Baroness Casey's review into the culture of the Metropolitan Police provides a timely reminder to organisations, both in the public and private sectors, about the significance of internal and external culture investigations.  We explore why looking at an organisation's culture is important, as well as how to approach an internal investigation and deal with the outcomes below.

Background

Much attention has been drawn to the findings of Baroness Casey's review, which considered the culture and standards of behaviour at the Metropolitan Police Service (the Met). The review looked across all levels of the institution, including recruitment, vetting, training, culture and communications, to consider whether standards relating to safety, diversity and inclusion, and public trust were being met. This is not the first review of its kind, with various other public sector organisations recently looking internally to consider whether a culture shift is needed. Notable examples include the Independent Culture Review of London Fire Brigade and NHS Highland's standards investigation. 

While these investigations are often associated with public sector organisations, which naturally are placed under a higher level of scrutiny due to the public interest, it is becoming increasingly common for employers in the private sector to undertake culture reviews. A notable Scottish brewery recently received commendations for its Independent Culture Review, which followed criticisms of its working practices and culture. The review considered how to ensure employees are treated fairly and respectfully, and the mental health support that could be provided by the employer. This is a good example of how lessons can be learned from external culture reviews, such as that undertaken into the Met, and put into practice by private employers. 

Why is looking at an organisation's culture important?

Cultural reviews such as those mentioned can be helpful tools in establishing areas for employers to improve. They can provide an opportunity to offer employees a safe environment to feedback on a diverse range of factors, such as working practices, inclusion and discrimination, salary and overall job satisfaction. This allows employers to get to the heart of issues facing their employees and understand what can be done to tackle these issues at an organisational level. 

Whilst external investigations and reviews are often triggered by an event acting as a "wake-up call" to potential malpractice, there is no need to await such an event. Indeed, it represents good practice for employers to be proactive in their approach to addressing culture changes through conducting their own internal process. This can demonstrate a willingness to hold themselves accountable to the standards they set as an organisation – that they walk the walk, as well as talk the talk.

Employers have a legal duty, including under the Equality Act 2010, to protect employees and prevent harassment or discrimination. An investigation into the organisation's culture can flag any issues and help employers to understand what action can be taken to safeguard employees and so reduce the risk of legal claims. In Baroness Casey's report, data on the Employment Tribunal claims raised against the Met between 2017 and 2022 was collected in order to identify patterns or themes emerging. By collecting and analysing this type of data, employers will be better placed to identify problems and take remedial action to prevent further litigation. 

Aside from the legal obligations, internal reviews and investigations help employers to better understand the areas in which employees are dissatisfied and make improvements.  That in turn can assist with attracting and retaining the best talent in a competitive recruitment market where an increased focus is placed on employers' ESG credentials. 

Approaching an internal review or investigation

Why? The key element of any internal review or investigation is establishing the areas of focus. If the review is prompted by a particular event, this is likely to determine its remit. A crucial first step, therefore, is understanding what you as the employer want to find out. This could be anything from overall employee satisfaction to the experiences of ethnic minorities. Drawing up a list of areas of focus is usually an important initial step. 

Who? Consideration should be given to who should conduct the review or investigation. Usually this will mean identifying the correct person or group of people that are sufficiently senior, have experience, or are trained in conducting investigations and will be perceived as unbiased. If an issue is particularly serious or complex, an employer might enlist the services of a specialist external investigator. 

How? The next step to consider is how you will ascertain the information. In some cases, analysing existing workforce data will be the natural first step. Employee surveys can be used to obtain a wide scope of feedback and, if anonymised, will often result in more honest opinions being provided.

Once high-level feedback is received, focused interviews on either a one-to-one or small group basis with employees can provide a more detailed insight into the company's culture and allow for wider discussion. These should be focused but allow for genuine feedback to be provided, and employees should be free to express views without fear of repercussions. 

Dealing with the outcomes

It is crucial to have a plan in place for how feedback obtained during the review will be put into action. It is therefore useful to have a dedicated team tasked with considering next steps. The outcomes should be tailored to the evidence gathered as part of the investigation. 

Examples of what those outcomes might be include:

• improving or implementing new policies or training;
• initiatives for employee mental health support, such as access to counselling;
• appointing diversity and inclusion leads;
• launching an independently managed ethics hotline for employees to address complaints;
• investment into social mobility, learning and development, or diversity and inclusion programmes;
• salary review and pay rises; and
• periodic reviews into the organisation's culture to address any future concerns.

It is vital that the information obtained in any review is put to use in the form of actions that will assist with culture change. 

How we can help 

Our experienced PRM team is well placed to advise on conducting an internal review or provide third party support. 

If you would like any further information on internal investigations, or assistance with carrying out a review in your own organisation, please reach out to a member of the team.