Division of General Counsel, Governance and Compliance

Public Interest Disclosure Policy & Raising Concerns

Public Interest Disclosure and Raising Concerns about the University

The University believes that staff should feel empowered to raise specific types of serious concerns in good faith, without fear of receiving detrimental treatment as a result; the right to do so is also set out in law. If you are a staff member with a serious concern, please refer to the University's Public Interest Disclosure Policy below; if your concern falls within the scope of the policy, you can use the Raising Concerns process and reporting form below to report it. For concerns falling outside the scope of the policy, please refer to 'Reporting Other Concerns' below.

Raising Concerns Process

Scope of the Raising Concerns process

1.1 The Raising Concerns process should be used to report serious concerns raised about specific types of matters known as ‘protected disclosures’ or ‘qualifying disclosures’, namely where a worker reasonably believes that one of the following has occurred or is occurring:

  • the committing of a criminal offence (e.g. fraud);
  • failure to comply with a legal obligation;
  • a miscarriage of justice;
  • a serious threat to the health or safety of any individual;
  • damage to the environment; or
  • deliberate concealment of any of the above matters.

1.2 The Raising Concerns process should be used only by staff (or ‘workers,’ as outlined in the Public Interest Disclosure Policy) and should only be used in relation to the types of matters laid out in part 1.1 above. This is because of the specific protection afforded to workers in law in relation to these particular types of concerns.

1.3 Staff wishing to raise concerns that do not fall within the scope of paragraph 1.1 should use the relevant internal University procedure(s) instead and other processes will also be signposted at the end of the policy for students or members of the public wishing to raise concerns about the University.

1.4 A worker who raises, in good faith, a genuine serious concern in the public interest relating to any of the types of matters laid out in part 1.1 above is also known as a ‘whistleblower’.

Raising a Concern

2.1 All concerns falling within the Raising Concerns process should be submitted via the online reporting form or directly by email to the Information Manager.

2.2 Any concern raised will be considered by the Information Manager in the first instance to ensure that it is a qualifying disclosure and that it is appropriate for the concern to continue to be dealt with via this process; if this is not the case, the Information Manager will contact the whistleblower to confirm.

Investigation and Outcome

3.1 In all cases where the concern is confirmed to be a qualifying disclosure, the Information Manager will acknowledge its receipt and keep a record of action taken. No further action is required by the whistleblower unless it is considered necessary as part of the investigation. N.B. The whistleblower may not necessarily receive further information about any investigation or the outcome.

3.2 If the concern requires investigation, the Information Manager will assess the nature of the concern to determine the appropriate route for escalation.

3.3 Usually most cases will be referred to the Chief Operating Officer, Director of Finance (e.g. if the concern relates to potential fraud, the Director of Finance will carry out an investigation according to the Fraud Response Plan), or General Counsel. If the concern relates to the individual who would normally investigate such types of cases, it will be referred to another appopriately senior/qualified individual at the University accordingly.

3.4 The Chief Operating Officer, Director of Finance, of General Counsel may also appoint another appropriate person to undertake the investigation on their behalf, depending on the requirements of the investigation.

3.5 Upon the conclusion of an investigation, the investigator(s) will decide what, if any, further actions are required and will report the outcome to the Information Manager. As noted in 3.1 above, the whistleblower may not necessarily be informed of the outcome.

3.6 The Information Manager will report to University Executive Group regarding the nature of reports received and the outcome of any investigations, where applicable (i.e. if the concern is eligible for consideration under this procedure).

3.7 If the University concludes that a person has made malicious allegations, in bad faith or with a view to personal gain, that person may be subject to the University’s disciplinary processes.

3.8 While the University cannot always guarantee the outcome the whistleblower is seeking, the University will deal with the concern fairly and in an appropriate way.

Contacts

4.1 Queries about the Raising Concerns process can be directed to the Information Manager.

4.2 Contact details for the individuals mentioned in the procedure, as well as Protect, the Whistleblowing Charity, are as follows:

Reporting Other Concerns

5.1 There are a number of other procedures at the University which exist to deal with other types of matters falling outside the scope of this procedure and the Public Interest Disclosure Policy:

*This page also includes information about applicant complaints