Coaching & Mentoring Services (UK) Ltd recognises that the decision to make an allegation can be a difficult one to make. However, whistle-blowers who make serious allegations in the reasonable belief that it is in the public interest to do so have nothing to fear because they are doing their duty either to the XXX and/or to those for whom Coaching & Mentoring Services (UK) Ltd or they are providing a service. Coaching & Mentoring Services (UK) Ltd will take appropriate action to protect a whistle-blower who makes a serious allegation in the reasonable belief that it is in the public interest to do so from any reprisals, harassment or victimisation.

### Confidentiality

All allegations will be treated in confidence and every effort will be made not to reveal a whistle- blower's identity unless the whistle-blower otherwise requests. However, if the matter is subsequently dealt with through other Coaching & Mentoring Services (UK) Ltd procedures such as a legal investigation, it may be necessary for the whistle-blower identity to be given to the relevant authorities. Confidential information will remain confidential as far as legally possible. Similarly, if the allegation results in court proceedings then the whistle-blower may have to give evidence in open court if the case is to be successful. Coaching & Mentoring Services (UK) Ltd will not, without the whistle- blower's consent, disclose the identity of a whistle-blower to anyone other than a person involved in the investigation/allegation.

### Anonymous Allegations

This procedure encourages whistle-blowers to put their name to an allegation wherever possible as anonymous allegations may often be difficult to substantiate/prove. Allegations made anonymously are much less powerful but anonymous allegations will be considered at the discretion of the CEO, Managing Director, Director or other person of authority and responsibility within the organisation in question. In exercising discretion to accept an anonymous allegation the factors to be considered:

- • seriousness of the issue raised • seriousness of the issue raised
- • credibility of the allegation; and • credibility of the allegation; and
- • the allegation can realistically be investigated from factors or sources other than the • the allegation can realistically be investigated from factors or sources other than the complainant

### Untrue Allegations

No disciplinary or other action will be taken against a whistle-blower who makes an allegation in the reasonable belief that it is in the public interest to do so even if the allegation is not substantiated by an investigation. However, legal or other suitable action may be taken against a whistle-blower who makes an allegation without reasonable belief that it is in the public interest to do so (e.g. making an allegation frivolously, maliciously or for personal gain where there is no element of public interest).

### Procedure for Making an Allegation

It is preferable for allegations to be made to an immediate manager of the supervisor/coach to whom they report. However, this may depend on the seriousness and sensitivity of the issues involved and who is suspected of the malpractice. For example, if the whistle-blower believes that management/owners are involved it would be inappropriate to raise it directly with them. The whistle-blower may then make an allegation direct to any of the following:

- • & Mentoring Services (UK) Ltd • & Mentoring Services (UK) Ltd

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