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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
1 Defini
NS ..
1.1 Definitions...
2 Overview...
2.1 — Introduction.
2.2 Purpose..
2.3 Core principles...
2.4 Application.
2.5 The risk...
3 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 Review
4.2 Alternatives to suspension...
4.3. Contract Suspension Decision Rational
4.4 Informing a postmaster of suspension...
4.5 Payment during suspension...
4.6 Temporary operation during suspension period.
4.7 Suspension period...
4.8 Postmaster Suspension Decisions Governance Committee.....
4.9 _ Reinstatement or termination following a period of suspension
4.10 Business improvement opportunities.
5 Where to go for help...
5.1 Additional policies.....
5.2 How to raise a concern...
5.3. Who to contact for more information..
6 Governance
6.1 Governance responsibilities.
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7 Document control
7.1 Document control record...
7.2 Oversight committee.
7.3, Company details...
8 Appendices...
8.1 Contract Suspension Decision Rationale...
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1 Definitions
1.1 Definitions
1. Postmaster Suspension Decisions Governance Committee (“Committee”) - The
purpose of Committee is to review and provide oversight on decisions taken in respect of
postmaster contract suspensions ensuring that any decision taken is done so within a legally
and procedurally compliant and ethical framework.
2. 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.
3. Review — A review into the matter that may give rise to Post Office exercising its suspension
rights undertaken by the Contract Advisor.
4. 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
5. Temporary Postmaster - this refers to a limited company, partnership, limited liability
partnership, other entity or individual that contracts with the Post Office for the operation of
a Post Office® branch on a temporary basis
6. Non-suspension monitoring — The period after any decision taken not to suspend a
postmaster's contract/agreement whereby there is continued monitoring of the issues
identified over a defined period of time.
7. Contract Suspension Decision Rationale (see appendix 8.1) — A rationale completed by the
Contract Advisor which captures the facts and findings of the review into the matter and sets
out the rationale outlining the recommendation for review by the Head of Contract
Management & Deployment (with support from Post Office legal services as required)
8. Suspension Review Period — An initial, then monthly, review of the suspension made by the
Postmaster Suspension Decisions Governance Committee to ensure there is still a basis for
suspension.
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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 Performance 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.
Post Office recognises that there may be occasions where it is necessary to suspend the contractual
relationship with a postmaster. The purpose of this policy is to identify the circumstances in which
suspension should be considered and the criteria which must be met before a decision to suspend is
made. It will also outline the procedures to be followed in the case of suspension. Wherever possible
Post Office will seek alternatives to suspension as outlined later in this policy.
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.
2.3 Core principles
The act of suspension is a neutral, precautionary act. It is used to investigate the cause of a potential
contractual breach identified by the Contract Advisor. It does not imply there has been any such
breach.
In this policy, “network” means branches not directly managed by Post Office.
? In this Policy “Post Office” and “Group” means Post Office Limited.
3 In this Policy “postmaster” refers to a limited company, partnership, limited liability partnership or ot her entity or individual that
contracts with Post Office for the operation of a Post Office® branch.
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It is recognised that suspension may have an impact on the postmaster's core business and on the
Post Office brand; therefore, a contract will only be suspended where absolutely necessary and after
all reasonable alternatives have been considered (set out further under 4.2).
The period of suspension should be for as short a time as possible and Post Office will remain in
touch with the postmaster throughout this time. Each suspended postmaster shall be assigned, and
notified of, a specific Contract Advisor to keep them up to date with developments during the period
of suspension.
Accordingly this policy, and its linked policies, sets out clear and consistent guidelines to ensure that:
* —areview is carried out to establish the applicable facts before any formal action is considered,
to provide the postmaster with the opportunity to identify and address any issues of concern
and to determine whether Post Office has the right to suspend the postmaster’s contract;
* consideration is given to the postmaster's particular circumstances before deciding, acting in
good faith, whether to suspend the postmaster’s contract;
* suspension only happens when it is necessary and alternatives have been considered; and
* postmasters continue to receive payment during any period of suspension.
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
In taking any decision to suspend a postmaster Post Office needs to:
ensure that any decisions taken in respect of a postmaster contract are not exercised
arbitrarily, capriciously or unreasonably;
* exercise any contractual power (including the right to suspend) honestly and in good faith
for the purpose for which it was conferred on Post Office; and
In this policy “employee” means permanent staff, temporary staff including agency staff, contractors, consultants and anyone
else working for or on behalf of Post Office and, for clarity, does not include postmasters or postmasters’ staff.
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* exercise any discretion in accordance with the obligations of good faith, fair dealing,
transparency, co-operation and trust and confidence.
The decision to suspend a postmaster's contract creates risk to Post Office and postmasters both
through how the decision is reached and by not suspending when it is appropriate to do so. These
risks include (but are not limited to):
* Post Office is not able to suspend a postmaster’s contract without reasonable and proper
cause. Post Office cannot suspend a postmaster’s contract where Post Office itself is in
material breach of duty in respect of matters which Post Office considers give it the right to
suspend. If a postmaster is suspended unneccessarily it may:
- cause distress and financial detriment to the postmaster; and
- Post Office may be perceived as not acting in good faith;
* areduction in confidence across the postmaster network in how Post Office manages the
contractual relationship with postmasters;
e stakeholders having reduced confidence in Post Office's ability to effectively manage
postmaster contracts;
both postmasters and Post Office may suffer financially;
e Post Office may suffer reputational damage; and
* Post Office may be in breach of their contractual or regulatory obligations, which could lead
to possible legal challenges.
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.
e Averse risk appetite for financial crime to occur within any part of Post Office or the network.
« Averse risk appetite in relation to unethical behaviour by Post Office employees.
e Averse risk appetite to risks around disputes and litigation.
© 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
« Postmaster Complaint Handling
e Network Monitoring and Branch Assurance Support
« Network Cash and Stock Management
« Network Transaction Corrections
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« Postmaster Account Support
e Postmaster Accounting Dispute Resolution
« Postmaster Contract Performance
e Postmaster Contract Suspension (this policy)
« 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
e 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
responsibilities set out at section 6.1.
* 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.
« Postmaster Suspension Decisions Governance Committee — A group whose role it is to
review all new, and ongoing suspensions, and consists of:
a) Head of Contract Management & Deployment (non-voting chair)
b) Head of Assurance & Complex Investigations
c) Retail Operations Director
d) Head of Postmaster Engagement
e) Head of Group Assurance
f) Head of Legal — Dispute Resolution
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g) Head of Risk
* 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:
© apply the Post Office's underpinning behaviours of fairness, transparency
and professionalism;
o be conversant with this policy and linked policies;
© gather as much preliminary information as possible relating to the issue which has
caused suspension to be considered, liaising as appropriate with the postmaster and
other Post Office teams;
© complete the Contract Suspension Decision Rationale when suspending a postmaster's
contract;
© consult with the Head of Contract Management & Deployment before suspending a
postmaster's contract, and as necessary during the suspension process;
© consider the options available as an alternative to suspension;
© ensure any decision is made in line with all other linked Post Office policies;
© ensure this suspension policy is adhered to and the postmaster is supported throughout
the procedure, including arranging for the postmaster to be notified of the specific
Contract Advisor dealing with their case;
© make the postmaster aware of the support available to them, including from the National
Federation of Sub Postmasters;
© explain at the outset, when a postmaster’s contract is being suspended, what
involvement will be requested from the postmaster during the contract suspension
period;
o keep in regular contact with the suspended postmaster throughout the suspension
period;
© deal with any contact (written or otherwise) from the postmaster, in a timely manner:
© if meeting is required, be flexible, within reason, over the availability of the postmaster;
and
o keep the suspension regularly under review (see 3.7), reinstating (or terminating) the
agreement as soon as practicable.
* National Federation of Sub Postmasters (NFSP) - is a professional trade association which
exists to support postmasters.
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e 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).
«In relation to this policy, the postmaster is expected to:
© comply with the terms of the suspension;
o be transparent and open towards Post Office;
© ensure they respond to written correspondence and telephone calls in a timely
manner in order to assist the Contract Advisor in reaching a decision; and
© be flexible and available for meetings with the Contract Advisor if one is required.
In relation to this policy, the postmaster may:
© 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;
co 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 investigation; and
contact a Contract Advisor at any time during the suspension process, including
regarding potential or actual termination.
If alternative action has been taken in preference to suspending the postmaster, the postmaster
should comply with the terms of such alternative action.
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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
Reaching a Post Office is not able to suspend I A Contract Suspension Decision Rationale will be Head of As required
decision to the agreement without completed to support any suspension decision Contract
suspend reasonable and proper cause. If _I setting out the factors to support the suspension. I Management &
Post Office itself has not complied I All decisions will be signed off by the Head of Deployment
with its material obligations, Contract Management & Deployment and, if
relating to matters that gives it required, with support from Post Office's legal
the right to suspend, Post Office team.
is not able to suspend the
postmaster from operating the The Postmaster Suspension Decisions Governance I Postmaster Monthly
branch. If the decision is made Committee will review any decision to suspend to Suspension
incorrectly it could lead to: ensure that the decision to suspend was taken in Decisions
. line with the relevant contract and Post Office Governance
*® unnecessary distress and policies Committee
financial detriment to the
postmaster;
Quality checks and training covering the Head of Quarterly
suspension process will take place with the Contract
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e Post Office may be perceived I Contracts Team to ensure that the correct process Management &
as not acting in good faith; is followed. Deployment
and Monthly
As part of the Branch Control Assurance Head of
* possible legal challenge from I Framework, rationale documents, methodologies, I Assurance &
the suspended postmaster. and evidential evaluations will be sampled on a Complex
monthly basis by the Branch Control Assurance Investigations
Framework.
Loss of If Post Office are not making the All decisions to suspend shall undergo a sign off Head of As required
confidence and I correct decisions by either: process with review by the Head of Contract Contract
possible * suspending when it has no Management & Deployment and, if required, Management &
financial & grounds to do so; or supported by Post Office's legal team. These Deployment/
reputational * not suspending when it decisions will subsequently be reviewed by the Postmaster
damage should, Postmaster Suspension Decision Governance Suspension
it may lead to a loss of confidence I Committee. Decisions
both across the network and with Governance
Post Office's stakeholders in how Committee
Post Office manages the
contractual relationship with its
postmasters. In addition, incorrect I As part of the Branch Control Assurance Head of Monthly
decisions may lead to financial Framework, rationale documents, methodologies, Assurance &
loss and reputational damage. and evidential evaluations will be sampled on a Complex
monthly basis by the Branch Control Assurance Investigations
Framework.
The Postmaster Contract Performance policy sets I Head of Annually
out the required steps as to how potential Contract
contractual issues across the network should be Management &
dealt with, providing a solid framework to ensure Deployment
that the contractual relationship with postmasters
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is managed consistently. The relevant stakeholders
are provided with training on the Postmaster
Contract Performance policy annually.
Postmaster Any decision to suspend may All postmasters will receive payment during the Head of Monthly
financial cause financial detriment for the suspension period (based on average fees received I Contract
detriment postmaster over the previous six-month period). A check will Management &
during be undertaken by the Head of Contract Deployment
suspension Management & Deployment with Post Office
Remuneration teams to ensure that payment is
being made.
Postmaster Monthly
Suspensions will be reviewed on a monthly basis to I Suspension
make sure there is still a basis for suspension and Decisions
any suspension period is kept to a minimum. Governance
Committee
Policy non- Non adherence to the policy could All members of the Contracts Team, the wider Head of Once approved and
adherence result in legal and regulatory risk I Retail Operations Team and any teams who may Contract annually thereafter (or
as well as reputational damage to I be involved in the decisions being taken will be Management & I sooner in the event of
Post Office and the relationship provided with training on this policy. Deployment material changes to the
with postmasters. policy).
The Head of Contract Management & Deployment I Head of Daily
is accountable for ensuring that they and their team I Contract
adhere to the policy, as it applies to their area. Management &
Deployment
The Policy should be reviewed, and if necessary As required (but
updated. reviewed at least
annually)
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4 Procedure
4.1 Review
Preliminary review
Any review will be a fair and unbiased method of considering 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.
Post Office will ensure that complete records are kept of all reviews and that any decisions taken in
relation to an investigation are documented in rationale documents.
Records will be retained in accordance with Post Office's document retention policy:
Details of the investigation and relevant supporting records and information will be shared with the
postmaster unless the material is subject to a restriction on disclosure such as:
« legal privilege;
data protection law; and/or
« material relating to a criminal investigation.
The Contract Advisor should make an asessment of 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 the postmaster is being
reviewed and the postmaster's rights to access information and records relating to the review.
When considering suspension, Post Office must complete a preliminary review. This preliminary
review will, as a minimum, include a review of the contract between Post Office and the postmaster
to confirm the extent of Post Office’s right to suspend.
The contractual right to suspend may arise:
if the postmaster is arrested or charged with a criminal offence;
if the postmaster has civil proceedings brought against them;
there are grounds to suspect the postmaster is insolvent; and/or
due to irregularities or misconduct in the operation of the branch.
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Post Office must check the contract in each case as the grounds may differ. If the contract does not
contain a contractual right to suspend, the Post Office must not suspend the postmaster from
operating the branch; and
A review of the facts related to the review to establish whether Post Office is itself in material breach
of duty in respect of the matters giving rise to the right to suspend. If it is, Post Office must not
suspend the postmaster from operating the branch.
This will include:
* areview of previous correspondence with the postmaster; and
* — areview of any other supporting documents held by Post Office.
This investigation may also include:
* a Branch Assurance visit;
* —areview of Network Monitoring records; and
« information provided to Post Office by an outside body or source, for example, the police,
insolvency practitioners, or Post Office clients.
Once this initial investigation has been completed, the Contract Advisor should refer to 4.3 (Contract.
Suspension Decision Rationale) to determine whether there is sufficient rationale to warrant
suspending the postmaster.
Review during suspension
Post Office is likely, in most cases, to need to complete further reviews once a postmaster is
suspended from operating the branch. These reviews may be complex but must be completed as
soon as practicable (in accordance with section 4.7 (suspension period)) in order to limit any period of
suspension to what is necessary to complete the review. The output of these further reviews should
be recorded in the Contract Termination Decision Rationale document.
A process map detailing the contract suspension process can be found in appendix 8.2.
4.2 Alternatives to suspension
Suspension will only be applied where absolutely necessary to review the cause of a potential
contractual breach identified by the Contract Advisor and where all alternative options have been
considered.
Alternative options to suspension may include:
e Non-suspension monitoring — continued monitoring of the issues identified over a defined
period of time, with any further or escalating issues being flagged to the Contract Advisor to
reconsider suspension.
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« Other contractual performance measures and/or restrictions contained in the Postmaster
Contract Performance policy’.
The Contract Advisor should document alternatives to suspension in the same way as a decision to
suspend a postmaster (in the Contract Suspension Decision Rationale) and Post Office should ensure
that records of these decisions are also kept in accordance with Post Office's document retention
policy.
4.3 Contract Suspension Decision Rationale
Post Office must not suspend any postmaster from operating the branch without reasonable and
proper cause (even if they have a contractual right to do so). This power is discretionary but must be
exercised in good faith. This is a question of fact but means that Post Office should apply its
underpinning behaviours of fairness, transparency, and professionalism.
Whenever a review leads to suspension being considered, the Contract Suspension Decision
Rationale must be completed by the Contract Advisor. This captures the background of the case,
investigation undertaken and rationale behind the decision to be taken. The document will be used by
the Head of Contract Management & Deployment, if required with support from Post Office's legal
team, as a basis for their decision on suspension. The rationale will subsequently be shared with the
Postmaster Suspension Decision Governance Committee as part of its monthly review.
Factors that the Head of Contract Management & Deployment should consider when deciding
whether or not to suspend a postmaster from operating the branch include:
e There being a risk to the postmaster;
e There being an immediate risk to Post Office assets;
* There being a risk to Post Office's brand and/or Post Office's reputation of the
postmaster continuing to operate the branch.
This is not intended to be a full list of considerations relevant to suspension and the Head of Contract
Management & Deployment should consider all the circumstances of the case and conduct a
balancing exercise of the relevant risks.
4.4 Informing a postmaster of suspension
In the first instance, the postmaster will be informed by the Contract Advisor via telephone call of any
suspension. Where a postmaster cannot be contacted immediately, Post Office will make every effort
to inform the postmaster of their suspension through whatever contact details they hold for the
postmaster. This initial contact will be followed up by a Suspension Letter, which will be sent as soon
as possible following suspension by the Contract Advisor.
° The Postmaster Contract Performance policy can be found on the hub, here
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When informing the postmaster of their suspension, subject to any restrictions on disclosure (see 4.1
above) the Contract Advisor should outline the following to the postmaster:
e The reason(s) for the suspension, including the factual circumstances and contractual basis;
« That they are being suspended in accordance with their contract and in line with the Post
Office Suspension Policy’, a copy of which can be made available to the postmaster on
request;
© That a preliminary review has already been carried out and that information and records
relating to the preliminary review and any subsequent review will be made available to them
where possible;
That the suspension period will be kept to the minimum period required to complete the
review and that the postmaster will be kept informed throughout the period of suspension as
per the processes outlined in 4.7;
e That the postmaster will receive payment during their suspension as per 4.5;
e The possibility of Post Office arranging for a temporary operator to operate their premises
and the processes involved in this, if the postmaster is willing (see 4.6); and
e Any other relevant information that should be shared with the postmaster at this stage.
4.5 Payment during suspension
Postmasters will receive payment during suspension. This will be based on average fees over the
previous six-month period. This does not include Christmas trading. Where the postmaster has been
appointed for less than six-months then this will be based on the average fees received since
appointment. Postmasters should contact their Contract Advisors to understand in more detail how
average fees are calculated.
4.6 Temporary operation during suspension period
In order to minimise the impact of any suspension period on the postmaster’s business, on
communities and on Post Office, Post Office will offer to attempt to find a temporary operator for any
premises where the postmaster has been suspended. A temporary operator will only be able to
operate with the express permission of the postmaster.
The postmaster and the temporary operator will be responsible for negotiating the commercial
arrangements between them. If a commercial arrangement is made between the postmaster and
temporary operator whereby the postmaster charges the temporary operator Post Office will need to
The Postmaster Contract Suspension policy can be found on the hub, here.
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consider whether any deductions need to be made to the payment made to the postmaster during
suspension.
4.7 Suspension period
Suspension periods will be kept to the minimum period reasonably required to complete the review
and both Post Office and postmasters must cooperate in this regard.
Post Office may suspend a postmaster for as long as it has a reasonable and proper reason to do so
in the view of the Postmaster Suspension Decision Governance Committee. The Post Office must act
promptly to review the circumstances of the suspension and decide to either re-instate the
postmaster or terminate the postmaster's contract as soon as is practicable.
Post Office will keep any suspensions under regular review to make sure it continues to have a
contractual basis for suspension throughout. The review will be completed by the Postmaster
Suspension Decisions Governance Committee (see 4.8).
In addition to this there should be regular communication with the postmaster through their Contract
Advisor.
4.8 Postmaster Suspension Decisions Governance Committee
The purpose of the Committee is to sit on a monthly basis and:
* Review and approve all decisions to suspend a Postmaster’s Agreement taken since the last
Committee meeting to ensure that a decision to suspend was taken in line with the relevant
contract and Post Office policies;
e Review all ongoing Postmaster Agreement suspensions and approve that it is reasonable
and proper to keep a Postmaster suspended. If not, the Committee will recommend that
steps are taken to reinstate the Postmaster’s contract or request that a termination review is
triggered (in which case the principles of the Postmaster Contract Termination Policy? will
apply);
e Ensure that the relevant team has been engaged with and there is a clear line of sight on the
actions required (for example any discrepancies associated with the suspension or
engagement with external agencies through the Assurance & Complex Investigations Team);
«Ensure the lessons learnt from the Committee are shared with the appropriate team(s) and
monitor progress to completion.
4.9 Reinstatement or termination following a period of suspension
Reinstatement or termination should happen as quickly as possible once a review has been
completed or Post Office identifies that it no longer has a reasonable and proper reason to maintain
the suspension.
® The Postmaster Contract Termination policy can be found on the hub, here
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For reinstatements, the postmaster should receive a letter confirming the end of the suspension
period and the outcomes of any review. For terminations, the postmaster will receive communications
in accordance with the Postmaster Contract Termination policy.
The Contract Advisor is responsible for ensuring the postmaster’s reinstatement is carefully planned,
supported and in accordance with the wishes of the postmaster. This may be assisted by liaising with
the relevant Area Manager, other Post Office support teams and/or the NFSP. Examples of
considerations that the Contract Advisor should make include:
* What date is appropriate for any re-fund or transfer branch assurance visits to take place;
e Whether it is appropriate for the postmaster to undergo further training prior to
reinstatement;
« Whether it is appropriate for the postmaster to have additional on-site support post
reinstatement. Any decision to terminate the postmaster's contract should be taken in
accordance with the Postmaster Contract Termination policy.
4.10 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 Suspension Decision Rationale document.
Itis the role of the Head of Contract Management & Deployment to follow up on any business
improvement opportunities identified. 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 Policies, or report
online at: http://speakup.postoffice.co.uk or call the Speak Up Line o
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
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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 Compliance Committee 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
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7.1 Document control record
Summary
GE policy sponsor Standard owner
Martin Roberts (Group ‘Tracy Marshall (Retail
Chief Retail Officer) Engagement Director)
aso I —o
Version
period
5.0 Annual
Revision History
I Standard implementer
David Southall (Head of
Contract Management and
I Policy - effective date
Standard approver
R&CC/ARC
Policy location
Postmaster Support
Policies on SharePoint
Hub
Ivesion [oe I ns [oars ey
11 2nd March 2020 Draft Version
13 6th March 2020 Legal Review
14 17th March 2020 For working group review
15 9th April 2020 Final Draft with working group revision
16 14th May 2020 Final draft following further legal review
2.0 6th April 2021 Annual review — initial draft changes
21 14th April 2021 Initial legal review
2.2 26th April 2021 Second legal review
Addition of process map
Alignment with other postmaster support policies
23 4th May 2021 Risk appetite amendment
3.0 23rd May 2021 Updated following ARC feedback including:
Updated to V3.0
Addition of definitions
Addition of Contract Performance Rationale
Added linked policy statement to front page
INTERNAL — Postmaster contract suspension policy v5.0
Tim Perkins
Tim Perkins
Tim Perkins
Tim Perkins
Tim Perkins
David Southall,
Head of Contract
Management &
Deployment
David Southall,
Head of Contract
Management &
Deployment
David Southall,
Head of Contract
Management &
Deployment
Jo Milton
David Southall,
Head of Contract
Management &
Deployment
Page 24 of 38
3.1
3.2
4.0
41
4.2
INTERNAL
16 November 2021
18 February 2022
1* April 2022
5! July 2022
10" October 2023
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
4.9 New section — referencing Decision Review
process and policy
4.10 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
I 2.1, 3.4, 3.5, 5.3, 6.1, 7.1— updated owner and
sponsor
Font updated to Nunito Sans
Annual Review
1.1 (and throughout) — addition of the Postmaster
Suspension Decisions Governance Committee
1.1 (and throughout) - Definition of ‘Investigation’
changed to ‘Review’ to better reflect what the
Contract Advisors do in reviewing the situation and
determining any necessary action
1.1 (and throughout) - Suspension Rationale
renamed Contract Suspension Decision Rationale
(plus associated changes throughout)
2.1 Policy owner changed to Retail Engagement
Director (and associated changes throughout)
3.4 RCC and ARC added
3.4 Clarified the wording to outline that
representation can be provided by NFSP or a legal
firm. Anything else would be classed as support
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 standard added whereby the
Postmaster Suspension Decisions Governance
Committee will review all decisions to suspend3.5
Assurance review now undertaken by Assurance &
Complex Investigations
4.8 Postmaster Suspension Decisions Governance
Committee added
4.9 Removal of this section as this review role is
covered by the Postmaster Suspension Decisions
Governance Committee (4.8)
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David Southall,
Head of Contract
Management &
Deployment
David Southall,
Head of Contract
Management &
Deployment
Jo Milton I
Jo Milton
David Southall
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5.2 Added Speak Up contact details
8.2 Process map updated to reflect Committee
5.0 115" December 2023 I Amended version number following approval Jo Milton I
I Rebranded I
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 9Q.
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 (HMRQ, 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 Suspension Decision Rationale
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).
Background Details
Date of Branch Assurance visit
(if applicable)
Amount of discrepancy
(if applicable)
Detailed breakdown of the
discrepancy
Who was spoken to (and by who)?
Reason for discrepancy, if offered (if
applicable)
Does the Operator believe that there
are any IT issues that could have
impacted the branch? If so, please
detail.
Does the Operator believe that there
are any training issues that could
have impacted the branch? If so,
please detail.
Is there any other relevant
information provided by the Operator
or staff? If so, please detail during a
Branch Assurance visit?
Please enter date(s) and details of
previous Branch Assurance visits
over the previous 12 months (If
required, the review can go back
further than 12 months)
Please advise if there have been any
performance issues over the previous
12 months. If so, please provide
details and outline what steps were
taken to address the issue. If required,
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the review can go back further than 12
months
What calls have previously been
made to Branch Support that are
relevant to the matter over the
previous 12 months? If required, the
review can go back further than 12
months)
Suspension Decision - Record Of Decision Making
All of the following criteria must be considered along with any other factors relevant to the case
when making a decision.
a) What is the impact on the
Operator, were we to
suspend, and how has this
impacted the decision you
have made?
b) What is the source of any
risk, and can this be
mitigated?
For instance, is the
Operator posing the risk or
have they been unaware of
events caused by
assistants?
c) Risk to the Operator
d) Risk to POL funds
e) Risk to POL brand or
reputation of the Operator
continuing to operate the
Branch
f) What is the impact of
suspension on customers
and suppliers?
Has someone suffered loss
or damage as a result of
gi
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the suspected or
confirmed breach?
This could be the Operator,
customer or supplier.
Please detail.
h
Has the Operator
cooperated following the
findings at Branch
Assurance visit?
Please note any relevant
information provided by
the Operator. This can
include any material issues
or concerns raised by the
Postmaster that need to
be considered.
(It is for the Contract
Advisor to exert their
judgement in each
individual case to ascertain
whether the circumstances
and reasons given are
pertinent to the reasons for
suspension.)
Has Post Office Ltd.’s
actions (or inaction)
contributed to the issue?
(For suspension
considerations only where
the material breach by Post
Office is connected to the
basis on which it is relying
to suspend)
k)
Are there any other
relevant criteria of facts
that have been considered
or disregarded as part of
the decision-making
process?
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Factors supporting continuation of service Factors supporting suspension
Suspension Decision - Rationale
Recommended Decision
(If suspension, please document
relevant clause that gives the
right to suspend)
Rationale to support
recommended decision
Where no suspension, detail
further action planned
Contract Advisor Details (Suspension Decision)
Name of Contract Advisor
making recommendation
Date completed
Suspension Decision Governance
Head of Contract Management & Deployment - Authority
Decision Making Manager
Rationale for decision
Date completed
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Suspensions Deci Governance Committee
Meeting Date
Committee Recommendation
Committee Members
Append Improvements Opportu s Identified
Note: This section is to note any potential business improvements which have been raised through the
review.
al a}wlr
SECTION 2 - BACKGR
Background Details
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Date of Branch Assurance visit
Amount of discrepancy (if
applicable)
Detailed breakdown of the
discrepancy
Were there any known Horizon YES/NO*
issues that could have affected
this branch? (if applicable) (Give
explanation of steps taken to
ascertain this)
*delete as applicable
Reason for discrepancy, if offered
(if applicable)
Is Horizon or Training an YES/NO*
area that has been cited as
a reason for the
discrepancy?
*delete as applicable
Any admissions volunteered? YES/NO*
*delete as applicable
a) Who volunteered the
admission?
b) What was said?
c) When was it said?
d) Who was it said to?
e) How was it
documented?
Is there any other relevant YES/NO*
information provided by the .
. *delete as applicable
Operator or staff during an
Branch Assurance visit?
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a) Who gave the
information?
b) What was said?
c) When was it said?
d) Who was it said to?
e) How was it
documented?
Please enter date and details of
previous Branch Assurance visits
Please advise if there have been
any performance issues
previously
If so, what steps were
taken to address the
issues?
What calls have previously been
made to Branch Support?
SECTION 3 - RECORD OF DECISION MAKING
All of the following criteria must be considered along with any other factors relevant to the case
when making a decision.
)
What is the impact on the
Operator, were we to
suspend, and how has this
impacted the decision you
have made?
m) What is the source of any
risk and can this be
mitigated? For instance, is
the Operator posing the
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risk or have they been
unaware of events caused
by assistants?
n
Risk to the Operator
°
Risk to POL funds
i?)
Risk to POL brand or
reputation of the Operator
continuing to operate the
Branch
q
What is the impact of
suspension on customers
and suppliers?
Ls)
Has someone suffered loss
or damage as a result of
the suspected or
confirmed breach? This
could be the Operator,
customer or supplier.
Please detail.
s)
Has the Operator
cooperated following the
findings at Branch
Assurance visit?
A)
Please note any relevant
information provided by
the Operator as part of an
informal discussion/
telephone conversation/
written explanation. (It is
for the Contract Advisor to
exert their judgement in
each individual case to
ascertain whether the
circumstances and reasons
given are pertinent to the
reasons for suspension.)
u
Has Post Office Ltd’s
actions (or inaction)
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contributed to the issue?
(For suspension
considerations only where
the material breach by
Post Office is connected to
the basis on which it is
relying to terminate)
v) Are there any other
relevant criteria of facts
that have been considered
or disregarded as part of
the decision making
process?
Factors supporting continuation of service
Factors supporting suspension
Section 4 - Decision and Rati
Recommended Decision (If
suspension, please document
relevant clause that gives the
right to suspend)
Rationale to support
recommended decision
Where no suspension, detail
further action planned
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Col Advisor Deta
Name of Contract Advisor
making recommendation
Date completed
Decision Making Manager
Head of Contract Management & Development - A
Rationale for decision
Date completed
investigation.
Business Improvements
Note: This section is to note any potential business improvements which have been raised through the
Section 5 — Governance
Operator Suspensions Decision Governance Committee
Meeting Date
Committee Recommendation
Committee Members
Meeting Date
Decision Review Panel
Panel Recommendation
Decision Review Panel
Members
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