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Message
From: Andrew Parsons: GRO
Sent: 25/07/2018 08:33:23
To: Angela i; Jane MacLeod
ii GRO ; Rodric William
ce: Mark Underwoo
Subject: RE: Draft Board Report on Contingency Planning - DO NOT FORWARD - SUBJECT TO LEGAL PRIVILEGE [WBDUK-
AC.FID26896945]
Attachments: Contingency Planning Mitigation Table 24th July 2018 (005).docx
Angela
I'm happy with your recommendations. Updated version attached ~ I've tidied up some typos and formatting.
I've also removed reference to the Judgment being “issued in November’, because the Judgment likely won't come out
until December, but perhaps January or even February. I didn’t want the Board getting the wrong in impression.
Andy
Andrew Parsons
Partner
Womble Bond Dickinson (UK) LLP
Andrew.Parsons GRO
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From: Angela Van-Den-Bogerd ~ :
Sent: 24 July 2018 23:40
To: Jane MacLeod; Rodric Williams
Cc: Andrew Parsons; Mark Underwood:
Subject: RE: Draft Board Report on Contingency Planning - DO NOT FORWARD - SUBJECT TO LEGAL PRIVILEGE
All
Please find attached the mitigation paper with my view on recommendations to action now/ahead of November. Please
let me have your thoughts?
Jane — I have made recommendations on ‘best practice’ but I’m mindful that these haven’t as yet had sufficient airtime
with AL, Debbie and their teams so would appreciate your thoughts on my recommendations and the wording I’ve used.
{ have a session with Julie and Tom on Friday to discuss these especially in light of the ongoing Retail review.
Thanks,
Angela
Angela Van Den Bogerd
People Services Director
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From: Jane MacLeod
Sent: 24 July 2018 2: .
To: Rodric Williams GRO }; Angela Van-Den-Bogerd <7”
Cc: Andrew Parsons ¢____.. GRO _Mark Underwood” z
Subject: Re: Draft Board Report on Contingency Planning - DO NOT FORWARD - SUBJECT TO LEGAL PRIVILEGE
Rod
Thanks for this. The papers have gone to the Board already - attached is an update of what I sent in as a
holding paper; we can hand round the updated mitigations paper in the meeting. We only have 20 mins on
the agenda on Tuesday, so this will be a very high level discussion. The key focus will be the mitigations paper
and we can work on that over the next few days.
Speak tomorrow.
Jane
Jane MacLeod
Director of Legal Risk & Governance
Post Office Limited
From: Rodric Williams
Sent: 24 July 2018 19:49
To: Jane MacLeod; Angela Van-Den-Bogerd
Cc: Andrew Parsons; Mark Underwood!
Subject: Draft Board Report on Contingency Planning - DO NOT FORWARD - SUBJECT TO LEGAL PRIVILEGE
Jane, Angela
Please find attached a draft “starter for 10” Board Report on the Contingency Planning Work, which I hope is
going in the right direction and on which all comment and guidance will be gratefully received
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I think the draft Report covers where we have got to so far, but I have left blank the “Input Sought” and “What
do we need to do next to progress?” sections as I’m not sure if this should be a noting paper (which is what it
feels like to me), or whether we want a specific decision/action from the Board.
lam conscious that Al wants to call out for the Board the need to start acting now if we want to mitigate a
potentially adverse finding in the Common Issues trial by proactively changing the postmaster contract. The
Report seeks to address this through the “DRAFT Mitigation Actions” document (also attached) which:
identifies contract change as one of four categories of mitigation action;
sets out (as it does for all other possible mitigation actions) the pros and cons of taking that action; and
will provide a recommendation on whether that action should be taken now.
I attach the latest version of that document. Angela will look to populate the final, “Recommendations”
column tomorrow, with whatever support she may need from the lawyers. The draft Report anticipates that
this document will be Appendix 2 once finalised.
The specific recommendation on the contract change mitigation will be not to change the contract now, but to
prepare suggested amendments with a view to implementing them if necessary after Judgment on the
Common Issues is received. That recommendation is based on Counsels’ written Advice dated 12 July 2018,
which I attach for your consideration. I do not propose appending the Advice to the Board paper given it is
summarised in the Mitigation Actions document, and I would prefer to restrict circulation of this type of
document. Please do not forward the Advice to anyone else, but let me know if you think anyone else should
see it.
I look forward to your comments, and otherwise remain available to support finalising this Report.
Rod
UJ Rodric Williams
Head of Legal - Dispute Resolution & Brand
20 Finsbury Street
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