STRICTLY CONFIDENTIAL — SUBJECT TO LEGAL PROFESSIONAL PRIVILEGE
POSTMASTER LITIGATION STEERING GROUP
Membership
Terms of Reference and Membership
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1.1. Post Office is the defendant in Alan Bates & Others v. Post Office Limited,
High Court of Justice Queen's Bench Division, Claim No. HQ16X01238 (the
“Claim’).
1.2 The Postmaster Litigation Steering Group (“PLSG”) is established to co-
ordinate Post Office’s approach and response to the Claim, and therefore
brings together representatives from affected teams in the business as set
out below at Table 1.
1.3. A deputy is permitted as a fully-empowered representative of the relevant
team, subject to this being agreed in advance with the PLSG Secretariat.
1.4 Other colleagues may be invited at the Chair's discretion.
1.5 The PLSG is chaired by the General Manager, Network, who has
responsibility for Network Operations. The Secretariat is provided by Post
Office Legal.
Table 1: PLSG Membership
Team
Representative
Deputy
Network & Sales
Tom Moran, General
Manager, Network
Support Services I Angela van den Bogerd,
Director of Support Services
Corporate Patrick Bourke
Services
Communications
Mark Davies,
Communications Director
IT Rob Houghton, Chief
Information Officer
CEO Tom Wechsler, Chief of Staff
Finance Nick Sambridge, Head of
Business Performance
Management
Post Office Legal
Rodric Williams, Solicitor
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External Legal* I Andrew Parsons, Partner,
Bond Dickinson
“Representatives from External Legal will attend as necessary depending on the
issues being discussed.
2. Terms of Reference
2.1. The objectives of the PLSG are to ensure that Post Office’s defence of the
Claim:
e protects the Network;
° is proportionately managed;
e does not place unplanned constraints or resource burdens on Post
Office; and
e is consistent with business as usual (BAU) practices, processes and
procedures.
2.2 In order to deliver these objectives, the Post Office Group Executive has
agreed the PLSG will undertake the following responsibilities:
a) providing a forum for cross-business discussion of Claim-related BAU
issues.so that all relevant matters are considered when making a
decision;
b) providing instructions to Post Office’s legal team on BAU/commercial
matters;
c) maintaining and progressing an Action Plan for Claim-related activity,
and monitoring the resources required to deliver against that plan;
d) signing off key Claim-related documents;
e) monitoring and approving Claim-related expenditure;
f) reviewing, challenging and signing off any Communications plans
developed as a consequence of the Claim’;
g) reporting matters to the Group Executive as appropriate.
2.3 Sign-off can be obtained through correspondence or discussion in a PLSG
meeting and is to be recorded by the Secretariat.
3. Escalation
3.1. Any issue which cannot be resolved at the PLSG should be escalated
immediately to the Post Office General Counsel by the Chair.
4. Organisation
4.1. The PLSG meets on an ad hoc basis as set by Post Office Legal. Any
papers for the PLSG are commissioned, co-ordinated and circulated by
Post Office Legal in advance.
1 NB: Any operational plans, including contingency plans, which are required as a consequence of the Claim
remain the responsibility of the respective operational units and/or the Business Protection Team as
appropriate.
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1.6 A PLSG will only be quorate for decision making and mandate setting
purposes if three or more PLSG Representatives (which need not include
the Chair) are present at the meeting? or have submitted their comments
including an explicit approval or rejection of any relevant proposal, to Post
Office Legal in advance of the meeting.
4.2 All PLSG Papers, Minutes and Actions are held by Post Office Legal.
Access is restricted and can be arranged by contacting Post Office Legal.
4.3. All PLSG discussions and papers are STRICTLY CONFIDENTIAL AND
SUBJECT TO LEGAL PROFESSIONAL PRIVILEGE and not for discussion
or circulation beyond the membership of the PLSG without express
permission of Post Office Legal.
Post Office Legal
June 2016
2 ‘Present’ includes PLSG members who dial-in to meetings via telephone.
3