It is an idea to put the whistleblowing policy in
context in an introduction explaining why there may be a need for a
system which allows for the confidential raising of
concerns.
It allows people who have a worry or suspicion to take it to the
right people and have confidence that their concerns will be
considered appropriately.
A clear statement that the school is committed to tackling fraud
and other forms of malpractice should be prominently stated in the
policy.
An indication of the sorts of matters regarded as malpractice
would likely include inappropriate use of delegated budget,
tampering with tender documents to advantage a particular party,
manipulation of accounting records and finances, decision making
for personal gain, inappropriate use of school assets, deceit,
abuse of position.
The policy should set out clear procedures on how matters will
be handled.
This should include whom to raise concerns with and should
assign responsibility to individuals to investigate the complaint
and report the findings.
It would be helpful to give an indication of how matters should
be raised, for example, in a written note or in certain
circumstances a telephone or personal conversation will
suffice.
The school may choose to make available a confidential postbox
or provide details of a home address or telephone contact
so concerns may be raised outside the school environment.
The procedures should make clear that full support will be given
to the whistleblower in respect of their confidentiality and, if
necessary, there will be protection from reprisals.
Whistleblowers should be encouraged to raise concerns internally
in the first instance to allow those people in positions of
responsibility to right the wrong.
Bypassing the internal system and raising concerns directly
through external channels may be perceived as adversarial,
unnecessarily.
The school may wish to nominate one individual to take
responsibility for investigating the issue.
In the case of a school the LA would recommend the responsible
officer, if available, as an appropriate person to whom such
matters should be directed and the LEA as the regulator where the
whistleblower is seeking anonymity from the school or governing
body.
The policy should make clear that concerns are taken seriously
and victimising employees or the public or deterring them from
raising concerns is unacceptable and may constitute a serious
disciplinary offence.
It should also be stressed that mischief making and raising
unfounded malicious allegations will be treated equally
severely.
The school should inform the whistleblower of the results of the
investigation stating what actions are to be taken.
If the whistleblower is not satisfied with the response and
proposed action or is unhappy with the conduct of the investigation
or alternatively prefers anonymity from the school and governing
body, the policy should include details of the regulatory body so
that concerns can be raised externally.
For a school the LA or
the Department for
Education (DfE) are the regulators in this context and
both organisations have procedures to ensure that appropriate
individuals in their organisation are alerted to the situation to
progress the case.
Alternatively, it may be more appropriate to discuss the matter
with the police.
The school should publicise its whistleblowing policy so
external parties are aware of its existence in the event that they
have legitimate concerns or complaints.
All staff and external parties should be aware that there is an
external route for raising the matter outside the management
structure of the school.
