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Whistleblowing policy
​​​The ABPI is committed to managing the ABPI examination to the highest standards of transparency and ethics. We expect all candidates and ABPI staff and contractors to be honourable in all aspects concerning the attempting and management of the exam process. 

However all institutions face the risk of things going wrong from time to time or of unknowingly harbouring illegal or unethical conduct. ABPI is committed to highest standards of openness, probity and accountability to prevent such situations occurring or to address them when they do occur.

Whistleblowing is the reporting of a suspected wrongdoing in relation to the ABPI examination. This policy is relevant to any suspected misconduct at any stage of taking the examination, whether before, during and after the day of any particular exam sitting.  A whistleblower is a person who raises a genuine concern in good faith. If you have any concerns related to suspected wrongdoing (a whistleblowing concern) you should report it to the ABPI. 

You are encouraged to set out your concerns in writing so that ABPI can acknowledge your request as received and being processed. Contact details can be found on the right hand side of this page. If your concern is about the ABPI Head of Education & Exam you should contact the ABPI Chief Executive directly.

The aims of this policy are 
to encourage candidates and colleagues (whether friends, family or otherwise) to report any suspected wrongdoing as soon as possible 
to provide guidance on how to raise or disclose concerns 
to reassure that a genuine concern raised in good faith will not cause reprisals for the discloser 

Public Concern at Work (an independent charity), offer a confidential helpline about whistleblowing.

Misconduct affected by this policy includes but is not limited to – 
attempts to cheat at the ABPI examination, or suspecting this might happen 
cheating by reviewing an unauthorised copy of exam paper or exam paper answers before taking the exam
cheating by attempting to copy or otherwise view or steal someone else’s exam responses, or suspecting this might happen 
accepting or receiving a bribe related to taking the examination, or suspecting this might happen in future 
being asked to give a bribe related to taking the examination, or suspecting this might happen in future
misrepresenting your identity when taking the ABPI examination, or suspecting this might happen 
taking the examination on behalf of another person, or suspecting this might happen 
bringing a mobile handheld device or unauthorised document to look up answers during the examination or suspecting this might happen
attempts to steal exam papers, or suspecting this might happen 
criminal activity such as fraud, dishonesty or deception
behaviour during an exam which disrupts the ability of other candidates to take the exam in peaceful conditions 
behaviour which assists another candidate in a unauthorised manner 
failure to follow the directions of the exam invigilator
leaving the examination room at any time unless authorised to do to by the invigilator
failure to use the answer sheet provided
communicating with other people in the examination room other than the invigilator
serious incapacity during exam sittings caused by alcohol or illegal drugs
use of words or behaviour which is threatening abusive or insulting to other candidates, the invigilator or any staff member of ABPI 

​The procedure  

Raising a concern

If the matter arises during the course of conduct of an examination sitting, you are encouraged to contact the Invigilator in the room as soon as possible to alert them of the conduct complained of. If possible or appropriate the Invigilator might observe candidate(s) misconduct complained of silently and where possible take digital photographs to show the circumstances of any matter complained of which will be used as evidence when reporting the matter to the ABPI Head of Education & Exam. 

If in the sole discretion of the Invigilator there is misconduct by an individual occurring at the time of the exam, the Invigilator has the power to warn the candidate that they are under observation and should stop the conduct complained of and may if the conduct is continued be asked by the Invigilator to leave the examination room. Following any incident the Invigilator will report to the ABPI Head of Education & Exam who will compile an investigator’s report to be examined by the ABPI Chief Executive. 

It is important that you tell the invigilator of your exam or contact the ABPI Head of Education and Exam as soon as possible to raise concerns about any issue or suspicion of malpractice. We hope that in the majority of cases you will be able to raise concerns with the ABPI Head of Education & Exam. You may tell them in person or put the matter in writing if you prefer. The ABPI Head of Education & Exam may be able to resolve your concern quickly and effectively in their report to the ABPI Chief Executive.

We encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. The ABPI will treat all disclosures seriously and will investigate as appropriate, where possible with confidentiality respected. After having made initial inquiries ABPI reserves the right to contact third parties including the police or known employers of affected persons to report any suspected serious misconduct. 

If you are unsure whether a particular act constitutes something to be reported, or you have any queries we encourage you to contact the ABPI Head of Education & Exam as soon as possible including by contacting the Invigilator during the process of an exam. If you feel that the ABPI Head of Education & Exam has not sufficiently addressed your concern within initial investigations, or you prefer not to raise it with them for any reason, you should contact the ABPI Chief Executive directly. 

The ABPI Chief Executive acting through the ABPI Head of Education & Exam is responsible for setting the curriculum, exam questions and quality assuring the exam process with IQ. The ABPI Chief Executive has overall responsibility for this policy and for reviewing the effectiveness of actions taken in respect of concerns raised under this policy, particularly in relation to the conduct of exams.

Investigations

We will arrange a meeting with you as soon as possible to take down a written summary of your concern and to discuss your concern. You may bring another person of your choice with you to any meetings held under this policy. We ask that your companion respects the confidentiality of your disclosure and any subsequent investigations. We will provide you with a copy of the written summary after the meeting as soon as reasonably possible. 

Once you have raised a concern, ABPI Head of Education & Exam will carry out an initial assessment to determine the scope of any investigation and will communicate with you to give an indication of how we propose to deal with the matter. You may be required to attend additional meetings in order to provide further information about the circumstances of your complaint. 

The investigation will then be put by the ABPI Head of Education & Exam to the ABPI Chief Executive  who will decide the outcome of their assessment. This communication will be sent to: (a) you; (b) the individual(s) under investigation; and, where appropriate, (c) members of the individual’s employer’s legal or management teams (where appropriate) and any external authorities who may need to consider whether action should be taken. 

We will aim to keep you informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent us giving you specific details of the investigation or any disciplinary action taken as a result. You should treat any information about the investigation as confidential.

Outcome

If a conclusion decided by the ABPI Chief Executive is that there has been serious inappropriate behaviour by someone, including any activity amounting to an offence under the Bribery Act, or leading to a pecuniary advantage obtained by deception, that conclusion will be promptly reported to the ABPI Exam Appeal Board and where appropriate and not already involved to any external authorities including the Police and any employers affected.

While we cannot guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way. By using this policy you can help us to achieve this. If you are not happy with the way in which your concern has been handled either during the process or after a result has been published by the ABPI Chief Executive, you can raise it with the independent ABPI Exam Appeal Board.

Having received the investigating officer’s report, the ABPI Chief Executive and the ABPI Exam Appeal Board might decide to prescribe any or all the following sanctions:
No further action
No case to answer
Award a mark of zero for the paper/unit concerned for relevant persons
Ask a candidate to retake or undertake further examination papers/units under the direct supervision of the ABPI Head of Education and Exams 
Refer the matter to the employer of the relevant person(s) or to the appropriate national authorities

Appeals

As a whistle-blower you may appeal against any decision made by the ABPI Chief Executive by writing within 14 days of notification of the result to the ABPI Head of Education & Exam who will refer the matter to the independent ABPI Exam Appeal Board to make a final decision. The appeal must set out the grounds and further information on which the appeal is being made.

The following grounds of appeal are applicable for whistle-blowers and candidates to give:
New evidence which could not reasonably have been made available at the original disciplinary hearing or
A procedural irregularity occurred which had a detrimental impact on the outcome of the disciplinary hearing, or
The penalty imposed was disproportionate given the nature of the alleged disciplinary offence.

The appeal may uphold, remove or amend any terms of the candidate under investigation’s outcome. The ABPI Exam Appeal Board decision is final.




Contacts

ABPI Head of Education & Exam 
Sarah Jones 
+44 (0) 207 9303477 
exams@abpi.org.uk 

ABPI Chief Executive
Stephen Whitehead   
+44 (0) 207 9303477​
getintouch@abpi.org.uk

ABPI Exam Appeal Board
Independent lawyer
Chair of ABPI Exam Governance Committee 
Medical Expert Network representative 

Contact in writing via ABPI exams@abpi.org.uk or
7th Floor Southside, 105 Victoria Street London SW1E 6QT
Public Concern at Work (Independent whistleblowing charity)
Helpline: (020) 7404 6609
E-mail: whistle@pcaw.co.uk 
Website: www.pcaw.co.uk ​


© ABPI 2016