Whistleblowing Policy
1. Introduction
NASA Umbrella Ltd is committed to maintaining the highest standards of ethical conduct and integrity in all its business activities. This whistleblowing policy outlines the procedures for employees and contractors to report concerns about unethical behaviour, fraud, or violation of company policies.
2. Purpose
Employees may, in properly carrying out their duties, have access to, or come into contact with, information of a confidential nature. Their terms and conditions provide that except in the proper performance of their duties, employees are forbidden from disclosing, or making use of in any form whatsoever, such confidential information. However, the law allows employees to make a ‘protected disclosure’ of certain information.
In order to be ‘protected’, a disclosure must relate to a specific subject matter (clause 3) and the disclosure must also be made in an appropriate way (clause 4). Whistleblowing protection is confined to a disclosure which, in the reasonable belief of the employee making the disclosure, is made in the public interest.
NASA Umbrella Limited (“the Company”) is committed to compliance with the Bribery Act 2010 and the Economic Crime and Corporate Transparency Act 2023, which introduced a corporate offence of failure to prevent fraud (in force from 1 September 2025). The Company actively encourages a culture of honesty and openness and therefore all employees are required to bring up to their manager or other designated person any issue that, in the employee’s opinion, might constitute bribery, corruption or fraud.
3. Specific subject matter
If, in the course of employment, an employee becomes aware of information which they reasonably believe tends to show one or more of the following:
That a criminal offence has been committed, is being committed or is likely to be committed.
That a person has failed, is failing or is likely to fail to comply with any legal obligation to which he is subject.
That a miscarriage of justice that has occurred, is occurring, or is likely to occur.
That the health or safety of any individual has been, is being, or is likely to be, endangered.
That the environment, has been, is being, or is likely to be, damaged.
That information tending to show any of the above, is being, or is likely to be, deliberately concealed.
That the business or any associated person has been, is being, or is likely to be receiving or offering bribes.
That an act of sexual harassment has occurred, is occurring, or is likely to occur.
They must use the Company’s disclosure procedure as set out below.
4. Disclosure procedure
Information which an internal employee reasonably believes tends to show one or more of the above should promptly be disclosed to their department Manager or Director so that any appropriate action can be taken.
For external contractor employees an email can be sent to a confidential whistle-blower email address which will deliver to the HR Director:
Or by telephone on 0117 929 7683 (Monday to Thursday 9am–5:30pm, Friday 9am–5pm).
If it is inappropriate to make such a disclosure to the department Director (or confidential email address), the employee should speak to an alternative Director:
Employees will suffer no detriment of any sort for making such a disclosure in accordance with this procedure.
However, failure to follow this procedure may result in the disclosure of information losing its ‘protected status.’
For further guidance in relation to this matter or concerning the use of the disclosure procedure generally, employees should speak in confidence to Pippa Elsey, HR Director.
In addition to internal reporting channels, workers have the right to report concerns directly to an external prescribed body. Relevant prescribed persons for NASA Umbrella Ltd include HM Revenue & Customs (for matters relating to tax, payroll, and National Minimum Wage compliance) and the Financial Conduct Authority (for financial services matters). A full list of prescribed persons is published on GOV.UK under the Public Interest Disclosure (Prescribed Persons) Order 2014 (as amended, most recently by the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025).
5. Protection for Whistleblowers
The Company prohibits retaliation or victimization against individuals who report concerns in good faith. Whistleblowers will be protected from any adverse actions, including but not limited to dismissal, demotion, harassment, or discrimination, as a result of their whistleblowing activity. For the avoidance of doubt, no clause in any settlement agreement, non-disclosure agreement, or other contractual arrangement entered into with the Company shall prevent a worker from making a protected disclosure in accordance with this policy or applicable law.
6. Investigation Process
Upon receiving a report, The Company will promptly initiate an investigation. The investigation will be conducted impartially, objectively, and with due diligence. Whistleblowers will be kept informed of the progress and outcome of the investigation to the extent possible without compromising the investigation's integrity.
7. Confidentiality
All reports and investigations will be treated with the utmost confidentiality to protect the privacy of the whistleblower and the individuals involved. Information will only be disclosed to those who need to know for the purpose of the investigation or as required by law.
8. Policy approval
This policy has been approved & authorised on behalf of the board by:
Marta Tabor, Contracts Manager 18/05/2026