Whistleblowing Policy

1. Statement and Purpose

BIG International College (UK) (“the College”) is committed to maintaining the highest standards of openness, integrity, and accountability. This Whistleblowing Policy establishes a safe and transparent mechanism for staff, students, contractors, and associated persons to raise genuine concerns about wrongdoing in the public interest without fear of detriment, retaliation, or victimisation.

The purpose of this policy is to:

• Encourage individuals to report serious concerns at the earliest opportunity.
• Ensure concerns are handled confidentially, impartially, and promptly.
• Provide clear channels for disclosure and investigation.
• Protect individuals making protected disclosures under the Public Interest Disclosure Act (PIDA) 1998.
• Ensure compliance with OfS expectations for effective governance, safeguarding, academic integrity, and organisational accountability.

This Policy is not intended to address personal grievances, student complaints, or employment disputes; these are managed through separate procedures. However, concerns raised in good faith under this Policy will always be taken seriously, even if they are proven to be unfounded. Conversely, malicious or knowingly false allegations may be subject to disciplinary action.

2. Legal Framework

This Policy aligns with:

3. Scope

This Policy applies to:

• All academic and professional services staff (full-time, part-time, temporary, agency, visiting)
• Members of the Board of Governors and its committees
• External examiners and assessors
• Contractors and consultants
• Volunteers and individuals with visitor or honorary status
• Students (where reporting concerns in the public interest)

Types of Wrongdoing Covered

A qualifying whistleblowing disclosure should relate to one or more of the following:

• Criminal offences or suspected criminal activity
• Fraud, financial malpractice, or corruption
• Breaches of legal or regulatory obligations (including OfS or UKVI requirements)
• Miscarriage of justice
• Risks to health, safety, or the environment
• Abuse of authority or unethical behaviour
• Harassment, sexual misconduct, or safeguarding failures
• Attempted concealment of any of the above

This is not an exhaustive list but represents the type of concerns which may be raised. BIGIC is also required to comply with the Government’s prevent strategy (Please see our prevent policy for more information).

Personal grievances such as interpersonal disputes, dissatisfaction with decisions, or employment matters must be raised through the College’s Complaints, Grievance, or HR procedures, unless the matter is clearly in the public interest.

4. Definitions

5. Roles and Responsibilities

Designated Officers (Primary Contacts for Disclosures)

• Head of Governance & Regulatory Compliance
• Director of Human Resources
• Academic Registrar

Where there is a conflict of interest, concerns may be raised with:

• Accountable Officer (AO)
• Chair of the Board of Governors

If all internal avenues have conflicts, the concern may be raised with a prescribed external body, such as the Office for Students.

Board of Governors

• Ensures culture of openness, integrity, and accountability
• Receives anonymised summaries of cases
• Oversees the effectiveness of the policy

All Staff and Students

• Must raise concerns in a timely and responsible way
• Must cooperate with investigations

6. Protections and Assurances

Protection from Retaliation

No person raising a genuine concern in good faith will suffer dismissal, disadvantage, or victimisation. This includes protection from:

• Demotion
• Disciplinary sanctions
• Bullying or harassment
• Negative impact on academic or employment progression

Confidentiality

Where requested, confidentiality will be preserved as far as legally and practically possible. Identity may need to be disclosed:

• To the police or regulatory bodies
• Where required by law
• Where nondisclosure could pose a serious risk

Anonymous Disclosures

Anonymous disclosures are permitted but discouraged. Lack of contact information may limit the ability to conduct a full investigation or provide feedback.

Malicious Allegations

Knowingly false or vexatious allegations may result in disciplinary action.

7. External Disclosures

In most cases, concerns should be raised internally.

However, disclosures may be made externally where appropriate to:

• Office for Students (OfS)
• Police
• Health & Safety Executive
• UKVI
• Information Commissioner’s Office (ICO)
• Funding agencies or awarding bodies
• The whistleblowing charity Protect (independent advice)

Media or social media disclosures are almost never appropriate and may not qualify for PIDA protection.

8. Procedure for Raising a Concern

Step 1 – Raising the Concern

Concerns should be raised with a Designated Officer.

They may be made:

• In writing (preferred)
• In person
• Via secure email

The complainant should provide:

• Description of the concern
• Evidence or information available
• Names of individuals involved
• Whether confidentiality is requested

Step 2 – Initial Review

The Designated Officer will:

1. Determine whether the matter falls under the Whistleblowing Policy.
2. Decide if immediate safeguarding or regulatory notification is required.
3. Inform the complainant of the outcome of the initial review.

Step 3 – Investigation

If accepted under this Policy, the Designated Officer will appoint an independent investigator. The investigator will:

• Establish facts
• Interview relevant parties
• Review documentation and evidence
• Produce a formal investigation report

The subject(s) of the concern will be given an opportunity to respond.

Step 4 – Outcomes

Possible outcomes include:

• No case to answer
• Disciplinary or HR action
• Referral to internal committees
• Report to OfS, UKVI, ICO, Police or other statutory bodies
• Referral under the Reportable Events Policy

Step 5 – Feedback to Whistleblower

The whistleblower will receive confirmation that the matter has been addressed, but detailed outcomes may not be shared where confidentiality applies.

9. Appeals

If the whistleblower believes due process has not been followed, an appeal may be submitted in writing to:

The Chair of the Board of Governors within 14 calendar days of the decision.

The appeal will review procedural fairness only.

10. Communication of the Policy

• Included in staff induction and training
• Included in student handbooks
• Available on the College intranet
• Annual refresher training for senior staff and Governors
• Reinforced through compliance reviews and HR processes

11. Monitoring and Review

• Oversight provided by the Audit & Risk Committee
• Annual review of:
  • Number of disclosures
  • Themes or patterns
  • Time taken to resolve cases
  • Lessons learned
• Full policy review every 2 years or earlier if required by legislation or OfS guidance
• Governance Office maintains secure records of disclosures for 6 years

12. Associated Policies

• Complaints Policy
• Student and Staff Disciplinary Procedures
• Anti-Bribery and Corruption Policy
• Prevent Duty Policy
• Safeguarding and Sexual Misconduct Policy (OfS E6)
• Reportable Events Policy
• Conflict of Interest Policy
• Data Protection Policy

13. Contact Information

14. Document Control