Speak Up Policy

3. Key Principles

3.1 Policy Statement

We actively encourage you to speak up about any wrongdoing that you encounter during the course of your professional duties (whether you personally observe such wrongdoing or whether you reasonably believe that it has occurred, is occurring, or is likely to occur). We are committed to maintaining an open, safe and discreet environment with the highest standards of honesty and accountability, where BBB Colleagues can report any legitimate concerns in confidence. It is important that BBB Colleagues are aware that they do not need to have any proof that a wrongdoing has been committed, is being committed, or is likely to be committed; just a reasonable suspicion that is the case.

3.2 Speaking-Up/Raising a concern

If you have any genuine concerns related to suspected wrongdoing or dangerous behaviour or circumstances affecting any of our activities, you should report it under this policy. This may include:

• criminal activity
• a failure to comply with any legal or professional obligation
• fraud, financial mismanagement, bribery or tax evasion
• serious breach of internal policies, procedures or controls
• conduct likely to cause reputational damage to BBB and/or the financial wellbeing of BBB
• miscarriages of justice
• endangering of any individual’s health and safety
• damage to the environment
• something improper which left unchecked could be damaging to BBB
• deliberate concealment of information relating to any of the above

3.3 Protection for those Speaking-Up

The Bank recognises that the decision to speak-up can be a difficult one to make, not least because of the fear of reprisal. We aim to encourage openness and we will support BBB Colleagues who raise genuine concerns under this policy even if they turn out to be mistaken.

BBB is committed to ensuring that BBB Colleagues will not suffer any detrimental treatment as a result of raising a concern that they reasonably believe to be true. This includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. BBB will also not tolerate any harassment or victimisation of BBB Colleagues who speak-up, and we will treat any allegations of this seriously. Where an allegation of detrimental treatment on the grounds of having raised a concern under this policy is upheld, this will be dealt with in accordance with the BBB Disciplinary Policy and Procedure.

If, as a result of speaking-up, you feel you have suffered a detriment please raise this either with HR or through the usual speak-up channels.

3.4 How to speak-up within BBB

You should normally raise concerns with your immediate line manager. However, depending on the seriousness and sensitivity of the issue and the nature of the concern, you may feel unable to do so. You may also feel unable to raise the matter within line management. If this is the case, then you can report your concern to one of the following designated officers (also known as Speak Up Champions) who have responsibility for dealing with concerns raised by BBB Colleagues:

• Managing Director, Internal Audit content removed
• Chair of the BBB Board Audit Committee content removed

We hope that BBB Colleagues feel able to voice concerns openly under this policy. However, if you wish to raise concerns on a confidential basis then there is a dedicated email address ([email protected]) to report a concern in confidence to the Managing Director of Internal Audit who will ensure it is recorded and investigated appropriately whilst maintaining confidentiality.

If the BBB Colleague raising the concern wishes to remain anonymous during the investigation process, they can confirm this within the email correspondence. The Managing Director of Internal Audit content removed will acknowledge this request for anonymity.

Anonymous reports can also be made but colleagues should be aware that it can be very difficult to act on and investigate anonymous submissions.

It is not always possible to keep information anonymous where an investigation has to take place and anonymity cannot be guaranteed.

A meeting will then usually be arranged as soon as possible to discuss the concerns and you will be provided with an indication of how we propose to deal with the matter. You may bring a colleague or union representative to any meetings under this Policy. Such a colleague or representative must respect the confidentiality of your concern and any subsequent investigation.

Once a concern has been raised, an investigation will be undertaken and we will keep you informed of the progress of the investigation. If necessary, we may require a further meeting with you. Please note, however, that sometimes the need for confidentiality may mean that we are not able to provide specific details of the investigation. Any details provided to you should be treated as strictly confidential.

All investigations and their findings will be reported to the BBB Board Audit Committee and where required the relevant Government department or regulatory body, taking into account any request for anonymity from the BBB Colleague who raised the concern.

If it is concluded that a malicious allegation has been made, the relevant person(s) may be subject to disciplinary action.

3.5 How to speak-up to an external person

This policy has been developed in order to provide BBB Colleagues with the guidance and reassurance they need to speak-up internally. However, it is recognised that there may be circumstances where a BBB Colleague feels it necessary to raise their concerns outside the business and in these circumstances, they have a number of external avenues open to them.

If you do not feel it is appropriate to raise the matter internally, you may contact a Prescribed Person. The table below provides a non-exhaustive list of some Prescribed Persons likely to be most relevant to BBB operations (some of these have their own ‘whistleblowing hotlines’):

Relevant Body	Issues that may be referred
HMRC	Administration of tax, national insurance, and tax credit systems.
Comptroller and Auditor General	Proper conduct of public business, value for money, or fraud and corruption in relation to the provision of public services.
Serious Fraud Office	Serious or complex fraud and civil recovery of the proceeds of unlawful conduct.
Financial Conduct Authority (FCA)	Conduct of funds, markets, firms and individuals subject to Financial Services and Markets Act 2000, including banks, building societies, consumer credit and investment or insurance businesses; about competition affecting financial markets in the United Kingdom and about the operation of mutual societies registered by the FCA under relevant legislation.
Prudential Regulation Authority (PRA)	Matters relating to the carrying on of deposit-taking business, insurance business, or investment business and the safety and soundness of persons authorised for such purposes.
Department for Business and Trade (DBT)	Fraud and other misconduct in relation to Department for Business & Trade as well as companies in public or private sector.
Information Commissioner	Compliance with the requirement of legislation relating to data protection and to freedom of information.

A full list of prescribed persons and guidance on making a disclosure to the relevant Prescribed Person is available here:

https://www.gov.uk/government/whistle blowing list of prescribed people and bodies

3.6 Making a disclosure to another body

It is recommended that BBB Colleagues report their concerns internally with their line management or a designated person in the first instance or with a Prescribed Person where they feel unable to raise the concern internally. However, if you have a concern which you feel unable to raise internally or with the relevant Prescribed Person, you may contact another body, e.g. the Police.

3.7 Advice for managers in receipt of a concern

BBB Colleagues should be encouraged to speak-up and raise genuine concerns. If a BBB Colleague approaches you to raise a concern:

• Listen to their concerns and be
• Assist the colleague with determining whether the concern should be dealt with under this policy or under the BBB Grievance Policy.
• Treat the disclosure in confidence, and only disclose information where required and to the appropriate persons.
• If the concern is being dealt with under this policy, report the disclosure to the Managing Director of Internal Audit for it to be recorded and investigated.
• Reassure the BBB Colleague speaking-up that they will not be subject to any detriment as a result of raising the concern.
• Manage the expectations of the BBB Colleague and what feedback they can
• Maintain records of your conversations with them, and document any actions
• If possible, confirm receipt of the report to the BBB Colleague within seven days, and inform them of any action you have taken within three months, as well as the status of the investigation and, if appropriate to do so, the outcome when concluded.

3.8 Internal Audit and the Chair of the BBB Board Audit Committee

The Managing Director of Internal Audit content removed, and the Chair of the BBB Board Audit Committee, content removed are responsible for:

• Receiving concerns from managers/BBB
• Maintaining the Speak-Up
• Investigating concerns raised, working with other teams such as Legal or HR as
• Documenting the findings and securing any
• Engaging with the Prescribed Persons where there is a
• Acting on the findings where
• Providing feedback to BBB Colleagues during/after the investigation;
• Providing an independent and confidential report to the Audit Committee on each matter investigated.

On an annual basis the Board Audit Committee shall receive an assurance statement confirming the policy is fit for purpose and enabling the committee to review the adequacy and security of the internal arrangements for colleagues to raise concerns, in confidence, about possible wrongdoing in financial reporting or other matters; and ensure that these arrangements allow proportionate and independent investigation of such matters and appropriate follow up action.

3.9 Maintenance of Records

All records relating to a BBB Colleague raising a concern in accordance with this policy must be kept in accordance with the BBB Records Management Policy.