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Police Conduct and Code of Ethics Complaints against Jane Palmer Collar number 4364

Chief Finance Officer and Chief Accountant engaged with North Yorkshire Police and based at
their Newby Wiske HQ.
Made by: Neil Wilby on 9th March 2016.

1. Events giving rise to the complaint and short chronology

a. I am a justice campaigner and accredited investigative journalist.
b. I am presently involved in public interest reporting on the conduct and financing
of two police investigations: Operation Rome and Operation Hyson.
c. It had already led to the publication of four articles. All of which have been
damaging to the already tarnished reputation of North Yorkshire Police (NYP).
Operations Rome and Hyson are characterised by deceit and subterfuge. The
details of such are set out in the articles referred to above. A huge and
disproportionate amount of public funds is being wasted as a result.
d. Ms Palmer is one of the NYP officers with whom I have been dealing in the
course of my investigative work. My first contact with her was in August, 2015
during the period when the police accounts were open to inspection. I found her
knowledgeable and helpful.
e. The Force Solicitor, Jane Wintermeyer, is another senior officer with whom I
have had dealings. She is already the subject of complaint in similar terms to
this one against Ms Palmer. That complaint is presently the subject of a second
appeal to the IPCC. The first was upheld.
f. It is my submission that Ms Palmer and Ms Wintermeyer are acting in joint
enterprise in seeking to suppress information that assists my reporting.
g. It is also more likely than not that they are being encouraged to breach the
Code of Ethics by the Chief Constable, on the premise that they will be immune
from meaningful sanctions.
h. The Chief Constable is the subject of a separate, but connected, complaint
arising mainly from false submissions he caused to be made to Leeds High
Court in connection with Operation Hyson on 26th June, 2015.
i. During the inspection of the accounts referred to at para d. I secured the
release of lawyers invoices relating to Op Hyson.
j. At the time I was focused on the invoice totals rather than the details contained
therein. I did not open three pdfs relating to the lawyers costs that were
embedded in a Word document, along with a large amount of other information.
k. In the event, the embedded pdfs were incapable of being opened. It is a known
Microsoft technical issue, seemingly.
l. On 12th February, 2016 I requested from Ms Palmer freestanding pdfs that
were capable of being opened. These were sent to me on the 18th.
m. It was apparent upon opening the pdfs that the information was incomplete. I
requested the missing information by return email on 18th February. That email
and two subsequent polite reminders have been ignored. The last of those was
on 3rd March, 2016.

n. The issues raised by my request are uncomplicated, and the materials

requested by way of disclosure should be very readily accessible in a well-run
public authority.
o. In any event, the invoices for which I require the complete information are
already mentioned in the force Freedom of Information Disclosure Log.
However, deliberately or otherwise, these are not capable of being opened and
examined, either.
p. Ms Palmer (and indeed Ms Wintermeyer and the Chief Constable) are aware of
the significance of the information I seek - and the impact it will have on
undermining what has been publicly stated about Op Hyson. That is the
motivation behind non-disclosure and the preparedness of Ms Palmer to breach
the Code of Ethics and, furthermore, to operate outside of her own professional
regulatory framework.
q. This complaint is not personalised. Indeed, it is made with some reluctance. Ms
Palmer has been notably helpful in the past. However, it addresses the
unprofessional and unethical behaviour of an officer acting in a very senior role
in the office of the Chief Constable. As stated above: very likely, in concert with
the Chief Constable and other high ranking officers, including Ms Wintermeyer.

2. Grounds for complaint

a. All police officers and staff are required to comply in all respects with the
College Of Policing Code of Ethics. Section 5 deals in detail with the
responsibilities of individual officers and police forces and the consequences of
breaches of the Code.
b. In this complaint, matters are aggravated by the fact that the officer complained
about is of very senior managerial rank.
c. Matters are further aggravated by the fact that every email sent out from North
Yorkshire Police carries the slogan Committed to the Code of Ethics.
d. At this point it is worth recording that I have yet to come across any officer in
North Yorkshire Police civilian or warranted whose conduct would bear
scrutiny when set against the Code of Ethics. It is a force with an appalling
culture that, I am afraid to say, cascades down from the top of the organisation.
e. In all my dealings with North Yorkshire Police there is this ever-present,
troubling and unethical lack of candour (and indeed a willingness to relentlessly
flout the law in the case of information requests): Ms Palmers recent conduct
towards me epitomises that very well. It is not acceptable, or indeed lawful, to
deny access to financial information simply because its disclosure causes the
police force embarrassment and/or loss of reputation.
f. This complaint alleges the following breaches of the Code of Ethics
Authority Respect and Courtesy It is self evident that Ms Palmer has not
treated me with either respect or courtesy. She has failed to acknowledge or
respond to three emails. She has not carried out her policing role in an efficient,
diligent or professional manner. I am a journalist trying to do my job and I am
entitled to be treated with the ordinary courtesies a member of the public might
expect from an employee of the police service. Ms Palmer is also indulging

herself in oppressive behaviour that is capable of interpretation as a form of

harassment and will, most certainly, bring damage to her own reputation and
that of the police force that engages her, as a result. I reserve all rights
available to me under the Protection from Harassment Act, 1997 in this regard.
Duties and Responsibilities All officers in senior roles are critical role models
in embedding the Code of Ethics. If a leader has Chief Officer in their job title
then it is incumbent upon them to set the highest standards of ethical
behaviour. Ms Palmer has self-evidently fallen well short of those standards
and, worse still, seems intent on continuing to do so. This complaint will be
publicised on the internet and via social media and it will be clear to any or all of
Ms Palmers departmental colleagues reading it that the Code of Ethics is
utterly meaningless as far as their leader is concerned. I am alert to the fact that
they may, of course, know that already. More specifically, Ms Palmer has failed
to take responsibility for her actions (or inactions) and has failed to explain or
justify her failure to provide the requested information. Or explain her
unconscious and stereotypical bias towards me as a journalist.

Honesty and Integrity By seeking to deliberately conceal information, that

should be properly and lawfully disclosed, Ms Palmer compromises not only her
integrity, but her professional standing as a Chartered Accountant.

3. Requested Outcome
a. Ms Palmer to receive a final written warning as to her future conduct.
b. A written, sincere apology to be given to me.
c. The information that I have requested from Ms Palmer, and to which I am fully
entitled (the Weightmans invoices in their entirety), to be provided without
further delay.
d. The matter of this complaint, together with that against Ms Wintermeyer and the
Chief Constable, be referred to the College of Policing so that all three can
undergo intensive training on Code of Ethics principles and practice. Such
training to be undertaken in their own leave time and not, in any way, at the
publics expense.