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Whistleblowing Policy


  1. Purpose and scope
  2. Legal Background
  3. Principles
  4. Internal Procedure
  5. External authorities
  6. Policy review and contacts

1. Purpose and scope

This policy applies to all employees within the Kaplan Professional UK group (KPUK) and UK employees of Hawksmere Ltd.

Other individuals performing functions in relation to the organisation, such as agency workers and contractors, are encouraged to use this policy.

This policy sets out the way in which individuals may raise concerns they have about wrongdoing, and how those concerns will be dealt with.

The procedure in this policy is for disclosures about matters other than a breach of an employee's own contract of employment. If an employee is concerned that their own contract has been, or is likely to be, broken, they should use the organisation's grievance procedure.

Kaplan’s businesses are also governed by Graham Holdings Company’s Code of Business Conduct and reference should be made to this document, which is available on the intranet, OurKaplan.

Safeguarding or Prevent concerns in relation to a learner or learners should be reported in accordance with the organisation’s Safeguarding and Prevent Policy.

The organisation encourages workers to raise their concerns under this procedure in the first instance. If a worker is not sure whether or not to raise a concern, they should discuss the issue with their line manager or the HR team.

2. Legal Background

The law (The Public Interest Disclosure Act (PIDA) 1998) provides protection for workers who raise legitimate concerns about specified matters. These are called "qualifying disclosures".

A qualifying disclosure is one made in the public interest by a worker who has a reasonable belief that:

  • a criminal offence;
  • a miscarriage of justice;
  • an act creating risk to health and safety;
  • an act causing damage to the environment;
  • a breach of any other legal obligation; or
  • concealment of any of the above;

is being, has been, or is likely to be, committed. It is not necessary for the worker to have proof that such an act is being, has been, or is likely to be, committed - a reasonable belief is sufficient. The worker has no responsibility for investigating the matter - it is the organisation's responsibility to ensure that an investigation takes place.

A worker who makes such a protected disclosure has the right not to be dismissed, subjected to any other detriment, or victimised, because they have made a disclosure.

More information can be found on the website - whistleblowing for employees.

3. Principles

Everyone should be aware of the importance of preventing and eliminating wrongdoing at work. Workers should be watchful for illegal or unethical conduct and report anything of that nature that they become aware of.

Where there are grounds for proceeding, any matter raised under this procedure will be investigated thoroughly, promptly, and confidentially.

No action will be taken against anyone who makes an allegation, reasonably believing it to be true, even if the allegation is not subsequently confirmed by the investigation.

We will not tolerate any negative behaviour towards an employee who has reported possible wrongdoing. Individuals who feel they have been unfairly treated as a result of reporting a concern under the Whistleblowing Policy should refer to the Grievance Policy.

Victimisation of a worker for raising a qualified disclosure will be a disciplinary offence.

If misconduct is discovered as a result of any investigation under this procedure the organisation's disciplinary procedure will be used, in addition to any appropriate external measures. Maliciously making a false allegation is a disciplinary offence.

An instruction to cover up wrongdoing is itself a disciplinary offence. If told not to raise or pursue any concern, even by a person in authority such as a manager, workers should not agree to remain silent. They should report the matter to a member of the Leadership Team or HR.

4. Internal Procedure

This procedure should be used to disclose a concern that, in your honest, reasonable belief, wrongdoing has been committed, is being committed or is likely to be committed.

Examples of wrongdoing include (but are not limited to):

  • Serious breach of Graham Holdings Company’s Code of Conduct
  • An unlawful or criminal offence (e.g. fraud, corruption or theft)
  • A breach of a legal obligation
  • A miscarriage of justice
  • A disregard of legislation governing health and safety at work
  • Action that has led to or could lead to damage to the environment
  • Breach of the Company’s Anti-bribery and Corruption Policy
  • Behaviour or action that harms, or poses a risk to the welfare of, a learner or learners
  • Conduct which appears likely to harm the reputation of any of Kaplan’s businesses
  • The deliberate covering up of information in relation to any of the above.

If a worker is not sure whether to raise a concern under this procedure, they should discuss the issue with an appropriate member of the management team or HR.

Reporting a concern

  • A worker who reasonably believes that inappropriate business conduct or activity has occurred, is occurring or is likely to occur should in the first instance raise the issue with a member of the Leadership Team, a Human Resources Manager or (in the event of a breach or likely breach of the Company’s Anti-Corruption policy) the Division Legal Counsel. Where the issue relates to the safety or welfare of a learner or learners, it should first be reported in accordance with the organisation’s Safeguarding and Prevent Policy.
  • The worker should advise that they are reporting the matter under the Whistleblowing Policy.
  • Every effort will be made to ensure confidentiality and if requested all reasonable steps will be taken to protect the anonymity of the whistleblower. However, under certain circumstances to assist with the investigation the individual’s identity may become known or need to be revealed.
  • Alternatively, the conduct or activity may be reported anonymously by calling Graham Holdings Company’s Ethics Hotline on 0808 234 0096 or visiting the Graham Holdings website, and reporting via their online platform. However, the Company encourages individuals to raise their concerns directly to the senior managers listed above to allow more effective investigation, follow up and provision of feedback.


  • Once an individual has raised a concern, the matter will be investigated by either the person to whom the matter was raised or, where more appropriate, the Company will appoint an alternative manager. It is not the responsibility of the individual raising the concern to investigate the wrongdoing in order to gather evidence.
  • The format of the investigation may vary depending upon the circumstances. However, the individual who raised the concern and other individuals involved may be required to attend an investigation meeting and/or provide a written statement.
  • Any investigation will be carried out in accordance with the principles set out above.
  • Once the investigation is complete, the individual who raised the concern will be informed of the outcome and further steps that are to be taken.
  • If the individual who raised the concern is dissatisfied with the investigation or outcome they should raise the matter with Kathy Walton, CEO or HR.

5. External authorities

Where a worker reasonably believes that, on conclusion of the internal procedures, the appropriate action has not been taken, they might consider reporting the matter to the proper authority (see 5b).

An individual considering reporting a concern may wish to seek independent advice before doing so, as this must be made to the correct prescribed person or body for the issue and there are additional requirements that will need to be met in order to qualify for the protections provided under the Public Interest Disclosure Act. The independent whistleblowing charity, Protect, operates a confidential helpline.

A list of the prescribed people and bodies to whom a disclosure can be made is available on - list of prescribed people and bodies.

If an individual wishes to make a disclosure to the Department of Education (DFE) or Education and Skills Funding Agency (ESFA), further information on how to make a disclosure and how the disclosure will be handled can be found on - how EFSA handles whistleblowing disclosures.

6. Policy review and contacts

If you have any questions about this policy, your line manager or the HR team can help.

Our policies are reviewed and (if required) updated at least every two years in line with legal obligations, business objectives, and operational needs. We will notify staff of some key changes, but it is not practical to notify of every change that occurs so it is everyone’s responsibility to keep themselves up to date with the current versions of policies as made available via our intranet.

Please revisit employment policies at regular intervals, and refer to specific relevant policies when the need arises.

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