Complaints Procedure

Introduction

FourCentric takes concerns about wrongdoing and complaints from suppliers, customers and interested third parties very seriously.

In addition to the rights and protections afforded to employees and workers under our Ethics and Whistleblowing Policy, FourCentric has developed this procedure to offer the same robust process for the investigation of issues highlighted by those external to the business as well as to ensure protection from detriment by FourCentric for those raising legitimate concerns.

A copy of this procedure will be provided to any external stakeholder who raises a concern or complaint within 7 days of the report being received.

FourCentric encourages anyone connected to the company to report suspected wrongdoing safely and early. We commit to impartial investigations, confidentiality, and zero retaliation.

What you can report

Report any suspected wrongdoing that is unlawful, unethical, or breaches FourCentric Ethics & Whistleblowing Policy (in relation to the conduct of our employees and those working on our behalf) or our Supplier Code of Conduct.

Who is protected

National law protects workers from dismissal/detriment for protected disclosures.

FourCentric protection applies regardless of jurisdiction and even if a concern is ultimately not substantiated, provided the report was made honestly and with reasonable belief applying the principles of trust, impartiality and protection.

We apply the same protections to suppliers, customers and interested third parties who raise concerns to us – we will not terminate contracts or withdraw services (for example) where complaints are made in good faith, as outlined above. We may however seek to end working or supplier relationships where we find a complaint has been made maliciously, or where the third party reporting it has been involved in the wrongdoing.

Reporting channels

External stakeholders can raise concerns confidentially through the following channels, 24/7:

1. Email: info@fourcentric.com – this email is publicised and available on www.fourcentric.com
2. In person: informally to any Partner or Director within the appropriate Group company. If not satisfactorily resolved, then reported formally to the relevant Group company MD, Legal or HR Director or Group CEO.

Individuals receiving formal reports made must ensure confidentiality, audit trails, and data protection.

Our commitments and protections

• No retaliation: Any form of retaliation (written warnings, suspending or ending contracts, blacklisting, financial penalties, negative reviews or discussion in public forums, or other contractual measures is strictly prohibited. Where appropriate, proactive case specific protection plans will be put in place for 12 months after closure. If retaliation by a FourCentric group employee is identified immediate corrective action will be taken in accordance with FourCentric’s Ethics & Whistleblowing Policy and Whistleblowing Procedure.
• Confidentiality: We keep your identity confidential and will not share it beyond those who need to know to address the concern; we seek your consent before sharing whenever possible.
• Fair process: Investigations are impartial, timely, and respect all parties. We separate case intake, investigation, and decision-making functions to avoid conflicts of interest.
• Support: Access to confidential advice; right to be accompanied in interviews; reasonable adjustments where needed.
• Data protection: We process personal data in line with GDPR and local laws; we retain only what is necessary for clearly defined periods.

How we handle a report (process & service levels)

Receive & Acknowledge (Day 0–7):

• Log the case, check for immediate risk, preserve evidence, acknowledge and provide a copy of this procedure within 7 calendar days (unless the reporter opts out).

Assess (Days 1–21):

• Triage (risk/materiality, legal scope, potential conflicts), decide investigation approach (internal vs. external), and assign an independent investigator.
• If a complaint will not be investigated using this procedure as it is outside policy scope as detailed on page 7of the FourCentric Ethics & Whistleblowing Policy, this will clearly be communicated with a justification.

Address (up to 90 days):

• Investigate proportionately (document review, interviews).
• Maintain confidentiality and chain of custody; if required implement interim safeguards to prevent retaliation.
• Provide status updates at least every 30 days and substantive feedback within 3 months (or explain if extended for complexity).

Conclude & Remedy:

• Issue findings, corrective actions, and learning actions (policy/process changes, training, discipline where warranted).
• Offer feedback to the reporter (respecting privacy laws).
• Close only when actions are implemented and retaliation monitoring is set.

Escalation: Material allegations (e.g., senior management, financial reporting, systemic safety/human rights risks) are escalated to the Chief Executive Officer immediately.

If, after escalating your concerns, you believe that the appropriate remedial action has not been taken, you should then report the matter to the proper authority. These authorities include:

• HM Revenue & Customs
• the Financial Conduct Authority
• the Health and Safety Executive
• the Environment Agency or Scottish Environmental Protection Agency
• the Information Commissioner

This list is not intended to be exhaustive, and you must take care to ensure you contact the proper authority in relation to the particular concerns you have.

Supplier & partner coverage

By publicising how to raise concerns on our website, suppliers and partners have access to safe reporting routes. Where FourCentric’s value chain is implicated suppliers will be expected to support in joint investigations.

Training & awareness

All workers:
Annual e-learning on what/when/how to respond to reports; confidentiality and anti-retaliation.

Managers & investigators:
Will receive enhanced training on fair investigations, bias avoidance, documentation, and local law.

Independent advice is available via:

• Email Address: whistle@protect-advice.org.uk
• Tel: 0203 117 2520
• Website: www.protect-advice.org.uk