Ofsted watch: ‘Unsafe’ college makes rapid safety improvements

A specialist land-based college branded “unsafe” in a shocking grade four report in April has made swift improvements to ensure the safety and welfare of students.

Moulton College, based in Northamptonshire, was hit with an ‘inadequate’ rating after Ofsted found learners were in danger when studying in areas such as construction and equine studies.

It had its first monitoring visit report published on July 26, in which inspectors found senior managers had responded “swiftly to tackle the weaknesses identified during the previous inspection relating to the safety and welfare of students and apprentices”.

They commissioned an “external specialist to carry out a thorough review” and implemented a “range of measures that included extensive staff training in health and safety and in managing students’ behaviour in classrooms and in workshops”.

In one animal care lesson during the full inspection, Ofsted said a “poorly conceived” internet research task placed a high needs student “at risk of looking at inappropriate content”.

Upon their return, inspectors found managers have “reviewed and strengthened” safeguarding arrangements.

“Staff understand how to use the electronic software, introduced in October 2017, to enable them to report safeguarding or welfare concerns to the team of designated safeguarding leads,” they said.

Since their introduction, the safeguarding leads have logged and dealt with over 350 reported incidents.

But safeguarding wasn’t the only ‘inadequate’ element of the college that Ofsted previously found.

Many of the “weaknesses” in teaching, learning and assessment identified during the inspection “remain”.

Managers have also “not successfully” tackled weaknesses related to students’ personal development and behaviour. Attendance and punctuality in lessons is still “poor”.

However, a newly appointed quality team has begun to “overhaul the observation of teaching and learning scheme, which previously focused on compliance with expectations rather than on the quality of learning”.

Early indications are that the revised arrangements are having a “positive impact”.

Senior leadership was highly criticised in Ofsted’s grade four report of Moulton College, so much so that its principal, Stephen Davies, resigned after seven years in the job.

Ann Turner, who has nearly two decades of experience at a land-based college, took the reins in an interim capacity.

At the time of Ofsted’s monitoring visit, she had only been in post for four weeks, which was “too recent to have had an impact”.

The only full inspection report to be published for FE this week was for GSS Solutions Limited, a private provider in Warwickshire.

It was given a disappointing ‘requires improvement’ rating in its first ever visit from Ofsted.

“Senior leaders and managers have not secured sufficient oversight to provide sector-related benchmarking, advice and challenge,” inspectors said.

“Assessors do not effectively plan and provide teaching, learning and assessment that take learners’ starting points into account. The most able learners do not make the progress of which they are capable.”

They added that leaders have “insufficient focus” on improving the quality of teaching, learning and assessment.

There was one monitoring visit of a new apprenticeship provider, in which Deere Apprenticeships Ltd was given ‘reasonable progress’ verdicts in all three fields judged.

Senior leaders and managers at the Nottinghamshire-based provider are “very committed to providing a high standard of training for all apprentices,” inspectors said.

Lastly, adult and community provider The Mary Ward Centre (AE Centre), in London, maintained its ‘good’ rating following a short inspection.

 

GFE Colleges Inspected Published Grade Previous grade
Moulton College 06/06/2018 26/07/2018 M M

 

Independent Learning Providers Inspected Published Grade Previous grade
GSS Solution Limited 19/06/2018 23/07/2018 3 N/A
Deere Apprenticeships Ltd 11/07/2017 27/07/2018 M M

 

Short inspections (remains grade 2) Inspected Published
The Mary Ward Centre (AE Centre) 27/06/2018 27/07/2018

 

New quality assurance rules will create a tiered apprenticeship system

The latest announcements on quality assurance of end-point assessments are a game-changer for assessment organisations – some standards will now be regulated more stringently than others, predicts Terry Fennell

Things just got serious for end-point assessment organisations (EPAOs) delivering standards that are externally quality assured by Ofqual, with new enforceable rules coming into effect on 27th July.

Things just got serious for end-point assessment organisations

That’s not to say the 42 awarding organisations, most of whom are members of the Federation of Awarding Bodies, have not been taking their role seriously so far. However, coupled with the financial investment of bringing an EPA to market, AOs now must also comply with new general conditions of recognition.

The new rules have not come as a surprise to awarding organisations, as Ofqual consulted extensively with FAB members, and the widely-shared opinion from colleagues is that the new conditions are, in the main, clear and serviceable.

Neither will it come as a surprise that Ofqual has set a high bar for external quality assurance (EQA) of EPAs, which will be treated in the same context as a regulated qualification – thus rightly placing the interests of apprentices at the heart of the delivery. The new rules will immediately apply to the delivery of 55 standards that are subject to EQA by Ofqual, and several thousand apprentices in scope for EPA in the next 12 months.

The problem lies in the discrepancy between the stringency with which Ofqual will carry out their duties, compared to other quality assurance bodies.

Awarding organisations will now have their assessment instruments evaluated against the standards and Ofqual has declared a clear intention to audit the capacity and capability of EPAOs to deliver compliant EPAs. Failure to meet the external levels of assurance can result in sanctions and enforcement from the regulator, the Institute for Apprenticeships, which will be keen to carry out its responsibility in the months ahead.

Just as Ofqual will undertake its EQA responsibilities to ensure the validity of EPAs under their remit, the awarding organisation has a legal obligation to comply with the conditions of each EPA. A particular condition that catches my eye is EPA3.1, which requires an awarding organisation to notify Ofqual where it believes that an event that could have an adverse effect has occurred or is likely to occur. This means that an awarding organisation must notify Ofqual even where an event has not yet happened, so long as the awarding organisation considers that it is likely to happen.

This scenario requires the awarding organisation to notify Ofqual if it believes the assessment plan has given, or could give, rise to an assessment that is not fit for purpose!

This is a game changer for end-point assessment organisations

This is a game changer for EPAOs, as while the IfA and other EQA bodies were open to receiving notifications of concern on an assessment plan, this was often a contentious area, as trailblazer groups had often worked hard to gain approval and did not like their instruments to be criticised. For many EPAOs, it’s not until their occupational assessment experts actually drill down into the assessment plan detail that issues occur, so the new obligations require EPAOs (at least for Ofqual standards) to formally notify the regulator. How this plays out in reality will be very interesting and I suspect a notification will need to be supported with a technical rationale for the concern.

The simple truth is the other constituent EQA bodies do not have the same powers to enforce and regulate EPAs like Ofqual, so last week’s publication of conditions are, I believe, a significant development in terms of the apprenticeship system creating a ‘tier’ for some standards over others.

With 127,000 apprentices on the new standards, the volume of EPAs will rise significantly in the next 12 months, so it will be interesting to see how the IfA will be able to compare and ensure consistency across a market with so many different EQA bodies.

DfE gives IoT bid special treatment to grade 3 NCG

The government appears to have broken its own rules in its Institutes of Technology competition, by putting NCG through to the final bidding round despite the group’s grade three Ofsted rating.

An update about the IoTs process was published yesterday which stated the Department for Education has now sent “interim guidance” about the next stage to the 16 providers successful in the previous round.

Surprisingly, however, the largest college group in the country was still included in the list of finalists even though it was downgraded to ‘requires improvement’ by the education watchdog last month.

DfE guidance for opening an IoT states that a provider’s Ofsted grade must be at least ‘good’.

A spokesperson for the department explained that NCG will need to improve its Ofsted rating by November to have a chance of getting approved.

“Applicants to the Institutes of Technology competition required at least a ‘good’ rating from Ofsted when stage one opened in December 2017,” she said.

”The deadline for stage two applications is in November 2018, and we require applicants to have at least a ‘good’ rating at that time or they will not progress further in the process.”

It was understood from DfE insiders that NCG would be thrown out of the IoT process following its grade three.

The apparent special treatment is likely to infuriate a number of other grade three providers who didn’t get the chance to apply in the first IoT round.

It will also raise questions about whether the decision to allow NCG to continue in the process is because the college group is now chaired by the former chief executive of the Education and Skills Funding Agency which appears to be giving the go ahead to the rule break.

Two teams of inspectors were deployed to NCG in May, in a visit prompted by achievement rate concerns.

Ofsted then took little over a month to publish its report, giving it a damaging ‘requires improvement’ rating in all but two of the headline fields judges.

Yesterday’s IoT update said the DfE expects to publish the official guidance for the final stage in September, with the outcome then revealed in March 2019.

Each of the 16 providers are bidding for a share of a £170 million pot to open an institute.

IoTs, which were first mooted back in 2015, are intended to bring FE and HE providers together with employers to deliver technical skills training, with a particular focus on levels four and five.

According to application guidance from the DfE, they will offer “higher-level technical skills on a par with more academic routes” and will “achieve the same level of prestige as universities”.

Post-16 segregation threatens ‘parity of esteem’ for technical education

Post-16 pathways are increasingly segregated, which risks damaging the government’s ambitions for technical education to be treated with parity of esteem, argues David Robinson

Where do disadvantaged young people go after they leave secondary school, and what does this mean for social mobility in England? Today the Education Policy Institute sheds light on this question by publishing research showing that, not only do the post-secondary destinations of disadvantaged 16-year-olds differ from their more affluent peers, but that this segregation is increasing over time.

This segregation is increasing over time

We consider the proportions of secondary school leavers that go on to further education colleges, sixth forms, other education destinations, employment (with or without training), or to none of the above.

In 2016 (the most recent year for which we have data) we find that 21.2 per cent of all disadvantaged pupils would have needed to switch their post-16 destination to match the destinations of their peers to eliminate this segregation. Recently this proportion has slowly, but consistently, risen at a rate of one percentage point every five years.

Obviously, different is not necessarily worse, but the segregation itself can have pernicious consequences.

Interestingly, there’s some broader good news that sits behind these figures. In 2015, the government raised the participation age, requiring all young people to continue in education or training until their 18th birthday, and by June 2017, it was estimated that 91 per cent of 16 to 17-year-olds were in education or training, with most of the increase coming from participation in full-time education.

This is clearly good for the life chances of these young people

Indeed our analysis shows that the proportion of disadvantaged 16-year-olds not in education, employment or training (NEET) decreased from 14 per cent in 2012 to 11 per cent in 2016. This is clearly good for the life chances of these young people.

But there are two important caveats to this. First, this still leaves 11 per cent of disadvantaged 16-year-olds leaving school as NEET. The corresponding figure for their more affluent peers is just 3 per cent. So clearly there’s some way to go in providing comparable opportunities for young people.

The second caveat is that while fewer disadvantaged 16-year-olds and their peers are becoming NEET, they are taking notably different routes. Disadvantaged 16-year-olds have increasingly been moving onto a range of destinations including employment, training, further education colleges and sixth forms, while the majority of their peers have increasingly been moving on to sixth forms. This is what has driven the increase in segregation observed in our metric, which measures only the differences in destinations and makes no judgement which destinations are “better” or “worse”.

Much of this divergence in destinations appears to be driven by the differences in grades achieved at the end of key stage four. Our report shows that the gap in average GCSE English and maths grades between disadvantaged pupils and their peers, while narrowing, is closing at an increasingly slower rate. At the current pace, it would take well over 100 years to reach parity. We see further divergence emerging after pupils leave school – with opportunities and provision at post-16 level highly dependent on where a student lives and the wealth of the area.

Parity of esteem is critical 

But in the end if fewer young people are NEET, does this increased segregation matter? In our view, yes it does. Segregation reinforces the lack of parity of esteem, whatever the actual quality of the routes. This parity of esteem is critical at a time when the government has committed to increasing the diversity of provision, including giving Britain “the technical education it has lacked for decades”. This apparent commitment is demonstrated by the introduction of T-levels, the review of Level 4 and level 5 qualifications, and the prominence given to technical and vocational in the terms of reference of the government’s review of post-18 education.

For example, as and when T-levels are fully rolled out, it’s likely that FE colleges will provide the bulk of these qualifications. It’s in the interest of neither young people (whatever their background) nor employers, if these qualifications are seen as a route for “other people’s children”, or indeed “my child, but not this year”. Indeed our previous research indicates that the UK economy needs more people with intermediate-level qualifications, and T-Levels will only be a success if they are seen as a credible and high quality vocational route, likely to last and gain labour market value.

So, while it’s good that more young people continue in education after they leave secondary school, the government needs to consider how the increased segregation of young people on account of their economic background puts its own ambitions at risk.

Ofqual to audit EPAOs amid ‘capacity and capability’ concerns

Ofqual will soon begin auditing apprenticeship end-point assessment organisations to find out how they are mitigating risks around the capacity and capability of assessors.

The exams regulator today confirmed its approach to its external quality assurance of EPAs, by publishing a final set of rules.

The conditions and guidance, which come into force tomorrow, will lead to Ofqual carrying out audits of end-point assessment organisations to fish out any issues with examiners.

It comes after chief regulator Sally Collier (pictured) said she was concerned about assessor capacity and capability at the AELP conference last month.

She made a plea for delegates to help keep tabs on EPAs by joining an expert panel that looks into their technical problems.

“With these rules in place, we are now beginning a programme of work on the delivery of EPAs,” Ofqual said today.

“This will include a programme of audits to help understand how the EPAOs we regulate are mitigating risks around the capacity and capability of EPA assessors.

“Where an apprenticeship trailblazer group has selected Ofqual as the external quality assurer for its apprenticeship standard, all EPAOs offering EPAs for that standard must be (or become) Ofqual-regulated and all EPAs must meet these new conditions and our general conditions of recognition.”

The regulator reiterated, as Ms Collier did at the AELP conference, that it was not “lowering the recognition bar”.

It has instead “streamlined our recognition process for organisations seeking to offer EPAs, and we will be publishing further information in the coming weeks so that all organisations are able to decide at an early stage whether Ofqual regulation is for them”.

Today’s published set of rules include a number of amendments to original proposals following a two-month consultation earlier this year.

Included is a change which allows some parts of the EPA to take place at the training centre where the apprentice studied, as well as clarity around what end-point assessment organisations must contain and how specifications must be published.

Ofqual has so far been asked to provide external quality assurance for 55 apprenticeship standards – with another 37 in the pipeline.

As an EQA, the exams regulator also includes a technical evaluation of a proposed EPAs, to ensure that EPAOs have “interpreted assessment plans correctly and consistently so that employers get what they want and expect from the assessments”.

Ofqual has looked at 19 EPAs so far and asked EPAOs to make changes where required.

EQA providers oversee EPA assessment procedures and employer groups who develop new apprenticeships can choose the body that regulates their standards.

They can opt for one of four different EQA options: Ofqual, the Institute for Apprenticeships, a professional body, or an employer designed option.

Colleges supported with £760,000 to engage inactive students in sport

Over three quarters of a million pounds will be invested in colleges over the next two years to engage inactive students in sport and physical activity.

AoC Sport announced today that Sport England will devote the sizeable chunk of its National Lottery funding to colleges from September 1, 2018 until August 31, 2020.

It will be used to run a series of “targeted interventions” aimed at increasing the levels of physical activity within “lower socio-economic groups, women and girls, inactive students and volunteers”.

According to Sport England, nearly one in five students at FE colleges in England are currently not active enough – which means 138,000 students are doing less than the recommended 30 minutes of physical activity each week.

“We are delighted that Sport England are continuing to invest in the college sector,” said AoC Sport managing director, Marcus Kingwell.

“Our vision is every student active and this funding will help us target the most inactive young people in colleges, which in turn will benefit their education, employability and health.”

The interventions planned over the next two years include a “This Girl Can Ambassador” programme, where ambassadors in at least 60 colleges will be trained to promote and deliver physical activity and sport to female college students.

They’ll encourage “non-traditional activities”, such as Raveminton Open in a new window which involves playing badminton under ultra-violet lights with fluorescent lines, neon nets and shuttlecocks sprayed with UV paint, as well as tag American football, and bubble football – where five-a-side football players go up against each while wearing an inflatable orb.

The funding will also be used to increase the diversity of student volunteers to “better reflect society,” an AoC Sport spokesperson said.

To achieve this, the association will work with departments in colleges other than sport with a diverse population to “ensure opportunities are available to all students”.

A marketing campaign which will include guidelines on regularity and intensity will also be launched to “start the conversation” on what being inactive actually means.

The £760,000 is in addition to the £5 million Sport England has already invested into 49 colleges, as part of the Tackling Inactivity in Colleges programme.

Cassell Bailey, head of children and young people (education) at Sport England, said: “College is a time when students often stop participating in sport and physical activity so this investment is a great opportunity to embed this into their lifestyles so they can continue to be active for years to come.

“Not only will it help improve their physical and mental health, it can also help them prepare for the challenge of university or the workplace.”

Sport England invests up to £300 million National Lottery and government money each year in projects and programmes that help people get active and play sport.

A subsidiary company of the Association of Colleges, AoC Sport is a membership organisation which campaigns for every college student to participate regularly in physical activity.

FE Week has previously been media partner for the AoC Sport National Championships.

European Social Fund protected until end of 2020, Chancellor confirms

Training providers will have their European Social Fund cash protected until the end of 2020, even if a “no-deal” Brexit is reached.

Chancellor Philip Hammond (pictured) made the promise today that any funding that organisations secure through EU programmes will be “guaranteed” by the UK government until that date.

It was always the case that the current ESF funding round, worth about €3 billion (£2.3billion) across England, would run over the period from 2014 to 2020.

But questions were raised if this would still happen in the event of the government and the EU ending Brexit negotiations without agreeing departure terms in 2019.

“The Treasury will guarantee funding for UK organisations which successfully bid directly to the European Commission until the end of this EU budget period if no deal is agreed,” the Treasury said today.

This will give potential applicants “continued confidence to bid for funding whatever the outcome of the negotiations, and ensure that UK organisations continue to benefit from funding post-Exit”.

The ESF was cash that the UK received, as a member state of the EU, to increase job opportunities and help people to improve their skill levels, particularly those who find it difficult to get work.

Although providers will be pleased that this current funding round of ESF is guaranteed to run until 2020, many are still concerned what happens after that deadline.

In April, the work and pensions committee said the government must “urgently” design a successor programme to the ESF to avoid a “disastrous” post-Brexit funding gap.

Leaving the EU gave the UK a “historic opportunity” to “design a truly world-class successor” programme that was “entirely in its national interests: plugging skills gaps, boosting productivity and lifting up disadvantaged communities,” the report said.

But it warned the government “must act now to guarantee certainty for providers and communities and avoid a potentially disastrous interruption in funding”.

Commenting on today’s announcement, Mr Hammond said: “We continue to make positive steps towards getting the best possible deal with the EU – one that works for the whole of the UK.

“The guarantee we are making today however means that, even in the unlikely event of a no-deal, our businesses, universities and local authorities can be confident that they will continue to receive the funding they successfully bid for from any EU programme.”

9 things we learned from the DfE’s annual report and accounts 2017-18

The Department for Education has this morning published its annual report, revealing payoffs, various bonuses and millions in unrecoverable debt.

The accounts sets out the expenditure and performance of the department over the period April 1, 2017 to March 31, 2018.

FE Week has the main findings:

 

1. Hinds’ ministerial direction ‘demonstrated strong commitment’ to T-levels

The accounts take note of the education secretary’s rare ministerial direction on the implementation of the new technical qualifications.

On May 17 Jonathan Slater drew attention to the ambitious timetable and the challenge in ensuring that the first three T-levels would be ready to be taught from 2020 and beyond to a consistently high standard.

But education secretary Damian Hinds, having “considered the advice in detail”, was “convinced of the case to press ahead”. The direction “demonstrated the government’s strong commitment to the future success of the T-level programme,” according to the accounts.

 

2. Justine Greening was handed a £16k payoff

The former education secretary was given a £16,876 severance payment when she left the department in January.

Damian Hinds replaced her and he was paid £15,425 salary until the end of the year.

Former skills minister Robert Halfon received no pay-off when he was sacked in June. But he did pick up £7,000 including pension on top of his MPs salary for his time as a skills minister that year.

Anne Milton joined on June 12 and received £25,432 until the end of the year. The overall salary for a skills minister has not changed, and sits at £31,680 for a full year.

 

3. Bonuses for senior staff

Three DfE directors received bonuses in 2017-18. Peter Lauener, the former chief executive of the Education and Skills Funding Agency received between £20,000 and £25,000 despite numerous torubles before he left, including two procurement fiascos and the Learndirect scandal.

Andrew McCully, the director general for infrastructure and funding, got between £10,000 and £15,000, and Paul Kett, director general for education standards, received between £5,000 and £10,000.

 

4. Presidents Club organiser Meller was paid £27k

Apprenticeships ambassador and businessman David Meller resigned as a non-executive board member at the DfE in January following revelations about the controversial Presidents Club charity dinner.

He set up the Meller Educational Trust, which runs four schools and a university technical college, and served as chair of the National Apprenticeship Ambassador Network and the Apprenticeship Delivery Board.

But he was also the co-chair of the charity set up to run the dinner, which was rocked by allegations of sexual harassment by guests following a Financial Times investigation.

Most non-executive board members are unpaid. However, DfE accounts show Meller was one of three to receive remuneration, paid £15,000 in 2016-17 and £12,500 in 2017-18.

The same payments were also made to board member Marion Plant, while Baroness McGregor Smith received £17,500 in 2016-17 and £15,000 in 2017-18.

 

5. Over £60m lost because of poor colleges and failed UTCs

As revealed in the ESFA’s annual accounts last week, the DfE waived huge amounts owing to its exceptional financial support for colleges.

The college with the biggest amount waived was Hull, where the ESFA abandoned £21,267,000. The second was Central Sussex College with £12,098,000, followed by Bournville College, which had £10.5 million waived.

Three failed University Technical Colleges – Daventry, Greater Manchester, and Lancashire – had a combined total of £3,137,000 written off as a result of closure.

 

6. Staff costs increased and spending on consultants and temporary staff on the rise

In 2017-18 the DfE spent £535 million on paying wages, up from £473 million the previous year.

The DfE meanwhile spent £9 million on consultancy in 2017-18, up from £6 million last year and £3.5 million in 2015-16.

Spending on temporary staff also rose to £27.2 million, up from £22.5 million last year.

 

7. The DfE employs 127 people ‘off-payroll’

The department and its various agencies is paying 127 staff off-payroll – something the Treasury isn’t too keen on because it means staff could use it as a tax dodge to pay a lower rate of tax.

These employees are paid more than £245 a day.

This includes 32 at the department itself, 54 at the ESFA and 21 at the Standards and Testing Agency.

Of the 127 arrangements, 27 have been in place for less than a year, 46 have been in place for between one and two years, 20 for between two and three years, nine between three and four years and 25 for more than four years.

 

8. 35 colleges in formal intervention

As at August 31, 2017, there were 35 colleges in intervention due to poor financial health. This was a decrease from the 40 at the same point in 2016.

Colleges that are in inadequate financial health can be referred to the FE Commissioner, who will conduct an intervention assessment.

 

9. Research spending has doubled in two years

In 2017-18, the DfE spent £22.6 million on research, compared to £16.7 million in 2016-17 and £11.1 million in 2015-16.

However, during that time, the DfE has grown in size, having taken on responsibility for adult skills and higher education in 2016.

None of its “key research strands” were for FE.

Why good governance is crucial for ITPs

The AELP’s new code of governance is a chance for training providers big and small to think about how they comply with best practice, observes Nichola Hay

Governance is a hot topic right now. Only a week after I spoke on the subject at the Association of Employment and Learning Providers’ national conference, Ofsted’s chief inspector dedicated a whole speech to its application in multi-academy trusts. Obviously Amanda Spielman hadn’t been taking her lead from the conference, but it has been rewarding to be part of an important initiative as AELP drives forward best practice in our part of the sector.

With support from the Further Education Trust for Leadership and the expert advice of sector luminaries Sue Pember and Karen Adriaanse, the AELP initiative takes the form of a new code of good governance for independent training providers (ITPs), which include limited companies, charities and not-for-profit organisations of all sizes. AELP has strongly recommended that the code be adopted by all its ITP members.

An ITP’s board should publish an annual account of its engagement with the main communities that it serves

Good governance is not new to ITPs. My organisation is part of the Seetec Group and our governance approach follows the principles of the Corporate Governance Code. As a public service provider responsible for public funds, we are also guided by the Nolan standards in public life, and many other AELP members do the same. But the new code developed by AELP is a major step forward because it helps to formalise governance within the sector, and provides a clear framework for AELP members to map their governance against.

The code can be applied to organisations of all sizes, and ideally all ITPs should review their governance structure, document what it looks like and how it complies with the best practice. However, it is expected there will be differences in the way organisations implement the code, given their structures and sizes.

Larger ITPs will simply need to review their current structure and map over to the code, bridging whatever gaps they identify.

Small and medium-sized organisations will need to think about what governance means to them, and consider how the senior management team will be challenged and questioned on decision-making. Their governance structure will need to be formalised.

My recommendation would be that if you are a small provider and feel that an aspect of the governance code doesn’t apply, then you should be transparent about the reasons for not adopting it, and what you have in its place to ensure the principles are being followed.

Ofsted’s scrutiny of the governance of all types of providers should be a reason in itself for adopting the code. But as a director, I am challenged and questioned daily on decisions made by stakeholders, including our employer clients. Following the code will bring additional comfort and security for me as well as being of benefit to stakeholders. I would recommend that those providers who have a board and haven’t got a non-executive director should consider appointing at least one to offer external insight and hold the management team to account.

Other aspects I believe will be of particular value are the code’s recommendations on transparency and openness. At least once a year, an ITP’s board should publish on the organisation’s website an account of its engagement with the main communities that it serves, the progress made towards meeting their needs for education and training, and how it aims to meet future needs. Again, the focus on how we deliver social value is vital when we are reporting on the use of public money, and this is why we should also encourage employers to put governance structures in place in respect of their levy funds. Via its annual report or self-assessment report, the ITP should also communicate that it has adopted the code and demonstrate how it complies with the principles.

The AELP code was published at the AELP conference as a “final draft” for consultation and it will be finalised shortly. By embracing it, a provider is sending out a signal in a very competitive marketplace that it has good values and ethics.