If you have a disability which makes reading this document or navigating our website difficult and you would like to receive information in an alternative format, please contact: anddegree@acm.ac.uk 

Procedure 077: EMERGENCY LOCKDOWN

Purpose:
This emergency lockdown procedure is designed to ensure the safety of students and staff in the event of a major incident outside of ACM buildings. The procedure will be enacted upon notification from the police or relevant authority that an emergency lockdown is necessary. 

Please note: where ACM uses premises operated or managed by a third party, e.g. Brixton House and The Bridge, the lockdown procedures of the building management shall be followed. 

What is lockdown?

Instigating lockdown means locking doors and other physical barriers to restrict entry to and/or exit from a site or one or more zones within a site. It is sometimes referred to as `dynamic lockdown’.

Why instigate lockdown? 

Analysis of historic attacks, including the attack on London Bridge and Borough Market in 2017 and research conducted by the Centre for the Protection of National Infrastructure (CPNI) have shown that instigating lockdown in the event of a marauding terrorist attack (MTA) can be a highly effective way of reducing casualties. 

It is typically most useful when an attack begins outside a site or building, where lockdown can delay attackers from entering an area or deter them altogether. The aims of lockdown are to reduce the immediate threat of harm by: 

• Delaying attackers’ progress in finding and killing victims;
• Preventing people inadvertently putting themselves into the path of attackers.

1. Initiating the Lockdown

• Upon receiving notification from the police or other relevant authority that an emergency lockdown is required, or when we assess the need ourselves, ACM’s security or designated person will immediately inform key stakeholders in each of ACM’s buildings via the walkie-talkie system. 
• The key stakeholders in each building (e.g. senior staff, designated lockdown coordinators) will communicate the lockdown to all staff and students within their respective buildings.
• It is recommended that students and staff follow the instructions of the key stakeholders as part of this lockdown procedure. However, Article 5 of the Human Rights Act 1998 protects the right not to be deprived of liberty or freedom unless it is in accordance with the law. It should therefore be understood that all individuals have the right to make their own decisions at any time as to whether they remain on ACM premises under lockdown or not. 

2. Securing the Premises

The designated staff in each building will secure the premises as follows:

• Buildings with a single entrance/exit: the designated staff member will secure the front door.
• Buildings with multiple entrances/exits: designated staff will simultaneously secure each entrance and exit.

• All external doors will be locked where possible to prevent entry.
• Windows must be closed and locked where possible.
• Blinds or curtains should be drawn where available.
• All individuals must move away from windows and doors, remaining out of sight where possible.
• Internal movement should be minimised; individuals should remain in classrooms, offices, or designated safe areas. 
• Staff and students should remain calm and quiet to avoid drawing attention. 

3. Communication During Lockdown

• The lockdown status will be maintained through ongoing communication via the walkie-talkie system.
• ACM’s security and/or safeguarding team will liaise with the police for updates and guidance.
• Staff should monitor their emails and other official communication channels for further instructions.
• Mobile phones should be placed on silent mode to prevent unnecessary noise but kept accessible for emergency use.

4. Registering Students

• Each classroom/office should take a register of all present individuals and report any absentees to the designated lockdown coordinator via email or internal communication systems.
• Any discrepancies should be reported to the safeguarding team, who will liaise with the police if necessary. 

5. Students or Staff Outside the Building

• Whilst every care will be taken to safeguard students, it is important to note that ACM does not act in loco parentis for students. 
• Any students and staff visible outside at the time of locking down should enter, or will be instructed to enter, the nearest ACM building immediately. 
• Students or staff who are not in view and are off the premises should follow the ProtectUK guidance:
  • Run: If there is a safe route, escape to a place of safety.
  • Hide: If escape is not possible, hide and stay silent. 
  • Tell: Once safe, inform the police by calling 999.

6. Lifting the Lockdown

• The lockdown will only be lifted when it is deemed appropriate to do so, such as from direct instruction from the police or relevant authority.
• ACM security will communicate the all-clear signal via the walkie-talkie system.
• The designated staff will relay the all-clear message to staff and students in each building.
• A final headcount will be conducted to account for all students and staff before resuming normal operations.

7. Post-Lockdown Actions

• A debrief session will be held for staff and key stakeholders to evaluate the lockdown response.
• Students will be offered appropriate support, including counselling if required.
• Any necessary amendments to the procedure will be made based on feedback and lessons learned.

8. Review and Training

• This procedure will be reviewed annually and updated as required.
• Regular training will be conducted to ensure preparedness.

 

9. Supporting Information for this Procedure

10.1 Internal

• ACM Run, Hide, Tell Policy
• ACM Prevent Policy

10.2 External 

• ProtectUK Advice and Guidance on Emergency Preparedness

https://www.protectuk.police.uk/about-protectuk 

 

10. Document History and Next Review

Version	1.0
Approved on	01 September 2025
Approved by	Academic Board
Date of next review	August 2026

Download: PRO_077 Emergency Lockdown_v1.0

If you have a disability which makes reading this document or navigating our website difficult and you would like to receive information in an alternative format, please contact: anddegree@acm.ac.uk 

Policy 076: RUN, HIDE, TELL

1. Introduction

The Academy of Contemporary Music (ACM) is committed to the safety and well-being of its students, staff, and visitors. In the event of a major incident, such as a fire, natural disaster, or terrorist attack, it is essential to have a clear and concise plan in place to ensure the safety of all those on campus. This procedure is designed to provide guidance on how to react in such an event. 

2. Scope

This procedure applies to all ACM campuses in Guildford, Birmingham, and Clapham. It applies to all staff, students, visitors, contractors, and anyone else who may be on campus during a major incident.  

3. Relevant Legislation and Guidance

This procedure is in accordance with the following legislation and guidance:

• The Health and Safety at Work Act 1974  
• The Human Rights Act 1998  
• The Data Protection Act 2018  
• The Terrorism Protection of Premises Act 2024  
• The UK government’s Run, Hide, Tell guidance  
• UK Contest Strategy
• Prevent Duty Guidance

4. Linked Policies and Procedures

This procedure should be read in conjunction with the following ACM policies and procedures:

• Health and Safety Policy  
• Fire Safety Procedure  
• Evacuation Procedure  
• Security Policy  
• Data Protection Policy  
• Prevent Policy  
• Safeguarding Policy  

5. Procedure

5.1 RUN

1. Be aware that in certain situations, physical ‘running’ could put individuals at greater risk. Do not take unnecessary risks. 
2. If there is a safe and accessible escape route, evacuate the premises immediately.  
3. Do not attempt to gather personal belongings. Your safety is your priority.
4. Follow the instructions of emergency personnel.  
5. If you encounter a fire, activate the nearest fire alarm.  
6. If there is an explosion, be aware of the potential for falling debris.  
7. If there is a chemical or biological hazard, avoid contact with the substance and evacuate the area immediately.  
8. Assist those who need help. If it is safe to do so, help others to evacuate, especially those who may need assistance.  
9. Warn others. As you evacuate, warn others to do the same.  
10. Do not use the lifts. Use the stairs instead.  
11. If you are caught in smoke, drop to the ground and crawl to the nearest exit.  
12. Once you are outside, move to a safe location and do not re-enter the building until you have been told it is safe to do so.  

5.2 HIDE

1. If it is not safe to evacuate, or if you are physically unable to do so, find a safe place to hide. This could be under a desk, in a cupboard, or behind a solid object.  
2. Lock and barricade the door if possible. This will help to delay the attacker.  
3. Silence your mobile phone and any other devices that may make noise. This will help to avoid detection.  
4. Stay low to the ground and away from windows. This will help to protect you from flying debris or gunfire.  
5. If there is an active shooter, try to find a solid object to hide behind. This will help to protect you from being shot.  
6. Do not leave your hiding place until you are certain it is safe to do so. Wait for instructions from the police or other emergency personnel.  

5.3 TELL

1. Once you are safe, call 999 and tell the operator what is happening.  
2. Provide as much detail as possible, including the location of the incident, the number of people involved, and any injuries or fatalities.  
3. If you have any information about the perpetrator, such as their description or vehicle, provide this to the police.  
4. Consider not leaving the scene until you have been instructed to do so by the police.  
5. Be prepared to answer questions. The police will want to know as much information as possible about the incident. 
6. Provide support to others. If you are safely able to, provide support to others who have been affected by the incident.  

6. Training and Exercises

ACM will conduct regular training to ensure that everyone knows what to do in the event of a major incident.  

7. Review

This procedure will be reviewed annually and updated as necessary.  

8. Policy Owner

The policy lead is responsible for the cyclical monitoring and review of the policy in liaison with the Quality Assurance Team. The Run, Hide, Tell policy lead is:

• Designated Safeguarding Lead

Decisions and appropriate actions in support of the implementation of the Policy will be authorised by the following designated staff:

• Campus Leads
• Designated Safeguarding Lead or nominee
• Quality Assurance and Enhancement Manager or nominee
• Senior Management, including Executive Senior Management 

 

9. Document History and Next Review

Version	1.0
Approved on	01 September 2025
Approved by	Academic Board
Date of next review	August 2026

Download: POL_076 Run, Hide, Tell_v1.0 

If you have a disability which makes reading this document or navigating our website difficult and you would like to receive information in an alternative format, please contact: anddegree@acm.ac.uk

POLICY 075: Student Use of Artificial Intelligence

1. SCOPE

1.1 This policy applies to all students enrolled on programmes at ACM, including all FE provision and all HE provision, including Foundation programmes, Integrated Masters programmes and Masters programmes. 

1.2 This policy should be read in conjunction with ACM’s Academic Integrity and Misconduct Policy (Policy 007). Policy 075 provides specific guidance regarding artificial intelligence, but all definitions, investigation procedures, and penalties remain governed by the overarching Academic Integrity and Misconduct Policy. 

2. INTRODUCTORY STATEMENT AND POSITION

2.1 ACM believes that AI tools are transformative and disruptive, and that they will feature in many academic and professional workplaces. As an institution, ACM is committed to exploring ways in which it can utilise AI to support and facilitate deeper learning. 

2.2 Rather than seek to prohibit the use of AI tools, ACM will support students in using them effectively, ethically and transparently where they wish to do so. Tools such as ChatGPT, Claude, Quillbot, CoPilot and Grammarly can help students in a number of ways. Examples might include: 

• Planning or structuring written materials ethically.
• Generating graphics, images and visuals ethically to support your work.
• Helping to improve grammar – especially helpful if English is a second language. 
• Deriving explanations. 

3. STUDENT RESPONSIBILITIES

3.1 Whilst AI tools are powerful and easy to use, they can negatively impact your learning as they can detract from the reflection and critical engagement that are essential for deep and meaningful learning. Students are always expected to engage with learning and research directly, and not use AI tools as a substitute for their own critical thought, independent analysis, or creative decision-making. 

3.2 AI tools can also easily provide misleading or incorrect information, despite the output sounding confident and assured. Students who rely on these tools unethically or without caution risk losing their own skills and expertise, and may struggle to study or work without them. 

3.3 Students should be aware that tools such as those listed in 2.2, whilst useful, can lead a student to commit academic misconduct if content is created that is not the student’s own but is then presented as such, either intentionally or unintentionally – this could include substantially altered wording, which students often report as being part of the pursuit of sounding ‘more academic’. These tools, and others, are multi-functional. It is the student’s responsibility to use these tools in a way that upholds academic integrity and to ensure you do not commit academic misconduct.

3.4 When an AI tool (such as ChatGPT, Claude, or Copilot) is used to generate text, including the presentation of ideas or arguments, you must cite it in the body of your text (in-text citation) and include it in your reference list at the end of your work. However, because generative AI can be an unreliable source that frequently lacks academic depth or accuracy, an over-reliance on AI-generated content may negatively impact your grade if, in the academic judgement of the reviewer, this is deemed to have occurred. Any generated text that is not referenced may be considered Academic Misconduct. Text that is generated and re-written may also be considered Academic Misconduct.  

Academic Integrity

3.5 To our students we say: Be enquiring, be conscientious, be honest. Although the use of AI supports studying in many ways, it must not lead you to neglect your study efforts and to rely on the outputs provided by these tools – keep academic integrity uppermost in your mind because academic misconduct is always taken seriously and can negatively impact your progression and final award. 

3.6 Students must always ensure they demonstrate academic integrity in their work. This means employing good judgement to ensure that AI has been used appropriately and without gaining an inappropriate advantage. It is crucial that you do not use AI tools to simply generate work and submit it without correct referencing and full disclosure. Passing off AI-generated content as your own will be treated as academic misconduct (plagiarism) in the same way as it would if the text were written/created by another individual. If AI-generated text or viewpoints are explicitly cited and declared, this will not be treated as misconduct, but may impact your grade if, in the academic judgement of the assessor, an over-reliance on AI is deemed to have occurred. 

Know the Limitations of Artificial Intelligence

3.7 The use of AI has clear limitations. For example, currently-available AI tools can: 

• Only simulate understanding. 
• ‘Hallucinate’ to create plausible sounding but factually incorrect answers. 
• Inherit bias and viewpoints from the training material. 
• Use information that is not always up to date. 

3.8 AI tools are not reliable sources. Think of them as the equivalent of asking a random stranger on the street something: the information they provide might be taken from any number of inaccurate, misleading, or misremembered sources, but made to sound convincing. 

Writing Style and Academic Writing 

3.9 ACM is aware that students, especially those new to Higher Education, may struggle with Academic Writing and the purpose of such writing as a skill set. Academic writing is about presenting existing, trusted sources that support your own ideas, which are themselves based on your research and/or your experiences throughout your learning. 

3.10 The academic writing approach allows you to deliver this as a body of work that is coherent and easily accessible by a university marker. But this is different to, and does not mean, using unnecessarily fancy words to make your work sound ‘smarter’. In fact, we have already seen instances of student work that has supposedly been ‘improved’ by AI actually become less coherent, or less in line with the Assessment task as a result of attempting to sound ‘academic.’ Importantly, work that has been significantly changed by AI as part of this pursuit may be in breach of Academic Integrity rules. It is important that written work remains substantially the students own.  

3.11 Make sure you focus on the substance required of the assessment brief and the learning outcomes. Speak to your tutors, who are there to support you, about what the assessment is actually asking for. 

3.12 It is a breach of academic integrity to blend AI-generated ideas, arguments, or uncredited text sequences with your own content without clear demarcation, citation, and declaration. 

Research authenticity and citations

3.13 The term ‘research’ does not only refer to work done for a dissertation or major project; it applies to any academic or creative investigation undertaken to support, develop, or inform any piece of submitted work, regardless of its FHEQ level, size or format. For the purposes of this policy and for the implementation of the Academic Integrity and Misconduct Policy (Policy 007), research is defined as any act of sourcing, evaluating, or utilising information to build an assignment. 

3.14 Writing is the primary vehicle through which you demonstrate your critical thinking and engagement. Therefore, outsourcing the writing process to AI without full disclosure is a form of intellectual dishonesty. When a student uses AI to generate the prose, arguments, or analytical narrative of their work and presents it as their own, they are actively faking the intellectual trail of their research, mischaracterising the authenticity of their own academic development, and presenting a false narrative of academic engagement. Where such use is fully disclosed and cited in accordance with Section 3.18, it will be evaluated under standard academic marking criteria rather than as misconduct.

3.15 While students are permitted to use AI tools to suggest and locate potential research sources, they are required to independently access, read, and evaluate those sources themselves. It is an act of intellectual dishonesty to use AI tools to fabricate or “pad” bibliographies, reference lists, or in-text citations with sources the student has not personally verified. Presenting citations to sources that the student has not personally accessed, read, and academically evaluated is a breach of academic integrity. This practice falsely represents the authenticity of the research process and misleads the assessor into believing independent research has occurred when it has not.

3.16 AI tools are known to “hallucinate” plausible-sounding but fake or inaccurate journal titles, authors, DOIs, and page numbers. Submitting work containing fabricated or partly fabricated/incorrect references (including those generated by AI) – or real references mapped onto claims they do not actually support – constitutes falsification and academic misconduct. This will be treated under the Academic Integrity and Misconduct Policy (Policy 007) as plagiarism. 

Declaration of AI Use 

3.17 Students should never pass off ideas or text taken from AI as their own, and there must be a clear and fully detailed account of how AI has been used in the work. Your assessment briefs require you to complete a Declaration of Authenticity. This includes a statement on the use of AI. 

3.18 ACM prioritises academic transparency. If a student explicitly quotes, references, and declares content generated by an AI tool (e.g., citing a viewpoint generated by ChatGPT), this will not be investigated as academic misconduct. Instead, it will be evaluated academically. Students should note that AI tools are not considered rigorous academic sources (see 3.7 and 3.8), and an over-reliance on cited AI text may result in lower marks for research quality and critical engagement. 

3.19 Completing the Declaration of Authenticity is a mandatory requirement of the submission process. You should complete this declaration whether you have used AI in your submission or not. It is important to be aware that any suspected AI use in a submission which is not accompanied by an appropriate declaration or referencing will be flagged for potential Academic Misconduct. 

AI Detection Tools

3.20 ACM employs the latest AI detection software, which includes Turnitin’s AI detector tool as a component of our academic compliance procedure. AI detection scores are treated as indicators to prompt closer review and are not ACM’s sole point of reference. 

Keeping Drafts of your work

3.21 Should you feel the need or desire to improve your work ethically through AI, such as those outlined in this policy, you are required to keep drafts of your work before the influence of AI. This will be requested as a part of the Academic Misconduct investigation should there be any suspicion of over-reliance on AI in your work, particularly where there is no Declaration of Authenticity apparent. Being able to show how your drafts lead to the finished work is a positive way of working with the academic integrity process. 

3.22 ACM provides unlimited storage in Google Drive to every student. It is good practice and in your own interest to create, draft and store your work in your Google Drive, thereby maintaining transparency and a clear record of document creation. 

3.23 Where ACM presents prima facie evidence of potential AI over-reliance, students will be required to provide drafts and version histories. Providing these materials is an effective way for a student to directly address the institution’s concerns. Where a student is unable or unwilling to provide draft history, ACM’s academic misconduct panel will make its final determination based on the available evidence before it. 

4. OTHER RELEVANT DOCUMENTS

4.1 Internal Documents

• Policy 007 Academic Integrity and Misconduct 
• Policy 012 Learning, Teaching, Assessment and Attainment
• Policy 061 Student Engagement and Participation
• Harvard referencing guide found on the student Canvas page 

5. DATE OF APPROVAL AND NEXT REVIEW

Version	2.0
Approved on	01 September 2026
Approved by	Academic Board
Date of next review	August 2027

Download this document: POL_075 Student Use of Artificial Intelligence

If you have a disability which makes reading this document or navigating our website difficult and you would like to receive information in an alternative format, please contact: anddegree@acm.ac.uk 

 

Policy 069: FREEDOM OF SPEECH CODE OF PRACTICE 

1. PURPOSE 

1.1  ACM is committed to promoting an environment that upholds the principles of academic freedom and freedom of speech, as enshrined in the Higher Education (Freedom of Speech) Act 2023. 

1.2  In accordance with the Higher Education (Freedom of Speech) Act 2023, ACM’s objective through this Code of Practice is to secure freedom of speech within the law for staff, members and students of ACM, and visiting speakers. 

1.3  ‘Academic freedom’ for academic staff at registered higher education providers refers to their freedom within the law to question and test received wisdom, and to put forward new ideas and controversial or unpopular opinions without placing themselves at risk of being adversely affected by the loss of their jobs or privileges at the provider, and without the likelihood of their securing promotion or different jobs at the provider being reduced.

1.4  This Code of Practice fulfils the requirements of section A2 of the Higher Education (Freedom of Speech) Act 2023. This Code will outline: 

1. ACM’s values relating to freedom of speech and an explanation of how those values uphold freedom of speech (see 1.5 and 2.2);
2. the procedures to be followed by staff and students of ACM and any students’ union or similar organisation for students at ACM in connection with the organisation of (i) meetings which are to be held on ACM’s premises and which fall within any class of meeting specified in the Code, and (ii) other activities which are to take place on ACM’s premises and which fall within any class of activity so specified (see 2.16 to 2.22);
3. the conduct required of such persons in connection with any such meeting or activity (see 2.2); 
4. the criteria to be used by ACM in making decisions about whether to allow the use of premises and on what terms (which must include its criteria for determining whether there are exceptional circumstances for the purposes of section A1(10)) of the Higher Education (Freedom of Speech) Act 2023 (see 2.13 to 2.15). Exceptional circumstances will normally arise only where no reasonably practicable mitigations would enable the event to proceed lawfully and/or safely. 

1.5 ACM recognises that the free exchange of ideas and diverse perspectives is essential for intellectual growth, critical thinking, and the pursuit of knowledge. This Code of Practice outlines ACM’s commitment to protecting and promoting freedom of speech while ensuring that it is exercised within the boundaries of the law. ACM expects members of its community to engage with one another with mutual respect and professionalism, while recognising that lawful freedom of speech includes the expression of differing, controversial, unpopular, offensive, shocking or disturbing viewpoints.

1.6 ACM recognises that freedom of speech includes the expression of ideas that others may find controversial, offensive, shocking or disturbing. 

2. CODE OF PRACTICE DETAILS 

2.1 The obligations and principles set out in this Code of Practice apply to ACM and, where relevant, to activities undertaken by any students’ union or equivalent organisation operating in connection with ACM. ACM will work with any such organisation to support freedom of speech and academic freedom and to ensure that activities taking place on premises controlled by ACM are managed consistently with this Code of Practice.

2.2  Guiding Principles:

1. Academic Freedom: ACM is dedicated to maintaining an atmosphere where academic staff and students can engage in open and robust discussions, research, and exploration of diverse viewpoints, theories, and ideas. Academic freedom ensures the pursuit of knowledge is uninhibited by external pressures.
2. Freedom of Speech: ACM respects and safeguards the right to freedom of speech for all members of our community. This includes the right to express opinions, beliefs, and ideas, even those that may be controversial, unpopular, or challenging.
3. Respectful Dialogue: While ACM encourages free expression, it is also important that all discourse remains respectful and tolerant of differing viewpoints. ACM recognises that freedom of speech includes the right to express ideas that may be controversial, offensive, or unpopular. The offensive nature of speech does not, of itself, justify restricting expression, provided that expression remains within the law.
4. Lawful Expression: Freedom of speech within the law is protected. Speech that breaches criminal or civil law is not protected. The fact that speech is controversial, unpopular, offensive, shocking, disturbing or causes offence does not, of itself, justify restricting or penalising that speech. Where ACM considers whether to regulate or restrict lawful speech, it will have particular regard to the importance of freedom of speech and academic freedom and will take reasonably practicable steps to secure lawful speech.

Unlawful speech

2.3 Unlawful Speech: ACM will not restrict or penalise speech solely because it is controversial, unpopular, offensive, shocking or disturbing. Speech is not protected as freedom of speech within the law where it breaches applicable criminal or civil law. This includes, but is not limited to, speech that amounts to a criminal offence, unlawfully incites violence or terrorism, unlawfully stirs up hatred under relevant legislation, constitutes unlawful harassment or victimisation under the Equality Act 2010, or is otherwise prohibited by law.

2.4  Hate Crime: Hate crime is a criminal offence punishable under UK criminal law. The law recognises five types of hate crime on the basis of:

• Race
• Religion 
• Disability
• Sexual orientation 
• Transgender identity

Hate crimes can take the form of physical assault, verbal abuse or incitement to hatred and are covered by legislation (Crime and Disorder Act 1998 and section 66 of the Sentencing Act 2020) which allows prosecutors to apply for an uplift in sentence for those convicted of a hate crime. The police and the Crown Prosecution Service (CPS) have agreed the following definition for identifying and flagging hate crimes:

“Any criminal offence which is perceived by the victim or any other person, to be motivated by hostility or prejudice, based on a person’s disability or perceived disability; race or perceived race; or religion or perceived religion; or sexual orientation or perceived sexual orientation or transgender identity or perceived transgender identity.”

2.5 Hate Incidents: A non-criminal hate incident is an incident which the victim, or any other person, perceives to be motivated by hostility or prejudice based on a person’s race, religion, disability, sexual orientation or transgender identity, but which does not amount to a criminal offence. The reporting or recording of a non-criminal hate incident will not, of itself, determine whether disciplinary or other action is appropriate. ACM will assess the underlying conduct on its individual facts, taking into account its obligations under this Code of Practice, including the protection of lawful freedom of speech and academic freedom, together with its duties under the Equality Act 2010, safeguarding responsibilities, and other applicable policies. ACM reserves the right to report incidents to the police where there are reasonable grounds to suspect that a criminal offence may have been committed.

Harassment

2.6 Harassment: ACM does not tolerate harassment, bullying or other inappropriate conduct. Harassment has the meaning given to it by applicable law, including the Equality Act 2010. ACM may also take disciplinary action in respect of conduct that does not meet the legal threshold for unlawful harassment but nevertheless breaches ACM’s policies or standards of behaviour, provided that any such action is consistent with ACM’s obligations to protect lawful freedom of speech and academic freedom. In applying its policies relating to harassment, ACM will have particular regard to the importance of freedom of speech, academic freedom and tolerance for controversial views in an educational context. ACM will apply a rebuttable presumption that students being exposed to course materials, or to statements or views expressed as part of teaching, research or discussion connected with the content of a higher education course, is unlikely in itself to amount to harassment.

Protection from retaliation

2.7 Protection from Retaliation: ACM will not subject any member of the community to adverse treatment solely because they have expressed a lawful opinion, belief or viewpoint, including where that opinion, belief or viewpoint is controversial, unpopular, offensive, shocking or disturbing. This protection extends to academic, employment-related and disciplinary matters, subject to ACM’s lawful duties and policies relating to conduct, performance and professional or educational requirements.

Balancing Legal Duties

2.8 Balancing Legal Duties: In implementing this Code of Practice, ACM will comply with all relevant legal and regulatory obligations, including its duties relating to freedom of speech and academic freedom, equality, human rights, safeguarding and the Prevent Duty. Where these obligations apply simultaneously, ACM will consider the specific facts and circumstances of the case and give particular regard to the importance of freedom of speech within the law and academic freedom. ACM will take reasonably practicable steps to secure lawful freedom of speech and, where a restriction of lawful speech is considered necessary, will ensure that any restriction is prescribed by law and proportionate in accordance with applicable legal requirements.

Application of the Code of Practice

2.9 Classroom and Learning Environments: In academic settings, tutors have the autonomy to teach and discuss topics relevant to their courses, subject to applicable professional, legal and educational requirements. Students are encouraged to engage in thoughtful discussion and express diverse perspectives. ACM recognises that students may be exposed to course content, teaching, research and discussion of subjects or viewpoints that they find controversial, offensive, shocking or disturbing. The lawful expression of such views, including in teaching, research and academic discussion, will not, of itself, constitute misconduct or harassment.

2.10 Events and Guest Speakers: ACM values the diversity of ideas and viewpoints that guest speakers bring to its campuses. Subject to this Code of Practice, student groups and organisations may invite speakers of their choice. ACM will not refuse permission for an event, or impose conditions on an event, solely because of the viewpoint or anticipated content of lawful speech. Where an event presents risks to safety, the prevention of disorder or crime, or other legitimate legal or operational requirements, ACM will consider reasonably practicable mitigations and, where appropriate, regulate the time, place or manner of the event in a viewpoint-neutral and proportionate manner.

2.11 Online and Social Media: The principles of freedom of speech extend to online platforms and social media where the relevant activity falls within ACM’s legal or regulatory responsibilities. ACM will not restrict or penalise lawful expression solely because it is controversial, unpopular, offensive, shocking or disturbing. Members of the ACM community remain responsible for unlawful conduct and for conduct that breaches applicable ACM policies, provided that those policies are applied consistently with ACM’s obligations to protect lawful freedom of speech and academic freedom.

2.12 Protests and Demonstrations: Peaceful protests and demonstrations are a legitimate form of freedom of expression. ACM will take reasonably practicable steps to facilitate lawful protest and will not restrict a protest solely because of the viewpoint expressed. Where necessary to protect teaching, learning, research, other lawful expression, public safety, access to premises or other essential functions, ACM may regulate the time, place or manner of a protest, using measures that are proportionate and, wherever reasonably practicable, viewpoint-neutral.

Events

2.13 Events: Where any person or body subject to the obligations of this Code of Practice wishes to hold an event for the expression of any views or beliefs held or lawfully expressed on premises controlled by ACM, consent shall not be unreasonably refused. ACM will have a strong presumption in favour of permitting lawful events and will take reasonably practicable steps to enable them to proceed.

2.14 Event Restrictions: ACM may refuse consent, withhold facilities or impose restrictions on an event only where this is justified by applicable law or where, having particular regard to the importance of freedom of speech and academic freedom, reasonably practicable steps cannot otherwise secure the event and any restriction is lawful and proportionate. Relevant considerations may include public safety, the prevention of disorder or crime, the protection of persons lawfully on ACM premises, or a reasonable and evidenced risk that the event would involve unlawful conduct. ACM will not refuse an event solely because of the viewpoint, identity or lawful opinions of a proposed speaker or because the event may be controversial or cause offence.

2.15 Conditions on Events: ACM may impose conditions or requirements upon organisers where they are reasonably necessary and proportionate in all the circumstances to enable the event to proceed safely and lawfully. Such conditions may include requirements relating to stewards, security, location, timing, ticketing, capacity, access arrangements or whether an event is open to the public. Wherever reasonably practicable, conditions will regulate the time, place or manner of an event rather than its viewpoint or content.

2.16 Exceptional Circumstances: ACM may decline to permit an event only in exceptional circumstances where no reasonably practicable mitigation would enable the event to proceed lawfully and safely, or where permitting the event would itself be unlawful. Any decision to refuse an event must be supported by clear reasons and an assessment of the relevant risks, alternatives considered and reasonably practicable mitigations available.

Booking an external speaker

2.17  All references to external speakers must be made in accordance with ACM’s External Speaker and Events procedure. The assessment and approval process set out in this section applies to all external speaker requests.

2.18  Most external speaker requests will be low risk and may be approved at departmental level following a proportionate risk assessment. Where concerns are identified, or where the proposed speaker or topic presents potential risks, the request must be escalated for further review in accordance with ACM’s risk assessment process.

2.19  All external speaker requests must be submitted by the event organiser using the approved External Speaker Submission Form and must be received at least ten working days prior to the proposed event date. Requests submitted outside this timeframe may be declined where insufficient time is available to complete the necessary review.

2.20 External Speaker Information: A transcript, summary or detailed outline of an intended talk may be requested only where this is considered necessary and proportionate following a risk assessment. ACM will not routinely require speakers to provide transcripts or detailed content where doing so would unnecessarily restrict or deter lawful freedom of speech. All external speakers must be informed of their obligation to comply with applicable law and ACM’s reasonable requirements concerning the safe and lawful conduct of the event. Where an event presents identified risks, additional information or mitigation may be required where reasonably necessary and proportionate. 

2.21  Where a request to host an external speaker is refused, the decision will be confirmed in writing with clear reasons provided. The organiser may request a review of the decision, which will be considered by a senior member of staff not previously involved in the original decision. The outcome of the review will constitute the final decision within ACM’s internal procedures, without prejudice to any external legal rights of challenge.

2.22 Monitoring of External Speaker Events: A member of staff may attend an external speaker event, or alternative proportionate monitoring arrangements may be put in place, where this is reasonably necessary based on the outcome of the risk assessment. Monitoring arrangements will be used to support the safe and lawful delivery of the event and will not be used to monitor or restrict lawful viewpoints. 

2.23  Speakers must be informed that ACM may record or film events for legitimate purposes including safeguarding, compliance monitoring, and institutional communications. Any recording will be carried out in accordance with applicable data protection legislation and ACM’s data protection and privacy policies, and attendees will be notified where such recording is taking place.

Responsibilities

2.24 Responsibilities: All those subject to this Code of Practice have a responsibility to support ACM in securing freedom of speech within the law and academic freedom. Concerns about a possible breach of this Code should be reported through the appropriate ACM procedure. ACM will assess any alleged breach on its individual facts and, where appropriate, may take action under its disciplinary or other relevant procedures. No person will be subject to disciplinary action solely for expressing a lawful opinion, belief or viewpoint.

2.25  Where breaches of UK criminal law occur, ACM will, where appropriate, assist the Police and the Crown Prosecution Service (CPS). In respect of any criminal charges, ACM will not normally proceed with its own disciplinary proceedings on the same matters until the conclusion of any ongoing criminal proceedings. This does not preclude suspension of a person(s), where deemed appropriate, when actioned in connection with any part of an investigative process. Suspension is not viewed as a punitive measure. 

2.26 This Code of Practice will be reviewed periodically to ensure its effectiveness and relevance. Changes or amendments to the Code will be made in accordance with UK law and the best interests of the ACM community.

2.27  By upholding the principles outlined in this Code of Practice, ACM aims to create an inclusive, intellectually stimulating, and respectful environment where freedom of speech is celebrated as a cornerstone of our academic and creative community.

Complaints

2.28 Complaints: Complaints relating to academic freedom and freedom of speech will be handled through ACM’s normal complaints, grievance or other appropriate internal processes for staff, students and other persons covered by this Code of Practice. Staff should contact hrrequests@acm.ac.uk and students should contact complaints@acm.ac.uk . ACM will ensure that complaints relating to lawful speech are subject to appropriate and proportionate preliminary assessment and, where they are vexatious, frivolous or obviously unmeritorious, are dismissed promptly. Complaints processes will be concluded as rapidly as is reasonably practicable and compatible with fairness. 

2.29 Academic Board: ACM’s Academic Board will have a role in grievance and complaints processes where academic freedom is in question. Where a staff member raises a concern that their academic freedom or freedom of speech has not been protected, the Academic Board may consider the matter and provide a recommendation to the Executive Board (Senior Management Team), through the Chair, to inform the decision on the matter. Where appropriate, and subject to the requirements of the relevant procedure, such matters will be referred to the Executive Board before a final decision is reached in a complaint, grievance or disciplinary process.

2.30 External Complaints – Staff, Members and Visiting Speakers: Where a complaint relating to freedom of speech or academic freedom has not been resolved satisfactorily through ACM’s internal procedures, eligible staff, members and visiting speakers may be able to refer the matter to the Office for Students under its free speech complaints scheme. The OfS has discretion as to whether it will consider a complaint and will apply its published rules and requirements. ACM will provide information about the OfS complaints scheme through its relevant complaints and grievance procedures.

2.31 External Complaints – Students: Where a student complaint about freedom of speech has not been resolved satisfactorily through ACM’s internal procedures, the student may, where eligible, refer the matter to the Office of the Independent Adjudicator for Higher Education (OIA) in accordance with the OIA’s rules and requirements.

3. RELATED POLICIES AND DOCUMENTS

• Higher Education (Freedom of Speech) Act 2023
• European Convention on Human Rights, Articles 10 and 11
• Public Order Act 1986 
• Equality Act 2010
• Human Rights Act 1998
• Counter-Terrorism and Security Act 2015
• Office for Students (OfS) Regulatory Framework
• Middlesex University Code of Practice on Freedom of Speech
• ACM Student Charter 
• ACM Prevent Duty
• ACM Equality and Diversity Policy
• ACM Safeguarding Policy
• ACM Student Disciplinary Policy

4. CODE OF PRACTICE OWNER

4.1 The lead for this Code of Practice is the Executive Board, with oversight provided by the Governing Body, which retains ultimate responsibility for approval, strategic direction, and monitoring of institutional compliance.

5. DOCUMENT HISTORY AND NEXT REVIEW

Version	2.0
Approved on	16 September 2026
Approved by	Executive Board
Next review	August 2027

6. APPENDIX TO THE FREEDOM OF SPEECH CODE OF PRACTICE

External Speaker Risk Assessment Checklist (ACM)

(For use with External Speaker Submission Form)

Instructions:

• Complete this checklist for all external speaker requests.
• Tick all boxes that apply.
• Use professional judgement, but base decisions on evidence where possible.
• Escalate where medium/high risk indicators are identified, with the aim of identifying reasonably practicable measures that will enable the event to proceed safely and lawfully.

1. Event & Speaker Details

☐ Speaker identified

☐ Topic/title confirmed

☐ Event format confirmed (lecture / workshop / panel / performance)

☐ Intended audience confirmed (students / staff / mixed / public)

☐ Date submitted at least 10 working days in advance

2. Content Risk Check

☐ Content is academic, professional, or creative in nature

☐ Content includes controversial or sensitive themes

☐ Content may be polarising or generate strong disagreement

☐ Content relates to politics, religion, identity, or social issues

☐ Specific risk of unlawful speech or conduct identified (e.g. incitement, threats, unlawful harassment or other criminal or civil offences)

☐ Evidence indicates a reasonably foreseeable risk that the event may involve unlawful conduct

Important: Controversial, unpopular, offensive, shocking or disturbing views are not, of themselves, grounds for refusing or restricting an event.

Notes (required if any box ticked other than first):
……………………………………………………………………

3. Speaker Risk Check

☐ Speaker has previously been associated with credible evidence of unlawful conduct relevant to the proposed event

☐ Speaker is associated with an organisation whose activities or objectives give rise to a specific and evidenced legal or safety concern

☐ Safeguarding or other specific operational concerns identified

☐ No specific safeguarding, legal or operational concerns identified

Notes:
……………………………………………………………………

4. Audience & Context Risk

☐ Internal audience only (students/staff)

☐ Mixed internal and external audience

☐ Open/public attendance

☐ Likely presence of vulnerable learners (e.g. FE cohorts)

☐ No significant risk of disruption identified

☐ Credible risk of disruption or protest identified

☐ Credible risk that disruption or protest may prevent the event from proceeding safely or lawfully

Notes:
……………………………………………………………………

5. Safety, Security & Operational Risk

☐ No safety concerns identified

☐ Some manageable safety/security concerns

☐ Elevated safety/security concerns

☐ Event may require security presence

☐ Event may require controlled access/ticketing

Notes:
……………………………………………………………………

6. Outcome Determination

Before determining the overall risk level, the following must be considered:

Have reasonably practicable measures to enable the event to proceed safely and lawfully been considered?

☐ Yes
☐ No – reasons recorded

If the event is to be refused, have alternative venues, timings, security arrangements or other reasonably practicable mitigations been considered?

☐ Yes
☐ No – reasons recorded

Based on the above, the overall risk level is:

☐ Low Risk → Standard departmental approval

☐ Medium Risk → Approval with conditions or other reasonably practicable mitigation required

☐ High Risk → Escalation to senior review required, with reasonably practicable mitigation considered before any decision to refuse the event

☐ Refusal required by law / exceptional circumstances → Event cannot proceed; reasons and alternative mitigations considered must be recorded

Notes / Decision rationale:

……………………………………………………………………..

 

7. Mandatory Mitigation (if applicable)

If Medium or High Risk, consider applying:

☐ Staff attendance / monitoring required

☐ Additional information about the proposed event required, where reasonably necessary and proportionate

☐ Specific materials requested where reasonably necessary and proportionate to an identified risk

☐ Restricted audience (internal only / ticketed)

☐ Controlled Q&A or moderated session

☐ Security presence required

☐ Venue/time adjustment required

8. Final Decision Record

• Decision made by: __________________________
• Role: _____________________________________
• Date: _____________________________________

☐ Approved 

☐ Approved with conditions

☐ Escalated to senior review

☐ Refused (reasons recorded separately)

Summary rationale (mandatory):

………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………

Download: POL_069 Freedom of Speech Code of Practice

The Equality Act 2010 (Specific Duties and Public Authorities 2017 requires gender pay reporting for employers with 250 or more employees to publish statutory calculations showing how large the pay gap is between their male and female employees. For organisations with less than 250 employees this is voluntary (as was applicable to The Academy of Contemporary Music in 2022-23).

View the organisation’s 2022-23 Gender Pay Gap Report here.

If you have a disability which makes reading this document or navigating our website difficult and you would like to receive information in an alternative format, please contact: anddegree@acm.ac.u

1. PURPOSE

1.1 This procedure outlines ACM’s approach to providing a campus environment in which all members of our community feel safe from sexual misconduct. For the purposes of this procedure, this includes sexual harassment, whether explicitly stated or not. 

1.2 This procedure sets out our expectations around the unacceptability of sexual misconduct and sexual harassment.

1.3 This procedure makes clear the ways in which ACM supports students who have experienced any form of sexual misconduct or sexual harassment.

2. PROCEDURE DETAIL

This document outlines our specific Process for handling allegations of sexual misconduct and sexual harassment.

Making a Disclosure
2.1 A disclosure is made when someone tells a member of ACM Safeguarding Team that they have experienced sexual misconduct or sexual harassment. A disclosure can be made in person, online or via other means such as phone or email.

2.2 Students can make disclosures of sexual misconduct or sexual harassment via ACM’s online reporting disclosure link. Where a member of staff has received a disclosure in person or via other means, they may submit a disclosure on behalf of the person who has disclosed via ACM’s online reporting disclosure link. 

2.3 The person who has chosen to disclose does not need to provide the full details of their experience if they do not wish to. They will not be pressured to make a formal complaint.

2.4 If the incident is historical, the person who has experienced it can still disclose it to the ACM safeguarding team and receive support. They can access Wellbeing Support Services, which will be offered.

2.5 Disclosure does not create a formal complaint and is not an instruction for ACM to take action. The person who has disclosed will have the opportunity to be heard and to consider their options before proceeding with any further steps. No action will be taken immediately by ACM unless there is a concern about immediate safety or if ACM has a duty under safeguarding.

2.6 Where a person chooses to disclose anonymously via ACM’s online reporting tool, no action will usually be taken on the basis of their disclosure. Anonymised data will help ACM to understand patterns in behaviour and inform future policy.

2.7 Where a person chooses to disclose, with contact details, via ACM’s online reporting tool, their disclosure will be received by the ACM safeguarding team. The person who has made the disclosure will be contacted by a member of the safeguarding team as soon as is practical to do so.

2.8 Where a disclosure is made but is not submitted via ACM’s online reporting tool, the person who has disclosed can still access support via Wellbeing Support Services.

2.9 The Academy of Contemporary Music recognises the importance of privacy for disclosures and formal complaints of cases of sexual misconduct and will only share information on a confidential, need-to-know basis. All personal data is recorded and held in accordance with the Data Protection Act 2018. ACM will retain anonymised data to understand patterns of behaviour and to inform future policy.

2.10   Confidentiality is not absolute secrecy. There may be circumstances where it is necessary or appropriate to share information either within ACM or with external organisations/bodies, for example to:

• Allow a case to be appropriately considered and investigated;
• Ensure those who disclose an experience or are alleged to have committed misconduct receive appropriate academic and pastoral support;
• Safeguard members of the ACM community and fulfil ACM’s duty of care;
• Discharge ACM’s duties or as required by law.

3. IMMEDIATE THREATS TO SAFETY

3.1 If after reviewing a disclosure submitted via the ACM’s online reporting tool, the ACM safeguarding team believes that there is a danger to the person who has disclosed or to anyone else, they will refer the disclosure to the ACM executive team along with a risk assessment.

3.2 If the ACM executive team decides via a risk assessment that it is necessary to take precautionary action, it will make a recommendation to the Registrar who will enact these measures. Such measures may include issuing a suspension of rights to restrict the person alleged to have committed the misconduct contact with the person who has disclosed, including restriction of access to campus facilities, and making a recommendation to the ACM safeguarding team regarding appropriate action.

3.3 If a suspension of rights is issued, the person alleged to have committed the misconduct will be informed in writing and, wherever possible, in person. They will be told what they need to do in order to comply with the suspension of rights. They will be assigned a member of the student services team, who will be their main point of contact.

3.4 If no suspension of rights is required, the person alleged to have committed the misconduct will not be informed of the disclosure or assigned a member of the student services team unless the person who has disclosed chooses to either pursue an informal resolution or submit a formal complaint to ACM.

4. STUDENT SUPPORT

4.1 ACM will assign a member of the student support team to the person who has made the disclosure. The member of the student support team will be the main point of contact throughout any subsequent steps, and will be able to help the person who has disclosed to make informed decisions about what happens next.

4.2 The member of the student support team does not represent the person they are assigned to within any subsequent Discipline Committee hearings. They are available to listen, to provide information and to facilitate practical support.

4.3 The member of the student support team will take into account the communications preferences of the person they are assigned to, and wherever possible will communicate key information in person, unless the person they are assigned to wishes otherwise.

4.4 The member of the student support team will contact the person who has made the disclosure as soon as is practical to do so to arrange a First Discussion Meeting between them and the member of the student support team. This will enable the person who has disclosed to talk about what they would like to happen. The member of the student support team will help them to consider the options and support available, to understand the role of the student support team, and to explore possible outcomes.

4.5 The outcome of an investigation, Discipline Committee hearing or Appeal will be shared with both parties and this will include setting out the rationale for the decision.

5. MALICIOUS REPORTS

5.1 Whilst extremely rare, the possibility of malicious reporting is recognised. ACM takes every disclosure seriously but reserves the right to cease consideration of a disclosure if it considers it to be malicious, vexatious or frivolous. In such cases, a member of the Safeguarding Team or its nominee will write to the reporting party explaining why consideration of the disclosure is being halted. This decision will be final.

6. CONDUCT

6.1 ACM recognises the possibility of retaliation against any individuals associated with a disclosure or formal complaint of sexual misconduct, including the Reporting Party, witnesses, the Responding Party, and staff.

6.2 Any retaliation will be dealt with under ACM disciplinary procedure as per policy.

6.3 If there is a further incident of sexual misconduct, anti-social behaviour or any other behaviour which breaches ACM’s regulations that occurs whilst an investigation is being conducted under the Sexual Misconduct Policy, this may be considered as an aggravating factor and taken into account during decision-making.

7. OPTIONS FOLLOWING DISCLOSURE

7.1 After disclosure there are several options available to the person who has disclosed their experience. They can choose the level and types of support that are right for them.

7.2 After discussion with their member of student support the person who has disclosed may choose to:

7.2.1 Take no further action at this time: In this case advice will be provided regarding the preservation of evidence which may be needed if they subsequently decide to make a report to the Police or to submit a formal complaint to ACM. They will also be informed of the ongoing support available to them via the student support team, Wellbeing Support Services and the safeguarding team.

7.2.2 Undertake an informal resolution: This option is dependent on the person alleged to have committed the misconduct being willing to participate. The member of student support assigned to the person who has disclosed will facilitate an informal resolution in collaboration with services such as Wellbeing Support Services and the safeguarding Team.

7.2.3 Make a report to the Police: In this case no disciplinary action will normally be taken by ACM whilst a Police investigation and legal proceedings are taking place, although ACM reserves the right to investigate and take action if it deems it necessary. Support will however still be available from the Wellbeing Support Services and the Safeguarding team.

7.2.4 Make a formal complaint to ACM: If the person who has disclosed chooses this option they will be asked to confirm that they wish ACM to proceed with a formal investigation. Support will be available from the Wellbeing Support Services and the Safeguarding team.

8. INFORMAL RESOLUTION

8.1 The person who has disclosed can always choose to make a formal complaint even if they have chosen informal resolution, and vice versa.

8.2 Where an informal resolution is appropriate, a member of student support will be assigned to the person alleged to have committed the misconduct. This will be a different member of student support to that assigned to the person who has made the disclosure.

8.3 The member of student support will arrange for the informal resolution to take place, in collaboration with services such as Wellbeing Support Services and the safeguarding team.

8.4 Informal resolution can only go ahead on the mutual agreement of both parties. The member of student support will follow up to check that the informal resolution has taken place, however as the allegation has not been proven they cannot enforce compliance.

8.5 Informal resolution may include, but is not restricted to, the following outcomes:

8.5.1 Written apologies

8.5.2 Attendance at awareness sessions

8.5.3 Participation in behavioural change programmes

8.5.4 No contact agreements

8.5.5 Any other penalties which are not punitive in nature

9. POLICE INVESTIGATION AND LEGAL PROCEEDINGS

9.1 If the person who has disclosed has made an independent report to the police they may still make a formal complaint to ACM.

9.2 ACM does not have the legal investigatory powers of the Police, and is not able to make a determination of criminal guilt.

9.3 Any disciplinary action is undertaken as a breach of ACM’s Sexual Misconduct Policy and is not a substitute for a Police investigation or a criminal prosecution.

9.4 The fact that criminal proceedings have been instituted or have concluded does not preclude ACM from taking its own disciplinary action, if it is thought fitting or necessary to do so.

9.5 The fact that the Police are unable or unwilling to proceed does not preclude ACM from taking its own disciplinary action.

9.6 A case which does not progress through legal channels, where a decision to take no further action has been made, and/or a ‘not guilty’ verdict has been returned, does not mean that the person has made a malicious or vexatious report.

9.7 The fact that criminal proceedings have returned a ‘not guilty’ verdict does not preclude ACM from taking its own disciplinary action.

9.8 If a student has been convicted of a criminal offence or accepts a Police caution in relation to behaviour that falls within the scope of ACM’s Sexual Misconduct Policy, then ACM will accept this as conclusive evidence that the behaviour took place. It may not be necessary for a further full investigation to take place and the complaint will be deemed proven and proceed directly to mitigation.

10. MAKING A FORMAL COMPLAINT TO ACM

10.1 The person who has experienced sexual misconduct may choose to make a formal complaint to ACM under the Sexual Misconduct Policy, and thereby seek a resolution via the ACM Disciplinary Procedure. A formal complaint is different to disclosure; it is a document informing ACM that something has happened and that the person who has made the complaint wishes ACM to take action. From this stage onwards, the person who has submitted the complaint is referred to as the Reporting Party, and the person who is alleged to have committed the misconduct is referred to as the Responding Party.

10.2 The complaint must be submitted via the online disclosure link. The complaints form may be completed by the Reporting Party, or if they prefer, someone can complete it on their behalf. The safeguarding team and Wellbeing Support Services can all provide help in completing the form.

10.3 The complaints form does not need to include in-depth detail about the experience. There does however need to be enough information so that ACM can take the complaint forward and understand what has happened.

10.4 The complaints form will be referred to the Student Discipline team. ACM will not take any action without the involvement of the Reporting Party unless there is an immediate threat to safety.

10.5 The Reporting Party has the right to withdraw their complaint and to stop the formal Sexual Misconduct Disciplinary Process at any time.

Freedom of Speech 

10.6 ACM has a statutory duty to protect the lawful speech of all staff, students and visiting speakers, which includes protecting the right to express views that are controversial or unpopular. However, vigorous debate does not mean students should be expected to tolerate harassment. Speech or other expression that amounts to harassment is not protected. ACM promotes a culture that is open and tolerant of differences, and students can expect to be able to take part in all aspects of university life without being harassed. 

11. PROCEDURE SCOPE

11.1 The procedure applies to all members of the ACM community, including students at all levels and campuses, staff, applicants, associate members, visitors, contractors and volunteers.

11.2 This procedure applies to sexual misconduct which:

• occurs on ACM’s property and/or land;
• occurs whilst a student is engaged in any ACM related activity (including placements and trips);
• occurs via electronic means including, but not limited to: internet, email, social media sites, chat rooms, text messages and instant messaging;
• results in a legal or police investigation, charge or conviction of an offence;
• raises questions about the fitness of the student on a fitness to practice programme; or
• in the view of ACM poses a serious risk or disruption to the institution or members of its community.

11.1 ACM recognises that sexual misconduct can be experienced by any individual, regardless of sex, gender, sexual orientation, relationship status, age, disability, faith, race, ethnicity, nationality or economic status.

11.2 Experiences of sexual misconduct may intersect with other forms of discrimination and harassment, for example in relation to sex, gender, sexual orientation, relationship status, age, disability, faith, ethnicity, nationality or economic status.

11.3 ACM has policies on Equality, Discrimination and Inclusion and does not tolerate any forms of bullying or harassment. ACM does not tolerate behaviour or attitudes supportive of sexual misconduct. 

12. RELATED POLICIES

• Safeguarding Policies
• Safeguarding Procedures
• Staff Code of Conduct
• Student Charter
• Data Protection Policy
• Prevent Policy
• External Speaker and Events Policy
• Acceptable Use of IT and E-Safety Policy
• Social Media Policy
• Student Disciplinary Policy
• Student Complaints and Grievances Policy
• Equality & Diversity Policy
• Staff Recruitment Policy
• Health & Safety Policy
• Whistleblowing Policy
• Criminal Convictions Policy

13. PROCEDURE OWNER

13.1 The responsibility for this Policy falls under the remit of the Designated Safeguarding Lead, overseen by the  Student Experience and Opportunity Board. 

13.2 The responsible committee will ensure the cyclical review of this Policy is carried out under ACM’s Quality Assurance Framework.

14. DEFINITIONS

 Sexual Misconduct: Sexual Misconduct covers a broad range of inappropriate and unwanted behaviours of a sexual nature. It covers all forms of sexual violence, including sex without consent, sexual abuse (including online and image-based abuse), non-consensual sexual touching, sexual harassment (unwanted behaviour of a sexual nature which violates your dignity; makes you feel intimidated, degraded or humiliated or creates a hostile or offensive environment), stalking, abusive or degrading remarks of a sexual nature, and a vast range of other behaviours.

Consent: Consent is the agreement to participate in a sexual act where the individual has both the freedom and capacity to make that decision. Consent cannot be assumed on the basis of a previous sexual experience or previously given consent, and consent may be withdrawn at any time.

Freedom to consent: For consent to be present, the individual has to freely engage in a sexual act. Consent is not present when submission by an unwilling participant results from the exploitation of power, or coercion or force, regardless of whether there is verbal or physical resistance.

• Coercion or Force includes any physical or emotional harm or threat of physical or emotional harm which would reasonably place an individual in fear of immediate or future harm, with the result that the individual feels compelled to engage in a sexual act.

Capacity to consent: Free consent cannot be given if the individual does not have the capacity to give consent. Incapacitation may occur when an individual is asleep, unconscious, semi-conscious, or in a state of intermittent consciousness, or any other state of unawareness that a sexual act may be occurring. Incapacitation may also occur on account of a mental or developmental disability, or as the result of alcohol or drug use.

• Alcohol and/or Drug Use: Incapacitation arising from alcohol or drug consumption should be evaluated on the basis of how the alcohol/drugs have affected the individual; signs of incapacitation may include, but are not limited to, one or more of the following: slurred speech, unsteady gait, bloodshot eyes, dilated pupils, unusual behaviour, blacking out, a lack of full control over physical movements, a lack of awareness of circumstances or surroundings, and/or an inability to communicate effectively. Intoxication is never a defence for committing an act of Sexual Violence and Misconduct, or for failing to obtain consent. If there is any doubt as to the level or extent of one’s own or the other individual’s incapacitation, the safest approach is to not engage in a sexual act.

Disclosure: Disclosure means that an individual tells a member of the ACM community that they have experienced Sexual Misconduct (this is different from a formal Complaint).

Formal Complaint: Submitting a formal Complaint to ACM regarding an individual’s experience of Sexual Misconduct is an instruction for ACM to take appropriate action. The Complaint will allow ACM to investigate the misconduct as set out in this Policy and the accompanying processes.

Reporting Party: The Reporting Party is the person(s) who has made a formal Complaint regarding an experience of sexual misconduct.

Responding Party: The Responding Party is the person(s) named in a formal Complaint who is alleged to have committed an act of sexual misconduct.

Safeguarding: Safeguarding is the action that is taken to promote the welfare of all people and protect them from harm.

Abuse:  any action that intentionally harms or injures another person

DSL: Designated Safeguarding Lead is the member of staff that coordinates all safeguarding concerns and oversees all referrals.

DDSL: Deputy Designated Safeguarding Lead is the member of staff who supports the DSL in maintaining the function of safeguarding throughout all campuses.

LADO: Local Authority Designated Officer

15. EXHIBITS/APPENDICES/FORMS

15.1 This procedure has been written in accordance with, and with reference to, the following statutory guidance and legislation:

• Keeping Children Safe in Education (DfE, 2021)
• Working Together to Safeguard Children (HM Government, 2018)
• What to do if you’re worried a child is being abused (DfE, 2015)
• The Prevent Duty (DfE, 2015, updated 2019)
• Child sexual exploitation; definition and guide for practitioners (DfE, 2017)
• Sexual violence and harassment between children in schools and colleges (DfE, 2018)
• The Children Act 2004 (with later amendments)
• Safeguarding Vulnerable Groups Act 2006
• The Sexual Offences Act 2003
• Office for Students (OfS) Condition E6 Harassment and Sexual Misconduct
• Guidance for English Higher Education Institutions (HEIs) (DIUS, 2007)
• Protection of Freedoms Act 2012
• Children and Families Act 2014
• Care Act 2014
• Information sharing: advice for practitioners providing safeguarding services to children, young people, parents and carers (HM Government, July 2018)

16. DOCUMENT HISTORY AND NEXT REVIEW

Version:                           1.2

Approved on:                 01 September 2026

Approved by:                 Academic Board

Date of next review:      August 2027

Download: PRO_064_Sexual Misconduct Procedure 

 

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Policy 064: SEXUAL MISCONDUCT

1. PURPOSE

1.1 This Policy outlines ACM’s approach to providing a campus environment in which all members of our community feel safe from sexual misconduct.For the purposes of this policy, this includes sexual harassment, whether explicitly stated or not. 

1.2 This Policy sets out our expectations around the unacceptability of sexual misconduct.

1.3 This Policy makes clear the ways in which ACM supports students who have experienced any form of sexual misconduct.

2. POLICY DETAILS

2.1 The Academy of Contemporary Music (ACM) is committed to safeguarding and promoting the welfare of all students, staff, visitors and guests and acknowledges its particular responsibilities to children, young people and adults at risk.

2.2 All staff within ACM have a responsibility to be involved in contributing to a culture in which safeguarding is embedded, discussed openly and risk proactively reduced. Every member of staff is DBS checked prior to commencing employment, and again every three years, and all staff members must complete training in the following areas:

• Safeguarding Young People
• Mental Health Awareness in Children & Young People
• An introduction to GDPR
• Health and Safety in Education Awareness
• The Prevent Duty
• First Aid Essentials

Members of the ACM safeguarding team also have further awareness and training regarding the following areas:

• Protecting Children from Child Sexual Exploitation
• Sexual Violence and Harrasment between Children and Young People
• Understanding and Working with people affected by Sexual Abuse

2.3 ACM takes a zero tolerance approach to sexual misconduct and sexual harassment, and will support anyone in the ACM community who is subject to any form of sexual misconduct, as per the details in the accompanying Sexual Misconduct Procedure.

2.4 ACM will ensure that reporting parties are responded to in a safe, supportive and trusting environment, as per the details in the accompanying Sexual Misconduct Procedure.

2.5 ACM will educate and support all staff and students to understand:

• what sexual misconduct is and that it is not tolerated;
• what consent is; and
• when consent is, and is not, given.

2.6 ACM will make clear how to disclose sexual misconduct, in person, online and anonymously, what options are available and the support that can be provided, via a clear and robust procedure.

2.7 ACM will ensure that all relevant staff are informed of how to receive and signpost a disclosure of sexual misconduct in a sensitive way. Empower those who disclose an experience to choose which options are best for them and provide access to expert professional support

2.8 ACM will set out all options and processes clearly and transparently. This includes the option to not make a formal complaint.

2.9 ACM will ensure that all relevant staff are provided with training to enable them to support and advise a student who has experienced sexual misconduct.

2.10 ACM will respect the sensitivity of disclosures of sexual misconduct and their consequences, and treat any disclosure confidentially, in line with our Data Protection Policy and the ACM’s duty of care under safeguarding.

2.11 Within Disciplinary Proceedings, ACM will ensure fairness to both Reporting and Responding parties.

2.12 ACM will ensure that all communications are sufficiently clear and detailed, and accurately reflect any decisions made.

2.13 ACM will learn from our experiences and regularly review this policy informed by data trends and with input from independent external experts to ensure it remains relevant.

3. POLICY SCOPE

3.1 The policy applies to all members of the ACM community, including students at all levels and campuses, staff, applicants, associate members, visitors, contractors and volunteers.

3.2 This Policy applies to sexual misconduct which:

• occurs on ACM’s property and/or land;
• occurs whilst a student is engaged in any ACM related activity (including placements and trips);
• occurs via electronic means including, but not limited to: internet, email, social media sites, chat rooms, text messages and instant messaging;
• results in a legal or police investigation, charge or conviction of an offence;
• in the view of ACM poses a serious risk or disruption to the institution or members of its community.

3.1 ACM recognises that sexual misconduct can be experienced by any individual, regardless of sex, gender, sexual orientation, relationship status, age, disability, faith, race, ethnicity, nationality or economic status.

3.2 Experiences of sexual misconduct may intersect with other forms of discrimination and harassment, for example in relation to sex, gender, sexual orientation, relationship status, age, disability, faith, ethnicity, nationality or economic status.

3.3 ACM has policies on Equality, Discrimination and Inclusion and does not tolerate any forms of bullying or harassment. ACM does not tolerate behaviour or attitudes supportive of sexual misconduct.

Freedom of Speech 

3.4 ACM has a statutory duty to protect the lawful speech of all staff, students and visiting speakers, which includes protecting the right to express views that are controversial or unpopular. However, vigorous debate does not mean students should be expected to tolerate harassment. Speech or other expression that amounts to harassment is not protected. ACM promotes a culture that is open and tolerant of differences, and students can expect to be able to take part in all aspects of university life without being harassed. 

4. RELATED POLICIES

• Safeguarding Policies
• Safeguarding Procedures
• Staff Code of Conduct
• Staff-Student Relationship Policy
• Student Charter
• Data Protection Policy
• Prevent Policy
• External Speaker and Events Policy
• Acceptable Use of IT and E-Safety Policy
• Social Media Policy
• Student Disciplinary Policies
• Student Complaints and Grievances Policy
• Equality & Diversity Policy
• Staff Recruitment Policy
• Health & Safety Policy
• Whistleblowing Policy
• Criminal Convictions Policy

5. POLICY OWNER

5.1 The responsibility for this Policy falls under the remit of the Designated Safeguarding Lead, overseen by the  Student Experience and Opportunity Board. 

5.2 The responsible committee will ensure the cyclical review of this Policy is carried out under ACM’s Quality Assurance Framework.

6. DEFINITIONS

Sexual Misconduct: Sexual Misconduct covers a broad range of inappropriate and unwanted behaviours of a sexual nature. It covers all forms of sexual violence, including sex without consent, sexual abuse (including online and image-based abuse), non-consensual sexual touching, sexual harassment (unwanted behaviour of a sexual nature which violates your dignity; makes you feel intimidated, degraded or humiliated or creates a hostile or offensive environment), stalking, abusive or degrading remarks of a sexual nature, and a vast range of other behaviours.

Consent: Consent is the agreement to participate in a sexual act where the individual has both the freedom and capacity to make that decision. Consent cannot be assumed on the basis of a previous sexual experience or previously given consent, and consent may be withdrawn at any time.

Freedom to consent: For consent to be present, the individual has to freely engage in a sexual act. Consent is not present when submission by an unwilling participant results from the exploitation of power, or coercion or force, regardless of whether there is verbal or physical resistance.

• Coercion or Force includes any physical or emotional harm or threat of physical or emotional harm which would reasonably place an individual in fear of immediate or future harm, with the result that the individual feels compelled to engage in a sexual act.

Capacity to consent: Free consent cannot be given if the individual does not have the capacity to give consent. Incapacitation may occur when an individual is asleep, unconscious, semi-conscious, or in a state of intermittent consciousness, or any other state of unawareness that a sexual act may be occurring. Incapacitation may also occur on account of a mental or developmental disability, or as the result of alcohol or drug use.

• Alcohol and/or Drug Use: Incapacitation arising from alcohol or drug consumption should be evaluated on the basis of how the alcohol/drugs have affected the individual; signs of incapacitation may include, but are not limited to, one or more of the following: slurred speech, unsteady gait, bloodshot eyes, dilated pupils, unusual behaviour, blacking out, a lack of full control over physical movements, a lack of awareness of circumstances or surroundings, and/or an inability to communicate effectively. Intoxication is never a defence for committing an act of Sexual Violence and Misconduct, or for failing to obtain consent. If there is any doubt as to the level or extent of one’s own or the other individual’s incapacitation, the safest approach is to not engage in a sexual act.

Disclosure: Disclosure means that an individual tells a member of the ACM community that they have experienced Sexual Misconduct (this is different from a formal Complaint).

Formal Complaint: Submitting a formal Complaint to ACM regarding an individual’s experience of Sexual Misconduct is an instruction for ACM to take appropriate action. The Complaint will allow ACM to investigate the misconduct as set out in this Policy and the accompanying processes.

Reporting Party: The Reporting Party is the person(s) who has made a formal Complaint regarding an experience of sexual misconduct.

Responding Party: The Responding Party is the person(s) named in a formal Complaint who is alleged to have committed an act of sexual misconduct.

Safeguarding: Safeguarding is the action that is taken to promote the welfare of all people and protect them from harm.

Sexual Harassment: Under the Equality Act 2010, sexual harassment is unwanted conduct of a sexual nature. It has the purpose or effect of violating the dignity of a worker, or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. Something can still be considered sexual harassment even if the alleged harasser didn’t mean for it to be. It also doesn’t have to be intentionally directed at a specific person.

Abuse:  any action that intentionally harms or injures another person

DSL: Designated Safeguarding Lead is the member of staff that coordinates all safeguarding concerns and oversees all referrals.

DDSL: Deputy Designated Safeguarding Lead is the member of staff who supports the DSL in maintaining the function of safeguarding throughout all campuses.

LADO: Local Authority Designated Officer

 

7. PROCEDURES

7.1 The details of the procedures relating to this Policy can be found in the accompanying procedure document.

8. EXHIBITS/APPENDICES/FORMS

8.1 This Policy has been written with reference to the following statutory guidance and legislation. For the avoidance of doubt, it should be noted that UK law carries ultimate authority:

• Keeping Children Safe in Education (DfE, 2021)
• Working Together to Safeguard Children (HM Government, 2018)
• What to do if you’re worried a child is being abused (DfE, 2015)
• Child sexual exploitation; definition and guide for practitioners (DfE, 2017)
• Sexual violence and harassment between children in schools and colleges (DfE, 2018)
• The Children Act 2004 (with later amendments),
• Safeguarding Vulnerable Groups Act 2006
• The Sexual Offences Act 2003
• Guidance for English Higher Education Institutions (HEIs) (DIUS, 2007)
• Protection of Freedoms Act 2012
• Children and Families Act 2014
• Care Act 2014
• Equality Act 2010
• Protection from Harassment Act 1997
• Office for Students (OfS) condition E6 Harassment and Sexual Misconduct;
• Information sharing: advice for practitioners providing safeguarding services to children, young people, parents and carers (HM Government, July 2018) 

9. DOCUMENT HISTORY AND NEXT REVIEW

Version:                          1.2

Approved on:                01 Sep 2026

Approved by:                Academic Board

Date of next review:     August 2027 

Download: POL_064_Sexual Misconduct Policy

 

If you have a disability which makes reading this document or navigating our website difficult and you would like to receive information in an alternative format, please contact: anddegree@acm.ac.uk 

Procedure 003: COMPLAINTS AND GRIEVANCES

1. PURPOSE

1.1 This procedure describes how ACM ensures the equitable, transparent and timely consideration of student complaints and grievances in relation to any aspects of their student experience, student services, administration, financial matters, and information for their programme of study.

1.2 This procedure aims to explain the reasonable due course which students are required to consider and follow when submitting a complaint or grievance.

1.3 This policy and procedure relates to students studying at ACM Guildford, ACM London and ACM Birmingham, on programmes validated by Middlesex University (HE) and University of the Arts London (FE).

2. PROCEDURE STATEMENT

2.1 ACM encourages all students to discuss any concerns they may have at the earliest opportunity to avoid delays and unnecessary escalation of matters. Most issues can normally be resolved quickly at the local level, without going through the complaints and grievances procedures. Key points of contact if there is a concern are:

• Student Relations Officers (in campus reception areas) 
• Student Services (Hub), who will direct you to the department or information source
• Registry team, who will direct you to the department or regulations, policies and documentation registry@acm.ac.uk 
• If unsure who to contact, the Student Hub team studentsupport@acm.ac.uk can assist students at this stage.

2.2 ACM seeks to resolve all complaints and grievances in a timely manner through considered escalation of concerns as outlined in this procedure. Students that wish to lodge an appeal of an academic decision should refer to the Academic Appeals Policy and Procedure (POL 002).

Stage 1: Early Resolution

2.3 In the first instance students who wish to make a complaint should discuss it with the relevant team responsible to be invited to an in-depth discussion for early resolution. They will advise whether or not the complaint is best progressed through:

• An informal meeting or mediation;
• A Student Forum or Board of Studies (for concerns impacting a wider group/cohort);
• Consultation with specific persons who can resolve the problem (E.g. Tutor, Module Leader);
• Referral to an external agency, or
• Escalation to the Formal Stage 2

2.4 A student should, if possible, address their complaint to the member of staff most directly involved in the event leading to the complaint in order to give that person the opportunity to address the concerns.

2.5 If for any reason the student does not feel that this is possible, they should seek advice from the Student Hub team (studentsupport@acm.ac.uk) in order to identify an appropriate alternative mechanism of early resolution. 

2.6 Every effort will be made to resolve the complaint simply and quickly. The member of staff investigating the complaint may invite the student to a meeting to discuss the matter in an attempt to reach a resolution. The member of staff investigating shall discuss the complaint with the student and, with the student’s consent, engage anyone else involved, to see if the concern can be resolved through early resolution.

2.7 Any resolutions and actions that are agreed with the student must be kept on record and communicated to the student in writing within 21 working days.  At the end of Stage 1, a student will be provided with a written response to their complaint, which will either:

• Detail the proposed resolution; OR
• If no resolution has been proposed, explain why the resolution has not been considered to be possible.

Stage 2: Formal Stage

2.8 If the student is dissatisfied with the outcome of an early attempt to resolve the matter, for example, under Stage 1, they may opt to escalate the complaint to the second (formal) stage.  All formal complaints must be submitted in writing to complaints@acm.ac.uk within 21 working days of the informal stage having been completed. The student should complete the Complaints Form and attach all relevant supporting materials and evidence to support their complaint. Complaints that lack relevant supporting documentation may be dismissed or referred back to the student for further consideration.

2.9 The Quality Assurance team will acknowledge receipt of the complaint in writing and notify the student of the next steps within 7 working days of receiving the complaint. Student Engagement will assign the complaint to a senior member of ACM staff who will undertake a provisional investigation to see if a resolution to the concern can be reached prior to the proceeding to a formal panel.

2.10 If a Quality Assurance team member was involved in the case at Stage 1, they will nominate an appropriate alternative individual to take a lead on the case. If no appropriate individual can be found, the Student Engagement team may refer it to Registry, who will then assign the lead to an appropriate individual.

2.11 The lead investigator shall convene a panel of relevant staff to consider the case appropriately. They will consider the evidence, written or otherwise, and, if necessary, hold such discussions with the complainant and any other persons they deem appropriate in order to fully investigate the complaint.

2.12 The complaints panel will determine appropriate timescales based on the nature and complexity of the case. These timescales should be communicated to the student and the student kept informed of any changes. Where possible, complaints should normally take no longer than 21 working days to investigate from the acknowledgement being sent.

2.13 The lead investigator having fully investigated the complaint over a period not normally exceeding 21 working days from its receipt, shall decide whether:

• the complaint should be progressed through other procedures; or whether
• there is no reasonable justification for the complaint, in which case the complaint shall be terminated at this stage; or whether
• there is reasonable justification for the complaint.

2.14 The lead investigator shall:

• make their decision known in writing and sent to the student within 5 working days;
• recommend resolutions to any justifiable complaint which all parties involved in the complaint shall be invited to accept; and
• if the recommendations are agreed, shall take steps to ensure that they are implemented in full within the agreed time period.

2.15 The Quality Assurance team will:

• Inform the student and the members of staff or other students involved of the decision.
• Monitor the agreed resolutions to the complaint as necessary.
• The Quality Assurance team will seek confirmation from the student(s) that they are satisfied with the agreed outcome. 

Where a student is not satisfied with the outcome of the second stage, and where the complaint is related to the student’s academic programme, they may escalate their appeal to the formal stage 3.

2.16 Where a student is not satisfied with the outcome of the second stage, and where the complaint is not related to the student’s academic programme, students are not required to escalate the matter to ACM’s validating partner (as described in Stage 3 of this Procedure) and  may escalate their appeal to the Office of the Independent Adjudicator (OIA) for Higher Education. Where this is the case, ACM will make this clear in the Stage 2 outcome letter and will also issue a Completion of Procedures (COP) letter. Information and eligibility rules are available at: www.oiahe.org.uk

Stage 3: Validating Body/ Partner Institution Review

Middlesex University Provision

2.17 This section applies to students studying on the BA(Hons) Music Industry Practice programme or the BA(Hons) Creative Industry Futures programme or the MCCI or MA/MSc in Creative Industry Futures programme at ACM Guildford, ACM Birmingham or ACM London.

2.18 If a student considers that:

1. there has been a procedural irregularity in the investigation of a complaint regarding a matter related to their academic programme carried out by ACM;
2. new information has come to light, which the student was unable to disclose previously, and which would have had a material impact upon the investigation previously undertaken;
3. the decision reached was unreasonable based on the information that had been available to ACM when the case was considered,

they can request a review of the outcome of the investigation carried out by ACM, by completing a CPULR form (Collaborative Partner University Level Review).

2.19 The student is expected to submit the CPULR form and all supporting documentation within 21 working days of receiving written confirmation from ACM of the final outcome of ACM’s investigation. The CPULR form must be submitted to the Director of Affairs at Middlesex University.

2.20 The receipt of the CPULR form will normally be acknowledged within 7 working days, and ACM will be informed of the nature and substance of the complaint.

2.21 The CPULR form will be reviewed by the Director of Student Affairs or nominee. The University review will consider whether a) there has been a procedural irregularity in the investigation of the complaint by ACM, or b) any new evidence has come to light which would have had a material impact on the investigation. Discussion may be held with the student and/ or subject of the complaint and with members of staff involved in ACM’s investigation process.

2.22 Where possible, reviews should normally take no more than 21 working days to investigate from the acknowledgement being sent. The Director of Student Affairs or nominee will establish appropriate timescales based on the nature and complexity of the case. These timescales should be communicated to the student and the student kept informed of any changes.

2.23 The Director of Student Affairs or nominee will inform all parties of the proposed outcome of their investigation and give all parties the opportunity to comment. Following consideration of any comments, the Director of Student Affairs or nominee will communicate the outcome of the review, with reasons and in writing, to all parties within 21 working days.

Stage 4: (HE students only)

2.24 When the review has been concluded, the student will be issued with a Completion of Procedures (COP) letter. Following this, any student who is dissatisfied with the final decision on their case may be able to apply to the Office of the Independent Adjudicator (OIA) for Higher Education. Information and eligibility rules are available at: www.oiahe.org.uk.

RSL Provision (FE)

2.25 This section applies to students on Level 2 and Level 3 provision at ACM whose complaints relate to their course/ award.

2.26 RSL will normally onIy consider a complaint from a student at a partner institution in circumstances where a student feels that there was a material or procedural error in the operation of ACM’s procedures, and the University Secretary and Registrar considers it fair and reasonable in all the circumstances to permit the complaint.

2.27 Students can find further information on RSL’s complaints procedure on their website (click here).

East Surrey College (FE)

2.28 This section applies to students on Level 2 and Level 3 provision at ACM whose complaints relate to funding.

2.29 Details on East Surrey College’s Concerns and Feedback procedure can be found on their website (click here).

Groups of Complainants

2.30 
ACM recognises that students may wish to lodge complaints collectively. In such instances students are asked to nominate one spokesperson with whom ACM staff will liaise to address the complaint. The spokesperson should endeavour to gather the views of all of the students who wish to lodge the complaint. If Stage 1 does not satisfactorily address the complaint, the spokesperson should complete a written explanation of the complaint (either a report or via the Student Complaints Form), which should be agreed by the entire group before submission. Students may opt to have their elected Student Representative act as spokesperson for the group.

Student Progression

2.31 Until the complaint is concluded, the student:

• Will be allowed to continue their studies, except under circumstances where there is a disciplinary matter involved where the student has been suspended for their own or others’ safety;
• Must continue to meet attendance, engagement, and assessment requirements for the programme.

3. PROCEDURE OWNER

3.1 The procedure lead is responsible for the cyclical monitoring and review of the policy in liaison with the Quality Assurance Team. The Student Complaints and Grievances Procedure lead is:

• Quality Assurance and Enhancement Manager

3.2 Decisions and appropriate actions in support of the implementation of the Policy will be authorised by the following designated staff:

• Quality Assurance and Enhancement Manager or nominee
• Head of Student Services
• Registry Manager
• Senior Management, including Executive Senior Management

4. SUPPORTING INFORMATION

4.1 Internal Documents

• Academic Appeals
• Academic Integrity
• Admissions
• Student Disciplinary
• Equality and Diversity

4.2 External Documents

• Middlesex University Regulations: Student complaints and grievance procedures
• RSL: Student Complaint Procedures
• East Surrey College: Client Feedback Policy
• QAA Quality Code, Chapter B9: Academic Appeals and Student Complaints
• OfS Conditions B1 – B6

5. DOCUMENT HISTORY AND NEXT REVIEW

Version	3.2
Approved on	03 September 2025
Approved by	Academic Board
Date of next review	August 2027

 

Download:   Procedure 003 Complaints and Grievances Procedure

1. Introduction:

This code of conduct exists to provide guidance of legal obligations relating to external speakers and events at ACM, and to ensure that all speakers taking part in an event or activity, on an ACM campus or elsewhere in relation to ACM, act in accordance with the ACM External Speaker and Events Policy.

It is the responsibility of the event or activity organiser – the individual, named in the External Speaker submission form and the ACM Industry Link team to ensure that:

• The External Speaker Code of Conduct is communicated to all external speakers (once approved and confirmed via the External Speaker Booking Process) and the declaration form is signed, returned and stored centrally with the respective booking form.
• That all reasonable steps are taken to ensure that the requirements within it are upheld during the running of the event or activity.

2. Freedom of speech:

Freedom of speech is fundamental to ACM as a Higher Education provider. The Higher Education and Research Act 2017 requires ACM to take such steps as are reasonably practicable to ensure that freedom of speech, within the law, is secured for its employees, students and visiting speakers. All staff and students through their membership are expected to tolerate and protect the expression of opinions, within the law.

Whilst the law promotes and protects freedom of speech, it also places limits on those freedoms in order to maintain public order and safety. ACM acknowledges that it has a legal responsibility to create a balance between minimising the possibility that extremism or unlawful conduct will arise on an ACM campus and ensuring that it meets its legal obligations in relation to securing freedom of speech.

3. Conduct 

ACM expects external speakers to act in accordance with the law and not to breach the lawful rights of others. Set out below are examples of the expectations, this is by no means an exhaustive list.

During the course of the event at which he or she participates, no speaker shall:

• Incite hatred, intolerance or violence or act in any way that is a breach of the Criminal Law.
• Encourage or promote any acts of terrorism or promote individuals, groups or organisations that support terrorism.
• Discriminate against or harass any person or group on the grounds of their sex, race, nationality, ethnicity, disability, religious or other similar belief, sexual orientation or age.
• Defame any person or organisation.
• Raise or gather funds for any external organisation or cause without express permission of the Director of Creative Industry Development.

ACM reserves the right to not permit an external speaker to speak at or attend an event, to refuse to permit an event and/or to halt an event at any time if it reasonably considers there may be a breach of the External Speaker and Events Policy or of any legal obligation.

4. Segregation

ACM as a Higher Education provider, employer and service provider has duties under the Equality Act 2010 and Higher Education (Freedom of Speech) Act 2023. ACM will not unlawfully discriminate against students, employees and other individuals to whom services are provided.

Segregation by sex or gender is not permitted in any academic meetings or at events, lectures provided for students, or at events attended by members of the public or employees of ACM. Segregation is therefore not permissible for any event covered by the ACM External Speaker and Events Policy and this Code of Conduct.

5. Date of Approval and Next Review

Version:                        1.3

Approved on:               01 Sep 2025

Approved by:               Academic Board

Next Review:               August 2026

Download this code of conduct

The .pdf version linked above contains the ACM ‘External Speakers and Code of Conduct Declaration Form’, which needs to be read and signed by all external speakers to ACM.