A whistleblowing code for educational institutions
Gerald Vinten
Southampton Business School, Southampton, UK
The essential ethos and values of higher education and education generally need con-stant reiteration, with corrective action ta-ken where necessary. One development in maintaining the culture was the introduction of Richard Shepherd's private member's Bill, the Public Interest Disclosure Bill, with the aim of protecting whistleblowers. The Bill aimed ``to protect individuals who make certain disclosures of information in the public interest; to allow such individuals to bring action in respect of victimisation; and for connected purposes.'' The Bill had gov-ernment, and indeed all party support, with the endorsement of the CBI, Institute of Directors and TUC. Ian McCartney, Minister of State at the Department of Trade and Industry, led for the government towards agreement on the detailed provisions. With the promise in opposition of Tony Blair to legislate, now realised, educational estab-lishments should regard this as highly sig-nificant legislation.
The Bill was in the spirit of the Nolan (1996) Committee's Second Report which contained three germane recommendations: 1 R6. Representative bodies, with the help of
the funding councils, should produce a common standard of good practice on the limits of commercial confidentiality, and should encourage all institutions to be as open as possible subject to those limits. All institutions should have publicly available registers of interests. 2 R7. Institutions of higher and further
education should make it clear that the institution permits staff to speak freely and without being subject to disciplinary sanctions or victimisation about academic standards and related matters, provided that they do so lawfully, without malice, and in the public interest.
3 R8. Where it is absolutely necessary to include confidentiality clauses in service and severance contracts, they should ex-pressly remind staff that legitimate con-cerns about malpractice may be raised with the appropriate authority (the fund-ing council, National Audit Office, Visi-tor, or independent review body as applicable) if this is done in the public interest.
Of higher education whistleblowers, the most famous were the pioneering ``Swansea four'' of Anne Maclean, Michael Cohen, Colwyn Williamson, and Geoff Hunt. They drew attention to concerns about standards relat-ing to student assessment, particularly of dissertations, at University College, Swan-sea's Centre for Philosophy and Health Care. Following judicial-type enquiry the three remaining were reinstated, and all four were presented with 1993 Freedom of Information Awards on the nomination of the present writer. Dr Bill Mallinson at the University of Bournemouth expressed worries about the way that commitments consequent upon Erasmus funding were not being fulfilled, and was eased out as course director, dis-criminated against, disciplined, and pres-surised towards resignation. However, on 17 March 1993 the university issued a press statement that £2,343 had been repaid to Erasmus in full and final settlement.
The culture of fear is not unknown in other parts of the educational system, and the lower down one goes, the more intimidated staff may become, since in higher education there are higher degrees of self-determina-tion, which are lacking at the primary stage. A secondary school example involved Harry Whitby (Vinten, 1994), who was unjustly accused by a teenage pupil in a remedial class. Coincidentally Harry was the trade union representative, and it suited the head-master to discipline and then dismiss him, despite any lack of convincing evidence. There were attempts to prove mental in-stability, until Professor Anthony Clare, the eminent psychiatrist contradicted this. A High Court judge found in Harry's favour, but despite this the school and education authority continued to play games, and the trade union was less than helpful. Over a decade on, Harry still awaits a vindication which will probably never come.
Despite the financial crisis at the Univer-sity of Luton, its first Vice-Chancellor con-tinued as Chair of a National Health Service Trust at remuneration of £20,000 a year, which meant that he was working an eight day week. He even promised to donate half of this to a charitable cause within the Uni-versity as token that half of the NHS Trust The International Journal of
Educational Management 13/3 [1999] 150±157
#MCB University Press [ISSN 0951-354X]
Keywords
Codes of practice, Colleges, Employment law, Ethics, Whistleblowing
Abstract
duties were performed within work time, although there is no evidence of such a donation. Even when such a dual existence was condemned by the Comptroller and Auditor-General (1997) at another university, he continued in the role, with the support of governors, who were equally criticised for allowing it to happen at the other institution. The culture was such as to deter anyone who might contemplate whistleblowing, but de-spite this there was a flurry of articles in local newspapers with information supplied by the staff. When there was a vote of no confidence in this Vice-Chancellor, the then Chair of the Governors dismissed it with the words that he did not believe the staff really meant it. Yet he considered that there was a culture of openness, and that staff should feel him approachable.
The University of Portsmouth case is worth exploring in its own right (Comptrol-ler and Auditor-General, 1997). In early 1996, the Comptroller and Auditor-General re-ceived correspondence from individuals, in-cluding the former Deputy Vice-Chancellor of the University, making a range of allegations relating to the governance of the institution and specifically the handling of irregularities in the former Vice-Chancellor's expenses claims and the handling of the departure of the former Deputy Vice-Chancellor. Even though the University has already taken action, there are general lessons for the sector and there was still disquiet about these matters in 1996. The University has reviewed the arrangements for governance and the Board of Governors has accepted the wide-ranging recommendations for improvement which emerged.
The National Audit Office found that errors of judgement were made in the Uni-versity's handling of the investigation of the former Vice-Chancellor's expenses and that the handling of that investigation and other aspects of the governance of the University did not comply with accepted good practice. The University has been subject to consider-able disruption and has incurred significant costs. These included some £140,000 for an independent inquiry by Mr Jeremy Lever QC and subsequent legal costs. In addition, the University's handling of the departure of the former Deputy Vice-Chancellor may have caused the severance costs to be greater than strictly necessary.
In relation to matters of alleged or proven impropriety, the National Audit Office Re-port recommends that the Higher Education Funding Council for England and the De-partment for Education and Employment consider whether there is scope for providing clearer or more emphatic guidance to higher
education institutions on various aspects of governance including: the role of the Audit Committee and the Board of Governors in relation to matters of impropriety; the prin-ciples which should inform decisions by institutions on the handling of misconduct by senior staff; and the procedures for handling whistleblowers in cases of alleged financial misconduct or maladministration as set out by the Committee on Standards in Public Life in their report on Local Public Spending Bodies.
The Investigation of Misconduct at Glas-gow Caledonian University (Comptroller and Auditor-General, 1998) also involved whistle-blowing. The National Audit Office and the Scottish Higher Education Funding Council received the allegations in February 1997. The Council's initial investigation found sufficient cause for the University to seek their principal's early departure in May 1997 and in September 1997, following their own review, the University dismissed their prin-cipal for gross misconduct. The Council completed their work in February 1998 and the University have implemented an action plan to reinforce proper conduct and systems within the University.
The National Audit Office concluded that:
This was a disturbing case but the Council acted promptly to investigate the allegations, and as a result they and the University have initiated action to reinforce proper conduct within the University. The Council's actions and the University's decision to dismiss their principal took into account recommendations of the Committee of Public Accounts in this area. In the light of this case there is clearly a need to establish whistle blowing procedures for the sector, and to publicise these to staff. Across the sector as a whole, Institutions should:
. avoid setting terms for severance for any
staff before completing any necessary disciplinary procedures;
. ensure vehicles provided at public
ex-pense are correctly authorised; and
. evaluate whether their policies governing
visits overseas ensure economy and value for money.
The National Audit Office welcomed the Council's undertaking to require Institutions to review and report formally on the effec-tiveness of their governance, as recom-mended by both the Dearing and Nolan committees in 1997.
The Public Interest Disclosure Act
1998: summary of provisions
The Public Interest Disclosure Act 1998 amends the Employment Rights Act 1996 by introducing new rights not to suffer Gerald Vinten
detriment or dismissal for making a pro-tected disclosure (``blowing the whistle''). It applies to virtually all workers in the public and private sectors. This makes it unique, since comparable legislation is confined to the public sector, and organisations in a contractual relationship with it. The Act came into force at the end of 1998, giving time for employers to adjust their procedures if they wish, and for necessary secondary legislation (on compensation and prescribed bodies) to be passed. The main provisions are summarised below.
The Act inserts into the Employment Rights Act 1996 (``the 1996 Act'') protections for workers against detriment or dismissal for raising concerns about matters in the public interest. It aims to encourage pro-blems to be resolved within the workplace, with public disclosures to be made only in limited circumstances.
Section 1 ± Protected disclosures This is the key section in the Act, which contains the essential features of the new rights.
Disclosures qualifying for protection New section 43B(1) of the 1996 Act specifies the categories of information that are cov-ered by the Act (``qualifying disclosures''). These are:
. criminal offences
. failures to comply with legal obligations . miscarriages of justice
. health and safety dangers . environmental risks
. concealing information about any of the
foregoing.
Disclosures may be protected even if they are about matters which took place abroad (43B(2)). A disclosure would not, however, be protected if it constituted a criminal offence, for example under the Official Secrets Act 1989 (43B(3)). Disclosures that are made by a person to whom the information was given in the context of obtaining legal advice will also not be protected (43B(4)).
Disclosure to particular persons
Sections 43C to 43F set out the requirements that are attached to protection when disclo-sures are made in various circumstances. Protection applies where a worker makes a disclosure:
. in good faith to his employer or to another
responsible person (43C);
. in the course of obtaining legal advice
(43D) (note that there are no conditions attached to protection where a worker makes a disclosure to a legal adviser);
. in certain cases, to a Government
Minis-ter (43E); and
. to a person or body prescribed by the
Secretary of State, provided that the worker acts in good faith and reasonably believes the information falls within the potentially protected categories and is substantially true (43F).
Disclosures in other circumstances to any other person are provided for in 43G and 43H.
Disclosures more generally
Section 43G protects workers who make ``external'' disclosures i.e. other than to the employer, a legal adviser, a Minister or a prescribed person. A worker will only be protected under this general category if he has previously disclosed the matter to the employer or a prescribed body, or has not done so because he reasonably believes he would have been victimised or evidence concealed or destroyed. He must also:
. make the disclosure in good faith; . reasonably believe that the information,
and any associated allegation, are sub-stantially true;
. not act for personal gain; and . act reasonably.
In deciding whether the worker acted rea-sonably the tribunal will take into account all the circumstances, including particularly:
. the identity of the person to whom the
disclosure is made;
. the seriousness of the matter; . whether the problem is continuing; . whether the disclosure is in breach of the
employer's duties of confidentiality to any other person;
. any action the employer or prescribed
person might reasonably be expected to take as a result of a previous disclosure;
. whether disclosure was made in
accor-dance with any internal procedures ap-proved by the employer.
Disclosure of exceptionally serious matters
Section 43H protects workers who make disclosures about exceptionally serious mat-ters. The requirements are that the failure disclosed should in fact be of an exceptionally serious nature, and
. the worker makes the disclosure in good
faith;
. he reasonably believes that the
informa-tion disclosed, and any associated allega-tion, are substantially true;
. he does not act for personal gain; and . it was reasonable for him to make the
disclosure, taking into account all the circumstances, particularly the identity of the person to whom the disclosure was made.
Gerald Vinten
Contractual duties of confidentiality Section 43J provides that any terms in an agreement between the worker and his employer are void to the extent that they preclude or restrict the making of a protected disclosure (so called contractual ``gagging'' clauses).
Those covered by the Act
The Act will apply to virtually all employees in the public and private sectors, and to other workers as set out in Section 43K. These are:
. certain agency workers;
. homeworkers who are helped to do their
work by others;
. NHS practitioners, such as GPs, dentists,
pharmacists and opticians; and
. certain categories of trainees.
Certain limited exemptions are made by sections 11 to 13 (see below) for workers in police service, who usually work overseas and on national security grounds.
Section 2 ± Right not to suffer detriment Section 2 inserts into the Employment Rights Act 1996 a new Section 47B which provides the new right not to be subjected to detriment for making a protected disclosure.
``Detriment'' may include any action against a worker, for example demotion, failure to give training or promotion, or withholding a pay rise. Workers who are not employees will be able to claim under this provision if their contracts are terminated. However, because employees can claim un-fair dismissal under Part X of the Employ-ment Rights Act 1996, the right to complain of detriment does not apply to employees who are dismissed, unless they are on fixed term contracts and have waived their right to claim unfair dismissal.
Section 3 ± Complaints to employment tribunals
Workers who are subjected to detriment for making a protected disclosure may submit a complaint to an employment tribunal, in the same way as other complaints made to tribunals.
Section 4 ± Limits on amount of compensation
Where a worker has had his contract termi-nated, compensation for detriment cannot be higher than it would have been if the worker had been an employee who had been dis-missed for the same reason.
Section 5 ± Unfair dismissal
This section introduces the new right for employees not to be unfairly dismissed for
making a protected disclosure. Dismissal on such grounds will be automatically unfair.
Section 6 ± Redundancy
This section provides that selection for redundancy on grounds of making a pro-tected disclosure will be automatically unfair dismissal.
Section 7 ± Exclusion of restrictions on the right not to be unfairly dismissed
This provides that the usual qualifying period and upper age limit for complaints of unfair dismissal do not apply to a worker dismissed for making a protected disclosure.
Section 8 ± Compensation for unfair dismissal
Compensation for those dismissed for mak-ing a protected disclosure will be set out in regulations to be made by the Secretary of State. (Proposals about compensation under the Employment Rights Act 1996 were in-cluded in para 3.7 of the recently published Fairness at Work White Paper.)
Section 9 ± Interim relief
This section enables employment tribunals to award interim relief (i.e. order re-employ-ment or the continuation of the contract of employment for the purposes of pay and other conditions and continuity of employ-ment). Tribunals will do so where they think the applicant is likely to establish at a full hearing that he or she had been dismissed for making a protected disclosure.
Section 10 ± Crown employment
This section ensures that the provisions in the Act apply to those in Crown employment.
Sections 11-18
The remaining sections relate to exclusions, e.g. on national security grounds (section 11), for work outside Great Britain (section 12), and police (section 13); and minor or con-sequential provisions.
The Act should avoid the traumas caused to legitimate whistleblowers, first of all by encouraging organisations to adopt proce-dures which should render whistleblowing unnecessary, and second by providing reme-dies in those few cases where whistleblowing is unavoidable. In summary, to qualify as a protected disclosure under the Act, the worker making it must reasonably believe that the information tends to show that one or more of the following has occurred, is occurring or is likely to occur:
. a criminal offence;
. a failure to comply with any legal
obliga-tion (this includes any breach of a Gerald Vinten
statutory requirement, or a requirement under common law or administrative law);
. a miscarriage of justice;
. danger to the health or safety of any
individual;
. damage to the environment;
. deliberate concealment of any of the
above.
Codes of practice
There is much value in setting up codes of practice for whistleblowing (Vinten, 1992, 1994, 1996), and this is becoming a require-ment in higher education. This can work to an organisation's advantage, as well as protecting whistleblowers. On the other side of the coin, there is a case for setting up a code for the whistleblowers themselves. There are degrees of validity, with extremes of unacceptableness and acceptability. Thus we have Norman Bowie's (1982, p. 143) ideal requirements of justifiable acts of whistle-blowing:
. that the act of whistleblowing stem from
appropriate moral motives of preventing unnecessary harm to others;
. that the whistleblower use all available
internal procedures for rectifying the problematic behaviour before public dis-closure, although special circumstances may preclude this;
. that the whistleblower have ``evidence
that would persuade a reasonable person'';
. that the whistleblower perceive serious
danger that can result from the violation;
. that the whistleblower act in accordance
with his or her responsibilities for ``avoiding and/or exposing moral viola-tions'';
. that the whistleblower's action have some
reasonable chance of success.
Other writers have suggested practical points for whistleblowers to ponder. Velasquez (1988, p. 381) has made a composite, based upon several other writers:
. How comprehensive is the worker's
knowledge of the situation? Is the work-er's information accurate and substantial?
. What, exactly, are the unethical practices
involved? Why are these unethical? What public values do these practices harm?
. How substantial and irreversible are the
effects of these practices? Are there any compensating public benefits that justify the practices?
. What is the employee's obligation to bring
such practices to an end? Can the em-ployee do more to end the practices by working within the organization or by
going outside? What probable effects will either alternative have on the company's practices? On society? On the firm? On other organizations? On the employee?
De George (1986) has suggested three condi-tions which may turn whistleblowing from being an act of disloyalty, damaging an organization, to being morally justifiable: 1 The firm, through its product or policy,
will do serious and considerable harm to the public, whether in the person of the user of its product, an innocent bystander, or the general public.
2 The matter should be reported to the immediate superior and the moral con-cern made known.
3 If no action results, the employee should exhaust internal procedures and possibi-lities. This usually involves taking the matter up the managerial ladder, and, if necessary and possible, to the board of directors.
In James' (1994) analysis, that relies heavily on De George (1986) the following list of considerations is provided:
1 Make sure that the situation is one that warrants whistleblowing.
2 Examine your motives.
3 Verify and document your information. 4 Determine the type of wrong-doing
in-volved and to whom it should be reported. 5 State your allegations in an appropriate
way.
6 Stick to the facts.
7 Decide whether the whistleblowing should be internal or external. 8 Decide whether the whistleblowing
should be open or anonymous.
9 Decide whether current or alumni whis-tleblowing is required.
10 Make sure you follow proper guidelines in reporting the wrong-doing.
11 Consult a lawyer. 12 Anticipate retaliation.
Under point 9, some blow the whistle after they have left their organisation (``alumni whistleblowing'') to avoid direct recrimina-tion, and in the knowledge that the law relating to employee confidentiality of com-pany practices and procedures is often im-practical to enforce on ex-employees, even if there were not a public interest defence.
Another strategy, related to minimising the risk of sabotage is (Analoui and Kaka-badse, 1992):
1 Reduce dissatisfaction at work through:
. working conditions
. recruitment and training policies . pay and reward systems
. supervision.
Gerald Vinten
2 Find out about problems through
. attitudinal surveys
. meetings and quality circles.
3 Give managers meaningful feedback. 4 Reduce temptations and opportunities to
get even:
. reduce pilferage;
. minimise rule breaking where rules
are vague and ambiguous; difficult to enforce and need voluntary participa-tion of the people involved; protecting the interests of individuals or groups at the expense of others; inflexible and restrictive; conflicting with other rules;
. improve cooperation;
. deal with destructive practices; . handle disturbances;
. ensure correct use of facilities.
5 Achieve a consistent message between top and other levels of management that motivate and involve the staff.
Some of the problems of the over-ready countenancing of whistleblowing have been outlined by Alan Westin (1981):
. Not all whistleblowers are correct in what
they allege to be the facts of management's conduct, and determining the accuracy of charges is not always easy.
. There is the danger that incompetent or
inadequately performing employees will whistleblow to avoid facing justified per-sonnel sanctions.
. Employees can choose some ways of
whistleblowing that would be unaccepta-bly disruptive, regardless of the merits of their protest.
. Some whistleblowers are not protesting
against unlawful or unsafe behaviour but against social policies by management that the employee considers unwise.
. The legal definitions of what constitutes a
safe product, danger to health, or impro-per treatment of employees are often far from clear or certain.
. The efficiency and flexibility of personal
administration could be threatened by the creation of legal rights to dissent and legalized review systems.
. There can be risks to the desirable
auton-omy of the private sector in expanding government authority too deeply into internal business politics.
An example of the equivalent of the vexatious litigant in organizational terms has been referred to in the US context as the troubling employee. These are employees who have entered into an ``I'm entitled'' mental set through Equal Opportunities legislation, Af-firmative Action, Supreme Court decisions and other special interest perpetuations
originally initiated for defensible, idealistic, human reasons. Such individuals are at an arrested development level of business ma-turity behaviour, and expect advancement on the basis of their special privilege rather than through merit. It is possible to help such individuals to grow up and mature with training and a suitable organisational envir-onment. It is a logical deduction that the potential for troubling employees to become whistleblowers is much higher than the average.
Apart from considering procedural and substantive ethical codes for individual whistleblowers, it is also vital to find reci-procation of organizations being prepared to act positively towards ethical whistle-blowers. In the USA organizations such as the Government Accountability Project have been attempting to protect the rights of legitimate whistleblowers. In many cases this may be a last port of call. One needs to have procedures at organizational level. Corporate codes of conduct will often be a formal safeguard. The Chartered Association of Certified Accountants has issued advice on the subject of whistleblowing:
Whistleblowing involves a breach of trust by an employee and cannot therefore be justified on a strict interpretation of what constitutes ``proper professional conduct''. In normal circumstances the course of action advisable for a member, if faced with action which is deemed to be ethically unacceptable, is to follow a series of steps:
. Bring the matter before the superior,
except where the superior is involved, in which case the matter should go to the next level up. If there is no satisfactory outcome, go to the next managerial level up.
. If the superior is the chief executive, go to
a relevant authority such as the Board, the Audit Committee or the owner(s). Unless the superior is involved, such consultation should be with the superior's knowledge.
. If the matter is unsolved after (a) or (b)
above, a member may have no alternative but to resign, putting the matter in writing for the record.
. The Stonefrost Committee in 1990 reported
on the workings of the Honours system, and even suggested that whistleblowers might be included in the Honours List (Stonefrost, 1990). ``As to `whistleblowing', we all regarded this as an important part of citizenship. We had no special problems with this issue as an element of citizenship although if there was too much `whistle-blowing' its effective value could be drowned by the noise.''
The ACCA advice was written prior to whistleblowing having reached ever higher levels of public and political acceptability, and so the reservations need no longer apply. The Gerald Vinten
Act will be of relevance in higher education, but the Nolan Committee resolutions are more relevant, and the safeguarding of the student experience and academic and other standards are matters which should be protected.
Public Concern at Work (1997) has pro-duced the following checklist, which is being adopted by an increasing number of organi-sations:
Whistleblowing policy checklist
Employees will often be the first to see or suspect misconduct, which may be innocent or which may turn out to be a fraud on your organisation, a public danger, or some other serious malpractice.
Making sure your employees keep their eyes open and raise such concerns is a sound way to demonstrate and ensure good prac-tice. It will give a clear message that those who empted to defraud you or who are reckless about your reputation will not get away with it.
This Checklist has been recommended by the Audit Commission and the Nolan Com-mittee.
Setting the context
. Involve your employees, listen to their
sense of right and wrong. Explain what fraud on the organisation is, its effect on their jobs and on your customers. Discuss other malpractice which may seriously damage the organisation.
. When you find serious malpractice, deal
with it openly. Remember you can't expect your employees to practise higher stan-dards than those you apply. If employees don't know that you will tackle the problem, they won't tell you about it.
. Make it clear that the organisation is
committed to tackle fraud and abuse, whether the perpetrators are inside or outside.
. Employees need to know that practices
are unacceptable (e.g. as to hospitality, gifts). If in doubt, they should ask man-agement if something is appropriate be-fore ± not after ± the event.
. Get staff unions to back and promote this
approach.
Be open to concerns
. It is never easy to report a concern,
particularly one which may turn out to be fraud or corruption.
. Try to ensure that management is open to
such concerns before they become part of a grievance and do not let management's lack of action itself become a grievance.
. Make it clear that you will support
con-cerned employees and protect them from reprisals. Do everything you can to re-spect their confidentiality.
. Aside from line management, make sure
employees have another route to raise a concern within the organisation. This should be to the chief executive, a non-executive director or a senior officer. Tell employees by posters, memos or messages on their pay slips how they can contact that person in confidence.
. Remind them of relevant external routes if
they do not have confidence to raise the concern internally, such as an external auditor, a regulatory body and that they can approach Public Concern at Work for confidential advice.
Dealing with concerns
. Remember there are two sides to every
story.
. Respect and heed legitimate employee
concerns about their own safety or career.
. Emphasise to both management and staff
that victimising employees or deterring them from raising a concern about mal-practice is a disciplinary offence.
. Make it clear that abusing this process by
raising unfounded allegations maliciously is a disciplinary matter.
. Offer to report back to the concerned
employee about the outcome of the inves-tigation and, where possible, on any action that is proposed.
Conclusion
Between the Act and the Nolan Committee, whistleblowers should be regarded more positively, with employers having had high-lighted that unlawful discrimination against them will be regarded very seriously indeed. Equally whistleblowers have their own re-sponsibilities and obligations to pursue their course in a way that accords with legal dictate and the codes of practice. This way the objective should be to encourage that type of whistleblowing that is exclusively in the public good. Educational institutions are well advised to formulate a code of practice on whistleblowing, and to engender a culture, as a natural part of educational management, which is open and positively encourages valid and constructive whistleblowing.
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Gerald Vinten
