WBON0000517 - WBD Note Client: Post Office LimitedMatter: Horizon IT System-Group Action

Evidence on official site

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WOMBLE
BOND
DICKINSON

Note

Client: Post Office Limited

Matter: Horizon IT System-Group Action Matter no: — 364065.1369
Attending:

Name: Mandy Robertson Location: Bristol Date: 15 January 2018
Start time: Units:

Interview for Post Office Witnesses

Person speaking

Victoria Brooks I thought if we just quickly introduce ourselves. So I am Victoria Brooks and I
am a Managing Paralegal at Womble Bond Dickinson and as you know I have
been working on the mediation scheme stuff before this but I have been with
Womble Bond Dickinson or before it in other guises for quite a long time and
been doing Post Office work on and off for all of that time.

Mandy Robertson I am Mandy Robertson and I am a Solicitor who works with Victoria and am
here today to support her and take some notes.

Angela Van-Den- lam Angela Van-Den-Bogerd. I am [@]Director with Post Office and I have

Bogerd — 42.4 been with Post Office for coming up to 33 years.

Victoria Brooks Wow. I just thought it would be helpful if I explained the purpose of the

meeting and see if you have got any questions.

Angela Yes, fine.

Victoria Brooks So why we want to meet with you today is to take a proof of evidence that a
sort of pre-cursor to a witness statement it is supposed to be a warts and all
document so we want to know about all of the good and all of the bad and this
is obviously so that we know where there might be any weaknesses in the
case and so we can advise Post Office about that. We want you to give us as
much detail as possible — on the other hand what we do want is your evidence
and not somebody elses. So if there is something you are not sure about and
you think we should speak to somebody else, if its second hand, please let us
know so we can follow that up rather than put your name against something
that isn't really you. What we are quite interested in as well is three time
periods pre Horizon — so before 2000 from the instruction of Horizon onwards
so 2000 onwards and on the introduction of the NC Contract. What we are

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going to do when we have done the notes of this meeting — so it won't be such
a polished document as you would expect for a witness statement. It is going
to be much more a record of what was said and we will send it to you to have a
look at just to check that you agree that what we have put is what you actually
said and that we didn't get the wrong end of the stick and we might have some
questions and then that will be a document that we will ask you to sign and
then ultimately that document will be the starting point for a witness statement
if we need witness evidence from you and I imagine we will.

Angela That's fine.

Victoria So that is basically what we are doing today. Okay?

Angela Yes.

Victoria So if we kick off. What I wanted to ask you about first, you have just told us

your current job title but could you tell us more about what jobs you have done
in the past. Your history at Post Office.

Angela Okay. So I started working for Post Office on 1 April 1985 and I started
working as a branch counter assistant as part of the directly managed
networks and I have always been employed by Post Office on an employment
contract. I spent about a year or two working in the branch and then worked
through the management structure in the DMB network so branch manager
and then area manager looking after a number of DMB branches and then
extended into the agency network. I probably went into the agency network
probably about 94ish and then did a number of....so I was managing the
network and I was responsible for DMB's in the Cardiff area and then about
300 agency branches as well across an extension outside Cardiff. We had
more branches in those days. Then I moved into managing Wales as a
Country so I was responsible for all the branches in Wales from every angle.
In those days we used to do our own recruitment of house masters — now it is
centralised but we used to do it in regions then, so I used to be responsible for
interviewing postmaster, appointing postmaster, managing the contract with
them and exiting and everything else in between, obviously depending on the
situation. I then moved into a number of the changed programmes wherein we
were compulsory closing Post Offices — I was involved in that. I was also part
of —I can give you my CV actually as it might be easier at some point.

Victoria That would be really helpful.

Angela ..-but just to give you a sense of what I have done, so I have managed the
training and audit team, I managed the teams that closed, maintained post
offices, dealt with the relocation and refurbishment of Post Offices and I was
also responsible for the contract team. So when we did moving to a more
centralised approach I took control of that team as well and I have been in and
out of those teams for a number of years so they have not always been a part
of my remit but I have always stayed very close. So thinking about time lines,
so when JFSA first came on the radar I was in a network programme. I think I
was head of network services at the time and therefore I was responsible for
the whole audit training function, contract function and that was when I got
involved because we had some contractual issues that I needed to get
involved in so whilst it was still a part of Royal Mail so I dealt with what would
have been the previous Post Office/Royal Mail lawyers on this as well as that is
going back probably about seven years ago.

Victoria Okay

Angela And then after that I moved into...what did I do next? That's right I went on to
become head of partnerships and I was responsible for the relationship with

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both Unions. Trade Unions which is Unite for Managers....specifically for
Employees and also the Federation of Post Masters which is the representing
body that we recognise on behalf of agents. I was responsible for that
relationship and pay negotiation: ind stuff. Then I went int What did I
do after that? Then the JFSA became more involved and I got involved in the
working group setting that up. At that point I stepped out of the head of
partnership role and I became Programme Director for the Branch Support
Programme which was whilst I was leading the investigations I went into the
mediation schemes into the investigations into those cases. We had 150 come
into the mediation scheme. I set up a team then of 20 Post Office investigators
to investigate those claims and write the reports which is where I obviously had
6.55 some involvement before. So Kath Alexander, Shirley [e], those were the girls
I recruited on the team. Some of which have come back to work for us as you
know in terms of reservation team as well.

Victoria Yes.

Angela And then I stepped into the back off role so I became the Director of Support
Services and I was responsible for NVSC — PoEx as it was then which was our
customer helpline. What else was I responsible for? The final service centre,
that would come under my remit as well as HOSC. I still kept the contract at
that point so the contract admin team to John Braden, Lynn Aubrey and Craig
Tussell was still in there- they worked for me. Then I moved into this role then
which meant I kept HOSC, I didn't keep the FSC or NVSC but then I moved
into HR so I do a HR Director role and I am responsible for Health and Safety
and I also manage the Training Portfolio across the organisation as well. So
that was a quick walk through 33 years. (Laughing) —I can give you my CV as
that would give you the best timeline.

Victoria That would be really helpful as that would give us the various dates for which
bit was happening when so that would be really helpful.

Angela So basically, I have always been close to the operation which is why I know
what happens in branches and obviously from your timeline I was involved
when we...so I used to operate the manual system myself when we were doing
pencils, rubbers and paper. I did that and then when we introduced Horizon
the first time around I was involved in supporting the agents and actually going
out in to the branch when it was in that very difficult transition period where
they just did....um, some of them just couldn't cope with the transition from
manually to...so I would be in the branch supporting them. So I have a very
hands on knowledge of how that branch works from you know the Horizon
system and then Horizon on line and then subsequently as well. So what
might get me a little bit today is some of the dates and stuff because I haven't
done this for a while now but clearly I have given the number of — so my name
will be on a number of documents you have used so all the information used in
the mediation scheme — I do the select committee which you are probably
aware of so some of this for me, I would need to refresh my memory because I
have not been....when the mediation scheme was at its height then you could
have asked me anything and I would have had the answer straight away but I
have slightly stepped back so I would need to re-visit some of my...to put in
back in order again because you know, I download and I put more stuff in my
head and you know.

Victoria It is not supposed to be a memory test with you so we can check the
documents match.

Angela Yes — but there is a number of stuff on record for me anyway is what I am
saying already.

Victoria That's great, so what we will do — I mean when it comes to being more of a

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formal witness statement that is when we will bring more of that in but we may
well bring that in to this document as well if there are gaps that need to be filled
that would be a good way of doing it. Good, brilliant.

One of the things we have been asking people just because it is normal to put
it in a witness statement is "Did you do anything before all of that experience —
what was your background at that point and what qualifications did you have
and that sort of thing.

Angela I did 'A’ Levels and I was taking a year out and I was going to Uni- I hada
Place in Newcastle actually to do teacher training and my father was a {i

man all his life and the: GR IHR lived close and just said "We are recruiting
for the summer — so how would you like to come and work with us". So I joined
and decided to stay. So that was at the ‘A’ level stage and then, you know, this
is a very good organisation to work with so I was sponsored to do an NVA and
NCIPD as well and it is a great place to be actually and we do get invested in,
providing we put the effort in of course.

Victoria Yes, I have spoken to lots of people and lots of people seem to have been
here a long time and that is a very strong message I am getting so that is really
nice.

Angela Yes.

Victoria One question I wanted to ask you is about where you have been based in a lot

of different roles. Have you always been based in Swansea or...

Angela So I have always lived in Swansea — I am field based so I travel. I travel the
Country so depending on the height of my network roles I was very usable in
the network so I would be in Scotland, Northern Ireland, Penzance and
everywhere else in between.

Victoria Okay, and who do you. This is not really a good question for you but who do
you work with primarily but over that time that would take all day to answer so I
think I will have to ask you that in the context of...

Angela Do you mean colleagues?
Victoria It is probably better to cover that when we go through the questions I think.
Angela As we go through then do you want me to tell you the people I worked with at

the time. Would that be helpful?

Victoria Yes, I think that would be helpful and we can also pick that up in connection
with the CV as well at first.

Angela Well there won't be any names on there so if I tell you as I go along.

Victoria Okay, that would be really helpful.

So the first section I wanted to ask you about is to do with Post Masters and
what contact and support they have with Post Office during their on-going
relationship while they are still current.

Angela You mean now, cos obviously...

Victoria Over those three time periods.

Angela Okay, so what is the first time period then, where do you want me to start?
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Victoria So the first time period is pre Horizon.

Angela Okay. So, again this will all be documented in other documents you have got
okay. So pre Horizon, so... I have had to work back. At the moment most of
our functions is centralised. Back in those days we were very much region
based and we were[n't] in control from the centre which is where we are today
so. With that, there is a plus and a minus in that because as a region you can
get very, very close to your Post Masters and the people you work with and at
that time I was probably working across both, the DMB's plus the Post Masters.
But also the downside of that is potentially there is lack of consistency of how
policies and procedures are applied and I am not saying that they do not reach
the minimum standard in terms but what you will get is some variances around
people going the extra mile and having a different approach. So I can talk from
my experiences obviously and I can give some insight into how I understood
other areas worked as well. So pre Horizon in the areas I worked which would
be in Wales predominantly it was, uh..we had a number of what we call cluster
offices so Bridgend, Carmarthen, Newport and we had a team of I think they
were called....the name has changed a number of times, at one point we were
14.12 called [@]managers, we were called business development managers, we were
called retail line manager but all of those names were pretty much the same so
we basically, for want of a better word, account managed a number of
branches. We were responsible for a number of branches and as I said we
were responsible then for practically the whole life cycle of the Post Master and
therefore we got very close to the Post Masters actually. So part of the role of
the RLM, RNM and BDM would be an annual visiting cycle that we would be in
branches say once a quarter okay so we did actually get very, very close. We
knew our branches very, very well which is quite different to today okay. You
know when you centralise things and you try to work in a more technologically
and savvy way then that kind of contact does disappear to a certain extent.

Not always, but it does and what you tend to get close to people that have
problems okay which predominantly are a number that.....Well particularly in
the mediation scheme, the ones that we saw in the mediation scheme are the
ones that had problems. What we are seeing now is the number of Claimants
in Class Action now which is probably around 590ish now isn't it. A number of
those are first time on the radar so these are people we have not had any
experience of before because the way Freeths have gone out and tried to drum
up the trade and the way they have asked very open questions, then you

know, these people have never raised their hands and we would have
no....and actually you could argue that they have not actually had problems as
such but if you ask the question "Have you ever suffered a loss and have been
asked by Post Office to make good", every Post Master would say yes
because that is the contract that we operate under. Okay, so that is the

difference.

Victoria Okay.

Angela So the level of support, so what happened, and the training offer —I will start
with the training offer if that is okay?

Victoria Yes that is fine.

Angela Right, the training offer has changed over the years. Always with a view of

improving the level of support that we give Post Masters and that does not
necessarily mean the amount of time that we give them but it is about the
quality of the training and actually how that training is received and is it
sustainable or not. So effectively, is our Post Master equipped to take the role
and to do the role that we have asked them to do well enough, okay. Because
it is a lot of responsibility and that is something that Post Masters sometimes
don't, before they become Post Masters realise is, just how much money they
will be responsible for and actually how if they are not careful and they do not

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adhere to the training and the guidance that we give them how easily they
could get themselves into difficulty. What I mean by difficulty is they could start
to make errors, they could start to make losses and because those losses are
as a result of their actions or their staffs’ actions they are liable under the
contract we have with them. So my personal experience of interviewing Post
Masters particularly...em I could show you as I have got an old contract here.
There are a number of areas in the contract I would always call out in an
interview and those would be... I would almost frighten Post Masters to death
actually just to make sure they really knew what they were getting themselves
into so that they could not come back to me and say "You never told me that"
and that would be things around the key contracts, and I forget the sections
now because I....but I would have been able to quote these at the time to them
and I used to have in there — in the contract post it notes down and these are
the sections that I am going to call out and at one point I had a note like this
(demonstrating to Victoria) and one of them would be "You are expressly
forbidden to use Post Office cash for anything other than Post Office", and
even if you know the bread man comes in and you have got a bill to pay, you
do not take that out of Post Office tills because as soon as you do that you
breach your contract. So these are the things I used to really call out and used
to make sure that they understood they are liable for losses but actually always
pointed them to what in that day would have been the regionalised helpline,
before it went centralised. So they understood what their support mechanism
was there and stressed on them the importance of attending the training and
making sure that they were properly in the room because typically when a Post
Master is coming in to take on the business it is not just about them stepping
into a business, they very often would be moving house at the same time.
Okay. A lot of them bought premises and they lived above, yes. So very often
there was a lot going on at the same time so they had a commercial
transaction which is they are buying a business and they also had a domestic
transaction where they would be moving home and we know that moving home
is one of the top stressful things. Then they were having to learn how to do a
different role in the Post Office and this is what we were interested in and then
they were also looking at how/if they were going into retail. If they were going
into a convenience store as well, to take all of them on this is a lot for them to
get their heads around and I always stressed to them that what that entailed
and actually offered some suggestions on how they would want to organise
themselves. You know, having worked in a branch I was quite easily able to
tell them how the little things are the really important things. So I always
remember when I came in to whichever role it was at the time, I will say
[branch manager] for ease, I went into a branch one day just to do my visit and
help and ask if he had any problems, and the Master was in at that time and he
said ...-head off and I said well tell me what the problem is and he
said "Well it is this, 1 don't know how to do this." So I said "I'll show you." So I
went on and was able to sort it and he said "Wow, you know what you are
talking about" and then he was different so I had that relationship with Post
Masters because I had been there, done that and got the T shirt and knew how
to work it really, really well because as a branch manager when we brought
Horizon into that branch, I was the one that knew everything and I was the one
that when they balanced (and we balanced weekly in those days) it was £1,000
short I was the one that was able to show them how to.....because there is a
way of looking for mistakes so I was, particularly in those days, very, very
skilled from experience of being able to do that which was very useful. So the
relationship we had was regionalised and we worked in areas and we knew our
Post Masters very well and they used to contact us if there any problems. So
they had had their training and the training in those days, there was a point at
which we only did two weeks so when I would come in to that which was
probably the 1995 we were doing just onsite training and actually I did not tell
you but I was a trainer at one point as well because when I was working in the
branch I forgot that I used to go out and train Post Masters myself before it
became Horizon because it was manual in those days. So it was two weeks

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on site and once I was able to stress to them...particularly if they had been or

id experience in the Post Office before they would go "Oh I don't need
"No, you need training — take the opportunity to have the training"
actually used to make it a condition of the appointment that they attend the
training course.

Victoria Why would you say to them that they needed the training even though it
worked?
Angela Because, because things change and actually the way we....our training

approach was always to look to make improvements to the training and always
to make sure that they had the opportunity to ask the questions because
different branches have different transactions. Every branch...there were a
number of products that were generic okay so back in those days we had
about 170 products and services and probably about 150 were generic so
things like car tax and passport checking were generic — they were the larger
branches but dependent on the type of branch and where that branch was
located, they very often would not be exposed to every transaction.

Victoria Yes.

Angela It just depends on the customer base. So when they go into a different branch
there might be transactions that they have never come across before. So for
me it was always important, it was always important for a refresh and what I
would say to them is if you don't think you need the training then bring your
wife or whoever else there might be. And wherever I could, so say we set a
training school up for like ten people, if there only eight people on there I would
offer those spaces to their assistants and things which we were not
contractually obliged to do but if we had the space I wanted them to take the
opportunity to get training. So there was the two weeks on site training in
those days. The trainer would be with them all of the time and it was on the job
training. There was nothing done in advance, okay? Then we moved into a
weeks' training course and then I think, but I might need to check this, it might
have kept two weeks at the time but it kind of transitioned into whatever we do
whether we do the different times. So it was always a week or so then it went
5 days and then 8 days.

Victoria And that was classroom training?

Angela Classroom training and then....but always on site. We have never removed
the onsite training. We might have varied the number of days depending on
the model and I will come on to that when we talk specifically around the new
models which were the mains and local but what we did do is we varied the
training to the model because the local model had a smaller product suite than
the mains and therefore it wasn't relevant.

Victoria Okay.

Angela So we did tweak them as we went along. So we have over that period of
time...and can I suggest we check the time but we had two weeks on site
training only then we moved to classroom training in advance of going on site
training. Then lastly we moved to online training as precursor to going into the
classroom to going into the onsite. And that was something I brought in...and
I forget the date but it was February (I don't know what date it was I can't
remember now) about five or six years ago maybe, but you have the dates
there Victoria so we need to check. That was whilst I was doing the mediation
scheme actually so what I was doing is I was investigating cases, looking for
ways that we could improve, right. So there were a number of things I was
doing during the investigation, one was did we breach our contract in any way,
did we fall short of the standards that we said we would give in terms of

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training support and barring the odd little issue in a number...you know, a few
cases, I was very comfortable that we had not. But what I was very keen to do
is as I am getting so close to branches and I mean really under the skin of their
experience over the years and we have not done that really before, which was
my view, then I wanted to look to see what the learnings were that I could take
and weaving to our future approach. So that is what I did. To parallel which is
what we have been talking to Gayle about because Gail was the programme
manager working for me and running the branch support programme and she
had people like Ann, Ann was working with her on there, Kendra would have
been working on some stuff...

Victoria And Alleka?

Angela And Alleka...yes was working. So if I remember correctly, Gayle was running
that and Alleka came in and did a lot of work with Gayle on that for me and
then Gayle went on maternity leave and then I got Craig to set it up and come
in to work with that. When Gayle came back from maternity leave she came
back on to that (she is on her first child now...no second child sorry). Then
afterwards she came to work for me then as she became the head of Branch
26.43 and Customer Support which is all [@] so you know, Gayle worked on and off
with me over a number of years. Sorry to come back to the training, so that is
how it is involved okay. The online training was very much about, so if you
think of it from a learning perspective, because what I recognised over the
years is that it is a lot to take in which is why I really made it important and
stressed the importance to the people coming in that they needed to spend this
time doing that. Because one of the things that did concern me and this is a
conversation that I have had with a number of people is "Oh it's okay, I have
got experienced staff and I am keeping the staff". You are responsible, you
have a contract with us and not your staff members and you are responsible
for their actions. So that is fine now, you might have experienced staff but
what if they all left you tomorrow, what would you do, because you are
responsible for training your staff members as well. So there was always that
conversation and part of my observation as I got close to the mediation cases,
and I saw in a number of cases where Post Masters come in and they got
trained and were very good at the start and then they became very reliant on
their staff members and they started to take their foot off the pedal in terms of
their involvement and they trusted their staff members. Then if their staff
members left or did something they were not close enough to be able to see
what they were doing so in some places then they got caught for a large
amount of money either through theft in some cases that we know has
happened, or errors or actually you know, just carelessness because they were
not close enough. You know, and that was one of the things again I used to
stress to people is you know, you might be good today but how do you know
they are good if you are not close enough. You are responsible, even if you do
not spend any time serving on the counter, you have to do that cash count, you
have to because it is your name that is going on that and you need to be sure
that when you make that declaration that you are comfortable it is happening.
Okay, so that pretty much has covered the training bit, but if you want to come
back to that further that is fine?

Victoria What we will do, I will check whether we have covered all of the questions on
training but it is really helpful that you tell it how you see it and then we can
...questions.

Angela The thing is....because I have been involved so much I tend to drift into
different things.

Victoria That is fine.

Angela If you need to pull me back, pull me back.

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Victoria I will do but I think what is quite helpful is at least for this first action if you tell
us these things and then I can go through the questions and pick up anything
that we have not actualh but it is really interesting and really helpful just
what you are telling us so...

Angela Okay, so that is probably about ten years into my career here then. So that
was very reassuring. So at the point at which, I think it was when Horizon
came in that we started to centralise things okay. So particularly the helpline.
So...and it is NBSC which is Network Business Support Centre but always
known as NBSC but some of our Claimants would give them different names
and there has obviously been some you know very rude names used...but
hey...that is fine. Em...so it became centralised, I forget the date but you have
30.00 it and it will be around...it was before we went to the [@]Horizon so it would
have been 97 ish if I remember okay. Em...I think we bought the first lot of
automation in about 95 I think, didn't we?

Victoria I'm not sure.

Angela = 30.12 95/97 and then it was [elby 2000 okay but again you have the dates so don't
quote my dates on that one.

Victoria Yes, that is fine we can check that.

Angela Em...so that was centralised and it was quite a difficult time actually for us in

the Network because we were used to having our Post Masters ring us and we
then had to say to them "No" you have to ring...you know, they would ring me
and say "Ang, I have got a problem, what is the answer" and I would say
“Look, I know the answer and I will tell you the answer but you have to ring the
helpline next time". And the reason you have to ring the helpline is the way we
set this up is we record the calls in terms of we log the calls going in and we
know what the queries are and what it allows us to do is to look at a national
level whether there are particular things that are not just one offs. So we can
do some trend analysis and we can see from that whether, you know, if we
brought a new product in for instance and we were having a large number of
calls like what type of calls. Does that mean that the training has not landed
properly. Does it mean that the product design is something not quite right. It
allowed us to do that forensic analysis and the root cause analysis on why. So
it was...and that was quite difficult because...they would...well not make life
difficult for me but would say "If you know the answer, just tell me". So that
was a transition that needed to happen so it was quite difficult at the time. So
we centralised the helpline and at the time at which we introduced Horizon and
what we did...and I am going to talk....because I was in Bridgend at the time
and Kath Alexander worked for me actually as BDM and people like Judith
Aubrey in the business worked with me.

Victoria Judith?

Angela Aubrey. You would not have come across her because she was in a different
role.

Victoria Okay.

Angela She was part of...there were about six or eight of us in that group. So there

was a nationwide roll out of Horizon em...I'm sorry I talk very quickly don't I?

Victoria You do (laughs). We are recording it anyway.

Angela You are doing very well. That's just being Welsh, we do talk fast. Yes so,
there was a nationwide roll out of Horizon okay and I forget what the beat rate

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was in terms of how many but it was quite...so imagine around the Country we
were doing probably as of now and that was the number we would be doing
every week because it was very coordinated. And em...so what we decided to
do in Bridgend...and I know we did this in Newport and Carmarthen...em...we
took a view that we would pool our resources okay. So there were a number of
people over there but we had different skill sets and we had come from
different backgrounds and there people like myself and Kath and Judith who
had come to the branch network and we were very good and hands on. So
what we decided to do is we would have a central coordinator in the office who
would field the calls from our Post Masters and the branches that were being
trained on Horizon would do that in the evening, which you will have seen I
was involved in as well, but we do support them in the network. So, when the
system got installed we were on site to make sure everything was okay with
them and then when they came to their balance we went out to support them
okay, and I have been there are 2 or 3 o'clock in the morning in some places
because it was very new and if they had not.....even in a manual situation
there is a certain order of where you do things to balance at the end of the
week okay and it is not just about the day you balance, it is about how you
build up to that. I remember going to a branch once, it was not one of my
branches, it was one of my colleagues. It was a chap called Keith Richards
and he actually became heavily involved in the federation, ........ beneath the
office quite close to here. So the guy had asked me, Ange he is new he has
been trained would you mind just keeping close on his balance. I said yeah
okay no problem so I rang up to look and the high manager balancing I will pop
in and see how you are doing. So I got there about 3 o'clock on a Wednesday.
He said oh you're a bit early, I said well its 3 o'clock but we don’t close until half
past 5. I said I know I just want to see how you're progressing. So they had
done nothing to this balance so I went right okay, I know you don't close until
half past 5 but there is a way you do this and I showed them how you got very
organised behind the scenes. So we did this and this and this. There are 3
positions and you close that position and close that position, you are left with
one position and you balance this so when it comes to help decide you have
only got this much to do which you balance by 6 o'clock and if you are not
balancing you have got time to look. It is quite interesting even now as in the
last couple of years, whenever I met him and his wife Linda at said conference
he always says to me, you were a revelation she said because had you not
told us that we would have still even today been there at midnight balancing
because we didn’t know the order we needed to work in. so these are the little
tips of the trade that gets people to be very organised. So if they were very
organised in the manual world and you go into Horizon so what they needed to
get their heads around was there is an order in which you have to do things.
So this computer is an addition to their transaction flow, you came into
something say pension book, I would take the pension book, I would open it, I
would look how much, I would stamp it, I would give you the money and I
would count it out. All of a sudden I had to put stuff into the machine, so there
is an order to this and we would say to them, train them, you would take your
book, you would scan it but then we didn’t need to input it. you put it into the
machine and then you take your directions from the machine because you
have to tell the machine that you have now given the cash and you have
completed you that transaction which is an error where some people started to
make some mistakes, so you have seen Horizon screen have you?

Victoria I think so.

Angela So it's a bit like that, got a screen but what it does is.. so whatever the
transaction is you have say a customer basket which we call a stack so it
would say that I have sold 5 first class stamps and I have paid out a pension, I
have done a car tax and then it would give me a balance, it would say take
from customer £20 or give to customer £20 when you do that then you end the
customer session and then it zeroes and then you start the next customer.

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Now what some people were doing which is what I found particular when I did
the mediation work is they were forgetting to zero the balance.

Victoria Ah okay

Angela It was particularly important when it says give to customer, okay so I have just
given you £200 and you have gone what I have not recognised is I have got
give to customer £200 on my stack and the next customer comes in and I
should give you £200, I have put £200 in to my stack and now it tells me to
give customer £400.

Victoria Oh I understand

Angela So I have given you £400 and now im £200 short. There is one particular case
of the mediation scheme, it was a case called Regoss which is not too far from
here. He was doing that and he actually admitted to me that was what he was
doing and because of the value of the transactions that can add up quite
quickly so you could be £1000 short in a week no problem at all.

Victoria That was what I was going to ask how could he know or you know that that
was happening if at all?

Angela You wouldn't know?

Victoria You would just have to look at the transactions and work out he must of done.

Angela Yes unless they realise at some point

Victoria So that would be a situation where Horizon would say one figure but the cash

would be less.

Angela Yes so Horizon is only as good as what you put into it and what you tell it to do
and whether that be manually entering something or scanning something.
However we get the information into the system it is what we tell it to do. So it
can do no more than that. So this is always the difficult thing where you are
having a conversation with post master when they say im £10,000 short Ange
and I swear I havent taken the money because there are only so many places
it can go and the one of the most difficult cases is themselves, if its themselves
operating there they know they havent taken it but they don't realise that they
are making mistakes. There was another example, wasn't in the mediation
scheme, on the back of the mediation scheme I used to get a lot of queries
coming my way so if anyone wrote into Paula, chief exec it would come to me.
Ange can you look at this please and there was one particular case come in a
few years back, he was a long standing post master and he had been involved
in and out of the federation was known to Paula, senior management. He
dropped in on Paula one day and said Paula, I have been a post master for
however many years and I am a very experienced person, I always balance
but I am £2,000 short. It has to be the Horizon system. She pinged it to me and
asked me to have a look. So I think it must have been Gail or Kath who looked
at the case for me. Anyway we had a chat with the guy and we pull all the
transaction information because if its thousands we kind of look for the big
transactions, £1000, £2,000 there is a way of holing in. so now we are down to
Saturday morning where it was most likely and looking at this chap on CCTV
and he had a CCTV that actually overlooked the counter so you could see the
screens, you could see everything, fantastic. I wish they all had that and they
narrowed it down so it was about 11 o'clock, there was a transaction we're not
comfortable with so we looked at this transaction, we can see the post master
himself serving the customer, so the customer comes in and he was giving all
the nice chat and that, customer comes in to deposit £1,000 into their bank
account, all clear on the screen you can see that. Post master is chatting to
him does the transaction. He processes it as withdrawal.

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Victoria Right

Angela The customer comes in to give £1,000 and he processes it, so rather than
taking the £1,000 he gives them £1000 but the system is now £2,000 short
because he processes it as a deposit but he had given it out so he had done it
the wrong way round, he had already gone through a deposit but didn’t take
the money and he gave a £1000 out so he was £2,000 short.

Victoria It was Gail who looked at that because she talked about that in less detail
actually.
Angela So it was Gail then, I couldn't remember. But the interesting thing in all of this

and this is the very interesting thing in all of this even though that was on
CCTV and he kind of went oh dear, yes I can see. Had we not had that CCTV
he would never have believed he would have done something like that. So in
the situations where we don’t have someone with CCTV how do you convince
them that that is a plausible explanation to why they are short that's always the
tricky thing in all of this and when I speak to post masters and I have a number
of very difficult conversations with them, they would call and say... my number
will be out there if you have a problem call Angela and I would be talking to
them and say there are only so many ways and I would go through their
checking process with them and say so what did you do to check?, what did
you do to validate? I would be giving them tips and say look just try this for
me? They would say no no you're wrong. I would say just humour me, can you
make sure every day you actually count your cash to the penny and then every
day you will see what you have as a discrepancy or not and by doing it every
day you will then either remember the transactions better or you will be on top
of it. if you leave it for a week or the month which is where we are now you are
required to balance every month. It's very hard to do that and they do that and
then the losses would stop. Then they go oh losses have stopped, so they stop
doing the daily timesheet. Im like no you are missing the point. So the reason
the losses have stopped is either because you are giving yourself better, you
know concentrate better to detail or actually if you do have a problem with your
staff members they will now know that you are on top of this and checking
things every day so there is less opportunity for it to be lost. Sorry I digressed
again but it's a bit of colour around.

Victoria This is exactly the sort of things we want actually, just some context.

Mandy Things with like human error as well, so if they put in an £2,000 withdrawal and
they accidently put in £2 the system would just show that £2 was withdrawn
even though...

Angela Absolutely, so there are some classic examples in there which is that exactly
that so somebody comes in with £100 and you put £1000 into the machine and
what we have tried to do over the years and this again, you have probably
seen this document. I have produced a document but I dropped it into Rod. It
was basically how you mitigate things. So I took all the lessons ive learnt and
said this is what you need to do going forward and it was about 50 odd pages
long and then I started to push them out to business owners, these are the
things that you need to put into your processes.

Victoria — 44.26 ‘So was that maybe eight years ago

Angela Well I have been out of this a couple of years but yes I resurrected it with Kath
the other day and what has happened over the last couple of years which is
why I put this on your radar didn’t I things have changed. So we have now got
change of personnel so the chap who has stepped into the network services
role when I left, a chap called Drew McBride has left and we the person we
have got taking over now is a lady called Pam Heath. Jude has just gone to

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work for her actually and I have been working very closely and I have sent
Judith the document. These are lessons learnt, these are the improvements I
made to how we operated, these are the things that we need to make sure are
still in place and if not we need to put them back in place. I am doing a piece of
work which I have given to Jane on this around media and assessment of what
we have got there today. Just to understand because I had a very strong view
on what we could do to improve and in doing that and this is important and im
not saying what we were doing was wrong but what im saying is my head
always goes to how I can improve things. Its understanding what the route
cause was of a particular issue but actually how we could make it better and
again how we could take as much as possible of the human element out of the
transaction so how do we automate. Wherever you have human interaction in
a process there is always the room for error and we will never be able to
remove that but we can reduce that as much as we possibly can. That's what I
have been working on. The stuff I have been working on it seemed really
important to do that. So I have gone off the script completely, take me back to
where you want me to be.

Victoria No no it's really helpful actually. We started off by talking about the contact that
post masters had with Post Office and I did have questions about the BDM and
the R&M roles. Maybe we could talk a little bit more about that and what they
did because it would be good to have an explanation as to what they did over
time so that we can have some more colour like you have been giving us.

Angela Would it be helpful if you had some old job descriptions for those roles?
Victoria Yes it would that would be really helpful

Angela — I will have a scan. Im thinking that might be helpful. So it’s the R&Ms the RLM,
47.20 EDMs. So even though the name changed the new ?? was because we went

through the structures and we needed to change it to make it better but very
often it was slight difference. So the essence of the role was really about
account managing the branches to make them as viable as possible for post
master and for us clearly because this is always about partnership now this is
the part I suppose the inconsistence gets and you can see this is some of the
claims that would come through is that there will be talk about very much an us
and them scenario of how much command and control of a parent/child in a
number of cases and that wasn’t actually just one way. In a lot of cases it was
both ways because you probably see that a number of post masters think that
they are employees of Post Office but clearly they are not.

Victoria That is something else I wanted to talk to you about

Angela Obviously that the issue and the states of the contract and all the stuff we were
working on anyway but my view has always been that it's about partnership
and they are franchisees and I was always very keen to make sure that they
realised they are a franchisee and I am here to help you help yourself to make
a really good business and my levels are slightly wider than some of my
colleagues across the country. They probably didn’t realise how different it was
until I start reading some of the cases because I obviously had a very national
perspective from that. I took a very strong interest in how the retail was
operating because the retail is about the whole viability, it was clearly why we
have actually come today because if there is a reason they were struggling it
would be putting pressure on the Post Office and having been around a very
long time if I walk into a branch I instantly know if there is a problem in the
branch by just how it is organised, whether there is not enough stock on the
shelves, just get a feel for.. The profit margin isn’t as good as it should be or
there is something not quite right, it is just one of those things you get when
you have been around a long time. This was why it was important for me to be
in and out of branches a lot which is probably one of the downsides actually
from where we are today if we are not in and out of branches quite as much

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you don’t get that...

Victoria When did that change come in? Was it around the time of MT contracts?

Angela It's been a gradual change in approach. As technology has become more
advanced. To have a field resource and default to a support model that face to
face is a very costing model and as our contracts got squeezed with clients
and our margins got squeezed and obviously what we pay post masters got
squeezed as well. We have to be able to look to our central cost base and how
we reduce that so that is always an ongoing challenge in terms of how we do
that. There are ways about how you work smarter and having the centralised
50.32 2? helps because I said earlier if you can analysis the information that you are
getting you can take a more holistic view of where the touch points are and
what punch points are and how you can make those improvements. I think that
is very important and that’s something we continue to do today. We are putting
in new systems now. Gail is acting on the case management system that goes
into support contact centres which means we can get better information which
means that we can look at what that’s telling us and we can actually be more
proactive in what support we are giving.

Victoria I understand it's going to be across more of the business.

Angela It will join FSC, HSC it will join all of it.

Victoria What was the name of it again? Is it dynamics?

Angela Yes dynamics, yes Microsoft dynamics which is the system behind it, not

technical but just the system behind the stuff. What it allows you to do and
workflow which means that whereas now if a query comes in from a post
master into the contact centre they then have to say okay we will get back to
you, they can just automatically flow it through and that person knows that
we've got it. so it's much slicker and quicker. It's a huge improvement for us/
unfortunately things take a while to implement, you know, obviously public
procurement takes us a while as you will appreciate so we can't operate as
quickly as we like and then this is complex stuff actually you know, to make
sure that you are thinking up front and make sure you get the right output. It
takes a while and then you have got to implement it. so those roles are pretty
much the same thing so it was really around how do you encourage the post
master to sell as much as they can in terms of product so they obviously
generate more income for themselves. How do you make sure they do it in the
right way? that it is compliant with all the regulations and everything else but
also it is around the premises they operate out of so they own the premises.
We have a contract with them and they have to provide.. they have to keep
them in a certain order. Do they have the right to operate? Do they have the
right liability insurance? Broad piece that we would look at at that time.
Victoria As part of that role what would happen if they noticed that there was a problem
in the branch or that they didn’t seem to know what they were doing?

Angela The roles transitioned more and there was a period of time where we were
quite sales focused and that probably came in around 2004 because.. sorry
another role I didn’t mention I wanted to become Head of Sales for the multiple
branches in about 2004 and it was very much.. that was when we entered into
the joint venture with Bank of Ireland at the time and it was about how we
introduce these products and got them to be selling, so it became much more
of a selling conversation and at that point some post master would claim that it
was all about sales and we never give them support and to some degree that
was the focus for some people but we always had the helpline there to support
whilst that BDM wasn't as perhaps as rounded as they had been previous
because that wasn't their role, it is still part of role would be if the post master
is in difficulty or they talked to us about... sometimes they might say I have

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spoken to help and I am not getting any help then that is when we would get
involved and we would escalate that so there was always the mechanism in
there providing they told us about it. so what we weren't able to do as well then
as perhaps we have done of late is to be able to see that there were problems
so we couldn't be proactively identifying there were problems because we
didn’t have a sophisticated in the systems that we operated.

Victoria With the focus on the sales aspect did the people who were doing those roles
within the Post Office were they incentivised in any way in relation to that? Im
thinking that’s a question the other side might ask.

Angela Part of the objectives would be yes to drive certain volumes of transactions but
it has always been, we have always have.. whether you had a kind of rounded
up target of you know this is the level of business going through and you
needed to either maintain or improve. What we became more focused on was
individual project sets so we expect you to set across your 50 branches we
would expect you to have 2000 sales of Post Office home phone for instance
as appose to the kind of the income piece. It depends on how you cut it but we
have always had that focus and this is always a win-win focus because if the
post master sells more they get paid more including we generate more income
from it so it was in everyone's interest to have that approach but it has also
been there but it was part of a balance scorecard in as much as there were a
number of errors that you would have to... the objectives have always been
linked so these are all managing the roles, managers roles are based on
objectives and they would have a great influence on those objections at that
level so they were incentivises to perform in those roles. If you go into some of
the non-manager roles it was much more generic and the line of sight probably
wasn't as tight.

Victoria Okay so we were sort of talking about how roles have changed over time BDM
and R&M. do you think we have covered that

Angela Where we havent touched is we did start to segment the network more and we
went from going away from geographical considerations to more tights of
branches and that in particular when you come into the reigns and locals so for
instance the level of support the network got changed and the only physical
support as in assigning branches to Post Office people were in the large
branches. So the more commercial branches had that sales force. We called
them Sales Capability Managers and there were a number of different versions
on that but basically it sort of morphed into that. The rest of the network that
was probably 2000 of those branches the rest of the network had more of a
pastoral support which was to do with project helpline but actually some branch
standards as well which is a different area that we set up now Gail manages

part of that.
Victoria We only had 2 hours with Gail so we might need to see her again.
Angela No she doesn’t manage part of that, I tell a lie actually Kim Abbots managed

part of that now which is that she took on the compliance area of it. Gail used
to manage that when she came to work for me. So Gail has been close to how
that would have been. So for a period of time.. you only had 2 hours with Gail.
You definitely more than that.

Victoria I am going up to Chesterfield in a couple of weeks so I will try and see her
again then or we might meet her in Newcastle.

Angela Gail has got great knowledge. Gail has got quite different background as to
entries, she was a grad entrant. Gail was one of these people that really got
her hands dirty and got close and when she worked with me she was one of
the people like Alleka one of my people and ask can you go and have a look at
this for me and I always knew they would get really interesting.. and the people

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that you knew would always look at it from both sides because I know there is
58.38 a view particularly when you are obviously going into legal situation like ?? you
always kind of defend the position but that's not the case. I have always looked
at both sides, Gail always does that and Alleka always did that.

Victoria If you want to improve things you have to

Angela you see some cases where we had some issues raised on some of the
decisions we made on it where particularly if we had gone to the contract we
would have given no leeway at all. I can understand the situation and actually I
think albeit exceptional goodwill payments I have made those over a number of
years and Gail has been heavily involved in a number of those cases so I
suggest you need more time with Gail. She ran branch standards and was very
close to that and she has been running the branch of customer support now
for, gosh when did she come in, four years ago. We actually closed Dillen and
moved it to Chesterfield and she was coming to do that we me at the time. She
has got great knowledge.

Victoria Yes she did, she was very interesting as well.

Angela So I think we have covered that particular in terms of the segmentation of the
network and so you almost have whilst we would never position as a pure tier
kind of support there is a two tier support because one is more focused on
sales which is the higher end type of branch and the other is more pastorial,
more supportive. Making sure that and equally across any type of branch we
want to make sure that post masters are as equipped as they possibly can to
make sure that they are able to 1 -sell those products and services in a very
compliant way but also that they do it in a way that means that they don’t make
the errors and they don't get the losses so that is how we train it, we train it a
certain way to make sure that they have got that. Everyone knows that we
have a helpline.

Victoria I was going to ask in terms of the ones you don’t have somebody who is
allocated to them any more of the branches that’s the helpline.

Angela So whenever we have trained people and interviewed people. Your first port of
call is NBSC and anything you need NBSC even if it was to get hold of me as
an R&M you would go through NBSC they page us years back, they would
page you please can you ring this branch. So there was always a system of in
to the NBSC and out to the R&M or BDM and then we would ring them. So we
were always contactable.

Victoria You calling them back that was reliant on you actually doing it there is no one
chasing you to actually do it.

TAPE 2 No it's a good question, so there would be a call, so the postmaster would
Angela ring in that would be logged so on the log in system it would say log and

postmaster request of BDM to call that would be paged and then we would
call but nothing check. the only way we would know if it hadn't happened is
they call back in and said my BDM hasn't rang me and in some cases, you
know if I had another call through and it came through this is the second
request and I sometimes go well im not that number 4. So when I rang the
branch I say Im sorry I have just got this but I havent.. Sometimes obviously
some things do breakdown. So the system worked pretty well

Victoria It sounds like if they had confidence in the person they were going to reach
at the other end they definitely can continue to try and get to you.
Angela Oh yes and even if we were on leave we had a buddy system so if I were on
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leave I had a buddy in my team that would pick up my calls so it was always
covered. There was always somebody someone could get hold of if they
needed to.

Victoria Okay that’s very helpful. I have got quite a wide question that sort of touches
on this but what did Post Office play in day to day running of the branch?
Now it's an obvious question

Angela There is a number of layers here now so Post Office set the requirements of
how they run the branch. So it's in the contract, it sets out what the
expectations of customer service, of the premises, you know the
presentation of the premise, opening of hours and the products and services
that you would transact so that is quite clearly stipulated in the contractual
relationship. You then have had different ways of monitoring performance
and when we were in the field as BDMs we had a quarterly visit with a
number of things we would have a conversation and it would be about
performance so we had was to pursue that performance mechanism, we
could see how they were performing and we would have a conversation so
in that respect we did influence, depending on how well they responded and
if they didn’t respond to the areas that they deemed to be in breach of
contract again we would influence because we either correct that situation
with them or we would actually deem they were in breach of their contract
and we would go through contractual procedures with them as well. All that
was very well understood by postmasters they understood what their
contractual obligations were even though I know 2? but it was reinforced and
3.05.5 so was visits. Now as you come through that timeline that we are talking

about you could argue that actually you weren't invited and therefore you

weren't ?? that’s where branch standards come in and branch standards in
3.16.8 terms of the number of calls and I don’t have the number in my head but it's
very substantial. Branch standards is the outbound call mechanism so if we
receive an inbound as was with the customer helpline we've switched off the
people element of customer helpline now. Did they tell you that?

Victoria No I don’t think so

Angela So predominantly you are interested in NBSC because that just corporate
but from a customer helpline if there is any issue the branch are clear they
come through the customer please so you can't just look in isolation so that
obviously plays into you. So we took a decision about a year and a half ago -
2 years so the helpline number is still there but you don’t get to speak to a
person you get all the IDR options and its only if you want a call back that

4.13 we actually ?? that
Victoria She mentioned that the customer helpline but she didn’t mention that aspect
of it.
Angela - 4.19.7 It's only a slight 22 but some people are probably not as helpful. Everything

is recorded, so we would log everything sometimes if we are having
problems with the branch if they had not told us about it a customer had told
us about it, I have been to this branch and its closed. I have been to this
branch and they have short changed me. I have been to this branch and
actually they were given too much money, it does happen. They tell us
sometimes.it almost a big brother in terms of the monitoring systems so
that's a question so what do day to day running. So we have influence
through the procedures are standard and by how we interact with post
masters as well and obviously we have a strict sins on what they can sell in
the retail side so again we influence in terms of the day to day running.

Victoria You are not physically there obviously from what you have been saying

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Angela No
Victoria I know it’s a silly question and I know the answer to it but its just for our note
Angela So they are franchisee, they run the business on our behalf under the terms

of their contract we give them the training we give them support and we give
them equipment. We give them everything that they would need to be able
to do that properly and in accordance with the contract and standards that
we set. They have a degree of say of how much influence we have on them
and the business by the interaction. So if they reach out to us more than we
give them more time. If they breach their contract by default they get more of
our time. If they have errors, if we see a high level of errors and we have
proactively done that in cases. What I was trying to build in that model was
that how to we proactively look at the top branches in terms of... and
actually some of the changes so if you have got a branch and we do do this.
Perhaps not as well as I would like us to. We don’t have the equipment yet
in system. For instance NBSC and Kendra particularly would give
information and say this branch we can see that they normally average 2
calls a month and suddenly they have got to 40 calls a month and we would
put a call out and say it is a problem and it might be that the Post master is
on holiday and they brought in a temp who is not quite so familiar and we
know that it is going to go back to normal so things like that... so there are
ways but the Post master can influence the level of involvement we have in
the running. I think its really important actually.

Victoria We have covered quite a lot of what I had on my list so if I just have a quick
flick through. If anyone wants a break at any point

Angela No im fine. We've got the guy coming to fix this so as soon as he comes I
suggest we break for lunch

Victoria That's a good idea. One of things that we are dealing with in the litigation is
that the other side want to imply a whole load of terms into the contract and
it would be quite useful to get your take on what as a person who knows
everything about Post Office so well what you take would have been if it had
been a contractual negotiation and they had suggested to you at the time
that these clauses would have been something that should have been in the

contract.
Angela Do you want to give me the clauses?
Victoria So if we go through. This might be a bit more clunky
Angela That's fine, it's interesting isn’t it so over my time, its depends on the type of

individual they are so people absolutely relish the fact that they are
independent business people and they particular tend to be the better post
master because they very much come in this, Im here because I don’t want
to be implied I want to be my own boss and im expected to be able to do
that. I want to be able to have the influence of running my own business and
have my destiny in my own hands and therefore they very much see us as
that overarching bit so they operate under the true franchise banner and
they have got others down the other end of the scale that go no I really want
to be implied and also I don’t want you to tell me exactly what to do so it's a
bit of a dilemma actually. Sorry I digressed.

Victoria If im bring this over, so this is to do with implied terms that they are saying
the terms that should have been in the contract and some of them you may
agree with but.. so it’s a but dull to go through im afraid but it might be
interesting to get your thoughts. So its these bits from here really, so to

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provide adequate training and support so if I give you the number 64.1
Mandy What document is this sorry
Victoria = 9.50 It's the G pok
Angela So we do have a clause in our contract currently that says we will provide

training and support and in the new contracts we really build into the new
contracts particularly that they had to attend the training because that was
an issue going forward so that is already in there. That is a reasonable
request

Victoria As you can imagine one of the things that we are saying in response but it's
good to have it from you as well. So then 64.1 is the next one. And when
they talk about a system here they are talking about Horizon.

Angela Yes. So we do provide a system that in fit for purpose and I have been in
and out of Horizon god knows how many times now and in terms of
adequate error. It depends on what they mean.

Victoria Well it's one of those things they have described terribly well but what we
understand it to mean is to make it difficult for errors to be in the system.

Angela So we do but as I said error where you have a human element of that there
is always going to be that. For instance the example I gave you earlier about
the banking deposit in and out it tells me to give money to customer so take

from give to.
Victoria Is that actual wording?
Angela Yes. So what we have done is we have looked at the system over the years

and we have tried to make it, with feedback how do we make it as risk free
as possible and I say as possible because you can't be 100% here. So for
instance if you go on the Horizon screen then the icons for banking deposit
and withdraw one is red and one is green.

Victoria Oh right

Angela We tried to colour code it. so say you come in and you put the bank account
in or sometimes you swipe a card now, these are things that have changed.
These have changed over the years and I can't remember the exact order.
So they put a card into the pin machine automatically pulls the banking
details up so we havent got to put the account details in we havent got to put
the sort code, its already there but what we have to put in is the amount. So
they come in and put £100 in so they have to type £100 in then what we
have to do is type in words so it’s a double thing. Then there is a question
that we built in that says are you sure?

Victoria So you have to type in one hundred?

Angela Yes so these are the things some of it has come in some of it was docked
out so you have to get exactly what we have got today but what post
masters and their staff do because they know the system so well they just
go onto autopilot and they click away so they are not reading the screen
okay. Im trying to think of others ones as there is another one. I have taken
the opportunity when I can to change things and there was one around
MoneyGram. Let's take MoneyGram as an example. So MoneyGram is
where.. sorry do you know what MoneyGram is?

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Victoria Sort of overseas bills and transfer of monies.

Angela Yes, so this transfer of money from one country to another typically. Some a
customer comes in and say give us £1000 to send to their family member in
Pakistan and it's an instance transaction so there is very little room here, so
you have to be very careful. So a number of checks so once you go yes its
sent, they could be picking that up in that outlet in Pakistan within a few

minutes
Victoria Right
Angela So it's well open to frauds. So a few years back Gail was involved in so we

had a situation where, and it was fraudulent, there were people making calls
to post masters to say this is an engineer and we are testing your system
could I test a transaction with you please? So they tested a MoneyGram
transaction and in the MoneyGram transaction its built that you have to put
ID in and everything. There are certain things that you have to fill in fields to
get to the next stage and the transaction is you never do that on the
telephone it’s a physical transaction so if somebody comes in and so they
have taken them through and this person whoever it is knows what they're
doing and they take them through and effectively what they have done they
have transferred money to somebody else. They havent taken the money
but actually it's now telling you to take the money as a test transaction don’t
worry about it and they do it. They don't just do it once some of these people
have done it 9 times in a day. So there is a ceiling on how much you can do

at a time.
Victoria Yes
Angela So I was dealing with a number of cases, one had lost £45,000 so now

looking at that transaction everything was built in then and they knew what
they were doing but they were duped into doing it. so I looked at that and
went okay this is stupid they clearly have just been had here so how can I
look at this and try and even try and make it even more secure than I can.
So what I did then was I got it so you could get a pop up to say we will never
ask you to do this over the telephone, completely in their face so what im
saying is so when this error displays, even though you look at it and think
that is water tight there is that human bit.

Victoria As you were saying just click yes, yes, yes.

Angela So a transaction reversal for instance or when you lose power or connection
so you could be serving a customer and power goes, the screen goes blank
and you are half way through. The customer might have given you money
but havent completed it so the system comes back up and there is a screen,
it asks you questions to establish at what point you were when you lost
power. Have you given money to the customer? Have you taken money
from the customer? Now depending on how you answer that the system
either rejects the transaction or completes the transaction but you have told
it. so if they read the screen properly as they should and it's not difficult then
fine or they could have just taken money from a customer and the customer
hasn't got a credited account so I would be keen to understand in this
particular one at what parts of the system or what transactions or what
products are you really talking about here because I could point to a number
of transactions where we have got those step points in place to try and
mitigate the risk of error.

Victoria Well that is really helpful. I just want your take on them. It wont change the
legal argument about whether or not we agree but it should be in there or it

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shouldn't be in there but your flavour around them is what im looking for so I
don't think I need more detail then that at the moment.

Angela I know I would need to pull the type of examples that we have got there. I
am just talking from my experience but there will be more in there.

Victoria This is really just to get a flavour around it and im not sure to the extent that
we will use this because it will come down largely to legal argument but part
of that will be if a post master is negotiating with you about the contract what
would you of said and the reaction to this clause being put forward so that is
why it is largely legal argument.

Angela So my view on this is, we have advertised a vacancy we have advertised
that we have an opportunity for a branch and this is a contract that we are
willing to engage on so you have the option to take up that contract it's a
choice so you either choose to engage with us and be a partner in the Post
Office or you can choose not to. We have never forced anybody. That's
probably the wrong answer but that’s my take

Victoria No I think that is a good answer and I also think that operationally why is
there a reason that you might need them to be all on the same contract.

Angela Its not just operationally actually there is a commercial and legal reason for
us. When we enter into our contracts with our clients we agree our terms of
this contract and in those contracts there will be clauses that stipulate how
many branches would sell that product only because they would cap them
and the way that they want that product sold so we are doing business on
behalf of our client so there is a contractual obligations that we have and
therefore we have to apply that otherwise we have breached our contract.
Commercially we restrict products and services around you know they are
only able to sell certain products in the retail so for instance we have an
exclusive contract with Royal Mail to transact mail and parcels through our
Post Offices. We then keep that contract tight and there is a clause in there
that says that you cannot enter into a private arrangement with another mail
company to transact from the premise as that is a breach of our contract.

Victoria — 20.20 So things like collect 2? and that sort of thing.

Angela'20.23 Yes ?? detail, all those things. We had the same with bill pay so there is a
number of things that they cannot negotiate on these points and then you
come back to the operational bit for us as an organisation to be able to
operate as effectively and efficiently as we can and this is to benefit the post
masters actually because then we can keep our cost base low and we can
actually make sure that we are generating enough revenue in the
organisation to be able to make reasonable payments in terms of
commissions for post masters we need to be able to do that. Standardisation
is the best way to be able to do that so if everyone operates in the same way
then we have not got any variances then we are not building additional costs
into how we transact in the back end so back office processing is something
we havent particularly been good at over the years and standardise because
our clients have something bespoke arrangements is where we go in
completely standardised so if you want to do business with Post Office this
is how Post Office does business. You can choose to do business with us or
choose not to.

Victoria That's really helpful. So that would be the overall response for any of these
but if we ask you about the individual ones. The next one is whether or not
Post Office should have an obligation to properly and accurately effect for
obtaining and keep records of all transactions effected. That is 64.2

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Angela We do, I don't understand why they say we don’t because we do.

Victoria It's probably and accurately to effect record maintaining and keep records
for transactions affected using Horizon. What they are saying is the
contracts that you have in place don’t have a specific obligation in them that
covers that off and they are saying that therefore it is something that should
be implied as a matter of law.

Angela So im telling you that we do it whether it's in the contract or not is separate

Victoria Is a separate part but that’s helpful because that helps us decide whether or
not that is a gap in the contract. We have obviously already responded to
this all through the legal...

Angela So is this specifically Horizon isn't it.

Victoria Yes

Angela So Horizon.. so we keep every keystroke that goes to that system for 7
years.

Victoria I have seen they are almost like spreadsheets of all of the things that have
gone in.

Angela What they would actually be in branch you would just print them off like till
receipts effectively. I mean you're talking masses of paper. Can you imagine
7 years’ worth of stuff or we can then filter it and ask for certain/different
reports and things like that so there is a filter question there but we do that
and we have always done that

Victoria Yes okay so that's helpful

Angela What we have changed from is paper in branch so we keep it for 7 years
they don’t have access to 7 years they get 60 days

Victoria 42 or 60 depending on the time they had been there.

Angela It used to be 42 and now it has gone to 60 and some of the post masters
when we went from manual to Horizon printed everything off even though
you didn’t need to and this is kind of a confidence bit I just need that. Even
now some people will just, so where something doesn’t produce a receipt,
we print a receipt to keep for the records. It's unnecessary because we
record all the information but for them its their comfort blanket. I've got it if I
need it.

Victoria People do that, do they tend to be the people you don’t have so many
problems with?

Angela Yes

Victoria Thought so

Angela We do have people we don't have problems with who use the system and
go with it.

Victoria And these are all obligations that they are saying Post Office should have
under the contract. So properly and accurately to produce all relevant
records and/or to explain relevant transactions and/or any alleged or 2

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Claimant's. That's 64.3

Okay so we don't on the whole basis do that no we don't. what we do do,
because that is very costly to do and very time consuming. So if you were to
apply something like feeding information and regulation on there then clearly
we wouldn't do that because that is silly. So what we do do is if they have
raised with us issues this is what we did particularly in the mediation
scheme. We are then able to investigate and pull up all that information.
Now I would have a particular problem putting that into any contract and the
reason I have a particular problem is is because it comes down to I suppose
distribution of responsibility under the contract around you post masters,
25.45 these are your responsibility not the ?? and these are ours so providing you
adhere to your contractual obligations we wouldn't expect you to have many
causes to request information

Angela

Victoria Yes

Angela So in the event that you did and you had complied with all that stuff we
would readily investigate but what that would open the door to and I have
seen this a number of times. Post masters cannot be bothered to do it
themselves so they then say right Post Office do that for me. That is not our

relationship.
Victoria Its shifting the responsibility isn’t it.
Angela res but even if they were our employees we still wouldn't have a clause like
at.
Victoria No
Angela So we but certain obligations on employees because they work in branch so
26.35 you do all these things and 22 declaration and we do this, this and this.

Someone who does that I would gladly investigate the issue because it
would be a genuine issue. It would not mean to be covering the gap for them
being lazy or complacent or just stupid.

Victoria That's helpful
Angela Over my dead body. I knew that one.
Victoria Post Office should cooperate in seeking to identify the possible likely causes

of any apparent or lead shortfalls and/or whether or not there was indeed
any shortfall at all? I think that is probably covered by what you have just
said. You would do that if they had followed everything they were supposed
to.

Angela There was more to that one actually. In this is the round shortfall would
come as a result of an error or something or inter business loss or they
would claim there was a glitch in the system. Where we see things and
obviously we did disclose a couple of issues we had with Horizon. Where we
see that then we don't just deal with that one we then and say right so he
has got a problem somewhere else. So in those instances we would do that
and we would investigate and then where we see issues we would reach out
and put right and we would tell them that was what we were doing. So it
comes back to this broad or very narrow lens actually so for me it's about. if
we were to concede all this stuff and we have a contract as a business we
would have to say that we were not going to operate anymore because we
couldn't do it because it would be so onerous on us then it would be
impossible. Well there would be no money there at all. It would be

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impossible to do.

Victoria That sort of thing is a sort of a reaction, that’s really helpful like why as a
business you couldn't have that clause obviously if it is one you think is
needed that's also fine because we would say that in our defence but its that
sort.. its ridiculous to have that.

Angela There might be things that we do today that our not in our contracts because
29.03 I have made a number of improvements over the last few years, like setting

up the issues resolution team which is Shirley 2? team which Kath used to
work in there. I set that up off the back of my involvement in the mediation
scheme on saying look going into NBSC it might be a bit too broad. We don’t
have that skill set to get at the hub of that issue was Cath and Shirley and
the teams they were running could do that on the phone. They could sort a
problem on the phone, talking to a post master and that isn’t in the contract
but that is an improved way of working and improved way of support that we
have put in place now if I am a post master coming into that would I expect
that to be in the contract. I probably would actually so I think providing we
can keep stuff tight in as much as. You do this, this and this and I do this,
this and this providing we do this and this we agree to do these things as
well. If you don’t do that then we're not agreeing to do that because a
reasonableness has to come to because if it's not reasonable commercially
we Cannot operate.

Victoria Okay so this is 64.5, Post Office to seek to identify such causes itself in any
event. So that is if there is a loss in branch that Post Office should be trying
to identify.

Angela No I don’t agree with that at all. So if it's our responsibility what are we

paying them to do. So it is part of their role, they are responsible and
therefore there are certain things that they need to do before they come to
us for help. Im not saying if they are totally alarmed about something for
instance they got a £50,000 loss you ring us and we tell you no these are
the steps you need to do and we will help you. Is it our responsibility or
should it be our reasonability to allow you to continue to operate in total
oblivion to anything that has happened as asked to tell you when you have
made a loss or when we can see an error that’s the wrong balance of that

relationship
Victoria And is that because you are psychically not there so you can tell.
Angela Yes there are a number of things. One we don't have the level of

sophistication in our system to do that and if we were to do that it would be
so costly it would make this the commercial relationship unsound. The
human element so unless we had CCTV in every one of those premises with
a view of every part of that building with 24/7 continuous monitoring we
couldn't sign up to that. We could build this but it would never work and
there is a number of reasons why and not least because commercially we
couldn't afford it. so you are building a way of operating that's going to cost
you thousands times more than the money you are making out of that
operation so why the hell would you do it.

Victoria Exactly that's the sort of thing. 64.6 — Post Office to disclose possible
causes of apparent or alleged shortfalls and the cause thereof to Claimants
candidly fully and frankly. Well I think we have probably covered that.

Angela Sorry just on that point can I just say so in that and if im reading this
correctly that means not just their alleged loss but other alleged losses.

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Victoria What do you mean?

Angela So if Mandy has a loss at her branch, you would have to tell the rest of the
network about the loss.

Victoria Yes that does cover that.

Angela So that actually comes into my view into breaching confidentiality as well.
Obviously it's part of law and you will tell me better than that but for me that
is personal information.

Victoria Yes

Angela So if I incurred a loss in my branch that’s personal to me and I wouldn't want
that shouted out and actually if that were the case I would never have
entered into that contract because I don't want me business so there is a
different angle

Victoria There is but then I suppose if there had been a glitch in Horizon that if you
pressed this button it meant you would have a £10 loss and that was in
every branch what would happen then?

Angela Well we clearly fix them and clearly tell everybody

Victoria So that's the different between the two

Angela But what I read into this is in terms of alleged shortfall it might not even be a
shortfall

Victoria That's true

Angela It could be I have made an error and it could come back next week so we

could have gone out to 12,000 branches and said by the way Mandy in
wherever you are has just incurred a loss of £1,000. We would just pull the
rug as how we operate this you know so there is a degree of confidence that
post masters have to have in Horizon system. There is a degree of
confidence the post masters have to have in Post Office in as much as we
are not here to tuck them up, we are not dishonest. We are not a two bit
organisation we are Post Office for Christ sake. There has to be a degree of
trust both ways and clearly what we are dealing with as part of this case
obviously there is a breakdown of trust and that could be on both parties
actually in terms of we have ended our contracts with that. That was 64.5.

Victoria So point 7 I think we are on. Post Office to make reasonable inquiry and
undertake reasonable analysis and even handle an investigation and give
fair consideration for factual information available as to possible causes the
34.51 appearance of ?? shortfalls. I think we might have covered that one. 64.8,
communicate alternatively not to conceal know problems or errors in or
generated by Horizon that might have financial and other resulting
implications for Claimant. I think we have discussed that already.

Angela And we have disclosed a couple in our first..
Victoria 64.9 — to communication or alternatively not to conceal the extent to which
other sub post masters are experiencing issues relating to Horizon
Angela That's breach of confidentiality
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Victoria

64.10 — not to conceal from Claimants the Defendants ability or to remotely
data or transaction upon which the calculation of the branch account and
any discrepancy or alleged shortfalls depended. I don’t know whether that's
one you want to comment on really because I don’t know the extent to what
you know on that one.

Angela

I do know about it

Victoria

Oh you do

Angela

Yes

Victoria

I wasn't sure if you knew about that one.

Angela

So I think this.. if im talking as a postmaster coming into that I thinks that a
reasonable request personally. I don’t know what our business position is
and clearly we would need to debate that and we havent expressed the
interface of that but it comes back to my point about the trust so the issue is
arising system is that if you are running the branch and you are suffering
losses and you start to look at how you operate so in many cases post
masters will say to me it's me, my husband and I got 2 members of staff and
I trust at least one of those people with my life so they would never do
anything and then they look at it like they can't possibly lose money here
because everything is tight and we check the bins before we put them out at
night all those kinds of things and then they go we have been really careful
that we are not making mistakes. If they convince themselves of all of things
at 100% whats left. Whats the only thing that they don’t have in depth
knowledge of in their head and that is Horizon. It has to be Horizon because
I trust everything else so if you look at it from that perspective is it then
reasonable to say right okay so if I pour water into this hole in this box but I
can't see the box how do I know that water isn't coming out of the bottom
because I can't see it. so in that example is it reasonable then for whoever
owes that box to tell me one a month they open the box for 10 minutes. I
know that's a silly example but you know what I mean.

Victoria £37.50

No it's good to get your take on it all. Post Office properly and fairly
investigate any alleged ??. Post Office not to seek recovery from Claimants
unless and until Post Office has complied with its duty. We don't need to
worry about that. Post Office has established that the alleged shortfall
represented a genuine loss to Post Office, might what to pause on that one.
I don't know whether you have got any views on that one.

Angela - 38.13

Well I have got a view on this because ?? of any matter years back in that
because of one of the cases particularly. There is a loss to us now the issue
with post masters is sometimes it's a paper loss though at some point down
the line we have to settle with the client and if the client expects him to get
£100,000 worth of payment and we are only giving them £90,000 and then
they say well now you owe us £10,000. It's always a loss to us. Now that's
my take I don’t know whether there has been any further discussions but for
me everything we have looked at, every case it has actually given us loss
somewhere along the lines.

Victoria

I would agree with you.

Angela

Post Office being liable to make good of that and its only reasonable that for
post masters if you have incurred that loss you suffer that. You have done
something that has created that loss and you should make that good.

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Victoria

I agree. On the point that Post Office shouldn't seek recovery from Claimant
until Post Office has established that the shortfall represented a genuine
loss to Post Office, I don’t know whether you have a view on that.

Angela

Is that point 14?

Victoria

64.12b

Angela - 39.36.7

So we work on the basis right so when they do their branch ?? statement
they declare discrepancy it could be up it could be down and at that point it
is declared as a loss. So from my view that is a loss at that point. They have
the opportunity to flag it to us and say I have got a loss I think it's this. I have
got a loss and I want to dispute it. I have got a loss but actually I want you to
investigate it. So at that point we would not recover the money from them. It
goes into the suspense account, we put it on hold and I have put things on
hold for many months and even in some cases years. So we don't
automatically default to you have to put that money in today, there is a
mechanism that we have built into our approach that allows them time,
either themselves to work on it or with us to work on it.

Victoria

64.12c — not seek recovery from Claimants unless and until Post Office has
carried out a reasonable and fair investigation as to the cause and reason
for the alleged shortfall and whether it was properly attributed to the
Claimant under the terms of the sub post master contact. So what they are
saying is we should be carrying out a reasonable and fair investigation
before we seek recovery from Claimants.

Angela

So my position would be its their responsibly to do that until they get to the
point where they have exhausted what within their gift to do and at that point
they raise that to us it comes back to the point before then then that’s what
would imply.

Victoria

Have they done everything they were supposed to do? That's helpful. We
are getting on to suspension and termination these are more a legal
argument but Post Office shouldn't suspend claimants arbitrarily, irrationally
or co-prissily, without reason and proper cause or in circumstances where
Post Office was itself a material breach of duty

Angela

So you have probably spoken to John Breeden on this.

Victoria

We are going to speak to John Breeden next week.

Angela

So I change how we did this a few years back, so we did operate quite a
black and white scenario a few years back before my time before I came to
this role and it was typically when a lady called Lynne Hobbs was running
that part of the organisation and it was then that you see the tolerance. So if
on audit you had a loss and at some point and even though it was normal if
it was less than £1,000 we didn't do anything but in instances where it was
less than £1,000 the default position was to suspend whilst we investigated
and that was always how it happened. Now when I became involved in this
and I worked with Craig Tusum at the time and he was working for me on
this and when I changed it and said Quarterly suspension should not be the
2? that should be the last part of the equation and the reason for this is
when we pre-cautionary suspend a post master no matter how well we try
and keep it under wraps no matter how well we try and not let customers
know, they know and whilst we have always argued that its precautionary
suspension whilst we investigate and doesn’t imply anything word gets
around the community and that has on occasion done reputational damage
to that post master. Whether that is perceived or that is reality or whether it

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just affects the post master themselves. What I am saying and I forget the
date but it will be logged somewhere I actually bought in a system where we
did more investigation on the day and in advance so that we did need to
precautiously need to suspend the post master and it was only if we were
absolutely clear and John will give you the guidelines on this because I
wrote them and they are still in place now. So our default position to keep in
post unless we had good reason not to and that might be in case if it was a
very large loss like £50,000 if it was something like 234 and he can give you
examples and track this of how many we actually do not cautiously suspend.
We have a precautionary suspension consideration but we will not suspend
and we keep them close. That is a very significant change and I think that for
me that demonstrates just how serious we take this and just how reasonable
we've look and worked with because that reputational damage is significant
when you are running a business. So talk to John and he will give you all
that, he will give you dates. It was probably 4 years ago now. But what I am
very keen to do is track like year on year what the difference was and the
number of things when doing that. One of the conditions in doing that though
is that if they have a £2,000 for instance today and we say right okay fine we
won't precautionally suspend you but you have to make that good, that loss
good. So what we want to do is keep someone in post when they are..
because that has a potential bigger problem. Talk to John and he will give
you all the detail on that. There is great data on how much that has worked.

Victoria I remember the days when it was immediate suspension.
Angela Black and white yes
Victoria Same sort of question but were Post Office not terminating claimant's

contracts arbitrarily, irrationally or co-prissily.

Angela We don't do that. We have a very well documented approach that we go
through and there are a number of touch points and decision points in there
and if we wanted to be able to close cases where we had looked at
mitigating circumstances and actually not gone to the lets of the contract we
could clearly do that.

Victoria That's really helpful. Post Office not to take steps which would undermine
the relationship of trust and confidence between claimants and the
defendant, so between Claimants and Post Office.

Angela I think it is what we do we try to take steps to try and build the relationship of
trust and again that document I refer to earlier was just that improvement
piece I think is evidence of us trying to do just that now you could claim well
actually you were only doing that last few years and it comes back to my
point in that we have always looked to improve by why we have changed
that model over the years so I would flip it on its head on that one.

Victoria Yes that's probably going to be a legal argument one anyway. Post Office to

46.51 exercise any contractual or other ?? power honestly and in good faith for the
purpose of which is was conferred.

Angela So my experience is that we do that.

Victoria — 47.06 Fine, that's good. 17 not to exercise any discretion ?? or unreasonably.

Again from what you have been saying to us there is lots of consideration
that goes into things.

Angela Honestly you might want to talk to John and get a couple of cases. If you say
sometimes the length of time it takes. It we were in a precautionary

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suspension and we were bringing post masters in for interview and if you
sought the length of time and the amount of effort that goes into making sure
that we are making the right decision on the facts that we are being
presented with. You know we don't just jump to last base overnight or
without due consideration or without giving it sufficient weigh that kind of
decision takes. We take this very seriously.

Victoria Yes, okay. Similar question — Post Office to exercise any some discretion I
accordance with the obligations of good faith, fair dealing transparency
corporation of trust. I think that’s a leaver that one.

Angela See I think that's a personal attack on us as individuals there because we do
all that stuff but if you think you have been here as long as I have been here,
its personal.

Victoria Yes that’s true it is very personal. I think that is also quite a good flavour we

are going to get from your proof of evidence because you can speak to so
much of what Post Office has done, so I think that really helpful.

Angela I had this conversation with Angela Bates once, no actually it was on the
back of quite a sensitive case, it was a chap that walked in front of bus.

Victoria Oh I have heard of that one. I think Paul did that one. I can't remember, one
of my close colleagues was dealing with that one.

Angela Yes so I got very close to the family. So when it happened and I had had a
conversation on the telephone with him and he was really laying into Post
Office and I said to Alan I said when you talk of Post Office who are you
talking about, who are these people you are talking about. You know the one
in the grey suit with the steel toe caps. I said who do you mean give me
some examples and I said but you're talking about me. I said what you are
talking about I have been here all this time. No im not talking about you. Yes
you are talking about me. So when you are saying these things you are not
seeing me in that frame then who are you talking about then because I have
been here for x number of years I have been involved in all of this. so I can
talk at that level of detail and confidence and then he will say to me, no
Angela I don’t mean you, well who do you mean then?

Victoria 19 is Post Office to take reasonable care in preforming its functions and/or
exercising its functions within the relationship, particularly those which could
affect the accounts and therefore liability led shortfalls. Business, help and
reputation of claimants.

Angela I think that comes under the stuff in terms of what did with suspension.

Victoria You do have a view to that very clearly and then the rest of it is anything that
we need to talk about in the contract. There were some questions to do with
whether or not why certain clauses of the contract were important but I don't
think it would be a good use of our time to go through those with you.

Angela Okay

Victoria I think based on the other things that you have been saying we can apply
that to those clauses if we need to and if there are any specific ones that we
can't then we can obviously come back and ask you but those general sorts
of principals are really important. If I go back to my note which is over here.
Do you want to have a break?

Angela Yes just a 2 minute break for a glass of water.

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Victoria So let's go back to the list of questions. One of the things on here to do with
contacting support is also issuing post master instructions because that is
one of the things in the contract currently at 16.22- are you familiar with that
or would should I find my screen shot I took earlier.

Angela Let me see just to make sure.

Victoria Sorry let's not do that. 16.22

Angela = 55.18 First provided product to services to standards 2? set out in the manual and
failed to ?? remedy within 14 days of notice.

Victoria It's a reason for termination.

Angela Which contract is this in?

Victoria This is in the main contract

Angela It's not standard and whats the question

Victoria I will go back to my questions, one of the reasons in which Post Office might

be able to terminate the contract and that's one of the clauses that is
discussed in the litigation which is why when it talks about instructions in that
clause can you shed any light on what is meant by instructions presumably it
is everything that we have just been discussing.

Angela Well for products and services so each part of the service that we operate
on behalf of one of our clients comes with specific requirements on how its
transacted. A number of them would have the financial regulations on our
counter service products things like dangerous goods, on the mails there are
a number of requirements that we have to adear to and therefore that clause
there is to ensure that we actually pass on that obligation to the post master
in terms of them doing their business so what we are asking them to do is
keep within our agreements.. given the agreement we have with our clients
to transact that business or that product service which given that the client
pays us and we pay them it is not an unreasonable request. In terms of the
way the mains and the locals contracts is written there are periods of
remedy in there which actually makes it quite difficult in some cases or quite
elongated to get to a termination because actually we have a number of
reasonable steps, if you were to pull out any situation where we have been
87.22 2 in that you will see that we even go further than the contract implies in
terms of trying to.. we want to be able to work with post masters so it
actually costs us more to get rid and rehire a post master than it does to
spend a bit of time trying to resolve a slight contractual issue like that.
Unless they were just completely refusing to do a number of things that were
causing us real problems and we do have some examples where for
instances some post masters refuse to accept the males for instance, you
know when you get as businesses you kind of put you mail into pouches and
you just drop it all off at a Post Office, post masters hate that as they don’t
get paid for that specific items, its all wrapped up in the broader contract
because they don't get paid for that specific item they don’t want to accept it.
now they are contractually obliged to and there are some cases where I
have had to deal with where we have actually been in real breach of our
contract with Royal Mail because they are not doing that so its things like
that and we would spend weeks and months in some cases and say look
you know this is what you need to do and if you don't do it we give them no
system stuff and in some cases we would end up because if we didn’t
comply with the terms of that contract with our client then clearly its more

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than one branch at stake.

Victoria Well that’s really helpful background actually. I have got a question here
about remuneration work but im not sure if that something I should really be
asking you about or whether I should cover that with somebody else.

Angela I could tell you but if you want to talk to the expert then you would need to

talk to Nick Beale. Nick Beale in head office, he has been in that area for a
number of years and he worked very closely with me for a number of years.
He has got a number of people working for him, Chris Howard, Nick Graham
or Andy Turret are the people to talk to but then we have different
remuneration level for different types of products and different types of
contracts. So each product and service attracts a certain level of
commission or remuneration and different model types would be paid
different amounts as well so a mains contract is different to a local contract
because there is different obligations in how they operate and then we have
also got things like call to your payment. That a fixed payment that we have
and then above that and then we have what we call a small office payment
or we top them up if they go below minimum wage which is one of the silly
things that we do considering we operate on a contract for services. It's
something that we took years ago to stop us trying to get some reputational
damage so small office payments what we do it

Victoria I am interested in that one

Angela So ever though it's a contract for services and they are not an employer, we
took a decision years ago I think it was Mike Granville who was the author of
that decision at the time. It was that for the smaller offices I say small, where
there is not a lot of business coming through and they are in remuneration
then was less then. If you did the number of hours they opened and the
calculation on minimum wage they were earning less and we then agreed
exceptionally and not under the terms of the contract to top them up to the
minimum wage level, which is always very strange.

Victoria And when you say the remuneration was less than the minimum wage is
that just the remuneration from the Post Office element because obviously
the retail is separate. So you put the 2 together financially it could be

Angela Exactly that is a very interesting point. So it was a decision that was taken to
stop us getting any... we took it to kind of stop any noise which I think is very
silly and not looking for the wrong turn actually Because when you think that
you know we are now being challenged on and we have already been
challenged on the quasi employee status of the contract

Victoria Yes

Angela Which the mains and locals was meant to try to resolve, it was meant to try
put that on a better footing legally.

Victoria It's certainly a lot clearer with mains and locals
Angela It's a bit silly to do it previously.
Victoria But that still happens to date.
Angela I do believe it does. A number of those smaller offices might have changed
oT it would be worth asking the question and Nick Beale will be able to
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Victoria Ok and it's Nick Beale, Chris Graham and was the other one Amanda
Angela Andy Territ
Victoria Sorry got the wrong name. Great. I have got a question about retail
business and in the impact of footfall in more detail. Is that for you?
Angela I think I can answer that one yes.
Victoria So um a bit more about how the Post Office and the retail business and how

footfall between the two. which generates which your views on that sort of
thing I suppose

Angela Right ok. So it's interesting that it might have changed over time ok so the
whole concept of Post Office is what you call the halo effect on retail. So the
footfall that we generate is a massive massive always was attraction to
retailers so particularly in the early days where it was more cash orientated
so customers come in, they get their cash. This is why the Post Office
counters are always at the back of the premises. So when you come into a
Post Office you go up to the counter and get your cash and then you walk
through the retail goods because you will be tempted to buy stuff.

Victoria Oh yes

Angela Yes. So by the time you get to the counter you have now got something in
your hand to pay for and that was massively important to the postmaster.
Now what Post Office didn’t recognise back in those days was actually the
value of that to us as an organisation so we just needed to look at Post
Office as an entity and basically looks at Post Office um the postmasters
could you know do something out of that post office on its own and many did
actually without any retail so if you went in to some post offices that was
more traditional they would have cards, stationary, no separate retail till and
you paid over the counter.

Victoria Yes

Angela Always at the back of the shop. Over the years and particularly as Post
Office profit margin has decreased because we have been squeezed and so
if you go back to when I started working in 1985 pay point wasn’t around, we
didn't have the different courier companies we've got for mails we very much
had a monopoly on lots of our traditional core business. Even though the
only product we actually owned in those days was postal order and we still
had monopoly on everything. So over the years that has changed so the
Post Office remuneration has declined for a number of people so the
volumes might have stayed the same but the actual margin they make on
that individual product has gone down and therefore they rely on the footfall

because the number of customers are still the same but we ” retail. What I
3.41 have dealt with some of the bigger multiple partners it became very evident
for me then as to how important the halo effect on retail was. I have got one
example of where we had I think it was Tottenham way somewhere in North
London we had a branch that closed and relocated into a Co-op I think it
was actually. So Co-op as a convenience store is a very well established it
is a destination store in its own right ok. And when we put this Post Office
into this store the increase it had on their retail was 25%.

Victoria Wow
Angela So that just tells you how important it is. It does depend on obviously the
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type that they sell but 25% uplift on the retail turnover is massive.

Victoria Yes

Angela You've got a very well established retailer. Now that is going back a few
years but I think the point is the same so it is really important. Now what we
have done and we recognise more now particularly with the mains and the
local model is that we have become more of a concession in that overall
5.10 operation depending on the site but if you think of a proper sea store where

they have got the full a offered you've got your bake off, you've got your
coffee, you've got all that kind of stuff general stuff and those are high
margin. If you go in to a really good convenience store they probably would
be earning about 27% they've got a 27% margin of the very good ones. The
ones that are kind of your corner shops and not quite well established are
probably about 15% margin. If you think of we just taking a turnover up by
25% what that does to your margin it is quite impressive so it is really
important.

Was there a supplementary question to that?

Victoria The only one was how is footfall measured if you know about that?

Angela So we measure it through the only mechanism we have to measure footfall
is the transaction data. Years ago we used to particularly in the DMB
network we used to have counters on the door so every time you walk past
the door every time you come into the door and out it registers two on our

counter.
Victoria Oh wow.
Angela So I used to have a little counter on the wall so I could see that we have had

4,000 customers in the branch today. Now we didn’t do that in our agency
network so all we can do is go on to the data. Now what the data tells us is
those people that have actually come and transacted have gone to the
horizon system. They might be people that come in ask a question and
never go through the system and actually some that come in and just go to
the shop but we wouldn't know that.

Victoria And you can tell it's one customer because it's one basket per customer
usually is it on horizon I mean

Angela There would be a number of products within that customer session.

Victoria Yes. That's how you can tell even though its five transactions.

Angela If you wanted to dive into
is the chap (Karl with a K). He has taken that on

for the last few years.

Victoria Ok that’s great.

The next section I've got is training which we have talked about quite a lot
already so if I just have a quick look through and see if there is any specific
points that we need to cover. So we covered the initial training that people
get when they start at the branch but what about training that might be given
during the contract when they are already so for new products

Angela Well it will be for new products or changes to products and depends on what
that change is will drive the type of training. So for instance some products
like lottery we get some face to face training when it goes live and some of

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that would be done by Camelot and again we have covered that in some of
the detail that we have given previously Victoria so

Victoria Yes there's a note on that I think.

Angela - 8.19 Yes so if you refer to that and it's a 2? some of the mediation where they
have an ATM and they weren't happy with the level of training or they had
an ATM two weeks before the training was scheduled and then they told
them to go and stock it and use it before they were trained and similar
situations like that. But broadly if it is something like an ATM which can be
quite involved or could be quite involved we are just about to change some
of the ways of operating then we would do face to face and we always issue
instructions, there's always an instruction manual which will typically well it
would now be on the horizon system as well so back in the day we had an
ops manual which was the bible. When we introduced horizon we basically
just cut and paste the ops guide into horizon which is why horizon online
help is quite clunky. It is just not easy to navigate its way around. We don't
have a search engine which is why we still get the volume of calls into NBSC
that we get. That is something we have tried to address and are looking to
address going forward but there is a big cost attached to doing that but it is
in the mix of how we simplify our transactions. If we get to a place where we
simplify a transaction sufficiently well enough you could argue you wouldn't
need horizon online help ok. So this is where we are trying to get to. As you
design a transaction product and we do this better now in my view than we
did and have still got some products that are quite clunky you design it so
that I could just walk in and just click a button on the screen it would
automatically take me where I needed to go. The more you scan it
automatically pulls through. So it makes it much easier. So there is almost
that chicken and the egg so if you address the root cause so why have you
got a manual that is 500 pages for instance because this is a potential
complexity in that transaction. If you address the complexity by default you
reduce the requirement to have 500 pages. This is continuous improvement
like first time kind of mantra. Get it right first time and you haven't got to do
the work around to correct some of the issues you might have with it. So
just overall then so the type of training is determined by the type of change
or the level of complexity around the product. There might be a new product
might come in for instance you might need to do some new bill payment
client but actually even though the client is new the product is the one we
already do. So therefore we wouldn't do anything face to face and we would
just issue instructions and we would have some easy to use guides and stuff
like that and webcams and stuff we have been doing of late as well.

Victoria Webcams

Angela Yes so little podcasts and video links and stuff and they will be showing you
how to do stuff.

Victoria That is a good idea.

Angela So talk to Kendra on that if you want any information. Kendra will give you
that.

Victoria Ok I've seen Kendra already and she was very helpful actually so if there is

anything more on it I will ask her.

You know you said about horizon online help and the operations manual
previously being printed although there is horizon online help now do they
still have a printed manual in branch do you know or shall I check with
somebody else.

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Angela I don't know. So they might have but it would be quite outdated.

Victoria Ok so the Post Office doesn’t issue a printed one anymore.

Angela I don’t think we do now you'll need to check though so check with Kendra.
Kendra would know that.

Victoria Ok.

Angela Kendra or Gail actually, the one you are talking to next will tell you.

Victoria I've seen Kendra but I'm sure we need to go again but she only had a
couple of hours so hopefully we can see her again in a couple of weeks.
On the training for the new products who would be trained and how would
that be decided? You've already told us about with new postmasters you
would try and involve other people

Angela It depends on the contract that you are on. So under the SBSO the
standard SBSO contract

Victoria Yes I think that is in there.

Angela So whilst we still say I believe again but please check this that the

postmaster or the mains operator local operator the obligation is with them
to train and to ensure that their staff are sufficiently trained we do offer more
assistance in doing that now. So what we do is when we look at the mains
and locals we look at the number of people that are already trained 2?
operator coming into a ready established and some staff would 22 for
instance we look at what the level of training they have had previously and
then how many of those would need to be assessed. We work on the basis
that at least if we could get to at least 50% of their staff members attending
our training that is where we would like to be in distance to the operator or
the postmaster. The issue of the online training is that we can make that
available to a much wider audience which is where I built it. I don’t think we
are using it to the full potential and that is something that I would like us to
work on more going forward is that we make it more conditional on
appointment that if I had my way everybody would have to do that training
not just the postmaster and a percentage of but we are not there yet but that
is something for me to work on going forward.

Victoria Is the online training is it just through any computer or is it through Horizon
terminal

Angela No its through Lync on to any

Victoria Oh any computer

Angela Yes. It's not through horizon actually.

Victoria I didn’t think it would be because I wouldn't have though that those terminals
aren't built for that.

Angela They are not. So it's basically set up so the postmaster applies for .. so

ongoing training typically the induction bit the postmaster applies, they go
through a process, we send them a link and they click on and they can do
the training. Now the way it's meant to work and this is something I don’t
think has been applied as properly as I set it up because when I set this up
originally was you did your online training and it is interactive. Its proper

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training stuff. You read you ask the question they tell you if you pass. It's
set up as you have to pass that before you go in to the classroom training.

Victoria Oh that's a good idea

And if you didn’t pass it wouldn't take you in. So you have to have a certain
level of knowledge to come in and then you do the classroom training was
then set up. This is all on the back of my learning from mediation and the
classroom is set up to reinforce that but so we have more time talking about
and training on the counting element how to balance how to find stuff what
to do if you have an issue all of that stuff. And I also built into that training at
the time the classroom bit was the bit round not using cash for anything
else. So I made it quite explicit the bit I dropped into the training. So then
you have to be competent of that bit before we would let you loose in the
branch and the analogy I always use to explain the reason why I do it that
way is if you think about learning to drive you have to pass your theory and
have driving lessons and then we test you before we let you loose with the
keys. That is how I constructed the training.

Victoria That's helpful.

Angela Now the problem in that is that I don’t think when I came out of so some
things change I mentioned to you before about the period which drew
McBride was in there he started to be responsible for NT targets and
opening offices and he started to play around with that and its one of these
things when I constructed end to end its meant to be end to end you can't
pick and choose because it's the thread that pulls all the way through and I
do believe and although I havent tested this is he tweaked around some of
the stuff I put out in there particular reasons because he didn’t appreciate
why it was in there to put some more sales focus in there. Which is the
watch point for us. Now we put stuff back in by the way and we are doing a
bit of a set, I haven't got a view on it yet in terms of where we have got to
but that is just a watch point for us which is why I flagged that to you in
terms of that time period you know so the claimants that go in ones that
come in in the latter years there is a couple of years I am particularly worried
about because I don't know what I don’t know. That is why I am worried. I
don’t know what I don’t know there to see what that looks like.

Victoria I had a couple of questions about the content of training but I think I should
probably raise those with the people in the training team rather than you.

Angela Who in training are you talking to?

Victoria I've got a meeting with Lee Hile.

Angela — 18.22 That's ??

Victoria Yes. And Paul Smith. Paul! Smith. But I may need to meet some other
people.

Angela You do need to meet other people.

Victoria Do you have any suggestions

I'm meeting Paul Inwood. I've got a list of people whose names have been
suggested against each of these areas by various people and they may or
may not be responsive to the questions depending on how accurate the
suggestions were I was given by other people.

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Angela I can tell you actually if you have got the right people
Victoria Who would you suggest for training
Angela For training this has changed actually the people I would have suggested
have left us so in terms of the central training team is TESREINERIA but in

terms of the index knowledge of the content of the training is that what you

want to get. The content of the training who would I put you in touch with.
Ok. So there is Shey Halstones team there lady caled Alesha

Hassan she used to be a field team leader which was one of the manager
roles in the training. I would suggest talk to her and she would give you a
good feel for the kind of the flow of training over the years but she did drop
out for one and came back but she would be able to tell you who today if
you wanted today who is the best person to talk to because there are some
people that have been there for the duration she would be the best person
to link into.

Victoria Ok that’s great. Basically we are seeing a lot of people and if obviously we
don't get that we want from the people we are seeing we are going to see
more people than we have scheduled to see but it is helpful to have a better
feel of who it should be because that's obviously one we haven't got a good
suggestion on already. So if we put training to one side the next section that
I've got is dealing with problems in branch and shortfalls and we have
touched on this quite a lot already but let's have a look through. The first
question I've got is to do with audits now I do have specific people I am
going to speak to about that but I don’t know whether or not that is
something as formally in charge of training and audits you would like to
speak to. So the sort of information I'm interested in is how the audits are
performed, who carries it out, what report is produced, what opportunities
are given for the sub postmaster at the time to explain the shortfalls and also
the process and how its change if it has re horizon instruction of horizon and
NT.

Angela I think just coming to the end of the last question that is important actually
because the process has changed over the years because in terms of what
the output is in terms of reports because they automated it, they have what
is called a financial , they called it a VAT, very strange

Victoria Yes I have seen something with that at the top.

Angela So in terms of who carried the audit out. So the audits were carried out by
the audit and trainers so this changed so I haven't got the dates but will
have them. So we used to have a separate audit function and a separate
training function they ran in separate teams and then we multi schooled
them and joined them as one team and that would have been when Lyn
was around. It was before my time in that role. Then they were multi
skilled and when I took over the audit and training team they were multi
skilled for the whole duration of my time there which would have been for
about five years I think. They carried out the whole audit. Now these are
the people that did the audit and the training and the beauty of doing the
audit and the training is that they were able to help. So if they went in and
did an audit and they found something and were able to help with the
queries as well. I am not quite sure how to do this to be able to do that. So
that was beauty of doing that. They had a very good working knowledge of
how the whole thing came together so they did just understand the numbers
they understood the transactions to get to the numbers again this was all
very helpful. The way the training was set up is when so when a trainer
went on site you do a transfer of a cash and stock first of all so they show
you how to put all your cash and stock in and then they are with you for 8

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days 10 days or a fortnight as it used to be. They also do balancing with
you as well. So when they do the balancing and then they come back and
they simply come back and do your audit. Not always the same person but
you know typically. So it was quite good. So the audit it's not an audit as in
an audit as some people think. It's not one of the ones that you have got
letters after your name. These are basically just checking cash and stock.
So they are not auditors they are people who verify that we have that cash
and stock that we say on site.

Victoria So they are people who are very competent at using the horizon system as
it should be used.

Angela Yes. Very competent at knowing where post masters could be hiding
money if they try to and why I say that for instance if one of the classic areas
to hide money or to try and hide money but the money isn’t actually there is
to say that you have got £40,000 in the ATM when actually you've only got
£20,000 because the ATM is separate to your accounts stuff and we had a
couple of cases when we did investigations through mediation we saw that
an auditor had forgotten to check the ATM and just taken at face value was
is in the ATM and there has been a deficit which has been hiding in there.
So this is why I said the resolution team like Kath and Shirley because they
are particularly skilled in knowing the ways of how to try to hide money that
isn’t there. So for instance booking out a REM so it leaves your system and
when you go in to verify cash and stock you want to verify what the system
says you have and you have just transferred £20,000 into a cash centre.
But that cash is still there it hasn't been booked in yet so therefore you can't
balance the two books so what we have seen in some places you go in and
do the cash and stock and see that yes that looks fine we've not checked
whether this has been received. And then what they do once they finish
they book it back in or reverse the transaction so the £20,000 shortfall
you've just had in there they've transferred out but transferred it back in so
the £20,000 shortfall but we have never clocked it. We have some
instances where we have seen that we've missed this and when we've gone
back in a second time this is part of the mediation is when you were audited
six months ago and clearly they have not lost that money in six months
because they didn’t have the money this time round. These are things that
lessons learned to build into so when you go into to an audit you make sure
when you check all the stuff before you go in you can see if there is any
postings or once you are there you call off additional reports to make sure
you are getting the full picture.

Victoria Do the auditors have like a guidance note or something?

Angela Yes they always have guidance notes. It's quite clearly documented so if
you talk to who is in in the team now because again it's changed. I am not
sure so Pam Heap is now responsible for that team so you would need to
talk to Pam of who the best person in that team would be to give you the
guidance documents now but there has always been very well documented
guidance around. Its very process driven. You do this this and this and this
is what you get. What I did introduce when I was running that team is the
document which was basically what postmasters could expect on the day of
an audit because what we found is that postmasters didn’t quite know so the
document was issued that says this is what the auditor will do, this is what
you need to do and we used to give that to them and I did actuall
27.05 communicate that across the network at one point to say and I ?? actually
thinking of it because they were saying look you know we have an audit and
actually this one or two pager these are the things you need to know which
they found very very helpful.

So do we have the opportunity to discuss discrepancies you said at the time.

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Yes they do. So what happens is when the auditor goes in they go in and
obviously put the notes up and its closed and then they talk through with the
postmaster what is going to happen but then what they do is they ask the
postmaster to call up all the reports that they need. So we try not to call
them up ourselves if we can help it. We want them to go into the system. It
doesn't always work because one they kind of say I don't know what to do,
some try to play dumb because they don’t want us to find some stuff. That
is evident. I am not just saying that it is evident in terms of what we see.
Others generally don’t know because they have not been hands on.
Sometimes we get there and the postmaster is not there and we have to get
a onetime password we need to get set up on the system so that we can go
in and access the documents and all that is traceable ok. So anyway we tell
them what we are going to do. We tell that at the point at which you need to
be verifying it. So if we are checking the cash we will say to them I am
going to be counting the cash would you like to be here with me to count the
cash and they always recommend that they do. They sometimes say no I
am happy to take your word for it but they have to sign everything but this is
what the findings are. Now we might say actually we are £1,000 short here
do you have any idea where that might be. Are you aware of an error that
might be causing that, we have those conversations at the time. So they are
completely clear on what the output audit is. Whether it is £10 over whether
it is £10 short whether its and they get a copy of that report.

Victoria And has that changed at all over the period that we are looking at so pre
horizon and after horizon and NT contracts.

Angela The format of the report might have changed slightly but in terms of the
basic things that they get no it hasn't they have always had a report. They
have always had the opportunity to discuss discrepancies they have always
been given the opportunity and we stress to them about observing what we
are doing at the time so that they are quite clear that what we are finding is
actually what they can verify as being found.

Victoria And the actual process of the audit pre horizon obviously must have been
different but I don’t know if you are the person to speak to about that.

Angela So the only difference is is how we produce the report. So when you used
to go in on the manual days you basically went in and you just did it
manually you counted it and used and pencil and a rubber and you
transferred it from what... so the cash account so there is a two page
document cash account that listed basically of your ins and your outs and
different tables that tell you right....that was your opening position with cash.
You had these transactions come in, deposits, you had those go out that is
the cash and stock you have got left that’s any discrepancy. So it was quite
as simple as that really.

Victoria I've seen one actually I many years ago had a case with one.

Angela So it's as simple as that. So all we've done with that is we have taken that
paper stuff and we've put it on to an electronic version. So now rather than
go in and count cash and stock because cash and stock are still the same
and you transfer then we had a case sometimes we put on to a piece of
paper and then we transfer that paper onto the system or now I think we go
straight into the electronic system so once the method of recording might
have changed the process itself hasn't changed.

Victoria Because it's physically what is happening in the branch.
Angela Yes. You count the cash, you count the stock, you verify the transactions
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that have been undertaken and you understand what the discrepancy is.

Victoria That's really helpful. I have got a question about when audits are carried out
or what triggers them. Be quite conscious that some of this might be
secretive stuff that we don’t want shared publicly but if you could tell us what

might
Angela We are not secretive about this actually.
Victoria I don’t want to do anything that might tip people off
Angela No we want people to be deterred. It is a deterrent. I don’t want to catch

people. I want them not to do it in the first place. So it's as open as that
really. So the person to get the really in-depth knowledge is Kim Abbots
have you dealt with Kim yet?

Victoria No

Angela Kim Abbots is the ford analysis team and she has been doing that for many
years and she will give you lots of information. But broadly there are
random audits that we just do randomly. Very few of those I think there is
about 100 a year. Now we were talking at one point of stopping that I am
not sure if we have but Kim will tell you if we have or not. And then we have
what we call risk based audits and Kim has a model that she uses which are
some flags for instance its quite heavily manualised albeit it comes off
horizon you have to run different reports and analyse the data and we've got
a system we are working on at the moment which she is quite excited about
which might automate a lot of that basically we have built a system that says
there are a number of factors that would deem it to be an at risk office for
instance we know how much money should be in the branch so we have a
33.02 model ?? if you've got this number of deposits and this number of
withdrawals this is the kind of the working cash you need to be able to
manage that. We would have what we call an overnight cash holding target
for each branch or level for each branch and if we see the branches are
holding more than that then why because it might be that they are just
holding so much cash and we ask them to send it back or it might be that
they are holding more because they actually physically haven't got as much
as they tell us they have got and therefore if they need £50,000 to operate
that branch and they are £40,000 short and they've only got £10,000 so they
need another £40,000 to be able to operate. So there is a number of
triggers and Kim will talk you through that. And then what that does then
generates almost a watch list of between 50 and 100 number of branches
that are at risk and there is a degree at which these are the higher
categories that we are concerned about. Again Kim will tell you how we get
to that. That then forms a schedule of audits that we go to on a monthly
basis. Now the numbers are varied between how many we do I can't
remember what we are doing today but we would have been doing I mean
back when I was, we were doing about 5000 audits a year sometimes
different types of audits you can have audits that are a transfer you
transferred from one branch to the next and therefore you do an audit at the
time and typically our turn rate has been about 10% of our net which we
would always have a good 1000 15000 generated on to the back of that.
You would have the audits you do for randoms. You have your risk based
audits and then you got special audits and these are the ones that
something triggers so it isn't done from the profiling per se something
doesn't feel quite right. So from a conversation somebody might have with a
postmaster or some intelligence we might get in from a third party we do a
special and the special audits are the ones that we arrange in 24 of 48 hours
and we get them quickly but again they are all coded the code names for the
audits Kim will give you all of that and tell you. You might want to see what

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the trend has been over the years in terms of the number of audits and
we've got the data and can pull that for you. You can also if it is relevant
what is the average loss level for each of those audits and we do those by
type so you can see what that looks like as well. Depending on how much
detail you want but Kim is the person that will give that to you.

Victoria

That is really helpful we will definitely see her and build her into our plan.
We've covered all those. It would be quite helpful to talk about what
happens after an audit if there is a loss. We talked a little bit about
suspension, termination shall I just speak to John Breedon about those

Angela

You can do. I can give you a quick overview if you want me to.

Victoria

Yes that would be helpful.

Angela

The auditor goes in does the audit they have a loss typically over £1,000 is
where they need to talk to the contracts adviser. They would then tell the
postmaster that is what they are doing. That they've got a loss and need to
take advice from the contracts adviser. They ring the contracts adviser, the
contract adviser would get the heads up of what's gone on and then they
would talk to the postmaster. They would gather some more facts and then
they would say to the postmaster look I need to look at this and I will come
back to you because I might I am considering whether I need to
precautiously suspend you or not. They do their bit and then depending on
what the level of loss is and what they find and what the cases have been
presented with they will then seek authority from their manager because
they don't have the authority levels to take the decisions it would be John
Breedon or Keith Bridges it is now. It was Lyn Norbury but she has left us to
suspend or not. Then after that there is a series of letters and there is a
process map that is quite clearly defined tells you what the process is and
what the consideration points are in terms of coming to a decision on
whether they should reinstate or whether they should actually terminate the
contract all well documented. If you wanted to look at some example cases
because they record all the decision rationale as well it's all in there. But
that is one of the areas that is really well documented in this organisation.

Victoria

Yes. I have been quite involved with that for the franchise side in the past. I
did quite a lot on that.

Angela

So there is an appeals process as well. I can take you through this as well.
There is an appeals process document in the sub postmaster contract.
There isn’t an appeals process as part of mains and locals but they can
request an audience with senior manager if they feel they have something
they want to discuss and I have actually done that a couple of times with
branches myself actually.

Victoria

Why was that changed if that is something you can talk to the locals and
mains

Angela

What from the appeals process

Victoria

Yes

Angela

Really to put it more on a company to company position because the
appeals process is the quasi employee kind of territory which is where we
wanted to get away from. Now the federation of postmasters hated it and
still hate it which is why we do this kind of catch all which is you have the
right to request a meeting with you know so what we really were doing was
running in parallel process that was never badged as appeal but we give it

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the same consideration.

Victoria Ok. That's helpful. One of the other things that we are looking at as part of
this is to do with the question about sub postmasters not being employees
so things like that are quite helpful that aspect of it.

Angela The whole quasi employee bit worries me actually.

Victoria Oh does it

Angela Yes it does worry me in terms of some of the what I see as anomalies that

we've built into the contracts so the postmaster so the SBSO contract we
have we pay allowances for holiday ?? we pay allowance for sick absence.

Victoria I've got questions on those. So we could cover that now if you want.

Angela So things like that and that whilst we try to do the hands off relationship bit
you are you know you have a contract for services not a contract of
employment and you do this and you do that. There is some muddying of
the waters there. I know we stand on legal position

Victoria Because one of the things that someone I think another firm has been
instructed to do is some advice on that which you........

Angela What we've instructed

Victoria I think so and since we are seeing a lot of people we are doing a bit of
helping that firm on this by asking a few questions on that while we are
seeing people so there are some questions about holiday and sickness
substitution. I was going to speak to Sarah Rimmer about that actually and
Paul Inwood's name is down here as well.

Angela So Sarah Rimmer works in HMSC as part of my team actually and she
would tell you the processing bit of it. Paulinwood would tell you the policy
bit of it.

Victoria Ok. So that sounds like..........

Angela And I will tell you from my experience what we've done.

Victoria Ok. Well I don’t know whether they would be the sort of questions that you

Angela I have been heavily involved in it over the years so

Victoria So why allow holiday and sick substitution

Angela I can't answer that one as it baffles me still. So if you think about it the

contract is a very old contract so that isn’t in the mains and locals so I was
involved in constructing mains and local contracts the SBSO contract was
way before my time and if you look at it. It is one of these it comes back to
us being nice. I just think it's probably the best way I can think. What we
wanted to be able to do and this is my take on this. Because I've asked this
questions why the bloody hell do we do this stuff is what we recognised and
what we wanted to enable the postmaster to do is take a break away from
running the business so what we wanted to be able to do is give them some
financial contribution to doing that to encourage them to do it recognising
that we all need holiday or to take time out and therefore we didn’t actually
and this is where in this case point of legal comes into play. So we didn’t
cover the full cost we made a contribution towards which is why it's an

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allowance. And the same with sick substitution is recognising that for
postmasters recognising that we all get ill at some point and recognising that
it would be beneficial and potentially aid their recovery we paid and to take
the pressure off them financially we made a contribution for them allowing
someone to come in and pick up the work when they weren't able to do that.
So that is my take on why we did that. Some postmasters chose never to
do it. They chose never to claim it because either they couldn't be bothered
to claim it even though they did take time out or they didn’t take time out. If
you are running a small business some people never take time away from
their businesses and sometimes those that never took the time away from
the business are the ones that we had suspicions about. Why would you
never want somebody else to see that part of the or the ones that did but
always came back in to do the balance was always the interesting one. So
these are things like you know we have spoken to people over the years you
know so they might ask them to come in but they might ask one of their staff
members to step up but don’t worry about the balance I'll come in and do it.
So you aren't going to open that safe leave that. And these are the things
that kind of got us thinking about stuff. Sorry I'm digressing on all of this
stuff for you aren't i.

Victoria No that's really helpful I just made sure I didn’t lose my place on this one
while I've got my place on this one.

Angela That is why the holiday substitution and sick substitution is the logic from my
perspective.

Victoria I've got a question about procedure but presumably Sarah Rimmer.

Angela Yes the process and she will give you that. It's worked on a two year cycle.

Victoria Oh ok.

Angela There will be a directive that she will be able to give you that tells you have it

operates and then as R&Ms RBM we were able to exceptionally authorise if
we saw fit and stuff like that. There was kind of an exceptions process.
Even if it is not documented we used to do it.

Victoria Ok. I'm going to speak to her as well about assistance and also Paul I
Smith.

Angela Paul I Smith. Isn't he FSC?

Victoria Yes but his name has been put down for lots of areas I am not sure why.

Angela If it's the one I am thinking of he has been around a long time that is
probably why.

Victoria — 45.28 That might be why. It might be worth asking you just in relation to

assistance about the discretion that Post Office had over whether the
system was 22 ie it didn’t I don’t think.. I don’t know

Angela The only discretion we had this is contractual obligations that they had to be
registered with us on a p250 and they have to be vetted and they had to be
trained although we never short any clarification or confirmation on the
training bit. We took it at trust that postmasters fulfilled their obligation to do
that but we have run an annual check on the p250 the register of assistance
and we basically write out to them and say can you please update our
records and tell us who you have got registered and when we go out to audit
we check to see whether they have actually been registered with us and

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actually whether they have been vetted. Because failure to do that is a
breach of their contract so Sarah will give you the process that we do. We
not to my knowledge have ever in isolation terminated a contract for a
breach of that but we have used it in some of the broader cases where we
have used a number of things to terminate a contract.

Victoria I have used it as part but never on its own.

Angela And particularly where it has been repeat offenders. Because in a number
of cases we just say look get this sorted. Go back again but as a wrap up of
other things which you have been involved in we would have done that.

Victoria And from the businesses point of view why is that important that they are
vetted and so on.

Angela Why is it important. A number of reasons the first one I am going to start
legally is that it is built in to some of client contracts. Particularly our
government ones and even more so now is the training requirement now on
our FCA contract you know our financially regulated ones. There is the
reputational damage it could potentially do you know we are a financial
institution and we are held in very high regard. I think we are probably the
second most trusted brand in the country and we hold that very dear and
actually that is why we are still here in terms of so that is very important to
us. And given obviously trying by doing that to protect the assets for
postmasters and ourselves so you know the criminal records check is really
important. You don't like to employ thieves if we know they are thieves but
obviously we will operate within the law if a conviction is spent and all of that
kind of stuff as well.

Victoria And presumably a postmaster themselves might not I am not even sure if
they would be entitled to a request for checks but they might not be rigorous
enough to request criminal records bureau checks if it was just entirely up to
them.

Angela — 48.27 They wouldn't do it. They don’t like spending money ?? half the time so and

that is just evident people just employ people without doing it and there is a
process by which. Now Senne runs the vetting piece in HMSC she
will give you the detail on it if you need any more details on that because
you know they fill a form and they get vetted we tell the postmaster whether
they have passed or not we don't tell them the reason why because
obviously that's personal data.

Victoria Of course yes. That's really helpful. We are back on to dealing with
problems in branch and shortfalls I am just going to look to see what other
questions I should ask you about that. A lot of it is covered in things that we
have already talked about and I have talked to a lot of other people about
some of these things already I mean I've got questions about disputing
liability for shortfall and what the process was but I have spoken to quite a
lot of people about that already I don’t know if that is something you
particularly felt close to you wanted to speak to

Angela I've given lots of information about the work I've done the last couple of
years. You've been speaking to people like and that have
you?
Victoria I've got their names but I haven't spoken to them. I've spoken to Alison
already.
Angela You absolutely need to have a good day each with Kath and Shirley. You
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might want to do them together actually it's up to you. Kath actually lives in
Swansea so you could have seen her here not that you had enough time
today anyway. So when we did the investigation and whilst I have stepped
out of this for the last couple of years they have still been in here ok so they
are your best people to talk to on all of this stuff. Now I am stepping back
more into this space now and have just released myself from part of my role
50.27 currently so I will be spending more time on this going forward so I will get
myself back into exactly ?? all this information but they will have this and
Kath particularly she just does not forget stuff. So they are the most rich
source of information.

Victoria Because partly what we are trying to get is not necessarily what the process
is now it's almost what the process has been over the years.

Angela That's why I am saying you need to talk to Kath. Kath has been here longer
than me.

Victoria Oh really

Angela Yes. She started about a year before me. She started working on branch,

she was a trainer, she was an auditor and she hasn't had such a broad
experience as me in terms of the operation but what she and Shirley have
both done working with me on the investigation we have made it our
business to know stuff so we have been the source of everything in terms of
getting under the skin of it. so this is why I know I would be on the witness
stand I have to be because where I've been involved in the past in all of the
stuff even some of the mediation scheme but these two have been
investigating everything.

Victoria You're definitely the first person I have seen we are for definite going to
asking to be a witness. Everyone else is sort of depends what they say and
you know what their...

Angela The fact that I have been on the select committee is enough to pull me in.
The fact that I was on the working group, the fact that I set up the
investigation, the fact that I worked on a template of the report, the fact that I
signed off on every single one of them and not one bit of information went
without me saying I was happy with it. I know I have to be there. So even if
I left the organisation tomorrow I know I'm not getting away with it. which is
why I am very keen on stepping back in that because I need to start to get
closer to information and just for reassurance i didn’t make this information
up I don’t need to rehearse it I just need to re familiarise myself with some of
the level of detail that I was operating at a couple of years ago.

Victoria Its vast so you can't be expected to remember it all.

Angela Give me six months and I will be back there it will be fine. I will literally have
everything on the tip of my tongue.

Victoria So this is all to do with disputing shortfalls so I will speak to Kath and Shirley
more about that.

Angela So when you do get to Kath and Shirley do you want to see them together or
do you want to see them apart.

Victoria I think probably apart and it does feel a bit silly asking the same questions to
lots of different people but it's to try and find who is going to be the best
witness for that piece of information

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Angela Why I say it to you is because they feed off each other and it might be
helpful for you to do it together.
Victoria Ok we'll think about it
Angela Give it some thought and then what you might be able to do is you might be

able to get them to kind of go to Chesterfield for two days and they will both
stay overnight it's not a problem and then you can just max two days you
know it's just a suggestion to you

Victoria Kath is Swansea where is Shirley

Angela Glasgow

Victoria Glasgow ok.

Angela But we have got a site at Chesterfield as well havent we

Victoria I spent a good two days there this week

Angela What I am saying is we have got offices there we've got space they stay

across the road in the Portland Hotel which is quite good actually its quite
decent in there and it might work was thinking of practical ways for you to
get the information but what they will do is they will remember stuff together
and they might and for one thing you might get a rather than go and have
one say you need to check then and go back you might just be better with
one

Victoria May be with them specifically it makes sense to see them together but most
of the time we don't want to see people together because we want to know
what that one person what their evidence is not somebody else but if they
sort of are speaking for the same thing

Angela It's a collective though see so Kath and Shirley will have their own personal
information around how they operate but since they came and worked on
the mediation stuff that is a collective. Kath and Shirley are one so they you
know and they have different particular skillset that compliments each other
but they are so connected for me it would just be worth thinking about

Victoria That's really helpful

This whole section is to do with the aspect that I think we should probably be
speaking to Kath and Shirley about so rolling branches trading period and
we have already obviously spoken to FSC about these things’?

55.04 remuneration but it might be quite useful to get your take on why the
postmaster is best placed to establish the cause of shortfall as opposed to
you Post Office. If you agree with that

Angela No I do agree with it. We just need to have a logical way to connect give
you my answer actually. When we enter into the contractual arrangement
with the postmaster it's that we provide them with the pot of money as a
starting position ok. Give you the money that you need to operate we give
you the cash we give you the stock give you all the equipment give you
everything and that is the starting position so providing you do everything
that we ask you to do which is just the practical stuff of how to transact the
project and how to do that balance and things then you should always come
back to where you started so you start with £100 you pay out £50 you take
in £50 you've still got £100. And invoice okay so that’s very simple. Then
we engage them to run that branch and we engage them because they are

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on site and their customers their stock numbers it's our cash and stock and
they are transacting on behalf but they are the people that are close to them.
So only they know what button they have pressed in terms of what button
they intended so we know what button they have pressed but only they
know why they have pressed the button ok because we can't see so if they
tell us that they pressed a button to sell a first class stamp but then they sell
a second class stamp we do not know that until they actually verify their
stock. But then you still don’t actually know that because they are the
people telling us what they have got on site so unless the only way I would
be the best person on behalf of Post Office to do that was if I was in with
them 24/7 so I can't see how we could ever be the best we can help and we
can have a degree of insight because of the way that the horizon system
works and because we can see every key stroke so for instance even if they
declare to us that they have got say they made a cash declaration that they
said they've got £100 we can see behind the scenes that they have taken
six attempts to get to that. Now in that case that could be perfectly innocent
but in other cases it could be very suspicious actually. But what we can also
see is that they are asking the system to tell them how much the
discrepancy is before they make the declaration. We can see that ok. So
what we are best placed to see from the information we have and the
equipment we can use is the process or the way in which they do that we
are best placed to see whether are they taking the long way round or are
there any anonymities

Victoria So we were just talking about Post Office is best placed

Angela So what we are best placed to do and this is really what Kim Abbots does as
well and what we can see and what we are best placed to do is see from not
100% but what we can see is whether that pattern of behaviour looks
normal. So its normal to count your cash and to put it into the machine as
you count your cash. Then you hit the button that tells you what your
discrepancy is and then it is normal if it's not to the penny to go back in and
check it and then to make some adjustments because you've found a
mistake somewhere. What is not normal is to say how much am I out before
I make my declaration unless either you know you've got a discrepancy and
you're not quite sure how much it is and you want to falsify the accounts or
you think well if its within £50 I am not going to bother anyway I'm just going
to take it and just adjust it because I am being lazy. There are a number of
reasons behind but that is what we are best placed to do. They are best
placed to tell us how it is in branch and that’s the trust bit in the relationship.
We trust you to give us the right information and will build our processes to
try and see where we are not getting that accurate information but I can't on
behalf of Post Office as a representative of Post Office possibly say I am
better placed than the postmaster to know what is going on in that branch
because I am not.

Victoria Ok. I think that leads us quite nicely into horizon which would be a good
place to stop.
Angela So are you going to stop there?
Victoria Yes we will. We will stop recording. Breaking meeting at 1.30pm.
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