POL00118101 - Appendix 3 - Offender reports and Discipline reports: “Compliance Guide to the Preparation and Layout of Investigation Red Label Case Files” - undated (date taken from parent email)

Evidence on official site

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Post Office Ltd

Security Operations Team

Compliance

Guide to the Preparation and Layout of Investigation Red Label Case Files.

Offender reports & Discipline reports

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GUIDE TO THE PREPARATION OF SUSPECT OFFENDER REPORTS

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The purpose of the Suspect Offender report is to provide a storyboard of the events and
evidence of an investigation to the relevant Stakeholders and Criminal Law Team (CLT) to
enable a decision to be made as to the future conduct of a case.

This guide is produced for all Security Operations Managers, irrespective of location, so
those in Scotland and Northern Ireland will need to interpret some of the content accordingly,
e.g. for Scottish cases read ‘Exhibits’ as ‘Productions’.

The general principle is that the description of investigation activities should read in the
sequence they occurred so it may be necessary to re-order the paragraphs or elements within
them. The following is only a guide to the preparation of an offender report and accordingly
relevant additional information should be included as appropriate.

A single report is required in cases where more than one suspect offender is identified and
interviewed as being involved in the same offence, however a separate preamble must be
included for each individual.

The text element of the Suspect Offender report should commence immediately underneath
the preamble/s. I The Header/Footer on the report should read ‘POST OFFICE® LTD
CONFIDENTIAL — INVESTIGATION, LEGAL’.

Where reference is made to evidence or property in the body of the report, the item reference
number (i.e. AA/1) should follow the description. If documents referred to in the report are
paged into the body of the file, or are associated at an appendix, reference must be made to
their location.

Use:

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The aim of this document is to give guidance to Security Operations Managers and Team
Leaders on the current compliance standards for the preparation of red label case
offender reports and discipline reports.

Contents:

1. Offender report:

Preamble.
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1.1. Header and footer.
1.2 Preamble as policy template
1.3 Correct heading.

Investigation Background.

1.4 Investigation Background reported.
1.5 Inquiries conducted reported.
1.6 Planning & Operation

Offender Interview Details.

Offender approach reported.

Reference to note book entry made.

Details of suspect interview and searches as applicable.
Preliminaries.

Admissions/denials identified and reported.

Details to identify and recover loss and assets.
Interview concluded and tape details.

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Post Interview.

Period of offences identified.

Assessment of evidence available to support charges.

Details of domestic and financial details of offender/s.

Reliability of witnesses.

Outstanding inquires confirmed.

Loss to Post Office LTD. Reported.

Accounting aspects status reported.

Subsequent enquiries and actions to identify and recover loss and assets.
NPA forms and antecedents.

Copy reports and tape summaries etc.

Details of failures in security, supervision, procedures and product integrity.
Concluding paragraph.

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2. Discipline report:

Preamble.

2.1. Header and footer

2.2 Preamble as policy template
2.3. Correct heading.

Investigation Background.

2.4 Investigation Background reported.
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2.5

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Inquiries conducted reported.

Offender Interview Details.

Details of suspect interview

Admissions/denials identified and reported.

All allegations in report substantiated and facts only supported.
Details to identify and recover loss and assets.

No reference to files or documentation that are not associated

Post Interview.

2.11
2.12
2.13
2.14
2.15

1.

Period of offences identified.

Outstanding inquires confirmed.

Loss to Post Office LTD. Reported and accounting aspects status reported.
Details of failures in security, supervision, procedures and product integrity.
Concluding paragraph.

Offender report:

Preamble

1.1

Headers and Footer- “POST OFFICE LTD. CONFIDENTIAL INVESTIGATION,

LEGAL”

1.2

Preamble as policy template (See below)
POLTD/0405/

OFFENCE

(Indicate here type of offence — i.e. Theft, False Accounting, Money Laundering...)

Name:

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Rank: Identification (Numbers 1 to 7
Code: only)
Office: FAD Code
Age: Date of Birth:
Service: Date Service
Commenced:
Personnel Printout: At Appendix: C
Nat Ins No:
Home Address:
Suspended/Contract for (date) on the authority of (managers name)
Services Suspended: (Delete either Suspended/Contract for Services
Suspended)
Handed into custody: (Date & name/rank of authorising officer)
(Delete rows if not applicable)
At: (Name of police station)
(Delete rows if not applicable)
Charged: To appear at (time) on (date) at (Court)
(Delete rows if not applicable)
To be prosecuted by: Royal Mail Group (including Post Office Ltd)/Crown
Prosecutor
Designated Prosecution Dave Pardoe, Senior Security Manager
Authority:
Discipline Manager: (Managers name)

1.3. Correct heading
To addressee, this is currently “Royal Mail Group Ltd Criminal Law Team”

Investigation Background

1.4 Investigation background reported.

This should cover details of the office, or location, of the offence/s with details or
information current or historical relating to the office or persons employed or

residing there. Give a brief description of the office involved,
urban/rural/small/large.

State details of sub postmaster and number of assistants employed.

e.g.

Give particulars of the suspected offence/s and how it/they came to notice including
items such as whom they concern or identify. State the loss to Post Office LTD. or

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other agency at the time of inaugural report. A copy of any reports/documents
should be referred to and associated at the relative appendix.

An explanation of correct procedures should be given in cases where it is felt that
information about the POLTD. process, may be of use to the Criminal Law Team.

1.5 Inquiries conducted reported.
Details of the inquiry undertaken by the investigator, to include items such as
evidence gathering, analysis, observations, tests and witness evidence gained pre
“offender interview”. The outcome of enquiries should be explained, together with
the conclusions reached by the investigator.

1.6 Planning & Operation
Reference must be made regarding applications for testing/surveillance operations,
with signed copies of testing/RIPA applications, Planned operation Risk
Assessments (PORA) forms, associated at appendix ‘B’. Forms and outputs for
other criminal checks should also be associated at appendix ‘C’.

NB: The exception to this is where a positive result has been obtained in relation to
a PNC check. In these circumstances the conviction details must be placed within
a sealed envelope, marked ‘In Confidence’ and be associated at appendix ‘C’.

NB: PORA must be completed in all cases that do not involve same day
apprehension/searches/interviews. Where immediate enquiries are made, verbal
risk assessment activities must be undertaken (by Investigator or a colleague) as a
minimum and results/details recorded in note book.

Offender Interview Details.

1.7. Offender approach reported.
This should contain detail of the investigator’s first approach to any suspect/s and
cover the date, time, location, introduction, explanation, caution, request to attend
voluntary tape-recorded interview and completion of the GS001 side A and GS005
if done at this stage. There are of course many variations and additions to this for
example if the police are involved or if the suspect/s make any admissions or
significant statements. All need to be reported at this stage in the offender report

1.8 Reference to note book entry made.
PACE advises that note-book entries must be made for each suspect offender
interview. Any such entry must detail date, time, place, subject and duration of
interview along with master tape number. In addition, note-book entries must be
made to account for conversations, observations and factual details not captured
by audio tape (or prior to commencing interview) and in particular to cover
prolonged periods between engaging suspect offender and eventual interview.

1.9 Details of suspect interview and searches as applicable
This should contain details of the date, start time, location, attendance
(investigation managers, suspect, legal representation Post Office friend and any
other) GS001 (not Scotland) and the GS003. Reference should be made to any

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tape transcription or summary if produced and the page numbers attributed to
either. For example:

At 0900 hours on 23 January 2005, I interviewed (name) at Leeds Branch Office.
Present throughout the interview were Mr Alan Smith, Investigation Manager and
Mr James Lawyer, Solicitor. The interview was tape-recorded and a tape summary

has since been prepared, a copy of which is now at pages ....... to...
Copies of the working tapes are enclosed at appendix “B”. I have retained the
Master tapes.

A copy of the form GS001 (item no. AA/1) is associated at appendix ‘B’.

Reference should also be made in this section to the outcome of searches
conducted during the interview process. Copies of search forms are to be
associated at appendix ‘B.

NB: Searches are mandatory for all losses. There are two main reasons for this; 1)
to identify, record and recover assets, 2) to secure any further evidence that may
assist the criminal investigation. Any decisions not to conduct searches must be
authorised by Team Leaders and such decisions recorded (in report and/or
notebook). Where a risk materialises that warrants safety concerns (e.g number of
individuals on the premises) police involvement should be sought.

1.10 Preliminaries.
This should contain brief, relevant, preliminary details asked at the start of the
interview and could include, career histories, employment, training, responsibilities,
security awareness and procedural questioning.

1.11 Admissions/denials identified / reported and points to prove covered.
This should contain admissions and denials made during interview and in particular
those relating to the offences listed in the preamble to the report (to include
amounts and offence dates of any admission). The section should be more
detailed if the investigator is not submitting a supporting tape transcription or tape
summary.

1.12 Details to identify and recover loss and assets.
This should contain details resulting from any questions and answers asked during
interview, which relate to or have an impact on identifying and recovering loss and
assets. A Financial Evaluation Sheet (FES) must also be completed as fully as
possible and submitted to the Financial Investigator within 72 hours of interview.
Evidence of assets and financial documentation are of paramount importance in
relation to asset recovery.

1.13 Interview concluded and tape details or custody record.
This should contain the time the interview concluded and where the tapes are now
stored. Reference should be made here to any custody records if applicable.

Post Interview.

1.14 Period of offences identified.
State the start and end date of offence/s detailed in preamble to report.

1.15 Assessment of evidence available to support charges.
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This should contain the investigator’s assessment of the evidence available to
support the offences detailed in the preamble to the report it should identify
conflicting evidence statements or admissions and include comment on demeanour
of offender, an assessment of their response to questioning, whether full scope of
offence has been admitted to and suggested reason as to why crime committed
(i.e. greed, gambling). It may contain opinion and any other matters not listed
above which are substantial and relevant. Recommend prosecution or,
alternatively, give an explanation why prosecution is not advised.

NB: Where appropriate, reference should be made to evidence of Money
laundering offences. Where Money Laundering is evident, this enables Financial
Investigators to utilise investigative powers within the Proceeds Of Crime Act
(POCA) 2002.

1.16 Details of domestic and financial details of offender/s.
This should contain any domestic, health and financial details including any
mitigating circumstances of offender/s gathered, at or post interview, which are not
readily found in any personal printout associated and which may have an impact on
prosecution and or financial recovery considerations.

1.17. Reliability of witnesses.
This should contain the investigators assessment as to reliability of any relevant
witness or witness statement in the case.

1.18 Outstanding inquires reported.
Reference should be made to any necessary inquires yet to be made, along with a
reasonable assessment as to there progress and or completion.

1.19 Loss to Post Office LTD. Reported.
State the overall loss to the business (after allowing for any recovery) caused by
the offender's wrongdoing. Also state the actual loss to the business if different.
Comment on any restitution received from offender, its disposal or location and the
‘without prejudice’ receipt.

1.20 Accounting aspects status reported.
State any accounting aspects dealt with or to be dealt with.

1.21 Subsequent enquiries and actions to identify and recover loss and assets.
This should contain details resulting from any subsequent investigations, which
relate to or have an impact on identifying and recovering loss and assets (GS045).
Reference must also be included as to whether the papers have been referred to a
Post Office Ltd Financial Investigation Manager, who should be engaged
throughout the end to end process of the investigation.

1.22 NPA Forms/Antecedents:
Refer to completion of NPA and antecedent documentation and where appropriate
the submission of them to ClO. Copy documents are to be associated at appendix
Cc.

1.23 Copy Reports/Tape Summaries, etc.:
State what has been submitted electronically to Casework and say where other

relevant documents are to be found, or give their disposal.
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1.24 Details of failures in security, supervision, procedures and product integrity.
This must be a comprehensive list of all identified failures in security, supervision,
procedures and product integrity it must be highlighted bold in the report.
Where the investigator concludes that there are no failures in security, supervision,
procedures and product integrity a statement to this effect should be made and
highlighted in bold.

The ‘Procedural Failings’ form (within the ‘All In One Case Raise’ spreadsheet)
should also

be completed within 48 hours of interview and circulated to relevant Stakeholders.

One of the Stakeholders is Crime Risk, who are responsible for capturing emerging

crime trends and/or prevalent failings that contribute to fraud within the business.

1.25 Reason for File Submission
Explanation as to reason for submission of case file.

2. Discipline report:
Preamble.

2.1 Header and footer “POST OFFICE LTD CONFIDENTIAL: INVESTIGATION,
PERSONNEL”

2.2 Preamble as policy template. (See above)
2.3 Correct heading. “Discipline Manager”
Investigation Background.

2.4 Investigation Background reported.

This should cover details of the office, or location, of the offence/s with details or
information current or historical relating to the office or persons employed or
residing there. Care must be exercised when detailing information relating to how
the suspected offences came to attention and in particular advice should be
sought, from Criminal Law Team, prior to including any information that has not
been divulged to the suspect offender as part of the enquiry proper. In particular,
advice must be sought when dealing with the issue of Covert Human Intelligence
Sources or Human Intelligence Source.

2.5 Inquiries conducted reported.
Details of the inquiry undertaken by the investigator, to include items such as
evidence gathering, analysis, observations, tests and witness evidence gained pre
“offender interview”. However, this again must be restricted to those details which
have been disclosed at interview and advice must be sought prior to including any
investigative practices / techniques not previously disclosed to the suspect.

Offender Interview Details.

2.6 Details of suspect interview.
This should contain details of the date, start time, duration, location, attendance
(Investigation Managers, suspect, legal representation Post Office friend and any
other). Reference should be made to the number of tapes used, and as to whether

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interview tape transcription / précis is associated or, if not, where copies of the
tapes can be obtained.

2.7. Admissions/denials identified and reported.
This should contain any admissions and denial made during interview. Reference
should be made to amounts and dates of any admission. The section should be
more detailed if the investigator is not submitting a supporting tape transcription or
tape summary.

2.8 All allegations in report substantiated and facts only supported
It is for the investigator to ensure that any allegation in the report is substantiated
by evidence or admissions made during the interview.

No supposition, inference or personal, unsubstantiated, comment should be
included within the report.

2.9 Details to identify and recover loss and assets.
This should contain details resulting from any questions and answers asked during
interview, which relate to or have an impact on identifying and recovering loss and
assets.

2.10 No reference to files or documentation that are not associated.
It is for the investigator to check the discipline report to ensure that all “opinion”
has been removed along with references to files or documentation associated to
the offender report, which are not necessarily associated or attached to the
discipline report.

Post Interview.

2.11 Period of offences identified.
State the start and end date of offence/s detailed in preamble to report.

2.12 Outstanding inquires confirmed.
Reference should be made to any necessary inquires yet to be made, along with a
reasonable assessment as to their progress and or completion. Again, care must
be exercised in revealing here any information that the investigator would not wish
immediately relayed to the suspect offender; examples would include fresh lines of
enquiry that the investigator may wish to test and challenge by way of re-interview
or actions relating to the use of POCA powers.

2.13 Loss to Post Office LTD. Reported and accounting aspects status reported.
State clearly any loss to Post Office LTD along with the status of any accounting
aspect to be dealt with.

2.15 Details of failures in security, supervision, procedures and product integrity.
This must be a comprehensive list of all failures in security, supervision,
procedures and product integrity it must be highlighted bold in the report. Where
the investigator concludes that there are no failures a statement to this effect
should be made and highlighted in bold.

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Significant failures that may affect the successful likelihood of any criminal action
and/or cause significant damage to he business must be confined, solely, to the
confidential offender report. Care must be exercised when including failures within
the Discipline Report as obviously this is disclosed to the suspect offender and may
have ramifications on both the criminal elements of the enquiry, as well as being
potentially damaging to the reputation or security of the business. If you are in any
doubt as to the appropriateness of inclusion or exclusion you must discuss with
your Team Leader.

Reason for File Submission
Include here the reason for submitting the discipline report.

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