The policy is applicable to all parents, contractors, concerned persons, clients, third party personnel seconded to Corona, and business partners (collectively called stakeholders) in all the schools’ and locations where the Trust Council operates and further covers concerns raised by members of the public.  

• Illegal/criminal activities; 
• Fraudulent activities; 
• Insider dealing; 
• Breach of fundamental internal control; 
• Bribery and corruption; 
• Health and safety risks, including actions likely to cause physical danger to any person or to give rise to a risk of significant damage to property; 
• Contravention of the code of business conduct & ethics  
• Conflict of interest, facilitation payments etc.; 
• Abuse of office or responsibility in connection with unauthorised activity for personal gain; 
• Gross misuse of assets including information assets; 
• Intentional misrepresentations directly or indirectly affecting financial statements; 
• Sexual harassment or physical abuse; 
• Abuse of power or the use of trust council powers and authority for any unauthorised or ulterior purpose 
• Other unprofessional or unethical behaviour; and 
• Deliberate concealment of the information tending to show any of the matters listed above. 

1. Harassment or victimisation: The Trust Council will not tolerate harassment or victimisation and will take action to protect stakeholders when they raise a concern in good faith.

2. Confidentiality: Individuals who raise concerns will not have their identity disclosed without their prior consent. However, in some situations the investigation process may not be concluded unless the source of the information and a statement by the individual is produced as part of the evidence. 

3. Anonymous allegations: Concerns expressed anonymously are much less powerful, but they will be considered at the discretion of the Trust Council. 

4. False/untrue allegations: Where there are deliberate false, malicious, or vexatious allegations, disciplinary measures will be taken against the whistleblower.  

5. Protection for whistleblower:  The Trust Council shall ensure that the whistleblower is not victimised in anyway, even if it becomes necessary for him/her to come forward to give evidence. The whistleblower will enjoy the protection under this paragraph even if the report turns out not to be true after investigation. 

6. Retaliation: All cases of retaliation shall be reported to the appropriate officer who after investigation shall refer the issue to the disciplinary committee for appropriate sanctions to be meted out. 

The action taken will depend on the nature of the concern. The matters raised may:

• Be investigated internally;
• Be referred to the Police;
• Be referred to the External Auditor/Consultant
• The Trust Council accepts that stakeholders need to be assured that the matter has been properly addressed.

Thus, subject to legal constraints, concerned persons will receive information about the outcomes of any investigations.

To get the full copy of this policy, download the abridged copy below.