Whistleblowing and Disclosures

Speak up with confidence, report concerns safely, confidentially, and in the public interest.

What is whistleblowing?

Whistleblowing occurs when an individual raises a genuine concern about suspected malpractice, wrongdoing, or the concealment of such behaviour that they have become aware of through their work.

If your concern relates to an AIA firm where you are employed, you should report it under this policy.

If your concern involves money laundering, you should refer instead to the section on Anti-Money Laundering Disclosures.

Disclosures

This section explains how whistleblowing disclosures are handled, including when legal protections apply and how concerns can be reported to AIA or other appropriate bodies.

Protected Disclosures

UK legislation protects employees from detrimental treatment where they make a qualifying disclosure in the public interest.

To be protected, a disclosure should normally be made to the individual’s employer. Where this is not appropriate, it may instead be made to a prescribed government body. The individual must reasonably believe that the information disclosed is substantially true and that it relates to a relevant form of wrongdoing.

This includes situations where a criminal offence has been, is being, or is likely to be committed; where a person has failed, is failing, or is likely to fail to comply with a legal obligation; where a miscarriage of justice has occurred or may occur; where the health or safety of an individual is or may be endangered; where there is damage to the environment; or where there has been deliberate concealment of any such matter.

Protection also applies where the concern relates to wrongdoing that has taken place abroad, including where the law of another country has been or may be breached.

Non-Protected Disclosures

UK employment legislation does not protect individuals who make disclosures in certain circumstances. This includes where an individual breaks the law in making a disclosure, knowingly provides false information, or discloses information that is subject to legal privilege.

If you are unsure whether your disclosure qualifies for protection, you are responsible for seeking appropriate guidance. Confidential advice on whistleblowing rights and the reporting process is available through Protect (formerly Public Concern at Work).

Disclosures to and from AIA

Where AIA receives disclosures from external sources relating to the conduct of study providers, exam venue providers, or other contractors, these are referred promptly to the relevant internal team. AIA will obtain as much information as possible and take action in line with its policies.

Individuals are protected from unfair treatment when raising concerns, including where the matter relates to events outside the UK.

In addition to reporting concerns to an employer, individuals may also report to prescribed persons or bodies identified by the UK Government. Under the Small Business, Enterprise and Employment Act 2015, these bodies are required to publish annual reports on disclosures, without identifying those who have made them.

Raising a Whistleblowing Concern

AIA treats all whistleblowing disclosures as confidential. When raising a concern, you should make clear that you are doing so under AIA’s whistleblowing policy so that we can take appropriate steps to investigate and protect your identity.

Once we receive your disclosure, we will contact you to discuss your concerns. We aim to keep you informed of progress and likely timescales. However, in some cases, confidentiality requirements may limit the level of detail we can share about the investigation or any resulting disciplinary action. While we cannot guarantee a specific outcome, we will handle your concern fairly and appropriately.

You may choose to raise your concern anonymously. AIA takes anonymous disclosures seriously and will investigate them as fully as possible. However, anonymity may make it more difficult for us to obtain further information or assess the credibility of the concern, which could limit the scope of our investigation.

If you ask us to keep your identity confidential, we will take reasonable steps to do so. If it becomes necessary for those investigating the matter to know your identity, we will discuss this with you before sharing it. If you are concerned about potential reprisals, you should let AIA know when submitting your disclosure so that appropriate measures can be considered.

For further advice you can contact the independent charity Protect (formerly, Public Concern at Work) for free, independent and confidential advice.

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