POL00279838 - Table of Changes to Operational Process

Evidence on official site

Confidential and legally privileged. Do not disclose, forward, scan or copy

TABLE OF CHANGES TO OPERATIONAL PROCESSES

Version: 5 July 2019

1. Onboarding of branch operators

Ref

End to end process
(chronological)

Current / pre-
Judgment process

Common Issues
Judgment
Requirements /
Impacts requiring a
change to the process

Changes to the
Process

Artefact / Tools

1.1

Source suitable leads.

Local Relationship
Managers are sent
leads from a team
in London. They
also walk the area
looking for
prospective suitable
branch
locations/retailers.

A new contractual term
has been implied,
requiring Post Office to
act in good faith
towards branch
operators.

This applies once the
contract is entered into,
but changes are also
being made to the pre-
contract process to
reflect the 'spirit' of the
Judgment.

A restructure has taken
place (effective from
23rd April 2019) which
means that this function
is now carried out by
Change Managers,
freeing up the Business
Support Manager (new
role introduced as part of
restructure) to solely
focus on supporting
branch operators. The
process undertaken by
Change Managers has
been shortened and now
ends at Contract stage.

001 New Agent and
Operational Support
Organisational structure

&

1.2

A visit is arranged to
the prospective branch
operator.

A call is made to
introduce and
arrange suitable
date.

N/A

No change.

‘ "Branch operator" refers to the person contracting with Post Office to operate a branch (also referred to as the "postmaster" / "Subpostmaster" / "agent" /
“operator").

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1.3. I The prospective The Local A new contractual term I No change to process,
branch operator is Relationship has been implied, except that this is now
visited. Manager visits the requiring Post Office to I carried out by the

premises and meets I act in good faith Change Manager. The
the prospective towards branch conversation is more
branch operator. operators. transparent, introducing
They assess the the Post Office,
suitability of This applies once the explaining pros and cons
premises and contract is entered into, I and talking about basket
branch operator's but changes are also values, fees and footfall,
retail business. At being made to the pre- restrictions policy,
this point contract process to branch layout. If the
discussion points reflect the 'spirit' of the I prospect isn’t right for
are: Post Office Judgment. the prospective branch
fees, increased operator or Post Office,
footfall, restrictions they will be advised and
policy and branch refused.
layout.
If unsuccessful, self-
generate lead.

1.4 I The prospective The online A new contractual term I Future improvement

branch operator is sent
a link to the
application form.

application link is
sent via an email
by an admin team
member and three
teams and several
individuals are
involved throughout
application process.

has been implied,
requiring Post Office to
act in good faith
towards branch
operators.

This applies once the
contract is entered into,
but changes are also
being made to the pre-
contract process to
reflect the ‘spirit’ of the
Judgment.

planned for delivery:

1. From 1% September
this step will happen
later in the process
(after suitability
assessment), to avoid
unnecessary work for
the prospective
branch operator.

2. The application form
is being reviewed to
make it easier to fill
in.

3. The 3 teams are

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4. cross training to
restructure as
Caseworkers. The
application is
assigned to one
Caseworker who will
send the link and
handhold the
prospective branch
operator throughout
the process.

Until the back office
changes occur, the
process will remain the
same.

1.5

Application Tracking.

The prospective
branch operator
would receive
updates from
AAPT/Network
Change Support
Team.

A new contractual term
has been implied,
requiring Post Office to
act in good faith
towards branch
operators.

This applies once the
contract is entered into,
but changes are also
being made to the pre-
contract process to
reflect the 'spirit' of the
Judgment.

Future improvement
planned for delivery:

Branch Hub will deliver
an online application step
tracker to allow the
prospective branch
operator to have easy
sight of the application
progress. This will
include reminders to
complete actions and
positive messages as
steps are completed.

The branch operator will
also have one point of
contact throughout their
application journey (the
Caseworker).

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1.6 I The prospective The business plan I A new contractual term I Future improvement
branch operator will fill I is detailed and has been implied, planned for delivery:
out a detailed business I complex. requiring Post Office to
plan. act in good faith 1. From 1% September
Local Relationship towards branch this step will happen
Manager completes I operators. later in the process
a Pen picture for (after suitability
telephone interview I This applies once the assessment), to avoid
or a business profile I contract is entered into, unnecessary work for
template for a face- I but changes are also the prospective
to-face interview. being made to the pre- branch operator.
contract process to 2. The Electronic
reflect the ‘spirit’ of the Business Plan is being
Judgment. relaunched on 1*
September. There will
now be three versions
tailored to the size
and circumstances of
the prospective
branch operator's
situation. This will be
decided via a decision
tree and knowledge
from the Onboarding
and Assessment
Manager following
step 1.7.

3. The Caseworker will
remain the single
point of contact.

1.7 Finance make a Finance may N/A No change.

decision on the
business plan.

approve, decline or
request further
information.

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1.8 Further suitability The Contract A new contractual term I 1. The interviews are
check takes place. Advisor carries out I has been implied, now called Suitability
a detailed and requiring Post Office to Assessments and are
formal telephone or I act in good faith a softer touch method
face to face towards branch of assessment.
interview with the operators. 2. The suitability
prospective branch assessment is no
operator. The This applies once the longer carried out by
Contract Advisor contract is entered into, the Contracts
will explain Post but changes are also Advisor, but by the
Office policies and being made to the pre- Onboarding and
guidelines and contract process to Assessment Manager.
explain that the reflect the 'spirit' of the
branch operator Judgment. Future improvement
must adhere to planned for delivery:
these, and the
consequences if 1. From 1% September
they are breached. the suitability
At this point the assessment will take
Contract Advisor place prior to the
will also complete application link being
suitability checks; sent and the business
passport/DBS etc. plan being filled in, to
avoid unnecessary
work if the suitability
assessment results in
an agreement to
cease the application.
1.9 I If suitability is agreed I Contract sent from I A new contractual term I Caseworker assigned to

a Contract is sent out.

the administrative
team.

has been implied,
requiring Post Office to
act in good faith
towards branch
operators.

This applies once the
contract is entered into,

the application sends out
the Contract, along with
vetting forms and Smart
ID applications. The
Change Manager leaves
the process at this point.

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but changes are also
being made to the pre-
contract process to
reflect the 'spirit' of the
Judgment.

1.10 I Contract is signed. Contract is signed. N/A No change.
1.11 I Initial Site Meeting A member of the N/A No change.
takes place. property team will
attend the premises
to arrange for the
counter build.
1.12 I Training takes place. 1. A link is sent for I New contractual terms I Future improvement

a 4 hour e-
learning
module.

2. 2/3 day
classroom
training (same
for all).

3. Trainer provides
6 days of onsite
training.

have been implied,
requiring Post Office to:

- provide adequate
training and support
to branch operators;
and

- provide reasonable
co-operation, as
necessary for the
performance of the
branch operator's
obligations.

planned for delivery from
31% July (and ongoing):

1. Caseworker sends
link to potential
branch operator for e-
learning module.

2. Caseworker will book
prospective branch
operator onto a 2 or 3
day classroom
training. This is
tailored to needs now
to provide more
suitable support.

3. The Quality
Assurance Trainer is
responsible for
ensuring that e-
learning is completed
prior to classroom

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ws

training.

Other training
initiatives are in flight
such as refresher
training, balancing
and back office,

Lotto, SSK.

1.13 I Pre-opening support. All pre-opening New contractual terms 6 weeks prior to opening,
support is provided I have been implied, the Caseworker will
by Local requiring Post Office to: I introduce the prospective
Relationship branch operator to a
Manager, Managers I- provide adequate Business Support
and trainers. training and support I Manager, who will

to branch operators; I support with things such
and as local marketing,
compliance etc.
- provide reasonable
co-operation, as
necessary for the
performance of the
branch operator's
obligations.

1.14 I Post-opening support. I 1. Originally, Area New contractual terms 1. The Business Support
Network Change have been implied, Manager will provide
Managers would requiring Post Office to: post opening support
support new and will work closely
branches amongst - provide adequate with the Area
their other training and support Manager.
branches. to branch operators; I 2. The training and

and support will feed into
2. Last August the a development plan
Local Relationship - provide reasonable and an agreement
Managers were set co-operation, as will be reached on
up to provide necessary for the how many visits are
continuous support performance of the required.
for up to 6 to 12 3. A Branch Visit report

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months beyond
branch opening.

- branch operator's
obligations.

4. is currently being
reviewed for sign off
— this will be filled in
by the Branch
Support manager and
uploaded to a branch
record to give the
Area Manager
visibility and enable a
co-ordinated support
approach.

2. Shortfalls / Losses (Prevention, Audit, Investigations, Recovery, Transaction queries/disputes)

2.1 Loss prevention

Ref I End to end process Current / pre- Common Issues Changes to the Artefact / Tools
(chronological) Judgment Judgment Process
process Requirements /
Impacts requiring a
change to the process
2.1 Branch operator is A daily cash count I N/A No change. N/A
1 required to reconcile is carried out by

their till daily and
balance their cash and
stock on a monthly
basis, but ideally
weekly.

the branch
operator and
compared to
expected cash. If

there is a variance,

further checks
should be made

(checking currency
and stock) to try to
find the source of

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the variance.

If help is needed,
the Branch
operator may call
Branch Support

(NBSC). See 2.3.1.

See 2.3.1.

See 2.3.1.

See 2.3.1.

Branches access
information on their
financial transactions
and performance.

Branch operators
can view financial
performance and
transactions via a
Horizon printout.

New contractual terms
have been implied,
requiring Post Office to:

- provide adequate
training and support
to branch operators;
and

- provide reasonable
co-operation, as
necessary for the
performance of the
branch operator's
obligations.

Post Office was
criticised in the
Judgment for a "culture
of secrecy" and
"excessive
confidentiality". To
address this, Post Office
should be more open
and transparent with
branch operators.

The Branch Insights Tool
has been created to give
a snapshot of key
indicators of the way a
branch is operating (cash
declarations, calls to
Branch Support etc.) and
can flag up early
warnings that a process
is not being followed
correctly. This is shared
with the branch operator
as part of routine field
visits by the field team
who can then arrange for
help and support to be
provided before a small
issue becomes a risk. For
example, this might take
the form of additional
training being provided.

Future improvement is
planned for delivery as
part of FY19/20
Operations
Transformation portfolio:

1. Information about a

002 Branch Insights Tool
Excerpts

rant

002 Branch Insights
Tool Excerpts

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2. branch’s compliance
with standards, which
was previously only
shared to some
branches via
telephone, to be
provided to all branch
operators
electronically via
online self-service
Branch Hub tool.

3. Full dashboard of
management
information to be
provided to branch
operators via Branch
Hub.

Branch analysis team
look at trends in cash
declarations and other
risk factors within the
network and rank the
branches based on the
ones that have the
biggest financial
variances. They pass
the highest risk cases
to the audit team, with
full reasons for the
audit.

There was no
documented initial
rationale for
conducting an
audit that could be
easily shared with
the branch
operator.

New contractual terms
have been implied,
requiring Post Office:

- not to exercise any
discretion arbitrarily,
capriciously, or
unreasonably; and

- to exercise any
discretion in
accordance with the
obligations of good
faith, fair dealing,
transparency, co-
operation and trust
and confidence.

The Audit Rationale
Document (ARD) is
created when an audit is
requested and sent to
the Audit and Contract
teams prior to the Audit.
It explains the reason for
the audit. The
information is shared
with the branch operator.

Future improvement
planned for delivery as
part of FY19/20
Operations
Transformation portfolio:

We are working toward
being able to give the

003 Audit Rationale
document

003 Audit Rationale
document

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Post Office was
criticised in the
Judgment for a "culture
of secrecy" and
"excessive
confidentiality". To
address this, Post Office
should be more open
and transparent with
branch operators.

Branch Analysis team
visibility of all IT issues,
including any Horizon
impacts, so that they are
able to rule out any IT
issues as a cause for the
discrepancy.

2.2 Audit
Ref End to end process I Current / pre- Common Issues Changes to the Artefact / Tools
(chronological) judgment process I Judgment Process

Requirements /
Impacts requiring a
change to the
process

2.2.1 Audit is scheduled The audit is A new contractual A new team (Caseworker I 004 Casework Team

with the branch
operator.

scheduled by a
general Post Office
administrative
team. There are
long lead times
between identifying
the requirement for
an audit and

scheduling an audit.

term has been
implied, requiring Post
Office to act in good
faith towards branch
operators.

Team) has been set up
to administer the end to
end audit process, which
will ensure accurate,
consolidated information
is maintained at an
individual case level.
This team will take on
the responsibility of
scheduling audits which
will result in less lead
time between a risk
being identified and the
branch having an audit,
as well as improved

Leader JD

004 Casework Team
Leader JD

005 Case Management
Tracker User Guide

005 Case
Management Tracke

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prioritisation.

2.2.2

Auditor receives
email notification of
scheduled audit and
Audit Rationale
Document (new),
which details the
reason for the audit.

There was no
documented initial
rationale for
conducting an audit
that could be easily
shared with the
branch operator.

See 2.1.3.

See 2.1.3.

See 2.1.3.

A specialised audit
team are deployed to
carry out the audit.

1. The audit team
provided both
audits and
(re)training.

2. The minimum
number of
auditors that
could be sent to
carry out an
audit was one.

3. Auditors are not
Officially
accredited.

New contractual terms
have been implied,
requiring Post Office:

- to provide
adequate training
and support to
branch operators;

- to take reasonable
care in performing
its functions and/or
exercising its
functions within
the relationship;
and

- properly, fully and
fairly to investigate
any alleged or
apparent shortfalls.

1. The teams have been
split to support the
delivery of more
specialised capability
and to allow the
teams to concentrate
on giving the branch
operator the best
standards of either
training or audit.

2. All audits are now
scheduled with at
least two auditors
required to attend, in
order to, improve
quality of audits.

3. Recommendation
being formulated that
auditors should
obtain an audit
accreditation.

006 Audit and Training
Team Restructure

006 Audit and
Training Team Restr.

2.2.4

Auditor reviews
information on the
Audit Rationale
Document and views

The scheduling
information includes
a line on the reason
for audit.

New contractual terms
have been implied,
requiring Post Office:

The Auditor now has the
full Audit Rationale
Document to give them
information about the

See 2.1.2 and 2.1.3.

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the Branch Insight
Tool (new) for the
most up to date
situation.

- to take reasonable
care in performing
its functions and/or
exercising its
functions within
the relationship;
and

- properly, fully and
fairly to investigate
any alleged or
apparent shortfalls.

reason for audit and the
Branch Insights Tool has
been created to give a
snapshot of key
indicators of the way a
branch is operating (cash
declarations, calls to
Branch Support etc.)

2.2.5

The audit is logged
into a case
management tracker,
which is used to
manage all live cases
and allow easy
communication of
progress to branch
operators.

Limited overall
visibility of open
audit cases for
these to be
managed effectively
internally and to
manage
expectations with
branch operators.

New contractual terms
have been implied,
requiring Post Office:

- to take reasonable
care in performing
its functions and/or
exercising its
functions within
the relationship;
and

- properly, fully and
fairly to investigate
any alleged or
apparent shortfalls.

An interim case
management solution
has been established
with a workflow and
tracker to give one single
view of progress to all
teams, enabling the
surfacing of process
delays and simple
reporting to drive
improvements.

Future improvement is
planned for delivery as
part of FY19/20
Operations
Transformation portfolio:

1. New case
management function to
be established, including
dedicated team and

N/A

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improved tooling.

2.2.6 The audit team A text message is N/A No change. N/A
arrive on site. sent to Contract
Auditor sends a text I Advisor.
message to the
designated Contract
Advisor to confirm
they have arrived.
2.2.7 The reason for audit I No reason for audit I New contractual terms I The Reason for Audit 007 Reason for Audit

is communicated to
the branch operator
upon arrival.

was given to the
branch operator.

have been implied,
requiring Post Office:

- not to exercise any
discretion
arbitrarily,
capriciously, or
unreasonably; and

- to exercise any
discretion in
accordance with
the obligations of
good faith, fair
dealing,
transparency, co-
operation and trust
and confidence.

Post Office was
criticised in the
Judgment for a
"culture of secrecy"
and “excessive
confidentiality". To
address this, Post
Office should be more

script ensures that the
Operator is fully
informed of the reason
for the audit. The script
is created with a view to
being open with the
Operator. It includes:
giving them the chance
to attend if they are not
in the branch; explaining
all the audit steps;
offering the opportunity
to accompany the auditor
throughout the audit;
explaining the full
reasons for the audit
being arranged.

Script (under review)

ie]

007 Reason for
Audit Script

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open and transparent
with branch operators.

2.2.8 I If the Operator is not I The audit begins as_ I A new contractual The auditor will invite the
present, the Auditor I soon as the auditor I term have been person in charge to
will invite the person I has introduced implied, requiring Post I contact the Operator if
in charge to contact I themselves. Office to act in good not present, to allow
the Operator and faith towards the them to travel to the
give them a branch operator. branch and attend the
reasonable amount audit within reasonable
of time to arrive. timescales.
2.2.9 Auditor will explain 1. The audit carried I New contractual terms I 1. All audits carried out I 008 Audit Chapters 03

in advance the steps
of the audit. The
audit is conducted
following a set
procedure as per
Knowledge Base
manual.

out could either
be a full ("Tier
2") audit with all
cash, currencies
and stock
counted, ora
light touch
version of this
that would count
only cash and
main currencies.

2. Regular reviews
of Knowledge
Centre Audit
manual.

3. A review of the
current Quality
Assurance
process was
conducted and
concluded
improvements
were required.

have been implied,
requiring Post Office:

- to take reasonable
care in performing
its functions and/or
exercising its
functions within
the relationship;

- properly, fully and
fairly to investigate
any alleged or
apparent
shortfalls;

- not to exercise any
discretion
arbitrarily,
capriciously, or
unreasonably; and

to exercise any
discretion in

are now full ("Tier 2")
audits to enable
consistency ad
transparency.

2. Full review of Audit
Chapters being
carried out.

3. In order to ensure
that the Audit Team
provide a quality
service to the
business and other
stakeholders, we are
designing and
overseeing a robust
Quality Assurance
process.

and 03a (under review)

008 Audit Chapters
03 and 03a

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accordance with
the obligations of
good faith, fair
dealing,
transparency, co-
operation and trust
and confidence.

2.2.10 I During an audit, a There is a count A new contractual The count sheets have N/A
reconciliation of sheet to record term has been been updated to contain
funds is conducted cash, currency and I implied, requiring Post I a declaration for the
between the actual stock and the Office to co-operate in I Operator/OIC to sign to
cash, currency and branch operator is seeking to identify the I say they have been
stock in branch and I asked to do an possible or likely given the opportunity to
the previous day independent count causes of any verify the findings and
declarations of cash, I of cash and apparent shortfalls have declined (if they
currency and stock. currency to verify and/or whether or not I have done so).
findings. there was any
shortfall.
2.2.11 I Once the audit is The auditor holds a_ I New contractual terms I The closing script 009 Auditor Closing

complete, the auditor
advises the branch
operator that the
audit has been
completed and
advises on the
findings. If the
variance is less than
£1,000 no further
action is taken and
the closing script is
read to the branch
operator.

simple meeting to
advise the branch
operator what had
been found.

have been implied,
requiring Post Office:

- to exercise any
discretion in
accordance with
the obligations of
good faith, fair
dealing,
transparency, co-
operation and trust
and confidence;
and

- provide adequate
training and

ensures that the branch
operator is fully informed
at the end of the audit.
The script is created to
ensure that the Operator
has all the information
they require and are
encouraged to ask
questions and give
feedback. It includes:
giving the branch
operator the chance to
verify the Auditor's
findings; allowing the
Auditor to go through the
findings in detail;

Script (under review)

By

009 Auditor Closing
Script

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- support to branch
operators.

explaining next steps
and any training or
support interventions.

2.2.12 I A full record of the No standardised A new contractual The Audit Reporting Tool, I N/A
closing script will be I record was made of I term has been which captures the audit
made, including any I the conversation or I implied, requiring Post I findings, will be updated
questions asked and I questions asked/ Office to exercise any I to include a place to
responses given. actions agreed. discretion in record all questions

accordance with the asked and answered,
obligations of good suggestions made and
faith, fair dealing, actions agreed at the end
transparency, co- of the audit.

operation and trust

and confidence.

2.2.13 I If the audit finds that I If the variance is Refer to 3. No change. N/A
there is a negative over £1,000, the Suspensions
variance of more auditor contacts the
than £1,000 between I contract advisor for
the cash in hand and I a decision on
the cash amount suspension.
shown on the
system, the auditor
contacts the contract
advisor for a decision
on suspension.

Refer to 3.
Suspensions.
2.2.14 I If the audit finds a If there is a Refer to 3. No change. N/A

negative variance of
more than £5,000
the Auditor will also
contact the Security
Advisor for advice on
how to proceed.

negative variance of
more than £5,000
the Auditor will also
contact the Security
Advisor for advice
on how to proceed.

Suspensions.

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Refer to 3.
Suspensions.

2.2.15 I If a precautionary Follow the ‘Closure’ I N/A No change 010 Document outlining
suspension has been I instructions to closure steps
implemented, the include:
auditor secures the
branch (unless an 1. Changing the
immediate temporary safe codes and 010 Document
operator is available making sure that outlining closure st.
in which case see all other users
2.2.15a). are deleted. (for

keyless safes)
2. Taking all safe
keys and using a
tamper evident
safe seal if spare
keys are not
available
3. Changing the
alarm codes
4. Removing all
users from
Horizon online
2.2.15 I If a temporary Carry out "Transfer I N/A No change. N/A
a operator (temp) is to Temp" Audit.

immediately
available and the
branch operator
agrees to the branch
being operated by a
temp, a “transfer to
temp” audit would
take place confirming
all PO assets that are
being taken over by
the appointed temp.

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2.2.16

Complete Audit
report and send to
branch operator
within 2 working
days.

Complete Audit
report and send to
branch operator
within 2 working
days.

N/A

No change.

N/A

2.3 Investigation

Ref End to end Current / pre- Common Issues Changes to the Process I Artefact / Tools
process Judgment process Judgment
(chronological) Requirements /
Impacts requiring a
change to the
process
2.3.1 Branch operator Branch operator New contractual 1. All advisors at Branch I Since Tier 2 support was

is unable to find
the reason for a
discrepancy in
their cash
balancing.

contacts Branch
Support (NBSC) and
they will talk the
branch operator
through some
balancing steps to help
them check for the
discrepancy reason.

Unresolved
discrepancies are sent
to Support Services
Resolution Team.

terms have been
implied, requiring
Post Office:

- to co-operate in
seeking to
identify the
possible or likely
causes of any
apparent
shortfalls and/or
whether or not
there was any
shortfall;

- to seek to identify
such causes
itself;

Support (NBSC) now
have a checklist to
use that will assist
them in helping the
branch operator to
find the discrepancy
reason.

2. A Tier 2 escalation
team has been
created that can
investigate branch
discrepancies, giving a
greater source of
support for unknown
losses in branch. Tier
2 can put in place
interventions such as
training, if required.
Unresolved
discrepancies are sent

set up on 1* April, the
statistics for case volumes
and outcomes are as
follows (correct as of 28'"
June 2019)

* Cases received -
311

« Cases resolved 263

e In progress - 47

* Cases escalated to
other department 9
(6 to SSRT and 2to
NSAT and 1 to IT)

011 Branch Support Tier 1
and Tier 2 Discrepancy
Checklist

POL00279838
POL00279838
to disclose
possible causes of
apparent or
alleged shortfalls
candidly, fully
and frankly;

to make
reasonable
enquiry,
undertake
reasonable
analysis and even-
handed
investigation, and
give fair
consideration to
the facts and
information
available as to
the possible
causes of the
appearance of
alleged apparent
shortfalls (and
the cause
thereof);

properly, fully and
fairly to
investigate any
alleged or
apparent
shortfalls; and

to provide
adequate training
and support to

3. to Support Services
Resolution Team.

Future improvement
planned for delivery as
part of FY19/20
Operations
Transformation portfolio:

We are working toward
being able to give Tier 2
visibility of all IT issues,
including any Horizon
impacts, so that they are
able to rule out any IT
issues as a cause for the
discrepancy.

011 Branch Support
Tier 1 and Tier 2 Disc

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20
- branch operators.

2.3.2 I A Branch Support Services A new contractual To reduce 012 Branch Analysis
Discrepancy from I Resolution Team term has been investigation time, Review Too!
Branch Support (SSRT) investigate implied requiring and subsequently
Tier 2 (refer to escalated disputes and I Post Office to suspension length, the
2.3.1) ora discrepancies with exercise any Branch Analysis
Transaction 80% of investigations I discretion in Review Tool has been I 012 Branch Analysis
Correction from taking 4 weeks. accordance with the created, offering a Review Tool
the Disputes obligations of good summary of data in
team is received faith, fair dealing, one place - a light
for further transparency, co- touch investigative
investigation by operation and trust tool to speed up lead
the Support and confidence. times.

Services

Resolution Team. Future improvement
planned for delivery as
part of FY19/20
Operations
Transformation portfolio:
1. Review SSRT ways of
working to enable simple,
transparent and regular
updates to branch
operators.

2.3.3 I The Support Investigation reports —_I A new contractual Review of feedback form I N/A
Services are completed ona term has been in progress to allow for a

Resolution Team
carries out a full
investigation and
creates a report
to be fed back to
the requestor and
then onto the

complex form that is
not easily understood
and cannot be shared
with branch operators.

implied, requiring
Post Office to
exercise any
discretion in
accordance with the
obligations of good
faith, fair dealing,

simplified version to be
shared with branch
operators.

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24
branch.

transparency, co-
operation and trust
and confidence.

2.4 Loss Recovery

Ref End to end Current / pre- Common Issues Changes to the Process I Artefact / Tools
process Judgment process Judgment
(chronological) Requirements /
Impacts requiring a
change to the
process
2.4.1 If a negative A former agent team in I A new contractual

variance is
registered on the
system after the
branch has
completed their
branch trading
statement, the
recovery process
begins.

the financial service
centre will begin a
recovery process. Loss
recovery function
managed as part of
Financial Service
Centre and not
integrated with other
loss prevention and
identification
functions, resulting in
limited end to end

term has been
implied, requiring
Post Office to act in
good faith towards
branch operators.

The loss recovery function
has been moved to sit
within the new loss
prevention structure,
resulting in improved
efficiency and end to end
visibility of cases.

013 Loss Prevention
Restructure
Announcement

my

013 Loss Prevention
Restructure Announ

22

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visibility of cases.

2.4.2

A negative
variance is
registered
following an audit
where the branch
operator has been
suspended, or
where a closing
audit has taken
place following
the closure of a
branch, the
recovery process
begins.

A former agent team in
the financial service
centre will begin a
recovery process. The
loss recovery function
managed as part of
Financial Service
Centre and not
integrated with other
loss prevention and
identification
functions, resulting in
limited end to end
visibility of cases.

A new contractual
term has been
implied, requiring
Post Office to act in
good faith towards
branch operators.

The loss recovery function
has been moved to sit
within the new loss
prevention structure,
resulting in improved
efficiency and end to end
visibility of cases.

See 2.4.1

2.4.3

Recovery letters
are sent to the
branch operator.

(1) Current branch
operators receive two
recovery letters, one
sent the Monday after
the trading period and
the next 6 days later,
if not paid.

Former and suspended
branch operators
receive one letter
within 3 days of
suspension. If there is
a guarantor, they will
receive a letter, if no
response from the
branch operator.

(2) If still not
recovered, a debt

Post Office is
criticised in the
Judgment for a
"oppressive"
behaviour.

A new contractual
term has been
implied, preventing
Post Office seeking
recovery of any
alleged shortfall from
the branch operator
unless and until Post
Office has:

(i) complied with its
new implied duties;

(ii) established that
the alleged shortfall

1. The letters are being
reviewed, having been
rewritten in a more
supportive tone,
giving clear ways to
pay, and a visible
route to disputing a
shortfall, including
email and telephone
direct contact details.

2. The Letter Before
Action is no longer
sent.

014 Recovery Letters
(under review)

my

014 Recovery
Letters

23

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recovery agency is
used to send a Letter
Before Action

represents a genuine
loss to Post Office;
and

(iii) carried out a
reasonable and fair
investigation as to
the cause and reason
for the alleged
shortfall and whether
it was properly
attributed to the
branch operator.

2.4.4 If there is no No call handling A new contractual A call handling system is I N/A
response to the system in place to term has been now in place in the
letters sent, and record and manage implied, requiring Financial Service Centre
the branch branch operator calls I Post Office to act in I and is being used for
operator is a on loss recovery. good faith towards outbound calls, increasing
current operator, branch operators. visibility of calls and
they will receive enabling call reporting.
phone calls.

There are 2 calls
for amounts less
than £1,000 and
4 calls for
amounts over
£1,000.
2.4.5 For current Once two recovery A new contractual Forced deductions have

branch operators
only, if there is
no response, the
loss recovery
process
continues.

letters had been sent
to a current branch
operator, and either 2
or 4 phone calls made
(depending on the
shortfall amount), a
forced deduction would
be arranged and the

term has been
implied, preventing
Post Office seeking
recovery of any
alleged shortfall from
the branch operator
unless and until Post
Office has:

been on hold since 15"
March.

This is a key outstanding
piece of work. Post Office
are currently considering
whether, and in what
circumstances, forced

POL00279838
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24
shortfall would be
deducted from the
branch operator’s
remuneration.

(i) complied with its
new implied duties;

(ii) established that
the alleged shortfall
represents a genuine
loss to Post Office;
and

(iii) carried out a
reasonable and fair
investigation as to
the cause and reason
for the alleged
shortfall and whether
it was properly
attributed to the
branch operator.

deductions can be
reinstated. If the decision
is made to reinstate, then
the process and
associated artefacts will
be reviewed.

3.5

Transaction queries/disputes

Ref I End to end process I Current / pre- Common Issues Changes to the Process I Artefact / Tools
(chronological) Judgment process Judgment
Requirements /
Impacts requiring a
change to the
process
2.5. I A Transaction The content of the A new contractual All Transaction Correction I 015 Top 10 TC Narrative
1 Correction is issued communication for term has been narratives have been Review
to a Branch. branch operators on implied, requiring rewritten and simplified,

the reasons for
Transaction
Corrections included
inconsistent and
confusing wording.

Post Office to exercise
any discretion in
accordance with the
obligations of good
faith, fair dealing,

so that the branch
operator can clearly
understand POL's position
and instructions. An
accompanying letter to

By

015 Top 10
Narrative Review

25

POL00279838
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transparency, co-
operation and trust
and confidence.

send with Transaction
Correction evidence when
sent to branch has been
created.

2.5. I A branch operator The Transaction N/A No change, but the new
2 wishes to get Correction contains a Disputes Team is an
information on a contact number for added escalation point.
Transaction the Financial Service
Correction issue that I Centre. The branch Refer to 2.35.5/6/7
they have been operator will call the
notified about. Financial Service
Centre and they
should be able to
provide information
and evidence to the
branch explaining the
reason for the
Transaction
Correction.
2.5 A branch operator The branch operator A new contractual A new team has been set
3 wishes to dispute a calls Branch Support I term has been up to handle disputes
Transaction (NBSC) and they implied, requiring relating to Transaction
Correction issue that I would pass on the Post Office to exercise I Corrections.
they have been query to the Financial I any discretion in
notified about. Service Centre. accordance with the
obligations of good
faith, fair dealing,
transparency, co-
operation and trust
and confidence.
2.5. I A branch operator The branch operator A new contractual A new team has been set
4 receives a loss calls Branch Support _I term has been up to handle disputes

26

POL00279838
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recovery letter and
wishes to dispute the
Transaction
Correction variance.

(NBSC) and they pass
on the query to the
Agent Accounting
Team.

implied, requiring
Post Office to exercise
any discretion in
accordance with the
obligations of good
faith, fair dealing,
transparency, co-
operation and trust
and confidence.

relating to Transaction
Corrections (see 2.5.5).

2.5. I Disputes team No previous process. I A new contractual An acknowledgement 016 Dispute Holding
5 receives disputed term has been letter is sent. Letters
Transaction implied, requiring
Correction. Post Office to exercise
any discretion in
accordance with the 016 Dispute
obligations of good Holding Letters
faith, fair dealing,
transparency, co-
operation and trust
and confidence.
2.5. I Disputes team No previous process. New contractual Disputes Team provides
6 investigates and terms have been evidence to the branch.

resolves disputed
Transaction
Correction.

implied, requiring
Post Office:

- to co-operate in
seeking to identify
the possible or
likely causes of
any apparent
shortfalls and/or
whether or not
there was any
shortfall;

27

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to seek to identify
such causes itself;

to disclose
possible causes of
apparent or
alleged shortfalls
candidly, fully and
frankly;

to make
reasonable
enquiry,
undertake
reasonable
analysis and even-
handed
investigation, and
give fair
consideration to
the facts and
information
available as to the
possible causes of
the appearance of
alleged apparent
shortfalls (and the
cause thereof);

properly, fully and
fairly to
investigate any
alleged or
apparent
shortfalls.

28

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Disputes Team is
unable to resolve
disputed Transaction
Correction.

No previous process.

New contractual
terms have been
implied, requiring
Post Office:

- to co-operate in
seeking to identify
the possible or
likely causes of
any apparent
shortfalls and/or
whether or not
there was any
shortfall;

- to seek to identify
such causes itself;

- to disclose
possible causes of
apparent or
alleged shortfalls
candidly, fully and
frankly;

- to make
reasonable
enquiry,
undertake
reasonable
analysis and even-
handed
investigation, and
give fair
consideration to
the facts and
information
available as to the

The dispute is escalated
to the Support Services
Resolution Team (SSRT)

Refer to 2.3
Investigations

29

POL00279838
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- possible causes of
the appearance of
alleged apparent
shortfalls (and the
cause thereof);

- properly, fully and
fairly to
investigate any
alleged or
apparent
shortfalls.

3. Suspension

End to end process
(chronological)

Current / pre-
Judgment process

Common Issues
Judgment
Requirements /
Impacts requiring a

Changes to the Process

Artefact / Tools

30

POL00279838
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change to the process

3.1

A potential reason for
suspension is
identified.

. Contract Advisor

(CA) is
contacted by
Audit Advisor on
day of audit if
there is a
negative
variance of
more than
£1,000

. CA becomes

aware of a
branch operator
losing their valid
property
interest and an
audit takes
place

CA becomes
aware that the
branch operator
has been
arrested,
charged, or is
being
investigated by
the Police and
an audit takes
place

. CA becomes

aware that civil
proceedings are
being brought
against the
branch operator
and an audit

N/A

No change

N/A

34

POL00279838
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e. takes place

CA becomes
aware that the
branch operator
is impacted
under the
Insolvency Act
and an audit
takes place.

=

3.2

CA obtains and
reviews relevant
information.

CA speaks to the
branch operator to
obtain further
information, if
necessary.

CA reviews
information
provided by auditor,
along with any
other relevant
information relating
to the audit reason
(i.e. Companies
House website for
bankruptcy,
Landlord
information for loss
of property interest
etc.)

If the branch
operator admits to
criminal activity, no
further questions
are asked relating
to the suspected
offence and the

Post Office was criticised
in the Judgment for a
"culture of secrecy" and
"excessive
confidentiality". To
address this, Post Office
should be more open
and transparent with
branch operators.

New guidance and
example script introduced
to assist the CA in
conducting its discussion
with the branch operator
regarding a variance
found at audit in an open
and transparent manner.
This document also
prescribes how the CA
should perform the
suspension notification by
telephone.

017 Suspension Script
(under review)

017 Suspension
Script

32

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matter is referred
to an Investigations
Manager.

3.3 I Make decision CA liaises with A new contractual term I The Suspension or Non- 018 Suspension or Non-
whether to suspend I Agent Contract has been implied, suspension Rationale Suspension Rationale
or not. Deployment meaning that Post Office I Document has been Document

Manager (ACDM) to I cannot suspend: (i) reviewed and is the
reach a decision. arbitrarily, irrationally or I process of being updated &
capriciously; (ii) without I so that Post Office can
CA completes reasonable and proper record and evidence its 018 Suspension or
Suspension or Non- I cause; and/or (iii) in decision against these Non-Suspension Ra
suspension circumstances where criteria in the Judgment.
Rationale Document I Post Office was itself in
and send to ACDM. I material breach of duty
in respect of matters
which Post Office
considered gave it the
right to suspend.
3.4 I Communicate CA speaks to the Post Office was criticised I New guidance and See 3.2

suspension outcome
to branch operator.

branch operator.

If the branch
operator admits to
criminal activity,
the matter is
referred to an
Investigations
Manager.

in the Judgment for a
"culture of secrecy" and
“excessive
confidentiality". To
address this, Post Office
should be more open
and transparent with
branch operators.

example script introduced
to assist the CA in its
discussion with the
branch operator regarding
a variance found at audit
in an open and
transparent manner.

33

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3.5 I Implement the
suspension.

Suspension letter
issued to branch

operator within 2
days.

Previously Post
Office withheld
remuneration
during suspension.

Suspension email
sent to all
stakeholders (asap
and within 24hrs).

Temporary operator
put in place if
agreed with the
branch operator.
Branch is de-funded
if no temp is
available.

Post Office was criticised
in the JJudgment for a
"culture of secrecy" and
"excessive
confidentiality". To
address this, Post Office
should be more open
and transparent with
branch operators.

Post Office's previous
policies deployed in
parallel with suspension
were also criticised in
the Judgment. To
address this, Post Office
should not deny the
branch operator access
to copies of information
and records if requested,
unless justified (eg for
data protection
reasons).

Post Office's contractual
right to withhold
remuneration during
suspension has been
struck down.

The suspension letter
wording has been revised
to include the reason for
the suspension, to cross
refer to the audit report
(which is sent separately)
and to confirm that the
branch operator will
continue to receive
remuneration whilst
suspended. The 'tone of
voice’ of the letter has
also changed.

Branch operators are now
paid during the period of
suspension. This is based
on average remuneration
during the 6 months'
prior to suspension.

019 Suspension
Notification letters

ay

019 Suspension
Notification letters

4. Termination

Ref I End to end process
(chronological)

Current / pre-
Judgment

Common Issues
Judgment

Changes to the Process

Artefact / Tools

34

POL00279838
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process

Requirements /
Impacts requiring a
change to the process

4.1 I If the branch operator I CA reviews the N/A N/A See 3.3
is suspended, CA Suspension or Non-
reviews information suspension
on which decision to I Rationale
suspend was taken, Document and any
to determine next other information
steps. provided by auditor
and/or the CA that
completed the
Suspension or Non-
suspension
Rationale
Document.
4.2 I If CA determines that I Decision to re- N/A No change.
continued suspension I instate is
is not necessary, the I documented.
branch operator is
reinstated.
4.3 I If the branch operator I A “notification of N/A No Change.
is not already investigation” letter
suspended, the is sent.
branch operator is
advised of the alleged
breach.
4.4 I If CA determines Security or police N/A No Change.

there is evidence of
potential criminality,
CA informs the
Security team, or
advises the branch

will investigate and
carry out an
interview under the
Police and Criminal
Evidence Act

38

POL00279838
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operator to report to
the police, if the
matter relates to one
of the branch
operator's staff.

(PACE).

Prosecutions are
currently on hold.

4.5 I CA continues If the branch Post Office is criticised in I Traditional contracts: The
investigation and operator is the Judgment for an source of the terminology
Conduct meeting with I appointed under a "oppressive" behaviour. used to describe the
branch operator (if traditional form of letter and meeting
required) and contract, they are ("charge letter" and
investigation. issued with a letter "Reason to Urge") was

setting out details investigated and it was

of the contract confirmed that the use

breach ("charge has been historical and

letter") anda not contractual. We are in

meeting with the the process of changing

branch operator these terms so that they

("Reason to Urge" do not infer a criminal

(RTU)) is held. process.
The meeting will be
arranged by telephone
and followed up by a
letter, in order to speed
the process.

If the branch N/A NT (Locals or Mains)

operator is contracts: No change.

appointed under an

NT (Local or Mains)

form of contract,

CA decides whether

to hold informal

meeting with the

branch operator.

4.6 I Further investigations I The Support A new contractual term The SSRT team's

36

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carried out as
required following any
meeting.

Services Resolution
Team (SSRT) may
be contacted to
carry out further
investigation.

has been implied
requiring Post Office to
act in good faith towards
branch operators.

priorities and workload in
the SSRT team is under
review to ensure cases
are prioritised
appropriately and
investigated swiftly in
order to bring the final
decision to the branch
operator as swiftly as
possible.

4.7

Make decision
whether to terminate
or not.

CA makes a
recommendation
and completes a
Conduct Case
Decision document
setting out the
rationale for the
recommendation.
The
recommendation is
reviewed by the
ACDM and a
decision made.

New contractual terms
have been implied,
requiring that:

Post Office cannot
terminate: (i)
arbitrarily,
irrationally or
capriciously; (ii)
without reasonable
and proper cause;
and/or (iii) in
circumstances where
Post Office was itself
in material breach of
duty in respect of
matters which Post
Office considered
gave it the right to
terminate;

Post Office is only
entitled to terminate
immediately for
breach of contract
where the branch
operator has

The Conduct Case
Decision Document is
being reviewed and will
be updated so that Post
Office can record and
evidence its decision
against these criteria in
the Judgment.

37

POL00279838
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committed a
fundamental
("repudiatory")
breach, or in the
case of certain
specified breaches
listed in the NTC
contracts;

If terminating on
notice, the notice
period provided must
be set in line with
Post Office's duty to
act in good faith,
which means that it
may be required to
offer more than the
minimum notice
period.

4.8 I Communicate Letter sent to the In response to criticisms I The template termination
termination or branch operator. in the Judgment, letters are to be reviewed
reinstatement communications with and amended if
decision to branch If appointed under I branch operators should I necessary in light of the
operator. a traditional form be open and Judgment.

of contract, the transparent.
branch operator is
notified of the right
to appeal.
4.9 I Respond to any The decision to N/A No change.

request for an appeal
(traditional forms of
contract only).

terminate is
reviewed by an
Appeal Manager.

Branch operator
may be re-instated

38

POL00279838
POL00279838
at this point, or
Post Office
proceeds with
decision to
terminate.

4.1 I Stakeholders notified I If the termination N/A No change.
0 of termination. is as a result of
finding a negative
cash variance, the
Loss Recovery team
is notified (see
2.4.3).
4.1 I Confirm termination Letter issued to In response to criticisms I The template letters are
0 decision if appealed branch operator in the Judgment, to be reviewed and
(traditional forms of ("consequences of I communications with amended if necessary in
contract only) and termination letter" I branch operators should I light of the Judgment.
notify branch / “letter 2D"). be open and
operator of next transparent.
steps. If the termination
is being carried out
“on notice" rather
than immediately
for breach, the
branch operator
may be reinstated
to work through
the notice period.
4.1 I Complete case All relevant N/A No change
1 summary. documents are

embedded and
uploaded to branch
record in

39

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I SharePoint.

40