This whistleblowing policy explains how to raise concerns about wrongdoing at Ingenious Partners safely and in confidence. Further guidance is available on GOV.UK, and you can also read our ethical employment policy.
Policy Owner: Tracy Clarke, Director
Approved By: Director
Effective Date: 30 September 2026
Review Date: 30 September 2027
Version: 1.0
1. Purpose of This Whistleblowing Policy
Ingenious Partners Ltd is committed to conducting its business honestly, ethically, lawfully and responsibly.
The purpose of this Whistleblowing Policy is to provide a clear and confidential framework for employees and other eligible individuals to raise genuine concerns about suspected wrongdoing, malpractice or risks to the public interest.
The Company encourages individuals to speak up where they have reasonable grounds to believe that something is wrong. No individual should suffer detriment, victimisation or retaliation for raising a genuine concern in accordance with this policy.
This policy is intended to support a culture in which concerns can be raised early and dealt with appropriately.
2. Scope
This policy applies to employees of Ingenious Partners Ltd and, where relevant, other individuals who have a work-related relationship with the Company, including:
- agency workers;
- contractors and consultants;
- temporary workers;
- apprentices and trainees;
- suppliers and individuals working for suppliers; and
- other individuals who are legally entitled to whistleblowing protection.
The Company will consider concerns raised by individuals outside these categories where appropriate, although the statutory protections available to them may differ.
3. What is Whistleblowing?
Whistleblowing occurs when an individual raises a genuine concern about suspected wrongdoing or a risk of wrongdoing in the workplace or in connection with the Company’s activities.
A whistleblowing concern generally involves information which the individual reasonably believes tends to show that one or more of the following has occurred, is occurring, or is likely to occur:
- a criminal offence;
- a failure to comply with a legal obligation;
- a miscarriage of justice;
- danger to the health or safety of any individual;
- damage to the environment; or
- the deliberate concealment of information relating to any of the above.
These matters are commonly referred to as “protected disclosures” under UK whistleblowing legislation.
The precise legal protection available to an individual will depend on the circumstances and applicable legislation.
4. Whistleblowing and Personal Grievances
Whistleblowing is different from raising a personal grievance.
A personal grievance normally concerns an individual’s own employment, such as:
- pay;
- working hours;
- annual leave;
- performance management;
- interpersonal disputes; or
- dissatisfaction with management decisions.
Such matters should normally be raised under the Company’s grievance procedure.
However, a concern may constitute whistleblowing where it has a wider public-interest dimension or otherwise falls within the legal definition of a protected disclosure.
If there is uncertainty about which procedure should be used, the Company will advise the individual and, where appropriate, consider the concern under both procedures.
5. Who Can Raise a Concern?
An individual does not need to be certain that wrongdoing has occurred before raising a concern.
The individual should have reasonable grounds for believing that the information they are reporting indicates wrongdoing or another matter covered by this policy.
Concerns should be raised honestly and in good faith. Individuals are not expected to investigate the matter themselves or establish conclusively that wrongdoing has occurred.
The Company recognises that concerns may subsequently prove to be unfounded. An individual will not normally be penalised simply because a concern cannot be substantiated, provided it was raised genuinely and responsibly.
6. Matters That Should Be Reported
Examples of matters that may be appropriate to report under this policy include:
- fraud, theft or financial misconduct;
- bribery or corruption;
- deliberate breaches of legal or regulatory requirements;
- serious conflicts of interest;
- falsification or deliberate manipulation of records;
- serious breaches of health and safety requirements;
- serious environmental concerns;
- deliberate concealment of wrongdoing;
- serious abuse of authority;
- unlawful discrimination or other unlawful conduct where the concern has a wider public-interest dimension;
- serious breaches of professional or regulatory obligations; and
- conduct that could cause significant harm to customers, employees, suppliers, the public or the Company’s reputation where it involves relevant wrongdoing.
This list is illustrative and is not exhaustive.
7. How to Raise a Concern
Concerns should be raised with:
Whistleblowing Contact: Tracy Clarke, Director
Email: hello@ingeniouspartners.co.uk
A concern may be raised verbally or in writing.
Written concerns should, where possible, include:
- the nature of the concern;
- the individuals or organisations involved;
- when and where the relevant events occurred;
- any supporting information or documents;
- whether the matter has previously been reported; and
- any immediate risks or concerns about evidence being destroyed.
Individuals should not put themselves at risk or conduct their own investigation in order to obtain evidence.
8. Concerns Involving the Whistleblowing Contact
If a concern relates to Tracy Clarke, the individual should not be expected to report the matter to Tracy.
In these circumstances, the individual may seek independent legal advice and/or raise the concern with an appropriate external regulatory, professional or law enforcement body, where applicable.
Nothing in this policy prevents an individual from making a disclosure to an appropriate external body where they are legally entitled to do so.
9. External Reporting
The Company encourages individuals to raise concerns internally where this is appropriate and safe to do so.
There may, however, be circumstances in which an individual wishes or needs to raise a concern with an external body.
Depending on the nature of the concern, relevant external bodies may include an appropriate regulator, professional body, law enforcement agency or other prescribed person under UK whistleblowing legislation.
Individuals should consider obtaining independent legal advice before making an external disclosure where they are unsure about the appropriate reporting route or the legal protections that may apply.
Nothing in this policy is intended to prevent an individual from making a disclosure where they are legally entitled to do so.
10. Confidentiality
The Company will treat whistleblowing concerns sensitively and, wherever reasonably practicable, confidentially.
Information about the identity of the person raising a concern will only be shared where there is a legitimate need to do so, subject to applicable legal requirements.
Individuals should understand that confidentiality cannot always be guaranteed. For example, disclosure of identity may be necessary to investigate the matter properly, comply with legal obligations, or provide a fair process to individuals who are the subject of allegations.
Where practicable and appropriate, the Company will discuss this with the whistleblower before their identity is disclosed.
Individuals receiving information about a whistleblowing concern must maintain appropriate confidentiality and must not discuss the matter with colleagues or others unless authorised to do so.
11. Anonymous Concerns
The Company will consider anonymous concerns where sufficient information is provided to enable appropriate enquiries to be made.
However, anonymity may make it more difficult to:
- investigate the concern fully;
- obtain clarification or further evidence;
- provide feedback; and
- protect the individual from potential detriment.
Where possible, individuals are therefore encouraged to identify themselves when raising a concern.
12. Protection from Detriment and Retaliation
Ingenious Partners Ltd will not tolerate retaliation against an individual for raising a genuine whistleblowing concern.
Retaliation may include:
- dismissal or threatened dismissal;
- disciplinary action where there is no legitimate basis;
- bullying or harassment;
- intimidation;
- threats;
- discrimination;
- exclusion or victimisation;
- unjustified changes to working arrangements;
- adverse treatment in relation to employment; or
- any other detriment because the individual has raised a protected concern.
Any employee found to have victimised, harassed or retaliated against an individual because they raised a genuine whistleblowing concern may be subject to disciplinary action, up to and including dismissal where appropriate.
The Company will also take reasonable steps to protect whistleblowers from retaliation by other individuals.
13. Malicious or Deliberately False Reports
The Company recognises that concerns may be raised which ultimately cannot be substantiated.
An individual will not be subject to disciplinary action merely because a concern proves to be incorrect, provided it was raised honestly and on reasonable grounds.
However, knowingly making a malicious, deliberately false or deliberately misleading allegation may constitute misconduct and may result in disciplinary action.
14. How Concerns Will Be Handled
Once a concern has been received, the Company will assess it and determine the appropriate course of action.
This may include:
- acknowledging receipt of the concern;
- carrying out an initial assessment;
- determining whether the matter falls within this policy;
- identifying any immediate risks requiring action;
- deciding whether an investigation is required;
- appointing an appropriate and sufficiently independent investigator;
- gathering relevant information and evidence;
- interviewing relevant individuals where appropriate;
- taking corrective or preventative action where necessary; and
- reporting the outcome to appropriate management or the Board.
The Company may use an external investigator or adviser where independence, specialist expertise or confidentiality requires it.
Investigations will be conducted as fairly and objectively as reasonably practicable.
15. Investigation Principles
The person investigating a concern should, wherever practicable:
- act impartially;
- avoid conflicts of interest;
- preserve relevant evidence;
- maintain confidentiality;
- give relevant individuals a fair opportunity to provide information;
- keep appropriate records;
- comply with applicable data protection requirements; and
- reach conclusions based on the available evidence.
The Company will not assume that an allegation is true merely because it has been raised.
Equally, the Company will not dismiss a concern without appropriate consideration.
16. Feedback to the Whistleblower
Where the whistleblower has provided their identity and it is appropriate to do so, the Company will normally:
- acknowledge receipt of the concern;
- provide an indication of how the concern will be handled;
- provide reasonable updates on progress; and
- provide appropriate information about the outcome.
The Company may be unable to provide full details of an investigation or any resulting disciplinary or other action because of confidentiality, privacy or legal considerations.
The Company will nevertheless seek to provide as much appropriate feedback as reasonably possible.
17. Timescales
The Company will seek to deal with concerns promptly.
The time required will depend on the nature and complexity of the concern, the availability of relevant evidence and individuals, and whether external parties or regulators need to be involved.
The Company will provide reasonable updates where an investigation is ongoing and the circumstances permit.
18. Protection of Evidence
Individuals must not destroy, alter, conceal or interfere with information relevant to a whistleblowing concern.
Employees should preserve relevant documents, emails, messages and other information in accordance with Company procedures and any instructions issued during an investigation.
19. Data Protection
The Company will process personal data arising from whistleblowing concerns in accordance with applicable UK data protection legislation and the Company’s privacy and data protection policies.
Information will only be accessed and shared where there is an appropriate legal or legitimate basis for doing so.
Records relating to whistleblowing concerns will be retained securely and only for as long as reasonably necessary, taking account of legal, regulatory and business requirements.
20. Conflicts of Interest
Anyone responsible for receiving, assessing or investigating a whistleblowing concern must disclose any actual or potential conflict of interest.
Where a conflict exists, the Company will appoint an alternative person to handle the matter where reasonably practicable.
Particular care will be taken where a concern involves the person who would ordinarily be responsible for handling the complaint.
21. Director Responsibilities
The Director is responsible for supporting an open culture in which concerns can be raised without fear of retaliation.
The Company will:
- ensure appropriate reporting channels are available;
- ensure relevant personnel understand this policy;
- investigate concerns appropriately;
- take reasonable steps to protect whistleblowers;
- address substantiated wrongdoing appropriately; and
- periodically review the effectiveness of its whistleblowing arrangements.
22. Employee Responsibilities
All employees and workers are expected to:
- raise genuine concerns promptly where appropriate;
- provide information honestly and accurately;
- cooperate with reasonable investigations;
- maintain confidentiality where required;
- avoid interfering with evidence; and
- treat individuals involved in an investigation fairly and respectfully.
23. Training and Awareness
The Company will ensure that relevant employees, managers and designated whistleblowing contacts understand:
- the purpose of this policy;
- how concerns should be raised;
- how whistleblowers should be protected;
- confidentiality requirements;
- how investigations should be conducted; and
- the Company’s obligations under applicable legislation.
Managers should not discourage an individual from raising a legitimate concern.
24. Monitoring and Review
The Company will periodically review this policy and its whistleblowing arrangements to ensure that they remain effective and appropriate.
Where appropriate, the Company may review anonymised information about:
- the number and nature of concerns raised;
- the time taken to address concerns;
- the outcomes of investigations; and
- any improvements required to Company processes or controls.
Individual whistleblowers will not be identified in management reporting unless there is a legitimate reason to do so.
25. Related Policies
This policy should be read alongside the Company’s other relevant policies and procedures, including:
- Grievance Policy;
- Disciplinary Policy;
- Anti-Bribery and Corruption Policy;
- Fraud Policy;
- Equality, Diversity and Inclusion Policy;
- Health and Safety Policy;
- Data Protection and Privacy Policy; and
- Code of Conduct.
26. Policy Statement
Ingenious Partners Ltd is committed to ensuring that individuals can raise genuine concerns about wrongdoing safely and responsibly.
The Company will take concerns seriously, assess them appropriately and take reasonable action where concerns are substantiated.