| Author: | Chief Finance and Operations Officer |
|---|---|
| Consultation: | TSCG Audit Committee |
| Approval: | TSCG Board of the Corporation |
| Version Date: | June 2026 |
| Approved Date: | July 2026 |
| Next Review: | June 2027 |
Trafford and Stockport College Group (TSCG) is committed to operating with integrity, openness and accountability. This Policy and Procedure provides a clear framework for workers and associated persons to raise concerns in the public interest about suspected wrongdoing at the earliest opportunity.
This includes (but is not limited to) concerns relating to:
This Policy forms a key part of TSCG’s arrangements to identify, prevent and respond to economic crime and other serious wrongdoing, and to support a culture in which individuals feel confident to speak up without fear of detriment.
TSCG recognises that effective whistleblowing arrangements are fundamental to maintaining strong governance, safeguarding public funds, and meeting its legal and regulatory responsibilities.
This Policy forms part of the Group’s reasonable and proportionate procedures to prevent bribery, failure to prevent fraud and the facilitation of tax evasion. It should be read alongside the Prevention of Economic Crime Policy, Financial Regulations, procurement procedures, Gifts and Hospitality requirements and Conflicts of Interest requirements.
TSCG is committed to:
Concerns may relate to actual, suspected or attempted wrongdoing and do not need to be proven at the point of disclosure.
This Policy applies to all workers including employees, officers, consultants, contractors, volunteers, agency staff and casual workers.
It also applies to:
References to “workers” within this policy should be read to include, where appropriate, these associated persons.
The law protects workers who, out of a sense of public duty, want to reveal suspected wrongdoing or malpractice.
The law allows workers to raise what it defines as a ‘protected disclosure’. In order to be a protected disclosure, a disclosure must relate to a specific subject matter (See Specific Subject Matter) and the disclosure must also be made in an appropriate way (See Section 3). A ‘protected disclosure’ must, in the reasonable belief of the worker making it, also be made in the public interest. A protected disclosure must consist of information and not merely be allegations of suspected malpractice.
A disclosure may relate to (but is not limited to):
This list is illustrative and not exhaustive.
| Signed: |  Principal & Chief Executive Officer: James Scott |
|---|---|
| Signed: |  Chairperson of the Board of the Corporation: Graham Luccock |
| Date: | 15 July 2026 |
Workers are encouraged to raise concerns through one of the following routes:
Individuals may choose whichever route they consider most appropriate in the circumstances.
Workers are encouraged to identify themselves when making a disclosure but workers are also permitted to make disclosures anonymously. If an anonymous disclosure is made, TSCG will not be able to notify the individual making the disclosure of the outcome of action taken by TSCG. Anonymity also means that TSCG may have difficulty in investigating such a concern. TSCG reserves the right to determine whether to apply this procedure in respect of an anonymised disclosure in light of the following considerations:
For further guidance in relation to this Policy and Procedure, or concerning the use of the disclosure procedure generally, employees should speak in confidence to the Chief Finance and Operations Officer.
When a worker makes a disclosure, TSCG will acknowledge its receipt, in writing, within 5 working days.
Prior to commencing any investigation:
TSCG will undertake an initial assessment of the concern raised to determine whether it falls within the scope of this Whistleblowing Policy and what form of investigation, if any, is required. The whistleblower will be informed of the outcome of this assessment. Where it is determined that the concern would be more appropriately addressed under an alternative policy or procedure (for example, the Grievance Policy), the investigating officer will explain this to the whistleblower and advise them of the next steps and any action being taken.
Upon receipt of a disclosure, TSCG will undertake a documented triage assessment within 2 working days to determine the appropriate handling route.
Disclosures will be classified as one or more of the following:
Once a disclosure is received, all relevant records must be preserved. This may include emails, financial records, procurement documentation, payroll data, learner/funding records, system logs and other relevant evidence.
Individuals must not delete, amend or interfere with potential evidence.
Appropriate escalation will be applied depending on the classification, including referral to the Audit Committee, Internal Auditors or external bodies where required.
Where a disclosure relates to financial irregularity, procurement, or senior individuals, independent or externally supported investigation will be considered.
TSCG will determine the appropriate action to take (including action under any other applicable TSCG policy or procedure). Possible actions could include internal investigation; referral to TSCG’s auditors; or referral to relevant external bodies such as the Department for Education, Police, Ofsted, Health and Safety Executive or the Information Commissioner’s Office.
If appropriate, any internal investigation will be conducted by a manager of TSCG without any direct association with the individual to whom the disclosure relates, or by an external investigator appointed by TSCG as appropriate. In some cases, TSCG may appoint a team of investigators including employees with relevant experience of investigations or specialist knowledge of the subject matter.
Any recommendations for further action made by TSCG will be addressed to the Chief Executive and/or Chair of the Corporation as appropriate in the circumstances. The recipient will take all steps within their power to ensure the recommendations are implemented unless there are good reasons for not doing so.
The worker making the disclosure will usually be notified of the outcome of any action taken by TSCG under this Policy and Procedure within 10 working days. However, sometimes the need for confidentiality may prevent TSCG giving the worker specific details of the investigation, or any disciplinary action taken as a result. Workers should treat any information about the investigation as confidential.
If the worker is not satisfied that their concern, has been appropriately addressed, they can raise it with the Principal/Chief Executive within 5 working days. The Chief Executive will make a final decision on action to be taken and notify the worker making the disclosure.
There may be circumstances where TSCG concludes that the disclosure is without substance or merit, or it is not appropriate to carry out further investigations. This might apply where:
A worker making a disclosure under this procedure can expect their matter to be treated confidentially by TSCG and, where applicable, their name will not be disclosed to anyone implicated in the suspected wrongdoing, without their prior approval.
TSCG will take all reasonable steps to ensure that any report of recommendations, or other relevant documentation produced by TSCG does not identify the worker making the disclosure without their written consent, or unless TSCG is legally obliged to do so, or for the purposes of seeking legal advice.
No formal disciplinary action will be taken against a worker on the grounds of making a disclosure made under this Policy or Procedure. This does not prevent TSCG from bringing disciplinary action against a worker where TSCG has grounds to believe that a disclosure was made maliciously or vexatiously, or where a disclosure is made outside TSCG without reasonable grounds.
A worker will not suffer dismissal or any detrimental action or omission of any type (including informal pressure or any form of victimisation) by TSCG for making a disclosure in accordance with this Policy and Procedure. Equally, where a worker is threatened, bullied, pressurised or victimised by a colleague for making a disclosure, disciplinary action will be taken by TSCG against the colleague in question.
The aim of this Policy and Procedure is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases workers should not find it necessary to alert anyone externally.
The law recognises that in some circumstances it may be appropriate for workers to report concerns to an external body such as a regulator. It will very rarely if ever be appropriate to alert the media. TSCG strongly encourages workers to seek advice before reporting a concern to anyone external. The independent whistleblowing charity, Protect (formerly Public Concern at Work), operates a free confidential helpline to any individual who is unsure whether to raise an issue under this policy, or who needs advice as to how to do it.
Workers may make a disclosure to an appropriate external body prescribed by the law. This list of ‘prescribed’ organisations and bodies can be found in information on the GOV.UK website.
Any protected disclosures made by ex-employees or workers after the termination of their employment should also be dealt with under this Policy and Procedure. In such cases, we normally ask that the employee/worker sets out the details of their concerns in writing, and we will then respond in writing, having undertaken such investigations as we deem to be appropriate.
TSCG will maintain a confidential whistleblowing register recording all disclosures, including their nature, outcome and actions taken.
Whistleblowing activity will be reported at least annually (with a verbal update at each committee meeting) to the Audit Committee and will include trend analysis, thematic risks and any significant control issues.
Serious allegations relating to economic crime or governance will be notified promptly to the Chair of the Audit Committee.
The effectiveness of this Policy will be reviewed annually by the Board.
TSCG will ensure that:
This ensures that individuals understand how and when to raise concerns.
When an individual makes a disclosure, TSCG will process any personal data collected in accordance with its Data Protection Policy collected from the point at which the individual makes the report is held securely and accessed by, and disclosed to, individuals only for the purposes of dealing with the disclosure.
TSCG will not tolerate any harassment or victimisation of workers who make disclosures. If, at any stage of this procedure a worker feels that they are being subject to informal pressures, bullying or harassment due to making a disclosure, they should raise this matter, in writing, to Principal/Chief Executive.
Workers must not threaten or retaliate against whistle-blowers in any way and staff that are found to be involved in such conduct you may be subject to disciplinary action. In some cases, the whistle-blower could have a right to a member of staff personally for compensation in an employment tribunal.
A worker making a disclosure may want to confidentially request counselling or other support from TSCG’s Employee Assistance Programme. Any such request for counselling or support services should be addressed to the Director of Human Resources and Performance. Requests will be treated in confidence.
Workers can also contact the charity Protect (formerly Public Concern at Work) for confidential advice on whistleblowing issues. Contact details are as follows:
3rd Floor, Bank Chambers, 6 – 10 Borough High Street, London SE1 9Q Whistleblowing Advice Line: 020 7404 609 http://www.pcaw.org.uk
The NSPCC’s “What you can do to Report Abuse” dedicated helpline (Whistleblowing AdviceLine | NSPCC) is also available as an alternative route for colleagues who do not feel able to raise concerns regarding child protection failures internally, or have concerns about the way a concern is being handled by TSCG. Colleagues can call 0800 028 0285 – line is available from 8:00 AM to 8:00 PM, Monday to Friday and email: help@nspcc.org.uk.
