1.1 The Whistleblowing Policy and Procedure (the ‘Policy’ and the ‘Procedure’) applies to all members of the Board, all Armonia Training Academy’s employees, all agency staff and all independent contractors and consultants working with Training Academy (Armonia).
1.2 The purpose of this policy and the associated procedure is:
1.2.1 To enable staff to raise relevant issues without fear of victimisation
1.2.2 To enable staff to receive an adequate response to the issues raised
1.2.3 To provide Armonia with the opportunity to investigate those concerns and take appropriate action.
1.3 The aim of the Policy is to:
1.3.1 provide staff with guidance as to how to raise those concerns;
1.3.2 reassure staff that they should be able to raise genuine concerns in good faith without fear of reprisals, even if they turn out to be mistaken.
1.3.3 provide safeguards to staff who raise genuine concerns about malpractice or illegal acts or omissions by Armonia’s employees or, where relevant, ex-employees.
1.4 Legitimate concerns are those which are in the public interest. Public interest means matters which warrant disclosure in the interests of protecting the public (or Armonia, staff or students), rather than matters which are interesting to the public
1.5 The Policy does not relate to mismanagement or poor management which does not constitute malpractice, allegations known to be untrue, or matters raised for the purpose of furthering any private dispute or for the purpose of financial gain by the person raising the matter.
1.6 This Policy does not prevent an individual from raising matters of immediate urgent concern with an appropriate regulatory body. Such circumstances are likely to be safety issues (to the Health and Safety Executive) or personal security issues such as assault (to the police).
2.1 Armonia is committed to the highest standards of honesty, integrity, probity and openness in public life. We will maintain a procedure in line with relevant legislation and best practice.
2.2 We expect all staff to maintain high standards. However, all organisations face the risk of things going wrong from time to time, or of unknowingly harbouring illegal or unethical conduct. A culture of openness and accountability is essential in order to prevent such situations occurring or to address them when they do occur.
2.3 We will:
2.3.1 Ensure all concerns are treated fairly and properly within a transparent and confidential process
2.3.2 Not tolerate the harassment or victimisation of anyone raising a genuine concern
2.3.3 Make every effort to keep the identity confidential of any individual making a disclosure unless they agree otherwise or subject to a court requirement or if they act maliciously
2.3.4 Ensure that any individual raising a concern is aware of who is handling the matter
2.3.5 Encourage staff to make the appropriate use of the Procedure but will take disciplinary action in response to malicious unfounded disclosures.
2.4 The policy not only covers possible improprieties in matters of financial reporting, but also legitimate concerns regarding:
2.4.1 Fraud*
2.4.2 Corruption, bribery or blackmail*
2.4.3 Criminal offences
2.4.4 Failure to comply with a legal or regulatory obligation
2.4.5 Failure to properly safeguard assets
2.4.6 Miscarriage of justice
2.4.7 Dishonesty
2.4.8 Acting contrary to Armonia’s Ethics Policy or Codes of Conduct for Staff and Governors
2.4.9 Cheating**
2.4.10 Poor or unsafe practice in regard to safeguarding and protecting learners
2.4.11 Endangering the health and safety of an individual
2.4.12 Concealment of any of the above
2.4.13 *To be investigated under the Counter-Fraud and Error Policy
2.4.14 ** To be investigated under the Plagiarism Policy
2.4.15 This list is not intended to be exhaustive.
3.1 “Whistleblowing” is the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include:-
3.1.1 criminal activity;
3.1.2 danger to health and safety;
3.1.3 damage to the environment;
3.1.4 failure to comply with any legal obligation or regulatory requirements including in relation to vulnerable persons, including children;
3.1.5 breach of our internal policies and procedures;
3.1.6 conduct likely to damage our reputation;
3.1.7 unauthorised disclosure of confidential information;
3.1.8 the deliberate concealment of any of the above matters.
3.2 A whistleblower is a person who raises a genuine concern in good faith relating to any of the above. If you have any genuine concerns related to suspected wrongdoing or danger affecting any of our activities (a whistleblowing concern) you should report it under this policy.
3.3 This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work. In those cases you should use the Grievance Procedure.
3.4 If you are uncertain whether something is within the scope of this policy you should seek advice from the Chief Executive.
4.1 We hope that in many cases you will be able to raise any concerns with your line manager. You may tell them in person or put the matter in writing if you prefer. They may be able to agree a way of resolving your concern quickly and effectively.
4.2 Where the matter is more serious, or you feel that your line manager has not addressed your concern, or you prefer not to raise it with them for any reason, you should contact the Chief Executive.
4.3 Should you wish to make a disclosure directly to DfE please read the guidance How Department for Education (DfE) handles whistleblowing disclosures which explains how to make a disclosure to DfE.
4.4 ‘Protect’ is the UK’s leading whistleblowing charity and provide free, confidential whistleblowing advice. Further information can be found here.
4.5 All UK workers are protected under the Public Interest Disclosure Act 1998 when they make a protected disclosure. This is a disclosure of information which, in the reasonable belief of the worker making the disclosure, covers the following employer activities:
4.5.1 A criminal offence has been, is being, or is likely to be committed
4.5.2 A person has failed, is failing, or is likely to fail to comply with any legal obligation to which they are subject
4.5.3 A miscarriage of justice has occurred, is occurring or is likely to occur
4.5.4 The health and safety of an individual has been, is being, or is likely to be endangered
4.5.5 The environment has been, is being, or is likely to be damaged
4.5.6 The individual’s actions will adversely impact upon achieving Armonia’s objectives either financially, its reputation or quality of student experience
4.5.7 Information relating to the above is being deliberately concealed
4.6 Workers in other territories will be treated by the institution as if such legislation applied to them. Armonia contact details are set out at the end of this policy.
5.1 The Policy provides safeguards to protect staff who raise genuine concerns about Malpractice.
5.2 Any disclosure must be treated in confidence and every effort made to maintain the anonymity of the person disclosing the information (the ‘Discloser’), if that is their wish. It must be noted, however, that anonymity may not always be possible; this is dependent on the nature of the disclosure.
5.3 Staff who raise issues in accordance with the Policy will not be victimised or bullied as a result of their actions. The Disciplinary Policy and Procedure will be applied to anyone found to be victimising the Whistle Blower; and if victimisation is proven, it will be considered as gross misconduct. Further information can be found on the GOV.UK website following the following link: Whistleblowing for Employees.
5.4 It is important that genuine concerns are raised and, provided that they are not known to be untrue, the fact that they are subsequently shown to be unfounded will not be reason for disciplinary action.
5.5 However, abuse of the Policy will be a serious matter and may result in disciplinary action.
6.1 STAGE 1
6.1.1 This procedure is not designed to deal with individual issues relating to a breach or likely breach of a contract of employment. The Grievance Policy and Procedure should be followed for those matters.
6.1.2 Should a Governor or member of staff wish to raise a matter of Whistleblowing, they should bring it to the attention of the Chief Operating Officer (the ‘COO’).
6.1.3 The COO will acknowledge receipt and their understanding of the disclosure in writing within five working days of the allegation and report the matter to the Chief Executive Officer (the ‘CEO’).
6.1.4 The CEO will review the disclosure and, if necessary, appoint an appropriate manager (or external investigator) as the ‘Investigating Officer’.
6.1.5 If the disclosure involves a member of the Executive team, the CEO will inform the Chair of the Governors who will review the disclosure and, if necessary, appoint an external and independent Investigating Officer.
6.1.6 If the disclosure involves the COO, then the Discloser should raise the matter with the CEO who will review the disclosure and, if necessary, appoint an internal or external Investigating Officer.
6.1.7 Following the receipt of a Whistleblowing disclosure, the Board will be informed at its next regular meeting.
6.1.8 The Investigating Officer will undertake all necessary investigations to establish the veracity of the whistleblowing claims. They will submit a written report to the CEO (or relevant reviewer), for consideration and determination of actions.
6.1.9 The purpose of the investigation is to obtain, clarify and confirm all available information concerning alleged malpractice. If an interview is held between the Investigating Officer and the Discloser, the Discloser may be accompanied in this meeting by a fellow employee or trade union representative (the “Companion”). The Discloser’s chosen Companion has the right to address the meeting to put the Discloser’s case, sum up the case and respond on the Discloser’s behalf to any view expressed at the meeting. The Companion may also confer with the Discloser during the meeting. However, there is no requirement for the Investigating Officer to permit the Companion to answer questions on behalf of the Discloser, or to address the meeting where the Discloser indicates that they do not wish this.
6.1.10 The Investigating Officer will, unless impractical to do so, agree their note of any interview with the Discloser before proceeding further (within ten working days of the interview).
6.1.11 The Investigating Officer will be permitted to take further professional advice.
6.2 REPORTING
6.2.1 In the event of alleged financial irregularities, the Chair of Governors will report the matter to the Internal and/or External Auditors and, if appropriate, the funding body in accordance with Armonia’s financial regulations. If the allegation concerns financial irregularities, the investigation shall be reported to the Board prior to any decision being reported to the Whistle Blower.
6.2.2 The Investigating Officer will inform the Discloser of the action they have taken within four weeks of any discussions with them. The Investigating Officer will keep the Discloser regularly informed of the progress of any investigation and of the outcome. It is acknowledged that some investigations may be complex and lengthy and, since the outcome may involve prosecution, all due diligence and caution will be required.
6.2.3 On completion of the Procedure, but prior to communication to the Discloser, the COO (or relevant reviewer) will inform the Board of the detail of the allegation, the action taken and the final recommendation. This will allow the Board to consider the matter at the completion of the investigation.
6.2.4 As far as possible, and subject to third-party rights, the COO (or relevant reviewer) will notify the Discloser in writing of the outcome of the investigation within ten working days of the decision of the Board.
6.3 STAGE 2
6.3.1 Should the Discloser feel that the matter has not followed the Procedures or that the conclusion is factually incorrect, the Discloser can refer the matter to the Chair of Governors within 10 working days of the conclusion explaining their reasons for disputing the outcome. The Chair will call a Special Committee to review the initial Whistleblowing disclosure, the Investigating Officer’s report and background evidence, and the action/remediation plan. From
these, the Special Committee will determine if the response was appropriate or if further work needs to be undertaken. The decision of the Special Committee will be final.
6.3.2 On completion of the Stage 2 process, the COO (or relevant reviewer) will bring the report to the next available Board Meeting along with a final action plan for approval.
6.4 TIMESCALES
6.5 Every effort will be made to adhere to the timescales set out in the procedure. However, it is recognised that such timescales should be flexible, bearing in mind the variation in the length of time it may take to investigate different types of concerns.
6.6 In the event of the investigation being a prolonged one, the Investigating Officer will keep the Discloser informed, in writing, as to the progress of the investigation, and as to when it is likely to be concluded.
Position Email address
Chief Executive Officer [email protected]
Chief Operating officer [email protected]
Chair of Governors [email protected]
© Armonia Health & Beauty – Whistleblowing Policy Ref: AT019
Renewal: July 2024
Reviewed: October 2025
Next review: October 2026
