POL00447996 - Speak Up - Two Year Strategy Version 1.0 - Report

Evidence on official site

POL00447996

POL00447996

Speak Up

Version 1.0
POL00447996
POL00447996

Contents page

1 Purpose .....

1.1 Purpose of the Strategy ..
1.2 Understanding Speak Up (Whistleblowing) ..

1.3 POL Commitments to Speak Up .

1.4 What does the Strategy aim to achieve? .

2 Focus Areas .....

2.1 Awareness ..
5

2.2 Confidence in Speaking Up .....
5

2.3 Training and Support

3 Delivering the Strategy ...

3.1 Improve awareness of the Speak Up Function ..

3.2 Improve confidence in Speaking Up...

3.3 Training and Support...

4 Communication Plan ..

4.1 Communication Plan .....
8

5 Measure of Effectiveness

5.1 Improved Awareness ...
9

5.2 Better Relationships ..
9

5.3 External Assurance ....
9

5.4 Continuous Improvement ...
9

6 Reviewing the Strategy ....

6.1 Reviewing the Strategy ..
10

Page 2 of 10
POL00447996
POL00447996

1 Purpose

1.1 Purpose of the Strategy

The Speak Up Strategy sets out Post Office Limited’s (POL) two-year vision for the Speak Up function.
The purpose of this Strategy is to deliver increased awareness, listening up and use of the Speak up
function as part of POL’s determination to restore trust in POL amongst our staff and post office
network.

It should be read in conjunction with POL’s Speak Up Policy, Code of Conduct and Dignity at Work
Policy, which provide guidance to employees and the wider network on the behaviours expected to
ensure everyone is treated with respect at work.

1.2 Understanding Speak Up (Whistleblowing)

Speak Up’ (Whistleblowing) is the reporting of issues of concern, wrongdoings, illegal activities, or
unethical behaviour made in good faith and in the interest of the public or POL.

We have followed external best practice in changing the terminology from ‘whistleblowing’ to ‘speak
up’ as its connotations are generally more positive, thus encouraging employees and Postmasters to
voice their concerns and speak up without fear of retaliation.

The Public Interest Disclosure Act (PIDA) 1998 makes it unlawful for an employer to dismiss or
victimise a worker for having made a ‘protected disclosure.’ A protected disclosure is one that is given
in good faith, is in the public interest and addresses one of more of a number of listed ‘wrongdoings.’
These fall under six categories:

© criminal offences;

failure to comply with legal obligation;

miscarriages of justice;

dangers to health or safety;

dangers to the environment;

or deliberate concealment of any of the above categories.

oo0o00

The Speak Up team provides monthly analysis of trends and common drivers from received reporting
to the Speak Up Champion and senior POL staff. This provides insights and helps increase an
understanding of the type of Reporters and risks. The business can then act on these identified risks.
Where an investigation results from Speak Up reporting, any findings are passed to Group Assurance
for resolution.

1.3 POL Commitments to Speak Up

Changing from ‘Whistleblowing’ to ‘Speak up’ as the function name and the promotion of ‘speaking
up’, which generally has more positive connotations, is to encourage employees and POL to voice their
concerns without fear of retaliation.

Page 3 of 10
POL00447996
POL00447996

Trust is a pillar of the Speak Up function. Without it, employees who want to speak up may hold back
due to concerns about possible consequences. To address these concerns, leaders need to have ‘buy
in’.

There is the negativity and belief that no action will be taken once the Reporter speaks up. Therefore,
itis important to keep the Reporter in the loop at each stage of the reporting process to reassure them
that their claims are being taken seriously. It is not enough to set up a telephone line and hope for the
best. To reap the benefits of transparency and trust, POL need to ensure that the speak up procedures
are effective.

It is therefore imperative that the Speak Up Team and POL raise awareness of the Speak Up function
on a continual basis, beyond merely posting guidance on the POL intranet.

It is not the sole responsibility of the Speak Up Team to foster a ‘Speak Up’ Culture. Everyone has their
role in promoting ‘doing the right thing’.

© We will work to remove any stigma and real or perceived barriers to Speaking Up to foster a
culture that gives Reporters confidence that they will be listened to, treated fairly and with
respect.

© Wewill work to remove barriers and regain trust, by engaging with the business and providing
awareness and being receptive to feedback.

1.4 What does the Strategy aim to achieve?

An effective ‘Speak Up’ function is key to cultivating a safe, supportive culture within POL and to
identify and manage risk within the business. Everyone in POL and the post office network should be
able to engage safely and meaningfully by having their voices heard. Speaking out against
wrongdoing, poor practice, discrimination, and intolerance can lead to real actions and create a culture
of openness and transparency where employees, Postmasters and the wider business network feel
confident to speak up.

Since the dedicated Speak Up function was formed in 2021 there have been 281 reports. Analysis of
the reports shows an increase in serious issues being raised. Fraud and theft remain the highest
categories, but code of conduct, compliance and regulation violation cases are the areas showing a
greater increase in reporting. We have also seen an increase in reporting from POL staff (31%) and
Postmasters and their staff (29%). We wish to build upon this. These groups, POL staff and
Postmasters will be central to this two-year strategy.

To deliver this strategy and help bring about change in culture, this strategy will concentrate efforts in
following focus areas depicted in the next page.

2 Focus Areas

2.1 Awareness

Page 4 of 10
POL00447996
POL00447996

Increased awareness of the Speak Up function is necessary among both postmasters and colleagues
so that everyone knows how to raise concerns confidentially or anonymously and to whom concerns
can be raised.

2.2 Confidence in Speaking Up

Encouraging employees and Postmasters to voice their concerns without fear of retaliation is
essential so that concerns are heard and are promptly and thoroughly investigated, with feedback

provided and outcomes shared wherever possible.

2.3 Training and Support

lf POL teams and Postmasters, particularly those in management and leadership roles, have a range of
training and support around the Speak Up process it is more likely that issues will be raised and

effectively resolved. It is important to improve the knowledge and visible support for Speak Up at the
top of the organisation relating to the value and processes of Speak Up.

To deliver the strategy, the following key objectives and actions have been identified based on the
premise of using multiple communications channels. These key objectives are outlined in the next

page.

Page 5 of 10
POL00447996
POL00447996

3 Delivering the Strategy

3.1 Improve awareness of the Speak Up Function

© All new starters are made aware of the Speak Up function. The rhythm of this awareness
activity will be increased throughout year, stages of employment, and the audience
broadened.

© An ongoing communications plan to ensure all employees and the wider network are made
aware of the Speak Up function through engagement with POL's colleague networks and
with Postmaster groups such as the NFSP and focus groups.

©. There is clear, living, and accessible information about how to speak up and raise concerns
on internal POL hub and Branch Hub pages (available to employees and postmasters
respectively).

© A programme of engagements takes place with the Speak Up Champion and GE members
across the key stakeholder groups to provide regular communication and to maintain visibility
and facilitate engagement.

3.2 Improve confidence in Speaking Up

© Provide increased visibility to the good work being carried out by publishing each quarter on
the Speak Up intranet page informative statistics and thematic insights. Where possible,
Reporters would provide publishable feedback (attributable and unattributable) as to their
experience for inclusion on the intranet site.

© Ensure that any cases are handled according to published timescales and that concerns are
dealt with promptly and confidentially.

© Wherever possible, case studies will be developed and communicated to share the outcome
from investigations, or examples will be given where case studies may not be possible.

© The Speak Up team will consult colleague networks and Postmaster groups as part of the
annual review of Speak Up policy and strategy to ensure they are fit for purpose.

© All those who raised concerns receive feedback on the outcome of the investigation and have
their opportunity to provide feedback on the process.

Page 6 of 10
POL00447996
POL00447996

3.3 Training and Support

© Annual training and provision of support on good Speak Up leadership behaviours for all
leaders and managers, including training on the importance of listening to and positively
responding to concerns, will be undertaken by SLG and managers.

© Training and support will be provided to key areas of the business to recognise Speak Up
reports and what to do when one is made, e.g., Executive Assistants, Area Managers and
Branch Assurance team.

O The training is not solely web-based and will provide an opportunity for employees and POL's
network to ask questions.

© Activities in these areas will be led by the Speak Up Team, with support from the People Team,
SLG, Board and Non-Executive Director Speak Up Champion.

4 Communication Plan

4.1 Communication Plan

Communicating and engaging with our different stakeholder groups is key to each of the focus areas.
Each focus area will have its own communications plan. A high-level outline of audiences and activities
has been created which will then be adapted into a communications timeline in collaboration with
communications colleagues and key stakeholders.

We will measure how effectively the strategy is being implemented using the approaches annotated in
the next page.

Page 7 of 10
POL00447996
POL00447996

5 Measure of Effectiveness

5.1 Improved Awareness

Using opinion poll surveys, understand what employees know about Speaking Up at POL and identify
improvements. We will provide MI reports and high-level findings to RCC and SEG for oversight on
trends and themes and then publish the findings on the intranet page.

5.2 Better Relationships

We will ask POL employees, Stakeholders and Reporters for feedback on our relationship via focus or
contact groups and whether they feel it is improving through our engagement and training.

5.3 External Assurance

The Speak Up team become members of Protect to conduct an assessment following their benchmark
assessment conducted in 2021. Membership of Protect would also enable the Speak Up team to attend
Protects’ masterclasses and training events to remain current with continuous learning in their
respective roles.

5.4 Continuous Improvement

We will ask Reporters for feedback. Assurance and Complex Investigations (AC&l) will review a sample
of the Speak Up team's investigations on a two-monthly basis, making recommendations as to
improvements and knowledge or training gaps. Group Assurance will review Speak Up's work annually.
The Speak Up team will establish a network of contacts in the Whistleblowing management industry
to access best practice and learn from the wider experience of their peers.

6 Reviewing the Strategy

6.1 Reviewing the Strategy

© Implementation of the strategy will be overseen by the Head of A&Cl. An evaluation of
progress will be made in April 2024 with revised/new priorities identified for 2024 — 2025 and
a report of progress published.

© Anew two-year strategy will be devised for April 2025-2027.

Page 8 of 10
POL00447996
POL00447996

Page

9 of 10
POL00447996

POL00447996