POL00460000 - Post Office Investigation Report: Pineapple

Evidence on official site

POL00460000
POL00460000

FORM

STRICTLY PRIVATE AND CONFIDENTIAL
INVESTIGATION REPORT: PINEAPPLE

INVESTIGATING I Nicola Marriott PHONE
MANAGER: People Partnering Director I NUMBER:
CONTACT
st i
DATE: 1* September 2024 EMAIL: Nicola.marriott:

INTRODUCTION & BACKGROUND

On the 18" January 2024 an email was sent from Nick Read to Ben Foat, Martin Roberts, Owen
Woodley, Tracy Marshall and Philippa Hankin requesting a response to be crafted to a complaint
received by Henry Staunton from Voice of Postmaster (VOP). Attached to this request was the
complaint from VOP as well as an email titled ‘Project Pineapple’, which was dated 15 January
2024.

The Project Pineapple email chain started with Henry Staunton summarising a discussion with Saf
Ismail and Elliot Jacobs on 10" January 2024. This was sent on 14" January to Saf and Elliot with a
request for them to confirm it was an accurate representation of concerns they had raised and to
ensure nothing had been missed. The subsequent responses from Saf and Elliot are also in the chain
the final response being from Elliot on 15" January. The email chain raises a number of concerns
about Senior Post Office employees, culture and working practices. Both Martin Roberts and Ben
Foat were specifically named in the email.

Nick Read is not a recipient on the email and received this as an attachment at the same time that
Henry sent on the Voice of PM (VOP) letter to Nick to be dealt with. Nick then forwarded this in error
to the wider group of employees for action.

On receipt of this email, Martin Roberts and Ben Foat both raised concerns about the tone and
allegations of the email and how they had come to receive it. This was escalated by Ben to Karen
McEwan and Ben Tidswell on the 18" January in an email within which he disputed the allegations.

Conversations subsequently took place over the remainder of January. Saf and Elliot met with Martin
Roberts following a Board meeting on 30" January to apologise for the tone of the email and the
manner in which it was received, reiterating that it was never their intention for it to be sent on in
that format. On 31* January Martin followed up to Saf and Elliot requesting the apology in writing.
This was escalated by Elliot into Owen in an email of the same date which was sent to Nick Read,
Ben Tidswell, Saf and Karen McEwan. Elliot explained the conversation and that whilst the tone and
way the message was delivered was unacceptable, he stood by a number of the allegations. Owen
replied on the same date saying he would take advice and come back with next steps.

During this period Saf and Elliot also met in person with Ben Foat.

Owen confirmed via email to Elliot and Saf on 6" February that the concerns, particularly in relation
to Martin Roberts, would be formally investigated.

Strictly Private and Confidential: Pineapple Investigation Outcome
1
POL00460000
POL00460000

FORM

Having subsequently been appointed to investigate the matters, I outlined the full scope of the
investigation to Nick Read cc Karen McEwan and Owen Woodley on 25" February 2024, as follows:
Issue / Allegation Source

No action from the escalation of clawbacks 2 years ago as a result of out of date Pineapple Email
documentation:

- ATM discrepancies

- Rejected foreign currency

- Rejected fake notes

Inherent views within the culture of the organisation that PM's (PM's) are not to be trusted Pineapple Email
and ‘toxic culture! - including approach to above ATM discrepancies etc as examples

Failure of the business to investigate formal complaints made against Martin Roberts Elliot email to
Owen
Martin Roberts Pineapple Email

- reference to an investigation regarding inappropriate behaviour and lack of integrity

- changes to PM accounts regarding postage stamps without their knowledge - Elliot being

on ARC ensured controls strengthened.

- view that Martin and his team do not want an extension to Saf and Elliot as less

experienced PM's would not be able to challenge

Ben Foat Pineapple Email
- him and members of his team act like PM's are guilty until proven innocent

- Pushed Phoenix into the long grass

- Uses his leadership of the Inquiry team as an instrument of his power

Stephen Bradshaw Pineapple Email
- went into one of Saf's stores years ago and said we are closing you down - PM's tell him

not much has changed

48 investigators employed within the business, just like Stephen Bradshaw, expectation _ Pineapple Email
that the business parts ways with all such employees

Generous sick leave - no similar benefits to PM's, how are we accepting so many people _—_ Pineapple Email
drawing sick benefits, especially in HR

Phoenix - should have been dealt with by now and is taking too long Elliot email to
Owen

Lack of engagement by the PM Engagement team with the NEDs - we are sidelined and Elliot email to

rarely consulted by the PM Engagement team on anything. Owen

METHODOLOGY

Fact finding meetings were undertaken as follows:

- 1 March 2024 - Saf Ismail and Elliot Jacobs (delayed from initial meeting request 27" Feb at
their request)

- 5" April 2024 - John Bartlett — initial informal conversation (not minuted but used to request
additional information)

- 26" June 2024 - Martin Roberts

- 30 July 2024 — Tracy Marshall

- 30% July 2024 — Pete Marsh

- 1% August 2024 — David Southall

- 1% August 2024 — Mel Park

- 6" August 2024 - John Bartlett

- 27% August 2024 — Russell Hancock

- 27% August 2024 - Simon Worboys

In addition relevant supporting emails / statements or documents were requested and reviewed as
follows:

Strictly Private and Confidential: Pineapple Investigation Outcome
2
POL00460000
POL00460000

FORM

- Project Pineapple emails dated 18" January 2024

- 20 March 2024 - request to John Bartlett and Claire Hamilton following informal discussion
for any complaints and subsequent action taken relating to Martin Roberts.

- 27" March 2024 - email from Mel Park following informal discussion containing the ‘Historic
Pouch discrepancies / activities GE paper, dated 24" January 2024

- 5" April 2024 - Project Venus shared by Andrew Morley — review of all investigation
documents including emails, documents, invitations to meetings and outcome letter.

- 8" April 2024 - email from Alison Hoyland containing extracts from an additional
extraordinary Board meeting relevant to anonymous allegations raised through
whistleblowing including against Martin Roberts. Board meeting took place 5" July 2023.

- 24% April 2024 — email from Mel Park containing further update on closure of action relating
to Historic Stock Pouch activity (forwards email from 9" February 2024 to Marie Malloy to
update on an open ARC action on the matter)

- 25" April 2024 — email from Claire Hamilton outlining all allegations received into Speak Up
relating to Martin Roberts

- 20% June 2024 - x 5 emails from Martin Roberts following fact finding meeting with him
sharing the history of the Project Pineapple situation from his perspective including a
timeline of activity. An e-christmas card he shared to Saf and Elliot and the emails I had
already had sight of requesting a written apology from Saf and Elliot.

- 30" July 2024 — email from Pete Marsh containing Branch Assurance Visits Stock
Corrections_v2.0 28JUN23 written by David Southall

- 1% August 2024 — David Southall email containing TOR Stamps Investigation PowerPoint,
summary of investigation timeline for Horizon Account corrections re Stamps and relevant
email trail from May — June 2023 discussing approach to resolving the concern when the
issue was first escalated

- 1% August 2024 - email from Marie Malloy containing PM NED role profile and letters of
appointment and conflicts of interest policy

- 7" August 2024 -email from Rebecca Porch in response to request for information re
Counterfeit Notes policy and process including document outlining summary of approach
dated 12" April 2024 and a forward of an email communicating the policy

- 7 August 2024 - email from Alison Clark re ATM discrepancies. Includes 2 x documents,
PM Accounting Dispute Resolution Policy v4.2 last updated 6 Aug 2024 and Process Non
Balancing Shortages last updated 5” Jan 2023.

- PM Support Network Cash and Stock management policy version 4.1

- PM Support Transaction Correction Policy version 4.2

- PM Support Accounting Dispute Resolution Policy 4.2

- Non Balancing strategies ATM process flow

- BRT ATM disputes Management guide November 2021 version 1.9

- Tim Perkins email 26th August 2024 - discrepancy management and root cause historically
within Central Operations

- Terms of reference: Tactical coordination group — attached to David Southall email dated 1°
August 2024

- 27 August email exchange re additional clarification on point 1 with Saf and Elliot

- Email Pete Marsh to David Southall 14" June 2023 — attached to email from David Southall
to me dated 1** August 2024

- 27% August email from Simon Worboys relating to pre April 21 discrepancy approach and
outstanding issues

-  26"/27% August — email Tim Perkins re management of discrepancies and outdated
documentation

Strictly Private and Confidential: Pineapple Investigation Outcome
3
POL00460000
POL00460000

FORM

- Jacki Adams Teams Chat 27" August re Post Office Process Review (PPR) remediation
scheme

- 28" August — Racheal Wheeler email containing Stamps Tactical Group TOR and GE Paper
on Prioritisation and Resourcing of CIU investigations

- 30" August — Nigel Clibbens email re PPR outlining scheme scope, approvals and
background of RC / Board updates

FINDINGS

1. No action from the escalation of clawbacks 2 years ago as a result of out of date
documentation:
- ATM discrepancies
- Rejected foreign currency
- Rejected fake notes

The investigation found that outdated documentation was a contributing factor in discrepancies
relating to such areas as above and this was resulting in disputes being raised into the Central
Operations team. Documentation had not been consistently updated and reissued in paper format to
all PM's due to cost, and the documentation at the time was not available on Horizon meaning that
not all PM’s had access to up to date processes and relevant processes or updates.

In April 2021 a new approach to supporting PM's with understanding losses / discrepancies was
implemented. The Network Support and Resolution team was introduced led by Simon Worboys
along with a new suite of policies that clearly outlined end to end processes, roles and
responsibilities as well as escalation routes relating to discrepancies. These policies were clearly
labelled PM Support and include Network Cash and Stock Management, Transaction Correction and
Accounting Dispute resolution. These policies outline guidelines for the management of
discrepancies arising out of all products including ATM, counterfeit notes and foreign currency and
ensure that post April 2021 there is consistent support and approach for PM's in addressing these
types of issues.

If there is a reconciliation error and a transaction correction is issued there is a clear dispute process
outlined in the Transaction Correction policy should the PM not agree with the reason given. An
independent review will then be carried out to make sure that the transaction correction was issued
correctly and the findings shared with the PM. PM's have to agree to a repayment plan and so the
opportunity for PM's to suffer detriment within the current processes are significantly mitigated.
Branch hub and Horizon Help have also now been introduced / updated to ensure PM's have access
to all relevant up to date processes and documentation.

It is of note that the Network Support and Resolution team were set up with a go forward
responsibility only, which has meant that any concerns regarding detriment incurred by PM's as a
result of these types of issues had no route to be addressed. Given this, and the acknowledgement
that the support provided historically to PM’s was inadequate, the Remediation Unit picked up the
issue of historical detriment and the Post Office Process Review (PPR) Scheme has been established
to provide a route to remediation for these kinds of issues for PM's.

Over the past two years the RU detriment team has investigated 19 processes/products to see if
there are any issues we could find that have or could cause detriment to PM's outside of the known
Horizon problems. The adequacy of training and documentation was considered as part of these

Strictly Private and Confidential: Pineapple Investigation Outcome
4
POL00460000
POL00460000

FORM

reviews. From these investigations 10 areas were identified where it was felt PM’s could have
suffered. These 10 areas became the scope of PRR. Included within these 10 areas are two Travel
Money and an ATM issue. In addition, and importantly, the PPR claim form gives PM's the
opportunity to claim for any other area where they have suffered loss and these will be considered
on a case by case basis. The PPR scheme is now in its pilot phase, with full roll out planned prior to
the end of the calendar year.

The final PPR approach and scope was approved at Remediation Committee (which has delegated
authority from the Board) on 20" March 2024.

There were seven further areas to look at based on items regularly being referred to RU. A review is
still ongoing on how such items can be taken forward and a paper will be taken to SEG shortly with
recommendations. This SEG paper will also highlight all claim types referred to RU that fall outside
the scope of the RU schemes so that they are not ignored. In summary, the combination of the ability
to claim for ‘other’ losses on the PPR form and the recommendations going to SEG will aim to give a
mechanism for all PM claims to be considered.

GE/SEG and Remediation Committee / Historical Matters Committee, have been updated regularly
and made decisions as required over the course of the development of the scheme.

Significant improvements have also been made, and continue to be made where possible, to the
policies, processes and the level of support for PM's in raising and having such issues investigated
and resolved. I do believe this demonstrates a commitment to want to provide an improved service
for PM's and mitigate the risk of detriment. There is evidence of policies being regularly reviewed and
updated, improved communication of policies to PM's and ongoing incremental improvements in
processes and tools for PM's in this space including but not limited to: access to process updates and
guidance documents on Horizon Help; Introduction of Branch Hub; simplification of ATM processes
to enable weekly rather than daily reporting and introduction of an ATM shortage button for raising
concerns on Horizon.

It is evident from the above that it is not the case that there has been no action in relation to these
issues in the last two years. However, it is true that whilst communication to PM’s on how to address
outstanding issues is imminent, this has not yet happened. It is also true that Post Office has not
calculated potential losses for PM's, although the catch all nature of the application form into PPR
and the minimum £1.2k payment have been incorporated into the scheme in an attempt to mitigate
this.

The extent of full Board / PM NED updates of the action being taken and opportunity for ongoing
debate on how the outstanding issues are managed /the effectiveness of the updates is questionable
given Elliot and Saf's prevailing views. The pace of scheme development may also be a question,
however has not been reviewed as part of this investigation specifically.

2. Inherent views within the culture of the organisation that PM's are not to be trusted and
"toxic culture’ - including approach to above ATM discrepancies etc as examples

Richard Taylor was referenced specifically by the PM NED's in the meeting with them to discuss the
Pineapple emails. It is acknowledged that comments from Richard were made public that could
undermine confidence in the attitude of Post Office employees towards PM's. Following the
publication of these comments, Richard Taylor left the organisation.

Strictly Private and Confidential: Pineapple Investigation Outcome
5
POL00460000
POL00460000

FORM

No further evidence was found over the course of the investigation of a toxic culture in relation to
inherent views within the organisation that PM's are not to be trusted. This was directly raised with
all members of the Retail Leadership team that were spoken to as part of the investigation and a
consistent view was expressed that the team are focussed on improving engagement and service
into PM's. This is corroborated by process changes, policy updates and engagement activities that
have been evidenced since 2021.

The discussion with Simon Worboys also provided evidence contrary to the view expressed by the
PM NED's. In addition to the improvements to policies and processes relating to PM Support outlined
in response to point 1 above, Simon clearly articulated (without prompting) the responsibility of
himself and his team as being there to support PM’s and explained this meant helping to get to the
bottom of why losses occurred. Simon clearly articulated a perspective that his team are there to
investigate losses themselves and not PM's. He also explained the link from his team back into all
other BAU teams to ensure that trends in issues and concerns resulting in losses were incorporated
into process and training to prevent unnecessary impact across a broader population. Simon
acknowledged the culture of the past and talked about the work he has done with his team to
address and change that.

3. Failure of the business to investigate formal complaints made against Martin Roberts

There have been three separate allegations relating to Martin Roberts that have been raised since he
joined the business. Two of these allegations were dealt with through formal investigation
undertaken by the Speak Up team with investigation reports completed and no evidence found of
any wrongdoing.

A further allegation was raised against Martin by an anonymous reporter as one part of a broad
complaint that highlighted a number of issues into the Chair mid 2023. The reporter raised concerns
about Martin regarding sexism and inappropriate behaviour.

An extraordinary Board meeting was convened 5" July 2023 to discuss this and several other
reports (aligned to the broader content of the anonymous report). There does appear to be some
misunderstanding of the outcome of this meeting. John Bartlett explained during a fact-finding
meeting that the Board had agreed to own the management of the issues raised with regard to
Martin and any other allegations regarding the leadership team. However, an extract of the Board
meeting highlights that the Board agreed to take on management of competency issues only and
were of the expectation that A&Cl would pick up Conduct issues.

Given broader concerns raised in the anonymous report, the Willow investigation was
commissioned, which is ongoing with an external law firm. However, the allegations against Martin
are not covered within the scope of Willow — likely because insufficient information was provided by
the reporter to enable an investigation into the comments relating to Martin as there was no detail of
who was affected or specific examples provided and the reporter made no further contact with the
business to provide such additional information.

I was made aware of the report (without seeing the full content directly) at the time, as part of
regular update sessions with the A&CI team on matters that may require ER input. I agreed the
evidence was insufficient to allow an ER investigation to take place.

The outcome reports available relating to the previous allegations demonstrate that the business
takes such issues seriously and that a thorough investigation was completed where sufficient detail

Strictly Private and Confidential: Pineapple Investigation Outcome
6
POL00460000
POL00460000

FORM

was provided to allow this to happen. These investigations found no evidence of misconduct on
Martin's part.

4. Martin Roberts
a) reference to an investigation regarding inappropriate behaviour and lack of integrity
b) changes to PM accounts regarding postage stamps without their knowledge - Elliot
being on ARC ensured controls strengthened.
c) view that Martin and his team do not want an extension to Saf and Elliot as less
experienced PM's would not be able to challenge

a) As explained above there was insufficient information provided by the reporter to allow for an
investigation. During the meeting with him and Elliot, Saf suggested that he was aware of female
colleagues who had issue with Martin's behaviour. However, he explained that the individuals
were not prepared to come forward and therefore he wasn't able to provide specific examples.

On the back of this, all members of the RLT that were spoken to as part of this investigation
were specifically asked whether they had witnessed inappropriate behaviour on Martin's part,
whether any allegations of inappropriate behaviour by Martin had been reported into them, and
whether they had witnessed any behaviour from Martin that could be deemed to be misconduct.
All responded no. One of his direct reports did suggest that on first joining the business he could
come across as friendly in a manner that some individuals may feel might be too much, e.g.
commenting on physical appearance. However she reiterated that she was not affected by this,
did not feel it was inappropriate and no one else had raised it as a concern.

There is however evidence within the Business engagement survey results showing a
concerningly high reporting of ‘unwanted comments or behaviour’. Listening groups and training
are currently in development to properly understand the type of behaviour or comments that are
concerning and equip colleagues and managers with the tools to deal with this or escalate as
required to prevent further recurrences.

b) The investigation has determined that there was historical practice by the Branch Assurance
Team to manually adjust Horizon accounts whilst in branch to correct the cash value of stock
discrepancies. This was long standing practice within the team.

As part of a broad ‘Stamp Stock project’ the practice was raised and reviewed in August 2020
and it was agreed by the then Head of Loss Prevention, Contracts and Security (latterly the
Director of Service and Support Optimisation — Tim Perkins) that this could continue subject to
specific controls being introduced to ensure PM's had full visibility of any changes and a clear
route to escalate and challenge. Whilst the amendments to practice were discussed on a call
with the wider Assurance team, these controls were never fully implemented through policy /
process and the practice continued unchanged.

The Stamp Stock project was sponsored within the business by Tim Perkins with Al Cameron as
Executive sponsor. The project at this time changed processes in Swindon and Central
Operations to deal with missing pouches. An early version of the Stock tool referenced below
was developed around this time and monitoring was in place within Central Operations to avoid
issues arising in stock discrepancies. It is clear that these processes failed at some point between
there implementation and 2022.

Strictly Private and Confidential: Pineapple Investigation Outcome
7
POL00460000
POL00460000

FORM

Following a £198,000 loss in a Strategic Partner branch in May 2022, a Stock Tactical
Coordination Group (TCG) was set up reporting into the Stock Governance Group, a subset of GE
of which Martin Roberts was a member. The work co-ordinated by this group identified gaps in
Post Office's monitoring processes which, had they been in place, would have identified the
issue in the Strategic Partner branch sooner and may have prevented the discrepancy.

The ‘Stock Tool’ was redeveloped / utilised to analyse nine stock data streams and rank branches
according to risk, identifying branches with suspected instances of manipulation of the stock
figures and signalling potential fraudulent activity. One of the outputs of the TCG identified a
number of branches where the Stock Tool, using data from the previous 2 years, highlighted
‘unusual’ stock transactions in branch. The most significant of these was where stock pouches
had been dispatched from Swindon/the branch but failed to have the appropriate rem into the
branch/receipt into Swindon.

Assurance visits were conducted between August 2022 and May 2023 across 36 branches,
during which the Branch Assurance Advisors used their personal SMART ID (as was common
practice at the time) to adjust the branch Horizon stock values. The cash value of the resulting
stock discrepancy (difference between the updated Horizon balance and actual stock in branch)
was posted to the PM account and PM advised to call the BSC should they want the discrepancy
investigating.

10th May 2023 the PM at Putney escalated a concern regarding this practice into Nick Read. The
issue was also raised at Audit and Risk Committee by Elliot on 16 May 2023. The Putney
complaint was passed on to Pete Marsh who stopped the practice (communicated into the
Branch Assurance team to stop the activity with immediate effect w/c 15" May). An
investigation was then undertaken by David Southall and a report ‘Branch Assurance Visits
Stock Corrections_v2.0 28JUN23' submitted to Pete. Investigations continued, culminating in a
paper to GE dated 24th January 2024 pertaining to Historic Stock Pouch activity.

There is no evidence to suggest that balances were amended by Branch Assurance without the
PM being aware and the transactions were fully auditable as the Branch Assurance team
‘corrected’ transactions using their own Smart ID. However, this practice sat outside of the by
now well established PM Support: Transaction Correction policy and was insufficient in ensuring
that PM's had sufficient understanding and opportunity to challenge the transactions being
amended.

Between May 2023 and January 2024 a full report on the detailed impact by branch was
finalised and presented to SEG. In addition to asking for a decision based on a recommended
approach to resolving the discrepancies, this report explained how the situation had arisen and
confirmed a number of steps that had already been taken to mitigate risk - including a process
change to ensure that all adjustments for ‘missing’ pouches following robust investigation are
now made either through issuing a Transaction Correction or by a registered assistant working in
branch once the reason behind the mismatch is understood and the correcting action agreed. In
both scenarios the branch has an opportunity to review, request further information and (if
required) dispute, whereby an investigation will be undertaken.

A number of updates were provided into Audit and Risk Committee between May 23 and Jan 24.
On 3% July 2023 an update to ARC explained the background to the situation and confirmed the
practice in question had been stopped. 18" September 2023 the update confirmed the
discrepancy value was £2.2m across 36 branches and a paper was being drafted for SEG to

Strictly Private and Confidential: Pineapple Investigation Outcome
8
POL00460000
POL00460000

FORM

confirm next steps. Finally on 6"" November 2023 the update explained that a paper would be
discussed at a forthcoming SEG and presented back to ARC thereafter. The reason for the length
of time before finalising the report back into ARC / SEG has not been addressed within the scope
of this investigation but it is evident that work was ongoing regarding the matter during this
period.

Actions were subsequently implemented as agreed with SEG on 24" January 2024 and a final
update provided by the Central Operations Director (Mel Park) into CoSec on 9" February 2024.
This update confirmed for the Audit and Risk Committee that where agreed, the transactions
had been removed from PM accounts and no recovery sought of the discrepancies arising as a
result of historic pouch activity (in 23 branches). It was also confirmed that an additional 6 cases
were with A&Cl and awaiting outcome from the respective crime authority. This closed the
action that had originally been raised on 16" May.

The above demonstrates that it is not the case as discussed in my meeting with Saf and Elliot on
1** March 2024, that following escalation of this issue nothing had been done. Immediate action
had been taken to stop this activity and the matter had been discussed in the July, September
and November 2023 ARC meetings (albeit the November update provided little evidence of
further progress other than a reference to a paper due to be presented at SEG). A full report had
been presented to SEG on 24" January 2024 with a subsequent update into ARC for the
February 2024 meeting which closed down the open action relating to this.

c) The investigation found no evidence of Martin or members of his team that were spoken to not
wanting an extension to Saf and Elliot's terms as PM NED's or any indication of a concern from
Martin or RLT around the level of challenge from the PM NED's. However, the conversations did
highlight a lack of alignment from members of the Retail Leadership Team of the scope of how
involved the PM NED's should be in Operational activity such as Communications vs the view of
the NED’s themselves. As a result of this, there was a lack of clarity from RLT on what was
expected from them in terms of engagement with the NED's. Most articulated a view that Martin
owned the relationship and caught up with the PM NED’s on a regular basis, bringing updates
and information from those sessions back to the team as relevant. This was supported by Saf
and Elliot who explained they did have quarterly meetings in the diary, but they did also suggest
that these meetings (circa 50%) were often cancelled.

Tracy Marshall in particular articulated a desire to work more closely with the PM NED’s but
explained that Richard Taylor and Nick Read were clear on the distinction between their PM and
NED roles and needing to ensure engagement and involvement in Operational activity was as it
would be for any other Board member. Whilst this may be appropriate given the scope of the
NED role outlined in the PM NED job description, Saf and Elliot had flagged concerns regarding
the level of involvement they expected and if there was not alignment this should have been
addressed with them at the time to prevent the subsequent build-up of frustration and mistrust.

The PM NED job description and appointment letter both clearly articulate expectations of the
role, but are understandably silent on ways of working in practice or how the role should be
implemented and what support this requires from the management population.

Given the apparent lack of alignment around expectations of the PM NED role and how it should
work in practice particularly in relation to PM communication and engagement, a
recommendation of the investigation will be for improved education across the NED’s, Corporate

Strictly Private and Confidential: Pineapple Investigation Outcome
9
POL00460000
POL00460000

FORM

Affairs (Comms) SEG and Retail Leadership teams to ensure alignment of expectations and to
agree ways of working going forward.

In addition to the Pineapple email content, Saf and Elliot explained during my meeting with them that
they were concerned at Martin’s attitude and having him lead the Retail estate. They used examples
such as lack of proactive addressing of discrepancies re ATM's, as well as the stock adjustments and
things like the intention to cancel the PM Survey following the Bates programme because it would
lead to poor feedback. Such examples were put to Martin during a fact finding meeting on 26" June
2024.

With regard the ATM / fake currency and counterfeit issues, Martin demonstrated a lack of
understanding of these issues that is surprising in the context of the volume of activity undertaken in
relation to them and to the ongoing development of the PPR scheme, especially given his role as a
GE member prior to January 2024. In response to being asked about this, Martin stated ‘all a surprise,
nothing in 1:1’s with Nick Read and no conversations have happened’. He explained that ATM issues
sit in Ross Borkett's world and any discrepancies go into BSC and Mel Park.

Martin's understanding of the stock correction activity was also limited despite his position as Chief
Retail Officer (CRO) and him being a member on a GE delegated subcommittee with oversight for
Stock issues. Martin confirmed that Pete Marsh had made the decision to stop the activity within 48
hours of being made aware and had briefed all relevant members of the team as it was
unacceptable. He did also articulate that Mel had led an investigation and that a decision had been
made by SEG to be fair to PM's in how this was handled, which was fully resolved.

Martin denied that there was consideration of cancelling the PM survey. He said that there had been
nervousness in Executive discussions because of the Bates programme but never a discussion to
cancel. However, Tracy Marshall confirmed that there had been discussion about cancelling the
survey and that she and others from within the team had pushed to ensure it went ahead — which
ultimately it did.

No evidence has been found to suggest malicious intent on Martin's part in relation to any of the
concerns raised by Saf and Elliot. Martin expressed a strong desire to support PM’s and described
them as his ‘customer’. This is supported by him being very visible and present in the network over
the course of his tenure and in him setting up regular listening groups to facilitate PM feedback as
well as advocating for initiatives such as ‘Adopt an Area’ to improve senior management
understanding of, and engagement with, PM's. Martin's team also refer to the expectation of the
roles they play as being to support and engage PM's.

However, Martin's lack of understanding of issues important to the PM NED's due to them negatively
impacting PM's, has undermined confidence on the part of the PM NED’s that Post Office are
appropriately dealing with issues. The evident lack of understanding and involvement in such issues
demonstrated by Martin in the fact finding meeting with him is also of concern given his role as CRO
and his prior attendance at GE. Martin has now left the business but had he still been in role a
recommendation of this report would have been to ensure feedback to his line manager and
appropriate intervention.

5. Ben Foat
a) him and members of his team act like PM's are guilty until proven innocent
b) Pushed Phoenix into the long grass
c) Uses his leadership of the Inquiry team as an instrument of his power

Strictly Private and Confidential: Pineapple Investigation Outcome
10
POL00460000
POL00460000

FORM

During the meeting with Saf and Elliot both were clear that the specific allegations relating to Ben
Foat were predominantly the view of Henry Staunton. Prior to our discussion they had sat down and
had a ‘fair discussion’ with Ben and didn't believe he set out to do anything on purpose. They
understood at this point that Ben was not accountable for the Inquiry team (per 5c above) and it was
not therefore possible for this allegation to be correct. They both also confirmed that they had seen
no behaviour from Ben that would constitute misconduct. As such no further investigation was
undertaken specific to Ben and the allegations specific to him e.g. 5a, b, c above, were considered
closed at this point.

The investigation did however seek to address the broader allegations relating to Ben’s team in point
5a above.

A) During the meeting with Saf and Elliot, Elliot articulated concerns with the approach and
impact of an investigation undertaken by A&CI into him / his branches, which led to the view
that PM's are treated by A&CI as if they are guilty until proven innocent.

It is clear from a review of the investigation that some of the approach over email at the start
of the investigation could have been softer on the part of the Senior Investigation Manager.
Whilst not inappropriate and standard in the context of an investigation, the nature of the
communication was particularly stark given that the situation was initially messaged to Elliot
by Henry Staunton and Ben Foat as more of an informal chat to help the team out. The
situation was also exacerbated by the fact that despite being on the Board, Elliot was not
aware of the A&C! team and was understandably concerned at being contacted by someone
with a job title similar to roles linked to past injustices.

Elliot raised the same concerns he discussed with me about the handling of the situation in
the meeting he attended with John and Andy (Senior Investigations Manager) as part of the
investigation. This is evident both in the recording and transcript from the meeting. John was
receptive to this feedback during the meeting and agreed to consider it. Elliot acknowledged
during my discussion with him and Saf that John himself handled things better once he was
involved and referred to him as a ‘nice guy’. It is evident that following Elliot's feedback, John
has fed learnings back into his team.

Given the context of the past and the seriousness of the issues being considered as well as
the initial positioning of how it would be handled by Ben and Henry versus how it was then
handled (according to A&CI documented processes) it is not surprising that Elliot was
impacted and upset by the situation. However, some of the concerns raised by Elliot are not
supported by the evidence available in the well documented investigation file.

The file contains all information relevant to the investigation, including all emails pertaining
to the subject from the point at which the investigation was requested to be undertaken to
its completion. Also in the file are invitation letters, meeting recordings and transcripts, all
evidence found and considered as well as found and disregarded, interim update reports and
final reports and outcome letters.

During my meeting with Elliot and Saf on 1** March 2024, Elliot expressed a concern that his
investigation was common knowledge and that there are people on the Board who think he
stole money. He said he was ‘interrogated like a guilty man’, that our ‘disclosure is wrong’
and ‘comms are wrong’. He explained that it went from Ben Foat contacting him to walk

Strictly Private and Confidential: Pineapple Investigation Outcome
41
POL00460000
POL00460000

FORM

through it, to a letter inviting him to an investigation under PACE and that if he didn't
consent it would escalate. He also said that he did not receive evidence in advance and if he
didn't consent to recording it would lengthen the interview.

The emails between Andy and Elliot and the invitation to the investigation meeting are
contrary to the concerns raised by Elliot. The emails show an initial approach from Andy on
14" March 2023 to Elliot asking for availability to attend a meeting — this first email states
‘Once I have your availability I will contact you again with a firm date and time for the
interview along with advanced interview disclosure’. Elliot responded very quickly and
positively providing a date. Andy responded on 16" March confirming the date and attaching
a letter confirming the invitation to the meeting and the evidence detailed in the investigation
invitation. Elliot responded later the same day acknowledging receipt and asking for
additional information (e.g. please can you supply the 44 page PDF in excel format broken
down by branch so that we can review this in a format that enables us to look at the data
properly’.

Whilst it is the case that Andy pointed Elliot in the direction of the PM Support Team for the
additional information he was asking for, when Elliot challenged this, Andy did liaise with the
team on his behalf in order to provide the information being asked for. There is no evidence
that the A&CI team refused to provide information as they were not legally required to and
there is clear evidence that Elliot did have access to supporting information prior to the
meeting.

The invitation to the investigation meeting dated 15" March 2023 does not reference PACE
and sets out the following statement: “I wish to re-iterate that your attendance at this
investigative meeting is entirely voluntary. If you choose to attend you may, of course,
leave at any time you wish, or you may choose not to answer some or all questions. This
is not an “under caution” interview; it is an opportunity for both you and the investigators
to discuss the three areas identified above in order to increase our understanding of what
has happened.” The letter also offers the right to have legal representation present at the
meeting. There is no suggestion that the situation would escalate if Elliot did not attend the
meeting and this does not support the view put forward by Elliot that PM's are only now
allowed legal representation present as a result of his intervention.

There is no evidence of a suggestion that refusing to consent to the meeting being recorded
would lengthen the process. The invitation to the investigation meeting states “We would
like your permission to audio record the meeting. This is to ensure that we can all give our
full attention to the discussion rather than taking lengthy notes. An audio recording also
provides the best record of a meeting which avoids mistakes or misunderstandings. We
will ensure that you have a copy of the recording as soon as is practicable after the
meeting. Please let Andrew know in advance of the meeting whether you consent to the
audio recording. If you decide that you do not want to have the meeting recorded, we will
arrange for a notetaker to be present. We will ask you to read the note at the conclusion
of the meeting and sign two copies of it - one for you and one for the file — attesting to
the accuracy of the note if you believe it is an accurate record.”

The recording / meeting transcript of the interview does not suggest that Elliot was
‘interrogated like a guilty man’. Comments made by John Bartlett and Andy Morley over the
course of the meeting include:

Strictly Private and Confidential: Pineapple Investigation Outcome
12
POL00460000
POL00460000

FORM

“JB: I want to put it out there that we are not accusing you of anything. You are free to
leave at any time you want. There’s none of that stuff from the past.

AM: Yeah, perfect. So, thank you and thanks John. So, as John said, the whole purpose of
this is to get your side of, there's always two sides to every story, to get your side of the
story and that’s what we are really interested in today. We are approaching this with an
open mind, we absolutely want to hear what you have got to say and if at times you're
looking at the top of my head, it’s because I'm taking notes, I am listening to you,
honestly.

JB: We might make some recommendations like I say around training is certainly one of
those that we would talk about and clearer communications for all concerned but we then
step out. So, what we are not is judge, jury and executioner. So, in some organisations
and here, previously, what the Investigation Team decided, happened. We don’t do that.
We try and establish fact as much as we can be or, at least, the different positions of the
parties involved and where there is commonality, we flesh that out, where there is
difference, we flesh that out. We make recommendations and then we step out.”

There is clear evidence that Elliot was offered the opportunity to respond in full to questions
asked and was encouraged to provide additional information supporting his case. When
asked by John Bartlett whether Elliot was happy with the way the meeting was conducted,
Elliot responded: “Yeah. I think it’s been okay. I guess, is there anything else you need in
terms of the gap in communication within the areas of improvement on the side of the
Post Office that you'd like to get from me at this point?”

There is also evidence that the investigation fully considered all available information and
took a balanced view, contrary to the assertion that PM's are considered guilty by the team.
This is exemplified in section 9 of the interim investigation update report which highlights
the need to consider that Elliot is not legally qualified and did not have access to legal advice
relating to the question as to whether UOE debt should have been disclosed prior to Elliot
signing the remuneration form declaration. I do not believe that an investigation seeking to
reinforce a position of guilt would have put forward such considerations.

There was one document reviewed within the investigation file entitled ‘Combined Strategy
Elliot Jacobs’ that raised a concern due to a header that referred to ‘Suspect(s) / Target(s) /
Respondent(s). This is a planning tool used within the team to document the approach to the
investigation. This was put to John Bartlett during a fact finding meeting on 6" August as
using words such as Suspect or Target in the context of Post Office's history and in relation
to the role of the A&CI team is inappropriate. John was surprised by the reference,
understood the implications of using such terminology and stated that this should have been
sanitised as the team do not use this language. John explained that this must have been
missed when updating template documentation that had been adapted from use in a
previous organisation.

Having reviewed all documentation relating to the investigation carried out by A&CI, I do not
believe there are issues with the communication or disclosure process.

B) It is not the case that the business, Ben or any member of Ben's team ‘pushed Phoenix into
the long grass’. The lack of effective update and communication into Board understandably

Strictly Private and Confidential: Pineapple Investigation Outcome
13
POL00460000
POL00460000

FORM

resulted in frustration and suspicion as to why the activity wasn't progressing, but there is no
evidence to suggest an intentional delay in progressing the project.

It was clear on speaking with Saf and Elliot as well as broader Senior stakeholders within the
business who were aware of both the Phoenix and Past Roles activities, that there was a
lack of understanding of both and that the two separate pieces of work had been conflated.
As a member of the Phoenix Steering Committee and having recently become more involved
in the Past Roles review, I was able to articulate some of this during the meeting with the PM
NED's and committed to clarifying the activities and providing more regular updates — which
has since been delivered.

There was a delay in setting up Phoenix initially whilst funding was secured to recruit
independent reviewers with the capability and experience to undertake PM case reviews —
and as part of this deal sensitively with the victims of past injustice. Access to relevant
documentation, recordings and relevant information to the cases has at times been
challenging, and across the cases needing to be reviewed, documents that were available
totalled more than 95,000.

The full scope of activity, size, complexity and volume of work involved in Phoenix had not
been fully articulated to or understood by Board until recently and the potential employment
risks in dealing with matters that at face value seem simple in the preferred manner for the
PM NED's had also not been fully explained.

The Board are now regularly updated and able to contribute to the approach taken in relation
to this and other relevant matters.

6. Stephen Bradshaw
- went into one of Saf's stores years ago and said we are closing you down - PM's tell
him not much has changed

This matter falls within the scope of a separate ongoing employment process and as such will not be
addressed here.

7. 48 investigators employed within the business, just like Stephen Bradshaw, expectation
that the business parts ways with all such employees

This is factually incorrect and is a symptom of ineffective updates into the Board and the
confounding of the Past Roles and Phoenix activities. There are not 48 investigators employed within
the business. Stephen Bradshaw and any other current employee that previously undertook the role
of Investigator or Investigations Manager in the context of historical prosecutions, no longer work in
such roles.

The Board are now regularly updated and able to contribute to the approach taken in relation to this
and other relevant matters.

8. Generous sick leave - no similar benefits to PM's, how are we accepting so many people
drawing sick benefits, especially in HR

PM's are self-employed franchisees and as such do not receive employee benefits.

Strictly Private and Confidential: Pineapple Investigation Outcome
14
POL00460000
POL00460000

FORM

The sick leave entitlements within Post Office are rooted in the Collective Agreements with Unite
and CWU. A recent benchmarking exercise highlighted that the sick entitlements at Post Office are
similar to those offered in many other Public Sector organisations including British Transport Police
(same entitlements), NHS (same entitlements but after 5 years service) and Royal Mail (same
entitlement but after 12 months completed service).

An amendment to the collective agreements with Unite and CWU was successfully negotiated in the
2023 pay agreement, which removed eligibility to Company sick entitlements until 6 months service
has been completed. This mitigated the impact of new starters having day one rights to six months
full pay. However, the entitlements are custom and practice and valued by the Union who are
unlikely to engage positively in discussions to amend them, particularly in light of the enhancements
expected to employment rights under the new Labour government. It is however noted that SLP
grades are not covered within the scope of the collective agreements and so the opportunity to
review benefits at this level is more achievable.

Average public sector absence rates are 3.6% and private sector 2.3%. Across Post Office the
average rate of absence was 3.9% in the last financial year. This rose steadily — predominantly as a
result of long term sickness — over the course of 2023 culminating in a spike of 5.12% in December.
This has steadily decreased and remained consistent around an average of 3.8% since. Absence is a
focus of the Employee Relations and People Partnering teams who are working closely together and
with Line Managers to resolve long term cases, ensure reporting and management of all absences
and early intervention to mitigate long periods out of the business. A number of complex long term
sick cases have been successfully resolved over recent months as a result of this.

Whilst HR has been specifically called out by the PM NED's, absence was highest in the last financial
year in the Retail function (as would be expected given the nature of the DMB and Supply Chain
workforce) at 4.29%, followed by LCASR at 3.52% and then People at 3.08%. It is true that across
the People function there were a number of absences due to work related stress / mental health
particularly across Senior Members of the team. This likely resulted from the impact of the churn in
Chief People Officers with 5 in less than 3 years in addition to the pressure on the team in managing
for long periods with no leadership and with a structure that was not equipped to manage the
significant demands of the business. Since joining the business Karen McEwan has rectified a
number of these issues, which has resulted in a corresponding drop in the absence rate across
People, reducing steadily since February 2024 to 2.89% as of July 2024. Additionally, all long term
sick cases in higher grades of the People function have been successfully resolved.

9. Phoenix - should have been dealt with by now and is taking too long
Findings in relation to this are contained within section 5C above.

10. Lack of engagement by the PM Engagement team with the NEDs - we are sidelined and
rarely consulted by the PM Engagement team on anything.

Findings relating to this are contained within section 4C above.

Summary

There is a consistent theme of lack of effective communication and updates into the Board sufficient
for Saf and Elliot to fully understand some of the issues raised, how they are being handled and in
some instances why things have taken so long.

Strictly Private and Confidential: Pineapple Investigation Outcome
15
POL00460000
POL00460000

FORM

Based on this investigation I do not believe there is a toxic culture towards PM's still prevalent within
Post Office or that there is an intentional attempt from current employees to prevent the PM NED’s
from having access to relevant information. However, I can understand why some of the situations
outlined by Elliot and Saf could be perceived in this way and the recommendations will address the
need to improve flow of information to the Board as well as clarify the scope of the PM NED role
including what is appropriate in terms of engagement outside of the Board with subsequent
engagement on this to all relevant stakeholders.

RECOMMENDATIONS

It is suggested that a single accountable owner be appointed to ensure appropriate action is taken in
line with the recommendations below. As the concerns were raised initially from the PM NED's,
CoSec may be best placed to do this. Any variation from the below for valid business reasons once
reviewed by relevant stakeholders, should be agreed by Neil Brocklehurst (in lieu of Owen Woodley
who commissioned the investigation but has now left the business).

1. CoSec/ CP /Dan O'Mahoney - by end of Dec - to review TOR and flow of information from
Remediation Committee into main Board to ensure sufficient updates into all Board
members, including PM NED's, of relevant activities and decisions taken in the delegated
forum. Findings and outputs from this activity should be fed into a broader governance
review ensuring the same quality of information into Board from other relevant
subcommittees.

2. Simon Recaldin or delegate by end of November - to provide a verbal update and written
summary into PM NED'’s on the remit and timing of the PPR scheme as well as latest update
following the pilot. Conversation should elicit feedback on how to ensure PM's engage in the
scheme and a view on any broader outstanding concerns or aspects of potential historical
PM detriment that may not be covered within its current scope.

3. Simon Recaldin or delegate by end of October - Agreement to be reached on the role of PM
NED's in supporting the communication and engagement with the PPR scheme with PM's in
advance of full scheme roll out.

4. CoSec — by end of November — review reporting into Board re all Remediation schemes to
ensure a summary if not already available is provided by RU going forward on applications
into each scheme / disputes outstanding / claims raised against PPR and resolutions etc

5. CoSec to run a session involving all relevant stakeholders including those outlined here by
end of November - Education and expectation setting regarding the PM NED role with the
NED's, Corporate Affairs (Comms), SEG, Head of People Partnering and Retail Leadership
teams to agree appropriate means and regularity of engagement aligned to expected
outputs of the PM NED role. As an output agreed ways of working should be documented
and communicated.

6. Dan O'Mahoney / Kayleigh Tague / John Bartlett - By end of October - Review of A&CI job
titles and job descriptions to mitigate any impact of correlations with past Post Office
practices.

7. Dan O'Mahoney /John Bartlett - Review of all A&C templates to ensure language in
templates is appropriate given the context of Post Office (this is a check following a piece of
work that has already been undertaken to ensure nothing was inadvertently missed)

8. lan Rudkin by end of December - Provide benchmarking to Board of Sickness entitlements
across Public and Private sector organisations. Review the opportunity to reduce sick pay
entitlements including a risk and benefits analysis.

Strictly Private and Confidential: Pineapple Investigation Outcome
16
POL00460000
POL00460000

FORM

9. Tim Perkins by end of December - Include Sickness Absence reporting on a Board
dashboard along with a clear action plan for resolving the volume of high long term sick
occurrences particularly in senior populations.

10. Group Assurance to undertake a review of network monitoring process in partnership with
Central Operations by end of December 2024 (if a report is not already available) to ensure

no opportunity for failure of monitoring processes such as led to the stock discrepancy /
pouch issues experienced through 2022.

Strictly Private and Confidential: Pineapple Investigation Outcome
7