Speak up early
Individuals should not wait for complete proof before reporting a genuinely held concern.
Protected Reporting
Whistleblowing Policy.
Black Fleet London encourages workers and relevant stakeholders to raise genuine concerns about wrongdoing, risk or unlawful conduct without fear of retaliation.
This policy provides an internal reporting framework. Whether a disclosure receives statutory whistleblowing protection depends on the applicable law and the individual circumstances.
Purpose
A safe route for raising serious concerns.
The purpose of this policy is to provide a clear and responsible route for reporting suspected wrongdoing affecting Black Fleet London, its workers, clients, passengers, suppliers or the public.
Early reporting can help prevent harm, protect passengers, identify unlawful activity and allow corrective action before a concern becomes more serious.
Scope of this policy
- Directors, employees and individuals with worker status
- Contractors and consultants working with the company
- Relevant personnel within licensed operating partners
- Suppliers and representatives who become aware of serious wrongdoing
- Concerns involving passengers, clients, operations or public safety
- Conduct occurring within or connected to Black Fleet London activities
Policy Statement
Genuine concerns should be heard, protected and assessed.
Black Fleet London will seek to receive whistleblowing concerns seriously, handle them sensitively and take proportionate action where wrongdoing or material risk may have occurred.
No retaliation
Retaliation against someone raising a genuine concern is not tolerated.
Confidential handling
Information should be restricted to those who reasonably need it.
Fair assessment
Concerns should be reviewed objectively and without predetermined conclusions.
Proportionate action
The response should reflect the seriousness, evidence and risk involved.
Organisational learning
Substantiated concerns should lead to correction and appropriate improvement.
Protected Disclosure Framework
Whistleblowing concerns wrongdoing affecting others or the public interest.
Whistleblowing is different from an ordinary personal complaint. Statutory protection generally depends on the person reasonably believing that the disclosure concerns relevant wrongdoing and is in the public interest.
Information
A disclosure should communicate information about suspected wrongdoing.
Reasonable belief
The person does not need final proof but should have a reasonable basis.
Public interest
The concern should extend beyond a purely private personal dispute.
Appropriate route
The circumstances and recipient may affect statutory protection.
Reportable Wrongdoing
Concerns that may fall within the whistleblowing framework.
The categories below are illustrative. Legal protection depends on the facts, the worker’s reasonable belief and the applicable statutory conditions.
Criminal offences
Suspected fraud, theft, bribery, corruption, violence or other criminal conduct.
Legal non-compliance
Failure to meet a legal or regulatory obligation.
Miscarriage of justice
Conduct that may cause or conceal a miscarriage of justice.
Health and safety danger
Serious or concealed risks to workers, passengers or members of the public.
Environmental damage
Actual or likely environmental harm or unlawful disposal practices.
Concealment
Deliberate concealment or destruction of information about wrongdoing.
Sexual harassment
Disclosures concerning sexual harassment may qualify for statutory whistleblowing protection under the framework effective from 6 April 2026.
Passenger or safeguarding risk
Serious misconduct placing passengers, children or vulnerable people at risk.
Serious compliance manipulation
Falsified licensing, insurance, vehicle, financial or operational records.
Personal Complaints
Not every workplace or service complaint is whistleblowing.
A concern that relates only to an individual’s own employment, contractual treatment or personal disagreement may be more appropriately handled as a grievance, complaint or commercial dispute.
A personal complaint may nevertheless contain a wider public-interest concern and should not be rejected merely because it also affects the person raising it.
Other appropriate routes may include
- Employment grievance or workplace complaint
- Equality, harassment or dignity-at-work complaint
- Passenger complaint and service recovery
- Supplier or payment dispute
- Data-protection request or privacy complaint
- Health and safety incident report
- Contractual escalation process
Internal Reporting Route
Concerns may be raised directly with the Director.
A concern should normally be submitted through Black Fleet London’s contact route and clearly marked as confidential and relating to whistleblowing.
Where the concern involves the Director or the internal route is reasonably believed to be inappropriate, the person may consider an appropriate external or prescribed reporting route.
A written disclosure should include
- The background and nature of the concern
- Relevant dates, places and individuals
- Why the conduct may be wrongful or dangerous
- Whether the matter has already been reported
- Any available documents or evidence
- Any immediate safety or safeguarding risk
- A safe method for further communication
Confidential Reporting
Identity restricted as far as reasonably possible
A person may request that their identity be kept confidential. Black Fleet London will seek to limit disclosure to those who reasonably need the information to assess or investigate the concern.
Absolute confidentiality cannot always be guaranteed where disclosure is legally required, necessary to prevent serious harm or essential to a fair investigation.
Anonymous Reporting
Anonymous concerns may be considered
Black Fleet London may assess an anonymous concern according to its seriousness, credibility, detail and the information available.
Anonymity may limit the ability to ask questions, verify evidence, protect the reporting person or communicate the outcome.
Non-Retaliation
No person should be penalised for raising a genuine concern.
Black Fleet London does not tolerate dismissal, threats, intimidation, exclusion, disadvantage, withheld work or other retaliation because a person raised or supported a genuine concern.
No threats
Threatening or intimidating a reporting person is prohibited.
No disadvantage
Work, access or treatment must not be altered as retaliation.
No interference
Evidence, witnesses or reporting channels must not be obstructed.
Report retaliation
Suspected retaliation should be escalated immediately.
Response Process
Concerns assessed through a controlled and impartial process.
01
Receive
Record the disclosure securely and identify immediate risks.
02
Protect
Consider confidentiality, safety, evidence and retaliation risk.
03
Assess
Determine scope, seriousness, credibility and appropriate ownership.
04
Investigate
Obtain relevant information through a fair and proportionate process.
05
Act
Apply corrective, contractual, disciplinary or external action.
06
Review
Record lessons and verify that relevant improvements are completed.
Investigation Principles
Fairness to the reporting person and those affected.
An investigation should seek to establish relevant facts rather than prove a predetermined conclusion.
The process should protect confidentiality, preserve evidence and allow individuals affected by allegations a fair opportunity to respond.
Investigation controls
- Assign an appropriately impartial reviewer
- Define the scope and relevant allegations
- Preserve documents and system records
- Separate facts, assumptions and opinions
- Give affected individuals a fair opportunity to respond
- Keep an appropriate investigation record
- Escalate criminal or regulatory matters where appropriate
Outcomes and Feedback
The reporting person should receive appropriate procedural feedback.
Where possible, Black Fleet London will confirm whether a concern has been reviewed and whether appropriate action has been considered or taken.
Confidentiality, data protection, employment duties and legal restrictions may prevent disclosure of detailed findings or action relating to another individual.
Possible outcomes
- No further action following assessment
- Additional monitoring or information gathering
- Corrective operational action
- Supplier restriction, suspension or termination
- Employment or contractual action
- Policy, process or system improvement
- Referral to an appropriate authority
External Reporting
External disclosures should be made through an appropriate route.
A worker may in some circumstances make a protected disclosure to an appropriate prescribed person or body rather than to the employer.
The correct recipient and the conditions applying to external disclosures depend on the subject and circumstances. Independent legal advice may be appropriate before making a wider public disclosure.
External routes may include
- An appropriate prescribed regulator or public body
- The police where criminal conduct or immediate danger is suspected
- A legal adviser
- A Member of Parliament where legally appropriate
- An emergency or safeguarding authority
- Another route expressly recognised under applicable law
Public or media disclosure requires particular care
Disclosure to the media, social media or the general public may be subject to stricter legal conditions. Individuals considering such disclosure should obtain appropriate independent advice.
Genuine but Unsubstantiated Concerns
Lack of evidence does not automatically mean misconduct
A person will not be criticised merely because a genuinely raised concern cannot ultimately be substantiated.
The reporting person is not expected to prove the entire case before raising information they reasonably believe may indicate wrongdoing.
Knowingly False Reports
Deliberately fabricated allegations are not protected by this policy
A report knowingly made with false information, malicious intent or fabricated evidence may result in appropriate corrective, contractual or disciplinary action.
A mistaken or unsubstantiated concern should not be treated as malicious merely because the allegation was not proven.
Records and Data Protection
Whistleblowing information treated as sensitive.
Disclosure and investigation records should be stored securely and accessed only by authorised persons with a genuine need.
Personal information should be limited to what is necessary for assessment, investigation, legal compliance and protection of those involved.
Information-handling principles
- Restrict access according to role and necessity
- Avoid unnecessary circulation of allegations
- Preserve evidence securely
- Distinguish allegation from established fact
- Retain records according to purpose and legal need
- Protect the rights of witnesses and accused persons
- Document significant decisions and outcomes
Roles and Accountability
Clear responsibility for reporting, protection and response.
01
Director
Owns the policy, receives or appoints review of disclosures and oversees significant outcomes and corrective action.
02
Operations and administrators
Protect relevant records, escalate serious concerns and avoid unauthorised investigation or disclosure.
03
Operating partners and suppliers
Cooperate with proportionate enquiries, protect reporting persons and report connected wrongdoing promptly.
04
All individuals
Raise genuine concerns responsibly, preserve relevant information and avoid retaliation or interference.
Awareness and Communication
Reporting routes communicated according to role
Relevant employees, contractors, operating partners and suppliers should receive proportionate information concerning reportable wrongdoing, confidentiality, non-retaliation and escalation routes.
Individuals responsible for receiving concerns should understand the difference between whistleblowing, grievances, complaints and routine incident reports.
Monitoring and Review
The framework reviewed against experience and legal change
Black Fleet London may review the number and type of concerns raised, response quality, confidentiality issues, retaliation concerns and corrective-action completion.
This policy should be reviewed at least annually and following a significant disclosure, retaliation concern or relevant legal development.
This policy does not replace independent advice
Individuals uncertain about statutory protection, external disclosure or employment rights may wish to obtain independent advice from Acas, a legal adviser or another appropriate organisation.
Related Governance
Protected reporting supported by connected policies.
Anti-Bribery and Corruption Policy
Prevention and reporting of bribery, improper payments and conflicts.
Modern Slavery Statement
Reporting and escalation of forced labour, trafficking and exploitation concerns.
Equality, Diversity and Inclusion Policy
Protection from discrimination, harassment, victimisation and retaliation.
Confidential Reporting
Need to raise a serious concern?
Contact Black Fleet London through the corporate contact route and mark the communication “Private and Confidential — Whistleblowing” so it can be directed appropriately.