Draft Whistleblower Policy
Introduction
Post Office Ltd (POL), attaches great importance to the ethical conduct of its
business and to the protection of its good reputation. This policy sets out
POL’ s requirements for enabling employees to disclose information
( “Whistleblowing" ) about breaches of its policies and standards of
conduct.
The implementation of such a policy becomes even more pressing with the
impending separation of the business from the wider Royal Mail Group. A
stand alone policy is therefore desirable to comply with all aspects of the
Public Interest Disclosure Act (PIDA) 1998, which ensures staff, or employees,
who make a genuine ‘protected disclosure’ are protected from
mistreatment or dismissal as a result of their acting in good faith.
Definition
A whistleblower is defined as a person who raises a concern about a
wrongdoing within an organisation (usually one in which they work). 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).
The Policy
Post Office Ltd is committed to trust and openness in its dealings with all
employees, and to listening to their views. It has adopted a Code of Business
Standards, and is determined to see that the standards in it are effectively
observed. It seeks to foster a working environment where line managers are
accessible to their staff and can be expected to give a fair hearing to any
legitimate concern which is raised with them, and to respond positively. In
some cases however, an employee may find it difficult to approach their line
manager with sensitive information for a number of reasons, the availability
of a whistleblower medium to capture such information should prove
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extremely beneficial to the business.
This policy will ensure that staff have a robust, yet discreet process to follow
to divulge actions, or information, relating to others within the business that
may prove of detriment to the business
This will be achieved by the initiation of a dedicated Whistleblower Helpline
and e mail address for such reporting means. The Helpline will be operated
by 3° party staff employed to pursue the various requirements emanating
from the POL Grapevine service. Grapevine is owned and funded by POL,
and has been operational since January 2007. A number of bespoke security
services are carried out by Grapevine, the whistleblower process will be an
addition to this portfolio.
The existence of a safe channel for employee disclosure is important to
ensuring the ethical health of the organisation, it needs to be sensitively
managed. It should support morale and promote employee confidence and
loyalty in the organisation. Genuine complainants must be encouraged and
protected, but malicious complainants are to be discouraged, and in this
respect the discipline process may be invoked to deal with individuals found
to be making such calls.
Training
e Grapevine personnel tasked with the operation of the whistleblower
line will need to be trained to a level to ensure that callers feel
comfortable with the professionalism and sensitivity displayed in
order to divulge as much information as possible, including their own
details ideally.
e Likewise, appointed whistleblower colleagues within POL may need
further training to enhance their capabilities to deal with the variety of
information types received via this source.
Call Management Process
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Callers should be encouraged to submit their details in order that a
thorough investigation of the information received can take place,
with further discreet contact with the source being available if
needed.
Genuine calls escalated back into POL by Grapevine for further
investigation should be to the designated whistleblower colleague
whose area of expertise the contents of the call falls under.
All information and data held be Grapevine in relation to this service
will be held securely, and remain the sole property of POL. All calls
will be recorded for accuracy and verification purposes. Reports and
other management information streams may be required from
Grapevine as detailed in any service level agreements in place.
Further Support For Callers
Employees who raise legitimate concerns under these guidelines in
good faith must not suffer disciplinary action or discriminatory
treatment as a result, even if a subsequent enquiry concludes that the
complaint cannot be substantiated in whole or in part.
All information sources should be treated with the upmost discretion
to ensure that personal details are not divulged to anyone acting
outside the limitations and guidelines of this policy.
Review
An annual review should be undertaken following deployment of this policy.
This can be undertaken on a more frequent ad hoc basis if this is deemed
necessary in conjunction with information from stakeholders, and/or the
service provider.
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