LEARNER COMPLAINTS
PROCEDURE

1. AIM

Brightbeam AI Limited ("Brightbeam") is committed to delivering high-quality learning programmes that meet the needs of every participant. We recognise that on occasion a learner may feel that the service they have received has fallen short of their expectations.

The purpose of this procedure is to:

• Provide a clear, accessible, and fair route for any learner to raise a complaint

• Ensure complaints are handled promptly, consistently, and without prejudice

• Enable Brightbeam to learn from feedback and continuously improve programme quality

• Demonstrate our accountability to learners, clients, and regulatory stakeholders

This procedure covers all dissatisfied learners participating in any Brightbeam-delivered programme, including AI Embed programmes, training sprints, coaching sessions, and capstone projects, regardless of whether the engagement is contracted directly by the learner or through a corporate client.

2. POINT OF CONTACT

All complaints should be directed to the designated Learner Complaints Lead. This individual is responsible for receiving, logging, and managing the complaints process from initial acknowledgement through to resolution.

Learner Complaints Lead
Name: Claire Iles
Role: Ops Lead - Embed
Email: embed@Brightbeam.com
Website: www.Brightbeam.com
Escalation contact: Scott Wilkinson - scott.wilkinson@Brightbeam.com

Where the complaint involves the Learner Complaints Lead directly, the learner should address their complaint to the escalation contact at the email address listed above.

3. PROCEDURE FOR LODGING A COMPLAINT

3.1 Time limit

Complaints must be raised within three (3) months of the event or issue giving rise to the complaint, or within three (3) months of the learner becoming aware of the issue. Brightbeam reserves the right to decline to investigate complaints raised outside this period, except where there are exceptional circumstances, which will be considered at the discretion of the Head of Operations.

3.2 How to lodge a complaint

Brightbeam encourages learners to attempt to resolve concerns informally in the first instance by speaking with their assigned coach, trainer, or the Brightbeam Project Lead for their programme. This informal step is not mandatory; learners may proceed directly to a formal complaint if they prefer.

To lodge a formal complaint, the learner should:

1. Contact the Learner Complaints Lead by email at embed@Brightbeam.com

2. Use the subject line: "Formal Learner Complaint - [Programme Name] - [Your Name]"

3. Include in the body of the email: (a) your full name and organisation; (b) the programme and dates of attendance; (c) a clear description of the complaint; (d) the outcome you are seeking; and (e) any supporting evidence or correspondence

Complaints may also be submitted in writing to: Brightbeam AI Limited, The Minaun, Faithlegg, Co. Waterford, Ireland, X91 T3P9.

3.3 Complaint handling

On receipt of a formal complaint, Brightbeam will:

• Log the complaint in the confidential complaints register

• Assign an investigating officer (a member of the operations team who was not directly involved in the matter complained of)

• Gather relevant documentation, including programme records, communications, and feedback data

• Where appropriate, invite the complainant to speak with the investigating officer to clarify the issues

• Prepare a written response setting out findings, conclusions, and any action to be taken

Complaints will be handled confidentially. Information will only be shared with those who need to know in order to investigate and resolve the matter.

4. RESPONSE TIMESCALES

Brightbeam is committed to responding to all complaints promptly. The following timescales apply:

• Acknowledgement — Timescale: Within 5 working days. Action: Written acknowledgement sent to complainant confirming receipt.

• Initial response — Timescale: Within 10 working days. Action: Substantive written response addressing the complaint.

• Full investigation — Timescale: Within 20 working days. Action: Full written response with findings, outcome, and any remedial actions.

• Appeal decision — Timescale: Within 15 working days of appeal lodged. Action: Written outcome of appeal with reasoning.

Where Brightbeam is unable to meet a stated timescale - for example due to the complexity of the investigation or the need to obtain third-party information - the complainant will be notified in writing of the revised expected timescale and the reason for the delay. Working days are Monday to Friday, excluding Irish public holidays.

5. OUTCOME AND APPEALS

5.1 Outcomes

Following investigation, Brightbeam will issue a written outcome letter that:

• Summarises the complaint as understood

• Sets out the findings of the investigation

• States Brightbeam's decision and the reasoning behind it

• Describes any remedial action Brightbeam will take (which may include, but is not limited to, a partial or full refund, re-delivery of a session, additional coaching, or a revised programme schedule)

• Confirms the right of the complainant to appeal

5.2 Appeals

If the complainant is not satisfied with the outcome, they may appeal in writing to the escalation contact within ten (10) working days of receipt of the outcome letter. The appeal should set out:

• The specific grounds for appeal (for example, procedural irregularity, new evidence, or a conclusion not supported by the evidence)

• Any additional supporting information

The escalation contact (or a suitably senior individual not previously involved in the complaint) will review the appeal and issue a written decision within fifteen (15) working days of receipt. The escalation contact's decision is final.

Appeals contact
Appeals should be emailed to: scott.wilkinson@Brightbeam.com with the subject line "Learner Complaint Appeal - [Programme Name] - [Your Name]"

6. EQUITY AND DIVERSITY STATEMENT

Brightbeam AI Limited is firmly committed to equality of opportunity and to creating an inclusive environment where every learner is treated with dignity and respect. This commitment is grounded in our Diversity and Inclusion Strategy and reflects the values that underpin all our work.

We will ensure that:

• Every complaint is taken seriously and investigated on its merits, without regard to the complainant's age, gender, race, ethnicity, nationality, disability, sexual orientation, religious beliefs, or any other protected characteristic

• No learner is disadvantaged, penalised, or treated less favourably as a result of raising a complaint in good faith

• Reasonable adjustments are made to this procedure where necessary to ensure accessibility for learners with disabilities or communication needs when given adequate notice in advance.

• All those involved in handling complaints receive appropriate training on unconscious bias and equitable decision-making

Brightbeam adheres to the Employment Equality Acts 1998-2015 and the Equal Status Acts 2000-2018, as well as applicable UK equality legislation for programmes delivered in the United Kingdom. We are committed to integrating best practice from international frameworks, including the UN Global Compact and International Labour Organization standards.

If you believe your complaint has not been handled equitably, you should state this explicitly in your complaint or appeal. Brightbeam takes allegations of discriminatory treatment in the complaints process with the utmost seriousness.

7. MONITORING, REVIEW AND RESPONSIBILITIES

7.1 Complaints register

All formal complaints are logged in a confidential complaints register maintained by the Embed Ops Lead. Each entry records: date received, complainant details (anonymised for reporting purposes), nature of complaint, programme involved, investigation timeline, outcome, and any remedial action taken.

7.2 Monitoring and reporting

The Embed Ops Lead will:

• Review the complaints register quarterly to identify patterns, recurring issues, or systemic concerns

• Prepare an annual summary report for the CEO and COO, including the number of complaints received, nature, outcomes, average resolution time, and lessons learned

• Use complaint data to inform programme quality improvements, trainer development, and policy updates

Complaint data will be retained for a minimum of five (5) years in accordance with Brightbeam's data protection obligations under the General Data Protection Regulation (GDPR) and applicable Irish and UK data protection law.

7.3 Policy review

This policy will be reviewed annually, or sooner in the following circumstances:

• A significant change in Brightbeam's programme offering or delivery model

• A change in applicable legislation or regulatory guidance

• A complaint or pattern of complaints that reveals a gap in the procedure

• A request from a client, regulatory body, or accreditation authority

The Embed Ops Lead is responsible for initiating and completing the review. Revisions require approval from the CEO and must be logged in the document control record.

7.4 Responsibilities

• CEO (Brian Hanly) — Final approval of policy; appeal decisions; escalation point

• Head of Operations (Marli van Sittert) — Policy ownership; policy review

• Embed Ops Lead — Complaints receipt and log; investigation oversight; annual reporting; policy review

• COO — Second-line escalation; policy sign-off

• Project Leads / Trainers / Coaches — Informal resolution; co-operation with investigations; adherence to this procedure

• All Brightbeam staff — Awareness of this procedure; prompt referral of any learner concerns to the Head of Operations

8. COMMUNICATION OF THIS POLICY

Brightbeam is committed to ensuring that every learner is aware of their right to raise a complaint and knows how to do so. This policy is communicated as follows:

• Published on the Brightbeam website at www.Brightbeam.com, where it is freely accessible to all current and prospective learners

• Provided to all learners in the programme welcome pack at commencement of any Brightbeam-delivered programme

• Referenced in all Statements of Work issued to client organisations, directing their nominated learners to the published policy

• Made available on request from the Head of Operations at go@Brightbeam.com

• Summarised in learner onboarding communications to ensure visibility from day one

Brightbeam will update the published version on the website whenever this policy is revised, and will notify active learners of material changes by email.

Brightbeam AI Limited - The Minaun, Faithlegg, Co. Waterford, Ireland, X91 T3P9 - www.brightbeam.com