Choice Home Tutoring Whistleblowing Policy
Latest review date: 2 September 2025
Next review due: September 2026
Contents
- Mission Statement
- Our Core Values
- Policy Aims
- Meaning of Whistleblowing
- Confidentiality
- Anonymous Concerns
- False and Malicious Allegations
- Employees’ and Tutors’ Responsibilities
- CHT’s Responsibilities
- How to Raise a Concern
- How the Matter Will Be Investigated: Informal Stage
- Formal Stage
- Investigation Outcome
- How the Matter Can Be Taken Further
1. Mission Statement
Choice Home Tutoring’s mission is:
“To provide learners with a personalised tuition service based on their specific needs.”
2. Our Core Values
The following core values illustrate how we believe Choice Home Tutoring needs to operate in order to succeed.
Our approach has always been to develop and maintain a brand that our customers and the general public can trust.
A Personal Service
As our mission statement makes clear, it has always been our aim to ensure that our customers receive the most personal service we can offer.
We know that our customers value this approach and that it has helped to enhance our reputation.
High Quality
We aim to provide a high-quality service by:
- Recruiting high-quality tutors
- Communicating positively and efficiently with customers
- Inspiring our staff and tutors to offer a service that is recognised as one of the best available within our marketplace
Satisfying Demand
We work hard to ensure that the range of subjects delivered by our tutors can fully meet the needs of our customers.
Friendly and Enthusiastic Tutors
While maintaining the highest levels of professionalism, our tutors must demonstrate:
- A passion for their subject
- An ability to engage with their students
- A desire to ensure that tuition has a positive impact on learning
Honesty and Integrity
We firmly believe in placing honesty and integrity at the heart of our business.
In practice, this means that when dealing with our customers and tutors, we will refuse to say or do anything that we do not believe is right.
Trust and Loyalty
Trust and loyalty cannot be built with our customers and tutors without honesty and integrity as our guiding principles.
These values form the basis of our strength and reputation as a business.
3. Policy Aims
This policy outlines Choice Home Tutoring’s approach to employee and tutor disclosures, commonly known as whistleblowing.
CHT is committed to providing a working environment that protects the health, safety and welfare of all employees and tutors.
We are also committed to maintaining the highest possible standards of openness and accountability and will not tolerate malpractice or wrongdoing.
This policy aims to protect individuals who make disclosures in the public interest concerning malpractice or wrongdoing.
Specifically, the policy aims to:
- Provide a clear process through which tutors and employees can raise genuine and legitimate concerns about misconduct or malpractice, including safeguarding concerns
- Confirm that misconduct and malpractice are taken extremely seriously
- Maintain confidentiality and reassure tutors and employees that concerns raised in good faith can be reported without fear of reprisal or victimisation
- Provide guidance explaining the arrangements and procedures for applying this policy
- Allow CHT to provide appropriate guidance or appoint another suitable organisation to investigate a concern on its behalf
- Enable CHT to take appropriate action to resolve the situation
4. Meaning of Whistleblowing
Whistleblowing describes the arrangements that allow people, usually employees or workers, to raise concerns about malpractice that may be taking place within the workplace.
This could include something that is, or may be:
- An unlawful or criminal offence
- A breach of a legal obligation
- A disregard for health and safety legislation
- A breach of financial regulations
- Improper conduct
- The inappropriate or unauthorised use of school funds
- A deliberate attempt to conceal information relating to any of the above
Whistleblowing arrangements are closely linked to creating a culture in which employees and tutors feel able to raise concerns without fear of intimidation or recrimination.
Any concerns reported will be treated seriously, confidentially and investigated fully.
These arrangements also allow concerns to be raised outside the normal management structure where necessary.
Employees and tutors who believe that something is seriously wrong within CHT must feel able to report their concerns without feeling disloyal or fearing harassment or victimisation.
CHT encourages employees and tutors who have serious concerns about misconduct or malpractice to come forward. This policy makes it clear that they can do so without fear of reprisal or victimisation.
Whistleblowing arrangements also recognise that allegations of wrongdoing may sometimes be false or malicious. False or malicious allegations will be treated as a serious disciplinary matter.
5. Confidentiality
CHT will do everything reasonably possible to protect the identity of a tutor or employee who raises a concern and does not want their name to be disclosed.
However, the investigation process may reveal the source of the information. A statement may also be required as part of the evidence, and the individual may need to act as a witness in future proceedings.
6. Anonymous Concerns
All complaints will be considered and, where appropriate, investigated.
The extent of the investigation will depend on:
- The nature of the allegations
- The seriousness of the issues raised
- The credibility of the concern
- The likelihood of confirming the allegations through identifiable sources
Concerns raised anonymously may be less persuasive than those raised formally by an employee or tutor.
It will also not be possible to report the findings of an investigation back to an anonymous complainant.
7. False and Malicious Allegations
While CHT encourages employees and tutors to raise matters of concern, we will guard against unfounded claims made deliberately to damage another employee’s or tutor’s reputation.
Where an employee or tutor makes an allegation in good faith that is not confirmed by the investigation, no action will be taken against them.
However, where an allegation is found to be malicious, it will be treated as a serious offence and appropriate disciplinary action may be taken.
8. Employees’ and Tutors’ Responsibilities
All employees and tutors are responsible for ensuring that their own behaviour is appropriate to their role within CHT.
Their behaviour must not contribute to an environment in which malpractice or wrongdoing is ignored, accepted or encouraged.
Employees and tutors should challenge inappropriate behaviour when it occurs or bring it to the attention of a CHT Director.
9. CHT’s Responsibilities
CHT has a responsibility to establish and maintain a positive and accountable working environment.
In particular, CHT is responsible for:
- Communicating this policy to all employees and tutors in a way that promotes understanding and ensures it is easily accessible
- Managing employees and tutors professionally and sensitively
- Creating a culture in which malpractice and wrongdoing are unacceptable
- Taking all concerns seriously
- Ensuring that appropriate action is taken promptly and that matters are handled sensitively and confidentially
- Making it clear that malicious allegations are serious and will not be tolerated
- Meeting all applicable legal duties and responsibilities
- Acting within the relevant legal framework at all times
10. How to Raise a Concern
CHT acknowledges that reporting a concern can be difficult for an employee or tutor, particularly where they fear reprisals from those responsible for the alleged malpractice.
CHT will not tolerate harassment or victimisation and will take appropriate action to protect anyone who raises a concern in good faith.
Employees and tutors should raise their concern with an appropriate CHT Director, taking into account who is suspected of the malpractice.
Wherever possible, concerns should be submitted in writing and should include:
- The background and history of the concern
- Relevant names, dates and locations
- The reason the individual is particularly concerned about the situation
Where an employee or tutor does not initially feel able to put the concern in writing, they may telephone or arrange to meet a CHT Director.
The Director will make a written record of the concerns raised.
The employee or tutor will need to demonstrate that there are reasonable grounds for concern so that the matter can be taken forward.
CHT will monitor how the person raising the concern is treated afterwards to ensure that there is no evidence of harassment or victimisation.
Concerns about CHT itself can be raised externally by contacting the Whistleblowing Helpline:
Email: enquiries@wbhelpline.org.uk
Telephone: 08000 724725
11. How the Matter Will Be Investigated: Informal Stage
All allegations will be handled confidentially and discreetly by those directly involved in the investigation.
Initial enquiries will be carried out to determine:
- Whether an investigation is appropriate
- What form the investigation should take
- Who should undertake the investigation
In some circumstances, an investigation may be completed without the person who is the subject of the complaint being made aware of it.
Some concerns may be resolved through agreed action without requiring a formal investigation.
In these circumstances, confirmation should be obtained from the employee or tutor that they are satisfied the matter has been resolved.
This does not prevent the matter from being raised again where further concerns arise.
Where it is determined that the matter should be dealt with formally, CHT should notify its outsourced HR provider before taking further action.
The CHT Whistleblowing Record Sheet should be used to record and monitor the investigation.
12. Formal Stage
The employee or tutor who raises the concern should receive a written acknowledgement within 10 working days of the concern being received.
The acknowledgement will explain:
- How CHT proposes to deal with the matter
- Approximately how long it may take to provide a response
- Any initial enquiries that have been made
- Whether a further investigation will take place
- Where no further investigation will take place, the reasons for this decision
After acknowledging receipt of the concern, CHT will consult its outsourced HR provider.
Where urgent action is required, appropriate action may be taken before a full investigation has been completed.
Investigations into allegations of malpractice must be:
- Independent
- Objective
- Conducted by someone with the appropriate knowledge and skills
The appointed CHT Investigating Officer must not have had any previous involvement with the case.
The Investigating Officer will be sensitive to the complainant’s wishes wherever reasonably possible.
Depending on the circumstances, external organisations may also be involved in the investigation.
At any meeting arranged to discuss the concern, the employee or tutor may be accompanied by a companion or representative who is not involved in the area to which the concern relates.
The person accused of wrongdoing is also entitled to representation during any interviews in which they are involved.
The first stage of the investigation will normally involve the Investigating Officer speaking to:
- The person who raised the concern
- The person accused of wrongdoing
Witnesses may also be interviewed and asked to provide written statements.
Where witnesses have been identified or interviewed, it is important that they do not suffer any personal disadvantage as a result, provided they have acted in good faith.
The investigation should normally be completed within 30 working days of the concern being registered.
Where the investigation is likely to take longer than 30 working days, the Investigating Officer will inform the complainant.
Every effort will be made to protect the legitimate rights of everyone involved in the investigation.
Strict confidentiality must be maintained at all times. Any breach of confidentiality may result in disciplinary action.
13. Investigation Outcome
The investigation will conclude with a written report prepared by the Investigating Officer.
The report will summarise the findings and make recommendations for further action.
Possible outcomes include:
- A finding that the allegation was unfounded and that no action is required
- A recommendation that no further action should be taken because there is insufficient evidence or the complaint is untrue
- A recommendation that appropriate action should be taken where the matter is not sufficiently serious to justify formal disciplinary action
- A recommendation that formal disciplinary action should begin where there is objective evidence that malpractice has occurred
Where action is required but formal disciplinary action is not considered appropriate, the response may include:
- Written management advice
- An instruction requiring the employee or tutor to receive appropriate guidance or training
- Appropriate changes to working arrangements, provided these changes do not disadvantage the person who raised the concern
A CHT Director will write to both the complainant and the person accused of wrongdoing to inform them of:
- The investigation findings
- Any action that will be taken
The letter will confirm that the complainant and any witnesses must not be victimised or suffer any disadvantage as a result of making or supporting the complaint.
Where CHT decides to take no action, regardless of the Investigating Officer’s recommendation, it will provide written reasons to the complainant and the person accused of wrongdoing.
Failure to provide this information will be regarded as a breach of this procedure.
Where the Investigating Officer considers that a complaint is both untrue and malicious, they may recommend a second investigation into the circumstances.
This may result in disciplinary action being considered against the complainant.
Suspension may be considered necessary during this process. However, suspension is a neutral action and does not imply that any judgement has already been made.
CHT will maintain a confidential central record of whistleblowing investigations for five years.
Where an allegation has been made anonymously and CHT decides that further action would be inappropriate, the details of the allegation and the reasons for the decision must still be recorded.
These central records will be used to:
- Review the effectiveness of the whistleblowing arrangements
- Analyse the outcomes of concerns raised
- Report back to CHT members
- Maintain a record of actions taken in relation to matters raised under the Public Interest Disclosure Act
14. How the Matter Can Be Taken Further
This Whistleblowing Policy and its associated procedures are intended to enable CHT to deal satisfactorily with concerns raised by employees and tutors.
Where an employee or tutor remains dissatisfied and considers it appropriate to take the matter further, they may make a protected disclosure to an appropriate third party in accordance with the Public Interest Disclosure Act 1998.
Employees and tutors may also contact the independent charity Public Concern at Work for free advice about raising concerns relating to fraud or other serious malpractice.
CHT will make every effort to reach a satisfactory conclusion and minimise the need for an employee or tutor to take these additional steps.