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Witness name: Rachel Scarrabelotti
Statement No: WITN11120400
Dated: 28 March 2024
THE POST OFFICE HORIZON IT INQUIRY
Fourth Witness Statement of Rachel Scarrabelotti
on behalf of Post Office Limited in the Post Office Horizon IT Inquiry
1. I, Rachel Scarrabelotti, of 100 Wood Street, London, EC2V 7ER, say as follows:
A. Introduction
2. I am Rachel Scarrabelotti, Company Secretary at Post Office Limited (“Post
Office,” "POL" or the “Company”). I joined Post Office in March 2022 and was
appointed as Company Secretary effective 12 April 2022. This is my Fourth
Witness Statement to the Post Office Horizon IT Inquiry (the "Inquiry”). Whilst
not having been employed by the Company during the period in question (the
“Relevant Period”), I feel that given my role as Company Secretary, I am the
appropriate person to provide this witness statement on behalf of Post Office.
3. This Fourth Witness Statement has been prepared in response to a request
made by the Inquiry pursuant to Rule 9 of the Inquiry Rules 2006, dated 6
February 2024 (the "Rule 9(50) Request").
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4. I have aimed to include within this Fourth Witness Statement evidence relating
to all matters or issues detailed in the Rule 9(50) Request insofar as the relevant
facts are within my own knowledge. The facts in this Fourth Witness Statement
are true, complete, and accurate to the best of my knowledge and belief. Where
my knowledge and belief, as set out in this Fourth Witness Statement, has been
informed by another person or by documents that I have reviewed, I
acknowledge that person or those documents. I have been assisted in
preparing this Fourth Witness Statement by Burges Salmon LLP and Fieldfisher
LLP (together "BSFf"), who act on behalf of Post Office in the Inquiry. I have
had online meetings with BSFf to assist my preparation of this Fourth Witness
Statement.
B. Rule 9(50) Request
5. In accordance with the Rule 9(50) Request, this Fourth Witness Statement
intends to address the following:
(a) Induction and/or training arrangements for members of the Post Office
Limited Board;
(b) Codes of Governance for members of the Post Office Limited Board;
(c) The procedures for annual or ad hoc evaluations of Board effectiveness and
the effectiveness of individual Board members; and
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(d) The Accountable’ Officer Functions of the CEO, and of any other person
who was directly accountable to the UK Government, and relevant
lines/structure of accountability.
. It is noted that the Rule 9(50) Request also asks Post Office to submit an
explanation of “any written procedures and policies specifying how
whistleblowing was to be treated within Post Office Limited and any other
relevant organisations including the required escalation and reporting process
within the Board or involving the Board”. This element of the Rule 9(50) Request
is being dealt with as part of a separate witness statement to be provided by
John Bartlett.
. Context
. As previously set out in my witness statement responding to the Inquiry’s Rule
9 Request No. 49 dated 27 November 2023 (‘First Witness Statement” relating
to the “Rule 9(49) Request”) [WITN11120100], the ownership of Post Office
during the Relevant Period can be categorised into the following ownership
structures, being:
1999 — 2001 POL was a subsidiary of the Post Office, a statutory public
corporation
2001 The majority of POL’s share capital was held by Consignia
plc, a holding company owned by the Government
1 Amended from “Accounting” in accordance with the clarification provided by the Inquiry on 11 March 2024.
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2002 -2012 POL was a direct subsidiary of Royal Mail Group PLC?
Royal Mail Group PLC (the operational company) was in
turn a subsidiary of Royal Mail Holdings PLC*
Royal Mail Holdings PLC was a Government owned non-
trading holding company
2012 - 2018 POL was a direct subsidiary of Royal Mail Holdings PLC
(“Separation”) Royal Mail Holdings PLC was a Government owned non-
trading holding company
2018 - 2020 The share capital in POL was directly held by the
Government*
8. As also stated in paragraph 5 of my First Witness Statement, “whilst the POL
Articles set out clear governance requirements, and notwithstanding annual
confirmation that the Royal Mail Holdings PLC Board also applied the principles
of the various iterations of the Corporate Governance Code over the period
2000 - 2012, POL holds limited information on the actual operation of the
governance framework of POL itself prior to 2012”. Each Annual Report for Post
Office from FY2000 - FY2012 is essentially a filing of its statutory accounts, with
no mention of adherence to the Combined Code on Corporate Governance (as
it was known prior to June 2010, and thereafter the UK Corporate Governance
Code) (together the “Code”). The same limitations to the completeness of Post
Office’s records relating to corporate governance apply to its ability to identify
2 Royal Mail Group PLC also variously named Consignia Public Limited Company (January 2001— November
2002) and Royal Mail Group Limited (from March 2007)
3 Royal Mail Holdings PLC also variously named Consignia Holdings Public Limited Company (January 2001-
November 2002) and Consignia ple (January 2001).Royal Mail Holdings PLC changed its name to Postal Services
Holding Company pic in September 2013 (which itself reregistered as a limited company in December 2013 to
become Postal Services Holding Company Limited)
4 Ownership of POL was transferred from the Department for Business, Energy and Industrial Strategy (“BEIS") to
the Department for Business and Trade ("DBT") on 3 May 2023
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potentially relevant materials and respond to the Rule 9(50) Request for the
phases of Post Office’s ownership prior to 2012.
(e) 2012 appears to have been a key year in the evolution of Post Office’s
corporate governance, being the year in which it was separated out from
Royal Mail (April 2012). A ‘POL Governance’ paper dated April 2012 from
the Legal and Compliance Director for a Post Office Leadership Meeting
Update [POL00362126] highlights that it was “necessary to establish POL
with standalone corporate governance processes”. In this context, the
Chair's foreword to Post Office’s “first Annual Report & Financial Statements
for the Post Office as an independent business” for FY2012/2013
[POL00026694] is of note, wherein the Chair (Alice Perkins) states that: “/
have completed the formation of my Board and we are now operating Board
governance in keeping with the best practice in the corporate world®”. Under
the Governance Section® of the same Annual Report, it is noted that “as the
Post Office is not a company whose shares are listed and traded on a public
exchange it is not formally required to report on its compliance with the UK
Corporate Governance Code (the Code). Nonetheless, the Board of the
Post Office believes this is an appropriate benchmark for reporting on
corporate governance. During the year the Post Office has further
established a full Board and Committee structure and has set principles for
good governance which follow the provisions of the Code, so far as they can
° Page 6, Post Office Limited Annual Report and Financial Statements 2012-2013 [POL00026694]
° Page 44, Post Office Limited Annual Report and Financial Statements 2012-2013 [POL00026694]
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apply to a government owned entity which has no private or institutional
external Shareholders”.
9. As set out in Section E, the Code is a key Code of Governance for Post Office
from 2012 onwards, including Post Office's approach to its Director inductions
and Board effectiveness reviews, as explained further in Sections D and F.
D. Induction and/or training arrangements for members of the Post Office
Board
10.Main Principle A.5 of the 2003 Combined Code on Corporate Governance
[POL00413520] states that “...a// directors should receive induction on joining
the board and should regularly update and refresh their skills and knowledge’”.
This requirement is mirrored in the 20088 [POL00409402], 2010°
[POL00413517], 2012'° [POL00413518], 20141 [POL00411067] and 201612
[POL00413519] Codes. Under the Supporting Principles, it is also stated that
“under the direction of the chairman, the company secretary’s responsibilities
include...facilitating induction”. Whilst induction wording is not contained in the
2018 revision of the Code [POL00363146], it is my understanding, however,
that industry practice is for organisations to continue to carry out inductions for
new board members.
7 Principle A.5
® Principle A.5
® Principle B.4
%° Principle B.4
™ Principle B.4
® Principle B.4
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(a) Pre-2012:
11.Following my comments in paragraph 8 above, I have not been able to identify
what processes were in place in respect of Board member inductions at Post
Office before 2012. The exception to this is some email correspondence from
Paula Vennells to Alice Perkins on 21 July 2011 regarding the incoming Chair's
induction’? [POL00409765], as well as an email from Manita Cooper to Alwen
Lyons on 28 February 2012 attaching documents collated for the induction of
Alice Perkins (Chair) and Neil McCausland (Senior Independent Director)
[POL00409853]. See paragraph 17 below.
12.Royal Mail Holding plc's (“Royal Mail”) Annual Reports from FY2004 — FY2012
state that Royal Mail Group had an induction process for its Directors (with no
such reference in its Annual Reports from the start of the Relevant Period up
until 2004), in which they received “information about the Group, the role of the
Board and matters reserved for its decision, the role of the principal Board
Committees, the Group's Corporate Governance arrangements and the latest
financial information about the Group. This is supplemented by visits to key
140
business locations'*". However, these Annual Reports are silent on whether
Royal Mail's board member inductions included any specific information on
Post Office, or indeed whether these processes were replicated at the Post
18 As highlighted in my First Witness Statement, preparatory governance work was undertaken in advance of the
formal separation.
4 For example, page 31, Royal Mail Holdings pic Annual Report 2008 [POL00362172]
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Office Board level. In addition, Post Office’s Annual Reports during the pre-
2012 period do not mention Board member induction or training. It is my
understanding that the Post Office Board during this time was predominately
an executive operational board, and so levels of adherence to the Code may
not have aligned with that of Royal Mail at the time.
(b) Post-2012:
13.Whilst the Royal Mail Annual Reports noted Board director inductions, the first
post-separation Annual Report of Post Office (FY2012/2013) does not.
Moreover, the only Post Office Annual Report post-2012 up until the end of the
Relevant Period to mention Board induction is the one for FY2014/2015
[POL00317841], where it is stated that “all Board members receive a
comprehensive induction on appointment, which includes training on their
responsibilities as statutory directors'>”. However, as per paragraph 9 above, it
was a Stated intention of Post Office that it adhered to the expectations of the
Code. A Board paper from March 2014 indicates that the Post Office Board
reviewed its adherence to the Code with regard to inductions (Principle B.4.1
of the Code), stating that “an induction programme has been developed and is
arranged for all new directors” [POL00030724]. In addition, as noted in the
minutes of a Post Office Board meeting held on 12 January 2012 the
organisation of such inductions was delegated to the Company Secretary
[POL00021503].
'S Page 35, Post Office Limited Annual Report and Financial Statements 2014/15 [POL00317841]
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14. Including the pre-April 2012 inductions mentioned in paragraph 12 above, the
Post Office Board member inductions following separation appear to have
taken a similar format to those provided by Royal Mail, with a series of one-on-
one meetings between an incoming Board member and key members of the
executive or management (usually 45 minutes - 1 hour), visits to branches, the
provision of strategy documents and recent Board papers, and on occasion,
external director training (for example, the induction of Richard Callard, who
subsequently reported positive feedback in respect of the ‘director's course’ he
attended (unspecified) in June 2014 [POL00411014]). The meetings scheduled
for, and documents received by, the incoming Board members varied over time
and also depended on the various committees the new Board member would
be joining (for example, the Chair of the Audit, Risk & Compliance Committee
would have meetings with external audit/assurance parties as part of their
induction programme).
15.In respect of the timing of inductions, the provision of materials and meetings
with other directors and senior executives of Post Office would usually occur
prior to, or within the first few weeks of, the formal appointment of a Board
member. One example of this is the induction of Richard Callard as a Non-
Executive Director (“NED”), who commenced his role as a NED on 26 March
2014, succeeding Ms Storey as the Shareholder NED, and participated in some
induction around 19 February 2014, which was prior to him joining
[POL00410946}.
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16.From at least September 2012, the primary way that key documents appear to
have been provided to incoming Board members was via a Board App (for
example, Diligent'®). The Diligent Board App (“Diligent”) allows for useful
documents to be stored in sub-folders, for ease of access and future reference.
At times, this would be supplemented by emailed materials from the Company
Secretary or their delegate.
17.In 2015, the incoming Chairman, Tim Parker, and after him in 2016 a new NED,
Ken McCall, each received a ‘Governance Pack' and ‘Strategy and
Performance Pack’. The Governance Pack included biographies of Board
members and Group Executive members, the legal ownership and governance
structures of Post Office, key terms of reference and matters reserved to the
Board, the Articles of Association, an overview of director's duties, as well as
future Board meetings dates. The Strategy and Performance Pack covered
topics including the Company’s key performance indicators, profitability and
other financial performance information, key transformation actions including IT
transformation, and key external relationships.
18.The Board induction program was reviewed in 2018 [POL00411940]. As well
as meetings with senior executives, incoming Board members were provided
with the Governance briefing pack described above, and Group policies on
conflicts of interest and anti-bribery and corruption.
16 See, for example, email from Ms Perkins to M Franklin in September 2012 noting that documents, including the
Articles of Association had been made available in his Reading Room, and that further documents such as the
latest Board papers, the Terms of Reference of Board Committees, the latestAnnual Reports and a contact list for
the Executive team would shortly be available to Mr Franklin on his iPad[POL004 10261],
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19.Later documents (from 2020) indicate that the induction pack was reviewed
every six months to ensure that it was up
to date [POL00412937]. This aligns
with the creation of two induction packs, which have been provided to all
incoming Board members since Octobe!
r 2019 (with the documents being
reviewed and updated each time they were issued to a new Board member).
These packs included the following:
Core Induction
Governance:
Material / Group
Post
Governance:
Office Induction Material / Company
(i) Corporate History (i)
(ii) Post Office Group Structure Chart
(iii) Post Office Group Business lines (ii)
(iv) Post Office Group Regulators.
(v) Boards & Executives
(vi) Company Secretariat
(vii) Funding Agreement
Directors’ Duties & Conflicts of
Interest
(viii)
(iii)
(ix) Glossary of Terms
(x) Guidance for Decisions Made Outside
of Board Meetings (iv)
(xi) Code of Conduct for Board Members
(v)
(xii) Director Applicable Group Policies
(a) Conflicts of Interest
(b) Anti-Bribery & Corruption
(incorporating Gifts & Hospitality)
(c) Anti-Money Laundering & Counter
Terrorist Financing
(d) Travel & Expense Policy
Company , Constitutional Documentation
(a) Articles of Association
(b) Framework Document
Governance Documents
(a) Matters Reserved to the Board including
appendices
(b) Audit, Risk & Compliance Committee Terms
of Reference (“ToR”)
(c) Remuneration Committee ToR
(d) Nominations Committee ToR
(e) Remediation Committee ToR
(f) Group Executive Committee ToR
(g) Structure Chart (pending review)
(h) Board Effectiveness Review
Accounts
(a) Post Office Limited Annual Report and
Accounts
Insurance
(a) Group Insurance
Practical Matters
(a) Meeting Dates
(b) Board & Executive Contact list
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20.In June 2021, two Postmaster NEDs were appointed to the Board. It was
proposed that the Postmaster NEDs received director training from an external
provider, had appointed mentors, and were provided with enhanced induction
and information packs [POL00413315].
21.From at least 2015, Board member appointment letters included this statement
(taken from 2015 and 2018 letters): "Induction. After the commencement of
your appointment, the Company will provide a comprehensive, formal and
tailored induction. We will arrange for site visits and meetings with senior and
middle management and the company's auditors and you will be expected to
make yourself available during your first year of appointment (in addition to the
time commitment outlined in paragraph 2.1) for the purposes of the induction.
The company secretary will contact you with further details”.
22.With regards to Board training, I have not been able to identify evidence of any
such training prior to April 2012 pre-separation. In the period post-separation,
Board records (from 2015) show that external providers attended Post Office
Board (and the Audit, Risk and Compliance Committee (“ARC”)) meetings to
deliver sessions on topical issues. For example:
(i) In December 2015, PwC appeared to provide a presentation to the Board
titled "Regulatory training programme: UK Regulation, Individual
Accountability, Culture, Conduct Risk and Outsourcing" [POL00411491 and
attachment POL0041 1492];
17 Appointment letter sent to Carla Stent in 2015 [POL00411494] and appointment letter sent to Ms Khoury-Haq in
2018 [POL00411972].
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(ii) PwC appear to have provided further training to the Board in April 2016 on
financial services [POL00411514];
(iii) Linklaters appear to have provided a financial services training session
immediately following a Board meeting on 25 October 2016
[POL00399586];
(iv) Training appears to have been delivered by Linklaters to the Board on 11
January 2017 on "The Changing Regulatory Environment: The impact of the
senior manager and certification regime on the financial services sector”
[POL00411733 and POL00411735]; and
(v) On 26 May 2020, Jonathan Allen from Amazon Web Services provided a
presentation to the Board on cloud migration [POL00167382].
23.In addition to external providers, there is also some evidence of Board training
being provided internally by the business itself. Examples include the following:
(i) A training session on the status and strategic direction of the IT function was
given on 25 July 2016 [POL00027206];
(ii) A training session on the Mails Market may have been provided at the June
Board away day in 2017, as a result of the 2016 - 2017 Board Effectiveness
Review [UKGI000367 11];
(iii) An update on the legislative and regulatory framework applicable to Post
Office was given to the ARC on 17 September 2017 [POL00411820]; and
(iv)A training session on the General Data Protection Regulation Programme
appears to have been provided to the ARC in January 2018 [POL0041 1937;
POL00391936]
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E. Codes of Governance for members of the Post Office Board
24.For the period prior to April 2012, the information I have been provided with is
very limited both on the operations of the Post Office Board and on the code(s)
of governance by which it operated.
25.Following separation, as highlighted in paragraph 9 above, Post Office
regarded the Code as “an appropriate benchmark for reporting on corporate
governance”.
26.As set out in my Second Witness Statement to the Rule 9(49) Request, the
Shareholder Relationship Framework Document (“Framework Document’) '®
[POL00362299] took effect on 1 April 2020 and whilst not legally binding (save
as to confidentiality obligations), it provides guidance on standards of good
corporate governance, including the standards by which Post Office is expected
to operate in conducting its business. For example, Paragraph 6.9 of the
Framework Document states that “the Chair will ensure that the Board acts with
probity and that appropriate corporate governance structures and controls are
in place in line with relevant governance codes and guidance”.
The Code:
27.As set out elsewhere in this Fourth Witness Statement, the Code has been a
key Code of Governance for the Post Office Board since April 2012 onwards.
18 The Framework Document was entered into between Post Office, the Department for Business, Energy and
Industrial Strategy (“BEIS”) and BEIS's representative, UK Government Investments Limited (“UKGI" or the
“Shareholder’s Representative’).
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28.Paragraph 9.4 of the Framework Document expects that “POL should seek to
comply with the principles and provisions of...the Code”. As stated in paragraph
21(c) of my Second Witness Statement, “POL’s Board regarded the UK
Corporate Governance Code to be an appropriate governance benchmark and
therefore endeavoured to comply with its spirit where appropriate. However, I
am not aware that this was formally recorded in a document dealing with POL’s
corporate governance arrangements in the way in which it is incorporated into
the Framework Document, together with other governmental governance
requirements and guidelines”. Notwithstanding this, it is noted that adherence
to the Code prior to the signing of the Framework Document was stated as
being Post Office’s intention in each of its Annual Reports following separation.
Government Guidance:
29.The reference to “other governmental governance requirements and
guidelines” in paragraph 29 above is to section 9 of the Framework Document
(‘Observance corporate governance guidelines’), which sets out under
paragraph 9.1 that “POL shall have regard to the government-wide corporate
guidance applicable to public corporations listed in Appendix 2: Government-
wide corporate guidance applicable to public corporations and any future
relevant guidance as specified by Government and applicable to POL as a
public corporation'®”.
1® Post Office is classified as a Public Non-Financial Corporation under the Office for National Statistics national
account system with DBT as its sponsoring department.
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30. Appendix 2 of the Framework Document lists the following guidance, it being
noted that the Framework Document refers to Post Office (being a ‘public
corporation’, not a Government department or entity per se) having regard to
such guidance:
(a) Corporate Governance
(i) Corporate Governance Code for Central Government Departments (April
2017)
(ii) Guidance note that supports the Corporate Governance Code (April 2017)
(iii) Code of Conduct for Board Members of Public Bodies (June 2019)
(iv) Management of Risk: Principles and Concepts (July 2019)
(b) Financial Management
(i) Managing Public Money (MPM) (March 2018)?°
(ii) HM Treasury and NAO Guidance on Tackling Fraud (2013)
(iii) HM Treasury Consolidated Budget Guidance (particularly Chapter 11)
(March 2019)
(c) Senior Appointments and Remuneration
(i) Governance Code on Public Appointments (December 2016)
(ii) HM Treasury Guidance for approval of Senior Pay (January 2018)
(d) Other
(i) Whistleblowing Guidance and Code of Practice (March 2015)
20 See Section G for further discussion on Managing Public Money
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31.As noted in footnote 24 to paragraph 21(c) of my Second Witness Statement
[WITN11120200] Post Office “commissioned an external review of its latest
Annual Report & Accounts (the “2023 ARA”, published in December 2023
[POL00363157]) in order to assess reporting alignment with the Code, and
consequently states the following in relation to Code adherence on page 18 of
the 2023 ARA: “While not a listed company, Post Office takes into consideration
the requirements of the 2018 UK Corporate Governance Code (“UKCGC”) and,
where necessary, sets out where certain provisions do not apply. The Post
Office also has regard to the principles of the Corporate Governance Code for
Central Government Departments. Post Office keeps corporate governance
arrangements under review to ensure they remain in line with relevant legal and
regulatory changes, as well as generally accepted principles of good corporate
governance. Examples of where governance arrangements differ for Post
Office from those set out in the UKCGC and the Corporate Governance Code
for Central Government Departments are principally where alternative
governance arrangements apply or because the Post Office is not listed, not a
Central Government Department or not an Arm’s Length Body”. Whilst this is
outside the Relevant Period, it is included in order to provide some context to
the Post Office Board’s adherence to both the Code and Government
Guidance.
32.1 am not aware of similar levels of Codes of Governance observation during the
Relevant Period (with the exception of stated intentions to adhere to the Code).
As highlighted in Section G, prior to the Framework Document identifying
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certain Government Guidelines, it is unclear the extent to which Post Office took
those into account, both pre- and post-separation.
Internal Code of Governance:
33. It is my understanding that since separation Post Office has had its own Code
of Business Conduct (also previously called the Code of Business Standards),
with each version owned by the incumbent Chief Executive, and each time
emphasising the need to ensure that everyone employed by the Post Office
adheres to the Code of Business Conduct and operates in line with it and the
corresponding Group policies [POL00411926; POL00412083; POL00413266;
POL00413265; POL00413268; POL00413267; POL00413270; POL00413269;
POL00413468; POL00413495; POL00413502; POL00411990].
34.The Code of Business Conduct is currently reviewed every year, with
modifications made as necessary and approved by the Board.
NED Appointment Letters:
35.A further indication of the Codes of Governance expectations of the Post Office
Board is contained in each NED’s appointment letter. The following extracts are
taken from Ben Tidswell’s NED appointment letter dated July 2021, with him
being required to exercise his powers in his role as a non-executive director
“having regard to relevant obligations under prevailing law and regulation,
including the Companies Act 2006 and the UK Corporate Governance Code
and associated guidance”. Particular regard is expected to be had to ‘the
general duties of directors in Part 10 of the Companies Act 2006, including the
duty to promote the success of the Company under which all directors must act
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in the way they consider, in good faith, would be most likely to promote the
success of the Company for the benefit of its members as a whole”.
Additionally, there is reference to having “regard to the Financial Reporting
Council's UK Corporate Governance Code and associated Guidance on Board
Effectiveness in respect of the role of the Board and the role of the non-
executive director and to the Code of Conduct for Board Members on Public
Bodies” [POL00363023].
36.1 have also seen NED appointment letters from different years which support
the understanding that adherence to the Government Codes / Guidance was
not in contemplation until close to the Framework Document coming into effect.
For example:
(a) ANED appointment letter for Neil McCausland dated September 2011 (at a
time when a more formal Post Office Board was being established in
anticipation of separation in 2012) states that the NED shall “observe the
terms and conditions of the City Code on Takeovers and Mergers and the
rules of the UK Listing Authority” [POL00362990].
(b) A NED appointment letter for Alasdair Marnoch from May 2015 has the
same wording as that outlined in the 2021 letter (see paragraph above),
except that it does not include the words “and to the Code of Conduct for
Board Members on Public Bodies” [POLO00362995].
(c) A NED appointment letter for Shirine Knoury-Haq dated May 2018 follows
the same wording as the one from 2015 in (b) above [POL00411972].
(d) A NED appointment letter for Lisa Harrington from January 2020 has the
additional wording that is in the 2021 letter (it being assumed that the
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Framework Document had already been largely agreed by this time)
[POL00363015].
(e) It is further noted that a NED appointment letter for Simon Jeffreys dated
March 2023 goes further than the 2021 letter in making specific reference
to the Framework Document: “You shall have regard to the principles set
out in relevant sections of guidance documents set out in Framework
Agreements agreed between the parties from time to time, currently listed
in Appendix 2 of the Company’s ‘Shareholder Relationship Framework
Document” [POL00363048].
F. The procedures for annual or ad hoc evaluations of Board effectiveness
and the effectiveness of individual Board members
37.Principle A.6 of the 2003 Combined Code on Corporate Governance states that
“The board should undertake a formal and rigorous annual evaluation of its own
performance and that of its committees and individual directors,” with the
additional Supporting Principles that (i) “evaluation of the board should consider
the balance of skills, experience, independence and knowledge of the company
on the board, its diversity, including gender, how the board works together as
a unit, and other factors relevant to its effectiveness”, and (ii) “the chairman
should act on the results of the evaluation by recognising the strengths and
addressing the weaknesses of the board”. In addition, “individual evaluation
should aim to show whether each director continues to contribute effectively
and to demonstrate commitment to the role (including commitment of time for
board and committee meetings and any other duties)”. It is then expected that
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“the board should state in the annual report how performance evaluation of the
board, its committees and its individual directors has been conducted”. These
are expectations that are repeated in the 2008 and 2010 Codes. The 2010
Code also introduced the concept that “evaluation of the board of FTSE 350
companies should be externally facilitated at least every three years?’”. The
Principle of ensuring “a formal and rigorous annual evaluation of the
performance of the board, its committees, the chair and individual directors”,
with the Chair acting on the results, as well as the Chair considering an
externally facilitated evaluation every three years continues to be contained in
the 2018 Code as Provision 21, with Principle L stating that the “annual
evaluation of the board should consider its composition, diversity and how
effectively members work together to achieve objectives. Individual evaluation
should demonstrate whether each director continues to contribute effectively”.
(a) Pre-2012:
38. As with the ‘Induction and/or training arrangements for members of the Post
Office Board’ set out in Section D above, it appears that in not committing to
adhere to the Code in the period prior to separation in 2012, Post Office did not
therefore regard Board evaluations as being necessary during that period. This
assumption is supported by an action for the Post Office Board in January 2012,
which was to "establish and [sic] process about reviewing board effectiveness
[POL00409845].
21 The 2014 Code introduced the requirement that the external facilitator should be identified in the annual report
(Provision B.6.2).
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39. Royal Mail Annual Reports do make reference to board evaluations, however it
is presumed that this was to board evaluations conducted at the Royal Mail
Holdings Plc level to which the Code was deemed to be applicable prior to April
2012.
(b) Post-2012:
40.A Nominations Committee paper from the Company Secretary dated 31
January 2013 entitled ‘Evaluation of Board and Committee Effectiveness’
[POL00410532] states its purpose to be to:
(i) “note that a “light touch” form of evaluation of Board effectiveness will
be undertaken within the coming year;
(ii) agree that an evaluation of the effectiveness of the Chairman will be
led by Neil McCausland, as the Senior Independent Director; and
(iii) I agree that a full, externally facilitated evaluation of Board and
Committee effectiveness will be undertaken once every three years,
starting from the financial year 2013-2014”.
41. The first Annual Report of Post Office following separation then states that “the
Board intends to carry out an annual evaluation on the effectiveness of the
Board and of the Board sub-committees. The initial performance evaluation will
take the form of an assessment by the Chairman. External evaluations will be
completed every three years”*”.
42. Notwithstanding the proposal in January 2013 to have an externally facilitated
evaluation in 2013/14, the Company’s FY2013/2014 Annual Report states that
22 Page 47, Post Office Limited Annual Report and Financial Statements 2012-2013
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“a board effectiveness review was carried out in July 2013 in the form of an
informal assessment by the Chairman and Non-Executive Directors. An
appraisal of the personal effectiveness of the Chairman was carried out by Neil
McCausland, Senior Independent Director®*”. The process for Post Office's July
2013 Board Effectiveness Review is set out in a report provided to the Board
prior to the Board meeting held on 16 July 201374 [POL00099210] and involved
the Chair interviewing all Board Directors and the Company Secretary on a one-
to-one basis using a discussion guideline circulated in advance”*, and the
Senior Independent Director conducting a peer review of the Chair's
performance which was fed back to her directly.
43. The proposed format of the 2015 Board effectiveness review is recorded in the
minutes of the Post Office Nominations Committee meeting dated 2 July 2014,
which state that “the Committee agreed that the Chairman should discuss the
next Board effectiveness review with the Shareholder Executive (ShEx) and
recommend a similar internal process” [to that conducted during Summer 2013]
[POL00411154]. The minutes further note that “if ShEx are supportive, a
similar internal review would be undertaken by the Chairman early in 2015
including a review of the Chairman by the [sic] Neil McCausland, Senior
Independent Director’. Whilst I have not found any documentation to
corroborate the involvement of ShEx, the Company’s FY2014/2015 Annual
Report [POL00317841] states that “an internal Board Effectiveness Review
23 Page 51, Post Office Limited Annual Report and Financial Statements 2013/14 [POL000267 16]
24 See pages 1-11 of 111, with a meeting agenda (page 1), the Board effectiveness report (pages 3-9), the
discussion guideline (pages 9-10) and a list of interviewees (page 11). The remaining pages 12-111 are not relevant
for the purposes of this Fourth Witness Statement.
25 See footnote 33 - reference to discussion guideline (pages 9-10)
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was carried out during January and February 2015. The Chairman conducted
one to one interviews with all the Non-Executive Directors, the Chief Executive,
the Chief Financial Officer and the Company Secretary, as well as receiving
written input from the Group Executive. Following completion of the interviews,
the Chairman correlated the results and presented her findings to the Board on
25 March 2015. An appraisal of the personal effectiveness of the Chairman was
undertaken by Neil McCausland, Senior Independent Director. The review
concluded that the Board, its individual directors and its Committees continues
to be effective and that the Directors had the requisite balance of skills,
experience, independence and knowledge to allow them to discharge
effectively their respective duties and responsibilities. No significant areas of
concern were identified. The review did identify some areas where
improvements could be made and, in addressing these, the Board will continue
to review its committee structure and the Group Executive will work on
enhancing the effectiveness of the Board papers. An externally facilitated Board
effectiveness review will be carried out in 201676”.
44. It is my understanding that 2016 was therefore due to be the first year post-
separation that an externally facilitated Post Office Board effectiveness review
was scheduled to take place. However, I have identified very limited information
indicating that the externally facilitated review took place. A key responsibility
of the Nominations Committee is stated in the Company’s FY2015/2016 Annual
Report [POL00242920] as being to “oversee the process of the Board and
26 Page 37, Post Office Limited Annual Report and Financial Statements 2014/15
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Committee performance evaluation?”
and yet there is no specific mention of
the Committee fulfilling this. The Company's FY2015/2016 Annual Report
[POL00242920] notes that “in 2015/16 the Board went through a period of
transition with a change in 50% of its Non-Executive Directors ”®”. In addition, a
Board ‘decision paper’ dated 12 April 2016 on conducting an Effectiveness
Review states on page 2 that "the changes in Post Office Board Directors over
the last year mean that a BER carried out as late as possible in 2016 would
probably be most beneficial“ [POL004 11511]. In the following year, an external
Board evaluation was commissioned.
45.In November 2016 Lintstock Ltd conducted an external review of the
effectiveness of the Post Office Board. A Board review overview document
prepared by Lintstock sets out the two phases of the review, including the
survey and presentation of findings. The Lintstock document refers to the
process of designing the effectiveness review survey and sets out that the
review content was designed ‘in close collaboration with the Chairman and
Company Secretary ... allowing questions to be framed around key events”.
And that “the review covers the performance of the Board, its Committees, the
Chairman and individual Directors”. Directors were requested to complete
surveys online [POL00103264].9 Lintstock then delivered “a report composed
of concise narrative, with supporting graphical data, including a series of key
recommendations and one-page executive summary” [POL0041 1661].
27 Page 28, Post Office Limited Annual Report and Financial Statements 2015/16 [POL00242920].
28 Page 24, Post Office Limited Annual Report and Financial Statements 2015/16.
28 Pages 37-41
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46.In January 2017, the Post Office Board was provided with a Board
Effectiveness Review paper which refers to the Board completing “an external
Board Effectiveness Review facilitated by Lintstock Ltd” in December 2016 and
to the post-review exercise conducted by Post Office. Post Office's Senior
Independent Director, Ken McCall, was said to have worked with the Company
Secretary and “analysed the feedback and proposed 4 actions in response to
the review”. In summary, the actions were to “(i) provide more focus on
performance results and future actions; (ii) increase the Board’s understanding
of the Mails Market; (iii) enable more support for the Board to give assurance
regarding the IT strategy decisions and IT transformation tracking ; and (iv) ARC
to focus more on reviewing the Internal Audit work*°”. This was reported in the
Company's FY2016/2017 Annual Report [POL00026839] as follows: “During
2016/17 an externally facilitated Board Effectiveness Review was undertaken,
with the results reported to the Board in January 2017. The overall results from
the review were positive, with some areas identified for further work. The Board
agreed to the implementation of the resulting recommendations, which included
the Board receiving greater support when making decisions on IT strategy and
the Audit, Risk and Compliance Committee having a greater focus on the
review of internal audit work?"”.
47. The financial year ending 2018 was another year where no Board effectiveness
review was conducted in respect of the Post Office Board and its committees.
The Company’s FY2017/2018 Annual Report [POL00259704] addressed the
lack of a review, stating that “an internally facilitated review was not carried out
% See page 1 of the Board Effectiveness document first referred to in paragraph 24(ii).
31 Page 26, Post Office Limited Annual Report and Financial Statements 2016-2017.
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in 2017/18 as it was decided to defer this until the new Non-Executives were in
place*?”.
48.An internal Board effectiveness evaluation was conducted in the financial year
ending 2019°°. This included formal evaluation of the performance of the Board,
its Committees, and the Chair by way of an internal online (Diligent)
questionnaire circulated to Board members, with respondents requested to
score answers numerically (1-5) and by making free text comments
[POL00412210], as well as a discursive evaluation of the Chair by the NEDs
facilitated by Ken McCall, Senior Independent Director, who thereafter (it is
believed) provided feedback to the Chair, UK Government Investments Limited
(“UKGI") and the Permanent Secretary at the Department for Business, Energy
and Industrial Strategy.
49.During financial year 2019, the Chair completed performance appraisals for
those NEDs seeking reappointment to the Board (being Carla Stent and Ken
McCall (SID)). Performance appraisals were performed at the request of UKGI
and involved the Chair providing each NED with a template appraisal form
against which their performance was to be assessed [POL00412186] and
shortly thereafter conducting an appraisal individually (by telephone). As part
of the appraisal process, the Chair also sought feedback on the performance
of the two NEDs from all NEDs. It is my understanding that the completed
appraisal form would have been provided to UKGI as part of the application to
%2 Page 23, Post Office Limited Annual Report and Financial Statements 2017/18
58 Page 22, Post Office Limited Annual Report & Consolidated Financial Statements 2018/19 [POL00026927]
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the shareholder seeking approval of the reappointment of Carla Stent and Ken
McCall.
50.Changes to the POL Board composition was attributed as the reason for not
engaging an external facilitator to conduct a Board and committee review for
financial year ending 2020. An internal evaluation was therefore undertaken,
adopting the same process as the previous year, including that the Board
questionnaire mirrored the questions used the previous year [POL00412909],
to permit comparison across years with additional questions to reflect areas of
particular focus for the organisation.
51.At this time there was also a formalised self-assessment performed by the Chair
[POL00412894], feedback on the Chair's performance provided by the
Permanent Secretary, and the Chair's performance was appraised by way of
an online questionnaire [POLO0412893] and discursive feedback sessions,
facilitated by Ken McCall and separately involving the NEDs and the Group
Executive. Further, it is my understanding that the Chair's performance
appraisal process culminated in a meeting between the Shareholder
Representative NED, SID, and the Chair and thereafter a report was prepared
by the SID for UKGI/BEIS. For the financial year ending 2021, another
externally facilitated Board and committee effectiveness review was conducted.
Independent Audit Limited undertook “a review of board and committee papers,
observation of board and committee meetings and interviews with board
members and managers who interact regularly with the Board*4”. It is also my
* Page 27, Post Office Limited Annual Report & Consolidated Financial Statements 2020/21 [POL00363149]
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understanding that Independent Audit had interviews with “representatives of
stakeholders at the Department for Business, Energy and Industrial Strategy
(BEIS),” all of which culminated in a 24-page report.
52.With regard to the annual appraisal of Executive Directors, as explained at
paragraph 8 above, it has not been possible to identify from a review of
documents the process that was in place prior to 2012. The Annual Reports
for Post Office contain very limited information beyond statutory filing
requirements and a Post Office Remuneration Committee (“RemCo”) had not
yet been established. However, each post-separation Annual Report
(FY2012/13 — FY2020/21) indicates that the Remuneration Policy on the Short
Term Incentive Plan (“STIP”) in which the Executive Directors participated, was
that “80% of the STIP award is based on the balanced scorecard and 20% is
based on individual performance objectives which are agreed with the Board
and will require approval by the Special Shareholder” (page 51 of the
FY2012/2013 Annual Report, which sets out the Post Office Remuneration
Policy). It is also my understanding that the annual appraisal of Executive
Directors was undertaken in conjunction with the RemCo. For example, the
RemCo paper on Post Office Short Term Incentive Plan Outturn and Payments
for 2014/2015 in the RemCo meeting pack for its meeting on 13 May 2015 notes
at paragraph 3.3 that ‘it has been determined that the Chief Executive has
achieved 80% of her personal objectives” [POL00228363]. Whilst I have not
been able to identify any documents to evidence appraisal meetings having
taken place, the percentage achievement against the Executive Directors’
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personal objectives suggests that some form of annual Executive Director
appraisal was considered post-2012.
G. The Accountable Officer Functions of the CEO, and of any other person
who _ was directly accountable to the UK Government, and_ relevant
lines/structure of accountability
53. The Framework Document sets out a number of key roles and accountabilities
for the shareholder (the Department of Business and Trade (“DBT”)), the
Shareholder’s Representative (UKGI) and Post Office in respect of Post Office’s
corporate governance. As at the date of submitting this Fourth Witness
Statement, I am not aware of documentation setting out similar levels of detail
on roles and accountabilities in the period prior to March 2020.
54. One such role is the Shareholder’s Principal Accounting Officer, being the DBT
Permanent Secretary (the “PAO”), who is accountable to Parliament in respect
of Post Office and is responsible for ensuring that arrangements are in place
for effective Shareholder oversight of Post Office.
55. Post Office being a “Public Corporation”, the PAO has, since around June 2019,
designated Post Office’s Group Chief Executive (“GCE”) as Post Office’s
Accountable Officer and consequently expects the GCE to observe the
principles set out by HM Treasury in Managing Public Money (“MPM”)
[POL00363159], with particular regard to the Standards Expected of the
Accounting Officer's Organisation summarised in Box 3.1 of MPM and set out
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in full at Appendix 1 of the Framework Document. These standards are also set
out in full in a letter to Nick Read from the PAO dated 6 September 2019 upon
his appointment as GCE [POL00288398]. I note this letter appears to pre-date
the inclusion in MPM of a recommendation for Government Departments to
consider appointing the chief executive of a public corporation as an
‘accountable person’. It appears that MPM was not updated with this
recommendation until May 2021.°5
56.Correspondence from as early as 2018 highlights that the possible terms of a
Framework Document were being set out and discussed well in advance of it
coming into effect in March 2020. This includes a Framework Document High
Level Issues List [UKGI00022411] showing Post Office comments of 6
February 2019 and UKGI’s responses of 6 March 2019°°. In this document
Post Office references the ‘Accounting Officer's’ “responsibilities under Chapter
3 of ‘Managing Public Money” and notes that “broadly, these responsibilities
are similar to those one would normally expect of a CEO“. The UKGI response
column contains the following: “HMT have informed BEIS that technically it is
incorrect for the Perm Sec to designate the CEO of POL as an “Accounting
Officer” (AO) because as a public corporation (PC) money flows to POL through
a BEIS grant rather than directly from parliament. However, the Perm Sec
should still delegate (in writing) similar accounting functions to the CEO so that
the principles of HMT’s Managing Public Money (MPM) flow to POL in its use
of grant funds and public money generally. HMT calls this position an
35 Compare the version updated in September 2019 [UKGI00018351] with that published in May 2021
[POL00413475]
%6 Issue 7 of the Framework Document High Level Issues List
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“Accountable Officer’ to distinguish it from AOs. However, in practice
accounting duties are almost identical since they are based on MPM. The
language in POL’s Framework Doc will reflect this, as will the formal letter from
the Perm Sec to the CEO delegating those accounting duties”. This appears to
have been the origin of the concept of an ‘Accountable Officer’ in the
Framework Document, and to explain the sending of the letter to Nick Read in
September 2019. It also appears to support the understanding that MPM did
not apply to Post Office directly but rather by virtue of bespoke arrangements
with the shareholder from 2019, including in particular from March 2020 under
the Framework Document. Prior to these arrangements I am not aware of any
requirement for Post Office to have had an Accountable Officer (see paragraph
33 above).
57.It appears that a letter relating to the Accountable Person also exists for Alisdair
Cameron's interim role as GCO from April 2019 to September 2019 (following
the departure of Paula Vennells and prior to the arrival of Nick Read), however
I have not been able to locate a copy. My assumption is based on an email
within an email chain (without attachments, therefore) that is from Tom Aldred
(Post Office Shareholder Team, UKGI) to Alisdair Cameron on 11 June 2019
stating: “A while ago we discussed your designation as Accounting Officer
(email below). Please find attached a letter from the BEIS Permanent Secretary
designating you as the "Accountable Person" to whom he is delegating
accountability for managing POL's public funds in line with the principles of
HMT's Managing Public Money (MPM)> [POL00412866]. I have not been able
57 It is also noted that the same email goes on the state the following: “As regards the “Accountable Person’ title,
HMT have advised that this is how CEOs of public corporations like POL are now to be designated (“Accounting
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to identify any reference to a similar letter to Paula Vennells, and nor did I
identify documents suggesting one exists.
58.As set out in paragraph 25 of my Second Witness Statement, it is my
understanding that Post Office addressed the need to comply with the
requirements of the Accountable Officer role under MPM by way of a report
presented to the ARC confirming how the responsibilities of the Accountable
Officer were met for the relevant financial year (with a report sometimes being
provided during the financial year also) [POL00413174].
Statement of Truth
I believe the content of this statement to be true.
Signature:
Date: 2¢ Marth 224
Officers” is only for ALBs) as they receive over 50% of their income from commercial activities, and therefore do
not get funding directly from Parliament (via the “Estimates’) meaning that accountability can only flow to POL via
the Perm Sec. In practice, the functions are the same as HMT requires both Accounting Officers and Accountable
Officers to follow MPM principles”.
Page 33 of 50
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Index to Fourth Witness Statement of Rachel Scarrabelotti on behalf of Post
Office Limited
RN
Document
Description
Control Number
POL00362126
POL Governance
paper dated April
2012
POL-BSFF-0190636
POL00026694
Post Office Ltd -
The Fabric of our
Society Annual
Report and
Financial
Statements 2012-
13
POL-0023335
POL00413520
UK Corporate
Governance Code
2003
POL-BSFF-0233700
POL00409402
UK Corporate
Governance Code
2008
POL-BSFF-0233610
Page 34 of 50
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POL00413517
UK Corporate
Governance Code
2010
POL-BSFF-0233697
POL00413518
UK Corporate
Governance Code
2012
POL-BSFF-0233698
POL0041 1067
UK Corporate
Governance Code
2014
POL-BSFF-0233635
POL00413519
UK Corporate
Governance Code
2016
POL-BSFF-0233699
POL00363146
UK Corporate
Governance Code
2018
POL-BSFF-0191149
10)
POL00409765
Email from Paula
Vennells to Alice
Perkins dated 21
July 2011
POL-BSFF-0233611
Page 35 of 50
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11
POL00409853
Email from Manita
Cooper to Alwen
Lyons dated 28
February 2012
POL-BSFF-0233614
12
POL00362172
Royal Mail Holdings
plc Reports and
Accounts Year
Ended 30 March
2008
POL-BSFF-0190682
13}
POL00317841
POL Annual Report
and Financial
Statements
2014/15
POL-BSFF-0155891
14
POL00030724
POL Board paper
dated March 2014
POL-0027206
15
POL00021503
POL Board minutes
from 2 January
2012
POL0000036
16)
POL00411014
Email chain
between Alwen
POL-BSFF-0233634
Page 36 of 50
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Lyons and Larissa
Wilson dated 11
June 2014
17I
POL00410946
Email from Neil
Hayward to Paula
Vennells, Chris
Day, Martin George
and others dated 19
February 2014
POL-BSFF-0233633
18)
POL00410261
Email chain
between Helen
Perkins and Tim
Franklin dated 24
September 2012
POL-BSFF-0233627
19)
POL00411940
Email chain
between Paula
Vennells, Jane
MacLeod and
Alisdair Cameron
dated February
2018
POL-BSFF-0233659
Page 37 of 50
20)
POL00412937
Email from
Rebecca Whibley to
Tim Parker, Tom
Cooper, Ken
McCall, Zarin Patel,
Nick Read, Alisdair
Cameron and Carla
Stent dated 11 May
2020
POL-BSFF-0233679
21
POL00413315
Email chain
regarding
Postmaster NED
induction dated 10
March 2021
POL-BSFF-0233690
22
POL00411494
Appointment letter
of Carla Stent dated
2015
POL-BSFF-0233642
23}
POL00411972
Appointment letter
of Shirine Khoury-
Haq dated May
2018
POL-BSFF-0233661
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24
POL00411491
Email chain
between Garry
Hooton and Jane
MacLeod dated 6
January 2016
POL-BSFF-0233640
25]
POL0041 1492
PwC presentation:
"Regulatory training
programme: UK
Regulation,
Individual
Accountability,
Culture, Conduct
Risk and
Outsourcing"
POL-BSFF-0233641
26
POL00411514
Email chain
between Jane
MacLeod and
various at PwC
dated April 2016
POL-BSFF-0233644
27
POL00399586
Email from Alwen
Lyons to POL
POL-BSFF-0226256
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Board dated 4
August 2016
28I
POL00411733
Email from Ben
Gray to Angela van
den Bogerd dated 6
July 2017
POL-BSFF-0233649
29)
POL00411735
Linklaters
presentation: "The
Changing
Regulatory
Environment: The
impact of the senior
manager and
certification regime
on the financial
services sector"
POL-BSFF-0233651
30)
POL00167382
POL Board minutes
26 May 2020
POL-0161322
31
POL00027206
POL Board Agenda
dated 25 July 2016
POL-0023847
Page 40 of 50
32)
UKGI00036711
Board Effectiveness
Review for meeting
date 31 January
2017
UKGI045606-001
33)
POL00411820
An Overview of the
Legal and
Regulatory
Framework at Post
Office to ARC dated
25 September 2017
POL-BSFF-0233653
34
POL00411937
Minutes of POL
Risk and
Compliance
Committee meeting
dated 18 January
2018
POL-BSFF-0233658
35]
POL00391936
POL Risk and
Compliance
Committee Agenda
dated 18 January
2018
POL-BSFF-0218823
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36I
POL00362299
Framework
Document entered
into between Post
Office, the
Department for
Business, Energy
and Industrial
Strategy and UK
Government
Investments Limited
POL-BSFF-0190809
37I
POL00363157
Post Office Limited
Annual Report &
Accounts 2022-23
POL-BSFF-0191160
38}
POL00411926
Code of Business
Standards V1
POL-BSFF-0233654
39)
POL00412083
Code of Business
Standards V2
POL-BSFF-0233663
40
POL00413266
Code of Business
Standards V3
POL-BSFF-0233685
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41 POL00413265 Code of Business POL-BSFF-0233684
Standards V4
42 POL00413268 Code of Business POL-BSFF-0233687
Standards VS
43) POL00413267 Code of Business POL-BSFF-0233686
Standards V6
44 POL00413270 Code of Business POL-BSFF-0233689
Standards V7
45] POL00413269 Code of Business POL-BSFF-0233688
Standards V8
46I POL00413468 Code of Business POL-BSFF-0233691
Standards V9
47 POL00413495 Code of Business POL-BSFF-0233695
Conduct v 10
48) POL00413502 Code of Business POL-BSFF-0233696
Conduct v 11
Page 43 of 50
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49I
POL00411990
Code of Standards
Pre 08 01 18
POL-BSFF-0233662
50)
POL00363023
Ben Tidswell
appointment letter
dated July 2021
POL-BSFF-0191052
51
POL00362990
Neil McCausland
appointment letter
dated September
2011
POL-BSFF-0191023
52)
POL00362995
Alasdair Marnoch
appointment letter
dated May 2015
POL-BSFF-0191028
53)
POL00363015
Lisa Harrington
appointment letter
dated January 2020
POL-BSFF-0191044
54
POL00363048
Simon Jeffreys
appointment letter
dated March 2023
POL-BSFF-0191077
Page 44 of 50
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55]
POL00409845
POL Governance
summary authored
by Susan Crichton
dated January 2012
POL-BSFF-0233612
56
POL00410532
Evaluation of Board
and Committee
Effectiveness dated
31 January 2013
POL-BSFF-0233632
57I
POL00026716
Post Office Limited
- Annual Report
and Financial
Statements for
2013/14
POL-0023357
58
POL00099210
POL minutes dated
16 July 2013
POL-0098793
59I
POL00411154
Post Office
Nominations
Committee dated 2
July 2014
POL-BSFF-0233636
Page 45 of 50
WITN11120400
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60}
POL00242920
POL Annual Report
and Financial
Statements
2015/16
POL-BSFF-0080983
61
POL00411511
Board Effectiveness
Review — Decision
paper dated 12
April 2016
POL-BSFF-0233643
62)
POL00103264
Linstock online
survey
questionnaire
POL-0102847
63}
POL00411661
Linstock Post Office
Board Review
Overview 2016
POL-BSFF-0233647
64I
POL00026839
Post Office Limited
Annual Report and
Financial
Statements 2016-
2017
POL-0023480
Page 46 of 50
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65
POL00259704
Post Office Limited
Annual Report &
Financial
Statements
2017/18, presented
to parliament
pursuant to section
77 of the Postal
Services Act 2000
(registered number
2154540)
POL-BSFF-0097767
66
POL00026927
POL Annual Report
& Consolidated
Financial
Statements
2018/19
POL-0023568
67
POL00412210
2018 Board
Evaluation
Questionnaire
template
POL-BSFF-0233666
68I
POL00412186
Annual
performance
POL-BSFF-0233665
Page 47 of 50
discussion: Non-
Executive Directors
template
69I
POL00412909
Board Evaluation
Questionnaire
2019/20
POL-BSFF-0233678
70)
POL00412894
Email chain
between Veronica
Branton, Tom
Aldred and Tom
Cooper in January
2020
POL-BSFF-0233675
71
POL00412893
Chairman
Feedback template
POL 2019/20
POL-BSFF-0233674
72
POL00363149
POL Annual Report
and Financial
Statements 2020-
2021
POL-BSFF-0191152
Page 48 of 50
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73I
POL00228363
RemCo meeting
pack for its meeting
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