Speaking up (internal whistleblowing) policy

Why do we need this policy?

When things are going wrong in an organisation the signs are often there for everyone to see. Usually they are spotted, reported up the management chain and acted upon. But sometimes they are not. Management may not listen. Staff may not feel confident enough to raise a concern. They may see management as the problem.

At the Bank, we want to ensure that this doesn’t happen and that all voices are heard. Therefore, if you have a serious concern about malpractice or misconduct that affects others or the Bank as a whole - such as possible fraud, criminality, breach of a legal obligation, environmental damage, or a danger to the Bank and its staff – it is vital that you report it so it can be addressed. This is how you can help protect other staff and the Bank.

Even if you aren’t completely sure if your concern is serious, but you feel that something isn’t quite right, it is important that you Speak Up. If your concern is not covered by this policy we can redirect your concern to the right people.

Speaking Up is an integral part of the Bank’s culture. We are committed to fostering an environment where individuals feel safe and have the confidence to raise serious concerns, either with line management or to designated staff outside their management line, without fear of retaliation or reprisal.

Please note that not all concerns raised under this policy will fall within the scope of the Public Interest Disclosure Act 1998^{footnote [1]} or ‘PIDA’ (legislation on the treatment of whistleblowers). Therefore, not everyone who raises a concern under this policy will be considered a “whistleblower” and entitled to the protections set out in PIDA. Neither PIDA nor this policy are for concerns about your own employment, or how you have personally been treated by your manager. That is for the Bank’s Grievance procedure as set out in section D3 of the Staff Handbook or Anti-Harassment and Bullying Policy. Breaches of Bank policies may be referred to the Compliance Division. If a concern is complex, we will determine the appropriate way forward with the relevant policy owners.

Examples of serious concerns covered by this policy are set out in our FAQ document.

Who does this policy apply to?

This policy applies to all Bank staff. This includes consultants, contractors and agency staff. This policy includes responsibilities for line managers when a member of staff raises a serious concern.

What you must know or do?

The Bank needs you to raise any serious concerns about malpractice or misconduct that affects others or the Bank as a whole, at an early stage, either orally or in writing, via one of the routes set out below. You don’t have to come forward with proof. You need only tell us that something needs to be looked into. This includes Speaking Up concerns passed to you by third parties outside the Bank.

If your concern does not fall under the Speaking Up policy, we would redirect it in consultation with you.

Our assurances to you

To those who Speak Up, we undertake that:

• You will not lose your job or suffer any other penalty as a result of Speaking Up. It doesn’t matter if you are mistaken. We do not tolerate any victimisation or harassment of those who Speak Up.
• We treat Speaking Up matters sensitively. Anonymous disclosures can be more difficult to investigate, so we don’t encourage them. If you ask us to protect your identity we will do so unless required to do otherwise by law. If it becomes impossible to investigate without disclosing your identity we will discuss this with you before taking further action.
• We will investigate your concern thoroughly and impartially as we determine is appropriate.
• We will update you as appropriate once our investigation is completed.

Once you have raised a concern:

• You will be advised how your concern will be handled, and who will be handling it. You will be informed as to how you can contact the person handling the matter.
• We will investigate your concern thoroughly and impartially as we determine is appropriate. We may appoint an independent investigator depending on the seriousness and complexity of the concern you raise. If we consider that an investigation is needed, we may seek support from Legal, People, Compliance, the Investigations & Monitoring Team, the Head of Internal Audit, or an external expert. The Senior Staff Counsellor may be briefed on the issue raised and the method for handling it.
• You will be given an initial estimate of how long the investigation into your concern is expected to take. (If the timescale changes, we will update you.) We will keep in contact with you at regular intervals during an investigation (unless you do not wish to be contacted) and update you as appropriate once our investigation is completed.
• You will be asked to make the person handling your case aware if you believe that you are suffering detriment for having raised a concern – both during the investigation and following its conclusion – the Bank does not tolerate any victimisation or harassment of those who Speak Up.

You are protected under this policy if you are mistaken about a concern you raise. However, maliciously reporting matters that you know to be false may result in disciplinary action.

The application of this policy will be in accordance with the relevant data protection legislation.

For all colleagues

If you have a serious concern about malpractice or misconduct that affects others or the Bank as a whole, it is vital that you Speak Up.

First, if you can, tell your line manager.

If you feel unable to do that, for whatever reason, or feel that they have not dealt with the matter appropriately, please raise the matter with any one of the following:

Secretary of the Bank
Deputy Secretary
Senior Advisers, Conflicts, Secretary’s Department
Central Policy Manager, Conflicts, Secretary’s Department
Analyst, Conflicts, Secretary’s Department
Senior Staff Counsellor
Executive Director, People
Internal Auditor
IAWB Manager, Legal

These people have been given special responsibility for escalating / dealing with the type of concerns that might be raised under this policy. They can also provide support to individuals who raise a Speaking Up concern. You may also raise a Speak Up concern via:

Unite Seconded Rep

If you feel unable to raise the issue with any of the above, you can raise a concern externally via a confidential helpline provided by Vita Health Group.

Alternatively, or if you feel that your concern is not being treated appropriately, you may contact the Bank’s Speaking Up champion, the Chair of the Bank’s Audit & Risk Committee (ARCo) or the Chair of Court. The Bank’s Speaking Up champion is responsible for ensuring and overseeing the integrity, independence, and effectiveness of our arrangements.

Protect, the UK whistleblowing charity, can provide confidential advice to people thinking of Speaking Up.

For all line managers

If a member of staff raises a concern about malpractice or misconduct that affects others or the Bank as a whole, Secretary’s will determine whether it should be treated as a Speaking Up case. This means you must:

Promptly notify the Secretary or Deputy Secretary of the case;

If it is a Speaking Up case, then the Secretary or Deputy Secretary will decide, in consultation with you, whether you should remain involved in the case.

What support is available to help you in relation to this policy?

Counselling support is available via the Bank’s counsellors and the Bank’s Employee Assistance Programme (Vita Health Group).

The following documents support this policy:

• Guidance for those who speak up.
• FAQs for additional background on Speaking Up.
• Guidance for managers handling a Speaking Up concern.

What is the impact of non-compliance?

It is important for us all to raise serious concerns if we have them, so the Bank can deal with them promptly and effectively.

It is imperative that line managers take action when a member of their team Speaks Up.