Whistleblowing Policy

Introduction

The Independent School of Jakarta (hereafter referred to as the School) is committed to the highest standards of openness, integrity and accountability. This Whistleblowing Policy is intended to enable staff and volunteers to raise concerns, in confidence, about wrongdoing or malpractice in the workplace, including concerns relating to safeguarding and child protection.

This policy is informed by UK best practice, including the principles set out in the Public Interest Disclosure Act 1998 (PIDA) and Keeping Children Safe in Education (KCSIE, statutory guidance, as applicable to British international schools).

Safeguarding

Nothing within this policy is intended to prevent staff from complying with their safeguarding duties. All staff and volunteers have a responsibility to raise concerns about poor or unsafe practice, or potential failures in safeguarding arrangements, in line with Keeping Children Safe in Education and the School's Safeguarding and Child Protection Policy.

Safeguarding concerns must always be acted upon promptly. Where a concern relates to the conduct of a colleague or the effectiveness of safeguarding arrangements, staff should use this Whistleblowing Policy if they feel unable to raise the matter through normal safeguarding reporting routes.

Policy Aims

The School's Whistleblowing Policy aims to:

• Encourage staff and volunteers to report concerns about wrongdoing or malpractice at an early stage
• Ensure staff feel confident to raise concerns without fear of reprisal or victimisation
• Provide clear procedures for raising concerns, including routes outside the normal line management structure
• Ensure that concerns are investigated thoroughly, fairly and in a timely manner
• Support a culture of openness, accountability and safeguarding

Scope

This policy applies to all staff, governors, volunteers, contractors and agency staff working for or on behalf of the School.

This procedure is separate from the School's Grievance Procedure. It should not be used to raise personal employment issues or complaints about contractual matters, which should be addressed through the appropriate HR processes.

Whistleblowing concerns must be raised in the public interest and relate to suspected wrongdoing, including (but not limited to):

• Safeguarding concerns or failures in child protection arrangements
• Criminal offences or suspected criminal activity
• Failure to comply with a legal obligation
• Financial malpractice, fraud, bribery or corruption
• Miscarriages of justice
• Serious risks to health and safety
• Damage to the environment
• Deliberate concealment of any of the above

Confidentiality and Anonymity

The School will take all reasonable steps to maintain the confidentiality of any individual raising a concern. A whistleblower's identity will not be disclosed without their consent, unless this is required by law or safeguarding obligations.

Absolute confidentiality cannot be guaranteed in all circumstances, particularly where safeguarding concerns or criminal matters are involved.

Concerns may be raised verbally or in writing. Anonymous disclosures will be considered, although individuals are encouraged to identify themselves where possible, as anonymity may limit the School's ability to investigate fully or provide feedback.

Internal Procedure

Staff are encouraged to raise concerns as soon as possible. Concerns may be raised with:

• The Academic Director
• The Head of Finance

Concerns will be investigated promptly and thoroughly. Where appropriate, the whistleblower will be kept informed of progress and, subject to confidentiality and third-party rights, the outcome of the investigation.

If a member of staff feels that their concern has not been addressed appropriately, they may escalate the matter in confidence to the Board of Governors of The Independent School of Jakarta.

External Whistleblowing Routes

Where staff feel unable to raise a concern internally, or believe that their concern has not been taken seriously or addressed appropriately, they may contact an external body. Depending on the nature of the concern, this may include:

• The Police
• The Ministry of Education and Culture (Indonesia)
• The Council of British International Schools (COBIS)
• The Independent Schools Inspectorate (ISI)
• The NSPCC Whistleblowing Advice Line (for safeguarding concerns): 0800 028 0285 or [email protected]
• Protect (formerly Public Concern at Work): an independent UK whistleblowing charity

Staff are encouraged to seek advice before making an external disclosure.

Bypassing Internal Procedures

In exceptional circumstances, staff may raise a concern directly with an appropriate external body without first using the internal procedures. Such circumstances may include where the individual reasonably believes that:

• They would be subject to detriment or victimisation if they raised the concern internally
• Evidence may be concealed or destroyed
• A previous disclosure has not resulted in appropriate action
• Immediate external action is required to protect children or others from harm

The Media

Staff must not disclose confidential information to the media. Disclosures made for personal gain or in bad faith may be treated as a disciplinary matter. This does not affect an individual's legal rights under whistleblowing legislation to make a protected disclosure to prescribed bodies.

Malicious or Vexatious Allegations

If an investigation concludes that an allegation was made maliciously, vexatiously or in bad faith, the matter may be addressed under the School's Disciplinary Procedure. This will not apply to genuine concerns raised in good faith, even if they are not substantiated.

Protection from Reprisal or Victimisation

The School is committed to ensuring that no member of staff suffers detriment, harassment or victimisation for raising a genuine concern in good faith under this policy.

Any acts of retaliation against a whistleblower will be treated seriously and may result in disciplinary action.

Review

This policy will be reviewed annually, or sooner if required, to ensure it remains compliant with statutory guidance and best practice.