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Message
From: Mark Underwood=[mark.underwood GRO
Sent: 04/03/2017 21:55:59 -
To: Parsons, Andrew [Andrew.Parsonsi ribben, Jonathan
[onathan.Gribben’, 3]
Subject: FW: Allegations Made in the Group Litigation re POL's Operation of Suspense Accounts: Private & Confidential -
Subject to Legal Privilege
Attachments: 170304 Private & Confidential _ Subject to Legal Privilege _ Suspense Accounts Scope.docx
Just FYI
Mark Underwood
Head of Portfolio: Legal, Risk & Governance
From: Mark Underwood,
Sent: 04 March 2017 21:
To: Alisdair Cameron; Amanda Radford
Cc: Jane MacLeod; 'Rodric Williams’
Subject: Allegations Made in the Group Litigation re POL's Operation of Suspense Accounts: Private & Confidential -
Subject to Legal Privilege
Dear Amanda & Alisdair,
To enable Bond Dickinson and (Tony Robinson QC) to prepare POL’s defence in the Group Litigation, I am looking to set
up meeting to scope the work necessary to address the below allegation, which is included in the claimants’ draft
Particulars of Claim:
POL operated one or more suspense accounts in which it held unattributed surpluses including those generated
from branch accounts. After a period of 3 years, such unattributed surpluses were credited to POL’s profits; and
POL thereby stood to benefit and/or did benefit from apparent shortfalls wrongly attributed to the Claimants
which did not represent real losses to POL.
An accurate response to the above allegation, and in particular the suggestion that losses were not ‘real’, will need to be
included in POL’s defence. Bond Dickinson have drafted a series of questions that, if answered, they believe will provide
an appropriate level of assurance. Further, even if definitive answers to some of the questions cannot be obtained, the
findings will be invaluable in shaping POL’s defence strategy.
The questions we are looking to obtain answers for are included in the attached table. You will see that the table also
sets out:
e The rationale for asking these questions;
e The value of these questions, even if we are unable to provide answers to them;
@ = The ‘shopping list’ of procedures that Deloitte believe are available to POL to discharge these questions; and
e The associated costs of Deloitte performing this piece of work (£80 - £150K — depending on the procedures
chosen).
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Bond Dickinson and Deloitte are both available to come to Finsbury Dials on Friday 10 March @ 15:00. It would be
fantastic if you were also able to attend this meeting to ensure that we are not duplicating work that has already been
done; that we are involving the correct people; and that the work is appropriately scoped. I will send you both a
calendar invitation shortly and I am of course happy to discuss any of the above in more detail.
Many thanks
Mark
Mark Underwood
Head of Portfolio: Legal, Risk & Governance
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