Whistleblowing Policy

CAP.CO – Creating Adventurous Places Ltd is committed to the highest standards of integrity, transparency, and accountability. This Whistleblowing Policy encourages and protects employees and stakeholders who wish to raise concerns about malpractice, wrongdoing, or behaviour that contravenes our ethical standards.

1. Purpose

This policy provides a clear framework for reporting concerns, ensuring that individuals can disclose information without fear of retaliation and that such disclosures are addressed appropriately and promptly.

2. Scope

This policy applies to all employees, contractors, suppliers, and any other individuals associated with CAP.CO.

3. What is Whistleblowing?

Whistleblowing involves reporting information that the individual reasonably believes is in the public interest and indicates serious malpractice or wrongdoing, including but not limited to:

Criminal offences

Failure to comply with legal obligations

Risks to the health or safety of individuals

Environmental damage

Deliberate concealment of any of the above

Whistleblowing is distinct from personal grievances or complaints, which should be addressed through our grievance procedures as set out in the Staff Handbook.

4. How to Report a Concern

Concerns can be raised verbally or in writing with your immediate manager. If this is not appropriate, please contact:

– Whistleblowing Officer: Bob Ottaway

– Email: bob@wearecapco.com

– Phone: 07771 883 080

We encourage individuals to identify themselves when raising a concern to facilitate investigation, but anonymous reports will also be considered.

5. Confidentiality

All disclosures will be treated in confidence. Every effort will be made to protect the identity of the whistleblower, unless disclosure is required by law, in which case we will inform the individual before revealing their identity.

6. Investigation Process

Upon receiving a disclosure, CAP.CO will acknowledge receipt within one week, conduct a preliminary assessment, carry out a thorough and impartial investigation where appropriate, and keep the whistleblower informed of progress and outcomes subject to legal constraints.

7. Protection Against Retaliation

Retaliation against anyone raising a concern in good faith is strictly prohibited and will result in disciplinary action, up to and including termination of employment.

8. False Allegations

Disclosures must be made in good faith. Deliberately making false or malicious allegations is a serious offence and may result in disciplinary action.

9. External Reporting

We encourage concerns to be raised internally in the first instance. Where internal reporting is inappropriate or ineffective, you may contact:

– Protect (formerly Public Concern at Work): protect-advice.org.uk | 020 3117 2520

– Acas: acas.org.uk | 0300 123 1100

External disclosures should be made in accordance with the Public Interest Disclosure Act 1998 to ensure legal protection.

10. Review

This policy will be reviewed annually to ensure its effectiveness and alignment with legal requirements and best practice.

Johnny Lyle

Director

CAP.CO – Creating Adventurous Places Ltd

Last updated: 26 May 2026