What lessons can employers learn from the final Sue Gray report?

In January 2022, I wrote an article about the lessons of general application for employers which could be learnt from UK senior civil servant Sue Gray’s interim report on ‘partygate’ — the name given to the lockdown-breaking parties in and around Downing Street. I suggested that we would have to wait just a few more weeks before the full report was published. A few weeks inevitably turned into a few months, but now that we have finally had sight of the full report — and beyond the anger that many will feel at the findings — there remain plenty of take-aways for business leaders.

First is the importance of leading by example: “senior leadership … must bear responsibility for [the] culture”.

It is clear from the report that some junior staff felt that going to, and remaining at, rule-breaking parties was acceptable because senior leaders were also in attendance. Whatever the size of an organisation, culture and core values flow from the top down — and a positive culture is absolutely essential to the effective operation of any business.

The way in which leaders conduct themselves is visible to all and it is vital that managers lead by example — not just in what they say, but also in how they conduct themselves in the workplace and beyond. Determining disciplinary sanctions is beyond the remit of her investigation, but Ms Gray does state that she hopes the fact that the conduct of juniors was sanctioned by senior leaders will be taken into account in considering disciplinary action.

Second is the importance of transparent leadership structures in embedding a speak-up culture: “…some staff had witnessed, or been subjected to, behaviours at work which they had felt concerned about, but at times felt unable to raise properly”.

Ms Gray notes that since publication of her interim report, steps have been taken to introduce more easily accessible ways of raising concerns — electronically, in person or online. She also expresses hope that this will embed a “culture that welcomes and creates opportunities for challenge and speaking up at all levels”.

Leaders must foster a culture in which staff feel able — and indeed encouraged and supported — to speak out about perceived misconduct. A clear and robust whistleblowing policy is necessary, but not sufficient.

The report also comments on the “fragmentary and complicated leadership structures in No 10”.

Reporting lines, both formal and informal, should be crystal clear and well-communicated — and staff should know that there are different ways in which reports can be made.

Staff should be trained on relevant processes and a zero-tolerance approach to retaliation should be communicated, enforced and well known within the organisation. Flagging issues promptly should be seen and openly discussed as a positive step, rather than a litigation risk, and managers should lead by example on this, flagging issues where they spot them and acknowledging their own mistakes.

Third is the importance of respect in the workplace: “I was made aware of multiple examples of a lack of respect and poor treatment of security and cleaning staff”.

This was one of the most striking areas of the conclusions, which was not clear from the interim report, and is another area in which leading by example is absolutely vital. Leaders must demonstrate and encourage a culture in which all staff, irrespective of seniority or capability, are treated kindly and with respect. This does not, of course, mean that difficult messages cannot be delivered — nor that performance issues cannot be managed — but care should be taken to deliver messages appropriately.

Fourth is the cultural, behavioural and reputational risks of excessive alcohol consumption.

Many of the press reports following publication of the report focused on stories of excessive drinking, spilt drinks and late-night vomiting. Social engagement is key to building a positive culture — and has been sorely missed by many businesses over the past two years.

However, socialising need not involve excessive alcohol consumption, which often leads to inappropriate behaviour which may not have happened had staff been sober. Policies should clearly set out an employer’s approach to consumption of alcohol in the workplace and at work events beyond the physical office.

As with a whistleblowing policy, this policy must be well communicated and well known within the organisation. It should include clear guidance on what will and will not be paid for by the employer, and should signpost available support for staff who may have an issue with alcohol or substance abuse. Again, leadership is vital here — attitudes to workplace alcohol consumption flow from the top down.

The political ramifications of partygate may not yet be fully clear, but responsible leaders should certainly start acting on the key learnings.

Beth Hale is partner at law firm CM Murray.