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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
ions..
11 Definitions...
2 Overview.... 7
2.1 Introduction 7
2.2 Purpose 7
2.3 Core principles. 7
2.4 Application 8
2.5 Therisk.... 8
3 Risk appetite ....
3.1 Risk appetite ..
3.2 Policy framework.....
3.3. Who must comply?
3.4 Roles & responsibilities ...
3.5 Policy required operational standards...
4 Procedure...
4.1 Accounting dispute resolution.
4.2 Postmaster circumstances.
43 Governance...
4.4 Informing a postmaster of the decision...
4.5 Loss Established.
4.6 Loss not Established .
47 Review of dispute resolution files...
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...
7 Control...
71 Document control record
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7.2 Oversight committee.
7.3 Company details.
8 Appendices...
8.1 Postmaster findings report and Tier 2 checklist...
8.2 Case investigation report.
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1 Definitions
1.1 Definitions
10.
11.
Internal
Accounting Dispute - the triage, management and resolution of any Discrepancy identified.
ARQ (Audit Request Query) Data - This is a process whereby a number of types of data are
formally requested from Fujitsu to recover from their archives.
Case Investigation Report (see Appendix 8.2) — A report that is supplied to the postmaster
following their investigation. The Case Investigation Report includes facts and findings of the
investigation, supporting evidence and data and the rationale used to determine the
outcome.
De minimis — This is a monetary amount below which a case will be considered for write off
at any stage. The de minimis value is reviewed periodically by the Dispute Resolution
Committee.
Discrepancy - Any difference between (i) the actual cash and stock position of a branch and
{ii) the cash and stock position shown on Horizon as derived from transactions input by
branch staff into the branch's terminals. A Discrepancy could be negative or positive.
Dispute Resolution Committee — A Committee chaired by the Head of Network Support &
Resolution, which is held quarterly with an extended list of attendees to make sure complex
cases seek resolution or require further authority. This is also used to discuss cause analysis
and appropriate action planning.
Established Gain - An event that causes a positive Discrepancy (i.e. the situation where the
branch has more cash and/or stock than the derived figures for cash and/or stock on
Horizon), which has been investigated by Post Office, or agreed by the postmaster, and
found to be a genuine gain to Post Office which was caused by the negligence, carelessness
or error of the postmaster and/or their assistants.
Established Loss - An event that causes a negative Discrepancy (i.e. the situation where the
branch has less cash and/or stock than the derived figures for cash and/or stock on Horizon),
which has been investigated by Post Office, or agreed by the postmaster, and found to be a
genuine loss to Post Office which was caused by the negligence, carelessness or error of the
postmaster and/or their assistants.
Service Level (SL) — the length of time that the Post Office expects that it will take to
investigate a dispute at each Tier (see table in Section 5.1).
Tier 1 — Phone based support teams that provide information and support to a postmaster
with a view to resolving a postmaster query or concern. These teams will be the first point of
contact.
Tier 2 — Escalation team that receives unresolved cases from Tier 1, or other internal teams
and investigates them further, including the dispute of transaction corrections.
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12. Tier 3 — The team that deals with issues escalated from or assigned directly to them by
Triage or the Review Committee. These cases are either unresolved (notwithstanding
investigation at Tier 1, Triage and/or Tier 2) or are too complex to be investigated at Tier 2.
13. Triage - Function for assessing cases when they are passed through Tier 1 or other routes in
and allocating to the relevant Dispute Resolution Team.
14. Weekly Case Review — held twice weekly to make sure cases are being progressed
appropriately.
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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 accounting disputes with postmasters.
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 is part of a framework that has been established to set the minimum operating procedures
relating to the management of postmaster accounting dispute resolution. The purpose of this policy is
to clarify the nature of the dispute(s), set out the standards expected in dealing with any dispute
resolution and the procedures that need to be followed in bringing any dispute to a conclusion.
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, customers, 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
The agreements between postmasters and Post Office set out that both parties must act at all times
in good faith and Post Office will seek to resolve all accounting disputes in good faith with fairness,
transparency, and professionalism (being the underpinning behaviours of Post Office).
Post Office has an obligation to postmasters to investigate any Discrepancy properly, fully and fairly,
and ensure that it complies with its contractual obligations in relation to Discrepancies and
investigations. These obligations include, but are not limited to:
* making decisions in accordance with the obligations of good faith, fair dealing, transparency,
co-operation, and trust and confidence;
providing adequate training and support to the postmaster;
“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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properly and accurately producing all relevant records and explaining all relevant transactions
and/or any alleged or apparent shortfalls attributed to postmasters;
* communicating, not concealing, any known problems, bugs or errors in or generated by
Horizon that might have financial (and other resulting) implications for the postmaster;
e making reasonable enquiries, undertaking reasonable analysis and even-handed
investigation, and giving fair consideration to the facts and information available as to the
possible causes of the appearance of alleged or apparent shortfalls (and the cause thereof);
and
* establishing whether the alleged shortfall represents a genuine loss to Post Office.
It is vital that the procedures followed in resolving disputes or conflicts are as clear as possible to
ensure a fair, transparent, robust and consistent process for all concerned.
2.4 Application
This policy is applicable to all Post Office employees? who are involved in processes related to
postmaster investigations or disputes 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
Disputes should be resolved fully, finally and with certainty. Any investigation should be carried out in
line with the core principles as set out above and completed in a timely manner with a clear
conclusion reached, where possible.
If Post Office fails to do this, there is a significant risk the Network Support & Resolution team fail to
carry out a timely, fair, and transparent investigation.
Section 3.5 sets out the required operational standards that the Post Office has implemented to
control this risk.
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 postmaster’ staff.
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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:
e 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.
« 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 Averse risk appetite towards risks around our core operational processes that impact
postmasters.
* 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 or network in line with Post Office's risk appetite. The framework includes the following
policies:
e Postmaster Onboarding
«Postmaster Training
e Postmaster Complaint Handling
* Network Monitoring and Branch Assurance Support
* Network Cash and Stock Management
e Network Transaction Corrections
* Postmaster Account Support
* Postmaster Accounting Dispute Resolution (this policy)
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« Postmaster Contract Performance
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 are involved in processes
related to postmaster investigations or disputes.
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 & 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.
«Assurance and Complex Investigation team — provides 2" line quality and assurance
oversight.
«Retail Engagement Director — is the policy owner, who must comply with the governance
responsibilities set out at section 6.1.
* Head of Network Support & Resolution - is accountable for the deployment of this policy.
This role is also responsible for regularly reviewing the effectiveness of this policy, the
standards and processes contained within and for drafting any amendments that may be
required.
* Network Resolution and Support Operations Manager - is responsible for overseeing the
day-to-day operation of the Dispute Resolution Team(s) ensuring compliance with policy
requirements, standards and processes.
* Network Resolution and Support Team Managers and Team(s) — are responsible for the
deployment of the procedures and decisions required in this policy and must be fully
conversant with this policy and linked policies.
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3.5 Policy required operational standards
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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 all employees
must ensure that they comply with the policy requirements. There must be mechanisms in place within each business unit to demonstrate compliance. The
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:
investigation.
The Network Support & Resolution Advisor must
upload the Case Investigation Report to the
Dynamics record and include all the key evidence
associated with the decision outcome. Each resolved
case must have a detailed check made the Team
Manager, to make sure it is the right outcome.
Risk area Description of risk Required operational standard Business Control(s) Frequency
owners
Conducting The Network Detective control Head of Check Horizon did Every time
timely, fair, Support & Resolution I All investigations must check Horizon was not a Network not cause the
and Team fail to carry out I contributing factor in causing the discrepancy. Support and discrepancy
transparent a timely, fair, and Resolution
investigations transparent
Detective control Team Managers I Check resolved Every time
cases have the
correct outcome
and documentation
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Risk area Description of risk Required operational standard Business Control(s) Frequency
owners
Detective control Team Managers I Postmaster skillset. I As required
Where the case handler identifies any postmaster
support requirements, they should escalate them to
the relevant department. This could include Training,
Network Monitoring (support visit) and area manager
support.
Preventive control
When Tier 2 or Tier 3 complete their investigation,
the Network Support & Resolution Advisor must
contact the postmaster by telephone to discuss the
case investigation report. If the postmaster requests
a copy of the case investigation report, the Network
Support & Resolution Advisor must send it to them. If
the postmaster disagrees with the findings, they or
their representative can escalate the case to Tier 3 or
the Monthly Review Committee.
The Head of Network Support and Resolution should
chair the Monthly Review Committee. The
Committee should have representatives from the
operational team leads, legal, contracts, Network
Monitoring, Assurance and Complex Investigations
and the Branch Support Centre present.
Detective control
A report, to identify all cases that have breached the
set service level, must be run daily from MS
Dynamics. Daily and weekly cases reviews should
Operations
Manager
Team Manager
gap - support
offered
Providing copies of
the investigation
report when
requested
Advising
postmasters of the
dispute process
Postmaster request
to escalate
Dispute Resolution
Committee
attendance
Speed of resolution
Every time / as
required
Every time / as
required
Monthly
Daily
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Risk area Description of risk Required operational standard Business Control(s) Frequency
owners
take place to check case position, including age and Twice weekly case I Twice weekly
progress. review meeting to
check status of
investigations
Detective control
Cause analysis must be carried out to identify the Operations Cause analysis of Daily
common causes of disputed discrepancies. Any Manager and disputed
findings should be shared with the relevant business I Head of discrepancies
areas, so they can put action plans in place where Network
required. Support and
Resolution
Preventive control
The Accounting Dispute and Resolution Support Head of Review of the As required (but
policy should be reviewed and updated where Network Accounting Dispute I reviewed at
necessary. RCC and ARC must approve any material I Support and and Resolution least annually)
amendments made to the policy before the new Resolution Support policy
versions are published and circulated to the
business.
Preventive control
The Accounting Dispute Resolution Teams and the I Head of Refresher training Annually or, if
. Network for the Accounting I sooner, after the
Postmaster Account Support Team must receive .
_. . . . i Support and Dispute and policy has had
training on this policy with regular refresher training Resolution Resolution Support I any material
thereafter. policy amendments
approved,
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4 Procedure
4.1 Accounting dispute resolution
The Postmaster Account Support Policy’ sets out the responsibilities of Post Office in relation to the
management of account Discrepancies. These responsibilities include notifying postmasters of such
discrepancies and taking payments, when agreed by the postmaster.
This section sets out the procedure for investigating Discrepancies in a fair, timely, transparent and
impartial manner in order to establish whether or not they are Established Losses or Established
Gains.
During the investigation process, the postmaster will not be contacted about settling the disputed
amount.
A postmaster may dispute a Discrepancy or a transaction correction, in which case Post Office will
support with an investigation.
All investigations teams will enter details of their investigations into the case management tool as
part of a standardised dispute resolution process. In situations where Horizon data of over 12 months
is required, there is a clear process for requesting ARQ Data and requesting user interaction
(keystroke logging) data to ensure a consistent approach to investigations. In addition, all voice calls
with postmasters are to be made using Puzzel to ensure that recording takes place.
Investigation teams will receive training on new processes and procedures and any change to
existing ways of working.
Tier 1 — These investigations are conducted by the Branch Support Centre and relate to enquiries
made by postmasters about account balancing and discrepancies. The Tier 1 team may liaise with the
Branch Reconciliation team that issue transaction corrections, to find out all relevant information.
Actions taken during a Tier 1 investigation could include the following:
e Talking the postmaster through basic methods to establish the reasons for their
Discrepancy or transaction correction and providing associated support.
* Arranging for additional postmaster support and/or training if required (for example,
classroom training on investigating balancing discrepancies).
Tier 1 investigations are intended to provide a quick resolution to postmasters on straightforward
balancing and transaction correction enquiries. As such, these investigations may be resolved in a
single contact and if further investigation is required, the matter will be escalated to Triage.
The Postmaster Account Support policy can be found on the hub, here.
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Triage — These cases include disputes passed through Tier 1 without resolution. Triage is intended to
ascertain the criteria to be used to assess cases and determine the allocation to investigations teams
and to ensure consistency in response times.
Actions taken during the triage process could include the following:
e Cases are entered into the case management tool, if not already completed.
* Cases are reviewed by team managers and prioritised based on risk to both the
postmaster and Post Office.
* Assign cases to the relevant team, noting escalations where necessary.
e A basic investigation takes place for the most common and frequent issues causing a
branch discrepancy to attempt to resolve the case without further escalation, where
possible.
Post Office will apply De Minimis criteria to certain cases (e.g. cases below a certain value or where
no previous issues have been identified) to improve the postmaster journey and allow greater focus
on priority cases. Post Office reserves the right not to apply the De Minimis if there have been more
than two write offs in the last 12 months.
Tier 2 - These investigations are full detailed investigations after being assigned by Triage.
Actions taken by a Tier 2 investigation could include the following:
Fully investigating the dispute by checking internal systems and contacting all relevant
teams to determine the relevant context behind, and investigating the reason for, the
Discrepancy.
e Undertaking a check of the Horizon system information to ascertain whether Horizon
was a contributory factor to the Discrepancy.
* Discussing the results of the investigation in detail with the postmaster or representative
team member.
« Checking if the dispute has been settled and confirming details of how and when.
* If the discrepancy is an entry on the postmaster’s account, ensure that it is marked as
being in dispute by the Postmaster Account Support Team.
e Checking if there are any related cases and documenting all steps of the investigation in
the case management tool.
* Arranging for additional postmaster support and/or training if required (for example,
classroom training on investigating balancing discrepancies).
e Flagging any issues that require root cause investigation to the relevant team.
Carrying out data reviews and completing other details as required under the Tier 2
checklist. (See Appendix 9.1 for further details)
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The Tier 2 team will aim, where possible, to complete their investigations within 10 working days of
escalation from Tier 1. The postmaster will be engaged and involved throughout the process,
including if they disagree with the outcome.
Tier 3 - Where a matter is unable to be resolved by the Tier 2 team, the Tier 2 team will escalate the
investigation to the Weekly Case Review who are responsible for allocation to Tier 3. The Tier 3 team
are responsible for carrying out an investigation to confirm, amongst other contractual thresholds,
that:
* The alleged shortfall has been properly, fully and fairly investigated in a timely manner.
* The shortfall represents a genuine loss to Post Office properly attributable to the
postmaster.
«The Horizon system information has been checked to ascertain whether the Horizon
system was a contributory factor to the Discrepancy.
* Any action (or inaction) by Post Office itself has been a contributory factor that may have
led whether wholly or partially to the Discrepancy.
«The shortfall has been caused through the postmaster's negligence, carelessness or error
and/or the shortfall has been caused by the negligence, carelessness or error of their
Assistant(s).
Post Office will offer the postmaster the Case Investigation Report (see Appendix 8.2) both for
transparency and to give the postmaster an opportunity to investigate using the same information
that is available to Post Office.
The Tier 3 team will aim, where possible, to complete their investigations within 10 working days of
escalation.
Summary of investigation timelines
Investigation level
Aim to investigate within...
Cumulative investigation time
Tier 1 1 working day 1 working day
Tier 2 10 working days 11 working days
Tier 3 10 working days 21 working days
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4.2 Postmaster circumstances
Post Office will consider any relevant circumstances of the postmaster, made known to them,
including those who find themselves in a vulnerable situation, due to:
a)
b)
c)
d)
Health
Financial capability
Financial resilience
Life events.
4.3 Governance
The Weekly Case Review will consist of a team of lead representatives from all Dispute Resolution
Teams for the following purposes:
Review any backlog of cases under investigation by managing, allocation, resourcing and
prioritisation.
Identify cases approaching Service Level (SL) which may pass the SL and decide actions
to be taken to ensure the cases are dealt with efficiently but without compromising on
the quality of the investigation and review.
Highlight any cases of notable interest or risk. This could include cases that exceed SL,
relate to discrepancies of a comparatively high value, are high profile (either with internal
or external stakeholders), pose a significant risk to the reputation of Post Office, are likely
to set a precedent or is an example of a frequently occurring trend. The highlighting of
such cases would be at the discretion of the team manager.
* Determine which cases should be escalated to Tier 3.
* Take decisions on how to conclude investigations up to a specified threshold.
Identify potential unusual trends or improvement points and escalate these to the
relevant section of Post Office.
The Weekly Case Review will use information from ongoing open cases to be escalated to the
Dispute Resolution Committee.
The Dispute Resolution Committee will consist of representatives of the investigation teams, the
Head of Network Support & Resolution (Chair), operational team lead representatives, Head of
Contract Management & Deployment, Director of Assurance and Complex Investigations and a legal
representative for the purpose of the following:
Internal
Review cases escalated from the Weekly Case Review and decide on actions to be taken for
resolution.
Review overall investigations performance dashboard vs SLAs
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e Provide oversight of the review process and feedback on cause analysis.
* Decide on resolution from findings and outcomes on cases documented to be passed on to
the relevant team to action.
* Assure decisions made are fair and reasonable for the circumstances of the case.
Minutes of the Committee meetings will be taken to record decisions.
4.4 Informing a postmaster of the decision
The postmaster will be updated throughout the process, including when the investigation moves to
another owner, and once the investigation is concluded. Once any level of investigation is completed,
from Triage to Tier 3, Post Office will offer the postmaster a copy of a Case Investigation Report.
This document is also used by the Head of Network Support & Resolution and Tier 1-3 managers as
the basis for their decision on the resolution of the case.
When informing the postmaster of the decision, Post Office will provide the following information:
their reason(s) for reaching the decision;
e confirmation that an investigation has been carried out and that documents relating to the
investigation will be offered to them; and
any other relevant information relating to the investigation that is appropriate to be shared
with the postmaster.
«Ifa postmaster disagrees with the outcome of a Tier 2 investigation, then the postmaster can
request their case to be reviewed Tier 3.
Ifa postmaster disagrees with the outcome of the Tier 3 review, then the postmaster can put
a case forward, by email to their Tier 3 case worker, who will present to the monthly
Committee for review.
4.5 Loss Established
If Tier 1, Triage, Tier 2 or Tier 3 investigations conclude that an Established Loss has occurred, the
outcome of the case will be forwarded to the Postmaster Account Support Team and the process as
set out in the Postmaster Account Support Policy‘ will be followed.
The Postmaster Account Support policy can be found on the hub, here.
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4.6 Loss not Established
If Tier 1, Triage, Tier 2, or Tier 3 investigations do not conclude that an Established Loss has occurred,
a decision about writing off the Discrepancy will need to be taken by the authorised roles listed
below. They must give their prior approval for any such financial write off.
The table below contains a list of authorised roles and the limits of the amounts they are authorised
to write off:
Up to £5,000 Tier 2 Team Manager/ Tier 3 / Postmaster Account Support Manager.
Up to £25,000 Network Support and Resolution Operations Manager.
Up to £100,000 Head of Network Support and Resolution.
Over £100,000 Central Operations Director.
Once an authorised role has approved a decision for financial write off, the manager of the Tier 1, 2
or the Tier 3 team must inform the Postmaster Account Support Team manager of the decision.
4.7 Review of dispute resolution files
All individual cases that are completed by Tier 2 and 3 will receive a summary quality control check
by a manager for completeness and to ensure that the correct procedure has been followed and a fair
and reasonable decision has been reached.
Any investigation report that is being shared with a postmaster is also to be reviewed to ensure that
the report is ready in all aspects to be released to the postmaster.
The Assurance and Complex Investigations team (A&Cl) will perform an independent sample check
of cases on a monthly basis. The A&C will share their findings with the Network Support and
Resolution Operations Manager and the Head of Network Support and Resolution.
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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:
Please note that a postmaster may also contact the h
for help and support, by contacting their helpline on
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,
se conta +t the Retail E1 ment Director, Tracy Marshall, by emailing
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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 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 Control
7.1 Document control record
Summary
GE policy sponsor I Standard owner I Standard implementer Standard approver
I
Martin Roberts (Group ‘Tracy Marshall (Retail Simon Worboys (Head of R&CC/ARC
Chief Retail Officer) Engagement Director) I Network Support and
Resolution)
Document review es A , s
Version I Policy ~ effective date Policy location
period I
Postmaster Support
4.0 Annual 07/2024 Policies on SharePoint
Hub
Changes I Updated by
19th November 2020 Initial draft version David Southall
10th December 2020 Amended section 4.1, changed version number to Jo Milton
0.2
03 15th December 2020 Added footnotes Jo Milton
0.4 3rd February 2021 Amended section 5 with timescales and controls. Jo Milton
Added section 1 — Definitions.
Added appendices.
0.5 5th February 2021 Updated following legal review Jo Milton
0.6 10th March 2021 Updated following ARC review Jo Milton
0.6.1 16th March 2021 Text adjustments (acronyms) Jo Milton
1.0 Ast April 2021 Final approved by ARC Jo Milton
11 8th April 2021 Updated draft to reflect Investigations Target Neil Davey
Operating Model 1.0
12 14th April 2021 Updated draft following 1st legal review Jo Milton
13 26th April 2021 Alignment with other postmaster support policies Jo Milton
14 4th May 2021 Risk appetite amendment Jo Milton
15 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.
Internal Postmaster accounting dispute resolution policy V 4.0 Page 22 of 36
1.6 18" February 2022
2.0 [1 April 2022
21 “B® July 2022
21 9" August 2022
3.0 26" September 2022
31 17" February 2023
3.2 I 8" December 2023
I
Internal
Removed reference to “settled centrally” in the
Case Overview of the Case Investigation Report
Annual Review
2.1 Addition of section stating that a postmaster
may authorise someone to act on their/its behalf
2.5 Risks updated
3.1 Updated risk appetite statements to include
Operational statements
3.4 Added in two new roles
3.5 Minimum Control Standards updated to reflect
updated risks
4.1 Review Committee updated with correct names
and aims
4.2 Added reference to the Decision Review
process and policy.
4.4 Removed Senior Network Monitoring and
Support Manager from write-off authorisation table
4.5 Updated role responsible for quality
8.1 Tier 2 Checklist (Postmaster Findings Report)
updated
Amended version number following approval
"2.1, 3.4, 5.3, 6.1, 7.1 - updated owner and sponsor
3.5 Amended Daily Case Review to when required
4.5 Revised Tier 2 case checks from 3 to all.
Font updated to Nunito Sans
Throughout — amended “Operational Review
Committee” to “Dispute Resolution Committee”
1.1 Removed Postmaster Information Pack and
updated description of Case Investigation Report to
include this. Split “Review Committee” definition
into two ~ Weekly Case Review and Monthly
Dispute Resolution Committee.
4.1 Small amends for clarity. Amended Postmaster
Information Pack to Case Investigation Report (as
the former is now included in the latter). Removed
reference asking the postmaster to confirm receipt.
4.2 Governance header added. Separated narrative
about weekly and monthly meetings. Added new
action for the Weekly Case Review - “Determine
which cases should be escalated to Tier 3.”
4.3 Simplified bullet points to show escalation
route
4.5 Removed paragraph about sample quality
checks as 100% of case files receive a check.
I Amended version number following approval
Minor clarifications and wording amendments
following legal review.
Updated owner
5.2 Added SI
Updated owner
1.1 Clarified Established Loss/Gain definitions
3.1 Amended risk exception statement __
Postmaster accounting dispute resolution policy V 4.0
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“Jo Milton
Jo Milton
Simon Worboys
Jo Milton
Simon Worboys
[Jo Milton
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3.2 Updated framework policy name ~ Contract
Termination Decisions Review
3.3. I 17 April 2024 ~~ \AnnualReview ~~~"I’Simon Worboys
1.1 Updated Monthly Dispute Resolution
Committee to Quarterly
2.5 Risks updated to reflect ServiceNow
3.4 Removed Finance Director and CFO and added
AC &I
3.5 Minimum Control Standards changed to Policy
Required Operational Standards
4.2 Addition of postmaster vulnerability section
4.3 Updated committee members
4.4 Removed reference to Decision Review Panel
4,7 Addition of A&CI sample check
5.2 Addition of NFSP contact details
“4.0 1*July2024.~~—~—~—~—~-«d Amended version number following approval “Jo Milton
7.2 Oversight committee
Oversight Committee: Risk and Compliance Committee and Audit, Risk and Compliance Committee
Committee Date approved
POL R&CC 13 JUN 2024
POL ARC 01 JUL 2024
Next Review: 31 JUL 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 (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
8.1 Postmaster findings report and Tier 2 checklist
Tier 2 - Investigation Details
Tier 2 Case Handler: Date Picked Up:
Branch Name: Branch Code:
Reference Number: Current Discrepancy:
Branch Contact: Contact Number:
Date Discrepancy Appeared: Stock Unit(s) Involved:
Date case escalated to
Tier 3 (if applicable)?
Case Summary:
Beginning — What does the postmaster believe to have happened? What does the postmaster need to
resolve the case? This should paint a picture of how the case was raised and who we have it
le.g. The dispute cases for xxx Post Office were raised by Postmaster Account Support Team following
ldiscrepancy values being settled to review and dispute.
On Xth XXXXX 202x, a shortfall/surplus discrepancy of £xxxx was settled to review and dispute.
IAttempts to contact the branch were unsuccessful due to the branch landline having a call screening
Imanagement set up. Email contact was attempted however no reply was received.
Postmaster stated that they believed the discrepancy was the result of xxx
(the following statement must be included in this section of the report)
IThe discrepancy review will be carried out in accordance with the Network Support & Resolution overarching
Postmaster Dispute Resolution Policy, associated processes, strategy and any actions and decisions recorded
lon the log contained within this report.
Overview of Investigation:
Middle - What have you done to investigate the case? What actions have you taken to support the
postmaster?
Evidence, timeline, findings
E.g. of structure of report
Branch Overview
Stock units
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Branch users
Opening hours
CFS
Start
What happened on the day the discrepancy was settled?
What does the branch balancing look like?
When did the discrepancy start?
Middle
What potential causes are there for the discrepancy within the date range identified?
Can any of these be found to be a definite cause? If so, why? If so, why not?
End
What conclusions can be made from the findings?
Case Outcome & Recommendation:
End - What has your investigation found? What outcome have you reached? What is your
recommendation to resolve?
Manager Comments:
Comments: Manager perform QA of case.
Has a fair and reasonable outcome been reached? Does the case need to be
escalated to weekly / monthly Committee? Does the case need to be escalated
to Tier 3? Is there any additional action/recommendations such as escalation
points?
Authorising Manager Date:
Action Log
Decision Agreed Action
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Document Checked Not Analyst Comments.
Checked
Contact the Branch, introduce oO oO
yourself as Case Handler &
obtain/capture any relevant
initial information from SPMR
Docume! N/A Found Not Analyst
Comments
Review Dynamics and initial case a Oo o ao
notes & familiarise with discrepancy
issue whilst reviewing (If not enough
detail or process has not been
followed, inform Team Leader to
pass back)
Has the discrepancy been settled? If Oo ao Oo ao
so how & when? Ensure that the
discrepancy has been blocked with
the Postmaster Account Support
Review any possible related o Oo o Oo
previous cases on Dynamics
Check if the Branch have raised any im) o Oo im)
incidents with ITDSD relating to any
system issues
Check HORice to establish the last Oo Oo o a
time the Branch balanced without
any problems. Also check the last
time they completed a BP and are
they being done regularly.
Check the latest Branch Impacting a a o a
Problem tracker (BIP) to ensure the
discrepancy is not related and add a
copy of the BIP tracker to the
dynamics case.
Checked where the discrepancy is i] oO a Qo
(Cash, currency, or stock)
Checked stock & cash rems Oo im] o QO
Checked stock adjustments a Oo o ia
Checked reversals new & existing o oO a a
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Document ZN Found Not Analyst
Found Comments
Checked transfers o ia ao a
Checked mis keys a Oo o ao
Checked non sales (housekeeping/ Oo Oo a Oo
Rep Events)
Check duplicate transactions a a a im]
Check trading statements im] im] ia) a
Check suspense account im] Qo a Qo
Check if there are any zero Oo o a Qo
transactions that should have a
value
Check any cash variance Oo Oo oO
Check recoveries — roll forward or a a Qo
roll back
Check for any Transaction o ia) o ia)
Correction's
Check for any Transaction im] Oo o a
Acknowledgement'’s
Dispute Policy Checklist
Document
Checked N/A
The alleged shortfall has been properly, fully and fairly investigated in a timely o oO
manner
The shortfall represents a genuine loss to Post Office properly attributable to the Oo o
postmaster
A review of the Horizon system has been undertaken to ensure that it was not a o oO
contributory factor to the discrepancy
Any action (or inaction) by Post Office Limited has not been a contributory factor Oo oO
that led directly to the shortfall
The shortfall has been caused through the postmaster's negligence, carelessness, or oa a
error and/or the shortfall has been caused by the negligence, carelessness, or error of
their Assistant(s)
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Case data
Use this box to embed your case data
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8.2 Case investigation report
Tier 3 Review Document
Investigation Details
Branch Name & Branch Code:
Case Reference Number:
Postmaster Name:
Legal Entity Contracted with:
Branch Format:
Former/Current:
Claim Value:
Executive Summary
Note: This section is to provide an overview of the case, key points and the conclusion. This section should
be in bullet point format (where possible).
Analyst Recommendation
Recommendation: Note: Recommendation to be completed by Analyst.
Value (If Applicable):
Case Handler: Date:
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Manager Comments
Comments: Note: Comments to be completed by Manager.
Authorising Manager: Date:
Case Summary
The discrepancy review will be carried out in accordance with the Network Support & Resolution
overarching Postmaster Dispute Resolution Policy, associated processes, strategy and any actions and
decisions recorded on the log contained within this report.
Case Overview
Branch Overview
Stock units
Branch users
Opening hours
CFS
Rough Notes
Case Conclusion
Note: This section is to finalise the findings of the Investigation Overview section into a conclusion on the
case.
Additional Case Findings
Note: This can be findings which do not specifically relate to the case, but are appropriate to send on to a
different team in the business; for example the branch are processing reversals for small value transactions
to cash, which could highlight the branch taking retail transactions at the Post Office counter. This would be
something to feedback to the Area Manager.
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Additional Support Required
Note: This section can contain any support which is recommended as being required. For example; It is
recommended that the branch is provided additional training and support around cash declarations and
lottery accounting. This additional training would then need to be requested by the analyst.
Business Improvements
Note: This section is to note any potential business improvements which have been raised through the
investigation.
Action Log
Decision Action
Case Evidence Log
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CIR-— Investigation checklist
Data Downloads for Discrepancies:
Session Data
Rep Events
Trading Period Data
Core Finance System Data
Transaction Corrections (if applicable)
Oo
a
oO
ies)
oO
item:
Ensure these are completed at earliest opportunity, to avoid risk of losing data.
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Document
Review Dynamics and initial case
notes & familiarise with discrepancy
issue whilst reviewing (If not enough
detail or process has not been
followed, inform Team Leader to
pass back)
hecked
N/A
Not Found — Analyst
Oo
Comments
Contact the Branch, introduce
yourself as Case Handler &
obtain/capture any relevant initial
information from SPMR
Has the discrepancy been settled? If
so how & when? Ensure that the
discrepancy has been blocked with
the Postmaster Account Support
Review any possible related
previous cases on Dynamics
Check if the Branch have raised any
incidents with ITDSD relating to any
Check HORice to establish the last
time the Branch balanced without
any problems. Also check the last
time they completed a BP and are
they being done regularly.
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Document hecked N/A und = Not Found Analyst
Comments
Check the latest Branch Impacting o o ia) a
Problem tracker (BIP) to ensure the
discrepancy is not related and add a
copy of the BIP tracker to the
dynamics case.
Checked where the discrepancy is o o ia o
(Cash, currency or stock)
Checked stock & cash rems o a ia) a
Checked stock adjustments oOo a ia o
Checked reversals new & existing a Oo Oo o
Checked transfers ao a a ia)
Checked mis keys o a ia) a
Checked non sales (housekeeping/ o o ia o
Rep Events)
Check duplicate transactions ia] Oo a a
Check trading statements oO a Oo [a]
Check suspense account oO ao Oo Oo
Check if there are any zero o a ia ia)
transactions that should have a
value
Check any cash variance a
Check recoveries — roll forward or
roll back
Check for any Transaction o a ia) o
Correction’s
Check for any Transaction o oO Oo Qo
Acknowledgement's
Dispute Policy Checklist
Document Checked
The alleged shortfall has been properly, fully, and fairly investigated in a timely manner a
The shortfall represents a genuine loss to Post Office properly attributable to the Oo
postmaster
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A review of the Horizon system has been undertaken to ensure that it was not a Oo
contributory factor to the discrepancy
Any action (or inaction) by Post Office Limited has not been a contributory factor that led Oo
directly to the shortfall
The shortfall has been caused through the postmaster’s negligence, carelessness, or error oO
and/or the shortfall has been caused by the negligence, carelessness, or error of their
Assistant(s)
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