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Postmaster support
policy
Version 3.1
(POST
OFFICE
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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 Panel Composition.
4.2 Postmaster challenges — Contract Termination...
4.3 Escalation process...
4.4 Meeting...
4.5 Informing a postmaster of the decision ..
4.6 Payment during the decision review process ...
4.7 Improvement opportunities.....
48 Training...
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.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. Decision Review Panel (or panel) - a panel consisting of two Post Office Senior Leadership
Group (SLG) Members, one former postmaster and a (non-voting) Panel Chair (also a former
postmaster). The panel are responsible for deploying the procedures set out in this policy and
for making a final decision on the challenges presented to them.
2. 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.
3. Contracts Team — the Post Office team responsible for deploying the Postmaster Contract
Termination policy in taking decisions on contract terminations regarding postmasters.
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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.
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 from time to time it will make decisions that postmasters may not agree
with. The purpose of this policy is to set out the procedures to be followed should a postmaster wish
to challenge a decision in respect of contract termination and to clarify who will be involved in the
process.
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).
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
A challenge will be heard by a Decision Review Panel who will have had no material prior
involvement in the circumstances which led up to the challenge that has been raised.
Post Office will handle challenges to decision-making in good faith and apply principles of fairness,
transparency, and professionalism (being the underpinning behaviours of Post Office).
1In 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, other entity or individual that
contracts with the Post Office for the operation of a Post Office® branch,
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2.4 Application
This policy is applicable to members of the Decision Review Panel and all Post Office employees*
involved in decision review process 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
A decision taken by Post Office to terminate a postmaster's Agreement has a direct and significant
impact on postmasters and Post Office has an obligation to ensure that these decisions are not taken
arbitrarily, capriciously or unreasonably, to exercise any contractual power honestly and in good faith
for the purpose for which it was conferred on Post Office and to exercise any discretion in
accordance with the obligations of good faith, fair dealing, transparency, co-operation and trust and
confidence.
If a postmaster wishes to challenge a decision to terminate their Agreement, it is important there is a
process by which this challenge can be reviewed. Having a decision review process in place helps to
mitigate the risk of inconsistent contractual treatment of postmasters by the contract management
team.
Section 3.5 sets out the required operational standards 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 postmasters’ staff.
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3 Risk appetite and required operational standards
3.1 Risk appetite
Risk appetite is the extent to which 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 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 of postmaster support policies 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:
* Postmaster Onboarding
Postmaster Training
* Postmaster Complaint Handling
* Network Monitoring and Branch Assurance Support
e Network Cash and Stock Management
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e Network Transaction Corrections
* Postmaster Account Support
* Postmaster Accounting Dispute Resolution
« Postmaster Contract Performance
* Postmaster Contract Suspension
e Postmaster Contract Termination
e Postmaster Contract Termination Decision Review (this policy)
3.3 Who must comply?
Compliance with this policy is mandatory for members of the Decision Review Panel and all Post
Office employees involved in decision review process.
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 Strategic Executive
Group 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 personnel who carry out actions under this policy, for regularly
reviewing the effectiveness of this policy and for drafting any amendments to it that may be
required.
« Decision Review Panel - a panel that has been designed to introduce independence in the
decision review making process whilst ensuring that Post Office retains its ability to make
decisions about its contracts. To this end the panel comprises four members:
a) Two Post Office Senior Leadership Group (SLG) Members;
b) One former postmaster; and
¢) A (non-voting) panel chair (also a former postmaster).
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The panel are responsible for deploying the procedures set out in this policy and for making a
final decision on the challenges presented to them.
The Decision Review Panel must:
e apply Post Office's underpinning behaviours of fairness, transparency, and
professionalism;
* be conversant with this policy and linked policies;
* be conversant with the background behind the decision being reviewed; and
ensure this policy is adhered to and the postmaster and, as appopriate, the
postmaster's staff or owner(s) are treated with fairness, transparency and
professionalism throughout the process.
« National Federation of Sub Postmasters (NFSP) — is a professional trade association which
exists to support postmasters.
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.
In relation to this policy, the postmaster is expected to:
o be transparent and open towards Post Office;
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
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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 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
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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(s) Frequency
owners
Postmaster Inconsistent Detective control
Contract contractual treatment I The Postmaster Contract Termination Decision Head of Documented When the
Termination I of postmasters by the I Review Panel will meet following the receipt of a Contract rationale of the postmaster
Decision contract management I postmaster’s request to review the decision made to I Management & I Postmaster requests a
Review team terminate the contract and, if required, consider any Deployment Contract review of the
additional information provided by the postmaster. Termination contract
Decision Review termination
The Panel will use the information provided to make Panel decision decision
sure Post Office followed the correct procedures, has
acted consistently with the obligation to good faith,
and grounds exist to give Post Office the right to
terminate the contract.
The decision, and its rationale, made by the
Postmaster Contract Termination Decision Review
Panel will be documented to support and explain the
reasoning behind the given outcome.
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Risk area Description of risk Required operational standard Business Control(s) Frequency
owners
Detective control
All Postmaster Contract Termination Decision Head of Issuing Postmaster I Every time
Review cases are checked to make sure a letter, Contract Contract
detailing the outcome of the review, has been sent to I Management & I Termination
the address listed in the preface to the postmaster Deployment Decision Review
agreement (or an alternative address nominated by letters
the postmaster).
Preventive control
All new Postmaster Contract Termination Decision Head of Postmaster Upon
Review Panel members receive training covering the _I Contract Contract appointment
decision review process before they attend their first I Management & I Termination and annually
meeting. Deployment Decision Panel thereafter
member training
Existing members of the Postmaster Contract,
Termination Decision Review Panel will receive
ongoing refresher training on the decision review
process.
Members of the Panel will receive ongoing refresher
training on an annual basis.
Preventive control
The Postmaster Contract Termination Decision Head of Annual review of Annually
Review Policy is reviewed every twelve months, or Contract the Postmaster
sooner in the event of material changes to a policy. Management & I Contract
The Risk and Compliance Committee (R&CC) and the I Deployment Termination
Audit, Risk and Compliance Committee (ARC) Decision Review
Policy
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Risk area Description of risk Required operational standard Business Control(s) Frequency
owners
approve the policy before the latest version is
published and circulated to the business.
Preventive control Head of Annual training of Annually
All members of the Contract Management Team, and I Contract the Postmaster
any teams or colleagues who may be involved in the I Management & I Contract
decisions being taken, will be provided with training I Deployment Termination
on the Postmaster Contract Termination Decision Decision Review
Review Policy. There will be initial training if they are Policy
new to role and ongoing annual refresher training
thereafter.
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4 Procedure
4.1 Panel Composition
The panel has been designed to introduce independence in the decision review process whilst
ensuring that Post Office retains its ability to make decisions about its contracts. To this end the
panel must comprise of four members:
* Two Post Office Senior Leadership Group (SLG) Members. These are senior Post Office
managers (Band 4 and above) who will (where reasonably practicable) have had no material
prior involvement in the contractual decisions being reviewed. The presence of two Post
Office employees ensures that Post Office retains some control over the decision taken in
respect of its contracts;
© One former postmaster. The presence of a former postmaster brings some objectivity to the
decision review process and gives a postmaster voice on the panel. As this individual no
longer holds a contract with Post Office (or is no longer the director of or partner in a
postmaster), but does have recent experience of the network, this limits the risk of any
conflict of interest.
* One (non-voting) panel chair (a former postmaster). The presence of a regular panel chair
provides consistency to the Decision Review process.
4.2 Postmaster challenges — Contract Termination
a) Postmaster Contract Terminations
Post Office may need to terminate the contractual relationship with a postmaster. The Contract
Termination Policy sets out the principles and procedures that need to be followed in Post Office
reaching any decision to terminate a postmaster’s contract either immediately or by notice (but does
not cover termination or resignation by the postmaster).
Once a decision is taken by Post Office to terminate the contractual relationship this will be
communicated to the postmaster who/which, if the postmaster chooses, may challenge the decision
that has been taken. This is applicable to a postmaster on any contract type and covers decisions to
both immediately terminate and terminate by notice.
During the review process, the Decision Review Panel may seek further information from the
postmaster who will be invited to attend the meeting remotely.
The role of the panel is to review the termination decision and, if required, consider any additional
information provided by the postmaster to establish;
«whether Post Office had the right to terminate the contract;
whether the decision to do so was taken consistently with the obligation of good faith; and
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whether the decision was taken in compliance with the termination provisions set out in the
relevant contract between Post Office and the postmaster.
Decision required
The panel will collectively review the termination decision and reach a majority decision on one of the
following options:
* uphold the decision to terminate the postmaster contract; or
e overturn the decision to terminate the postmaster contract, end the suspension period (if
suspended) and reinstate the postmaster contract subject to conditions (if applicable); or
* uphold the decision to terminate the postmaster contract, but if the decision was to terminate
immediately, change the decision to terminate on notice and confirm the notice period; or
e uphold the decision to terminate the postmaster contract, but if the decision was to terminate
on notice, reduce or extend the notice period (in line with the minimum notice period as set
out in the Contract Termination Policy).
4.3 Escalation process
The Decision Review Panel will collectively review the postmaster’s challenge and reach a majority
decision regarding the challenges set out in 4.2. Each panel member will have the right of escalation,
in which case the matter will be referred to the Group Chief Retail Officer who may seek further
assurance from the Group CEO if required.
4.4 Meeting
A Decision Review Panel meeting will be held once per month.
Attendees
In addition to the mandatory panel members additional attendees will be invited (as required) to
attend either in person or remotely:
The postmaster who/which challenged the termination decision;
* Postmaster representation (if requested by the postmaster); and/or
* Contract Advisor a Head of Contract Management & Deployment who dealt with the case
may be invited to input.
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4.5 Informing a postmaster of the decision
The postmaster will be informed of the outcome by the Decision Review Panel as soon as practicable
after the decision is made. The decision, and the rationale for the decision, will be set out in a decision
letter, which will be sent to the postmaster.
4.6 Payment during the decision review process
If applicable payment under the contract to the postmaster continues during any period of
suspension (as set out in the Postmaster Contract Suspension Policy).
4.7 Improvement opportunities
As part of the Decision Review Panel process the panel may identify improvement opportunities or
business issues outside of the decisions being reviewed (for example internal processes that could
have worked better) In these instances, the panel will report back on any opportunities to the Head of
Contract Management & Deployment.
Itis the role of the Head of Contract Management & Deployment to follow up on any business
improvement opportunities identified.
4.8 Training
It is important that training is provided to anyone involved with the Decision Review Panel process,
particularly the panel members themselves. To this end initial training will be provided to all panel
members to cover postmaster contracts and the Decision Review Panel process itself with the
objective of being able to provide:
* Anunderstanding how we contract with postmasters;
« Anunderstanding of the decisions that are taken that may impact a postmaster in respect of
their contract; and
* Anunderstanding of what the expectations are of a panel member and their role in the
decision review process.
Training will be provided to all new panel members (as and when they join the panel) and as it is
recognised that it may be several months between panel members having to sit on a panel a review
of knowledge/refresher training will be undertaken every six months. In addition to this if there are
any changes in procedure additional ad hoc training will need to be provided.
It is up to the Head of Contract Management & Deployment to arrange initial training as well as
ensure the ongoing training is monitored and provided.
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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.
Ifa 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:
http//speakup.postoffice.co.uk or call the Speak Up Line on!”
Please note that a postmaster may also contact the National Federation of Sub-Postmasters (NFSP)
for help and support.
5.3 Who to contact for more information
If you need further information about this policy or wish to report an issue in relation to this policy,
please contact Tracy Marshall, Retail Engagement Director at tracy.marshall(_
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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 is 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 is 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
Standard implementer
Standard approver
Martin Roberts (Group Tracy Marshalll (Retail
Chief Retail Officer) Engagement Director)
Document review
Version
David Southall (Head of
Contract Management and
Deployment)
R&CC/ARC
Policy location
period
31 Annual 07/2024
1.0 13" December 2021 Annual policy review.
Postmaster Termination Decision Policy
rewritten as the Postmaster Decision Review
Policy
11 15" December 2021 1.1 Definitions added
12 18 February 2022 Legal Services review
NFSP feedback
New version number
13 18 March 2022 RCC feedback
2.4 and 3.3 (Application and Who Must
Comply? sections) Addition of the review
panel.
4,3 Replacement of Group Chief Operating
Officer with Group Chief Retail Officer as the
escalation point.
20 1% April 2022 Amended version number following approval
a1 5t July 2022 2.1, 3.4, 3.5, 5.3, 6.1, 7.1 - updated owner
and sponsor
Font updated to Nunito Sans
2.2 27* July 2022 4.2 — updated to reflect the established loss
process in that the decision taken on
accounting disputes will be to uphold or
overturn, not to reduce the amount.
23 5t October 2023 Annual Review
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Postmaster Support
Policies on SharePoint
Hub
lated by
David Southall, Head
of Contract
Management &
Deployment
David Southall, Head
of Contract
Management &
Deployment
David Southall, Head
of Contract
Management &
Deployment
David Southall, Head
of Contract
Management &
Deployment
Jo Milton
Jo Milton
David Southall
David Southall
Page 19 of 21
Policy changed from Decision Review Policy
to Postmaster Contract Termination Decision
Review Policy to reflect that there is a
separate governance process in place to
review suspension decisions (see Contract
Suspension Policy) and that the Accounting
Dispute process is being looked at separately.
This change has been reflected throughout
the policy document.
3.4 RCC and ARC added
3.4 Addition of a (non-voting) Panel Chair to
the Decision Review Panel
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
5.2 Added Speak Up contact details
3.0 15% December 2023 I Amended version number following approval
Rebranded
[3a I 28% June 2024 2.5 Risks amended to reflect ServiceNow
3.4 GE replaced with SEG
3.5 Minimum Control Standards changed to
Policy Required Operational Standards and
updated to reflect ServiceNow
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Jo Milton
Jo Milton
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
084597 18 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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