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Section 1: Purpose and scope. 

1.1 Frontline aims to provide fair and consistent treatment for all leaders, staff and contractors who are involved with any aspect of the Pathways programme. It also has a duty to take reasonable steps to protect the learning environment from harm and to ensure the Pathways programme is a safe and secure environment for everyone. To fulfil this Frontline has expectations in relation to conduct of its stakeholders.  

1.2 We are committed to achieving an inclusive culture that encourages, supports, and celebrates diversity in all its forms. Part of our responsibility in making that possible is to have a clear, transparent, and simple process for when an incident needs to be escalated. We have a zero-tolerance approach to discrimination, harassment or bullying on grounds of age, disability, gender (or sex), gender reassignment, race, religion or belief, sexual orientation, pregnancy and maternity, marriage and civil partnership, or any other grounds. All allegations of discrimination are dealt with seriously, confidentially (as far as is practicably possible) and swiftly.  

1.3 This policy extends to responding to incidents of an alleged breach in the Leader Charter and/or Training and events code of behaviour policy.    

1.4 This policy relates to leaders, contractors and suppliers attending, observing, contributing to, or providing services at or for any Pathways programme training and events. Reports of discrimination and/or inappropriate behaviour concerning Frontline staff will be dealt with in accordance with Frontline’s internal reporting discriminatory incidents policy and in some cases, Frontline’s internal disciplinary policy.  

1.5 There are a range of possible consequences for those who engage in discriminatory or inappropriate behaviour, depending on the circumstances.  

1.6 In serious cases, this could end in withdrawal of place on the programme (for leaders) or termination of contract (for contractors and suppliers). However, we recognise that discrimination and inappropriate behaviour can often be unintentional and due to a lack of awareness and/or education. Whilst this does not make the incident any less harmful, we may decide the best approach is restorative which could include additional training, education, and apologising. In any situation, we will always discuss with the individual impacted or witness and take what they would like to happen on board. 

Section 2: General principles. 

2.1 Frontline encourages a culture in which all members of its community feel empowered and confident to challenge and/or to report unacceptable behaviour. 

2.2 Reasonable effort will be made to communicate the regulations set out in this policy and all stakeholders are expected to be familiar with them. Ignorance of these regulations will not be deemed an acceptable reason for not behaving in the expected ways. 

2.3 Following receipt of a complaint, Frontline will begin an investigation into the allegations of improper conduct.  

2.4 Frontline will take a sensitive approach in enacting this policy and will ensure reasonable effort to maintain anonymity when investigating and discussing this with third parties. 

2.5 Frontline recommends concerns to be raised within thirty days of the alleged incident. Frontline reserves the right to consider cases under this policy outside of the thirty-day window, particularly where they are of a sensitive and/or serious nature. 

2.6 If anyone’s behaviour breaches the code of conduct, we reserve the right to withdraw them from the programme. Depending on the nature of the breach we may consider the need to inform a Local Authority/employer.  

2.7 Proceedings related to escalated incidents are internal Frontline processes that, while subject to law, are not themselves legal proceedings. Frontline does not have the legal investigatory powers of the police and does not determine criminal guilt. These proceedings focus on whether Frontline’s expectations for stakeholder behaviour have been breached and are not to be regarded as a substitute for a police investigation or criminal prosecution. Frontline reserves the right to refer cases to the police where it is considered they may constitute a criminal offence. 

Section 3: Reporting a breach of leader charter and code of behaviour.  

3.1 This policy aims to set out a clear procedure for any incidents that are deemed to require escalation. The process is outlined in sections 4-6 below.  

3.2 Where a person is witness of inappropriate behaviour they should intervene where appropriate.  

3.3 Where a person is informed of, subjected to or witness of inappropriate behaviour (and it is not appropriate to intervene), this should be escalated to a senior staff member (if in person) or made in writing via the pathways programme email address:

Section 4: Investigating a breach. 

4.1 We know that disclosing a breach of the leader charter and/or code of conduct can be difficult and Frontline endeavours to support individuals who have made a report throughout the process.  

4.2 Frontline will aim to complete investigation within 30 days of receiving the alleged breach. 

4.3 Upon receipt of an alleged breach of this policy, the relevant Pathways Programme Manager in conjunction with the Principal Programme Lead and/or Principal Curriculum Lead will investigate the incident.  

4.3.1. if the incident relates to the above-named roles the report will be escalated to the Head of Leadership Programmes or Head of People. In either case, Frontline’s Director of Diversity and Inclusion may be consulted in relation to the report. 

4.4 The investigating officer will arrange a follow up conversation with the person reporting the breach to find out further details and understand how they would prefer to proceed. 

4.5 The investigating officer will normally contact the person alleged to have breached the policy to gain their perspective of the incident and whether they accept or contest the allegation. 

4.6 The investigating officer may contact persons who have witnessed or are aware of the incident if necessary to gain further information. 

4.7 Upon conclusion of the investigation and the assessment of possible risk, the investigating officer should recommend one of the following outcomes: 

4.8 The outcome of the investigation and any actions taken will be formally communicated to the leader impacted (if known) via email and opportunity for a meeting to discuss this will be offered. 

Section 5: Formal Meeting 

5.1 A formal meeting is an opportunity for Frontline staff (usually Pathways Principal programme lead or Principal Curriculum and Learning lead) to discuss with the leader the incident in question, any contextual factors and the individuals plans to ensure that the behaviour in question does not recur. 

5.2 The matter may be referred to a formal meeting on the following conditions: 

5.3 Following a formal meeting the Pathways Principal programme lead or Principal Curriculum and Learning lead will determine the outcome of the case, which will include one of the following penalties: 

Section 6: Dissatisfaction with outcomes and appeal process 

6.1 Where a leader is dissatisfied with the outcome of a complaint under this policy, they may submit a complaint to Frontline’s complaint team at

6.2 Disagreement with the outcome of the disciplinary procedure does not in and of itself constitute a ground for a complaint.