External Whistleblowing Policy

1. Purpose

Dynamic Training Ltd is committed to operating with integrity, transparency, and accountability. This policy enables staff, learners, contractors, and other stakeholders to raise genuine concerns about wrongdoing or risks that may harm individuals, the organisation, or the public interest. The Board of Governors supports a culture of openness and ensures that whistleblowing concerns are handled fairly, independently, and in accordance with legal and regulatory expectations.

The purpose of this policy is to:

Encourage the reporting of concerns without fear of reprisal.

Ensure that disclosures are handled appropriately, consistently, and in line with the law.

Protect those who raise concerns from victimisation or disadvantage.

Ensure that the organisation meets its safeguarding, regulatory, and ethical obligations as an education and training provider.

2. Scope

This policy applies to:

All Dynamic Training Ltd employees (full-time, part-time, or temporary).

Apprentices, learners, volunteers, contractors, consultants, and associates.

Members of the governing body or trustees.

It covers concerns relating to wrongdoing, misconduct, safeguarding failures, or unethical behaviour within Dynamic Training Ltd or by those acting on its behalf.

3. Definition of Whistleblowing

Under the Public Interest Disclosure Act 1998 (PIDA), a “protected disclosure” is a disclosure of information that the whistleblower reasonably believes shows that one or more of the following has occurred, is occurring, or is likely to occur:

A criminal offence.

A failure to comply with a legal obligation.

A miscarriage of justice.

A danger to the health or safety of any individual.

Damage to the environment.

Deliberate concealment of information about any of the above.

A disclosure must be made in the public interest. It should not be confused with personal grievances, which are handled under the Grievance Policy.

4. Legal and Regulatory Context

This policy aligns with:

The Public Interest Disclosure Act 1998 (PIDA) and Part IVA of the Employment Rights Act 1996.

The Education and Skills Funding Agency (ESFA) and Department for Education (DfE) guidance on whistleblowing.

The Safeguarding and Prevent duties applicable to education and training providers.

The Health and Safety at Work Act 1974, Equality Act 2010, and Bribery Act 2010.

Dynamic Training Ltd recognises its duty to respond appropriately to any concerns raised under these frameworks.

5. Relationship to Other Policies

This policy should be read alongside:

Safeguarding and Prevent policy and/or Staff Wellbeing and Safeguarding Policy and Procedures – for concerns involving staff or learner wellbeing, safety, or safeguarding risks. Health and Safety Policy. Equality, Diversity and Inclusion Policy. Complaints Policy. Grievance and Disciplinary Procedures. Finance and Fraud Policy. Data Protection and Confidentiality Policy

Where concerns overlap (for example, a safeguarding or wellbeing issue that also raises organisational misconduct), both the Whistleblowing and Safeguarding policies will apply, and the Managing Director (as both DSL and Whistleblowing Lead) will determine the most appropriate response pathway.

6. Policy Statement

Dynamic Training Ltd encourages a culture of openness, accountability, and fairness.

Anyone raising a concern in good faith under this policy will be supported and protected. The organisation will not tolerate victimisation, dismissal, or any form of reprisal against those who make a protected disclosure, even if their concern is not upheld.

All disclosures will be treated seriously, investigated promptly, and handled with sensitivity and confidentiality.

7. Principles

Concerns should be raised at the earliest opportunity.

Individuals will not be disadvantaged or dismissed for raising a genuine concern.

Malicious or knowingly false allegations will be treated as a disciplinary matter.

Confidentiality will be maintained wherever possible.

Investigations will be objective, fair, and timely.

Where a concern involves wellbeing or safeguarding, it will be managed in partnership with the Safeguarding and Prevent policy and procedure and/or Staff Wellbeing and Safeguarding Policy and Procedures.

8. Examples of Concerns That Should Be Reported

Safeguarding failures or abuse of learners or staff.

Health and safety risks or unsafe practices.

Financial malpractice, fraud, or corruption.

Breach of legal, regulatory, or awarding-body obligations.

Misuse of organisational funds or resources.

Discrimination, harassment, or bullying.

Serious mismanagement or unethical behaviour.

Covering up wrongdoing.

9. How to Raise a Concern

Step 1 – Internal Reporting

Concerns should be raised, preferably in writing, with one of the following:

Managing Director (Whistleblowing Lead & Designated Safeguarding Lead)

HR Director (for matters relating to employment, wellbeing, or conflict of interest)

If the concern involves or implicates senior management, or if the individual reasonably believes that it cannot be raised internally with the Managing Director or HR Director, it may be escalated directly to the Chair of Governors.

Concerns for the Chair of Governors should be submitted via the “Contact a Governor” button on the Dynamic Training Ltd website. Submissions made via this route are received through the organisation’s central email system and are immediately redirected to the Chair of Governors (or a designated alternate Governor where appropriate).

Access to these messages is restricted, and they are handled in accordance with strict confidentiality and data protection requirements.

 Concerns may also be raised anonymously, though this may limit the organisation’s ability to investigate.

Step 2 – Information to Provide

When raising a concern, include:

The nature of the concern and background information.

Dates, times, and individuals involved (if known).

Why you believe it to be true.

Any evidence available.

Whether the concern has been raised elsewhere.

Step 3 – Initial Response

Acknowledgement of the concern will normally be given within 5 working days.

An initial assessment will determine whether the concern falls under whistleblowing or another policy (e.g. safeguarding or grievance).

If urgent action is required (e.g. risk to safety or welfare), this will be taken immediately.

Step 4 – Investigation

An impartial Investigating Officer will be appointed where appropriate.

The investigation may include document review, interviews, and liaison with relevant parties.

Interim measures may be implemented to manage any risks identified.

Step 5 – Outcome

The outcome will be communicated to the whistleblower (if known), within the limits of confidentiality.

Where wrongdoing is confirmed, appropriate corrective or disciplinary action will be taken.

Where necessary, matters will be reported to external bodies such as the police, ESFA, or DfE.

10. Confidentiality and Protection

Dynamic Training Ltd will make every effort to protect the identity of the whistleblower.

Retaliation or victimisation of anyone raising a genuine concern is strictly prohibited.

Any such behaviour will be treated as a disciplinary offence.

11. External Disclosures (Prescribed Persons)

If a concern cannot be raised internally or has not been handled properly, disclosures can be made to “prescribed persons,” including:

Department for Education (DfE)

Education and Skills Funding Agency (ESFA)

Ofsted

Health and Safety Executive (HSE)

Protect (formerly Public Concern at Work) – for free, confidential advice: www.protect-advice.org.uk

Disclosures to external regulators must be made in the public interest and in good faith to remain protected under the law.

12. Support and Wellbeing

Raising a concern can be stressful. Dynamic Training Ltd will offer support through:

HR-led wellbeing check-ins.

Referral to confidential advice services via Simplyhealth.

Access to the Staff Wellbeing and Safeguarding Policy and Procedures, which sets out how the organisation supports staff wellbeing and safety.

13. Monitoring and Review

The Managing Director will maintain a confidential record of all whistleblowing concerns, actions, and outcomes.

An anonymised report will be submitted annually to the Senior Leadership Team for oversight.

The Board of Governors (or Trustees) provides independent oversight of the whistleblowing process.

An anonymised summary of concerns and outcomes will be reviewed annually by the Board to ensure transparency, accountability, and organisational learning.

This policy will be reviewed annually or sooner if legislative, regulatory, or organisational changes occur.

14. Contact Details

Whistleblowing Lead & DSL Managing Director –

Claire.Gardner@dynamictraining.org.uk

HR Director- HR@dynamictraining.org.uk

External Advice - Protect (Independent Charity)    020 3117 2520 / www.protect-advice.org.uk

15. Quick Reference Flow

Concern identified → Report to MD/HR Director → Initial assessment → Investigation → Outcome → Feedback → Monitoring and review