Update of Morris Inquiry Recommendations

Report: 8
Date: 12 November 2009
By: Chief Executive and the Commissioner

Summary

The MPA commissioned the Morris inquiry, chaired by Sir Bill Morris, to conduct an independent and impartial investigation into professional standards and employment practice in the Metropolitan Police Service (MPS) examining the way complaints, grievances, allegations against individuals and conflict within the workplace is handled by the organisation. The inquiry was formally launched on 21 January 2004 and the report was published on Tuesday 14 December 2004. The MPA as well as commissioning this work maintained an oversight role in terms of ensuring that the recommendations were adequately addressed.

The Morris Inquiry made 37 recommendations for the MPS and MPA. Since this time the MPA and MPS have been working hard to deliver and embed the outcome of those recommendations. The MPS and MPA have achieved a great deal since 2004, in particular the work on eliminating discriminatory management practice has encouraged a fall in age discrimination claims. However more work needs to be done in regards to lowering employment tribunal claims on the grounds of race, sex and disability.

The MPA and MPS have also made significant strides in developing a framework that encompasses all aspects of equality and diversity. Both organisations developed a Generic Equality Scheme (GNES). The spirit of the statutory duty of the MPS to monitor race, disability and gender will be applied to discrimination on the grounds of age, religion and/or belief and sexual orientation, where the statutory duty does not apply. In doing so the MPA and MPS intend to create a more holistic approach to equality and diversity to both challenge the organisations and to champion and drive equality and diversity issues.

The challenge in the future for both the MPS and the MPA will be to ensure that our respective Equalities Schemes remain as living documents and are used as a framework and drivers for the Equalities work we carry out in our organisations.

On 6 October 2008, Boris Johnson, Chairman of the MPA, invited Cindy Butts to chair an inquiry into race and faith issues in the MPS. This Inquiry has examined the current position of the MPS in order to establish what has changed as a result of lessons learnt from the past, identifying success and good practice and further opportunities to build upon this. The Race and Faith Inquiry has provided an opportunity for the MPA to review its own oversight role and make recommendations for improvement. It is therefore sensible at this time to take stock of what the MPA has achieved in terms of implementing the Morris Inquiry recommendations in order to formally sign off this work.

The Race and Faith Inquiry went beyond the remit of the Morris inquiry as it covered the impact on race and faith on recruitment, retention and progression within the MPS. It also focussed on the corporate leadership provided to ensure equality and diversity is mainstreamed effectively throughout the organisation and the extent to which the MPS communicates and effectively builds relationships with all staff and officers through representative groups. The retention and progression of under-represented groups, particularly BME officers and staff will be considered within the findings of the inquiry.

This paper highlights progress on the Morris Inquiry recommendations.

A. Recommendation

1. Members formally sign off all Morris Inquiry recommendations that are cited as achieved.
2. Members consider the remaining Morris Inquiry recommendations in light of the Race and Faith Inquiry, and agree that future updates are combined with the final recommendations of the MPA Race and Faith Inquiry.

B. Supporting information

In 2004, when the Morris Inquiry was commissioned the chair of Inquiry (Sir William Morris) wrote in the Chair’s foreword:

‘As the frontier of crime expands with the rise of global terrorism and the changing social and demographic profile of London, it is inevitable that the social cohesion between police and citizens will be subject to some stress and much tension. But despite that, let us pause to remember that scores of police officers daily put themselves in harm’s way in the defence of the nation’s security’ AND

‘There was a common misapprehension that our Inquiry was about race. We have considered discrimination issues as part of our work, and some of our Recommendations focus on the way in which black and ethnic minority officers and staff are treated and managed. We hope that our recommendations will help the MPS manage difference in its widest sense. Whilst we can see much which is good about the MPS, we are nonetheless extremely concerned by the lack of direct accountability at senior levels within the organisation’

The MPS and MPA have worked hard at making a difference, however we still have some challenges. Since the publication of the Morris Inquiry, we have experienced the London Bombings and the aftermath of this tragedy. The MPS continues to work on the improvement of its intelligence gathering and counter terrorism measures.

The recommendations that cover discrimination in all its guises continue to be a concern, and whilst great strides have been made to address how the MPS manage difference, it seems that the early findings from the Race and Faith Inquiry suggests there is a lot more work to be done.

The following text highlights the progress on all 37 Morris Inquiry recommendations. The recommendations have been split under four distinct headings. The headings are:

• Achieved – this indicates that the recommendation has been implemented and the MPA are satisfied through demonstrable examples that the recommendation has been achieved;
• Not Achieved – this indicates that the recommendation has not been implemented with reason and highlights what steps are being taken to rectify this;
• Unachievable – this indicates that the recommendation for various reasons is not obtainable and the rational as to why this is AND
• Ongoing – this indicates that work has started on the recommendation and will be progressed until it is has reached ‘achieved’ status or that by the very nature of the work required to implement the recommendation it will continue and will be monitored and reviewed.

Achieved

The following recommendations have been achieved.

1) That the office of constable should be retained for all police officers. (Para. 3.18)

In evidence to the Inquiry, there was strong support for retaining the office of constable from, among others, the Association of Chief Police Officers, the Association of Police Authorities, the Police Superintendents’ Association of England and Wales (National and Metropolitan), the Police Federation (National and Metropolitan) and the Metropolitan Police Service itself. The only way to change this status would be by a change in legislation and none of the main political parties have shown any interest in making such a change. The only ‘dissenting voice’ was the Police Action Lawyers Group (PALG), a group of lawyers who represent complainants against the police in England and Wales. They stated: “We see no reason why any special status for police officers should be retained, we accept the need for independence and the exercise of discretion by officers when exercising their policing powers. We see no reason why this cannot be safeguarded in their contracts of employment.” Given that no legislative change has been made to affect the office of constable, the recommendation has been implemented.

2) That employment law should be extended to police officers within the framework of the office of constable.

Police officers do not under employment legislation have the right to claim unfair dismissal. They are not employees in this sense although they may be for other purposes eg, in respect of income tax and national insurance, in respect of the protection afforded by discrimination law (race, gender, disability, age, sexual orientation and religion or belief), for tortious liability, and for health and safety at work matters etc. The conduct and disciplinary process in respect of police officers is regulated by statute. It is the view of ACPO, the APA, the MPA and the MPS that if the right to claim unfair dismissal was extended police officers could in principle be afforded necessary employment protection and the advantages of simplified procedures whilst retaining their independence and discretionary legal autonomy. However, this would require legislative change and none of the main political parties have shown any interest in making such a change.

2a) That appropriate structures and systems are devised for negotiating national terms and conditions and for deciding which terms and conditions should be national and which left to local determination.

The Police Negotiating Board was established by Act of Parliament in 1980 to negotiate the hours of duty; leave; pay and allowances; the issue, use and return of police clothing, personal equipment and accoutrements; and pensions of United Kingdom police officers. The PNB makes recommendations on these matters to the Home Secretary, Secretary of State for Northern Ireland and Scottish Ministers.

The parties to negotiation are the Official Side, comprising representatives of the Secretaries of State, police authorities and chief police officers, and the Staff Side comprising representatives of the police staff associations.

In July 2008 the National Policing Board (NPB) commissioned ACPO, APA and the Home Office to develop a package of targeted reforms for police pay and reward arrangements. The NPB commission was informed by and developed from consultation during late 2007 including with the PNB Official Side and PSC Employers Side, on the strategic aims for any pay reform. The results of this consultation and analysis by ACPO, APA and Home Office reward leads, were reported to the NPB resulting in this commission.

The NPB commission was for a package that focused on possible changes that could best support and enable key workforce areas in the Green Paper; supporting the effective deployment of responsive and visible policing to the public by professional and effectively managed officers and staff. The NPB commission to ACPO, APA and the Home Office was therefore that the development of possible changes should focus on three key areas in the Green Paper: Development, Leadership and Deployment.

The NPB consideration included the criteria for the assessment of possible changes, options and packages. These are:

• Clear cost benefits analysis (including support for wider reform)
• Dependency identification and assessment (how can we ensure that there are reliable mechanisms to implement any changes, e.g. PDR development and managerial capacity and capability)
• Negotiability

2b) That the terms and conditions should include disciplinary, capability and grievance procedures in line with the ACAS Code of Practice on Disciplinary and Grievance Procedures. The current regulatory framework for complaints and discipline for police officers would no longer apply.

Recommendation implemented.

The Codes of Practice have been amended by ACAS.

From 1 December 2008 a number of revised arrangements were introduced:

• The Police (Performance) Regulations 2008
• The Police (Conduct) Regulations 2008
• The Police (Complaints and Misconduct) (Amendment) Regulations 2008
• The Police Appeals Tribunals Rules 2008
• The Police Amendment Regulations 2008

These were based on the Taylor Review of the police officer disciplinary arrangements published in 2005, which recommended a new disciplinary procedure and a review of the unsatisfactory performance procedures for police officers.

2c) That the office of constable is enhanced by the addition of a Code of Conduct, similar to the Civil Service Code and the Code of Ethics for the Police Service in Northern Ireland, which would form part of the terms and conditions of all police officers and police staff. This would replace the current Code of Conduct for police officers.

2d) That a provision dealing with unlawful discrimination should be included in the new Code of Conduct. Additional provisions may also be appropriate.

Recommendation implemented.

The Conduct Regulations contain the new Standards of Professional Behaviour which set out the standards of behaviour that police officers are expected to maintain. These standards should be actively promoted to all staff. Appendix A lists these standards.

2e) That disciplinary cases involving serious criminal allegations should continue to be dealt with under the special procedure, which requires cases to be referred to the Crown Prosecution Service out of region, but that more routine matters should be dealt with in the same way as similar allegations against members of the public, that is, by referral to the local Crown Prosecution Service lawyer

Recommendation implemented.

Any circumstance involving a senior officer disciplinary with potential serious criminal allegations already go to the IPCC and this is the same for the MPS Directorate of Professional Standards.

2f) That a procedure, involving conciliation and / or arbitration, is devised to resolve industrial disputes in the police service.

There is a process for pursuing ‘failures to agree’ at PNB to a Police Arbitration Tribunal (PAT). Police Officers in the United Kingdom are prohibited by statute from the right to strike. Under the Constitution of the Police Negotiating Board, therefore, matters on which no agreement can be reached, and which cannot be resolved by conciliation, may be referred by either Side to arbitration. Pension matters are, however, not arbitrable. Arbitration is carried out by a standing PAT, which operates under the auspices of the Advisory, Conciliation and Arbitration Service (ACAS). The PAT consists of three arbitrators appointed by the Prime Minister.

In recent years a number of issues namely: 2007 pay settlement; the ‘level playing field’ claim by the Staff Side; claim by the Staff Side for an on call allowance for police officers, have been referred to the Tribunal.

No such machinery exists for police staff. The national arrangements negotiated by the Police Staff Council represent a framework of pay terms and conditions which can be adopted by local forces to a greater or lesser extent. Bargaining and negotiation on substantive and procedural issues takes place locally in many forces.

Police Staff in the Metropolitan Police Service (MPS) were historically civil servants with terms derived from those applicable to Home Office civil servants. Over the years devolved bargaining and the creation of the Metropolitan Police Authority has led to a different approach to pay terms and conditions being adopted to the rest of the country.

The four trade unions recognised for collective bargaining in the MPS have indicated as recently as 2007 that they do not wish to include as part of the machinery of negotiation referral of issues to external bodies for conciliation or arbitration, preferring to rely on negotiation between parties to resolve issues.

3) That the post with overall responsibility for Human Resources should be held by a suitably qualified and experienced individual, and that the post-holder should be by designation a member of the strategic management board.

Recommendation implemented.

At the time of the Morris Inquiry an Assistant Commissioner (Bernard Hogan-Howe) was responsible for the Human Resources Directorate, although his two predecessors had been professionally qualified police staff. In order to support him in his role, Martin Tiplady, a professionally qualified member of police staff, was appointed Deputy Director of HR in December 2001. When Bernard Hogan-Howe was appointed as Chief Constable of Merseyside, Martin Tiplady replaced him as a Management Board member in 2004.

3a) That, in addition to relocating the Employment Tribunals Unit from the Directorate of Professional Standards to the Human Resources directorate, the people management aspects of the work of the Diversity Directorate are also moved to the Human Resources directorate.

Recommendation implemented.

The responsibility for all learning and development (including equality training) rests with the Commissioner and his Management Board. Management Board is supported in this through the Training Management Board (TMB). The strategic direction and prioritorisation of MPS training is agreed and maintained by TMB. A senior ACPO officer serves as the Director of Training and Development with overall responsibility for all training delivered across the MPS. This post now has responsibility for equality training.

In addition, the Diversity Learning and Development Branch transferred from the Diversity and Citizen Focus Directorate to HR in April 2008.

3.b) That the policy review process be given new momentum with a view to simplifying and reducing the number of human resources’ policies even further.

Recommendation implemented.

A three year programme to replace the current HR model is nearing completion. Transforming HR (THR) is a key MPS modernisation programme that will introduce a more efficient and modern delivery model for the HR function and a more strategic HR capability The THR Programme will deliver a new HR organisation, new service delivery processes, a new technology solution, and is underpinned by a wide-ranging and innovative business change initiative.

Under Transforming HR Day to day HR services will be delivered by a Service Centre based at Empress State Building. A 24/7 capability will provide improved access for operational staff, and field-based teams will offer face to face customer support. Line managers and staff will be able to get policy advice either interactively from an Aware terminal or by telephoning the Service Centre.

HR have undertaken a full policy review and rationalisation process which culminated in the number of HR policies being reduced from 35 to 17.

3.c) That the Human Resources directorate reviews the management information it currently collects with a view to ensuring that it has the data needed for the MPS to fulfil its objectives.

Recommendation implemented.

MetHR continues to be the organisation's human resources database and the information held within this system is reported in the HR Headline Scorecard, and other management information reports. The information presented in the HR Headline Scorecard plays an integral role in shaping the strategic and operational decisions of the MPS. To ensure that the data held within the MetHR database remains accurate, a compliance strategy (published on the intranet) is in place that requires BOCUs and business groups to take ownership for the system. Compliance with this policy continues to be monitored centrally.

3.d) That the MPS should ensure that the Human Resources directorate plays a full part in the management of discipline cases, with responsibility for maintaining contact with officers under investigation and overseeing welfare support and re-entry into the workplace for suspended officers.

Recommendation implemented.

The central Practice Support Team provides a range of training, awareness and information events/newsletters. An internal MPS report (Dialogue to delivery March 2009) states ‘following the recommendation from the Morris Inquiry, the Suspension Support Policy and associated SOPs were developed to ensure the MPS provides an appropriate and consistent level of support to officers and staff who are suspended pending the outcome of an investigation. This included setting up a Suspension Support Unit (SSU).

The SSU exists to maintain an overview of MPS suspension policy and to ensure that relevant managers are aware and undertake their responsibilities in this. This applies to all officers up to and including ACPO level.

A key objective of the SSU is to provide a corporate overview and governance of the support provided to individuals who are suspended while under investigation. The SSU undertakes to monitor and track the support provided by Operational Command Units. A dedicated member of Employment Support Unit (ESU) staff undertakes this specific activity. At the time of suspension the relevant BOCU is required to inform the SSU. This acts as a trigger and provides key details about the individual, the reason for the suspension, details of local management involvement and confirmation that a Suspension Support Officer has been offered. It should also indicate if the individual wishes to be placed on the corporate Keep In Touch Scheme (KITS).

On receipt of this information, a new entry is created on the SSU database that captures key information. This establishes a separate audit trail that will serve to evidence the on-going support provided to a member of the Service throughout the duration of their suspension. On a monthly basis, the dedicated member of the SSU establishes contact with every HR manager that has suspended staff on their BOCU requesting an up-date on the on-going support provided by both line management and the Suspension Support Officer.

At the end of a suspension or at the conclusion of a case the SSU database is updated to show the particular case is closed. The electronic and associated paper records are held securely in the SSU for seven years. Where officers and members of police staff elect to be placed on the corporate KITS scheme they are provided with a weekly newsletter advising of developments across the Service together with copies of policy/legislation etc. The SSU are available to provide advice and guidance to HR staff, and Suspension Support Officers (SSOs) to ensure compliance with policy and the Standard Operating Procedures. An example of the practical support provided to suspended officers would be to act as a sounding board for the individual and as a conduit between them and the B/OCU, to facilitate routine administrative matters such as the delivery of correspondence. Whilst such matters may appear on the surface to be low level, they are often of great importance to individuals who are suspended from duty. The SSO also ensures that the individual is fully aware of the appropriate professional support networks and advisory services available to them.

Prior to the creation of the SSU, previous arrangements were ad hoc and locally administered. It is important to note that the work of the SSU in this area is independent of the Directorate of Professional Standards (Police Officer Suspensions) and HR Practice Support Team (Police Staff Suspensions) in that it plays no part and has no influence in the actual suspension process, including the decisions on whether or not to suspend. However, where appropriate there is liaison between the respective units. The implementation of the policy relies on management at a local level. Corporate governance by the SSU is able to identify (at an early stage) those command units that do not appear to be complying with policy such as the contact log not being kept up to date and will therefore trigger intervention to rectify the situation.

Cross Reference Mechanisms have also been built into the process to ensure that the details of all suspended staff are captured by the SSU. The dedicated member of staff has access to the DPS database and will cross reference information held on the SSU database to identify any police officers recently suspended that have not been disclosed to us by a BOCU. The HR Practice Support Team submits a spreadsheet with details of all police staff on suspension and this is again cross-referenced with the SSU database to identify any staff not known. Whilst the unit is proactive in offering direct support and access to appropriate support mechanisms, it is a voluntary scheme and therefore staff may choose not to participate in taking up the services offered.

4) That the MPS replaces its Fairness at Work policy with a new grievance procedure based on the ACAS Code of Practice on Disciplinary and Grievance Procedures. The procedure should cover all workplace conflicts involving officers and staff.

Recommendation implemented.

The MPS reviewed the Fairness at Work policy in response to the Morris recommendations and the MPA HR Committee endorsed the conclusion that Fairness at work should be retained but revised to put an emphasis on early resolution and mediation as a means to resolve disputes.

It is important to note that in 2004, the then Home Secretary commissioned a review of the current arrangements for dealing with police misconduct and unsatisfactory performance. The ‘Taylor Review of Police Disciplinary Arrangements’ was the review conducted by William Taylor (a former Commissioner of the City of London Police and former HM Inspector of Constabulary for Scotland) into the effectiveness of disciplinary arrangements for police officers.

The Taylor Review advocated that the Police Service must manage disciplinary arrangements dynamically and demonstrate this by actively engaging with all groups internally to drive through the change to the internal culture of the organisation and promote the acceptance of responsibility at all levels of management.

A new misconduct procedure for police officers has been drawn up by a working party of the Police Advisory Board to replace the current police disciplinary process. The procedure applies to all police officers and special constables and underpins the Standards of Professional Behaviour, which sets out the high standards of behaviour that the Police Service expects. Any failure to meet these standards may undermine the important work of the police service and public confidence in it.

The misconduct procedures provide a fair, open and proportionate method of dealing with alleged misconduct. The procedures are intended to encourage a culture of learning and development for individuals and / or the organisation.

Since the publication of the Morris Inquiry, the reforms to the Police performance and disciplinary regulations have come into effect as of December 2008.

In light of the new misconduct regulations, it is too early to evaluate their impact on the MPS Fairness at Work policy given the intention of the new regulations to encourage a culture of learning and development. The MPA Race and Faith Inquiry will ensure continued monitoring of the Fairness at Work process.

4a) That any pilot projects on mediation follow best practice, particularly the Northamptonshire model, and take account of the wealth of learning and experience which exists within established organisations such as ACAS.

4b) That the MPS carefully monitors the development of the Thames Valley pilot on mediation.

Recommendations implemented.

Under the FaW procedure first line managers have an obligation to take early action to resolve concerns of staff informally. In certain cases managers may feel that the concerns raised could be addressed through the use of mediation, which will be available as a prelude to stage one of the FaW procedures. Local managers will be responsible for ensuring that any selected option for informal resolution has been exhausted before commencement of the formal procedure.

As with FaW, the process is confidential and will not be discussed outside of those involved. A confidentiality agreement has been drafted and should be agreed by both parties before the process commences.

Ideally the mediation process should consist of just those concerned, however it is recognised that in some situations, one or both parties may wish to have a ‘friend’ present. They are there merely to support the parties involved and will not act as representatives– there will be no need for mediators to negotiate with them as part of the process.

Should mediation be unsuccessful, or be stopped for any reason the case can proceed to FaW or another process. The FAW advisor will not be told that the case has already been to mediation to preserve the objectivity and impartiality of the FAW process.

4c) That mediators should be brought together on a regular basis to share experience and refresh their knowledge of common developments in mediation techniques.

Recommendation Implemented.

Refresher training was provided by an external organisation (Conflict Management) who delivered the week long training course to all staff selected as mediators. Marketing of mediation has taken place and included a workshop for Federation/TUS/SSA Reps. The use of the AWARE system was one of several methods used to promote the scheme and to sell its benefits. Individuals are encouraged to use mediation as a prelude to FAW.

4d) That the MPS reviews its use of mediation to provide appropriate training to its officers and staff and to encourage its use throughout the grievance process in appropriate cases.

Recommendations implemented.

A pilot mediation scheme was introduced in the MPS during May 2006 to offer staff an alternative avenue to resolve workplace disputes. Mediation is designed to compliment the FAW Procedure by affording staff access to an informal and timely process, aimed at helping them to build effective relationships. Mediators conduct both individual and group meetings with the parties in order to facilitate a process of constructive communication. This assists those in conflict by allowing them to identify solutions that will help them work more effectively in the future. An evaluation of the pilot scheme found it to be of great benefit to the organisation. For example, post-mediation questionnaires highlighted the fact that:

• 64% of respondents stated that the matter that led to mediation had now been resolved.
• 85% of respondents said they would recommend the process to others.
• Mediation has also been successful in resolving a number of cases where the Fairness at Work procedure had already been initiated.
• In one example, resolution was achieved within 4 days.

Please see Recommendation 4c) for comments in relation to training.

5) That the Director of Legal Services (DLS) invests time and resources in explaining the Directorate’s work, and how it operates, to a wider section of the organisation and to the Metropolitan Police Authority. (Para. 4.134)

Recommendation Implemented.

1. DLS reports to the MPA every six months providing information on the activities that they have undertaken and supported by a wide range of statistical information. The reports have been well received by the MPA and have improved relationships.
2. DLS have promoted their services within MPS by playing a significant role in the Corporate Governance initiatives promoted by the MPA/MPS. Only DLS are authorised to complete the Legal Implications Section on a variety of MPA/MPS reports.
3. DLS have launched MetLaw which is the MPA/MPS Purchase to Pay (P2P) system to acquire external legal services. This has involved DLS in provision of legal advice for parts of the MPS which previously used external solicitors directly.
4. The Director now attends the MPS Management Board as legal adviser.

7) That the MPS takes urgent steps to eliminate the discriminatory management practice which has led to a disproportionate number of investigations of black and minority ethnic officers.

Recommendation implemented.

Recognising that some minority ethnic groups were statistically more likely to appear within the professional standards area of business, the Directorate of Professional Standards (DPS) commissioned the Cambridge research in September 2004. It was intended both to inform the on-going review of its functions and processes and to assist in preparation for the findings and recommendations of the Morris Inquiry. With the support of MPA, the Cambridge Institute of Criminology was commissioned to provide a snapshot of DPS performance regarding its policies, processes and systems as they related to black and minority ethnic officers.

The MPS landscape - as it relates to diversity and disproportionality - has significantly changed since the research was commissioned in 2004. There is much to evidence that, not only does the MPS regard disproportionality as a strategic issue, but that the organisation has been proactive in addressing it.

A significant number of the issues raised within the Cambridge Report formed the platform for the work of the Together approach which aims to increase management and leadership capability and promote a culture where staff feel valued and supported to maximise their potential in delivering quality policing.

The Equalities Scheme sets the standard for how people can expect to be treated. It contains specific actions to ensure that equalities issues are mainstreamed into every element of service delivery and employment practice. For example, this includes ensuring that impact assessments are undertaken on policies and processes.

The Scheme articulates the requirements of individuals at all levels in promoting equality - individual, team/unit and organisational. The Scheme also includes a framework for training to ensure that all personnel are provided with information and opportunities to develop their skills and expertise in equalities matters and to ensure that their competence is assessed.

The Equalities Scheme includes an overarching performance framework to manage organisational performance on equalities. A performance management framework is already being actively used by the Diversity Board to manage and address organisational performance on a range of diversity, equality and fairness issues in both service delivery and employment practices. Work is also under way to introduce an assessment process for all OCUs across the MPS to monitor their performance against the Equality Standard for local government.

DPS Equalities Forum has a specific strand, led by a Detective Chief Inspector, looking at disproportionality issues as they affect the Directorate. The ACC has put in place a system that scrutinises disproportionality in the decision making aspects of intelligence development.

8a) That the MPS refreshes and revitalises its work in managing difference and devises a way of truly engaging all officers and staff on this important issue.

Recommendation implemented.

The launch of the Race & Diversity (Confidence & Equality) strategy in April 2006, outlined the way that the MPS proposed to give adequate priority to all aspects of diversity and increase trust and confidence of Londoners built around an Equality standards approach.

Work has since been completed to develop an Equalities Scheme which outlines the arrangements being made by the MPS to meet the legislative requirements of Race, Disability & Gender legislation and which would apply the same principles to the non legislative strands of Age, Faith and Sexual Orientation.

Supporting this major programme of work, the MPS undertook to introduce the Local government equality framework Equality Standards Assessment Tool ( E-SAT). This process proved to be unsuitable for the organisations needs and the decision was taken to design an Equality Standard for the policing of London. This performance tool has since been the subject of national interest and was adopted by the National Police Improvement Agency (NPIA) and will be implemented across all National forces after its formal launch on the 2nd of December 2009.

The MPS was finally in a position to commence training of all of its staff on the Race Relations Act General & Specific Duties in January 2009. The development of a national NCALT training module had delayed this process but will provide staff with the context to understand their 'individual responsibility with respect to discrimination, equality and role in promoting good relations both within the organisation as well as outside the MPS.

June 26th 2006 saw the opening of the MPS Leadership Academy. The Academy plays a major role in improving organisational knowledge and understanding of equality issues and provides staff with the confidence and support to take a more interventionist approach within the workplace.

A wide range of consultation mechanisms exist with representative groups. Closer links have been established between HR and Diversity & Citizen Focus Directorate. The implementation of the Police Race and Diversity Learning Programme (including the race and diversity national learning requirement) will also address this matter.

12) That the Metropolitan Police Authority puts in place comprehensive oversight systems and processes to scrutinise grievances and Employment Tribunal cases as soon as possible, taking account of the Association of Police Authorities’ guidance in this area.

Recommendation implemented.

The MPA has a responsibility to secure the maintenance of an efficient and effective police service. As part of its fulfillment of that duty, the MPA has a responsibility for monitoring the way in which the MPS deals with Employment Tribunals and Fairness at Work (FaW) cases. The Association of Police Authorities (APA) guidance entitled “Tackling Discrimination: Police Authority Oversight and Scrutiny of Grievance Procedures and Employment Tribunals” mainly dealt with establishing a protocol for the oversight role.

Following extensive discussions with colleagues in the MPS agreement was reached in principle about how this might operate for closed Employment Tribunal and FAW cases. There are naturally concerns expressed by the MPS about issues of confidentiality. Whilst the Authority has a statutory responsibility in respect of closed police discipline cases, there is not a similar responsibility in respect of closed Employment Tribunal or FAW cases.

Reports are now made to the Human Resources and Remuneration Sub Committee every six months. From the most recent Employment Tribunal cases that have been dip sampled (roughly 8-10 every month) there are two ‘themes’ emerging. The first of these, not surprisingly, is the relationship between the line manager and a member of staff which accounted for the majority of Tribunal cases that were sampled. There are any number of reasons for the problems which arise but for line managers these can be summarised as:

• The importance of good oral communication rather than email
• The importance of understanding HR policies, particularly performance development reviews (PDRs), sickness and special leave, and timekeeping
• The importance of being consistent and fair in dealings with staff.
• Keeping written records of any concerns raised by staff and the actions taken

The second theme is for the individual to understand that Employment Tribunals are not about someone being found ‘guilty’ for their behaviour or the action they have taken. This refers back to the third bullet point that staff need to understand why certain actions may or may not be taken.

It is evident from the work of the Employment Tribunal Unit that these messages – and others – are continually being reinforced, but the MPS is a very large organisation and there is no ‘quick fix’. It is also the case that when the Commissioner lodges his detailed Grounds of Resistance challenging a claimant’s version of events or it becomes clear that the claim will be contested, many of the claims are withdrawn or settled.

In terms of FaWs, the Authority does not have the resources available to be able to review all closed cases. Between 8-10 cases have been identified by the HR Policy Officer for inspection each month. The first point to make is that FAW issues raised by staff are treated with a very high level of consideration and care. If a member of staff has sought to raise a FAW, there is clearly a perception that there is something going wrong within the Operational Command Unit (OCU) or Borough Operational Command Unit (BOCU).

There are genuine attempts to take these issues seriously, to try to discover what is going wrong and what the individual is seeking by way of resolution. It is this latter point that is frequently elusive. From the FAW cases that have been dip sampled there are two ‘themes’ emerging which can be defined as ‘context’ or ‘content’. In both cases it is invariably the relationship between the line manager and a member of staff which accounted for the majority of FAW cases that were sampled. In terms of ‘context’ the main issues were:

• Interpersonal skills - poor relations or communication between a manager and a member of staff
• Decision making - lack of control over work or little participation in decisions
• Role - lack of clarity around role / fit within OCU or BOCU
• Work-life balance - conflicting demands and perceived lack of support at work
• Career / development - perceived lack of either a ‘career’ or development (e.g. training)

In terms of ‘content’ the main issues raised were:

• Task design - ill defined and subject to change in nature or priority
• Workload - inflexible or unpredictable workloads

In the majority of the FAWs which were dip sampled there was some ‘learning’ from the issues raised, although the majority (around 75%) were not substantiated. In the majority of the remaining cases that were dip sampled, the aggrieved does not agree with the findings and the matter remains unresolved. The FAWAs in particular work consciously to try to find a resolution, invariably talking to all parties and trying to repair damaged working relationships. This means looking as much at why the grievance was brought as what the grievance was about. At all stages it is equally evident that those trying to resolve the grievance are listening to the individual and trying to work with them to find a solution that tackles the issue or issues raised. Where no resolution has been reached, this occurs most frequently where the aggrieved has not been clear about the resolution they are seeking or where there is a perception that resolution involves them being found ‘guilty’ of the allegations or of their behaviour or the action they have taken. (This is an identical issue with Employment Tribunals).

13) That the Metropolitan Police Authority should convene and chair a case conference involving the Commissioner and all relevant stakeholders (including, in particular, those individuals and organisations who have given evidence to this Inquiry on this point) to establish what progress has been made in implementing the recommendations of the Virdi Inquiry Report and to determine what, if any, further action should be taken. (Para. 6.54)

Recommendation Implemented.

On 7th December 2006 the MPA’s Co-ordination and Policing Committee received a progress update on the Virdi Inquiry as part of the programme of implementation of the Morris Inquiry recommendations. It provided an update on progress on the recommendations of the Report and Supplementary Report of the Virdi Inquiry. The Committee approved the state of compliance by the MPS with the recommendations of the Virdi reports and agreed that the requirement for further update reports is now discharged.

15) That the Independent Advisory Group is properly resourced and that this should include a budget for expenditure on items such as independent professional advice (this includes legal advice), where the Independent Advisory Group believes this is necessary.

The MPS review found that Independent Advisory Groups were properly resourced. There is a budget for the Corporate IAG’s. In 2007/08 and 2008/09 this was £120,000.

17) That the Commissioner orders a fundamental review of the Directorate of Professional Standards, to be personally assured that the policies governing the practices and procedures of the directorate hold senior managers fully to account for the conduct and management of discipline investigations. (Para. 7.45)

Recommendation implemented.

A review was carried out and inspected by HMIC.

17.a) That the MPS creates a policy database and reference source that is cogent and succinct, by reducing the number of policies which impact on the process of discipline and conduct. (Para. 7.7)

Recommendation implemented.

There is only one policy that impacts on the process of discipline and conduct under which sit 14 SOPs representing key work in DPS supporting law in these areas. The policy and SOPs are reviewed annually.

17.b) That the Commissioner takes steps to ensure that the Directorate of Professional Standards appreciates the importance of scrutiny to public confidence. (Para. 6.40)

Recommendation implemented.

Communicated to staff in DPS via Information Day,s in support of the Commissioners 5 Ps programme, and Taylor News letters in circulation to all DPS staff.

17.c) That the MPS puts in place recruitment processes which are transparent and provide for equality of opportunity. These processes must ensure that people of the right calibre are recruited to posts within the Directorate of Professional Standards and must be extended to all ranks including the most senior positions. (Para. 7.56)

Recommendation implemented.

DPS recruitment processes follow the MPS SOPs in relation to recruitment / selection which ensure transparency and equality of opportunity.

Although the migration to THR is not live, all MPS selection processes are administered by Hendon. This provides a structured selection process template that is appropriate for all areas of the MPS.

17.e) That the MPS takes steps to ensure that the future profile of the Directorate of Professional Standards reflects the diversity of the MPS as a whole. (Para. 7.56)

Recommendation implemented

DPS has undertaken a specific recruitment process for under represented groups, e.g. in order to update the profile of the surveillance team, a specific process took place directed at BME groups, offering full training to successful applicants. This is a role usually advertised for 'trained' staff. DPS has also held several 'information days' to promote the DPS work and opportunities, to all groups of staff’. DPS ensures that vacant posts are also advertised directly with staff support associations as and when they are prepared for Notices.

As Sept 2009, of the total DPS staff of 500, 11% are BME and 42% are women. As the situation will inevitably fluctuate with the natural turn over of staff within the directorate the situation is monitored and proactively addressed through DPS Equalities Forum.

17.f) That a system of time-limited tenure of posts is considered. (Para. 7.56)

DPS have established a ‘Posting Period Policy’. Staff have an agreed expectation for a minimum of 2 years and a maximum of 5 years.

18) That the MPS and the Metropolitan Police Authority adopt our recommended model of case management. (Para. 7.81

Recommendation Implemented.

The former MPA Professional Standards and complaints Committee approved the introduction of a Case Management Model closely based on the Morris recommendation.

19) That the Home Office, the Independent Police Complaints Commission, the Association of Police Authorities and the Association of Chief Police Officers’ Professional Standards Committee consider the introduction of a national model. (Para. 7.81)

Recommendation implemented.

Commander Moir Stewart has informed the Authority that DPS investigative processes have been encapsulated in the Manual of Investigation (MIG) and the Policies Procedure and Practice, relevant there to, in the Manual of Guidance (MOG). The investigations reflect MPS crime policies, especially relating to victim and witness care. Both these manuals are systemically and regularly reviewed. The total documents, being fully reviewed over a 12-month period. MOG is done monthly and MIG quarterly. Proportionally issues feature prominently, with the requirements of the Independent Police Complaints Commission (IPCC) implementation and the implementation of the Statutory Guidance have provided an additional impetus and rigor to the review process.

The Review of Investigations is dealt with in quantitative and a qualitative ways. Statistical relationships, stemming from CDS, IOWA and IOTA, are reviewed monthly against target and peer comparisons are made. Qualitatively - investigations are examined every 14 days at Branch level with a quarterly review being conducted with the OCU Commander. When an investigation is 60 days old it is automatically assessed and subject to additional scrutiny thereafter. All investigations are risk assessed upon receipt, and high-risk investigations singled out for ongoing scrutiny. IPPC Supervised and Managed investigations are subject to their ongoing oversight and direction. All investigations are risk assessed upon receipt and high-risk investigations singled out for ongoing scrutiny. IPCC Supervised and Managed investigations are subject to their ongoing oversight and direction. DPS has provided training based on PCA Guidance on Investigation of Racial Incident - expended to include all diversity issues has been provided to MPS SIOs, Staff Associations, IPCC staff and the MPA.

A protocol has been developed with Operation Sapphire to ensure that appropriate expertise and skills are made available to DPS Investigating Officers when undertaking sensitive cases. MPA case management procedures have been accepted and implementation commenced.

20.c) That, except in the most serious cases (such as allegations of criminal behaviour) where doing so is clearly inappropriate, the MPS should always explore options for early informal resolution. (Para. 10.119)

Recommendation Implemented.

Commander Moir Stewart has informed the Authority that the MPS have created an innovative new Prevention Command to drive the DPS commitment to move away from a blame culture and towards a more productive de-briefing and learning culture. This will be coupled with the empowerment of local managers and supervisors for early intervention and resolution of misconduct issues.

20.d) That the Independent Police Complaints Commission should consider issuing detailed guidance as to the proper parameters for disclosure in disciplinary proceedings, including an appropriate timescale for responses to disclosure requests. (Para. 7.120)

Recommendation implemented.

IPCC have issued statutory guidelines.

Guidelines for exploring early resolution are contained in the Misconduct Investigation Guide.

20e) That, when more than one officer is involved in a case, regular and frequent assessments are made of the facts with a view to determining who, if anyone, is actually culpable and which officers are peripheral to the central facts. (Para. 7.124)

Recommendation implemented.

With the available evidence culpability is tested at various stages.

• during the initial investigation.
• when the IOs report is overseen by the head of the BSU.
• if findings are present by the Hearings Unit.

20f) That the MPS reviews the existing criteria for suspension to provide greater clarity on when suspension should be used. (Para. 7.135)

Recommendation implemented.

Commander Moir Stuart informed the Authority that a new Standard Operating Procedure SOP was published in May 2006. In addition a Suspension Support Unit has been established within HR. The MPA also maintains a regular overview of the suspensions and suspension policy.

With the introduction of the Taylor reforms, guidance can be found in the Misconduct Investigation Guide.

20.g) That the MPS takes steps to ensure that, in each case when suspension is considered, it accords with the recommendation of the Review of Operation Lancet that the use of suspension always needs to be proportionate to both the allegation and the risk. (Para. 7.136)

Recommendation implemented.

This is covered in the Misconduct Investigation Guide.

20h) That the MPS examines the adequacy of welfare support to officers under investigation. (Para. 10.85)

Recommendation Implemented.

This is covered in the Misconduct Investigation Guide.

It is a requirement of the Police (Complaints and Misconduct) Regulations 2004 Police (Conduct) Regulations 2008 that contact is maintained with officers subject to investigations. This instruction is contained within the DPS Misconduct Investigation Guide. A Record of such contact is maintained in the investigators progress log on the Tribune system. With the implementation of the new procedures from December 2008 time scales for such contact will be stipulated- (every four weeks).

1. That, when an officer is under investigation, the MPS should:
2. give the officer a copy of any media release before it is issued;
3. tell the officer when information is likely to be released to the media; and
4. provide the officer with advice for dealing with media intrusion, doorstepping, etc.

(Para. 7.153)

Recommendation implemented.

The DPA follows a clear and consistent approach to communicating information about professional standard issues. A potentially high profile internal investigation or discipline case should be brought to the attention of the DPA at the earliest opportunity.

A DPS Media Strategy, which available on the DPA website, exists for handling these cases and this was refined in light of the Morris Inquiry findings in 2005.

Following notification of a potentially high profile case the DPA will prepare a media statement in consultation with the SIO from DPS. The individual under investigation or facing discipline (and any victim) will be provided with a copy of the media statement by either the SIO handling the investigation or other appropriate officer and informed when it is likely to be released to the media.

Advice and support on how to deal with intrusive media attention as a result of publicity surrounding the case will be provided to the individual under investigation by the Human Resources press office.

Whilst we believe that it is in the public interest to release information about how we are tackling corruption and wrongdoing amongst officers and staff, the rights and needs of those under investigation or facing discipline, must always be taken into consideration.

We should not disclose any information that could prejudice the outcome of any proceedings or comment on an individual's guilt or innocence before the appropriate body has made its decision. (Para 6.4 Media Relations SOP)

The MPA note that this recommendation has been implemented and that in circumstances where the person bringing the ET publicly criticises the MPS, then the service may need to respond. In addition an internal MPS report (Dialogue to delivery March 2009) states ‘It is a requirement of the Police (Complaints and Misconduct) Regulations 2004 and Police (Conduct) Regulations 2008 that contact is maintained with officers subject to investigations. This instruction is contained within the DPS Misconduct Investigation Guide. A Record of such contact is maintained in the investigators progress log on the Tribune system. With the implementation of the new procedures from December 2008 time scales for such contact will be stipulated- (every four weeks). Officers are served with written notice both of any allegations that they are being investigated for and when those matters are submitted to misconduct proceedings (i.e. charges). In both cases the allegations are stated on the notices’.

20i) That the MPS take steps to ensure that discipline matters relating to individuals are kept confidential and not discussed with third parties in a public forum. (Para. 10.119)

Recommendation implemented.

The revised Suspensions and Restrictions policy has now been agreed by the MPA. A central HR Suspensions Support Unit has also been established to provide support to officers and staff. DPS IIC investigative processes have been encapsulated in the Manual of Investigation and the associated policies, procedures and practices are contained in the Manual of Guidance. Proportionality issues feature prominently with the requirements of IPCC implementation and the implementation of statutory guidance (yet to be published). Other activities, such as the establishment of a new Prevention and Organisational Learning Command, are also operating to support progress/developments in this outcome.

20j) That no comment is made about an officer’s guilt or innocence by the MPS until it has been established by the appropriate decision-making body, and no embargoed interviews should be given. (Para. 10.76)

Recommendation implemented.

That no comment is made about an officer’s guilt or innocence is the case as a matter of course. However after careful risk analysis there may be occasions where it is deemed appropriate not to adhere to this stance.

20k) That the MPS reviews its policy in relation to correcting errors in media reporting about its officers and staff. (Para. 10.85)

Recommendation implemented.

Addressed in section 4.10 of the Media Relations SOP’:

“It can be extremely frustrating as well as damaging to the organisation or an individual when the media publish or broadcast a story that is inaccurate, misleading or gives an unfair interpretation of the facts. In such cases a response should be considered to clarify the situation or the Met's position.

Officers or members of police staff who wish to respond to an unfair article about a particular (B)OCU or an individual should always seek advice from the DPA or their (B)OCU press officer. Where it is felt appropriate to submit a letter for publication, the relevant Head of Branch, (B)OCU Commander or line manager should correspond with the news organisation concerned. This approach ensures a coordinated corporate response.

Individual officers or police staff wishing to write their own letters for publication should seek advice from their OCU commander about whether it is appropriate for them to do so.

It is common practice now to place letters of rebuttal addressing Corporate and Metwide issues on both the Intranet and Internet sites”.

20m) That measures are put in place to ensure that officers under investigation (other than covert investigations) are kept informed of developments and that officers are told of the detail of any charges at the time they are told of a decision to discipline them. (Para. 7.161)

Recommendation implemented.

Officers are served with written notice both of any allegations that they are being investigated for and when those matters are submitted to misconduct proceedings (i.e. charges). In both cases the allegations are stated on the notices’.

20n) That officers under investigation be provided with a written record of the outcome of such an investigation and a summary of the reasons for that outcome. (Para. 10.119)

Recommendation implemented.

This us covered in the Misconduct Investigation Guide. The content of such a record is subject to consideration of potential harm/risk to witnesses, other investigations etc’. Copies of reports are made available notwithstanding the above.

20o) That the conduct of disciplinary hearings should be reviewed to make them less akin to a criminal court. (Para. 7.164)

Recommendation implemented.

The 2008 Police Conduct Regulations mean that misconduct is now addressed locally by the officers’ line managers; this is a more informal procedure than with the 2004 regulation. Qualified legal advisors (i.e. solicitors, barristers) are not permitted in these proceedings

Gross misconduct has also changed in that a member of the panel is an independent person nominated by the MPA. Also the conduct of these procedures no longer follows that of a criminal court in that the chair and other panel members have sight of relevant documents beforehand, and can now determine hearing content and demeanour. There are no longer codes of conduct to be breached rather standards of behaviour to be attained.

20p) That, in sensitive cases, or where there are vulnerable witnesses, thought should be given to the layout of the room and other practical considerations, such as allowing those involved to be accompanied by a friend or partner, so that the process is less daunting for all those involved. (Para. 7.164)

Recommendation implemented.

Special measures are in place for vulnerable witnesses and victims. DPS Misconduct Hearings Unit have used screens to safeguard vulnerable individuals and on occasion have utilised video link to victims and witnesses. The unit is also able to accommodate victims and witnesses within separate locations within the building where necessary.

21) That the issue of duty time and other resources for all representative groups, including staff support associations, is reviewed.

Recommendation implemented.

However, the arrangements are being reviewed to produce a memorandum of understanding.

21a) That the MPS reviews, with relevant stakeholders, the extent to which existing central processes inhibit devolution of real authority to managers in the Operational Command Units, with a view to streamlining the process to give local managers real responsibility for their budgets and people.

Recommendation implemented.

The THR and Finance and Resource reorganisations will continue to push decision making down the management hierarchy. Both of these reviews aim to reduce duplication and bureaucracy and provide flexibility in service provision. They will provide professional support direct to local managers empowering them to make appropriate local decisions in relation to staff management and budgeting.

The MPS is also revising its corporate decision making processes and Scheme of Delegation to ensure managers have suitable authority to undertake their role.

21b) That the MPS takes urgent steps to compile a comprehensive Scheme of Delegation setting out the levels of authority for different decisions throughout the organisation. This should be available to all officers and staff.

Recommendation implemented.

The MPS Scheme of Delegation sets out all significant functions and decisions which are delegated to police officers and police staff, which are of a statutory, financial or managerial nature, but not those of a purely operational nature. The Scheme does not define how decisions under delegated authority should be taken nor does it attempt to list all the matters which are incidental to the exercise of those responsibilities and which are part of the everyday management functions of authorised officers.

The MPS, in carrying out its functions, operates within a statutory framework. The MPS Scheme of Delegation reflects that statutory framework and provides officers with the legal power to exercise delegated functions from either the MPA or the Commissioner. The MPS scheme, therefore, operates within the framework of the MPA Standing Orders and Scheme of Delegation. The MPS Scheme of Delegation is an integral element of the MPS Corporate Governance Framework and supports the MPA’s Standing Orders which include:

• Financial Regulations;
• Contract Regulations;
• Scheme of Delegation;
• Anti Fraud and Corruption Policy.

The MPS Scheme sets out the framework for the delegation of authority within the MPS to support the general management of the MPS. It has been emphasised to all Business Groups that everyone taking decisions within the MPS must ensure they comply with the terms of the Scheme and that failure to do so will result in appropriate management action. It is therefore essential that Business Groups understand the need to ensure that officers are made aware of their responsibilities under the Scheme and the authority limits within which they must operate.

The MPS is now updating its Scheme of Delegation (expected April 2010) and will set out more specific authority levels for its corporate boards and (senior) staff.

21c) That the MPS reviews its internal communication in the light of best practice in other large public and private sector organisations.

Recommendation implemented.

Internal communication has a vital role to play in the leadership, management and development of the MPS. Good internal communication involves regular and effective two-way communication with staff at all levels. It not only leads to increased morale and engagement of staff, it also has a knock-on effect on performance and in turn the reputation of the organisation. Effective upward communication ensures that senior managers have an understanding of the issues affecting staff working at all levels of the organisation and allows staff to actively take part in the decision-making processes that will shape strategies, policies and the direction of the organisation. See appendix B.

22) That the MPS commits itself to a Code of Practice setting out the basis on which it will consult its workforce. This should be based on the following principles:

1. consulting with an open mind whilst proposals are at a formative stage;
2. giving consultees full information about proposals;
3. ensuring that consultation information reaches those who are being consulted;
4. giving consultees sufficient time to respond;
5. considering carefully the results of consultation exercises; and
6. providing consultees with full information about decisions taken at the end of the consultation period and, if relevant, the reasons for taking a different view from those who were consulted.

Recommendation implemented,

This recommendation already exists within the principles of the Partnership Framework Agreement. The agreement is the product of discussions between MPS management and the trade unions, and sets out an agreed framework within which they will work together to consult on issues that will affect the workforce. Guidelines are provided within the framework in relation to when management are required to consult, the process by which they must do so, and appropriate consultation (formal or informal), along with distinctions between when the organisation will consult, negotiate or share information and associated timescales

23) That the issue of duty time and other resources for all representative groups, including staff support associations, is reviewed.

Recommendation implemented.

Duty times and other resources for Staff Support Associations have been reviewed and the review will be ongoing. A Memorandum of Understanding, which sets out the basis for how Staff Support Associations operate (and are funded), has been agreed following consultation.

24) That, in addition to consulting through representative bodies, the MPS takes steps to involve its workforce in decisions on issues that concern them.

Recommendation implemented.

The MPS recognise that these bodies have an important role to play in the development of equality within the Service particularly toward effecting cultural change. The MPS has 17 groups collectively known as the Staff Associations Meeting Up Regularly and Interacting (SAMURAI). Executive members of each group meet with the MPS Director of HR and he takes questions from the floor and invites subject matter experts from HR Directorate to also attend, responding directly to any issues of either concern or interest.

The HR Director also regularly hosts a ‘live-time’ HR forum on the MPS internal intranet where any MPS staff member can ask him a direct question relating to HR policy. The HR Director holds regular one-to-one informal chats with many members and the Commissioner frequently holds ‘get-togethers’ with large numbers of staff where together with management board he takes direct questions from the audience.

The MPS recognises the value of all associations and supports their involvement in activities that add value to policing, i.e. involvement in recruitment campaigns targeted at under represented groups, to represent minority interests & to act as a sounding board for new policies or ideas.

As part of a wider strategy the Home Office intend to conduct a review of the national groups in order to establish what arrangements should be put in place to support them and what benefits this will bring to their members, the police service and partners. This review is intended to include consideration of the funding arrangements of staff associations and staff support associations.

25) That the MPS considers the views expressed in our survey and how the issues revealed can be addressed. We would recommend a follow-up survey in one to two years’ time.

Recommendation implemented.

‘Your Views Count’ - the MPS’ staff survey, provides the opportunity for all officers and staff within the organisation to share their views in relation to their experiences of working for the MPS. The whole organisation has the opportunity to share their views twice a year, during April - September and October - March. Results from the survey, are presented to senior management to help build a picture of what the organisation is doing well and where improvements are needed, with action plans developed to improve in those areas where required. Seven of the 23 closed questions within ‘Your Views Count’ can be compared to those within the Morris Inquiry staff survey (2004). Recent data shows that current responses are above those provided in 2004 on all seven items.

26) That the MPS takes active steps to remain vigilant and to monitor the culture at Hendon, and to ensure that all staff and recruits are aware of what constitutes inappropriate behaviour (such as that which is bullying and / or discriminatory) and that any incidents which do occur are treated with the seriousness they deserve.

Recommendation implemented.

Issues of integrity and corruption are addressed in a highly interactive and informative session at Hendon for new recruits by a senior police officer from DPS. This session weaves in key themes such as equality, diversity and its content has recently been further strengthened by contributions made by the Diversity Officer, DPS, officers from the MPA’s Professional Standards and Race & Diversity Units and representatives from MPS Staff Associations. The Code of Expectations is now included in the Student Officer handbook issued to all successful candidates prior to joining the MPS. The Code has been suitably amended to cater for members of the extended police family’.

27) That the MPS ensures that there are effective, formal support mechanisms in place for all recruits. These should cover the period after acceptance and before they arrive at Hendon, as well as their time spent there.

Recommendation implemented.

The Skills to Achieve Results Team (START) assist students with the police recruit foundation course. They cover study and revision skills and exam technique. START looks at how people learn and how to help them. Some recruits have come directly from university or college, some haven't studied for some time whilst others have never studied. All age groups are included with the youngest being just 19 years, to some at the other end of the scale in there 50s.

Visual, kinaesthetic, audio and digital learners are identified through a quick questionnaire. Whilst homing in on their primary learning style they encourage multi-sensory learning to enhance retention.

In the recent past further issues such as English as a second language (EASL) and dyslexia have become issues for START to deal with. In relation to EASL a course in English language is available to students which runs alongside the main course. For students with dyslexia, members of the START team have been trained by Independent Dyslexia Consultants to carry out dyslexia assessments.

The Students Options and Solutions Team (SOST), based at Hendon, was launched as the Morris Inquiry sat. The First Contact Scheme has been launched and all available support is being extended to include all satellite sites, IPLDP sites, and training delivered within the Extended Police Family. SOST allow students to discuss any issues which are troubling them, whether work related nor not. The idea is to help students identify options they may wish to take. The final decision rests with the student. The SOST can only support and assist with that process, not make the decision for them. The team work 7am – 5pm Monday to Friday. Appointments are not necessary.

In addition:

• Exit interviews for those resigning are done by two independent senior managers
• Staff Support Associations have full time rep at Hendon, and attend events called ‘Pathway’ at Hendon
• Details of associations are publicised at Hendon, and recruits are given time to meet the association representatives during work hours
• Recruits have a full time Police Federation representative at Hendon

There is a list of people you can approach within the MPS who you can talk to on a one-to-one basis if staff have a problem with a manager or other members of staff. The SOST team carry out exit interviews for anyone resigning.

29) That the MPS evolves effective induction processes to cover entry into the organisation, and all changes of role within it, and that the Human Resources directorate institutes formal mechanisms for monitoring compliance.

Recommendation implemented.

The MPA notes that induction is a critical process that ensures all new staff are integrated into the workplace and feel valued. Induction enables the new appointee to hit the ground running and to bed into the organisation more quickly. At a local level it is primarily the line manager’s responsibility to include as a comprehensive induction checklist and attendance at a corporate induction day within three months. This will allow enable an individual to obtain and better understand the objectives and key functions of the organisation in a timely fashion and should also help the individual to more easily settle into your new role / environment etc.

An internal MPS report (Dialogue to delivery March 2009) states ‘Induction is carried out at a number of levels. For police officers it is carried out at the training centres. For police staff there are corporate induction days that staff normally attend within their first three months. These include presentations from a wide range of speakers and numerous “stands” with, e.g. trade unions, staff associations, specialist units etc. There is also an online Multi Media Induction programme to complete. In addition, each Borough and business group is also expected to run its own induction programme, with specific information relating to the area/business group’.

In order hand to develop corporate induction process for senior officers and staff joining/ to ensure compliance, every HR unit in the MPS is evaluated on an annual basis with respect to its performance in a number of key HR activity areas, including the quality, standard and comprehensive implementation of the induction process.

Corporate induction is in 4 stages: A corporate induction day, an induction pack, and intranet site and checklist for the use of local HR managers. Research and planning is now in transferring into the MPS.

30) That the Human Resources directorate takes steps to ensure that the Performance Development Review process is fully implemented across the MPS as a meaningful management tool. This should be centrally monitored and the Human Resources directorate should carry out periodic reviews across the organisation to monitor quality and consistency.

Recommendation implemented.

It is a corporate requirement for all staff to have a Performance Development Review completed every year in order to assess performance against key competencies and objectives and set work related and developmental objectives for the following year. Compliance is measured monthly through a Key Performance Indicator (KPI) within the HR scorecard, and monitored by HR Performance Board. Localised compliance and quality is evaluated annually by the HR Evaluation Unit through B/OCU visits, which include a review of all PDRs to ensure they have been completed to a required standard. The findings of the evaluation process are discussed with each B/OCU Commander during a performance meeting chaired by the Director of HR.

To ensure consistency corporate training is provided to MPS staff in relation to PDRs. The following training modules were developed by the Career Management Unit:

• During 2008 People Management Workshops delivered to all 1st and 2nd line managers, which included a module on PDRs
• The Leadership Academy training for new line managers also includes a module on PDRs

30a) That the Human Resources Directorate should keep data on the training undertaken by officers and staff both in terms of the time spent on training and the training undertaken.

Recommendation implemented.

As part of the THR programme, there is also an expectation that line managers will be able to update training records of their staff and individual members of staff will be able to check their own training records.

30b) That Operational Command Unit commanders and departmental managers should use this data to ensure that the officers and staff for whom they are responsible receive the training they need to do their jobs and that there is fair and equal access to appropriate training opportunities. A pre-requisite of this is full devolution of training budgets.

Recommendation implemented.

At a local level B/OCU Commanders have devolved responsibility for training budgets, with the support of senior training managers. Line managers through self service have direct access to the training records of staff they manage, and can identify training requirements at an early stage. Non-mandatory additional development is available to staff, and there is a requirement to complete a training request form, which must be approved by the line manager before development/training is provided. Requests for training are monitored in relation to disproportionality for age, ethnicity and gender, and reported annually in the Duty in Employment report. Data for sexual orientation and religion, faith or belief were not previously collected; however the training request form has now been updated to reflect all diversity strands. Future reports will include this data.

Some training remains a corporate responsibility. The primary purpose of learning and development is to maintain and improve the performance of the MPS. To achieve this, training is delivered both through corporate programmes and on the basis of local needs. Major training units include the Directorate of Training and Development’s training schools, the Crime Academy, Leadership Academy, Firearms and Public Order training at Gravesend and the IT training establishment. However, the eighty-two training units across the MPS deliver both corporately agreed programmes and training to meet local needs.

Although classroom based training continues to be the most frequent method of delivery, the MPS has a long tradition of delivering practical training through role–play, simulation and work based experiential learning. It has also pioneered immersive learning through its Hydra training facilities. An underlying principle is that training will be designed and delivered in such a way as to minimise abstractions from the workplace. Wherever practicable, training is conducted at or near the workplace, using, if available, corporately produced training and learning materials.

The MPS continues to develop its use and application of e-learning and to exploit the benefits this mode of training delivery offers. Every permanent member of the MPS now has a learning account on the National Centre for Applied Learning Technologies (NCALT), Managed Learning Environment (MLE) which enables access to national and MPS specific e-learning modules. An interface between the MLE and the MetHR system now exists whereby individual learning records and new accounts are semi-automatically updated and created.

This means that all permanent staff have the opportunity to undertake corporate training at the workplace, or even away from the workplace, which has allowed the MPS to reach an audience that were often unable to attend training. These groups include part time workers, those with mobility concerns or issues, those on secondment, those on maternity or paternity leave, those with caring responsibilities and those on a career break. In addition, the design standards for e-learning make specific provision for disability. E-learning provides greater flexibility for learners to progress at their own speed, thus enabling learning for those with different levels of ability.

However the MPA Race and Faith Inquiry have indicated that there is a lack of confidence in the process. The inquiry recommendations will identify any training issues.

30c) That the MPS implements a more effective management development programme.

Recommendation implemented.

Police officers of any rank may undertake relevant studies designed to encourage registration with a university in order to conduct research into current police problems. The research must lead to a higher degree awarded by a university. For substantive officers up to the rank of Chief Inspector, the MPS can help fund all or some of the costs of relevant studies outside of the MPS. The programme is open initially to black, Asian and minority ethnic police officers at constable, sergeant, inspector and chief inspector rank who aspire to join the HPDS or the MPS talent pool. As part of their talent management scrutiny the MPA made a number of recommendations. See Appendix D for the details.

30d) That the MPS introduces development programmes which will increase the opportunities available for cross-fertilisation with those managing other public and private sector organisations.

Recommendation implemented.

The MPA talent management scrutiny recommended that the MPS should encourage all ACPO and Superintending ranks to provide internal coaching and mentoring or work shadowing opportunities as part of the talent management and succession planning strategy. This should be in addition to the external coaching and mentoring opportunities for senior police officers and senior police staff with London First. In the absence of personal coaching, mentoring or work shadowing opportunities, coaching and mentoring opportunities should be provided with or by external organisations.

The MPS stated that work is already in progress to encourage ACPO and superintending ranks to provide coaching, mentoring and career development support as part of a Talent Cascade. This Talent Cascade uses the skills and experiences of more senior staff and officers, who show a clear focus on their own development, to coach more junior staff and officers. It creates a talent network and provides further opportunities for staff to coach and mentor and evidence how they are maximising potential in others.

In addition, the partnership with London First continues with the Leadership Exchange programme having been re-launched to increase the number of partnerships across Superintending ranks. For members of the talent programmes, access to external mentoring and/or coaching is facilitated based on identified development needs within personal development plans.

The MPA talent management scrutiny recommended the opportunity to expand existing senior secondment initiatives with organisations such as London First should be explored, together with secondment opportunities to and from other parts of government, local government and the criminal justice sector for lower and middle ranking officers.

The MPS stated that an evaluation of existing arrangements with London First is currently taking place, with a view to expanding the business partnerships currently available and offering secondments. These secondments would be sourced for individuals within the talent groups and would be based on identified development needs

The MPA talent management scrutiny recommended that the opportunity to incorporate existing police development programmes into the talent management and succession planning strategy should be explored as part of a “development centre” programme, e.g. using programmes run by the NPIA. The MPS stated this is the approach taken within the talent management framework, which builds on existing national programmes, such as the HPDS and NSCAS.

Looking internally within the MPS, the Senior Careers Advisor is developing an integrated approach to development activity across leadership, talent management and diversity areas in collaboration with the Director of the Leadership Academy, the Deputy Director of Human Resources and the DAC for Diversity and Citizen Focus.

30f) That the MPS’ management development programme should be available to police staff as well as police officers.

Recommendation implemented.

See previous answers, as much relates to both officers and staff.

30g) That the MPS ensures that it has systems in place to develop all its officers and staff.

Recommendation implemented.

Please see Recommendation 30 in relation to PDRs and also Recommendation 30b.

It should be noted that the MPA Race and Faith Inquiry has indicated that many MPS officers have little faith in the performance development process. The Inquiry recommendations will highlight these issues.

31) That the MPS develops procedures for promotion and appointments to specialist posts which are fair and transparent and that the Human Resources directorate monitors their application.

There are no specialist police officer promotion processes other than for specific ACPO posts. There are promotion opportunities for police staff and these are competency based. The MPA talent management scrutiny made a number of recommendations around specialist officers. See Appendix C.

In addition:

• The MPS Police Promotion Exercises are all now subject to equalities impact assessment, and trailed to ensure they are not discriminatory
• The Police Federation and the Superintendent's Association are fully engaged to ensure they can challenge any perceptions of unfairness for all their members
• There are now a number of chances to appeal to independent oversight if a candidate feels they have been unfairly treated
• There have been recent attempts to improve the cultural-mix of MPS assessors.
• All Assessors in MPS promotion processes are soon to attend bespoke cultural awareness training
• A new SOP has been introduced to ensure that decisions in relation to Temporary Promotion are fair
• The MPS has recently introduced a new Independent Advisory Group of external HR specialists to scrutinise the fairness of MPS promotion processes
• The number and frequency of employment tribunals lodged against the MPS in relation to promotion matters has significantly reduced since these measures have been introduced

32) That the MPS takes steps to ensure that its policy on flexible working is fully understood and implemented, and that the Human Resources directorate rigorously monitors that implementation.

Recommendation implemented.

Please see below.

32a) That the MPS establishes a central resource to provide guidance to managers on managing flexible working and to match requests for flexible working with job opportunities.

32b) That consideration is given to a childcare co-coordinator post based on the Greater Manchester Police model

Recommendations implemented.

The MPS’ approach to flexible working has received several plaudits and awards including Employer of the year by Family Friendly Employers in 2007.

The MPS appointed a Work/Life Balance Advisor and Childcare Co-ordinator to cover a range of associated issues including Flexible Working and Child/Elder Care. The revised Flexible Working Standard Operating Procedure promotes an accommodating, creative approach to flexible working and encourages managers and staff to consider all reasonable possibilities based on the preferences expressed by the post holder or applicant and on the business needs of the role and department. Comprehensive guidance has been issued to all staff and illustrates the benefits of a variety of flexible working options. The MPS now has a very comprehensive and robust Work/Life Balance Policy and associated Standard Operating Procedures (SOPs). The policy and SOPs are available on the People Pages website on the intranet and these are supplemented by the Think Flexibly booklet which is available on the intranet.

33) That the MPS sets up a central resource to match officers and staff with disabilities to suitable vacancies and to ensure that any necessary adjustments are made speedily.

Recommedation implemented.

The Workforce Planning Unit have a process in place to match staff with disabilities to suitable postings. The MPS now also has a Disability Advisor in post to provide advice and guidance to line managers on staff disability matters. Further support can also be provided by Occupational Health, if necessary.

34) That there should be a full case review of Operation Helios which is independent of the MPS. The review should include examining the issue of race discrimination. (Para. 10.74)

Recommendation implemented.

On 5 June 2007 the former MPA Chair Len Duvall responded to the announcement that mutually acceptable terms had been agreed, resolving all disputes arising out of Operation Helios, Len Duvall said:

"The MPA welcomes the constructive resolution agreed by the National Black Police Association and the Met Black Police Association with the Metropolitan Police Service in relation to Operation Helios. We are very grateful for the hard work and commitment of all the parties involved."

He continued:

"It is part of the MPA's duty to promote equality and diversity within the MPS. The Authority hopes that everyone can now move on and that all those involved in Operation Helios and subsequent events can learn from the experience.

“Our responsibility is to hold the MPS rigorously to account and oversee continuous improvement. In 2004 the Authority set up the independent Morris Inquiry to examine professional standards and employment matters in the service and make recommendations for change

"We are committed to working with all our partners to ensure fairness of treatment for our own staff, and to working with the MPS to achieve cultural change throughout the service to maintain confidence in policing."

35) That the MPS avoids entering into agreements in relation to professional standards and conduct matters that are ultra vires. (Para. 10.76)

Recommendation Implemented.

There is a structured payment process that once reaching a threshold of £60K goes through MPA. Any ex-gratia payments are through the MPA. In any such circumstances advice would be sought from DLS.

37) That the MPS provides Chief Inspector Pendry with written responses to the questions she has posed in her submission to the Inquiry. (Para. 10.119)

Recommendation implemented.

Not achieved

The following recommendations have not been achieved.

6) That the Department of Trade and Industry gives consideration to a specific provision extending the protection afforded to discussions involving ACAS to discussions that take place between the parties at a mediation so that the discussions become privileged. (Para. 4.108)

Recommendation has not been implemented.

There is no specific provision in force, and the MPA is unaware of any future legal changes. However, in April 2008 the European Parliament and Council adopted a Directive on mediation and Article 7 of the Directive enables member states to enact measures to protect the confidentiality of mediation. UK law and procedures must be compliant by May 2011. It may be that any such general measures will assist in this context but that remains to be seen.

21) That the MPS and the Metropolitan Police Authority create a police staff post, which would undertake the functions of a Chief Operating Officer, to bring all the support services in the MPS (Finance, Human Resources, Communications, Legal Services, Property, Information Systems and Technology, Procurement, Logistical Services, etc.) together under one individual who would be equal in status to the Deputy Commissioner with a remit which spans the whole of the organisation.

Recommendation previously considered and rejected.

21.e) That the MPS takes immediate action to implement the HMIC recommendation on a High Potential Development Scheme for police staff.

Recommendation has not been implemented.

This scheme has still not been launched by NPIA.

Unachievable

The following recommendations are unachievable.

2g) That attestation is delayed until the officer has satisfactorily completed his or her initial training.

Recommendation is unachievable at this time.

The Inquiry felt delaying attestation would avoid the ‘taint’ of probationers filmed in “The Secret Policeman” as they would be employees not police officers. Home Office, HMIC and APA have all expressed support for the principle of delaying attestation from Day 1 to a point further into police training where they are likely to be better able to and capable of execising the responsibilities and powers of constable. This requires primary legislation.

It is important to note that the training programme has changed for probationers since the Morris Inquiry. Instead of 18 weeks at Hendon there is now 5-6 weeks at Hendon followed by 12 weeks training on Borough. The principle of IPLDP training which localises training would be seriously impaired if attestation did not occur at the commencement of training.

20q) That the MPS strengthens its guidance on Assistant Commissioner Reviews by including provisions:

1. making it clear that the reviewing officer should have access to all available documentation as of right; and
2. for the reviewing officer to be satisfied that he or she has all the necessary information required to make a proper decision. (Para. 7.170)

Recommendation no longer relevant.

On December 1st 2008 the new Police (Conduct) Regulations came into force. Assistant Commissioners reviews have now ceased under the new regulations, and 20q) no longer relevant.

20r) That the relevant Committee of the Association of Chief Police Officers should consider issuing guidance on Chief Constable (Assistant Commissioner) Reviews. (Para. 7.170)

This recommendation no longer needs to be addressed.

On December 1st 2008 the new Police (Conduct) Regulations came into force. Assistant Commissioners reviews have now ceased under the new regulations, and 20r) is no longer relevant.

28)That the MPS gives consideration to early implementation of any proposed scheme of multi-point entry for officers.

Recommendation is unachievable at this time.

The ‘multi-point entry’ scheme for police officers was initially discussed at a national level as part of the workforce modernisation programme. The MPS could not implement this without a change to legislation. However, the scheme has recently been progressed in several other ways.

Firstly, the High Potential Development Scheme and Intensive Development Programme have resulted in a number of police officers and police staff gaining a wide range of skills through lateral development, resulting in speedier progression. Secondly, use of the language operational requirement has resulted in police recruits, with a range of languages and community knowledge that directly support service delivery (e.g. through CCRU), recently joined the MPS. Thirdly, the workforce modernisation programme has now started a project within SO15 to evaluate the national modernisation model. Finally, the PCSO role provides an opportunity to gain an insight into the MPS and is increasingly becoming a career pathway route to the police officer role, particularly for under-represented groups.

Multi-point entry for officers is also being considered as part of the MetForward programme. The MPA Race and Faith Inquiry is also considering this.

Ongoing

The following recommendations are ongoing.

7.a) That the MPS takes immediate action to engage black, minority ethnic and white officers and staff at all levels in the important practical steps required to ensure that black and minority ethnic officers and staff are not discriminated against on grounds of race.

Recommendation is ongoing.

A wide range of consultation mechanisms exist with representative groups. Closer links have been established between HR and Diversity & Citizen Focus Directorate (DCFD). The implementation of the Police Race and Diversity Learning Programme (including the race and diversity national learning requirement) will also address this matter. The MPS also maintains good working relationships with all the staff support associations both through individual meetings with these associations and through regular consultation on a wide range of policies, activities and initiatives. The Diversity Board and DCFD work closely with the staff support associations to set the policy and procedures in respect of equalities and diversity and for leading, monitoring and driving diversity through the MPS.

It is felt that this recommendation will be signed off as complete once e-learning is completed (end of March 2010), and in the case of NOS AA1 in the PDR, when the organisation will be in a position to see how well this has been completed by reporting officers for reporting period 2009-10.

8) That the MPS gives adequate priority to all aspects of diversity, particularly in light of the Framework Equal Treatment Directive 2000.

Recommendation ongoing.

The Deputy Commissioner is the chair of Diversity Board.

The MPS Equalities Scheme with its common and disability specific sections was published on 4 December 2006. In compliance with the Equality Act 2006, the Gender specific section was published on 30 April 2007. Therefore there is now a proportional focus on six equality strands. The MPS are also in the process of piloting a National Policing standard. The MPA are concerned that the implementation of this new standard by the MPS is overly bureaucratic and that it may not be achievable because of the size of the MPS.

In terms of the Leadership Academy, this has developed significantly since 2006. The Leadership Academy designs, develops and delivers high-quality values based open leadership programmes and bespoke products and services to meet the needs of policing locally, nationally and internationally. They aim to help improve operational performance and service delivery through effective leadership capability in all ranks and grades.

In addition, Leadership Academy local aims include:

• To provide MPS officers and staff in leadership roles with the skills and tools of effective leadership
• To engage officers and staff at the local level in helping make the MPS a more Values consistent workplace
• To ensure that the connection between operational activity and the Values is clear to all staff.

8b) That consideration is given to extending the Diversity Excellence Model to other Operational Command Units and directorates. However, we would recommend that its implementation be kept under review to guard against it becoming another ‘tick box’ exercise.

Recommendation is ongoing

The MPS has developed a new Diversity and Equality Strategy for 2009 - 2013, which sets out what the organisation aims to achieve in diversity and equality over the coming three years in both service delivery and employment practices. It recognises the progress that the MPS has made over recent years but identifies those areas where more work still needs to be done. The strategy has been designed to provide a simple framework for managing diversity and equality in the MPS, enforcing a more consistent approach to managing these issues across the organisation. The strategy has been developed around four main themes of:

• Delivering efficient and effective policing services that are fair and responsive to the diverse needs of the people we serve
• Enhancing engagement with all communities
• Building and developing a talented workforce and working culture that promotes mutual respect, teamwork, productivity and pride in the MPS
• Good governance and performance management

In addition, the Equality Standard is essential in helping us measure whether we are fulfilling our primary Pledge commitment of treating people fairly, with dignity and respect, making sure everyone, regardless of their background, has access to our services which are delivered to a high standard, leading to improved confidence in all communities. It sets out a structure for recording good work and makes it easier to share best practice, also enabling gaps in service delivery to be identified and remedied at an early stage. This will be a requirement for all MPS B/OCUs, therefore further embedding consideration of all diversity strands into working practices.

A three month field testing trial of the standard was launched by the National Police Improvement Agency (NPIA) in April 2009 and involved 11 forces including the MPS. The MPS Diversity & Citizen Focus Directorate (DCFD) identified five trial sites: Enfield, Richmond, CO19 Firearms Branch, Human Resources and DCFD. DCFD provided the trial sites with guidance notes to clearly explain the range and type of evidence sought. In addition to the guidance documents, each site was introduced to the ESPS through a facilitated seminar, where Single Points of Contact from each of the trial sites were guided through the criteria. They were also introduced to additional tools for the trial, such as risk and learning logs. The aims of these tools were to assist the MPS team in passing on effective feedback to the NPIA project team as well as determining how DCFD could best implement the ESPS to a wider MPS audience. In reviewing the trial sites experience, DCFD was able to measure the time and resources committed to implementation of the evidence gathering process. Now this data has been collected, the Directorate will be better placed to quantify the potential cost in time.

9) That the Metropolitan Police Authority enters into greater dialogue with other police authorities to establish best practice in discharging the oversight role. (Para. 6.40)

Recommendation is ongoing.

The MPA is actively involved with the ‘People’ and ‘Diversity’ networks within the Association of Police Authorities (APA) at both officer and Member level . In this way the Authority has ensured that equality and diversity is a cross cutting theme in all areas of police authority activity (including oversight) and the development of the national Equality, Diversity and Human Rights Strategy for the Police Service and the revision of the APA’s “People Matters” guidance on police authority oversight of human resources and professional standards activities

10) That the Metropolitan Police Authority keeps under review the protocol with the MPS on the provision of information to the Authority on complaints and conduct cases, in order to ensure that it meets its responsibility for scrutiny. (Para. 6.43)

Recommendation is ongoing.

The MPA regularly monitors complaints, police misconduct, employment tribunals and fairness at work through six monthly reports to the MPA’s Strategic Operational Policing Committee and Communities Equalities and People committee. As a result of these reports the approach to these activities, both within the MPS and the MPA, has been refined and continues to be refined through experience. This is to ensure that where trends and issues are identified, they enable the MPS to take remedial action.

11) That the Metropolitan Police Authority reviews the resources it is able to devote to supporting its role in overseeing complaints and conduct cases,with a view to increasing activity further, particularly in relation to dip-sampling of files. (Para. 6.43)

Recommendation is ongoing.

The MPA has reinvigorated its oversight of MPS complaints and is currently reviewing existing procedures and protocols for dip sampling of files to strengthen those procedures and ensure adequate resources are available. This review will be considered alongside the MPA’s proposals for restructuring in order to ensure that the MPA utilises its expertise and resources beyond the Professional Standards Unit

14) That the ‘Nolan Principles’ for public appointments should apply to the appointment of members of the Independent Advisory Group and that:

Recommendation is ongoing.

Awaiting ratification and sign off of the MPS, post IAG Review (2006-09), draft Standard Operating Procedures.

The Nolan Principles have now been superseded by “The Office of the Commissioner for Public Appointments (OCPA), Code of Practice for Ministerial Appointments to Public Bodies”. The draft MPS Standard Operating Procedures (SOP), reflect how these should be applied to the appointment of Independent Advisors across the MPS.

14a) their appointment should be by the Metropolitan Police Authority;

With the agreement of the Police Authority, recommendation 26 of the review determined that the Director of the Diversity and Citizen Focus Directorate would be responsible for the appointment of corporate independent advisors; that the respective senior police lead to a Specialist Advisory Group (SAG) will accept the appointment of an advisor to a SAG and that a Borough Commander will accept the appointment of an advisor to a Community Advisory Group (CAG).

14b) they should be appointed in a transparent way following open competition by public advertisement;

The process to recruit new independent advisors is coordinated by the MPS in the strict spirit of OCPA. This is enshrined within the draft MPS SOP. Senior police leads are aware of this requirement.

14c) the terms of their appointment, including tenure of office and any remuneration, should be made public; and

Terms of appointment, including tenure of office were formulated as part of the MPS review of Independent advisors and are detailed in the draft MPS SOP.

14d) candidates should be assessed for their suitability against a formal specification which should also be made public by the Metropolitan Police Authority.

Recommendation is ongoing.

The required candidate abilities are set out in the draft MPS SOP.

A review of the Independent Advisory Groups has now been completed. The review recommendations are now being implemented. The MPA through the Communities, Equalities and People committee are monitoring this process and a paper has been requested for the meeting of 10 September 2009.

16) That the Independent Advisory Group and the MPS agree a protocol in relation to disclosure of documentation and the rationale for decisions to Independent Advisory Group members. This must be based on the presumption that Independent Advisory Group members see everything that is available to the investigating officers. Where possible, this should be before decisions are taken.

Recommendation is ongoing.

The disclosure of information is detailed in the draft MPS SOP.

17d) That the MPS puts in place processes to ensure that those recruited receive the appropriate training to undertake the roles to which they are assigned. (Para. 7.56)

Recommendation is ongoing.

An internal MPS report (Dialogue to delivery March 2009) states ‘A performance needs analysis of all staff requirements will be conducted as part of the implementation of New Way Model. The MPA requested that the HR Training Standards Unit evaluate the training being delivered by DPS to its staff. This is not yet completed’

20) That the MPS works with appropriate stakeholders to implement the recommendations in the Review of Operation Lancet. (Para. 7.60)

1. That investigations by the Directorate of Professional Standards should be run along the lines of the normal investigative process for criminal cases and arrangements should be made to put the necessary systems in place as a matter of urgency. (Para. 7.115)
2. That the MPS gives clear guidance to Directorate of Professional Standards’ officers on the use of powers of arrest where the real objective is to search the premises of an officer under investigation. (Para. 10.133)

Recommendation is ongoing.

36) That where Gold Groups are established in relation to disciplinary matters:

1. their purpose and powers are set out in writing so that all involved are clear about their role and lines of accountability; (Para. 10.76) and
2. clear guidelines are established about the make-up of a Gold Group as, for example, it is not appropriate for representatives of complainants or other parties involved to be members of such a Gold Group or to be present at any meetings. (Para. 10.119)

Recommendation ongoing

The MPS is currently carrying out a review of gold groups by specifically examining oversight mechanisms. One strand of this work is organisational learning and gold groups. Recommendation 36 will be picked up during the course of these reviews and as part of the organisational learning strand.

C. Race and equality impact

The terms of reference of the Morris Inquiry and the associated notes set out by the MPA, requested the inquiry panel:

“To inquire into the conduct by the MPS of the following matters in relation to police officers and police staff – policies, procedures and practices for and resolution of Employment Tribunal claims, in particular those claims involving allegations of race or other discrimination against the MPS.”

To establish whether the policies, practices, procedures and structures of the MPS in relation to those matters represent good effective practice in line with key strategies and the statutory obligations of the MPA and MPS under the Race Relations (Amendment) Act 2000 and other relevant legislation.

To identify lessons to be learnt from the outcome of recent high profile cases (including recommendations made by the Gurpal Virdi Inquiry, and the outcome of the case involving Supt. Dizaei).

To consider whether there are disparities in the treatment of black and other minority police officers in relation to grievance, complaint and disciplinary proceedings and hearings.”

It is crucial that the MPS and the MPA continue to build on the learning from the areas of improvement highlighted by the Morris Inquiry, and successfully implement the remaining recommendations of the Morris Inquiry and those of the Race and Faith Inquiry.

Race and equality issues are fundamental to the Morris Report. They must, therefore, also be integral to the way that the MPA and the MPS address the remaining recommendations.

D. Financial implications

There are no financial implications specifically resulting from this report.

There are continuing costs in the MPA budget for Professional Standards work within the MPA, in order to implement recommendations of the Inquiry relating to the MPA’s functions for the complaints and discipline process. The MPA is currently funding a temporary resource to aid with this work. Other costs are subsumed into the function the MPS and MPA day to day work.

E. Legal implications

The legal implications are dealt with within the body of the report.

F. Background papers

• A Case for Change – Morris Inquiry, 2004
• MPS Dialogue to Delivery -Internal Diversity Review, March 2009
• MPS Internal DPS progress report – April 2007

G. Contact details

Report author(s):

• Julliett Fearon-Knott (MPA)
• Alan Johnson (MPA)
• Glen Allison (MPS)
• Clive Chalk (MPS)
• Terah Enoch (MPS)

For information contact:

MPA general: 020 7202 0202
Media enquiries: 020 7202 0217/18

Appendix A – New MPS Standards of Professional Behaviour

• Honesty and Integrity
  Police officers are honest, act with integrity and do not compromise or abuse their position.
• Authority, Respect and Courtesy
  Police officers act with self-control and tolerance, treating members of the public and colleagues with respect and courtesy. Police officers do not abuse their powers or authority and respect the rights of all individuals.
• Equality and Diversity
  Police officers act with fairness and impartiality. They do not discriminate unlawfully or unfairly.
• Use of Force
  Police officers only use force to the extent that it is necessary, proportionate and reasonable in all the circumstances.
• Orders and Instructions
  Police officers only give and carry out lawful orders and instructions. Police officers abide by police regulations, force policies and lawful orders.
• Duties and Responsibilities
  Police officers are diligent in the exercise of their duties and responsibilities.
• Confidentiality
  Police officers treat information with respect and access or disclose it only in the proper course of police duties.
• Fitness for Duty
  Police officers when on duty or presenting themselves for duty are fit to carry out their responsibilities.
• Discreditable Conduct
  Police officers behave in a manner which does not discredit the police service or undermine public confidence in it, whether on or off duty. Police officers report any action taken against them for a criminal offence, any conditions imposed on them by a court or the receipt of any penalty notice.
• Challenging and Reporting Improper Conduct
  Police officers report, challenge or take action against the conduct of colleagues which has fallen below the Standards of Professional Behaviour.

Appendix B - MPS Corporate internal communication objectives

Corporate internal communication objectives

The overall strategy will deliver the following internal communication objectives:

• Create greater focus, clarity, and shared understanding about the MPS' overall mission, values, priorities and objectives and how people can contribute to achieving them.
• Support leaders in their communication role to ensure staff are aware of key decisions and policies, the reasons behind them, and how they affect individuals and their work.
• Encourage two-way communication in the organisation to ensure that MPS senior managers have an understanding of the issues affecting staff working at all levels so that these are taken into account during the development of strategies and policies, as appropriate.
• Make better use of technology to target information and reduce information overload.
• Increase knowledge of the changing external world, its impact on the MPS and, where appropriate, the need for change.

Roles and responsibilities

The revised strategy has implications for all parts of the MPS, starting with Management Board

Management Board

• Provide context and clarity about strategic and organisational priorities
• Provide communication leadership, be visible – walk the talk
• Regularly brief team members face to face
• Consider the communication implications of decisions
• Make sure that the central / corporate parts of the Met are communicating
• Support the DPA in its internal communication work
• Hold other leaders in the organisation accountable for their communication responsibilities
• Seek feedback and dialogue with staff from across the organisation
• Build trust by listening and responding

Leaders – BOCU /OCU Commanders and departmental heads

• Take corporate information and create borough / unit / departmental and operational relevance and local priorities
• Ensure communication standards are maintained and hold people accountable for their responsibilities in this area
• Seek and ensure feedback and communicate this back up
• Appoint communication liaison officers to build the professional communication infrastructure in the Met
• Communicate directly with these people, brief them effectively, and provide them with the information they need to talk to others
• Foster a climate where regular face-to-face team briefings are the norm

Directorate of Public Affairs and Internal Communication

• Guardian of the strategy and the principles on behalf of the organisation
• Run key activities and communication channels e.g. intranet homepage, The Job and Met-Get-Togethers
• Support and work with the organisation on issues as internal advisers
• Help to create better streamlining and co-ordination of communication from the ‘centre’ of the Met
• Be well-informed and keep in touch with what is happening
• Ensure that there is a productive communication infrastructure across the organisation and facilitate the flow of communication in all directions
• Advise Management Board on internal communication issues
• Measure and evaluate communication effectiveness
• Ensure messages are available for everybody – easy to find and easy to understand
• Work to improve understanding of messages across the Met

BOCU / OCU / communication champions

• Support and advise leaders in their internal communication role
• Provide a key two-way link with the DPA
• Help with the implementation of Met-wide communication campaigns, working with the ‘centre’

Staff

• Take responsibility for being well-informed – keep up to date with important information and act upon it
• Provide productive feedback

The benefits of improved internal communication

Through a process of improved internal communication, the MPS will benefit by:

• promoting ownership/understanding of key policies and messages by all individuals
• improving morale
• improving motivation and engagement
• engendering pride
• creating 55k potential ambassadors for the MPS who will help promote accurate information to Londoners in an informed and positive way
• improving an individual's feeling of value to the organisation
• capturing contributions from right across the organisation, so that individuals feel listened to
• Improved performance

Primary channels – face-to-face

• Meetings and briefings with staff
• Focus groups
• Consultation
• Management visibility
• Met-Get-Togethers

Support channels

• Intranet
• Online forums
• Video messaging
• Notices
• Publications and documents
• The Job
• email

Background

• Posters
• Videos / DVDs / CDs
• Noticeboards

Evaluation

Delivering a message is relatively straightforward, but how effective has your communication been? There are three broad approaches to the measurement of communication:

• Measuring output: DPA will monitor and record what information has been disseminated, the methods used and whether people received it.
• Measuring impact: DPA will check to see if people understand the messages.
• Measuring outcome: DPA will monitor the number of people engaging in the consultation processes and assess the impact on motivation and performance.

DPA will measure and evaluate through feedback, focus groups, dip sampling, informal contacts, formal and informal surveys, the consultation processes, and monitoring communication.

Appendix C - Recommendations around specialist officers taken from the MPA talent management scrutiny.

15.): That as part of the approach to a revised HPDS, the MPS supports the MPS proposals around:

• graduate recruitment linked to a work based assessment promotion route to Superintending rank; and
• for existing police officers a work based assessment route to Superintending rank, linked to NSCAS.

16.) In the absence of NPIA support for the proposals at Recommendation 15, the MPS develops its own programmes along similar lines.

The MPS welcomed the MPA support for these proposals. The newly revised police HPDS will be open to constables and sergeants who are not members of the current scheme. It is aimed at a smaller number of officers who have the potential to progress to ACPO level, whereas the former scheme selected officers evidencing the potential, desire and commitment to reach Superintendent. Accordingly, the places available each year will be very limited. The NPIA anticipate that Forces will implement their own internal talent programmes to supplement the national HPDS.

As part of the talent framework, the MPS are trialling work-based assessment for HPDS Inspectors to Chief Inspectors, with a full review planned for Summer 2008. The trial of work-based assessment for HPDS Chief Inspectors to Superintendents has begun. Detailed guidance is currently being drawn up to ensure rigour when assessing HPDS Chief Inspectors’ suitability to commence work-based assessment and their performance during the 6-month assessment period.

Under the (IPLDP), student officers will do their initial training on or near the BOCU that they are posted to as opposed to undertaking the 18-week Initial Training Foundation course at Hendon.

For chief officers, and those with the potential to become chief officers, is a major plank in the national strategy to develop leadership ability.

There are two NVQs available for police officers: there are a variety of programmes:

• Positive Action Leadership Programme
• Promoting Difference Mentoring Scheme
• Barriers to Career Development - a workshop for Deaf & Disabled people
• Springboard Programme
• Leadership Development for Senior Women

The (PDR) is a key tool to identify areas of development and performance in order to be ready for your next role.

For police staff of any band wishing to undertake relevant studies, the Bramshill Fellowship scheme is designed to encourage registration with a university in order to conduct research into current police problems. The research must lead to a higher degree awarded by a university. For substantive members of police staff up to the Band C, the MPS can help fund all or some of the costs of relevant studies outside of the MPS.

The (IDP) is designed to identify and develop those members of police staff who have what it takes to succeed in leadership roles

For senior staff, and those with the potential to become senior staff, the is a major plank in the national strategy to develop leadership ability. Also for senior staff (Bands A and B) is which enables them to access and apply existing knowledge to encourage a sustainable change throughout the organisation.

The following vocational qualifications are available for police staff: NVQ in management, there are a variety of programmes:

• Positive Action Leadership Programme
• Promoting Difference Mentoring Scheme
• Barriers to Career Development - a workshop for Deaf & Disabled people
• Springboard Programme
• Leadership Development for Senior Women

The (PDR) is a key tool to identify areas of development and performance in order to be ready for your next role.

Appendix D – MPA talent management scrutiny recommendations

18.) That the MPS, in consultation with HMIC and the appropriate ACPO leads, produces tailored positive action programmes for ‘pulling through‘ under-represented groups into specialist roles, particularly more senior roles, as part of a development programme.

Once the Promoting Difference Programme has been embedded and evaluated, its value and impact to the Service generally will be assessed, with a view to tailoring and expanding aspects as required.

19.) That the MPS, in consultation with HMIC and the ACPO lead on Workforce Modernisation, carries out further work on making specialist roles and specialist career pathways more attractive to those seeking development and / or promotion opportunities.

This is agreed and will be taken forward by the Deputy Director of Human Resources through the appropriate Workforce Modernisation mechanisms.

20.) For specialist officers seeking promotion or lateral development, consideration should be given to providing advice and support for programmes run by business schools or the Leadership Academy in order to broaden their awareness and enhance their promotability / suitability.

Current Leadership Academy courses are designed to equip officers and staff from across the organisation with generic leadership and management development training, irrespective of their particular area of work. Officers transferring from a specialism or seeking promotion should, therefore, have no requirement for further training over and above that offered by the Leadership Academy.

21.) For specialist officers who notify their intention to seek lateral development, consideration should be given to internal coaching and mentoring or work shadowing opportunities in the period leading up to their transfer to another area of work.

Under THR, identifying development needs and finding appropriate mechanisms to meet them will be a line management responsibility. The Expert Centre will be able to provide appropriate advice and support to line managers, as required.

22.) That the national Workforce Modernisation programme be asked to look at practical and innovative ways of encouraging officers to seek lateral development opportunities to broaden their careers, i.e. into and out of specialist or non-specialist roles.

The views of the MPA and MPS have been passed onto the Workforce Modernisation Programme for review.

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