Complaints Policy

Status: v2.0
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 Complaints Policy sets out how Global Talent Pathway receives, manages, and resolves complaints relating to its platforms, workforce services, operations, and conduct.

Its purpose is to:

  • provide a fair, accessible, and transparent process for raising concerns,

  • support early identification and resolution of issues,

  • protect individuals from retaliation, and

  • ensure complaints are handled consistently and lawfully.

This policy applies to complaints that do not meet the threshold of whistleblower disclosures or safeguarding incidents, which are addressed through specialised handling under the Complaints & Disclosures Gateway.

2. Relationship to the Complaints & Disclosures Gateway

All complaints are received through the Complaints & Disclosures Gateway.

This policy:

  • defines how complaints are handled after intake and triage, and

  • does not create a separate reporting pathway.

Where a matter is reclassified as:

  • a whistleblower disclosure,

  • a safeguarding concern,

  • a modern slavery issue, or

  • a fraud or serious misconduct matter,

handling will proceed under the applicable framework following gateway triage.

3. Scope

This policy applies to complaints made by:

  • candidates and jobseekers,

  • workers,

  • employers and recruiters,

  • suppliers and agents,

  • staff, contractors, and representatives,

  • members of the public.

Complaints may relate to:

  • platform functionality or access,

  • recruitment or workforce processes,

  • conduct of staff, employers, recruiters, or suppliers,

  • service quality or fairness,

  • alleged breaches of Global Talent Pathway policies (other than whistleblower or safeguarding matters).

4. What Is a Complaint

A complaint is an expression of dissatisfaction about:

  • Global Talent Pathway’s services or decisions,

  • the conduct of individuals acting on behalf of Global Talent Pathway, or

  • the way an issue has been handled.

A complaint does not include:

  • whistleblower disclosures,

  • safeguarding concerns,

  • criminal allegations requiring immediate reporting,

  • general enquiries or requests for information.

These are triaged separately under the Gateway.

5. Principles

Complaints are handled in accordance with the following principles:

  • Accessibility: complaints can be raised without undue burden or cost.

  • Fairness: all parties are treated respectfully and impartially.

  • Proportionality: response is proportionate to the nature and risk of the issue.

  • Confidentiality: information is shared only on a need-to-know basis.

  • No retaliation: complainants are protected from adverse treatment for raising concerns in good faith.

6. Complaint Handling Process

6.1 Receipt and Acknowledgement

Following gateway intake and classification:

  • complaints will be acknowledged where contact details are available,

  • the complainant may be asked for additional information if required.

6.2 Assessment

Complaints are assessed to determine:

  • scope and seriousness,

  • whether informal resolution is appropriate,

  • whether escalation or reclassification is required.

6.3 Resolution

Resolution may include:

  • clarification or explanation,

  • corrective action,

  • changes to process or controls,

  • referral to another policy framework where appropriate.

Not all complaints will result in a change of outcome.

6.4 Timeframes

Global Talent Pathway will aim to resolve complaints within a reasonable timeframe, taking into account:

  • complexity,

  • availability of information,

  • need for investigation.

Indicative timeframes are guidance only and not guarantees.

7. Confidentiality and Records

Complaints are:

  • recorded in a secure complaints register,

  • retained in accordance with the Records Management & Retention Policy,

  • handled in line with the Privacy Policy.

8. Support and Adjustments

Where appropriate, reasonable adjustments may be made to support complainants, including:

  • alternative communication methods,

  • assistance with understanding the process.

9. Outcomes and Feedback

Where lawful and appropriate:

  • complainants may be informed of the outcome,

  • details may be limited by privacy or confidentiality obligations.

10. No Retaliation

Retaliation against any person who raises a complaint in good faith is prohibited and may result in disciplinary or other action.

11. Continuous Improvement

Complaints data may be analysed (in de-identified form) to:

  • identify systemic issues,

  • improve services and controls,

  • inform risk management.

12. Review

This policy will be reviewed annually and updated as required.