Who we are
Bubble Fresh (Bubblefresh Limited, company number 12691029) is a specialist cleaning and clearance company. Our registered office is 6 Carnegie Street, Rushden, Northamptonshire, NN10 9SN. We provide services for vulnerable adults and local council partners. This policy applies to all workers at Bubble Fresh, including employees, agency workers, contractors, volunteers, and anyone working on our behalf.
Our commitment
Bubble Fresh encourages an open culture where workers feel able to raise genuine concerns about wrongdoing without fear of reprisal. We want you to feel safe speaking up. This policy is underpinned by the Public Interest Disclosure Act 1998 (PIDA), which inserted sections 43A to 43L into the Employment Rights Act 1996 (ERA), providing legal protection for workers who make qualifying disclosures in the public interest. We take all concerns raised under this policy seriously and will act on them.
What counts as a qualifying disclosure
Under the Employment Rights Act 1996 s.43B(1), a qualifying disclosure is one where you reasonably believe that one or more of the following is happening, has happened, or is likely to happen: a criminal offence, a failure to comply with any legal obligation, a miscarriage of justice, a danger to the health and safety of any individual, damage to the environment, or the deliberate concealment of information about any of these matters. Given the nature of our work with vulnerable adults, concerns about safeguarding, abuse, neglect, financial exploitation, or unsafe working practices are particularly important and should be raised immediately. This policy is not intended for personal grievances such as disputes about pay, working conditions, or interpersonal disagreements, which should be raised through our Complaints Procedure or normal HR processes.
How to raise a concern
You can raise a concern in any of the following ways. In writing to the Director, Lance James, at rncceygmploaohaprukgtefvqz@bikxutblbxztbooblvyyeegofldvrbqleoyvselqhlwo.mgvcubcowqa.mqbuocrktln. By phone on 01933 213045 (Relay UK: 18001 then 01933 213045). Verbally in confidence with any manager. If your concern is about the Director, you may report it directly to an external prescribed person (see the External reporting section below) or to our independent HR adviser. When raising a concern, include as much detail as you can: what happened, when it happened, who was involved, where it took place, and any evidence or documents you have. You do not need proof that something wrong has happened. A reasonable belief is enough. We accept and will investigate anonymous reports, although it may be harder to look into the matter fully without being able to ask you follow-up questions.
Confidentiality
We will keep your identity confidential wherever possible. We will not disclose your name or identifying details without your consent unless we are legally required to do so. There are limited situations where we may need to reveal your identity, including where disclosure is required by law or by a court order, where a regulator or law enforcement body requires it as part of an investigation, or where it is necessary to prevent a serious risk to the health or safety of any person. If we need to disclose your identity, we will tell you beforehand wherever it is safe and practical to do so, and we will explain why.
Protection for whistleblowers
Under the Employment Rights Act 1996 s.47B, workers are protected from any detriment on the grounds of making a protected disclosure. Under s.103A, any dismissal for making a protected disclosure is automatically unfair. These protections apply from your first day of work, with no qualifying service period required. They apply to all workers, not just employees, including agency workers, contractors, and anyone working on our behalf, in line with the broad definition of 'worker' under the Employment Rights Act 1996. Detriment includes dismissal, disciplinary action, demotion, reduction in hours, exclusion from training or promotion opportunities, bullying, harassment, or any other unfavourable treatment connected to you raising a concern. If you feel you have been treated unfairly as a result of raising a concern, tell the Director immediately. If your concern is about the Director, contact our independent HR adviser or an external prescribed person.
Support for whistleblowers
We understand that raising a concern can be stressful. We will support you throughout the process. This includes keeping you informed of progress (see the Feedback to whistleblowers section below), making sure you are not isolated or disadvantaged at work, offering access to our Employee Assistance Programme (EAP) for confidential counselling and emotional support at no cost to you, and allowing reasonable time off for any related meetings, interviews, or appointments. If you need advice before raising a concern, you can contact Protect (formerly Public Concern at Work), the UK's independent whistleblowing charity, on 020 3117 2520 or at protect-advice.org.uk. Their advice is free and confidential.
Investigation
We will investigate all concerns raised under this policy promptly, thoroughly, and fairly. The Director will decide how to investigate based on the nature and seriousness of the concern. Where the concern involves the Director, our independent HR adviser will lead the investigation. Within 5 working days of receiving a concern, we will acknowledge it in writing, explain who will investigate, and give an expected timescale for the investigation. We aim to complete investigations within 20 working days where possible, but more serious or complex matters may take longer. Where a concern relates to an immediate risk to the health or safety of any person, we will take interim protective measures straight away, before the investigation is complete. The investigation will be proportionate and may include interviews, document reviews, and consultation with external advisers or regulators where appropriate. We will make sure the investigation is independent, meaning the person investigating will have no personal involvement in the matter being investigated.
Feedback to whistleblowers
We will keep you informed about the progress of the investigation and its outcome, as far as we are able to without breaching confidentiality owed to other people. As a minimum, we will acknowledge your concern within 5 working days, provide an update within 20 working days, and tell you the outcome of the investigation once it is complete. If we cannot share certain details due to data protection or confidentiality, we will explain that to you. Where your concern was raised anonymously, we will not be able to provide individual feedback, but we will still act on the concern.
Malicious or bad-faith disclosures
This policy is designed to protect workers who raise genuine concerns in good faith. If someone raises a concern they reasonably believe to be true, no action will be taken against them even if the investigation finds the concern was mistaken. However, if an investigation finds that a disclosure was made maliciously, in bad faith, or with the deliberate intention of causing harm to another person, we may treat this as a disciplinary matter under our Code of Conduct. A disclosure is not malicious simply because it turns out to be unfounded. We will only consider disciplinary action where there is clear evidence that the person knew the allegation was false or intended to cause harm.
Record keeping
We keep a confidential written record of every concern raised under this policy. The record includes the date the concern was raised, a summary of the concern, how it was raised (including whether it was anonymous), who investigated, the steps taken during the investigation, the outcome, any action taken as a result, and feedback given to the person who raised the concern. These records are stored securely and access is restricted to the Director and, where relevant, the independent HR adviser. Whistleblowing records are retained for 6 years from the closure of the investigation, in line with our Privacy Policy and the Limitation Act 1980. The legal basis for processing personal data in whistleblowing records is legal obligation under Article 6(1)(c) of the UK General Data Protection Regulation (UK GDPR), and where special category data is involved, substantial public interest under Article 9(2)(g) and Data Protection Act 2018 Schedule 1 Part 2.
Annual reporting
The Director reviews whistleblowing activity annually. This review includes the number of concerns raised during the year, the types of concerns raised (without identifying individuals), the outcomes of investigations, any patterns or trends, and any improvements made as a result. Where we work under council contracts, we will share anonymised whistleblowing data with council partners on request, as part of our commitment to transparency and good governance.
External reporting
If you are not satisfied with our response, or if you feel unable to raise the concern internally, you have the right to make a protected disclosure to a prescribed person or body under the Employment Rights Act 1996 s.43F and the Public Interest Disclosure (Prescribed Persons) Order 2014. A full list of prescribed persons is available at gov.uk. Relevant bodies for our type of work may include the Health and Safety Executive (HSE), the Care Quality Commission (CQC), the local authority safeguarding team, the Information Commissioner's Office (ICO), His Majesty's Revenue and Customs (HMRC), the Environment Agency, and the police. You do not have to raise a concern internally before going to an external body. Your legal protections under the Employment Rights Act 1996 apply whether you report internally or externally. You can also seek confidential advice from Protect (formerly Public Concern at Work) on 020 3117 2520 or at protect-advice.org.uk.
Related policies
This policy should be read alongside our Safeguarding Policy, which covers how we identify and respond to safeguarding concerns; our Code of Conduct, which sets out the standards of behaviour expected of all workers; our Complaints Procedure, which covers how we handle complaints from clients and the public; our Anti-Bribery and Corruption Policy, which covers our approach to preventing bribery and corruption; our Equality and Diversity Policy, which confirms our commitment to fair treatment; our Privacy Policy, which explains how we handle personal data including whistleblowing records; and our Health and Safety Policy, which covers workplace safety concerns.
Changes to this policy
We may update this policy from time to time to reflect changes in legislation, guidance, or best practice. Any changes will be posted on this page with an updated date. Where we make material changes that affect how concerns are raised, investigated, or how whistleblowers are protected, we will notify all workers directly. We encourage you to review this policy regularly.
Review
The Director, Lance James, reviews this policy annually. We make all workers aware of this policy during induction and through regular reminders. Last reviewed: February 2026. Next review due: February 2027.
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