Equal Opportunity & Dignity Policy and Process
General Principal
General Principals
We at Pinehirst Education are committed to equality and diversity, ensuring that everyone has access to the same opportunities and same fair treatment. It’s about showing fairness and respect to others, regardless of any actual or perceived difference. We will support and encourage all under-represented groups and will promote an inclusive culture which values diversity. Any allegations of bullying, harassment, or victimisation should be reported through our appropriate channels.
Paul Morton, Director of Curriculum, Pinehirst Education June 2023
We at Pinehirst Education are committed to equality and diversity, ensuring that everyone has access to the same opportunities and same fair treatment. It’s about showing fairness and respect to others, regardless of any actual or perceived difference. We will support and encourage all under-represented groups and will promote an inclusive culture which values diversity. Any allegations of bullying, harassment, or victimisation should be reported through our appropriate channels.
The purpose of the Equal Opportunity & Dignity at Work Policy is:
To confirm our commitment to Fairness, Respect, Equality, Diversity, Inclusion, & Engagement (FREDIE).
To confirm the actions required of you, to support us in creating a nd maintaining a positive, equal, and inclusive workplace.
To provide an overview of equality, diversity, bullying, harassment & victimisation to raise awareness and understanding.
To empower you to challenge and eliminate instances of bullying, harassment, and victimisation and ensure that our values are maintained.
To provide guidance as to what would be considered by us to be unacceptable behaviour.
To confirm what you should do if you feel bullied, harassed, victimised, or mistreated.
To confirm what you should do if you observe inappropriate behaviour being directed at others.
To confirm who you can approach for support.
This policy has been created to reinforce the types of workplace conduct which are not acceptable, to help you understand how to resolve your concerns, and to have the confidence to come forward and speak up.
Scope
This policy applies to all employees of the Pinehirst Education and covers the following:
Any incident that may occur at Pinehirst Education centres.
Any incident that may occur offsite, either during or after working hours, which relates to potential misconduct and mistreatment of any of our employees, students, or Governors, thereby giving rise to complaints of bullying, harassment, or victimisation.
Any occasions where an employee is representing Pinehirst Education in any activity.
Any accusations from students about employees.
Introduction
By creating and maintaining a diverse and equal workplace, we can draw on a wide range of ideas from a workforce full of different skills, experiences, resources, talents, and energies; all of which helps you to thrive and enjoy a happy and harmonious working environment.
Our commitment:
To treat all employees and job applicants equally, fairly, and respectfully.
To do our upmost to ensure that the workplace is free from unlawful and unfair discrimination.
To ensure that all employment decisions taken, are free from discrimination.
To ensure that the work environment is free from harassment, victimisation, and bullying, and to ensure that everyone is treated fairly, ethically, and with dignity and respect.
To promote and advance equality of opportunity.
If you believe that one of your fellow employees, or the Pinehirst Education as a whole, may be falling short of its commitment, then we do not want you to remain silent. We want – and need – to hear from you.
Principles
We have a zero-tolerance approach to bullying, harassment, and victimisation - in any form. We consider bullying and harassment to be a serious issue and it is because of this that we are committed to the elimination of harassment and bullying.
Employment at the Pinehirst Education is based solely upon individual merit, which will be causally related to professional competencies, such as skills, experience, knowledge, and qualification. We do not permit unlawful discrimination or harassment based on race, colour, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or any other characteristics protected by law.
We will make all reasonable accommodations, to meet our obligations under laws protecting the rights of those who have a disability.
Any complaints of bullying, harassment, or victimisation should be reported through our Resolution Policy, which will lead to a triage assessment, which will determine an appropriate approach for resolution.
Any allegation of bullying, harassment, or victimisation, which is substantiated, may result in disciplinary action up to and including dismissal; this includes unprofessional conduct, which is in breach of the values of this policy. We have a zero-tolerance approach to bullying, harassment, or victimisation; therefore, where concerns are substantiated, dismissal may apply for a first offence.
We not only fulfil our legal position in relation to current and future equality legislation but have an ethos that goes beyond compliance in providing and promoting “Opportunities to succeed”, free from any aspect of discrimination, harassment, or victimisation.
You all have a duty of care towards each other: to look after the interests of and support your colleagues. This policy takes account of our commitment to eliminating discrimination, identifying, and removing barriers, and providing equal opportunities for our learners, employees, and visitors to ensure that no one feels excluded or disadvantaged. We recognise that young people and vulnerable adults (as defined in Pinehirst Education Safeguarding Policy) are specific groups who may need particular protection from bullying and harassment.
Roles & Responsibilities
Responsibility of all managers:
To take the lead in creating a positive, open culture that challenges inappropriate behaviour.
To be familiar with this policy and ensure that it is followed correctly.
To role model the correct behaviours, setting a good example to others. This will help shape and influence a positive work environment free from harassment, bullying, and victimisation.
To be alert to signs of harassment, bullying, or victimisation by others and be aware of what is unacceptable behaviour.
To actively participate in an investigation, when required.
To be aware of Pinehirst Educations legal responsibilities as an employer in relation to harassment and bullying.
To ensure appropriate training and development is provided to support managers’ and employees’ understanding of this policy.
To set a good example, and to ensure all decision making is fair and free from any form of discrimination.
To ensure that there is a supportive working environment.
To make sure that employees know what standards of behaviour are expected of them.
To be alert to signs of harassment, bullying, or victimisation by others and be aware of what is unacceptable behaviour.
To intervene to stop bullying or harassment.
To report promptly to the Director Of Curriculum , any complaint of bullying or harassment, or any incident of bullying or harassment witnessed by them.
To resolve any issues promptly, fairly, and consistently.
Responsibility of Employees:
To role model the values outlined in this policy - demonstrating these values through your actions and behaviours; this will involve treating everyone (employees, students, job applicants, governors, volunteers, and suppliers) fairly, inclusively, respectfully, empathetically, and professionally at all times.
To immediately report any breaches of this policy, (whether subject to unfair treatment, inappropriate conduct, or where this is observed with others) to a manager or member of the management .
To support Pinehirst Education with the investigation of any complaints; if a complaint of harassment or bullying is made, you must not prejudge or victimise the complainant or alleged harasser.
To respond positively to feedback and modify your behaviours or actions accordingly.
To maintain confidentiality and not become involved in gossip or speculation.
To remain calm and respectful when speaking or dealing with others; remove yourself from any situation which is escalating - where a calm and professional discussion has failed.
To inform others calmly, professionally, and respectfully when you find their behaviour unacceptable; alternatively, you may report the matter to a manager or member of the management - if you feel unable to approach them directly.
To intervene calmly and respectfully, where possible, to stop harassment or bullying and give support to recipients.
Please be aware that you can be held personally liable, as well as, or instead of, Pinehirst Education, for any act of unlawful discrimination. If you commit a serious act of harassment you may be guilty of a criminal offence.
Equal Opportunity
What Is Equality?
Equal opportunity is about ensuring fairness for everyone and removing any disadvantage.
Equal opportunity is focussed upon addressing the difference between the representation of a community, (the different types of people who live within a community) compared with the representation within a workforce (the different types of people who are employed within a business). It is about the actions and measures being taken to ensure fairness in employment.
In a fair and equal workplace, you would see the following:
All people being treated as individuals - without judgements being made of them based on any stereotypes.
Understanding, appreciating, and valuing the different sets of skills and abilities of all staff members.
Opportunities being available to all.
A working environment where people of all backgrounds and abilities feel included, valued, and appreciated.
Diversity
What Is Diversity, and How Does It Differ from Equality?
Equality is about ensuring everybody has an equal opportunity, is not treated differently, or less favourably. Diversity is about taking account of the differences between people and groups of people and placing a positive value on those differences. Diversity is about acceptance and respect. It means understanding that everyone is unique and recognising and respecting our individual differences.
Bullying, Harassment & Victimisation
What Is Bullying?
Bullying is when an individual, or a group of people - often with more power - repeatedly and intentionally cause hurt or harm to another person or group of people who feel helpless to respond. Bullying can continue over time, is often hidden, and will probably continue if no action is taken.
Bullying is offensive, intimidating, malicious or insulting behaviour - an abuse or misuse of power, which is meant to undermine, humiliate, or injure the person on the receiving end.
Bullying and harassment means any unwanted behaviour that makes someone feel intimidated, degraded, humiliated, or offended. It is not necessarily always obvious or apparent to others and may happen in the workplace without our awareness.
Bullying Is Not:
A single episode of social rejection or dislike.
A single occasion of nastiness or spite.
A disagreement or argument.
Examples of Bullying: (this is not an exhaustive list)
Examples of bullying can include intimidating behaviour, constantly shouting, swearing or constantly ignoring/singling one person out, stalking etc.
Cyber bullying, as it is often called, might take the form of “real world” bullying being played out online. Situations may be deliberately planned in order to photograph someone in a humiliating way and circulate this online. Increasingly, bullying is happening through technology. This can involve sending inappropriate, or hurtful text messages, emails, instant messages, or posting malicious material online (i.e. on social networking websites), or sending or posting offensive or degrading comments, images, or videos.
Racist and religious bullying can be defined as “A range of hurtful behaviour, both physical and psychological, that makes a person feel unwelcome, marginalised, excluded, powerless or worthless because of their colour, ethnicity, culture, faith community, national origin or national status.”
Under the Equality Act 2010, all public bodies have a duty to eliminate discrimination, promote and advance equality of opportunity and promote good race relations. Sexual, sexist, and transphobic bullying includes any behaviour, whether physical or non-physical, where sexuality is used as a weapon. Sexist bullying refers to bullying simply because of the victim’s gender, based on singling out something specifically gender linked. Transphobic bullying refers to bullying because someone is or thought to be transgender.
Homophobic bullying targets someone because of their sexual orientation (or perceived sexual orientation). For example, the term “gay” as an insult is unacceptable and should be challenged. Regulations made under the Equality Act 2010 outlaw discrimination on the grounds of sexual orientation.
Bullying against disabled people - bullying involving people with disabilities employs many of the same forms as other types of bullying. The Equalities Act 2010 makes it unlawful to discriminate against disabled people in the provision of facilities and service, and all public bodies have a duty to have regard to the need to eliminate discrimination on grounds of disability and promote positive attitudes towards disabled people.
What Is Harassment?
Harassment is when a person annoys or upsets someone else, usually repeatedly. It is done on purpose and makes the person feel scared or worried. It is unjustified and unwanted behaviour. It can be an isolated event or a series of events.
Conduct may be harassment whether or not the person intends to offend. Something intended as a "joke" may offend another person. Different people find different things acceptable; everyone has the right to decide what behaviour is acceptable to them and to have their feelings respected by others.
Behaviour that any reasonable person would realise would be likely to offend, will be harassment, without the recipient having to make it clear, in advance, that behaviour of that type is not acceptable to them.
Harassment is more formally defined as unwanted conduct related to a relevant protected characteristic, which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual. The relevant protected characteristics are age, disability, gender reassignment, race, religion, or belief,
sex, sexual orientation, marriage and civil partnership, and pregnancy and maternity. It may be related to any personal characteristic of the individual and may be persistent or an isolated incident.
The key is that the actions or comments are viewed as demeaning and unacceptable to the recipient. We take harassment to include any behaviour that is offensive, intimidating, or hostile; which interferes with individuals’ working or social environment, or which induces stress, anxiety, fear, or sickness on the part of the harassed person.
The defining features are that the behaviour is offensive or intimidating to the recipient and would be so regarded by any reasonable person.
It is important to note that differences of attitude, background, or culture and the misinterpretation of social signals can mean that what is perceived as harassment by one person may not seem so to another. The perception of the person complaining of harassment is, however, an important factor in determining whether or not bullying/harassment/victimisation has taken place.
Harassment may take many forms and involve more than one individual, both as the harasser and the victim. It can range from extreme forms such as violence and bullying, to less obvious actions such as ignoring someone at work.
Harassment can be in various forms such as peer to peer, group harassment or a staff member harassing a manager or vice versa. It may occur where the harasser has a position of authority (where a teacher, supervisor, or administrator is able to affect another person’s job, career, or grade) and relies upon the fact that the recipient(s) are reluctant to complain about fear of ridicule or reprisals.
What Is Victimisation?
Victimisation means punishing or threatening to punish someone or treating them less favourably and subjecting them to detriment (disadvantage).
To elaborate, victimisation is where a person is treated less favourably than other people, because, for example, that person has brought proceedings, given evidence, or complained about the behaviour of someone who has been harassing or discriminating again them.
We need to be confident that you are able to bring cases of bullying, harassment, and discrimination to the attention of management. In this respect we wish to offer reassurance to those who are considering registering a complaint, or to those with a claim in progress, that such victimisation will not be tolerated, and action will be taken against those who discriminate.
Examples of the types of behaviour or actions which could constitute bullying, harassment, or victimisation:
Behaviour that undermines a person’s work performance, working relationships, or perceived value in the workplace.
Persistent use of abusive, insulting, or offensive language.
Aggressive yelling or shouting.
Unwarranted physical contact or threatening gestures.
Making repeated negative comments about a person’s appearance, lifestyle, family, or culture.
Regularly inappropriately teasing or making someone the brunt of pranks or practical jokes.
Circulating inappropriate or embarrassing photos or videos via email or social media.
Unnecessarily interrupting or disrupting someone’s work; inappropriately interfering with a person’s personal property or work equipment.
Repeatedly discounting a person’s statements in group meetings; unfavourably comparing one person to others.
Blaming a person for problems they did not cause.
Taking credit for another’s contributions.
Spreading misinformation or malicious rumours.
Purposefully and inappropriately excluding, isolating, or marginalising a person from normal work activities.
Establishing unrealistic timelines, or frequently changing deadlines.
Denying access to information, consultation, or resources.
Giving feedback in an insincere or disrespectful manner.
• Repeatedly reminding someone of past errors or mistakes.
• Inconsistently following or enforcing rules, to the detriment of an employee.
• Ignoring an employee or isolating them from others.
• Denying equal access to earned time off.
• Overbearing supervision or other misuse of power or position
• Unwelcome sexual advances – touching, standing too close, display of offensive materials, asking for sexual favours, making decisions on the basis of sexual advances being accepted or rejected.
• Making threats or comments about job security without foundation.
• Deliberately undermining a competent worker by overloading and constant criticism.
• Preventing individuals progressing by intentionally blocking promotion or training opportunities.
• Unwelcome sexual remarks, such as jokes, innuendo, teasing and verbal abuse.
• The display of pin-ups, pornographic pictures of suggestive subject matter.
• Use of electronic media to send offensive messages or material.
• Copying memos that are critical about someone to others who do not need to know.
Always remember, bullying and harassment is not necessarily face to face, it may occur through written communication, visual images (for example pictures of a sexual nature or embarrassing photographs of colleagues), email, phone, and online.
Discrimination
What Is Discrimination?
Discrimination means treating a person unfairly because of who they are, or because they have certain characteristics.
The Equality Act was introduced in 2010, with the aim of providing employees with legal protection from discrimination in the workplace and in wider society. The Equality Act highlights 9 protected: characteristics:
• Age
• Gender
• Race
• Disability
• Religion
• Pregnancy and maternity
• Sexual orientation
• Gender reassignment
• Marriage and civil partnership
Discrimination that occurs because of one or more of the above characteristics is unlawful. Considering every person has at least some of these characteristics such as age, race, or gender, the Act protects every person from being discriminated against.
You are personally responsible for any acts of discrimination, harassment, or victimisation carried out by you during your employment, whether or not we are also liable. Ultimately, you can be held personally liable and could be ordered to pay costs and may also be subject to criminal proceedings.
Examples of the types of behaviour or actions which could constitute discrimination:
Not processing a job application because of someone’s age;
Not promoting someone because of their gender;
“jokes” or “banter” which knowingly offend;
Unwanted or offensive nicknames;
Demeaning comments about a person’s appearance;
Unwanted questions about personal life;
Unnecessary and degrading references to someone’s sexual orientation, gender identity, or their perceived sexual orientation or gender identity;
Inappropriate use of authority, job security threats;
Obscene gestures;
Abusing your position of power;
Displaying offensive material;
Isolation or non-co-operation at work;
Spreading malicious rumours;
Physical harassment / invading personal space intentionally;
Unwelcome sexual advances;
Not following procedure;
Deliberately excluding someone without good reason
Banter
Is Banter in the Workplace Acceptable?
This depends on the type of humour. Any banter which is of a personal nature, or is intended to embarrass or humiliate someone else, is not acceptable. Humour linked to appearance, personality, gender, gender identity, race, age, disability, sexual orientation, culture, or religion / religious belief is not acceptable. It is important that you consider any humour used and ensure any comments are not of a personal nature, offensive or likely to humiliate or embarrass another person.
It is important to be aware that, whilst you may believe that you and your colleagues understand and are happy with the levels of banter between you, it is important to remember that others who overhear the remark may be offended (even if it is not directed at them). Banter will not be an acceptable excuse for inappropriate conduct; therefore, any humour used must be acceptable and inclusive. You may be subject to disciplinary action for any inappropriate or unacceptable comments made.
Reporting Unacceptable Conduct
What Should You Do If You Think You Are Being Bullied, Harassed or Victimised?
If you think you are being bullied or harassed, then you may be able to resolve it informally; the person may not know that their behaviour is unwelcome or upsetting. You may feel able to approach the person yourself, or with the help of someone else at Pinehirst Education. You should tell the person what behaviour you find offensive and unwelcome and say that you would like it to stop immediately.
You should only attempt to resolve an issue informally and directly, if you feel able to remain calm and professional throughout the discussion, to avoid the situation escalating.
Should you feel unable to resolve the matter directly, then you should raise a ’Complaint’ via our Policy and process. This will lead to a triage assessment being undertaken, which will determine an appropriate approach for resolution; for example, your concerns may be able to be resolved via the Resolution Policy or, in more serious cases, your concerns may need to be investigated in accordance with the Disciplinary Policy .If your concerns relate to the conduct of any Manager at Pinehirst Education , then you can raise your concerns with your manager or a member of the Senior Leadership Team.
We will treat all complaints of bullying and harassment sensitively and will maintain confidentiality to the maximum extent possible. You have the right not to be victimised for making a complaint in good faith, even if the complaint is not upheld. However, making a complaint that you know to be untrue, may lead to disciplinary action being taken against you.
What Should You Do If You Witness Unacceptable Behaviour Towards Others?
It is of the upmost importance that any behaviour, which is observed, which is inappropriate, is reported. In failing to report incidents of unacceptable behaviour or conduct, you prevent us from fulfilling our duty of care and restrict our ability to oversee a fair and harmonious work environment.
You should report any incidents to your line manager or a member of the Management team- whoever you feel most comfortable speaking with.
Every effort will be made to support you and your identity will not be disclosed unnecessarily.
Ultimately, should you fail to report an incident, without good reason, then you could be subject to disciplinary action for stopping us in fulfilling our employment obligations.
Consequences of a Policy Breach
What Will Happen If You Are Found to Have Bullied, Victimised, Harassed or Discriminated Against Another Person?
Disciplinary action will be taken against you, if you have bullied, victimised, harassed, or discriminated against another person. The action taken will be dependent upon the seriousness of the misconduct, and this could lead to the termination of your employment.
We take a zero-tolerance approach to bullying, harassment, victimisation, or discrimination; therefore, you could be dismissed for a first offence or single incident - where your conduct is found to be in breach of the values and principles outlined in this policy.
Support
Reporting a Complaint:
Our Policy is to be used to address any concerns of bullying, harassment, or victimisation. A ‘request for complaint’ should be submitted to enable a triage assessment to be undertaken to identify the most appropriate approach for establishing a resolution.
We will treat all complaints sensitively and will maintain confidentiality to the maximum extent possible. If you have any worries or apprehensions, then you can speak with your manager for advice and support. your manager can help develop your understanding of the process and what will happen next. HR can agree how best to keep in touch with you, so that you are kept up to date on what’s happening. HR can also explore whether any supportive actions are required, in the interim, so that you feel comfortable whilst your concerns are being looked into.
A Pinehirst Education Officer can be appointed to provide support during this period and the benefits of this can be explained to you, early in the process, following notification of a complaint. The appointed person would be independent from the complaint and will be someone who could be approached to discuss any issues or concerns; they will also be someone to discuss and explore support with.
You may request referral to a counsellor at any time. The role of our internal counsellor is to provide support and assistance during this time. The counsellor has no role in formal investigations, and neither are they a source of evidence in any proceedings - since all discussions between counsellor and client are confidential. If both parties agree, then we may arrange mediation for the parties involved in an attempt to discuss the issue/s and conclude at an informal stage. If you would benefit from wellbeing assistance, your manager or appointee can discuss and signpost appropriate wellbeing support.
Allegations of Bullying, Harassment or Victimisation:
Equally, we appreciate that it can be a difficult and worrying time personally if allegations are made against you and you are waiting for a process to complete. Any concerns reported will be assessed by to determine the most appropriate route to resolution; this could be via the Complaints Policy or in cases of alleged serious misconduct, the Disciplinary Policy. All allegations of serious and unacceptable conduct must be investigated. The focus of any investigation will be to establish the facts in a fair, impartial, and considerate manner. Any outcomes reached will be fair, balanced, and proportionate.
Every effort will be made to complete the investigation as quickly as possible, to reduce any unnecessary worry, given that this will inevitably be a period of uncertainty.
An accusation of bullying/harassment/victimisation does not signify a judgement that you are guilty; we would wish to emphasise that there will be no pre-judgement following receipt of a complaint/ allegation.
A Pinehirst Education Officer can be appointed to provide support during this period and the benefits of this can be explained to you, early in the process, following notification of a complaint. The appointed person would be independent from the complaint and will be someone who could be approached to discuss any issues or concerns they will also be someone to discuss and explore support with.
You may request referral to a counsellor at any time. The role of our internal counsellor is to provide support and assistance during this time. The counsellor has no role in formal investigations, and neither are they a source of evidence in any proceedings - since all discussions between counsellor and client are confidential.
If both parties agree, then we may arrange mediation for the parties involved in an attempt to discuss the issue/s and conclude at an informal stage.
If you would benefit from wellbeing assistance, HR can discuss and signpost appropriate wellbeing support. We will do our upmost to consider the feelings of all parties involved, whilst overseeing the fair application of the process.
Malicious Allegations & False Statements
Unfounded allegations of bullying and harassment/victimisation for malicious reasons will not be tolerated. Any such cases will be investigated and dealt with under our Disciplinary Policy and may be serious enough to constitute gross misconduct, which may result in summary dismissal.
Where a witness is found to have deliberately misled an investigation, we will treat this as a serious disciplinary offence.
In such cases any reports of investigations will be transferable for the purpose of any further action.
Confidentiality/ Record Keeping
Equality and dignity proceedings are confidential between you, the College, and your trade union representative or workplace colleague. Any information made available during the proceedings must not be shared with anyone except those directly involved.
All documentation will be treated as personal data and only shared where it is appropriate to do so. We collect and process personal data relating to our employees’ conduct to manage the employment relationship. We have a ‘legal obligation’ and ‘legitimate interest’ in processing your personal data under this procedure, as this allows us to ensure compliance with employment legislation.
Equality and dignity at work records will be retained as follows:
• 12 months post-employment
Equality and dignity at work information will be retained on your personal file. Information will also be retained on your electronic personal file, which is held in a secure location only accessible by the Director of Curriculum.
Monitoring
Each policy will be subject to internal audits and reviews. By carrying out an audit it enables us to identify whether the processes and documentation are being followed or if other improvements can be made. This is to ensure that the process is being followed and that it remains the most suitable and applicable process for use by Pinehirst Education.
All Pinehirst Education Policies are subject to screening for Equality Impact Assessment
Equality Impact Assessments are carried out to see whether the policy has, or is likely to have, a negative impact on grounds of age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, marriage or civil partnership, sex, or sexual orientation.
Pinehirst Education not only fulfils its legal position in relation to current and future equality legislation, but additionally goes beyond compliance in providing and promoting “Opportunities for all to succeed”, free from any aspect of discrimination, harassment, or victimisation.
All staff have a duty of care to look after the interests of and support their colleagues. This policy takes account of our commitment to eliminating discrimination, identifying, and removing barriers and providing equal opportunities for our learners, staff, and visitors to ensure that no one feels excluded or disadvantaged.
Safeguarding, Child Protection, Prevent and Missing from Education
All staff have a responsibility to support and promote Pinehirst Education Education’s commitment to providing a safe environment for students, staff, and visitors. Additionally, all staff have a responsibility to report any safeguarding or Prevent issues to the Designated Senior Lead for Safeguarding and Prevent.
• Disciplinary Policy and Process
• (Students) Disciplinary Policy and Process
• (Staff) Investigation Policy and Process Assessment Policy
• Whistle Blowing Policy
• Open Awards Malpractice and Maladministration Policy and Process
• Complaints Process