Introduction
Malvern is committed to providing a learning environment where all students feel safe, respected and free from bullying and harassment.
We do not tolerate any form of bullying or harassment, whether it takes place on campus, online, during lessons, or at student social events or activities. All students and staff are expected to always behave respectfully towards others.
If you feel you are being bullied or harassed, you are encouraged to speak up. Any reports made will be taken seriously and handled with care, fairness and confidentiality.
What is Bullying and Harassment?
Bullying and harassment refer to unwanted behaviour, whether from one person or a group that makes you feel:
- Intimidated
- Humiliated
- Offended
- Isolated or excluded
- Unsafe
This behaviour may involve words, action, physical contact, or images, and can occur in person or online (e.g. on social media or messaging platforms)
Examples of bullying and harassment include:
- Verbal abuse or offensive comments, jokes or pranks related to age, disability, gender reassignment, marriage, civil partnership, pregnancy, maternity, race, religion, belief, sex or sexual orientation.
- Lewd or suggestive comments.
- Display of pin-ups, pornography, inflammatory or abusive literature or graffiti.
- Deliberate exclusion from conversations or work activities.
- Practical jokes, initiation ceremonies or inappropriate birthday rituals.
- Physical abuse such as hitting, pushing or jostling.
- Rifling through, hiding or damaging personal property.
- Subjecting a person to humiliation or ridicule, belittling their efforts, often in front of others.
The policy applies to all students enrolled at Malvern International, including those on pathway, foundation, or pre-sessional programmes, whether studying on-campus or at a partner university campus. It applies to behaviour occurring in any context connected to a student’s enrolment, including on campus, online, and at events or activities organised by or associated with the institution.
Reporting and Disclosure
Malvern International encourages all members of the community to speak up if they experience or witness bullying or harassment. We recognise that making a disclosure can be difficult, and we are committed to responding with sensitivity, fairness, and care. Individuals can choose whether, how, and when to disclose or report their experiences. Support will be available regardless of whether a formal complaint is made.
Malvern International recognises that individuals may face personal, cultural, or systemic
barriers to reporting bullying or harassment. These may include fear of retaliation, concerns about academic or immigration consequences, distrust of institutional processes, or past trauma. We are committed to building trust through confidentiality and transparency. Individuals are encouraged to disclose in the way that feels safest to them and are supported regardless of whether they pursue a formal complaint.
Malvern International recognises that most disclosures are made in good faith. However, where an investigation concludes that a complaint was made maliciously, dishonestly, or with intent to cause harm to another individual, this may be treated as a conduct matter and addressed under the relevant student disciplinary procedure. This provision is not intended to deter genuine reporting and will only be applied in clear and evidenced cases of bad faith.
Disclosure
There are several ways to disclose an incident:
a) Informal Disclosure
Students and staff may disclose an incident to a trusted member of staff, such as a lecturer, centre director, or safeguarding officer. These disclosures may result in signposting to support, informal resolution (where appropriate), or advice on making a formal complaint.
b) Anonymous Disclosure
Individuals may disclose incidents anonymously via designated reporting forms. While anonymous reports limit the institution’s ability to investigate or respond directly, they are important for monitoring patterns and assessing risk.
c) Third-Party Disclosure
Staff, students, or others may report concerns on behalf of someone else (with or without their knowledge). These will be managed carefully, with a focus on safety and appropriate
safeguarding where necessary
Formal Complaint
A formal complaint triggers an internal process which may include:
- An initial risk assessment;
- Fact-finding or formal investigation;
- Disciplinary or conduct proceedings (if appropriate);
- Coordination with partner institutions if relevant;
- Signposting to external services or the police where requested.
Formal complaints should be submitted via the Student Complaints Procedure/Non-Academic Misconduct and Disciplinary Procedure.
Timeframe
While there is no strict time limit for making a disclosure or complaint, earlier reporting can help with evidence gathering and ensure timely support. The institution will, however, consider all reports regardless of when the incident occurred.
Partner University Procedure
Where a student is enrolled on a partner university programme or located on a university campus:
- The individual may choose to report through the partner university’s bullying and harassment procedures;
- MHEP will support the student in accessing those procedures and coordinate responses where appropriate;
Confidentiality
All disclosures will be handled confidentially and in accordance with data protection legislation. Information will only be shared where necessary:
- To protect individuals at risk;
- To comply with safeguarding duties;
- As required for the investigation or resolution of a complaint.
Where disclosures involve under-18s or vulnerable adults, the Designated Safeguarding Lead (DSL) will be informed immediately. The DSL can be contacted for each centre. If the DSL is unavailable, concerns should be directed to the Centre Director, who will ensure the matter is escalated without delay.
Where a disclosure involves behaviour that may be connected to radicalisation, extremism, or activities that could pose a risk to the safety of others, the institution’s obligations under the Prevent duty will apply. Such cases will be referred in accordance with Malvern International’s Prevent Policy and, where appropriate, to the relevant statutory authorities. This does not affect the confidentiality protections set out above, except where disclosure is required by law or to protect individuals from serious harm.
Where a disclosure involves behaviours that may be connected to sexual harrassment and sexual misconduct, these cases will be referred in accordance with MHEP’s Student Harassment and Sexual Misconduct Policy, and, where appropriate, to the relevant statutory authorities.
Raising a Concern – Stage 1
If you feel you are experiencing bullying or harassment, you may be able to resolve the situation by letting the person know their behaviour is unwelcome and asking them to stop.
When a disclosure or formal complaint is made, Malvern International will respond promptly and appropriately, ensuring that individuals are supported, risk is managed, and any necessary action is taken in line with institutional and legal obligations. This section outlines how reports of bullying and harassment are handled internally. Where appropriate, referrals or joint action with a partner university may also apply.
We understand it can be difficult to speak out, and your concern will be treated confidentially and with care.
Upon receiving a disclosure or complaint, the Designated Safeguarding Lead will:
- Acknowledge receipt sensitively and promptly;
- Conduct an initial risk assessment to identify immediate safeguarding, wellbeing, or academic support needs;
- Provide information about support services and procedural options;
- Clarify the reporting individual’s preferences, including whether they wish to proceed with a formal complaint or engage external support. Immediate safeguarding concerns will be referred to the Designated Safeguarding Lead (DSL) without delay.
From the point of disclosure, Malvern International will ensure that appropriate support is made available to the individual, regardless of whether a formal complaint is pursued. This may include:
- Referral to student wellbeing or counselling services;
- Temporary academic adjustments, such as extensions or changes to timetabling, where the individual’s studies have been affected.
- Physical separation arrangements between the parties, where this can be reasonably managed.
- Signposting to external support organisations, including mental health services or specialist charities.
- Regular check-ins from a designated member of staff throughout the process.
Support arrangements will be kept under review and adjusted as circumstances develop.
Making a Formal Complaint – Stage 2
If Stage 1 of this procedure is unsuccessful or considered inappropriate in the circumstances, you can make a written complaint of bullying and/or harassment.
You can report your concern to a member of the student support team or to the Centre Director. You can also report your concern using our reporting tool available on our website. If the complaint involved a staff member, it will be handled in line with our internal policies.
While your complaint is being investigated, we may arrange for you and the other party to be separated, if needed. In some cases, temporary suspension of the person complained about may be necessary while we investigate.
Where a complaint involves online or digital behaviour, including messages sent via social media, messaging platforms, email, or any other digital channel, complainants are advised to:
- Take and save screenshots of relevant content, including dates, times, and usernames where visible.
- Avoid deleting any messages or content that may be relevant to the investigation.
- Note the platform(s) involved and, where possible, report the content directly to the platform using its own reporting mechanisms.
Malvern International will take digital evidence into account during investigation and will handle all such material in accordance with its data protection obligations.
We will investigate your complaint fairly, sensitively, and as privately as possible. You will be invited to speak with us about what happened. We may also speak to others involved, including the person you are making a complaint about, to hear all sides of the situation.
Once the investigation is complete, we will meet with you and provide you with the outcome.
An outcome letter will be issued within 10 working days.
The investigation will normally be concluded within 30 working days of the formal complaint being received. Where this is not possible, for example, due to the complexity of the case, the availability of witnesses, or the involvement of a partner institution, the complainant will be informed in writing of the revised timescale and the reason for any delay. Progress updates will be provided at least every 10 working days.
Please note: the other party has the right to be informed of the complaint and to respond.
Appealing the Outcome – Stage 3
If you are dissatisfied with the outcome of your complaint, you may appeal. Appeals must be submitted in accordance with the Complaints and Appeals Policy and Procedures, a copy of which is available on the MHEP website. Students are encouraged to read that policy before submitting an appeal to ensure they understand the grounds, process, and timescales that apply.
Where a partner institution is involved, joint decision-making may apply. Appeals in cases involving both staff and students will follow the relevant procedure for each party. Student appeals will be handled under the Non-Academic Student Appeals Policy and Procedure. These will be coordinated to avoid duplication and ensure procedural fairness.
Your Right and Support
Malvern believes all students have the right to:
- Study in a safe, respectful environment
- Be treated fairly and without discrimination
- Report concerns without fear or retaliation
If you raise a concern, you will not be punished or treated unfairly for doing so. Retaliation or victimisation of any kind will not be tolerated.
If you remain dissatisfied following the conclusion of the internal appeals process, you may be eligible to refer your complaint to the Office of the Independent Adjudicator for Higher Education (OIA). The OIA provides a free, independent scheme for the review of student complaints. You will need a Completion of Procedures letter from Malvern International before submitting a complaint to the OIA. Further information, including eligibility criteria and how to make a referral, is available at www.oiahe.org.uk.