Targeted Provision - Whistleblowing Policy

Created by
Last updated: 3 April 2026, 15:23

Policy owner

Head of People

Last updated

4 March 2026

Next update due

4 September 2026

1. Definitions

The Public Interest Disclosure Act 1998 provides statutory whistleblowing protection for employees and workers as defined by the Employment Rights Act 1996. Targeted Provision Ltd extends equivalent protection to all self-employed contractors engaged by it, as a matter of policy and as a condition of its contracts with commissioning Local Authorities. Any contractor who makes a protected disclosure in good faith will not have their engagement terminated or otherwise suffer detriment as a result of that disclosure. Targeted Provision Ltd is involved in the provision of education for young people, we also ensure we follow the HM Government’s guidelines laid out in the documentation Keeping Children Safe in Education 2025.

If someone discloses information about wrongdoing, the law protects that individual from being treated unfairly as a result of that disclosure. For employees and workers this includes protection against dismissal. For self-employed contractors engaged by Targeted Provision Ltd, this policy provides equivalent protection against termination of the contract for services or reduction in referral allocation as a direct result of a protected disclosure.

Targeted Provision Ltd takes the rights of all engagers extremely seriously. Any disclosure from someone engaging with Targeted Provision Ltd disclosing something about Targeted Provision Ltd qualifies for the aforementioned protection from the law.

A disclosure must be about something that affects the general public, such as, but not limited to:

  • a criminal offence has occurred

  • a criminal offence may occur imminently

  • the breach of a legal obligation

  • there has been a miscarriage of justice

  • the health or safety of any individual, has been endangered

  • environmental damage has occurred

  • information about any of the above disclosures that is being or had been concealed

Any expectations set out in this document apply to all individuals who deliver services through or work for Targeted Provision Ltd, regardless of employment status. They arise from Targeted Provision's statutory obligations under the Public Interest Disclosure Act 1998, Keeping Children Safe in Education 2025, and the terms of its contracts with commissioning Local Authorities — and not from any exercise of management direction or control over how individuals carry out their work. Compliance with this policy is a condition of working with Targeted Provision Ltd in any capacity and reflects the minimum standards required by law and by the nature of the work, rather than employer-imposed rules of conduct.

2. Whistleblowing should be seen as distinct to a complaint.

A complaint is when an employee, worker or contractor (or someone close to either of these parties) has been treated unfairly and that individual is seeking redress or justice themselves or the person close to them. Complaints of this nature should be dealt with in accordance with our Complaints Policy, which is sent to every employee, worker or contractor alongside this policy.

Self-employed contractors who have concerns about the commercial terms of their engagement or the allocation of referrals should refer to the dispute resolution provisions of their contract for services in the first instance, rather than to this policy or the Complaints Policy, unless the concern relates to a matter of public interest as defined in Section 1.

3. Aim of the policy

The aim of the policy is to:

  • Enable employees, workers and contractors to understand that they can raise any concerns or allegations in the strictest confidence and for a sensitive enquiry to take place

  • The steps we take to facilitate efficient and fair Whistleblowing at Targeted Provision Ltd

Targeted Provision Ltd takes its responsibility for ensuring that all employees, workers and contractors are aware of whistleblowing policy and procedures and what to do if they have something to report.

All employees, workers and contractors should know that they can raise any concerns to Senior Management, the Board or other individuals in the organisation no matter what the concerns are.

4. How do we facilitate efficient and fair Whistleblowing?

Whistleblowing can be done by a named employee, worker and contractor, or can be made anonymously. For advice on making an anonymous disclosure please contact Protect.

Targeted Provision Ltd takes false or misleading allegations seriously. For directly employed staff and workers, disciplinary proceedings will be considered where a disclosure is found to be knowingly false or misleading. For self-employed contractors, Targeted Provision Ltd reserves the right to terminate the contract for services where a disclosure is found to have been made knowingly falsely or with intent to mislead.

4.1. How we deal with Whistleblowing:

Employees, workers and contractors can share their concerns in writing or in person with any member of senior management or the board. If the concern involves a member of either the senior management or the board then the concern should be raised with an individual at this level of seniority to which the concern does not relate. Employees, workers and contractors should consider including as much detail as possible, including any written materials which support the allegations being made.

Every single concern raised will be logged and handled in the strictest confidence.

Employees, workers and contractors will be invited to an interview to discuss the allegation in more detail. The interview will aim to discuss the allegation is as much detail as possible, including who the allegation relates to, who is at risk, when the event(s) occurred.

The member of senior management or the board will then decide on the next course of action. The course of action will depend on the severity of the allegation and may involve reporting the allegation to external authorities. The course of action will likely follow one of the following:

  • an investigation by managers or internal audit, or through the disciplinary process (for employees and workers) or contract review process (for self-employed contractors)

  • an investigation under other procedures such as child/adult protection

  • an investigation under procedures designed to deal with allegations made against professionals (including possible referral to DBS/LADO)

  • a referral to the police

  • a referral to the external auditor or other external investigation

  • an investigation under other forms of prosecution and inspection such as the protection of public health and safety

  • a referral to an independent investigator

Any allegations involving the safety or wellbeing of young people will be acted upon immediately. Allegations not involving young people will be acted on within 2 working days.

Genuine concerns that require following whistleblowing procedures will be discussed by senior management and/or the board. If the concern involves a member of either the senior management or the board then this individual or individuals will not be part of these discussions.

The outcomes of any allegations raised by the whistleblower will be reported back to them, in writing, to their home address, within 14 days of the outcome the allegation(s) made.

Any concerns raised that fall outside the scope of this policy but fall under the procedures laid out in our other policies will be dealt with in the appropriate way laid out in the relevant policy documentation.

5. Who else can you turn to?

At Targeted Provision Ltd, we will do everything within our power to make sure disclosures are dealt with both fairly and promptly. However, should you feel that additional support be required, the following may be of use to you: