A copy of this policy is available
as a pdf download here.
The University of Wolverhampton's
core values are to act in a manner which is ethical, respectful,
transparent, inclusive and fair, challenging, confident,
collaborative and professional. The University is also under a duty
to account for the proper use of public funds and standards
required in public life.
Under the Public Interest
Disclosure Act 1998 "workers" are able to make disclosures about
wrongdoing within their organisation to their employer so problems
can be identified and resolved quickly within the organisation.
This policy enables staff, students, Governors and members of the
University community to raise, in good faith, concerns of
malpractice, impropriety or wrongdoing without fear of reprisal.
This policy details how such a disclosure can be made and how the
University will deal with the matter.
The term "Workers" in this policy
refers to staff, students, Governors and members of the University
A person who makes a disclosure in
good faith and without malice and in accordance with this policy
will not be penalised for doing so. For this protection to qualify,
the worker must reasonably believe one or more of the activities
listed in section 3 (below) if this policy are either happening
now, took place in the past or are likely to happen in the future.
This belief need not be correct, but must be reasonably held at the
time of the disclosure.
This procedure is not to be used by
individuals seeking to challenge decisions already made by the
University or to consider matters already dealt with via internal
procedures, such as disciplinary matters.
"Workers" are able to disclose
serious concerns which are in the public interest. Examples of what
constitutes "serious" are misconduct, impropriety or malpractice.
The University has a zero tolerance approach for these activities
and will take such matters seriously.
Examples of serious misconduct,
impropriety or malpractice, which may lead to such a disclosure are
those which tend to show one or more of the following matters is
either happening now, took place in the past or is likely to happen
in the future:
Any suspicions of misconduct,
impropriety or malpractice connected with University business
should be reported.
This guidance does not supersede
established procedures such as the formal complaints procedures,
the grievance procedure, or the policies on discrimination,
harassment or bullying.
The University will endeavour to
treat any disclosures under this policy in a confidential manner.
If appropriate, the identity of the person making the disclosure
will remain confidential for as long as possible, providing this is
compatible with a thorough investigation. However, the identity of
any reporter may need to be revealed at some stage during the
investigation and the individual may need to make a statement for
evidential purposes. If a criminal investigation ensues, the
individual may be called as a witness in any proceedings. The
University will, however, seek to protect you from any subsequent
victimisation as a result of a disclosure made in good faith (as
detailed in section 13 of this policy).
You may make an anonymous
disclosure, however, individuals are encouraged to provide their
name as the purpose of this policy is to promote transparency and
discourage any fear of reprisal. It may also be more difficult to
effectively address issues which are raised anonymously.
A disclosure should be made to the
Secretary to the Board of Governors, Tony Lee. You may make your
disclosure in writing either by email email@example.com or by post to Tony
Lee, Secretary to the Board of Governors, Wulfruna Street,
Wolverhampton, WV1 1LY. Please ensure you mark your correspondence
"private and confidential".
In circumstances where your
disclosure involves or implicates the Secretary to the Board of
Governors is unavailable, you should send your disclosure direct to
the Vice Chancellor. This could be done via email to firstname.lastname@example.org or post to
Professor Geoff Layer, Vice Chancellor's Office, MA Building,
Wulfruna Street, Wolverhampton, WV1 1LY. Please ensure you mark
your correspondence "private and confidential".
The delegated individual will then
consider the disclosure and if there are sufficient grounds for
proceeding. If it is decided there are sufficient grounds, the
delegated individual will decide what form the investigation will
take and appoint a relevant and appropriate person to undertake the
investigation. This appropriate person will depend upon the nature
of the investigation. The appropriate person will have no personal
interest in the outcome of the case and no potential conflict of
The original person who made the
disclosure will remain separate from the investigation.
Where appropriate, the Vice
Chancellor, the Chair of Audit Committee and the Chair of the Board
of Governors will be informed that a disclosure has been made and
is being investigated.
Once the matter has been
investigated, the delegated individual will make a decision about
whether the matter should be progressed and how it should be dealt
with. The outcome will be reported, where appropriate to the Chair
of Audit Committee, the Chair of the Board of Governors and the
The reporting of the findings of
the investigation will depend on the nature of the disclosure.
A disclosure should normally only
be made internally to ensure there is no possible prejudice to the
internal investigation process.
Under the Public Interest
Disclosure Act 1998 there are limited circumstances where an
individual who makes a disclosure to an external body relating to
one of the matters covered by the Act may be protected from
detriment or dismissal.
In those limited circumstances,
workers who are concerned about wrongdoing or failures can make
disclosures to a person or body who are prescribed by the
Secretary of State. If the worker makes such a qualifying
disclosure it will be treated as a protected disclosure provided
the worker makes the disclosure in good faith, reasonably believe
the information and any allegation it contains are substantially
true and reasonably believes the matter falls within the
description of matters which the person/body has been prescribed
for. The list of prescribed persons and details of matters which
they deal with is located within the Department of Trade and
Industry's Guide to the Public Interest Disclosure Act 1998 which
is located at
If an allegation is made against a
named individual, at an appropriate point in the investigation the
named individual will be informed of the allegation and supporting
evidence. The nature of the investigation will dictate at what
point they will be informed. The nature individual will be given an
opportunity to respond either orally or in writing. If an interview
is required, they will have the opportunity to take a member of the
University community to accompany them.
Upon receipt, the report will be
investigated. The individual who made the disclosure will be
informed of the handling of the investigation and the outcome.
However, if the investigation is
the result of an anonymous disclosure this will not be
If you are unsatisfied with the
outcome or the process of the investigation you may send your
complaint to the Chair of the Board of Governors. This can be
marked for the attention of the Chair of the Board of Governors and
sent to Corporate Strategy & Governance Unit, MA216, MA
Building, Wulfruna Street, Wolverhampton, WV1 1LY.
Upon receipt of such a report, the
Chair in his absolute discretion shall decide the course of action
to take and the form of response to you.
Action will not be taken against
any individual who has made a disclosure in good faith.
If subsequent investigation reveals
that the individual has made a malicious or vexatious disclosure,
they may be subject to disciplinary or other appropriate
The University will not tolerate
any victimisation of an individual who has made a disclosure in
good faith under this policy. Such victimisation may provide
grounds for grievance, disciplinary or other appropriate
Approved by Finance and General
Purpose Committee, 10th May 2012.
University of Wolverhampton, Wulfruna Street, Wolverhampton, WV1 1LY
Course enquiries: 0800 953 3222, General enquiries: 01902 321000 | Email: email@example.com
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