POL00123004 - Email from Belinda Crowe to Andrew Parsons, Andy Holt and Angela Van-Den-Bogerd re Sparrow - text for CEO’s report

Evidence on official site

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From: Belinda Crowe[IMCEAEX-
_O=MMS_OU=EXCHANGE+20ADMINISTRATIVE+20GROUP+20+28FY DIBOHF23SPDLT+29
_CN=RECIPIENTS_CN=BELINDA+20CROWE79B93F 1 1-569F-4526-A078-
F5B4958A8917220@C72A47 ingest.local]

Sent: Mon 21/10/2013 11

To: uk];
Ce:
0.uk]; Belinda
Subject: RE: Sparrow - text for CEO's report [BD-4A.F1D20472253]
Thanks Andy

This looks about right to me. And in light of the subject matter, I would say that level of detail is about right. I’ve
added one bit in red but want to confirm exactly what has been said to them with Susan Crichton.
Copying Angela in case she has any comments on the two bullet points:

e Adedicated internal POL team has been setup to streamline SS' investigation process.

Next steps
e¢ Continue to migrate the investigation of cases from SS to the internal POL team.

Angela may also have comments on other points made.
Best wishes

Belinda

Belinda Crowe
148 Old Street, LONDON, EC1V 9HQ.

From: Parsons, Andrew {
Sent: 21 October 2013 10:43
To: Andy Holt
Cc: Matthews, Gavin; Belinda Crowe; Jarnail A Singh
Subject: RE: Sparrow - text for CEO's report [BD-4A.FID20472253]

Andy
Draft answers to Martin's questions below — too much detail or not enough?
1. Would be good to include a line on the review of prosecutions policy — i.e. just updating the Board that work

on this is progressing and they will see a paper at the next ARC or Board. Following yesterday’s discussion,
please can we confirm the arrangements?

Brian Altman QC's review of the prosecution policy is being finalised. The report was originally due on 31 Oct
but should now be ready by 25 Oct. The review will address the question of how POL may wish to approach
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prosecutions in the future. [ANDY — I'm not sure what the board process is for this report. Hugh mentioned
that there might be an extraordinary ExCo to review the report before it goes to ARC or the Board.]

I think we should have a few lines on compensation policy, as this is very much on the Board’s mind given the
link to costs and outcomes. Please can we have some sentences to explain what work has been done so far,
the initial conclusions and the next steps to develop the policy in more detail?

Awritten Settlement Policy for the Scheme is being produced. The Policy will explain (1) the process for
refining our understanding of the costs and outcomes of the Scheme and (2) the parameters for where/how
POL may be prepared to settle individual cases. This policy is being developed to ensure that a consistent
approach is taken to each case and to ensure that those attending each mediation on behalf of POL have a
clearly defined mandate for what may be offered by way of settlement. Meetings have been held with
internal stakeholders and external lawyers are preparing a first draft Policy. This Policy will be reviewed and
approved by the Sparrow Steering Group before submission to ExCo / the Board.

I think the Criminal Case review process needs more explanation, in particular an explanation of the
implications of the 11 cases where disclosure has been recommended. (Even if we don’t want to include too
much on this in the text itself, useful for Paula to have in her background notes). Can we also have an
explanation of the high level conclusions of the Brian Altman review, along the lines outlined by Rodric
yesterday?

[Jarnail / CK to amend / complete]

Brian Altman QC's First Review has now been received. This First Review looked into POL's compliance with
its prosecution duties in light of Second Sight's findings — in particular, it considered POL's legal duty to ensure
that SS' findings were fully disclosed to any person who is currently being or has previously been prosecuted
by POL. Mr Altman QC concluded that POL is complying with its duties and that the approach adopted by the
prosecution team was "fundamentally sound". This report gives POL good grounds to resist any formal
external review of its historic prosecutions (ie. by the Criminal Cases Review Commission).

Further to yesterday’s discussion, please could we also have some lines for background speaking notes on the
process/outlook for resolving SS’s involvement in the WG etc?

[ANDY / BELINDA — thoughts on the below?]

Work is continuing on managing SS out of the Scheme. In general, SS' role is gradually being reduced until
they can be removed entirely. This work has already begun:

e  SS' role has been reduced to investigating specific cases — under its original scope of work SS was entitled
to look broadly at any aspect of Horizon.

e SS is no longer required to give a definitive view on the efficacy / reliability of Horizon — it only needs to
offer its best assessment of each Subpostmaster's case.

e Susan Crichton has explained to SS that the aim is for their involvement will not extend beyond the end of
the calendar year, and this has also been communicated to the Independent Chair of the Working Group.

e Adedicated internal POL team has been setup to streamline SS' investigation process.

Next steps
e Use the appointment of Sir Anthony to remove the need for SS to formally vote at Working Group

meetings — thereby moving them to an advisory role only.
¢ Continue to migrate the investigation of cases from SS to the internal POL team.
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5. Would be good to put in a rough date (or at least month) for the first meeting of the Branch User Forum. Late
October? Early November? Or at least by end November?

[One for you Andy]

6. At what point do we expect the first cases to go to mediation?
The first few selected cases should hopefully go through mediation before Christmas. The majority will be Q1
2014. The more complicated cases are likely to be held off until Q2 2014 (so that POL has a good track record

before taking on these difficult cases)

7. Finally, as mentioned to Charles, Paula/Chris will need a few background notes on projected costs and
accounting arrangements.

[One for you Andy — but happy to discuss]

Andrew Parsons
Senior Associate
for and on behalf of Bond Dickinson LLP

Follow Bond Dickinson

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www.bonddickinson.com

From: Andy Holt
Sent: 21 October 2
To: Parsons, Andrew

Subject: RE: Sparrow - text for CEO's report

Hi Andy

Martin wants this back asap so something by early afternoon would we great.
Thanks

Andy

From: Rodric Williams

Sent: 20 October 2013 23:49
To: Andy Holt .
Cc: ‘andrew.parsons_
Subject: Fw: Sparrow - text for CEO's report

Andy - I've asked Andy P to help respond to Martin's points.

Kind regards, Rodric
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From: Martin Edwards

Sent: Friday, October 18, 2013 03:25 PM

To: Andy Holt

Cc: Belinda Crowe; Rodric Williams; Chris Aujard; Hugh Flemington; Angela Van-Den-Bogerd; Charles Colquhoun
Subject: Sparrow - text for CEO's report

Andy

Thanks very much for this. A few questions/requests for further information (which copy recipients may be better
placed to answer).

1. Would be good to include a line on the review of prosecutions policy — i.e. just updating the Board that work
on this is progressing and they will see a paper at the next ARC or Board. Following yesterday’s discussion,
please can we confirm the arrangements?

2. I think we should have a few lines on compensation policy, as this is very much on the Board’s mind given the
link to costs and outcomes. Please can we have some sentences to explain what work has been done so far,
the initial conclusions and the next steps to develop the policy in more detail?

3. I think the Criminal Case review process needs more explanation, in particular an explanation of the
implications of the 11 cases where disclosure has been recommended. (Even if we don’t want to include too
much on this in the text itself, useful for Paula to have in her background notes). Can we also have an
explanation of the high level conclusions of the Brian Altman review, along the lines outlined by Rodric
yesterday?

4. Further to yesterday’s discussion, please could we also have some lines for background speaking notes on the
process/outlook for resolving SS’s involvement in the WG etc?

5. Would be good to put in a rough date (or at least month) for the first meeting of the Branch User Forum. Late
October? Early November? Or at least by end November?

6. At what point do we expect the first cases to go to mediation?

7. Finally, as mentioned to Charles, Paula/Chris will need a few background notes on projected costs and
accounting arrangements.

For the additional text which needs to go into the report itself it would be good to have this as soon as possible.
We’ve got more time for the background notes (would need these finalised by the end of next week).

Give me a shout if useful to discuss.

Thanks,
Martin

From: Andy Holt

Sent: 16 October 2013 16:21

To: Martin Edwards

Subject: RE: Information for Paula's 1:1 with Chairman

Martin

Does this look like the right sort of level/content. I have tried to stick to the themes of the previous update so this is
relevant to the board. I have not mentioned next steps on compensation policy as I couldn’t find a reference to this in
the last paper but for you info I would expect another iteration next week before we can look at how this works with
a sample of current submissions. We will bring this back to the steering board for review in 2 weeks.
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Project Sparrow Update

The Improvement Work stream has completed the ‘as is’ experience for subpostmasters. The team are now
progressing with the “to be” picture and identifying the gaps and issues as well as the activities that will be needed get
us to our future model. Members of the programme are now tasked with articulating the vision, behaviours and
outcomes they as leaders should be looking for from their teams so that they address both cultural challenges as well
as the improvement activities needed to achieve the outcomes required.

The Mediation Scheme has now received 46 applications from subpostmasters since it was opened at the end of
August. 37 of the application have been accepted on to the scheme and await full submissions from the
subpostmasters. The remainder require additional information, need to exhaust internal Post Office processes or are
in legal processes which exclude them from joining at this time. The application closure date is the 18"° November, we
will then have all the cases we will need to manage in the initial scheme. We are in the final stages of appointing Sir
Anthony Hooper as the independent chair and expect to have him in place by the end of October.

The Criminal Case reviews continue with our external firm of solicitors. They have completed several sifts of past
cases and have recommended disclosure on 11. Brian Altman QC’s review is also progressing well and it is expected
to complete as planned by the end of October.

Having approved the terms of reference for the Branch User Forum we are now recruiting subpostmasters to
participate on the forum so that the initial meeting can convene.

Regards

Andy

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