Employee Disclosure (Whistleblowing) (G7)
Royal Mail Group attaches great importance to the ethical conduct of its business and to the
protection of its good reputation.
This statement sets out Royal Mail Group policy for enabling employees to disclose
information (“whistleblowing”) about breaches of its policies and standards of conduct. This
policy will be supported by each of the Royal Mail Group businesses, which will maintain
arrangements for giving confidential and fair consideration to such disclosures, and for taking
appropriate and effective remedial action.
The Public Interest Disclosure Act 1998 gives workers the right not to be subjected to any
detriment if they make a protected disclosure. The dismissal of a worker because they have
made a protected disclosure is automatically unfair.
Employee disclosure means an allegation made by an employee that Royal Mail Group policy
or standards are being broken or disregarded, or that unethical, unlawful or unprofessional
practices are being pursued. This may concern criminal activity or corruption, financial
irregularity, conflict of interest, malpractice in relation to suppliers or clients, harassment,
bullying, neglect of duty, neglect of health and safety hazards, etc.
Such concerns may be raised where the employee feels that his or her line manager or head
of department is implicated in the behaviour complained of, or that for some reason they may
not be willing or in a position to provide an impartial hearing or remedy. The employee may
feel threatened or otherwise inhibited by the consequences of raising their concerns by the
normal management channel or via the grievance procedure.
This policy does not form part of an employee's contract of employment and applies to all
employees of Royal Mail Group.
Reserved Powers & Delegated Authorities framework
Overall accountability is held by the Head of Employee Relations, Royal Mail Group. Any
change to this policy must be signed off by the Head of Employee Relations, Royal Mail
Group.
Each Business Unit will nominate a Senior Manager(s) to be the contact point for dealing with
employee disclosures and these managers will ensure that any disclosures are investigated
fully and fairly. These contacts can be found in section 4.
200 Leadership behaviours for Royal Mail linked to Royal Mail commercial direction
RMG00000317
RMG00000317
RMG00000317
RMG00000317
3.1 Royal Mail Group is committed to trust and openness in its dealings with all employees,
and to listening to their views. It has adopted a Code of Business Standards, and is
determined to see that the standards in it are effectively observed. It seeks to foster a working
environment where line managers are accessible to their staff and can be expected to give a
fair hearing to any legitimate concern which is raised with them, and to respond positively.
3.2 In normal circumstances, employees should feel able to discuss any problem at work with
their line manager or, failing that, to raise the issue with the next most senior manager or the
head of department. "Employee disclosure" concerns those occasional cases where the
employee feels that these routes cannot be used without compromising their position, or that
the issue is so serious that it needs to be escalated to a senior level of management. An
employee may also use the disclosure system if an approach by the normal channel has been
tried but has failed to provide an effective remedy of the abuse complained of.
3.3 In an organisation the size of Royal Mail Group, situations may occasionally arise where
the interests or standards of the organisation are put at risk by the misguided, irresponsible or
even criminal actions of a few individuals or a group of people. Reporting such behaviour is
not disloyal: it is protecting the good reputation of Royal Mail Group and of the honest majority
of its employees. It is essential that there should be a safe and confidential channel by which
employees can have concerns about unethical or unlawful conduct impartially investigated by
someone outside their department. Employees should have a means of expressing any
anxieties inside the organisation, and feel confident that justice can be obtained by elevating
the problem to a senior level. This is preferable to keeping silent, or feeling that their only
recourse is to pass information to the media or to some outside body, or even to resign. Each
business has a duty to provide such a channel. Employees have a duty not to disclose a
grievance to the media before they have raised it with management and have made a
reasonable attempt to resolve the issue internally by following the procedures described in
this guideline.
3.4 Whilst the existence of a safe channel for employee disclosure is important to ensuring
the ethical health of the organisation, it needs to be sensitively managed. It should support
morale and promote employee confidence and loyalty in the organisation. Genuine
complainants must be encouraged and protected, but malicious complainants are to be
discouraged.
3.5 Royal Mail Group will take disciplinary action as appropriate against anyone who is shown
to have acted in an unethical or unlawful manner, in breach of its Code of Business Standards
or other standing instructions. Criminal penalties may also be appropriate in serious cases.
3.6 Employees who raise legitimate concerns under these guidelines in good faith must not
suffer disciplinary action or discriminatory treatment as a result, even if subsequent enquiry
concludes that the complaint cannot be substantiated in whole or in part. However,
disciplinary action will be taken against any employee who is shown to have used the
employee disclosure system deliberately, maliciously or mischievously to lay false or
misleading information. Penalties may range from reprimand when the integrity and reputation
of another employee have been impugned without reasonable cause, to dismissal in serious
cases where there has been a knowingly false accusation of criminal activity.
Contacts
Business Unit
Employee Disclosure contacts
Parcelforce Worldwide
Peter Walls, Head of Employee Relations
Post Office Ltd
‘Letters - Commercial
RM Letters
Colin Stretch, P&OD Advisor, Network & Sales
Dominic Scarlett, Head of P2OD Commercial
Jonathan Allen, Head of Employee Relations, Royal Mail Group
Central Functions - Group
Karen McKay, Head of P&OD Central Functions
RMG00000317
RMG00000317
4.1 Code of Business Standards
4.2 Mlemployee Disclosure Guidelines (size 35k)
4.3 G5 Conflicts of Interest
4.4 G9 Gifts
4.5 G10 Hospitality and Entertainment
4.6 The Public Interest Disclosure Act 1998
4.7 G13 Data Protection Act 1998
4.8 Royal Mail Corporate Securit)
5.1 Owner : Head of Risk and Assurance
5.2 Enquiry point :
Elizabeth M Law
Head of Risk and Assurance
Corporate Centre
Royal Mail Group ple
Internal Audit & Risk Management
Rowland Hill House,
Boythorpe Road,
CHESTERFIELD,
S49 1HQ
5.3 Effective from : 28/07/2006
5.4 Version : 1.1 (revised)
5.5 Review date : November 2007
5.6 Last updated : October 2006
RMG00000317
RMG00000317