• Purpose

    OTM Apprenticeships is committed to maintaining the highest standards of integrity, openness and accountability. We encourage all employees, associates, apprentices, contractors and other individuals working with or on behalf of OTM Apprenticeships to raise genuine concerns where they believe there is evidence of wrongdoing, malpractice, illegal activity or risks to the health, safety or welfare of others.

    This policy provides a clear and confidential process for reporting concerns in the public interest and ensures that individuals who raise concerns honestly and reasonably are protected from victimisation or detriment in accordance with the Public Interest Disclosure Act 1998 (PIDA) and the Employment Rights Act 1996.

    Scope

    This policy applies to all employees, contractors, associates, apprentices, volunteers and any individual working on behalf of OTM Apprenticeships.

    The policy covers concerns relating to activities undertaken by OTM Apprenticeships, including:

    • Criminal offences.
    • Fraud, bribery or financial malpractice.
    • Failure to comply with legal or regulatory requirements.
    • Safeguarding concerns.
    • Health and safety risks.
    • Environmental damage.
    • Malpractice or maladministration.
    • Serious breaches of organisational policies.
    • Deliberate concealment of any of the above.

    This policy does not apply to personal employment matters, grievances or complaints, which should be managed through the appropriate Grievance or Complaints Policy.

    Principles

    • OTM Apprenticeships will:
    • Promote an open and honest culture where concerns can be raised without fear.
    • Treat all disclosures seriously, fairly and confidentially.
    • Investigate concerns promptly and impartially.
    • Protect individuals making genuine disclosures from victimisation or detrimental treatment.
    • Maintain confidentiality wherever reasonably possible.
    • Comply with relevant legislation and regulatory requirements.
    • Use learning from whistleblowing concerns to improve organisational practice.

    Roles and Responsibilities

    The Managing Director/Designated Safeguarding Officer has overall responsibility for ensuring this policy is implemented effectively and that whistleblowing concerns are investigated appropriately and is responsible for:

     

    • Receiving and managing whistleblowing concerns.
    • Appointing an impartial investigator where appropriate.
    • Maintaining confidential records.
    • Liaising with external agencies or regulators where required.
    • Monitoring trends and identifying opportunities for improvement.

    Senior Managers are responsible for:

    • Creating an environment where staff feel confident to raise concerns.
    • Reporting concerns promptly.
    • Cooperating with investigations.
    • Maintaining confidentiality throughout the process.

    Employees and Other Workers:

    All employees and individuals working on behalf of OTM Apprenticeships are responsible for:

    • Raising genuine concerns as soon as reasonably practicable.
    • Providing accurate information to support an investigation.
    • Maintaining confidentiality throughout the process.
    • Acting honestly and in the public interest.
    • Reporting a Concern

    Concerns should normally be reported to the individual’s line manager or the Designated Safeguarding Lead . Where the concern involves either of these individuals, or the individual feels unable to raise the matter internally, concerns should be reported directly to the Managing Director.

    A whistleblowing disclosure may be made verbally or in writing and should include, where possible:

    • The nature of the concern.
    • Relevant dates, locations or individuals involved.
    • Any supporting evidence available.
    • Details of any previous action taken.

    Individuals are not expected to investigate concerns themselves but should have a reasonable belief that the information disclosed is true and made in the public interest.

    Where appropriate, concerns may also be reported to the relevant regulator or prescribed body in accordance with the Public Interest Disclosure Act 1998.

    Investigation and Outcome

    All whistleblowing concerns will be acknowledged promptly and assessed to determine the most appropriate course of action.

    Investigations will be conducted fairly, proportionately and confidentially by an appropriately appointed individual who has not been directly involved in the matter where possible.

     

    Following the investigation, OTM Apprenticeships may:

    • Take no further action where concerns are not substantiated.
    • Implement corrective or preventative actions.
    • Refer matters to the disciplinary process.
    • Notify the appropriate regulatory authority, awarding organisation or external agency.
    • Refer matters to the police or other statutory authorities where necessary.

    The individual raising the concern will normally be informed when the investigation has concluded, although confidentiality may limit the information that can be shared.

    Protection of Whistleblowers

    OTM Apprenticeships will not tolerate victimisation, harassment or detrimental treatment of any individual who raises a genuine concern under this policy.

    Individuals making disclosures in good faith will be supported throughout the process, even where the concern is not ultimately substantiated.

    Knowingly making false, malicious or vexatious allegations may result in disciplinary action.

    Appeals

    Where an individual believes that a whistleblowing concern has not been managed appropriately, they may request that the matter is reviewed by the Managing Director or another senior manager who has had no previous involvement.

    Where appropriate, individuals may also raise concerns directly with a prescribed external body in accordance with current whistleblowing legislation.

    Records, Confidentiality and Data Protection

    OTM Apprenticeships will maintain secure records of all whistleblowing concerns, investigations and outcomes.

    Information will be processed in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the OTM Apprenticeships Data Protection Policy.

    Information will only be shared where there is a legitimate legal, regulatory or safeguarding requirement to do so.

    Monitoring and Review

    The Managing Director/Designated Safeguarding Officer will monitor whistleblowing concerns to identify trends, ensure appropriate action is taken and support continuous improvement.

    This policy will be reviewed annually, or sooner where there are changes to legislation, regulatory requirements or organisational practice.

    Lessons learned from whistleblowing investigations will be used to strengthen governance, quality assurance, safeguarding and organisational compliance.