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Post Office Ltd - SECURITY POLICY
[Theft and Fraud by Sub Office Assistants]
Document Information
Title Theft and Fraud by Sub Office Assistants
Category Standard
Subject Fraud
Version Control 1.0
Author Derek Pratt, Internal Crime Policy Manager
Owner Head of Security & Audit, Post Office Ltd.
Purpose To define the responsibilities of Sub Postmasters and the
accountabilities of Post Office Ltd. in respect of theft and
fraud by Sub Office assistants
Audience Sub Postmasters
Retail Line
Security & Audit staff
National Federation of Subpostmasters
Keywords
Privacy level National Federation of Subpostmasters
Retail Line
Security & Audit staff
Sub Postmasters
Document format _I Arial 12
Document type Electronic (MS Word. Doc) , Paper,
Review date Annual
Expiry date Ongoing subject to review
Assurance Phil Gerrish Jan 2002
Authorised Head of Security and Audit, Post Office Ltd Feb 2002
Version control
Version 1.0/ New Standard Feb 2002
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Theft and Fraud by Sub Office Assistants
Purpose
© To define the responsibilities of Sub Postmasters and the accountabilities of
Post Office Ltd. in respect of theft and fraud by Sub Office assistants
Methodology
© Developed to meet Post Office Ltd Security Policies
¢ Consultation with
¢ The original draft was reviewed by the Head of Investigations and
authorised by the Head of Security and Audit following amendments
¢ The document was signed off by the Head of Security and Audit
Detailed Specification
¢ The policy outlines recommendations for Subpostmasters to apply during
the recruitment of Assistants and if subsequent dishonest activity is
suspected following their appointment. The policy also outlines the
financial accountability for losses incurred at an outlet in cases where
Assistants commit a fraud or theft. Equally it deals with exception criteria
(in certain circumstances where the matter is under inquiry by the
Investigation Team) and the appeals process
¢ Recommended ownership by Internal Crime Policy Manager
Guidance for Deployment
¢ Internal Crime Policy Manager
Enquiries
ime Policy Manager, Post Office Ltd. Security and
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THEFT AND FRAUD BY SUB OFFICE ASSISTANTS
Introduction
From a purely contractual perspective a Subpostmaster, or other agent, is
responsible for all losses caused through his or her own negligence,
carelessness or error. He/she is also responsible for all kinds of losses
caused by the action of any assistants, managers or relief Subpostmaster
employed by him/her.
Prevention
Naturally, the best way of minimising losses is to prevent them occurring in
the first place. There are ways in which any office’s vulnerability to theft or
fraud by assistants can be reduced.
e Employment of Assistants
The contractual position in this respect is clear; section 15 paragraph 1 & 2 of
the Subpostmaster’s contract states:
A Subpostmaster must provide, at his own expense, any assistance which
he may need to carry out the work in his sub office.
Assistants are employees of the Subpostmaster. A Subpostmaster will be
held wholly responsible for any failure on the part of his Assistants to apply
Post Office rules, or to provide a proper standard of service to the public.
He will also be required to make good any deficiency, of cash or stock,
which may result from his assistants’ actions.
Prior to employment of staff the Subpostmaster should take all reasonable
steps to ensure that their candidate is suitable in all respects for the position.
The Resourcing Guide for Subpostmasters is a useful source for advice on
the recruitment of assistants. The guide provides the Subpostmaster with in-
depth advice on how to recruit and train their assistants to ensure they have
staff with the right skills and attributes to work on a Post Office counter.
Once the Subpostmaster has chosen a new counter assistant, they must
ensure they are registered with The Post Office via The Human Resources
Service Centre (HRSC) in Salford Quays. Each new member of staff should
sign an Official Secrets Act form and personal declaration, which when
completed will be processed by the HRSC who will instigate a security check
and feedback the results to the Subpostmaster.
The Subpostmaster should take all reasonable steps to ensure that staff in
his/her employ are acting honestly and to minimise the opportunities for them
to act otherwise. If the office is experiencing shortages and dishonesty is
suspected, the Subpostmaster should be prepared to undertake whatever
checks are necessary to pinpoint where the problem lies.
Business Policy
Subpostmasters are contractually responsible for all losses at their office,
including those due to the actions of their assistants. In the case of proven
fraud or theft by an assistant, Post Office Ltd. may require a contribution of up
to 100% of the loss from the Subpostmaster, dependant on the
circumstances of the case.
Such cases will be judged on their merits and RLMs will consider the full facts
of each case, including comments from the Subpostmaster, in coming to a
decision on the level of contribution required. The general principle of a
separation between the culpability decision and the decision on contribution
will be followed, as in the robbery/burglary process. A major factor to be
considered is the extent to which the Subpostmaster was in effective control
of his office and his staff, and whether he had taken all reasonable steps to
implement good security practice.
If the Subpostmaster is in a position where he is unable to make good the
loss because of financial hardship, consideration should be given to
repayment by instalments over a maximum 12 month period by deductions
from remuneration or, exceptionally, to writing off part of the loss. In
considering financial hardship in these cases, the capability of the agent to
obtain recovery from the assistant should be taken into account as a factor.
Account should also be taken of any Restitution Orders issued against the
assistant should the case come to court.
Appeal Process
The agent has the right of appeal against the RLM decision, either because of
the level of contribution required or the terms of the repayment. The appeal
will be heard by the Head of Area and can be conducted in person or in
writing. If the Subpostmaster chooses personal appeal, he has the right to be
represented by a representative of the National Federation of
Subpostmasters or a friend (who must be either a Subpostmaster or
employee of Post Office Ltd or a registered assistant)
The person hearing the appeal will take a view on whether the level of
contribution is reasonable, taking account of all the facts. They can take the
view that the level of contribution is too high or too low or that the terms of
repayment will cause unnecessary financial hardship and alter them
accordingly.
Investigations
The only exception to the foregoing is where the Subpostmaster has notified
his Retail Line Manager, Area Manager or Head of Area in writing of
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suspicions regarding the conduct of one or more assistants and has been
requested by a representative of the Post Office Ltd Security and Audit team
to defer taking his own action (e.g. to defer terminating one or all the
assistants’ employment with him) in order for further evidence to be gathered
in support of a criminal enquiry.
In such cases any losses incurred from the point at which the agent reported
the position and was requested to defer taking his own action, may be written
off and no recovery sought from the agent. Naturally, this dispensation would
only apply to losses due to the action of the assistant(s) involved and not to
losses that have some other cause.
The Security and Audit team representative with the relevant Head of Area (or
their representative) should ensure that any cases where the Subpostmaster
has been specifically requested not to take action are fully documented with
the Subpostmaster so that a clearly understood basis is available for future
loss recovery decisions.
Guidelines for dealing with requests from Subpostmasters to
investigate suspected thefts by Assistants.
1. Upon receiving such a request a representative of the Post Office Ltd
Security and Audit team will arrange to discuss the matter with the
Subpostmaster at a suitable location (preferably away from the sub
Office).
2. Details of the losses should be gathered and the agent asked if (s)he has
any evidence, or firm suspicion, as to the person responsible. If the agent
does not have any suspect in mind, (despite knowing and working
alongside the staff) it must be impressed upon them that it is unlikely that
the offender will be quickly identified.
3. As much advice as possible will be offered in order to isolate opportunities
for the offender to steal (e.g. keep coats and handbags away from the
counter, follow correct procedures regarding security of tills, and conduct
checks of vouchers prior to despatch).
4. The agent will be encouraged to attempt to identify the culprit (e.g. by
analysis of the losses by date and of staff having access).
5. Under the Human Rights Act, the use of covert cameras is strictly
regulated and requires special authorisation. Few circumstances of theft
of fraud will warrant such an installation although every case will be
reviewed on its merits. If an agent wishes to install his/her own covert
camera they may be able to obtain advice and support from the National
Federation of Subpostmasters but they are reminded of the implications
of such an act under the Human Rights Act.
6. The agent must be advised that (s)he remains fully responsible for
all losses and that this remains the case even if Post Office Ltd
agrees to take on an investigation. Losses incurred during the
course of an investigation still remain the responsibility of the agent,
even if it takes some time to identify the offender. (The only
circumstances in which losses may be written-off are those losses
1
1
incurred after the investigator has identified a suspect but requires the
person to continue working in order that more evidence may be obtained.)
Relief on losses is entirely a matter for the retail line once any
investigation has been finalised.
Where it is agreed that an investigation will be taken on the Security and
Audit team representative must be realistic with the agent concerning
workload and resources and ensure that the agent understands that such
enquiries may take some time to complete.
The agent must be advised that if an investigation is taken on, it will be
the intention to gain sufficient evidence to support a prosecution and that
(s)he will be expected to provide support for any prosecution, e.g. by
giving a witness statement.
It must be confirm that even if an investigation takes place, the agent still
has the right to dismiss any employee at any point.
0. If the agent wishes to report the matter to the Police for investigation,
he/she must be advised they may do so and that all suitable assistance
will be provided to the police by Post Office Ltd.
1. Any request for an investigation to be carried out should be put in writing
via the Retail Line Manager.
RECOMMENDED PREVENTATIVE MEASURES
1
. Office controls and procedures to prevent internal fraud/theft.
Maintain accurate attendance records (actual starting and finishing times),
including holidays and sick periods to identify staff involved when losses
occur.
Visitors to the secure area to be restricted and, where admitted, supervised
at all times. A visitors book should be maintained and signed by all
visitors.
Consider provision of “uniform” without pockets to minimise risk.
No serving of family/friends to be allowed and no staff “self-serving”.
Restrict counter cleaning to outside of opening times.
Where operationally possible, avoid leaving one member of staff on their
own.
Where counter drawers containing money are used, keep them locked
when not in use.
Restrict access to safe to subpostmaster only, if operationally possible, and
keep locked at all times.
All listed paid pensions and allowances to be checked, and signed, by
subpostmaster and then security sealed, e.g. in banknote envelopes, to
avoid docket tampering
Weekly paid voucher despatch to be controlled by subpostmaster in line
with above.
Subpostmaster to be second checker of all daily and weekly vouchers.
Errors found to be recorded and taken into account re individual staff
monitoring.
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2.
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Ensure that where any summaries, or listings, are double checked, the
identity of the checking officer can be readily identified by a signature as
well as a date stamp.
Daily cash on hand accurately recorded each night and reconciled with
ONCH return.
Subpostmaster to carry out regular spot checks of cash, stock and
vouchers, irrespective of balance result.
All handbags, coats, etc., to be kept away from the secure area where
possible, or, if no other area available, then away from counter drawer
area/back of chair.
Ensure staff are aware that it is Post Office policy to prosecute thieves.
Actions instigated by subpostmaster to identify dishonest staff.
If the office is showing consistent shortages and assistant dishonesty is
suspected, the following actions may be taken, as appropriate, by
subpostmasters.
Inform staff of level of losses and emphasise concerns, making staff aware
that subpostmaster is liable for all losses.
Make staff aware of possible implications of financial loss, e.g. regarding
their continued employment.
Inform staff that the losses are due to either inefficiency or dishonesty and
it will be the intention to introduce measures to resolve the problem.
Consider speaking to individual staff in order to elicit any suspicions
regarding losses.
Where possible, introduce individual balancing.
Complete surprise checks of individual’s dockets/cash/stock, as
appropriate.
Discreetly check the state of the balance, at suitable times, to establish
possible suspects.
Re-arrange attendance times of staff, if necessary.
Look for tell tale signs of changing lifestyles of staff, such as unusual
behaviour/ holidays/ new clothes/ living beyond means. Do not totally
dismiss gossip.
Consider installation of overt (visible) CCTV cameras with VCR recording
facility.
. Employment of Assistants.
References should be sought from previous employers for all new staff,
including from subpostmasters at previous offices if applicable.
Details of new staff should be supplied to Personnel Agency Recruitment
for completion of Personal Declaration P13/P250.
Personal contracts of employment should be issued to all staff.
Staff should be employed on reasonable rates of pay (seek advice from the
NFSP and take account of the national minimum wage).
e Trial periods and reports for new staff should be considered to ensure high
standards.
e Set targets and define standards expected from staff.
Other security measures.
Although not relevant to internal fraud, subpostmasters should always
practice correct security procedures as detailed in the “Counter Attack” and
“Personal Guide to Security” booklets. Examples of some of the most
important are:
e Opening / closing procedures
Cash / stock locked in safe when secure area left unattended.
ABS door kept closed.
Parcel hatch closed when not in use.
Time Overlock set to come off guard 15 minutes prior to opening.
Time delays used to maximum effect.
Safe door locked at all times. Key removed when not in use.
Office keys concealed at all times (e.g. behind counter drawer).
Cash at counter restricted to immediate operational needs (max. 1% hours
requirement).
e Time Delay Compartment, if installed, utilised to afford maximum security
to bulk cash.
e Remittances delivered via the parcel hatch and secured immediately upon
receipt, or as soon as time delay locks allow.
e At close of business, including lunch times, all cash/stock and vouchers
secured.
e Alarms tested and records maintained.
e Overnight cash holdings kept to a minimum.
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