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Whistleblowing Policy

Issue Number

Author of the plan

Date Approved by Board of Trustees

Review Date


Karen Dobney

September 2021

September 2022


  1. Introduction
    1. Employees or service users are often the first to realise that there may be something seriously wrong within the school. However, they may not express their concerns because they feel that speaking up would be disloyal to their colleagues, the school or to the Trust. They may also fear harassment or victimisation. In these circumstances it may be easier to ignore the concern rather than report what may just be a suspicion of malpractice.
    1. The PENNiNE Trust is committed to the highest possible standards of openness, probity and accountability. In line with that commitment we expect all service users, and others that we deal with, who have serious concerns about any aspect of the school or the Trust’s work to come forward and voice those concerns. It is recognised that most cases will have to proceed on a confidential basis.
    1. Under this Whistleblowing Policy you can raise such concerns without fear of victimisation, subsequent discrimination or disadvantage. The Policy is intended to encourage and enable all service users to raise serious concerns within the Trust rather than overlooking a problem or 'blowing the whistle' outside.
    1. The policy applies to all service users ie employees, and applies equally to those designated as casual, temporary, agency, authorised volunteers/work experience, governors. It also applies to those contractors working for a school or the Trust, on a school or Trust premises e.g. agency staff, builders, drivers, and cover suppliers and those providing services under a contract with the school in their own premises.
    1. These procedures are in addition to the Trust’s complaints’ procedures and other statutory reporting procedures. Service users should be made aware of the existence of these procedures.
    1. This policy has been discussed with the recognised Trade Unions/Professional Associations and has their support.
  1. Aims and scope of this policy
    1. This policy aims to:
      • encourage you to feel confident in raising serious concerns and to question and act upon concerns about practice;
      • provide avenues for you to raise those concerns and receive feedback on any action taken;
      • ensure that you receive a response to your concerns and that you are aware of how to pursue them if you are not satisfied; and
      • reassure you that you will be protected from possible reprisals or victimisation if you have a reasonable belief that you have made any disclosure which is in the public interest.
    1. There are existing procedures in place to enable you to lodge a grievance or complaint relating to your own employment. The Whistleblowing Policy is intended to cover major concerns that fall outside the scope of other procedures.

These include:

      • conduct which is an offence or a breach of law;
      • failure to comply with a legal obligation;
      • disclosures related to miscarriages of justice;
      • health and safety risks, including risks to the public/pupils as well as other all service users;
      • damage to the environment;
      • the unauthorised use of public funds;
      • possible fraud and corruption;
      • sexual or physical abuse of pupils where referral under Safeguarding procedures is not appropriate;
      • other unethical conduct; and
      • actions which are unprofessional or inappropriate

Note: There is a requirement under the Internal Financial Regulations for a school within the Trust to notify the Audit Committee immediately of all suspected financial or accounting irregularities. This requirement does not supersede the Whistleblowing Policy and the procedure within this policy will need also need to be followed.

    1. Any serious concerns that you have about any aspect of service provision or the conduct of school or trust staff , governors, the board of trustees, Members or others acting on behalf of the Trust can be reported under the Whistleblowing Policy. This may be about something that
      • makes you feel uncomfortable in terms of known standards, your experience or the standards you believe the PENNiNE Trust subscribe to;
      • is against the Trust's Standing Orders and policies;
      • falls below established standards of practice; or
      • amounts to improper conduct.
    1. This policy does not replace the Trust’s complaints procedures.
  1. Key principles
    1. It is recognised that the decision to report a concern can be a difficult one to make. If what you are saying is true, you should have nothing to fear because you will be doing your duty to your employer and to those for whom you are providing a service.
    1. The PENNiNE Trust will not tolerate any harassment or victimisation (including informal pressures) and will take appropriate action to protect you when you raise a concern which is in the public interest.
    1. Investigations into allegations of potential malpractice will not influence or be influenced by any disciplinary or redundancy proceedings that are already taking place.
  1. Confidentiality
    1. All concerns will be treated in confidence and every effort will be made not to reveal your identity if you so wish. At the appropriate time, however, anyone making a disclosure under this Policy may need to provide evidence as a witness, and in these cases, it may not always be possible for you to remain anonymous.
  1. Anonymous allegations
    1. This policy encourages you to put your name to your allegation whenever possible.
    1. Concerns expressed anonymously may be less powerful but will be considered at the discretion of the Trust. In exercising such discretion, the following factors may need to be taken into account:
      • the seriousness of the issues raised;
      • the credibility of the concern; and
      • the likelihood of confirming the allegation from attributable sources.
  1. Untrue allegations
    1. If you make an allegation which you believe is in the public interest but it is not confirmed by the investigation, no action will be taken against you. If, however, you make an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against you.
  1. How to raise a concern
    1. In raising a concern all service users should provide the following information:
      • the background and history of the concern (giving relevant dates);
      • the reason why you are particularly concerned about the situation;
      • the name(s) of any colleague’s/service user who you consider are directly involved; and
      • the name(s) of any colleague’s/service users who you believe may be able to help provide further information.
    1. All service users should normally raise concerns with a senior member of staff e.g. Headteacher/Deputy Headteacher. This depends, however, on the seriousness and sensitivity of the issues involved and who is suspected of the malpractice. For example, if you believe that senior management of the school is involved you may wish to approach the Chief Executive Officer. If you believe the Chief Executive Officer is involved, you should approach the Chair of the Trust or in the case of a financial issue, the Chair of the Audit Committee.
    1. Concerns may be raised verbally, in writing, or by using the whistleblowing complaints email address ( Calls can be initially be made to the Head of Governance or Head of HR at the Central Team on (01282865200) Concerns can also be made in writing and correspondence should be sent to Whistleblowing Complaint, The Central Team, PENNiNE Trust, Park High School, Venables Avenue, Colne, BB8 7DP.

Alternatively, you may contact the Head of Human Resources:

  • Head of HR – 01282 856032
  • Head of Governance – 01282 865200
    1. The earlier you express the concern the easier it is for action to be taken.
    1. Although you are not expected to prove beyond doubt the truth of an allegation, you will need to demonstrate to the person contacted that there are reasonable grounds for your concern.
    1. You may wish to consider discussing your concern with a colleague first and you may find it easier to raise the matter as a collective concern if there are two (or more) of you who have had the same experience or concerns.
    1. If you believe that you have to take the matter externally, possible contacts are listed at Section 10 of this policy.
  1. How the Trust will respond
    1. The Trust will provide a response to your concerns. If you confirm your wish to raise the concerns formally under this policy, a responsible person will be designated by the school management, where appropriate, or by the Board of Trustees, to co- ordinate the response to the concerns you have raised. The responsible person will respond to you in accordance with Paragraph 8.5 below and where the responsible person is outside the management of the school, they will notify the Chair of the Trust for registration, monitoring and annual reporting purposes.
    1. Where appropriate, the matters raised may:-
      • be investigated by the individual school, the Executive Headteacher, the Board of Trustees, internal audit committee, or through the disciplinary procedure;
      • be referred to the police;
      • be referred to the external auditor; or
      • form the subject of an independent inquiry.
    1. In order to protect individuals and those accused of misdeeds or possible malpractice, initial enquiries will be made to decide whether an investigation is appropriate and, if so, what form it should take. Such testing out of your concerns is not the same as either accepting or rejecting them. The overriding principle which the Trust will have in mind is the public interest.
    1. Concerns or allegations which fall within the scope of specific procedures (for example, child protection or discrimination issues) will normally be referred for consideration under those procedures.
    1. Some concerns may be resolved by agreed action without the need for investigation. If urgent action is required, this will be taken before any investigation is conducted.
    1. Within ten working days of a concern being raised, the responsible person will write to you to:
      • acknowledge that the concern has been received;
      • indicate how it is proposed to deal with the matter;
      • provide an estimate of how long it will take to provide a final response;
      • inform you whether any initial enquiries have been made;
      • supply you with information on staff support mechanisms (where appropriate), and inform you whether further investigations will take place and if not, why not.
    1. The amount of contact between those considering the issues and you will depend on the nature of the matters raised, the potential difficulties involved and the clarity of the information provided. If necessary, further information will be sought from you.
    1. Where any meeting is arranged under this Policy, away from school premises if you so wish, you can be accompanied by a Trade Union or Professional Association representative or work colleague.
    1. The Trust will take steps to minimise any difficulties which you may experience as a result of raising a concern. For example, if you are required to give evidence in criminal or disciplinary proceedings, arrangements will be made for you to receive appropriate advice about the procedure.
    1. It is accepted that you need to be assured that the matter has been properly addressed. Thus, subject to legal constraints, you will be informed of the outcome of any investigation.
  1. The responsible officer
    1. The Headteacher has overall responsibility for the maintenance and operation of this policy in respect of concerns raised formally within the school, and should maintain a record of concerns raised and report the outcome to the Chief Executive Officer who will inform the Board of Trustees.
    1. The Chair of the Trust has overall responsibility for the maintenance and operation of this policy in respect of concerns raised formally outside the management of the school and will maintain appropriate records of concerns raised and report as necessary to the Council.
  1. How the matter can be taken further
    1. This policy is intended to provide you with an avenue within a School or the Trust to raise concerns. The Trust hopes you will be satisfied with any action taken. If you are not, and if you feel it is right to take the matter outside the Trust, you may wish to contact your Trade Union/Professional Association or one of the following possible contact points:

Public Concern at Work

Public Concern at Work CAN Mezzanine

7-14 Great Dover Street London SE1 4YR

020 7404 6609

Public Sector Audit Appointments Ltd

PSAA Limited

3rd Floor Local Government House Smith Square

London SW1P 3HZ

020 7072 7445

Lancashire Constabulary

Lancashire Constabulary Headquarters Saunders Lane

Hutton Preston PR4 5SB

01772 614444

HM Customs and Excise

HM Revenue and Customs BX9 1AA

0300 200 3200

The Information Commissioner

The Office of the Information Commissioner

Wycliffe House, Water Lane Wilmslow


Cheshire SK9 5AF

0303 123 1113

The Environment Agency

National Customer Contact Centre PO Box 544

Rotherham S60 1BY

03708 506 506

Health and Safety Executive

Redgrave Court Merton Road Bootle

Merseyside L20 7HS

0845 300 9923


Ministerial and Public Communications Division

Department for Education Piccadilly Gate

Store Street Manchester M1 2WD

    1. If you do take the matter outside the Trust, you should ensure that you do not disclose confidential information that falls outside the scope of the complaint. You should check with the relevant contact point about that.