Whistleblowing Policy

Concerns may include criminal conduct, fraud, bribery, unsafe work, environmental harm, modern slavery, regulatory breaches, misuse of personal data, concealment of wrongdoing or retaliation against someone who speaks up.

Personal employment grievances are handled under the relevant business's employment procedures unless they also involve a wider public-interest concern.

A concern should be reported using the contact route published by the relevant Participating Business. Reports should explain what happened, when, who was involved and any supporting evidence. A person does not need proof before raising a genuine concern.

Concerns raised honestly are treated seriously and as confidentially as the circumstances and law permit. Information is shared only where necessary to assess, investigate or meet a legal duty. Retaliation, victimisation or deliberate disadvantage for raising a genuine concern is prohibited.

The responsible business acknowledges and assesses the concern, appoints an impartial investigator where appropriate, protects evidence, takes urgent protective action and records the outcome. Confidentiality, privacy and fairness are maintained throughout.

Nothing in this policy prevents a person from making a protected disclosure or contacting an appropriate regulator, prescribed person, law-enforcement body or professional adviser.

Concerns may include criminal conduct, breach of legal obligation, miscarriage of justice, danger to health and safety, environmental damage, bribery, fraud, modern slavery, safeguarding, serious privacy or security failure, or deliberate concealment. Personal employment complaints are normally handled as grievances unless they also engage a wider public-interest issue.

A report should identify the concern, relevant dates, people, evidence and immediate risk where known; proof is not required before reporting. Reports may be made confidentially and anonymous information will be assessed. Confidentiality cannot be guaranteed where disclosure is legally required or essential to a fair process, but information is limited and the reporter is informed where lawful.

The receiving business logs and triages the concern, protects people and evidence, appoints an investigator without a material conflict, defines scope, keeps appropriate contact and records findings and actions. The subject is treated fairly and allegations are not presented as proven. Deliberately false allegations may be addressed, but an unsubstantiated good-faith concern is not misconduct.

Retaliation, threatened retaliation and attempts to identify or silence a reporter improperly are prohibited and investigated separately. Workers may seek independent advice and use a prescribed external route; internal reporting is encouraged but is not a compulsory first step for a protected disclosure.

Approved by David Swaddle, Founder, on 30 August 2026.