Here at the Co-op we take whistleblowing very seriously and are committed to investigating any allegations raised. If a colleague raises a whistleblowing issue to a manager, here are the steps managers should follow to deal with it. There’s a list in the Whistleblowing Policy of the types of things that class as whistleblowing.
Colleagues can also raise their concerns to other internal contacts which can be found in the Whistleblowing Policy. They can also contact the free and confidential whistleblowing line “speak up” 24/7 on 0800 915 1571 or www.safecall.co.uk/coop.
1) Colleague raises concerns to a manager
Colleagues should raise any concerns with their line manager first, so they can try to resolve the issue. But if colleagues feel unable to do this, or their line manager’s involved in the activity they have concerns about, they can talk to another manager, or to the other contacts detailed in the Whistleblowing Policy.
Colleagues can raise concerns either in person or in writing. Concerns can be raised anonymously, but it may then be difficult for managers to carry out a full investigation if they need further details from the colleague.
2) Manager receives the whistleblowing concern
If a manager receives a whistleblowing complaint, it’s important to deal with it as soon as possible. Depending on what type of issue it is, there might be a legal timescale for resolving it. It’s important that managers recognise the difference between a whistleblowing concern and a grievance.
A grievance is a complaint about something to do with the colleague as an individual, like how they feel they’re being treated at work. Whistleblowing is usually a concern about a wrongdoing that affects the Co-op more widely – there are examples in the Whistleblowing Policy.
3) Inform Internal Audit
All Whistleblowing cases must be logged with the Internal Audit Team for monitoring and reporting purposes. Internal Audit keeps a track of each allegation, who is investigating and what the outcome is. Statistics are reported half yearly to the Risk and Audit Committee. Please let the Internal Audit team know of any whistleblowing reports you receive.
4) Whistleblowing investigation
Once it’s clear that it’s whistleblowing, it’s important that it’s investigated as quickly as possible. You should only investigate if you’re independent to the issue raised. If the complaint involves you, then you should pass it to another manager to deal with.
If you are asked to investigate a whistleblowing case take note of the key points below:-
- You must not treat the colleague differently because they have spoken up. If you do, you may be investigated, and this could lead to disciplinary action against you
- If the allegations were made anonymously, a thorough investigation should be carried out but no attempts should be made to try and identify the whistleblower
- If the complaint was not anonymous you must not reveal their identity without their consent. The investigation may mean you need to contact the colleague to get more information. You should ask them if they want their identify to be kept confidential and if that’s the case, let them know that you won’t share their details without their consent. Reassure them that they won’t be treated any differently at work for speaking up
You should then consider who else you need to speak to, depending on the nature of the whistleblowing concern. For example;
- if the concern is about health and safety speak to the Health and Safety team
- if it’s about financial irregularities speak to your Finance Partner
- if it’s about a potential criminal matter speak to the Risk team
When a concern is about the conduct of another colleague, get advice from ER Services before you speak to that colleague. If you are unsure, contact the Internal Audit team for advice by emailing email@example.com.
There’s no set timescale for investigating a whistleblowing complaint, as each situation will be different - but 21 days is a guideline. You should carry out your investigation as quickly as possible, while making sure you look into things thoroughly. Keep the whistleblower informed if your investigation is taking longer than you originally thought, so they know it’s still ongoing and hasn’t been forgotten. Remember to also keep the Internal Audit team up to date on the progress of your investigation.
5) Regulated businesses
If you work in a regulated part of the business and you receive a whistleblowing concern, it’s important that you notify an appropriate member of the senior team so that they can help with any kind of investigation. The key contacts are;
- Jamie O’Brien, Regulatory Risk Manager (CISL – Co-op Insurance Services Ltd). firstname.lastname@example.org
- Steven Martin, Head of Legal Practice Compliance (Co-op Legal and Life Planning Services) email@example.com
If the whistleblowing concern is of a serious nature and you don’t know who you need to speak to for advice, you can contact Saleem Chowdhery, Director of Risk and Internal Audit, firstname.lastname@example.org
Depending on what you find in your investigation, there are different outcomes you may have.
If you don’t find anything to support the colleague’s concern, or you find evidence to suggest that it isn’t true, you should inform the colleague that the matter has been investigated and there’s no information to support their concern.
Remember that a colleague’s whistleblowing complaint doesn’t have to turn out to be true. They just need to reasonably believe that it was true when they raised it. So thank the colleague for speaking up about their concerns and reassure them that things have been taken seriously and thoroughly looked into.
If you do find evidence to support their concern, you should take the necessary steps to resolve the matter. If you find that individual colleagues are accountable, then you should contact ER Services for advice. An independent manager will need to carry out a disciplinary investigation into their conduct.
Again, you should inform the colleague who raised the concern that you have investigated the matter and actions are being taken to address the issues raised – but you shouldn’t tell them about any action that may be taken against other people, as this is confidential.
For all cases – on completion of the investigation – please provide the outcome to the Internal Audit team with a proposal of the next steps being taken to resolve the matter.
7) Investigation records and Paperwork
Once the whistleblowing case has been dealt with, it’s important that you keep all the paperwork for 6 years in case it needs to be referred to. This includes notes from your investigations, evidence you gathered, letters you’ve sent and any emails you’ve received.
You should keep these in a secure place, and they should remain confidential unless you are asked for them by a member of the Internal Audit or Legal teams.