Whistleblowing Policy

Introduction

TBT Recruitment is committed to openness, accountability and integrity.

This policy gives employees and others a safe way to raise concerns about wrongdoing without fear of reprisal. It works alongside the Company’s Bribery Policy (TBTR 37) – any suspicions of bribery, corruption or facilitation payments should be raised under this procedure.

The policy complies with the Public Interest Disclosure Act 1998 and protects staff who report genuine concerns in good faith.

Scope

This policy covers concerns that are in the public interest, including but not limited to:

• Financial malpractice, bribery, corruption, or fraud.
• Breaches of laws or regulations (including the Bribery Act 2010 and Corporate Criminal Offences legislation)
• Health & Safety or environmental risks
• Criminal activity
• Unethical or improper behaviour, including breaches of Company policies (such as the Bribery policy)
• Attempts to conceal any of the above
• Sexual harassment (unwanted conduct of a sexual nature, as defined in the Equality Act 2010)

Safeguards

• Protection: Staff raising concerns in good faith will not suffer dismissal, penalty, or disadvantage. Malicious or knowingly false allegations may result in disciplinary action.
• Confidentiality: Disclosures will be handled sensitively. Identities will be kept confidential where possible, although they may need to be revealed during investigation.
• Anonymous reports: Will be considered but are harder to investigate and may carry less weight.
• Unfounded concerns: If made in good faith, no action will be taken against the individual even if the concern is not upheld.

How to raise a concern

• Normally raise concerns with your Line Manager
• If this is not suitable (e.g. concern about a manager), you may contact a Director or the HR Department.
• You may also contact Debbie Starr – Head of Operations and Resources (Independent Point of Contact).

If criminal activity is suspected, the investigating officer may involve the police.

Investigation

1. Details of the concern will be recorded
2. The subject of the concern will be informed and may be accompanied at any meeting
3. The matter will be investigated promptly and fairly. External auditors or regulators may be consulted if appropriate.
4. Findings will be reported to the Directors, who will decide on any action (disciplinary or otherwise).
5. The whistleblower will be updated in writing on progress and outcome.

Escalation

If you believe your concern is not being dealt with properly, you may escalate it to the Directors or independent contact.

If still unsatisfied, you have the right to contact a prescribed external body such as:

• Health & Safety Executive
• Adult Commission
• Utility Regulators

Note: disclosure to the media or social media is not considered appropriate and may result in disciplinary action.

Review

This policy will be reviewed annually or sooner if there are significant changes in legislation, regulation, or Company procedures. Any updates will be approved by the Operations Director and communicated to all staff.

Reviewed April 2026 by Operations Director – Scott Jeffrey