Investigation Policy - June 2026
In this section
- 1. Introduction
- 2. Scope
- 3. Procedure
- 4. Appointing an Investigating Officer
- 5. People Services - HR Business Partner (HRBP)
- 6. Employee Responsibilities
- 7. Sickness Absence During an Investigation
- 8. Notification of an Investigation
- 9. Representation
- 10. Recording an Investigation Meeting
- 11. Timescale
- 12. Support for Employees
- 13. Confidentiality
- 14. Ensuring Equality of Treatment
- Appendix 1 - Guidelines for Investigating Officers
- Appendix 2 - Template Terms of Reference for Investigation
- Appendix 3 - Investigation Planning Template
- Appendix 4 - Template Investigation Meeting Record
- Appendix 5 - Investigation Officer’s Report Template
- Appendix 6 - Protocol for Disciplinary Hearing
- Appendix 7 - Questioning Approaches to Use
4. Appointing an Investigating Officer
An investigation officer will normally be appointed by the Director or nominated Head of Service in accordance with the relevant policy* (see below). Who should be the investigator will often depend on the seriousness and/or complexity of the matter.
In most cases, where the matter to be investigated appears to be clear and the facts are not in dispute, the role of the investigator may be carried out by an appropriate line manager.
If the evidence to be investigated is more serious or complex (such as potential gross misconduct, discrimination or bullying) then the person appointed should be someone more senior or experienced where possible.
In exceptional circumstances, it may be appropriate to appoint someone who is detached from the matter. This could be a manager from another department or an external investigator. However, this needs to be carefully considered, and any decision should balance the needs for fairness against a cost effective and efficient investigation.
Questions to consider when choosing an investigator:
Are they personally involved in the matter being investigated?
Would the appointment raise any conflict-of-interest concerns?
Are they likely to be influenced by people involved in the matter?
Might they be involved in any subsequent decision making on the matter?
What is their availability during the investigation’s provisional timeframe?
Are they trained and/or experienced in how to conduct investigations?
How confident are they at communicating in writing and/or orally?
What training or support may they require?
What is most important is that whoever is chosen to be the investigator acts fairly and objectively.
* Any case of suspected fraud or corruption by any officer or member of the Council must be reported immediately to the Head of Revenues and Financial Compliance. Where cases are logged on the Whistleblowing Database, the Monitoring Officer will be responsible for formally referring the case to the Head of Revenues and Financial Compliance. No internal investigation should be attempted by any Department. The Head of Revenues and Financial Compliance will arrange for the necessary investigation to be carried out. Where, as a consequence of the investigation, there appears to be reasonable grounds to indicate that an officer has been guilty of fraud or corruption, the Head of Revenues and Financial Compliance will discuss the matter with the Director of Corporate Services who will be responsible for deciding whether the matter should be formally referred to the Police.
Where cash or items are stolen, all such incidents, regardless of value, should be referred to Internal Audit prior to reporting to the Police. If it is suspected that a member of staff may have been involved in the theft advice must also be sought from an HR Advisor.