Whistleblowing Policy

1. Document Control

2. Purpose

This policy sets out EnableAll Limited’s approach to whistleblowing and provides a framework for employees and others to raise concerns about wrongdoing in a safe and responsible way.

The purpose of this policy is to:

• Encourage the reporting of genuine concerns
• Ensure concerns are handled seriously, consistently, and appropriately
• Protect individuals who raise concerns in good faith from detriment or victimisation
• Support compliance with applicable UK whistleblowing legislation

3. Scope

This policy applies to:

• Employees (including permanent, fixed-term, and part-time employees)
• Directors and officers
• Contractors, consultants, agency workers, and interns

This policy applies to concerns about wrongdoing connected to EnableAll Limited’s activities.

This policy is non-contractual and does not form part of any individual’s contract of employment.

4. Policy Statement

EnableAll Limited is committed to conducting its business with honesty, integrity, and accountability.

The Company encourages individuals to speak up if they have genuine concerns about wrongdoing, malpractice, or unethical behaviour. All concerns raised in good faith will be taken seriously and investigated appropriately.

No individual will suffer detriment, retaliation, or victimisation for raising a concern in accordance with this policy.

5. Roles and Responsibilities

6. Legislative Framework

This policy is informed by and complies with the following UK legislation:

• Public Interest Disclosure Act 1998
• Employment Rights Act 1996
• Equality Act 2010

7. Definitions

Whistleblowing
The disclosure of information which an individual reasonably believes shows wrongdoing and is made in the public interest.

Protected Disclosure
A qualifying disclosure made in accordance with the Public Interest Disclosure Act 1998.

8. What Concerns Can Be Raised

Concerns may relate to actual or suspected:

• Criminal offences
• Fraud, bribery, or corruption
• Failure to comply with legal obligations
• Health and safety risks
• Environmental damage
• Miscarriages of justice
• Deliberate concealment of any of the above

This policy is not intended to replace normal grievance procedures.

9. What This Policy Does Not Cover

This policy does not apply to:

• Personal employment grievances
• Complaints about terms and conditions of employment

Such matters should be raised in accordance with the Grievance Policy.

10. Raising a Concern

Concerns should normally be raised with:

• A line manager; or
• The Policy Owner; or
• The CEO, where the concern is serious or involves senior management

Concerns should be raised as soon as possible and may be made verbally or in writing.

11. Confidentiality and Anonymity

EnableAll Limited will take reasonable steps to protect the identity of individuals who raise concerns.

Anonymous disclosures will be considered, although they may be more difficult to investigate.

12. Investigation and Outcome

All concerns will be assessed and, where appropriate, investigated promptly and fairly.

Individuals who raise concerns will be informed of the outcome where possible, subject to legal and confidentiality constraints.

13. Protection from Detriment

EnableAll Limited will not tolerate harassment, victimisation, or retaliation against individuals who raise concerns in good faith.

Any such behaviour may result in disciplinary action.

14. External Disclosures

In certain circumstances, individuals may be entitled to raise concerns with external prescribed bodies.

Independent advice can be obtained from organisations such as Protect (formerly Public Concern at Work).

15. Malicious or Vexatious Allegations

If an individual knowingly raises false or malicious allegations, this may result in disciplinary action.

16. Related Policies

• Anti-Fraud, Bribery, and Corruption Policy
• Ethical Sourcing Policy
• Employee Code of Conduct
• Grievance Policy

17. Review and Maintenance

This policy will be reviewed annually or sooner if required due to legislative or organisational change.

18. Revision History