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Postmaster support
policy
Version 5.0
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Post Office is determined to reset its relationship with
postmasters and has introduced policies that set out guidelines
on how Post Office should support postmasters, specifically for
use across twelve areas.
The policies stand on their own but should be reviewed in
conjunction with each other. Support teams should have an
awareness of all twelve policies and how they link together.
The twelve Postmaster Support Policies are listed in section
3.2 of this policy and can be found on the hub, here.
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Contents page
2 Overview...
2.1 — Introduction...
2.2 Purpose...
2.3. Core principles ..
2.4 Application
2.5 The risk...
w
Risk appetite ....
3.1 Risk appetite.
3.2. Policy framework...
3.3 Who must comply?.
3.4 Roles and responsibilities.
3.5 Minimum control standards.....
4 Procedure...
4.1 Contract performance issues
4.2 Review...
4.3. Recording decisions...
4.4 Review outcomes.
4.5 Monitoring period...
4.6 Business improvement opportunities...
5 Where to go for help
5.1 Additional policie:
5.2 How to raise a concern..
5.3. Who to contact for more informatio
6 Governance.
6.1 Governance responsibilities...
7 Document control...
7.1 Document control record...
7.2 Oversight committee.
7.3, Company details...
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8 Appendices
8.1 Contract Performance Rationale...
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1 Definitions
1.1 Definitions
1. Branch Assurance - This is a comprehensive assessment of the current trading position of a
branch, and includes the verification of reported levels of cash, foreign currency (if
applicable), stock items and vouchers as well as a compliance review, to check if mandatory
business conformance and regulatory compliance controls are operating as intended.
2. Contractual Action — the means of resolving a performance matter with a postmaster
through a formal request, most commonly a Written Direction.
3. Contract Performance Issue — A matter that arises where a postmaster is not meeting their
obligations as set out in their contract to the required standard in relation to a material
matter.
4. Contract Performance Rationale (see Appendix 8.1) - A rationale completed by the Contract
Advisor which captures the facts and findings of their review into the matter and sets out the
rationale outlining next steps.
5. Postmaster or postmaster- this refers to a limited company, partnership, limited liability
partnership, other entity or individual that contracts with Post Office for the operation of a
Post Office® branch.
6. Written Direction — A formal letter issued following the review which outlines the breach of
contract, sets out expectations and what is required of the postmaster and explains the
consequences of not doing so.
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2 Overview
2.1 Introduction
The Retail Engagement Director has overall accountability to the Board of Directors for the design
and implementation of controls to manage risk in the network’. Risk in the network is an agenda item
for the Risk Committee and the Post Office? board is updated as required.
This policy is a non-contractual document provided for information. It does not form part of a contract
between any postmaster? and Post Office.
This policy forms part of a suite of policies designed to deal with the management of postmaster
contracts and for those teams deploying any aspect of this policy it should be read together with the
Postmaster Contract Suspension and Postmaster Contract Termination policies. These polices can be
found on the hub, here.
2.2 Purpose
This policy is part of a framework that has been established to set the minimum operating policies
relating to the management of contracts with postmasters.
It is important that each postmaster is able to ensure the obligations as set out in their contract are
performed to the standards required and are provided support by Post Office to meet these
standards. Post Office recognises that there will be occasions where these standards are not being
met.
The purpose of this policy is to identify the circumstances where these standards are not being met,
the review process and to outline the procedures to be followed to ensure performance of the
contract, while supporting the postmaster in this process.
This policy is one of a number of policies which provide a clear risk and governance framework and
an effective system of internal control for the management of risk across the Group. Compliance with
these policies supports the Group in meeting its business objectives and to balance the needs of
postmasters, customers, shareholders, employees, other stakeholders (such as the government
departments) and third party commercial partners including Royal Mail.
In this policy, “network” means branches not directly managed by Post Office.
? In this policy, “Post Office” and “Group” means Post Office Limited.
In this policy, “postmaster” refers to a limited company, partnership, limited liability partnership, other entity or individual that
contracts with Post Office for the operation of a Post Office® branch
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2.3 Core principles
Post Office has an obligation to its customers and clients to ensure that all branches are providing a
quality of service and adhering to agreed standards. Post Office is committed to supporting its
postmasters in this process.
It is vital that, to the extent reasonably possible, any performance issues are resolved through Post
Office and postmasters supporting and working with each other through the available methods. It is
recognised that formal actions to ensure performance of the contract can be stressful for the
postmaster and may have an impact on the operation of the branch; therefore, formal action should
only be taken where necessary and where alternative methods to resolve the performance issue have
been considered.
Accordingly this policy, and its linked policies, sets out clear and consistent guidelines to ensure that:
e areview is carried out to establish the facts before any formal contractual action may be
taken and that the postmaster is given the opportunity to identify and address any issues of
concern; and
* consideration is given to the postmaster’s circumstances when Post Office is deciding
whether to take formal contractual action.
Post Office will handle these situations in good faith and apply the principles of fairness,
transparency, and professionalism (being the underpinning behaviours of Post Office).
2.4 Application
This policy is applicable to all all Post Office employees who manage postmaster contracts on behalf
of Post Office and defines the minimum standards to control financial loss, postmaster impact,
regulatory breaches and reputational damage in line with the Post Office's Risk Appetite.
2.5 The risk
Post Office is required to review a potential contract performance issue before taking any contractual
action and in doing so needs to:
ensure that any decisions taken in respect of a postmaster contract are not exercised
arbitrarily, capriciously or unreasonably;
* exercise any contractual power honestly and in good faith for the purpose for which it was
conferred on Post Office; and
* exercise any discretion in accordance with the obligations of good faith, fair dealing,
transparency, co-operation and trust and confidence.
f, temporary staff including agency staff, contractors, consultants and anyone
In this policy “employee” means permanent si
else working for or on behalf of Post Office and, for clarity, does not include postmasters or postmasters’ staff.
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Failure to deal with a contract performance issue in the correct manner creates risks for both Post
Office and postmasters, which include (but are not limited to):
e formal contractual action being taken without proper cause or a contractual basis may cause
unneccessary distress for the postmaster and Post Office will not have acted in good faith;
e loss of confidence in how Post Office manages the contractual relationship;
* stakeholders having reduced confidence in Post Office's ability to effectively manage
postmaster contracts;
* Post Office may suffer reputational damage; and
e Post Office may be in breach of its contractual or regulatory obligations.
Section 3.5 sets out the minimum control standards that the Post Office has implemented to control
these risks.
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3 Risk appetite
3.1 Risk appetite
Risk appetite is the extent to which the Post Office will accept that a risk might happen in pursuit of
day-to-day business transactions. It therefore defines the boundaries of activity and levels of
exposure that Post Office is willing and able to tolerate.
Post Office takes its legal and regulatory responsibilities seriously and consequently has:
« Averse risk appetite to risks around service and support provided to postmasters.
e Averse risk appetite towards risks around our core operational processes that impact
postmasters.
« Averse risk appetite to being non-compliant with our statutory and regulatory obligations.
« Averse risk appetite for financial crime to occur within any part of Post Office or the network.
e Averse risk appetite in relation to unethical behaviour by Post Office employees.
« Averse risk appetite to risks around disputes and litigation.
e Cautious risk appetite towards the risk of service interruptions that would considerably
reduce branch availability across the network resulting in the inability to serve customers.
Post Office acknowledges however that in certain scenarios even after extensive controls have been
implemented a risk may still sit outside the agreed Risk Appetite/Risk Tolerance. Risks outside of
Appetite/Tolerance may be presented to the relevant governance forums for escalation/agreement of
the risk position.
If a risk is identified which is outside of agreed policy a risk exception note will be required, details of
which can be found here.
3.2 Policy framework
This policy is part of a framework that has been established to set the minimum operating policies
relating to the management of postmaster contract risks throughout the business and network in line
with Post Office's risk appetite. The framework includes the following policies:
e Postmaster Onboarding
e Postmaster Training
e Postmaster Complaint Handling
e Network Monitoring and Branch Assurance Support
e Network Cash and Stock Management
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« Network Transaction Corrections
* Postmaster Account Support
e Postmaster Accounting Dispute Resolution
e Postmaster Contract Performance (this policy)
e Postmaster Contract Suspension
« Postmaster Contract Termination
« Postmaster Contract Termination Decision Review
3.3 Who must comply?
Compliance with this policy is mandatory for all Post Office employees who manage postmaster
contracts on behalf of Post Office.
Where non-compliance with this policy by Post Office employees is identified by Post Office, Post
Office will carry out an investigation. Where it is identified that an instance of non-compliance is
caused through wilful disregard or negligence, this will be investigated in accordance with the Group
Investigations Policy.
3.4 Roles and responsibilities
« Audit, Risk and Compliance Committee — is the Committee of the Post Office Limited Board
which reviews and approves Postmaster Support policies.
« Risk and Compliance Committee - is the standing committee of the Group Executive who
review and approve Postmaster Support policies for recommendation to the Audit, Risk and
Compliance Committee.
e Retail Engagement Director — is the policy owner, who must comply with the governance
responsiblities set out at section 6.1.
e Head of Contract Management & Deployment - is accountable for the deployment of this
policy, for supporting Post Office personnel who carry out actions under this policy and for
regularly reviewing the effectiveness of this policy and for drafting any amendments to it that
may be required.
* Area Manager(s) - is (are) responsible for the relationship between Post Office and
postmasters regarding the management of their branches, including raising performance
issues prior to the deployment of the procedures and decisions required in this policy.
e Contract Advisor(s) — is (are) responsible for deploying the procedures set out in this policy.
The Contract Advisor(s) form part of the Contracts Team.
The Contract Advisor must:
o apply the Post Office's underpinning behaviours of fairness, transparency and
professionalism;
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© be conversant with this policy and linked policies;
© act as a guide and advisor to those Post Office teams, particularly Area Managers,
dealing with contract performance issues to ensure consistency of approach;
© ensure that all necessary steps have been taken by Post Office teams to support
postmasters to address the identified issues, with the appropriate documentation
completed;
© revert to the relevant Post Office team to address any identified instances where steps
have not been taken or appropriate documentation not completed by Post Office in
relation to managing performance issues;
© review the contract performance issue, gathering as much information as possible
relating to the contract performance issue that has come to light, liaising as appropriate
with the postmaster and other Post Office teams and keeping complete records, before
taking any formal contractual action;
© consider the options available as an alternative to contractual action, discussing if
required with the Head of Contract Management & Deployment;
© deal with any contact, written or otherwise, from the postmaster, in a timely manner;
© ifa meeting is required, be flexible, within reason, over the availability of the postmaster;
© ensure any decision is made in line with all other linked Post Office policies;
© make the postmaster aware of the support available to them, including from the National
Federation of Sub Postmasters;
© ensure that once any formal contractual action is taken the situation is monitored (by
other Post Office teams if necessary) and the postmaster is clear on the consequences of
not complying with the formal contractual action.
* National Federation of Sub Postmasters (NFSP) - is a professional trade association which
exists to support postmasters.
* Postmaster — refers to a limited company, partnership, limited liability partnership, other
entity or individual that contracts with Post Office for the operation of a Post Office® branch.
As many postmasters are limited companies or partnerships (and as individual postmasters
may appoint managers to operate a branch on their behalf) any steps that need to be taken
by a postmaster under this policy can be taken by someone authorised to act on that
postmaster's behalf (such as a director or partner).
e In relation to this policy, the postmaster is expected to:
© be transparent and open towards Post Office;
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ensure they respond to written correspondence and telephone calls in a timely
manner in order to assist the Contract Advisor in reaching a decision;
be flexible and available for meetings with the Contract Advisor if one is required;
and
comply with the terms of any letter (including a written direction) issued by the
Contract Advisor once any investigation is complete.
In relation to this policy, the postmaster may:
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contact their NFSP representative to support them through the process;
arrange legal representation or other support for any written correspondence or
meetings with Post Office;
let their NFSP representative, legal representation or other support talk on their
behalf during any meeting with Post Office Ltd
request information and evidence from Post Office in connection with this process
and wider review; and
contact a Contract Advisor at any time during or after the review process, including
in relation to a written direction that Post Office has issued to a postmaster.
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3.5 Minimum control standards
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A minimum control standard is an activity which must be in place in order to manage the risks, so they remain within the defined risk appetite statements (as
set out at section 3.1). There must be mechanisms in place within each business unit to demonstrate compliance. The minimum control standards can cover
a range of control types, i.e. directive, detective, corrective and preventive which are required to ensure risks are managed to an acceptable level and within
the defined risk appetite.
The table below sets out the relationships between identified risks and the required minimum control standards in consideration of Post Office's risk
appetite.
Risk area Description of risk Minimum control standards Who is When
responsible
Taking If formal contractual action is e The Contract Advisor will conduct a review, Contract As required
contractual taken without proper cause or keeping full records, and if required complete a_I Advisor
action without contractual basis it may cause Contract Performance Rationale capturing the
proper cause unneccessary distress for the relevant facts and rationale for next steps,
postmaster and Post Office will ensuring that Post Office itself is not in material
not have acted in good faith. breach of duty and any action is being taken
with proper cause.
This may also lead to reputational
damage and put Post Office in ® = Quality checks and training covering the
breach of contractual and contract performance process will take place Head of Quarterly
regulatory requirements, which with the Contracts Team to ensure that the Contract
could lead to legal challenges. correct process is followed. Management &
As part of the Branch Control Assurance Deployment
Framework, rationale documents, methodologies,
and evidential evaluations will be sampled on a
monthly basis by the Branch Control Assurance
Framework. Head of Monthly
Assurance &
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Complex
Investigations
Loss of If Post Office are not making the « Alldecisions to take formal contractual action Contract As required
confidence correct decisions by either: are supported by a rationale setting out the Advisors
e taking formal contractual grounds for doing so, taking account of all
action when it has no relevant factors after having reviewed the
grounds to do so; or alleged contractual performance issue.
* not taking contractual action As part of the Branch Control Assurance
when it should, Framework, rationale documents, methodologies,
it may lead to a loss of confidence I and evidential evaluations will be sampled on a Head of Monthly
both across the postmaster monthly basis by the Branch Control Assurance Assurance &
network and with Post Office's Framework. Complex
stakeholders in how Post Office Investigations
manages the contractual
relationship with its postmasters.
Policy non- Non-adherence to the policy * Allmembers of the Contracts Team, the wider I Head of Once approved and
adherence could result in legal and Retail Operations Team and any teams who Contract annually thereafter (or
regulatory risk as well as may be involved in the decisions being taken Management & I sooner in the event of
reputational damage to Post will be provided with training on this policy. Deployment material changes to the
Office and the relationship with policy)
postmasters. * The Head of Contract Management &
Deployment is accountable for ensuring that Daily
they and their team adhere to the policy, as it
applies to their area.
* The Policy should be reviewed, and if As required (but
necessary updated. reviewed at least
annually)
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4 Procedure
4.1 Contract performance issues
A contract performance issue arises where a postmaster is not meeting their obligations as set out in
their contract to the required standard in relation to a material (i.e. non-trivial) matter. The following
are examples which may, depending on the circumstances, indicate that there is a contract
performance issue:
e — Escalating/continuing discrepancies;
e Not adhering to contracted opening hours;
e Customer complaints, such as failure to adequately deal with customer complaint(s), the
existence of an unusually high level of customer complaints, or of a pattern of complaints
suggestive of underlying failures to meet their obligations. However, the mere existence of
customer complaints against the branch should not be assumed to amount to a contractual
performance issue;
«Branch accounting non-conformance;
e Financial or other irregularities, including possible fraudulent activity (including Fees fraud);
e Breach of contractual non-compete restrictions;
e Failure to comply with legal or regulatory requirements e.g. Anti-Money Laundering
regulations, mails integrity requirements; and
e Failure to meet premises standards.
The contract performance issues procedure is intended to be used for breaches of contract which do
not entitle Post Office to immediately terminate the contract. Very serious breaches of contract which
entitle Post Office to immediately terminate the contract are outside the scope of this policy and are
dealt with in the Postmaster Contract Termination policy®. However, for reference, these may include
(but are not restricted to):
«Where the postmaster is bankrupt or insolvent;
* Where the postmaster is no longer operating the basic business;
« Where the postmaster has been charged on suspicion of a criminal offence (other than a
road traffic offence not involving imprisonment);
* Other breaches which are very serious (“repudiatory”) in nature, which may include:
The Postmaster Contract Termination policy can be found on the hub, here.
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o Where the postmaster has admitted theft of Post Office funds;
© Any action by the postmaster that demonstrates the postmaster no longer intends to
be bound by the contract including loss of a valid property interest;
© Sustained non-compliance by the postmaster following the issuing of written
directions by Post Office; and
o Where a shortfall of a significant value has been caused by the negligence,
carelessness or error of the postmaster, resulting in a loss to Post Office, and which
have been fully investigated by Post Office.
Further details are included in the Postmaster Contract Termination policy when dealing with matters
which may give rise to serious breaches such as the above.
A process map detailing the contract performance process can be found in appendix 8.2.
4.2 Review
Post Office will review a potential contract performance issue before taking any formal contractual
action.
Any review will be a fair and unbiased method of investigating issues identified prior to any formal
action being considered. The process of review allows Post Office to establish facts and gives the
postmaster the opportunity to identify and answer any issues of concern raised.
In the review process, the Contract Advisor should seek further information from the postmaster
through written correspondence (including emails), telephone conversation(s) or a face to face
meeting.
Post Office will ensure that complete records are kept of all reviews and that any decisions taken in
relation to a review are documented in rationale documents. Records will be retained in accordance
with Post Office's document retention policy®.
Details of the review and the supporting records and information willbe shared with the postmaster
unless the material is subject to a restriction on disclosure such as:
e legal privilege;
e data protection law; and
«material relating to a criminal investigation.
® The Document Retention and Disposal Policy (Group Policy) can be found in the Group Key Policies on The Hub
https//poluksharepoint.com/sites/thehub/Policies/Forms/Alllitems.aspx?id=%2F sites%2Fthehub%2FPolicies%2F acumen
Policy2
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The Contract Advisor should make an asessment whether any restrictions on disclosure apply in
advance of sharing material with the postmaster and seek advice from Post Office’s Data Protection
and Information Rights Team if required.
The Contract Advisor will inform the postmaster of the grounds on which it is being reviewed and its
rights to access information and records relating to the review, as set out above, upon the
commencement of and during the review process.
4.3 Recording decisions
Once a review is complete the Contract Advisor will keep a record of any decision taken, including
the reasoning behind why any decision was taken. This may include preparing a Contract
Performance Rationale document capturing the material information provided by the postmaster,
relevant documentation provided by other Post Office teams connected to the issue, any action taken
by the Contract Advisor and a rationale outlining next steps.
If the matter being reviewed is raised through a Branch Assurance visit the rationale for next steps,
and any contractual action, will be captured in the non-suspension rationale.
Post Office will not take any formal contractual action in connection with a contract performance
issue without ensuring that:
the performance issue has been raised with the postmaster through the most appropriate
team (most commonly the Area Manager) in accordance with the requirements of section 4.2,
with clear expectations having been set and any reasonably required support provided
(including additional training if required). All action taken, including anything agreed with the
postmaster, will be documented appropriately by the relevant Post Office team;
e it has knowledge of the relevant applicable facts and a review of the contract between Post
Office and the postmaster has been carried out to establish that there is a contract breach;
* consideration has been given as to the seriousness of the breach; and
« ithas considered whether Post Office is itself in material breach of duty in respect of the
matters giving rise to the right to take contractual action (i.e. the contract performance issue).
In line with the Postmaster Contract Suspension policy and Postmaster Contract Termination
policy, the Post Office must not suspend or terminate a contract with a postmaster where it
is itself in material breach of duty in respect of the matter giving rise to Post Office's right to
suspend or terminate (as applicable).
If required, the Contract Advisor can request support from the Head of Contract Management &
Deployment in reviewing the decision.
In circumstances where the review has concluded that there has not been a breach of contract by the
postmaster and, therefore, Post Office will not take formal contractual action, Post Office will write to
the postmaster to advise them of this.
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Following an investigation, Post Office may also decide that even though there has been a
contractual breach, it does not intend to take formal action at this time. In these circumstances, Post
Office will write to the postmaster to advise them of this.
4.4 Review outcomes
Following review the Contract Advisor may take the following steps:
a)
c)
d)
e)
Performance Intervention — the postmaster will be advised that whereas no formal contractual
action is taken they will be reminded of the need to deploy the obligations of their Agreement
and, ultimately what the consequences of not doing so may be. In these circumstances, Post
Office will write to the postmaster to advise them of this and appropriate support to the
postmaster can be offered.
Written Direction - this is a means by which a postmaster is formally requested in writing to take
steps to resolve the contract performance issue. A written direction (using a standardised
template letter) will only be issued, other than in genuine cases where very urgent action is
required, if all of the steps outlined under section 4.3 (Recording Decisions) have been
completed. A written direction will:
outline the breach(es) of contract based on the applicable facts;
give the postmaster a period of time to rectify the issue explaining what is required to do
so. In determining the period of time, regard should be had to the terms of the contract
relevant to the breach and to what is reasonable in the circumstances; and
* explain the consequences of not doing so.
If the postmaster fails to rectify the issue by the time required to do so or indicates they will not
rectify the issue, then the Postmaster Contract Termination policy should be referred to.
Branch Assurance - if the review has highlighted a serious risk either to the postmaster or Post
Office then a Branch Assurance visit may be requested and the steps outlined in the Postmaster
Contract Suspension policy followed, if appropriate.
If a very serious breach (or breaches) of contract are identified as part of the review these will be
dealt with in the Postmaster Contract Suspension policy and Postmaster Contract Termination
policy.
In addition to the action outlined above Post Office may consider further measures to reflect the
nature of the performance issue when considered against regulatory risk to Post Office and its
customers, for example financial consequences (in the form of reasonable costs to undertake
training) and removal of products. Any action taken in this respect will be considered against the
principles and processes as set out in this policy document.
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4.5 Monitoring period
Following a review the appropriate Post Office team will monitor the situation. An assessment will be
made on the length of monitoring period dependent on the individual circumstances but it is unlikely
that this will last longer than 12 months. Should the issue reoccur then the facts will be reported to
the Contract Advisor for them to consider appropriate next steps.
Sustained non-compliance may amount to a repudiatory breach.
4.6 Business improvement opportunities
As part of the review process the Contract Advisor may identify improvement opportunities or
business issues outside of the decisions being reviewed (for example have avenues of support not
offered to the postmaster been identified). In these instances, the Contract Advisor will capture
opportunities on the Contract Performance rationale document and escalate to the relevant team.
These will be monitored and tracked.
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5 Where to go for help
5.1 Additional policies
This Policy is one of a set of policies. The full set of policies can be found on the SharePoint Hub
under Postmaster Support Policies.
5.2 How to raise a concern
Any postmaster, any postmaster's staff or any Post Office employee who suspects that there is a
breach of this Policy should report this without any undue delay.
If a postmaster or any postmaster's staff are unable to raise the matter with the area manager of the
relevant branch or if a Post Office employee is unable to speak to her or his line manager, any person
can bring it to Post Office’s attention independently and can use the Speak Up channels for this
purpose. Any person can raise concerns anonymously, although disclosing as much information as
possible helps ensure Post Office can conduct a thorough investigation.
For more details about how and where to raise concerns, please refer to the current Whistleblowing
Policy which can be found on The Hub under Post Office Key Polici sed here, or report online
at: http://speakup.postoffice.co.uk or call the Speak Up Line on’
Please note that a postmaster may also contact the National Federation of Sub-Postmasters (NFSP)
for help and support.
5.3 Who to contact for more information
If you need further information about this policy or wish to report an issue in relation to this policy,
GRO
please contact Tracy Marshall, Retail Engagement Director at tracy.marshalli
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6 Governance
6.1 Governance responsibilities
The Policy sponsor, the Group Chief Retail Officer of Post Office, takes responsibility at Group
Executive level for policies covering their areas.
The Policy Owner is the Retail Engagement Director who is responsible for ensuring that the content
is up to date and is capable of being executed. As part of the review process they need to ensure that
the minimum controls articulated in the policy are working or to identify any gaps and provide an
action plan for remediation
Additionally, the Retail Engagement Director and the Head of Contract Management & Deployment
are responsible for providing appropriate and timely reporting to the Risk and Compliance Committee
and the Audit, Risk and ComplianceCommittee as required.
The Audit, Risk and Compliance Committee are responsible for approving the Policy and overseeing
compliance.
The Board is responsible for setting Post Office's risk appetite.
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7 Document control
7.1 Document control record
Summary
GE policy sponsor Standard owner Standard implementer Standard approver
Martin Roberts (Group Tracy Marshall (Retail David Southall (Head of R&CC/ARC
Chief Retail Officer) Engagement Contract Management and
Director) Deployment)
Document review " : s
Postmaster Support
5.0 Annual 12/2023 Policies on SharePoint
Hub
Revision History
11 2° March 2020 Draft Version David Southall
1.2 3" March 2020 Minor Edits Tim Perkins
13 6" March 2020 Legal Review Tim Perkins
14 17" March 2020 For working group review Tim Perkins
15 9" April 2020 Final Draft with working group revision Tim Perkins
16 14" May 2020 Final draft following further legal review Tim Perkins
2.0 6" April 2021 Annual review — initial draft changes David Southall,
Head of Contract
Management &
Deployment
21 14® April 2021 Initial legal review David Southall,
Head of Contract
Management &
Deployment
22 26" April 2021 Second legal review David Southall,
Head of Contract
Management &
Alignment with other postmaster support policies Deployment
23 4" May 2021 Risk appetite amendment Jo Milton
Addition of process map
3.0 23 May 2021 Updated following ARC feedback including: David Southall,
Head of Contract
Management &
Addition of definitions Deployment
Updated to V3.0
Addition of Contract Performance Rationale
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3.1
3.2
4.0
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16 November 2021
18 February 2022
1 April 2022
5% July 2022
5" October 2023
15" December 2023
Added linked policy statement to front page
Added reference to the Group Investigations Policy
to section 3.3 Who Must Comply?
Updated link to section 5.1
Added footnotes to link to other policies referred to
in this policy.
Annual Review
3.1 Updated risk appetite statements to include
Operational statements
4.4 Additional paragraph referencing possible
further measures
4.6 New section — Business Improvement
Opportunities
Updates made to reflect legal review of Decision
Review Policy and changes relevant to this policy.
NFSP review
Amended version number following approval
2.1, 3.4, 5.3, 6.1, 7.1- updated owner and sponsor
Font updated to Nunito Sans
Annual Review
2.1 Policy owner changed to Retail Engagement
Director (with associated changes throughout)
3.4 RCC and ARC added
3.4 Addition of a note to say that the NFSP
representative, legal representation or other
support talk on a postmaster's behalf during any
meeting with Post Office Ltd
3.5 Control amendment - a Contract Performance
Rationale may not be completed on every occasion
3.5 Assurance review now undertaken by
Assurance & Complex Investigation
4.2 Section title changed from ‘Investigation’ to
‘Review’ to better reflect what the Contract
Advisors do in reviewing the situation and
determining any necessary action.
4.3 Changed from Contract Performance Rationale
to Recording Decisions to reflect that a Contract
Performance Rationale may not be needed for
every escalation dealt with by the Contracts Team
but that full records will be kept.
4.4 Changed from Contractual Action to ‘Review
Outcomes’ to set out the options available to the
Contract Advisor following review
5.2 Added Speak Up contact details
Governance - Policy owner changed to the Retail
Engagement Director
8.1 Most up to date Contract Performance rationale
added
Amended version number following approval
Rebranded
Postmaster contract performance policy V5.0
POL00447950
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David Southall,
Head of Contract
Management &
Deployment
David Southall,
Head of Contract
Management &
Deployment
Jo Milton
Jo Milton
David Southall
Jo Milton
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7.2 Oversight committee
Oversight Committee: Risk and Compliance Committee and Audit, Risk and Compliance Committee
Committee Date Approved
POL R&CC 10 NOV 2023
POL ARC 27 NOV 2023
Next review: 30 NOV 2024
7.3. Company details
Post Office Limited and Post Office Management Services Limited are registered in England and Wales. Registered numbers 2154540 and
08459718 respectively. Registered Office: Finsbury Dials, 20 Finsbury Street, London EC2Y 9AQ.
Post Office Management Services Limited is authorised and regulated by the Financial Conduct Authority (FCA), FRN 630318. Its Information
Commissioners Office registration number is ZA090585.
Post Office Limited is authorised and regulated by Her Majesty's Revenue and Customs (HMRC), REF 12137104, Its Information Commissioners
Office registration number is 24866081.
VAT registration number GB 172 6705 02. Registered office: Finsbury Dials, 20 Finsbury Street, London, England EC2Y 9AQ
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8 Appendices
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8.1 Contract Performance Rationale
Contract Performance Rationale Document
Bral Details
Branch Name
Branch Code
Contract Type and Code (i.e., Local NT1)
Operator Name
Named individual (any reference made to this
individual within this document is as
representative of the Operator)
Is the Operator an absentee
(i.e., managing from a distance)?
YES/NO*
*delete as applicable
If so, please explain the situation with
the Operator's involvement.
If the Operator is an absentee please name the
person in charge of the branch (including
details of the person present at the time of the
Branch Assurance visit (if applicable)).
Appointment date
Original appointment date
(If not same as above, for example if the branch
converted under Network Transformation)
Is the contract with a Limited Company?
YES/NO*
*delete as applicable
If so, please list the Director's names:
Date Contract Signed
Date Contract Countersigned
Fees over last twelve months (or since opening
if less than twelve months — please note time)
Associated Retail (please refer to Preface and
explain any difference with the Agreement)
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Details of registered assistants
Does the Operator hold a Post Office
Agreement at other branches? If so, please list
the branch name(s) and branch code(s).
Contract Performance - Background
Details of what has
happened outlining the
nature of the issue and
why it has been
escalated for contractual
action to be considered
Contract Performance
s
®
=
Details of review
undertaken outlining
what steps have been
taken to resolve the
issue prior to escalation
for contractual action to
be considered
Onboarding Application
Review — relevant details
Details of Onboarding
training
«e-learning
¢ classroom
© onsite (including
first balance)
Details of early days
support
Details of formal training
intervention
Details of any branch
visits
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Review of inbound
branch support call logs
for anything relevant to
the matter being
reviewed
(recommendation of a 12
month review however if
needed the review can
go back further)
Review of outbound
branch support call logs
for anything relevant to
the matter being
reviewed
(recommendation of a 12
month review however if
needed review can go
back further)
Relevant supporting
branch transaction data
(which could include cash
declarations, trading
statement details and any
other pertinent
information).
Record of any
performance history in
branch over the past 12
months:
Record any relevant
details from the
Operator's history in the
past 12 months prior to
this issue (for example
service length and record,
any previous or ongoing
written directions or
warnings and how Post
Office followed up on any
warning and direction
and provided necessary
support and training
during/afterwards. If
required, the review can
go back further than 12
months)
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Contract Performance —- Meeting(s)
Notes from any
meeting(s) held with the
Operator during the
course of the Contract
Performance review.
Detail any areas coming
from the meeting(s) held
with the Operator that
warrant further review
Criteria for Con:
eration
Contract Performance - Decision Making
a) Has the issue has been raised with the
Operator through the most appropriate
team with clear expectations having
been set and any reasonably required
support provided (including additional
training if required)?
b) What consideration has been given as
to the seriousness of the breach and
has a review of the contract between
Post Office and the Operator been
carried out to establish that there is a
contract breach?
c) Has any action (or inaction) by Post
Office itself been a contributory factor?
d) Please note any relevant information
provided by the Operator. This can
include any material issues or concerns
raised by the Operator that need to be
considered.
) Operator's history i.e. service length
and record, any previous written
directions or warnings and how POL
followed up on any warning and
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direction and provided necessary
support and training during/afterward
f) Any other comments to support your
decision
Contract Performance — Breaches of Agreement Considered
Write what the breaches are — what is the evidence -
Factors for or against in determining whether contractual action is appropriate
Factors supporting formal contractual action Factors supporting no formal contractual action
Contract Performance - Decision Tak
Decision taken and why
Next steps (who will monitor, is
further support required, what are
the expectations of the Area
Manager, expectations on the
postmaster etc)
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[et
act Advisor Details (Contract Perfor
Name of Contract Advisor
completing Rationale document
Date completed
Appendix 1 — Operator Contact
Notes from contact with Operator,
through the course of the review (not
including details of any meetings
with the Operator):
Appendix 2 — Improvements Opportunities Identified
Note: This section is to note any potential business improvements which have been raised through the review.
Appendix 3 —- Relevant Documents
Number
afafwolnte
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