POL Investigations Policy
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Post Office Group
Investigations Policy
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POL Investigations Policy
Contents Page
Contents
Contents Page wee
Document Control Sheet............. ces
Section A. Introduction. -4
Section B. Context.. 5
About this Policy... —
Principles to be considered at the outset 2
Principles to be considered during the investigation... 6
Who is responsible for this policy .....
Who must comply and how....
How we monitor compliance
How to raise a concer!
Contact us and more information...
Section C. Key Terms and References .............
0 © oN N
Key Terms
References.
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Document Control Sheet
MMA
GE Policy Sponsor Policy Owner Policy Implementor Policy Approver
Post Office
General Counsel Employment Lawyer Employment Lawyer
Risk & Compliance
Jane MacLeod Committee
Nisha Marwaha Nisha Marwaha
Version and Policy Policy Review Effective from: Policy location:
Status: Period
‘Annual Review (from 28 September 2016 Policy intranet site
v.1.0 Final date effective)
Version Reason For Change
POLICY APPROVAL
Role/Forum
Executive Owner and Sponsor General Counsel (Jane MacLeod) 30 March 2016
Executive Committee Post Office Risk & Compliance Committee (RCC) I 8 Sept 2016
Board Committee Post Office Audit, Risk and Compliance 28 Sept 2016
Committee (ARC)
DOCUMENT DISTRIBUTION STATUS
Distribution Document Sensitivity
(Mark x as appropriate) (Mark x as appropriate)
Internal Only Non-sensitive
External Only Sensitive
Next review
date
Quality Control
This document is periodically reviewed and at least once each year starting
from the last effective date. This policy has been reviewed against the latest January 2017
Post Office policy standards.
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Section A. Introduction
(~ Chief Executive’s Note »
Post Office Group (‘Post Office’) is committed to doing things correctly. Our
Business Standards are our code of behaviours that represent the conduct we
expect. This policy supports the code to help us ensure the highest
investigation policy standards are maintained.
This policy sets out what is and is not acceptable but if you have any doubts
or questions, these should be referred in the first instance to the policy
owner, our principal employment lawyer within our Legal team who oversees
compliance with this policy. It is essential that you read this policy.
X y,
Introduction by the Group Executive
Policy Owner: General Counsel
As Post Office’s General Counsel and the Group Executive Policy Owner I have
overall accountability for the governance framework to which this policy
relates to the Board of Directors. Post Office’s Audit, Risk and Compliance
Committee considers investigations and related matters as an agenda item.
The Post Office Board is updated as necessary.
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Section B. Context
[ About this Policy I
The purpose of this policy is to provide key principles for individuals to consider and
use where necessary when conducting internal investigations. The policy sets
standards Post Office employees should aim to achieve.
The definition of investigation is the act or process of investigating someone or
something.
This policy should be read in conjunction with any other applicable Post Office policies
which require an investigation to be conducted, including in particular the Post Office
Prosecutions Policy (located on the Post Office intranet). It applies to the Post Office
Group as defined in Section C.
This policy is reviewed on a regular basis with relevant individuals and at least at half
yearly intervals each year.
This policy enables us to comply with our obligations under applicable legislation and
with regulatory requirements. It also protects Post Office’s brand and reputation.
This policy’s effective date will be determined by the date on which final approval is
given by the appropriate governance forum.
[ Principles to be considered at the outset ]
e¢ Before commencing an investigation, the following should be considered:
Identify the nature of the investigation and its purpose;
e Identify who and what is being investigated;
e Identify if there are any other applicable existing Post Office procedures. For
example, Whistleblowing, Bullying and Harassment, Information Security, Fraud
or Financial Crime;
e Identify who should ‘own’ the investigation (who is responsible for it);
e Consider the sensitivity and confidentiality of the investigation and any special
measures that are required before proceeding;
e Consider who should or should not be informed prior to commencing the
investigation (e.g. person being investigated, the line manager, HR etc.); and
whether this is appropriate and/or legally compliant; and
« Remember that the person responsible for the investigation is also responsible for
taking legal advice from Post Office Legal as required
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Principles to be considered during the
investigation
The following principles should be adhered to wherever possible during an
investigation:
.
Confidentiality - where possible and appropriate, maintain confidentiality.
Ensure that all communications are labelled ‘confidential’ and are kept secure.
Balance the need for confidentiality with the need to carry out an effective
investigation. Be aware of legal obligations regarding disclosure of
information;
Fairness - when following any investigation procedure, keep relevant
individuals informed as appropriate. Seek expert input where necessary, e.g.
from HR, from Security Teams, from Information Security Teams. Advise
individuals of their right to appeal, if there is such a right under the applicable
Policy;
Objectivity - try to remain impartial and wherever possible base your
conclusions on facts. Avoid making snap judgments or assumptions about
culpability or wrongdoing;
Transparency - ensure there is an audit trail of your investigation. Keep
records of discussions and meetings, and notes of interviews. Retain
documents in accordance with Post Office’s Acceptable Use and Document
Retention policies; and
Decision making - prior to making your decision, ensure you have all the
information you reasonably need. Prepare a report of findings. Consider who
needs to be: (i) informed of the report outcome in conjunction with any
applicable procedures, (ii) provided with the findings/ outcome report, (iii)
advised of any follow-up actions. In some circumstances it may not be
appropriate to share outcomes/ findings, e.g. in the context of whistleblowing
investigations.
Who is responsible for this policy
Post Office’s Board of Directors have overall responsibility for ensuring that Post
Office has a framework to ensure compliance with legal, regulatory and contractual
requirements. The Board is kept abreast of relevant matters relating to the
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management of investigations by reports from its committees including its ARC
Committee.
Key individuals and their specific responsibilities in relation to this Policy are:
. The General Counsel for Post Office is the Policy Sponsor, accountable to the
Post Office Board overall.
. The Principal Employment Lawyer is the Policy Owner responsible for the day
to day implementation of and compliance with this Policy. The Employment
Lawyer is accountable to the General Counsel.
Who must comply and how ]
Compliance with this policy is mandatory for all Post Office employees, officers,
contractors, casual workers and agency workers. This policy applies wherever in the
world Post Office’s business is undertaken.
It is important that you read, understand and comply with this policy. Your actions,
behaviour and conduct to apply the provisions of this policy are your responsibility.
You must adhere to all parts of this policy. You should avoid any activity which may
lead to a breach of this policy. We may request your confirmation of agreement to
this policy. You must notify your line manager, in the first instance, as soon as
possible if you believe or suspect that a breach of this policy has occurred or may
occur.
You may request a policy exception or waiver to this policy, but you must follow the
Post Office’s exceptions and waivers procedures which can be obtained from the
business continuity Policy Owner.
If non-compliance is identified the matter must be referred to the General
Counsel. Any investigations should be carried out in accordance with this policy. If
the cause is found to be due to wilful disregard or negligence, it will be treated as a
disciplinary offence.
[ How we monitor compliance I
The Principal Employment Lawyer will ensure that this policy is implemented,
reviewed and remains effective. Post Office’s internal systems and controls ensure
that this policy is regularly independently assessed for effectiveness, suitability and
adequacy. In addition, Internal Audit will periodically test compliance with this
policy.
Review and assessment of compliance with this policy is done on a regular and timely
basis. Reports are made to the Risk & Compliance Committee.
How to raise a concern }
7
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Any Post Office employee who has concerns about a failure to comply with this policy
has a duty to:
discuss the matter fully with their Line Manager; or,
discuss it directly with their Head of Business Unit; or
discuss it with Legal Services; or
bring it to Post Office’s attention independently of management, via the Speak Up
Line (see Section E ‘References’ for more information).
[ Contact us and more information ]
If you need further information bout
Marwaha - Employment Lawyer o:
Policy, please contact Nisha
Section C. Key Terms and References
[ Key Terms I
Term or Acronym Description
Post Office Group (‘Post Office’) Post Office Limited and all subsidiaries
and entities within the Post Office Group
which includes Post Office Management
Services Limited (POMS)
[ References
References Description
Speak Up Line
“Speak Up” is confidential reporting service
which is run by InTouch MCS Ltd, an
independent company. More details can be
found in the Post Office Whistleblowing
Policy. The Speak Up service is available on
via a secure on-line web