Whistleblowing and speaking up

Raise a concern. Be heard. Be protected.

Kent Business College encourages people to speak up about suspected wrongdoing, risk or concealment in the public interest. You do not need to prove the concern, use your line manager, or wait until harm has occurred.

Raise a confidential concern See every reporting route

For sensitive information, use a named confidential route below rather than the general website contact form.

Policy overview

Speaking up about wrongdoing in the public interest

This page explains what can be reported, who may report it, the available internal and external routes, and what KBC will do after a disclosure is received.

What is whistleblowing?

Whistleblowing is the disclosure of information that a person reasonably believes tends to show wrongdoing, risk or deliberate concealment and that is in the public interest. It can concern something that has happened, is happening, or is likely to happen.

Statutory protection depends on the facts and legal tests, including reasonable belief, a qualifying disclosure, public interest and the route used. KBC’s internal commitment not to retaliate is broader and applies to genuine concerns even when they are not substantiated.

You do not need to prove the concern. Do not hack, unlawfully access systems, secretly remove records or put yourself at risk to obtain evidence. Share information and documents already available to you lawfully.

What can be raised

Examples of reportable concerns

The examples below are not exhaustive. KBC considers the substance of the information, not the label used by the person reporting it.

Fraud and public funds

Fraud, theft, bribery, corruption, forgery, procurement manipulation or misuse of public money.

Funding and ILR manipulation

Deliberate manipulation of learner dates, eligibility, employment status, RPL, prices, off-the-job training, completion or payment evidence.

Fabricated or concealed evidence

Ghost learners, fabricated learning, false attendance, copied signatures, backdating or concealment of withdrawals and breaks.

Safeguarding and Prevent failure

Serious safeguarding or Prevent failures, unsafe practice, exploitation, harassment, abuse, discrimination or deliberate failure to act.

Assessment malpractice

Certification irregularity, assessment malpractice, plagiarism-control failure, hidden conflicts or compromised independence.

Data and cyber security

Serious personal-data or cyber-security breaches, incident concealment or unauthorised use of learner information.

Legal, safety or environmental harm

Criminal offences, legal or contractual breaches, danger to health and safety, environmental damage, miscarriage of justice or sexual harassment.

Concealment or retaliation

Deliberate concealment of wrongdoing or retaliation against a person who raised, supported or witnessed a concern.

Choosing the right route

Matters normally handled under another procedure

A mixed report may still contain a protected whistleblowing element. KBC will route each part according to its substance.

Personal employment issue onlyUse the Staff Grievance Policy unless the matter also alleges public-interest wrongdoing.

Learner or employer dissatisfactionUse the Learner, Apprentice and Employer Complaints process.

Immediate or possible learner harmUse the Safeguarding and Prevent procedure, with parallel whistleblowing action where concealment or systemic wrongdoing is alleged.

Assessment result challengeUse the relevant appeals or malpractice procedure.

Routine error openly identifiedUse normal compliance or error-management controls unless there is concealment, repeated failure or systemic misconduct.

Unsure which route applies?Send the information to the Whistleblowing Officer. KBC will route it without rejecting a protected element.

Internal reporting routes

Choose the safest and most independent route

A concern may be written, verbal, anonymous or raised through an advocate. You do not have to use your line manager or start with the lowest route.

Head of Compliance / Whistleblowing Officer

Nada.Ibrahim@kentbusinesscollege.com

Use this confidential route for any public-interest wrongdoing concern that does not involve the role holder.

Recommended email subject: Private and Confidential – Whistleblowing Disclosure

Senior alternative: Chief Executive

Amgad.Badewi@kentbusinesscollege.com

Use this route if the primary route is implicated, conflicted, unavailable, or you reasonably prefer an executive route.

You may go directly here. Prior use of another internal route is not required.

Governance route

Private and Confidential – Governance Board Chair
37–39 Maidstone Innovation Centre
Medical Campus
Maidstone, Kent, ME14 5FY

Use this route where the concern involves the Head of Compliance, Chief Executive, a director, or where independence cannot be secured internally.

Postal marking: Private and Confidential – To be opened by the Governance Board Chair only.

Safeguarding and Prevent route

safeguarding@kentbusinesscollege.com

Use for immediate learner-safety, abuse, exploitation or Prevent risk. Call 999 in an emergency.

The Whistleblowing Officer will also be informed where wrongdoing, concealment or systemic failure is alleged.

You may also tell any KBC staff member. They must preserve your original concern and pass it promptly to a non-conflicted authorised route. You may ask an advocate to raise the concern with or for you.

Making a disclosure

Tell us what you know, in your own words

A report is not rejected because it is incomplete, verbal, anonymous, has no documents attached, or does not use the word “whistleblowing”.

Where possible, include a safe way to contact you. This helps KBC acknowledge the concern, ask focused questions and provide appropriate updates.

Describe the concernExplain what happened or may happen and why you believe it may involve wrongdoing, risk or concealment in the public interest.
Identify relevant detailsInclude people, dates, systems, learners, programmes, employers, places or records where known.
Explain how you became awareState how the information became known to you and whether the risk or conduct is continuing.
Flag immediate riskIdentify danger, safeguarding, fraud, data loss, cyber risk, retaliation or possible destruction of evidence.
Share available evidence lawfullyProvide documents or information already available to you without hacking, unlawfully accessing, copying or removing records.
State your communication needsGive safe contact details, confidentiality or anonymity needs, accessibility requirements and any fear of retaliation.

What happens next

A controlled, independent and evidence-based process

Timescales are targets for ordinary cases. Immediate risk is acted on at once; complex, safeguarding, police, DfE, legal or data-recovery cases may take longer, with reasons and appropriate updates provided.

1
Receive and preserve

The original wording, channel, date and attachments are preserved and assigned a restricted case reference.
On receipt
2
Immediate risk check

KBC checks safeguarding, fraud, criminal, cyber, data, retaliation and evidence-destruction risk.
Same working day where urgent
3
Acknowledge

Where contact details are available, KBC confirms the handler, next step, confidentiality limits and support.
Within 2 working days
4
Triage and protect

KBC determines urgency, route, independence, reporting duties, scope and proportionate interim safeguards.
Normally within 5 working days
5
Independent investigation

A competent, non-conflicted investigator preserves evidence, interviews fairly and produces reasoned findings.
Ordinary aim: 30 working days
6
Outcome and review

Appropriate closure information is provided. A procedural review may be requested after the decision.
Review request: within 10 working days

During an open investigation, the reporting person receives an appropriate update at least every ten working days, subject to safety, confidentiality, data-protection and fair-process limits.

Protection and confidentiality

Speaking up must not lead to disadvantage

KBC separates the reporting person’s protection needs from the investigation and acts promptly on any allegation of retaliation.

Protection from retaliation

Dismissal, threats, harassment, ostracism, reduced hours or pay, adverse work allocation, denied training, blocked progression, a negative reference, pressure to withdraw, evidence interference or any other disadvantage because someone spoke up are prohibited.

A protection plan may cover safe contact, work risk, support and monitoring.
Managers must not intimidate or disadvantage the reporting person or witnesses.
Any alleged detriment is logged, triaged and investigated separately.

Confidential and anonymous reporting

Identity and case information are restricted to people who need them for receipt, protection, investigation, advice or mandatory reporting. Case references and pseudonyms are used where appropriate.

Anonymous reports are assessed by seriousness, specificity, credibility, continuing risk and ability to investigate fairly.
Absolute secrecy cannot be promised where disclosure is required by law, safeguarding need, fair process, court order or regulatory duty.
Where identity may need to be disclosed, KBC normally explains why and discusses protective steps first, unless unsafe or prohibited.

An unsubstantiated concern does not establish malice. A knowingly false allegation may be considered under a separate fair process, but lack of evidence or a finding that the concern is not substantiated does not by itself justify action against the reporting person.

External disclosure and independent advice

You may be entitled to report outside KBC

You do not always have to use KBC’s internal process first. KBC will not retaliate because a lawful external route is used. Independent advice is recommended where you are unsure about legal protection or the correct prescribed body.

Department for Education

Official guidance and reporting routes for whistleblowing disclosures about academies and post-16 providers.

Open DfE whistleblowing guidance

DfE fraud and financial irregularity

Report suspected deception, funding-rule breaches or education and training that was claimed but not delivered.

Open the official fraud route

Protect

Free, confidential and independent whistleblowing advice about options, legal protection and retaliation.

Visit Protect

Acas

Current guidance on what whistleblowing is, legal protection, making a disclosure and workplace detriment.

Read Acas guidance

Prescribed people and bodies

Use the current GOV.UK list to identify the regulator or official body responsible for the subject of the disclosure.

View the current list

Police or emergency services

Call 999 where there is immediate danger. Criminal concerns may also require an appropriate police report.

Call 999 in an emergency

Information Commissioner’s Office Health and Safety Executive Ofqual concerns and malpractice GOV.UK whistleblowing overview

Policy operation and governance

How KBC maintains an effective speaking-up system

The full controlled policy includes case records, triage and conflict controls, evidence preservation, investigation standards, governance reporting, staff training and operating templates.

Independence and conflicts of interest

Recipients, investigators, advisers, decision-makers and reviewers must declare actual, potential and perceived conflicts. A person named in or materially connected with a disclosure cannot control the case. External legal, forensic, safeguarding, HR, funding or quality expertise is appointed where internal independence or competence is insufficient.

Evidence, findings and possible outcomes

KBC lawfully preserves and reviews relevant records, assesses authenticity and alternative explanations, interviews relevant people fairly, and makes internal findings on the balance of probabilities or records the case as inconclusive. Outcomes may include learner protection, data correction, repayment, regulatory notification, disciplinary or contractual action, independent audit, policy or system change, training and effectiveness testing.

Review of the outcome

A review may be requested within ten working days where there is alleged procedural unfairness, conflict, material evidence omission, an unreasonable finding or an unimplemented remedy. The reviewer must be independent of the original decision and may uphold or vary the decision, require further investigation or appoint an external review.

Records, data protection and retention

Whistleblowing files are held in restricted storage, separate from ordinary HR, complaints and learner records. The central register uses the minimum necessary information, routine governance reporting is anonymised, evidence handling is logged where appropriate, and retention follows KBC’s approved schedule, legal advice and regulatory requirements. A legal hold overrides routine disposal.

Training, monitoring and governance assurance

Staff receive policy awareness at induction and annually. Managers and relevant HR, Compliance, Safeguarding, Finance, MIS, IT and governance personnel receive role-specific training. KBC tests its reporting routes and case-handling process at least annually through a documented simulation or case review and reports anonymised performance information to governance.

Policy codeHR12

Current version2.1 – Approved consolidated revision

Effective date1 July 2026

Review date30 June 2027, or earlier after material change

Document ownerHead of Compliance / Whistleblowing Officer

ApprovalGovernance Board, Chief Executive and Compliance Director

ProviderKent Business College Ltd · Company No. 10367575 · UKPRN 10093689

Operational and correspondence address37–39 Maidstone Innovation Centre, Medical Campus, Maidstone, Kent, ME14 5FY

Ready to speak up?

Choose the route that feels safe and independent.

You may report directly to the Whistleblowing Officer, use the senior or governance alternative, speak to any KBC staff member, or use a lawful external route. Do not delay an emergency, safeguarding concern or serious risk while deciding which process applies.

Email the Whistleblowing Officer Compare reporting routes DfE external route

This webpage is a public-facing explanation of KBC Policy HR12 Version 2.1. The controlled electronic policy, approval evidence and version history determine the operative version. Printed copies are uncontrolled.