Introduction

1.1 Purpose of this Policy

Providence English Private School (PEPS) is committed to the highest standards of openness, honesty and accountability. This policy sets out how a member of staff, or anyone else working with or on behalf of the school, can raise a genuine concern about suspected wrongdoing, safely and without fear of being treated unfairly for doing so.

1.2 Scope

This policy applies to all staff, contractors, volunteers and governors of PEPS. It covers concerns about suspected wrongdoing within the school that go beyond a personal grievance or a routine complaint (see Section 5).

1.3 Our Statement of Intent

Legal Context

Whistleblowing is not yet the subject of a single, comprehensive federal law in the United Arab Emirates outside of certain financial free zones, which do not apply to PEPS. This policy is written to provide protections for genuine concerns that go beyond the current minimum legal position, drawing on the following relevant UAE law:

• The UAE Penal Code (Federal Decree-Law No. 31 of 2021), which places a general obligation on individuals to report criminal conduct, and provides a degree of protection for good-faith reporting.
• UAE Labour Law, which provides protection against unlawful termination for an employee who files a serious complaint with the Ministry of Human Resources and Emiratisation (MOHRE).
• Federal Law No. (3) of 2016 concerning Child Rights (Wadeema's Law), which places a specific duty on anyone in contact with children to report suspected child abuse (see the Child Protection & Safeguarding Policy).

This policy's protections against victimisation, described in Section 6, are a school commitment that applies whether or not a specific concern also happens to fall within one of the legal provisions above.

What Is Whistleblowing?

Whistleblowing is the disclosure of information by someone who reasonably believes it shows serious wrongdoing, made in the public interest rather than for personal gain. It is distinct from a personal grievance or complaint, which relates to how someone has been personally treated (see Section 5).

Examples of the kind of concern this policy covers include:

• Financial malpractice, fraud, or misuse of school funds or resources.
• A risk to the health or safety of students, staff or visitors.
• A breach of UAE law, SPEA regulations, or the school's licensing conditions.
• Abuse of position or authority by a member of staff or governor.
• Malpractice in relation to examinations or assessment (see also the Malpractice & Maladministration Policy).
• A deliberate attempt to conceal any of the above.

What This Policy Does Not Cover

This policy is not the right route for every concern. Depending on the nature of the issue, a different policy applies:

Where a concern raised under this policy turns out to be more appropriately handled under one of the policies above, it will be redirected accordingly, and the person raising it will be informed.

How to Raise a Concern

A concern can be raised verbally or in writing, using the Concern Form in Appendix A if helpful, though this is not required.

• In most cases, the simplest route is to raise the concern with your line manager or Head of Department.
• Where the concern involves your line manager, or you do not feel comfortable raising it with them, it may instead be raised directly with the Principal.
• Where the concern involves the Principal, it should be raised directly with the Chair of the Governing Body.
• A concern may be raised anonymously; however, the school's ability to investigate and provide feedback is often more limited where the source cannot be contacted for further information.

Whoever the concern is raised with, it is acknowledged within 3 school days, and the person raising it is told, so far as confidentiality allows, what will happen next and roughly when they can expect an update.

Confidentiality and Protection from Detriment

• Every effort is made to protect the identity of a person raising a concern, and information is shared only with those who need to know in order to investigate it properly.
• PEPS will not tolerate any employee, contractor or volunteer being victimised, disadvantaged, or subjected to any detriment as a result of raising a genuine concern in good faith under this policy, even if the concern is not subsequently upheld.
• Any attempt to victimise someone for raising a genuine concern is treated as a serious disciplinary matter in its own right.
• This protection does not extend to a disclosure made maliciously, or one the person making it knows to be false; the school reserves the right to consider disciplinary action in such cases, following a fair process.

Investigation Process

External Escalation

While PEPS encourages concerns to be raised internally first, wherever it feels safe to do so, a person may take a concern to an appropriate external authority, particularly where they believe it has not been, or cannot be, properly addressed internally. Depending on the nature of the concern, this may include:

• The Sharjah Private Education Authority (SPEA), for concerns relating to the school's compliance with its licensing and regulatory obligations.
• The Ministry of Human Resources and Emiratisation (MOHRE), for serious employment-related complaints.
• The Police, for suspected criminal conduct.
• The relevant examination awarding body, for suspected malpractice affecting the integrity of an external qualification.

Roles and Responsibilities

9.1 All Staff, Contractors, Volunteers and Governors

• Raise a genuine concern about suspected wrongdoing promptly, using the routes described in Section 5.
• Cooperate fully and honestly with any investigation carried out under this policy.

9.2 Line Managers and Heads of Department

• Listen to a concern seriously and without judgement, and escalate it appropriately where it cannot be resolved or addressed at their level.

9.3 Principal

• Ensures concerns raised are investigated fairly and promptly, and that this policy's protections against victimisation are upheld in practice.
• Reports, at least annually and in anonymised form, on the operation of this policy to the Governing Body.

9.4 Governing Body / Chair of Governors

• Acts as the escalation route for a concern involving the Principal, and maintains oversight of the school's culture of openness and accountability.

Monitoring and Review

This policy is reviewed annually by the Principal and Governing Body, and sooner if required by a change in relevant UAE legislation, SPEA guidance, or if a review of concerns raised indicates the process needs adjustment.

Links to Other Policies

• Child Protection & Safeguarding Policy — the route for any concern about a child's safety or welfare.
• Complaints Policy — the route for a parent or student concern about the school's general provision.
• Malpractice & Maladministration Policy (within the External Examinations Policies) — the route for concerns specific to examination integrity.
• Data Protection & Privacy Policy — how personal data arising from a concern raised under this policy is handled.

Raising a Concern — Form

This form is optional; a concern may equally be raised verbally or in any written format. Where used, it should be given to your line manager, the Principal, or the Chair of the Governing Body, as appropriate to the nature of the concern (see Section 5).

Nature of the Concern

(What happened, when, and who was involved, so far as known)

Have You Raised This Anywhere Else?

Glossary of Terms

Legislative References

Note: the UAE does not currently have a single, comprehensive federal whistleblowing law outside certain financial free zones (which do not apply to PEPS); this policy's protections reflect the school's own commitment, which goes beyond the current statutory minimum.