Maladministration, Malpractice, Plagiarism and Whistleblowing Policy

1. POLICY STATEMENT

DTMK Limited is committed to maintaining the highest standards of integrity, fairness, transparency, and regulatory compliance in all aspects of its operations.

This policy sets out the arrangements for preventing, identifying, reporting, investigating, and managing cases of maladministration, malpractice, plagiarism, collusion, cheating, and whistleblowing disclosures. It applies across all regulated and non-regulated training and qualifications delivered by DTMK Limited.

DTMK Limited will:

Take all reasonable steps to prevent malpractice, maladministration, plagiarism, collusion, and cheating
Manage all concerns promptly, thoroughly, fairly, and impartially
Notify the relevant Awarding Organisation immediately where required
Cooperate fully with any external investigation, monitoring activity, or regulatory requirement
Protect staff, contractors, learners, and partners who raise genuine concerns in good faith from detriment, victimisation, or retaliation

2. SCOPE

This policy applies to all individuals involved in the development, delivery, assessment, quality assurance, administration, or award of training or qualifications delivered by DTMK Limited, including:

Directors
Employees
Contractors and associates
Trainers, Assessors, and Internal Quality Assurers
Learners registered with DTMK Limited
External or third-party individuals engaged in qualification delivery, assessment, or quality assurance

It applies to all activities relating to:

Training and qualification delivery
Learner assessment and internal quality assurance
Record keeping and certification claims
Communication with Awarding Organisations and regulators

This policy covers:

Suspected or confirmed malpractice
Suspected or confirmed maladministration
Plagiarism, collusion, and cheating
Whistleblowing disclosures made in the public interest

3. DEFINITIONS

Malpractice

Any deliberate act, neglect, default, misconduct, or unethical practice that compromises, or could compromise, the integrity of training delivery, learner assessment, quality assurance, certification, or administration. Malpractice includes any action that prejudices learners, undermines confidence in qualifications, or breaches awarding organisation or regulatory requirements.

Examples include falsification of records, collusion, cheating, plagiarism, misuse of position, unauthorised disclosure or use of assessment materials, deliberate failure to follow procedures, inappropriate assistance to learners, discrimination or bias, and misrepresentation of approval or certification status.

Maladministration

Any activity, error, omission, or poor practice resulting in non-compliance with required administrative or procedural arrangements. This may arise through error, neglect, or mismanagement.

Examples include incorrect learner registration, inaccurate certification claims, failure to maintain auditable records, delays or failures in communication, mishandling of assessment documentation, or failure to follow internal procedures. Persistent or serious maladministration may be treated as malpractice.

Plagiarism

The submission of another person’s work, ideas, words, or outputs as one’s own without appropriate acknowledgement or referencing, whether done deliberately or unintentionally.

Plagiarism includes, but is not limited to:

Copying from published sources, websites, or learning materials without appropriate referencing
Submitting work that is identical or highly comparable to another learner’s work
Collusion between learners or between learners and staff
Cheating in assessments or examinations
Use of Artificial Intelligence generated content submitted as a learner’s own work without appropriate acknowledgement, verification, and referencing

Use of AI tools does not remove the requirement for learners to demonstrate their own knowledge, understanding, skills, and competence. Even where AI generated content is referenced, its use may still be treated as plagiarism or malpractice where it undermines the validity of assessment evidence.

Plagiarism, collusion, and cheating are treated as forms of malpractice.

Whistleblowing

The disclosure of information relating to suspected wrongdoing, malpractice, maladministration, or the covering up of such issues, where the disclosure is made in the public interest.

This may include concerns relating to safeguarding, criminal offences, health and safety breaches, financial irregularities, regulatory non-compliance, unethical behaviour, or actions that may adversely affect learners or public confidence.

Whistleblowing is distinct from complaints and appeals, which are managed under separate procedures.

4. RESPONSIBILITIES

Directors and Responsible Person

The Director, as Responsible Person, has ultimate accountability for preventing, identifying, and managing malpractice and maladministration within DTMK Limited.

Responsibilities include:

Ensuring effective systems, controls, and procedures are in place
Ensuring all staff and contractors are aware of this policy and their responsibilities
Notifying the relevant Awarding Organisation immediately upon suspicion of malpractice or maladministration, regardless of any internal investigation
Leading or commissioning investigations where appropriate
Cooperating fully with Awarding Organisation, regulatory, or external investigations
Implementing corrective actions and monitoring their effectiveness

Trainers, Assessors, and Internal Quality Assurers

Must:

Follow all awarding organisation, regulatory, and internal procedures
Act with integrity and professionalism at all times
Maintain accurate, complete, and auditable records
Ensure assessments are conducted under appropriate conditions
Actively monitor for plagiarism, collusion, and cheating
Escalate any concerns immediately to the Responsible Person

Learners

Must:

Submit work that is their own and in their own words
Appropriately reference any sources used
Comply with assessment rules and conditions
Refrain from plagiarism, collusion, and cheating
Report concerns where appropriate

All staff and contractors

Must:

Act honestly, comply with this policy, and report suspected wrongdoing immediately.

5. PREVENTATIVE MEASURES

DTMK Limited implements preventative measures including:

Induction and refresher training for staff and contractors
Clear learner guidance on plagiarism, collusion, cheating, and assessment rules
Secure storage and controlled access to assessment materials
Appropriate invigilation of assessments and examinations
Assessment design that enables learners to demonstrate knowledge in their own words
Monitoring and verification by trainers and assessors, including questioning where required
Use of comparison methods and suitable software to identify plagiarism or AI generated content
Regular internal audits of registrations, assessments, QA activity, and certification claims
Ongoing risk assessment of delivery and assessment practices

6. REPORTING MALPRACTICE, MALADMINISTRATION, OR PLAGIARISM

All suspected or actual cases must be reported immediately using the DTMK reporting process.

Reports must be submitted to the Director or, where the Director is implicated, to an appropriate senior individual or directly to the Awarding Organisation.

Internal reporting and investigation do not delay or replace the requirement to notify the Awarding Organisation immediately upon suspicion.

All reports are:

Acknowledged promptly
Logged on the Malpractice Register. The Malpractice Register is an internal controlled document and is not publicly accessible.
Managed confidentially

7. INVESTIGATION PROCESS

Investigations will be conducted fairly, independently, and without bias.

They may be led internally by the Director or a nominated investigator, or externally by the Awarding Organisation.

The investigation process may include:

Evidence gathering and review
Interviews and witness statements
Analysis of records and assessment materials
Production of a written investigation report

Possible outcomes include:

No action required
Process improvement
Staff retraining
Disciplinary action
Learner disqualification or requirement to resubmit
Referral to the Awarding Organisation or external authorities

The Awarding Organisation may take control of an investigation at any stage and may impose sanctions, withhold certification, or revoke certificates where required.

8. WHISTLEBLOWING PROCEDURE

Concerns may be raised confidentially with the Director.

Where an individual feels unable to raise concerns internally, or where concerns are not addressed, disclosures may be made directly to the relevant Awarding Organisation or regulator.

Anonymous disclosures will be accepted and investigated where sufficient information is provided.

Whistleblowers raising concerns in good faith will be protected from retaliation or detriment.

Information disclosed may be shared with regulators, Awarding Organisations, or other authorities where required.

9. CONFIDENTIALITY AND DATA PROTECTION

All reports and investigations will be handled confidentially and sensitively.

Personal data will be processed only where necessary and in accordance with UK GDPR and the Data Protection Act 2018.

Confidentiality may be overridden where disclosure is required by law, regulators, courts, or law enforcement agencies.

10. RECORD KEEPING

All records relating to malpractice, maladministration, plagiarism, and whistleblowing will be stored securely.

Records will be retained for a minimum of five years and longer where required, including where sanctions, certificate invalidation, or appeals apply.

Records will be made available to Awarding Organisations or regulators upon request.

11. RELATIONSHIP WITH OTHER POLICIES

This policy incorporates and replaces the need for separate plagiarism and whistleblowing policies.

Complaints and appeals are managed under the Appeals, Enquiries and Complaints Policy and are not covered by this policy unless malpractice or maladministration is suspected.

12. REVIEW OF POLICY

This policy is reviewed annually or sooner if legislation, regulatory requirements, awarding organisation guidance, or operational practices change.

Last reviewed: February 2026
Next review due: 28th February 2027

Responsible Person: Christopher Cook, Director
Email: christopher@dtmk.co.uk