Version: 2.0 | Status: Active | Last Updated: March 2, 2026 | Next Review: March 2027 Responsible Officer: Board of Trustees Applies to: All NSEMM staff, volunteers, trustees, contractors, and agency workers
The National Society for Education, Mentoring and Media (NSEMM), a Charitable Incorporated Organisation (CIO), is committed to the highest standards of openness, accountability, and integrity. This policy encourages and enables all workers to raise serious concerns about wrongdoing within the organisation without fear of reprisal.
NSEMM recognises that whistleblowing is distinct from a grievance or complaint. Whistleblowing is when a worker reports a concern about wrongdoing that is in the public interest. Grievances relate to personal employment matters and are handled under the Complaints Policy.
Whistleblowers are protected by law under the following legislation:
To qualify for legal protection, a disclosure must meet the following conditions:
Important: You do not need to prove that wrongdoing has occurred. A reasonable belief is sufficient. You will not face any penalty for raising a genuine concern, even if the investigation finds no wrongdoing.
You should raise a whistleblowing concern if you reasonably believe that any of the following is occurring, has occurred, or is likely to occur:
| Category | Examples |
|---|---|
| Criminal offences | Fraud, theft, bribery, corruption, money laundering |
| Failure to comply with legal obligations | Breach of charity law, employment law, or regulatory requirements |
| Miscarriage of justice | Wrongful accusations, suppression of evidence |
| Danger to health and safety | Unsafe working conditions, failure to follow safety procedures |
| Damage to the environment | Improper waste disposal, pollution |
| Safeguarding failures | Failure to follow safeguarding procedures, cover-up of abuse |
| Financial malpractice | Misuse of charity funds, fraudulent accounting, undeclared conflicts of interest |
| Policy violations | Serious breaches of NSEMM policies, codes of conduct, or constitutional obligations |
| Deliberate cover-up | Attempts to conceal any of the above |
Use direct reporting if the concern involves the person you would normally report to, or if you are unable to access the Protect app.
If you feel unable to raise your concern internally, or if NSEMM has not addressed your concern adequately, you may report to an external prescribed person:
| Prescribed Person | Types of Concern |
|---|---|
| Police / Serious Fraud Office | Criminal matters, fraud |
| Health and Safety Executive (HSE) | Health and safety breaches |
| Ofsted | Education standards, safeguarding |
| Information Commissioner’s Office (ICO) | Data protection breaches |
| Charity Commission | Charity governance, misuse of funds |
| Environment Agency | Environmental damage |
| Criminal Cases Review Commission (CCRC) | Miscarriage of justice |
| HM Revenue and Customs (HMRC) | Tax fraud, financial irregularities |
NSEMM accepts anonymous whistleblowing reports. The Protect app includes an identity-stripping feature that allows you to submit a report without your identity being disclosed to investigators.
However, please be aware that:
| Step | Timeframe | Detail |
|---|---|---|
| Acknowledgement | Within 3 working days | Written confirmation of receipt and outline of next steps |
| Initial assessment | Within 5 working days | Determine whether the concern falls within scope of this policy |
| Investigation | Within 4-8 weeks | Proportionate investigation by designated officer or independent investigator |
| Outcome | Within 2 weeks of investigation | Written summary of findings and any actions taken (subject to confidentiality) |
| Appeal | Within 14 days of outcome | If dissatisfied, escalate to Board of Trustees |
The investigation may involve:
NSEMM will not tolerate any form of retaliation against a whistleblower. This includes:
Any person found to have retaliated against a whistleblower will face serious disciplinary action, up to and including dismissal. Workers who experience retaliation should report it immediately via the Protect App or directly to the Chair of Trustees.
While NSEMM encourages the reporting of genuine concerns, deliberately false or malicious allegations may result in disciplinary action. A concern raised in good faith that is not upheld by investigation will not be treated as malicious.
All whistleblowing reports and investigation records are maintained securely in the Protect app for a minimum of 7 years. Records are processed in accordance with the Data Protection & GDPR Policy.
The Board of Trustees reviews this policy annually and receives a summary report on the number and nature of whistleblowing disclosures received during the year (anonymised to protect identities).
This policy is maintained by NSEMM leadership and reviewed annually. For queries, contact leadership@nsemm.org.uk.