POL00267481
POL00267481
No. I Work Deliverable By When Owner / Manager
Stream
1.1 I Legal Determine whether the Judgment has any impact on the Horizon Trial which ASAP but no later than Counsel: DCQC + TRQC
begins on Monday Close Saturday 9 March Junior: Owain Draper
POL Lawyer oversight: Ben Beabey
1.2 I Legal Establish: ASAP but no later than Counsel: DCQC
i) the basis and merits of an Appeal; Close Sunday 10 March WBD: Victoria Brooks + Dave Panaech
ii) the optimal timing of that appeal; and POL Lawyer oversight: Ben Beabey
iii) whether there are grounds / an ability to prevent the Judgment from
being handed down and or its findings from ‘having teeth’ pending an
appeal being heard.
1.3 I Legal Produce a legal analysis of the Judgment and the impacts it has on how POL ASAP but no later than Counsel: DCQC
operates today (commercially and operationally); mapped to the risk assessment Close Sunday 10 March WBD: Victoria Brooks + Dave Panaech
table used for contingency planning. Especially in terms of the recoverability of POL Lawyer oversight: Zoe Brauer
losses.
1.4 I Legal Determine whether it is possible to seek consent from the Judge to share the draft I ASAP but no later than Counsel: DCQC
Judgment with our Shareholder. Close Sunday 10 March WBD: Victoria Brooks + Dave Panaech
POL Lawyer oversight: Ben Beabey
1.5 I Legal Provide advice on whether we can do anything immediately in order for the ASAP but no later than Counsel: DCQC
Branch Trading Statement to be relied on as a statement of account. Close Sunday 10 March WBD: Victoria Brooks + Dave Panaech
POL Lawyer oversight: Ben Beabey
1.6 I Legal Identify and submit the factual inaccuracies included within Judgment. No later than Wednesday Counsel: Gideon + 2" Junior
13 March POL Lawyer oversight: Ben Beabey
1.7 I Legal Provide a ball park cost for: Close Friday 15 March WBD: Andrew Parsons
- The Appeal
- Trial 3 (November)
- Trial 4 (March ’20)
-__ Mediation
2.1 I Ops Once in receipt of the legal analysis at 1.7; finalise and execute the relevant Ongoing. Execution cannot I POL: Julie Thomas & Amanda Jones
elements of the contingency plan to allow us to operate, trade and manage cash,
on the assumption that we are unable to enforce the contract. Focus on:
- suspension process
be before being in receipt
of 1.7.
WBD: Rachel Scott + Paula Bartlett
POL Lawyer oversight: Zoe Brauer
POL00267481
POL00267481
- contracts / clauses within contracts
- Ability to sign up new agents / partners on existing contracts
- Ability to ask Postmasters to accept accountability for cash before
providing it to them?
- Compliance (cash declarations, balancing etc)
- Cash management (identification of losses, analysis)
- Managing new issues transparently, and quicker
- Clearing any backlog of queries asap
-__ Allocation / redistribution of resources accordingly
3.1 I Comm I Determine whether maintaining ‘no comment’ remains the correct position in No later than Wednesday POL: Mark Davies & Mel Corfield
s response to media enquiries 13 March WBD: Rachel Scott
POL Lawyer oversight: Ben Beabey
3.2 I Comm I Execute the Comms and Media plan to: Upon the Judgment being POL: Mark Davies & Mel Corfield
s - Agents (settle & reassure) — can NFSP support? handed down (?). WBD: Rachel Scott
- Employees: L300, L50, key operational teams, One, all, heads of client POL Lawyer oversight: Ben Beabey
relationships, suppliers, helplines
3.3 I Comm I Execute the Stakeholder Management plan to: Upon the Judgment being POL: See detail included in column
- Board & GE (Al + Jane)
- _ BEIS (Mark Davies + Patrick Bourke)
= UKGI (Al + Jane + Patrick Bourke)
- MPs & Political Parties (Mark Davies + Patrick Bourke Team)
- NFSP (Debbie + Nick Beale)
- Banks (Martin K)
- Fujitsu (Rob H)
- — Royal Mail (Mark S)
- Bol (Owen W/ CP)
- Bill Payment clients (Andrew Goddard / Martin Rouse)
- Unions (Lee Kelly)
-__ Others?
handed down (?).
WEBD: Rachel Scott
POL Lawyer oversight: Ben Beabey