Speak Up Policy

4. Key Principles

4.1 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 Colleagues can report any legitimate concerns in confidence. It is important that 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 belief that is the case.

4.2 Speaking Up/Raising a concern what is covered by this policy

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, in terms of Public Interest Disclosure:

• that a criminal offence has been committed, is being committed or is likely to be committed;
• that a person has failed, is failing or is likely to fail to comply with any legal obligation to which they are subject;
• that a miscarriage of justice has occurred, is occurring or is likely to occur;
• that the health or safety of any individual has been, is being or is likely to be endangered;
• that the environment has been, is being or is likely to be damaged; or
• that information tending to show any matter falling within any one of the preceding paragraphs has been, is being or is likely to be deliberately concealed.

“The Bank is owned by His Majesty’s Government (“HMG”) but Colleagues are not Civil Servants. The Bank’s Executive team nevertheless believe that codes of conduct that operate within the civil service set standards that the Bank wishes to take on as its own. The Bank’s Code therefore draws on and is consistent with the Civil Service Code, and other standards directly applicable to those in government and wider public service.” This policy provides a reporting process for any wrongdoing under the Code of Conduct.

4.3 Who should I make a disclosure to?

You should normally raise concerns with your immediate line manager. However, we recognise that you may not always feel comfortable raising your concerns with your manager. If this is the case, then you can report your concern to one of the following designated  Speak Up Champions who have responsibility for dealing with concerns raised by Colleagues:

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

4.4 How should I make a disclosure?

You should raise your concerns in writing, providing specific examples of the alleged wrongdoing.  You should state that you are using this policy and if possible provide your details, bearing in mind that we will take measures to preserve confidentiality where possible.

If you wish to raise concerns on a confidential basis then there is a dedicated email address [email protected] or you can use the Speak Up Portal.

4.5 Investigation of disclosures

We are committed to investigating disclosures fully, fairly, quickly and confidentially where circumstances permit.

The length and scope of the investigation will depend on the subject matter of the disclosure.  

In most cases a Speak Up Champion or a member of the Human Resources team will carry out an initial assessment to determine whether there are grounds for a more detailed investigation to take place.

If a full investigation is considered necessary, the Speak Up Champion or Human Resources will appoint an appropriate person to investigate your disclosure.  You may be asked to attend a meeting to provide further information.

You may bring a colleague or Trade Union representative to any meetings under this Policy. Such colleague or representative must respect the confidentiality of your concern and any subsequent investigation.

If the Speak Up Champion considers it appropriate and practicable you will be informed of the progress of the investigation, however the need for confidentiality may prevent you being given specific details of the investigation or actions taken.

It is not normally appropriate to set a specific timescale for completion of speak up investigations in advance, but we aim to deal with all disclosures in a reasonable timeframe.

All investigations and their findings will be reported to the Board Audit Committee and where required the relevant Government department or regulatory body. 

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

4.6 Corrective action and compliance

If an investigation highlights areas of concern, the Speak Up Champion or investigator will make recommendations for change. The audit committee will be responsible for reviewing and implementing these recommendations.

4.7 How to speak-up to an external person

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

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

A full list of prescribed persons and guidance on making a disclosure to the relevant Prescribed Person is available via the .gov.uk website. 

4.8 Making a disclosure to another body

It is recommended that you report your concerns internally with your line management or a designated person in the first instance. 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.

You can seek guidance before reporting a concern externally. The independent charity Protect (formerly Public Concern at Work, PCAW) provides further advice for any Colleagues who are concerned about possible wrongdoing at work or who need further guidance.

4.9 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 Colleagues who raise genuine concerns under this policy even if they turn out to be mistaken.

The Bank is committed to ensuring that you will not suffer any detrimental treatment as a result of raising a concern that you reasonably believe to be true. 

If you believe that you are being subjected to a detriment as a result of raising your concerns under this policy you should inform the Speak Up Champions immediately or raise your concerns with your line manager or HR using the HR portal.  If the matter is not resolved, you should raise it formally under our grievance policy.

Colleagues who victimise or retaliate against anyone who has raised concerns under this policy may be subject to disciplinary action under our Disciplinary Policy, which could result in action up to and including dismissal without notice. 

If concerns raised under this policy are considered to have been made maliciously, vexatiously or with a view to personal gain, you may be subject to disciplinary action under our Disciplinary Policy which could result in action up to and including dismissal without notice.

4.10 Confidentiality and anonymity

If you make a disclosure under this policy, we will make every effort to keep your identity confidential, at least until any formal investigation is under way. There may, however, be circumstances in which, because of the nature of the investigation or disclosure, it will be necessary to disclose your identity however we will discuss this with you in advance.

In order not to jeopardise the investigation, you will be expected to keep the fact that you have raised a concern, the nature of the concern and the identity of those involved confidential. 

We would encourage you not to make disclosures anonymously. Proper investigation may be more difficult or impossible if the investigator cannot obtain further information from you. Also, we will not be able to provide you with feedback.

If you are concerned about disclosing your identity, speak to the Speak Up Champion, your line manager or HR about it.

4.11 Maintenance of Records

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