Post Office
Whistleblowing Policy
The purpose of this Policy is to set out the process by which Post
Office employees and others who are contracted to personally perform
work on behalf of Post Office, can raise concerns in confidence and, if
required, anonymously about serious malpractice in the organisation.
Version History
Version Number Date Editor Status
0.1 17/02/2014 Georgina Draft
Blair
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Version History
Date Version Updated by Change summary
Document Location
The latest version of this document can be found in the Post Office
SharePoint Policy Library
For Sign-off - This document has been approved by the following
people:
Name Title - Department Date of Sign
off
David Mason Head of Risk Governance
Chris Aujard General Counsel
For Information - This document will be distributed to the following
people:
Name Title - Department
This policy will be reviewed annually. Next review date March 2015.
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Contents
1. Purpose 4
an Scope and definitions
4
Se Governing principles
4
4. Types of concerns
5
5. Ways to report concerns
5
6. Investigation of reported concerns
5
7. Roles and responsibilities
6
8. Risk 6
9. Contact
6
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1. Purpose
The Whistleblowing Policy sets out the process by which Post Office
employees and others who are contracted to personally perform work
on behalf of Post Office, can raise concerns in confidence and, if
required, anonymously about serious malpractice in the organisation
in the knowledge that concerns will be acknowledged and action
taken where appropriate. This policy is intended to ensure that
the treatment of workers who raise concerns within Post Office does
not breach their rights as expressed in the Public Interest
Disclosure Act (PIDA).
iS}
Scope and definitions
This policy applies to Post Office employees and others who are
contracted to personally perform work on behalf of Post Office.
This policy does not apply to agents, operators and their
assistants.
The term ‘worker’ is used throughout the policy to refer to Post
Office employees and those who are contracted to personally perform
work on behalf of Post Office.
The term ‘whistleblowing’ refers to the disclosure by a worker of
serious concerns about malpractice that has taken place or is
taking place within the organisation, to a line manager,
independent manager or external body.
The Public Interest Disclosure Act (PIDA) is legislation which
provides workers who raise a concern with the right not to suffer
any detriment or dismissal by the employer if they make a protected
disclosure. PIDA identifies protected disclosures as those which
are made in good faith and are reasonably thought to show one or
more of the following:
s That a criminal offence has been committed, is being committed
or is likely to be committed
. That a person has failed, is failing or is likely to fail to
comply with any legal obligation to which he /she is subject
. That a miscarriage of justice has occurred, is occurring or is
likely to occur
. That the health or safety of any individual has been, is being
or is likely to be at risk
. That the environment has been, is being or is likely to be
damaged; or
. That information about any of the above matters is being or is
likely to be deliberately concealed
A disclosure will not qualify as protected if the person making the
disclosure commits an offence by making it.
3. Governing principles
Post Office is committed to conducting business with the highest
standards of honesty, integrity and openness in order to create a
workplace where workers feel able to raise concerns internally.
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Any worker who raises a legitimate concern in good faith under this
process will not in any way be liable to disciplinary action or
loss of benefits, rights or prospects as a result of their action.
Disciplinary action may be taken against any worker who is shown to
have used whistleblowing procedures to make malicious or misleading
allegations that they know to be false.
4. Types of concerns
Workers should raise a concern if they are aware of, or suspect,
wrongdoing which affects others (eg. customers, members of the
public, colleagues or the Post Office).
Some examples of situations where a worker may raise a concern are:
. Fraud
: Giving or taking of bribes
. Financial malpractice
. Misreporting
. Practices that might put individuals or the environment at
risk
5. Ways to report concerns
In the first instance workers should raise concerns with their line
manager, or a senior HR manager in the Post Office. They will
either act on the information given to them, or pass it to the
relevant person who can deal with it.
It is recognised that sometimes raising a concern directly with the
business will not be possible, for example, if the worker considers
that the line management may be involved in the issue or if they
have a concern about confidentiality.
In such instances workers should contact the “Speak Up”
confidential reporting service which is run by InTouch MCS Ltd, an
independent company. InTouch will treat concerns in complete
confidence and the worker does not have to provide contact details.
The Speak Up service is available on L or via a secure
on-line web portal at http://www.intouchfeedback.com/postoffice.
The worker will be requested to provide information about their
concern, for example the history of the concern, relevant
individuals and the reason why they are particularly concerned
about the situation.
There is no requirement to provide contact details. However, not
providing details may reduce the business’ ability to make a
thorough investigation into the concerns raised. All reports to
the Speak Up line will be acknowledged within five working days.
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6. Investigation of reported concerns
Details of concerns raised via the Speak Up service will be
forwarded to the Post Office who will act on each concern in the
most appropriate way. Any resulting investigations will be made by
people with appropriate authority who have the technical and
professional knowledge needed for the particular case.
In some cases it is possible that the business may wish to directly
contact the worker to request additional information. This will be
done only where the worker has given express consent and are happy
for a representative from the Post Office to speak directly to
them. In all cases the individual’s concern will be treated
sensitively and in confidence.
Where concerns about serious malpractice are raised through other
routes, such as via line managers, other senior managers or by
other business helpdesks, and the concern would appear to be
sufficiently serious as to be covered by the Public Interest
Disclosure Act, this should be investigated and managed in line
with this policy.
The Post Office does not have to inform a worker who raises a
concern the outcome of any investigation and in some cases the Post
Office may need to protect confidentiality or rights of other
individuals and workers. However, the Post Office may provide an
update on progress where this is deemed appropriate.
7. Roles and responsibilities
The Risk and Compliance team supplies an annual summary of reports
made via the Speak Up line and other known instances of
whistleblowing to the Risk and Compliance Committee and to the Post
Office Board.
Any serious concerns reported by whistleblowing will be escalated
by the Head of Risk Governance to the Chairman of the Audit and
Risk Committee.
7. Risk
8. Contact
For further information about this policy contact the Risk and
Compliance team on/ GRO
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