IB whistleblowing policy

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The IB adopted the whistleblowing policy in November 2023.

If, after reading the policy, you would like to report a concern, see the contact section below.

Purpose of the IB whistleblowing policy

The IB values openness, integrity, probity, and accountability to the highest standards. The IB supports a speak-up culture and encourages reporting of any instances of suspected unethical, illegal, corrupt, fraudulent, or undesirable conduct involving the organization’s activities in line with this policy. The IB provides protections and measures to individuals who make disclosures in relation to such conduct without fear of victimization and reprisal. 

What can be reported? (“Scope”) 

The following violations can be reported under this policy. 

  1. A breach or a threat of breach of national or EU law on the following topics: public procurement; financial services, products and markets, prevention of money laundering and terrorist financing; product safety and product conformity; transport safety; protection of the environment; radiation protection and nuclear safety; food and feed safety, animal health and welfare; public health; consumer protection; protection of privacy and personal data, and security of network and information systems.
  2. An act or omission where the public interest is at stake in the event of:
    • a breach or threat of breach of a law applicable to the IB;  
    • a breach or threat of breach of internal rules of the IB provided they are based on a regulatory provision; or  
    • a threat to public health, to the safety of persons, to the deterioration of the environment or to the proper functioning of the organisation as a result of an improper act or omission, if it regards something that affects multiple people, occurs regularly or can have serious consequences.  

Who can report? (‘Whistleblower’) 

Anyone who has acquired information about breaches within Scope in a work-related context1 (i.e., individuals with a current, former, or future working relationship with the IB) and who could suffer retaliation such as dismissal, suspension, demotion, and other forms of retaliation.  

Conditions for protection 

A Whistleblower must be in a work-related relationship with the IB and have a reasonable belief the information being disclosed is true at the time of reporting and the disclosure must be within the Scope of this policy.  

A work-related relationship includes the following roles: staff members; trainees; interns; volunteers; self-employed; applicants; management; board members; non-executive directors; suppliers; contractors; subcontractors and advisors. 

Where can you report? 

You can report internally to the IB’s dedicated whistle-blowing channel or externally to a competent authority.  

How can you report internally? 

You can report concerns confidentially online, orally by telephone during UK, Netherlands and Swiss working hours, by voicemail at any time or in person during UK and Swiss working hours to the CXI team (UK) or Legal & Compliance team (Switzerland). See below for contact details. 

If you leave a message in a voice recording system, then you thereby agree to allow the IB to keep the message. If you provide information over the phone, the IB should transcribe the call and you should be given an opportunity to check, rectify and agree to the transcript and sign it. If the IB wishes to record the call, then you must provide prior written consent. If you request an in-person meeting, minutes should be taken and you should be given the opportunity to check, rectify and agree to it or have a recording made of it with your prior consent. 

Anonymous reporting is possible. However, if you would like us to follow-up, you must provide an e-mail. 

Confidentiality of disclosures 

The IB will treat the whistle-blower and other persons mentioned in a report confidentially and prevent access to the report to non-authorised employees. The IB will comply with confidentiality obligations required under the relevant legislation relating to the recording of reports and their follow-up. 

Reporting procedures and timelines  

The IB whistleblowing team will receive and record all reports logged via the internal whistleblowing channels and reports will remain traceable and auditable for a period of time in accordance with the relevant regulations (such as GDPR). 

The whistleblowing team consists of a small number of staff authorised to receive and review reports and if necessary, refer them to Legal and Compliance for further review.  

The independence of Legal and Compliance is guaranteed by having in place a Compliance Charter under which Legal and Compliance reports into the Finance Audit and Risk Management (FARM) Committee for matters reported under the whistle-blowing policy. 

A whistleblower may consult a confidential advisor. Please indicate in your report if you wish to speak to an internal confidential advisor. You are always allowed to speak to an external advisor. 

The IB will acknowledge receipt of whistle-blowing reports within seven days and provide feedback regarding the report within three months from acknowledgement of receipt. Feedback may relate to information on the assessment or investigation of the report or the progress of the investigation process.  

The IB will comply with data protection laws, will keep records safe, collect only what is necessary and store data about reports no longer than necessary. 

Annual reporting  

The whistle-blowing team will submit an annual report to the FARM Committee and the Works Council in the Netherlands. 

Protection provided to whistleblowers 

If you report an incident under this policy, the IB will protect you and ensure you are not disadvantaged because you made a disclosure. This includes protection from dismissal or demotion and from threatening, coercive or intimidating behaviour. For example, the IB may not dismiss or offer a lower position because of your report. Nor should the IB intimidate, bully, exclude, or coerce you. You are protected from harm if your report is based on reasonable grounds at the time, you make the report. This means that your suspicion is not based on hearsay. You must have seen or experienced things yourself, and for example (list documents, e-mails, photos or other evidence) and be able to show on which you base your suspicion. 

If you report an incident, the IB may not prejudice you and the IB would be required to prove it had not done so in legal proceedings. 

The person making a report in the scope of this policy is indemnified from procedures (e.g. breach of confidentiality, prohibited information acquisition, defamation, copyright infringement, disclosure of trade secrets or protection of personal data). 

Revision of this policy  

This policy will be revised regularly by Legal & Compliance to ensure it complies with all laws applicable to the IB. The executive team and the Works Council (The Netherlands) will approve and periodically review this policy.  

Questions or further information 

Contact the Legal and Compliance team if you have any questions about making a notification.

Report a concern

A. Make an online report

B. Report by telephone

You can make a report by telephone by contacting +44 (0)29 547 767 during UK, Netherlands and Swiss working hours to the CXI team or you can leave a voicemail at any time. 

C. Report in person

You can contact us in person to make a report during UK and Swiss working hours to the CXI team (Cardiff) or the Legal & Compliance team (Geneva). 

Report a concern

Your relationship with the IB (If you do not have an IB role, the “Feedback about services provided by IB World School” page explains how you can contact us. If we receive contact from you through this channel in these circumstances, we will refer you to this page*.)
Which section of the policy scope does your report relate to?
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*Visit the Feedback about services provided by IB World Schools page for more information.

**In order to benefit from the protection offered by the policy, you must believe your concern is based on reasonable grounds and you must have direct experience of the action or omission that led to your report.  

If your concern is not with either of the sections mentioned above, it is unlikely to qualify as whistleblowing. Contact your line manager or your local human resources team for further information. 

Next steps 

After you submit this form, we will acknowledge receipt of your notification within seven days. We may contact you at this stage to clarify any information you provided. 

Following investigation, we will provide feedback, which may be written or oral, within three months. In all circumstances, we will keep a record of the feedback provided securely with other information relating to your report.