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Post Office Whistleblowing Investigations Procedure
1. Introduction
This guidance explains the procedure to follow when a whistleblowing
disclosure as defined by the Post Office Whistleblowing Policy is received.
This document should be read together with the Post Office Whistleblowing
Policy.
2. Who is covered by the Whistleblowing Policy?
The statutory protection under the Employment Rights Act 1996 applies to
employees and workers which (for these purposes) include agency workers,
homeworkers, casual workers and contractors.
3. Investigating procedure
When a whistleblowing disclosure is made, the Whistleblowing Officer will
decide whether an investigation is appropriate and what form the
investigation should take. He/she can decide to take no action if the
complaint appears to be vexatious or is a matter which is more appropriate
to be investigated under a different procedure. If the Whistleblowing Officer
concludes that a whistleblower has made false allegations maliciously or with
a view to personal gain, the whistleblower may be subject to disciplinary
action.
The action taken following a disclosure will depend on the nature of the
concern and may be:
e resolved by agreed action as determined by the Whistleblowing Officer
without the need for investigation
e investigated internally;
e referred to the police;
e referred to a regulatory authority.
If an investigation is appropriate, the Whistleblowing Officer will appoint an
Investigation Manager to investigate the concern. The appointed
Investigation Manager must be a manager at an appropriate level for the
matter under investigation. They must not have any conflict of interest with
the people or issues concerned. In some cases an investigator or team of
investigators may be appointed including staff with relevant experience of
investigations or specialist knowledge of the subject matter.
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4. Responsibilities of the Investigation Manager
Following this appointment, the Investigation Manager should write to (if the
whistleblower’s identity is known) or otherwise contact the whistleblower
acknowledging their disclosure and confirming that an investigation will be
carried out.
If the whistleblower is prepared to meet, the Investigation Manager should
arrange a meeting as soon as possible to discuss the concerns. The individual
is entitled to bring a companion who must be a Post Office colleague or a
Post Office recognised Trade Union representative. Any companion must
respect the confidentiality of the disclosure and any subsequent
investigation.
The Investigation Manager should obtain full details and clarifications of the
complaint and keep a written record of the key points of concerns raised,
especially if the worker has not put the matter in writing themselves.
The Investigation Manager should fully investigate the allegation with the
assistance, where appropriate, of other individuals. The Investigation
Manager should keep the Whistleblowing Officer updated during the
investigation and liaise with the Whistleblowing Officer in the event of any
concerns or questions.
5. Confidentiality and Anonymity
The Whistleblowing Officer and Investigating Manager should ensure that,
whenever possible, those making disclosures are protected through a
confidential investigation of their concerns.
If it is necessary for anyone involved in the investigation of the concern to
know the whistleblower’s identity this should be discussed with the
whistleblower and explained. Proper investigation may be more difficult or
impossible if Post Office cannot obtain further information from the
individual. It is also more difficult to establish whether any allegations are
credible. If whistleblowers are concerned about possible reprisals if their
identity is revealed, they should come forward to the Whistleblowing Officer
and appropriate measures can then be taken to preserve confidentiality
6. The rights of the whistleblower
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 the Investigation Manager believes the whistleblower has
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suffered any such treatment the Whistleblowing Officer should be informed
immediately.
7. Conclusion of the investigation
The Investigation Manager must conclude the investigation by writing a
report containing the findings of the investigation, including conclusions as to
the validity of the allegations and recommendations for further action. The
report should be submitted to the Whistleblowing Officer.
Post Office does not have to inform the whistleblower of the outcome of any
investigation, nor provide them with any copies of any reports produced
during the investigation, and in some cases Post Office may need to protect
confidentiality or rights of other individuals. However, Post Office may
provide an update on progress of the investigation where this is deemed
appropriate.
8. Investigation records
The investigation paperwork including interview records, correspondence and
final report should be sent to [xxxxxxx]
6. Advice and Support
For advice and support relating to this procedure please contact the
Whistleblowing Officer.
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