Feel safe in speaking up
We want everyone who works at L&G to feel safe in speaking up about things they have noticed.
In the first instance, we encourage our colleagues to speak with a line manager, or another trusted leader. They can also report concerns through Human Resources (HR).
Our colleagues can also raise their concern via our speak up channels. This can be via an online referral form, email to speakup@landg.com or using a freephone 0800 number. External stakeholders, for example, suppliers, customers or other third parties, can also use the email address to report a concern. All concerns can be anonymous and are treated confidentially.
Colleagues may also confide in their Unite, the union, representative or managers’ forum representative (UK only), and we encourage them to speak to Protect, the whistleblowing charity, for free and independent legal advice where necessary.
We do not tolerate retaliation against those who speak up and any reports of this would be thoroughly investigated, and appropriate disciplinary action taken for colleagues breaching our speak up standards.
Training and awareness
Our Speak Up Policy is proactively communicated to colleagues, supported by compulsory training programmes and regular communications from senior leaders, including the Group Management Committee and our Speak Up Champion. We test awareness and confidence through our annual colleague survey and engagement with our colleague communities and business areas.
What to look for
Potential wrongdoing in a financial services organisation could take several different forms, such as processes or policy not being adhered to, or if wrongdoing is taking place. We may also take action where our colleagues have behaved inappropriately outside of work in line with the FCA’s latest guidance on non-financial misconduct. This does not include private civil matters.
We each have a responsibility to raise any queries or concerns we may have at work and encourage our colleagues to report the following concerns:
- Non financial misconduct – this includes bullying, all forms of harassment and violence in the workplace, as well as breaches of the FCA’s conduct rules around acting with integrity
- Company polices or procedures are intentionally or deliberately not being followed
- The company is breaking the law
- A criminal offence has been, is being or is likely to be committed by an individual or the company
- Health and safety danger that has not been addressed
- Risk or actual damage to the environment
- Something else which could cause harm to the company
- Retaliation or victimisation for having spoken up
- Covering up or deliberately concealing wrongdoing
Assessment process
All referrals are assessed within five days of receipt. We determine what action needs to be taken and will inform individuals of the steps we plan to take.
Investigations are conducted fairly and impartially and are led by experienced investigators. We will assess the potential for detriment and take appropriate steps where necessary to mitigate the risk. We will provide regular updates to referrers throughout the process and afterwards we will follow up with them to ensure they have been treated fairly
HR consultants are on hand to support anyone involved in one of our speak up matters with welfare concerns.
Governance
The Speak Up Committee, which meets quarterly, is the designated sub-committee of the General Management Committee that oversees the effectiveness of the function and the fair treatment of our referrers. They assess performance using a range of key performance indicators in line with industry peers and track the timely completion of investigations against a 60 working-day service level agreement.
The Speak Up Committee members receive information on all cases which detail the findings and any recommendations. Reports are presented to the Group Board and other boards on an annual basis. In line with regulatory requirements, Clare Bousfield, one of our Independent Non-exec Directors, is our Speak Up Champion. She meets regularly with the Speak Up team.