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 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.

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, 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.

In addition to this, Bank employees are public servants. As such they are expected to always uphold the ‘Nolan Principles’ that set the standards for officials to carry out their roles as well as a commitment to the wider core values of the Civil Service of integrity, honesty, objectivity and impartiality. Anyone who reports any concerns over this, or who reports that they have been put in a position where they are asked to breach this duty, will not be subjected to any detriment as a result of that report.

If the concern you are raising relates to your work or working conditions and only affects you, you should raise it under the Grievance Policy and Procedure or, where appropriate, the Prevention of Bullying; Harassment and Sexual Harassment Policy.

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

The Bank is committed to ensuring that Colleagues will not suffer any detrimental treatment as a result of raising a concern that they reasonably believe to be true. This includes (but is not limited to) dismissal, disciplinary action, threats, bullying or other unfavourable treatment connected with raising a concern. The Bank will also not tolerate any harassment or victimisation of Colleagues who speak-up on any matter, 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 Bank Disciplinary Policy and Procedure.

If, as a result of speaking-up, you feel you have suffered a detriment please raise this with HR through the HR Portal on the Intranet, with your line manager or directly with HR.

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 or that it is not appropriate to do so. 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 Colleagues:

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

If you wish to raise concerns on a confidential basis then there is a dedicated email address speakup@british-business-bank.co.uk 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 as far as is possible.

We hope that Bank Colleagues feel able to voice concerns openly under this policy.

If the 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. 

You may also choose to speak to one of the Colleague Forum representatives.

Additionally, the Bank provides a portal through which Speak Up reports can be made either anonymously or not, which are handled by the HR team. You can find this portal on this link:

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It is not always possible to keep information anonymous where an investigation has to take place, and anonymity cannot be guaranteed in all cases. The Bank would, however, inform an individual if there was a situation where their complaint was no longer anonymous.

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 Trades Union representative to any meetings under this Policy. Such 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 Board Audit Committee and where required the relevant Government department or regulatory body, taking into account any request for anonymity from the Colleague who raised the concern.

It may be the case that a Colleague bringing a concern is not given information on the outcome of the investigation.

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 Colleagues with the guidance and reassurance they need to speak-up internally. However, it is recognised that there may be circumstances where a 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 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 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 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.

We would strongly advise you to 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. Protect’s website can be found at https://protect-advice.org.uk/

3.7 Advice for managers in receipt of a concern

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

• Listen to their concerns and be empathetic and open minded;
• Assist the colleague with determining whether the concern should be dealt with under this policy or under the Bank’s Grievance Policy and Procedure, or Prevention of Bullying; Harassment and Sexual Harassment 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 Colleague speaking-up that they will not be subject to any detriment as a result of raising the concern;
• Manage the expectations of the Colleague and what feedback they can expect;
• Maintain records of your conversations with them, and document any actions taken;
• If possible, confirm receipt of the report to the 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 Board Audit Committee, content removed are responsible for:

• Receiving concerns from managers/Colleagues;
• Maintaining the Speak-Up Register;
• Arranging for investigations of concerns raised, working with other teams such as Legal or HR as appropriate;
• Documenting the findings and securing any evidence;
• Engaging with the Prescribed Persons where there is a need;
• Working with the investigator to propose actions as a result of the findings where necessary.
• Providing feedback to Colleagues during/after the investigation;
• Providing an independent and confidential report to the Audit Committee on each matter investigated;
• Pastoral support for the individual who has raised an issue, even if no outcome is able to be communicated to that person.

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.

The Managing Director of Internal Audit, content removed and the Chair of the Board Audit Committee, content removed are responsible for monitoring and following up on any reports received in the portal.

3.9 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.