Grievance and Whistleblowing Protection Policy

1. Purpose

Blick Rothenberg  is committed to operating with the highest standards of ethics, transparency, and accountability. This policy outlines how stakeholders may raise grievances or report misconduct and the procedures we follow to address these concerns. It also outlines our strict protections for whistleblowers and our zero-tolerance approach to retaliation. 

Scope 

This policy applies to all internal and external stakeholders, including but not limited to: 

• Employees (full-time, part-time, contractors) 
• Clients and customers 

• Suppliers and vendors 

• Business partners 

• Community members or the general public 

2. Grievance/Complaint Mechanism

2.1 What Can Be Reported

We encourage the reporting of concerns related to: 

• Ethical misconduct (e.g., fraud, corruption, bribery) 

• Environmental violations or unsustainable practices 

• Human rights violations or abuse 

• Unsafe or illegal workplace behaviour 

• Breaches of our policies, codes of conduct, or third-party obligations such as, but not limited to, the requirements of the regulators that oversee the firm or employees of the firm 

Excluded Issues:
Issues not related to the company’s conduct, or internal HR matters not relevant to third parties, may not be investigated through this process. 

Matters relating to client service standards are covered by the complaints section of our client Terms of Business BR-TERMS-OF-BUSINESS-APRIL-2026_V15.pdf and include the option to lodge a complaint with our regulator where appropriate. 

2.2 How to Submit a Grievance

Internal users may submit a grievance by multiple means (including that documented here with others available for all to access via out intranet including a link to an independent third party) You may raise a grievance by sending an email to our compliance team at complaints@blickrothenebrg.com (Subject: “Confidential – Grievance/Whistleblower”). 

The reporting message should contain details such as a description of the violation, date, time, location, and any supporting evidence.  You may choose to remain anonymous and can submit a notification by post to The Complaints Team  at the current Blick Rothenberg trading address available on our website (Contact Us – Blick Rothenberg) should you wish to do so. 

3. Grievance Handling 

3.1 Grievance Handling Process

Stage 1. Acknowledgement
Timeline: Within 3 business days
A confirmation will be sent to the complainant (unless submitted anonymously). 

Stage 2. Initial Review
Timeline: Within 10 business days
Assess admissibility and assign a Case Manager. 

Stage 3. Investigation
Timeline: Within 30 business days
A thorough and impartial investigation. Updates provided every 10 business days. 

Stage 4. Resolution
Timeline: Varies by complexity
A written outcome will be shared. If grievance is not accepted, a clear explanation will be provided.

3.2 Responsibilities 

• Case Manager: Assigned to each grievance; manages communication and coordination. 

• Investigative Team: May include internal or external experts, depending on the issue. 

• Senior Leadership: Reviews high-risk or sensitive cases. 

Note that every effort will be made to ensure that those with responsibilities in relation to a complaint are independent of any individuals or teams noted in that complaint. 

3.3 Actions Against Third Parties 

If the investigation finds that a third party (e.g., vendor, supplier, client) has acted unethically or illegally, we may: 

• Terminate the contract or engagement 

• Report the matter to regulatory authorities 

• Prohibit future collaboration

4. Disciplinary Procedure for Staff

Our aim is to support all employees in meeting the standards expected of them, fostering an environment where issues are resolved quickly and informally whenever possible. This section outlines our approach to handling situations where further action may be needed.

4.1 Principles 

• Fairness: Everyone deserves to be treated fairly and respectfully. 

• Clarity: We will clearly explain any concerns and the improvements needed. 

• Support: We aim to assist employees in meeting expectations through guidance and support. 

4.2 Steps in the Disciplinary Process 

4.2.1. Informal Discussion 

It is encouraged that any issues regarding performance are initially dealt with on an informal basis. We will initially arrange to have a one to one discussion with individuals to see if the concerns can be resolved informally. Following discussion of any concerns raised, understanding any contributory factors and considering what help may be available to improve we would set out the areas where the individual is falling below the required standard and explain the improvements that are required and a timeframe over which improvement would be expected. If additional support or training is needed this would be arranged as appropriate.  

4.2.2. Formal Performance Process  

If earlier informal discussions have not resolved concerns, or if the initial concerns are particularly serious, we will write to ask the individual to attend a formal Performance Management meeting with their People Manager. The letter will set out the concerns about performance, along with any accompanying documents that may be referred to, such as an informal performance improvement plan and or feedback, and how it does not meet the required standards. Following the meeting, further investigation may be needed, or new evidence may come to light that needs to be considered. Following the meeting and any subsequent follow up, a decision will be explained along with an individual right to appeal.  

4.2.3. Follow-Up 

Follow-ups will be scheduled to review progress and provide ongoing support. If issues remain, we might need to meet again, and further actions, such as additional warnings or other measures, may be considered. There are circumstances where matters raised would require disclosure to a regulatory body providing oversight to either the firm itself or the individual in question and where this is the case the firm would ensure that such disclosures were made. 

4.2.3 Appeal 

If  the individual disagrees with a disciplinary decision, they have the right to appeal as per our detailed performance management procedures.  This would be reconfirmed in writing in an outcome letter. 

4.3 Documentation 

To keep everything transparent, all formal procedures and decisions will be documented and shared with the individual. This ensures both parties have a clear understanding of what was discussed and agreed upon. 

5. Whistleblower Protection Policy

5.1 Protection from Retaliation 

Blick Rothenberg strictly prohibits retaliation against anyone who reports a concern in good faith, regardless of the outcome of the investigation.

Retaliation includes, but is not limited to: 

• Termination or demotion 

• Harassment or intimidation 

• Contract cancellation 

• Denial of future work or business 

5.2 Consequences for Retaliation 

• Employees: Subject to disciplinary action, up to and including termination. 

• Suppliers/Vendors/Clients: Subject to contract termination and permanent disqualification. 

• Business partners: Subject to suspension or termination of business relationships. 

5.3 Anonymity & Confidentiality 

• Complainants may report anonymously through the grievance form or by omitting personal details in email or post. 

• All reports are handled with strict confidentiality. Identities are only disclosed with consent or when legally required. 

• Access to grievance details is limited to personnel involved in the investigation. 

6. Communication and Updates

• Complainants (unless anonymous) will receive regular updates on the progress of the grievance. 

• A summary of the findings and actions taken will be shared once the matter is resolved. 

• In cases where the grievance is not investigated, a written explanation will be provided. 

7. Policy Accessibility

This policy is publicly available at [weblink to be included]. 

8. Review

This policy will be reviewed annually or in response to significant legal, regulatory, or organisational changes. 

Policy owner: BR COO 

Last reviewed: August 2026 

Due for review: August 2027