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Item 2.1.1.1 Postmaster Polices - Appendices
@
GROUP POLICIES
Postmaster Complaint
Handling Policy
Version - V0.6.2
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Item 2.1.1.1 Postmaster Polices - Appendices
. Definitions ....
. Introduction by the Policy Owner
. Purpose.
. Core Principles ...
. Application....
. The Risk ..
. Risk Appetite...
. Policy Framework ....
. Who must comply?
. Roles and Responsibilities
» Minimum Control Standards
. How to Report a Complaint ....
. Escalating a Complaint
. Whistleblowing ...
. Control Framework (controls reporting risks and process)
. Reporting ...
. Closing a case....
. Additional Policies ....
. How to raise a concern...
. Who to contact for more information
. Governance Responsibilities
Definitions...
Overview ....
Dana
7
Risk Appetite and Minimum Control Standards
Procedures...
Where to go for help
Governance
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7. Control ..
7.1. Policy Version...
7.2. Policy Approval...
Company Details
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Definitions
1.1. Definitions
1.
Complaint - any oral or written statement of dissatisfaction, whether justified or
not, from, or on behalf of, a Postmaster (whether a limited company, a partnership,
a limited liability partnership or an individual) about the provision of, or failure to
provide, a product, process or service from Post Office, or the way that Post Office
interacts with the Postmaster.
Complaint Handler - any Employee of Post Office that is in a position to receive
a Complaint from a Postmaster in accordance with one of the Complaint reporting
channels set out at paragraph 4.1 of this Policy.
Employee - an individual who has entered into or works under (or, where the
employment has ceased, worked under) a contract of employment or any other
relevant contract, as defined in sections 230(2) and (3) of the Employment Rights
Act 1996, with Post Office or the Group or is defined as a “worker” under section
43K Employment Rights Act 1996.
Postmaster - this refers to a limited company, partnership, limited liability
partnership or individual that contracts with the Post Office in its or their capacity
as a postmaster in the network, or assistants of such postmasters.
Post Office and Group - Post Office Limited and any wholly owned subsidiary that
formally adopts this Policy.
RCC - this refers to Post Office Risk and Compliance Committee.
Service Level (SL) - the length of time that the Post Office expects that it will
take to acknowledge and resolve a Complaint that has been formally raised.
Whistleblowing - the act of a person or, in the case of a postmaster that is a
limited company, partnership. or limited liability partnership, entity (the
“Whistleblower") making a disclosure that the Whistleblower reasonably believes
is (a) in the public interest, and (b) regarding past, present or likely future
wrongdoing that falls into one or more of the following categories:
« criminal offences (this may include types of financial impropriety such as fraud)
« failure to comply with an obligation set out in law (including regulatory
breaches)
* miscarriages of justice
* endangering of someone’s health and safety
« damage to the environment
* covering up wrongdoing in the above categories
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* a breach of the Post Office’s policies and procedures
« behaviour that harms or is likely to harm the reputation or financial well-being
of the Post Office
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2. Overview
2.1. Introduction by the Policy Owner
The Service and Support Optimisation Director has overall accountability to the Board of
Directors for the design and implementation of controls to manage Complaints received
from Postmasters as defined in this Policy.
This policy is a non-contractual document provided for information. It does not form part
of the contract between Postmasters and Post Office.
2.2. Purpose
This Policy has been established to set the minimum operating standards relating to the
management of Postmaster Complaints.
Post Office recognises that Complaints will occur and this Policy lays out the formal
Complaints procedure which is intended to ensure that Post Office handle all Postmaster
Complaints consistently, fairly and within agreed timescales.
It is one of a set of policies which provide a clear risk and governance framework and
facilitate an effective system of internal controls for the management of risk across Post
Office. Compliance with these policies is essential to Post Office in meeting its business
objectives and to balance the needs of our Postmasters, clients, and other stakeholders
including our shareholder.
2.3. Core Principles
Post Office will seek to resolve all Postmaster Complaints with fairness, transparency, and
professionalism (being the underpinning behaviours of Post Office).
Post Office has an obligation to its stakeholders, clients and Postmasters, to understand,
address, resolve and provide insight on Postmaster Complaints. This Policy sets out clear
and consistent guidelines to encourage Postmasters to raise issues with Post Office, and
to ensure that:
* astandard and consistent process is followed for all Postmaster Complaints.
* the prompt reporting of any Postmaster concerns is encouraged and Post Office will
take Complaints raised seriously and investigate as appropriate.
« Post Office will monitor and endeavour to adhere to SLs, and keep the Postmaster
informed, with a reason and regular updates, if there is an indication that SLs may
be exceeded.
* Post Office will analyse Complaints data to surface common and/or recurring issues
and themes and address them collectively where necessary and improve our
business operations.
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* Post Office will use Complaints data, and seek feedback on Postmaster satisfaction,
to constantly improve our Postmaster experience.
* Post Office will produce information on the volume of Complaints and Post Office’s
performance agains SLs and publish this both internally and to Postmasters on a
regular basis.
* Postmaster Complaints data is regularly reviewed at the Risk and Compliance
Committee.
It is vital that the procedures followed in managing Complaints are as clear as possible to
ensure a fair, transparent, robust and consistent process for all concerned.
2.4. Application
This Policy is for use by Complaint Handlers in relation to Complaints raised by
Postmasters, as defined in this Policy, and outlines the manner in which Post Office will
encourage, receive and manage Postmaster Complaints.
2.5. The Risk
Complaints should be taken seriously and managed effectively. Complaints are a good
source of feedback about how Post Office can improve. If a mistake has been made, it
should be resolved effectively, as soon as possible and the root cause surfaced and
addressed to prevent recurrence. Complaints that are not raised, addressed and resolved
can lead to Postmaster dissatisfaction, the inability of a Postmaster to operate effectively
and the failure of Post Office to meet legal and regulatory requirements.
The risks in this area include:
« _ If Postmasters are discouraged to raise and pursue Complaints, their issues will be
unknown to Post Office and remain unresolved.
« If Post Office do not provide suitable channels for Complaint raising, Postmasters
will not be encouraged to share their Complaints.
+ If Post Office Employees are not aware of the guidelines and principles set out to
deal with Postmaster Complaints, Postmasters may suffer an inconsistent service.
* If Whistleblowing reports are not recognised and reported to the Whistleblowing
team, the Postmaster may not be offered protections in accordance with the
Whistleblowing Policy.
« If Postmaster Complaints are not understood and investigated as appropriate, the
root cause may not be addressed and the same Complaints could recur, leading to
Postmaster dissatisfaction.
* If Post Office do not take reasonable steps to achieve resolution within reasonable
timescales, there is a risk that Postmasters may not be able to operate effectively.
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« If Post Office are unable or unwilling to recognise consistent thematic issues
Postmasters will suffer recurring issues and Post Office will forfeit opportunities to
address common Complaint issues.
« If Post Office are not transparent with performance against SLs applied to the
Complaint handling process, Postmasters and stakeholders may lose faith in Post
Office's abillity to effectively manage Complaints.
« Non adherence to this Policy could result in financial loss, legal and regulatory risk,
detriment to Postmasters and reputational damage to Post Office.
Section 3.5 sets out the minimum control standards that the Post Office has implemented
to control these risks.
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3. Risk Appetite and Minimum Control
Standards
3.1. Risk Appetite
Risk appetite is the extent to which the Post Office will accept that a risk might happen in
pursuit of day to day business transactions. It therefore defines the boundaries of activity
and levels of exposure that Post Office is willing and able to tolerate. Post Office takes its
legal and regulatory responsibilities seriously and consequently has:
+ Averse risk appetite to corporate non-compliance with legal and statutory
obligations.
* Averse risk appetite for taking risks which might result in failure to maintain the
service commitment in respect of customers in line with our social purpose and
Government's policy on subsidy
« Averse risk appetite for financial crime to occur within any part of the
organisation.
« Averse risk appetite associated to the health, safety and wellbeing of POL
customers and colleagues in everything we do.
¢ Averse risk appetite in relation to unethical behaviour by Post Office staff.
+ Cautious risk appetite to litigation.
« Cautious risk appetite for inefficient or ineffective processes that result in: lost
time, duplicated effort, and increased risk of financial loss or errors in any part of
its business or core processes
« Neutral risk appetite for dissatisfaction related to BAU services recognising that
in a complex business there will be a level of dissatisfaction as part of the normal
course of business of achieving our commercial objectives.
* Flexible risk appetite to lose the engagement of any key stakeholder in the
process and for staying the course in face of opposition if in the wider interests of
the business and its commercial priorities.
The Post Office acknowledges, however, that in certain scenarios, even after extensive
controls have been implemented, a process may still sit outside the agreed Risk Appetite.
In this situation, a risk exception waiver will be required pursuant to the Exemption
Process.
3.2. Policy Framework
This Policy is part of a framework of Postmaster policies that has been established to set
the minimum operating standards relating to the management of our postmaster contract
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risks throughout the business in line with Post Office’s risk appetite. The framework
includes the following policies:
* Postmaster Onboarding
* Postmaster Training
* Postmaster Contractual Performance
« Postmaster Suspension
* Postmaster Termination
* Postmaster Termination Decision Review
* Network Monitoring and Audit Support
« Network Cash and Stock Management
* Network Transaction Correction
« Postmaster Account Support
* Postmaster Accounting Dispute Resolution
« Postmaster Complaint Handling (this Policy)
The Postmaster Complaint Handling policy should be considered and read in conjuction
with the Whistleblowing Policy should a Complaint be identified as a potential
Whistleblowing report.
3.3. Who must comply?
Compliance with this Policy is mandatory for Complaint Handlers, as defined in this Policy. .
Where non-compliance by a Complaint Handler is identified, an investigation will be carried
out. Where it is identified that an instance of non-compliance is caused through wilful
disregard or negligence, this may be treated as a disciplinary offence.
3.4. Roles and Responsibilities
« Risk and Compliance Committee - should:
o Review all Postmaster Complaint themes on a regular basis as part of the
RCC agenda.
* Service and Support Optimisation Director - is the Policy owner.
*« Issue Resolution Team Manager - is accountable for the deployment of this
Policy and the support of the team that manage Postmaster Complaints. This role
also has the responsibility for regular review of the effectiveness of this Policy and
for drafting any amendments that may be required.
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The Issue Resolution Team Manager will lead a team of Issue Resolution Support
Advisors in carrying out thorough and effective investigations to resolve any
Complaints raised.
« Issue Resolution Support Advisors and all Complaint Handlers - should:
°
°
be fully conversant with this Policy and linked policies;
ensure that the Complaint is acknowledged when received;
record and log all details of the Complaint promptly and accurately;
take reasonable steps to ascertain all the facts and detail of the Complaint;
where necessary, seek open and transparent dialogue with the Postmaster
to further understand the Complaint;
identify Whistleblowing reports and pass these on to the Whistleblowing
team whilst respecting the confidentiality of the Whistleblower in accordance
with and subject to any exceptions in the Whistleblowing Policy and
Procedures;
act with integrity at all times;
ensure the Postmaster is kept up to date if SLs are likely to be exceeded ;
own and monitor the progress of any investigation carried out by internal
departments and third parties;
resolve the Complaint within agreed timescales and inform the Postmaster
accordingly;
keep records of all material discussions with a Postmaster and other internal
departments in the pursuit of information and resolution of a Complaint;
update case records regularly, and detail Complaint resolutions when the
Complaint case is closed;
* Service & Support Insights Manager- should:
°
°
understand the requirements of the business to create useful reports for
both an internal and Postmaster audience;
explore and interrogate the data to surface thematic and recurring detail
« Whistleblowing Manager- should:
°
ensure that any Complaints that are passed to the Whistleblowing team are
dealt with in accordance with the Whistleblowing Policy;
communicate regularly with the Issue Resolution Team Manager to ensure
that all Complaints that are Whistleblowing reports are identified
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3.5. Minimum Control Standards
A minimum control standard is an activity which must be in place in order to manage the risks, so they remain within the defi ned Risk
Appetite statements. There must be mechanisms in place within each business unit to demonstrate compliance. The minimum co ntrol
standards can cover a range of control types, i.e. directive, detective, corrective and preventive which are required to ensu re 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 minimum control standards in consideration of the stated
risk appetite. The subsequent pages define the terms used in greater detail:
Risk Area
Description of Risk
Minimum Control Standards
Postmaster ease
of raising
Complaints
If Postmasters are
discouraged to raise and
pursue Complaints, their
issues will be unknown to
Post Office and remain
unresolved.
If Post Office do not
provide suitable channels
for Complaint raising,
Postmasters will not be
encouraged to share their
Complaints.
Communication with Postmasters at all
levels should encourage the reporting of
issues and Complaints.
Post Office will regularly review channels
available to Postmasters for the raising of
Complaints.
Postmaster facing teams will take
reasonable steps to identify Postmaster
dissatisfaction which is expressed during
their contact with Postmasters and offer
the Postmaster the opportunity to raise a
formal Complaint.
Training of this
Policy and
If Post Office Employees
are not aware of the
Training to cover the principles and
minimum standards relating to
Who is When
responsible
Postmaster facing At every
teams interaction
Quarterly
Head of Service and
Support
Optimisation
At every
Postmaster facing interaction
team managers
Head of Service and
Support Annually
Optimisation
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procedures for guidelines and principles Postmaster Complaints will be rolled out
handling set out to deal with across all teams that could receive one.
Complaints Postmaster Complaints,
Postmasters may suffer
an inconsistent service.
Receipt and If Whistleblowing « All Complaint Handlers will undertake a I Learning and Annually
identification of incidents are not training and awareness programme, so I Development with
Whistleblowing recognised and reported that they are aware of the Whistleblowing I input from the Head
reports to the Whistleblowing Policy and procedure. of Financial Crime
team, there is a risk that
the most serious « Regular case reviews of Complaints that Whistleblowing Monthly
Complaints may not be have/have not been identified as Officer and Issue
investigated and resolved Whistleblowing reports to ensure Resolution Team
as a priority. consistency and continued understanding I Manager
of the triage guidelines.
Investigation and I If Postmaster Complaints I * Knowledge based articles and processes Issue Resolution Quarterly
resolution of are not fully understood will be rolled out through training and Team Manager
Complaints and investigated, the root reviewed regularly.
cause may not be
addressed and the same * Quality checks and training will take place I Issue Resolution Monthly as
Complaints could recur, with Complaint Handlers to ensure that Team Manager standard and
leading to Postmaster all information is gathered, and the weekly by
and branch correct process is followed. exception
dissatisfaction.
* Complaint SLAs will be regularly reviewed I Issue Resolution Daily
If Post Office do not take by the Complaint Handler and spot Team Manager and
reasonable steps to checked by the Issue Resolution Team Complaint Handlers
achieve resolution within Manager. Any risk to SL will be notified to
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reasonable timescales,
there is a risk that
Postmasters and
branches may not be able
to operate effectively.
the Postmaster in advance and flagged to
the Issue Resolution Team Manager.
Any Complaints that are unable to be
resolved will be escalated for review.
At each
occurrence
Issue Resolution
Team Manager
Reporting and
Insights
If Post Office are unable
or unwilling to recognise
consistent thematic
issues Postmasters and
branches will suffer
recurring issues and Post
Office will forfeit
opportunities to address
common Complaint
issues.
If Post Office are not
transparent with
performance against SLs
applied to the Complaint
handling process,
Postmasters and
branches and
stakeholders may lose
faith in Post Office’s
ability to effectively
manage Complaints.
Complaint handling reporting dashboards
will be maintained and updated to show
volumes, channels, SLs, subjects and
resolution of Complaints
Interrogation of Complaints data will be
undertaken to identify themes that could
surface common Complaint issues.
Common and recurring issues will be
escalated to the Voice of the Postmaster
meeting for awareness and discussion
with the aim of establishing overarching
solutions.
Postmasters will be provided with regular
updates on the number of Complaints
raised by Postmasters, key issues raised
and what Post Office are doing if they
haven't been resolved.
Service and Support I Weekly
Insights Manager
Issue Resolution Weekly
Team Manager
Voice of the Monthly
Postmaster meeting
Service and Support I Monthly
Insights Manager
and Issue
Resolution Team
Manager
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Policy non-
adherence
Non adherence to the
Policy could result in
financial loss, legal and
regulatory risk, detriment
to Postmasters and
branches and
reputational damage to
Post Office.
The Policy will be rolled out in training to
Issue Resolution Support Advisors and
wider Complaint Handler teams, with
regular refresher sessions.
The Issue Resolution Team Manager is
accountable for ensuring they and their
team adhere to the Policy.
The Policy should be reviewed, and if
necessary updated regularly.
Issue Resolution
Team Manager
Issue Resolution
Team Manager
Issue Resolution
Team Manager
Once approved
and annually
thereafter
Daily
Annually
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4. Procedures
4.1. How to Report a Complaint
Post Office is committed to finding more ways to listen to Postmasters and supports a
number of Complaint reporting channels. The main channels for Complaint raising are:
Branch Hub
In order to provide a consistent way for Postmasters to voice any concerns, Branch Hub
is the preferred channel to use as it can be accessed at any time, from anywhere. The
Complaint will be logged on the case management tool, acknowledged within 24 hours by
email and a member of the Complaint Handling team will take ownership of investigation
and resolution.
Area Managers
Area Managers are able to receive Complaints from Postmasters in their area and will
resolve these where possible. They will be logged onto the Branch Visit form and
transferred to the case management tool by the Complaint Handling team.
Branch Support Centre
Postmasters can telephone the Branch Support Centre with a Complaint and a Branch
Support Advisor will take ownership of the Complaint and escalate to the Complaint
Handling team where necessary.
Unexpressed. Complaints
Post Office support teams will take reasonable steps to identify Postmaster dissatisfaction
which is expressed during their contact with Postmasters and offer the Postmaster the
opportunity to raise a formal Complaint.
4.2. Escalating a Complaint
Complaints that require escalation
If the Complaint Handler is unable to resolve a Complaint, or believes they will be unable
to resolve it, the Complaint should be escalated to the Issue Resolution Team Manager
for review. They will either advise the Complaint Handler or take ownership of the
resolution.
A Complaint can be directed to the relevant Group Policy Owner for an investigation
under the Investigations Policy if it meets a certain risk threshold. The Investigations
Policy lists a number of “Persuasive Factors” in favour of an investigation, one of which is
Postmaster Complaints relating to a material, frequently arising or systemic issue. The
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risk assessment that should be conducted in relation to such Complaints is discussed
further in the Investigations Policy.
Please refer to the Investigations Policy for further information regarding the referral of a
Complaint for an investigation and also for contact details of the Group Policy Owners.
Postmasters disputing the Complaint resolution
When a Postmaster contacts Post Office to dispute a resolution to an original Complaint,
this will be escalated to the Issue Resolution Team Manager to review and provide a
response.
4.3. Whistleblowing
Difference between Complaints and Whistleblowing
A Complaint, as defined in this Policy, is about something that affects the Postmaster
(whether a limited company, a partnership, a limited liability partnership or an individual)
or the branch. For example, if deliveries are not picked up on time. However, if reporting
the wrongdoing is in the public interest then it could fall under the definition of
Whistleblowing, as defined in this Policy.
Whistleblowing disclosures can have certain protections that Complaints do not. Therefore,
it is important to identify which type of report is being made from the outset.
The Whistleblowing Policy should be consulted before a report is made or sent to another
team by the Complaint Handler.
In order to assist in identifying whether a report is a Complaint or Whistleblowing , please
see the examples below. Further examples of events which may lead to a Whistleblowing
disclosure are set out in the Whistleblowing Policy.
Whistleblowing
Complaint
A Postmaster’s assistant has seen card
payments processed with someone else’s
card and with no customer present.
A Postmaster complains that their card
machine does not work, and that no
replacement has been sent.
A Postmaster’s assistant notices that
customers ID is not being checked where
required and the customer is handing
over cash as a personal payment for
processing the transactions.
A newly hired Postmaster’s assistant
forgets to ask the customer for their ID.
A Postmaster’s assistant believes that the
Postmaster is using personal customer
information to set up fraudulent accounts.
A Postmaster complains that they do not
understand how to process a customer's
Savings account application and that Post
Office training has not been provided on
this.
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Whistleblowing Complaint
A Postmaster’s assistant complains that A Postmaster’s assistant complains that
racist/discriminatory remarks are made to I they feel they are being bullied by the
other members of staff and members of Postmaster.
the public.
Any Complaints received that are triaged and found to be Whistleblowing reports will be
forwarded to the Whistleblowing Team immediately in accordance with the Whistleblowing
Policy and Procedures, and with confidentiality protected subject to any exceptions set out
in the Whistleblowing Policy.
For more details as to where and how to make Whistleblowing reports, please refer to the
Whistleblowing Policy.
4.4. Control Framework (controls reporting risks and process)
Self-assessment controls are in place around the risk descriptions and these must be
adhered to.
4.5. Reporting
Regular and accurate reporting is required to give information about Complaints to both
Post Office internal functions and Postmasters.
Reporting on Complaints should include, at a minimum:
Number of Complaints received over a variety of timescales
Complaints via channel
SL data against target - minimum, maximum, average and outliers
Resolution types
General themes of Complaint types
Identification of recurring themes and issues
Detailed information contained within different themes, where required
Repeat Complaints from the same Postmaster
Insights to inform Post Office improvements based on Postmaster feedback
4.6. Closing a case
Post Office will close a Complaint case if the Postmaster is in agreement. However, in the
absence of an agreement, or otherwise, the case can be closed at the discretion of the
Post Office.
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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 Policies.
5.2. How to raise a concern
Any Postmaster (whether a limited company, partnership, limited liability partnership or
an individual) or any Post Office Employee who suspects that there is a breach of this
Policy should report this without any undue delay.
If the Postmaster is 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, you can
bring it to Post Office’s attention independently of management and you can use the
Whistleblowing channels for this purpose. You can raise your 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 your concerns, please refer to the current
Whistleblowing Policy which can be found on The Hub under Post Office Key Policies ,
accessed here.
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 polit i ind Support Optimisation Director, Tim Perkins, by
emailing! GRO I
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6. Governance
6.1. Governance Responsibilities
The Policy sponsor, responsible for overseeing this Policy is the Retail and Franchise
Network Director of Post Office Limited.
The Policy owner is the Service and Support Optimisation Director who is responsible for
ensuring that the Issue Resolution Team Manager conducts an annual review of this Policy
and tests compliance across the Post Office. Additionally, the Service and Support
Optimisation Director and the Issue Resolution Team Manager and their team are
responsible for providing appropriate and timely reporting to the Risk and Compliance
Committee.
The Audit and Risk Committee are responsible for approving the Policy and overseeing
compliance.
The Board is responsible for setting the Post Office's risk appetite.
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7. Control
7.1. Policy Version
Date Version Updated by I Change Details
22" January 2021 I 0.1 Jo Milton Draft Version
22° January 2021 I 0.2 Tim Perkins Initial review
25 January 2021 I 0.3 Jo Milton Minor revisions to draft
1% February 2021 I 0.4 Jo Milton Additional risk added on training. Additional
principle. Footnote to define postmasters in
this policy. Minor text corrections.
25" February 0.5 Jo Milton New principles about case closure and
2021 postmaster satisfaction added to 2.3.
Postmaster Policy list updated.
8% March 2021 0.6 Jo Milton Amended risk appetite statements.
9 and 19" March I 0.6.1 and I Jo Milton Amendments following operational review.
2021 0.6.2
7.2. Policy Approval
Oversight Committee: Risk and Compliance Committee and Audit and Risk Committee
Committee Date Approved
POL R&CC 16‘ March 2021
POL ARC
Policy Sponsor: Retail and Franchise Network Director
Policy Owner: Service and Support Optimisation Director
Policy Author: Senior Operational Improvement Manager
Next review: 31 MAR 2022
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UKGI00044333
UKGI00044333
Item 2.1.1.1 Postmaster Polices - Appendices
Company Details
Post Office Limited and Post Office Management Services Limited are registered in England and Wales. Registered numbers
2154540 and 08459718 respectively. Registered Office: Finsbury Dials, 20 Finsbury Street, London EC2Y 9AQ.
Post Office Management Services Limited is authorised and regulated by the Financial Conduct Authority (FCA), FRN 630318. Its
Information Commissioners Office registration number is ZAO90585.
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.
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