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POSTMASTER SUPPORT
POLICIES
Postmaster Termination
Decision Review Policy
Version ~ V2.3
Post Office is determined to reset its relationship with postmasters and has introduced policies that set out guidelines on how
Post Office should support postmasters, specifically for use across twelve areas
The policies stand on their own but should be reviewed in conjunction with each other. Support teams should have an awareness
of all twelve policies and how they link together.
The twelve Postmaster Support Policies are listed in section 2.2 of this policy and can be found on the hub, here
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1. Overview .........
1.1. Introduction by the Policy Owner
1.2. Purpose
1.3. Core Principles ....
1.4. Application
1.5. The Risk.
2. Risk Appetite.
2.1. Risk Appetite .
2.2. Policy Framework
2.3. Who must comply?..............
2.4. Roles & Responsibilities
2.5. Minimum Control Standards
3. Procedure..............
3.1. Right of challenge
3.2. Decision review investigation.............
3.3. Decision................
3.4. Informing a postmaster of the decision
3.5. Decision review conclusion
3.6. Payment during the decision review process .............
4. Where to go for help
4.1. Additional Policies
4.2. How to raise a concern...
4.3. Who to contact for more information
5. Governance..
5.1. Governance Responsibilities .
6. Control...
6.1. Policy Version
6.2. Policy Approval & Review
Company Details
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1. Overview
1.1. Introduction by the Policy Owner
The Franchise Partnering Director has overall accountability to the Board of Directors for
the design and implementation of controls to manage risk in the network!. Risk in the
network is an agenda item for the Risk Committee and the Post Office? board is updated
as required.
This policy is a non-contractual document provided for information. It does not form part
of a contract between postmasters? and Post Office.
1.2. Purpose
This policy is part of a framework that has been established to set the minimum operating
policies relating to the management of contracts with postmasters (which may be
companies, sole traders or partnerships) throughout the network.
Post Office recognises that if a decision is taken to terminate a contract in the network
then the postmaster may not agree with the decision taken. The purpose of this policy is
to set out the procedures to be followed should a postmaster wish to challenge the decision
to terminate the agreement and to clarify who will be involved in the process.
This policy is one of a number of policies which provide a clear risk and governance
framework and an effective system of internal control for the management of risk across
the Group. Compliance with these policies supports the Group in meeting its business
objectives and to balance the needs of customers, shareholders, employees, other
stakeholders (such as the government departments) and third party commercial partners
including Royal Mail.
1.3. Core Principles
A challenge will be heard by a Review Panel who will have no prior involvement in the
circumstances which led up to the termination and the challenge being raised.
Post Office recognises that it should provide appropriate support to the postmaster during
the decision review process. In particular, the Review Panel should ensure that the
postmaster is kept up to date at all stages of the review.
Post Office will handle challenges to decision making in good faith and apply principles of
fairness, transparency, and professionalism (being the underpinning behaviours of Post
Office).
"In this policy, “network” means branches not directly managed by Post Office
2 In this policy, “Post Office” and “Group” means Post Office Limited
2 In this policy, “postmaster” refers to the person or entity (which may be a company, sole trader or partnership) contracted with
Post Office and any person acting on the postmaster’s behalf.
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1.4. Application
This policy is applicable to all postmaster contracts? in the network.
1.5. The Risk
Post Office has an obligation to:
e ensure that any decisions taken in respect of a postmaster contract are not
exercised arbitrarily, capriciously or unreasonably;
e exercise any contractual power honestly and in good faith for the purpose for which
it was conferred on Post Office; and
* exercise any discretion in accordance with the obligations of good faith, fair
dealing, transparency, co-operation and trust and confidence.
Post Office is not able to terminate the agreement without reasonable and proper cause.
If Post Office itself has not complied with its own obligations, relating to the matters that
led to the termination decision, Post Office is not able to terminate the agreement.
Post Office may only terminate the agreement:
° if there has been a repudiatory breach (a breach so serious and fundamental to the
contract that it cannot continue) or
. there is a termination right which applies to the relevant issues.
If a postmaster believes Post Office is not entitled to terminate the agreement, it is
important that there is a process by which to challenge the decision. Failure to have a
decision review process presents risks, including the risk of financial loss through any
claims made by the postmaster as well as reputational damage.
Additional risks include:
« If Post Office does not fully understand and investigate challenges to its
termination decision-making, it loses the opportunity to consider the valuable
opinions of its postmasters. Additional information may be available which may
have influenced the decision had it been available at the time. This process will
also provide Post Office a valuable opportunity to audit decisions taken by the
Contracts Team to ensure that the principles in the Postmaster Contractual
Performance, Postmaster Suspension and Postmaster Termination policies are
being adequately deployed; and
e If Post Office does not provide a suitable channel for a challenge to be heard,
postmasters may not share their or their staff’s concerns, causing discontent and
resentment within the network.
Risks of Post Office conducting an inadequate process include:
e If a challenge is not heard within reasonable timescales, Post Office may be
perceived as failing to act in good faith; and
* In this policy, “postmaster contract’ means contracts which relate to those branches not directly managed by Post Office
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e If Post Office are not transparent in relation to its performance against SLAs
applicable to the process, postmasters and stakeholders may have reduced
confidence in Post Office’s ability to effectively manage postmaster contracts.
Section 2.5 sets out the minimum control standards that the Post Office has implemented
to control these risks.
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2. Risk Appetite
2.1. Risk Appetite
Risk appetite is the extent to which the Post Office will accept that a risk might happen in
pursuit of day-to-day business transactions. It therefore defines the boundaries of activity
and levels of exposure that Post Office is willing and able to tolerate.
Post Office takes its legal and regulatory responsibilities seriously and consequently has:
« Averse risk appetite to corporate non-compliance with legal and statutory
obligations.
« Averse risk appetite for financial crime to occur within any part of the
organisation.
« Averse risk appetite in relation to unethical behaviour by Post Office staff.
« Averse risk appetite for litigation.
e Cautious risk appetite for inefficient or ineffective processes that result in: lost
time, duplicated effort, and increased risk of financial loss or errors in any part of
its business or core processes
Post Office acknowledges, however, that in certain scenarios, even after extensive controls
have been implemented, a process may still sit outside the agreed Risk Appetite. In this
situation, a risk exception waiver will be required pursuant to the Exemption Process
details of which can be found here.
2.2. Policy Framework
This policy is part of a framework of postmaster support policies that has been established
to set the minimum operating policies relating to the management of our postmaster
contract risks throughout the business in line with Post Office’s risk appetite. The
framework includes the following policies:
e Postmaster Onboarding
e Postmaster Training
e Postmaster Complaint Handling
« Network Monitoring and Audit Support
« Network Cash and Stock Management
¢ Network Transaction Corrections
e Postmaster Account Support
e Postmaster Accounting Dispute Resolution
« Postmaster Contract Performance
« Postmaster Contract Suspension
« Postmaster Contract Termination
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2.3.
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e Postmaster Termination Decision Review (this policy)
Who must comply?
Compliance with this policy is mandatory for all Post Office employees®> who manage
postmaster contracts on behalf of Post Office, including members of the Review Panel.
Where non-compliance with this policy by Post Office employees is identified by Post Office,
Post Office will carry out an investigation. Where it is identified that an instance of non-
compliance is caused through wilful disregard or negligence, this will be investigated in
accordance with the Group Investigations Policy.
2.4.
Roles & Responsibilities
Franchise Partnering Director — is the policy owner, who must comply with the
governance responsibilities set out at section 5.1.
Contract Investigation and Resolution Manager- is accountable for the
deployment of this policy, for supporting Post Office personnel who carry out
actions under this policy and for regularly reviewing the effectiveness of this policy
and for drafting any amendments to it that may be required.
Contract Advisor(s) - is (are) responsible for deploying the procedures set out
in this policy. The Contract Advisor(s) form part of the Contracts Team.
Review Panel - A panel, consisting of independent, external members, who are
responsible for deploying the procedures set out in this policy and for making a
final decision on the review requested by the postmaster. The Review Panel will
be supported by the Contract Investigation & Resolution Manager to:
o apply Post Office’s underpinning behaviours of fairness, transparency, and
professionalism;
o be fully conversant with this policy and linked policies;
o gather as much information as possible relating to the background behind
the termination;
o complete a Termination Decision Review Rationale Document before making
a decision in consequence of a challenge. The rationale document is a report
which includes facts and findings of the investigation, and the rationale used
to determine the outcome;
© ensure any decision arising from a challenge is made in line with all other
Post Office policies set out at section 2.2;
© ensure this policy is adhered to and the postmaster is treated with fairness,
transparency and professionalism throughout the process;
5 In this policy, “employee” means permanent staff, temporary including agency staff, contractors, consultants and anyone else
working for or on behalf of Post Office and, for clarity, does not include postmasters or postmasters’ staff
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o make the postmaster aware of any support available to them, including from
the National Federation of Sub Postmasters;
o deal with any contact, written or otherwise, from the postmaster, in a timely
manner; and
o if a meeting is required, be flexible, within reason, over the availability of the
postmaster.
National Federation of Sub Postmasters (NFSP) - is a professional trade
association which exists to support postmasters.
Postmaster - this refers to a limited company, partnership, limited liability
partnership or individual that contracts with the Post Office in its or their capacity
as a postmaster in the network, or (as applicable) assistants of such postmasters.
In relation to this policy, the postmaster is expected to:
o be transparent and open towards Post Office;
o ensure they respond to written correspondence and telephone calls in a
timely manner in order to assist the Review Panel in reaching a decision;
o be flexible and available for meetings with the Review Panel if one is
required.
In relation to this policy, the postmaster may:
o contact their NFSP representative to support them through the process;
o request information and evidence from Post Office in connection with this
process and wider investigation;
o arrange legal or other representation for any written correspondence or
meetings with Post Office;
o contact their nominated Contract Advisor at any time regarding potential or
actual termination
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2.5. Minimum Control Standards
A minimum control standard is an activity which must be in place in order to manage the risks, so they remain within the defined Risk
Appetite statements (as set out at section 2.1). There must be mechanisms in place within each business unit to demonstrate
compliance. The minimum control standards can cover a range of control types, i.e. directive, detective, corrective and preventive which
are required to ensure risks are managed to an acceptable level and within the defined Risk Appetite.
The table below sets out the relationships between identified risks and the required minimum control standards in consideration of Post
Office’s Risk Appetite.
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Risk Area Description of Risk Minimum Control Standards Who is When
responsible
Investigation If challenges to the decision The decision review process and associated Contract Quarterly
and resolution I to terminate are not fully documents will be reviewed. Investigation &
of an appeal investigated, any potential Resolution
issues in the decision-making Manager
process in the Contracts
Team may not be addressed Quality checks and training covering the Contract As required
and the same issues could decision review process will take place with _I Investigation &
recur. This could mean that all members of the Review Panel to ensure Resolution
Post Office are not acting in that the correct process is followed. Manager
good faith and upholding the
principles as set out in the
Postmaster Contractual The Franchise Partnering Director will review I Franchise Quarterly
Performance, Postmaster decision review outcomes to ensure Partnering
Suspension and Postmaster consistency of decision making. Director
Termination policies.
Postmaster If postmasters do not have a_ I The right for postmasters to challenge a Contract Six monthly
ease of raising I straightforward way to termination decision with be clearly Investigation &
a challenge challenge a termination signposted to postmasters in any Resolution
decision taken by the correspondence notifying the postmaster of Manager
Contracts Team, systemic
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issues in the decision-making I termination. This correspondence will be
process may not come to reviewed at regular intervals.
light and remain unresolved.
Reporting If Post Office is not The following data related to challenges will I Contract Monthly
transparent with its be maintained and updated: volumes of I Investigation &
performance against SLAs challenges, performance against SLAs, reason I Resolution
relevant to the decision for challenge and outcome. Manager
review process, postmasters
and stakeholders have
reduced confidence in Post
Office’s ability to effectively
manage challenges to
termination decisions.
Policy non- Non adherence to the policy I The Review Panel, Contracts Team and any __I Contract Once approved and
adherence could result in legal and teams who are involved with the decision Investigation & I annually thereafter
regulatory risk as well as review process will be provided with training I Resolution (or sooner in the
reputational damage to Post on this policy. Manager event of material
Office and the relationship changes to the
with postmasters. policy)
The Policy should be reviewed, and if Contract As required (but
necessary updated. Investigation & I reviewed at least
Resolution annually)
Manager
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3. Procedure
3.1. Right of challenge
Post Office can, in certain circumstances, terminate a postmaster contract:
e immediately if there has been a repudiatory breach or if Post Office has a right to
terminate immediately on notice under the agreement; and
e by giving a period of notice.
Where Post Office has a right to terminate under the agreement (in all cases except where
a repudiatory breach has been committed), Post Office can only exercise the right where
the following conditions are met:
« Post Office itself is not in material breach in relation to the matters relevant to the
reason for termination. This is explained in more detail in section 4.11 of the
Postmaster Contract Termination Policy®;
e Post Office has reasonable and proper cause to terminate; and
e Post Office has knowledge of and has considered the applicable facts, so as not to
act arbitrarily, irrationally and capriciously.
Additionally, where Post Office seeks to exercise its right to terminate for convenience
under the Agreement, it must consider what the appropriate duration of the notice period
should be in the individual circumstances.
Post Office recognises that if a decision is taken to terminate a postmaster agreement and
the above conditions have not been met then there should be a process by which this
decision can be challenged.
As set out at section 4.13 of the Postmaster Contract Termination Policy, the Contract
Advisor should explain when informing the postmaster of the termination of the contract:
« The reason(s) for the termination, including the factual circumstances and
contractual basis;
e That the contract is being terminated in accordance with the contract and Post
Office's termination policy, of which a copy can be made available on request; and
e That an investigation into the circumstances giving rise to the right to terminate
has been carried out and that the information and records relating to the
investigation have been/will be made available.
The right of challenge and actions required will be set out in the formal notification of
termination. The postmaster will be given the option of submitting a challenge in writing
setting out the grounds for challenge (i.e. a description of the reasons for believing that
Post Office’s grounds to terminate the agreement are non-compliant with the termination
provisions set out in the agreement with Post Office). Any challenge should be submitted
® The Postmaster Contract Termination policy can be found on the hub, here.
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within fourteen days of the date of termination notice and be addressed to the Contract
Advisor who issued the termination letter.
On receipt of a written request a review will be undertaken by the Contract Investigation
& Resolution Manager to:
e Check the grounds for challenge and why it is believed that Post Office is not
entitled to terminate the contract; and
« Ensure the case papers received from the Contract Advisor are complete and, if
not, to return any incomplete files to the Contract Advisor for the Contract Advisor
to complete or explain why the papers/documents are missing;
The case will then be allocated to the Review Panel within two working days.
If a challenge is not received within fourteen days of the termination notice being issued
the agreement will terminate in accordance with the termination notice.
3.2. Decision review investigation
It is the role of the Review Panel is to ascertain whether the decision to terminate was
taken in compliance with the relevant contract and requirements set out in section 3.1
Any investigation must be a fair and unbiased method of investigating the issues raised in
the challenge. The process of investigation allows the Review Panel to establish facts
relating to the issues raised and gives the postmaster the opportunity to identify and
answer any points or queries raised by the Review Panel. The Review Panel may have to
undertake further enquiries as a result of new and/or additional information provided as
part of the decision review process.
In the investigation process, the Review Panel may seek further information from the
postmaster through written correspondence, telephone conversation(s) or face to face
meetings. The Review Panel must ensure that complete records are kept of all material
information and communications related to the investigation. Such records will be retained
in accordance with Post Office's document retention policy.
Details of the investigation and the relevant supporting records and information will be
shared with the postmaster unless the material is subject to a restriction on disclosure
such as:
¢ legal privilege;
¢ data protection law; and
material relating to a criminal investigation.
3.3. Decision
It is up to the Review Panel to establish whether Post Office had the right to terminate the
contract, whether the decision to do so was taken consistently with the obligation of good
faith, and whether the decision was taken in compliance with the termination provisions
set out in the relevant agreement with Post Office.
Following completion of the review, the options open to the Review Panel are as follows:
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e uphold the decision to terminate the postmaster contract; or
e uphold the decision to terminate the postmaster contract but if the decision was to
terminate immediately change the decision to terminate on notice and confirm the
notice period (as defined in 4.12 of the Postmaster Contract Termination Policy);
or
« overturn the decision to terminate the postmaster contract, end the suspension
period (if suspended) and reinstate the postmaster contract subject to conditions
(if applicable).
The Review Panel must complete the Termination Decision Review Rationale Document to
capture the details of the investigation undertaken and the rationale behind the final
decision.
The Termination Decision Review Rationale Document will also set out any learning points
or improvement opportunities identified by the Review Panel during their investigation.
These findings will be shared with, and acted on by, the Franchise Partnering Director.
3.4. Informing a postmaster of the decision
The postmaster will be informed of the outcome by the Review Panel as soon as practicable
after the decision is made. The decision, and the rationale for the decision, will be set out
in a decision letter, which will be sent to the postmaster.
When informing the postmaster of the outcome of the review the Review Panel should
outline the following to the postmaster (subject to any restrictions on disclosure as set out
in Section 3.2):
* That the decision is to:
- uphold the decision to terminate the contract; or
- uphold the decision to terminate the postmaster contract but if the
decision was to terminate immediately change the decision to terminate
on notice and confirm the notice period (as defined in 4.12 of the
Postmaster Contract Termination Policy); or
- overturn the decision to terminate the postmaster contract, end the
suspension period (if suspended) and reinstate the postmaster contract
subject to conditions (if applicable).
e Outline the reason(s) for the decision taken;
«That the information and records relating to the investigation have been/will be
made available to the postmaster
e Any other relevant information that should be shared with the postmaster.
3.5. Decision review conclusion
On conclusion of the decision review process the Review Panel will arrange for the
Contracts Team to complete the following:
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¢ arrange for all stakeholders to be made aware that the decision to terminate the
contract has been upheld; or
* arrange for all stakeholders to be made aware that the decision to terminate the
contract has been amended to terminate the contract by notice. The Contract
Advisor to take all necessary steps to implement the termination by notice.
* arrange the reinstatement of the postmaster contract subject to any conditions
(where applicable) set by the Review Panel; or
The Review Panel will update the Case Summary document (to include all relevant
information, correspondence and rationale(s)). The Review Panel will then return the Case
Summary to the Contracts Team, copying the Contract Investigation & Resolution Manager
and the Franchise Partnering Director.
It will be the responsibility of the Review Panel to outline any lessons learnt from their
investigation to the Franchise Partnering Director to ensure any issues identified in the
review are addressed and to ensure that the principles as set out in the Postmaster
Contractual Performance, Postmaster Suspension and Postmaster Termination policies are
upheld.
3.6. Payment during the decision review process
Payment under the contract continues during any period of suspension.
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4. Where to go for help
4.1. Additional Policies
This Policy is one of a set of policies. The full set of policies can be found on the SharePoint
Hub under Postmaster Support Policies.
4.2, How to raise a concern
Any postmaster (whether a limited company, partnership, limited liability partnership or
an individual), any postmaster’s staff or any Post Office Employee who suspects that there
is a breach of this Policy should report this without any undue delay.
If a postmaster or any postmaster’s staff are unable to raise the matter with the area
manager of the relevant branch or if a Post Office Employee is unable to speak to her or
his line manager, any person can bring it to Post Office’s attention independently and can
use the Whistleblowing channels for this purpose. Any person can raise concerns
anonymously, although disclosing as much information as possible helps ensure Post Office
can conduct a thorough investigation.
For more details about how and where to raise concerns, please refer to the current
Whistleblowing Policy which can be found on The Hub under Post Office Key Policies,
accessed here.
4.3. Who to contact for more information
If you need further information about this policy or wish to report an issue in relation to
this policy, Franchise Partnering Director at
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5. Governance
5.1. Governance Responsibilities
The Policy sponsor, responsible for overseeing this Policy is the Retail and Franchise
Network Director of Post Office.
The Policy owner is the Franchise Partnering Director who is responsible for ensuring that
the Contract Investigation & Resolution Manager conducts an annual review of this Policy
and tests compliance across the Post Office. Additionally, the Franchise Partnering Director
and the Contract Investigation & Resolution Manager and their team are responsible for
providing appropriate and timely reporting to the Risk and Compliance Committee.
The Audit and Risk Committee are responsible for approving the Policy and overseeing
compliance.
The Board is responsible for setting the Post Office’s risk appetite.
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6. Control
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6.1. Policy Version
Date Version
Updated by
Change Details
224 July 2020 I 1.1
Glenn Chester, Contract
Advisor
Draft Version
2st 1.2
September
2020
David Southall, Contract
Investigation &
Resolution Manager
Revised draft version for submission
3" February 1.3
2021
David Southall, Contract
Investigation &
Resolution Manager
Final draft update ahead of legal
service review.
26 February I 1.4
2021
David Southall, Contract
Investigation &
Resolution Manager
Updated draft following legal services
input.
st March 1.5 David Southall, Contract I Name change to Postmaster
2021 Investigation & Termination Decision Review policy
Resolution Manager and appetite statements updated.
9% March 1.5.1 David Southall, Contract I Updated following operational review
2021 1.5.2 Investigation &
Resolution Manager
17% March 1.6 David Southall, Contract I Updated following RCC feedback
2021 Investigation &
Resolution Manager
30% March 2.0 David Southall, Contract I Final approved by ARC
2021 Investigation &
Resolution Manager
29% April 21 David Southall, Contract I Updated risk appetite statements
2021 Investigation &
Resolution Manager
Alignment with other postmaster
support policies
4 May 2021 I 2.2
Jo Milton
Risk appetite amendment
25' May 2021 I 2.3
Jo Milton
Added linked policy statement to
front page
Added reference to the Group
Investigations Policy to section 2.3
Who Must Comply?
Updated link to section 4.1
Added footnotes to link to other
policies referred to in this policy.
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Changed reference to section
numbers in other policies where
these had changed.
6.2. Policy Approval & Review
Oversight Committee: Risk and Compliance Committee and Audit and Risk Committee
Committee Date Approved
POL R&CC 16" March 2021
POL ARC 30" March 2021
Policy Sponsor:
Policy Owner:
Policy Author:
Next review:
Company Details
Retail and Franchise Network Director
Franchise Partnering Director
Contract Investigation & Resolution Manager
31 MAR 2022
Post Office Limited and Post Office Management Services Limited are registered in England and Wales. Registered numbers
2154540 and 08459718 respectively. Registered Office: Finsbury Dials, 20 Finsbury Street, London EC2Y 9AQ.
Post Office Management Services Limited is authorised and regulated by the Financial Conduct Authority (FCA), FRN 630318. Its
Information Commissioners Office registration number is ZA090585.
Post Office Limited is authorised and regulated by Her Majesty’s Revenue and Customs (HMRC), REF 12137104. Its Information
Commissioners Office registration number is 24866081.
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