The Kelmac Group® Malpractice and Maladministration Policy

The Kelmac Group® (hereinafter referred to as “Company”, “We”, “Us” or “Our”) owns, operates and maintains the website (“Website”) through which the Company provides services to its clients (hereinafter referred to as “Client”, “user”, “You” or “Your”) and assist in managing intra-city/ country management consulting and training for scheduled and on-demand deliveries (“Services”). In order to provide the Services in an efficient manner, the Company offers and manages relevant and approved Scheme Owner courses, including the reporting and dealing with any suspected or actual cases of malpractice or maladministration. We follow the highest standards of malpractice and maladministration guidelines to protect the information shared by you with us.

The statement highlights our policy with regards to how we treat matters related to plagiarism, cheating, external whistleblowing, collusion, etc.

This policy applies to all customers, being learners who are taking or have taken any assessment and personnel with responsibilities for managing, delivering, assessing and quality assuring Kelmac Group® and relevant Scheme Owner approved courses, who suspect or become aware that malpractice or maladministration has occurred. This policy holds for any Kelmac Group® personnel or partner organization, who suspect or become aware that malpractice or maladministration has occurred.

Malpractice and Maladministration Process

Flow Diagram


The following list provides examples of  Kelmac Group® personnel, partner organizations and learner malpractice. This list is not exhaustive and is intended as guidance on Kelmac Group’s definition of malpractice. 

  • Deliberate failure to adhere continually to Kelmac Group’s® and/or Scheme Owner requirements or actions assigned to the Learner or Kelmac Group® personnel or partner organizations within stated       timelines. 
  • Denial of access to premises, records, information, learners and staff by any authorised Kelmac Group® representative and/or Scheme Owner and/or the regulatory authorities; 
  • Inadequate Kelmac Group policy and procedures for the induction of staff or any contracted person involved in the delivery of Kelmac Group® and Scheme Owner approved courses; 
  • Failure to carry out internal assessment, internal moderation or internal verification in accordance  with Kelmac Group’s requirements; 
  • Deliberate failure to adhere to Kelmac Group’s ® learner registration and certification policy and/or  procedures; 
  • Deliberate failure to maintain appropriate auditable records, e.g. course certification claims and/or forgery of evidence. 
  • Fraudulent claim for certificates. 

There are many other examples such as intentional withholding information from Kelmac Group® which is critical in providing the best service to our customers, plagiarism of any sort, cheating, creation of false records, cash for certificates, false IDs, etc. 


The following list provides examples of Kelmac Group® and/or personnel, partner organization and learner maladministration. This list is not exhaustive and is intended as guidance on Kelmac Group’s® definition of maladministration. 

  • Breach of Security – tampering with leaner’s assessments or examination scripts, etc. 
  • Deception – damaging a learner’s work, improper assistance to learner’s, etc. 
  • Failure to co – operate in the investigation 
  • Failure to keep accurate learner’s records 
  • Failure to upload accurate learner data to the Kelmac Group® and/or Scheme Owner;
  • Failure to store and dispatch certificates securely and in a timely manner;
  •  Unreasonable delays in responding to requests and/or communications from the Kelmac Group®; 
  •  Inaccurate claim for certificates


All Kelmac Group® personnel and partner organizations are obliged to inform Kelmac Group® promptly of any suspected or alleged cases of malpractice or maladministration. Where malpractice or maladministration is suspected or has occurred in the Kelmac Group® or a partner organisation involved in the marketing, sales, administration or assessment of the Kelmac Group® and relevant Scheme Owner approved course, the Kelmac Group® may suspend persons from processing any further registrations and/or certification claims, and/or impose other sanctions immediately, pending the outcome of the investigation.

Identifying possible or actual malpractice of maladministration

Any person may identify a matter that they think could constitute malpractice and maladministration, the person will normally be a Kelmac Group® employee, manager, consultant, a learner, a contractor, etc.

Once the person is identified, Kelmac Group® will then notify, the relevant Scheme Owner(s), about the allegation received. If the notification implicates the CEO, the Quality Management Representative and/or Deputee will be notified and they will liaise with the relevant Scheme Owner(s) for direction and advice on the preferred course of action. Failure to report any suspected or actual malpractice or maladministration may result in the immediate suspension of the Kelmac Group® for registrations and/or certifications until a full investigation has been completed.

Anonymity and Whistle Blowing Policy

There are times when an informant who is concerned about possible adverse consequences may like to not disclose their identity. The Kelmac Group® always aim to keep a whistle blower’s identity confidential where asked, but they can’t always guarantee. There are instances such as the matter leads to issues that need to be taken up by the other parties such as the police, fraud prevention agencies or other law enforcement agencies, the courts (regarding any court proceedings) or the relevant Scheme Owners. The investigator will advise the whistle blower if it becomes necessary to reveal their identity.

A whistle blower should also understand that they may be identifiable by others due to the nature or circumstances of the disclosure (e.g. the party against whom the allegation is made may identify possible sources of disclosure without such details being disclosed to them).

Once a concern has been raised, it can’t be withdrawn. The Kelmac Group® is obliged by the relevant Scheme Owners to follow up and investigate any allegations related to malpractice or maladministration.


Where possible the Kelmac Group® aims to:

  • resolve all stages of the investigation within 20 working days of receipt of the allegation;
  • produce the draft investigation report within 10 working days of receipt of the
  • allegation;
  • confirm factual accuracy of the draft report within 5 working days of its availability;
  • publish the final report and actions within 5 working days of confirmation of the draft report. If it is likely that any stage of the investigation may take longer, the Kelmac Group® will advise all parties concerned of the anticipated revised timescale.

Retention of materials 

The Kelmac Group® will: 

  • ensure all materials collected as part of an investigation are securely kept by the Kelmac Group®. 
  • retain, for a period of not less than 5 years, all record and original documentation concerning a completed investigation leading to sanctions; 
  • retain, until the case and any appeals have been heard and for five years thereafter, all records and original documentation of an investigation leading to the invalidation of certificates, or criminal or civil prosecution. 

Use of sanctions during the investigation

Either at notification of a suspected or actual case of malpractice or maladministration and at any time during the investigation, The Kelmac Group® reserves the right to impose sanctions in accordance with the Kelmac Group’s® sanctions policy, to protect the interests of leaners and the integrity of the course and certificates. The Kelmac Group® also reserves the right to withhold or invalidate a learner’s and/or companion’s results for all the Kelmac Group® certificates and/or courses or modules they were studying at the time of the notification or investigation. 

Investigation outcomes and actions 

If the investigation confirms that malpractice or maladministration has taken place, the Kelmac Group® considers what action to take to: 

  • minimise the risk to the integrity of the course, certificate(s), the Kelmac Group® and relevant  Scheme Owners and/or Training Certification Bodies; 
  • maintain interested party confidence in the course delivery and awarding of Kelmac Group® and/or Scheme Owner and/or Training Certification Body certificates; 
  • discourage others from carrying out similar instances of malpractice or maladministration; 
  • ensure there has been no gain from compromising the Kelmac Group’s® standards. 
  • The actions the Kelmac Group® may take include: 
  • undertaking additional/increased monitoring activities to provide a greater level of support and/or monitoring; 
  1. requiring specific Kelmac Group® staff to undergo additional training and/or scrutiny by the Kelmac Group® if there are concerns about their ability to undertake their role effectively in the delivery of  the Kelmac Group® and relevant Scheme Owner courses; 
  2. not permitting specific Kelmac Group® personnel to be involved in the delivery or assessment of the Kelmac Group® and relevant Scheme Owner approved courses (e.g. invigilation); 
  3. imposing sanctions on the learner – if so, these will be communicated to the learner in accordance with the Kelmac Group’s® sanctions policy together with the rationale for the sanction(s) selected; 
  4. taking appropriate action against a learner(s) in relation to proven instances of cheating, plagiarism or fraud (see the Plagiarism, Cheating and Collusion policy); 
  5. amending aspects of the Kelmac Group’s® development, delivery and awarding arrangements, and if required, assessment and monitoring arrangements and associated guidance to prevent the issue from recurring; 
  6. informing partner organization of suspicion and/or termination of our agreement or arrangement

Right to Appeal/Appeals Policy

An appeal can be made against a decision or action taken/to be taken following an investigation into maladministration or malpractice. See the related process for dealing with suspected or actual case of malpractice or maladministration

  • An initial notification of suspected or actual malpractice or maladministration should be submitted to no later than 2 days after the occurrence of the event. The notification must include the following information:
  1. contact details of person submitting the notification;
  2. learner’s name and registration number (if applicable);
  3. name(s) and job role(s) of Kelmac Group® personnel involved in the case;
  4. course(s) or service(s) affected;
  5. nature of the suspected or actual malpractice or maladministration and associated dates;
  6. details and outcome of any initial investigation carried out by the Kelmac Group® or other person involved in the case, including any mitigating circumstances;
  7. declaration of any personal interest by the person making the allegation. 
  • On receipt of the investigation report, the Kelmac Group® undertakes to complete its review of the report within 5 working days. If for any reason this is likely to take longer, the interested parties will  be notified immediately. If the Kelmac Group® does not agree with points of factual accuracy in the report, the interested parties will be notified and a record will be maintained. 
  • Where the Kelmac Group® investigates, it aims to complete this within 10 days of notification and produces a draft report summarising, in line with the objectives:
  1. the origin of the issue or mode of discovery of the alleged irregularity;
  2. where the breach, if any, occurred;
  3. the facts of the case;
  4. any mitigating factors;
  5. with whom the responsibility for the breach lies;
  6. details of the investigation;
  7. the evidence provided;
  8. the conclusions drawn. 
  • The draft report is submitted to all parties concerned to check for factual accuracy. Any subsequent amendments are agreed between the parties and the Kelmac Group®. 
  • The Kelmac Group® decides whether malpractice or maladministration has occurred. 
  • If the Kelmac Group® has concluded that malpractice or maladministration has or is likely to have occurred, it decides upon the appropriate action to be taken, in line with its sanctions policy. 
  • If malpractice or maladministration is not found, the Kelmac Group® lifts any related sanctions which have been imposed. 
  • The Kelmac Group® produces and submits a final summary report to all relevant parties and informs them in writing of any actions to be taken and sanctions to be imposed/removed. 
  • The Kelmac Group® submits the final report and action plan to the relevant Scheme Owner(s). 
  • The Kelmac Group® makes the final report available to other external agencies as required. 
  • Where an independent/third party made the original allegation, the Kelmac Group® informs them of the outcome. In doing so some details may be withheld, if to disclose such information would breach a duty of confidentiality or any other legal duty. 
  • Where the allegation was about a member of the Kelmac Group® personnel, appropriate training and/or disciplinary procedures will be implemented, reference the Kelmac Group® disciplinary procedure. In some circumstances the police or other external authorities may need to be alerted.

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