1. Purpose of this Procedure

1.1 This Procedure sets out how whistleblowing concerns raised under the University of Bath’s Whistleblowing (Public Interest Disclosure) Policy are handled in practice.

1.2 It explains:

• How disclosures are received and assessed;
• How decisions are made about next steps;
• How investigations are conducted;
• How whistleblowers are supported; and
• How outcomes and learning are managed.

1.3 This Procedure supports and should be read alongside the Whistleblowing Policy and relevant linked policies. The definitions in the Policy apply to this Procedure.

1.4 The University aims to handle whistleblowing concerns in a timely and proportionate manner. Indicative timeframes are set out in this Procedure, although these may vary depending on the nature and complexity of the concern.

2. Key Roles

2.1 Whistleblowing Officer The University Secretary & Registrar acts as the Whistleblowing Officer and will ensure that disclosures are handled impartially and, where appropriate, that independent investigators are appointed. The Whistleblowing Officer has overall responsibility for:

• Receiving and overseeing whistleblowing disclosures;
• Ensuring appropriate triage and handling;
• Appointing investigators;
• Ensuring protections for whistleblowers;
• Reporting themes and providing assurance to the Audit & Risk Assurance Committee.

2.2 Deputy / Alternative Contacts The Whistleblowing Officer retains the right to delegate responsibility for the handling of a whistleblowing disclosure to an alternative senior governance contact.

Where a disclosure involves, or could reasonably be perceived to involve, the Whistleblowing Officer, or where an individual does not feel comfortable raising a concern through the usual routes, an alternative senior governance contact will assume responsibility or disclosures may be made directly to the Chair of the Audit & Risk Assurance Committee.

2.3 Investigating Officer(s) Investigations will be carried out by individuals with appropriate expertise and no conflict of interest. This may include internal staff or external specialists.

2.4 Audit & Risk Assurance Committee (ARAC) ARAC provides oversight of the effectiveness of whistleblowing arrangements and receives assurance reporting.

3. Making a Disclosure

3.1 Disclosures may be made:

• Verbally or in writing;
• Openly, confidentially, or anonymously.

3.2 A disclosure should include, where possible:

• The nature of the concern;
• Relevant dates, locations, and parties;
• Any supporting evidence;
• Whether the concern has been raised previously.

3.3 Where appropriate, individuals may choose to raise concerns in the first instance with their line manager or another appropriate member of staff, particularly where the issue may be capable of informal resolution.

3.4 However, individuals may raise a concern directly with the Whistleblowing Officer at any stage, particularly where:

• The matter is serious or sensitive;
• The concern relates to their line manager or local area; or
• They do not feel comfortable raising it through local channels.

3.5 Anonymous disclosures will be considered and assessed on their merits. The University will take all reasonable steps to investigate concerns raised anonymously where sufficient information is provided. However, anonymity may limit the University’s ability to seek further information, fully investigate the concern, or provide feedback on the outcome. Individuals are therefore encouraged, where possible, to provide contact details so that appropriate follow-up can be undertaken.

3.6 Contact details are set out in section 15 of this Procedure.

4. Receipt and Acknowledgement

4.1 All disclosures received under this Procedure will be logged securely.

4.2 Where contact details are provided, the whistleblower will normally receive acknowledgement within 5 working days of the allegation being received.

4.3 The whistleblower will be informed of:

• Who is handling the concern;
• The next steps in the process;
• Expected timescales, where possible.

5. Initial Assessment (Triage)

5.1 The Whistleblowing Officer will carry out an initial assessment to determine:

• Whether the disclosure falls within the scope of the Whistleblowing Policy;
• Whether there is a public interest element;
• Whether there is sufficient information to proceed;
• The appropriate route for handling the concern.

5.2 As part of the initial assessment, the Whistleblowing Officer may wish to meet with the person making the allegation to further discuss their concerns and where possible obtain evidence; and following the meeting, will provide them with an agreed written summary of the concern.

5.3 The initial assessment will normally be completed within 10 working days of acknowledgement of the disclosure. Where this is not possible, the whistleblower will be informed of the revised timeframe where appropriate.

5.4 Following assessment, the concern will be:

• Accepted for investigation in accordance with section 7 of this Procedure; or
• Referred to another policy or process in accordance with section 6 of this Procedure; or
  • Closed with reasons recorded.

5.5 Where a concern is redirected, the whistleblower will be informed of the rationale and, where appropriate, advised of the alternative route.

5.6 The whistleblower will normally be informed of the outcome of the initial assessment and next steps, subject to confidentiality constraints.

5.7 Anonymous disclosures will be subject to the same initial assessment criteria as all other disclosures.

6. Referral to Other Procedures

6.1 Some concerns may be more appropriately handled under other University policies and procedures, including:

• Staff disciplinary procedures;
• Dignity and respect policy and related procedures;
• Research misconduct procedures;
• Health and safety or safeguarding procedures;
• Grievance procedures.

6.2 Referral does not invalidate whistleblowing protections where the original disclosure was made with a reasonable belief that it is true and in the public interest. Where a concern is redirected, appropriate steps will be taken to ensure that confidentiality, protection from detriment, and oversight arrangements continue to apply.

7. Investigation

7.1 Where an investigation is required, the Whistleblowing Officer will appoint an Investigating Officer and set clear terms of reference.

7.2 Investigations will:

• Be conducted independently and impartially;
• Be proportionate to the concern raised;
• Respect confidentiality and data protection requirements.

7.3 The Investigating Officer may:

• Gather documents and records;
• Interview relevant individuals;
• Seek specialist advice.

7.4 Investigations will normally be completed within a reasonable timeframe, usually within 8-12 weeks. While timescales will vary depending on the complexity and nature of the concern, the whistleblower will be provided with periodic updates where appropriate.

8. Support and Protection During the Process

8.1 The University is committed to ensuring that whistleblowers do not suffer detriment or retaliation as a result of raising a concern with a reasonable belief that the information disclosed is true and in the public interest. Individuals may seek advice and support when making a disclosure, including from Student Support & Safeguarding, Trade Unions, or the SU Advice & Support Service. Any such behaviour will be taken seriously and addressed promptly.

8.2 Support may include:

• Confidentiality measures;
• Adjustments to working or study arrangements;
• Access to wellbeing or support services including: for students, Student Support & Safe

8.3 Any concerns about retaliation should be reported immediately and will be addressed promptly.

8.4 Individuals may also seek independent advice from Protect, the UK whistleblowing charity, which provides confidential and impartial guidance on raising concerns in the public interest. Further information is available via their website.

8.5 Individuals who are the subject of a concern will also be treated fairly and with respect throughout the process. Where appropriate, they will be informed of the concern and provided with access to appropriate support, including wellbeing or support services, in line with the principles of natural justice and procedural fairness.

8.6 Individuals raising a concern, and those who are the subject of a concern, may be accompanied at meetings under this Procedure by a colleague, Trade Union representative, Students’ Union adviser, or other appropriate supporter. Any accompanying person must respect the confidentiality of the process.

9. Investigation Outcomes

9.1 At the conclusion of an investigation, a report will be produced setting out:

• Findings;
• Conclusions:
• Recommendations, where appropriate.

9.2 Possible outcomes include:

• No further action;
• Recommendations for improvement;
• Referral for action under other procedures;
• Escalation to senior management or governance bodies.

9.3 The whistleblower will normally be provided with a summary of the outcome, within 10 working days of the conclusion of the investigation, subject to confidentiality and legal constraints.

10. Review of Handling

10.1 Whistleblowing does not provide a right of appeal against outcomes.

10.2 A whistleblower may request a review of the handling of their disclosure where they reasonably believe:

• The Procedure was not followed;
• There was a conflict of interest or bias;
• New material information has emerged.

10.3 Reviews will be conducted internally, in the first instance, by a senior individual independent of the original handling.

10.4 Requests for review should normally be submitted to the University Secretary & Registrar, or where there is a conflict of interest, to the Chair of Audit & Risk Assurance Committee within 10 working days of the outcome being communicated. Requests submitted outside of this timeframe will normally only be considered where exceptional circumstances are demonstrated and explained in the request for review.

10.5 The availability of an internal review does not prevent a whistleblower from raising their concerns with an appropriate external body.

11. Record-Keeping and Confidentiality

11.1 Secure records will be kept of:

• Disclosures;
• Decisions;
• Investigations;
• Outcomes.

11.2 Records will be retained in accordance with the University's records retention schedule and data protection requirements.

12. Malicious or Bad-Faith Disclosures

12.1 Disclosures made with a reasonable belief that the information is true and in the public interest, will be supported, even where they are not upheld following investigation.

12.2 Where there is clear evidence that a disclosure has been made with deliberate intent to mislead, including fabrication of information, this may result in action under relevant disciplinary procedures.

13. Reporting and Oversight

13.1 The Whistleblowing Officer will provide an annual report to the Audit & Risk Assurance Committee, including:

• Number and types of disclosures;
• Themes and systematic issues;
• Actions taken;
• Assurance on the effectiveness of arrangements.

13.2 Reports will not include information that could identify individuals.

13.3 The University may publish anonymised thematic information and organisational learning arising from whistleblowing disclosures.

14. Review of this Procedure

14.1 This Procedure will be reviewed periodically to ensure it remains effective, compliant, and aligned with best practice.

14.2 Minor operational updates may be approved by the University Secretary & Registrar; material changes will be approved through appropriate governance routes.

This Procedure supports the University's commitment to integrity, transparency, and responsible governance. Reasonable adjustments and accessible formats will be made available to support individuals engaging with this Procedure.

15. Contacts