UK contact office: 25 Southampton Buildings, London WC2A 1AL. Routine enquiries: guardian@intergreat.com.
Introduction
InterGreat Education Group has implemented a whistleblowing policy and associated procedure to provide an avenue for staff, volunteers, students, parents, and host families to internally and confidentially raise concerns about a range of issues, such as fraud, malpractice, health and safety, criminal activities, failures to comply with legal obligations, or unethical behaviour. The policy also includes provisions for reporting such concerns outside the company if necessary.
We are dedicated to upholding the highest standards of transparency, integrity, and accountability in all our operations and interactions, ensuring lawful and ethical conduct in all circumstances. Every individual has a responsibility to uphold this commitment in their daily professional activities. Nevertheless, situations may arise where the appropriate course of action is uncertain, or where there is suspicion of misconduct, unethical behaviour, or inappropriate actions. We are both legally and morally obliged to identify and address such situations promptly.
It can be challenging to decide whether to speak up about concerns. Individuals may be hesitant to get involved, but this could have severe repercussions for InterGreat Education Group, its staff, and other associated individuals. This whistleblowing policy is designed to instil confidence that any suspicions of wrongdoing will be addressed appropriately and in a timely manner.
As a member of our staff, volunteer, parent, student, or host family, you might be the first to notice potential issues within the company. However, you might feel reluctant to voice your concerns, fearing disloyalty to your colleagues or the organisation, or anticipating potential harassment or victimisation. Nevertheless, these feelings should never lead to a child or young person being exposed to unnecessary risks.
Remember: Don't think "What if I'm wrong?" – think "What if I'm right?"
Aims
The purpose of this policy is to:
- Ensure that all employees, host families, parents, and students feel supported to come forward confidentially and report any suspected misconduct, unethical conduct, or inappropriate actions.
- Promote the identification and challenging of any misconduct, unethical behaviour, or inappropriate actions at all levels of the organisation.
- Establish clear procedures for reporting such concerns.
- Handle all disclosures promptly, consistently, and professionally.
- Provide assurance that all disclosures will be taken seriously, treated confidentially (unless this conflicts with safeguarding or GDPR guidance), and managed without fear of reprisal.
In line with the Nolan Principles, InterGreat Education Group's whistleblowing policy aims to demonstrate that the company:
- Will not condone malpractice.
- Will safeguard the confidentiality of staff, volunteers, parents, students, and host families who raise concerns, ensuring procedures are in place to maintain confidentiality in a manner consistent with effectively addressing the issues (except where this conflicts with safeguarding or GDPR guidance).
- Will offer options to report concerns outside of the regular line management structure when appropriate.
- Will enforce the company's Disciplinary Policy and Procedure (Staff Handbook) for false, malicious, vexatious, or frivolous allegations.
- Will provide a clear and easily accessible procedure for raising concerns for all staff, volunteers, parents, students, and host families.
Procedure
- Tell a Director, verbally, by email or in writing, that you are raising a concern under the Whistleblowing Policy.
- Provide relevant details, context and information about the parties involved so the concern can be investigated.
- A Director will provide a written response within 10 days, acknowledging receipt and explaining how the concern will be addressed under this or another applicable policy.
This procedure is to enable members of staff, volunteers, parents, students, and homestays to express a legitimate concern regarding suspected malpractice within InterGreat Education Group.
Malpractice is not easily defined; however, it includes allegations of fraud, financial irregularities, corruption, bribery, dishonesty, acting contrary to the staff code of ethics, criminal activities, failing to comply with a legal obligation, a miscarriage of justice or creating or ignoring a serious risk to health, safety or the environment.
Reasons for Whistleblowing
Every individual bears the responsibility of reporting concerns about unacceptable practices or behaviours for the following reasons:
• Preventing the escalation or broadening of a problem
• Safeguarding and reducing risks for others
• Avoiding personal implication
Barriers to Whistleblowing
• Triggering a series of events that escalate
• Disrupting ongoing work or projects
• Fear of making an incorrect assessment
• Apprehension regarding potential repercussions or damage to careers
• Anxiety about not being taken seriously
Types of Concerns to Raise
Concerns falling under the purview of the whistleblowing policy may encompass issues that:
• Violate the law
• Contravene the company's regulations
• Fall below established standards or practices
• Constitute improper conduct
As a member of the staff, a volunteer, a parent, a student, or a homestay, you possess the right to raise issues, which could pertain to the conduct of fellow employees or independent contractors. According to the company’s Health & Safety Policy, you are obligated to report potential health and safety hazards.
Before disclosing concerns, please consider the following:
• All staff, volunteers, parents, and homestays share the responsibility to voice concerns about unacceptable practices or behaviours.
• It is advisable to utilise meetings with senior staff and other available opportunities to pose questions and seek clarity on matters that trouble you.
• Although it can be challenging to address concerns about a colleague's practices or behaviour, it is necessary to act to prevent the situation from deteriorating, minimise potential hazards to others' health and safety, and avert potential implication.
Self Reporting
Any individual associated with InterGreat Education Group is required to promptly disclose any convictions they incur to the Director.
At times, a staff member, volunteer, parent, student, or homestay may encounter personal challenges, such as physical or mental issues, which they are aware are affecting their professional capabilities.
You are obligated to address such a situation with a senior staff member at InterGreat Education Group to receive professional and personal assistance. However, confidentiality cannot be ensured in cases where personal difficulties raise concerns regarding the well-being or safety of children and young people.
How should you raise a concern?
The sooner a concern is voiced, the quicker and easier it becomes to address.
We understand that due to the sensitive nature of certain situations, discussing concerns may be uncomfortable. Below are individuals you can reach out to:
Designated Safeguarding Lead: Terence Murray
Email: terence.m@intergreat.com
You can raise concerns via email, verbally, or in writing, specifying that you are utilising the Whistleblowing Policy.
When making a disclosure, we encourage you to include the following information, if possible:
- An indication that you are utilising the whistleblowing policy
- Background and history of the concerns or suspected wrongdoing
- Names, dates, and places where feasible
- Details, to the best of your knowledge, about when, where, and how the incident occurred
- Reasons for particular concern about the situation
- A list of names of those suspected to be involved
- A list of names of those who may have relevant information
- Details of how you became aware of the situation
- Any breaches of company policies or procedures, if applicable
- Names of individuals with whom you have discussed the incident
- Your name and contact details (to be kept confidential as far as possible)
- Date and time of the report
You will not be required to substantiate the wrongdoing that you have witnessed or suspected. We recognize that some individuals may prefer to make a disclosure anonymously. In such instances, we will make every effort to fully investigate your concerns, although our ability to investigate may be hindered if we are unable to obtain further information from you.
Remember: The sooner you express a concern, the easier and quicker it is for the company to take action.
What happens next?
Upon raising a concern, InterGreat Education Group will:
- Provide information regarding the nature and progress of any investigations.
- Take steps to safeguard you from harassment or victimisation.
- Offer mediation and dispute resolution where appropriate.
- Endeavour to protect your identity if you prefer anonymity (although this may not be feasible in all cases, particularly if a signed statement is required from you through an alternate procedure, e.g., the disciplinary procedure).
- Refrain from taking action against you if you raise a concern in good faith that is later found to be unfounded.
InterGreat Education Group will conduct initial inquiries (typically involving a meeting with you) to determine if an investigation is necessary and in what form. The matter raised might result in:
- A straightforward resolution without further investigation.
- Internal investigation by a suitable senior staff member.
- Referral to the Local Authority Designated Officer for advice.
- Referral to the Police.
- Initiation of an independent inquiry.
Concerns or allegations falling under other company policies/procedures will typically be addressed under those procedures (e.g., disciplinary, health and safety, grievance, safeguarding, and child protection).
Within ten working days of receiving your concern, the recipient will send you a written response:
- Acknowledging receipt of the concern.
- Outlining how they intend to handle the matter.
- Providing an estimate of when a final response will be given.
- Indicating any initial inquiries made and if further investigations are warranted.
- Explaining the decision not to pursue further investigation, if applicable.
- Specifying when additional details can be expected if the situation remains unresolved.
It's important to note: if your concern, following investigation, is confirmed as unfounded, the company will consider the matter concluded, and will not expect you to raise the issue through another procedure or to the individuals listed above unless new evidence arises.
Please be aware that if there is clear evidence of deliberately making a malicious or false statement, disciplinary action may be taken against you.
Confidentiality
Persons wishing to raise a concern under this procedure, including staff, volunteers, parents, students, and homestays, have the right to have the matter treated confidentially, unless it conflicts with Safeguarding or GDPR guidance or legislation. The complainant's identity will not be revealed to the individual accused of malpractice without the complainant's prior consent. In the interest of confidentiality, it may be more suitable for concerns to be raised verbally rather than in writing, although all individuals are encouraged to document their concerns when possible. If criminal activity is suspected, the Police will always be notified.
External Procedures
It is important to highlight that according to the Public Interest Disclosure Act 1998, certain circumstances allow staff members, volunteers, parents, students, and homestays to potentially raise concerns directly with an external entity if they reasonably believe one of the following:
that exceptionally serious circumstances warrant such action. that the company would hide or destroy pertinent evidence. that they would face victimisation by others. that the Secretary of State has mandated such action.
Malicious Accusations
Unfounded, spiteful, or frivolous allegations will be addressed in accordance with the organisation's Disciplinary Procedure.
Protection from reprisal or victimisation
No staff member, volunteer, parent, student, or homestay will face disadvantage or disciplinary action for raising an authentic and valid concern, as long as they do so in good faith and in accordance with the Whistleblower procedures.
Further advice and support
Recognising that whistleblowing can be challenging and stressful, guidance and support are available from the Directors. Additionally, advice can be sought from the Designated Safeguarding Lead.
For those who find it difficult to raise concerns about child protection issues internally, the NSPCC whistleblowing helpline is accessible to staff, volunteers, parents, students, and homestays. Individuals can reach out by calling 0800 028 0285 from 8am to 8pm, Monday to Friday. Alternatively, they can also email help@nspcc.org.uk.
If you are dissatisfied with the response received from the company, you may opt to raise the matter externally. Points of contact include:
- Public Concern at Work (Phone: 0207 4046609, Email: whistle@pcaw.co.uk or helpline@pcaw.co.uk): This registered charity provides advice on addressing concerns about poor practice at work. The charity also offers guidance to the School on how best to address your concerns.
- Relevant professional bodies or regulatory organisations (e.g., Health & Safety Executive, Local Authority for Safeguarding, or AEGIS)
- A solicitor