policies and procedures
CT Skills provides opportunities for young people and adults to learn new skills gain confidence and maximise their potential. The learning programmes we deliver help young people and adults prepare for the world of work and give many adults employed in elementary positions their first formal qualifications. Promoting safe working practices and an understanding of rights and responsibilities at work are key components of all learning programmes. Working Together to Safeguard Children (2015) defines safeguarding as;
- protecting children from maltreatment;
- preventing impairment of children’s health or development;
- ensuring that children grow up in circumstances consistent with the provision of safe
and effective care; and
- taking action to enable all children to have the best outcomes.
Prevent is part of CONTEST, the Government’s Counter Terrorism strategy. It aims to stop people becoming terrorists or supporting terrorism. The Prevent strategy has three main
- to respond to the ideological challenge faced from terrorism and aspects of
extremism, and the threat faced from those who promote these views
- to provide practical help to prevent people from being drawn into terrorism and
ensure they are given appropriate advice and support
- to work with a wide range of sectors where there are risks of radicalisation that
needs to be dealt with
As part of the Prevent Strategy, CT Skills has a duty to have “due regard to the need to prevent people from being drawn into terrorism”.
The Prevent Duty: Guidance for further education institutions in England and Wales (2015) defines our role as helping prevent people being drawn into terrorism (violent and non violent extremism), which can create an atmosphere conducive to terrorism and can popularise views which terrorist exploit.
Extremism is defined in the Prevent Strategy as: “vocal or active opposition to fundamental British Values, including democracy, the rule of law, individual liberty and mutual respect
and tolerance of different faiths and beliefs.” This also includes calls for the death of members of the British armed forces.
Prevent also encourages promotion of the nine protected characteristics under the Equality Act 2010 (age; disability; gender reassignment; marriage and civil partnership, pregnancy and maternity, race, religion and belief, sex; sexual orientation).
If an individual is identified as vulnerable to extremism they would be referred through the Channel process. This process is a multi-agency approach to identify and provide support to
individuals who are at risk of being drawn into terrorism.
CT Skills understands there are two main aspects to Safeguarding, and promoting welfare of learners in the context of their work;
- minimising risks, and
- having arrangements in place to address concerns.
The aim of this policy is to define actions and behaviours expected by CT Skills employees and volunteers to ensure all learners are safeguarded against harm and abuse.
Please view the full policy by clicking on the Safeguarding and Prevent Policy below.
Policies Relating to Safeguarding & Prevent
Communications are an important and integral part of the everyday business and our ethos for all such communications is derived from the company’s core ‘PRAISE’ values:
- Service Excellence
CT Skills aims to achieve compliance with the policy by ensuring that all communications:
- are timely, relevant and accurate;
- always strive to adhere to any stakeholder deadlines and requirements;
- are set out in clear format and in plain English;
- are issued at the relevant times and in the manner appropriate to, or requested by, each stakeholder;
- are compliant with GDPR and other legislation;
- are approved by the relevant staff member or group as appropriate;
- are communicated through the relevant channels or posted to the appropriate medium as required;
- are displayed, stored or archived if appropriate.
CT Skills are committed to promoting equality of opportunity and eliminating discrimination in all those areas over which it has influence.Our aim is that our workforce and learners, both potential and actual, will be truly representative of all sections of society and will feel respected and able to give their best. To that end, the purpose of this policy is to promote equality in our employment and for those accessing our services and not to discriminate on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion and belief and gender or sexual orientation. We oppose all forms of unlawful and unfair discrimination.All employees, whether part-time, full-time or temporary, will be treated fairly and with respect. Selection for employment, promotion, training and any other benefit will be on the basis of aptitude and ability. All employees will be helped and encouraged to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise efficiency of the organisation.CT Skills are committed to widening access to its services and facilities to members of under-represented groups. This commitment is accompanied by the recognition that equality must encompass programme, teaching and learning issues.Responsibilities
The cooperation of all employees is essential to the success of this Policy. However, ultimate responsibility for achieving the Policy’s objectives, and for ensuring compliance with the relevant Acts of Parliament as well as the various codes of practice, lies with the company. CT Skills’ management are committed to the Policy and overall responsibility lies with the Senior Leadership Group. The Policy is underpinned by the Equality Action Points embedded within the Quality Improvement Plan which will focus attention on the key tasks to be met, monitoring and review. Please access our full Equality Policy here.
- CT Skills believes the protection of the environment is an integral part of good institutional business practice and that it has a duty to conduct all of its operations with due regard for the environment, and commits to maintaining and, wherever possible, improving the quality of the environment through continuous improvement of its management system. In addition, to advise and support others to share the CT Skills’ commitment through relevant best practice and communication, to make a positive contribution to the environment.
- CT Skills is furthermore committed to safeguarding the health, safety and welfare of all employees and of all other persons affected by its operations. To this end, the CT Skills management system promotes a proactive approach to identifying and reducing risks so as to facilitate a safe working environment for all its employees and those working under its control.
- Some CT Skills service users may be from particularly vulnerable groups, and operations are accordingly conducted in the specific context of emphasis on all learners being entitled to a safe, healthy and supportive learning environment.
- CT Skills seeks to make the most effective and efficient use of all resources to encourage all employers, learners, contractors and wider stakeholders to embrace an HS&E culture based on continual improvement in both management and performance. As part of this commitment, and aspirations to optimum standards of governance, CT Skills places HS&E considerations at the heart of all its business activities.
- CT Skills will review this Policy at least annually, ensuring that it reflects both the HS&E intentions and the overall direction of the organisation, and also continues to be appropriate to the nature and scale of its HS&E risks and impacts.
This Policy furthermore provides the framework for setting HS&E objectives and will be available to all interested parties. CT Skills holds and will maintain certification to relevant Standards ISO 14001 and OHSAS 18001.
In particular, CT Skills, will:
- Meet all relevant legislation, government guidelines, regulations, codes of practice and other requirements as set in Health and Safety at Work etc. Act 1974, Management of Health & Safety at Work Regulations 1999 & 2006, Environmental Protection Act 1990, GDPR 2018, and associated Legal Requirements.
- Ensure that, on a continual improvement basis, HS&E hazards and aspects are identified, risks assessed and suitable management controls put in place to prevent injury, ill health and adverse environmental impacts.
- Develop management processes to ensure that HS&E factors are considered during planning and implementation.
- Engage with learners, employees, contractors and wider stakeholders to further reduce HS&E risks and impacts associated with working for, with, or on behalf of CT Skills.
- Reduce resource consumption and prevent pollution to air, ground and water.
- Work with subcontractors to ensure that partners delivering CTS contracts are aware of our requirements and that they review and adopt environmental best practice appropriate to their organisation during delivery.
- Ensure that exercising due diligence in respect of HS&E responsibility is a condition of employment.
- Maintain a commitment to train all staff in Health, Safety and Environmental awareness.
All employees and managers have a statutory responsibility with regard to CT Skills’ Health, Safety and Environmental obligations. Overall operational responsibility lies with the Chief Executive Officer, Directors and the Heads of Operations.
CT Skills places a premium on the excellence of service delivered and on making its customers feel as committed to CT Skills as it is to them.
CT Skills strives to provide training and development services that are of high quality and exceed national standards. Teaching and learning strategies are geared towards inspiring learners to achieve qualifications, gain employment and progress to higher levels of learning and job security.
CT Skills is intent on meeting and, where practicable, exceeding the requirements and expectations of its range of stakeholders and using the invaluable feedback from them to inform continuous improvement planning.
CT Skills provides professional development, support and motivation for all staff. They are further empowered to each be a key and integral part of the continuous improvement cycle to which CT Skills is committed and which underpins all CT Skills quality endeavours.
CT Skills ensures that all learners, staff and partners are valued, respected and given the best opportunities to succeed.
CT Skills aims to achieve the above by:
- Fulfilling contractual obligations to ensure the business is able to provide the optimum level of teaching and training to its learners and aspire to exceed the national qualification success rates.
- Providing excellent customer care, responding promptly and productively to the views of learners, partners, employers and other interested parties, using this information to inform improvement planning.
- Formulating a strategic business plan which can accommodate change and meet the expectations of its diverse stakeholder group.
- Using effective management information systems to monitor progress in the achievement of quality objectives, targets and key performance indicators.
- Taking the strategic decision to adopt an Integrated Management System that aligns with Quality Management System ISO 9001 and incorporates other national and international standards and requirements (ISO 14001, OHSAS 18001, Investors in People, Common Inspection Framework, Matrix and the Qualifications Curriculum Authority).
- Ensuring that the Quality Management System enables consistent achievement of business objectives and targets, meeting customer requirements and delivering products that meet required quality standards.
- Achieving compliance with applicable statutory and regulatory requirements.
All Directors, Managers and staff within the company are individually and collectively responsible for the quality of their work and the service they provide to both internal and external customers, and for promoting and demonstrating the organisation’s core values: Pride, Respect, Accountability, Integrity and Service Excellence (‘PRAISE’).
The Directors and the Strategic Leadership Group are responsible for communicating and verifying comprehension of this Policy across the business; for monitoring the Quality Management System, for reviewing it for continuing suitability and for reporting to the CEO the Management System’s implementation, status and effectiveness.
Whilst we hope your time and contact with CT Skills has been positive and smooth, we understand we may not have got it always right. We appreciate any feedback good or bad in order to help us ensure the right learning journey for you and our future learners. In order to contact us to let us know how we are doing you talk to us in the following ways:
- Fill in our form: Complaints form (below)
- Via text on 07880 510452;
- By email to firstname.lastname@example.org;
- Face to face with a member of staff.
What happens when you give us your feedback?
CT Skills take pride in meeting your individual needs and adjusting working practices to accommodate specific needs. However, if you feel that you have not been treated fairly or are unhappy with a service you have received, you can make a complaint by following the procedure below.
- An informal discussion with a member of our staff may well be able to resolve your issue. A written record of the discussion will be kept, detailing any actions we have agreed.
- If the issue needs a more formal resolution, a grievance form will be completed to record the issue in writing. This will then be investigated by a member of the management team.
2.1. If the formal or informal attempts at a resolution fail, the issue will be raised with the Chief Executive Officer to decide upon a resolution.
CT Skills is committed to being transparent about how it collects and uses the personal data of its learners, staff and others, and to meeting data protection obligations, in accordance with the General Data Protection Regulations (GDPR) May 2018. This policy sets out the organisation’s commitment to data protection, and individual rights and obligations in relation to personal data.
This policy applies to all personal data processed for HR-related and business purposes such as, but not limited to; the personal data of learners, parents and guardians, job applicants, employees, workers, contractors, volunteers, interns, apprentices and former employees. CT Skills processes personal data in accordance with the following data protection principles:
- The organisation processes personal data lawfully, fairly and in a transparent manner;
- The organisation collects personal data only for specified, explicit and legitimate purpose;
- The organisation processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing;
- The organisation keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay;
- The organisation keeps personal data only for the period necessary for processing;
- The organisation adopts appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.
CT Skills will, within the rules of the Loans Bursary Fund (‘the Fund’), and to the best of its ability, allocate the Fund to help support eligible vulnerable learners to undertake and achieve their aims and qualifications. Such vulnerable learners may include those with learning difficulties or disabilities, parents who need help with childcare, and ex-military personnel. The Fund will be distributed at the discretion of CT Skills and is not an automatic entitlement to any loans-funded learner. CT Skills will grant Fund moneys to the most vulnerable qualifying learners subject to compliance within the Fund guidelines and overall Funds within the bursary being sufficient. Learners qualifying for bursary funding may include the following:
- Discretionary Learner Support (DLS) type activity for hardship, childcare and residential support;
- Learning support (including exceptional Learning Support) type activity for ’in learning’ support.
CT Skills is committed to promoting equality of opportunity and eliminating discrimination in all those areas over which it has influence. Our aim is that our workforce and learners, both potential and actual, will be truly representative of all sections of society and will feel respected and able to give their best. To that end, the purpose of this policy is to promote equality in our employment and for those accessing our services and not to discriminate on the grounds of gender, marital status, race, disability, sexual orientation, religion/belief or age. We oppose all forms of unlawful and unfair discrimination. Our policy of awarding bursary Funds to eligible qualifying learners adheres to all aspects of our equality and discrimination policies. Click here to read our full equality policy and here to read our complaints procedure.
Supply chain partnerships (management and fee policies 2020-21)
CT Skills is committed to providing a well-managed and high standard of approved subcontract partnership delivery for the benefit and progression of our employers and learners.
This policy sets out the key aims and requirements of the CT Skills partnership policy for 2020-21 within the ESFA and ESF funded contract delivery provided.
Use of subcontract partners
CT Skills (CTS) works with subcontracting partners for a number of reasons which can include:
- Provision of specialist sector support for learners;
- Provision of specialist geographic support for learners;
- Supporting wider engagement in the learner community through partnerships with third sector organisations (voluntary and charity partners);
- Supporting wider engagement with partners who can access harder to help and disadvantaged learners, including focus on equality and diversity delivery;
- Strengthening partnership delivery through embedding our own CTS core skills and experiences into the subcontracted delivery through identification of learners and employers and providing resource to complement the partner’s in-house delivery.
CTS will only subcontract with partners who are approved providers within the ESFA Register of Training Organisations (ROTO) and / or the Register of Apprenticeship Training Providers (RoAPT) assurance gateway as appropriate.
CTS will ensure that any delivery through sub-contracting agreements will follow the Subcontracting obligations contained in the ESFA Funding Rules and the relevant Subcontractor Policies, the terms of which will not differ materially from the applicable ESFA master contract between each funding body and CTS.
Commitment to improving the quality of teaching and learning
CTS is committed to continuously improving its own quality of teaching and learning and extends this support to its subcontract providers including through sharing of CTS teaching and learning policies, areas with identification for improvement, learning tracking systems, and resource support for delivery observations and recommendations.
CTS requires high standards of teaching and learning quality from its delivery partners but also recognises that some partners benefit from support in this area and therefore provides this within its core partnership delivery policies.
CTS holds 9001 Quality, 14001 Environmental, and 18001 HS&E quality accreditations. Within these subcontractor management relationships the company supports and encourages subcontractors to adopt appropriate elements of these processes and best practice as an integral part of the wider commitment by CTS to these standards.
Subcontract partner contracts and management fee structures and charges
Viability of contracts and associated management fee charges are agreed with subcontract partners dependent upon an assessment of criteria including:
- Date of establishment and financial stability of partner;
- Assessment of teaching and learning capability and wider quality issues;
- Desirability of sector, geographic, and socio-economic provision;
- Engagement with local employers and learners and evidence of progression routes;
- Size of delivery contract proposed;
- CTS risk assessment of ability of partners to deliver contract volumes and required quality of outcomes;
- Levels of additional CTS support requested by subcontract partners;
- Promoting British values and Citizenship.
For ESFA contracts CTS will agree bespoke subcontractor fee charges with each subcontractor in line with ESFA contracting requirements for 2020-21.
For non-ESFA contracts, and for ESFA contracts in prior years, core management fee charging structures are based on 20% of ESFA income drawdown for a standard level of support with additional charges being made for higher levels of support or for administration costs and disbursements where these are paid or incurred directly by CTS on behalf of a partner.
Payments to partners for satisfactory contract delivery are made within 30 days following each monthly upload deadline.
Subcontract partner support packages
To support and protect the required level of delivery service from subcontract partners, CTS provides the following management and guidance to delivery partners within the core fee structure:
- An annual contract (based on the overarching Government funding body contract) detailing values of contracts and standards of delivery and learner service required;
- The services of a designated contract manager and support from CTS in-house quality and HSE resources;
- Regular monthly performance updates and administration support for claims procedures and queries;
- Annual performance tracking to contract, forecast out-turn and profiling support;
- Procedures for validating earned funding claims using ESFA evidence of learning rules;
- Learner claim file audits, evidence checking and compliance recommendations.
- Regular partner review meetings and CTS best-practice forums incorporating specific training around quality of delivery and improvement plans;
- Quality of teaching and learning observations and recommendations;
- Support, health and safety audits and recommendations.
Policy review dates and communication
CTS reviews its subcontract partner policies at least annually and publishes this policy on its corporate website in addition to providing all subcontract partners with copies and support directly.
Prior year subcontracting activity and declarations
CT Skills is committed to safeguarding the health and wellbeing of all employees, learners and visitors, and to maintaining compliance with all current smoking legislation.
Exposure to second hand tobacco smoke has been medically proven to increase the risk of heart disease, lung cancer and other serious illnesses. It is, therefore, the intent of this policy to declare that all CT Skills premises be one hundred percent ‘No Smoking’, including the use of any electronic cigarettes, vaporisers or associated unregulated products.
This policy covers all CT Skills premises and learning centres, and extends to all buildings, rooms, corridors, car parks and grounds.
In particular, CT Skills, will:
- Meet all relevant legislation and government guidelines (e.g. The Health and Safety at Work Act 1974, Health Act 2006)
- Provide a healthy working environment and protect the current and future health of employees, learners, customers and visitors.
- Guarantee the right of non-smokers to breathe in air free from tobacco smoke.
- Raise awareness of the dangers associated with exposure to tobacco smoke.
- Take account of the needs of those who smoke and to support those who wish to stop.
A support service to help empower smokers to give up is offered by the NHS. The NHS Smoke free service can be found at www.nhs.uk/smokefree
Supporting compliance with the law and the organisation’s Smoke Free Policy will be the responsibility of the Chief Executive Officer, Directors and Heads of Operations.
All members of staff are responsible for ensuring their own compliance with the law and this Smoke Free Policy, and for reporting any known non-compliance to their Line Managers, who have responsibility for investigating and initiating appropriate action.
CT SKILLS is a responsible employer and takes its fire safety duties seriously. For this reason we have formulated this policy to help us comply with the REGULATORY REFORM (FIRE SAFETY) ORDER 2005. In compliance with this legislation, we will adopt a risk assessment based approach to managing fire safety within our premises. Based on the findings of the fire risk assessment (FRA) we will also create an emergency action plan, which provides explicit guidance to all staff, learners and visitors to ensure that in the event of a fire our premises are safely evacuated.
This policy covers all sites, learning centres and areas under CT Skills’ control.
In particular CT Skills will:
- Meet all relevant legislation, government guidelines, regulations and industry codes of practice on Fire Safety.
- Ensure that, on a continual improvements basis, all Fire hazards are identified, risks assessed and suitable controls put in place to ensure Fire Safety.
- Engage with employees, contractors and visitors to further reduce Fire Hazards and risks associated with working for, with, or on behalf of CT Skills.
- Develop our management processes to ensure that Fire Safety is considered during planning and implementation of any operations.
- Maintain a commitment to train all staff in Fire Safety awareness.
- Maintain a commitment to train all staff that are responsible for designated roles, such as Fire Wardens.
All employees have a duty to take reasonable steps to ensure that they do not place themselves or others at risk of harm. They are also expected to co-operate fully in complying with any fire precaution procedures that are introduced as a measure to protect the safety and well being of our staff, learners, visitors and premises. All employees have a responsibility to make sure they sign-in and sign-out of CT Skills buildings accordingly, and are familiar with the layout of the building, noting where fire exits are and where they lead. They must also ensure the correct use of fire doors and ensure that all fire exits and evacuation routes are clear at all times.
We will keep staff informed of any changes that are made to our fire safety procedures and FRA. We will also ensure that all learners and visitors to our premises are asked to sign-in on arrival, briefed on the evacuation procedure, issued with a visitor/identification card, and supervised by a member of staff at all times. All learners will be given a site tour of the building they attend, including exit routes, final exits and assembly points, as part of their induction.
CT Skills endeavour to provide a safe and secure learning environment for every learner that attends training and education with them. For those with specific financial hardship that prevents them from taking part in learning there is the Discretionary Learner Support (DLS) available. Please be assured that the DLS arrangements in place for CT Skills learners are dependent on their financial circumstances and should not under any circumstances be based on any other discriminating factor. The criteria and procedures operated by CT Skills for considering and making payments are based on funding rules issued by the SFA. The funds are ultimately used to support those most in need to achieve whilst learning with CT Skills. Please note, awards are subject to fund availability and are not an entitlement. They are also awarded on the expectation a learner should aim to achieve at least 90% attendance. Assessment and documentation for eligibility for will be held in the strictest confidence within a one to one session. Evidence of benefits are required. If you are on an Apprenticeship programme within an employers premises then unfortunately you are not eligible for any travel support. Any costs for you to travel to workshops must be covered by your employer.
How we can support you?
Within DLS there are several strands to the funding. The details below show how they are broken down and who is eligible.
19+ Hardship Fund
This funding maybe available to those on pre employment training programmes who are vulnerable and disadvantaged and the funding would remove financial barriers to learning. This may be to cover costs such as:
- Registration fees.
To evidence this we will require a copy of your Jobseekers Agreement (JSAG) or evidence you are claiming ESA (WRAG)
Funding maybe available to support learners over the ages of 20 who are at risk of not being able to start or continue learning due to childcare arrangements and are not receiving any support from other sources. CT Skills will pay the Ofsted registered provider directly at the end of each month on confirmation the learner attending training. Along with the usual evidence we require to ensure you can access funding for training we will also require:
- Details of Childcare provider and Ofsted number;
- A copy of your Jobseekers Agreement (JSAG) or evidence you are claiming ESA (WRAG).
The funding will only fund childcare for timetabled hours plus reasonable travel time to and from CT Skills premises.
Non payment of bursaries
CT Skills reserve the right to withdraw access to support payments for any reason deemed as misuse or abuse of the funding.
If you feel you have been discriminated against for whatever reason throughout the support payments process, the grievance procedure can be found in your learner handbook. Please ask for a copy if you no longer have this. If you wish to appeal against any decisions regarding bursary payments please contact the Senior Contracts Manager of CT Skills at Unit 1 Priory Court, Derby Road, Nottingham, NG9 2TA. They shall endeavour to investigate the situation and reply to your written communication within 10 working days.
What is Whistle blowing: CT Skills is committed to the highest standards of openness, accountability, and honesty. As a business we are committed to preventing fraud, corruption, and improper conduct. To help us achieve this you can speak up directly to us if you feel CT Skills is failing to maintain these standards via our Whistle blowing service.
Aim of the policy: CT Skills wants to reinforce and promote a culture that helps all our employees, and our wider stakeholders, to know that there is a safe alternative to silence and we will appropriately address serious concerns reported in good faith. It is in all our interests that any wrongdoing which threatens our business is identified and acted upon swiftly and with integrity. This Policy is designed to ensure that you can raise your concerns about wrongdoing or malpractice within CT Skills without fear of reprisal. It is also intended to encourage and enable you to raise serious concerns within the company rather than ignoring a problem or seeking external redress.
When to use Whistle Blowing: Having a trusted whistle blowing helpline is not a replacement for normal day to day interaction and most employee concerns and issues will be correctly communicated in the normal course and framework of the business. However, if you have a significant concern and feel you are unable to speak to your line manager directly, or more informally to someone senior, we have in place an independent reporting process to protect both you and the company from any untoward behaviour and business concerns.
The company recognises that the decision to report a concern can be a difficult one to make. If you honestly and reasonably believe what you are saying is true, you should have nothing to fear because you will be doing your duty to your employer, your colleagues and those for whom you are providing a service.
Rarely, a case might arise where it is the employee that has participated in the action causing concern. In such a case it is in the employee’s interest to come into the open as soon as possible. The company cannot promise not to act against such an employee but the fact that they came forward will be taken into consideration.
Our CTS whistle blowing helpline: ‘email@example.com’ sends any messages to, and directly alerts, our Head of HR and Chief Financial Officer of any issues. These two staff members are deemed to be sufficiently senior, empowered, and can access resources to investigate any issues fairly and diligently. Our CT Skills whistle blowing process is accessible through our main corporate website and may be used by:
- all employees of CTS
- all learners undertaking a period of study with CTS
- all employees of contractors, and those providing services under contract for CTS, including subcontractors
The whistle blowing process: Any emails that you communicate to ‘firstname.lastname@example.org’ will be handled confidentiality. Emails can be anonymous but it is likely to help our process if we can access further details from you as part of our investigation into any messages received. We will not disclose your identity at any stage unless required to do so by law or where we have first gained your direct consent in advance.
To assure you that your disclosure has been properly addressed, unless there are any legal reasons why this cannot be done, where we have your name and contact details you will be kept informed of the progress.
This policy is designed to enable the company a mechanism to review and act on any significant concerns at an early opportunity. Our preference is always that any day-to-day concerns be raised with your direct contact or line manager in the first instance where this can be done safely, with whistle blowing as a further safeguard or fallback procedure. If you instead choose to raise an issue directly with someone outside of the company this may be deemed a breach of trust and bring into question the terms of your employment contract, or other interactions with CT Skills.