Post Office
Whistleblowing Policy
Version History
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Version Date Editor Status
Number
0.1 17/02/2014 Georgina Draft
Blair
0.2 28/04/2015 Georgina Updated for
Blair comments from
Nisha Marwaha
(Legal)
0.3 30/04/2015 Georgina Updated after
Blair further discussion
with Nisha Marwaha
0.4 01/05/2014 Georgina Updated for amends
Blair from Nisha
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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
Jane MacLeod 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 May 2016.
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Contents
a
Purpose
Scope and definitions
Governing principles
Types of concerns
Ways to report concerns
Investigation of reported concerns
Roles and responsibilities
Risk
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Contact
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1. Purpose
The Whistleblowing Policy sets out the process by which Post Office employees,
officers, consultants, contractors, casual workers and agency workers
(“Workers”) can raise concerns in confidence and, if required, anonymously
about suspected wrongdoing in the organisation in the knowledge that concerns
will be acknowledged and action taken where appropriate. IWrongdoing
includes criminal activity, civil offences (including negligence, breach of
contract, breach of administrative law), miscarriages of justice, dangers to
health and safety or the environment and the cover up of any of these.
This policy is intended to
(a) I encourage Workers to report suspected wrongdoing as soon as possible,
in the knowledge that their concerns will be taken seriously and
investigated as appropriate, and that their confidentiality will be
respected;
(b) provide Workers with guidance as to how to raise those concerns; and
(c) reassure Workers that they should be able to raise genuine concerns
without fear of reprisals, even if they turn out to be mistaken.
This policy should not be used for complaints relating to your own personal
circumstances, such as the way you have been treated at work. In those cases
you should use the Grievance Procedure or the Stop Bullying and Harassment
Policy as appropriate. If you are uncertain of whether something is within the
scope of this policy you should seek advice from the Whistleblowing Officer,
whose contact details are in section 2.
y
Scope and details of Whistleblowing Officer
The term ‘Worker’ is used throughout this policy to refer to Post Office
employees, officers, consultants, contractors, casual workers and agency
workers. This policy applies to Workers; it does not apply to Subpostmasters
(i.e. agents, operators) and their assistants.
The term ‘whistleblowing’ refers to the disclosure by a Worker of serious
concerns about any wrongdoing that has taken place or is taking place within
the organisation, to a line manager, manager Whistleblowing Officer or in some
circumstances, an 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 be dismissed
by their employer if they make a ‘protected disclosure’. The following are
‘protected disclosures’:
. 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;
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. 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.
The Whistlebl
MacLeod
I Counsel, currently Jane
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.
Any Worker who raises a legitimate concern in good faith under this process will
not in any way be liable to disciplinary action or suffer any detriment 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, offering or taking of bribes
Financial fraud or mismanagement
Misreporting
Practices that could put individuals or the environment at risk
Breach of our internal policies and procedures (including the Code of
Business Standards)
e Any conduct likely to damage Post Office’s reputation
eoeeee
5. Ways to report concerns
(a) In the first instance, Workers should raise concerns with their line
manager, or a senior HR manager in the Post Office.
(b) Alternatively Workers can notify the Whistleblowing Officer directly, using
the contact details given in section 2.
(c) 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
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MCS Ltd, an independent company. InTouch will treat concerns in
complete confidence and the Worker does not have to provide contact
details.
or via a secure on-
HYPERLINK
The Speak Up service is available on}
line web portal
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. We hope that Workers will feel
able to voice whistleblowing concerns openly under this policy. However,
if you want to raise your concern confidentially, we will make every effort
to keep your identity secret. If it is necessary for anyone investigating
your concern to know your identity, we will discuss this with you. All
reports to the Speak Up line will be acknowledged within five working
days and will be passed to the Whistleblowing Officer.
6. Investigation of reported concerns
All concerns will be passed to the Whistleblowing Officer who will carry out an
initial assessment to determine the scope of any investigation. In some cases
the Whistleblowing Officer may appoint an investigator or team of investigators,
including staff with relevant experience of investigations or specialist knowledge
of the subject matter.
In some cases it is possible that Post Office may wish to directly contact the
Worker to request additional information. This can be done anonymously
through the Speak Up service via secure voicemail or secure messaging on the
web portal. Where the Worker's identity is known, this will be done only where
the Worker has consented and is happy for a representative from Post Office to
speak directly to them. In all cases the individual’s concern will be treated
sensitively and in confidence.
Subject to concerns about confidentiality, the Worker may be required to attend
additional meetings in order to provide further information. Workers can bring a
colleague or union representative to any meetings under this policy. The
companion must respect the confidentiality of the disclosure and any
subsequent investigation.
N
Outcomes
Post Office does not have to inform a Worker of the outcome of any
investigation and in some cases Post Office may need to protect confidentiality
or rights of other individuals and Workers. However, Post Office may provide
an update on progress where this is deemed appropriate.
External Disclosures
The aim of this policy is to provide an internal mechanism for reporting,
investigating and remedying any wrongdoing in the workplace. In most cases
you should not find it necessary to alert anyone externally.
The law recognises that in some circumstances it may be appropriate for you to
report your concerns to an external body such as a regulator. It will very rarely,
if ever, be appropriate to alert the media.
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We strongly encourage you to seek advice before reporting a concern to
external parties. The independent whistleblowing charity, Public Concern at
Work, operates a confidential helpline. They also have a list of prescribed
regulators for reporting certain types of concern. Their contact details are as
follows:
Helpline:
E-mai
Website: www.pcaw.co.uk
9. Roles and responsibil
ies
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 Audit and Risk Committee The
confidentiality of whistleblowers will be respected.
Any serious concerns reported by whistleblowing will be escalated by the
Whistleblowing Officer to the Chairman of the Audit and Risk Committee.
10. Protection and Support for Whistleblowers
It is understandable that whistleblowers are sometimes worried about possible
repercussions. We aim to encourage openness and will support Workers who
raise genuine concerns under this policy, even if they turn out to be mistaken.
Whistleblowers must not suffer any detrimental treatment as a result of raising
a concern. Detrimental treatment includes dismissal, disciplinary action, threats
or other unfavourable treatment connected with raising a concern. If you
believe that you have suffered any such treatment, you should inform the
Whistleblowing Officer immediately. If the matter is not remedied you should
raise it formally using Post Office’s Grievance Procedure.
Workers must not threaten or retaliate against whistleblowers in any way. If
anyone is involved in such conduct they may be subject to disciplinary action.
11. Contact
For further information about this policy contact the Whistleblowing Officer,
Jane MacLeod on }_ ~~ }
or;
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