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POSTMASTER
SUPPORT POLICIES
Postmaster Contract
Suspension Policy
Version — V3.0
Post Office is determined to reset its relationship with postmasters and has introduced policies that set out guidelines on h ow
Post Office should support postmasters, specifically for use across twelve areas.
The policies stand on their own but should be reviewed in conjunction with each other. Support teams should have an awareness
of all twelve policies and how they link together.
The twelve Postmaster Support Policies are listed in section 3.2 of this policy and can be found on the hub, here.
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1. Definitions
1.1. Definitions
2. Overview
2.1. Introduction by the
2.2. Purpose ....
2.3. Core Principles .
2.4. Application
2.5. The Risk....
3. Risk Appetite
3.1. Risk Appetite
3.2. Policy Framework
3.3. Who must comply?.
3.4. Roles & Responsibilities
3.5. Minimum Control Standards .....0.... ee
4. Procedure
4.1. Investigation
4.2. Alternatives to suspension
4.3. Suspension Rationale
4.4. Informing a postmaster of suspension .............:0000
4.5. Payment during suspension
4.6. Temporary operation during suspension period
4.7. Suspension period
4.8. Reinstatement or termination following a period of suspension.
5. Where to go for help
5.1. Additional Policies
5.2. How to raise a concern
5.3. Who to contact for more information...........
6. Governance...........
6.1. Governance Responsibilities
7. Control...
7.1. Policy Version
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7.2. Policy Approval & Review
Company Details
8. Appendices
8.1. Suspension Rationale Document
8.2. Process Map
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1. Definitions
1.1. Definitions
1. Audit - This is a comprehensive assessment of the current trading position of a
branch, and includes the verification of reported levels of cash, foreign currency
(if applicable), stock items and vouchers as well as a compliance review, to check
if mandatory business conformance and regulatory compliance controls are
operating as intended.
Investigation - An investigation into the matter that may give rise to Post Office
exercising its suspension rights undertaken by the Contract Advisor.
Postmaster - this refers to a limited company, partnership, limited liability
partnership or individual that contracts with the Post Office in its or their capacity
as a postmaster in the network, or assistants of such postmasters.
Temporary Postmaster - this refers to a limited company, partnership, limited
liability partnership or individual that contracts with the Post Office on a
temporary basis
Non-suspension monitoring - The period after any decision taken not to
suspend a postmaster’s contract/agreement whereby there is continued
monitoring of the issues identified over a defined period of time.
Suspension Rationale (see appendix 8.1) — A rationale completed by the
Contract Advisor which captures the facts and findings of the investigation into
the matter and sets out the rationale outlining the recommendation for review by
the Head of Contract Management & Deployment (with support from Post Office
legal services as required)
Suspension Review Period - A review of the suspension made by the Head of
Contract Management & Deployment (with the support of Post Office legal
services) to ensure there is still a basis for suspension. The first review is
completed within 10 working days of the suspension commencing, and then each
subsequent review is completed every 5 working days.
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2. Overview
2.1. Introduction by the Policy Owner
The Franchise Partnering Director has overall accountability to the Board of Directors for
the design and implementation of controls to manage risk in the network?. Risk in the
network is an agenda item for the Risk Committee and the Post Office? board is updated
as required.
This policy is a non-contractual document provided for information. It does not form part
of a contract between postmasters? and Post Office.
This policy forms part of a suit eof policies designed to deal with the management of
postmaster contracts and for those teams deploying any aspect of this policy it should be
read together with the Postmaster Contract Performance and Postmaster Contract
Termination policies. These polices can be found on the hub, here.
2.2. Purpose
This policy is part of a framework that has been established to set the minimum operating
policies relating to the management of contracts with postmasters (which may be
companies, sole traders or partnerships) throughout the network.
Post Office recognises that there may be occasions where it is necessary to suspend the
contractual relationship with a postmaster. The purpose of this policy is to identify the
circumstances in which suspension should be considered and the criteria which must be
met before a decision to suspend is made. It will also outline the procedures to be followed
in the case of suspension. Wherever possible Post Office will seek alternatives to
suspension as outlined later in this
policy.
This policy is one of a number of policies which provide a clear risk and governance
framework and an effective system of internal control for the management of risk across
the Group. Compliance with these policies supports the Group in meeting its business
objectives and to balance the needs of customers, shareholders, employees, other
stakeholders (such as the government departments) and third party commercial partners
including Royal Mail.
2.3. Core Principles
The act of suspension is a neutral, precautionary act. It is used to investigate the cause
of a potential contractual breach identified by the Contract Advisor. It does not imply there
has been any such breach.
* In this policy, “network” means branches not directly managed by Post Office
In this Policy “Post Office’ means Post Office Limited.
* In this Policy “postmaster” refers to the person or entity (which may be a company, sole trader or partnership) contracted wi th
Post Office and any person acting on the postmaster’s behalf (as applicable).
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It is recognised that suspension may have an impact on the postmaster's core business
and on the Post Office brand; therefore, a contract will only be suspended where absolutely
necessary and after all reasonable alternatives have been considered.
The period of suspension should be for as short a time as possible and Post Office will
remain in touch with the postmaster throughout this time. Each suspended postmaster
shall be assigned, and notified of, a specific Contract Advisor to keep them up to date with
developments during the period of suspension.
Accordingly this policy, and its linked policies, sets out clear and consistent guidelines to
ensure that:
e an investigation is carried out to establish the applicable facts before any formal
action is considered, to provide the postmaster with the opportunity to identify and
address any issues of concern and to determine whether Post Office has the right
to suspend the postmaster’s contract;
e consideration is given to the postmaster’s particular circumstances before deciding,
acting in good faith, whether to suspend the postmaster’s contract;
* suspension only happens when it is necessary and alternatives have been
considered; and
« postmasters continue to receive payment during any period of suspension.
Post Office will handle these situations in good faith and apply the principles of fairness,
transparency, and professionalism (being the underpinning behaviours of Post Office).
2.4. Application
This policy is applicable to all postmaster contracts? in the network.
2.5. The Risk
In taking any decision to suspend a postmaster Post Office needs to:
* ensure that any decisions taken in respect of a postmaster contract are not
exercised arbitrarily, capriciously or unreasonably;
* exercise any contractual power (including the right to suspend) honestly and in
good faith for the purpose for which it was conferred on Post Office; and
* exercise any discretion in accordance with the obligations of good faith, fair
dealing, transparency, co-operation and trust and confidence.
The decision to suspend a postmaster’s contract creates risk to Post Office and postmasters
both through how the decision is reached and by not suspending when it is appropriate to
do so. These risks include (but are not limited to):
“In this policy, “postmaster contract” means con tracts which relate to those branches not directly managed by Post Office
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e Post Office is not able to suspend a postmaster’s contract without reasonable and
proper cause. Post Office cannot suspend a postmaster’s contract where Post Office
itself is in material breach of duty in respect of matters which Post Office considers
give it the right to suspend. If a postmaster is suspended unneccessarily it may:
- cause distress and financial detriment to the postmaster; and
- Post Office may be perceived as not acting in good faith;
* a reduction in confidence across the postmaster network in how Post Office
manages the contractual relationship with postmasters;
e stakeholders having reduced confidence in Post Office’s ability to effectively
manage postmaster contracts;
«both postmasters and Post Office may suffer financially;
e Post Office may suffer reputational damage; and
e Post Office may be in breach of their contractual or regulatory obligations, which
could lead to possible legal challenges.
Section 2.5 sets out the minimum control standards that the Post Office has implemented
to control these risks.
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3. Risk Appetite
3.1. Risk Appetite
Risk appetite is the extent to which the Post Office will accept that a risk might happen in
pursuit of day-to-day business transactions. It therefore defines the boundaries of activity
and levels of exposure that Post Office is willing and able to tolerate.
Post Office takes its legal and regulatory responsibilities seriously and consequently has:
e Averse risk appetite to corporate non-compliance with legal and statutory
obligations.
e Averse risk appetite for financial crime to occur within any part of the
organisation.
« Averse risk appetite in relation to unethical behaviour by Post Office staff.
e Averse risk appetite for litigation.
e Cautious risk appetite for inefficient or ineffective processes that result in: lost
time, duplicated effort, and increased risk of financial loss or errors in any part of
its business or core processes
Post Office acknowledges, however, that in certain scenarios, even after extensive controls
have been implemented, a process may still sit outside the agreed Risk Appetite. In this
situation, a risk exception waiver will be required pursuant to the Exemption Process,
details of which can be found here.
3.2. Policy Framework
This policy is part of a framework that has been established to set the minimum operating
policies relating to the management of our postmaster contract risks throughout the
business in line with Post Office’s risk appetite. The framework includes the following
policies:
« Postmaster Onboarding
¢ Postmaster Training
¢ Postmaster Complaint Handling
e Network Monitoring and Audit Support
e Network Cash and Stock Management
* Network Transaction Corrections
e Postmaster Account Support
e Postmaster Accounting Dispute Resolution
¢ Postmaster Contract Performance
« Postmaster Contract Suspension (this policy)
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Postmaster Contract Termination
Postmaster Termination Decision Review
3.3. Who must comply?
Compliance with this policy is mandatory for all Post Office employees® who manage
postmaster contracts on behalf of Post Office.
Where non-compliance with this policy by Post Office employees is identified by Post Office,
Post Office will carry out an investigation. Where it is identified that an instance of non-
compliance is caused through wilful disregard or negligence, this will be investigated in
accordance with the Group Investigations Policy.
3.4. Roles & Responsibilities
« Franchise Partnering Director - is the policy owner, who must comply with the
governance responsibilities set out at section 6.1.
e Head of Contract Management & Deployment - is accountable for the
deployment of this policy, for supporting Post Office personnel who carry out
actions under this policy and for regularly reviewing the effectiveness of this policy
and for drafting any amendments to it that may be required.
e Contract Advisor(s) - is (are) responsible for deploying the procedures set out
in this policy. The Contract Advisor(s) form part of the Contracts Team.
The Contract Advisor must:
°
apply the Post Office’s underpinning behaviours of fairness, transparency
and professionalism;
be fully conversant with this policy and linked policies;
gather as much preliminary information as possible relating to the issue
which has caused suspension to be considered, liaising as appropriate with
the postmaster and other Post Office teams;
complete the Suspension Rationale Document before suspending a
postmaster’s contract;
consult with the Head of Contract Management & Deployment before
suspending a postmaster’s contract, and as necessary during the suspension
process;
consider the options available as an alternative to suspension;
ensure any decision is made in line with all other linked Post Office policies;
5 In this Policy “employee” means permanent staff, temporary staff including agency staff, contractors, consultants and anyone
else working for or on behalf of Post Office and, for clarity, does not include postmasters or postmasters’ staff.
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ensure this suspension policy is adhered to and the postmaster is supported
throughout the procedure, including arranging for the postmaster to be notified
of the specific Contract Advisor dealing with their case;
make the postmaster aware of the support available to them, including from
the National Federation of Sub Postmasters;
explain at the outset, when a postmaster’s contract is being suspended, what
involvement will be requested from the postmaster during the contract
suspension period;
keep in regular contact with the suspended postmaster throughout the
suspension period;
deal with any contact (written or otherwise) from the postmaster, in a timely
manner;
if a meeting is required, be flexible, within reason, over the availability of the
postmaster; and
keep the suspension regularly under review (see 3.7), reinstating (or
terminating) the agreement as soon as practicable.
e National Federation of Sub Postmasters (NFSP) - is a professional trade
association which exists to support postmasters.
e Postmaster - this refers to a limited company, partnership, limited liability
partnership or individual that contracts with the Post Office in its or their capacity
as a postmaster in the network, or (as applicable) assistants of such postmasters.
In relation to this policy, the postmaster is expected to:
o comply with the terms of the suspension;
o be transparent and open towards Post Office;
o ensure they respond to written correspondence and telephone calls in a
timely manner in order to assist the Contract Advisor in reaching a decision;
and
o be flexible and available for meetings with the Contract Advisor if one is
required.
In relation to this policy, the postmaster may:
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o contact their NFSP representative to support them through the process;
o arrange legal or other representation for any written correspondence or
meetings with Post Office;
request information and evidence from Post Office in connection with this
process and wider investigation; and
contact a Contract Advisor at any time during the suspension process,
including regarding potential or actual termination.
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If alternative action has been taken in preference to suspending the postmaster, the
postmaster should comply with the terms of such alternative action.
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3.5. Minimum Control Standards
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A minimum control standard is an activity which must be in place in order to manage the risks, so they remain within the defined Risk
Appetite statements (as set out at section 3.1). There must be mechanisms in place within each business unit to demonstrate compliance.
The minimum control standards can cover a range of control types, i.e. directive, detective, corrective and preventive which are required
to ensure risks are managed to an acceptable level and within the defined Risk Appetite.
The table below sets out the relationships between identified risks and the required minimum control standards in consideration of Post
Office’s Risk Appetite.
Risk Area Description of Risk Minimum Control Standards Who is When
responsible
Reaching a Post Office is not able to « A Suspension Rationale Document will be I Head of As required
decision to suspend the agreement completed to support any suspension Contract
suspend without reasonable and decision setting out the factors to support I Management
proper cause. If Post Office the suspension. All decisions will be & Deployment
itself has not complied with signed off by the Head of Contract
its material obligations, Management & Deployment with support
relating to matters that gives from Post Office’s legal team.
it the right to suspend, Post
Office is not able to suspend © Quality checks and training covering the Head of Quarterly
the postmaster from suspension process will take place with Contract
operating the branch. If the the Contracts Team to ensure that the Management
decision is made incorrectly it correct process is followed. & Deployment
could lead to:
* unnecessary distress andI. The Franchise Partnering Director will Franchise Quarterly
financial detriment to the review decisions to ensure consistency of I Partnering
postmaster; decision making. Director
e Post Office may be
perceived as not acting in
good faith; and
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e possible legal challenge
from the suspended
postmaster.
Loss of If Post Office are not making e All decisions to suspend shall undergo a Head of As required
confidence the correct decisions by sign off process with review by the Head _ I Contract
and possible either: of Contract Management & Deployment Management
financial & * suspending when it has and, if required, supported by Post & Deployment
reputational no grounds to do so; or Office’s legal team.
damage * not suspending when it
should,
it may lead to a loss of e The Franchise Partnering Director will Franchise Quarterly
confidence both across the review decisions to ensure consistency of I Partnering
network and with Post decision making. Director
Office’s stakeholders in how
Post Office manages the * The Postmaster Contract Performance Head of Annually
contractual relationship with policy sets out the required steps as to Contract
its postmasters. In addition, how potential contractual issues across Management
incorrect decisions may lead the network should be dealt with, & Deployment
to financial loss and providing a solid framework to ensure
reputational damage. that the contractual relationship with
postmasters is managed consistently. The
relevant stakeholders are provided with
training on the Postmaster Contract
Performance policy annually.
Postmaster Any decision to suspend may Ie All postmasters will receive payment I Head of Monthly
financial cause financial detriment for during the suspension period (based on I Contract
detriment the postmaster average fees received over the previous I Management
during six-month period). A check will be I & Deployment
suspension undertaken by the Head of Contract
Management & Deployment with Post
Office Remuneration teams to ensure that
payment is being made.
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Suspensions will be regularly reviewed to
make sure there is still a basis for
suspension and any suspension period is
kept to a minimum.
Head of
Contract
Management
& Deployment
After 10 working days
from the date of
suspension and
thereafter every 5
working days
Policy non- Non adherence to the policy All members of the Contracts Team, the Head of Once approved and
adherence could result in legal and wider Franchise Partnering Team and any I Contract annually thereafter
regulatory risk as well as teams who may be involved in the Management (or sooner in the
reputational damage to Post decisions being taken will be provided & Deployment I event of material
Office and the relationship with training on this policy. changes to the
with postmasters. policy).
The Head of Contract Management & Daily
Deployment is accountable for ensuring
that they and their team adhere to the
policy, as it applies to their area.
The Policy should be reviewed, and if Head of As required (but
necessary updated. Contract reviewed at least
Management annually)
& Deployment
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4. Procedure
4.1. Investigation
Preliminary investigation
Any investigation will be a fair and unbiased method of investigating issues identified prior
to any formal action being considered. The process of investigation allows Post Office to
establish facts and gives the postmaster the opportunity to identify and answer any issues
of concern.
Post Office will ensure that complete records are kept of all investigations and that any
decisions taken in relation to an investigation are documented in rationale documents.
Records will be retained in accordance with Post Office's document retention policy®.
Details of the investigation and relevant supporting records and information will be shared
with the postmaster unless the material is subject to a restriction on disclosure such as:
« legal privilege;
« data protection law; and/or
* material relating to a criminal investigation.
The Contract Advisor should make an asessment of whether any restrictions on disclosure
apply in advance of sharing material with the postmaster and seek advice from Post
Office’s Data Protection and Information Rights Team if required.
The Contract Advisor will inform the postmaster of the grounds on which the postmaster
is being investigated and the postmaster’s rights to access information and records relating
to the investigation.
When considering suspension, Post Office must complete a preliminary investigation. This
preliminary investigation will, as a minimum, include a review of the contract between
Post Office and the postmaster to confirm the extent of Post Office’s right to suspend.
The contractual right to suspend may arise:
o if the postmaster is arrested or charged with a criminal offence;
o if the postmaster has civil proceedings brought against them; and
o there are grounds to suspect the postmaster is insolvent.
o due to irregularities or misconduct in the operation of the branch.
Post Office must check the contract in each case as the grounds may differ. If the contract
does not contain a contractual right to suspend, the Post Office must not suspend the
postmaster from operating the branch; and
® The Document Retention and Disposal Policy (Group Policy) can be found in the Group Key Policies on The Hub
https://poluk.sharepoint.com/sites/thehub/Policies/Forms/Allitems.aspx?id=%2F sites%2Fthehub%2FPolicies%2F Document
%20Retention%20and%20Disposal%20Policy%20v1%2E3%2Epdf&parent=%2F sites%2F thehub%2F Policies
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A review of the facts related to the investigation to establish whether Post Office is itself
in material breach of duty in respect of the matters giving rise to the right to suspend. If
it is, Post Office must not suspend the postmaster from operating the branch.
This investigation will include:
* areview of previous correspondence with the postmaster; and
e areview of any other supporting documents held by Post Office.
This investigation may also include:
¢ a financial audit;
e areview of Branch Analysis monitoring records; and
e information provided to Post Office by an outside body or source, for example, the
police, insolvency practitioners, or Post Office clients.
Once this initial investigation has been completed, the Contract Advisor should refer to 4.3
(Suspension rationale) to determine whether there is sufficient rationale to warrant
suspending the postmaster.
Investigation during suspension
Post Office is likely, in most cases, to need to complete further investigations once a
postmaster is suspended from operating the branch. These investigations may be complex
but must be completed as soon as practicable (in accordance with section 4.7 (suspension
period)) in order to limit any period of suspension to what is necessary to complete the
investigation. The output of these further investigations should be recorded in the
Termination Rationale Document.
A process map detailing the contract suspension process can be found in appendix 8.2.
4.2. Alternatives to suspension
Suspension will only be applied where absolutely necessary to investigate the cause of a
potential contractual breach identified by the Contract Advisor and where all alternative
options have been considered.
Alternative options to suspension may include:
e Non-suspension monitoring - continued monitoring of the issues identified over a
defined period of time, with any further or escalating issues being flagged to the
Contract Advisor to reconsider suspension.
e Other contractual performance measures and/or restrictions contained in the
Postmaster Contract Performance policy’.
The Contract Advisor should document alternatives to suspension in the same way as a
decision to suspend a postmaster (in the Suspension Rationale Document) and Post Office
should ensure that records of these decisions are also kept in accordance with Post Office's
” The Postmaster Contract Performance policy can be found on the hub, here.
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document retention policy.
4.3. Suspension Rationale
Post Office must not suspend any postmaster from operating the branch without
reasonable and proper cause (even if they have a contractual right to do so). This power
is discretionary but must be exercised in good faith. This is a question of fact but means
that Post Office should apply its underpinning behaviours of fairness, transparency, and
professionalism.
Whenever an investigation leads to suspension being considered, the Suspension Rationale
Document must be completed by the Contract Advisor. This captures the background of
the case, investigation undertaken and rationale behind the decision to be taken. The
document will be used by the Head of Contract Management & Deployment, if required
with support from Post Office’s legal team, as a basis for their decision on suspension.
Factors that the Head of Contract Management & Deployment should consider
when deciding whether or not to suspend a postmaster from operating the branch include:
e There being a risk to the postmaster;
e There being an immediate risk to Post Office assets;
e There being a risk to Post Office’s brand and/or Post Office's reputation of the
postmaster continuing to operate the branch.
This is not intended to be a full list of considerations relevant to suspension and the Head
of Contract Management & Deployment should consider all the circumstances of the case
and conduct a balancing exercise of the relevant risks.
4.4. Informing a postmaster of suspension
In the first instance, the postmaster will be informed by the Contract Advisor via telephone
call of any suspension. Where a postmaster cannot be contacted immediately, Post Office
will make every effort to inform the postmaster of their suspension through whatever
contact details they hold for the postmaster. This initial contact will be followed up by a
Suspension Letter, which will be sent as soon as possible following suspension by the
Contract Advisor.
When informing the postmaster of their suspension, subject to any restrictions on
disclosure (see 4.1 above) the Contract Advisor should outline the following to the
postmaster:
e The reason(s) for the suspension, including the factual circumstances and
contractual basis;
e That they are being suspended in accordance with their contract and in line with
the Post Office Suspension Policy®, a copy of which can be made available to the
postmaster on request;
® The Postmaster Contract Suspension policy can be found on the hub, here.
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e That a preliminary investigation has already been carried out and that information
and records relating to the preliminary investigation and any subsequent
investigation will be made available to them where possible;
e That the suspension period will be kept to the minimum period required to complete
the investigations and that the postmaster will be kept informed throughout the
period of suspension as per the processes outlined in 4.7;
e That the postmaster will receive payment during their suspension as per 4.5;
e The possibility of Post Office arranging for a temporary operator to operate their
premises and the processes involved in this, if the postmaster is willing (see 4.6);
and
e Any other relevant information that should be shared with the postmaster at this
stage.
4.5. Payment during suspension
Postmasters will receive payment during suspension. This will be based on average fees
over the previous six-month period. This does not include Christmas trading. Where the
postmaster has been appointed for less than six-months then this will be based on the
average fees received since appointment. Postmasters should contact their Contract
Advisors to understand in more detail how average fees are calculated.
4.6. Temporary operation during suspension period
In order to minimise the impact of any suspension period on the postmaster’s business,
on communities and on Post Office, Post Office will offer to attempt to find a temporary
operator for any premises where the postmaster has been suspended. A temporary
operator will only be able to operate with the express permission of the postmaster.
The postmaster and the temporary operator will be responsible for negotiating the
commercial arrangements between them. If a commercial arrangement is made between
the postmaster and temporary operator whereby the postmaster charges the temporary
operator Post Office will need to consider whether any deductions need to be made to the
payment made to the postmaster during suspension.
4.7. Suspension period
Suspension periods will be kept to the minimum period reasonably required to complete
the investigations and both Post Office and postmasters must cooperate in this regard.
Post Office may suspend a postmaster for as long as it has a reasonable and proper reason
to do so in the view of the Head of Contract Management & Deployment with the support
of Post Office’s legal team. The Post Office must act promptly to investigate the
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circumstances of the suspension and decide to either re-instate the postmaster or
terminate the postmaster's contract as soon as is practicable.
Post Office will keep any suspensions under regular review to make sure it continues to
have a legal basis for suspension throughout. The regular review must be completed by
the Head of Contract Management & Deployment. The first review and must be completed
within 10 working days of the suspension commencing, and then each subsequent review
must complete every 5 working days. After each review, the Contract Advisor will write to
the postmaster informing them whether their suspension will continue.
In addition to these letters there should be regular communication with the postmaster
through their Contract Advisor.
4.8. Reinstatement or termination following a period of
suspension
Reinstatement or termination should happen as quickly as possible once an investigation
has been completed or Post Office identifies that it no longer has a reasonable and proper
reason to maintain the suspension.
For reinstatements, the postmaster should receive a letter confirming the end of the
suspension period and the outcomes of any investigation. For terminations, the postmaster
will receive communications in accordance with the Postmaster Contract Termination
policy®.
The Contract Advisor is responsible for ensuring the postmaster’s reinstatement is carefully
planned, supported and in accordance with the wishes of the postmaster. This may be
assisted by liaising with the relevant Area Manager, other Post Office support teams and/or
the NFSP. Examples of considerations that the Contract Advisor should make include:
e What date is appropriate for any re-fund or transfer audits to take place;
e Whether it is appropriate for the postmaster to undergo further training prior to
reinstatement;
e Whether it is appropriate for the postmaster to have additional on-site support post
reinstatement. Any decision to terminate the postmaster's contract should be taken
in accordance with the Postmaster Contract Termination policy.
® The Postmaster Contract Termination policy can be found on the hub, here.
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5. Where to go for help
5.1. Additional Policies
This Policy is one of a set of policies. The full set of policies can be found on the SharePoint
Hub under Postmaster Support Policies.
5.2. How to raise a concern
Any postmaster (whether a limited company, partnership, limited liability partnership or
an individual), any postmaster’s staff or any Post Office Employee who suspects that there
is a breach of this Policy should report this without any undue delay.
If a postmaster or any postmaster’s staff are unable to raise the matter with the area
manager of the relevant branch or if a Post Office Employee is unable to speak to her or
his line manager, any person can bring it to Post Office’s attention independently and can
use the Whistleblowing channels for this purpose. Any person can raise concerns
anonymously, although disclosing as much information as possible helps ensure Post Office
can conduct a thorough investigation.
For more details about how and where to raise concerns, please refer to the current
Whistleblowing Policy which can be found on The Hub under Post Office Key Policies,
accessed here.
5.3. Who to contact for more information
If you need further information about this policy or wish to report an issue in relation to
this policy, please contact Andrew Kingham, Franchise Partnering Director at
andrew. kingham@! i
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6. Governance
6.1. Governance Responsibilities
The Policy sponsor, responsible for overseeing this Policy is the Retail and Franchise
Network Director of Post Office.
The Policy owner is the Franchise Partnering Director who is responsible for ensuring that
the Head of Contract Management & Deployment conducts an annual review of this Policy
and tests compliance across the Post Office. Additionally, the Franchise Partnering Director
and the Head of Contract Management & Deployment and their team are responsible for
providing appropriate and timely reporting to the Risk and Compliance Committee.
The Audit and Risk Committee are responsible for approving the Policy and overseeing
compliance.
The Board is responsible for setting the Post Office’s risk appetite.
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7. Control
7.1. Policy Version
Date Version I Updated by Change Details
2°4 March 2020 LA Tim Perkins Draft Version
6% March 2020 1.3 Tim Perkins Legal Review
17% March 2020 1.4 Tim Perkins For working group review
gt April 2020 1.5 Tim Perkins Final Draft with working group
revision
14 May 2020 1.6 Tim Perkins Final draft following further legal
review
6 April 2021 2.0 David Southall, Annual review - initial draft changes
Head of Contract
Management &
Deployment
14° April 2021 2.1 David Southall, Initial legal review
Head of Contract
Management &
Deployment
26" April 2021 2.2 David Southall, Second legal review
Head of Contract Addition of process map
Management & Alignment with other postmaster
Deployment fs
support policies
4' May 2021 2.3 Jo Milton Risk appetite amendment
23" May 2021 3.0 David Southall, Updated following ARC feedback
Head of Contract including:
Management & Updated to V3.0
Deployment Addition of definitions
Addition of Contract Performance
Rationale
Added linked policy statement to
front page
Added reference to the Group
Investigations Policy to section 3.3
Who Must Comply?
Updated link to section 5.1
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Added footnotes to link to other
policies referred to in this policy.
7.2. Policy Approval & Review
Oversight Committee: Risk and Compliance Committee and Audit and Risk Committee
Committee Date Approved
POL R&CC 4 May 2021
POL ARC 18st May 2021
Policy Sponsor:
Policy Owner:
Policy Author:
Next review:
Company Details
Retail and Franchise Network Director
Franchise Partnering Director
Head of Contract Management & Deployment
31 MAR 2022
Post Office Limited and Post Office Management Services Limited are registered in England and Wales. Registered numbers
2154540 and 08459718 respectively. Registered Office: Finsbury Dials, 20 Finsbury Street, London EC2Y 9AQ.
Post Office Management Services Limited is authorised and regulated by the Financial Conduct Authority (FCA), FRN 630318. Its
Information Commissioners Office registration number is ZA090585.
Post Office Limited is authorised and regulated by Her Majesty's Revenue and Customs (HMRC), REF 12137104. Its Information
Commissioners Office registration number is 24866081
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8. Appendices
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8.1. Suspension Rationale Document
Suspension Rationale Document
BRANCH DETAILS
Branch Name
Branch Code
Contract Type and Code (i.e. Local NT1)
Postmaster Name
Legal entity the contract is with (if
different from above)
Is the Postmaster an absentee (i.e.
managing from a distance)?
YES/NO*
*delete as applicable
If so, please explain the situation
with the Postmaster’s involvement.
If an audit occurred, name the person
in charge present at the audit
Appointment date according to current
contact
Original appointment date (if not same
as above)
Is the contract with a _ Limited
Company?
YES/NO*
*delete as applicable
If so, please list the Director’s
names:
Is the contract guaranteed by a
third party?
YES/NO*
*delete as applicable
Guarantor Details:
Date Contract Signed
Date Contract Countersigned
Remuneration/fees for last twelve
months (or since opening if less than
twelve months - please note)
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Associated Retail
period for this branch?
What is the date of the last trading
Is there an outstanding discrepancy at
this branch?(state amount and age)
Is this part of a group of branches
owned by the same Postmaster?
YES/NO*
*delete as applicable
If so,
branches operated
please advise the other
branches
And advise the audit results at other
Date of Audit
UDIT DETAILS
Amount of discrepancy
Detailed breakdown of the
discrepancy
Were there any known Horizon
issues that could have affected
this branch? (Give explanation of
steps taken to ascertain this)
YES/NO*
*delete as applicable
Reason for
offered
discrepancy, if
Is Horizon or Training an
area that has been cited as
a reason for the
discrepancy?
YES/NO*
*delete as applicable
Any admissions volunteered?
YES/NO*
*delete as applicable
a) Who volunteered the
admission?
b) What was said?
c) When was it said?
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d) Who was it said to?
e) How was it
documented?
Is there any other relevant
information provided by the
Postmaster or staff during an
audit?
YES/NO*
*delete as applicable
a) Who gave the
information?
b) What was said?
c) When was it said?
d) Who was it said to?
e) How was it
documented?
Please enter date and details
of previous audits
Please advise if there have
been any performance issues
previously
If so, what steps were
taken to address the
issues?
What calls have previously
been made to Branch Support?
RECORD OF DECISION MAKING
All of the following criteria must be considered along with any other factors relevant to the
case when making a decision.
a) What is the impact on
the Postmaster, were
we to suspend, and how
has this impacted the
decision you have
made?
b
LS
What is the source of
any risk and can this be
igated? For instance,
is the Postmaster
posing the risk or have
they been unaware of
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events caused by
assistants?
c)
Risk to POL funds
d)
Risk to POL brand or
reputation of the
Postmaster continuing
to operate the Branch
e)
What is the impact of
suspension on
customers and
suppliers?
f)
Has someone suffered
loss or damage as a
result of the suspected
or confirmed breach?
This could be the
Postmaster, customer
or supplier. Please
detail.
LY
Has the Postmaster
cooperated following
the findings at audit?
h
2
Please note any
relevant information
provided by the
Postmaster as part of
an informal discussion/
telephone
conversation/ written
explanation. (It is for
the Contract Advisor to
exert their judgement
in each individual case
to ascertain whether
the circumstances and
reasons given are
pertinent to the reasons
for suspension.)
Are there any other
relevant criteria of facts
that have been
considered or
disregarded as part of
your decision making
process?
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Factors for or against appropriate
ered).
Factors supporting continuation of service Factors supporting suspension
Recommended De
right to suspend):
ision (If suspension, please document relevant clause that gives the
Rationale to support recommended decision:
Where no suspension, detail further action planned:
Contract Advisor Details
Name of Contract Advisor completing decision document:
Date completed:
Business Improvements
Note: This section is to note any potential business improvements which have been raised
through the investigation.
Decision Making Manager
Date of Decision
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8.2. Process Map
Matter occurs
whereby a suspension
Sntract Advisor t
send request to
‘onboarding team,
decision isneeded
io Contract Advisor to
‘arrange defund
Yes
Collate all
relevant
documents and
upload to
Dynamics
sion t
to terminate
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