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Guidance on raising concerns about adult education funding

Raising concerns about adult education funding

This guide sets out

  • how to report allegations about suspected fraud or financial irregularity to the GLA
  • the types of allegation the GLA will consider
  • how the GLA handles confidential and anonymous allegations
  • how the GLA handles reported allegations
  • how allegations made by whistleblowers are protected

Reporting and investigating instances of fraud and corruption

The GLA's role is to confirm

  • if allegations or information from any source indicates financial irregularity
  • if a GLA funded education provider has broken the funding rules

The GLA will consider and determine appropriate action when we receive allegations of suspected fraud and/or financial irregularity, including;

  • a funded provider (e.g. college or training provider) has claimed funding from the GLA through deception
  • a funded provider has broken the funding rules
  • a funded provider has not delivered education and/ or training funded by the GLA
  • corruption and bribery - for example, in relation to sub-contracting
    • corruption is the offering, promising, giving, requesting, receiving or agreeing to accept an inducement or reward (i.e. a bribe), which may influence a person to act against the interest of the GLA.  The definition of what constitutes a bribe is broad and covers any financial or other advantage offered to someone to induce them to act improperly.  The Bribery Act 2010 creates offences of;
      • offering, promising or giving a bribe  (active bribery)
      • requesting, receiving or agreeing to accept a bribe (passive bribery)
    • the Act also creates an offence of commercial organisations (applicable to both private and public organisation) failing to prevent persons associated with them (including third party providers) from bribing another person on their behalf.  The organisation will have defence if it can show that it had adequate procedures in place to prevent persons associated with it from committing bribery. 

The GLA will not usually consider concerns about;

  • the quality of education or leadership, or concerns affecting the organisation, which are addressed through OFSTED inspections (unless these concerns link to a suspected fraud or financial irregularity)
  • discrimination; you can raise complaints about this with Equality Advisory Support Service data protection. Data protection; you can raise complaints about this with the Information Commissioner's Office
  • exam malpractice or maladministration; any complaints should be raised with Office of Qualifications and Examinations Regulation (Ofqual) or the relevant awarding body
  • child protection (safeguarding); issues should be raised with your local authority designated officer (LADO) and/ or the Director of Children's Services using the report child abuse to [local council].gov.uk page
  • concerns relating to employment and/ or contracts of employment of individual staff should be directed to the individual's employer 
  • contractual disputes between employees and employers, and complaints about managers, including bullying and harassment, should be directed to the employer

The above list are not exhaustive.  Where appropriate, the GLA will share your allegation with other government departments and organisations that may have an interest, or hold jurisdiction over specific funding streams

How to report allegations of suspected fraud or financial irregularity

Before raising a concern with the GLA you must have a reasonable belief that the disclosure is true

For allegations relating to colleges and training organisations, please email [email protected]

You can also telephone on (020) 7084 2590 or 7983 4475

or contact the Audit Lead by post at;

GLA Adult Education Budget, Skills and Employment unit, 169 Union Street, London SE1 0LL

Confidentiality and anonymous allegations

It is helpful if you are able to provide your name and contact details as it is difficult to investigate matters where we are unable to contact you for further information.  However, we understand that you may not feel comfortable doing this.  Unless we receive a sufficient amount of information and/or evidence to proceed with an investigation, we may not be able to act on anonymous allegations.

If you raise an allegation we will not disclose your identify without your consent, unless this is required for legal reasons.  In some circumstances it may not be possible to act upon your concerns without disclosing your identity.  We will always seek your consent before disclosing information to a third party if you previously requested that your identity is not disclosed. 

If you do not wish to provide this consent, we may not be able to investigate your allegations properly, or at all.

Whistleblowers

A whistleblower is someone who works at an organisation or is involved in governing it, and reports certain types of wrongdoing.  This will usually be something you've seen at the organisation - though not always.

Whistleblowing relates to making disclosures about wrongdoing in the public interest.  This means things that affect others; for example, the general public. 

As a whistleblower you're protected by the law.  That means you won't suffer a detriment - for example, lose your job or be disadvantaged at work - if you report something

You can raise your concern at any time about an incident that happened in the past, is happening now, or you belive will happen in the near future.  However, the sooner you raise your concern, the better the chance of addressing it. 

Action GLA takes when receiving an allegation

Where you have provided contact details, we will acknowledge your allegation.  We may also seek further information from you at this stage.  This plan sets out the steps the GLA will take when fraud corruption and related wrongdoings are reported to;

  • investigate the incident;
  • document, secure and retain evidence;
  • analyse and evaluate evidence;
  • document findings and conclusions;
  • secure evidence for any civil or criminal action;
  • carry out a post investigation review to identify underlying fraud risks, trends and other system and supervisory weaknesses.  Value for money and organisational learning considerations are also assessed to prevent any further loss in the immediate future
  • ensure processes are strengthened to prevent recurrences of similar wrongdoing.

If we cannot handle your allegations, we may refer them to another body.  We cannot commit to notifying you of the outcome of any action we may take. 

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