External Stakeholder Grievance & Complaints Policy
1. Purpose
Sullivan & Stanley (“S&S”) is committed to conducting its business ethically, transparently, and responsibly. This policy sets out how clients, associates, suppliers, contractors, business partners, and members of the public (“external stakeholders”) can raise a grievance or complaint about S&S's conduct or operations, and describes the process S&S follows to review, investigate, and resolve such grievances fairly.
This policy operates alongside S&S's internal Grievance Procedure, which covers employees, workers, and contractors. Together, the two policies ensure that anyone affected by S&S's business - whether inside or outside the organisation - has a clear route to raise a concern and receive a response.
This policy, together with the dedicated grievance channel set out in Section 3, is published on Sullivan & Stanley's website, giving clients, associates, suppliers, contractors, business partners, and members of the public a clear and accessible means to raise a grievance about Sullivan & Stanley's conduct or operations at any time.
2. Scope
This policy applies to grievances raised by:
Clients and prospective clients
Associates, consultants, and contractors engaged by S&S who are not directly employed
Suppliers and vendors
Business partners
Members of the public affected by S&S's operations
It covers concerns about S&S's own conduct, including (but not limited to) the quality or delivery of services, ethical or professional standards, breaches of policy or contractual obligation, and environmental or social impact.
This policy does not cover employee grievances relating to their own employment, which are handled under S&S's internal Grievance Procedure, or matters more appropriately addressed through a separate commercial dispute resolution clause in a signed contract.
3. How to Raise a Grievance
External stakeholders can raise a grievance at any time by contacting S&S using the following channel:
Where possible, please include a description of the concern, relevant dates, names of individuals involved, and any supporting evidence. Grievances may be submitted anonymously; however, S&S's ability to investigate and provide a direct response may be limited where a complainant's identity and contact details are not known.
4. Grounds for Accepting a Grievance
S&S will accept a grievance for investigation where it relates to S&S's own conduct or operations and is not more appropriately dealt with under another process (for example, a commercial dispute resolution clause in an existing contract, or an ongoing legal proceeding).
A grievance may not be accepted where, for example, it:
Falls outside the scope of this policy as set out in Section 2;
Has already been fully addressed through another process or contractual mechanism;
Concerns a legitimate commercial, contractual, or operational decision made by S&S, rather than an allegation of unethical or unlawful conduct;
Is trivial in nature, or reflects dissatisfaction or disagreement that is not supported by any evidence of actual wrongdoing;
Does not contain sufficient information for S&S to investigate; or
Is raised in a manner that is abusive, vexatious, or clearly without foundation.
5. Grievance Process and Timelines
Stage 1 - Acknowledgement
S&S will acknowledge receipt of a grievance within 3 business days, unless it has been submitted anonymously.
Stage 2 - Initial Review
Within 10 business days of acknowledgement, S&S will assess whether the grievance is accepted for investigation and, where accepted, assign a named individual to oversee it.
Stage 3 - Investigation
Where a grievance is accepted, S&S will carry out a fair and impartial investigation, aiming to conclude within 30 calendar days of acceptance. Where this is not possible due to the complexity of the matter, the complainant (where contactable) will be updated on progress at least every 10 business days, even where there is no material change to report.
Stage 4 - Resolution
On conclusion of the investigation, S&S will communicate the outcome in writing to the complainant (where contactable), including any action taken. Where a grievance is not accepted under Section 4, S&S will provide a written explanation of the reason within the same timeframe as Stage 2.
6. Communication and Updates
Except where a grievance has been submitted anonymously and no contact details are available, S&S will keep the complainant informed at each stage of the process described in Section 5, culminating in a written outcome or a written rationale where the grievance was not accepted.
7. Actions Following Investigation
Where an investigation finds that a third party - such as a supplier, contractor, or client - has acted unethically, illegally, or in breach of S&S's policies, S&S may:
Terminate the relevant contract or engagement;
Report the matter to the relevant regulatory or professional body; and/or
Decline to enter into future business with the party concerned.
Where an investigation finds fault with S&S's own conduct, S&S will take appropriate corrective action and, where relevant, update its internal policies or procedures to prevent recurrence.
8. Protection from Retaliation
S&S will not retaliate against any external stakeholder for raising a grievance in good faith, regardless of the outcome of the investigation. Retaliation includes, but is not limited to, termination or non-renewal of a contract, refusal of future business, or any other form of detriment connected to the grievance having been raised.
Any S&S employee, worker, or contractor found to have retaliated against an external stakeholder for raising a grievance in good faith will be subject to disciplinary action under S&S's internal Disciplinary Policy, up to and including dismissal.
9. Confidentiality
S&S will treat grievances confidentially so far as reasonably possible. Information may need to be shared with individuals directly involved in investigating and resolving the grievance, but access will otherwise be restricted to those who need it to carry out the investigation.
10. Data Protection
Any personal data collected from external stakeholders as part of a grievance will be processed in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and S&S’s Data Protection Policy. Personal data will only be collected, used, and shared where necessary to investigate and resolve the grievance, comply with legal obligations, or protect the rights of those involved.
11. Policy Availability and Review
This policy is published on S&S's website and may also be referenced in client, supplier, and partner contracts and onboarding materials. It will be reviewed annually, or sooner in response to significant legal, regulatory, or organisational change.