| Policy Title | Whistleblowing | Date of Last Review | August 2024 |
| Policy Reference | FTEC 2 | Date of Next Review | July 2025 |
| Authorised by: | Board of Directors | August 2024 |
MISSION STATEMENT
Friendlytutors & Education Consultancy (FTEC) is committed to providing outstanding tutoring
services to all our user, students, parents, and tutors. FTEC welcomes compliments and
complaints from our learning community, from our stakeholders and from the general public. We
use this process positively to improve services for our students, parents, tutors, and the wider
community.
We recognise that, occasionally, mistakes will be made, or the service offered will not meet an
individual’s requirements or expectation. As well as being managed as set out in this procedure,
complaints will be used as feedback to improve the service which we offer
EQUALITIES STATEMENT
All who work at the Friendlytutors & Educational Consultancy (FTEC) Limited are committed to
the celebration of diversity, and the challenging of disadvantage and discrimination, in all its
forms.
These values are explicit to the ethos of the Friendlytutors & Educational Consultancy (FTEC)
Limited and embedded into all our policies and practice.
These values are explicit to the ethos of the FTEC and implicit in all policies and practice
As a Rights Respecting company, we recognise Article 28 ‘The right of every child
to a good quality education’ and Article 19 ‘All children have the right to be protected
from danger’ from the UN Convention of the Rights of the Child.
It is a primary aim of our company that every member of the community feels valued
and respected, and that each person is treated fairly and well. We are a caring
community, whose values are built on mutual trust and respect for all. FTEC behaviour
policy is therefore designed to outline the way in which all members of staff can live
and work together in a supportive manner. It aims to promote an environment where
everyone feels happy, safe and secure, so that people can work together with the
common purpose of helping everyone to learn.
This policy should be read with reference to:
∙ The Safeguarding Policy
∙ The Online Safety Policy
∙ The SEND Policy
Designated Safeguarding Officer/Behaviour
Lead
J. Adat
Contact details
jadat@friendlytutors.co.uk.
Tel: 07985138926
Christabel Achunike (Mrs) (Director/PSC) –
Recruitment team
Tel: 07961732757-1
Gabrielle Adat (Mrs) (Attendance Lead) Tel: 07944844558
Gabrielle@friendlytutors.co.uk.
Policy Title Whistleblowing Date of Last Review August 2024
Policy
Reference
FTEC 3 Date of Next Review July 2025
Authorised by: For Board of Directors August 2024
Registered address: 65 The Broadway, London E15 4BQ. Registered in England & Wales: Company no.
- Website: www.friendlytutors.co.uk; Email: contact@friendlytutors.co.uk.
Introduction
The Board of Director is committed to the provision of high-quality services and promoting
the highest standards of openness, probity and accountability. Members of staff and others
who have serious concerns about any aspect of our work should be able to raise these
concerns without fear of victimisation, discrimination or disadvantage.
It is in the interests of FTEC, the Board of Directors, members of staff and the public that a
wrongdoing is exposed and dealt with effectively.
Members of staff are often the first to realise that there may be something seriously wrong
within an organisation. In many circumstances it will be appropriate for staff to raise their
concerns with their Manager/Directors and this procedure is not intended to discourage this.
However, where staff may be cautious about expressing their concerns because they feel that
speaking up would be disloyal to their colleagues or to their FTEC, it may be easier to ignore
the concern rather than report what may just be a suspicion of malpractice. Alternatively, there
may also be circumstances where a member of staff has reported their concern to their
manager and received an unsatisfactory response.
This policy and procedure are intended to ensure that suspicion of wrongdoing can be dealt
with speedily and effectively. It seeks to balance safeguards for members of staff who raise
genuine concerns about malpractice against the need to protect other members of staff, the
FTEC and the Management Committee against uninformed or vexatious allegations which
can cause serious difficulty for innocent individuals.
Our aims: - to promote a culture of openness and a shared sense of integrity throughout the
company by inviting all members of staff to act responsibly to uphold the reputation of
the FTEC and maintain public confidence.
to provide safeguards so that members of staff feel able to raise concerns about
malpractice (‘a disclosure’) within the setting, without fear of adverse repercussions
to the individual and an effective mechanism for investigation of those concerns.
to provide feedback on action taken and advice on how to pursue those concerns
further if the individual is not satisfied with the outcome.
“Malpractice” for the purpose of this policy, includes the following on the part of another
member of staff, a member of the Management Committee, or any other person or persons
acting on the FTEC’s behalf:
Abuse of clients, improper discrimination against or relationship with clients.
Fraud or financial irregularity.
Corruption, bribery or blackmail.
Other criminal offences.
Failure to comply with a legal or regulatory duty or obligation.
Miscarriage of justice.
Endangering the health or safety of any individual.
Endangering the environment results permanent damage.
Improper use of authority or powers.
Serious financial maladministration arising from the deliberate commission
of improper conduct.
Unethical or improper conduct or conduct which breaches FTEC/Council
policies or falls below the standards which the FTEC/Council subscribes
to.
Registered address: 65 The Broadway, London E15 4BQ. Registered in England & Wales: Company no. - Website: www.friendlytutors.co.uk; Email: contact@friendlytutors.co.uk.
Concealment of any of the above. - Application of the Policy
This policy is intended to tackle genuine concerns of malpractice experienced by:
a member of the FTEC staff.
the staff of Council contractors employed on FTEC work;
members of the FTEC’s Management Committee
For the purposes of this policy, an individual who has grounds to believe that malpractice
has occurred, is occurring or is likely to occur in connection with the FTEC is referred to as
‘the discloser’. - This Policy Does NOT Apply To:
the relationship between members of staff, their managers and the Management
Committee, for which the employee complaints procedure or collective dispute
procedures are more appropriate.
concerns and complaints by members of the public to which the FTEC complaint
procedure will apply - Designated Assessors
Designated Assessors are senior members of staff of appropriate experience and standing
within the Council who have received appropriate training in this procedure and have been
appointed to act as “Designated Assessors” by the Board of Director for Children, Families &
Education (CFE)Department in the Council.
Following receipt of a disclosure the Board of Director CFE (or a senior contact officer to
which this is delegated) will identify a Designated Assessor who will be responsible for the
preliminary investigation of a disclosure and making recommendations to the Council’s
Monitoring Officer and Board of Director CFE as to what further steps, if any, should be
taken.
With the agreement of the Board of Director, CFE (or senior officer to whom this is
delegated) a Designated Assessor may seek assistance from another officer where specialist
knowledge or additional support may be required for proper investigation of the disclosure.
The Board of Director CFE may revoke any such designation as necessary and appoint new
Designated Assessors. - Making a Disclosure
Stage One
An individual, who has grounds to believe that the malpractice has occurred, is occurring or
is likely to occur in connection with the FTEC, should raise their concerns first with their
Manager. This may be done orally or in writing.
Stage Two
If the individual feels unable for whatever reason to raise the matter with their manager under
stage one, then they should raise the matter with their Board of Directors.
On receipt of the disclosure, the Managing Director/ Board of Director will offer to interview
the Discloser in confidence. The interview should take place as soon as practicable after the
Registered address: 65 The Broadway, London E15 4BQ. Registered in England & Wales: Company no. - Website: www.friendlytutors.co.uk; Email: contact@friendlytutors.co.uk.
initial disclosure. The Disclosure may be accompanied by a local trade union representative
or work colleague at the interview. The Board of Directors may also be accompanied by an
administrative assistant/clerk to take notes, which will not identify the Discloser. For
safeguards in relation to confidentiality, see section 9 below.
The purpose of the interview will be for the Managing Director/ Board of Director to:
obtain as much information as possible from the Discloser about the grounds of the belief
of malpractice; and
to consult with the Discloser about further steps which could be taken.
Stage Three
If stage one and/or two have been followed and the individual still has concerns, or if they
feel that the matter is such that they feel they cannot raise it with their Managing Director/
Board of Director, for example because it concerns them or it is very serious, then the
Discloser should communicate the disclosure by an email to: school whistleblowing team.
The initial disclosure should be made either:
wherever possible, in writing.
The Discloser should provide as much supporting written evidence as possible about the
disclosure, the grounds for the belief of malpractice and indicate why they have not felt able
to raise their concerns through normal management channels.
Alternatively, there is a confidential reporting service available to FTECs through the
‘Learning without Boundaries’ services traded to FTECs. The service is provided by Public
Concern at Work (PCaW) (telephone number 0207 404 6609 (advice line) who will
provide advice and, should the Discloser wish them to do so, also provide details of the
allegations to the Board of Director People who will refer it to a Designated Assessor to be
dealt with in accordance with this procedure.
Where a disclosure is made through the Council’s confidential reporting facility, full details of
the allegations will be recorded and a report passed on to Board of Director CFE for referral
to one of the Designated Assessors.
Registered address: 65 The Broadway, London E15 4BQ. Registered in England & Wales: Company no. - Website: www.friendlytutors.co.uk; Email: contact@friendlytutors.co.uk.
Disclosers are encouraged to give details of their identity. If in making a disclosure the
Discloser provides details of their identity these will not be passed to the Board of Director
CFE or any other member of FTEC or Council staff without the Discloser’s express consent
(and see Section 9 below)
Anonymous disclosures are much less powerful but may nevertheless be considered having
regard to:
the seriousness of the issues raised;
the credibility of the concern;
the likelihood of confirming the allegation through other suitable sources.
On receipt of the disclosure, where their identity is known, the Designated Assessor will offer
to interview the Discloser in confidence. The interview should take place as soon as
practicable after the initial disclosure but no later than within 3 weeks of the matter being
referred to the Designated Assessor by the Board of Director CFE. The Disclosure may be
accompanied by a local trade union representative or work colleague. The Designated
Assessor may be accompanied by an administrative assistant to take notes, which will not
identify the Discloser. For safeguards in relation to confidentiality, see section 9 below.
The purpose of the interview will be for the Designated Assessor to:
obtain as much information as possible from the Discloser about the grounds of the belief
of malpractice including why the disclosure is in public interest; and
to consult with the Discloser about further steps which could be taken. - Enquiries and Report by Managing Director/Board of Directors
As soon as practicable after the interview (or after the initial disclosure if no interview takes
place) and where possible within 3 weeks of the interview or initial disclosure if not interview
takes place, the Managing Director/ Board of Director or the Designated Assessor will
determine their recommendations as to the further steps that should be taken such as:
a report to the police or other appropriate public authority.
investigation by the Council’s Internal Auditor (this will be the usual course where
there are allegations of financial irregularities) or referral to the Education Funding
Agency if an Academy.
Registered address: 65 The Broadway, London E15 4BQ. Registered in England & Wales: Company no. - Website: www.friendlytutors.co.uk; Email: contact@friendlytutors.co.uk.
a full investigation either internally by the Council or externally e.g. by the Council’s
auditors or by investigators appointed by the Council.
action under the FTEC’s grievance, disciplinary, harassment and bullying or
complaints procedures.
referral for consideration under other specific procedures (e.g. child protection);
no further action (the basis for which see below).
The Managing Director/ Board of Director or Designated Assessor’s recommendations will be
made to the Council’s Monitoring Officer and the Board of Director CFE to decide whether they
agree with them. If the recommendations are agreed they will be referred to the Managing
Director/ Board of Director for implementation.
The recommendation will be made without revealing the identity of the Discloser except in the
circumstances set in Section 9 below.
The grounds on which the Headteacher/Chair of Governor or Designated Assessor may
recommend that no further action are as follows:
if satisfied that the Discloser has not shown that malpractice within the meaning of this
procedure has occurred, is occurring or is likely to occur.
if satisfied that the Discloser is not acting in good faith e.g. if after investigation it
appears that the disclosure is willfully malicious or vexatious, (in which case it may be
referred to for disciplinary action);
if the matter concerned is already the subject of legal proceedings or has already been
referred to the police or other public authority.
if the matter is already, has already been, or should be, the subject of proceedings under
one of the FTEC/Council’s other procedures relating to staff.
Once it has been decided what further steps (if any) should be taken, the Managing Director/
Board of Director or Designated Assessor will, where their identity is known, inform the
Discloser of the decision. If no further action is proposed, the Managing Director/ Board of
Director or Designated Assessor will give the Discloser the reasons for this in writing.
If the Management Committee decides not to fully implement any recommendations the Board
of Directors reserve the right to issue a warning and to inform the Secretary of State. - External Disclosure
It is recognised that in exceptional circumstances, or if dissatisfied after using this procedure,
an individual might wish to make a disclosure without using the FTEC’s procedure. However,
individuals considering such a step are advised to take legal advice before making an
external disclosure.
They may make an external disclosure: –
on a confidential basis directly with bodies such as the external auditor or other appropriate
public authority or such person as may be prescribed by the Secretary of State under Section
43F of the Public Interest Disclosure Act 1998. Before taking any such action, the Discloser
is encouraged to inform the Managing Director/ Board of Director or Designated Assessor
where one is already undertaking an investigation.
if they have reasonable grounds for believing that disclosure would lead to evidence
being concealed or destroyed or that the Discloser will be subjected to a detriment as
a result of making the disclosure.
on a confidential basis for the purpose of taking legal advice.
Registered address: 65 The Broadway, London E15 4BQ. Registered in England & Wales: Company no. - Website: www.friendlytutors.co.uk; Email: contact@friendlytutors.co.uk.
- Safeguards and Confidentiality
Any document, report or recommendation prepared by the Managing Director/ Board of
Director or Designated Assessor in relation to the matter will not identify the Discloser,
unless: –
the Discloser has consented to this in writing; or
There are grounds to believe the Discloser has acted maliciously; or
where the Managing Director/ Board of Director or Designated Assessor
is under a legal obligation to do so; or
where the information is already in the public domain; or
on a strictly confidential basis to the Designated Assessor’s
administrative assistant/administrative support; or
on a strictly confidential basis to a professionally qualified lawyer for the purpose
of obtaining legal advice.
The Managing Director/ Board of Director or Designated Assessor will ensure that all
information relating to the disclosure (including that held electronically) is kept secure so that,
as far as practicable, only the Managing Director/ Board of Director or Designated Assessor
shall have access to it.
Disclosers will be under obligation to use all reasonable endeavours to ensure that they and
their representative or work colleague (if any) keeps this
matter strictly confidential save, as permitted under this procedure, as required by law
or until such time as it comes into the public domain.
The Discloser will not be required by the Board of Directors, without consent, to participate in
any enquiry or investigation into the matter established by the FTEC unless there are grounds
to believe that the Discloser may have been involved in misconduct or malpractice.
Where the Discloser participates in any enquiry or investigation, that participation will usually
be required to be on an open rather than a confidential basis. The obligations of the
Managing Director/ Board of Director or Designated Assessor detailed above will remain in
relation to the identity of the individual as the original Discloser of information.
The Management Committee will not (and it will use all reasonable endeavours to ensure
that members of staff do not) subject the Discloser to any detriment, on the grounds of the
Discloser’s disclosure of information under this procedure (unless there is proved abuse of
this procedure through the making of willfully malicious or vexatious disclosures).
The Discloser should report any complaints of such treatment to the Managing Director/ Board
of Director or Designated Assessor.
If the Discloser wishes the Managing Director/ Board of Director or Designated Assessor to
act in relation to such complaints, the Discloser may be asked to consent in writing to the
Managing Director/ Board of Director or Designated Assessor revealing the Discloser’s
identity for the purposes of such action.
Training
All new staff receive training in this policy on whistleblowing as part of their induction training. All
staff receive updated training as policies change.
Registered address: 65 The Broadway, London E15 4BQ. Registered in England & Wales: Company no. - Website: www.friendlytutors.co.uk; Email: contact@friendlytutors.co.uk.
Further information
- Public Concern at Work: www.pcaw.org.uk (for advice and guidance on ways forward).
- www.gov.uk/whistleblowing
Who to Contact for Advice on the Procedure
Please use the following contact details:
Email: educationessex.essex.gov.uk/Enquiry/Enquiry
Form
Telephone: 0333 013 9891
Registered address: 65 The Broadway, London E15 4BQ. Registered in England & Wales: Company no.
- Website: www.friendlytutors.co.uk; Email: contact@friendlytutors.co.uk.
APPENDIX – WHISTLEBLOWING PROCEDURE
GUIDANCE FOR Managers/Directors ON RESPONDING TO A DISCLOSURE - You should ensure that members of staff employed on FTEC work are aware of the
Whistleblowing Procedures and know where it can be located. - If you receive a disclosure in respect of any of the matters set out under
section 2 ‘Aims of the procedure’ in the Whistleblowing Procedure you must
take the following action:
2.1 take the matter seriously and do not dismiss or belittle the information.
2.2 respect as far as possible the confidentiality of the employee and adhere to the
procedure under section 9 ‘Safeguards and confidentiality’ where the employee has
specifically asked for confidentiality.
2.3 ensure that the employee understands the Whistleblowing procedure.
2.4 offer to interview the Discloser in confidence.
2.5 discuss ways that the employee could be supported.
2.6 investigate the concern objectively, dealing with all parties with sensitivity and tact.
2.7 seek advice from the contact officer nominated by the Board of Directors if applicable
or using the contact details given on page 8 of this document;
2.8 set out clearly how the concern is to be taken forward, ensure that dated notes are
made and kept of the process followed, notes of discussion etc.;
2.9 Keep the Discloser informed about the progress made and outcome of the
investigation.
2.10 provide the contact officer nominated by the Board of Director People if applicable
with details of the concern and inform them about the progress and outcome of the
investigation.
2.11 if at the conclusion of your investigations you are of the view that the concern was not
raised in good faith, seek further advice - Note that if the concern relates to alleged fraud, this should be reported
to the Council’s Internal Auditor.