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The Speak Up Champion Terms of Reference
The Purpose of the Role
Post Office Ltd (POL) has appointed an independent Non-Executive Director as Speak Up Champion
(the NED).
The NED's primary purpose as Champion is to be a point of assurance for the integrity, objectivity,
independence, effectiveness, and evolution of the Speak Up function in adherence with the Group
Speak Up Policy and associated procedures.
This role also provides, as a critical friend:
e Board-level insight to the Speak UP function
e Advice in approaches in managing reporters, nuance in preserving anonymity/confidentiality,
and management of investigative findings
e Advocacy both on behalf of the Speak Up function into senior POL staff, and reciprocally to
the Speak Up function from other parts of POL
e A senior escalation point for POL’s Speak Up function. This function is represented by the
Head of The Post Office Investigation Branch (HIB) who is also the Head of the Central
Investigation Unit.
Through HIB, the NED will influence where appropriate the high-level understanding of Speak Up so
that the interests of fairness, transparency, and public interest are protected and advanced.
Role & Responsibilities
The NED does not have line management responsibilities for POL's Speak Up function nor
responsibility for the management of individual Speak Up investigations other than in exceptional
circumstances (outlined below).
New Speak Up-related policies will be passed for comment to the NED by HIB as necessary,
particularly where they are of a strategic nature. Whilst HIB has discretion as to what is sent to the
NED for comment, any re-drafting of the Group Speak Up Policy must go to the NED for comment.
The NED will meet quarterly with HIB. The purpose of these meetings is primarily to discuss
developments within the Speak Up function and secondly to provide an overview to the NED of the
current reporting portfolio. It is also an opportunity for HIB to benefit from the NED's insight into the
wider POL environment. This is advice and commentary given by the NED, not a directive, but will be
considered seriously by HIB. The Group Legal Director may also attend and participate.
HIB will provide a report to the NED regarding the development of the function every six months which
will outline successes, lessons learned, future plans, blockers, and functional development
opportunities. HIB will also provide the monthly Central Investigations Unit MI report to the NED.
Feedback on these reports will be actively sought to improve the impact of the content.
Through this role, the NED will be able to provide an insight to the Board of the work of theSpeak Up
function which will assist in the Board's understanding of matters concerning or originating from the
function.
If the independence of a Speak Up investigation or the resulting report is threatened, HIB or the
Group Legal Director or the General Counsel may escalate the matter to the NED. The NED will then
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seek to resolve the matter with the prime objective to maintain the independence the investigation and
investigative reporting as well as any reporter-related anonymity/confidentiality issues.
The NED will also be an additional point of escalation for complaints or feedback regarding the Speak
Up function from other parts of the organisation. This alternative route to line management will be
helpful in gathering as much constructive commentary as possible on the remit, purpose,
development, methodologies, and effectiveness of the function to aid continual improvement.
Case Oversight by Exception
There may be times when HIB's line manager (Group Legal Director) and the General Counsel may
be conflicted regarding a specific Speak Up investigation. In this situation, HIB may approach the
NED and seek their oversight and reporting channel for that case. In this circumstance, the Group
Legal Director and General Counsel will be notified. The NED will then carry the escalation point and
block-clearing roles HIB's line management normally perform. Where HIB is also conflicted, the
relevant investigator may engage the NED in this way.
Interaction with the Investigation Champion
The Investigation function has a separate NED acting as their Champion. Part of the role of the Speak
Up team is to conduct investigations originating from Speak Up reporters. The Speak Up Champion is
concerned with the preservation of anonymity and confidentiality of the reporter and in ensuring there
is no retaliation against that person as a consequence of making the report. How the Speak Up
investigation is conducted — in terms of investigative approach, methods, minimum standards, and
adherence to the Group Investigation Policy — falls within the Investigation Champion's area of
interest.
To ensure there is positive and continual learning and development in these two spaces, the two NED
Champions will meet every six months to discuss subjects of mutual interest in relation to the conduct
of the Speak Up and Investigation functions. HIB, the Speak Up & Intelligence Manager, and the
Group Legal Director may also attend.