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PURPOSE
This policy describes Royal Mail Group Ltd response to crime and suspected crime against
the organisation.
LINK TO ACCOUNTABILITIES
Criminal Investigation Team
PO Ltd Investigation Team
PFWW Investigation Team
Criminal Intelligence and Support Team
Planning and Development Team
Criminal Lawyers
POLICY
Policy
Royal Mail Group will investigate crime and suspected crime against the organisation, identify
offenders, highlight factors that facilitated crime and take appropriate action - not excluding
prosecution
3.1.1 Protecting the Integrity of the Mail
This policy supports the Postcomm Code of Practice “Protecting the Integrity of the Mail”
section 6.3 (c) in preventing and detecting criminal loss, theft and interference with ‘Code
Postal Packets’.
3.1.2 Protecting the Business
This policy supports paragraphs 15, ‘Security and Trust’ and 22, ‘Preventing and Reporting
Crime’ in the Code of Business Standards. Furthermore, in highlighting crime facilitators,
investigations will identify (i) non-compliance with security procedures, (ii) non-compliance
with the code of business standards (iii) poor management and (iv) shortcomings in physical
security.
3.1.3 Policing Crime
Royal Mail Group Security Investigation Teams are the providers of in-house investigations
and will maintain the lead in all dealings with the Police.
3.1.4 Conduct of Investigations
The conduct, course and progress of an investigation will be a matter for the investigators as
long as it is within the law, rules and priorities of the business. Investigators will ultimately
report to the Director of Security with regard to the conduct of criminal investigations.
3.1.5 Role of Royal Mail Employees
Royal Mail employees are expected to maintain a high standard of integrity and whatever
their position in the company, are expected to assist investigators with their inquiries.
Employees have a duty to:
(i) report crime against the business and suspicion of crime against the business to
Policy Title S02 Royal Mail Group Criminal Investigation and Prosecution Policy
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3.2
the Security Helpdesk; GRO Crimestoppers on
' GRO _ [even if the employee wishes to remain anonymous
(i) WW ‘the company if they are charged, cautioned, summonsed or
convicted in connection with any criminal offence.
3.1.6 Prosecuting Criminals
This policy supports the Code of Business Standards in normally prosecuting those who
commit theft or fraud and where appropriate offences against the Postal Services Act 2000
Sections 83 and 84.
Criminal investigations will be conducted in accordance with the procedures and to the
standards required by legislation, case law and the courts.
3.1.7 Procedures and Standards
Criminal investigations will be conducted in accordance with legal powers, restrictions and
guidelines provided by the government or governed by Royal Mail policies (see para 3.2).
Procedures and Standards
3.2.1 Gathering Intelligence
Investigators and colleagues in Criminal Intelligence will adhere to the principles of the Data
Protection Act 1998, The Data Protection (Processing of Sensitive Personal Data) Order
2000 and the Code of Practice for the Management of Police Information when acquiring,
retaining, storing and disclosing intelligence.
The P6 process will be adhered to when accessing the computer or official telephone records
of employees.
As the Communications Data Order 2003 scheduled Royal Mail as a public authority for the
purposes of the acquisition of communications data, the Regulation of Investigatory Powers
Act (RIPA) Code of Practice for the Acquisition and Disclosure of Communications Data will be
adhered to for the purposes of RIPA Part 1 Chapter 2.
Anonymous informants will be recorded on the Information Source Register. The Police will
handle any person likely to become a Covert Human Intelligence Source and investigators
will adhere to the Covert Human Intelligence Sources Code of Practice.
3.2.2 Conducting Enquiries and Exhibit Management
Evidence will be gathered and retained in accordance with the Criminal Procedure And
Investigations Act 1996 (S. 23(1)) Code Of Practice.
3.2.3. Safety and Planning
In accordance with The Management of Health and Safety at Work Regulations 1999, a Safe
Working Practices Committee will conduct an annual risk assessment of investigatory duties
reviewing existing, and setting new controls and measures where required. investigators will
adhere to these controls and measures.
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Investigators will plan for and assess the risks of all investigation operations (with the
exception of responses to immediate events) using the PORA operational planning tool:
Planned Operation Risk Assessment.
3.2.4 — Surveillance and Testing’
The Regulation of Investigatory Powers Act 2000 Schedule 1 Part 2 lists Royal Mail as a
public authority for the purpose of conducting directed surveillance. Directed surveillance will
be carried out according to the Regulation of Investigatory Powers Act 2000 Part 2 and the
Covert Surveillance Code of Practice
Where appropriate ‘tests’ may be applied to the honesty of individuals suspected of crime.
Authorised ‘testing’ will be carried out in accordance with investigation guidelines.
3.2.5 Approach and Arrest
Suspects will be dealt with in accordance to the Police and Criminal Evidence Act 1984, in
particular the ‘Code Of Practice For The Detention, Treatment And Questioning Of Persons
By Police Officers’.
3.2.6 Interviewing
Suspects will be interviewed in accordance to the Police and Criminal Evidence Act 1984, in
particular the ‘Code Of Practice On Tape Recording Interviews With Suspects’. Suspects who
are employees are entitled to the additional rights provided for in the Royal Mail Conduct
Code.
3.2.7 Searching
Searches will be carried out in accordance to the Police and Criminal Evidence Act 1984, in
particular the ‘Code Of Practice For Searches Of Premises By Police Officers And The Seizure
Of Property Found By Police Officers On Persons Or Premises’. Suspects who are employees
are entitled to the additional rights provided for in the Royal Mail Conduct Code.
3.2.8 Casework
Investigations leading to potential prosecution will be reported in accordance with the
Criminal Procedure And Investigations Act 1996 and the Criminal Procedure And
Investigations Act 1996 (S. 23(4)) Code Of Practice.
3.2.9 Prosecution
Suspect offenders will be prosecuted where there is sufficient evidence and it is in the public
interest in accordance with the Code for Crown Prosecutors. Decisions to prosecute in non-
Crown Prosecution Services cases will be taken by nominated representatives in the business
with consideration to the advice provided by the Royal Mail Group Criminal Law Team:
3.2.10 Conduct and Oversight of Investigations
Royal Mail Group Security employees perform a vital role on behalf of the public, the Criminal
Justice system and Royal Mail Group Ltd customers and employees. These stakeholders
must have absolute confidence in the integrity, conduct and professional status of
Investigators.
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This means adherence to the laws, regulations and codes along with their respective
Procedure and Standards referred to above.
Complaints should be forwarded in the first instance to either the Head of Investigations
(Royal Mail, PFWW or POL) or to the Complaint Manager (RMLS Policy, Standards and
Investigation Support Manager) or his nominated deputy for initial assessment and selection
of the business procedure, namely Criminal Investigation, Grievance Procedure, Conduct
Code or the Bullying and Harassment procedure.
3.2.11 Scots Law and Northern Ireland
Paragraphs 3.1 to 3.2.10 all apply to Scotland and Northern Ireland except where specifically
articulated in Scots law, Northern Ireland Statutory Instruments or by the Northern Ireland
Assembly, Procurator Fiscal or Director of Public Prosecution (NI) guidelines.
3.2.12 Post Office Ltd Investigation
While adhering to legislative and group policy requirements, the POL Investigation team have
additional and, in some cases, alternative Procedures and Standards, and supporting
documentation with which Post Office Ltd colleagues will comply. Post Office Ltd Investigation
team will maintain a separate casework procedure and database.
4. Deployment
This Policy is published on the Royal Mail Intranet site as policy No. S2
The procedures to investigate crime against the Royal Mail Group have been in existence for
many years and are regularly reviewed in response to changes in legislation.
Investigation Procedures and Standards relating to this policy are included in the induction
and ongoing training courses and material provided to investigators. Any changes to the
procedures and standards are notified to investigators via investigation circulars and
communications.
5. Compliance
Reports of Incidents of crime or suspected crime are evaluated, categorised and prioritised for
investigation by the Criminal Investigation Casework Teams.
The Casework teams report on volumes of investigations, RM/POL/PFWW products,
processes and services affected, and types of offences and outcomes of prosecutions.
The Casework Teams monitor compliance with investigatory procedures and standards.
Complaints will be investigated as per the complaints procedure.
Policy Title $02 Royal Mail Group Criminal Investigation and Prosecution Policy
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Date
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6. Monitoring
Representatives from Group Security, Criminal Law and the business unit investigation teams
will review this policy at least annually.
In addition The Criminal Justice Inspection Northern Ireland will conduct an occasional review
of all investigatory processes in Northern Ireland.
7. Contract Manager
Not applicable.
8. Document details
81 Author Ray Pratt.
82 Owner Head of Criminal Investigation, RMLS
83 Enquiry point Ray Pratt
8.4 I Effective from 1 December 2007
8.5 I Review date November 2008
86 Last updated December 2007
8.7 I Version 11
9. Assurance Details
91 Name Tony Marsh, Phil Gerrish, Rob G Wilson, Roger Duckworth, Ray
Pratt, Simon Ramsden, Marcus Copper, John M Scott
9.2 Business Unit Royal Mail Group
9.3 I Assurance Date October 2005
10. I Final Review
10.1 I Approved by Phil Gerrish, Andrew Wilson
10.2 I Documented (Hard NO Location
Copy)
10.3 (Electronic) YES Location : Corporate Security Database
Policy Title S02 Royal Mail Group Criminal Investigation and Prosecution Policy
Version December 2007
Date
1 December 2007