The College recognises the need for researchers to protect their own research interests and both the College and its funding bodies encourage researchers to be as open as possible. This openness includes such common practices as the scholarly exchange of ideas and data and the submission of work to peer review or to another forum where it can be challenged and questioned without the loss of face. Such an environment is essential not only to the establishment of good scientific conduct, but to the development of good and innovative science itself. Openness also implies that all steps will be taken to avoid, or at least declare, conflicts of interest.

This policy is designed to enable workers and other members of the University to raise concerns at a high level or to disclose information which the whistleblower in good faith believes shows malpractice or impropriety.

Enquiries about the operation of these procedures, or about potential concerns of malpractice or impropriety may be addressed in confidence to the College Secretary.

 
 

Public Interest Disclosure (Whistleblowing) Policy

The text below reproduces Council Regulation 9 [PDF]. 

Public Interest Disclosure (Whistleblowing) Policy

9.1 Purpose and overview

9.1.1. This Regulation 9: Public Interest Disclosure (Whistleblowing) Policy (“Policy”) sets out the University's approach to handling workers’ concerns pursuant to the Public Interest Disclosure Act 1998 (“PIDA”). It ensures that individuals can raise concerns about serious wrongdoing in good faith and without fear of reprisal or detriment, and that such concerns are assessed and, where appropriate, investigated in a fair and proportionate manner.

9.1.2. The University is committed to the highest standards of integrity, accountability, and transparency. This Policy supports those aims by providing a clear route for raising concerns that fall within the scope of PIDA, and is informed by the Seven Principles of Public Life (Nolan Principles): Selflessness, Integrity, Objectivity, Accountability, Openness, Honesty, and Leadership.

9.2 Scope

9.2.1. This Policy applies to disclosures made by individuals who fall within the definition of “worker” under PIDA, including employees, contractors, trainees, and agency staff.

9.2.2. A “qualifying disclosure” under PIDA must relate to matters that are in the public interest and which the discloser reasonably believes shows one or more of the following:
           9.2.2.1. A criminal offence;
           9.2.2.2. Breach of a legal obligation;
           9.2.2.3. Miscarriage of justice;
           9.2.2.4. Endangerment of health or safety;
           9.2.2.5. Environmental damage;
           9.2.2.6. Deliberate concealment of any of the above.

9.2.3. Other members of the University community (including students, volunteers, and self-employed individuals) are encouraged to raise concerns, but are not covered by the statutory protections afforded by PIDA. Therefore, where a concern is raised outside of PIDA requirements or does not fall within the scope of this Policy, the University reserves the right to redirect it to the appropriate procedure to ensure it is considered in the most suitable and effective manner. These include (but are not limited to):

  • Staff Resolution Policy and Grievance Procedure – for concerns about personal treatment or working conditions.
  • Staff Disciplinary Policy – for allegations of misconduct by staff members.
  • Staff Sexual Misconduct Policy – for allegations of sexual misconduct by staff members.
  • Student Complaints Procedure – for dissatisfaction with academic or administrative services.
  • Student Disciplinary Procedure – for allegations of student misconduct, including breaches of the Student Code of Conduct.
  • Academic Appeals Procedure – for requests to reconsider decisions made by Boards of Examiners or Mitigating Circumstances Panels, on limited procedural grounds.
  • Research Misconduct Policy – for concerns about the integrity or ethics of research activities.
  • Conflict of Interest Policy – for concerns about undeclared or improperly managed conflicts affecting decision-making or research.
  • Regulation 8: Policy and Response Plan for the Treatment of Fraud, Bribery, Corruption & Irregularities – for financial or ethical misconduct.
  • Freedom of Speech Complaints Procedure – for concerns relating to the exercise or restriction of lawful freedom of speech.
  • Safeguarding Policy – for concerns about the welfare or safety of students, volunteers, or vulnerable individuals.

9.2.4. Concerns may also be raised via the University’s Report and Support tool or through other formal procedures. Whistleblowing disclosures should follow Regulation of Council 9. Where the concern involves the President or Provost, Regulation of Council 13 applies. The Report and Support tool may be used to initiate concerns, which will be triaged and directed to the appropriate process.

9.2.5. This Policy operates alongside the University’s duties under the Higher Education (Freedom of Speech) Act 2023 and other applicable legislation. Where a concern relates to interference with lawful free speech or academic freedom, the University will consider its obligations under that legislation and may refer the matter to appropriate internal or external processes.

9.3 - Responsibilities

9.3.1. Designated Person

9.3.1.1. The “Designated Person” is the individual responsible for receiving and managing disclosures under this Policy. This will normally be the Registrar & University Secretary.

9.3.1.2. Where a disclosure concerns the Registrar & University Secretary, the matter  should be referred to the President. If the President is also conflicted, the disclosure may be made to the Chair of Council or the Chair of the Audit and Risk Committee.

9.3.2. Investigating Officer

9.3.2.1. The “Investigating Officer” is the person appointed by the Designated Person to conduct an investigation into the disclosure. The Investigating Officer will be supported by the Institutional Compliance and Risk Management team.

9.3.2.2. This may be a member of staff or, where appropriate, an external or independent party with relevant expertise (such as where the Designated Person is either the Chair of the Council or the Chair of the Audit and Risk Committee and the allegation concerns senior members of the University).

9.3.2.3. The Investigating Officer must not be involved in determining the outcome of the investigation, to ensure procedural fairness and maintain the integrity of the process.

9.4 Policy (and procedure)

STEP 1: MAKING A DISCLOSURE

Disclosures should be made in writing (either by email or post) to the Designated Person.*

The University will take reasonable steps to protect the identity of the whistleblower, where requested, and to prevent any form of retaliation or detriment (disadvantage or harm suffered as a result of making a qualifying disclosure). Any victimisation of a whistleblower will be treated as a disciplinary matter.

Anonymous disclosures may be considered, but the University’s ability to investigate may be limited.

The University will not use non-disclosure agreements to prevent individuals from raising concerns under this Policy or from seeking appropriate support or redress. This does not extend to commercial or research NDAs entered into with external partners, which will remain valid and enforceable.

STEP 2: INITIAL ASSESSMENT

The Designated Person will assess whether the disclosure falls within the scope of this Policy and whether there is a prima facie case to answer. They will determine whether to:

  • Commission an internal investigation;
  • Refer the matter to an alternative internal procedure;
  • Refer the matter to an external authority (e.g. police, HSE, GMC);
  • Take no further action.

STEP 3: INVESTIGATION

Where an investigation is warranted, an Investigating Officer will be appointed. The investigation will be conducted promptly and proportionately, and findings will be reported to the Designated Person.

STEP 4: OUTCOME

Upon completion of the investigation by the Investigation Officer, the Designated Person will determine what, if any, further action is required. This may include:

  • Management action;
  • Referral to disciplinary or other internal procedures;
  • Referral to an external body.

The University will maintain a confidential record of disclosures and outcomes. An anonymised summary will be reported annually to the Audit and Risk Committee to monitor effectiveness and compliance.

The whistleblower will be informed of the outcome, subject to legal and confidentiality.

*STEP 1: CONTACT DETAILS:

Registrar & University Secretary:

university.secretary@imperial.ac.uk 
FAO Registrar & University Secretary
Level 1 MediaWorks
191 Wood Ln 
London W12 7FP

President:

president@imperial.ac.uk 
FAO President
Level 4 Faculty Building 
South Kensington Campus 
London SW7 2AZ

Chair of Council:

FAO Chair of Council
Level 4 Faculty Building 
South Kensington Campus 
London SW7 2AZ

Chair of Audit and Risk Committee:

FAO Chair of Audit and Risk Committee
Level 4 Faculty Building 
South Kensington Campus
London SW7 2AZ

Associated documents