POL00021990 - Post Office Limited Work Plan and issues (DRAFT).

Evidence on official site

PRIVILEGED AND CONFIDENTIAL
DRAFT: 4 March 2014

Post Office Limited —- Work Plan and issues

POL00021990
POL00021990

Legal relationship between Post Office Limited
and the Sub-Post Offices

e Review contract
o Parties
o Duration
o Provision for termination
oc Accounting between Post Office and Sub-Post-Offices
e Variations to the contract to address uncertainty/improve Post Office position in future?

Definition of losses
e How are they defined in the contract?
e How are they determined in practice?
e Methods of payment

e Review contract

¢ Practice to determine losses

e Correspondence between Post Office and Sub-Post-Office about claims or potential claims
e Practice as to payment or recoupment

Basis for claiming losses
¢ Contractual claims
e Other legal bases for a claim?

e Review contract

e Analysis of any other legal bases for claim

e Other legal analysis

e Review prior legal advice

¢ What has been said to Sub-Post-Offices about the basis of claim?

Criminal aspects.

e Review advice from Cartwright King
e Prosecution policy
e Basis for prosecutions

« Outcomes of prosecutions to date

A17823075/0.2/04 Mar 2014
PRIVILEGED AND CONFIDENTIAL
DRAFT: 4 March 2014

POL00021990
POL00021990

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Mediation as a dispute resolution technique

Typical features
The dynamics of mediation
Its limitations and benefits.

Legal analysis

Mediation Scheme

The application process and acceptance
criteria for the Scheme

Contractual basis — at what point does a
contract arise?

Nature of the relationship outside the
contract?

Are there any estoppel or other issues
arising?

Current status of the scheme — closed to
new applicants?

Proposals for dealing with complaints that
aren't dealt with through Scheme

Scheme publicity and value for reputation

Review Scheme overview and settlement policy
Consider criteria for Scheme acceptance and mediation
Is there standard form correspondence?

Legal analysis

Consider costs implications

Review public statements/publicity

The Working Group

Status
Ability to bind the Post Office

Implications of not following a
recommendation

Review terms of reference

Review relevant correspondence

Review public statements/publicity

Assess what the Working Group has done to date/what else it could be doing

Second Sight

Review engagement terms

A17823075/0.2/04 Mar 2014
POL00021990
POL00021990

PRIVILEGED AND CONFIDENTIAL
DRAFT: 4 March 2014

e Basis of engagement e Review reports

e Material available to them for their work « Correspondence with Second Sight?

¢ Their status and role

e Terms of engagement

« Ability to opine on relevant issues

e What can be done to challenge the
reports already given?

¢ Interaction between Second Sight and the
Working Group

Horizon e Review of Second Sight reports
¢ Its features and alleged shortcomings ¢ Discussion with Post Office Limited
e Expert view on the shortcomings e Questions to Fujitsu?

Individual complaints ¢ Review of case files
e Legal basis e Legal analysis

e Calculation of compensation
e Interaction with the criminal process

¢ Time period for which complaints allowed

Proposals for the future « Analysis
¢ Potential modifications to existing Scheme ¢ Discussion with Post Office Limited
e Potential alternatives to existing Scheme
e Horizon
e Reputation

A17823075/0.2/04 Mar 2014