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Whistleblowing Policy

Whistleblowing Policy

This Whistleblowing Procedure provides a mechanism for any person to alert CTHS on an anonymous basis of any conduct that may relate to manipulation of STAR MI Submissions by participants or STAR Accreditation Award administered by CTHS (STAR).  

CT Holdings & Services Ltd (‘CTHS‘) is a joint venture between TISA Exchange (TeX) and Criterion Tec as a not-for-profit organisation to deliver STAR for the industry. This will include agreeing Service Level Definitions for completing a transfer and measuring performance against those targets through the accreditation of STAR participants and the STAR Accreditation Awards.

If you wish to make a disclosure to CTHS, the contact details are respectively in sections 5 and 6 below. You may make a disclosure on an anonymous basis, however this may make the disclosure more difficult to investigate, or in some cases impossible.  Nonetheless anonymous disclosures will be investigated if possible to do so.

You should consider making a disclosure if you have reasonable belief that the information you would disclose indicates manipulation of the data or resultant STAR Accreditation Award administered by CTHS – whether manipulation has potentially or actually occurred, is occurring or is likely to occur.  

You should also consider making a disclosure if you have reasonable belief that information submitted by another STAR participating organisation indicates manipulation of the data or resultant STAR Accreditation Award administered by CTHS – whether manipulation has potentially or actually occurred, is occurring or is likely to occur.  

If the disclosure would be in relation to your current employer, you should consider making a disclosure under your employer´s whistleblowing policy where one exists. You should still consider reporting your concerns to your employer even if they do not have a whistleblowing policy.

You may wish to seek advice from the whistleblowing charity Protect, which aims to protect society by encouraging workplace whistleblowing. If you are in the UK, Protect’s free and confidential Protect Advice Line can be contacted on +44 (0)20 3117 2520 or by email to whistle@protect-advice.org.uk.  If you live outside the UK, Protect suggests that you contact your trade union, a lawyer or, if there is one in your country, an organisation that specialises in advising Whistleblowers.  Protect’s website contains contact details for other Whistleblower organisations.

On receipt of your whistleblowing disclosure, we will first check whether the disclosure relates to information that manipulation, or attempted manipulation, of a STAR Accreditation Award administered by CTHS has occurred, is occurring or is likely to occur.  

If we consider that the information does not relate to potential manipulation of a STAR Accreditation Award administered by CTHS, we will advise you accordingly if your identity and contact details are known to us.

Where the information does relate to potential manipulation of a STAR Accreditation Award administered by CTHS, we will acknowledge the disclosure if your identity and contact details are known to CTHS.  

CTHS will then seek to investigate whether the whistleblowing information can be substantiated. 

If you have requested anonymity but your identity and contact details are known to CTHS, we will take reasonable steps to keep your identity confidential.  However, there are circumstances in which, because of the nature of the investigation or disclosure, it will be necessary to disclose a person’s identity – for example, in connection with associated legal or regulatory investigations or proceedings. If in CTHS’s view such circumstances exist, we will seek to inform you that your identity is likely to be disclosed. We will not disclose your identity unless we are required to do by the FCA or otherwise by the operation of law.

Where we concur that manipulation has potentially or actually occurred, is occurring or is likely to occur, CTHS will refer the allegation to the STAR Accreditation Committee and we will generally provide to the STAR Accreditation Committee the results of our investigatory work on the matter. 

If you make a whistleblowing disclosure to CTHS, we expect you to respect confidentiality and to refrain from making the information known to persons who do not have a legal or regulatory role relating to the disclosure.

CTHS will take all reasonable steps to protect you if you make a disclosure from any detriment including victimisation or criticism.

Please note that disclosures cannot be withdrawn once received by CTHS.

The Board of Directors of CTHS and the STAR Steering Group receive an anonymised summary at least yearly of any whistleblowing disclosures made to CTHS, together with an analysis of whether the information in a disclosure was substantiated.  All disclosures included in the summary will be fully anonymised.

We will retain all whistleblowing records for at least seven years. 

CT Holdings & Services Limited registered office is at Regent’s Court, Princess Street, Hull, HU2 8BA  

Email: whistleblowing@joinstar.co.uk

You may wish to raise your concerns with the FCA as the regulator prescribed in respect of financial services and markets matters under the Public Interest Disclosure Act 1998 (PIDA).   

The FCA would encourage you first to use the whistleblowing procedures in your workplace. 

The PIDA is available at http://www.legislation.gov.uk. 

You can telephone the FCA on +44 (0)20 7066 9200 during office hours or leave a message on voicemail and, if you wish, they will ring you back. 

The FCA’s other contact details for whistleblowing are:

Enforcement and Financial Crime Division (ref PIDA) Financial Conduct Authority 12 Endeavour Square London E20 1JN Email: whistle@fca.org.uk

This Whistleblowing Procedure is reviewed at least annually by the CTHS Board.   

© 2022 CT Holdings and Services Limited (CTHS), a joint venture between TISA Exchange Limited and Criterion Tec Limited.

All rights reserved. Company number: 11700872.

SERVICING AGREEMENT

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A problem was detected in the following Form. Submitting it could result in errors. Please contact the site administrator.
1. APPLICANT COVERED BY THIS REGISTRATION.
Please note this registration will not be processed if Step 1 has not been completed.
If your organisation is acting only as an affiliate, you do not need to complete Step 2.
2a. CHOOSE YOUR BRAND
STAR manages the administration of third-party access to the portal, rather than the member firm. This allows for a smoother transition for the member firm and allowing immediate access to the supplier to submit MI on their behalf. STAR will hold an approved list of users per supplier, which will be allocated to your account at the point of registration. This ensures each ‘external’ user has the same access across all their client accounts. Supplier access is restricted and they do not have any ability to see any company information for any client other than what they submit on your behalf. You as the member control access for any other users within your organisation. We will include a more detailed description about the user access on your welcome email and it is clearly defined as part of the User Guide.
STAR RELATIONSHIP MANAGER FOR FIRST BRAND
This person will be the main contact for all notices and other formal communications under this agreement and will be responsible for the administration of the members portal access (including without limitation the providing, updating and removing of authorised User access to the portal during the Term).
2b.
STAR RELATIONSHIP MANAGER FOR THE SECOND BRAND
This person will be the main contact for all notices and other formal communications under this agreement and will be responsible for the administration of the members portal access (including without limitation the providing, updating and removing of authorised User access to the portal during the Term).
2c.
STAR RELATIONSHIP MANAGER FOR THE THIRD BRAND
This person will be the main contact for all notices and other formal communications under this agreement and will be responsible for the administration of the members portal access (including without limitation the providing, updating and removing of authorised User access to the portal during the Term).
2d.
STAR RELATIONSHIP MANAGER FOR THE THIRD BRAND
This person will be the main contact for all notices and other formal communications under this agreement and will be responsible for the administration of the members portal access (including without limitation the providing, updating and removing of authorised User access to the portal during the Term).
3. INVOICE INFORMATION
Invoices are sent by email as standard, if a printed invoice is required please note the address and your requirements in the additional information section.
4. DECLARATION
Before we can process your Brand Registration a STAR Servicing Agreement needs to be signed. Your signatory must be duly authorised for and on behalf of the organisation named in this application.
We only need one signed STAR Servicing Agreement which will cover all brands that you wish to register.
STAR will email the servicing contract to the signatory email address (provided below) through our electronic platform Yoti. This declaration must be signed in order for your application to complete, once we receive the signed agreement we will instruct our finance department to issue your invoice.
You have already supplied a STAR Servicing Agreement, we will be in touch if we need anything else.

Application submitted successfully

Thank you for applying to join the STAR accreditation scheme. We will endeavour to respond as soon as possible using the contact information you’ve provided to us.