POL00006706
POL00006706
Minutes of Meeting Confidential / Legally Privileged/ Do not Share
®
GLO CONTINGENCY PLANNING GOVERNANCE
Finsbury Dials
[7 May 2019; 4.00 pm]
Attendees: Ben Foat (BF), Zoe Brauer (ZB), Rodric Williams (RW), Rawa Hussain (RH)
Apologies: Mark Underwood (MU), Angela Van-Den-Bogerd (AVB)
Agenda
1 Operational Focused Updates
2 Litigation Focussed Updates
3 Mailwork Variation
4 AOB
5 Actions
1 Operational Focussed Updates
BF- there was a GE discussion earlier today and one of the prominent themes was on Group
Litigation which has formed a significant proportion of the Post Office plan. Group Litigation is
the biggest thing that everyone needs to focus on and Al Cameron expressed strong concerns
about operational transformation. He wants a position on the contract/ losses by next week. We
can’t keep telling him there is background work as that has been the case for several weeks. We
now need an options paper and solutions.
* BF -examples of options include: a) we do nothing; b) what we think commercially and
reasonably should happen taking into account what the Judgment says; c) make changes
altogether. Whatever position we recommend, now is the time to make decisions and take a
stance.
¢ BF-we need a table with answers/ recommendations. A briefing note on what the approach is
on contracts to be provided before Monday.
* ZB-we have given advice to the business but there has been no interaction/ engagement back
from the business and there has been some confusion from the client about who the client is.
¢ BF —Julie Thomas is the client and Al thinks so too.
e ZB-with regards to Julie’s transformation programme — this should be intertwined with the
contract work we are doing but Julie is seeing it separately.
¢ BF-—the transformation programme is not seen as separate. Julie’s programme is the
overarching programme and Group Litigation provides different segments as part of that.
* ZB—examples of bad behaviour of K advisors — Julie sent me — wants a weekly catch up with me
and is separating that.
e RW-Julie has an idea that we deliver the perfect legal solution but we explained in our meeting
with her earlier today (related to historic claims) that we are here to provide advice and options.
¢ BF-—a ways of working needs to be established with Julie. For now, a paper is to be drafted
capturing the following: 1. What is the issue?; 2. What is the ‘answer’/ recommendation?; 3.
What are the options? With options, provide pros and cons and their consequences. If it comes
down to it, come to a view.
¢ BF-inGE, the issue of resource was raised and I explained we are getting backfill for ZB and RW.
Secondees start next week Monday.
e ZB -oncontracts piece, this is more straightforward as we can take Norton Rose’s mark up of
the contract. However, the business still needs to make a call on that. Once we have that
clearance, that is our go ahead.
POL00006706
POL00006706
Minutes of Meeting Confidential / Legally Privileged/ Do not Share
« 7ZB—TIhave an Operations table which I provided to Julie and it more or less has what we need
on there. (ZB to pass to RH operations table and RH to print with the attachments and to give to
BF and RW).
e ZB-—the emails received over weekend from Julie shows she is confused about her expectations.
¢ BF -provide in the table name of decision maker in a separate column.
¢ BF-—Iwant to present a sensible, logical approach to GE on Monday. Some reassurance we’re
not going to have envisaged every single thing that we think will come out. On Monday, Al will
want a paper proposing what we will do and continue to look at over the year. We have at least
finalised one contract that is recommended.
2 Litigation Focussed Updates
1. Main Appeal
e BF-there is a board sub- committee this Thursday about the appeal.
e RW-we went through draft grounds. Errors of law, procedural unfairness and findings of fact.
Revised grounds were circulated at midday today with skeleton argument.
© BF —we want to approach the board to say we want your consent to file our appeal- there needs
to be a board paper for this.
« RW-Herbert Smith can do a draft document.
2. Recusal Application
¢ RW- permission to appeal may come this week.
3. Horizon Issues Trial
e RW- Preps continue. Our expert wants to file another report which we have no permission for.
Still need to update BF on this (previously updated Jane MacLeod).
3 Mailwork Variation
¢ BF - Dieter sent an email today — issuing 8 bespoke letters.
¢ BF - happy to present to GE that we have provided advice and someone needs to provide sign
off.
4 AOB
None.
Actions
No Description Owner Status
1 ZB to send RH Operations table. zB Done.
2 RH to print off and give a copy of Operations table to BF and RW. RH Done.
3 To draft a briefing note/ table of the issues, recommendations and ZB
pros and cons of relevant options in time for GE meeting on Monday.
4 To draft a board paper for the sub-committee for this Thursday in RW
relation to the main appeal.
Author of Minutes: RH
Date: 7 May 2019