1. Purpose and commitment

The Guild of Young Freemen (the “Guild”) is committed to conducting its affairs with honesty and integrity.

We encourage all members to raise concerns about wrongdoing or risk as early as possible. We will take concerns seriously, investigate them appropriately, and ensure that individuals who raise concerns in good faith are treated fairly.

This policy supplements the Guild’s Whistleblowing Policy.

2. Who this policy applies to

This policy applies to all members of the Guild, those that sit on any of its committees, and all members of the Court. (Collectively referred to as “members” for this policy.)

This policy also applies to any third parties interacting with the Guild.

The Court, in the course of its business, is able to bring a complaint of its own motion (proprio motu). Should the Court act proprio motu in bringing a complaint, the provisions of paragraph 9 still apply.

3. What is a complaints procedure

A complaints procedure is an official, structured process used to receive, record, investigate, and resolve complaints. It ensures transparency, accountability, and quality improvement by outlining how to lodge complaints, expected timeframes, and options for redress if the complainant remains unsatisfied.

Key Components of our Complaints Procedure

• Clear Guidance: Instructions on how and where to submit a complaint.
• Acknowledgment and Recording: A formal, timely, and documented acknowledgment of the issue.
• Investigation: A fair, thorough, and objective examination of the facts.
• Independence: An independent panel member as part of the panel who considers your complaint or an independent panel if required because of the subject of your complaint.
• Resolution and Response: A formal decision letter outlining findings and actions taken.
• Escalation Routes: Clear details on how to escalate the complaint to an external body if internal resolution fails.

4. What should be reported under this policy

Complaints should cover serious issues that cannot be resolved informally including (but not limited to) harassment, discrimination, unethical behaviour, safety violations, and being the victim of retaliation. These categories may include:

• Harassment & Bullying: Persistent, unwelcome, and/or offensive behaviour (e.g., sexual harassment, public humiliation, yelling, intimidation).
• Discrimination: Unfair treatment based on protected characteristics like race, gender, religion, age, or disability.
• Safety & Ethics: Violations of health and safety regulations, theft, fraud, or misuse of company resources.
• Retaliation: Punitive action taken against anyone for reporting a previous issue or participating in an investigation

Whistleblowing

If the complaint also raises wider issues in the public interest (e.g., unsafe practices affecting others) the complaint may be raised, (both instead of this Complaints Policy, or in addition to it) via the Guild’s Whistleblowing Procedure.

Some examples of what can be considered as a qualifying disclosure are listed below

• a criminal offence
• breach of a legal obligation
• miscarriage of justice
• danger to health and safety
• environmental damage
• deliberate concealment of any of the above

5. Confidentiality and anonymity

We will treat all complaints sensitively and will seek to keep your identity confidential as far as possible, and consistent with:

• a fair investigation,
• legal requirements, and/or
• regulatory expectations.

We expect that both the complainant and subject of the complaint will keep matters confidential. Failing to do so may affect the integrity of any investigation.

6. Protection from retaliation

Any form of retaliation, victimisation, or detrimental treatment of anyone who raises a concern in good faith will not be tolerated. Any retaliation will be treated as a disciplinary matter.

Support may include:

• adjustments to reporting lines, if working on a committee,
• wellbeing/member assistance support,
• steps to protect confidentiality,
• escalation to senior oversight.

7. How to raise a complaint (internal reporting)

We encourage a complainant to raise concerns internally first, where appropriate.

Step 1: choose a reporting route

You may lodge a complaint via the following routes:

(i) By email to the Guild’s Clerk (clerk@youngfreemen.org)

The Clerk will triage the complaint to determine if it concerns members of the Court and should proceed on the senior escalation pathway or does not involve members of the Court and can proceed to be investigated by the Guild’s complaints panel as detailed below.

(ii) Senior Escalation Route: by email to the Honorary Court Assistant (honcourtassistant@youngfreemen.org)

If you feel unable to submit a disclosure to the Clerk as set out above, for example if the complaint involves the Clerk, a disclosure can be made to the Guild’s Honorary Court Assistant who will consider the complaint and decide whether to open an investigation under the senior escalation route provisions as set out below.

Where the Honorary Court Assistant is unavailable or for any reason it is appropriate to do so, the Master of the Guild of Young Freemen may appoint an alternative senior member of the livery movement to consider the complaint.

Step 2: What to include in any complaint

Provide as much detail as you can, including:

• what happened / is happening,
• dates/times/locations,
• names of individuals involved (if known),
• how you became aware of the issue,
• any supporting documents or evidence,
• whether you have raised the issue before, and the outcome,
• what outcome you are seeking (if any),
• whether you specifically want confidentiality and/or anonymity.

9. What happens after you lodge a complaint

Acknowledgement

We aim to acknowledge receipt within 3 working days, unless you reported anonymously or did not provide contact details.

Initial assessment (triage)

The Clerk will triage the complaint to determine if it concerns members of the Court and should proceed on the Senior Escalation Pathway or does not involve members of the Court and can proceed to be investigated internally.

In the event the complaint can be investigated internally the Clerk must, as soon as is reasonably practicable, inform the Court that a complaint has been received and convene a complaints panel (the “Complaints Panel”) to consider the complaint and decide any appropriate actions to be taken in response to the complaint.

In the event the complaint is brought by the Court proprio motu, the Court and Clerk must, as soon as is reasonably practicable, convene a complaints panel to consider the complaint and decide any appropriate actions to be taken in response to the complaint. If any complaint is brought by the Court proprio motu and involves a member of the Court, the complaint must proceed via the Senior Escalation Route.

Composition of the Complaints Panel

The Complaints Panel will consist of the following individuals (unless it is determined that this composition is inappropriate for the particular complaint based upon independence, conflicts of interest and/or any other relevant matter):

• three Court members
• Honorary Court Assistant
• one External Livery Master or Clerk appointed pro tempore

Timeline

We aim to complete investigations within 28 days of written receipt of the complaint, but this may vary depending on complexity.

As soon as is reasonably practicable, a meeting of the Complaints Panel will be convened (at which all members of the Complaints Panel must be present) to consider the complaint and all available evidence. The Complaints Panel may require further evidence before completing its investigation.

Outcome and Actions

Where feasible and appropriate, the Complaints Panel will provide feedback on:

• whether the matter was investigated,
• the broad outcome (e.g., substantiated/not substantiated/inconclusive),
• general actions taken (without breaching confidentiality).

Such feedback will be communicated to the complainant, the subject of the complaint and the Court, unless it is inappropriate to do so.

10. Disciplinary actions available to the Complaints Panel

The following disciplinary actions are available to the complaints panel if they uphold a complaint:

A. Verbal Warning

Used for minor misconduct or where informal steps have not resolved an issue. Where concerns can be explained, and a verbal warning is issued and confirmed in writing, including expected standards.

B. Written Warning

Used for more serious matters or further issues during a live verbal warning. A written warning sets out findings, required improvements, support to be offered, and consequences of further misconduct, including potential suspension or expulsion.

C. Suspension

For matters of allegations are serious, or where suspension is necessary to protect others or the integrity of the Guild. Suspension can be in the form of suspension from membership or position within the Guild.

D. Expulsion

Used for gross misconduct or when repeated misconduct makes continued membership untenable or when it is found that the person complained of is no longer a proper person to be part of the Guild.

11. Action which can be taken if Complainant is aggrieved by the result of the Complaints Panel

Where the complainant is aggrieved by the result of the Complaints Panel’s investigation or the actions taken, the complainant may request a review within 28 days of being informed of the result of the investigation and/or the actions taken.

A review will be undertaken by the Guild’s Honorary Court Assistant who will consider the complaint, the response to the allegation, and any other evidence which was received by the Complaints Panel. The Honorary Court Assistant will determine whether the Complaints Panel considered the complaint objectively and fairly, taking into account the rights of the complainant as well as those of the subject(s) of the complaint. The Honorary Court Assistant will also consider whether the outcome and actions taken were within the range of outcomes and actions that might be taken by a reasonable person acting reasonably.

If the Honorary Court Assistant determines that the complaint has been considered objectively, fairly, and that the outcomes or actions were within the range of outcomes and actions that might be taken by a reasonable person acting reasonably, such feedback will be communicated to the complainant and to the Court unless it is inappropriate to do so.

If the Honorary Court Assistant determines that the complaint has not been determined objectively, fairly, or that the outcomes or action were not within the range of outcomes and actions that might be taken by a reasonable person acting reasonably, then the Honorary Court Assistant will commence the Senior Escalation Route as set out below.

The Honorary Court Assistant will endeavour to complete the assessment above within 28 days, but this may vary depending on complexity. Where possible the outcome of the Honorary Court Assistant’s review will be communicated to the individual who made the disclosure and the Court unless it is inappropriate to do so. We may need to limit what we can share due to confidentiality, data protection, or legal/regulatory constraints.

Where the Honorary Court Assistant is unavailable or for any reason it is appropriate to do so, the Master of the Guild of Young Freemen may appoint an alternative senior member of the livery movement to consider the actions of the Complaints Panel.

12. The Senior Escalation Route

Where a complaint is:

• made directly to the Honorary Court Assistant as there is a reason why it could not be determined by the Complaints Panel (if it concerns a member of the Court for example),
• it is allocated to the Senior Escalation Route by the Guild’s clerk upon receipt of the disclosure,
• it is allocated to the Senior Escalation Route by the Court acting proprio motu; or
• the Honorary Court Assistant upholds a complaint about the Complaint Panel’s decision,

then the complaint shall proceed using the Senior Escalation Route.

Composition of the Senior Escalation Panel

The Senior Escalation Route Investigation will be conducted by a panel (the “Senior Escalation Panel”) composed of the following:

• Honorary Court Assistant,
• two Livery Masters or clerks as appointed pro tempore by the Honorary Court Assistant

Where the Honorary Court Assistant is unavailable or for any reason it is appropriate to do so, the Master of the Guild of Young Freemen may appoint an alternative senior member of the livery movement to chair the Senior Escalation Panel.

13. Disciplinary actions available to the Senior Escalation Panel

The following disciplinary actions are available to the complaints panel if they uphold a complaint:

A. Verbal Warning

Used for minor misconduct or where informal steps have not resolved an issue. Where concerns can be explained, and a verbal warning is issued and confirmed in writing, including expected standards.

B. Written Warning

Used for more serious matters or further issues during a live verbal warning. A written warning sets out findings, required improvements, support to be offered, and consequences of further misconduct, including potential suspension or expulsion.

C. Suspension

For matters of allegations are serious, or where suspension is necessary to protect others or the integrity of the Guild. Suspension can be in the form of suspension from membership or position within the Guild.

D. Expulsion

Used for gross misconduct or when repeated misconduct makes continued membership untenable or when it is found that the person complained of is no longer a proper person to be part of the Guild.

14. Timeline and Finality of Senior Escalation Route

We aim for the Senior Escalation Route investigation to be completed within 28 days, but this may vary depending on complexity and the availability of the panel. This decision of the Senior Escalation Panel will be communicated to the individual who made the disclosure and the Court unless it is inappropriate to do so. We may need to limit what we can share due to confidentiality, data protection, or legal/regulatory constraints.

Determination of outcomes and actions by the Senior Escalation Panel are final. The Panel has right to determine whether to admit fresh evidence when considering matters that have proceeded to the Senior Escalation Route following a challenge to the determination of the Complaints Panel.

15. Repeat Complaints or Complaints Alleging Materially Similar Conduct

Where it appears that a complaint has been made which has previously been subject to a determination under the processes set out above, that complaint may be forwarded to the Honorary Court Assistant for his consideration.

If the Honorary Court Assistant considers that the complaint is materially different to one previously made or should be considered together with any other complaint for reasons of expediency or fairness, then that complaint will proceed following the processes set out in this Policy.

If the Honorary Court Assistant considers that the complaint is materially the same as one previously made and that that there is no proper reason for it to be reconsidered under this Policy, then that complaint will be considered as being previously determined and not subject to any further consideration under this policy. This decision will be communicated to the individual who made the complaint and the Court unless it is inappropriate to do so. We may need to limit what we can share due to confidentiality, data protection, or legal/regulatory constraints.

16. Fair treatment of those implicated

We will treat anyone named in a report fairly. Raising a concern does not mean wrongdoing has occurred; allegations will be assessed and investigated appropriately.

Before any factual determination is made by the Complaints Panel or Senior Escalation Panel the subject(s) of any complaint shall be asked whether they wish to provide a written account or response to any allegation against them where it is felt that it is appropriate to do so. Should the subject(s) decide not to provide a written account or response to any allegation against them if invited to do so, that decision must be conveyed to the Complaints Panel or Senior Escalation Panel (as constituted) in writing. Where such accounts or responses are given, they shall be considered as part of the evidence by the panels.

17. Malicious or knowingly false reports

We encourage people to speak up. However, deliberately false or malicious allegations may lead to disciplinary action. Honest reports made in good faith will not lead to disciplinary action even if they are mistaken.

18. Learn and review

Once the complaints process has been completed under either of the two routes the clerk will inform the wider Court of the outcome of the complaint and the actions taken. From here the Clerk will invite members of the Complaints Panel and the wider Court to consider what procedures or guidance could be implemented to reduce the risk of similar incidents in future.

19. Retention

Records relating to complaints and disciplinary matters shall be retained securely for six years from the conclusion of the matter. After this period, records shall be securely destroyed unless legal or regulatory reasons require continued retention.