POL00201708
POL00201708
Linklaters Linklaters LLP
‘One Silk Street
London EC2Y 8HQ
Telephond 1
Facsmie, GRO I
jonathan. swi
Belinda Crowe and David Oliver
Post Office Limited
148 Old Street
London EC1V 9HQ
By Email 10 March 2014
Our Ref Christa Band/ Jonathan Swil
Dear Belinda and David
Outline of report on Initial Complaint Review and Mediation Scheme
As requested, we enclose a draft outline of the report the Board of Post Office Limited (“Post Office”) has
commissioned us to prepare in connection with the Initial Complaint Review and Mediation Scheme (the
“Scheme’).
The outline sets out the facts and issues we envisage the report will cover and its general structure. The
final report may differ in some respects from the outline, including to the extent necessary having received
your comments on the report before it is finalised. However, the outline should serve as a reliable guide of
what the final work product will be.
In preparing the report we will bear in mind the following comments made by the Board as to the reason
for our commission and its expectations as to the matters on which we will report:
“In respect of each individual application, the project team were taking extensive advice about
Post Office’s legal potential exposure. However, it was acknowledged that, in light of the facts
now available, and the projected level of claims and costs, it would be sensible to commission
more generic legal advice on the overall level of legal and financial exposure (taking into
account the possibility of class actions) and steps that could be taken to mitigate any exposure
including considerations of alternative structures that might be available to deal with the
mediation cases. Such advice should have regard to alternative dispute resolution mechanisms,
such as the Financial Ombudsman Service.”
In particular, our report will focus on what we understand are the two key aspects of the commission:
e — the legal and financial risks arising from and associated with the Scheme in its current form; and
«the issues on which we believe Post Office will need to form a view in order to resolve its current
concerns about the Scheme and proposals for how it might do so, including any alternatives to
the Scheme.
We look forward to receiving any comments Post Office has on the outline document.
This communication is confidential and may be privileged or otherwise protected by work product immunity.
Linklaters LLP Is a limited liability partnership registered in England and Wales with registered number 0C326345. It is a law firm authorised and regulated by
the Solicitors Regulation Authority. The term partner in relation to Linklaters LLP is used to refer to a member of Linklaters LLP or an employee or consultant of
Linklaters LLP or any of its affliated firms or entities with equivalent standing and qualifications. A list of the names of the members of Linklaters LLP together
with a list of those non-members who are designated as partners and their professional qualifications is open to inspection at its registered office, One Silk
Street, London EC2Y 8HQ or on www.linklaters.com and such persons are either solicitors, registered foreign lawyers or European lawyers.
Please refer to vww.linklaters, com/regulation for important information on our regulatory position.
[ DOCPROPERTY "DOCUMENT NUMBER" )/[ DOCPROPERTY "VERSION" }/[ DOCPROPERTY "LAST MODIFIED" }
POL-BSFF-0039771
POL00201708
POL00201708
Linklaters
Yours sincerely
Christa Band
Partner
[DOCPROPERTY "DOCUMENT NUMBER" [I DOCPROPERTY "VERSION" Jf DOCPROPERTY "LAST MODIFIED"] — Page [
PAGE ] of [ SECTIONPAGES ]
POL-BSFF-0039771_0001