TLM Qualification Fraud Prevention and Investigation Policy

Purpose

This policy outlines The Learning Machine Ltd.’s (TLM) approach to preventing, detecting, and investigating qualification fraud across all qualifications. It brings together our internal controls, centre responsibilities, regulatory obligations, and structured fraud response, including the use of the Fraud Investigation Model (FIM). This supports our compliance with Ofqual’s General Conditions of Recognition, especially Conditions A5, A6, and A8.

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1. Context and Regulatory Environment

TLM is committed to maintaining the integrity of its qualifications and ensuring public confidence in learner outcomes. Qualification fraud poses risks to learners, employers, and society at large. Our strategy is informed by:

• The Little Book of Big Scams, published by the Metropolitan Police

• The Take Five anti-fraud campaign

• Intelligence shared by regulators and sector partners

• Our risk-based internal and external quality assurance systems

We apply proportionate controls tailored to qualification type and risk level.

2. Key Measures to Prevent Fraud

TLM’s fraud prevention approach includes a mix of technical, procedural, and educational controls:

• Secure Exam Delivery for High-Risk Qualifications
  Delivered via our in-house online system with live video/audio proctoring and randomised question banks. Includes ID verification requirements.

• Proportionate Controls for Other Qualifications
  For lower-risk or classroom-based qualifications, centres follow centre-led security protocols. Controls are agreed and monitored by TLM.

• Learner Onboarding & ID Validation
  All centres must follow TLM’s onboarding procedure, confirming a learner’s readiness, including prior learning checks and mandatory ID validation where exams are required.

• Certification Security

  • All certificates feature a unique QR code linking to our secure verification portal.

  • A certificate number checker is available via our website with no login required.

  • Certificate access patterns are monitored for suspicious activity.

3. Centre Responsibilities

TLM-approved centres play a vital role in preventing qualification fraud. Centres must:

• Implement a robust learner onboarding process

• Deliver appropriate support for Guided Learning Hours (GLH)

• Ensure learners meet the required Knowledge, Skills and Understanding (KSU) before assessment

• Verify learner identity where required, especially for high-risk exams

• Maintain accurate records and submit honest certification claims

• Report suspected fraud or malpractice to TLM promptly

• Reference and follow our Centre Fraud Prevention Guide

TLM audits centre practices as part of our ongoing monitoring and support.

4. Fraud Investigation Model (FIM)

TLM uses the nationally recognised Fraud Investigation Model (FIM) to manage all fraud cases. This ensures structured, fair, and proportionate action.

• Know
  We collect intelligence from learner activity, system data, quality assurance, whistleblowing, and reports.

• Test
  We assess the risk and credibility of evidence and determine whether further action is needed.

• Enforce
  If fraud is confirmed, TLM may invalidate results, withdraw certificates, sanction centres or staff, or report incidents to regulators or law enforcement.

5. Reporting and Continuous Improvement

All suspected cases of qualification fraud, malpractice, or maladministration must be reported directly to TLM’s Responsible Officer. Investigations are carried out by trained and impartial staff and may involve centre cooperation.

We commit to:

• Protecting the identity of whistleblowers

• Acting on evidence fairly and proportionately

• Keeping accurate records of all investigations

• Informing regulators and affected parties when required

This policy is reviewed biannually and updated based on risk trends, investigations, or regulatory developments.

To report suspected qualification fraud or malpractice, please contact us confidentially at helpdesk @ tlm.org.uk

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