Employee Disclosure Guidelines
1.1 Each business should nominate a senior manager, and additional managers if its size
and structure make this appropriate, to deal with cases of employee disclosure. Nominees
should preferably be people with HR training and skilled in interview techniques.
Arrangements should be publicised internally to all employees, giving contact details.
1.2 On receipt of information about any unethical or unlawful practice, the nominated
manager should approach the complainant discreetly and sympathetically and invite them to
be interviewed confidentially. During the confidential interview, all relevant information should
be gathered and an initial assessment should be made of whether the complaint is made in
good faith or whether it appears to be malicious, mischievous or made out of a desire for
personal vengeance. In cases of doubt, it must be assumed that the complaint is made in
good faith. A confidential note of the interview may be made, but the informant should not be
identified in it by name or by inference if they wish their anonymity to be respected at this
stage. (But see section 1.4 below).
ligation, the case must be reported to the
in order for the case to be logged.
1.3 When a disclosure c:
Head of Internal Audit on
1.4 The nominated manager should then pursue the complaint with the director of the
department concerned (provided he or she is not implicated in the complaint) and conduct an
enquiry to confirm the facts. If it is apparent that financial irregularity is involved, Royal Mail
Internal Audit and Risk Management must be involved immediately. If there is a suspicion of
criminal activity, Royal Mail Corporate Security must be involved immediately. Royal Mail
Internal Audit and Risk Management and/or Royal Mail Corporate Security will pursue their
investigations independently of management, but may require the production of, and retain,
any documentation relating to the complaint or initial management enquiry. They may also
require the disclosure of the identity of the employee who has provided information.
1.5 Once an enquiry has been completed, the nominated manager should (after appropriate
consultation with other senior managers) recommend to the line manager whether there is a
case to be pursued under the business conduct code. If it is decided that there is not, the
complainant should be told, and given reasons. If the complaint is found to be wholly or partly
substantiated, appropriate action should be taken according to the business conduct code. In
this case (and particularly if criminal prosecution is involved), the complainant should be
advised only that their concern is being dealt with and that they will be notified of the
outcome. They should be given a further report, in writing if requested, once resulting action
has been concluded, and asked to confirm that their complaint has been dealt with
satisfactorily. The need for any further action should then be reviewed by management.
1.6 Once a disclosure enquiry has been completed, the outcome must be reported to the
Head of Internal Audit (contact numbers in 1.3) to close the case.
1.7 Employees who have disclosed information about any misconduct or malpractice must be
given every reasonable protection against any form of recrimination or intimidation. This will
be particularly necessary where the complaint involves previous instances of harassment or
bullying. The complainant's identity must be protected so far as possible, and not disclosed to
the person who is the subject of the complaint. If it becomes absolutely necessary to disclose
it in order to substantiate the complaint, the subject of the complaint should be warned that
any attempt at recrimination will be a serious disciplinary matter, and firm action must follow if
the warning is ignored. If separation of the employees in question is appropriate, then on
principle (as in sexual harassment cases) it is the perpetrator, not the victim, who should be
moved. If, however, the victim asks to be moved for their own protection or peace of mind,
prompt and supportive action must be taken to help them. If appropriate, the complainant
should be supported by counseling both during and after the outcome of the investigation.
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1.8 Where information is provided anonymously, the allegation should be investigated as in
1.4 above and appropriate action should be pursued. There need be no attempt to establish
the identity of the complainant unless their testimony is essential to substantiating a serious
complaint.
1.9 Any complaint upheld against a Royal Mail Group director must be notified in confidence
to The Secretary to Royal Mail Group. If financial activity and/or criminal activity are involved,
Royal Mail Internal Audit and Risk Management and Royal Mail Corporate Security must also
be notified.
1.10 Throughout the enquiry process, the rights of the person or persons complained of must
be adequately respected while the facts are being established. It may be that the perpetrator,
or alleged perpetrator, requires counseling or other support and this should be provided as
appropriate. Managers making enquiries must take care to establish facts and to take an
evenhanded approach. This will be particularly challenging when allegations and denials of
harassment or bullying may largely depend on the differing perceptions of the parties
involved.
1.11 Nothing in this guideline should be taken to affect an employee's right to involve their
trade union in accordance with agreed practice should they choose to do so.
Further Information
In such a sensitive area, no rule can cover every eventuality. It is essential that good
behaviour and integrity are fostered and supported throughout the organisation, and recourse
to the employee disclosure system should be necessary only as a last resort. Its effectiveness
will depend on the discretion, good judgement and impartiality of the nominated managers
responsible for operating it and of managers who are called on to take remedial action.
The channels for making a protected disclosure are listed below:
Contact Number
Your manager
Your manager's manager.
Any contact listed below where
appropriate.
Your manager's manager.
Any contact listed below where
appropriate.
Concerned about
A colleague or a contractor
Your manager or contract manager
Financial irregularities, fraud
Head of Internal Audit
Unsafe work practices, Health &
Safety policy
CSR Helpdesk
Crime or suspicion of a crime
Royal Mail Corporate Security
Helpdesk
Crime Stoppers
Post Office Ltd Security
Bullying and harassment
Bullying and Harassment
Helpline
A Royal Mail Group Director
Company Secretary
Q@
rs
Aconcern about any employee or
contractor where you are not
comfortable with any of the above
alternatives, or if you believe that
Head of Internal Audit
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appropriate action hasn't been taken
from an earlier report
Any employee disclosure matter Your local CWU or CMA union
representative
Wrongdoing at work — free of charge I Public Concern at Work
confidential advice can be obtained
from the whistleblowing charity, Public
Concern at Work
the Public Interest Disclosure Act 1998 please contact People Contact __
or! “GRO _I Post Office Ltd employees should contact, GRO;
For advice
Once a disclosure is received via the above channels, it should be re-directed to a nominated
senior manager for further investigation. Nominated contacts for each Business Unit can be
found in the contacts table.