POL00423202
POL00423202
Royal Mail Group Policy Royal Mail Group
@ om: BS
Employee Confidential Disclosures
Royal Mail
Royal Mail Group Policies
Code Policy Title
G07 Employee Confidential Disclosures
Brief Description: _ I RMG places great importance on the ethical conduct of its business and the protection of its
good reputation.
In accordance with best practice, RMG has adopted this Employee Confidential Disclosure
Policy. This policy allows workers to raise reasonably held concerns relating to serious
matters that could put RMG, its workers, or members of the wider public at risk. Worker
confidential disclosures usually involve bringing forward concerns that are in the
organisation’s interest to investigate and resolve. Examples include fraud, the giving or
taking of bribes, financial malpractice, misreporting, or practices that might endanger
individuals or the environment.
Owner: Group Executive Committee (GET)
Date Created: 28 July 2006
Version: 2.0
Effective From: 02 August 2010
Last Updated: 02 August 2010
Next review: August 2011
Enquiry Point: [internal Audit & Risk Management (IA&RM)
Contact Address Contact Numbers
Peter Tansley i
Head of Internal Audit
Rowland Hill House
Boythorpe Road
CHESTERFIELD
$49 1HQ
Keywords: I Employes Confidential Disclosures
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Royal Mail Group Policy Royal Mail Group
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Employee Confidential Disclosures
1. ROYAL MAIL GROUP (RMG) POLICY STATEMENT
RMG is committed to the highest standards of probity, transparency and accountability. The
RMG Employee Confidential Disclosures Policy sets out the process by which workers (i.e.
employees and others who are contracted to personally perform work on behalf of RMG) can
raise concerns in confidence and, if required, anonymously about serious malpractice in the
organisation in the knowledge that reports will be taken seriously and action taken where
appropriate.
Workers, who appropriately raise legitimate concerns under the process in good faith, will not
suffer any detriment as a result. RMG will endeavour to inform workers who raise such
concerns of the results of investigations or actions taken wherever possible. However, in
order to protect the confidentiality of third parties, this may not always be possible.
2. BACKGROUND
Every organisation faces the risk that something will go seriously wrong. Whenever such a
risk arises the first people to know something about it will usually be those who work in, or
with, the organisation. It is vital therefore that workers are confident that they can raise their
concerns without suffering any detriment. Workers should ideally raise concerns initially with
line management, or where appropriate, with other dedicated helplines, such as the Security
Helpdesk, the Bullying and Harassment Helpline, and the Corporate and Social Responsibility
Helpline. The Speak Up hotline has been created in order to supplement existing helplines, to
be used where the worker concerned does not feel confident in raising concerns via these
existing routes. (See appendix A).
Worker rights in law where a concern is raised are covered by the Public Interest Disclosure
Act (PIDA) 1998. PIDA enables workers to approach their employer or other relevant person
in the event of a significant concern, and sets out the protection afforded to workers where a
concern is appropriately raised. PIDA protects workers who make certain disclosures of
information in good faith, and which in the reasonable belief of the worker are related to a
dangerous or illegal activity that has occurred, or is likely to occur.
3. PURPOSE
RMG places great importance on the ethical conduct of its business and the protection of its
good reputation.
In accordance with best practice, RMG has adopted this Employee Confidential Disclosure
Policy. This policy allows workers to raise reasonably held concerns relating to serious
matters that could put RMG, its workers, or members of the wider public at risk. Worker
confidential disclosures usually involve bringing forward concerns that are in the
organisation's interest to investigate and resolve. Examples include fraud, the giving or taking
of bribes, financial malpractice, misreporting, or practices that might endanger individuals or
the environment.
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Employee Confidential Disclosures
4. SCOPE
This RMG policy applies to all business units within RMG including RMG Letters and
Wholesale, Parcelforce Worldwide, Post Office Ltd and all group and support functions. For
clarification, General Logistics Systems is not in the scope of this policy.
5. CONFIDENTIALITY AND THE PROTECTION OF WORKERS
Workers should ideally disclose any concern in the first instance to RMG in order to provide
management with an opportunity to attempt resolution of the issue appropriately.
Confidentiality is not the same as anonymity. Workers who raise concerns through
confidential disclosure procedures are sometimes understandably concerned about their
position, and may wish to remain anonymous. However, it is often difficult to conduct an
effective investigation without being able to discuss it fully with the person who raised the
concern. Consequently, although the hotline staff will ask callers if they are willing to provide a
contact name and number, callers do not need to provide contact details.
Although the business will attempt to investigate anonymously raised concerns wherever
possible, practical difficulties may prevent the commencement of investigations in certain
cases.
RMG will always seek to protect workers who raise concerns under this policy from reprisal.
Reprisals against workers who raise concerns in good faith are unacceptable and may give
rise to disciplinary proceedings. In addition, workers are protected by legislation: PIDA
provides workers who raise a concern with the right not to be subjected to any detriment
through an act (or a failure to act) on the part of the employer, where a protected disclosure is
made. PIDA identifies protected disclosures as those which, in the reasonable belief of the
individual making the disclosure, tend to show one or more of the following, and are made in
good faith to designated parties (including the employer):
(a) That a criminal offence has been committed is being committed or is likely to be
committed;
(b) That a person has failed, is failing or is likely to fail to comply with any legal
obligation to which he /she is subject;
(c) That a miscarriage of justice has occurred, is occurring or is likely to occur;
(d) That the health or safety of any individual has been, is being or is likely to be
endangered;
(e) That the environment has been, is being or is likely to be damaged; or,
(f) That information tending to show any matter falling within any one of the preceding
paragraphs has been, is being or is likely to be deliberately concealed.
Note: a disclosure will not qualify as protected if the person making the disclosure commits an
offence by making it.
Disciplinary action may be taken against any worker who is shown to have used employee
confidential disclosure procedures to make malicious or misleading allegations.
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Employee Confidential Disclosures
6. RMG’S APPROACH TO EMPLOYEE CONFIDENTIAL
DISCLOSURES
RMG prefers workers to raise concerns about serious malpractice with line management in
the first instance. The business also has in place specialist helplines to offer advice and
address certain types of concern (Appendix A). However, RMG recognises that sometimes
escalation through these routes will not be possible (for example, if the worker considers that
the line management may be involved in the issue, or the worker has a concern about
confidentiality). In such instances RMG encourages workers to contact the “Speak Up”
confidential hotline, which is run by InTouch MCS Ltd, a third party supplier.
Access to the hotline can be made by phone or via an on-line web service. InTouch will treat
concerns in complete confidence and workers do not have to provide contact details. The
worker will be requested to provide information about their concern, for example the history of
the concern, relevant individuals and the reason why the worker is particularly concerned
about the situation.
There is no requirement to provide contact details. However lack of such details may reduce
the business’ ability to undertake a full and robust investigation into worker concerns.
Details of the concern raised will be forwarded to RMG who will act on it in the most
appropriate way. Any resultant investigations will be undertaken by people with appropriate
authority who have the technical and professional knowledge relevant to the particular case.
It is possible that the business may wish to directly contact workers to request additional
information. This will be undertaken only where workers have given express consent and are
happy for a representative from RMG to speak directly to them. In all cases worker concerns
will be treated sensitively and in confidence.
All calls to the Speak Up hotline will be acknowledged within 5 working days. RMG is not
obliged to inform a worker who raises a disclosure the outcome of any investigation. In
certain cases, to do so, could breach the rights of other individuals or workers. However,
RMG may provide an update on progress where this is deemed appropriate. RMG will not
provide such information in response to claims where the person making the call is not
identifiable to RMG.
Worker concerns about serious malpractice may also be raised via other routes (e.g. through
discussions with line managers or through raising concerns via alternative business
helpdesks). Where concerns are raised by workers through these routes, but the concern
would appear to be sufficiently serious to be covered by PIDA, the concern should be
investigated and managed in line with this RMG policy. If clarification is required as to
whether or not a claim raised by a worker is relevant to the Employee Confidential Disclosure
Policy, please email “speakupenquiries~""" GRO “i or contact Internal Audit & Risk
Management. Morne ~
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Employee Confidential Disclosures
7. RESPONSIBILITIES
Key responsibilities under this policy are as follows:
Group Executive Committee (GET)
e Approval of the Employee Confidential Disclosures Policy;
e Ensuring that resources are made available within RMG as required.
Internal Audit & Risk Management (IA&RM)
« The development and maintenance of the Employee Confidential Disclosures policy;
e The development and maintenance of the framework and associated high level
processes;
e Coordinating the receipt of cases from RMG's hotline provider and reporting back on
progress and outcomes;
e Reporting incidents and outcomes to the Audit & Risk Committee and to GET;
e Chairing a working group consisting of the subject matter experts, to ensure that
serious claims are effectively investigated.
* Contractual management of the 3” party hotline provider.
Group Functional Heads
e Facilitating a consistent approach to investigations that cover multiple business units /
group functions, and for developing any cross-unit plans that are required.
Business Unit / Group Function Heads
e Deploying the resources to ensure that the applicable business unit / group function
develops and maintains its disclosure investigation capabilities so it complies with this
policy and associated procedures.
8. MAINTENANCE & CONTINUOUS IMPROVEMENT
1A&RM is responsible for ensuring that this policy is reviewed annually, and that learning and
latest good practice are applied where appropriate.
Business Units and Group Functions are responsible for ensuring that local processes that
support the investigation of worker confidential disclosures are maintained and updated to
take account of changes to business structures.
Date of Next Review: August 2011
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Appendix A
Employee Confidential Disclosures
CONTACT POINTS
Employee Confidential Disclosures
To report a concern.
Telephone J and choose to either speak to an operator, or
leave a voicemail message. Your call will be treated in confidence.
Alternatively leave a message using the confidential on-line web based
service using www.intouchfeedback.com/royalmail
Note: For queries relating to this policy or related processes contact Internal Audit &
Risk Management (Email: speakupenquirie:
Bullying & Harassment Helpline
A free helpline, operated by an independent company, to offer confidential advice
relating to bullying or harassment concerns, and to assist in initiating harassment
complaints.
Telephone: I ~ “GRO
Security Helpdesk
To report any information about a crime relating to RMG, or for advice regarding
security.
Telephone:
Corporate & Social Responsibility Helpdesk
To ask a question relating to health, social engagement, the environment, and safety
issues.
Ask Adam
The Ask Adam channel encourages all our people to voice their opinions, share their
ideas or seek clarification on any subject.
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