Unions and legal representatives have raised concerns about their fairness and validity when trying to ensure due process.
1) Who will gather the statements - how can their neutrality be ensured and what skill set will they have in order not to influence the statement whilst also ensuring information is specific to the registrant and not about a team or cultural issue?
2) At what point will the statements be introduced - once a case is proven and before sanctioning or as part of the evidence presented?
3) At what point will the registrant get to see the statement and make their own comments? Will these comments be seen as "lack of insight" or "blaming others" as happens sometimes in current cases.
It is an interesting concept but will take some very careful planning with clear guidance and a lot more consultation

