Whistleblowing Policy

Policy Owner: Directors, Nexus Spark Group
Effective Date: 1st October 2026
Review Frequency: Annually, or following a significant change in legislation or business operations
Next Review: 1st October 2027

1. Purpose

Nexus Spark Group is committed to conducting its business honestly, ethically and with integrity.

The purpose of this Whistleblowing Policy is to provide a clear and confidential process through which employees, workers and other individuals working with Nexus Spark Group can raise genuine concerns about suspected wrongdoing without fear of retaliation or detrimental treatment.

Nexus Spark Group takes concerns about malpractice, unlawful conduct and unethical behaviour seriously and will investigate appropriate concerns fairly and objectively.

2. Scope

This policy applies to individuals working for or with Nexus Spark Group, including:

  • Employees.
  • Directors.
  • Workers and temporary workers.
  • Contractors and consultants.
  • Agency workers where applicable.
  • Interns and work experience personnel.

Candidates, clients, suppliers and other third parties are also encouraged to raise serious concerns relating to Nexus Spark Group’s conduct where appropriate, although statutory whistleblowing protections may differ depending on their legal status.

3. What is Whistleblowing?

Whistleblowing is the disclosure of information relating to suspected wrongdoing or dangers connected with the organisation or its activities.

A concern may qualify as a protected disclosure under UK law where an individual reasonably believes that the disclosure is in the public interest and relates to certain types of wrongdoing.

Examples may include:

  • Criminal offences.
  • Fraud, bribery or corruption.
  • Failure to comply with a legal or regulatory obligation.
  • Miscarriages of justice.
  • Health and safety risks.
  • Damage to the environment.
  • Serious breaches of company policies or professional standards.
  • Deliberate misuse or inappropriate disclosure of confidential or personal data.
  • Unethical conduct that could cause serious harm to candidates, clients, workers or other parties.
  • Deliberate concealment of any of the above.

In the context of recruitment, concerns could include deliberate misrepresentation of candidates or vacancies, unlawful discrimination, misuse of candidate or client information, improper financial practices, bribery or other serious breaches of recruitment-related legal obligations.

4. Whistleblowing and Personal Grievances

Whistleblowing generally concerns wrongdoing that affects others or the wider public interest.

Personal employment concerns relating solely to an individual’s own circumstances, such as disagreements about pay, working relationships or individual employment decisions, will normally be dealt with through the appropriate grievance or employment procedure rather than this policy.

However, a personal concern may also constitute whistleblowing where it raises a wider public-interest issue.

5. How to Raise a Concern

Concerns should normally be raised with a Director of Nexus Spark Group as soon as reasonably practicable.

A concern can be raised verbally or in writing. Individuals are encouraged to provide as much relevant information as reasonably possible, including:

  • The nature of the concern.
  • When and where the relevant events occurred.
  • The individuals or organisations involved.
  • Any supporting evidence available.
  • Whether the concern has previously been raised and, if so, with whom.

A whistleblower does not need to prove the allegation before raising it. A genuine and reasonable concern is sufficient.

If the concern relates to a Director, it should, where possible, be raised with the other Director.

6. Confidentiality

Nexus Spark Group will treat whistleblowing concerns sensitively and, where reasonably possible, confidentially.

If an individual asks for their identity to be kept confidential, Nexus Spark Group will make reasonable efforts to respect that request. There may, however, be circumstances where disclosure of an individual’s identity is necessary to properly investigate a matter or comply with a legal obligation.

Where this occurs, the situation will be discussed with the individual where legally and practically possible.

7. Anonymous Disclosures

Concerns may be raised anonymously.

However, anonymous reports can sometimes be more difficult to investigate because further information or clarification cannot easily be obtained.

Nexus Spark Group will consider anonymous allegations based on factors including the seriousness of the concern, the credibility of the information provided and the ability to investigate the matter.

8. Investigation Process

Once a concern has been raised, Nexus Spark Group will assess the information provided and determine the appropriate next steps.

Depending on the nature and seriousness of the concern, this may involve:

  • An internal investigation.
  • Requesting further information from the whistleblower.
  • Reviewing relevant documents, records or communications.
  • Obtaining independent professional or legal advice.
  • Referring the matter to an appropriate regulatory, law enforcement or other external authority.

Investigations will be conducted as fairly, objectively and promptly as reasonably practicable.

Where appropriate and legally permissible, the person who raised the concern will be informed that the matter has been reviewed and, where possible, given an indication of the outcome. Nexus Spark Group may be unable to provide full details where doing so would breach confidentiality, data protection obligations or the rights of another individual.

9. Protection Against Retaliation

Nexus Spark Group will not tolerate retaliation, victimisation, harassment or detrimental treatment against an individual because they have raised a genuine whistleblowing concern.

This applies whether or not an investigation ultimately confirms the concern.

Any individual who believes they have suffered detrimental treatment as a result of raising a concern should report the matter to a Director immediately.

Anyone found to have deliberately retaliated against a whistleblower may be subject to appropriate action.

10. False or Malicious Allegations

Individuals will not be penalised for raising a concern genuinely and reasonably, even where an investigation determines that the concern was mistaken or cannot be substantiated.

However, deliberately making an allegation known to be false, malicious or misleading may result in disciplinary or other appropriate action.

11. External Disclosures

Nexus Spark Group encourages concerns to be raised internally in the first instance where appropriate, as this can allow the matter to be investigated and addressed promptly.

However, UK whistleblowing law provides protection in certain circumstances for disclosures made to prescribed persons or bodies, subject to applicable statutory requirements.

Depending on the subject of the concern, relevant external bodies may include regulators, law enforcement agencies or other prescribed organisations.

Individuals may also seek independent advice before making a disclosure, including from Protect, the UK’s whistleblowing charity, or an independent legal adviser.

Nothing in this policy is intended to prevent or discourage an individual from making a protected disclosure in accordance with applicable law.

12. Data Protection and Records

Information collected as part of a whistleblowing report or investigation will be handled in accordance with applicable UK data protection legislation and Nexus Spark Group’s data protection and privacy requirements.

Records will only be retained for as long as reasonably necessary, taking into account the nature of the concern, investigation requirements and applicable legal obligations.

Access to whistleblowing records will be restricted to those who reasonably require access.

13. Responsibilities

The Directors of Nexus Spark Group are responsible for:

  • Promoting an environment in which legitimate concerns can be raised.
  • Ensuring whistleblowing concerns are treated seriously.
  • Protecting whistleblowers from retaliation.
  • Ensuring appropriate investigations are undertaken.
  • Maintaining appropriate confidentiality.
  • Reviewing this policy periodically.

Everyone working for Nexus Spark Group is expected to act with integrity and raise serious concerns where they reasonably believe wrongdoing has occurred or is likely to occur.

14. Policy Review

This policy will be reviewed at least annually and may be updated sooner where there are changes to legislation, regulatory requirements, Nexus Spark Group’s operations or recognised good practice.

15. Approval

This policy has been approved by the Directors of Nexus Spark Group and applies from the effective date stated above.