Whistleblowing Policy

1. About this policy
2. 1. We are committed to conducting our business with honesty and integrity and we expect all employees, stakeholders and external parties to maintain high standards. Any suspected wrongdoing should be reported as soon as possible.
   2. Individuals who work with or for us whether internally or through external collaboration are often best positioned to identify early indications of potential misconduct. This means that there may be instances where individuals who are not employees need to report a concern.
   3. This policy covers all external contractors, suppliers, partners, and other third parties such as customers, who engage with our organisation.
   4. We may amend this policy at any time.
3. What is whistleblowing?
4. 1. Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our activities. This includes bribery, facilitation of tax evasion, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment and any breach of legal or professional obligations.
5. What are we doing about it?
6. 1. We are committed to fostering a culture of integrity by ensuring our people are informed about how to report concerns. Clear internal policies are in place to guide the reporting of potential misconduct, with a strong emphasis on protecting and supporting those who come forward.
   2. Those not directly working for us and without access to our internal systems can still voice their concerns and report misconduct by reaching out via our dedicated email address.
7. How to raise a concern
8. 1. We hope that in many cases you will be able to raise any concerns with your main point of contact within our organisation. However, where you prefer not to raise it with your point of contact for any reason, you should send your concerns to: [email protected].
   2. We will follow up with you as soon as possible to discuss your concern. If you would prefer to be contacted by phone, please include your telephone number within your email. Your email should include as much detail as possible about the concern, including any specific dates or names of those involved where possible.
9. Confidentiality
10. 1. We understand that coming forward with a concern can be difficult. We are committed to treating all disclosures seriously and, wherever possible, in confidence. Your identity will only be shared with those involved in handling or investigating the concern and only when absolutely necessary. We will take all reasonable steps to ensure your privacy is protected throughout the process.
11. External disclosures
12. 1. This policy aims to provide a mechanism for reporting, investigating, and remedying any wrongdoing in our organisation or operations. In most cases, you should not need to alert anyone externally.
    2. The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. We encourage you to seek advice before reporting a concern to anyone external.
13. Protection and support for whistleblowers
14. 1. We will not tolerate retaliation against anyone who raises a concern in good faith. External parties who raise genuine concerns will be supported and protected from adverse treatment. If you believe you have faced retaliation or negative consequences as a result of speaking up, please contact us immediately. We will take appropriate steps to investigate and address any such issues. If the matter is not remedied, you should raise it formally using our formal complaints process.
    2. No one must threaten or retaliate against whistleblowers in any way. If they are involved in such conduct, they may be subject to appropriate action as per our agreements or applicable law. In some cases, the whistleblower could have a right to sue the individual concerned personally for compensation in a court of law.
    3. However, if we conclude that a whistleblower has made false allegations maliciously, the whistleblower may be subject to appropriate action as per our agreements or applicable law.

External Grievance/Complaints Mechanism Policy

1. Purpose
2. 1. This policy outlines our commitment to providing an accessible and transparent grievance and complaints mechanism for stakeholders, including but not limited to contractors, partners, vendors, customers, and the general public. Our aim is to ensure that concerns are addressed in a fair, timely, and respectful manner in line with our values and legal obligations.
3. Scope
4. 1. This policy applies to all stakeholders who wish to raise grievances or complaints regarding business practices, operations, or any aspect of their relationship with us, excluding internal employee grievances which are addressed by the internal grievance policy.
5. Reporting a Grievance or Complaint
6. 1. We offer several means for stakeholders to raise grievances or complaints:
   2. • Dedicated Email Address: Stakeholders can submit grievances or complaints via our dedicated email address: [email protected].
      • Business-to-Business Contracts: The majority of contracts with us include provisions for dispute resolution in case of grievances. You should review these and follow the dispute resolution procedure set out within the agreement.
      • Open-Door Policy: We encourage stakeholders to approach us directly with concerns. We are committed to maintaining open lines of communication.
      • Customer Services: Our customer service department is available to address any concerns or complaints.
      • Consumer Complaints Mechanisms: We have established consumer complaints processes for addressing issues related to products and services. These can be found by visiting the Complaints Policy page.
      • Supplier & Third Party Mechanisms: Suppliers and other external parties can raise issues through the grievance mechanisms outlined in this policy.
      • Direct Stakeholder Engagement: Stakeholders may also engage with us directly through meetings, calls, or written communication.
7. Information on the External Grievance Process
8. 1. When submitting a grievance or complaint, the person submitting the concern will be provided with clear information regarding the grievance process.
   2. The grievance must pertain to a breach of agreements, unethical practices, business disputes, or other significant issues related to the person’s engagement with us.
   3. Once a grievance is submitted, the following steps will be followed:
   4. • We will acknowledge receipt of the grievance.
      • We will investigate the grievance in a fair and impartial manner.
      • We will communicate the progress of the investigation and a resolution or decision within a reasonable timeframe.
   5. Each grievance will be processed with the aim of reaching a resolution within 30 days from the date of submission, unless a more complex investigation is required.
9. Resolution and Communication
10. 1. We commit to responding to all grievances or complaints in a clear and transparent manner
    2. Stakeholders will be notified of the outcome of their grievance, including steps taken to resolve the issue.
    3. If a grievance is not accepted, stakeholders will be provided with a clear explanation of why the issue was not considered valid for further action.
11. Controls and Monitoring
12. 1. We implement measures to ensure the effectiveness of our grievance mechanism. These include:
    2. Conducting periodic audits to assess the effectiveness of the grievance process, including feedback from stakeholders.
    3. Engaging with stakeholders, including workers and suppliers, to ensure continuous improvement of our grievance mechanisms.
    4. Maintaining transparency in all grievance processes, ensuring stakeholders are kept informed at each stage of their grievance resolution.
13. Confidentiality and Protection
14. 1. All grievances will be handled with the utmost confidentiality. We are committed to protecting the identity and privacy of stakeholders who raise concerns. We will also take all necessary steps to ensure that no retaliation occurs as a result of filing a grievance.
15. Contact Information
    For further information or to submit a grievance, please contact us at:
16. • Email [email protected].
    • Phone: 020 7871 9990
17. Policy Review
    This policy will be reviewed annually and updated as necessary to ensure that it remains compliant with applicable laws and reflects best practices.