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Postmaster support
policy
Version 4.0
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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 Definitions
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 and required operational standards.....
3.1 Risk appetite...
3.2 Policy framework.....
3.3. Who must comply?.
3.4 Roles and responsibilities.
3.5 Policy required operational standards..
4 Procedure:
4.1 How to report a complaint...
4.2 — Service levels
4.3 Executive complaints..
4.4 Escalating a complaint...
4.5 Speak Up...
4.6 Control framework (controls reporting risks and process).
4.7 Reporting...
4.8 Closing acase...
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...
7 Document control
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7.1 Document control record...
7.2 Oversight committee...
7.3 Company details...
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1 Definitions
1.1 Definitions
1. Complaint - any oral or written statement of dissatisfaction, whether justified or not, from, or
on behalf of, a Postmaster (whether a limited company, a partnership, a limited liability
partnership or an individual) about the provision of, or failure to provide, a product, process or
service from Post Office, or the way that Post Office interacts with the Postmaster.
2. Complaint Handler — any Employee of Post Office that is in a position to receive a Complaint
from a Postmaster in accordance with one of the Complaint reporting channels set out at
paragraph 4.1 of this Policy.
3. Employee — an individual who has entered into or works under (or, where the employment
has ceased, worked under) a contract of employment or any other relevant contract, as
defined in sections 230(2) and (3) of the Employment Rights Act 1996, with Post Office or
the Group or is defined as a “worker” under section 43K Employment Rights Act 1996.
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, Post Office and Group — Post Office Limited and any wholly owned subsidiary that formally
adopts this Policy.
6. RCC - this refers to Post Office Risk and Compliance Committee.
7. Service Level (SL) - the length of time that the Post Office expects that it will take to
acknowledge and resolve a Complaint that has been formally raised.
8. Whistleblowing (or Speak Up)? — the act of a person or, in the case of a postmaster that is a
limited company, partnership or limited liability partnership, entity (the “Whistleblower")
making a disclosure that the Whistleblower reasonably believes is (a) in the public interest,
and (b) regarding past, present or likely future wrongdoing that falls into one or more of the
following categories:
e criminal offences (this may include types of financial impropriety such as fraud)
* — failure to comply with an obligation set out in law (including regulatory breaches)
¢ —miscarriages of justice
e endangering of someone's health and safety
«damage to the environment
*® covering up wrongdoing in the above categories
* The terms, ‘whistleblowing’ and ‘speak up’ are often used interchangeably to promote a ‘speak up’ culture.
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* abreach of the Post Office’s policies and procedures
e behaviour that harms or is likely to harm the reputation or financial well-being of the Post
Office
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2 Overview
2.1 Introduction
The Central Operations Director has overall accountability to the Board of Directors for the design
and implementation of controls to manage Complaints received from Postmasters as defined in this
Policy.
This policy is a non-contractual document provided for information. It does not form part of the
contract between any Postmaster and Post Office.
2.2 Purpose
This Policy has been established to set the minimum operating standards relating to the management
of Postmaster Complaints.
Post Office recognises that Complaints will occur and this Policy lays out the formal Complaints
procedure which is intended to ensure that Post Office handle all Postmaster Complaints
consistently, fairly and within agreed timescales.
It is one of a set of policies which provide a clear risk and governance framework and facilitate an
effective system of internal controls for the management of risk across Post Office. Compliance with
these policies is essential to Post Office in meeting its business objectives and to balance the needs
of Postmasters, clients, and other stakeholders including our shareholder.
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, partner or manager).
2.3 Core principles
Post Office will seek to resolve all Postmaster Complaints with fairness, transparency, and
professionalism (being the underpinning behaviours of Post Office).
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 by understanding, addressing, resolving and providing insight on
Postmaster Complaints. This Policy sets out clear and consistent guidelines to encourage
Postmasters to raise issues with Post Office, and to ensure that:
* astandard and consistent process is followed for all Postmaster Complaints.
« the prompt reporting of any Postmaster concerns is encouraged and Post Office will take
Complaints raised seriously and investigate as appropriate.
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* Post Office will monitor and endeavour to adhere to Service Levels, and keep the Postmaster
informed, with a reason and regular updates, if there is an indication that Service Levels may
be exceeded.
* Post Office will analyse Complaints data to surface common and/or recurring issues and
themes and address them collectively where necessary and improve our business operations.
«Post Office will use Complaints data, and seek feedback on Postmaster satisfaction, to
constantly improve our Postmaster experience.
* Post Office will produce information on the volume of Complaints and Post Office’s
performance against Service Levels and publish this internally on a regular basis.
« Postmaster Complaints data is combined with other postmaster insights and regularly
reviewed at the Postmaster Experience Forum.
It is vital that the procedures followed in managing Complaints are as clear as possible to ensure a
fair, transparent, robust and consistent process for all concerned.
2.4 Application
This Policy is for use by Complaint Handlers in relation to Complaints raised by Postmasters, as
defined in this Policy, and defines the minimum standards to control financial loss, postmaster
impact, regulatory breaches and reputational damage in line with Post Office’s risk appetite.
2.5 The risk
Complaints should be taken seriously and managed effectively. Complaints are a good source of
feedback about how Post Office can improve. If a mistake has been made, it should be resolved
effectively, as soon as possible and the root cause surfaced and addressed to prevent recurrence.
Complaints that are not raised, addressed and resolved can lead to Postmaster dissatisfaction, the
inability of a Postmaster to operate effectively and the failure of Post Office to meet legal and
regulatory requirements.
The risk in this area is that the Issue Resolution Team fail to carry out timely and fair resolutions to
postmaster complaints.
Section 3.5 sets out the minimum required operational standards Post Office has implemented to
control this risk.
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3 Risk appetite and required operational standards
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.
« 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.
© Averse risk appetite towards risks around our core operational processes that impact
postmasters.
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 of Postmaster support policies that has been established to set the
minimum operating standards 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
* Postmaster Training
* Postmaster Complaint Handling (this policy)
e Network Monitoring and Branch Assurance Support
e Network Cash and Stock Management
e Network Transaction Corrections
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* Postmaster Account Support
e Postmaster Accounting Dispute Resolution
« Postmaster Contract Performance
« Postmaster Contract Suspension
e Postmaster Contract Termination
« Postmaster Contract Termination Decision Review
The Postmaster Complaint Handling policy should be considered and read in conjuction with the
Speak Up Policy? should a Complaint be identified as a potential Speak Up report.
3.3 Who must comply?
Compliance with this Policy is mandatory for Complaint Handlers, as defined in this Policy.
Where non-compliance by a Complaint Handler is identified, an investigation will be carried out.
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.
e Risk and Compliance Committee - is the standing committee of the Strategic Executive
Group who review and approve Postmaster Support policies for recommendation to the
Audit, Risk and Compliance Committee.
* The Postmaster Experience Forum meeting, chaired by the Postmaster Experience
Director— should:
o Review available Postmaster insights on a regular basis.
e Retail Engagement Director — is the Policy owner who must comply with the governance
responsibilities set out at section 6.1.
e Issue Resolution Team Manager — is accountable for the deployment of this Policy and the
support of the team that manage Postmaster Complaints. This role also has the responsibility
for regular review of the effectiveness of this Policy and for drafting any amendments that
may be required.
The Issue Resolution Team Manager will lead a team of Issue Resolution Support Advisors in
carrying out thorough and effective investigations to resolve any Complaints raised.
e Issue Resolution Support Advisors and all Complaint Handlers — should:
The Speak Up Policy can be found on the hub, here.
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o be conversant with this Policy and linked policies;
© ensure that the Complaint is acknowledged when received;
© record and log all details of the Complaint promptly and accurately;
© take reasonable steps to ascertain all the facts and detail of the Complaint;
o where necessary, seek open and transparent dialogue with the Postmaster to further
understand the Complaint;
© identify Speak Up reports and pass these on to the Speak Up investigation team
whilst respecting the confidentiality of the Whistleblower in accordance with and
subject to any exceptions in the Speak Up Policy and Procedures;
© act with integrity at all times;
© ensure the Postmaster is kept up to date if Service Levels are likely to be exceeded;
© own and monitor the progress of any investigation carried out by internal
departments and third parties;
o resolve the Complaint within agreed timescales and inform the Postmaster
accordingly;
o keep records of all material discussions with a Postmaster and other internal
departments in the pursuit of information and resolution of a Complaint;
© update case records regularly, and detail Complaint resolutions when the Complaint
case is closed;
e Central Operations Insight Manager- should:
© understand the requirements of the business to create useful reports for both an
internal and Postmaster audience;
© explore and interrogate the data to surface thematic and recurring detail
e Speak Up Manager - should:
© ensure that any Complaints that are passed to the Speak Up investigation team are
dealt with in accordance with the Speak Up Policy;
© communicate regularly with the Issue Resolution Team Manager to ensure that all
Complaints that are Speak Up reports are identified
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3.5 Policy required operational standards
A required operational standard defines the level of control that must be in place to manage inherent risks so that they remain within the defined Risk
Appetite statements. This section of the policy also sets out the Business Area(s) responsible for managing that risk through their controls, and allemployees
must ensure that they comply with the policy requirements. There must be mechanisms in place within each business unit to demonstrate compliance. The
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policy required operational standard 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 risk and the required policy operational standard in consideration of the stated risk appetite.
The subsequent pages define the terms used in greater detail:
Risk area Description of risk Required operational standard Business Control Frequency
owners
Fair and The Issue Resolution Team fail Preventive control: Central Training Annually
Timely to carry out timely and fair All employees receive complaint handling training I Operations
resolution of __ I resolutions to postmaster detailing the Postmaster Complaint Handling Director
postmaster complaints policy, how to identify a postmaster complaint and
complaints the correct complaint handling processes to follow.
Preventive control: Issue Resolution I Training Ongoing
The Issue resolution team receive product training Team Manager
when new products are introduced, or changes are
made to existing products.
Preventive control: Issue Resolution I Time to Daily
Service levels are monitored to make sure Team Manager resolve data
complaints are resolved in a timely manner.
Detective control: Issue Resolution I Performance I Monthly
Quality checks are carried out to make sure the Team Manager management
issue resolution team are following the correct
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Risk area Description of risk Required operational standard Business Control Frequency
owners
processes, are compliant with the policy and Identification
complaint resolutions are fair. of Speak Up
cases
Detective control: Issue Resolution I Performance I At each
Postmasters are advised how they can escalate Team management I occurrence
their complaint if they are unhappy with the Manager and
resolution provided. Complaint Escalated
Handlers complaint
data
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4 Procedures
4.1 How to report a complaint
Post Office is committed to finding more ways to listen to Postmasters and supports a number of
Complaint reporting channels. The main channels for Complaint raising are:
Branch Hub
In order to provide a consistent way for Postmasters to voice any concerns, Branch Hub is the
preferred channel to use as it can be accessed at any time, from anywhere. The Complaint will be
logged on the case management tool, acknowledged within 24 hours by email and a member of the
Complaint Handling team will take ownership of investigation and resolution.
Branch Support Centre
Postmasters can telephone the Branch Support Centre with a Complaint and a Branch Support
Advisor will take ownership of the Complaint and escalate to the Complaint Handling team where
necessary.
Area Managers
Area Managers are able to receive Complaints from Postmasters in their area and will resolve these
where possible. They will be logged onto the Branch Visit form and transferred to the case
management tool by the Complaint Handling team.
Unexpressed complaints
Post Office support teams will take reasonable steps to identify Postmaster dissatisfaction which is
expressed during their contact with Postmasters and offer the Postmaster the opportunity to raise a
formal Complaint.
4.2 Service levels
The Issue Resolution team will aim, where possible, to resolve the complaint within 10 working days
once the case is created.
Summary of timelines
Complaint stage Timeline
Acknowledgment sent Within 1 working day
Aim to resolve Within 10 working days
The Issue Resolution will ensure that regular updates are sent to the branch whilst they seek
resolution.
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4.3 Executive complaints
Postmasters may address their complaints and issues to senior leaders within Post Office, including
the CEO and Board members. These complaints are forwarded to the Issue Resolution team for
resolution.
Complaints received from a Member of Parliament are dealt with by the External Affairs team.
Complaints received from journalists are dealt with by the Press Office.
4.4 Escalating a complaint
Complaints that require escalation
If the Complaint Handler is unable to resolve a Complaint, or believes they will be unable to resolve it,
the Complaint should be escalated to the Issue Resolution Team Manager for review. They will either
advise the Complaint Handler or take ownership of the resolution.
Postmasters disputing the Complaint resolution
When a Postmaster contacts Post Office to dispute a resolution to an original Complaint, this will be
escalated to the Issue Resolution Team Manager to review and provide a response.
4.5 Speak Up
Difference between Complaints and Speak Up
A Complaint, as defined in this Policy, is about something that affects the Postmaster (whether a
limited company, a partnership, a limited liability partnership or an individual) or the branch. For
example, if deliveries are not picked up on time. However, if reporting the wrongdoing is in the public
interest then it could fall under the definition of Whistleblowing (or Speak Up), as defined in this
Policy.
Speak Up disclosures can have certain protections that Complaints do not. Therefore, it is important
to identify which type of report is being made from the outset.
The Speak Up Policy? should be consulted before a report is made or sent to another team by the
Complaint Handler.
The Issue Resolution Team Manager meets with the Speak Up Manager monthly to quality assure
any complaints that could potentially be Speak Up cases.
In order to assist in identifying whether a report is a Complaint or Speak Up, please see the examples
below. Further examples of events which may lead to a Speak Up disclosure are set out in the Speak
Up Policy.
The Speak Up Policy can be found on the hub, here.
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Speak Up
Complaint
A Postmaster’s assistant has seen a colleague
processing card payments with someone else's
card and with no customer present.
A Postmaster complains that their card machine
does not work, and that no replacement has
been sent.
When reporting an issue with a SmartID, a
Postmaster’s assistant reports that a POL
employee asked her to use a colleague's
SmartID to access Horizon.
A newly hired Postmaster's assistant forgets to
ask the customer for their ID.
A Postmaster contacts an Area Manager with a
discrepancy that they can't find the reason for
and is immediately advised that it's best that
they just pay for it. The Postmaster feels this is
not in the spirit of the GLO and complains.
A Postmaster complains that they do not
understand how to process a customer's
Savings account application and that Post
Office training has not been provided on this.
A Postmaster’s assistant complains that a
colleague has been making racist/discriminatory
remarks to other members of staff and
members of the public.
A Postmaster’s assistant complains that they
feel they are being bullied by the Postmaster.
Any Complaints received that are triaged and found to be Speak Up reports will be forwarded to the
Speak Up Investigation Team immediately in accordance with the Speak Up Policy and Procedures,
and with confidentiality protected subject to any exceptions set out in the Speak Up Policy.
For more details as to where and how to make Speak Up reports, please refer to the Speak Up Policy.
4.6 Control framework (controls reporting risks and process)
Self-assessment controls are in place around the risk descriptions, and these must be adhered to.
4.7 Reporting
Regular and accurate reporting is required to give information about Complaints to both Post Office
internal functions and Postmasters.
Reporting on Complaints should include, at a minimum:
« Number of Complaints received over a variety of timescales
e Complaints via channel
* Service Level data against target — minimum, maximum, average and outliers
© Resolution types
© General themes of Complaint types
* — Identification of recurring themes and issues
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e Detailed information contained within different themes, where required
e Repeat Complaints from the same Postmaster
e Insights to inform Post Office improvements based on Postmaster feedback
4.8 Closing a case
Post Office will close a Complaint case at resolution. The resolution email sent to the postmaster will
set out the options for disputing the findings.
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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 Speak Up Policy
which can be found on The Hub under Post Office Key Policies, accessed here, or report online at:
httpy/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)
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,
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6 Governance
6.1 Governance responsibilities
The Policy sponsor, the Group Chief Retail Officer of Post Office, takes responsibility 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 Central Operations Director 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
7.1 Document control record
Summary
Martin Roberts (Group Tracy Marshall (Retail Mat Thorley (Issue R&CC/ARC
Chief Retail Officer) Engagement Director) I Resolution Manager)
Document review I
Version I Policy — effective date Policy location
period
Postmaster Support
4.0 Annual 05/2024 Policies on SharePoint
Hub
Changes Updated by
0.1 22nd January 2021 Draft Version Jo Milton
0.2 22nd January 2021 Initial review Jo Milton
0.3 25th January 2021 Minor revisions to draft Jo Milton
0.4 1st February 2021 Additional risk added on training. Additional Jo Milton
principle. Footnote to define postmasters in this
policy. Minor text corrections.
05 25th February 2021 New principles about case closure and postmaster __Jo Milton
satisfaction added to 2.3. Postmaster support
policy list updated,
0.6 8th March 2021 Amended risk appetite statements. Jo Milton
0.6.1 9th and 19th March Amendments following operational review. Jo Milton
and 2021
0.6.2
1.0 30th March 2021 Final Version approved by ARC. Jo Milton
11 26th April 2021 Minor text amendments for alignment to Jo Milton
postmaster support policies
12 4th May 2021 Risk appetite amendment Jo Milton
13 25th May 2021 Added linked policy statement to front page Jo Milton
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.
14 14" February 2022 Annual Review Jo Milton
1.1 Amended Postmaster definition
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2.0
21
2.2
3.0
3.1
3.2
3.3
4.0
INTERNAL
Ist April 2022
4" July 2022
4" October 2022
5 December 2022
19" June 2023
8" December 2023
15 March 2024
21% May 2024
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2.2 Addition of section stating that a postmaster
may authorise someone to act on theirfits behalf
3.1 Updated risk appetite statements to include
Operational statements
4.8 Removed Senior Network Monitoring and
Support Manager from write-off authorisation table
3.4 Added in that the Voice of the Postmaster
committee should review complaint themes
regularly
4.3 Changed the Whistleblowing examples in the
table
Amended version number following approval Jo Milton
2.1, 3.4, 5.3, 6.1, 7.1- updated owner and sponsor Jo Milton
Rebranded policy.
Annual Review Jo Milton
Throughout - ‘Whistleblowing’ references changed
to ‘Speak Up’
Updated to full version number following approval Jo Milton
at ARC
Updated owner Jo Milton
Updated Voice of the Postmaster meeting to Retail
Committee
I Updated owner Jo Milton
3.1 Amended risk exception statement
3.2 Updated framework policy name ~ Contract
Termination Decisions Review
Annual Review Jo Milton
Updated Whistleblowing Policy to Speak Up Policy
2.3 Amendment of last two principles to reflect the
workings of the new Postmaster Experience Forum
2.5 Risks updated to reflect ServiceNow
3.4 Retail Committee replaced with Postmaster
Experience Forum
3.5 Minimum Control Standards changed to Policy
Required Operational Standards
4.2/4.3 Additional sections on Service Levels and
Executive complaints
4.4 Removal of paragraph referring to persuasive
factors found in the Investigations Policy (policy
being rewritten)
4.5 Addition of QA practices between IRT Manager
and Speak Up Manager
4.8 Update on case closure process
5.2 Addition of Speak Up and NFSP contact details
"Updated to full version number following approval I Jo Milton
at ARC
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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 7 May 2024
POL ARC 21% May 2024
Next review: 31 MAY 2025
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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