What is whistleblowing?
Whistleblowing is a term used when an individual raises a genuine concern about suspected malpractice or wrongdoing and/or the covering up of malpractice or wrongdoing. Whistleblowing is different from raising a grievance. Its aim is to prevent harm to others or to an organization; it is not to provide redress to you for a complaint you may have.
ISC takes whistleblowing very seriously. This policy describes how whistleblowing is distinct from both complaints and employment disputes or grievances that an individual may have. It also explains how you can raise your concern with ISC under this policy and how ISC will handle this concern.
What types of disclosures can be submitted under this policy?
The difference between a whistleblowing issue and an employee grievance or private complaint is that in the case of whistle-blowing, the concern is about a danger or illegality that has a public interest to it.
The whistleblowing policy is not designed for the questioning of financial or business decisions taken within the ISC; nor will it apply to complaints about a product/service or personal grievances concerning an employee’s terms and conditions of employment, or any other aspects of the working relationship, i.e. complaints relating to bullying, harassment, or disciplinary matters. Such complaints shall be dealt with under line management structure and/or the works council responsibility.
This policy applies to disclosures relating to malpractices occurring within ISC.
Examples of malpractice which you should report include, but are not limited to, the following:
- Corruption, bribery or blackmail;
- Other criminal offenses;
- Fraud and financial irregularity;
- Failure to comply with legal or regulatory obligations;
- Irregularities with ISC’s Procurement;
- Abuse of position at ISC to obtain personal benefits;
- Showing undue favor over a contractual matter or to a job applicant;
- Endangering the health and safety of any individual;
- Endangering or abusing (either physically or mentally) children;
- Incidences of discrimination based on race, sex, religion or language;
- Unauthorized disclosure of confidential information;
- Environmental damage;
- Concealing any of the above.
A qualifying disclosure will be ‘protected’ provided you:
- make the disclosure in good faith
- reasonably believe that the information disclosed and any allegation contained within the disclosure is substantially true and in the best interest of ISC
This policy gives specific examples of matters which are of serious concern and which should be reported. This document is not exhaustive and, if you cannot find the guidance you need, or if you remain unsure, it may be helpful to go through the following questions:
- Does this feel right to me?
- Does it appear reasonable?
- Would I feel comfortable justifying this to public scrutiny?
If you answer ‘no’ to these questions, you should report the concerns.
Who can hand in a report under this policy?
Every person inside and outside ISC can hand in a report.
Procedures How to Raise a Concern
As a first step, employees should normally raise concerns with their immediate line manager, or they may prefer to make the disclosure independently of line management to a trusted senior manager. This depends, however, on the seriousness and sensitivity of the issues involved and who is suspected of malpractice. If you have exhausted all options of redress at school level and remain concerned by the response provided, or if you feel the departmental route is inappropriate, you can raise your concerns via the confidential email which is monitored by the ISC Board: email@example.com
Concerns of non-employees may be raised verbally or preferably in writing to the school management or via the confidential email which is monitored by the ISC Board: firstname.lastname@example.org
When raising concerns, you will be required to provide information relating to:
- The background and history of the concern, giving relevant dates;
- The reason why you are particularly concerned about the situation;
- The extent to which you have personally witnessed or experienced the problem, providing documentary evidence where possible.
What action will ISC take?
ISC will acknowledge receipt of the disclosure within seven days latest. If necessary, your disclosure may be forwarded to the relevant authority for further review. ISC may contact you to request additional information that may be required for this review. Please note that for privacy reasons, ISC will not provide the whistleblower with information relating to the steps taken by ISC or any outcomes resulting from the disclosure and subsequent investigations.
ISC will consider each disclosure of information sensitively and carefully, and decide upon an appropriate course of action. ISC will look into anonymous whistleblowing disclosures. However, it may not always be possible to investigate or substantiate such disclosures.
ISC may not always treat disclosures received as whistleblowing. It may be more appropriate to treat the disclosure as feedback. There may also be occasions where it is not appropriate for ISC to investigate under the circumstances, for example, if the disclosure falls outside of ISC’s remit. In this case, ISC may recommend another course of action for the whistleblower to take.
Confidentiality of Disclosure
As much as possible, ISC will treat any information provided in a sensitive and confidential way. Every effort will be made to keep the identity of the whistleblower confidentially, however, ISC may be required to disclose this information under certain circumstances. If it does become necessary to reveal your identity, you will be consulted before this action is taken. You should also recognize that you may be identifiable by others due to the nature or circumstances of the disclosure.
If you raise a concern or make an allegation in good faith that is then not confirmed by the investigation, the case will be closed and the disclosure will remain protected.
However, if you make an allegation frivolously, maliciously or for personal gain, it will result in appropriate action being taken against you, including disciplinary action.