Policy 14
Whistleblowing & Speak-Up
“Speaking up early protects people, clients and the company.”
Anyone working with us should be able to raise a genuine concern about wrongdoing without fearing for their career or working relationship.
At a glance
The short version.
No retaliation
Victimisation, dismissal, blocked opportunities or threats for speaking up are prohibited.
You don’t need proof
Explain what you believe is happening. You don’t have to prove the case first.
NDAs can’t silence you
Contracts never prevent protected whistleblowing or lawful reports to regulators, police or safeguarding authorities.
In practice
What we commit to.
- Raise concerns with a Managing Director, or the other director if it involves one
- Report externally to a prescribed body where internal reporting isn’t appropriate
- Protect the identity of whistleblowers as far as possible
- Consider anonymous reports
- Investigate independently of the alleged wrongdoing
- An honest concern never becomes misconduct just because it isn’t upheld
Step by step
What happens when you speak up
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1
Acknowledge
We confirm we’ve received your concern.
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2
Assess risk
We act on any immediate risk and preserve evidence.
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3
Decide who investigates
Independently, with outside advice if needed.
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4
Investigate
Proportionately and fairly.
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5
Act
Corrective, disciplinary, contractual or reporting action where warranted.
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6
Feed back
You hear what we can share, within confidentiality and legal limits.
The detail
Everything else.
The key parts of the policy, in plain English. The downloadable PDF is the full, controlled version.
Who it’s for
Primarily employees and workers, including those with statutory protection. Contractors, freelancers and placement students are also encouraged to raise serious concerns.
What can be raised
Crime such as fraud or bribery, breaches of legal obligations, danger to health and safety, environmental damage, sexual harassment, concealment of wrongdoing, misuse of funding, and serious safeguarding or data failures.
The public-interest test
Statutory protection normally needs a reasonable belief that the disclosure is in the public interest. Purely personal grievances usually go through the grievance process.
Records and review
Concerns and outcomes are recorded securely. Managers learn how to receive a concern without dismissing it or turning it into an interrogation. Reviewed every year.
Laws and guidance this policy follows
- Employment Rights Act 1996, Part IVA (protected disclosures), as amended
- GOV.UK: Whistleblowing for employees
- GOV.UK: Whistleblowing guidance for employers (April 2026)
- Employment Rights Act 2025: protection for disclosures about sexual harassment
The full document
Whistleblowing & Speak-Up Policy
Version 1.0 · Effective October 2026 · Owner: Managing Directors
Questions about this policy?
If you need to raise a concern, contact one of our Managing Directors directly.