Whistleblowing

1. Purpose

We want people to speak up early when something is wrong. Whistleblowing means raising a concern about wrongdoing that affects others, such as risk to children, danger, fraud or a breach of the law. This policy explains what counts, how to raise a concern inside Care Cove, including a route outside the management line, which outside bodies you can go to, and how you are protected.

2. Scope

This policy applies to employees, agency staff from First Class Teachers, counsellors from My Solution Wellbeing, sessional and vocational tutors, volunteers, students on placement, members of the Social Work Management Committee (SWMC) and contractors. The law protects workers. We give volunteers and others the same protection as a matter of policy.

It covers concerns about Care Cove Alternative Provision and about partners, schools or other organisations connected with our work. It does not cover personal complaints about your own employment, such as pay or a dispute with a colleague. These go through our grievance procedure unless they also raise a wider public interest concern.

3. Law and guidance

• Public Interest Disclosure Act 1998, which added protection for whistleblowers to the Employment Rights Act 1996.

• Keeping Children Safe in Education 2026, which expects every setting to have whistleblowing procedures and staff to feel able to raise concerns about poor or unsafe practice.

• Bribery Act 2010 and Modern Slavery Act 2015.

• UK GDPR and the Data Protection Act 2018.

4. Roles and responsibilities

5. What counts as whistleblowing

The law protects you when you disclose information that you reasonably believe shows one or more of the following, and that you reasonably believe is in the public interest:

• a criminal offence, such as fraud, theft or bribery;

• a failure to meet a legal obligation;

• a miscarriage of justice;

• a danger to anyone's health or safety;

• damage to the environment;

• deliberate concealment of any of these.

You do not need proof, only a reasonable belief. Examples at Care Cove include:

• learners being put at risk by unsafe practice, such as ratios not being met or unvetted adults working unsupervised;

• records being falsified, including registers, attendance, safeguarding records, KPI data or invoices for days not delivered;

• misuse of money, or a bribe offered or requested;

• serious breaches of data protection;

• health and safety dangers on site, on visits or on transport;

• learners being given full-time education, which Care Cove is not registered to provide;

• discrimination, or signs of modern slavery in our supply chain;

• an incident or concern being covered up.

6. Safeguarding concerns

Concerns about children follow our safeguarding procedures first:

• If you are worried about a child, tell the Designated Safeguarding Lead immediately, as the Safeguarding and Child Protection policy sets out.

• If you are worried that an adult may have harmed a child, tell the Director the same day (or the SWMC Chair if it is about the Director), as the Managing Allegations Against Staff and Low-Level Concerns policy sets out.

Use this policy as well if you think a safeguarding concern is not being acted on or is being covered up, or if you are worried about our safeguarding practice more widely.

7. Raising a concern inside Care Cove

You can raise a concern with:

1. the Head of AP, or your line manager;

2. the Director;

3. the SWMC Chair. This is the independent route outside the management line. Use it if the concern involves the Director, the Head of AP or the DSL, or if you do not feel able to use the line.

You can raise a concern in person, by phone, by email or in writing. Say that you are raising a whistleblowing concern. Give as much detail as you can: what happened, when, where, who was involved and any evidence. Do not investigate yourself or collect evidence you are not entitled to see. You may bring a colleague or a trade union representative to any meeting about your concern.

8. Raising a concern outside Care Cove

We hope you will feel able to raise concerns with us. You may also go to an outside body, particularly if you think the matter is very serious, that Care Cove is involved, or that you will not be listened to. This policy authorises the routes below, so using them honestly is treated as raising the concern with us.

The law also protects disclosures to bodies listed by the government as "prescribed persons", such as Ofsted, the Information Commissioner and the Health and Safety Executive, where you reasonably believe the information is substantially true and falls within their remit. You can always seek confidential advice from a trade union or a legal adviser. Wider disclosures, for example to the media, are protected only in limited circumstances, so take advice first.

9. Protection from detriment

• The law protects workers who make a protected disclosure from dismissal and from any other detriment because of it. We give volunteers and others the same protection.

• Anyone who victimises, bullies or pressures a person for raising a concern will face disciplinary action. Colleagues can also be personally liable in law.

• No confidentiality clause or agreement can stop you making a protected disclosure.

• If you raise a concern honestly and it turns out to be mistaken, no action will be taken against you. Raising a concern you know to be false may lead to disciplinary action.

• If you think you are being treated badly because you raised a concern, tell the SWMC Chair straight away.

10. Confidentiality and anonymous concerns

We keep your identity confidential and share it only with those who need to know to investigate, unless you agree or the law requires otherwise, for example in a police investigation. If we need to share your identity, we will tell you first wherever possible.

You can raise a concern anonymously and we will consider it. Anonymous concerns are harder to investigate, and we cannot feed back to you. We look at how serious the concern is, whether it is credible and whether it can be checked from other sources. We encourage you to give your name in confidence instead.

11. How we investigate and feed back

1. Acknowledge. The person receiving the concern passes it to the Director the same day, or to the SWMC Chair if it involves the Director. You receive written acknowledgement within 3 working days and an offer to meet.

2. Assess. Any risk to a child is dealt with immediately under our safeguarding procedures. Within 10 working days, the Director (or the SWMC Chair) decides how the concern will be handled. This may be an internal investigation, an independent investigator, or referral to the police, the LADO, the commissioning local authority, the Information Commissioner or the Health and Safety Executive.

3. Investigate. The investigator is independent of the matter. Where the concern involves the Director, the SWMC Chair leads and may appoint an investigator from outside Care Cove. We aim to finish within 4 weeks, and will tell you if it will take longer and why.

4. Act. Where the concern is upheld, we put it right and take any disciplinary or other action needed. Allegations of misconduct affecting a learner are reported to the commissioning local authority's contract manager, with a report of the investigation and action taken. Any request for a bribe is reported to the commissioning local authority. The Director tells the contract manager about any upheld concern that affects delivery of the contract.

5. Feed back. You are told in writing what was done and the outcome, as far as the confidentiality of others allows.

6. Not satisfied? Raise it with the SWMC Chair, or use the outside routes in section 8.

12. Records

The Director keeps a confidential whistleblowing log in a restricted area of Care Cove Connect. It records the date, a summary of the concern, who handled it, the action taken, the outcome and the date of feedback. Access is limited to the Director and the SWMC Chair, and never includes anyone named in the concern. Records are kept in line with our retention schedule. The SWMC reviews the log every term and reviews every concern involving the Director.

13. Monitoring and review

The Director owns this policy and the Social Work Management Committee ratifies it. Staff are introduced to it at induction and in annual boundaries and low-level concerns training. The SWMC's termly review of the log, and the annual external safeguarding audit, test whether staff know how to speak up and whether concerns are dealt with properly. The policy is reviewed every year, or sooner after a concern, a change in law or guidance, or a change to our contracts.

14. Related policies

• 01 Safeguarding and Child Protection
• 03 Managing Allegations Against Staff and Low-Level Concerns
• 15 Health and Safety, including Fire and First Aid
• 17 Data Protection, Retention and Information Sharing
• 19 Complaints
• 21 Staff Code of Conduct
• 22 Anti-Bribery and Anti-Corruption
• 23 Modern Slavery and Ethical Sourcing
• 32 Disciplinary, Capability and Grievance
• 43 Dignity at Work and Preventing Sexual Harassment

Appendix A: Contacts

Checked October 2026, re-check termly.

Document control and ratification

This policy is signed off by the Designated Safeguarding Lead and the Head of Alternative Provision, and ratified by the Social Work Management Committee. It is reviewed every year, or sooner after an incident or a change in law, statutory guidance or contract requirements, and it is available to any commissioning local authority on request.