MPS reporting wrongdoing policy

Report: 7
Date: 16 June 2003
By: Commissioner

Summary

This report outlines the MPS reporting wrongdoing policy and describes the improvements made to the policy and operating procedures following the recent policy review. The policy was introduced to the MPS in June 2000 and has been reviewed as part of the recently launched MPS Professional Standards Strategy.

The policy describes the obligations of MPS staff to report wrongdoing by their colleagues. It sets out a number of ways to do this and explains how staff who report wrongdoing, must be supported and protected. The policy provides guidance on how each report will be investigated, by whom and sets out formal administration and monitoring procedures.

Reporting wrongdoing is a key policy to raise the professional standards of MPS staff and root out corruption and other unethical behaviour. Whilst it is a wholly internal policy there is likely to be impact on the public by raising their confidence in the MPS and it will influence recruiting and retention.

A copy of the policy is circulated with this agenda as a separate document for members. Additional copies are available on request.

The MPA Website version of the 'Reporting wrongdoing policy' has had the exempt information on Standard Operating Procedures (part 10) removed.

A. Recommendation

That the report and policy be noted.

B. Supporting information

Policy review - introduction

1. The MPS reporting wrongdoing policy was published in June 2000 as part of the MPS Corruption and Dishonesty Prevention Strategy. In July 2002 the MPS published the new and revised MPS Professional Standards Strategy. The strategy directs five ‘Strands’ of activity. Strand 1 focuses on ‘Leadership, Supervision and Standards Adherence’ and is led by Commander Bob Broadhurst of Territorial Policing. The review of this policy is an agreed element of Strand 1 and is part of a comprehensive review of all professional standards policies under the Race Relations (Amendment) Act, 2000. (RRAA)

Methodology

2. Commander Broadhurst tasked Chief Superintendent Archie Torrance, (Lewisham Borough Commander) with leading the review of the policy. Ch Supt Torrance formed a working group of experienced and interested parties to review and revise the policy including:

• Policy developer from the Directorate of Professional Standards (DPS);
• Operational officers;
• Personnel Manager;
• Federation representative, and
• Officers who had previously reported wrongdoing.

The working group brought their own views and experience to the review and carried out a scoping, or fact finding, exercise.

Scoping and consultation

3. The working group asked colleagues in the MPS what they thought of the existing policy and how it could be improved. This was done in three ways:

• All staff associations and trade unions were approached in writing;
• All DPS staff were consulted;
• MPS staff were contacted via a message on the Intranet home page.

4. A large amount of information and constructive criticism was received as a result of this exercise and has informed and influenced the review. The MPA Professional Standards and Complaints Committee received a presentation on the work of Strand 1, including the review of this policy on 28 April 2003.

5. As a result of this scoping exercise, a new and revised draft policy was written and agreed with the working group. This draft was sent out for consultation to:

• All staff associations and trade unions;
• The DPS Command Team;
• All other stakeholders named in the policy; and
• MPS policy clearing house.

6. All further views and comments received following the consultation were considered in drawing up the final policy.

MPS Policy statement

7. The Metropolitan Police Service has developed and operates a reporting wrongdoing policy to assist in rooting out corruption or wrongdoing of any kind within the organisation. It assists the creation of an environment where wrongdoing is prevented and discouraged. However, where wrongdoing does exist there is a real prospect of detection by colleagues. The operation of such a policy will continue to promote a culture of ‘doing the right thing’ where staff are prepared to report wrongdoing with confidence that any such report will be dealt with correctly. In doing so they will be appropriately supported and protected.

Key aspects of the policy

Methods of reporting wrongdoing

8. There are nine different methods and avenues for staff to initiate a report of wrongdoing both internally and externally. This provides choice for the person in how they wish to report the wrongdoing.

Reception of reports

9. All reports of wrongdoing will be centrally collated and monitored by DPS who will ensure that they are investigated by the most appropriate department or member of staff according to the policy.

Culture

10. The policy reinforces the need to continue the change in culture to encourage reporting and to support and protect those members of staff who ‘do the right thing’ and report wrongdoing. The policy demands that staff in leadership and supervision roles receive reports willingly and take immediate and appropriate action.

Support

11. The policy demands and ensures appropriate support and protection for staff who report wrongdoing, including statutory protection under the Public Interest Disclosure Act, 1998. (Soon to be amended by the Police Reform Act to include police officers).

Improvements made to policy

12. The review of the policy found that there was general acceptance that this was a sound policy but that there were some problems with the implementation and operation of it on occasion. This was thought to be due, in the main, to the absence of formal operating procedures and processes to support the policy. Improvements to the policy centred on the formation and development of Standard Operating Procedures (SOPs) to ensure that the policy was clearly drawn up, consistently applied and effectively monitored.

13. Other improvements included:

• New central collation and monitoring point;
• Guidance on most appropriate investigation authority;
• New administration procedures to ensure monitoring;
• New investigation strategy in all cases;
• Requirement to consult staff reporting before setting strategy;
• Addition of Police Complaints Authority (PCA) and Criminal Cases Review Commission (CCRC) as external agencies to report to;
• Emphasis on investigations being fully inclusive so that staff who report wrongdoing have a real influence over the investigation;
• Regular and documented case reviews;
• Clearer guidance on resulting and completing cases;
• 24 hours given to staff to reflect and gain further advice before giving informed consent to agreed course of action.

Implementation and communication

Policy approval

14. The policy was approved by the MPS Professional Standards Committee (PSSC) on 1 May 2003.

Implementation

15. DPS Policy Unit are responsible for implementation of the revised policy and have devised the following implementation and communication plan:

• Presentation to DPS Internal Investigations Command (DPS IIC) senior staff on 4 June 2003 and delivery of a communication package.
• Presentation of this report to MPA PSCC on 16 June 2003
• DPS IIC senior staff to cascade communication package to their Borough Liaison Investigation Officers (IOs) from 17 June 2003
• IOs to deliver communication pack and present new policy to BOCU and OCU commanders from 17 June to end of July.
• All DPS staff to be trained on new policy throughout June and July
• New Police Notice to be published
• Further internal communication by ‘Job’ newspaper article, Intranet site publicity, letter and information packs to all BOCU and OCU commanders from Commander Broadhurst.

Monitoring and review

16. All reports of wrongdoing will be sent to a central collation and monitoring point at DPS. Each report will be allocated a unique reference number and allocated for investigation.

17. At the conclusion of each investigation the report will be concluded by the central collation point.

18. Each report will be monitored by allegation, outcome, as well as gender and ethnicity where this is known or revealed.

19. Annual statistics will be available.

C. Equality and diversity implications

1. This policy has been reviewed using the corporate policy review booklet and model. This ensures that the policy is ‘fit for purpose’. This includes ensuring that it complies with all legislation but with particular reference to the Human Rights Act, Race Relations (Amendment) Act, Disability Discrimination Act and the MPS Diversity Strategy. The policy complies with all legislation and MPS strategies.

2. As an internal policy there are no implications for the general public in its application, however the reputation of the service and the way in which staff are treated are clearly factors that influence recruiting and retention.

3. Whilst the policy does not target any section of MPS staff, the protection measures to be put in place for any person who reports wrongdoing will assist those who may be vulnerable. The policy has been used to protect and support gay officers and officers from ethnic minority communities with great success in the past.

4. Whilst it would not be appropriate to give specific examples of the use of the policy to protect the identity of the staff reporting and the member of staff accused, there are a number of examples of successful use of the policy over the previous two years.

5. Development of the policy has involved wide consultation including all staff associations and trade unions.

D. Financial implications

The financial implications for this policy are restricted to the opportunity costs to investigate and administer the reports of wrongdoing and the communication and implementation of the new policy.

E. Background papers

• MPS Reporting Wrongdoing policy

F. Contact details

Report author: Stuart Palmer, Chief Inspector, Directorate of Professional Standards, MPS.

For more information contact:

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

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