Internal whistleblowing

Overview

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. Colleagues 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 concern about potential wrongdoing or malpractice that affects others or the Bank as a whole, you reasonably believe it is in the public interest to report – 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 colleagues and the Bank.

Even if you aren’t completely sure if your concern falls under the internal whistleblowing policy, but you feel that something isn’t quite right, it is important that you report it. If your concern is not covered by this policy, we can help by redirecting your concern to the right people.

Reporting potential wrongdoing or malpractice 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 concerns, either with your direct managers or to designated people outside your 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]} (PIDA), the 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 others at work, including your manager. That is for the Bank’s grievance process as set out in section D3 of the Staff Handbook or Anti-Bullying and Harassment 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 concerns covered by this policy are set out in our FAQ document.

Who does this policy apply to?

This policy applies to all Bank colleagues. This includes consultants, contractors, and agency staff. This policy includes responsibilities for line managers when an individual raises a concern.

This policy is part of Our Code, which we are all required to attest to annually.

What you must know or do

The Bank needs you to raise any concerns about potential wrongdoing or malpractice that affects others or the organisation as a whole (where there may be a public interest in the disclosure), 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 internal whistleblowing concerns passed to you by third parties outside the Bank.

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

Our assurances to you

To those who report a concern under our whistleblowing policy, we undertake that:

• You will not lose your job or suffer any other detriment (eg disciplinary action, threats or any other unfavourable treatment) for raising a whistleblowing concern in good faith. It doesn’t matter if you are mistaken. We do not tolerate any victimisation or harassment of those who whistleblow. Individuals working at the Bank must not threaten or retaliate against whistleblowers in any way, and they may be subject to disciplinary action if involved in such conduct.
• We treat internal whistleblowing matters sensitively and in confidence. 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, and it will only be disclosed on a confidential ‘need to know’ basis to those individuals responsible for investigating the concern. If it becomes impossible to investigate without disclosing your identity beyond this, we will discuss this with you before taking further action. In exceptional circumstances protecting your identity may not be possible, for example, if we are required to do otherwise by law.

Once you have raised a concern

• We will set up a confidential meeting or call with you. We will assess whether your concern falls under internal whistleblowing or not. 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 and 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).
• You will be asked to make the person handling your case aware if you have any concerns around victimisation or believe that you are suffering detriment for having raised a concern – both during the investigation and following its conclusion. If any such issues should arise, you should report this to the person handling your case, or if your case has concluded, to the Secretary or any member of Secretary’s internal whistleblowing team. The Bank does not tolerate any victimisation or harassment of whistleblowers.
• Depending on any investigation findings, appropriate and proportionate action will be taken to address any issues identified. Once an investigation is completed, where possible, we will update you on its findings. Given confidentiality obligations to staff, you may not be provided with the full outcome of an investigation (for example, if disciplinary action is taken).

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 information on how the Bank processes your data, please see our staff data privacy notice.

For all colleagues

If you have a concern about potential wrongdoing or malpractice that affects others or the Bank as a whole, it is vital that you report it.

If you have a concern about potential wrongdoing or malpractice that affects others or the Bank as a whole, it is vital that you report it.

First, if you can, tell your line manager or HoD.

If you feel unable to do that, for whatever reason, or feel that they have not dealt with the matter appropriately, please use one of the other channels below.

You can email Secretary’s internal whistleblowing team via its dedicated mailbox

Alternatively, you can raise the matter with any one of the following:

• Secretary of the Bank of England.
• Deputy Secretary.
• Executive Director, People.
• IAWB Manager, Legal.
• Head of Internal Audit.

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 an internal whistleblowing concern. You may also raise an internal whistleblowing concern via:

• Unite Seconded Rep (you don’t need to be a member of the Union). The Unite Seconded Rep can pass the concerns on to the relevant authorities on behalf of the whistleblower if they need support to do so.
• If you feel unable to raise the issue with any of the above channels, you can raise a concern externally via a confidential helpline provided by the Bank’s Employee Assistance Programme.
• Alternatively, or if you feel that your concern is not being treated appropriately, you may contact the Bank’s internal whistleblowing champion, the Chair of the Bank’s Audit & Risk Committee (ARCo) or the Chair of Court. The Bank’s internal whistleblowing champion is responsible for ensuring and overseeing the integrity, independence, and effectiveness of our arrangements.
  Please note that the internal whistleblowing champion and the Bank Chair don’t have a day-to-day operational role in handling whistleblowing disclosures, but they will ensure that appropriate action is taken. Communications may be shared by them on a confidential ‘need to know’ basis with those individuals responsible for investigating the concern.
• Protect, the UK whistleblowing charity, can provide confidential advice to people thinking of whistleblowing.

For all managers

You should make sure that your team are aware of this policy and encourage a positive open working culture in which individuals feel comfortable in raising concerns.

If an individual raises a concern about wrongdoing or malpractice that affects others or the Bank as a whole, Secretary’s Department will determine whether it should be treated as an internal whistleblowing case. This means you must:

• Promptly notify the Secretary or Deputy Secretary of the case (and make the individual who has raised the concern aware that you will do this); You should speak to the Secretary or Deputy Secretary for guidance if an individual has confidentiality concerns about your reporting to Secretary’s on a named basis.
• If it is an internal whistleblowing case, then the Secretary or Deputy Secretary will decide, in consultation with you, whether you should remain involved in the case.

Further information is available in our Guidance for managers handling an internal whistleblowing concern.

What support is available to help you comply with this policy?

The following documents will aid your understanding of, and compliance with, 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 on what to expect when you raise an internal whistleblowing concern.
• FAQs for additional background on internal whistleblowing.
• Guidance for managers handling an internal whistleblowing concern.

What is the impact of non-compliance?

It is important for us all to raise 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 raises an internal whistleblowing concern.