come forward in good faith with genuine concerns with the knowledge they will be taken seriously. If individuals raise malicious unfounded concerns or attempt 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.
Existing good practice within St Clare’s School in terms of its systems of internal control both financial and non-financial and the external regulatory environment in which the school operates ensure 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.
Ratified by Governors December 2016
To be Reviewed December 2018