ASTON HOLMES SPEAK UP AND WHISTLEBLOWING POLICY
OVERVIEW:
At aston holmes, we are committed to operating with integrity, transparency, and accountability.
This policy outlines the framework for employees, contractors, candidates, clients, suppliers, service providers, and other stakeholders to report serious concerns regarding unethical, unlawful, or harmful conduct connected to aston holmes' operations.
Anyone who raises a concern in good faith under this policy will be treated fairly and protected from retaliation.
WHEN TO USE THIS POLICY
Use this policy if you become aware of activities that you believe may involve any of the following:
• Corruption and abuse of power.
• Financial irregularities, including fraud or other criminal activity.
• Legal or regulatory violations.
• Threats to health and safety.
• Discrimination, harassment, bullying, or unethical workplace conduct.
• Human rights concerns, including modern slavery or forced labour.
• Environmental misconduct.
• Any conduct that may damage the integrity, reputation, or responsible operation of aston holmes.
This policy applies where the issue is of public interest or may impact the ethical operation of our business.
GUIDELINES FOR REPORTING
When raising a concern, please include as many details as possible, even if you do not have absolute proof.
Please:
• Keep reports factual and avoid speculation.
• Provide specific examples where possible.
• Include dates, names, locations, and supporting information where available.
Concerns should be raised in good faith. Individuals will not be penalised for reporting concerns that are ultimately not substantiated, provided the report was made honestly and reasonably.
HOW TO RAISE A CONCERN
Reports may be submitted through any of the following channels:
1. The Whistleblowing function on AboardHR (for employees and contractors).
2. The whistleblowing form available on the aston holmes website.
3. Email: legal@astonholmes.com
4. Any alternative reporting channel designated by aston holmes from time to time.
ANONYMITY AND CONFIDENTIALITY
Anonymous reporting is permitted where legally allowed and operationally practical.
Your identity will be protected wherever possible. Information provided will be kept confidential and shared only with those who need access in order to review, investigate, and resolve the matter appropriately.
NEXT STEPS FOR WHISTLEBLOWERS
After submitting a report, you will receive confirmation that it has been received within 3 working days.
We will:
• Review the matter and provide an estimated timeline for next steps.
• Keep you informed at key stages of the review and investigation process.
• Confirm when the matter has been resolved and communicate the outcome where appropriate.
• Explain if the concern falls outside the scope of this policy and direct you to a more appropriate process.
INVESTIGATION PROCESS
All whistleblowing reports will be investigated fairly, impartially, and thoroughly.
Investigations will be documented appropriately, and outcomes will be based on the facts and evidence available. Appropriate corrective action will be taken where necessary.
GRIEVANCE HANDLING WITHIN WHISTLEBLOWING
We recognise that concerns raised under this policy may also lead to grievances regarding the handling of whistleblowing matters.
Grounds for Accepting a Grievance:
Whistleblowing-related grievances may be accepted when they involve:
• Failure to act on reported wrongdoing.
• Retaliation or mistreatment following a disclosure.
• Concerns regarding the handling of an investigation.
• Improper treatment in relation to a candidate, client, contractor, or supplier engagement.
• Concerns relating to safety, fairness, legality, or ethical conduct.
Grounds for Rejecting a Grievance:
A grievance may be rejected if:
• It falls outside the scope of whistleblowing.
• It lacks sufficient detail to allow proper assessment.
• It is raised maliciously or in bad faith.
• It has already been reviewed and no new information is provided.
Process and Timelines
1. Submission of concern.
2. Acknowledgement within 3 working days.
3. Initial review within 5 working days.
4. Formal investigation, where applicable, within 10 working days.
5. Written outcome within 15 working days, or an update where additional time is required.
Facilitation of Resolution
• Stakeholders will be updated throughout the process.
• Outcomes will be communicated clearly and respectfully.
• Any agreed actions or resolutions will be documented and implemented where appropriate.
PROTECTION FOR WHISTLEBLOWERS
Anyone who reports a concern in good faith, participates in an investigation, or assists with the resolution of a concern is protected under this policy.
aston holmes will not tolerate retaliation, victimisation, harassment, discrimination, intimidation, or any other adverse treatment as a result of a disclosure made in good faith.
Consequences for Retaliation
Where retaliation is identified, appropriate action will be taken against those responsible. This may include disciplinary action, termination of employment or engagement, or other corrective measures.
Where appropriate, aston holmes may also involve relevant authorities.
Additional Protection Measures
• Anonymous reporting options.
• Confidential handling by authorised personnel only.
• Alternative reporting routes where required.
• Ongoing monitoring where there is a risk of retaliation or negative impact.
ACCESSIBILITY AND SUPPORT
We are committed to ensuring that all stakeholders can raise concerns safely and effectively.
Where required, aston holmes will provide reasonable accommodations or alternative reporting methods to support accessibility and participation in the process.
If you are unsure whether a matter should be reported under this policy, please contact legal@astonholmes.com for confidential guidance.
WHEN NOT TO USE THIS POLICY
Whistleblowing is intended for serious concerns relating to unethical, unlawful, unsafe, or harmful conduct.
Please use alternative channels for:
• Personal employment grievances, performance concerns, or workplace disputes that do not involve wrongdoing.
• Candidate application updates or recruitment feedback.
• Client or supplier contract, billing, or service queries.
• General feedback, suggestions, or business enquiries.
Using the appropriate channel helps ensure matters are handled promptly and by the most suitable team.
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