HR policy amendment – independent audit

KPMG has concluded an independent audit into the publication of an update to Imperial’s bullying and harassment policy without due process.

The audit confirms that the President, Provost, CFO, Chair of Council and their offices did not request or approve changes to the Harassment, Bullying and Victimisation Policy on gross misconduct that were published on 1 December 2020.

The President, Provost, CFO, Chair of Council and their offices had no involvement in amendments to the policy on gross misconduct John Cullen Chair, Audit and Risk Committee, Council

The agreed version of the bullying and harassment policy was applied in the independent investigation into the conduct of the President and CFO, and this policy remains in place, as the KPMG audit confirms.

The audit was conducted by KPMG and reported to John Cullen, chair of the Audit and Risk committee of Imperial’s Council.

The audit shows that different HR policies have been undergoing development for the past year, with changes on different aspects overseen by different sponsors. This includes the HR team starting work on implementing the recommendation from the independent investigation that the policy should be reviewed.

The audit confirms that these changes to the HR policy on bullying, harassment and victimisation were made and published without the necessary approvals.

The process for approving changes was not clearly defined within HR practices at the time. The Director of HR has now put in place improved processes for approval before policies are published to prevent such a clerical error occurring again.

Clearer procedure

John Cullen said: “The KPMG investigation into the changes made to the Harassment, Bullying and Victimisation Policy in December 2020 has concluded.

“The report I have received and the Audit and Risk Committee has accepted from KPMG indicates that the President, Provost, CFO, Chair of Council and their offices had no involvement in amendments to the policy on gross misconduct posted on 1 December 2020.

“The report suggested that a clearer procedure for final approval of HR policies was needed, and this has now been put into place.”

Although Imperial’s audit contract with KPMG means all investigations are subject to strict confidentiality, the College requested an exemption and KPMG allowed an executive summary to be published.

Imperial has published the independent audit’s executive summary.

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