Policy for Preventing Malpractice and Maladministration

Last updated 28 October 2026.

Introduction

This policy applies to both staff and learners, and sets out the steps to follow when dealing with suspected or actual malpractice or maladministration. Staff and learners are made aware of it as part of Tula Training's induction process, including how to report a concern.

What counts as malpractice

Malpractice is any activity or practice that deliberately contravenes regulations and compromises the integrity of the internal or external assessment process, or the validity of certificates and associated achievement. It covers deliberate actions, neglect, default or other practice that compromises, or could compromise, the assessment process, the integrity of a regulated qualification, the validity of a result or certificate, or the reputation and credibility of Tula Training or Active IQ.

Examples include:

• Denying an authorised Active IQ or regulatory representative access to premises, records, information, learners or staff
• Failing to carry out internal assessment, moderation or verification in line with Active IQ's requirements
• Deliberately failing to follow learner registration and certification procedures
• Deliberately failing to keep up with Active IQ centre recognition or qualification approval requirements
• Deliberately failing to maintain appropriate records for audit, or forging evidence relating to certificates
• Fraudulent claims for certificates, or unauthorised use of materials or equipment (such as mobile phones) in assessment settings
• Intentionally withholding information from Active IQ that's critical to quality assurance and qualification standards
• Misusing Active IQ's logo or trademarks, or misrepresenting the centre's relationship or approval status with Active IQ
• Collusion, or permitting collusion, in exams or assessments
• Certification claims made before a learner has actually completed the qualification

What counts as maladministration

Maladministration is any activity or practice resulting in non-compliance with proper administrative processes — for example, inappropriate learner records or persistent mistakes.

Examples include:

• Deliberately contravening the assessment arrangements Active IQ specifies for its qualifications
• Loss or theft of, or a breach of confidentiality in, assessment materials
• Plagiarism by learners or staff, or copying from another learner
• Assuming another learner's identity, or having someone assume yours, during an assessment
• Unauthorised amendment, copying or distribution of exam or assessment materials
• Inappropriate assistance to learners by staff — for example, unfairly helping them pass a qualification or unit
• Deliberately submitting false information to gain a qualification or unit
• Deliberately failing to follow, or circumventing, Active IQ's Reasonable Adjustments and Special Considerations Policy

Investigation procedure

The investigation follows eight stages.

Stage 1 — Briefing and record-keeping: investigators are given a clear brief and understanding of their role, and record every action taken during the investigation to demonstrate they've acted appropriately. The staff member assigning the investigator(s) arranges secure storage for all material associated with the investigation, in case of a subsequent legal challenge. Where Active IQ is jointly investigating, Tula Training passes on Active IQ's clarifications about roles and process to its investigator(s).

Stage 2 — Establishing the facts: investigators review the evidence and relevant Active IQ guidance, establishing what happened, why, who was involved, where it occurred, and what action (if any) Tula Training has already taken.

Stage 3 — Interviews: interviews are prepared for and conducted properly, with clear records kept — all interviews are recorded, and interviewers may use the "PEACE" technique (plan and prepare, engage and explain, account, closure, evaluation). Face-to-face interviews are normally conducted by two people, one as interviewer and one as note-taker. Those interviewed may bring someone of their choosing, and don't have to answer questions. Both parties sign the account as a true record.

Stage 4 — Other contacts: where learners or employers need to be contacted for facts or information — by interview, phone, post or email — the investigator uses a prepared set of questions, records responses in writing, and logs the number of contact attempts made. Accounts are signed for agreement and formatted as non-editable PDFs.

Stage 5 — Documentary evidence: documentary evidence is authenticated wherever possible by reference to its author — for example, confirming handwriting, dates and signatures. Receipts are given for any documentation removed from Tula Training, and independent expert opinion (such as a forensic examiner) may be sought on the validity of documents.

Stage 6 — Conclusions: the investigator(s) gather and review all relevant evidence and draw a conclusion for the report.

Stage 7 — Reporting: a draft report is prepared and agreed for factual accuracy. The final report is submitted to the relevant Tula Training staff member for review and sign-off, and shared with Active IQ and other relevant parties.

Stage 8 — Actions: any resulting action plan is monitored appropriately, and Active IQ is notified.