Whistleblowing Policy

April 2024
Version 2.0Public© 2017 PeopleCert | All rights reserved
Process: Quality Management & Excellence | ID No: ….ver01.0 / 28.12.17

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TABLE OF CONTENTS

1Introduction ..................................................................................................................................... 4

2

Partner’s / AO’s responsibility ........................................................................................................ 4

3

What is whistleblowing? ................................................................................................................. 4

4

How to whistleblow ......................................................................................................................... 6

5

Protecting your identity ................................................................................................................... 6

6

What we will do upon receiving a whistleblowing allegation .......................................................... 6

7

Outcomes of an investigation ......................................................................................................... 78

Contact us ...................................................................................................................................... 7© 2024 PeopleCert | All rights reservedProcess: Manage Quality and Excellence
ID No: QME_PO_10-4 Whistelblowing Policy ver2.0 |03/04/2024
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Document Revision History
VersionDate

2.0
1.0

03/04/2024
08/03/2018

Description of Change
2024 Rebranding
Initial version© 2024 PeopleCert | All rights reserved
Process: Manage Quality and Excellence
ID No: QME_PO_10-4 Whistelblowing Policy ver2.0 |03/04/2024
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1Introduction

PeopleCert always strives to maintain a culture of openness with its whole ecosystem. By becoming
aware of any malpractice/poor practice, we are able to take the necessary steps to safeguard theinterests of our partners/Accredited Organisations (AOs), candidates and any other stakeholders.
Therefore, we encourage our staff, partners/AOs and candidates to get in touch with us and ‘speak up’or ‘blow the whistle’, and to raise any concerns in relation to the delivery of our exams and services.
This policy is designed to provide you with information about the process by which you may blow thewhistle. It also presents measures that PeopleCert has in place in order to protect whistleblowers.
This policy is reviewed annually as part of our internal audit and continuous improvement arrangements;
it will be revised when and if necessary in response to external feedback, market trends, changes inour practices, new requirements set by the Regulatory Authorities, Accreditors/Test Owners or changes
in legislation.

2

Partner’s / AO’s responsibility

It is important that your staff and customers (trainees and/or candidates) are fully aware of this policy
and its contents, therefore we expect you to communicate the right to whistleblowing as appropriate.
We also expect our partners/ Accredited Organisations to maintain a culture where staff can freely raise
concerns about activities and practices without the risk of adverse consequences to their future
employment or career.

3

What is whistleblowing?

Whistleblowing is when an individual reports suspected malpractice or maladministration and/or thecovering up of malpractice or maladministration.
The malpractice or maladministration may be committed by an Accredited/approved Organisation andmay be reported by an employee of the Organisation, or a trainee and/or candidate.
Whistleblowing is different from both complaints and employment disputes and should not be confusedwith any expression of personal dissatisfaction. An individual raising an allegation under thesewhistleblowing arrangements should have a reasonable belief that the disclosure is in the publicinterest. Individuals can raise a concern with PeopleCert under the arrangements outlined in this policy
if they have a reasonable belief that malpractice and/or a maladministration is occurring or is likely tooccur. Examples of whistleblowing disclosures that could be made to us include:•a member of staff of an Accredited Organization making a disclosure about actual or possible
malpractice/ maladministration at the Accredited Organization and/or the Organization’s failure tocomply and adhere to the Accreditation requirements;•a trainee and/or candidate making a disclosure about possible malpractice/maladministration at
one of our Accredited Organizations;•making a disclosure about possible malpractice / maladministration being carried out by a member(internal or external associate) of PeopleCert.

Malpractice is essentially any activity or practice (deliberate actions, neglect, default or other practice)which deliberately contravenes regulations and compromises the integrity of the assessment process
and/or the validity of certificates. Malpractice may include a range of issues from failure to maintainappropriate records or systems to the deliberate falsification of records in order to claim certificates. For
the purpose of this policy, this term also covers criminal activity; failure to comply with any legal© 2024 PeopleCert | All rights reserved
Process: Manage Quality and Excellence
ID No: QME_PO_10-4 Whistelblowing Policy ver2.0 |03/04/2024
Page 4 of 8obligation; miscarriages of justice; danger to health and safety; damage to the environment; misconduct;
and forms of discrimination or bias towards individual or groups of candidates.
Maladministration is essentially any activity or practice which results in non-compliance withadministrative regulations and requirements and includes persistent mistakes or poor administration
within a centre.
The categories listed below are examples, but not an exhaustive list, of Organizations and candidate
malpractice/ maladministration:•Persistent failure to adhere to our requirements; poor administrative/operational arrangements;•Fraudulent claim for certificates and/or deliberate submission of false information to achieve acertification;•

Using non accredited/approved trainers and/or invigilators;•Failure to maintain appropriate auditable records, e.g. training and/or examination records and/orfalse records;•

Misuse of PeopleCert and Accreditor’s/ Test owner’s logos, brand names and trademarks or
misrepresentation of an Organization’s relationship with PeopleCert and/or its accreditation andapproval status; promoting services or products for which the Organization is not accredited;•Denial of access to premises, records, information, candidates and staff to any authorised
PeopleCert representative and/or regulatory authorities;•Intentional withholding or delaying information, which is critical to maintaining the quality standardsof our services;•The unauthorised use of inappropriate materials / equipment during examinations (e.g. mobilephones, books or notes, etc);•A loss or theft of, or a breach of confidentiality in any exam materials; inappropriate
circulation/distribution of exam materials, insecure storage of exam materials;•

Unauthorised amendment, copying or distributing of exam papers/materials;•

Inappropriate assistance/support to candidates (e.g. unfairly helping them to pass an exam);•

Failure to arrange for Reasonable Adjustments and Special Considerations;•Plagiarism by candidates/staff;•Copying from another candidate;•

Cheating by candidates/staff;•Personation - assuming the identity of another candidate or having someone assume their identity
during an assessment;•

Selling certificates, papers/assessment details;•Fraud;In case of doubt on how best to proceed, you can always contact the PeopleCert Quality team.

© 2024 PeopleCert | All rights reserved
Process: Manage Quality and Excellence
ID No: QME_PO_10-4 Whistelblowing Policy ver2.0 |03/04/2024
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4How to whistleblow

To raise an allegation or concern under these whistleblowing arrangements, you may contact thePeopleCert Quality team (contact details are available at the end of this policy).
Upon making an allegation or raising any concern it is helpful to provide as much information andsupporting evidence as possible to help us identify inform the nature of the investigation we need tocarry out.
Although it is important to note that it is not essential to have clear evidence before making an allegation
under this policy, we nevertheless ask that you explain as fully as you can the nature of the allegationor circumstances that gave rise to your concern.

5

Protecting your identity

Sometimes a person making an allegation may wish to remain anonymous, although it is always
preferable to reveal your identity and provide us with your contact details so that we are able to contact
you as part of the investigation as necessary. However, if you are concerned about possible adverse
consequences that may occur should your identity be revealed to another party, then please inform usthat you do not wish for us to divulge your identity and we will work to ensure your details are notdisclosed.
Whistleblowers must not suffer any detrimental treatment as a result of raising a genuine concern.
Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment
connected with raising a concern. If you believe that you have suffered any such treatment, you should
inform PeopleCert immediately.
The investigator(s) assigned to explore the allegation will not reveal the whistleblower’s identity and willkeep it confidential unless the whistleblower agrees or if it is necessary for the purposes of theinvestigation, such as to:•the police, fraud prevention agencies or other law enforcement agencies (to investigate or prevent
crime, including fraud);•

the courts (in connection with court proceedings), to which we are required by law to disclose youridentity;•

other third parties, where we consider it necessary to do so [e.g. the regulator(s)].

The investigator will advise you if it becomes necessary to reveal your identity against your wishes.
A whistleblower should also recognise that he or she may be identifiable by others due to the nature or
circumstances of the disclosure (e.g. the party which the allegation is made against may manage toidentify possible sources of disclosure without such details being disclosed to them).

6What we will do upon receiving a whistleblowing allegation

Once a concern has been raised, we have a duty to pursue the matter. Depending upon the nature of
the allegation, we will appoint someone to investigate the allegation who has the appropriate skills andtraining and who has not had any previous involvement or personal interest in the matter.
The person(s) appointed to investigate the matter [the investigator(s)] may contact the whistleblower toascertain the details of their concern. If the whistleblower does not wish to make a written statement,
the investigator(s) will write a brief summary of the issue and the whistleblower will be expected toconfirm this as correct.

© 2024 PeopleCert | All rights reserved
Process: Manage Quality and Excellence
ID No: QME_PO_10-4 Whistelblowing Policy ver2.0 |03/04/2024
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The investigator will then conduct an investigation to establish the facts in accordance with our internalprocedures.
In all cases, we will keep the whistleblower updated as to how we have progressed the allegation (e.g.
we have undertaken an investigation). However, we will not disclose all details of the investigation
activities and it may not be appropriate for us to disclose full details of the outcomes of the investigation
due to confidentiality or legal commitments (e.g. disclose full details on the action that may be taken
against the parties concerned). The whistleblower will be expected to treat any information about theinvestigation confidential.

7

Outcomes of an investigation

If the investigation results in a proven case of malpractice or maladministration, we will take appropriate
action against the relevant parties in accordance with our relevant and, where necessary, we may
impose the applicable sanctions.
If the allegation is not proven by the investigation, provided that the whistleblower did not deliberately
raise an allegation which they knew to be untrue, no action will be taken against them by PeopleCert.
If the allegation was made due to a genuine misunderstanding, the individual(s) or the Organisation thathave been the subject of the investigation will be expected to bear no malice or ill feeling towards theirwhistleblower.
If, however, the investigation concludes that the whistleblower raised a false allegation maliciously, wereserve the right to take any legal or disciplinary action.
PeopleCert will not disclose to the whistleblower the actions taken or the sanctions imposed.

8Contact us

If you wish to make an allegation as outlined in this policy, have a query in relation to our whistleblowing
arrangements, or if you would like to feed back any views please contact us throughquality@peoplecert.org© 2024 PeopleCert | All rights reserved
Process: Manage Quality and Excellence
ID No: QME_PO_10-4 Whistelblowing Policy ver2.0 |03/04/2024
Page 7 of 8Ε-mail: info@peoplecert.org, www.peoplecert.org
Copyright © 2024 PeopleCert International Limited and its affiliates (“PeopleCert”)
All rights reserved. No part of this document or the information in it may be copied, distributed, disclosed orused other than as authorized by PeopleCert. PeopleCert: Dream It, Do It® and the Swirl logo are registeredtrademarks of PeopleCert.
DISCLAIMER
This publication is designed to provide helpful information to the recipient. Although care has been taken
by PeopleCert in preparation of this publication, no representation or warranty (either express or implied) is
given by PeopleCert with respect to the completeness, accuracy or suitability of the information or advice
contained within it, and PeopleCert shall not be held responsible for any loss or damage whatsoever relating tosuch information or advice.

© 2024 PeopleCert | All rights reserved
Process: Manage Quality and Excellence
ID No: QME_PO_10-4 Whistelblowing Policy ver2.0 |03/04/2024
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