Complaints & Disclosures Gateway

Status: v1.0
Tier: Tier 1 – Core Corporate & Platform Policy
Owner: Governance and Compliance Function
Approval Authority: Board of Directors
Effective Date: 5 January 2026
Next Review: 12 months from approval

1. Purpose

This document establishes a single, unified gateway for receiving, triaging, and managing:

  • complaints,

  • whistleblower disclosures,

  • safeguarding concerns (including PSEAH and child safeguarding),

  • fraud, corruption, or financial misconduct reports,

  • modern slavery or ethical recruitment concerns, and

  • any other integrity, legal, or compliance issues.

Its purpose is to:

  • remove ambiguity for reporters,

  • prevent procedural failure,

  • ensure lawful handling and escalation, and

  • override conflicting reporting pathways across policies.

2. Core Principle: One Door In

Global Talent Pathway operates one external entry point for all complaints and disclosures.

No individual is required to determine which policy applies when raising a concern.

Classification, routing, escalation, and reporting obligations are internal governance responsibilities.

3. Scope

This gateway applies to reports made by:

  • candidates and jobseekers,

  • workers,

  • employers and recruiters,

  • suppliers and agents,

  • staff, contractors, and Board members,

  • partners and third parties,

  • members of the public.

It applies across all Global Talent Pathway activities, jurisdictions, and platforms.

4. Reporting Channels (Single Gateway)

All complaints and disclosures are received through the following channels:

Primary Channel

  • Secure online reporting form (web-based)

Secondary Channels

  • Dedicated email address

  • Telephone hotline

  • External whistleblowing service (where engaged)

All channels feed into the same intake register.

5. Intake Acknowledgement

Upon receipt of a report:

  • acknowledgment will be provided where contact details are available,

  • anonymity will be respected where requested,

  • no assurances beyond lawful protections will be given.

6. Internal Triage Model (Non-Public)

All reports are internally triaged by the Governance and Compliance Function using a controlled decision matrix.

Step 1: Initial Classification

Reports are classified into one or more of the following categories:

  • General complaint

  • Workforce or recruitment conduct

  • Whistleblower disclosure

  • Safeguarding concern (adult)

  • Child safeguarding concern

  • Modern slavery / labour exploitation

  • Fraud, corruption, or financial misconduct

  • Data protection or security incident

  • Legal or regulatory risk

Classification is non-exclusive. One report may fall into multiple categories.

Step 2: Risk Assessment

Each report is assessed for:

  • immediacy of risk,

  • potential harm to individuals,

  • legal or regulatory obligations,

  • reputational risk,

  • need for external notification.

Step 3: Routing & Escalation

Based on classification and risk, the report is routed to:

  • appropriate internal investigators,

  • safeguarding focal points,

  • senior management,

  • external investigators (if required),

  • regulators or authorities (only where required by law).

7. Relationship to Other Policies

This Gateway supersedes all individual reporting instructions contained in:

  • Complaints Policy

  • Whistleblower Policy

  • PSEAH Policy

  • Child Safeguarding Policy

  • Modern Slavery & Human Trafficking Policy

  • Ethical Recruitment & Fair Work Policy

Those policies define standards and obligations, but not intake mechanisms.

8. Safeguarding & Mandatory Reporting

Where a report involves:

  • child safeguarding, or

  • sexual exploitation, abuse, or harassment,

mandatory reporting obligations under law or funding agreements will be assessed and discharged after triage, not at intake.

No reporter is required to notify external bodies directly unless required by law.

9. Whistleblower Protections

Where a report qualifies as a whistleblower disclosure:

  • confidentiality protections apply to the extent permitted by law,

  • protection from retaliation applies,

  • specialised handling procedures are triggered.

False or malicious reports may result in action.

10. Confidentiality & Data Handling

All reports are:

  • recorded in a secure register,

  • access-restricted on a need-to-know basis,

  • handled in accordance with the Privacy Policy and Information Security Policy.

11. Investigation & Resolution

Investigations will be:

  • proportionate to risk,

  • conducted fairly and independently,

  • documented appropriately.

Outcomes may include:

  • no action,

  • corrective action,

  • disciplinary action,

  • termination of relationships,

  • external reporting where required.

12. Feedback to Reporter

Where appropriate and lawful:

  • reporters will be informed of progress or outcomes,

  • confidentiality and privacy constraints may limit detail.

13. Governance & Oversight

The Board retains oversight of:

  • serious or systemic matters,

  • whistleblower trends,

  • safeguarding incidents,

  • modern slavery risks.

Periodic reporting is provided to the Board in de-identified form.

14. No Retaliation

Retaliation against anyone who raises a concern in good faith is prohibited and constitutes serious misconduct.

15. Review

This Gateway will be reviewed annually and updated as required.