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Royal Mail Group
Speak Up (Whistleblowing) Policy
Royal Mail Group is committed to conducting business with the highest
standards of honesty, integrity and openness where our employees feel able
to raise concerns internally. This policy outlines how employees can raise
genuine concerns about wrongdoings at the earliest possible stage and in
the right way.
Main topic areas Getting help
i Contact your line I
ninieianel manager if you have
any queries about this
@ Policy statement policy.
@ What is Whistleblowing? Line managers can obtain
i dvice by:
© Confidentiality and protection of workers ane oF
Calling the HR Sen
Advice Centre on: GI
ices
RO
@ Underpinning legislation
@ When should concerns be raised?
. Managers working for
@ How should concerns be raised? Parcelforce Worldwide
@ Other routes to raising concerns i
@ How should concerns be dealt with? For web access go to: I
https://www.psp.royalmail
@ Investigation outcome group.com
@ Responsibilities
@ Where to go for further information
@ Forms I
@ Related documents
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Overview
Policy
statement
What is
whistleblowing?
Confidentiality
and protection
of workers
Underpinning
legislation
Speak Up (Whistleblowing) Policy
This policy applies to all employees of Royal Mail Group Ltd unless stated
otherwise within the policy. “Royal Mail Group Ltd’ will be referred to as ‘Royal
Mail Group’.
Employees working for Post Office Ltd should refer to their own Speak Up Policy.
This policy is effective from 28 April 2012.
This policy does not form part of contracts of employment. Royal Mail reserves
the right to amend this policy from time to time.
The Speak Up (Whistleblowing) Policy sets out the process by which workers,
ie. employees and others who are contracted to personally perform work on
behalf of Royal Mail Group, can raise concerns in confidence and if required,
anonymously, about serious malpractice in the organisation, in the knowledge
that concerns will be acknowledged and action taken where appropriate.
Any worker who raises a legitimate concern in good faith under this process will
not in any way be liable to disciplinary action or loss of benefits, rights or
prospects as a result of their action.
Disciplinary action may be taken against any worker who is shown to have used
whistleblowing procedures to make malicious or misleading allegations.
Whistleblowing refers to the disclosure by an employee of serious, potentially
criminal matters that have taken place or are taking place within the organisation,
to a line manager, independent manager or external body.
Confidentiality is not the same as anonymity. Workers who raise concerns via
whistleblowing procedures are sometimes understandably concerned about their
position, and may wish to remain anonymous.
However, it is often difficult to conduct an effective investigation without being
able to discuss it fully with the person who raised the concern. Consequently,
although the helpline staff will ask callers if they are willing to provide a contact
name and number, callers do not need to provide contact details.
Although the business will attempt to investigate anonymously raised concerns
wherever possible, practical difficulties may prevent investigations from being
undertaken in certain cases.
Workers are protected by the legislation, Public Interest Disclosure Act, which
provides workers who raise a concern with the right not to suffer any detriment by
the employer if they raise a concern (make a protected disclosure).
The Public Interest Disclosure Act identifies protected disclosures as those which
are made in good faith and are reasonably thought to show one or more of the
following:
e That a criminal offence has been committed, is being committed or is likely to
be committed
e That a person has failed, is failing or is likely to fail to comply with any legal
obligation to which they are subject
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e That a miscarriage of justice has occurred, is occurring or is likely to occur
e That the health or safety of any individual has been, is being or is likely to be
at risk
e That the environment has been, is being or is likely to be damaged; or
e That information about any of the above matters is being, or is likely to be,
deliberately concealed
A disclosure will not qualify as protected if the person making the disclosure
commits an offence by making it.
When should Concerns should be raised if they are in the organisation's interest to investigate
concerns be and resolve.
raised?
Some examples of situations where a worker may raise a concern are:
e Fraud
e Giving or taking of bribes
e Financial malpractice
e Misreporting
e Practices that might put individuals or the environment at risk
How should We hope that employees are able to tell Royal Mail Group about any concerns to
concerns be provide the business with the opportunity to solve the issue appropriately. In the
raised? first instance workers should raise concerns with their line manager, or a senior
HR manager in Royal Mail Group. They will either act on the information given to
them, or pass it to the relevant person who can deal with it.
Alternatively, the business provides a specialist help line to offer advice and
address certain types of concern. Details of these are contained in the ‘where to
go for more information’ section of this policy.
Royal Mail Group will try to inform the worker of the results of investigations or
actions taken wherever possible. However, in order to protect the confidentiality
of third parties, this may not always be possible.
Other routes to InTouch MCS Ltd
raising
It is recognised that sometimes raising a concern directly with the business will
concerns
not be possible, for example, if the worker considers that the line management
may be involved in the issue or if they have a concern about confidentiality.
In such instances workers should contact the “Speak Up” confidential helpline,
which is run by InTouch MCS Ltd, a third party supplier. Access to the helpline
can be made by phone or via an on-line web service. InTouch will treat concerns
in complete confidence and the worker does not have to provide contact details.
The worker will be requested to provide information about their concern, for
example the history of the concern, relevant individuals and the reason why they
are particularly concerned about the situation.
There is no requirement to provide contact details. However, not providing details
may reduce the business’ ability to make a thorough investigation into the
concerns raised. All calls to the Speak Up helpline will be acknowledged within
five working days.
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How should
concerns be
dealt with?
Investigation
outcome
Responsibilities
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Details of the concern raised will be forwarded to Royal Mail Group who will act
on it in the most appropriate way. Concerns will be reviewed and prioritised
depending on the issue. Any resulting investigations will be made by people with
appropriate authority who have the technical and professional knowledge
required for the particular case. Serious issues will be investigated independently
with the most serious investigated externally
Itis possible that the business may wish to directly contact the worker to request
additional information. This will be done only where the worker has given
express consent and is happy for a representative from Royal Mail Group to
speak directly to them. In all cases the individual's concern will be treated
sensitively and in confidence.
Where concerns about serious malpractice are raised through other routes, such
as other business helpdesks, and the concern would appear to be sufficiently
serious to be covered by the Public Interest Disclosure Act, this should be
investigated and managed in line with this policy.
Royal Mail Group does not have to inform a worker who raises a concern of the
outcome of any investigation and, in some cases, Royal Mail Group may need to
protect the confidentiality or rights of other individuals and workers. However,
Royal Mail Group may provide an update on progress where this is deemed
appropriate.
Chief Executive Committee (CEC)
e Approval of the Speak Up (Whistleblowing) Policy
e Ensuring that resources are made available within Royal Mail Group as
required
Internal Audit & Risk Management (IA&RM)
e The development and maintenance of the Speak Up (Whistleblowing) policy
e The development and maintenance of the framework and associated high
level processes
e Coordinating the receipt of cases from Royal Mail Group's helpline provider
and reporting back on progress and outcomes
e Reporting incidents and outcomes to the Audit and Risk Committee and to
CEC
¢ Chairing a working group consisting of the subject matter experts, to ensure
that serious claims are effectively investigated
e Contractual management of the third-party helpline provider
Group Functional Heads
e Facilitating a consistent approach to investigations that cover multiple
business areas/group functions, and for developing any cross-unit plans that
are required
Business Area/Group Function Heads
e Deploying the resources to ensure that the applicable business unit / group
function develops and maintains its disclosure investigation capabilities so it
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complies with this policy and associated procedures
Where to go for Speak Up (Whistleblowing)
further '
iterinelien To report a concern .
° __..} and choose to either speak to an operator or leave
a voicemail message
e Alternatively leave a message using the confidential on-line web based
service using www.intouchfeedback.com/royalmail
If clarification is required as to whether a claim raised by an employee is relevant
to the Speak Up (Whistleblowing) Policy email speakupenquiries@royalmail.com
or contact Internal Audit and Risk.
Bullying & Harassment Helpline
A free helpline, operated by an independent company, to offer confidential advice
relating to bullying or harassment concerns:
Telephonet.—.
Security Helpdesk
To report any information about a crime relating to Royal Mail Group, or for
advice regarding securi
e Telephon
e Email: securityhelpdesk@royalmail.com
Just Say It
The Just Say It channel encourages all our people to ask questions, suggest
ideas or make comments about the business:
Forms There are no forms relevant to this policy.
Related There are no related documents to this policy.
documents
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