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SUMMARY OF AGREED AND DISPUTED CLASSES OF DOCUMENTS
ISSUE FOR PLEADING REF AGREED CLASSES OF DOCUMENTS CLAIMANTS' ADDITIONAL REQUESTS WHICH ARE
albert ss (Info only) e Defendant's original classes are set out in black. tesa Re UE Wadd Mlk
e Classes / words in green are additions proposed by
the Claimants and accepted by the Defendant.
Products and GPOC 4-5, 15 1. Indexes, organisational charts, schedules or diagrams of a) Policies, manuals, process documents, setting out
services offered GDef 24-25 the suite of products and services offered by Post Office procedures to be applied between Post Office and
by Post Office. . since 1999 its clients for dealing with discrepancies, shortfalls
Reply 20 2. Written policies and process documents relating to the or losses.
rolling out of products and services to postmasters since
1999.
Post Office's GPOC 8-10 3. Suite of standard contractual documents used by PO when b) Minutes of management meetings to discuss the
standard appointing postmasters, since 1999. variation of postmasters’ contracts nationally insofar
GDef 28 - 31 Ren -
contract terms 4. Suite of product or service-specific contracts between Post as such variations concerned or impacted upon the
Office and postmasters and guidelines referred to in the Operation or use of Horizon, branch accounts and/or
: discrepancies and shortfalls that may arise therein.
reports of Second Sight
ote - . c) Minutes of management meetings in which the
5. Contractual variations issued to the branch network since operation and effect of section 12, clause 12 of the
. standard contract was considered or discussed.
6. Written policies and process documents relating to the d . .
" ) Standard guidance, rules, or Instructions to
process of varying a postmaster's contract. Managers / Contract Advisors regarding the
7. Standard and template documents, letters, notes and operation and effect of section 12, clause 12 of the
memos issued to postmasters relating to the variance of
their contracts.
standard contract.
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Appointment of
postmasters
GPOC 42 - 46
GDef 78 - 82
8.
Written policies and process documents relating to:
a. the advertising for vacancies (permanent and
temporary)
b. the postmaster application processes
c. the on-boarding process (including the provision
of contracts)
d. checks on postmasters prior to appointment
e. upfront payments made by postmaster to Post
Office; and
f. deductions from postmasters remuneration upon
a postmaster joining Post Office
Standard and template documents, letters, notes and
memo issued to postmasters before or shortly after
appointment as a postmaster.
Operation of Horizon}
GPOC 12 - 17, 22
— 24, 25-28
GDef 33 - 38, 57-60
Reply 9, 36, 41
10.
11.
12.
13.
14.
Technical documents regarding Horizon stored by Fujitsu in
its Dimensions systems (Subject to Post Office using its
best endeavours to give disclosure of those documents that
are under Fujitsu's control)
Known Error Log (subject to a suitable means of inspection
being agreed).
Branch Operating Manual (including previous versions or
equivalent historic document).
Operating instructions and rules issued to all postmasters.#
Minutes of meetings of Post Office's board of directors (or
historic equivalent) (a) between 1999 and 2001 at which the
roll-out of Horizon, its operation and any associated
operational risks were considered or discussed, and (b)
between 2010 and 2011 at which the same was considered
or discussed with respect to Horizon Online, limited in each
case to matters associated with financial reconciliations,
shortfalls, discrepancies or losses.
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Fujitsu GPOC 20-21 15. Contract between Post Office and Fujitsu (ICL) for Horizon e) Minutes of meetings between Post Office and
GDef 47 - 50 and all written contractual variations to it. Fujitsu at which any known or suspected bugs,
errors, or defects (of the nature referred to at
Reply 9.6(e), 44 paragraphs 22 to 24 of the Amended Generic
and 45 Particulars of Claim) were considered or discussed,
including the Calendar Square/Falkirk issues,
Payments Mismatch issue, and Suspense Account
bug.
Information GPOC 14.2 and 16. Technical documents regarding Horizon stored by Fujitsu in f) Written instructions to Managers and Trainers
available to 19.3 its Dimensions systems (Subject to Post Office using its regarding the availability and provision of
postmasters best endeavours to give disclosure of those documents that transaction information to postmasters.
regarding GDef 35, 76(6), 92 are under Fujitsu's control)
: 93 g) Internally and externally produced management
transactions 7 4 : ; + . fa
Reply 11, 14.2- 17. Branch Operating Manual (including previous versions or information, reports and briefing papers containing
14.4. 15. 16.1 equivalent historic document). information and data relating to the aggregate
“oe 18. Any written policies or process documents regarding the yume: value ane nature of qonsaction
completion of branch accounts in the period immediately ‘Orrections Issued annually since °
before Horizon was introduced.
19. Any guidance notes or written advice issued to postmasters
on accessing transaction information through Horizon.
Information GPOC 55 h) Written policy and process documents, guidance,
available to Post
Office regarding
transactions
GDef 76(4)-(6), 92
93
Reply 46, 47
notes or memoranda relating to:
i. The ability of Post Office (whether itself or by
Fujitsu) remotely to detect the occurrence of
shortfalls or other branch account
discrepancies, when the same occurred and
whether those discrepancies were caused by
bugs, errors and/or defects in the Horizon
system;
ii. the ability of Post Office and/or Fujitsu to
conduct transactions, (by entering, deleting
or otherwise altering the same) in
postmasters’ branches remotely;
iii. specific authorization to conduct such
transactions;
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iv. the exercise of any such ability referred to in
a. above;
v. the use of “Global User” authorization by
Post Office employees and/or contractors;
vi. the use of “privileged user access rights” by
Fujitsu employees and/or contractors; and
Balancing Transactions.
vii.
Any written policies or process documents and
network-wide instructions to Managers / Contract
Advisors / Auditors regarding the recovery of
shortfalls from postmasters.
Minutes of meetings / memoranda / reports relating
to Post Office's network-wide approach to
identifying, tracking or managing discrepancies,
shortfalls or losses, or to Postmasters' ability to
dispute shortfalls.
Transaction GPOC 18 20. Branch Operating Manual (including previous versions or k) [Claimants version of request 22] Post Office written
Corrections GDef 39-41 equivalent historic document). policies, and process documents, internal guidance
7 21. Operating instructions and rules issued to postmasters in and briefing notes regarding the issuing of
Reply 21, 32 relation to Transaction Corrections. Transaction Corrections.
22. Post Office written policies and process documents
regarding the issuing of Transaction Corrections.
Declaring, GPOC 19.1 - 19.3 23. Branch Operating Manual (including previous versions or
Making Good GDef 44-46 equivalent historic document).
and Disputing 24. Guid: d hi ,
Shortfalls Reply 9.3, 22 . Guidance notes issued to postmasters on low to complete
~ overnight cash declarations and Branch Trading
Statements.
25. Guidance notes issued to postmasters on how to make
good, settle centrally and dispute shortfalls, including, but
not limited to, outside of the 42/60 period
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26.
27.
Written policies regarding postmasters making good and
settling centrally shortfalls.
Written policies or process documents regarding the reports
which could be run or steps taken by postmasters to
investigate shortfalls.
Training GDef 17, 61(2), (4), 28. Written policies and process documents relating to the 1) Policies, instructions and guidance notes issued
(5) provision of training when a new postmaster joins Post network-wide to trainers related to training on
Office, from 1999. Horizon and Horizon Online.
Reply 42 - 43
29. Written policies on when further training is offered due to m) Course materials focusing on the dealing with or
the introduction of new products and services. disputing of discrepancies.
30. Training materials and other standard / template n) Network-wide instructions to Post Office trainers in
documents used for new postmasters. how to train a postmaster to deal with and dispute a
F as . . shortfall.
31. Written policies or process documents relating to ongoing
training which is provided due to theneeds of postmasters
or the introduction of new practices, systems or services.
Helpline GPOC 29 - 30, 57 - 32. NBSC Knowledge Base (subject to a suitable method of ©) [to be included at the end of 33] and (b) instructions
58 inspection being agreed). to both Helplines in dealing with queries from
GDef 61-62 33. Written policies and procedures regarding the operation of Postmasters regarding shortfalls .
Reply 18 - 19 either the NBSC or HSD helplines, including but not limited
to (a) the operation of the escalation process, particularised
at paragraphs 61-62 of the Generic Defence (excluding
criminal investigations).
34. Formal notices issued to postmasters regarding the
operating hours of helplines.
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Investigations GPOC 31 35. Written policies and procedures regarding the investigation
of shortfalls in branches (excluding investigations into
GDef 63 - 64 suspected criminal misconduct).
Reply 23 - 24 36. Written policies and procedures for initiating and
progressing audits.
37. Instructions or guidance (excluding emails) given to
auditors on dealing with discrepancies, shortfalls and losses
identified or suspected in branch.
Termination GPOC 32 - 33 38. Written policies and process documents relating to:
GDef 65 - 66 a. the suspension of postmasters; and
b. the termination of postmaster's contracts (and any
connected appeals process).
Suspense Accounts I GPOC 38 - 39 39. Written policies and process documents in relation to the
GDef 73 - 74 operation by Post Office of any "suspense" account
associated with branch accounting, including, specifically,
Reply 29 -33 the account or accounts in which unattributed surpluses
generated from branch accounts (such as, for example,
perceived overpayments by banks in respect of particular
transactions) were placed and, after a period of 3 years,
credited to Defendant's profits and reflected in its profit and
loss accounts.
Assistants
GPOC 43, 56 and
74
GDef 79, 95 and
116
40.
41.
Written policies and process documents relating to the
appointment and registration of assistants.
Training materials provided to postmasters for the training
of assistants.