Targeted Provision - Whistleblowing Policy

1. Purpose, scope and protection

This policy explains how to raise a concern about wrongdoing at Targeted Provision Ltd, how we will deal with it, and how you are protected. As we provide education for children and young people, we also follow Keeping Children Safe in Education 2026, which expects everyone working with children to be able to raise concerns about poor or unsafe practice.

The policy applies to:

• employees: people employed by Targeted Provision;

• workers: people engaged under a worker contract who are not employees; and

• contractors: self-employed tutors and other professionals engaged under a contract for services.

In this policy, "everyone who works with us" means all three.

Legal protection. The Public Interest Disclosure Act 1998, which amended the Employment Rights Act 1996, protects employees and workers who make a protected disclosure from dismissal and from any other detriment because of it. Whether a self-employed contractor has this statutory protection depends on their circumstances.

Protection under this policy. As a matter of policy, and as required by our contracts with commissioning local authorities, Targeted Provision extends equivalent protection to contractors. A contractor who makes a protected disclosure will not have their contract for services ended, have referrals withheld, or suffer any other detriment because of it.

Status. For contractors, this policy forms part of their contract for services. It reflects Targeted Provision's legal and safeguarding obligations and its contracts with commissioners, not any control over how contractors carry out their work, and it does not create an employment or worker relationship.

2. What whistleblowing is

Whistleblowing is raising a concern about wrongdoing that you reasonably believe is in the public interest. A disclosure is protected if you reasonably believe it shows that one or more of the following has happened, is happening or is likely to happen:

• 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, including a child or young person;

• damage to the environment; or

• the deliberate concealment of information about any of the above.

You do not need proof, and you will be protected even if your concern turns out to be mistaken, as long as you reasonably believed it.

3. Whistleblowing, complaints and grievances

Whistleblowing is different from a personal complaint. A complaint is where you, or someone close to you, has been treated unfairly and you want that put right.

• Employees and workers should raise personal complaints under the Grievance Procedure.

• Contractors should raise personal complaints under the Complaints Policy. Concerns about the commercial terms of their engagement or the allocation of referrals should be raised under the dispute resolution provisions of their contract for services.

If a concern is about something in the public interest (section 2), raise it under this policy, even if it also affects you personally.

4. How to raise a concern

You can raise a concern in writing or in person with any member of senior management or the board. If your concern is about a member of senior management or the board, raise it with someone at that level who is not involved.

Give as much detail as you can, including what happened, who was involved, who may be at risk, and when it happened, and any documents that support your concern.

If your concern is about the safety or welfare of a child or young person, also follow the Safeguarding and Child Protection Policy and tell the Designated Safeguarding Lead straight away.

4.1. Senior management contacts

4.2. 2 Confidentiality and anonymity

We will keep your identity confidential as far as possible. We may need to share it if the law requires, or with external authorities such as the police or the LADO, and we will tell you before we do wherever we can.

You can raise a concern anonymously, although this can make it harder to investigate and to give you feedback. Protect (section 7) can advise on making an anonymous disclosure.

5. What happens next

1. Logging. Every concern is logged and handled confidentially.

2. Timing. Concerns about the safety or wellbeing of children or young people are acted on immediately. Other concerns are acted on within 2 working days.

3. Meeting. You will be invited to a meeting to discuss your concern in more detail. You may bring a colleague or other companion if you wish.

4. Deciding next steps. The person handling your concern will decide what to do next, depending on how serious it is. Anyone the concern is about will not take part. Next steps may include:

   • an investigation by management or internal audit;

   • action under the Disciplinary Procedure (employees and workers) or a review under the contract for services (contractors);

   • action under child or adult protection procedures;

   • action under the procedures for allegations against people who work with children, including referral to the LADO or the DBS;

   • referral to the police, the external auditor, a regulator or an independent investigator.

5. Feedback. We will tell you the outcome in writing within 14 days of it being reached, as far as we can without breaching anyone else's confidentiality.

Concerns that fall under another policy will be dealt with under that policy.

6. Protection from detriment and false disclosures

No one who raises a concern under this policy will be dismissed, have their engagement ended, have referrals withheld, or be treated unfavourably in any other way because of it. Anyone who victimises or threatens someone for raising a concern will face action under the Disciplinary Procedure (employees and workers) or their contract for services (contractors).

We take knowingly false or misleading disclosures seriously. Where a disclosure is shown to have been made knowingly falsely or with intent to mislead, we may take action under the Disciplinary Procedure (employees and workers), or end the contract for services (contractors). No action will be taken against anyone who reasonably believed their concern, even if it turns out to be mistaken.

7. External routes

We will do everything we can to deal with concerns fairly and promptly. You can also get advice or raise a concern externally: