Public interest disclosure procedure
Making a disclosure
(1) The employee should make the disclosure to the designated person.
(2) The designated person is the Registrar in his/her capacity as the Secretary to the Council of the University. If the disclosure is about the Registrar, then the disclosure should be made to the Vice-Chancellor. If the disclosure is about the Vice-Chancellor, then the disclosure should be made to the Chair of the Council of the University.
(3) Upon receipt of a disclosure under this Procedure, the designated person will immediately inform the Vice-Chancellor and Chair of the Council in writing.
Investigation of disclosures
(4) The designated person will consider the information made available to him/her and decide on the form of investigation to be undertaken. This may be:
- to investigate the matter internally or arrange for the issues to be investigated independently of the University;
- to refer the matter to the police;
- to refer the matter to an interested external body (eg Funding Council or Research Council).
In appropriate circumstances, the designated person may decide that more than one of these actions is necessary.
(5) Where the matter is to be the subject of an internal investigation or where the matter is to be investigated independently of the University, the designated person will:
- appoint a senior manager, the University’s Internal Auditor or an appropriate person independent of the University (or an investigation team) to undertake the investigation;
- determine the terms of reference of the investigation;
- determine any other parameters or procedures to be followed, including timescale, which may be necessary to the investigation.
(6) Investigations should not be carried out by the person who will have to reach a decision on the matter either under this Procedure or any subsequent procedures which may be invoked.
(7) The University will seek to conduct the investigation as sensitively and speedily as possible.
(8) As part of the investigation, the person(s) against whom the disclosure is made will be told of it, the evidence supporting it and will be allowed to comment.
(9) The person(s) conducting the investigation will submit a written report of their findings and (where appropriate) recommendations to the designated person.
Outcomes of the investigation
(10) Following consideration of the report of the investigation, the designated person may:
- invoke the appropriate Disciplinary Procedure;
- refer the matter to the police;
- refer the matter to an interested external body (eg Funding Council or Research Council);
- review and modify appropriate University Procedures, taking account of any recommendations made in the report of the investigation;
- make a recommendation or instruction to a manager;
- take no action.
Reporting of outcomes
(11) Subject to data protection standards, the designated person will inform the employee making the disclosure in writing of what action, if any, is to be taken. If no action is to be taken then the employee concerned should be informed of the reason for this.
(12) If no action is taken, the employee may, within 14 days of receipt of the notification from the designated person, submit a written request to the Chair of the Audit Committee (if the issue falls within the purview of that Committee) or the Chair of the Council of the University that the decision be reviewed. The employee’s request should explain why they are dissatisfied with the outcome of the investigation of their concern. The Chair of the Audit Committee/Chair of the Council will consider the information considered by the investigation, the procedures that were followed and the reasons for not taking any further action. The outcome of this will be either to confirm that no further action is required or to decide that further investigation is required in accordance with the procedures referred to under ‘Investigation of Disclosures’ above.
(13) A report of all disclosures and any subsequent actions taken will be made by the designated person, who will (subject to data protection standards) retain such reports for at least three years. In all cases a report of the outcomes of any investigation will be made to the Audit Committee: in detail where the issue falls within the purview of the Committee, and in summary in other cases as a means of allowing the Committee to monitor the effectiveness of the Procedure.
- Registrar (the designated person) - email Registrar@exeter.ac.uk or write to Registrar, Northcote House, University of Exeter, Exeter EX4 4QJ
- Vice-Chancellor - email Vice-Chancellor@exeter.ac.uk or write to Vice-Chancellor, Northcote House, University of Exeter, Exeter EX4 4QJ
- Chair of the Audit Committee - write to Chair of Audit Committee, c/o Executive Suite, Northcote House, University of Exeter, Exeter EX4 4QJ
- Chair of the Council of the University - write to Chair of Council, c/o Executive Suite, Northcote House, University of Exeter, Exeter EX4 4QJ
- University multi-faith Chaplaincy team: http://as.exeter.ac.uk/support/chaplaincy/
Revised and agreed by the Vice-Chancellor’s Executive Group, November 2010