1. General 

1.1. Pathway Fund, particularly in its role as a Funder/ Investor, as well as in its other roles as a Knowledge Builder, a Convener and Influencer, and a Visionary, aims to be fair and meet the highest practical standards of practice. However, we recognise that our practices may not always meet the expectations of our stakeholders and that we can always improve our work. 

1.2. We welcome feedback from our stakeholders in the form of comments, suggestions or complaints.  

1.3. This policy sets out the procedure for Pathway stakeholders to send any comments, suggestions or complaints to Pathway and outlines what they can expect from the process.  

1.4. The overall responsibility of this policy and its implementation lies with the Chief Operating Officer (COO). Any queries related to this policy and its application should be directed to the COO by emailing impact@pathwayfund.org.uk  

2. Purpose of this policy 

2.1. To publish a clear and informative procedure that is easily accessible to relevant stakeholders, so that stakeholders know how to contact Pathway to share their feedback and/or complaint. 

2.2. To ensure that Pathway team members are aware of and equipped to take action when a feedback and/or complaint is received. 

2.3. To ensure that Pathway, as an accountable organisation, reviews all feedback and complaints fairly and in a timely manner.  

2.4. To support Pathway’s ongoing learning and improvement. 

3. Who and What is covered within this policy 

3.1. Pathway’s key stakeholders can send their feedback and complaints in accordance with this policy, this includes funders, co-investors, applicants, deployment partners, grantees, suppliers, and contractors. This includes stakeholders in Pathway’s value chain and supply chain, such as applicants and portfolio enterprises to funding programmes administered by Pathway’s deployment partners as well as suppliers to Pathway’s programmes and funds. 

3.2. This policy does not cover complaints from Pathway’s team, governance or outsourced consultants that are part of Pathway’s organisational structure, such as outsourced HR, IT, accounting or EA support providers. Pathway’s team, governance and outsourced consultants must use Pathway’s internal Grievance Policy and Disciplinary Procedure. 

3.3. Stakeholders may provide feedback and complaints about the actions of Pathway and/or its representatives such as team members and representatives, in accordance with this policy. If a stakeholder wishes to make a comment or complaint about the work of an organisation that Pathway funds or works with, for example a deployment partner, this should be raised directly with said organisation following their policy and procedure and may be escalated to the relevant regulator. However, if the stakeholder wishes to make Pathway aware of any issue with one of Pathway’s partner organisations, they can notify Pathway by emailing impact@pathwayfund.org.uk and the relevant programme team member (if known to the stakeholder). The feedback will be considered by programme or investment teams and escalated to leadership if necessary, however it may not be treated as a formal feedback or complaint under this policy.  

3.4. Stakeholders may file a complaint if they are dissatisfied with Pathway’s work, the actions or lack of actions by Pathway team members and if they believe that Pathway has not met its expected standards of service, has treated them unfairly, has not followed its own processes, or has provided incorrect or misleading information. However, any decision where Pathway has followed proper procedure but come to a decision that a stakeholder may disagree with, is not covered by this policy. A stakeholder may only complain about a decision, for example a funding decision, if they have evidence to support suspicion of unfairness, maladministration or other extenuating circumstances.  

3.5. Any feedback or complaint that is judged to be vexatious may also not be treated as a valid feedback or complaint under this policy. A complaint made with the intention of harassing, annoying or subduing someone can be considered vexatious; furthermore, Pathway may also consider the following types of complaints as vexatious: any complaint that is unreasonable and persistent, including if the complaint has already been investigated; complaints that may lack foundation, showcase uncooperative behaviour, include excessive demands, include abusive or offensive language, use falsified document or irrelevant information, or seek to replace staff or partners.  

4. Providing a Suggestion to Pathway 

4.1. A stakeholder who wishes to provide a suggestion proposing an improvement to Pathway’s systems and ways of working are welcome to do so by emailing impact@pathwayfund.org.uk. Pathway team shall review any suggestions received as part of its continued learning and development. Pathway team may not respond to a suggestion, unless further clarity is needed on the matter. 

5. Making a Complaint to Pathway 

5.1. If the stakeholder who wishes to make a complaint to Pathway is an applicant to Pathway or a deployment partner/ fund manager of Pathway, they should, in the first instance, contact the Pathway team member they have dealt with, for example the programme team or investment team member. However, if they don’t have direct contact with the relevant Pathway team member, they may send their complaint by emailing impact@pathwayfund.org.uk.  

5.2. If the stakeholder who wishes to make a complaint is a grantee/ investee of a Pathway deployment partner or fund manager, they may in the first instance contact the relevant team member at the deployment partner or fund manager, following their complaints policy and if needed requesting the deployment partner or fund manager to escalate the issue with Pathway. If the issue remains unresolved, the stakeholder may send a direct complaint to Pathway by emailing the relevant programme or investment team member at Pathway, if known, or by emailing impact@pathwayfund.org.uk. 

5.3. Any other stakeholder wishing to make a complaint may do so by emailing impact@pathwayfund.org.uk. 

5.4. Stakeholders wishing to make a complaint should endeavour to send clear and concise complaints covering relevant details, including full name, name of their organisation, relationship of the organisation to Pathway and contact details.  

6. Confidentiality  

6.1. All information shared by a stakeholder making a complaint to Pathway will be handled sensitively and will only be shared on a need-to-know basis. Relevant data protection requirements will be followed by Pathway in processing any complaint. 

7. Resolving Complaints 

7.1. Any complaint received by Pathway, either directly by a team member or via email to impact@pathwayfund.org.uk shall be acknowledged within five working days. The acknowledgement shall include information on who is handling the complaint and if possible, when they can expect a response. All complaints will also be notified to the CEO within five working days of receipt.  

7.2. At first instance the key person at Pathway, for example the relationship holder from the programme or investment team, shall endeavour to resolve the issue swiftly if it is possible and appropriate to do so, but no later than four weeks from receipt. They should respond to the complaint with a description of the actions taken to review the complaint and if appropriate any actions resulting from the complaint. If it is not possible to resolve the issue within the prescribed timeframe either due to need for further information or if the investigation has not been completed, the relationship holder/ responsible team member shall notify the stakeholder making the complaint with an indication of when the final response can be expected. 

7.3. If the stakeholder making the complaint is not satisfied with the outcome or the response from Pathway team, they may escalate it to Pathway’s COO either by emailing them directly or by emailing impact@pathwayfund.org.uk marking the correspondence for the attention of the COO, who may further escalate the complaint to the CEO if relevant. At this instance, Pathway leadership shall review and respond to the complaint no later than eight weeks from escalation or notify of any potential delay and an indication of when the final response can be expected. 

7.4. The final responses at each stage of the resolution process can: 

Uphold the complaint and offer redress 

Offer redress without upholding the complaint 

Reject the complaint and explain why 

7.5. If at any stage, the stakeholder making the complaint does not respond to Pathway’s final response within four weeks, Pathway shall consider that they are satisfied with the response they have received.  

Policy last reviewed: June 2025