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IDG: Speak Up & Investigations
Sarah Gray and John Bartlett
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Contents
=» Aims
= Strategy & Delivery
= What does success look like?
= Resource & Funding
=» Assurance
Dependencies
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Aims
Speak Up Investigations
For POL to have a Speak Up culture which: For POL to demonstrate that we have learned from the past
re ClJ, HJ and Hamilton in the conduct of investigations:
* Staff, Contractors, Partners, Postmasters and 8
their staff use to raise concerns regarding actions -That investigations are fair, transparent, evidence-led,
or behaviours/ wrongdoing in POL's operations lawful, respectful, disclosure-compliant
* Is trusted by those using it -Will follow evidence away from as well as towards the
working theor
* Is recognised top down as an important part of : u
POL's good governance framework For POL to protect our operations by the effective use
of investigations into:
-Potential losses of >£100k
-Allegations of misconduct by GE/Board members
-Enterprise-wide process failures where facts are not known
Strategy & Delivery
Speak Up
Two Year Strategy (develop following EY's
review)
* Outreach
-Conduct a rolling programme of awareness team
talks promoting & explaining Speak Up (inc manager
awareness/ roles and responsibilities)
-Experience at POL and elsewhere shows an increase
in reporting following team talks
-Coordination with strategic partners' Speak Up
teams
-Postmasters & their staff to be included
*Continuous Improvement
-CPD events, connectivity to other Speak Up teams,
periodic external assessments/reviews, feedback
culture, legal developments such as EU
Whistleblowing law, and assurance all feed a Cl
culture
Investigations
Continue to build an investigative target
operating model
*Within the CIU
-Equip team with suitable tools
-Maintain and develop external contacts, particularly with
law enforcement and prosecutors
-Deliver the strategic liaison approach to police
investigations
*Within other teams
-Through assurance work, increase their capabilities and
reduce risk
-By being an escalation point for criminal cases, assist other
teams in reducing potential losses
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What does success look like?
Speak Up (strategy being developed so Investigations
below are proposed measures) -Investigations conducted in a judgement-compliant
Quantitative manner
-PIDA-qualifying reports increase as a proportion -Risk is identified and managed by investigative findings
of reports received year on year being implemented
-Number of reports increases by X% each year -Process and procedure improvements made from
assurance work
-Criminal benefit recovered by the courts and returned to
Qualitative POL
-Feedback from reporters shows trust in the
service
Resource & Funding
Speak Up
*Current team of 1x Manager, 2x Integrity
Investigators, & 1x Triage/Analyst
*Volume of cases requires Manger to run the
complex and serious cases which distracts from
strategic development and outreach impeding overall
effectiveness
*An additional Integrity Investigator (c£42k incl NI
etc) would give increased capacity for outreach and
so increase risk awareness
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Investigations
Clu
*Current team of 1x Head of CIU, 2x Senior Investigations
Managers
*Current case load unsustainable with current team size —
Head of CIU carrying case load so TOM development slowed
*Assurance work limited by capacity
*cf1m in identified losses not being investigated despite good
evidence due to lack of resource
Other teams
*Postmaster-facing Retail teams unable to handle investigation
volumes
Assurance
Speak Up
-Will form part of the Investigation
assurance work from May 2023
-Cases will be assessed every two months
against an agreed criteria to identify lessons
learned as part of continuous improvement
-periodic benchmarking such as self-
assessment against specialist NGO's criteria
and peer organisations through engagement
by the team
Investigations
-CIU assures some of the other
investigative teams against an agreed set
of criteria.
-Recommendations from assurance and
investigations are reported to Compliance
as well as local management for
consideration and action.
-Additional teams investigative activities
could be assured given additional
CIU capacity
-Compliance assures CIU's activities
-Intent to have an external review of
investigations carried out in 2024
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Dependencies
Speak Up
-Success of outreach work to improve quality
and quantity of reporting
-Establishing and maintaining an appropriately
sized and skilled team
-Moving to a more effective case management
system to better manage risks related to
disclosure, operational effectiveness,
confidentiality, case hand-offs between
investigators/teams, and intelligence-gaps
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Investigations
-Moving to a more effective case management system to
better manage risks related to disclosure,
operational effectiveness, confidentiality, case hand-offs
between investigators/teams, and intelligence-gaps
-Sufficient specialist transaction analysis support either in
CIU itself or within the Retail investigation teams to support
the provision of complex statements of evidence to police
-An increase in numbers of investigators in CIU to make
impact of case work strategically effective ie establish a
deterrence effect as well as volumes of detections
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Current Non-BAU delivery timetable (based on current resources)
30 Human Impact / P&P referral First tranche by mid-June 2023 New staff to be on-boarded
Merits Assessments Remainder throughout FY2023/24 throughout May and June
2023. Matters concerning current
employees to form first tranche.
Case management system Ready for use by end of Q1 FY2023/24 Funding secured already.
Requirements were agreed in March
2023. Contract being completed.
Strategic relationship with City of Agreements reached during Q3 Objective to have a single referral
London Police, PSNI, and Police FY2023/24 point for criminal matters in each
Scotland jurisdiction
Speak Up Two-Year Strategy To be completed by end of June 2023 __‘_EY review now received.
Recommendations to be considered
for Strategy. Will include outreach
plan.
Combined Investigation & End of Q2 FY2023/24 Draft has been reviewed by P&P. Next
Cooperation with Law Enforcement draft under way. Will require to go
Policy active through RCC and ARC.