Whistleblowing Briefing Paper
Definition & Legalities
A whistleblower is defined as a person who raises a concern about a
wrongdoing within an organisation. The revealed misconduct may
take a number of forms, including violation of a law, direct threat to
public interest, fraud, health & safety, or corruption.
The allegations may be made internally (to people within the
business), or externally (regulators, law enforcement agencies, media).
Whistleblowers frequently face reprisals, sometimes at the hands of
colleagues, the organisation, or under law depending on the nature
or validity of the concerns raised.
Employees and staff who make a genuine ‘protected disclosure’
are protected from being treated badly or being dismissed under the
‘Public Interest Disclosure Act (PIDA) 1998.
A clear procedure for raising issues or concerns will help to reduce
the risk of such concerns being mishandled, whether by employees or
the organisation.
The existence of such a policy, together with evidence that an
employer was concerned to deal effectively with any malpractise, will
make it less likely that any tribunal will find an employee was
behaving reasonably by making disclosures to an outside body or
person
Creating a Whistleblowing Policy within Post Office Ltd (POL)
The above points give good reason why it is important and sensible
to develop a bespoke employee confidentiality disclosure policy
unique to POL, especially with the impending separation from Royal
Mail Group.
The provision of a whistleblower facility would be available to all
employees within POL, including Agents staff within the Network.
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Such a policy and confidential helpline would supplement existing
specialist services within the overall business, including, Security
Helpdesk, Bullying & Harassment Helpline, NBSC and HR Helpline.
By creating a whistleblower facility, it may also mitigate against illegal
or inappropriate activities by employees, in as much as such a facility
may have a deterrent value to staff who may have been
contemplating inappropriate actions.
In recent months much groundwork has been done to pave the way
for the implementation of such a policy. Activities undertaken have
included liaison and benchmarking within RMG, as well as with
external companies.
Further stakeholder engagement will be necessary in the future and
prior to any official launch. Engagement should be sought with
appropriate personnel from Network, Supply Chain, Admin functions,
NFSP and unions.
It is intended to utilise the Post Office Grapevine service to manage
and operate this facility. The facility will incorporate a confidential
helpline number which can either generate an operator response, or
on which a message can be left. There will also be a dedicated e mail
address to facilitate the provision of information by secure electronic
means
Grapevine is owned and funded by POL, and has been operational
since January 2007. A number of bespoke security orientated services
are provided to POL by Grapevine.
All information and data held be Grapevine in relation to this service
will be held securely, and remain the sole property of POL.
Future progress towards implementation & potential obstacles
Although the intended use of 3 party staff to manage this operation
should be of benefit in creating an atmosphere of impartiality and
reassurance in the mind of the whistleblower, it will also highlight
some concerns which will need to be managed.
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Not least of these concerns will be ensuring that all staff assigned to
this task receive the necessary level of training to enable them to deal
professionally with incoming calls.
Line operator training will to some degree determine the level and
type of information the caller is willing to divulge. If a professional
environment is engendered, the caller may feel more comfortable in
divulging more comprehensive information.
Further escalation of initial calls will need to be managed carefully
The use of a 3" party operated helpline may suggest a mistrust of
individuals, or the company, by the whistleblower in the first instance.
If calls are escalated back into the business as part of a pre-defined
policy, there must be absolute transparency and impartiality from all
those involved for the reasons outlined in the point above.
Calls received on the helpline that are found to be of a malicious
nature must be investigated thoroughly with a view to the disciplinary
process being invoked if appropriate.
Prior to any launch, engagement should be sought with the Internal
Communications Team. They should be able to guide and assist in
terms of poster/literature content and design, as well as identifying
the appropriate vehicles to ensure the launch is communicated in a
timely and comprehensive manner.