External Stakeholder Grievance Policy

The Forward Institute is committed to the highest standards of transparency, integrity and accountability. This policy provides a framework for external stakeholders - including clients, customers, suppliers, partners, community members, and the general public - to raise concerns about our conduct or activities.

This policy covers both general grievances and whistleblowing disclosures, with additional protections applied where concerns relate to suspected wrongdoing in the public interest.

1. Scope for External Stakeholders

External stakeholders may raise grievances related to:

• Breaches of law, ethical standards, or professional obligations by the Forward Institute

• Health and safety risks created by our activities

• Environmental damage or risks

• Fraud, corruption, or financial misconduct

• Discrimination, harassment, or other unethical treatment

• Breach of contractual obligations or supplier standards

• Any other conduct that conflicts with our responsible leadership values

2. Information Provided to External Stakeholders

When an external stakeholder submits a grievance, the Forward Institute will provide clear information about our grievance process, including:

2.1 Grounds for Accepting a Grievance

A grievance will be accepted if it:

• Relates to suspected wrongdoing, illegal conduct, or unethical behaviour by the Forward Institute or its representatives

• Falls within the scope outlined in Section 1

• Is raised in good faith with a reasonable belief that the concern is genuine

• Provides sufficient detail to allow for investigation

2.2 Grievance Process Steps and Targeted Deadlines

The grievance process follows these steps:

Step 1: Initial Contact

External stakeholders should submit grievances to:

• [email protected] our Head of People and Operations (Senior Responsible Officer for External Grievances). OR

• [email protected] who sits on our Board of Directors

Step 2: Acknowledgement (within 10 working days - 5 working days to gather information and an additional 5 days to respond) We will confirm receipt and provide:

• How we propose to handle the matter

• Estimated timeline for a final response

• Whether initial enquiries have been made

• Information about the grievance process and support available

• Whether further investigation will take place and, if not, why not

Step 3: Assessment (within 15 working days of acknowledgement)

We will determine whether the grievance meets the grounds for acceptance and the appropriate investigation method

Step 4: Investigation (timeline depending on complexity, typically 30-60 working days)

A thorough investigation will be conducted by appropriate senior staff or external investigators if required.

If the grievance discloses evidence of a criminal offence, it will be immediately reported to the Board and to the appropriate authorities, including the Police where required by law. The Forward Institute will comply with all legal obligations to report criminal activity. If the grievance concerns suspected harm to children or vulnerable adults, the appropriate safeguarding authorities will be informed immediately in accordance with statutory safeguarding requirements.

Step 5: Resolution and Response (within 10 working days of investigation completion)

We will communicate the outcome and any remedial actions

2.3 How a Resolution Will Be Facilitated

Depending on the nature of the grievance, resolution may include:

• Corrective action to address the wrongdoing identified

• Changes to policies, procedures, or practices

• Disciplinary action against individuals involved

• Remediation or compensation where appropriate

• Referral to external authorities (regulators, law enforcement) if required

• Mediation or dialogue with the stakeholder to reach a mutually acceptable outcome

3. Communication Throughout the Process

The Forward Institute commits to either:

• Regularly communicating with the stakeholder at each step of the process, providing updates on progress, findings, and outcomes, and confirming when a resolution has been achieved Or:

• Providing a clear rationale as to why the issue raised was not accepted as a grievance, including reference to the grounds outlined in Section 2.1

Where confidentiality requirements limit the detail we can share, we will explain this to the stakeholder while providing as much information as possible about the process and outcome.

4. Protection for External Whistleblowers

While statutory whistleblowing protections under UK law apply primarily to workers, the Forward Institute voluntarily extends equivalent protections to external stakeholders under this policy. External stakeholders who raise legitimate grievances are protected from retaliation.

4.1 Commitment to Protection from Retaliation

The Forward Institute commits that:

• No external stakeholder will suffer detrimental treatment for raising a genuine concern in good faith

• This includes protection from: termination of contracts or partnerships, reduction in business opportunities, harassment, intimidation, discrimination, or any other adverse action

• All team members and representatives of the Forward Institute are prohibited from retaliating against external whistleblowers

4.2 Consequences of Retaliation

If retaliation against an external whistleblower is identified:

• The individual(s) responsible will be subject to disciplinary action under our Disciplinary Policy and Procedure, up to and including termination of employment or contract

• The Forward Institute will take immediate steps to remedy any harm caused to the whistleblower

• If the retaliation involved a breach of contract or law, appropriate legal action may be taken

• The Board will be notified and will oversee remedial actions

4.3 Mechanisms to Ensure Whistleblower Protection

The Forward Institute implements the following protective measures:

• Confidentiality: The identity of external whistleblowers will be kept confidential to the greatest extent possible. Only those directly involved in investigating the grievance will be informed of the whistleblower's identity, and only where necessary.

• Risk Assessment: Before taking action on a grievance, we will assess potential risks to the whistleblower (e.g., commercial, reputational, or safety risks) and implement appropriate safeguards

• Secure Reporting Channels: Grievances can be submitted through secure, confidential channels (encrypted email, confidential postal address, secure web form)

• Anonymous Reporting Option: External stakeholders may submit grievances anonymously. We encourage stakeholders to identify themselves where possible as anonymous grievances may be more difficult to investigate and resolve. Anonymous grievances will be accepted at our discretion, considering: the seriousness of the issue raised, the credibility of the allegation, and whether the allegation can realistically be investigated without the complainant's identity

• Monitoring and Oversight: The CEO and Board will monitor all external grievances to ensure appropriate handling and protection of whistleblowers. Themes and learning from grievances will be reviewed where necessary by the Board to inform organisational learning and continuous improvement.

• Third-Party Support: External whistleblowers are encouraged to seek independent advice from organisations such as Protect (Helpline: 0203 117 2520)

• Non-Retaliation Clauses: Contracts with suppliers and partners will, where appropriate, include explicit non-retaliation commitments

5. Record Keeping and Oversight

The CEO and the Board have overall responsibility for the operation of this policy.

All personal data will be processed in accordance with UK GDPR and our Data Protection Policy, using legitimate interests as the lawful basis, and retained only for as long as necessary.

All external grievances will be recorded in a confidential Register maintained by the Company Secretary, documenting:

• The stakeholder category (client, supplier, community member, etc.)

• The date on which the grievance was received

• The nature of the grievance

• Details of the person who received the grievance

• Whether the grievance is to be investigated and, if yes, by whom

• Communication touchpoints and dates

• Any protective measures implemented

• The outcome of the investigation

• Any other relevant details

The Register will be confidential and only available for inspection by the Board

Need Independent Support?

'Protect' (formerly 'Public Concern at Work') operates a confidential helpline. If you need further support, please go to Protect (Independent whistleblowing charity):

Helpline: 0203 117 2520 or Website: https://protect-advice.org.uk