Date published: 30/07/2026

1.     How many incidences of whistleblowing has Scottish Qualifications Authority recorded in each of the last five financial years (please break down by year, 2021/22, 2022/23, 2023/24, 2024/25, 2025/26)?

2.     Does your whistleblowing policy encourage or direct whistleblowers to raise concerns with a "prescribed person" (as defined under the Public Interest Disclosure Act 1998). If so, please specify which prescribed person(s) are referenced.

3.     Does your whistleblowing policy or process guarantee anonymity to individuals who raise a concern? If so, please provide a copy of the relevant section of the policy addressing this.

4.     Does your whistleblowing policy include a non-recrimination or non-retaliation provision, protecting whistleblowers from detriment or reprisal as a result of raising a concern? If so, please provide a copy of the relevant section of the policy addressing this.

5.     Has your internal whistleblowing policy been subject to any external review, audit, or assessment (by an external body, auditor, regulator, or independent consultant) within the last five years? If so, please provide:

a.      the name of the body/organisation that conducted the review;

b.     the date of the review; and

c.     a copy of any resulting report or summary of findings, subject to any applicable exemptions.

1. There was one whistleblowing incident within the time period stated, in 2023/2024.

2. The whistleblowing policy encourages and directs whistle-blowers to raise concerns with the following organisations:

Accounts Commission for Scotland

Auditor General for Scotland

Audit Scotland

Children and Young People’s Commissioner Scotland

Commissioner for Ethical Standards in Public Life in Scotland

Commissioners for His Majesty’s Revenue and Customs (HMRC)

Competition and Markets Authority

Equality and Human Rights Commission

Financial Conduct Authority

Health and Safety Executive

Pensions Regulator

Revenue Scotland

Scottish Environment Protection Agency

Scottish Information Commissioner

3. Qualifications Scotland’s whistleblowing policy does not guarantee absolute anonymity to individuals who raise a concern. The policy explicitly distinguishes between confidentiality and anonymity.

While the policy states that every effort will be made to protect a whistleblower's identity, it outlines specific limitations regarding both confidential and anonymous reports.

The relevant sections of our Whistleblowing Policy addressing this are provided below:

Section 3: Confidentiality "If you make a disclosure under this policy, we will make every effort to keep your identity confidential. There may, however, be circumstances in which it will be necessary to disclose your identity, perhaps because of the nature of the investigation or disclosure made, or because personal evidence is essential. Proper investigation may prove impossible if the investigating manager cannot obtain further information from you. We will discuss this with you."

Section 1.4: Raising a disclosure or concern anonymously "If you raise a disclosure or concern anonymously, we will assess the anonymous information as best we can to establish whether there is substance to the concern and whether it can be addressed. However, our ability to investigate it fully will be limited if you cannot be contacted. It will also be more difficult for you to demonstrate your entitlement to protection under the Public Interest Disclosures Act (1998) if there is no evidence that it is you who has made the disclosure."

4. Qualifications Scotland’s whistleblowing policy includes a comprehensive non-retaliation and non-recrimination provision designed to protect individuals from detriment or reprisal.

The relevant section of the Whistleblowing Policy addressing this is provided below:

Section 3.2: Protection and support for whistleblowers "Under this policy, if you raise a genuine concern, you are protected from being subjected to any detriment or victimisation, or from being unfairly dismissed, because of your disclosure. You will not be subjected to disciplinary action or any other detriment, simply because you raise a concern under this policy.

If you believe that you are being subjected to a detriment within the workplace (whether by us or by a colleague) because of raising concerns under this procedure, you should inform the investigating manager (once appointed under the procedure), or the HR Shared Service team immediately.

Members of staff, or associated workers, who victimise or retaliate against those who have raised concerns under this policy may be subject to disciplinary action under our Disciplinary Policy. In serious cases, this may be treated as gross misconduct leading to dismissal without notice.

No one should be victimised for raising a disclosure, regardless of the outcome. Any such instances involving our members of staff will be fully investigated in line with the Dignity at Work Policy."

5. A. An external review was conducted by Grant Thornton UK LLP, an independent audit and consulting firm.

B.  The final report is dated August 2024.

C. The report provided a summary of findings of ‘Reasonable assurance with some improvement required.’ Overall, they concluded that in the areas examined, there were only minor weaknesses in the risk management activities and controls designed to achieve the risk management objectives required by management. Those activities and controls that were examined were operating with sufficient effectiveness to provide reasonable assurance that the related risk management objectives were achieved during the period under review.