Whistleblowing and Anti-Bribery Policy

Last Review: July 2026
Next Review: July 2027
Approved by: Head of Learning & Development

1. Company Details

Registered company name: Pyrometrix Ltd
Company registration number: 16302312
Registered office: 5 The Hawthorns, Maple Cross, Rickmansworth, England, WD3 9UH
Country of incorporation: England
Trading names for training delivery: Pyrometrix Ltd

2. Purpose & Commitment

Pyrometrix Ltd is committed to the highest standards of integrity, transparency, and accountability in all areas of operation. This policy sets out our approach to:

• Whistleblowing: Providing a safe and confidential mechanism for reporting concerns, including malpractice, unethical behaviour, or breaches of policy.

• Anti-Bribery: Preventing bribery, corruption, or undue influence in accordance with the UK Bribery Act 2010.

We operate a zero-tolerance approach to bribery and corruption and encourage all stakeholders to raise concerns without fear of reprisal

3. Scope

This policy applies to all employees, consultants, contractors, learners, suppliers, and stakeholders engaged with Pyrometrix Ltd.

It covers:

• Bribery and corruption.

• Fraud, theft, and financial malpractice.

• Breaches of health & safety, data protection, or other regulatory requirements.

• Misconduct or unethical behaviour.

• Any activity that may compromise the integrity of Pyrometrix Ltd.

4. Whistleblowing Principles

• Protection: Individuals raising concerns in good faith are protected from dismissal, victimisation, or retaliation.

• Confidentiality: All disclosures are treated confidentially, with identities protected where possible.

• Independence: Concerns are investigated objectively, without conflict of interest.

• Transparency: Outcomes of investigations are communicated to the reporting party where appropriate.

5. Whistleblowing Procedure

1. Raising Concerns

• Concerns should be reported to kevin.boon@pyrometrixltd.com.

• Reports may also be made in writing to the Head of Learning & Development.

2. Acknowledgement

• Reports will be acknowledged within five working days.

3. Investigation

• Concerns will be reviewed by the Head of Learning & Development or an independent representative.

• Investigations will be completed within 30 working days where possible.

4. Outcome

• Findings will be documented, corrective actions identified, and feedback provided.

• Where necessary, matters will be escalated to external authorities (e.g., police, regulatory bodies).

6. Anti-Bribery Principles

Pyrometrix Ltd prohibits:

• Offering, giving, requesting, or receiving bribes in any form.

• Facilitation payments (“grease payments”).

• Gifts, hospitality, or expenses intended to improperly influence decision-making.

• Retaliation against anyone who refuses to participate in bribery.

7. Anti-Bribery Procedure

• Due Diligence: All suppliers, contractors, and consultants must confirm compliance with the UK Bribery Act 2010.

• Gifts & Hospitality: Must be modest, transparent, and not intended to influence. A gifts & hospitality register will be maintained.

• Training & Awareness: All staff, contractors, and trainers will receive periodic training on anti-bribery obligations.

• Reporting: Any suspicion of bribery must be reported through the whistleblowing procedure.

8. Monitoring & Continuous Improvement

• All whistleblowing cases and bribery risks are logged in the Continuous Improvement Register.

• Patterns are reviewed annually to identify risks and inform updates to this policy.

• Policy effectiveness is monitored through internal audits, feedback, and Board-level oversight.

9. Policy Review Cycle

This policy is reviewed annually by the Head of Learning & Development and updated in line with evolving best practice, legislation, and accreditor expectations.