Reporting concerns about suspected malpractice or wrongdoing connected with Educate the Planet (EtP)
For persons other than EtP employees
1.1 We are committed to ensuring that:
(a) every EtP service is delivered, assessed and awarded fairly, and in accordance with our policies and relevant standards of good practice;
(b) the award of an EtP scholarship always accurately reflects genuine attainment by the individual Applicant, and that EtP scholarships are awarded consistently between applicants;
and (c) we undertake all of our activities as an nonprofit organisation with honesty and integrity. Accordingly we expect everyone involved in the delivery, assessment and award of EtP scholarship to conduct themselves appropriately so that standards and public confidence are maintained.
1.2 However, we recognise that all organisations face the risk of things going wrong from time to time, or of unknowingly harbouring or being connected with malpractice, wrongdoing or unethical conduct. We consider that a culture of openness and accountability is essential in order to prevent such situations occurring or to address them when they do occur.
1.3 We are proud that EtP are delivered successfully across the world. We recognise however that there will be occasions when it is appropriate and necessary for concerns to be reported to us, rather than being raised locally.
1.4 The aims of this policy are:
(a) To encourage persons other than EtP staff who are involved in the delivery or assessment of EtP scholarships and services, and Applicants, to report suspected malpractice or wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected.
(b) To provide guidance as to how those concerns can be raised.
(c) To reassure any person raising genuine concerns in good faith that they should do so without fear of reprisals, even if they turn out to be mistaken.
1.5 This policy takes account of the Whistleblowing Arrangements Code of Practice issued by the British Standards Institute and Public Concern at Work.
1.6 This policy does not form part of any employee’s contract of employment and it may be amended at any time.
2.1 This policy applies to persons who do not work for EtP but who are involved in delivering EtP scholarships and services, and to applicants. EtP staff should consult the separate staff whistleblowing policy. More specifically, this policy applies to:
(a) any person who is not an employee of EtP but who is involved in any way with the delivery, assessment or award of an EtP scholarship and services (collectively referred to as connected persons in this policy);
and (b) applicants who are currently undertaking a EtP scholarship, or who have previously undertaken a EtP scholarship (collectively referred to as Applicants in this policy).
2.2 This policy applies to connected persons or applicants who make a whistleblowing report, regardless of how the report arises. For example, you may decide to contact us on your own initiative to discuss a concern. Alternatively, it may be that you choose to discuss a concern with us during or following a communication that we have initiated. In either case this policy would apply, and we would offer the protections and support outlined in this policy as appropriate to the particular circumstances.
3.1 Whistleblowing is the disclosure of information which relates to suspected malpractice, wrongdoing or dangers in connection with an EtP scholarship. This may include:
(a) persons impersonating an applicant so as to prepare an assessment or join interview in their place;
(b) plagiarism, or unfair collaboration between applicants in application’s assessment where joint working is not permitted;
(c) any form of bribery or inducement being offered or sought with a view to altering the outcome of an assessment, or the outcome of any other decision relating to a EtP’s scholarship or service;
(d) conduct likely to damage EtP’s reputation or public confidence in EtP scholarship or service;
(e) criminal activity;
(f) miscarriages of justice;
(g) danger to health and safety;
(h) damage to the environment;
(i) failure to comply with any legal obligation or regulatory requirements;
(j) any other form of bribery;
(k) financial fraud or mismanagement;
(m) significant breach of our internal policies and procedures;
(n) unauthorised disclosure of confidential information;
or (o) the deliberate concealment of any of the above matters.
3.2 A whistle-blower 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 malpractice, 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.
3.4 If you are uncertain whether something is within the scope of this policy you should seek advice from the Compliance Office, whose contact details are at the end of this policy. Such discussions will be treated confidentiality if requested.
4.1 We hope that in many cases you will be able to raise any concerns with the relevant EtP staff and partners. 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. In some cases they may refer the matter to EtP’s Compliance Officer.
4.2 However, where the matter is more serious, or you feel that staff of partners has not addressed your concern, or you prefer not to raise it with them for any reason, you should contact one of the following:
(a) The Compliance Officer;
or (b) The Director.
Contact details are set out at the end of this policy.
4.3 We will endeavour to obtain the full details about your concern as soon as possible. Where feasible, we will meet with you in person. Where this is not convenient we may alternatively arrange a video conferencing call (using Skype or similar software) or a telephone discussion. A colleague, union representative or fellow may accompany you to any meetings under this policy, or join any video conference or telephone discussions. Your companion must respect the confidentiality of your disclosure and any subsequent investigation.
4.4 We will take down a written summary of your concern and provide you with a copy after the meeting. We will also aim to give you an indication of how we propose to deal with the matter.
4.5 In some circumstances the quickest and easiest way of understanding your concern may be for us to communicate with you by email, rather than using the methods discussed above. In every case we will try to use the method of communication that most conveniently and appropriately allows you to express your concern to us.
5.1 We hope that you will feel able to voice whistleblowing concerns openly under this policy. However, if you want to raise your concern confidentially, we will make every effort to keep your identity secret. If it is necessary for anyone investigating your concern to know your identity, we will discuss this with you first.
5.2 We do not encourage anyone to make disclosures anonymously. Proper investigation may be more difficult or impossible if we cannot obtain further information from you. It is also more difficult to establish whether any allegations are credible and have been made in good faith. Whistle-blowers who are concerned about possible reprisals if their identity is revealed should discuss their concerns, on an anonymous basis if you wish, with the Compliance Officer or the Director. We will do our best to advise you on what measures we can put in place to preserve your confidentiality based on your particular circumstances, providing of course that you are able to give us enough information to do so. If you are in any doubt you can seek advice from Public Concern at Work (PCAW), the independent whistleblowing charity, who offers a confidential helpline. Their contact details are at the end of this policy. Please note that if you are based outside the UK, then PCAW may not be able to offer advice, or may refer you to an alternative organisation that is able to advise in your location.
5.3 Please note that while we will always endeavour to preserve your confidentiality where possible, we cannot guarantee this in every case. In certain circumstances, we may be required by law to divulge a whistle-blower’s identity, for example to the police, fraud prevention agencies, other law enforcement agencies, the courts, or regulatory bodies. A whistle-blower should also recognise that he or she may potentially be unavoidably identifiable by others due to the specific nature or circumstances of the disclosure.
5.4 Our scholarship and services are delivered in many countries around the world, and local contexts can vary very widely. We will always do our best to preserve confidentiality where requested, regardless of the location of the whistle-blower. If you are concerned about your confidentiality you should discuss this with the Compliance Officer or the Director who will be able to advise you on what protections can be put in place in your particular circumstances.
6.1 The aim of this policy is to provide a clear mechanism for reporting, investigating and remedying any malpractice or wrongdoing connected to a EtP scholarships and services, or related to any other aspect of EtP’s activities. In most cases you should not find it necessary to alert anyone externally.
6.2 The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. It will very rarely if ever be appropriate to alert the media. We strongly encourage you to seek advice before reporting a concern to anyone external. The independent whistleblowing charity, Public Concern at Work, operates a confidential helpline. They also have a list of prescribed UK regulators for reporting certain types of concern. Their contact details are at the end of this policy.
7.1 Once you have raised a concern, we will carry out an initial assessment to determine the scope of any investigation. We will inform you of the outcome of our assessment. You may be asked to attend additional meetings, video conferences or telephone discussions, in order to provide further information, or to provide further information by email.
7.2 In some cases we may appoint an investigator or team of investigators including staff with relevant experience of investigations or specialist knowledge of the subject matter. The investigator(s) may make recommendations for change to enable us to minimise the risk of future malpractice or wrongdoing.
7.3 We will aim to keep you informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent us giving you specific details of the investigation or any disciplinary action taken as a result. You should treat any information about the investigation as confidential.
7.4 If we conclude that a whistle-blower has made false allegations maliciously, in bad faith or with a view to personal gain, the whistle-blower may be subject to disciplinary action, depending on the nature of their relationship to EtP.
8.1 While we cannot always guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way. By using this policy you can help us to achieve this.
8.2 If you are not happy with the way in which your concern has been handled, you can raise it with one of the other key contacts in paragraph 4. Alternatively you may contact the Director. Contact details are set out at the end of this policy.
9.1 It is understandable that whistle-blowers are sometimes worried about possible repercussions. We aim to encourage openness and will support connected persons or students who raise genuine concerns in good faith under this policy, even if they turn out to be mistaken.
9.2 Anyone raising a concern in good faith should not suffer any detrimental treatment as a result of doing so. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
9.3 Our staff must not threaten or retaliate against whistle-blowers in any way. Anyone involved in such conduct will be subject to disciplinary action.
9.4 Connected persons or students may feel that they are being treated detrimentally by an EtP or its education partner as a result of raising whistleblowing concerns. You should report such treatment to the Compliance Officer. While EtP may not be able to directly control the conduct of external organisations or other third parties, we will use all reasonable means available to us to prevent such detrimental treatment.
10.1 The Director has overall responsibility for this policy, and for reviewing the effectiveness of actions taken in response to concerns raised under this policy.
10.2 The Compliance Officer has day-to-day operational responsibility for this policy, and must ensure that all managers and other staff who may deal with concerns or investigations under this policy receive regular and appropriate training.
10.3 The Compliance Officer, in conjunction with the Director and Board of Advisors should review this policy from a legal and operational perspective at reasonable intervals.
10.4 Staff, connected persons and applicants are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Compliance Officer.
Compliance Officer. C/O Tcs Corporate Services Ltd, 84 Brook Street, London, W1K 5EH. Compliance@educatetheplanet.world
The Director. C/O Tcs Corporate Services Ltd, 84 Brook Street, London, W1K 5EH.
Last updated November 2015