Whistleblowing Policy

⚠️ LEGAL / HR CONTENT — REQUIRES REBUILD AND HUMAN SIGN-OFF — the source school's group guarantees, external hotline contract and UK/EU data-transfer wording do not transfer; every such fact below is a placeholder for AFS to supply.

DOCUMENT CONTROL

Table of Contents

1. Introduction
2. Audience & Scope
3. Aims of the Policy
4. Purpose of the AFS Whistleblowing Policy
5. How to Raise a Concern
6. How the School Will Handle the Concern
7. Raising a Concern Outside the School
8. Confidentiality
9. Right of Information and Right of Access
10. Protection Against Retaliation
11. Complaints
12. Untrue Allegations
13. Relevant Data
14. Keeping Records
15. Sharing of Data
16. Status of this Policy

1.0 Introduction

1.1 Al Fajer Private School (AFS) is committed to safeguarding and promoting the welfare of children and expects all staff, volunteers, students and visitors to share this commitment.

1.2 All outcomes generated by this document must take account of, and contribute to, safeguarding and promoting the welfare of children at the school.

1.3 This policy enables members of staff to raise concerns internally and in a confidential fashion about fraud, corruption, serious malpractice, health and safety, criminal offenses, miscarriages of justice, failure to comply with legal obligations, inappropriate behavior or unethical conduct.

1.4 AFS is committed to the highest possible standards of openness and accountability. In line with that commitment, we encourage employees who have serious concerns about any aspect of the school's work to come forward and voice those concerns. AFS acknowledges that raising a concern about a colleague is challenging for staff, but asks that staff remember that their colleague could be struggling to cope, and alerting senior staff will enable us to put any necessary support and guidance in place.

2.0 Audience & Scope

This policy applies to all permanent and temporary employees, agents and contractors. It is intended to complement the protections available under Bahraini law and the school's other policies and, for the avoidance of doubt, no legal rights are affected in any way by this policy. [NEEDS AFS INPUT: Bahrain employment counsel to confirm the legal protections available to whistleblowers in Bahrain — the source policy assumed UK statutory protection, which has not been carried over] For the purposes of this policy, the reporting employee is also referred to as the "whistleblower" and the reported person or persons as the "person(s) concerned."

3.0 Aims of the Policy

In its pursuit of excellence, AFS is committed to the highest standards of openness, honesty and accountability, and takes all malpractice very seriously, whether it is committed by an employee, supplier, client, competitor or contractor. AFS believes that a culture of openness and accountability is essential in order to prevent such situations from occurring, or to address them when they do.

3.1 The policy on whistleblowing is intended to demonstrate that AFS:

3.1.1 has a culture of safety for raising concerns, valuing staff and reflective practice;

3.1.2 will not tolerate malpractice;

3.1.3 respects the confidentiality of employees raising concerns and will provide procedures to maintain confidentiality so far as is consistent with progressing the issues effectively;

3.1.4 will provide the opportunity to raise concerns outside of the standard line-management structure where this is appropriate;

3.1.5 will invoke the school's disciplinary procedures [NEEDS AFS INPUT: AFS equivalent policy — a Disciplinary Policy is not in the current AFS policy set] in the case of false, malicious, vexatious or frivolous allegations;

3.1.6 will provide a clear and straightforward procedure for raising concerns, which is accessible to all employees.

3.2 To encourage staff to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected wherever possible.

3.3 To provide staff with guidance as to how to raise those concerns.

3.4 To reassure staff that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.

4.0 Purpose of the AFS Whistleblowing Policy

4.1 Employees will usually be the first to know when someone inside or connected with AFS is doing something illegal, dishonest or improper, but may feel apprehensive about voicing their concerns. AFS does not believe that it is in anyone's interests for employees with knowledge of wrongdoing to remain silent.

4.2 We wish to encourage a working environment where employees feel comfortable about highlighting malpractice. If you have reasonable concerns or suspicions that malpractice is taking place, or is likely to take place, within our workplace, we would encourage you to raise this in accordance with the process below. We believe everyone should feel able to disclose concerns and "speak up" (whistleblow) safe in the knowledge that the issue will be investigated, with no adverse impact on themselves. This whistleblowing procedure has been set up to give everyone this comfort if you believe that there has been, or continues to be, serious malpractice or wrongdoing which the school should be aware of.

4.3 All AFS employees may, in adequately carrying out their duties, have access to, or come into contact with, information of a confidential nature. Contractual terms and conditions provide that, except in the proper performance of duties, employees are forbidden from disclosing, or making use of, in any form whatsoever, such confidential information.

4.4 AFS does, however, adopt this policy on disclosing in the public interest, i.e. whistleblowing, to enable members of staff to raise concerns internally and in a confidential fashion about fraud, malpractice, health and safety, criminal offenses, miscarriages of justice, and failure to comply with legal obligations, inappropriate behavior or unethical conduct. The policy also provides, if necessary, for such concerns to be raised outside the school.

4.5 This procedure is separate from the school's adopted policies regarding grievances [NEEDS AFS INPUT: AFS equivalent policy — a Grievance Policy is not in the current AFS policy set]. Employees should not use the whistleblowing procedure to raise grievances about their personal employment situation. This procedure is to enable employees to express a legitimate concern regarding suspected malpractice within the school, and potential failures in the school's safeguarding regime; these concerns should be in the public interest.

4.6 People working within organizations are often the first to realize that there may be something seriously wrong in the place in which they work. They may be wary of expressing concerns because they feel that to do so would be disloyal to their colleagues or to their school. They may also fear harassment or victimization. In these circumstances, it may feel more comfortable to ignore the concern rather than report what may be a suspicion of malpractice.

4.7 Malpractice is not easily defined; however, it includes allegations of fraud, financial irregularities, corruption, bribery, dishonesty, acting contrary to the staff code of conduct, criminal activities, or failing to comply with a legal obligation, a miscarriage of justice, or creating or ignoring a severe risk to health, safety or the environment.

4.8 Employees who wish to raise a concern under this procedure are entitled to have the matter treated confidentially, and their name will not be disclosed to the alleged perpetrator of malpractice without their prior approval. It may be appropriate, to preserve confidentiality, that concerns are raised orally rather than in writing; however, employees are encouraged to express their concern in writing wherever possible. If there is evidence of criminal activity, the Police will be informed.

4.9 Victimization or harassment of anyone using this policy, or any attempt to discourage others from coming forward, will be deemed to be a disciplinary matter.

5.0 How to Raise a Concern

5.1 If you become aware of any such activities or other possible malpractice, and do not feel that you can raise this with your line manager or through the normal routes, or believe that due to the serious nature of the issue it is not appropriate, you are encouraged to follow the process set out below, which is called whistleblowing. It will not always be clear that a particular action falls within one of these categories, and so you will need to use your own judgment. However, if you believe the matter to be serious, AFS would prefer you to report your concerns by speaking up rather than keeping them to yourself.

5.2 In raising a concern through this process, AFS does not expect you to have absolute proof of any malpractice that you report; however, you will need to be able to explain the reasons for your concern, and you must have reasonable grounds on which to base any allegation related to the types of examples listed as serious malpractice above. AFS will not tolerate spurious, abusive, vexatious or malicious allegations, and disciplinary action may be taken against you under the relevant disciplinary processes.

5.3 Employees are at liberty to express their concerns to their line manager. If this is not appropriate, they should contact the Principal or the staff member responsible for human resources [NEEDS AFS INPUT: AFS HR structure — role and contact]. Should the allegation be of a safeguarding nature, the concern should be raised directly with the Principal or the school's Designated Safeguarding Lead (DSL) [NEEDS AFS INPUT: name and contact details of AFS's designated safeguarding lead and deputy].

5.4 Wherever possible, concerns should be raised in writing. If the employee makes a written report, the school recommends that they include the background and history (giving relevant dates) and provide the reason why they are particularly concerned about the matter.

5.5 If the employee has a concern about any financial loss or irregularity, they should raise this directly with the member of staff responsible for school finances [NEEDS AFS INPUT: AFS finance lead — role and contact].

5.6 This procedure is separate from the school's procedures regarding grievances. Employees should not use the whistleblowing procedure to raise grievances about their employment situation; instead, this procedure is to enable staff to express a legitimate concern regarding suspected malpractice within AFS.

6.0 How the School Will Handle the Concern

6.1 Please note that this whistleblowing process is not a replacement for any grievance, appeal, safeguarding or other school policies or processes. Any grievance about you personally should be raised under a grievance procedure in the first instance; please speak to your line manager for further information about this. The following process should only be followed if you have reasonable grounds to suspect serious malpractice or wrongdoing.

6.1.1 Step One – Raising a Concern (Whistleblowing)

6.1.1.1 The first step in most instances should always be to follow any school policies and procedures that exist with regard to raising a concern or a safeguarding issue. Typically, in the first instance, you should raise your concern with your line manager, who will then raise the matter, confidentially, with the Principal or the relevant member of the school leadership team, who will request a meeting with you in order to ascertain the key facts of the concern.

6.1.1.2 If you are not comfortable reporting your concern to your line manager, or to anyone else through any existing policy or process, or you wish to raise your concern anonymously, you should raise your concern through the school's confidential reporting channel. [NEEDS AFS INPUT: AFS confidential reporting channel — the source school contracted an independent third-party hotline; AFS must designate its own channel (internal or externally operated), and publish here how to contact it, in which languages, and how anonymous reports are handled]

6.1.1.3 The confidential reporting channel must ensure the confidentiality of the identity of reporting persons and of others mentioned in the report.

6.1.1.4 However, it is strongly recommended that, where possible and where they are comfortable to do so, individuals give their names and details to enable AFS to conduct a thorough investigation.

6.1.2 Step Two – Recording of the Details

6.1.2.1 When you report your concern through the confidential reporting channel, you will be given a reference for your report which you need to keep safe in order to receive feedback [NEEDS AFS INPUT: how the designated channel issues report references and returns feedback]. Please provide as much information as you are able, and include:

6.1.2.1.1 the date of your report;

6.1.2.1.2 your name, work location and your line manager;

6.1.2.1.3 details of the suspected malpractice, including: dates, times, people, places and location.

6.1.3 Step Three – Investigating the Details

6.1.3.1 Once your concern has been reported through the confidential reporting channel, it will be escalated to an appropriately nominated and impartial individual designated by the school's governance body [NEEDS AFS INPUT: AFS governance body — who receives and acts on reports made through the confidential channel; the source policy escalated these to a group-level officer, which does not transfer], who will act on it without compromising any individual. If you have raised your concern with the Principal or a member of the school leadership team, this will trigger a number of steps to ascertain the details directly with you in line with the current processes.

6.1.3.2 In all cases, AFS will endeavor to acknowledge receipt of your concern within 5 working days.

6.1.3.3 Preliminary inquiries will be made by an independent senior manager as confidentially as possible. If it is determined that a fuller investigation is necessary, this will proceed either with further internal investigation or by referral to the appropriate external body, dependent upon the nature and seriousness of the report.

6.1.3.4 The investigation process may include interviews with you and with anyone who might be involved in the suspected malpractice. Our aim is to ensure that any investigation is as proportionate and independent as possible, while always maintaining confidentiality and anonymity where possible.

6.1.4 Step Four – Taking Action

6.1.4.1 A high-level summary record of any incident registered through whistleblowing will be held by the Principal and the staff member responsible for human resources [NEEDS AFS INPUT: AFS HR structure]. Possible results of the investigation process may include:

6.1.4.1.1 no further action;

6.1.4.1.2 disciplinary action (under the school's disciplinary procedures);

6.1.4.1.3 further investigation by an external authority, only where appropriate.

6.1.4.2 Subject to any legal and confidentiality constraints, AFS will communicate the findings of the investigation to:

6.1.4.2.1 the person raising the report or issue;

6.1.4.2.2 the individual(s) under investigation (if appropriate); and

6.1.4.2.3 if appropriate, those members of the school's leadership or governance, or external authorities, who need to consider whether action should be taken on the basis of the findings.

6.1.4.3 Cases relating to suspected criminal activity, including but not limited to fraud, will be reviewed by the Principal together with the member of staff responsible for school finances and the staff member responsible for human resources [NEEDS AFS INPUT: AFS finance and HR roles] to decide whether they should be referred to the Police or other relevant authority. If you are unhappy about the outcome of an investigation, you have the option to make a further report, which will be investigated, but only if there is good reason to do so or there is new evidence, and not for any inappropriate reason listed in section 4.

6.1.4.4 Any concerns raised will be investigated thoroughly and promptly, and appropriate corrective action will be pursued. The employee making the allegation will be kept informed of progress wherever possible and, subject to third-party rights, will be notified of the outcome.

6.1.4.5 An employee who is not satisfied that their concern is being properly dealt with has the right to raise it in confidence with the Principal. If the concern involves the Principal, it may be raised in confidence with the school's governance body [NEEDS AFS INPUT: AFS governance body — role and contact].

6.1.4.6 If urgent action is required, this may be taken before any investigation is conducted.

7.0 Raising a Concern Outside the School

7.1 The school hopes that this policy gives you the confidence to raise your concern within the school through the routes in sections 5 and 6. If you feel unable to do so, the school would prefer that you raise your concern with the school's governance body or the relevant Bahraini authority rather than not at all.

7.2 It should be noted that there are circumstances where an employee may be entitled to raise a concern directly with an external body, where the employee reasonably believes that:

• it is justified by exceptionally serious circumstances;
• the school would conceal or destroy the relevant evidence;
• they would be victimized by the school; or
• the relevant statutory, regulatory or enforcement authorities have ordered it.

7.3 If the employee acts in good faith and genuinely and reasonably believes that the malpractice falls within the remit of an external authority, and that the information disclosed is substantially true, the employee should report the matter to the Principal, to the school's governance body, or to the relevant Bahraini authority. [NEEDS AFS INPUT: which Bahraini authorities are the appropriate external recipients for each category of concern (e.g., safeguarding, financial, labor, data protection) — the source policy relied on a UK "prescribed person or body" regime, which has not been carried over; Bahrain counsel must confirm]

8.0 Confidentiality

8.1 This policy encourages everyone directly or indirectly employed by AFS to put their name to any disclosure they make, and to avoid anonymous disclosures where serious malpractice is suspected. It is recommended that all issues raised through this process are raised openly, because concerns expressed anonymously are sometimes less easy for AFS to investigate thoroughly.

8.2 AFS will protect your identity at all times. Unless there are exceptional circumstances, the reported person(s) has the right to know about any whistleblowing issue raised, but your identity as a reporting employee will not be disclosed to the reported person under any circumstance unless you have expressly consented or such disclosure is required by law. This duty also applies to any information from which the identity of the reporting person can be deduced.

8.3 The records will be kept confidential, and the school and its governance body [NEEDS AFS INPUT: AFS governance body — the source policy relied on a group-level guarantee, which does not transfer] guarantee the prohibition of retaliation against the reporting employee in any form, including threats or attempts of retaliation.

8.4 In addition to providing protection to reporting employees, AFS will also implement measures for the protection of "persons concerned" who are referred to in a report or public disclosure as persons to whom the breach can be attributed. These persons are guaranteed the right to an effective remedy, a fair hearing, the presumption of innocence, and the rights of defense, including the right to be heard and the right to access the file. The same protection of identity extended to reporting persons must also be extended to the identity of persons concerned.

8.5 Reports containing personal data will be shared only with those who need to have access to the data for the purposes of investigating the allegations or for taking follow-up measures, under appropriate confidentiality and security safeguards.

8.6 If there is evidence of criminal activity, the Police will, in all cases, be informed.

9.0 Right of Information and Right of Access

9.1 Your right to information about any investigation and any action taken in relation to your concern, as well as the possible recipients of the report, will be guaranteed at all times.

9.2 You can also exercise your right to access and rectify incorrect, incomplete or outdated personal data, or to have your data erased. These rights are exercised in accordance with Bahrain's Personal Data Protection Law (PDPL, Law No. 30 of 2018). [NEEDS AFS INPUT: confirm with legal counsel that the PDPL is the data-protection basis governing AFS whistleblowing records — the source policy reflected UK/EU data-protection law, which has not been carried over]

9.3 Your rights may be limited only to ensure the protection of the rights and freedoms of others affected by the reporting, or where processing is required to comply with a legal obligation. Persons concerned have the right to object to the processing of their personal data in the context of a report, subject to the school's or a third party's legitimate interest.

10.0 Protection Against Retaliation

If any person raises a malpractice concern, this will be taken seriously, and such person(s) will be treated fairly and with discretion. All staff have a responsibility to ensure that their colleagues are not subjected to detrimental treatment as a result of disclosing malpractice. Where an individual has disclosed malpractice and is then penalized in some way for doing so, both the school, as the employer, and the person taking the detrimental action may be liable, and any individual who penalizes a colleague for disclosing malpractice will face disciplinary proceedings. [NEEDS AFS INPUT: Bahrain employment counsel to confirm the liability and compensation framing under Bahraini law — the source policy stated a personal-compensation rule drawn from UK law, which has not been carried over]

11.0 Complaints

If you are unhappy with the outcome of an investigation, you should submit another report explaining why this is the case. Your concern will be investigated again if there is a good reason to do so.

12.0 Untrue Allegations

12.1 False, malicious, vexatious or frivolous accusations will be treated as gross misconduct and dealt with under the school's disciplinary procedures.

12.2 If an employee makes an allegation in good faith, but the evidence produced during the investigation does not substantiate it, no action will be taken against them. If, however, an employee makes an allegation maliciously or for personal gain, this may result in disciplinary action being taken against them.

12.3 No employee will suffer a detriment or be disciplined for raising a genuine and legitimate concern, provided that they do so in good faith and follow the whistleblowing procedures.

13.0 Relevant Data

We will not process more personal information than necessary. The school will only collect the information relevant to the particular case: it will carry out an initial check of the information reported, and only the relevant data will be kept.

14.0 Keeping Records

Records will be kept for no longer than is necessary and proportionate to comply with the requirements imposed by this Whistleblowing Policy. The school will take all reasonable technical and organizational measures to preserve the security of personal data that are part of a whistleblowing report. These records will be protected from accidental or unlawful destruction, accidental loss, and unauthorized disclosure or access.

15.0 Sharing of Data

Personal data is shared only with those who need to have access to the data for the purposes of investigating the allegations or for taking follow-up measures. Anyone receiving such data must ensure that it is handled confidentially and subject to data-security safeguards.

Whistleblowing reports are handled within the school. If the investigation of a report requires personal data to be shared outside the school — for example with external investigators, professional advisers or the relevant Bahraini authorities — the school will comply with the PDPL (Law No. 30 of 2018), including its requirements governing any transfer of personal data outside the Kingdom of Bahrain. [NEEDS AFS INPUT: confirm with legal counsel whether any cross-border sharing scenario exists for AFS and the PDPL safeguards that apply — the source policy contained group-level UK/EU data-transfer wording, which has not been carried over]

16.0 Status of this Policy

This policy is not part of any contract of employment and does not create contractual rights or obligations. It may be amended by the school at any time. [NEEDS AFS INPUT: AFS governance body — who holds the authority to amend this policy]

If you require guidance or support with the details of this policy or compliance with it, or are unsure about any part of the policy, please contact the Principal and/or the staff member responsible for human resources [NEEDS AFS INPUT: AFS HR structure].