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Title: Postmaster Policies Meeting Date: I 30 March 2021
Amanda Jones, Retail and
Franchise Network Director
Tim Perkins, Service and
Author: Support Optimisation Director
Sponsor: Reviewed & approved by
sponsor for presentation to the
Committee.
Input Sought: Decisions
The Committee is asked to approve the six new Postmaster policies (set out in the Appendices),
to be effective from the date of Audit, Risk & Compliance Committee’s (ARC) approval:
Postmaster Complaint Handling Policy
Network Transaction Corrections Policy
Network Cash and Stock Management Policy
Postmaster Termination Decision Review Policy
Postmaster Onboarding Policy
Postmaster Training Policy
The Committee is asked to separately approve the issuing of a policy guide for postmasters
(also set out in the Appendices), considering the legal advice, to be issued from a date to be
confirmed after ARC’s approval:
« Postmaster Guide to Policies
Previous Governance Oversight
The policies listed above were approved by the Risk and Compliance Committee on 16" March,
subject to the following additions, which have been completed.
1. In the Termination Decision Review Policy, to make clear that the Review Panel referred
to is independent and external.
2. In the Postmaster Training Policy, to make clear that a trainer will be present at the
postmaster’s first cash collection, delivery and branch monthly balancing.
Executive Summary
Following the Group Litigation Order (GLO), Post Office set about ensuring that its processes
complied with the findings of the GLO.
The focus on processes delivered a large number of changes to the support that Post Office
offers postmasters, but these processes were not necessarily governed by a policy at the point
of process changes being made. Primarily this was the case because no policy existed in the
first instance or the policy was so dated that it was irrelevant to the processes undertaken pre
or post the GLO.
Having policies in place for the support Post Office provides postmasters will bring Post Office
in line with best practice franchise businesses. The purposes of the policies are to provide
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Tab 2 Postmaster Policies
guidance, set down principles and highlight risk areas, while also ensuring that Post Office is
able to support postmasters effectively and compliantly with the GLO.
As part of an overall review of postmaster support policy requirements, this paper seeks
approval for four new postmaster policies to reflect how Post Office will provide support to
postmasters as well as a guide to policies that will be made available to postmasters.
Questions addressed
1. What policies are required to support the changes made to postmaster support following
the GLO?
2. What policies have recently been developed and now require approval?
3. What further policy work is required to ensure there is a full complement of postmaster
support policies in place and how will these be continually reviewed in the future?
Report
Background
1. Following the Common Issues Judgment and Horizon Issues Judgment in the GLO, Post
Office focused on improving processes to ensure compliance with the outcomes of the
judgments.
2. Whilst process improvements were delivered, Post Office has identified that there was an
absence of overarching policies for these processes to sit under. Where policies previously
existed, they were often very aged and did not bear relevance to the processes that Post
Office had improved.
3. As such, Post Office has set about developing a set of postmaster policies across key areas
of postmaster support.
Postmaster Policies
4. Post Office has identified that a comprehensive suite of postmaster policies is required to
demonstrate and ensure GLO compliant support to postmasters in the following areas:
* Network Monitoring and Audit Support
* Network Cash and Stock Management
« Network Transaction Corrections
e Postmaster Account Support
* Postmaster Accounting Dispute Resolution
« Postmaster Contractual Performance
« Postmaster Suspension
* Postmaster Termination
« Postmaster Termination Decision Review
* Postmaster Complaint Handling
e Postmaster Training
« Postmaster Onboarding
5. The policies relating to Network Monitoring and Audit Support, Postmaster Account Support,
Contractual Performance, Postmaster Suspension and Postmaster Termination are already
approved and in use.
6. The policy relating to Postmaster Accounting Dispute Resolution is ready for ARC approval
by written resolution following offline reviewing with members of the ARC and legal.
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7. This paper seeks approval of the policies relating to Postmaster Complaint Handling,
Network Transaction Corrections, Network Cash and Stock Management, Postmaster
Termination Decision Review, Postmaster Onboarding and Postmaster Training. These
policies can be found in the appendices to this paper.
8. This paper also seeks approval of the Postmaster Guide to Policies which can be shared with
postmasters. This document can also be found in the appendices to this paper.
9. Previous papers to the RCC and ARC indicated that a Postmaster Accountability policy would
also be developed. Following a review of the requirements for this particular policy, the
requirement for such a policy has been de-scoped.
10.All policies and the policy guide have been reviewed by Post Office internal stakeholders,
the National Federation of Subpostmasters (NFSP) and have had external legal oversight
from Herbert Smith Freehills or Norton Rose Fulbright.
Policy Overviews
11.The Postmaster Complaint Handling policy sets out the standards relating to the
management of postmaster complaints, that a fair process is followed for all postmaster
complaints and that any complaint raised is taken seriously and investigated fully. It also
gives guidance on the identification of whistleblowing reports. To help the ARC understand
the application of the policy in practice, the Complaint Handling process is included in
Appendix 8 and the template used for internal reporting of complaints and progress against
resolving them is at Appendix 9.
12.The Network Transaction Corrections policy details the standards behind how Post Office
identifies and issues Transaction Corrections and Transaction Acknowledgements, ensuring
that postmasters are notified without undue delay and that support is provided to
understand the reasons behind the issuing. The process for issuing a Transaction Correction
is included in Appendix 10 to this paper to help the ARC understand the application of the
policy in practice and the list of controls that are monitored within Service and Support are
in Appendix 11 (Operational Controls Self-Assessment) for the same purpose.
13.The Network Cash and Stock Management explains the principles to ensure that postmasters
are supported effectively in managing cash and stock provisions in branch.
14.The Postmaster Termination Decision Review policy sets out how Post Office will deal with
any situation whereby a postmaster does not agree with a decision to terminate their
agreement, either by notice or immediately.
15.The Postmaster Onboarding policy details the principles that ensure that new postmasters
are supported effectively in their early days, ensuring that the onboarding process meets
regulatory and contractual obligations.
16.The Postmaster Training policy sets out the standards for ensuring that postmasters receive
a comprehensive training provision to support the effective running of their branch(es).
Postmaster Guide to Policies
17.The Postmaster Guide to Policies is a document that can be shared with postmasters and is
a guide to the principles that Post Office teams need to follow and how these principles are
linked to specific policies.
18.A legal review of this document has identified some legal risks in the publication of this
document. These are:
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. These risks have been mitigated to some extent by including wording in the guide and eac!
policy to state that they do not form part of the contract with postmasters, and through
ensuring that the guide will not be issued to postmasters prior to them entering into a
contract with Post Office.
20.These risks should also be taken in perspective with Post Office’s desire to provide
reassurance to postmasters that Post Office has robust policies in relation to postmaster
support following the GLO and its desire to be transparent in its dealings with postmasters.
Next Steps & Timelines
21. Following approval of the six policies, Post Office will ensure that:
* all relevant teams are fully trained on the new policies by the end of April 2021.
«the policies will be reviewed annually, for approval at RCC, beginning April 2022.
22.Policies previously approved at RCC and ARC in 2020 and 2021, will be updated and
resubmitted with a list of changes at the RCC meeting to take place on the 4" May 2021,
and the ARC meeting on the 18'" May (following the request from the ARC Chair), in line
with the annual review requirements of the policies.
23.In addition to the annual review of policies, as requested by the RCC, there will be quarterly
reporting to the RCC on compliance with the Postmaster policies.
24.Following approval of the policy guide, Post Office will ensure that:
e the guide is published to postmasters in line with the re-issue of the Postmaster
Support Guide.
« the guide is made available for postmasters to access online.
« the guide will be reviewed annually in line with policy approvals beginning April 2022.
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Postmaster Complaint Handling Policy
Network Transaction Corrections Policy
Network Cash and Stock Management Policy
Postmaster Termination Decision Review Policy
Postmaster Onboarding Policy
Postmaster Training Policy
Postmaster Guide to Policies
. Postmaster Complaint Handling Process
Postmaster Issue and Complaints Dashboard Template
10. Transaction Correction Issuing Process
11. Operational Controls Self-Assessment
Appendices
CONAN
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