POL00106889 - Post Office Chairman Briefing Session - Sparrow

Evidence on official site

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Chairman Briefing Session
Sparrow

2 June 2014

DRAFT NOT POLICY

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Agenda

Introduction and context
Options and recommendation
Communications plan, narrative and stakeholder handling

PFoN >

Conclusion
Annexes

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Annexes ©

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Progress of the Scheme

Case MO22

Options to amend existing ToR

Financial modelling

Horizon definitions

Tony Hooper

Justice For Subpostmasters Alliance

Second Sight

Timeline

Draft PO / Linklaters ‘Horizon report’ (separate Word document, work in progress)

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Alternative narratives

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1. Introduction and context

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Today is an informal opportunity to discuss:
* Position with the Scheme

- ahead of sub-committee meeting

- following Board and sub-committee requests for information
* Assessment of opportunities, benefits, handling and risks of core options
« Assessment on likely outcomes if we are to maintain status quo position
* Case progression

- PO has completed 24 investigations

- Second Sight has provided its report on three of those investigations

- One recommended for mediation

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1. Introduction and context ©

We are in a challenging position with the Scheme — our session is aimed at
assessing all options openly and frankly.

Whatever decisions are made by the sub-committee, we believe that we can develop
and deliver communications and stakeholder approaches which will manage and
respond to adverse publicity and reaction. However, we do recommend a specific option.

We have developed communications approaches for all the options set out here.

We have engaged a senior PR professional to work solely on Sparrow over the next
three months and are in discussions with Brunswick PR.

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1. Introduction and context ee)

Post Office Board/Chair has asked for:

* Consideration be given to changes that could be made within the existing ToR
* Whether the caseload could be “triaged” to allow the caseload to be minimised
* Steps to be taken to settle case M022

Sub Committee has asked for the following to be developed:

« Animplementation plan following their agreement in principle to PO “taking control” of
the Scheme

¢ Linklaters letter, drawing on the further independent assurance work, for potential use
in the context of this plan

James Arbuthnot MP has written to the Post Office Chief Executive to:
* Express concerns over how long the Scheme and investigations are taking

* Request a draft letter for MPs and a meeting in July to update MPs on Scheme
progress :

Post Office Minister Jo Swinson MP returns to role in late June:
« with BIS pre-brief on June 9

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1. Introduction and context @

What does success look like?

¢ We bring a close to the discussion on the Horizon IT system as there is no evidence
there are systemic issues with it (independent assurance provided)

* 150 applicants feel that their concerns have been addressed

* MPs and the media are interested in our strategy and modernisation as opposed to
our IT systems

* Inrun up to the election the Horizon issue does not cause the minister any problems

* We-can proactive to changes in our IT systems and ensure they are received
positively

* Limited internal resource (from chairman to administration)/money spent on Horizon
and more on profit-making activity

* Second Sight no longer producing poor quality work that POL cannot rebut publicly

* Existing subpostmasters and customers continue to have confidence in our systems
and processes, particularly in relation to digital and financial services development

* Impact of Scheme on the brand re-launch and commercial agenda is minimal

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1.

Introduction and context . @

Principle concerns:

Mounting cost and use of management time ~

Potential for Scheme to continue until the end of 2015 (if Second Sight submit three
cases a week)

JFSA and-Second Sight are increasingly taking a harder line — in the case of JFSA
escalating to Ministers and threatening to go to media

Governance of Scheme as constituted does not allow Post Office any ability to amend
approach in best interests of the Business and applicants

Second Sight’s reports are of poor quality and inflammatory and will become public
(with no opportunity for Post Office to rebut)

Prospect of sustained media and stakeholder activity (possibly to tie into election
sensitivities)

Controversial cases and high profile decisions on a monthly ‘basis, plus one off
adverse media/stakeholder reaction when process completed

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1. Introduction and context @

Principle concerns (continued):

* Due to Conditional Fee Agreements there is an increasing likelihood of sub-
postmasters entering detrimental financial arrangements

* Potential impact the continuation of the Scheme could have on confidence in the
business

* This is all in the context of:
* Post Office having very limited legal liability, based on the Linklaters report

« Further evidence of there being no systemic issue with the Horizon computer system
through the independent assurance report and the results of 26 Post Office
investigations

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2. Options and recommendation @

An assessment of options has been undertaken by the Programme, Legal and
Communications and Corporate Affairs teams:

i. Continue with the Scheme as it is
- i.e. current arrangements

ii. Continue with the Scheme but seek to refine its work within the existing Terms of
Reference

- including ‘triaging’ cases post-investigation

iii. Completing the Post Office investigation in each case and moving the governance
and management of the Scheme in-house

- including ‘triaging’ cases post-investigation and disbanding Working Group and
ending Second Sight’s engagement

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2. Options and recommendation

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Continue with the Scheme as it is, i.e. current arrangements

Benefits:

.

Delivers on Ministerial and Post Office commitments
Potential for short term stability (in external context)
Delayed adverse PR impact (potentially)

Risks:

Number of dissatisfied applicants increases

Media coverage and speculation increased as ratio of dissatisfied applicants grows
Scheme costs continue to rise as it continues for further 18 months

Diverting management time from core business

Scheme damages credibility of the Post Office

Continued pressures for MP meetings

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2. Options and recommendation @

ii. Continue with the Scheme but seek to refine its work within the existing Terms
of Reference

Press for a number of reforms to its operation:

* Criminal cases: Make clear we will investigate last and are unlikely to mediate

* Bankruptcy: only engage if the Official Receiver has agreed to assign the rights
* Old cases: do not investigate where data is not available

* Case Questionnaire Response submission: A hard deadline is set and enforced

* Linklaters and independent assurance work: dissemination based on a duty to
applicants

¢ Regular quality and delivery review meetings with Second Sight

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2. Options and recommendation @&

ii. Continue with the Scheme but seek to refine its work within the existing Terms
of Reference (continued)

Benefits:
* Scheme administration improved
Risks:

* Likely to be resisted by Working Group, including Tony Hooper, as infringing
independence

¢ Ifissues forced to disagreement Post Office will either need to back down or risk
causing the Working Group to break up

« Adverse on-going media coverage and speculation agitated by JFSA to put pressure
on Post Office to concede or revert

* Negative stakeholder reaction

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2. Options and recommendation @

iii. Completing the Post Office investigation in each case and moving the
governance and management of the Scheme in-house

Publish a report in July on Horizon and the Mediation Scheme, including the Linklaters
letter and the independent assurance report. We disband the working group and end
Second Sight involvement. Pledge to investigate all the cases.

Benefits:

¢ Reduced administration costs saving millions of pounds

¢ Earlier Scheme completion (by end 2014)

* Ability to manage the Scheme processes and implement them effectively

« Manages the expectation gap through making clear to applicants the likely maximum
legal liability leading to more realistic mediations

* POcontrols timing of announcement and is prepared to manage consequent publicity
* Will release management time

* Completes all investigations and Scheme closed within current Parliament and before
general election

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2. Options and recommendation @

iii. Completing the Post Office investigation in each case and moving the
governance and management of the Scheme in-house (continued)

Risks:

* Highly likely to lead to one or two days of criticism in national media
* May cause applicants to abandon the Scheme in favour of litigation
« Removes independent element from process

* Increased risk (in the short term) of parliamentary scrutiny

* Adverse ministerial and stakeholder reaction

¢ Irreparable damage to relations with JFSA

These are all risks which are likely to materialise in any event and under any option. This
option, we believe, gives us the opportunity to manage these risks more effectively.

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2. Options and recommendation @

It is the view of the Programme, Legal and Communications and Corporate Affairs teams
that Option iii, where we move the Scheme in-house is the option most likely to meet the
needs of the Business.

We take this view in the light of the following:
The inquiry into the allegations raised by the JFSA and MPs was set up in summer 2012.

There has been no evidence in the two year period since of any systemic issue with the
Horizon computer system, the central contention of the allegations.

Alongside increasing costs (with £3.2m already spent on the programme), we now have
a body of evidence and other factors which suggest that we should amend the approach
taken — while ensuring that all applicants have their cases heard.

We could expend time, energy and cost pursuing a process which results in the
applicants and stakeholders being more dissatisfied at the end than they were at the
beginning.

From a reputation perspective, one or two days of negative media is likely to have less
impact than 18 months of coverage and speculation, which may damage the brand re-
launch.

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3. Comms plan, narrative & stakeholder handling @

Proposal

We publish a report in July on Horizon and the Mediation Scheme, including the
Linklaters letter and the independent assurance report. We disband the working group
and end Second Sight involvement. Pledge to investigate all the cases.

Narrative and media line to take

As a responsible business the Post Office is committed to listening and learning from its
people. As such in 2012, following allegations raised with us by some subpostmasters,
we set up an inquiry into the Horizon computer system. We appointed an independent
firm, Second Sight, to lead this inquiry.

In the two years since the inquiry began there has been no evidence of deficiencies with

the Horizon system. Indeed, Second Sight found no systemic issues in its report in 2013.

It has since been investigating cases and this work supports this finding.

We have also commissioned independent assurance work to examine the Horizon
system further and received assurance around the integrity of the system, which has
around 68,000 users and deals with more than six million transactions every day.

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3. Comms plan, narrative & stakeholder handling @

As part of our commitment to investigate cases raised with us by a small number of
subpostmasters we set up a Mediation Scheme in order to offer an opportunity for them
to have their cases heard. At the same time we launched a Branch Support Programme
to find ways of improving the support we offer the subpostmaster community.

Having fully investigated 26 of the 70 cases submitted, it has now become clear that few
of the cases submitted to us raise genuine issues with the Horizon computer system.
The mediation scheme will not therefore work in the interests of those who have
submitted cases.

We have therefore decided to move to a new approach.

We will investigate all cases and provide applicants with a report of their investigation to
help them understand what happened in their case.

When all investigations are completed we will consider what action is appropriate in
individual cases and what improvements can be made in the light of any findings.

This is consistent with the approach we have taken with the Second Sight Interim Report
through our Brach Support Programme.

We will publish a report when all investigations have been completed.

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3. Comms plan, narrative & stakeholder handling @

Stakeholder Key Message/handling

Minister Value for money considerations and potential play into general election timing. I

The longer the scheme runs, and the more dissatisfied applicants emerge, the greater the
risk of calls for a public inquiry and BIS select committee involvement.

MPs with cases could find themselves facing criticism where cases are not resolved in a
way which satisfies applicant.

Right thing for the business at time of massive change.

LL and other independent assurance/possible further independent role

Role for NFSP?

Duty of care to existing subpostmasters (and applicants ~ expectation gap)

If we continue the next 9 months will be littered with local negative stories
Protection against SS quality of work.

Independence remains in mediation process through respected mediators CEDR
All applicants will receive the full investigation report.

Legal options remain open to dissatisfied applicants.

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3. Comms plan, narrative & stakeholder handling @

In relation to Ministerial handling, other factors to consider are:

°

Discuss possible role with NFSP

Post Office takes lead in media handling

Plan communications opportunities for the minister
Timing of announcement

Network Transformation factors in key MP areas
Consider independent oversight by a third party

These factors could mitigate difficult communications factors and ease handling.

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3. Comms plan, narrative & stakeholder handling @

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Stakeholder

Key Message/handling

Media

Now to summer: Allegation of white wash by POL resulting in 1-2 days media coverage
(poss BBC, Computer Weekly as well as nationals such as Mirror, Mail as well as regional
print and broadcast) This will be drive by and include quotes from JFSA, MPs and
Applicants

Over the summer: Potential for media coverage driven by any Fol placed by JFSA on cost
of the scheme.

Summer — Christmas: Possible regional and national stories by those who continue to
follow the story e.g BBC and Computer Weekly and regionals

Run up to election: Potential remains for follow up around any announcement on IT&C
contract. Though hopefully story becoming of less interest in this scenario as no live cases.

Sir Anthony
Hooper

Our decision to make; we need to put applicants and business first
We have listened, given time and we need to act now.

We understand your view and of course this is no criticism of you.
How do we handle this in a way that helps you?

At end of day it’s a decision we need to take

Second Sight

Remind of obligations around confidentiality

Legal letter.

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3. Comms plan, narrative & stakeholder handling @

Stakeholder Key Message/handling

James Face to face meeting (AP and PV) — use letter as basis

Arbuthnot Play back concerns in last letter — you’ve been chasing about progress, I share your
concerns and now I am taking action
We are concerned about applicants which is why we are making the changes
Committed to investigations.
This and Branch Support Programme important legacy of your involvement (offer him
involvement in media release on initiatives delivered as result of programme).
We will publish a report as soon as investigations completed (and this will be before you
stand down as an MP)
If we don’t take this action, the work will not be completed before the general election.
Opportunity to share more information about Scheme progress with him and other MPs.
Update meetings with MPs which he could chair.

Other MPs Write to MPs with a constituent in the case and offer meetings.

engaged All cases still live so we must be mindful of that and keep information confidential
We are committed to investigating all cases.

JFSA Current arrangements haven't worked. We are committed to investigating every case,
including yours, with mediation where appropriate.

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3. Comms plan, narrative & stakeholder handling @

Stakeholder Key Message/handling

Applicants Letter to all PA and Applicants at the same time

Timescale of when to get CQRs in (4 weeks)

Case by case basis

Change in process to ensure timely investigation of their case

LL advice
Other NFSP — re-engage and reclaim support
Stakeholders Consumer Futures — assurances that no adverse impact for customers.
(consumer

futures, NFSP)

Professional Letter to all PA and Applicants at the same time
Advisors Timescale of when to get CQRs in (4 weeks)
We are committed to investigating all cases

Case by case basis

LL advice. Will be paid for work as committed.

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4. Media handling . &

Holding line for media

We have decided to make changes to the approach to this issue in the best interests of
applicants and the Post Office business.

We are committed to investigating all cases. It would be inappropriate to comment on
individual cases. We have confidence in the Horizon computer system and this has been
further consolidated through independent verification which has repeatedly shown no
systemic issues within it.

We have published a report setting out the position we have reached and will publish a
final report at the end of the Scheme.

This approach would attract some media coverage from outlets which have previously
covered the issue (last July it was covered in a 12 hour cycle by the BBC, with the most
high profile being the Today Programme and BBC News at 10. This would be a one day
news cycle.

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5. Conclusions @

* Hope this has been a useful session

* Recognise some of the difficulties and challenges it raises

* We believe that the recommended approach is in the best interests of the business
and the applicants and is deliverable in such a way that can be managed in relation to
media and stakeholders

* Subject to your views our next step will be to prepare papers making this
recommendation for the sub-committee

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Annexes @

Progress of the Scheme

Case MO22

Options to amend existing TOR

Financial modelling

Horizon definitions

Tony Hooper

. Justice For Subpostmasters Alliance

Second Sight

Timeline

Draft PO / Linklaters ‘Horizon report’ (separate word document, work in progress)

ACT ToeMNmMmIOD>

Alternative narratives I

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Case tracker: saci Group Case Overview

Case tracker: Working Group Case Overview Roport generated: “0210612014 00:48

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Annex A: Progress of the scheme
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Annex B: Case MO22 @ I

MO22:

First case to progress through the Scheme.

Second Sight have produced a draft report which Post Office (as a member of the
Working Group) have commented on.

Post Office will send a detailed response rebutting the inaccuracies in the report this
week.

The applicant and their advisor have reviewed the report and are also due to
comment on the report this week.

The Working Group has already approved the report for mediation (this occurred
prior to the recent Board discussion)

Post Office is actively trying to settle the case.

According to the agreed processes if no settlement is reached the case should
reach mediation by mid July.

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Annex C: Options to amend existing TOR @

Ministerial Commitments

* Working Party will consider all 47 cases bought forward by JFSA and MPs
¢ Independent figure will chair a review

* Independence of process

¢ Second Sight and JFSA Working Party

¢ Further work on cases must be independent

* Working Party must be independent

* Scheme open from 27th August — 18th November 2013

¢ Working Group is independent of Government and responsible for meeting interim
report recommendations

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Annex C: Options to amend existing ToR @

Detail of the scheme as published

There will be a Working Group

Second Sight and JFSA will be members

There will be an independent Chair

Second Sight will recommend whether a case should be mediated
Second Sight will investigate and provide a case review
Applicants will receive a copy of the case review

Mediation process will be independently administered

Post Office will pay for a professional advisor to articulate the applicants's case and
attend mediation.

Scheme will take in Criminal cases
Scheme will take in old cases

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Annex C: Options to amend existing TOR

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Working Group ToR (not published)

WG will oversee Scheme
Membership may change by agreement of WG currently PO, JFSA, SS and Chair
SS will be investigator and advisor

Scheme objectives to achieve mutual and final resolution of applicants concerns
about Horizon and associated issues.

Investigate proportionately and efficiently an applicant’s claims

Scheme must ensure value for money

WG may modify operations and: practices

WG should ensure cases are completed in a timely manner

Ensure all cases treated consistently

Proceedings will be confidential

SS are non voting, JFSA and POL are voting members, Chair has casting vote
Only confidentiality is legally binding

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Annex C: Options to amend existing ToR @

Journey to the WG and Scheme

Ministerial commitments following SS Report set out broad way ahead.
PO/JFSA/SS designed the Scheme and published details

WG established and agreed its ToRs (not published)

What changes could be made within existing ToRs?

Ministerial commitments relatively broad - some scope for change
Published Scheme but can be varied BY WG

Under TORs for WG PO would need agreement of WG to change - experience to date
shows reluctance to do so

Therefore:

if PO asks for change what happens if WG refuses?
where does that leave us?
would we be prepared to force the issue and break the WG?

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Annex C: Options to amend existing ToR

Ministerial Detail of the scheme . Management
Commitments as published Working Group ToR Cost Time overhead
Tighten the focus of Second Sight role (e.g. Save ard peeks on”
lose job 1, lose pre-CQR stage, switch to Yes Yes Yes £40K / month? Pay ane tigation oral Increase
piece rate) £1,500 per case. cases = 1 year +
Saving 10 weeks /
a ’ , case (pre- and SS- I Short term increase
Sn POL to ihneats fale to advisor to WG Yes No No e500 nth? investigation) I followed by long term
° Investigation of all decrease
cases = 5 months
Saving [X] weeks /
one , case (pre- Short term increase
Replace Second Signt Investigation role with Yes No No ee Investigation) followed by long term
Investigation of all decrease
cases = 30 weeks
‘ore d Decrease followed by
investigate every case before deciding - , spot increase at
approach to resolution (FOS?) Yes Yes Yes sald Nile decision
announcement
Avoid future WG
, as - decisions that
laliow POL. veto over Working Group decisions Yes Yes No Minimal nec rict Decrease
timeframes
Fj , , ‘ble I Short term increase
Publish independent assurance / Linklaters ‘Small due to possible I Small due to possible
biece Yes Yes Yes withdrawal of cases I withdrawal of cases I “owed! by long term

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Annex D: Financial modelling

POL Initial Complaints Review and Mediation
Forecast Cumulative Monthly Spend (£,000) for Current Position, Option 2 and ToR Variation

10,000

@ Current Position

@ Option 2
O ToR Variation

4900

3,000 +

Forecast cumulative spend (£,000)

Apra4 — Mayt@ Junta Judd Augad — Sep-t4Oce14@—Novdd—Dec-t4JandS—FebtS—MarlS Apr

Month

MayaS Jun UMS AugaS —Sep-as

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Annex E: Horizon definitions @

At the Board’s request we examined the impact of the Horizon definition on the cases
where we have received detailed case questionnaire responses (70 cases). We used
the definitions below::

* Core Horizon: ghost transactions; power/telecoms issues; recovery process; lost
data; Horizon terminal/hardware failures; remote access to Horizon

* Branch operating issues: cash and stock remittances; synchronisation with client
systems; other hardware failures (eg. pinpad/lottery/etc); branch accounting practices;
ATMs; paystation;

¢ Support: training; NBSC / HSD support; lack of investigation team; lack of audit trail;
allocation of risk; access to Horizon data; proof of errors

* Other: NT payments / branch relocations / issues with previous SPMRs / anything
else

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Annex E: Horizon definitions @

Results:
* 30 of the 70 have raised core horizon issues

* 59 of the 70 have referenced branch operating issues (38 of these cases do not menti
on core horizon issues).

* 67 of the 70 have raised support issues (only 2 cases relate to support issues only).
* 20 cases are criminal.
* 38 refer to incidents that occurred prior to 2007

We also examined the history of the wider Horizon definition and found it has been in us
e since 2012. Given this we do not recommend using this approach to reduce the caselo
ad facing the Scheme.

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Annex F: Tony Hooper @

The programme team have considered Tony Hooper's likely positioning in relation to
the Scheme and any possible modifications. In summary the team believe:

¢ That Tony will not remain as Chair of a radically modified Scheme if Post Office take
Control.

* That Tony will not assist Post Office if it looks to disband the Working Group and
end Second Sight’s engagement

¢ That he is unlikely to take a public stance against Post Office .

* That he believes that Post Office should accept that the Scheme will take around 18
months and that is normal for a Scheme of this type.

* That as Chair he will maintain the Status Quo rather than managing conflict
necessary to redesign the Scheme.

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Annex G: Justice For Subpostmasters Alliance @

Despite having collaborated with them since summer 2012 and given them prominent
role they stance against post office continues to harden

* AB has said that he is still looking for a public enquiry

* He has said he has not confidence that post office are going to act in good faith at
mediation

* He has said he is expecting to see evidence of post offices willingness to pay large
sums of money

* He said he is continuing to gather and use FOI and other channels to gain evidence
against post office

Summary

After 2 years of post office working closely with JFSA we have not been to establish
credibility with him. This position is likely to deteriorate over the course of the scheme
regardless of the option post office chooses

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Annex H: Second Sight @

The Post Office has a number of concerns with the state of the relationship with
Second Sight:

* They are a small firm who have struggled with the scale of the work they have taken
on

* They are expensive (60K pcm)
* Their work is both partisan and of poor quality

* We have written evidence of them coaching applicants and advisors to minimise any
admission of guilt.

* They have resisted all attempts to manage them and to restrict the Scope of their
work.

* Over the 18 months they have been reviewing Horizon they have not found anything
new

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Annex

: Timeline

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DATE EVENT
October 2008 Gartner report on Horizon Online (HNG-X)design
2009 JFSA established
11/05/2009 Computer Weekly article on deficits with Horizon system published
2010 Horizon upgarde
31/03/2010 AB sends a letter to Edward Davey MP, Minister for Postal Affairs (ED)
14/10/2010 Feedback AB and ED meeting.
States that: Horizon is the root cause of ALL issues for JFSA members.
« JFSA has no other agenda than to redress the wrongs that have inflicted upon them
February 2011 —_I Horizon integrity subject of 2 features on BBC's "Inside Out" programme
20/08/2011 ° 4 Notification of lawsuits (Letters of Claim ) being filed by SPIMRs against POL on Horizon system with the Courts.
« Letters of Claim cover above plus legality of SPMR contract (old one)
e Implies no future in working with ED's department.
15/12/2011 JA writes to Moya Greene (RMG CEO) regarding closure of Odiham Post Office and problems due to Horizon
January 2012 JA writes to Minister and Moya Greene regarding closure of Odiham Post Office due to "irregularities" and questioned
the Horizon system

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DATE EVENT

24/02/2012 - JA contacts Alice raising his concerns regarding Horizon and requests a meeting.

- Alice responds by agreeing to meet with JA

February 2012 —_I Internal Audit Assurance review of Key System Controls in Horizon

27/02/2012 JA chairs a meeting at Portcullis House to discuss Horizon

13/03/2012 JA meeting with Alice Perkins (AP) and Alwen Lyons

02/04/2012 AP letter to invite JA for a meeting

15/05/2012 + Received proposal from independent assurance to conduct a forensic investigation into Horizon. They had done

similar work in the banking and telecom sectors.

+ Their cost estimate was £250K.

17/05/2012 Meeting with James Arbuthnot, Oliver Letwin, Alice, Paula, Alwen, and Angela where they agree to appoint forensic
accounts
23/05/2012 AP agrees that MPs only should be briefed

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01/06/2012 NDAs with Second Sight signed
01/06/2012 Initial proposal from Ron Warmington received
(they propose a cost of £15k)
06/06/2012 Alice and Susan Crichton prepare a TOR for Second Sight to work on the investigation
07/06/012 - Meeting with Paula, Alice, Susan, Lesley, Alwen, Simon where the independent assurance and Second Sight options
are discussed.
+ Second Sight option was agreed as the best way forward
- TOR for Second Sight was also discussed.
07/06/012 Independent assurance make alternative proposals with lower costs.
08/06/2012 Alice makes some minor adjustments to the Second Sight TOR
11/06/2012 TOR goes to JA to approve
18/06/2012 - JA meets with MPs, with Post Office present.
19/06/2012 JA message to Tadge Channer at Shoosmiths explaining the MP meeting outcome on 18 June

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DATE EVENT
25/06/2012 Susan Crichton asks SS hold off until JA endorsement secured though SS will have a TC with Simon Baker and Rod Ismay
to begin work on understanding the helpdesk processes but hold off
04/07/2012 + Second Sight attend first meeting with JA.
+ The following MPs are also present: Andrew Bridgen MP, Mike Wood MP, Tessa Munt MP, Mary Glindon MP.
- Primary purpose was to get JA’s approval of Second Sight
05/07/2012 JA expresses that Alan Bates should have no power of veto over SS appointment or how the investigations ought to be
undertaken.
12/07/2012 + Second Sight attend second meeting with JA. This time Alan Bates and Kay Linnell are present.
+ At this meeting the subject of “how to carry the sub-postmasters with us" was discussed.
23/08/2012 Post Office sends Second Sight the first CD containing documents for the initial batch of cases
13/09/2012 lan Henderson attends a workshop with Fujitsu to get a technical understanding of Horizon
December 2012 I- ToR for the investigation issued jointly by POL and JFSA.
+ ToR published on JFSA website
+ Submission for SPMRs to submit relevant cases to JFSA and/or Second Sight opens

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28/02/2013 ° Deadline for SPMRs to submit issues to Second Sight for their Inquiry.
° No indication that these issues will automatically go into any future resolution plan.
25/03/2013 Meeting with MPs
25/03/2013 JA comments on lan Henderson's account of the MPs meeting on 25 March
01/05/2013 Captured CSC Data (7 accounts totalling 17.5Gb) sent to Second Sight
21/05/2013 . AB engages with POL (PV)
° Meeting request post-JA meeting. Kay Linnell (independent forensic accountant) to be invited as she was
monitoring SS work on behalf of JFSA.
° Wants to ensure Paula is updated on all SS work. Believes evidence is sufficient to show that many POL
prosecutions should not have happened.
08/07/2013 SS Interim report published on 4 cases reviewed
08/07/2013 POL announcement - 3 recommendations
“...1. The creation of a working party to work collaboratively to complete the review of cases started by Second Sight
last year. This would examine the themes identified by Second Sight and consider all cases brought forward by the
JFSA and MPs, together with any new themes which emerge from these cases. The JFSA have been invited to join this
working party..."

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09/07/2013 Jo Swinson reports to Parliament on SS Interim report
11/07/2013 AB Proposes barebones of scheme. Each case assessed on 2 areas.
Thematics/systemic failures & issues
Software/hardware problems
11/07/2013 . PV agrees to look at approach.
. Asked if '4a' is effectively (civil) early settlement
27/08/2013 . Case application opens for SPMRs (past & present).
.
. Post Office announces independent mediation scheme for subpostmasters
o  “...the Post Office, JFSA (Justice for Subpostmasters Alliance), and Second Sight, the independent
investigators, have formed a working group to collaboratively develop and monitor this scheme which is
available to current and former subpostmasters from 27 August 2013..."
September Case Review Mediation pack published
2013
24/09/2013 Paula Vennells, Alasdair Marnoch and Martin Edwards -Sir Anthony Hooper (AH) meeting
16/10/2013 Role of the Working Group proposed

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DATE EVENT

29/10/2013 POL announcement of Sir Anthony Hooper appointed as independent chair of working group overseeing initial
mediation scheme for Subpostmasters

",..The Post Office, JFSA (Justice for Subpostmasters Alliance), and Second Sight, the independent investigators, have
formed a Working Group to develop and monitor the scheme which is available to both current and

former subpostmasters..."

18/11/2013 Case application closes for SPMRs (past & present).

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PV and CA meeting with WG Chair
24/03/2014 PV meeting with JA
PV and WG Chair meeting with MPs
PV meeting with Second Sight
xx/03/2014 Linklaters commissioned to review legal risk
xx/03/2014 Linklaters report
xx/04/2014 independent assurance commissioned to review Horizon control environment
30/04/2014 independent assurance report produced though issues with report quality
xx/04/2014 Second Sight produce their first Case Reviews that are discussed at Working Group

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DATE EVENT
xx/05/2014 Factfile (Part 2) agreed
xx/05/2014 AB sends a letter directly to the Minister
xx/05/2014. Minister replies and letter notified to JA, SAH and Post Office
xx/05/2014 JA letter to AB
xx/05/2014 JA letter to PV regarding updating MPs
23/05/2014 PV meets Sir Anthony Hooper
xx/05/2014 M022 Case Review and Factfile sent to applicant and Post Office
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Annex J: Draft PO / Linklaters ‘Horizon report’ @

Separate word document - (work in progress)

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Annex K: Alternative Narratives Fe)

Continue with the Scheme as it is, i.e. current arrangements

Narrative

Subpostmasters are the lifeblood of our organisation and we want them to have faith in
our systems and processes. As a responsible business the Post Office is committed to
listening and learning from its people. As such in 2012, following allegations raised with
us by some subpostmasters, we set up an investigation into the Horizon computer
system.

In the two years since the investigations began there has been no evidence of system
issues with the Horizon system. We have also commissioned independent assurance to
examine the Horizon system further and received assurance around the integrity of the
system, which deals with 68,000 transactions every day.

As part of our commitment to investigate cases raised with us by a small number of
subpostmasters we set up the initial compliant and mediation Scheme in order to offer an
opportunity for them to have their cases mediated, where apprriate. At the same time we
launched a Branch Support Programme to find ways of improving the support we offer
the subpostmaster community.

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Continue with the Scheme as it is, i.e. current arrangements (Continued)

We are working hard to ensure that any cases submitted to the scheme are processed
as quickly as possible, and we remain committed to investigating all outstanding cases.

We will publish a report when all investigations have been completed.
If pressed on why taking so long?

Post Office has employed a dedicated team to ensure that applications are processed as
quickly as possible.

The Working Group needs to balance the need to progress cases through the scheme
with pace with the need to be thorough. The Post Office is a member of the Working
Group as is Second Sight, JFSA and the Chair of the Working Group is Sir Anthony
Hooper. We are working with all members of the Working Group to progress cases as
quickly as possible.

If press on how cases might be resolved?

The Post Office is committed to addressing the concerns raised by subpostmasters. Post
Office is keeping an open mind to all possibilities for resolution and mediation enables
the parties to explore any type of settlement which reflects the parties’ realistic positions

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Annex K: Alternative Narratives Ce)

Continue with the Scheme but seek to refine its work within the existing Terms of
Reference. Narrative - should WG fracture

VERSION 1 (If an action is taken by a WG party is public and we do not agree with)

We are surprised and disappointed by these comments/letter/action. They are not in the
spirit of the Scheme or the Working Group of which JFSA are a founding member.

The Scheme investigates very sensitive complaints and these investigations are on-
going. It is critical that no party to the mediation or the Scheme administration makes
any statement/take any action that harms the ability to resolve these cases. For that
reason it would be inappropriate to enter into a public discussion on the detail of the
Scheme.

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Annex K: Alternative Narratives @

Continue with the Scheme but seek to refine its work within the existing Terms of
Reference. Narrative - should WG fracture (continued)

This unfortunate and very regrettable intervention has the potential to undermine the way
in which the Working Group operates. Therefore, we will be working with the
independent Chair, Sir Anthony Hooper, who is responsible for overseeing the Scheme,
to agree a way forward.

Post Office has been working hard to ensure that any cases submitted to the mediation
scheme are investigated as thoroughly as possible, and we remain committed to
resolving all outstanding cases. This remains our primary concern.

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Annex K: Alternative Narratives )

Continue with the Scheme but seek to refine its work within the existing Terms of
Reference. Narrative - should WG fracture

VERSION 2 (if action is taken within WG by a member we are not happy with)

As a responsible business, the Post Office is committed to listening and learning from its
people. This is why in 2012, following allegations raised by some Subpostmasters, we
commissioned an investigation into the Horizon computer system. We appointed an
independent firm, Second Sight, to lead this inquiry.

In the two years since the investigation: began, no evidence of systemic issues with the
Horizon system have been found. Indeed, Second Sight found no systemic issues in its
report in 2013. It has since been investigating cases and this work supports this finding.

We have also commissioned independent assurance to examine the Horizon system
further and received assurance around the integrity of the system, which is used by
68,000 people, processing over six million transactions every day.

As part of our commitment to investigate cases raised by a small number of
Subpostmasters, we set up the Initial Complaint and Mediation Scheme. At the same
time we launched a Branch Support Programme to find ways of improving the support
we offer our Subpostmaster community. mam

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Annex K: Alternative Narratives @

Continue with the Scheme but seek to refine its work within the existing Terms of
Reference. Narrative - should WG fracture (continued)

VERSION 2 (if action is taken within WG by a member we are not happy with)

Having fully investigated 26 of the 70 cases submitted, it is clear that few of the cases
submitted to us actually revolve around the Horizon computer system.

We would like to thank the JFSA and Second Sight for their input into the Scheme and
would like to reassure applicants that we will continue to investigate all cases and
provide a thorough report of their investigation.

When all investigations are completed we will consider what action is appropriate in each
case and what improvements can be made in the light of any findings.

This is consistent with the approach we have taken with the Second Sight Interim Report
through our Branch Support Programme.

We will also publish a report when all investigations have been completed.

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