Operation Hotton recommendations - Metropolitan Police Service, September 2021

The IOPC recommends that the MPS should take appropriate steps to assure itself that the bullying and harassment identified through Operation Hotton is not more widely prevalent across the MPS.

This follows an investigation into allegations of bullying and harassment amongst a team of officers working at Charing Cross Police Station. This found pervasive evidence of such behaviours, including demeaning and intimidating actions towards police officers on probation; officers being shouted at by supervisors; and women being treated as a “weary female” when speaking out about the behaviours of male colleagues. The culture of bullying appears to have been accepted and not challenged.

A review conducted by the Independent Police Commission, an independent inquiry focusing on the future of policing in England and Wales, found a positive correlation between reported bullying and the number of complaints received about police officers’ conduct. This is supported by the Operation Hotton investigations as multiple conduct issues were identified and bullying was present. Bullying and harassment at work is unacceptable and it is recognised that this is even more serious given the difficult job that officers have to undertake and the likely abuse they may experience from the public when carrying out their frontline duties. 
 

Do you accept the recommendation?

Yes

Accepted action:

The Metropolitan Police Service (“MPS”) has reviewed and accepts this recommendation by the IOPC.

Since 2018, the MPS has made significant changes which includes investment in inclusive leadership campaigns, management training, our grievance and mediation framework and upskilling of leaders. We will review current channels and processes to identify whether these need refreshing or re-communicating in order to address bullying and aggressive behaviour.

This is included in the Commissioner’s ‘Rebuilding Trust’ plan under ‘Improving our Culture’. Actions include, upskilling 10,000 leaders across the MPS on ‘Inclusive Leadership’ and the ‘Operation Signa’ programme (a programme to tackle sexual harassment and misogyny in the MPS) which will work to ensure our people actively intervene and challenge inappropriate behaviour. This is built on the feedback from women in the MPS, to increase confidence in reporting sexual harassment and unacceptable conduct.

The MPS has comprehensive systems and processes in place for reporting wider bullying and aggressive behaviours. These are clearly signposted on our Human Resource’s advice pages on our internal website and include; the ‘Right Line’, a facility for officers and staff to anonymously report wrongdoing or crime to the Directorate of Professional Standards (DPS); Crime Stoppers and direct to the IOPC. These have recently been strengthened under the MPS ‘Raising Concerns’ Policy.

‘Knowing the Line’ is an initiative that deals specifically with sexual harassment, supporting the NPCC campaign ‘Know the Line’. This makes clear that sexual harassment is ‘completely unacceptable and will not be tolerated at any level.’ There are also regular Bullying and harassment at work is unacceptable and it is recognised that this is even more serious given the difficult job that officers have to undertake and the likely abuse they may experience from the public when carrying out their frontline duties. communications, such as blogs that highlight specific relevant topics and issues, for example, the grievance process and informal resolution champions.

The introduction of the PEQF (Policing Education Qualifications Framework) recruit training model has created a new landscape to manage in respect of recruit professional standards. We now run four different recruit training programmes delivered at six different geographical sites, four of which are outside the MPS estate. Most officers now complete their initial training out of uniform (the warrant card is issued in week 11). In support of robust independent accreditation, there is an integrated training delivery team comprising colleagues from the MPS, Babcock and the four Higher Education Institutions (HEIs). At any one time, we have approximately 1,200 in their initial foundation training.

A range of interventions are in place focused on professional standards:

• The introduction of a new three day recruit induction / engagement event with a strengthened focus on professional standards (including a presentation from the Deputy Commissioner). ‘Not In My Met’ content is now also covered.
• The DPS Prevention and Learning Team present to all recruits. Messages are reinforced by a Learning and Development Superintendent when recruits commence their HEI based training. This emphasises our personal responsibility to step forward and challenge wrong doing. If it feels wrong then you must say something. Recruits are made aware of all the mechanisms in place to report wrong doing. 
• Further specific inputs are provided at week 7, week 12 (BCU Familiarisation Week) and week 17 (immediately prior to Street Duties). These inputs are delivered as part of the curriculum by officers from Learning and Development. 
• A specific induction programme has been created for Tutor Constables and Tutor Sergeants to ensure the transition from central training to BCU retains the appropriate focus on recruit professional standards. Under Year 2 growth, 24 additional police sergeant posts have been built into Front Line Policing for recruit line management.
• Recruit line managers (sergeants) are based permanently at all HEI sites to focus on recruit professional standards, performance and welfare. The recruit training Target Operating Model approved by MPS Management Board under the PEQF Full Business Case, affords a 1:90 sergeant to recruit ratio for the first 20 weeks. Additional sergeants are being mobilised (pressure posts) to ensure we hold this ratio under Year 3 of uplift.
• A monthly Performance and Assessment Board ensures central oversight of recruit performance throughout their probation period under all training pathways. This includes central oversight of professional standards issues / themes, resignations as well as the use of Regulation 13 of the Police Regulations 2003 in support of consistency and proportionality. This feeds into a monthly joint agency Service Review Board chaired by the Director, Learning.

The MPS systems for recording cases of grievance, misconduct and employment tribunals enable us to identify and monitor trends and to share this information at both local and Chief Officer Group levels and to intervene where there are issues of concern. A risk management approach is used to triage grievances to further identify patterns and provide support to management teams, upskilling them to deal with behavioural issues.

A recent improvement has been the implementation of a new Standard Operating Procedure (SOP) issued by our Grievance Management Team (GMT). This provides clarification on channels for officers and staff to raise concerns and guidance as to whether grievance is appropriate, or whether an alternative process should be used. Grievance (and deputy) Single Points of Contact (SPOC) have been appointed to each business area and are available to provide advice and support. They receive annual training and are building this capability, networking and sharing of learning through a Microsoft Teams channel and training is being extended to line managers. A data ‘dashboard’ is circulated monthly to these SPOC’s who sit on local Senior Leadership Team meetings and use this data to highlight themes and trends so that appropriate action can be taken. The GMT meets quarterly with HR Business Partners to highlight risks and trends to be discussed within Chief Officer Groups.

This recommendation aligns with planned continuous improvement activities with the Grievance framework. Our recently launched new SOP clearly defines roles and responsibilities and has seen us increase the volume of independent assessors. We will ensure we continue to communicate and assure complainants regarding the independence of the process. We acknowledge the feedback in regard to training. Whilst input regarding intolerance and discrimination has been covered within previous training packages, we will work with providers to ensure this is fit for purpose and increase the level of input if required.

We will undertake this work as part of the roll out of our training programme (from April 2022). We agree that building transparency and confidence in the grievance process is a high priority for us. We can see the value in better reporting outcomes and will incorporate this within our action plan for 2022/2023 and are relaunching a satisfaction survey to inform this work. Lastly, we note the comments regarding reviewing cases with senior leaders and staff associations. Such a forum already exists and we will review the terms of reference and frequency to ensure this remains fit for purpose. We are keen to share learning across the MPS and continue to explore ways to enhance this approach. Sharing learning from grievances and employment tribunals will be incorporated within the new organisational learning app being developed.

In addition, and in support of the Grievance Management Team, the MPS remain the only police service in the country who has a dedicated Discrimination Investigation Unit (DIU) within the Directorate of Professional Standards. Their work encompasses all allegations of bullying and harassment in the workplace when at a level of gross misconduct or linked to a grievance or employment tribunal. Considerable steps have been taken to improve the communication and the working relationship between the HR led Grievance Management Team and the Employment Tribunal Team. This includes bi-monthly meetings to discuss cases, revised tri-unit working instructions and process maps to ensure every element of the concern is addressed by the most appropriate unit.

The IOPC recommends that the MPS ensures those investigating allegations of bullying and harassment are adequately detached and independent to avoid potential conflicts of interest and to build confidence.

This follows an investigation into allegations of bullying and harassment amongst a team of officers working at Charing Cross Police Station. This found pervasive evidence of such behaviours, including demeaning and intimidating actions towards police officers on probation; officers being shouted at by supervisors; and women being treated as a “weary female” when speaking out about the behaviours of male colleagues. The culture of bullying appears to have been accepted and not challenged. A reason for not reporting such behaviour was a lack of confidence that it would be dealt with effectively. In one case, allegations of bullying were not dealt with effectively or promptly by the supervisor who was in a relationship with the person making the allegations.

Ensuring those investigating allegations of bullying and harassment are independent of the matter will provide more assurance to those making the reports that it will be dealt with appropriately and, may build confidence in the system and encourage reporting. Ultimately, this may reduce instances of such behaviour.
 

Do you accept the recommendation?

Yes

Accepted action:

The Metropolitan Police Service (“MPS”) has reviewed and accepts this recommendation by the IOPC.

Not all bullying and harassment misconduct investigations are dealt with by the DPS, some are passed to the local Professional Standards Unit (PSUs) to investigate. Since 2016, those that are assessed as gross misconduct and investigated by the DPS will be dealt with by the Discrimination Investigation Unit (DPS DIU).

The DIU currently quality assure the outcome reports for all other additional discrimination investigations dealt with by local PSUs prior to submission to the appropriate authority, to ensure that IOPC guidance is followed.

The DIU also investigate all allegations of discrimination, victimisation, bullying and harassment linked to a grievance case or Employment Tribunal (ET).

The DIU has developed their own ‘Discrimination Investigation Toolkit’ to support local PSU investigators and currently deliver training on tackling discrimination to police officers on the sergeant to inspector promotion course.

The allocation process within the DPS investigation teams means that all investigations are allocated to an investigating officer who is independent and will have no conflict of interest. Upon initial allocation from an Appropriate Authority (AA) the investigating officer will be asked to raise any conflict of interest.

On the investigating officer’s initial severity assessment of the investigation, they will confirm they are independent and have no conflict of interest. Any further severity assessments will again require the investigating officer to confirm this. Matters that are passed to the PSUs are reminded to consider any conflict of more assurance to those making the reports that it will be dealt with appropriately and, may build confidence in the system and encourage reporting. Ultimately, this may reduce instances of such behaviour. interest by the DPS Complaints Resolution Unit. By April 2022, communications will be sent to all PSUs to remind them of their duty to disclose any conflict of interest and record whether there are any conflicts or not when allocated.

All local PSUs within the MPS have “buddy” units. In relation to the investigation of any officer or police staff member on the Basic Command Unit or Operational Command Unit (BCU/OCU) where there could be an apparent or perceived conflict of interest, then an investigator and AA (decision maker) from an alternative PSU can be appointed to maintain transparency and impartiality at all times throughout the conduct investigation process.

In addition to the above, HR’s recently launched new Standard Operating Procedure clearly defines roles and responsibilities and has seen an increase in the volume of independent assessors. We will ensure we continue to communicate and assure complainants regarding the independence of the process. Whilst input regarding intolerance and discrimination has been covered within previous training packages, we will work with providers to ensure this is fit for purpose and increase the level of input, if required. We will undertake this work as part of/prior to the next roll out of our training programme (from April 2022).

The IOPC recommends that the MPS ensures there are metrics in place to measure and demonstrate, in a transparent way, improvements made in tackling bullying and harassment and confidence in the MPS approach to this. This could include reporting on the outcomes of allegations by protected characteristics. Consideration could also be given to the involvement of staff associations in reviewing grievances at a strategic level.

This follows an investigation into allegations of bullying and harassment amongst a team of officers working at Charing Cross Police Station. This found pervasive evidence of such behaviours, including demeaning and intimidating actions towards police officers on probation; officers being shouted at by supervisors; and women being treated as a “weary female” when speaking out about the behaviours of male colleagues, as well as bullying based on protected characteristics. The culture of bullying appears to have been accepted and not challenged.

Measurement and reporting relating to bullying and harassment and the confidence in the MPS approach will enable insight into where improvements are being made and where there is still work to be done; providing transparency and enabling accountability. Reporting on outcomes by protected characteristics can help identify any trends regarding disproportionality and there may also be opportunities to work more closely with staff associations to identify areas for improvement and embed changes. This recommendation has been informed by feedback received from the Chair of the National Black Police Association. 
 

Do you accept the recommendation?

Yes

Accepted action:

The Metropolitan Police Service (“MPS”) has reviewed and accepts this recommendation by the IOPC.

The MPS approach to making improvements goes beyond just the scope/remit of the Grievance Team and we will ensure this recommendation is jointly owned and managed across the DPS and HR. The DPS scope will focus on reinforcing standards, educating leaders in partnership with HR and ensuring metrics and outcomes are in place for matters relating to misconduct.

In terms of the grievance element; the recommendation aligns with planned continuous improvement activities with the Grievance framework. Our recently launched new Standard Operating Procedure clearly defines roles and responsibilities and has seen us increase the volume of independent assessors. We will ensure we continue to communicate and assure complainants regarding the independence of the process. We agree that building transparency and confidence in the grievance process is a high priority for us.

We can see the value in better reporting outcomes and metrics and will incorporate this within our action plan for 2022/2023. In relation to reviewing cases with senior leaders and staff associations, such a forum already exists and MPS HR will review the terms of reference and frequency in partnership with DPS to ensure this remains fit for purpose. This work will ensure we are reporting on and learning on thematic areas in a way that we really drive change and confidence, particularly in our Staff Associations. There is current work to enhance automatic population of ‘Centurion’ (the DPS Complaints and Conduct recording database) with PSOP (“PSOP” and “MyHR” are the MPS integrated systems for HR and Training along with other operational functions) on protected characteristics to ensure accurate and complete recording.

This will further improve the existing dashboards, enabling both local leadership teams and the central GMT and DPS teams to implement learning and build leadership capability. And as mentioned in response to Recommendation 1, we are bolstering our capacity to share learning through the organisational learning app.

We are committed to sharing data and insight with our staff support associations and will continue to do so with the enhanced reporting once in place. We will work with staff associations regarding the outcomes of the grievance satisfaction survey as part of our continuous improvement work and to continue to build trust and confidence in the process and outcomes.

The IOPC recommends that the MPS should build on the steps it has taken internally against bullying and harassment, by publicly committing to a position of zero-tolerance on bullying and harassment, which is embedded through messaging, guidance, training and on-going support for police officers and staff to proactively and robustly challenge such behaviour.

This follows an investigation into allegations of bullying and harassment on a team of officers working at Charing Cross Police Station. This found pervasive evidence of such behaviours, including demeaning and intimidating actions towards police officers on probation; officers being shouted at by supervisors; and women being treated as a “weary female” when speaking out about the behaviours of male colleagues. The culture of bullying appears to have been accepted and not challenged.

A review conducted by the Independent Police Commission, an independent inquiry focusing on the future of policing in England and Wales, found a positive correlation between reported bullying and the number of complaints received about police officers’ conduct. This is supported by the Operation Hotton investigations as multiple conduct issues were identified and bullying was present. Bullying at work is unacceptable and it is recognised that this is even more serious given the difficult job that officers have to undertake and the likely abuse they may experience from the public when carrying out their frontline duties.

Adopting and announcing an organisational position of zero-tolerance would reflect the MPS view that bullying and harassment is not acceptable in any circumstance and provides a clear and simple message on this for officers, staff and the wider public. A clear expectation needs to be set that evidence of bullying and harassment will never be ignored or accepted, and always challenged and dealt with proactively and robustly, and officers and staff will be protected from being subject to these behaviours. Messaging, guidance, training and on-going support would all be important in embedding a zero-tolerance position and creating a culture where police officers will feel empowered to report and challenge such behaviour and be supported in doing so. 
 

Do you accept the recommendation?

Yes

Accepted action:

The Metropolitan Police Service (“MPS”) has reviewed and accepts this recommendation by the IOPC.

The MPS believe that our very strong position on harassment and bullying is absolutely clear. The Code of Ethics, in place since 2014, is widely published and is frequently referenced in relevant communications. Our policy clearly states that ‘bullying and harassment are both types of inappropriate behaviour that are not tolerated by the MPS in any way.’

We are content to incorporate the language ‘zero tolerance’ into the Policy that will thus read, bullying and harassment are both types of behaviour that will not be tolerated by the MPS in any way and we will adopt a zero tolerance approach in dealing with them.

The Standards of Professional Behaviour for Police Officers and the Police Staff Discipline Standard Operating Procedures both state that misconduct ‘could include bullying in the workplace, harassment or other discriminatory behaviour.’ We have taken, and continue to undertake, active steps against bullying and harassment through training. We have invested in the ambitious ‘Leading for London’ programme which included mandatory workshops for all officers and staff from the rank of sergeant to superintendent and police staff bands D to B.

More recently the MPS have also delivered the ‘Inclusive Leadership Campaign’. This aims at encouraging behaviour in line with Met Values and the Code of Ethics. This campaign was launched at Chief Officer and Director levels and it has now been expanded to local leaders through online learning and is available across the MPS.

Newly promoted sergeants and inspectors receive specialist training. The detail of areas covered in this training is provided below. This also includes input from the DPS on professional standards, behaviour at work and the Equality Act, including victimisation. The Grievance Management Team also input on these courses to highlight the mediation and grievance process and best practice to achieve early resolution.

The IOPC recommends that the MPS should review and ensure the adequacy of its current training and guidance on the appropriate use of social media, including duties under the Code of Ethics that extend to officer’s private lives. In particular, ensure all officers and staff conform to the expectations of their behaviour under the Code of Ethics; make clear that information posted by officers and staff on social media platforms should conform to these guidelines; and that privacy is not a defence to discreditable conduct. Further, it should make clear that deleting offensive or derogatory material from digital devices is not a suitable method to avoid disciplinary action.

This follows an investigation into allegations of bullying and harassment on a team of officers working at Charing Cross Police Station. The investigation found evidence of messages exchanged between police officers that was often highly sexualised and/or violent and discriminatory. When questioned about the messages, many relied to some extent on the defence that they were private. Other evidence suggested officers were told they should regularly delete conversations, indicating that they knew such messages could bring the force into disrepute.

Police officers are expected to adhere to professional standards of behaviour at work and in their private life. This indicates that clarity is needed around officers being held to a higher standard than members of the public, even in their private lives.
 

Do you accept the recommendation?

Yes

Accepted action:

The Metropolitan Police Service (“MPS”) has reviewed and accepts the recommendation by the IOPC.

The MPS are absolutely focused and committed on this area. The MPS’s ‘Ethical Use of Social Media and Online Communication Principles’ were introduced in February 2020. These are delivered on the key training touchpoints for new recruits and promotion courses.

They have been continually reinforced with an internal media campaign. The principles remain current and have been circulated nationally as best practice. They apply to use of all forms of social media and require adherence, including to the Code of Ethics and Standards of Professional Behaviour in both a personal and professional capacity. The Code of Ethics is widely published and is frequently referenced in relevant communications.

There is however, a continuing issue of unacceptable ‘banter’ escalating to Misconduct and Gross Misconduct communicated on WhatsApp groups and other social media. The OCU Commander of the Directorate of Professional Standards sits on the NPCC ‘Inappropriate Use of Instant Messaging and Social Media Working Group’ chaired by an Assistant Chief Constable. They have volunteered to be the policy and procedure lead to influence good practice and change in this area. Options that are being considered for policy changes in the MPS are personal versus private use of work mobile devices and the use of ICT systems.

The DAC for Professionalism chairs the ‘Professionalism and Standards Working Group’. This provides strategic and policy delivery on three work streams, which specifically include WhatsApp and Social Media.

This group makes recommendations to MPS Management Board through the Learning and Development Executive Steering Group on changes required. The issue of social messaging is one of three priorities highlighted by the Deputy Commissioner to address our culture, stating ‘our professional standards must extend to all communications both on and off duty. This means that ‘you should not write or share anything on social media or via messaging apps that you would not be happy to share with your parents, grandparents, your children, your supervisor, the person you are commenting on or have the material appear on the front page of a newspaper. In short if you have any doubt about the appropriateness of the material you probably shouldn’t be sending it.’

The Assistant Commissioner for Frontline Policing also highlighted this issue in an all staff blog , declaring ‘the absolute imperative for us to wake up and recognise the sickness that does undoubtedly exist in some of our number in respect of their attitude to the public, as evidenced in offensive material, language and sentiment shared on social media groups. It must stop now or we lose our public.’

Learning and Development provide training to both new recruits and to newly promoted sergeants and inspectors on these issues. The training provided to newly promoted supervisors highlights the negative impact of bullying and harassment, it looks at signs and symptoms that it may be occurring and examines how to address it effectively.

This training includes the following areas which will be built into a new promotion course currently being designed:

Personal Values and Personality Types - defines acceptable behaviours and relationships with our staff, aligned with the Met Values. It looks at how we can adapt and recognise different personalities and how best to work with them to get the very best from our people.

Inclusive Leadership - examines the importance of being fair and consistent to ensure all our staff feel included, listened to and part of the teams we lead. It emphasises that rank does not give the right to be overbearing. It highlights the importance of having good relationships with our staff and to understand their needs and differences to make sure everyone feels included, irrespective of background, culture, rank or personal situations, such as being carers or parents or having a disability.

Pressure – this looks at ‘strain curves’ and how these can affect new leaders, how they can impact behaviours and we provide them with tools to understand demands, constraints and supports in order to be able to address pressure and stress and to recognise this in their staff and offer them tools and support.

Leadership Impact – the MPS look at the importance of creating a lasting legacy of support, diversity and encouraging talent and how our impact and behaviours as leaders can shape this legacy throughout our service.

Motivation – we look at how four areas of motivation can ensure we get the best out of our staff and how things like autonomy and being a micro/bullying/over-burdening manager can have real negative impacts on morale and motivation. We give managers the tools to be able to address lack of motivation.

Quality Conversations – the MPS examine how we really support and deliver to our staff and the importance of quality conversations and feedback to prevent escalating management actions. We also highlight the ‘cost of conflict’ and how being a bully/intimidating or harassing/non-inclusive leader leads to conflict and potentially sickness, grievance and an Employment Tribunal. We also provide tools for different types of feedback and when is the best time to enable a calm, structured and positive discussion.

Difficult Conversations – we look at tools and discuss how we support and develop our staff when issues or problems arise and the importance of starting these conversations constructively and early to avoid ‘finger pointing’, harassment, etc. DPS provides training input on these courses through the DPS Discrimination Investigation Unit (DIU) and DPS Prevention & Learning Team (P&L).

The DIU input defines harassment and bullying, as well as victimisation and discrimination, both direct and indirect, and provides examples. This includes the National Police Chiefs Council (NPCC) video on sexual harassment and inappropriate behaviour in the workplace. This gives insight into these behaviours and invites consideration on how they should be challenged and acted on. It also clarifies reporting channels and the support and quality assurance role provided by the DIU when allegations are made. P&L input includes discussion on the Code of Ethics.

This highlights ‘Challenging and Reporting Wrongdoing’ i.e. if a matter is reported to you as a supervisor, you must do something about it. There is a video of a bullying example followed by discussion on the correct actions of a supervisor to deal with the issue. There is also scenario based training where supervisors are asked to consider a case concerning sexual harassment and bullying of a female officer by male colleagues and how they would deal with it.

P&L also provide input to all new police officer recruits which includes issues of harassment, reporting and ‘banter’. This takes place during the initial 27 weeks of new officer training with additional input within this period on two occasions from the DPS Civil Actions Unit and the officer’s local Professional Standards Unit.

DPS P&L are currently reviewing these inputs to ensure issues highlighted in the recommendations are strengthened. As illustrated above, ‘Inclusive Leadership’ training has recently been delivered to all supervisors on MS Teams sessions across three modules and follows the ‘Leading for London’ programme, both of which focused on values and ethics in leadership.

The ‘Not in my Met’ communications package which was published on the MPS internal website on 24th February 2022 highlights the need to challenge inappropriate behaviour, including that related to WhatsApp and social media messaging rather than just deleting it. The challenging of inappropriate behaviour is a theme throughout all training and communications inputs on this subject.

The IOPC recommends that the MPS should review and ensure its current training and guidance on bullying and harassment adequately covers when remarks that may be viewed by some as ‘friendly’ banter, can create an intimidating, hostile, degrading, humiliating or offensive environment for others, and therefore be seen as ‘ignorant’ or ‘malicious’ banter by others.

This follows an investigation into bullying and harassment on a team of officers working at Charing Cross Police Station. Evidence of messages exchanged between police officers that were often highly sexualised and/or violent and discriminatory were generally described as “banter” by police officers in their defence. When the behaviour was challenged by their supervisors, the use of the word ‘banter’ in defence was accepted, allowing the sender to get away with the bullying. Accepting such messages as ‘banter’, led to inaction, allowing the culture to permeate and persist, whilst those on the receiving end felt harassed and that they had to accept it to avoid feeling humiliated and ostracised.

By recognising that the term ‘banter’ can be used inappropriately to describe behaviour that is malicious and/or ignorant and by not tolerating the term as an excuse for unacceptable conduct those on the receiving end of it or who witness it may feel empowered to be able to challenge it and feel supported in doing so.
 

Do you accept the recommendation?

Yes

Accepted action:

The Metropolitan Police Service (“MPS”) has reviewed and accepts this recommendation by the IOPC.

We believe that these issues are covered under Recommendation 3 and that this recommendation is previously addressed. The MPS is adopting a new pledge to be undertaken by all staff when attending training courses.

This is currently within a consultation process where we anticipate this to be completed by March 31st. This pledge will make quite clear the dangers of “banter” and the potential for it to be seen as oppressive. This will be published at every training site in the MPS, including Public and Personal Safety Training (PPST) delivery sites and the MPS Driving Academy. Attention will be drawn to the document at the beginning of every training day including by the Learning and Development Basic Command Unit Teams.

It will also feature in the Line Management Guide that accompanies all Student Police Officers when released from their Street Duties course into BCUs, the student handbook for all Student Police Officers and it will be included in the Public and Personal Safety Training Handbook that the students receive as a pre-read. The pledge will also be used to frame feedback conversations regarding training with Learning and Development.

A copy of the finalised pledge will be supplied to IOPC when consultation with Staff Associations has been completed.

In addition, under the terms of the Rebuilding Trust work the MPS is undertaking, we have the following priorities that will support this recommendation:

• We require all Line Managers to reinforce standards with their officers and staff.

• Deliver Operation Signa - an internal programme to ensure our people actively intervene and challenge inappropriate behaviours.

• Deliver the next phase of our leadership programme (Leading for London). This will be followed by a second campaign focused on creating high performing (and inclusive) teams.

• Strengthen our existing Met Values.

Furthermore, the Commissioner set out additional measures:

• A letter was sent to all MPS staff from the Commissioner setting out in very clear terms what she expects from them and the behaviours that will not be tolerated.

• On the 5th February 2022 the Commissioner led a call with all her senior leaders, spelling out what she expects from them and went through the detail of this letter. They were then required to speak to every team in the following few days to ensure everyone had seen and read the Commissioner’s letter; understood it, and to spell out clearly and explicitly the standards that she expects and the requirements the MPS places on people to come forward and report wrongdoing wherever they see it. Senior leaders were required to report back to the Commissioner within two weeks that these briefings had taken place.

• The Commissioner and Management Board visited as many locations as they could to join these briefings to ensure the importance of what was being said was understood by all.

• The Deputy Commissioner will personally brief all 733 recently promoted sergeants, reiterating the Commissioner’s expectations of them in their key leadership role to promote and maintain the highest of standards.

The Directorate of Media and Communication published the ‘Not in My Met’ campaign and in collaboration with the DPS Prevention and Learning Team created a new ‘Dilemma of the Month’ on the MPS internal website.

The above action supports this recommendation and provides an example of how we are addressing ‘banter’ in our current messaging.

The IOPC recommends that the MPS should assure itself that it is taking sufficient steps to eradicate racism from the force, ensuring continued progress against learning recommendations issued by the Macpherson Report and with specific measures to demonstrate improvements. As part of their ongoing work to build community confidence, the MPS should commit publicly to being an anti-racist organisation with a zero-tolerance position on racist behaviour.

This follows an investigation into allegations of misconduct in a team of police officers working at Charing Cross Police Station. During the investigation, the IOPC found evidence of communications discriminatory and offensive in nature. The IOPC spoke to police officers who described being on the receiving end of persistent bullying behaviour by colleagues because of their race. The evidence found by the IOPC could bring the police service into disrepute and undermine public confidence in the MPS. The tolerance of such behaviour suggested it was viewed as acceptable.

Given the diverse communities served by the MPS, communications of this nature are deeply concerning as they may reflect officers’ attitudes and their ability to police communities sensitively and impartially. The seriousness and frequency of such comments that went unchallenged suggested a systemic cultural issue that allowed the behaviour to pervade and persist. 
 

Do you accept the recommendation?

Yes

Accepted action:

The Metropolitan Police Service (“MPS”) has reviewed and accepts this recommendation by the IOPC.

The MPS is anti-racist and does not tolerate racism. In fact, the MPS does not tolerate discrimination in any form.

The MPS has spent many years working to eradicate racism within the organisation in a range of ways since the Macpherson Report’s publication in 1999, best documented in our regular and published returns to the Home Affairs Select Committee (HASC). Most recently in 2019 the MPS made a full submission to the HASC on our progress against the 27 relevant recommendations of Macpherson. In July 2020, the Commissioner appeared before the HASC and confirmed her position that ‘we have come an enormous way’ since Macpherson. There is a lot of activity that has been undertaken, and will be continued to be undertaken, set against the Report’s recommendations.

The MPS has publically stated that it has a zero-tolerance approach to racism. DAC Javid (MPS Professionalism) recently stated on BBC Newsnight (February 2022): “Let me be really clear on this: there’s absolutely no room for racism in policing, and especially here in the Metropolitan Police. We made that very, very clear to our people, anyone who works for us and demonstrates any type of racism or discrimination behaviour will be removed from the organisation…You know, we’ve done a huge amount of work over a long period of time to make it one absolutely clear stance for anti-racism, and zero tolerance on any form of discrimination”. This was widely reported by mainstream media channels.

Met Direction makes clear that the principles of fairness, championing difference and diversity; creating an open and reflective culture and caring for each other are at the forefront of our strategic vision.

Our priority to ‘mobilise partners and the public’ states that, ‘we will work harder to earn the trust of more young people and ethnic minority communities.’ This is reinforced in the recent update to the strategy to focus on ‘improving trust and confidence.’ It is also underpinned by the Met Business Plan, which describes the key activities to progress this strategy. Our position on not tolerating racism (or other kinds of discrimination) is made clear to officers and staff when they join the MPS. This includes ‘unintended’ and ‘misunderstood’, as well as overt discrimination. This is reinforced by mandatory training on racism awareness, diversity and inclusivity. Recruit and promotion training includes input on challenging and reporting inappropriate behaviour and officers on promotion also receive training on unconscious bias.

Our Strategy for Inclusion, Diversity and Engagement (STRIDE) has been refreshed as STRIDE 25. This is in line with recommendations from the Her Majesty’s Inspectorate of Constabulary and Fire and Rescue Services (HMICFRS) inspection in 2020. It also directly supports the Mayor’s Action Plan which aims at increasing the transparency, accountability and trust in policing, particularly among London’s Black communities. It provides commitments set against four key themes underpinned by an Action Plan with 16 commitments, each with a senior lead reporting progress to MPS Management Board, a declaration that ‘our pace must accelerate’ and ambitious targets to be achieved by March 2022. This work has a strong governance and delivery framework.

Our 16 Commitments, by theme, are:

Protection: The MPS’s core mission is to keep London safe for everyone. We achieve this through preventing crime, solving crime – which prevents further crime – and protecting people from a range of harms.

1) We will confront those who cause pain and fear through hate crime.
2) We will work proactively with communities to reduce violence by building trust. 
3) We will work with partners to reduce criminal victimisation of those who are most disadvantaged. 
4) We will work with partners to increase opportunities to divert people away from offending.

Engagement: The relationships between the police and the public in London are strong – and there is always more to do to improve them. Every day our officers and staff are working to strengthen those relationships, to speak to, and hear from, the breadth of London’s diverse populations. We want the MPS to be a trusted and effective social institution so we will engage with communities and partners about the challenges London faces and how we can address these together, as well as how we can make a wider positive contribution to society and support the values that matter to Londoners.

5) We will ensure that every ward has a ward panel which people can engage with online. 
6) We will transform our two way communication with the public. 
7) We will engage with, understand and celebrate all of London’s communities.
8) We will make more relevant equalities information available to all.

Equality: Working together as a diverse organisation will help us break down systemic and institutional challenges inside and outside our organisation and make London a safer city. It will help us increase public trust across all groups in London. It will mean that all our people, with all the diversity and commonality that they bring, will thrive.

9) We will work with communities and partners to achieve our recruitment, retention and progression aspirations for those from under-represented groups. 
10) We will work to ensure that our people feel included and that they are treated with fairness and respect. 
11) We will continue to reduce disproportionality in our internal processes. 
12) We will improve the inclusion and confidence of our Disabled officers and staff members.

Learning: Our overall Met Strategy, The Met Direction, sets out learning as one of our most important priorities.

13) We will develop a generation of inclusive leaders. 
14) We will improve our response to complaints from the public. 
15) We will make community engagement central in our use of powers. 
16) We will increase transparency and understanding of our use of powers.

The Commissioner chairs the Inclusion, Diversity and Engagement Management Board which meets every six weeks and provides oversight on performance. Diversity and Inclusion is also a key agenda item for the People and Learning Board, chaired by Chief of Corporate Services, and Performance Delivery Board, chaired by the Deputy Commissioner. The MPS is committed to equality for all, whether due to formally protected characteristics or otherwise, and each action and commitment area is reviewed regularly at STRIDE Boards. To maximise public awareness of this work and show its priority to the MPS, we will publish publically annual action updates.

The current STRIDE Strategy is directly linked to the work of the Deputy Commissioner’s Delivery Group (DCDG), which was established in 2020 as a time-limited group focused on improving the confidence of the Black community. The confidence of the Black community in policing, notably the MPS, is recognised as an area of historical importance; the murder of Stephen Lawrence being pivotal in that history. Reflecting on the Macpherson Report has been part of the DCDG Delivery Plan.

The DCDG function remains in place and is delivering the Mayor’s Action Plan alongside other MPS actions. Its oversight is maintained internally by the Deputy Commissioner directly as well as through relevant MPS/MOPAC Boards. This is complemented by quarterly public meetings, where the progress and detail of the Mayor’s Action Plan are shared and feedback obtained.

The MPS promotes the Code of Ethics and the MPS Values that both set out standards and principles on race and diversity. Failure to comply with these high standards and allegations of racism by members of the public or internally by MPS officers or staff, are treated very seriously. The MPS is the only police service which has a dedicated Discrimination Investigations Unit (DIU).

The DIU is part of the DPS and investigates discrimination allegations, whether made by a member of the public or a MPS officer or member of staff. It works closely with the Grievance Management Team which deals with all internal grievances. The Discrimination Thematic Working Group (which includes DPS, Mayor’s Office for Policing and Crime (MOPAC), Crime Prevention, Inclusion and Engagement, Independent Advisory Group and Learning and Development) monitors outcomes from complaints of discrimination and supports implementation of recommendations from the IOPC race thematic review. Research conducted by MOPAC in 2015, found that Black , Asian and Multiple Ethnic Heritage officers were twice as likely as White officers to be the subject of a misconduct investigation. The MPS has made changes which aim to improve consistency of decision making in this area and to promote early management intervention to prevent escalation to misconduct.

The MPS has been criticised also for disproportionality in the use of force, handcuffs, stop and search and Taser in respect of Black, Asian and Multiple Ethnic Heritage communities. The Commissioner has frequently explained the challenge of seeking to drive down serious violence which disproportionately impacts on young Black males. These are nonetheless areas for improvement.

We have actively worked to implement the Mayor’s Action Plan, with public updates released on the MOPAC website. The MPS has 23 actions under the plan, all of which are shown as either progress on track or complete. These cover a range of diversity and inclusion issues, including operational (stop and search, use of handcuffs and Taser), community confidence (development of a cultural awareness toolkit, reform of public complaints handling with confidence survey) and ambitious recruitment targets for officers from under-represented ethnic groups.

We seek to achieve 16% Black, Asian and Multiple Ethic Heritage officer recruitment by next year, rising to 28% by 2030. This means Page 28 of 53 40% of officer recruits being from Black, Asian and Multiple Ethnic Heritage communities over the next decade. In 2021, the MPS introduced Outreach teams, supported by recruitment specialists, on all 12 Basic Command Units (BCUs) dedicated to work in the community to recruit Black, Asian and Multiple Ethnic Heritage and women officers. Recruitment events are held in locations such as high footfall areas, transport hubs, shopping malls and places of worship. Events have also been held in higher and further education establishments, schools, and in partnership with external groups and community forums. Analysis has indicated that community and large scale four day events have been most successful. The effective use of the cultural calendar enables the teams to plan events in advance and brigade the support of volunteers from the London Safety Centre, Cadets and Specials and Staff Support Associations making this a truly collaborative effort.

Over the past 12 months, over 20% of Black Female (our biggest recruitment challenge) applicants heard about the police officer vacancy from Outreach. 27% of Black Female applicants spoke only to an Outreach member before making an application. It is within this group the biggest impact has been seen. Similar successes are seen for Black candidates as a whole (22%), Female candidates (14%) and Asian Female applicants (17.3%). The highlighted percentage of each group of these candidates spoke only to an Outreach member before making an application. We have sought to strike the balance between getting sufficient candidates from London to apply, whilst also ensuring we continue to attract more broadly for the skills and experience we require for some of our more specialist pathways.

The IOPC recommends that the MPS should build on the positive steps it is taking to eradicate sexism and misogyny from the police force, which should include committing publicly to a position of zero-tolerance. This should include reviewing its current policies, training and guidance on bullying and harassment to ensure they adequately cover how toxic masculinity, sexism, and misogyny can create an intimidating, hostile, degrading, humiliating or offensive environment for others. Training should include how police officers and staff can challenge such behaviour, as well as specialist training for supervisors.

This follows an investigation into allegations of misconduct in a team of police officers working at Charing Cross Police Station during which evidence was found of a culture of ‘toxic masculinity’, sexual harassment and misogyny. During the investigation, the IOPC found evidence of teams dominated by macho officers using discriminatory, misogynistic and offensive language. When challenged by colleagues, those who reported the behaviour were ostracised, harassed and humiliated. Whilst some witnesses recognised that the language used was unacceptable, others dismissed it as ‘laddish banter” and failed to understand the impact of the comments made. Supervisors appeared to have failed to understand the impact of the comments made. Women were expected to be ‘strong’ and able to ‘take the banter’.

The evidence found by the IOPC could bring the police service into disrepute and undermine public confidence in the MPS, as it could be seen as a reflection of how male officers may respond to the women they come into contact with during the course of their duties.

Adopting and announcing an organisational position of zero-tolerance would reflect the MPS view that sexism and misogyny has no place in policing and provides a clear and simple message on this for officers, staff and the wider public. A clear expectation needs to be set that evidence of sexism and misogyny will never be ignored or accepted, and always challenged and dealt with proactively and robustly, and officers and staff will be protected from being subject to these behaviours. Messaging, guidance, training and on-going support would all be important in embedding a zero-tolerance position and creating a culture where police officers will feel empowered to report and challenge such behaviour and be supported in doing so.
 

Do you accept the recommendation?

Yes

Accepted action:

The Metropolitan Police Service (“MPS”) has reviewed and accepts this recommendation by the IOPC.

The Commissioner has set out the priorities for our ‘Rebuilding Trust.’

Specific immediate actions include the following:

Raising Standards; to review allegations of sexual misconduct and domestic abuse by officers and staff, an uplift in officers for the DPS, a specific root and branch review of the Parliamentary and Diplomatic Protection Command and a quick response to Her Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS) recommendations on vetting;

Improving our Culture; ‘Inclusive Leadership Campaign’, Operation Signa, investing in leadership development for women seeking promotion and refreshing our flexible working policy, and Doing our Job Well in Protecting Women and Girls; this includes better criminal justice outcomes for victims, with an action plan to be published in the coming weeks.

Our culture and standards of behaviour are now subject to a formal review by Baroness Casey of Blackstock. This will include reviewing allegations of sexual and domestic abuse cases against MPS officers and staff. In addition, a dedicated sexual and domestic abuse team has been created within DPS to improve our response in respect of these crimes and misconduct.

In November 2021, the Deputy Commissioner set out three priorities through which all officers and staff must address these issues, specifically; the ‘absolute adherence to professional boundaries’ stating, ‘we all hold (regardless of rank) positions of power and influence and often deal with people who are vulnerable and seeking support from us. It is completely unacceptable for us to step beyond our professional role in our contact and behaviour. We will deal robustly with anyone who makes sexual advances, ’flirts’, or makes unprofessional contact or responds in kind to sexual approaches in any form with victims, witnesses or other vulnerable individuals. Professional boundaries must also be respected with colleagues; sexual harassment, bullying or behaviour that isolates, marginalises or excludes colleagues must not and will not be tolerated.’

The DAC for Professionalism chairs the ‘Professionalism and Standards Working Group.’ This is progressing strategic and policy issues to improve standards across the three key work streams of Sexual Misconduct in the Workplace, WhatsApp and Social Media and Uniform and Appearance. Leads have been appointed for each work stream and they report on a regular basis on activity being delivered to drive improvement in standards.

This Working Group makes recommendations to Management Board through the Learning and Development Executive Steering Group on changes required. In respect of Sexual Misconduct in the Workplace, this includes;

• Development of a sexual harassment policy and recording mechanism (see Operation Signa below).

• Reporting for leaders within the Met to understand culture within their business area.

• Working with BCU Learning & Development Units to educate new recruits and embed expectations.

• Working with colleagues in other forces to learn and share good practice .

• Development of toolkits to assist individuals and teams in dealing with this issue.

‘Knowing the Line’ is our existing initiative against sexual harassment. The MPS has launched ‘Operation Signa’ against sexual harassment and sexism. This is a ‘choose to challenge’ programme and includes a reporting mechanism, a new policy based on that recommended by the Equalities Commission, and strategies for intervention for everyone to challenge when they see this behaviour happening. It will include training, a communications strategy and clear explanation on what is acceptable and not acceptable behaviour.

The ‘Network of Women’ provides support and advice for women across the organisation. In addition, the MPS fully supports the United Nations’ initiative ‘HeForShe’ through which male officers and staff seek to advance gender equality and to challenge negative stereotypes and behaviours.

The Employer’s Independent Domestic Victims Advisor (IDVA) is a support service provided by the Hestia Domestic Violence Charity to MPS officers and staff who are a victim of sexual violence and domestic abuse. The service can be accessed by self-referral and it provides free and independent advice on legal options, finance and housing.

New guidance for DPS investigators was launched in November 2021 where there is now referral of all domestic abuse cases involving MPS employee victims to the IDVA. This can be monitored on Centurion for compliance. DPS is also engaged in an initiative to better include IDVA in support for victims in cases which are referred to the Hearings Unit for potential Gross Misconduct.

Operation Signa is based on months of research on what works in this arena and is linked into the NPCC Sexual Harassment Working Group. Signa has been launched and provides a recording tool for people to report sexual harassment, sexism and other demeaning behaviours.

The records coming in are used to educate the wider workforce on what behaviours are going on and the impact they have; this is to reinforce the message that it is widespread and not just a number of isolated incidents. The tool also allows Senior Leadership Teams (SLT) to understand what the culture is on their commands and gives them the tools to tackle it from the Signa Toolkit.

The Signa training has been mandated under the Violence Against Women and Girls strategy. It is an interactive training programme that revolves around stories told by women within the MPS and gives the attendee the opportunity to discuss when interventions should take place and what to look out for. It is clear what the impact of “banter” and other behaviours are and seeks to drive upstanding behaviours and gives the participant the tools to challenge.

This training will be mandatory across the MPS and the roll-out started on 14th February 2022. Signa will be evaluated with the University of Cardiff to ensure it is fit for purpose and meets the required needs.

The IOPC recommends that the MPS should review how it deals with internal reports of sexual harassment, including how the Directorate of Professional Standards (DPS) should engage with victims, seeking their views about designating them as persons entitled to information during the investigation to ensure a victim centred approach, and include appropriate support and updates regarding their allegation.

This follows an investigation into allegations of misconduct in a team of police officers working at Charing Cross Police Station during which evidence was found of a culture of ‘toxic masculinity’, sexual harassment and misogyny. During the investigation, the IOPC found evidence that women who reported their experience of sexual harassment felt unsupported by those from who they should have expected care including a lack of information about investigations. Victims of crime are designated with important rights under the Victims Code during criminal investigations, however these rights and entitlements are not mirrored for police officers who are victims of misconduct by their colleagues. Victims who are police officers are not entitled to make complaints under police misconduct regulations about fellow officers within the same force. This means that legally they are not provided with a default right to engagement and information during investigations which arise from their allegations. Whilst the MPS Grievance policy stipulates that aggrieved persons reporting bullying and harassment at work should be involved in the investigation and receive regular updates, it does not stipulate how often. The MPS Behaviour at Work policy links to information about DPS but that does not include information about how victims will be engaged, consulted, updated nor supported during misconduct investigations.

It is recognised that reporting a colleague comes with significant personal risk and knowledge of colleague’s poor experiences who have done the same can prevent other victims from coming forward and embolden perpetrators to continue their behaviour.
 

Do you accept the recommendation?

Yes

Accepted action:

The Metropolitan Police Service (“MPS”) has reviewed and accepts this recommendation by the IOPC.

As outlined in Recommendation 8 above, there is a lot of ongoing work to improve in this area. In addition to the independent review, there is a Gold Group (strategic senior leadership meeting inclusive of relevant stakeholders) that provides oversight on investigations into sexual and domestic abuse allegations committed by officers and staff.

The following actions come within the terms of reference of this group:

• To ensure there is a clear understanding of the amount of active cases within the MPS.

• To ensure that cases are progressed in a timely and efficient manner, including the updating of victims and suspects.

• To monitor patterns of behaviour and mitigate risk of those who remain employed by the MPS.

• To ensure sufficient interaction with Public Protection in support for victims.

• To provide oversight and delivery of the DPS recommendations from the learning from the Super Complaint from the Centre for Women’s Justice. These are a bespoke reporting channel, external disciplinary procedures and IOPC oversight, updating victims about misconduct procedures and restricting roles of officers facing allegations to prevent working with victims of domestic and sexual abuse.

As mentioned above, the ‘Knowing the Line’ Campaign was launched in 2019 nationally to tackle sexual harassment and to increase awareness. As part of this campaign, the Directorate of Professional Standards’ Discrimination Investigation Unit (DPS DIU) led on a series of MPS internal website articles aimed at promoting awareness and explaining their work. At that time the DIU remit included all allegations of sexual harassment, bullying, harassment and victimisation. The Detective Superintendent leading the DIU chaired a monthly ‘Sexual Harassment Implementation Plan’ (SHIP) meeting. This group worked to implement new guidance and learning for DPS investigators and, following a de-brief with a victim, learning in relation to improving victim care formed part of new guidance which was launched in November 2021.

As part of the ‘Rebuilding Confidence and Trust’ work (October/November 2021) the DPS conducted a series of internal reviews. This included a review of over 300 live investigations where domestic abuse and sexual offences were identified, and a dip sample of 100 historical cases also linked to domestic abuse or sexual offences from the previous 10 years, to capture any learning to improve future investigations. From these reviews a series of learning outcomes were identified. These have been used to inform the working practices of the newly formed Domestic Abuse and Sexual offences Unit (DASO) who are part of the DPS. The outcomes cover a range of topics specific to internal reports of domestic abuse and sexual misconduct. These include the appropriate initial response to reports of sexual misconduct, the means of support available to those making such reports, together with guidance on several elements of the investigative process.

The DASO Unit were launched in January 2022, and consist of a team of dedicated officers who are experienced in and receive specialist training in matters linked to sexual misconduct and domestic abuse, and who provide a robust response to both public complaints and internal reports of police perpetrated domestic abuse and sexual misconduct.

The SHIP meeting has now developed and has now widened its remit to include all sexual misconduct and domestic abuse allegations. Internal reports to DPS are dealt with on a case-by case basis, treating those who report matters as victims in the first instance, as opposed to an interested person, therefore remaining focused on victim care. The DPS have also introduced a new tile on the MPS internal website providing best practice on all DPS matters, including sexual harassment investigations, to ensure the legislation is followed. This is an on-going initiative and will be added to and updated regularly to inform the organisation of the steps being taken to improve standards in this area.

In relation to better use of interested person status (IP Status), following a separate internal review of police perpetrated sexual misconduct and domestic abuse, the MPS identified the need to ensure that in all relevant cases, due consideration is given to designating those who make such reports as an interested person, a specific status within Section 21 Police Reform Act 2002.

Having this status means the MPS would be obligated to keep the person making the internal report properly informed of:

a) the progress of the handling of the recordable conduct matter;

b) the outcome of the handling of the recordable conduct matter, and

c) the progress of any criminal, disciplinary or performance proceedings or reflective practice review process brought in relation to or arising from any matter which was the subject of the recordable conduct matter, the outcome of any such proceedings or process and the outcome of any appeal (as applicable). Regulation 34 The Police (Complaints and Misconduct Regulations) 2020.

Without IP Status, and in the absence of a crime having been committed against them, a person making an internal report of sexual misconduct would not be entitled to any of the information listed at points a – c.

From April 2022, all internal reports of sexual misconduct will be considered for interested person status. There will be a monitoring system to ensure this is completed by the DASO team.

As is referenced in the Operation Hotton Learning Report, ‘Victims of crime are designated with important rights under the Victims Code during criminal investigations, however these rights and entitlements are not mirrored for police officers who are victims of misconduct by their colleagues.’ Whilst this is true, affording IP Status to those who make internal reports of sexual misconduct, in tandem with the other steps mentioned above, will lead to significant improvements in the MPS approach to those who make internal reports of sexual misconduct.

With additional resources the DPS will have capacity to review all such allegations, including the vetting and conduct history of accused officers and staff, and to ensure victims are being properly supported and investigations are absolutely thorough.

Our vetting processes are subject to an HMICFRS inspection and we will respond promptly to recommendations from this. We have an increase in staff planned for the Reference and Vetting Unit to enhance its work. The above also highlights work in place with Network of Women, HeForShe and the Signa initiative that have recently been launched.

In addition to this specific recommendation the MPS wish to highlight the additional work we are currently engaging in to support victims of rape and serious sexual offences (RASSO).

Operation Soteria-Bluestone is an academic-led transformational approach to rape investigation in the MPS. Pillar three of Soteria Bluestone concerns developing and embedding a systematic procedural justice approach to victim engagement. Central to Pillar three is the MPS ambition to shift focus of RaSSO investigations firmly onto the suspect.

This will require a change in culture that addresses the requirement to focus investigations primarily on the suspect, as opposed to the victim’s background and credibility.

The findings of Operation Soteria-Bluestone were shared internally with the Head of Profession, Management Board and MOPAC in December 2021 and a number of recommendations for improvement were made. The recommendations concerning the reform of the MPS’s approach to victim engagement will be driven by a dedicated ‘Pillar lead’ at Detective Chief Inspector level.

The IOPC recommends that the MPS should review and ensure the adequacy of its current training and guidance on the requirement by police officers to report, challenge or take action against the conduct of colleagues. This should include the responsibilities under the College of Policing Code of Ethics, available routes of reporting and the support available for those who report wrongdoing.

This follows an investigation into allegations of misconduct in a team of police officers working at Charing Cross Police Station. During the course of the investigation, it became apparent that there was a reluctance to challenge inappropriate behaviour and misconduct, despite one of the standards of professional behaviour for police officers and police staff being a requirement to “report, challenge or take action against the conduct of colleagues which has fallen below the standards of professional behaviour”. Reasons why behaviour was not reported included people feeling it would not be dealt with effectively; they were ostracised and feared repercussions, labelled a “grass”, and felt unsupported. Other officers spoke of loyalty, and a ‘them and us’ culture. This enabled the conduct identified to persist without challenge.

Do you accept the recommendation?

Yes

Accepted action:

The Metropolitan Police Service (“MPS”) has reviewed and accepts this recommendation by the IOPC.

In June 2021, the MPS launched the ‘Raising Concerns Policy’. This brings together a number of existing policies to provide clarity to officers and staff on the requirement to report wrongdoing and the methods through which to do this. This widens the scope of the previous ‘Whistleblowing’ policy to include ‘anyone who raises any concern to anyone.’ It sets out clear responsibilities for line managers and the expectation that anyone who raises a concern in good faith will be listened to and supported. It reinforces the flexible range of options for reporting improper conduct.

These include contact with line managers, direct contact with the DPS Intelligence Bureau, the Right Line telephone and online reporting (including anonymous reporting), Crime Stoppers Integrity Line and the IOPC. The ‘Raising Concerns Policy’ is available on the MPS internal website via both the Rebuilding Trust and Professional Stands portals.

This has been reinforced under the Deputy Commissioner’s priority to ‘actively intervene and challenge’ which clearly states ‘to earn the trust of the public it is not enough to behave professionally we must all actively intervene and take appropriate action to challenge or report it. We are all part of the solution to ensuring high professional standards are maintained and creating an environment where wrong doing is not tolerated’.

Training on this policy, and the systems and processes that underpin it, have been delivered to local Professional Standards Units and is part of the regular training input that the DPS Prevention and Learning Team delivers.

The DPS Prevention and Learning Team has an MPS wide commitment to improve public trust and confidence in the MPS’s professional standards. The team deliver professional standards presentations to newly recruited police probationers, Metropolitan Special Constabulary and police staff, newly promoted police officers up to and including the rank of superintendent and officers transferring into the MPS from other police forces.

In addition, the team are often asked to deliver presentations to existing officers on locally facilitated professional development days. Presentations are tailored to the audience, but they all include core delivery of the Raising Concerns Policy and the National Police Chief Council (NPCC) key threats (STUDIOS: Sexual misconduct, including abuse of position for sexual purpose; Theft and fraud; Unauthorised disclosure of police information; Drugs use and supply; Inappropriate associations; Organised crime and Social media). The presentations encourage audience engagement, with the inclusion of scenario and case study led learning, concluding with a dedicated question and answer session. In addition, dedicated Professionalism Chief Inspector posts are now in place in all 12 Basic Command Units (BCU’s).

Their role has a specific focus on driving better professional standards, including:

• Supporting the BCU Commander to lead and ensure effective oversight of standards across all aspects of local activity.
• Setting standards, identifying risks and ensuring a timely and effective response to improving standards across all operational areas (uniform, behaviour, buildings, vehicle fleet and equipment).

• Raising awareness and educating in standards, ensuring any organisational learning is shared and acted on. 
• Driving a culture where standards matter and implementing an appropriate performance management framework to identify areas of risk. 
• Overseeing a local communications and engagement strategy to explain expectations, communicate the rationale and ensure understanding amongst the workforce. 
• Where necessary, addressing poor standards and ensuring appropriate action is taken at the individual, team and BCU level. 
• Leading the local BCU Professional Standards Unit and undertaking the role of Appropriate Authority. 
• Acting as Organisational Learning specific point of contact.

The Commissioner’s ‘Rebuilding Trust’ plan under ‘Improving our Culture’ includes:

• The “Not in My Met” campaign where all officers and staff have been spoken to regarding the standards we expect, their role in rooting out inappropriate behaviour and clear guidance on where to go and get support and report all wrongdoing. We have launched the ‘Not in my Met’ tile on the MPS internal website home page, signposting key messages and materials / support for managers and staff. 
• Upskilling 10,000 leaders across the organisation on ‘Inclusive leadership’. 
• Operation ‘Signa’ programme which will work to ensure our people actively intervene and challenge all inappropriate behaviour.

The MPS will make it clear as part of our attraction and recruitment process for officers, staff, volunteers and contingent workers what we expect in terms of values and standards. We will enhance our hiring manager guidance to support hiring managers with selection so they clearly assess that candidates’ values and behaviours align with those of the MPS.

The MPS Learning and Development Command are currently updating the corporate induction packs and supervisory training.
 

The IOPC recommends that the MPS should take steps to ensure that when it has been identified that an officer has failed to report or challenge improper conduct, whether or not misconduct processes are initiated against that officer, appropriate steps are taken to understand the reasons from a learning perspective.

This follows an investigation into allegations of misconduct in a team of police officers working at Charing Cross Police Station. During the course of the investigation, it became apparent that there was a reluctance to challenge inappropriate behaviour and misconduct, despite one of the standards of professional behaviour for police officers and police staff being a requirement to “report, challenge or take action against the conduct of colleagues which has fallen below the standards of professional behaviour”. Reasons why behaviour was not reported included people feeling it would not be dealt with effectively; they were ostracised and feared repercussions, labelled a “grass”, and felt unsupported. Other officers spoke of loyalty, and a ‘them and us’ culture. By seeking the rationale for police officers’ failure to report improper conduct, it can identify areas for improvement, and potentially misconduct, for example the bullying and intimidation that took place at Charing Cross Police Station.
 

Do you accept the recommendation?

Yes

Accepted action:

The Metropolitan Police Service (“MPS”) has reviewed and accepts this recommendation by the IOPC.

The MPS accepts this recommendation and points to policy that is already in place to address this. Our ‘Raising Concerns Policy’ makes clear the responsibility of all staff to raise concerns when they identify unethical or unprofessional behaviour by a colleague, irrespective of rank, grade or role. It confirms that such behaviour should never be ignored and that the same professional standards apply whether an individual is on or off duty and communicating in person or online. We do recognise that, in order to achieve the aims of this policy, there is a requirement to understand the reasons why staff on occasion fail to raise concerns at an early stage. To address this, the following additional changes are proposed to identify officers and staff who have ‘failed to raise concerns’ and the reasons for this:

• Met Form MM1 (used for reporting misconduct) has a section, ‘Reporter of Wrongdoing’, which documents the information provided and makes clear that the reporter is to be properly supported. It does not have a specific section to identify occasions where staff have been identified for failing to report. A ‘Failing to Report’ section could identify officers or staff where there is an indication that they knew of certain events or behaviours that should have been reported, but were not. This section should include the reasons, if known, why they failed to report.

This will assist the Appropriate Authority in their decision-making as to whether that person should be dealt with by reflected practice or investigation for misconduct or on occasion, for criminality. Outcomes would be assessed for wider organisational learning. There is a review of the current MM1 as part of a wider work to deliver the future Professional Standards operating model.

• Centurion is the system used by DPS to record complaints and misconduct. It includes an ‘organisational learning’ page. DPS investigators will be directed to include in their closing report, occasions where witnesses have been identified who are police officers and staff and who should have raised concerns earlier and the reasons why they failed to do so. This information could will then be recorded on Centurion to better understand underlying themes and to help identify mitigations. This is being explored under current work to improve use of Centurion.

• Specific guidance should be developed for Appropriate Authorities as to when officers and staff might be considered for misconduct for failing to report. However, it is important to acknowledge that the MPS supports a learning culture through processes such as reflective practice and encouraging staff to raise concerns through a variety of overt and discrete reporting systems.

• The above changes would have oversight under the DPS Organisation Learning team, which already has responsibility for collating identified learning from DPS cases. A new performance category of ‘raising concerns’ could be created to identify best practice of what encouraged staff to report, or prevented them from doing so. This would then be cascaded through the Professional Standards Units across the MPS to drive improvements.

• It is important that any focus on failure to report does not set back recent progress in staff confidence in reporting. Each case should be decided on its own facts and must be proportionate to the gravity of the principal matter reported. In addition, guidance should consider the subject of the allegation and whether they hold a more senior position over the officer or staff member reporting, as this may have influenced why a report was not made.

In February 2022, the Directorate of Professional Standards launched a new Learning Through Reflection scheme.

The process is designed to promote greater use of line manager led reflective practice, supporting the MPS’s priority of developing a culture of learning, listening to feedback and intervening early to encourage small changes in behaviour, and where necessary, identify training needs.

The scheme is not part of the legislated misconduct or performance processes although it is aligned with guidance laid down by the Home Office and College of Policing on the wider use of reflective practice within the police service.
 

The IOPC recommends that the MPS should review whether frontline roles, particularly response policing of busy areas such as Leicester Square, are assessed as roles which carry greater risk of stress and trauma, and apply the College of Policing psychological risk management guidance, 2017.

This follows an investigation into allegations of misconduct in a team of police officers working at Charing Cross Police Station who policed the West End of London on permanent night duty. The IOPC received evidence from police officers of how difficult policing the area was - the atmosphere was tense, many members of the public were highly intoxicated, and aggression and violence were commonplace. The evidence demonstrated that this was extremely stressful, and could lead to a ‘them and us’ environment. College of Policing guidance recognises that particular roles within policing carry a greater risk of exposure to stress and trauma and suggests a number of risk management measures for forces, including that, “Resilience can become depleted with time, with the need for consideration being given to introducing job rotation and tenure for particularly demanding roles”.[1] Ensuring the necessary risk management measures are in place will provide support for officers, adding to their resilience and reducing levels of stress.
 

Do you accept the recommendation?

Yes

Accepted action:

The Metropolitan Police Service (“MPS”) has reviewed and accepts this recommendation by the IOPC.

The health and wellbeing of people is one of the five priority areas for the Commander of Central West Basic Command Unit. There is a dedicated Chief Inspector (Westminster Neighbourhood Policing Team) leading the wellbeing pillar of their people strategy. Wellbeing days are held with Charing Cross Officers and Occupational Health Services are on hand.

In respect of Leicester Square, the MPS would like to point out that this specific team no longer works permanent night duty, but rather performs a range of early, late and night shifts. This reduces risks around permanent work in a night-time economy environment. The stresses and demands are challenging, but these are largely consistent with those in other areas of response policing in Westminster. Within Central West Command Unit they have introduced a Welfare Support Team, a Trauma Incident Management (TRIM) processes is in place, a robust review of Operation Hampshire (response to injuries to officers on duty) and a weekly governance processto review cross-strand resourcing for the West End.

The MPS Senior Lead for Occupational Health and Wellbeing has, in liaison with the Chief Inspector Neighbourhoods for Central West Basic Command Unit, commenced a role related risk assessment against identified Front Line Policing roles to assess the psychological risk and requirements for psychological monitoring/additional support. This does not, however, include the roles already on our psychological monitoring programme.
 

The IOPC recommends that the MPS should assure itself that sufficient steps have been taken to ensure appropriate supervision and welfare is in place to prevent officers becoming isolated through their duties.

This follows an investigation into allegations of misconduct in a team of police officers working at Charing Cross Police Station who policed the West End of London on permanent night duty. Although other teams were on rotating night shift duty with them, the permanent team operated in isolation, preferring to receive briefings, and take breaks in a room separate from others. The team is understood to have rarely seen colleagues above the rank of sergeant. Being isolated from wider police teams and the lack of adequate supervision may have created a sense that the isolated team were not subject to the same standards and scrutiny, allowing for conduct issues to become more widespread and unchallenged.
 

Do you accept the recommendation?

Yes

Accepted action:

The Metropolitan Police Service (“MPS”) has reviewed and accepts this recommendation by the IOPC.

The MPS agree with the spirit of this recommendation. Improving our effective management and the visibility of middle to senior managers in general is being progressed by MPS Learning and Development.

Our organisational design works on a principle of supervisory ratios. Over the last couple of years, as part of the Growing the Met Programme, we recognised that in some areas our supervisory ratios were becoming too large to effectively manage the number of new recruits. We have already added supervisors to frontline policing to create an additional 84 posts. We have reviewed supervisory ratios across the MPS and are awaiting Management Board decision for an agreement for an officer uplift to increase supervision as part of the MPS Year 3 Growth Uplift. It is anticipated this will be completed by March 31st 2023.

Over the past couple of years we have significantly invested in leadership training to improve our supervision and support to officers. This includes the ‘Leading for London Programme’, an NCALT (online) Training package on ‘Inclusive Leadership’, Health and Safety Leadership Excellence Courses which are now mandatory for ranks from sergeant to chief superintendent, the ‘Leadership Framework’ underpinned by practical ‘toolkits’ and ‘Time to Talk’ campaign.

We would also like to highlight changes in hand with our new ‘Blended Working’ policy. This reflects opportunities identified from policing through COVID, our Estates Strategy, enhanced digital capabilities and achieving the right work-life balance. The policy places emphasis on the role of supervisors; ‘visibility and accessibility’ of our leaders plays a key part in the efficient and operationally effective running of the MPS with a requirement for supervisors to spend an agreed and reasonable proportion the bulk of their time working flexibly across buildings in their Basic Command Units or Operational Command Units.
 

The IOPC recommends that the MPS should take steps to ensure there is effective supervision and quality assurance in place for officers where there is little measurable work output to review, to ensure the maintenance of policing standards and officers’ well-being.

This follows an investigation into allegations of misconduct in a team of police officers working at Charing Cross Police Station who policed the West End of London on permanent night duty. The team is understood to have rarely seen colleagues above the rank of sergeant. There were two sergeants per team, which was made up of approximately 20 police officers. There was one police inspector responsible for six such teams. Further, given the nature of the police officers’ work, there was no way of monitoring their work other than going out with them, or phoning them on their radio, which was rarely done. The lack of adequate supervision may have allowed conduct issues to become more widespread and unchallenged.
 

Do you accept the recommendation?

Yes

Accepted action:

The Metropolitan Police Service (“MPS”) has reviewed and accepts this recommendation by the IOPC.

The MPS has clear structures and processes for effective supervision. Supervision ratios are dependent on the roles of teams, and a lower ratio is used where teams are assessed to be managing more risk that requires more supervisor oversight and decision-making.

This was strengthened by the ‘Leading for London’ programme delivered in 2018 - 2019 to ensure all our officers and staff, from first line managers to Management Board, understand the importance of good leadership and to provide quality training to improve our leadership skills and capabilities. The more recent ‘Inclusive Leadership’ programme builds upon this.

On a local level, the BCU’s hold supervisor training days, where leadership values, positive culture and behaviour are discussed. In addition, the MPS has invested in Professionalism and Standards Chief Inspectors now posted to each Basic Command Unit (BCU) to improve ethics and standards of behaviour (see above). Presently, all staff and officers are expected to complete a performance review once a year, however, going forward there will be an expectation that line managers will have more regular conversations and record this. 
Specifically in relation to Central West BCU (Charing Cross Police Station), there are now: 
• Five dedicated inspectors leading the West End Team. 
• One chief inspector, providing leadership dedicated to the West End area. 
• A performance framework being developed to monitor officer output and outcomes regarding crime and anti-social behaviour in the West End. 
• Weekly West End Resource and tasking meetings against priorities, chaired by the Superintendent Neighbourhoods. 
• Each new officer joining Central West BCU is personally hand delivered a letter of expectations regarding high standards expected of them. West End Officers productivity is monitored by the Neighbourhood Superintendent with key performance indicators including, but not limited to, stops and searches, arrests, etc.

The MPS currently has 19 Town Centre Teams (“TCT”) across the 12 Basic Command Units (BCUs).

Each TCT provides monthly data on performance/work output for review. For example, arrests, stop and search, weapons/drugs seized and inclusive of proactive initiatives such as partnership policing, ‘trust and confidence’ activities, crime reduction and positive activity initiatives (PIAs) are all monitored.

Each officer has a clear set of personal objectives recorded within the PDR (Personal Development Review) process which should include;

• Contribution to MPS violence suppression and Violence Against Women and Girls strategy (VAWG).

• Contribution to the MPS Direction objective of detection of crime that results in demand reduction in the town centre area.

• Contribution to improving confidence, trust and legitimacy and personal development objective that links to the values of the MPS; Integrity, Professionalism, Courage and Compassion.

These objectives are agreed and managed by sergeants and inspectors and reviewed quarterly.
 

The IOPC recommends that the MPS should review current guidance and policy in relation to acting up to ensure there is transparency and clarity on how acting up positions are decided. The guidance should ensure that decisions for officers acting up are recorded, and there is an appropriate balance between short-term business needs and its commitment to equality and diversity.

This follows an investigation into allegations of misconduct in a team of police officers working at Charing Cross Police Station. During the course of the investigation, investigators noted a particular issue with perceptions about the fairness and transparency of how ‘acting up’ opportunities were decided and the impact on the rest of the team in terms of being supervised effectively and on those who felt overlooked. A lack of understanding about the process for acting up and transparency surrounding those opportunities, including documented rationales, can also create concerns around equality of opportunity. 
 

Do you accept the recommendation?

Yes

Accepted action:

The Metropolitan Police Service (“MPS”) has reviewed and accepts this recommendation by the IOPC.

The MPS policy on ‘acting up’ is set out in on the MPS internal website under Knowledge Management Section of “MyHR”.

‘Acting up’ is a non-pensionable allowance available to those ‘acting up’ to work at a higher ranked role to manage a short-term vacancy of up to 56 days.

For longer vacancies, temporary promotion should be used. The MPS policy is that officers that have completed the Objective Structured Performance Related Examination (OSPRE) / NPPF Legal Knowledge Exam will, in most circumstances, be given priority over non-qualified officers.

The MPS will be reviewing guidance (to make expectations clearer for leaders) and compliance locally to assure ourselves this is being interpreted and implemented consistently as per the policy intent.

We have recently introduced Career Development Leads (Chief Inspectors) on BCUs who are leading work to ensure we have a transparent and consistent process to identify officers for acting up opportunities. Currently this is being trialled in East Area, North East, Central North and South Area, although Front Line HQ Superintendents took part in a survey to understand disparity in approach in autumn 2021 and have since been briefed on the trial process. There is a strong desire to implement a structured process across all BCUs and Specialist Crime once evaluated.

The pilot process is designed to prepare applicants for substantive promotion processes through an online evidenced based competency and values application, and creates a select list which allows the HQ Superintendent to hold responsibility as a single point of contact for all acting promotion. Moderation and selection is overseen by internal engagement groups for transparency.