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Whistleblowing Policy

  1. Introduction

Employees may, in properly carrying out their duties, have access to, or come into contact with, information of a confidential nature. Their terms and conditions provide that except in the proper performance of their duties, employees are forbidden from disclosing, or making use of in any form whatsoever, such confidential information.

However, the law allows employees to make a ‘protected disclosure’ of certain information. In order to be ‘protected’, a disclosure must relate to a specific subject matter (clause 2) and the disclosure must also be made in an appropriate way (clause 3). Whistleblowing protection is confined to a disclosure which, in the reasonable belief of the employee making the disclosure, is made in the public interest.

We are committed to compliance with the Bribery Act 2010. We actively encourage a culture of honesty and openness and therefore all employees are required to bring up to their manager or other designated person any issue that, in the employee’s opinion, might constitute bribery or corruption.

  1. What are the Specific Subject Matters?

If, in the course of employment, you become aware of information which you reasonably believe tends to show one or more of the following:

2.1 That a criminal offence has been committed, is being committed or is likely to be committed.

2.2 That a person has failed, is failing or is likely to fail to comply with any legal obligation to which they are subject.

2.3 Discrimination of an employee or service recipient on the grounds of sex, age, race, disability, religion, belief or sexual orientation.

  1. 2.4 Sexual harassment involves reporting specific, unwanted conduct of a sexual nature that violates an employee’s dignity or creates a hostile, degrading, or offensive environment. This includes: Unwelcome Physical Contact: Touching, standing too close, hugging, massaging, kissing, or sexual assault/groping.
  2. Sexualised Verbal Behaviour: Sexually offensive jokes, innuendo, comments about someone’s body, clothing, or appearance, and unwelcome sexual advances.
  3. Intrusive Sexual Inquiries: Asking personal questions about a colleague’s sex life or discussing one’s own.
  4. Visual/Digital Content: Displaying, sending, or sharing pornographic, suggestive, or sexually graphic pictures, posters, emails, or social media content.
  5. Environmental/Behavioural Issues: Sexualised gestures, leering, staring, or whistling.
  6. Systemic/Cultural Issues: A workplace culture that permits or fails to prevent sexual harassment, including the cover-up of incidents by senior management.
  7. Quid Pro Quo: Demanding sexual favours in return for career advancements or threatening adverse action if advances are rejected.
  8.  
  9. 2.5 That a miscarriage of justice that has occurred, is occurring, or is likely to occur.
  10. 2.6 That the health or safety of any individual has been, is being, or is likely to be, endangered.
  11. 2.7 That the environment, has been, is being, or is likely to be, damaged.
  12. 2.8 That information tending to show any of the above, is being, or is likely to be, deliberately concealed.
  13. 2.9 That the business or any associated person has been, is being, or is likely to be receiving or offering bribes.
  14. 2.10 Other unethical conduct you must use the disclosure procedure as set out below.

3. What is the Disclosure Procedure?

3.1 Information which you reasonably believe tends to show one or more of the above should promptly be disclosed to Kealy Smith, Operations Manager, kealy@ontrakrecruitment.co.uk so that any appropriate action can be taken.

3.2 If it is inappropriate to make such a disclosure to the manager, you should speak to Maria Riley. Independent HR Consultant, maria@acornsandoaks.uk

3.3 You will suffer no detriment of any sort for making such a disclosure in accordance with this procedure.

3.4 However, failure to follow this procedure may result in the disclosure of information losing its ‘protected status.’

3.5 For further guidance in relation to this matter or concerning the use of the disclosure procedure generally, you should speak in confidence to Maria Riley, Independent HR Consultant, maria@acornsandoaks.uk

Name of Organisation: Ontrak UK Ltd

Address: Unit 19, Greenwich Centre Business Park, 53 Norman Road, Greenwich, London SE10 9Q

Signed: Ashley Spence

Position: Company Director

Date: 13.02.2026