Conflict of interest is defined as “a situation in which a party's responsibility to a second-party limits its ability to discharge its responsibility to a third-party.” Business Dictionary 2020.
This policy is aimed at all stakeholders using Nurture EPA Hub. The policy is set out to protect users from conflict of interest and to highlight individual obligations, procedure and sanctions that can be imposed by Nurture in the event of conflict of interest, breach of contract and/or malpractice and maladministration.
The documents that support this policy:
- Terms and Conditions
- Malpractice and maladministration policy
- Privacy notice
This policy takes into consideration the conflict of interest as outlined by Ofqual that must be implemented by stakeholders and adhered to by all parties involved in the practices and processes of (EPA) End Point Assessment regardless of using the hub. This does not disregard those policies.
Nurture must highlight that although Nurture EPA Hub is designed to provide (IA) Independent Assessors with active participation and support effective practices and processes for (EPA) End Point Assessment with our stakeholders; we do not take responsibility should a conflict of interest policy be breached by any party involved. You can find out more by visiting out T&Cs by clicking here
Each (EPAO) End Point Assessment Organisation is responsible for writing their own conflict of interest policy and ensuring that the IA is aware from the outlay.
It is the responsibility of the (IA) Independent Assessor to read and comply with each EPAO they work with.
Nurture does however hold the right to check the quality statuses within the hub including:
- Knowledge and competence of (IA) Independent Assessor
- Check booking allocations to ensure that all reasonable arrangements are in place and confirmed to protect the apprentices EPA arrangements and the reputation of Nurture.
- Review any malpractice and/or maladministration claims
- The right to investigate any unjustified reviews by any stakeholder
- The right to suspend users
- The right to remove profiles completely
- Confirming a booking and not adhering to the booking
- Informing of cancellation without a reasonable timescale.
- Failing to acknowledge reasonable adjustments or special considerations that could disadvantage an apprentice
- The failure to display relevant knowledge, skills and continuous professional development
- Using the hub to profit by way of avoiding the terms and conditions
- Failing to upload evidence and reports for the EPAO to review in a timely manner or at all
- Disclosing any personal data that could risk or harm any individual or organisation
- Failing to declare knowing an apprentice that may cause risk to the process of EPA
- Failing to declare an apprentice; purposefully putting the apprentice at an advantage
Should any of the above be suspected or proven; Nurture holds the right to impose sanctions on users that include:
- Suspend accounts temporarily
- Withdraw users permanently
Should any conflict of interest arise; dependent on the nature of the situation; Nurture reserves the right to act accordingly. The procedure in place is as follows:
Our webpage contact form can be found at: Nurture EPA This provides you with the opportunity to tell us what you think, what you like, any aspect of our provision that you are unhappy about and where we could improve. We welcome you're feedback so that we can improve outcomes for all our stakeholders.
Nurture’s formal complaints procedures do not cover complaints that relate to matters of academic judgement. Complaints on such grounds are therefore not likely to be accepted and will be ordinarily dismissed or otherwise deemed ineligible for consideration. Complainants of this nature should refer to the Appeals Policy & Procedure.
About the complaints process
If you are dissatisfied with Nurture support services, you should follow the procedure as detailed below.
Nurture aims to handle complaints in a way which is sympathetic, fair and efficient, which encourages informal conciliation, facilitates early resolution, maintains individual privacy and confidentiality and permits useful feedback.
The complaints process has three stages and it is anticipated that most problems will be resolved in the first two stages.
The three stages are:
- Discussion and advice
- Informal process
- Formal process
You may withdraw a complaint or stop the process at any time in stage 1 or 2 and, in stage 3, with the consent of the Reviewer. Personal privacy will be respected.
If you are contemplating making a complaint relating to Nurture support services, you may wish to contact the Managing Director
Stage 1: Discussion and advice
It is very important to voice concerns or to register the nature of a complaint as soon as possible, and to seek informal resolution and conciliation if possible, as this facilitates early resolution. Raising an issue can often resolve a problem quickly and informally; a complaint (which may, for instance, be founded on a misunderstanding or disagreement) can sometimes simply require a calm, balanced and non-prejudicial discussion between parties, without the need for any further action.
At the earliest stages, a complaint may be resolved quickly and efficiently by simple consultation or discussion with the right person - such as those listed below:
- Training provider
- Nurture staff
Where possible you should raise your concern with the person to whom the complaint refers. The person you contact might be able to solve the problem directly, to intervene, or at least offer suitable advice about how to proceed or where to go for assistance or advice. They may be able to advise about what would constitute an appropriate remedy, and opportunity to consider whether there is indeed a complaint to be addressed. You will then be in a position to decide whether to proceed further, and how.
If, however, you feel that a complaint has not been dealt with satisfactorily at the initial, local level or if the problem is of a more serious nature, then you should follow the formal procedures set out below.
Stage 2: Informal process
Before making a complaint under stage 2 of the process, you should have exhausted informal routes, as outlined under stage 1. If informal routes seem not to have been exhausted, then the complaint may be referred to informal resolution under stage 1.
To submit a formal complaint, you should contact the Managing Director. A complaint should normally be made within three months of the occurrence of the matter complained about. If there is a delay you should explain the reason.
If the Managing Director, on inquiry, judges that the complaint appears to be unjustified, misconceived or vexatious, the Managing Director may write to you to invite withdrawal of the complaint. The complaint will proceed only if you respond, in writing, within 10 working days and request the complaint to proceed.
In the event the complaint has not been resolved by informal discussion or does not appear capable of informal resolution, the Managing Director will proceed to consider the complaint formally in consultation with those concerned in the provision of the service, e.g. the Course Tutor/Assessor, Internal Verifier, or other Service Manager. You will be informed at this stage that formal procedures have been initiated.
Where a complaint puts in issue a matter of academic freedom and/or the professional judgement and/or reputation of the person about whom you are complaining s/he will have a right to put their case to the Managing Director
The Managing Director will provide you with a provisional response in writing as soon as reasonably practicable, and normally within 20 working days of the initiation of the formal procedure. You will be invited to comment on the provisional response in writing within 15 working days or longer, where appropriate.
The Managing Director will review the provisional response in light of any observations made by you, and then provide you with a final written response normally within 15 working days after the date by which you were invited to comment on the provisional response.
If the Managing Director upholds the complaint, s/he will procure so far as possible such remedy as they consider fair and equitable in all the circumstances, which may include:
- A full explanation
- An apology (which is not an admission of liability)
- The matter put right if possible
If you are not satisfied with the outcome, whether the complaint is upheld or not, you may consider whether to pursue the complaint through stage 3.
Stage 3. Formal process
If you decide to pursue your complaint, you should contact the Managing Director in writing to the Office address (quoting stage 3) within 20 working days of learning the outcome of the investigations under stage 2.
On receiving a complaint form, the Managing Director will provide, normally within 15 working days, a full written report covering all the circumstances leading to the complaint, the investigation and the outcome, a copy of which will be sent to you. The Managing Director will invite you to make representations in writing on the written report within a further 15 working days, or longer where appropriate, and will then appoint a Company Reviewer, with no prior involvement in the case.
The Reviewer will be appointed by the Managing Director and will be a senior member of Nurture. The appointment of a Reviewer is a formal procedure that will normally be completed within 30 working days.
The Reviewer will consider all documents relating to the case, including the report to the manager, you're representations and the results of any further enquiries they may make, at their discretion. All documents considered by the Reviewer will be made available to you. If the Reviewer agrees that the matter has been considered fully and appropriately and that there are no grounds for a hearing, you will be informed that your complaint has been dismissed and the reasons for the decision. If, however, it appears that you may have grounds for making a complaint, the Reviewer will arrange a hearing to which you will be invited and you may, if you wish, be accompanied by an appropriate person.
Others involved in the case may also be invited to appear before the Reviewer and will be provided with the same documents as you and the Reviewer.
Nurture manager will assist the Reviewer and will be present throughout the whole proceedings of any hearing and will prepare the draft report. The Reviewer will issue a report containing findings about the complaint and may make recommendations as to remedies, if any, to be adopted or other action recommended to be taken. If the complaint is dismissed, the Reviewer will provide reasons for their decision.
The Reviewer may terminate the proceedings, determine that a complaint is rejected as vexatious or frivolous, or refer the complaint for informal resolution.
The Managing Director will communicate the decision of the Reviewer to you, normally within 15 working days of the meeting or hearing.
When the recommendations of the Reviewer are completed, Nurture will send a completion of procedures letter to you.
The decision of Nurture Reviewer is final within Nurture EPA Hub.
All decisions reached by a Company Reviewer will be reported to Nurture Managing Director: Debbie Richards
Conflict of interest is constantly monitored and reviewed by Nurture EPA Hub and will be updated accordingly. The version will therefore change as a result; we aim to conduct an update annually; however this will be aligned to changing business landscape and external requirements.
If you have any queries about the content of this policy; please contact account manager directly on 07810640128 or email firstname.lastname@example.org