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Witness name: Melanie Park
Statement No: WITN11600100
Dated: 22 August 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF MELANIE PARK
ON BEHALF OF POST OFFICE LIMITED IN THE POST OFFICE
HORIZON IT INQUIRY
I, Melanie Park, of 100 Wood Street, London, EC2V 7ER, will say as follows:
INTRODUCTION
1 I am the Central Operations Director within Post Office Limited (“Post
Office”). I report into the Interim Chief Operating Officer, Neil Brocklehurst
and am a member of the Post Office Leadership Team. My areas of
responsibility cover the Branch Support Centre, the Network Monitoring
and Reconciliation Team, the Network Support and Resolution Team, the
Branch Planning, Operations & Communications Team. All of these exist
to provide operational support to branches.
2 This witness statement has been prepared to assist the Post Office Horizon
IT Inquiry (the “Inquiry”) with matters set out in two requests made by the
Inquiry under Rule 9 of the Inquiry Rules 2006:
(a) Rule 9 Request 57 dated 12 June 2024 (“R9(57)”); and
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(b)
Rule 9 Request 58 dated 2 July 2024 (“R9(58)”)
(together, the “Rule 9 Requests’).
3 The Rule 9 Requests sought witness statements from individuals presently
involved in the matters underlying questions set out in their respective
Annexes.
4 This statement addresses the questions from the Rule 9 Requests set out
in the table below:
Rule 9 (Questions Section of this Paragraph
Requests istatement which references
addresses them
IR9(57) (Question 4 Civil recovery Paragraphs 24 to 28
IR9(57) Questions 13 to 16 [Branch assurance Paragraphs 56 to 70
isits (“audits”)
IR9(57) Questions 21 to 24 [Civil recovery Paragraphs 29 to 37
IR9(58) [Section D, Investigating and [Paragraphs 99 to 184
(Questions 26 to 34 Iresolving discrepancies
IR9(58) ISection E, QuestionIReduction and Paragraph 98
35
identification of
potential
(discrepancies
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IR9(58) [Section E, Investigating and Paragraphs 185 to 207
[Questions 36 to 40 [resolving discrepancies!
IR9(58) Section F, [Transaction Paragraphs 208 to 217
Questions 41 to 42 corrections
IR9(58) ISection F, Question [Postmaster complaints [Paragraphs 218 to 239
46 policy
5 I understand from Burges Salmon LLP and Fieldfisher LLP (together
“BSFf’), who are assisting Post Office in relation to the Inquiry, that other
Post Office individuals will address the other questions set out in the Rule
9 Requests.
6 This statement is split into the following further sections:
(a)
(b)
(c)
Definitions
Key documents and policies
Civil recovery
Branch assurance visits
Reduction and identification of potential discrepancies
Investigating and resolving discrepancies
Transaction corrections
Postmaster complaints policy
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To make clear which questions I am answering in each part of this witness
statement, I have copied or paraphrased (where clearer in the context to
do so) the relevant questions into the sub-headings of the sections of this
witness statement that answer each question.
The facts and matters set out in this witness statement are complete and
accurate to the best of my knowledge and belief.
Where my knowledge and belief has been materially informed by another
person or by documents that I have reviewed, I acknowledge that person
or those documents.
Throughout this statement I refer to the use of Horizon data. Many Post
Office processes utilise Horizon data as it is a major data source within the
organisation. Other Post Office staff would be better placed than I am to
provide evidence in relation to the technical aspects of the reliability of the
Horizon system.
BSFf have assisted me in the preparation of this witness statement.
DEFINITIONS
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I use the following defined terms in this witness statement (some other
terms are defined in context within the body of this witness statement):
(a) “ARC” means Post Office’s Audit, Risk and Compliance Committee.
(b) Discrepancy is used in the same way as in the Postmaster
Accounting Dispute Resolution Policy and the Postmaster Account
Support Policy [POL00448229] [POL00448000], namely: “any
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(c)
(f)
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difference between (i) the actual cash and stock position of a branch
and (ii) the cash and stock position shown on Horizon as derived
from transactions input by branch staff into the branch's terminals”
which may be negative or positive.
“ClJ” means Judgment (No.3) “Common Issues” in Bates and others
v Post Office Limited [2019] EWHC 606 (QB).
I use “Postmaster” and “Postmasters” to refer to independent
Postmaster businesses operating under a Post Office franchise
contract. Post Office, as a corporate body, operates a network of
over 11,600 branches, the majority of which, save for 114 Directly
Managed Branches, are operated by self-employed, independent
businesspeople and companies’.
“NFSP” means the National Federation of Sub-Postmasters.
“NSRT’ means the Network Support and Resolution Team, which
includes the Postmaster Account Support Team (“PAST”). NSRT
and PAST are described in further detail below in the context of my
response to Rule 9(58) question 26.
“RCC” means the Risk and Compliance Committee.
“Rule 9 Start Date” means 8 July 2013 (I understand from BSFf that
my colleague, John Bartlett, explains the basis for Post Office using
this date at paragraph 83 of his second witness statement).
' Sub-Postmasters and Sub-Postmistresses are both types of "Postmaster’, but a Postmaster can be a limited company,
partnership, or limited liability partnership, as well as an individual that contracts with Post Office as a postmaster in the
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Shortfall is used to refer to a negative discrepancy (i.e., where the
actual cash and stock position of a branch is less than the cash and
stock position shown on Horizon as derived from transactions input
by branch staff into the branch's terminals ).
Transaction corrections is used in the same way as in the Network
Transactions Corrections Policy [POL00460566 ].
namely: "corrections to errors made in branches, or by other Post
Office areas, that have been (i) identified in the reconciliation
between files received from third parties (clients or suppliers), or
cash and stock centres, and the data recorded by the branch in
Horizon, or (ii) caused by mis-keys notified by the branch or a third
party/client, or (iii) to provide funds to the postmaster in some cases
where repayment is required".
KEY DOCUMENTS AND POLICIES
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14
15
I have been asked by BSFf to state that I am not authorised by Post Office
to waive any legal professional privilege that belongs to Post Office.
I understand that the Inquiry wishes only relevant and key documents to
be produced as exhibits to this witness statement. I have sought to take a
common-sense approach to what would objectively be considered key by
reference to the potential for the document to inform the Inquiry or assist
its understanding of my narrative evidence.
At this stage of my evidence, I consider it would assist the Inquiry to explain
that Post Office has a suite of Postmaster Policies, each setting out
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guidelines on how Post Office should support Postmasters (and their
assistants) across a number of key areas. Each policy captures minimum
operating standards that Post Office should adhere to, ensuring that it
meets its business objectives and responsibilities to Postmasters within a
clearly defined risk and governance framework:
(a) Postmaster Onboarding
(b) Postmaster Training
(c) Postmaster Complaint Handling
(d) Network Monitoring and Branch Assurance Support
(e) I Network Cash and Stock Management
(f) Network Transaction Corrections
(9g) Postmaster Account Support
(h) Postmaster Accounting Dispute Resolution
(i) Postmaster Contract Performance
(i) Postmaster Contract Suspension
(k) I Postmaster Contract Termination
(l) Postmaster Contract Termination Decision Review
16 Each of these policies has been produced to the Inquiry [POL00448294];
[POL00448207]; [POL00447972]; [POL00448252]; [POL00448331];
[POL00460566]; [POL00448000]; [POL00448229]; [POL00448204];
[POL00448254]; [POL00448206]; and [POL00448205].
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Each of the twelve postmaster policies are updated by the business on an
annual basis and formally approved for use by the Audit and Risk
Committee (ARC). Prior to submission to ARC, each policy is reviewed and
agreed with the National Federation of Postmasters (NFSP), with feedback
also obtained from the Postmaster Experience Director, a serving
Postmaster working within Post Office. One of Post Office’s Postmaster
Non-Executive Directors will also approve the new policies as a core
member of ARC.
The policies themselves are currently Post Office's internal documents but
a summary of each of the policies is available in the Postmaster Guide to
Policies section of the Postmaster Support Guide [POL00448077]. This is
available to view on an information platform known as Branch Hub,
accessible to all Postmasters.
For completeness I note I am aware of the Common Issues Judgment
Assurance Review dated 31 July 2023 completed by colleagues from
Group Assurance. This identified a number of recommendations. I
understand from my colleague Tracy Marshall that the Retail Team have
provided regular updates to ARC on the improvements implemented to
date, including at the most recent ARC meeting which took place on 1 July
2024.
CIVIL RECOVERY
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Rule 9(57) questions 21 to 24 concern "civil enforcement action". I
understand civil enforcement action to mean the use by Post Office of the
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Courts to require Postmasters to pay sums to Post Office pursuant to a
court order (by consent or otherwise).
At the outset of this section, and before addressing individual questions, I
consider it is important for the Inquiry to be aware that Post Office does not
currently have a team (or any individuals) taking civil enforcement action
against Postmasters to recover Shortfalls shown by Horizon and, for the
avoidance of doubt, at present no civil enforcement action relating to any
shortfalls is being carried out against Postmasters.
While I appreciate that Rule 9(57) question 4 seeks historical data (and I
have addressed that question accordingly), I also understand that, in
relation to Rule 9(57) questions 21 to 24, the Inquiry is interested in the
current position on civil enforcement action. This witness statement is
drafted on that basis. If the Inquiry is interested in the historical position, I
would defer to others who have provided evidence on it during previous
phases of the Inquiry, including current and former Post Office staff such
as Alison Bolsover, Michelle Stevens, Mandy Talbot, Andrew Winn and
Rodric Williams. They might be able to provide some evidence from direct
knowledge (albeit possibly limited due to the elapse of time), whereas I only
joined Post Office in October 2022.
However, I have been told by colleagues from Post Office’s Remediation
Unit there are some extant charges and some repayments being made
relating to legacy civil enforcement activity. I am not able to provide further
detail about that and I am not the person currently involved in any work
within Post Office relating to those facts/matters.
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Rule 9(57) question 4: The number of civil claims pursued by POL based on
Horizon data since the Rule 9 start date, the quantum and the outcome of
those claims including payments of legal costs by parties.
24
25
26
27
I am informed by colleagues from Post Office’s Remediation Unit that Post
Office has some legacy data reflecting Post Office civil enforcement activity
from around and after the Rule 9 Start Date. However, I understand owing
to the incompleteness of records, changes over the years to relevant
team(s) involved in civil enforcement activity and the fact that many of
those individuals no longer work at Post Office, those informing me have
been unable to establish and assure the source(s), completeness and
accuracy of this data.
The data that has been identified indicates that Post Office was successful
in obtaining civil remedies (i.e., County Court Judgments and interim
Charging Orders in Post Office’s favour) against Postmasters in fewer than
100 instances since the Rule 9 Start Date.
However, the Post Office data does not indicate which (if any) of these
claims were based on Horizon data. Additionally, the data does not record
additional claims that were advanced (and potentially issued) in which Post
Office was unsuccessful or obtained remedies without a Court order since
the Rule 9 Start Date.
Accordingly, I cannot affirm that the above information is comprehensive
or wholly accurate. It is the best answer I can provide based on Post
Office's data that has been identified and the information provided by the
Remediation Team.
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28 For that reason, Post Office has reached out to those of Post Office’s
former external advisors that I understand from others were instructed on
this type of activity to ask them to review their records. At the time of
finalising this witness statement, Post Office has not received all the
information it has sought. I will update the Inquiry once I am able to do so,
particularly if it appears to contradict the response I have provided above.
Rule 9(57) question 21: Key guidance, training or instruction (applicable in
any of the four countries of the United Kingdom) given to those responsible
for taking civil enforcement action to recover shortfalls shown by Horizon.
29 On the basis that there is nobody within Post Office currently taking such
civil enforcement action and there has not been since I joined Post Office,
I confirm that there is no such guidance, training or instruction to identify.
Rule 9(57) question 22: The experience, expertise and qualifications of
those responsible for taking civil enforcement action to recover shortfalls
shown by Horizon (or, any minimum level that is required, if any).
30 As Post Office does not currently have any team or individuals taking civil
enforcement action to recover shortfalls shown by Horizon, there are no
relevant requirements of experience, expertise or qualifications to identify.
Rule 9(57) question 23: Which department(s) hold responsibility for making
determinations in relation to the bringing of civil enforcement action against
subpostmasters to recover shortfalls shown by Horizon, and who is
responsible for the management and oversight of that department?
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There is no such current department or team and no such department or
team has been involved in that sort of activity since I joined Post Office.
Rule 9(57) question 24: Key reports, reviews, formal legal advice or
investigations (produced by POL or by an external firm on POL’s behalf)
which address the fairness and / or appropriateness of taking civil
enforcement action against subpostmasters to recover shortfalls shown by
Horizon.
32
33
I cannot give any evidence from direct knowledge in relation to historical
civil enforcement practices at the Post Office as I only joined Post Office in
October 2022, However, I understand from discussion I have had with
colleagues and documents I have seen since I joined Post Office that by
2019 Post Office stopped taking civil enforcement steps to recover losses
from Postmasters. As discussed below in my response to Rule 9(58)
question 26, there are cases where a Postmaster agrees to repay shortfalls
voluntarily and proceeds to do so.
In January 2021, Post Office commissioned Deloitte to review the extent to
which the Post Office had moved towards its goal of “putting Postmasters
at the heart of the business”. Deloitte’s resulting Postmaster Journeys
Report (March 2021) set out a finding at [POL00448058] that:
“Where a branch loss is established, POL processes are not in place
to reclaim such losses. For example, if there is an instance where a
PM intentionally misappropriates POL funds and admits to doing so,
clear and consistent POL processes are not in place to reclaim the
balances accordingly. This creates a risk that PMs are not treated
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consistently and/or fairly by POL, with some PMs choosing to make
payments for established losses, whereas others do not.”
Deloitte recommended that Post Office should “agree a set of processes
for recovering established losses, as per POL’s vision and risk tolerance”.
Post Office has also engaged with other professional advisers in relation
to its conformance with the ClJ’s key legal findings. I understand from BSFf
that Post Office has not waived any relevant legal professional privilege in
relation to that engagement.
Post Office has been reviewing its model for recovering shortfalls, giving a
lot of thought to the unintended possibility of unfairness between
Postmasters (arising from the practice of recovering where a Postmaster
agrees to make repayments but not taking civil enforcement action against
a Postmaster who does not agree to or actually make repayments and/or
from not making that approach fully clear to Postmasters) and ways to
mitigate any such adverse impacts on Postmasters.
The latest status of that work is reflected in a presentation by the Interim
Chief Operating Officer, Neil Brocklehurst to Post Office's Strategic
Executive Group ("SEG") on 17 July 2024 (for which I exhibit the slide deck
at [POL00448362)]). This presentation:
(a) outlined the current model under which shortfalls are recovered with
a Postmaster's voluntary agreement;
(b) identified possible risks associated with the current model, including
that Post Office considers that this model may gave rise to the risk
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of an unfair and inconsistent experience between Postmasters and
is presently reviewing different options to mitigate this risk; and
(c) set out proposed next steps to explore options to mitigate these risks
with a view to making a recommendation to the Board.
(d) As recorded in the meeting notes [POL00448520], these options
(and others) were considered. SEG agreed the recommended
option set out in the slide deck “was the right direction of travel".
Further work and analysis are required before a final decision on the
model can be made.
BRANCH ASSURANCE VISITS (“AUDITS”)
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The Inquiry has used the term “audits” in relation to Rule 9(57) questions
13-16. Post Office does not carry out audits on branches. The Branch
Assurance Team attend a branch to count the physical cash and stock and
establish whether that agrees with what is recorded on Horizon.
This was previously referred to as an audit by Post Office and subsequently
has been referred to as a Branch Assurance Visit. In late July 2024, the
name of these visits was changed (by Post Office’s Head of Operational
Excellence) to “Stock Checks” (see [POL00448356]). However, for the
avoidance of doubt, the scope of these visits has not been narrowed: the
visits encompass more than a simple “stock take” (in the sense of how the
term is usually understood) as they also involve providing support to the
Postmaster. These changes simply reflect changes in Post Office's
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terminology. Please see paragraphs 43 - 56 below for more detail about
the nature of these visits.
I understand from Post Office’s Head of Operational Excellence this is part
of a broader rebranding of the Branch Assurance Team to the Operations
Support Team, intended (among other things) to emphasise the
Postmaster support role which the team members already provide (for
example, as described in paragraphs 45 - 53 below) and training rolled out
in recent years to emphasise the behavioural standards expected of Post
Office staff (for example, as described in paragraph 65 below). I am further
informed by the Head of Operational Excellence that the documentation
used by the team is undergoing review (expected to complete around end-
September 2024) to reflect this. For ease of reference and consistency
with the currently used documentation, which I exhibit, I will continue to use
the term “Branch Assurance” in my witness statement.
The Branch Assurance Team
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The Branch Assurance Team holds the responsibility for conducting cash
and stock checks (Branch Assurance Visits) and this team is headed by
the Head of Operational Excellence. The Head of Operational Excellence
reports into the Director of Retail Operations, Pete Marsh who reports to
the Interim Chief Operating Officer, Neil Brocklehurst. Any changes to
Branch Assurance processes and procedures are approved at the Retail
Committee and any significant changes to the policy are approved by RCC
and ARC.
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There are currently 18 Branch Assurance Advisors who cover all 4
countries of the United Kingdom (see [POL00448224]). The Branch
Assurance Advisors work in pairs to undertake the Branch Assurance Visits
(with 1 person being assigned the role of Lead Branch Assurance Advisor).
The Branch Assurance Advisors report into 2 Team Leaders, who cover
half of the country each, and whose main role is to observe and coach the
Advisors to deliver quality and consistency across all visits. The Team
Leaders report into the Branch Assurance Manager. In addition to this,
there are 3 colleagues whose role is to schedule the visits with the
Postmasters. They are called the Operational Support Administration
Team.
The Branch Assurance Visit
43 A Branch Assurance Visit is performed by the Branch Assurance Team
where:
(a) I Network Monitoring activity has identified stock or cash may be at
risk;
(b) A Postmaster’s contract is terminated (by either party);
(c) Following a security incident where the loss is suspected to be
greater than £5,000, such as a robbery or burglary, at a branch; or
(d) A Post Office colleague has flagged to the Network Monitoring team
a concern e.g. lack of engagement with the cash management team
or a growing amount of excess cash.
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In general, for a business-as-usual risk-based visit, the visit will occur within
5 to 7 weeks. However, dependent on the specific circumstances, we might
choose to expedite the visit. For example, in the case of a security incident
where losses are suspected to be over £5,000, we will aim to complete a
visit within 48 hours so the branch can recommence trading.
The Operational Support Administration Team will attempt to book the visit
and contact the branch in advance to agree a suitable date. The current
position is that, if a Postmaster does not engage with the request for Post
Office to complete a Branch Assurance Visit, the Operational Support
Administration Team will continue to attempt to contact the Postmaster to
agree a convenient time for a visit. If a Postmaster has failed to engage or
cancelled the visit on a number of occasions, Post Office may choose to
notify a branch of a visit date without the requirement to gain agreement
from the Postmaster.
In the past year there have been two unannounced visits which took place
in exceptional circumstances with sign off from the Chief Executive Officer,
Nick Read. These were due to suspected extreme breaches of contract.
Post Office is currently reviewing the circumstances where an announced
visit may not be the most appropriate cause of action. The intention is for
there to be a three-tier process: (i) announced visits (as is current practice);
(ii) notified visits, whereby Postmasters are informed that a visit will be
taking place on a specified date; and (iii) unannounced visits, with a clear
governance protocol as to how and when these may be required. Both
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Retail Committee and the NFSP have approved the proposal, and a paper
will be taken for SEG approval in September 2024.
A rationale document ([POL00448357] is a pro forma version) is produced
by the Network Monitoring Team on the reason a visit has been requested.
This is provided to the Postmaster or their representative both before and
at the outset of the visit. The Branch Assurance Advisors engage with the
Postmaster or their representative throughout the visit and, as a minimum,
will talk through the rationale document. There is a script to ensure the
Branch Assurance Advisors cover certain key points, for example the
purpose of the visit and the support available, although this is still an open
conversation between the Advisor and the Postmaster. A copy of the Script
can be found in Chapter 2 of the Branch Assurance ‘Chapters’ at section 7
[POL00448200]. More information on the importance of the Chapters is set
out below (the Chapters are presently undergoing review by the Head of
Operational Excellence as part of the renaming of Branch Assurance to
Operational Support and to reflect the behavioural expectations
communicated to the team in recent years). Throughout the visit, the
Branch Assurance Advisors will provide regular updates to the
Postmaster.
Branch Assurance Visits are solely focussed on performing a full cash and
cash equivalent stock count, comparing those totals with the balance
recorded on the Horizon system for that branch, and providing support to
the Postmasters. This will identify if there is a discrepancy. However, no
attempt is made during the branch assurance visit to engage with the
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Postmaster around the reasons why that discrepancy may have
occurred.
I am informed by Post Office’s Head of Operational Excellence of the
following practice. No Postmaster’s documents are removed from their
branch as part of a Branch Assurance Visit. The Branch Assurance
Advisors, however, print off reports from Horizon (a branch snapshot) and
use "working papers" to record counted cash and stock. This assists the
Branch Assurance Advisors to compare the counted cash and stock to the
branch snapshot. The working papers and Horizon print outs are then
included in the case file. Post Office is currently digitising this process, so
paper documents can be scanned and uploaded to the case file in
Microsoft Dynamics, before being safely destroyed, to mitigate the risks of
holding paper copies. A copy of a Branch Assurance Visit findings letter
(for which I describe the content in paragraph 53 below) will be left with the
Postmaster on the day of the Branch Assurance Visit. The Branch
Assurance Advisor will aim to send the full visit report by email to the
Postmaster within 48 hours of a Branch Assurance Visit.
In addition to a Branch Assurance Visit, the Branch Assurance Advisor
might also support a branch to improve operational processes via a face-
to-face visit or telephone call.
If a discrepancy is identified by a Branch Assurance visit, the Branch
Assurance Advisor will log on to the branch Horizon system using their own
Horizon ID to update the cash and stock holdings on the branch Horizon
system. As such, the discrepancy is declared and the surplus or shortfall is
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then settled to the final account. This follows a similar process to the review
or dispute (“RorD”) function (discussed below in the Investigating and
Resolving Discrepancies section of my witness statement), moving that
discrepancy onto the branch account following which the business-as-
usual process in the Network Support and Resolution team is started. The
process of reviewing a branch discrepancy by the Network Support and
Resolution team is considered in more detail in response to Rule 9(58),
question 26. If a Postmaster does not agree with the discrepancy
described in the Branch Assurance Visit findings letter, they can dispute
the finding with the NSRT (following the NSRT process described in
response to Rule 9(58) question 26).
During a visit, the Lead Assurance Advisor will give the Postmaster a
Branch Assurance Visit findings letter [POL00448253] explaining the
variance between the total of physical cash and stock found and that
recorded on Horizon i.e. the discrepancy, the support available, the
complaints process and appropriate next steps. The form also gives
Postmasters an opportunity to give feedback on the Branch Assurance
Visit and their experience with the team [POL00448253]. In July 2024, 34
Branch Assurance Visits were completed, and 14 responses were received
to the feedback request. Of these 14 responses, 12 visits were ranked as
‘excellent’, one was ranked as ‘very good’, and one was ranked as ‘good’.
Whilst the terminology has changed (from “Audif’ to “Branch Assurance”
and now to “Operations Support’ visit) the activities of counting the physical
cash and stock in a branch and comparing it to that recorded on the Horizon
system is fundamentally the same. Rather, it is the implications of a
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discrepancy being identified and the guidance as to how Post Office staff
must engage with Postmasters which have changed. As I mentioned
above, if a discrepancy is identified (surplus or shortfall) the balance is
updated on the branch Horizon system by the branch assurance advisor,
which will move the discrepancy onto the branch account and ensure
Horizon, and the physical cash and stock in branch, balance. The
discrepancy will then follow the same review process in the NSRT as when
a Postmaster uses the Review or Dispute function to declare a discrepancy
at trading period end (detailed in response to Rule 9(58) question 26).
It is not the responsibility of the Branch Assurance Advisor to ascertain
from the Postmaster any details of how the discrepancy might have arisen
as this will be done during the Network Support and Resolution review. I
would also like to make clear that no member of any team that might
ultimately investigate a discrepancy arising from a Branch Assurance Visit
will be present during the Branch Assurance Visit.
As illustrated in paragraph 65, Branch Assurance Advisor training is
focussed as much on how they should conduct themselves during a visit,
as the practical steps to carrying out the count. Feedback is requested on
all visits via the Branch Assurance Visit form (see paragraph 53 for recent
examples of such feedback) and action is taken when this feedback
suggests that the conduct of the Branch Assurance Advisor was not in line
with Post Office’s expectations. In addition, Post Office no longer assumes
any shortfall identified is the fault of the Postmaster and/or their assistants
and therefore that they have a liability to repay. Where the Postmaster is
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willing, the discrepancy review process is conducted with input and
collaboration from them, and findings are shared at the end of the review.
I trust that the context in this substantive introduction will assist the Inquiry’s
understanding of my answers to Rule 9(57) questions 13-16, which are set
out below.
Rule 9(57) Question 13: Key guidance, training or instruction (applicable in any of
the four countries of the United Kingdom) given to those responsible for
conducting audits of branch accounts currently in force.
Induction
58
59
60
When a new person joins the Branch Assurance team, they follow a
documented induction training programme [POL00448256], in addition to
their Post Office-wide training. All of the current Branch Assurance
Advisors have had prior knowledge of Post Office operations and
completed the Post Office-wide training. For the avoidance of doubt, the
whole Branch Assurance Team will have completed these training
modules.
Upon joining the team, the new joiner is assigned a buddy who is a more
experienced member of the Branch Assurance Team. The more
experienced Branch Assurance Advisor manages face-to-face interaction
and assurance visits in the first few weeks, with the new joiner observing.
The Branch Assurance Advisor Induction and Training plan
[POL00448256] sets out the training for a new starter. There have been
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no new starters in the team since this was last updated (January 2023) and
it will be updated when next required.
Following the completion of the induction training, the new starter is
assessed (on an informal basis) by their Team Leader, until they reach a
stage when the Team Leader agrees they are able to take lead of a Branch
Assurance visit.
Training or instruction
62
The Network Monitoring and Branch Assurance Support Policy
[POL00448252] contains the principles, risks, controls and procedures
relating to Branch Assurance activity. The process for carrying out a
Branch Assurance Visit is detailed in the Chapters (for example, Branch
Assurance Chapter 2 at [POL00448200]; Branch Assurance Chapter 5 at
[POL00448201]; and Branch Assurance Chapter 6 [POL00448202)),
which are an operating guide for all Branch Assurance work, although the
majority of the training is practical and involves shadowing a Lead
Assurance Advisor and receiving feedback from the Team Leaders. Post
Office’s Retail Engagement Director, Tracy Marshall is the Policy Owner
responsible for making sure that the content is up to date and capable of
being executed. Post Office’s Central Operations Director (currently me)
and the Retail Operations Director, Pete Marsh have joint accountability to
the Board of Directors for the design and implementation of controls and to
manage risk, assure levels of cash and stock and reduce discrepancies
and losses in the network. After each review, the Branch Assurance
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63
64
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Advisors are informed of the key changes and receive annual training on
the Network Monitoring and Branch Assurance Policy.
The Team Leaders provide ongoing support and feedback to the Branch
Assurance team. Feedback and improvement actions are given to
individuals based on the findings. Individuals requiring further development
following a quality assurance review will receive bespoke training.
There is a weekly call to provide team training and updates to the Branch
Assurance Team. This is recorded to ensure anyone absent receives the
same training.
Reflective of the cultural shift within Post Office as to how staff are trained
to engage with Postmasters:
(a) In July 2023, Post Office provided training to members of the Branch
Assurance Team and Contracts Team to reemphasise the
supportive behaviours to be provided to Postmasters and lessons
learned from the evidence provided in the Inquiry’s hearings
[POL00448047].
(b) In May 2024, Post Office launched a charter for the Branch
Assurance Team, which expressly sets out the behaviours the team
is expected to demonstrate in its interactions with Postmasters
[POL00448199].
Rule 9(57) question 14: The experience, expertise and qualifications of
those currently responsible for conducting audits of subpostmasters’
branch accounts (or, any minimum level that is required, if any).
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Whilst the current Branch Assurance Advisors all have experience at Post
Office, this is not a role that requires any professional qualifications and
expertise. As part of the recent rebranding, an updated job description
was circulated to Branch Assurance Advisors [POL00448356]. This
requires the Branch Assurance Advisors to be “Highly skilled in Horizon
day-to-day operations and back-office accounting” as well as have
“proficiency in Microsoft office applications”. The job description also sets
out the soft skills required for this role.
Rule 9(57) question 15: Which department(s) hold responsibility for
conducting audits of subpostmasters’ branch accounts and who holds
responsibility for the oversight and management of that department?"
67
Please see paragraphs 41 - 42 in the introduction to this section, which
answer this question in context.
R9(57) question 16: Key reports, reviews and file reviews, formal legal
advice or investigations (produced by POL or by an external firm on POL’s
behalf) which address the quality of the audits conducted in respect of
subpostmasters’ branch accounts.
68
A Branch Assurance Visit Alignment Meeting takes place every week
between the Heads of and/or Senior Managers from Operational
Excellence (representing Branch Assurance), Network Monitoring,
Network Resolution, Contracts, Training, Assurance & Complex
Investigations and Financial Crime. The terms of reference for this meeting
can be found at [POL00448255]. This forum offers the opportunity to
discuss Branch Assurance Visit findings, and the specific circumstances of
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future Branch Assurance Visits to agree the visit approach. This meeting
enables coordinated support for Postmasters across multiple teams and
introduces an element of case management by bringing together key
stakeholders.
69 Quality Assurance is conducted by Team Managers on all Branch
Assurance Advisors. Feedback and improvement actions are given to
individuals based on the findings [POL00448203].
70 The Deloitte Postmaster Journeys Report [POL00448058] also considered
Branch Assurance Visits. Post Office Group Assurance carried out a review
of ClJ actions which took into account that external advice, amongst other
things.
REDUCTION AND IDENTIFICATION OF POTENTIAL DISCREPANCIES
71 In this section, I have set out a detailed introduction. The context in that
introduction means that I have been able to address the Inquiry’s request
in Rule 9(58) question 35 briefly and should assist the Inquiry's
understanding of the subsequent section (Investigating and Resolving
Discrepancies), in which I address the Inquiry's requests in Rule 9(58)
questions 26 to 34 and 36 to 40. I hope that this approach assists the
Inquiry.
Introduction
72 Since the ClJ Post Office has introduced and improved processes (many
of which are set out in Postmaster Support Policies) to provide Postmasters
with operational support and as such try to reduce the likelihood of potential
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discrepancies occurring (or reducing their severity) in the ways set out in
the next sub-sections.
Risk modelling process conducted by Post Office’s Network Monitoring Team
73
74
Post Office describes the purpose of the Network Monitoring activity as
helping to ensure branches follow the correct operational processes and
as such reduce the likelihood of cash and stock discrepancies occurring,
as well as identifying discrepancies as soon as possible. Network
Monitoring is in place to identify branches where the integrity and accuracy
of cash and stock, in that branch, could be at risk due to a lack of
compliance with the required operational processes. This monitoring
activity can lead to a number of interventions (including Branch Assurance
support)? which are designed to help the branch improve compliance and,
where necessary, resolve any associated issues identified during the
intervention.
The Network Monitoring Team is part of Central Operations and led by the
Head of Network Monitoring and Reconciliation. On a day-to-day basis, the
Operations Manager — Network Monitoring and Support is responsible for
assuring the effectiveness of the processes, tools and activities of the
Network Monitoring team (a Team Leader and nine Advisors). The Network
Monitoring Advisors, supported by the Team Leader, will carry out desk-
based reviews into branch accounts using branch data to identify potential
accounting and compliance issues. They will work with Branch Assurance
Advisors, the Postmaster and other internal and external teams to review
A list of possible interventions is set out below at paragraph77
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any identified issues, explain potential areas of concern, and agree with
the Postmaster solutions to any issues found in order to remedy the
situation [POL00448252].
The desk-based reviews are initiated by the Network Observation
Monitoring Analysis Dashboard (NOMAD) an internally created application
built on SQL Server Reporting Services (SSRS) which assesses
compliance to a number of branch operational processes and ranks
branches most at risk from failure to comply with each process
[POL00448252].° The NOMAD data is refreshed each week and as such
the metric rankings are re-calculated on a weekly basis. The high ranking
branches for each metric are assigned to an advisor to complete the full
desk top review (a case is created for each in Dynamics) in which the
advisor will review trends and patterns for that specific input measure and
consider all of the other metrics in NOMAD in order to understand the full
operational health of that branch and make informed recommendations to
address issues or concerns identified with the Postmaster. All data and
actions taken in relation to that case, including phone calls made to the
Postmaster and the record and results of any visits made, are recorded
against the case in Dynamics.
The Network Operational Risk Model (NORM) is an Excel based model
that monitors metrics focussed on the branch operational processes
designed to help branches identify potential discrepancies in a timely
3 Metrics included in NOMAD data are reversals volume and value; spoilt postage labels; rejected postage labels; cash
bagged up and prepared to be dispatched to the cash centre; cheque adjustments; cheque totals not yet received for
processing; failed cash declarations; differences between declared cash totals and the system generated figure; value of
£100 notes declared on Horizon (should be returned to the cash centre); value of unusable notes declared on Horizon
(should be returned to the cash centre); value of £50 notes declared on Horizon (should be returned to the cash centre);
excess cash; stamp adjustments; and trends in discrepancies.
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manner and, as such, be able to either resolve themselves, in branch, or
seek support from Post Office teams on a timely basis.4 The model
calculates a rolled-up score based on overall branch performance against
each metric allowing for easier comparison with other branches or to track
performance over time. The data in NORM is reviewed as part of the
business-as-usual case review outlined in paragraph 74 above and is also
used to select branches for trials/pilots and to focus the monthly Area
Manager Operational Excellence visits (see paragraphs 82(c) to 82(g)).
Following the desk top review the advisor could make one of a number of
recommendations including (see [POL00448252] page 17 and a letter
template giving advice to a Postmaster following a Branch Assurance Visit:
[POL00448253)):
(a) Calling the branch to discuss a particular issue;
(b) Directing the Postmaster to an online training module specific to the
issue or more general back-office processes;
(c) I Requesting a Field Trainer visits the branch and delivers a face-to-
face training update;
(d) I Scheduling a Support Call or Support Visit from a Branch Assurance
Advisor;
* Metrics included in NORM data are frequency of trading period balance completion; frequency of cash declaration
completion; excess cash value; excess cash frequency; volume of transaction corrections; value of transaction
corrections; volume of transaction corrections by product; Review or Dispute trading period discrepancy volume; Review
or Dispute trading period discrepancy value; in branch trading period discrepancy volume; in branch trading period
discrepancy value; account balance; and, open trading.
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(e) Ensuring the Area Manager/Business Support Manager are aware
of the potential issues;
(f) Requesting a Branch Assurance Visit to assure the value of physical
cash and stock in branch (this process requires the advisor to
complete a rationale document to detail why this course of action is
deemed appropriate); and
(g) Referral to a Contract Advisor for a follow up conversation about
their contractual obligations.
The Network Monitoring Team Managers perform monthly monitoring of
phone call activity between Postmasters and the Network Monitoring team.
The Network Monitoring team, made up of nine advisors, makes on
average 250 telephone calls to Postmasters each period. Team Manager's
monitor four calls for each advisor each period and therefore, on average
14%, of the calls made by advisors to Postmasters are monitored by
Network Monitoring Team Managers. The calls are selected at random and
are assessed against nine specific competencies with a score recorded for
each competency and an overall competency level for the call.5 Post office
also monitors the Network Monitoring Team’s output in relation to the
number of branches monitored within a period and the number of branches
contacted by telephone. First line monitoring of calls is performed by a
Network Monitoring Team Manager and second line quality checks are
5 Network Monitoring Team Managers retain a coaching call log tracker in which are recorded observations by the Team
Manager in relation to the competencies of the advisor and the coaching instructions and actions of the Team Manager.
The nine competencies against which calls are assessed are knowledgeable, issue diagnostics, issue resolution, clear
communication, active listening, confidence, positive language, advocacy and case review. There are five overall
competency levels used: minimum standard, develqping, competent, advanced, and aspirational. Call feedback is provided
to the advisor at their be monthly meeting with their Team Manager.
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performed by the A&CI (Assurance and Complex Investigations) Team.
The A&CI Team conducts monitoring on 5 randomly selected cases for
which the focus is on the way in which the Network Monitoring Advisors
perform their role®. In addition to this, a sample of Dynamics cases are
quality checked by the Team Managers each period. The Dynamics cases
reviewed are chosen to include Branch Assurance Visit rationale
documents and, of the approximately 175 cases per period, 4 cases per
advisor per period are reviewed giving a review pool of approximately 20%
of the total cases.
Branch Assurance Visits
79 A Branch Assurance Visit might be conducted by the Branch Assurance
Team if certain events are triggered. A Branch Assurance Visit enables
Post Office to assure the value of cash and stock in a branch, identify any
potential discrepancy and support Postmasters with an appropriate
intervention as described in paragraphs 38 to 57 above. I have set out more
information on this team and Branch Assurance Visits in the relevant
section above.
Operational Excellence Programme
80 Post Office’s Operational Excellence Programme commenced in June
2023 with its objective being to review and improve the operational support
provided to Postmasters during each stage of their journey with Post Office
(ie., Onboarding, Contracts, training, operating their branch (during the
° The A&Cl team assesses and scores the Network Monitoring team advisors performance against a set criteria relating
to initiating the investigation, conducting the investigation, interaction with Postmaster (to include fact finding calls
conducted with Postmasters), and case closure. An overall score and additional comments are also noted by the A&CI
team.
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first 6 months and after), managing discrepancies and data led
interventions), and to improve the reporting and insight available to Post
Offices about discrepancies. To start the programme, the processes
involved in each stage of the journey were reviewed and those requiring
improvement documented. This resulted in 2 outcomes both aimed at
improving the operational health of branches and reducing the volume and
value of discrepancies [POL00448231]:
(a)
Identification of significant system and process changes requiring
additional funding and separate project status which are monitored,
although not delivered, via the Operational Excellence Programme,
including:
(i) Note counter trial and roll out (see paragraphs 81(a) to 81(b)
below);
(ii) Auto Stock Rem in (see paragraph 81(c) below); and
(iii) I Operational Excellence Incentive (see paragraph 81(d)
below).
and
Overseeing delivery of the functional business as usual
improvement activity delivered within existing resource and budget,
including, amongst others:
(i) Review and relaunch of Operations Manual (see paragraph
82(a) below);
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(ii) Branch on a Page (branch level field management
information) (see paragraph 82(b) below);
(iii) I Operational Excellence visits (see paragraph 82(c) to 82(g)
below); and,
(iv) I End-to-end reporting of discrepancies (see paragraph 82(h)
to 82(j) below).
81 As to those projects supporting operational excellence and requiring
additional budget to deliver (see paragraph 80(a) above), the Operational
Excellence Programme has monitoring, but not delivery, responsibilities for
these. Such projects, that support Post Office’s objective to improve the
effectiveness of back-office processes and as such reduce discrepancies,
are set out below:
(i) Note counter trial
(a) Cash has historically been a significant cause of discrepancies. Put
simply, a discrepancy can arise from the inaccurate processing of
customer deposits and withdrawals and from inaccurate back-office
processes when cash is passing between a branch and Post
Office’s cash centres. Historically, branches transacted a higher
value of customer cash withdrawals than deposits (for example,
paying out benefits and pensions) and as such more cash flowed
from the Post Office cash centres to the branches. However, this
trend has now reversed; exacerbated by the closure of high street
bank branches, cash deposits now outweigh withdrawals. This
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means branches are more at risk from fraudulent activity (i.e.,
counterfeit notes) and from mistakes when counting and returning
these high volumes of cash to the cash centre, both of which could
result in a discrepancy.
To try and mitigate this risk, Post Office is providing note counters
to Postmasters to support them with more accurately transacting
cash, both in and out of the branch, and also identifying counterfeit
notes. Following an increase in the volume of counterfeits being
passed through Post Office branches last year, the Counterfeit
Banknote Taskforce was created, one of the outputs of which was
to commence a 40 branch note counter trial [POL00448231]. This
activity was also supported by feedback from Postmasters who
“consistently raised the importance of note counters to enable them
to accurately and efficiently process growing cash volumes”
[POL00448190]. Following early success and feedback from
Postmasters about the importance of note counters, in March
2024 Post Office made a £3.5m investment to roll out a further 2,782
high-grade note counters for its branches most at risk from cash
discrepancies. Branches have now been selected and contacted to
confirm whether they wish to receive a note counter. Delivery of
note counters is expected to be between August and October 2024.
Post Office estimates the note counter initiative is expected to
reduce current annual losses for recipient branches by 50%
(£1.23M/year) from reductions in branch discrepancies, cash pouch
errors and counterfeit notes. In addition, note counters are expected
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to bring about a time saving benefit to branches with an estimated
value of £2.67M each year [POL00448358]; and [POL00448328].
(ii) Auto Stock Rem-In
The vast majority of Post Office’s stock is postage stamps. Post
Office is developing end-to-end tracking of stamps from Post
Office’s warehouse to branches at an item code level. Auto Stock
Rem-In will enable a Postmaster to simply scan the barcode on a
pouch of stamps to input the number and value of the stamps onto
Horizon. Presently, Postmasters are required to physically count
and input the number and value of stamps received from Post Office
onto the Horizon system. The new process will do away with the
need for manual entry of stamps saving significant time for
Postmasters and also reducing the risk of manual error. Post Office
assesses that in the financial year 2023/24 there were 5,287
transaction corrections in relation to stock, of which 1,586 (30%)
related to remitting-in stock [POL00448235]. Post Office has
scheduled a pilot of the new process to commence in September
2024 with roll out to 7 pilot branches completed by October 2024. A
full roll out plan will be developed following completion of the trial
and is likely to be across 2025/26 [POL00448230].
(iii) Operational Excellence Incentive
Post Office is launching an Operational Excellence Incentive to
encourage accurate completion of key back-office processes. The
proposal is for Post Office to pay up to 5% of a Postmasters total
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variable remuneration each month based on the Postmaster
meeting set requirements for daily cash declarations, cash pouch
remittances and cash holdings together with a qualifying
requirement that the branch completes its monthly trading period
accounting within a 1-week window of it falling due [POL00448234].
A sliding scale of increased remuneration is proposed measured
against existing operational requirements for the three metrics and
is hoped by Post Office to promote early identification of
discrepancies, reduce the number and value of discrepancies and
to reduce risk (to Postmaster and Post Office) of error from branches
holding high volumes of cash. The Operational Excellence Incentive
is scheduled to commence in September 2024 with the first month’s
incentive being based on August trading period data
[POL00448234]; and [POL00448192].
As to those projects supporting operational excellence but not requiring
additional budget to deliver (see paragraph 80(b) above), the Operational
Excellence Programme has oversight of various functional business as
usual process improvement activities identified at the outset of the
programme. These activities, outlined below, are owned within the Retail
function of Post Office, and, as such, will be delivered without the need for
additional funding, and will support Post Office’s ambition to reduce the
volume and value of discrepancies in the branch network:
(i) Review and relaunch of Operations Manual
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The review and relaunch of the operations manual will, I understand,
be described in the First Witness Statement of Tracy Marshall and I
will not repeat evidence that she will provide to the Inquiry. Post
Office is hopeful that the new version of the Operations Manual will
further support Postmasters in the operation of their branch and, in
the process, help to reduce the number of discrepancies.
(ii) Branch on a Page
Branch on a Page is an application built using PowerBl and
designed to consolidate a number of key branch level performance
metrics (operational and commercial) in a simple, easy to navigate
dashboard for Post Office employees. Branch on a Page was
introduced in July 2024 and its main purpose is to enable retail field
teams (mainly Area Managers) to have informed conversations
(face to face and by phone) with Postmasters (and their staff) on
their performance - highlighting both good performance and
opportunities for improvement. The application is available via
laptop or mobile and reduces the need for an Area Manager to use
multiple reports/dashboards to gain a holistic view of branch
performance as had historically been the case [POL00448193].
Having only recently introduced Branch on a Page, Post Office is
not at present able to evidence tangible improvements from the
initiative. However, early feedback from field teams, obtained
during team meetings, is that the report is enabling field teams to
have more informed conversations with branches and saves them
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time now that the data is in one place and accessible on their
devices.
(iii) Operational Excellence Visits
In July 2023, Post Office introduced Operational Excellence visits
which are performed by Area Managers as part of their core role
[POL00448245]. The aim of these visits is to improve branch
compliance to key operational processes thereby reducing the risk
of a discrepancy occurring. Visits are carried out during a planned
week in each period and cover the same subject area. Note this is
different to the Commercial Excellence visits conducted by Area
Managers during the remainder of the month which focus on driving
product sales and as such improving Postmaster remuneration
[POL00448188].
The NORM (described in paragraph 76 above) is a key source of
data to focus the Operational Excellence visits on those branches
most at risk from a potential discrepancy due to failure to comply
with operational processes and also to provide the Area Managers
with the data to facilitate a supportive discussion during the visit. At
certain points in the year the visit may be focussed on a specific
business priority (for example, Lottery exit scratch card balance,
excess cash volumes, obsolete stock) and, as such, data specific to
that business priority will be used to select the branches to visit and
provide Area Managers with the backing data to drive the right
conversation.
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(e) I Operational Excellence visits are a subset of Area Manager visits.
There is a current population of 94 Area Managers in role’, reporting
into 11 Regional Managers to ensure every Post Office is supported
by an Area Manager. Area Managers will conduct face-to-face visits
with postmasters, as well as regular telephone conversations. For
context, the number of Area Manager visits over recent years is as
follows®:
(i) 2019/2020: 25,481 visits;
(ii) 2020/2021: 13,223 visits (impacted by Covid-19 lockdown,
so 84,071 telephone calls were made);
(iii) 2021/2022: 30,368 visits;
(iv) I 2022/2023: 39,791 visits; and
(v) 2023/3024: 44,528 visits.
(f) Between July 2023 (when visits commenced) and the end of the
financial year (March 2024), Area Managers performed 10,305
Operational Excellence visits across 5,613 branches.°
7 The Area Manager role is focussed on providing support for Post masters and their teams, Area Managers seek to build
effective commercial relationships with Postmasters, developing a culture of support and community. They also support
Postmasters to grow and enhance their businesses, assisting with driving sales initiatives and continuous improvement,
with a real focus on branches achieving excellent service to customers.
° Every time an Area Manager completes a branch visit they complete a branch visit report which is held centrally and
managed within the Retail Operations Team. This means that Post Office has an ongoing view of the number of branches
that have been visited, By reference to Branch Visit report data, which is collated centrally, it is possible to view the number
of Area Manager visits across different years. Pivot tables were used to extract the number and types of attendance for
the relevant years.
° Raw data for Operational Excellence visits is maintained by the Head of Network Planning and Performance . The data
is drawn from the visit logs completed by Post Office's Retail field team and captured via a PowerApps form, with data
stored on SharePoint, at which point it is maintained by the Central Data team. To provide the information in relation to the
visits performed, the raw data has been exported into Excel from SharePoint and filtered by the number of Operational
Excellence visit forms were completed in the financial year 2023/24
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(g) I An Operational Excellence Visit review in November 2023 noted
that, when reviewing data for branches which received an
Operational Excellence visit, in the subsequent 30 days the
percentage of cash declarations had increased by 3.8%; and, in the
2 subsequent periods the volume of discrepancies raised via RorD
had reduced 24% and the absolute value had reduced by 24%
[POL00448188]."°
(iv) End-to-end reporting of discrepancies
(h) In January 2024, Post Office developed end-to-end discrepancy
tracking in Dynamics for all discrepancies created when a branch
uses the RorD function on Horizon [POL00448231]. Prior to
implementing this Dynamics work flow, there was a potential delay
to a discrepancy case commencing as case creation was dependant
on whether a Postmaster contacted the BSC or if the Postmaster
could be contacted by the PAST (see paragraph 123 below).
Previously, there was also a risk that duplicate cases could be set
up as multiple teams may be working on the same case and
attempting to support the Postmaster.
(i) The end-to-end discrepancy process creates a discrepancy case in
Dynamics via a daily data upload from Post Office’s Core Finance
System (“CFS”) on the day following a Postmaster using the RorD
function on Horizon. The case is then updated as it moves through
the investigation process (described in paragraphs 122 to 149
'° Absolute value refers to the gross value of surpluses and shortfalls (not net)
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below), giving Post Office greater visibility of the overall time taken
to resolve the discrepancy and a breakdown of where outstanding
cases are in the investigation process. In developing this new
process, Post Office has taken the opportunity to add greater detail
to the potential case outcomes and therefore, once this process is
fully embedded in the operating model, Post Office hopes to have
greater visibility on the cause and outcome of all discrepancy cases
and plans to use the improved insight to deliver further network wide
initiatives to reduce the occurrence of discrepancies.
(j) The data relating to this new workflow process will be surfaced
through a new reporting dashboard which Post Office is still in the
process of developing. As such, it is too soon for Post Office to be
able to assess the effectiveness of the process on improving the
identification, review and resolution of discrepancies.
Identification of potential discrepancies
83 There are several ways in which a branch discrepancy might be identified
for current Postmasters:
(a) As a result of work undertaken by Post Office (e.g., following a
Branch Assurance Visit or a transfer of a branch)".
(b) In between trading periods through the Postmaster performing
routine back-office processes (e.g., end-of-day activities and weekly
"' Post Office counts cash and stock held at a branch as part of the transfer of undertaking for a branch (i.e., prior to a
branch changing hands).
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85
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accounting exercises or identifying transaction errors made in
branch (e.g., banking mis-keys) (see paragraph 86 to 90 below).
(c) _ As part of trading period end activity as a result of the Postmaster
identifying the issue and reporting it to Post Office in line with trading
period end process (see paragraphs 91 to 97 below).
I have set out further detail on each of these below.
(a) Identification of branch discrepancies by Post Office
Post Office might identify branch discrepancies by performing Branch
Assurance Visits (see paragraphs 38 to 57 and 79 above) and following
the process carried out after the transfer of a branch to another Postmaster.
The effect of each process is broadly the same and is focused on
performing a full cash and stock count and comparing these totals with the
totals expected by the Horizon system.
(b) Identifying discrepancies between trading periods
Post Office has in place an Operational Training Guide which is referenced
in the Operations Manual. The Operations Manual forms part of the
contractual agreement between the Postmaster and Post Office (I
understand from BSFf that this is also discussed in the First Witness
Statement of Tracy Marshall). The Operational Training Guide is
signposted as part of the Postmaster’s classroom training during their
induction phase in relation to the Postmaster’s training obligations section
of the Operations Manual [POL00448361]. Postmasters also receive
classroom training in relation to the relevant back-office processes as part
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of the Postmasters classroom training sessions (I understand from BSFf
that this is also discussed in the First Witness Statement of Tracy
Marshall).
The Operational Training Guide sets out, amongst other things, the
activities that should be performed by a Postmaster at the end of each
trading day, including preparing pouches and bags for mail despatch and
daily accounting reports. The daily accounting reports are to be produced
for every stock unit that has been active and identify all product and service
transactions completed. In completing end of day accounting procedures,
cheques accepted in payment for goods and services are to be remitted
out, put in a pouch and despatched via a Royal Mail postal service to Post
Office’s third-party cheque processing company and cash on hand is to be
declared on the Horizon system. Declaration of cash on hand requires an
accurate cash declaration for every counter position transacted on during
the day [POL00448268]."2
The Operational Training Guide recommends that Postmasters complete
acash declaration at the start and end of their working day. The Training
Guide explains that accurate daily cash declarations are important
because if one counter position is not declared on time, the system shows
that the whole branch declaration is incomplete and the branch figures
cannot be taken from Horizon into the cash management system
[POL00448272]°°.
® Postmasters are informed to complete daily cash declarations as close to, but not after, 7pm. Further guidance is
provided to assist Postmasters whose branches are open after 7pm
* Note also, if a Postmaster identifies a discrepancy during a cash declaration, the Postmaster should perform a Trial
Balance before contacting the BSC (the process of contacting the BSC in relation to discrepancies is considered at
paragraphs 107 to 121): Operational Training Guide, Section 10, End of Day Activities (v4.0) (page 4)[POL00448268},
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The Operational Training Guide also sets out the weekly accounting
processes to be performed by the Postmaster which include the daily
accounting activities (as detailed in paragraphs 87 to 88 above) except that
the cash declaration will be completed as the last step in the weekly
balancing activity before the Postmaster rolls over each stock unit into the
subsequent week. The Postmaster is required to check the physical stock
held in branch against the stock in branch as recorded on the Horizon
system and, if necessary, adjust the record on the Horizon system. The
Postmaster is also required to count and declare the value and volume of
stamps, foreign currency and cash in branch. The Postmaster may then
rollover to a new Balance Period‘ (or Trading Period) and should print,
sign and date stamp their final balance report and retain in branch for two
years with the declarations attached [POL00448269].
While performing the end of day and weekly accounting activities set out
above, a Postmaster might identify a discrepancy. If a discrepancy is
identified, the Postmaster should follow the process discussed in
paragraphs 107 to 121 below.
c) Identifying discrepancies at trading period end
Branch trading periods are either 4 or 5 weeks in length, with 2 4-week
trading periods followed by a 5-week trading period. Post Office’s
Postmaster Operational Training Guide sets out that, throughout the
‘* Balance Period is the name given to the weekly balancing within the four week / five week accounting process known
as the Trading Period.
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trading period, branches should perform cash declarations daily, weekly,
and at the end of the trading period.
To move the branch into the following trading period, Postmasters are
required to balance and roll over each stock unit by counting stock and
cash in branch and inputting these figures into Horizon. If the physical cash
and stock counted does not equal the Horizon derived figure on any
counter the Postmaster is asked to either cancel the stock unit roll over or
continue and transfer any discrepancy to the local suspense account (see
[POL00448048] page 3).
Once all the stock units have been rolled over, the branch will see a
message if there is a balance in the local suspense account and ask if they
would like to settle the local suspense or cancel the roll over (see
[POL00448048] page 4).
If settle local suspense is selected the Postmaster will be presented with
the options to settle in branch (either by cash or cheque) or RorD
(described in paragraphs 115 to 121 below, see [POL00448048] page 5).
Once one of these options has been selected a message will display
indicating roll over into the next period has been successful (see
[POL00448048] page 6) and the branch should then print and retain a copy
of the Suspense Account report and the Monthly Trading Statement (see
[POL00448048] pages 7 and 8 and [POL00448270}).
If a Postmaster does not complete the trading period accounting process,
they are not prevented from continuing to trade and may continue to do so
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without moving into the new trading period on Horizon. One of the Network
Monitoring metrics described at paragraph 76 above includes the
identification of branches that have not completed a trading period end in
the last 60 days.
97 However, a branch is prevented from completing the trading period end
process and moving into the subsequent trading period if it has not
actioned all transaction corrections (by either accepting them or using the
RorD function in Horizon) and/or has a balance remaining in the local
suspense account.
Rule 9(58) question 35: What is the current process for SPMs, managers and
assistants to complete Branch Trading Statements?
98 This question is answered in context in paragraphs 91 to 97 above.
INVESTIGATING AND RESOLVING DISCREPANCIES
Rule 9(58) question 26: Please describe the process by which SPMs,
managers or assistants can raise a dispute against an alleged loss,
discrepancy, shortfall or transaction correction (‘TC’). In your response,
please confirm whether it is still the process that one must ‘accept’ a
shortfall on the Horizon counter before being able to lodge a dispute?
99 Given the length of my answer to this question, to assist the Inquiry, I have
provided:
(a) an overview of the Network Support and Resolution Team ("NSRT")
and the Postmaster Account Support Team ("PAST");
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a brief overview of the Review or Dispute ("RorD") function;
an overview of the key, relevant documents;
an overview of the dispute process;
a detailed explanation of the end-to-end dispute process; and
a short, direct response to the Inquiry’s request for confirmation as
to whether a Postmaster must accept a shortfall before being able
to lodge a dispute.
Overview of the NSRT and the PAST
100 The NSRT is the team responsible for the investigation anytime a
Postmaster disputes a branch discrepancy or a transaction correction
beyond a Tier 1 level. The NSRT organisational chart [POL00448219]
outlines the structure of the NSRT and shows the tiers of escalation for
handling Postmaster concems once a dispute is escalated from the Branch
Support Centre ("BSC") to the NSRT. The NSRT comprises:
(a)
(b)
The Head of Network Support and Resolution who leads the NSRT.
The Operations Manager who is responsible for overseeing the day -
to-day operation of the Dispute Resolution Team within NSRT
through 3 Team Managers and 6 Tier 3 Case Investigation and
Resolution Analysts. The Team Managers are responsible for
approximately 35 Tier 2 Support Advisors.
(c) Tier 2 Resolution Support Advisors who are responsible for,
amongst other things, investigating balancing queries and
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transaction correction disputes [POL00039629]. Disputes are
typically escalated to Tier 2 from the BSC (Tier 1), or the Branch
Reconciliation Team. NSRT Tier 2 has triage and investigation
functions as set out below from paragraph 125.
(d) Tier 3 Case Investigation Resolution Analysts who are responsible
for investigating complex branch discrepancies escalated from Tier
2 and supporting Tier 2 in their decision-making processes by
conducting quality assurance of Tier 2_ investigations
[POL00448081].
(e) The PAST, which is responsible for initiating contact with
Postmasters who have escalated disputes using the RorD function
but have not contacted the BSC and, following investigation by the
BSC and/or NSRT, for arranging repayment plans and write-offs
where appropriate with Postmasters. There are 5 Postmaster
Account Support Advisors and a Postmaster Account Support Team
Manager. The Postmaster Account Support Advisor role is
described in [POL00039629] as a Tier 2 role.
101 The BSC (I understand BSC functions are also discussed in Tracy
Marshall's statement) provides the Tier 1 function for investigating
discrepancies or disputed transaction corrections in the first instance. The
BSC is the team responsible for first-line telephone assistance to
Postmasters, using Knowledge Articles (which cover many issues,
including known Branch Impacting Problems within Horizon), should they
require support or assistance in relation to Horizon (amongst other things).
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In the context of investigating discrepancies or transaction corrections, the
BSC is responsible for conducting initial checks with the Postmaster to
attempt to resolve discrepancies. If necessary, the BSC will escalate a
case to the NSRT.
Overview of the Review or Dispute (i.e., the RorD) function
102
Post Office previously had a settle centrally function (see my response to
Rule 9(58) question 36 below). However, as of 13 May 2021, the settle
centrally function was renamed “Review Dispute” on Horizon and this is
now the function a Postmaster can use to contact Post Office to seek
support to investigate and resolve an unknown discrepancy or to dispute a
transaction correction that has been issued. In February 2023, the
onscreen display of “Review Dispute” was changed to “Review Dispute
CALL BSC” on Horizon to emphasise the importance of the Postmaster
contacting the BSC in relation to the discrepancy (see [POL00448048]
page 5) once they have used RorD.
Overview of the key policies and other key documents
103
104
Post Office has a Postmaster Account Support Policy [POL00448000] and
a Postmaster Accounting Dispute Resolution Policy [POL00448229].
These policies outline the process for Postmasters and Post Office to work
together to investigate branch discrepancies or disputed transaction
corrections. The NSRT operates subject to both policies.
The Retail Engagement Director, Tracy Marshall, is the policy owner
(responsible for ensuring that the content is up to date and is capable of
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being executed). As Central Operations Director, I have overall
accountability for implementing the policies applicable to NSRT, however,
the Head of Network Support and Resolution is the primary policy
implementer on a day-to-day basis. The Head of Network Support and
Resolution and the Retail Engagement Director, Tracy Marshall are
responsible for providing appropriate and timely reporting to RCC and ARC
as required.
105 To assist the Inquiry, I have exhibited Post Office internal process maps
teflecting investigation processes [POL00448070] [POL00448072]
[POL00448069] [POL00447943] [POL00448068]. However, I would like
to make clear that some of these are being updated following
improvements to the way cases are created and moved through the
workflow process in Dynamics (Post Office's case management system)
after a Postmaster uses the RorD function in Horizon. Further, as with
many process maps, these are indicative of the relevant processes (and
only intended to be so) and, in particular, do not reflect the continual
operational improvements that are implemented on an ongoing basis and
the need for appropriate flexibility from time to time.
106 I would also like to note that Post Office is reviewing the communications
that are sent to Postmasters at the various stages of the disputes and
investigation process and anticipates being able to implement the outputs
of that review shortly.
Overview of the dispute process
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109
110
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At any point during daily, weekly or trading period end account balancing a
Postmaster (or manager or assistant) can contact the BSC to seek support.
Postmasters are provided with guidance on how to contact the BSC to
dispute branch discrepancies or transaction corrections see:
[POL00448191]; [POL00448270]; [POL00448187]; from page 6 of
[POL00448073}; and [POL00448077].
For transaction corrections, initial support will typically be sought from the
issuer of the transaction correction whose details will be on the narrative.
That might be the BSC or the Branch Reconciliation Team.
If a Postmaster contacts the BSC about a branch discrepancy, the BSC.
(also referred to as Tier 1) will support the Postmaster to attempt to resolve
the issue (page 14 of [POL00448229]). A BSC Support Advisor will work
through the Tier 1 checklist, which is contained in the section of the BSC
Discrepancies Knowledge Article (see from page 7 of [POL00448257]).
If the BSC Support Advisor completes the checklist with the Postmaster
without resolving the discrepancy, they will ask the Postmaster to review
the discrepancy again at trading period end and formally declare (using the
RorD function within Horizon) if it still exists at that point. The RorD
functionality will become available during the trading period end process.
If a Postmaster does not want to wait for trading period end, the BSC can
escalate the issue to the NSRT Tier 2 triage prior to trading period end.
The BSC is currently trialling a new account balancing support process
(which began 20 May 2024) whereby if a discrepancy is reported by the
Postmaster as part of the weekly balancing period and it cannot be
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resolved using the basic checklist, a more skilled advisor will carry out
additional checks to try and resolve the discrepancy. If they are unable to
do so at this point, they will proactively contact the Postmaster every
weekly balance until trading period end and advise the Postmaster if the
discrepancy still exists at trading period end to use the RorD function. To
support this new process, the BSC is also developing a Branch Hub form
that Postmasters can use to report a discrepancy to the BSC without
needing to call, highlight the checks they have already taken and ask for a
review and call back from the Account Balancing Support Advisors.
A Postmaster wishing to dispute a transaction correction may use the RorD
function at any time if they do not resolve the issue with the first point of
contact (e.g., the issuer of the transaction correction or the BSC) and
remain unhappy with the reason(s) the transaction correction has been
issued, and this would be escalated into the NSRT (specifically the
transaction correction disputes team) who may then escalate for a full Tier
2 investigation if they are unable to resolve the dispute.
A Postmaster wishing to dispute a branch discrepancy must await trading
period end to use the RorD function but can seek BSC support earlier than
that.
A case should be created in Dynamics whenever a dispute is raised. A
case is created automatically when a dispute is raised via RorD within
Horizon's in relation to a branch discrepancy. A case is created manually
when a dispute is raised via the BSC (or the Branch Reconciliation Team
'® All such cases are flagged to NSRT Tier 2 triage although they might still be dealt with by BSC Tier 1 in the first instance.
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or Cash Centre) without the Postmaster using the RorD function or where
the case relates to a transaction correction. If a dispute is raised both via
the Postmaster initiating contact with the BSC prior to using the RorD
function and via use of the RorD function within Horizon, the Dynamics
cases will be linked manually. The case is then used to manage all
communications and actions relating to the dispute.
115 At trading period end, if a Postmaster still has a branch discrepancy they
have the following options:
(a) Settle to cash.
(b) Settle to cheque.
(c) Use the RorD function on Horizon.
116 If a branch settles to cash this means the Postmaster is agreeing to either
put in or take out the cash value of the discrepancy. If a branch settles to
cheque this means that the branch is agreeing to put in the value of a
shortfall by cheque (from page 9 of [POL00448257]).
117 If the discrepancy is a shortfall, the Postmaster is agreeing to put the
amount in from their own money. If the discrepancy is a surplus the
Postmaster is agreeing to take the amount out of the counter till. The
guidance note for BSC on this states that most branches that have
surpluses keep the amount to one side to wait and see if it is as a result of
an error that might be corrected in a subsequent period. This is not
enforced but it is generally advisable. It is also advisable that branches
keep a record of any shortfalls or surpluses which can be looked over at
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each trading period to identify any patterns. A branch may contact BSC
advising they have rolled over trading period end and have settled to cash
but in hindsight would like the discrepancy reviewed. In this case they
would be advised to remove the cash at the next trading period end and
settle the resulting discrepancy to RorD.
118 If a Postmaster does not elect to settle to cash or cheque and wants Post
Office to investigate the discrepancy, they need to use the RorD function
on Horizon (see page 3 of [POL00448048] and page 11 of
[POL00448257]). The effect is to post the discrepancy to the branch
account, enabling the branch to roll over into the new trading period
(described in paragraphs 91 to 97 above). I also discuss the RorD function
in my answer to Rule 9(58) question 36 (in paragraphs 185 to 189 below).
119 Once a Postmaster has used the RorD function in relation to a branch
discrepancy or transaction correction, Post Office does not consider the
shortfall to be a debt of the Postmaster. The intention at this stage is to
create a joined-up investigation between the Postmaster and Post Office
to determine the cause of the issue and ultimately agree a resolution. This
is a means by which both the Postmaster and Post Office can discharge
their responsibilities to co-operate.
120 Before Post Office will treat the shortfall as a debt of the Postmaster it must
have identified that the cause of the loss was a result of the Postmaster’s
(or the Postmaster’s assistant's) negligence, carelessness or error (as set
out in the Contract Restatement Guide referred to in Tracy Marshall's
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statement at paragraph 26 [POL00037518]). This will be investigated
through a tiered process as set out in detail in the next section.
121 During preparations for Phase 7 of the Inquiry, Post Office identified that
before a Postmaster elects to settle to cash or cheque there is currently no
reminder in Horizon that the Postmaster should only use this function if
certain that the issue has been caused by the Postmaster’s (or the
Postmaster’s assistant's) negligence, carelessness or error. Post Office is
investigating if such a reminder could be implemented in the Horizon
system before completing the settle to cash/cheque process. Post Office
will also review all BSC knowledge articles to ensure when advisors are
talking to Postmasters about settle to cash/cheque they remind
Postmasters that this should only be done if they are certain that the
discrepancy has been caused by an error in branch and if not, they should
advise the postmaster to use the RorD function. Knowledge Articles will
also be updated and BSC advisors will be trained to notify postmasters
when using the RorD function that Post Office does not consider a shortfall
to be a debt owed by unless the outcome of the discrepancy review has
established the cause of the discrepancy to be the Postmaster’s (or the
Postmaster’s assistant's) negligence, carelessness or error. Post Office
proposes to frame this information clearly, in lay terms and in a manner
intended to not cause undue concern to Postmasters. As such, payment
by the Postmaster is only to be discussed if those conditions are met. Once
amended, this will be trained out to the BSC advisors.
End-to-end overview of the RorD process
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122 The following initial steps occur after a Postmaster uses the RorD function:
123
(a)
The discrepancy is moved off the Postmaster’s Horizon system and
onto the Postmaster’s branch account in CFS.'° This aligns, for the
purposes of double-entry book-keeping, the branch's physical cash
and cash equivalent stock balances against the Horizon system and
then assigns the balance (debit or credit) to the branch account in
CFS.
Acase is automatically created on Dynamics (if a case was already
created (e.g., by the BSC because the Postmaster contacted the
BSC) it will be manually linked to the case created by Dynamics).
The Postmaster should contact the BSC (but does not always do
SO).
If the Postmaster contacts the BSC after pressing RorD, the BSC
Support Advisor will attempt to resolve the discrepancy with the
Postmaster using Knowledge Articles and by working through the
Tier 1 checklist.
If the dispute cannot be resolved at Tier 1, the BSC will update the
case details on Dynamics and will transfer the case to the NSRT
(specifically the Tier 2 triage team initially).
If the Postmaster does not contact the BSC after using the RorD function,
the PAST will seek to contact the Postmaster to gather further details as
*® For completeness, I note that in some documents the branch account is erroneously referred to as a central holding
account.
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follows (disputes relating to branch discrepancies under £1,000 or over
£10,000 will be immediately escalated to NSRT Tier 2 triage):
(a)
(c)
The PAST will make an outbound call to the Postmaster and send
them a letter and a statement of their account. The call script is
[POL00448295], and examples of the letter and statement are
[POL00448197] and [POL00448186]. The first letter is known as
Discrepancy Letter 1.
If the postmaster does not respond to the first letter or the phone
call, the PAST will send them a further letter the following week
[POL00448246]. The second letter is known as Discrepancy Letter
2.
The PAST will call out to the Postmaster 3 times during the 42-day
period. If the Postmaster engages with the PAST within the 42 days
and they require support the case is escalated to NSRT Tier 2
Triage. If the Postmaster does not engage within the 42 days, the
case will be escalated to NSRT Tier 2 triage at that point.
NSRT Tier 2 triage will then support the Postmaster if they have
made contact or continue to try and make contact if they have not
engaged.
If necessary, the PAST or NSRT Tier 2 triage will also contact the
Area Manager and ask that they assist with contacting the
Postmaster or understand any circumstances why the Postmaster
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is uncontactable (the underlying circumstances are not discussed
with the Area Manager).
124 At any point at which the Postmaster makes contact with Post Office
following use of RorD the NSRT will note against the amount on the branch
account that the Postmaster has contacted the BSC which should prevent
the PAST sending the above letters and statements to the Postmaster
regarding the amount (this is because Post Office knows that the BSC
and/or NSRT has made contact and is working with the Postmaster to
resolve the investigation). For an example of communications at this point
see [POL00448082]. If a Postmaster has contact the BSC and the dispute
is not resolved at BSC Tier 1, it will be passed to NSRT Tier 2 triage. Once
acase is transferred from the BSC to the NSRT the Tier 2 triage team will
seek to contact the Postmaster. If the case relates to a transaction
correction, the NSRT will also liaise with the Branch Reconciliation Team
and other Post Office units and departments as appropriate.
125 The triage process is outlined from page 15 of [POL00448229], in the
process map [POL00448070] and there is also an example of the Tier 2
triage checklist [POL00448223]. The Tier 2 triage team will initially
undertake a basic investigation to check that the BSC checklist was
completed correctly and will apply a de minimis write off amount to certain
cases (e.g., cases below a certain value or where no previous issues have
been identified), although Post Office reserves the right not to apply a de
minimis write off if there have been more than 2 write offs in the preceding
12 months. Post Office’s fully updated write-off policy has just passed
through internal governance process [POL00448365].
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126 __ If there is no de minimis write off, the case will usually be moved into Tier
2 investigation status [POL00448072]. The Postmaster will be contacted
by phone and email to advise them that their case has been assigned for
Tier 2 investigation (see the email template [POL00448059]).
127 If a case is high risk, it can be escalated from Tier 2 triage directly to Tier
3. Tier 2 triage will discuss any cases that might need assigning directly to
Tier 3 with the NSRT’s Operations Manager. Tier 2 triage can also refer
cases to the weekly review panel if they believe it should skip Tier 2 review
but is not urgent enough to require immediate escalation to Tier 3 (see the
process map [POL00448072]).
128 The Tier 2 investigation is a fully documented process to ensure the
consistency of delivery and a fair and transparent outcome (see
[POL00448229] at page 15 and in particular page 27 to 29 for the Tier 2
Checklist). The Tier 2 Support Advisor will complete the Tier 2 checklist.
129 One of the process steps in the investigation is for the advisor to "Check
the latest Branch Impacting Problem tracker (BIP) to ensure the
discrepancy is not related and add a copy of the BIP tracker to the
dynamics case" (see page 27 of [POL00448229]). To do this the Tier 2
Support Adviser will review the possible cause of the discrepancy and
whether it is consistent with any of the known Branch Impacting Problems
within Horizon. The list of Branch Impacting Problems is managed by the
IT Team, which is responsible for updating the list with any changes. The
list is shared with NSRT from IT on a monthly basis. If the discrepancy is
not caused by one of the listed Branch Impacting Problems, then the Tier
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2 Support Adviser will conduct checks against the session data and
reported events in HORice and will also contact the IT team to check if the
branch has reported any issues or if any other branches have reported
similar issues. If there are no suspected issues, the investigation will
continue and that might lead to a conclusion that Horizon was not a
contributory factor in the discrepancy. However, if the data suggests that
there could be an issue, the IT Team would do further analysis.
130 The Tier 2 Support Advisor will conduct the process steps as outlined in
the checklist and complete a case investigation report (including a case
summary; case overview; case outcome and recommendations and an
action log). The case investigation report is page 25 -— 29 of
[POL00448229]. When the Tier 2 Support Advisor contacts the
Postmaster with the outcome of the investigation they offer them a copy of
the report. If the report is sent to the Postmaster, Post Office removes the
internal facing elements of the document (the checklist, managers
comments and the internal decision and action log) before sending.
131 Tier 2 support advisors can escalate cases to their Tier 2 team manager
for assistance or for review at the twice Weekly Case Review meeting, who
in turn, can escalate unresolved cases to Tier 3 or the Dispute Resolution
Committee [POL00448072]. The Weekly Case review is a twice weekly
internal team meeting of lead representatives from NSRT (see page 17 of
[POL00448229)).
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132 At that point there are several potential outcomes depending on whether
the cause of discrepancy has been established (see paragraphs (a) to (d)
below) or not (see paragraph (e) below):
(a) Discrepancy established and written off (if Post Office determines
that this is appropriate given all the circumstances).
(b) Discrepancy established and Postmaster agrees to pay (the
Postmaster is asked to contact PAST to arrange payment).
(c) Discrepancy established and Postmaster disagrees with the
outcome (the Postmaster can ask that the case is referred to a Tier
3 review or contact Tier 3 directly (the email address is provided with
the communications to the Postmaster). See the Weekly Case
Review process map [POL00448069)]).
(d) IThe cause of the discrepancy is identified, and a transaction
correction is issued to correct the position in branch Horizon system.
(e) Discrepancy is not established and is written off (the PAST is also
responsible for writing off amounts on the Postmasters branch
account when it is appropriate to do so).
133 The NSRT aims to complete Tier 2 investigation within 20 working days.
However, some investigations will take longer to arrive at a fair and
reasonable outcome due to the circumstances and complexities of the case
and therefore the NSRT is managed to a service level of completing at
least 70% of cases within the 20-day timeframe. See the Central
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134
135
136
137
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Operations Dashboard [POL00448196] and Retail Performance
Dashboard [POL00448230] which monitor this.
All Tier 2 support advisor reviews will receive Quality Assurance (see the
Quality Assurance Checklist [POL00448218]). That quality assurance
exercise is either undertaken by a Tier 3 reviewer (if it involves an
accounting discrepancy of over £5,000 or it is under £5,000 but complex)
or a Tier 2 advisor's team manager (under £5,000 and not complex). This
is to ensure that the correct process has been followed by the Tier 2
Support Advisor and a fair and reasonable outcome has been reached (see
page 19 of [POL00448229]). The relevant Team Manager or Tier 3 Case
Investigation Analyst will complete the management comments section in
the case management report. This is not included when the report is
provided to the postmaster.
As set out above, a case could come to NSRT Tier 3 review directly through
escalation from triage or Tier 2 due to sensitivities or risks or via the Weekly
Case Review.
The NSRT Tier 3 team is responsible for carrying out a further investigation
see page 16 of [POL00448229] for details of what that investigation entails.
A case will be allocated to a Tier 3 Case Investigation Resolution Analyst
(having checked that the Tier 3 analyst has not previously reviewed the
case as part of the quality assurance exercise of Tier 2 Support Advisor
reviews to avoid any perceived conflicts of interest). The Tier 3 Case
Investigation and Review Analyst will complete an investigation following
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the Tier 3 checklist and produce a case investigation report. See page 30
— 34 of [POL00448229] for the checklist and report.
138 Tier 3 Reports are quality assured by the Operations Manager and Head
of Network Support and Resolution.
139 The Postmaster will be advised of the outcome of the Tier 3 review and
offered a copy of the Case Investigation Report. The action log, managers
comments and checklist will not be provided to the Postmaster with the
report. See page 18 of [POL00448229] for an outline of the
communication between Post Office and Postmaster during investigations.
140 ‘If a Postmaster disagrees with the outcome of the Tier 3 review, then the
postmaster can challenge the decision by email or phone call to their Tier
3 Case Investigation Resolution Analyst, who will present the case to the
Dispute Resolution Committee for review (see the escalation process
[POL00448072] and [POL00448229] at page 17 and the Dispute
Resolution Review Committee’s Terms of Reference are [POL00448043]).
The Dispute Resolution Review Committee’s remit is to review whether the
correct process has been followed. The Dispute Resolution Committee can
also comment on a Tier 3 review and indicate a need for further
investigation.
141 If a Postmaster disagrees with the outcome of the Dispute Resolution
Committee, there is currently no further or independent review forum (Post
Office is currently considering the use of an independent panel as part of
reviewing its model for recovering shortfalls outlined in paragraphs 35 and
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142
143
144
145
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36 above). At that point (and at all stages of the investigation process) Post
Office signposts Postmasters to the NFSP.
Ifa loss is established and the Postmaster disagrees with the outcome Post
Office does not take any civil enforcement action against the Postmaster.
My responses to Rule 9(57) questions 21-24 (above) set out Post Office’s
current position in relation to civil enforcement in more detail.
The amount will remain on the branch account. However, no proactive
statements or communications are issued other than if a statement is
triggered (e.g., if a Postmaster reports a new accounting discrepancy or an
invoice is issued for branch property works or a TC is disputed), in which
case the previous unresolved accounting discrepancy will show on the
Postmaster’s branch statement of account as "disputed".
If Tier 1, Triage, Tier 2 and/or Tier 3 investigations (as applicable) conclude
that a loss is established the case will be forwarded to the PAST and the
process as set out in the Postmaster Account Support Policy will be
followed (see page 18 of [POL00448229] and from page 18 of
[POL00448000] and for examples of communications sent to Postmasters
if investigation at Tier 2 or Tier 3 finds a loss has been established see
[POL00448083)).
Ifa loss is established and the Postmaster agrees with the outcome, PAST
will work with the Postmaster to discuss payment. A Postmaster agreement
to pay is either recorded in writing or on a recorded telephone call.
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146
147
148
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Ifa loss is established but the Postmaster does not agree with this outcome
the amount will remain on the branch account, but Post Office does not
currently take any civil enforcement action against the Postmaster.
If the Tier 1, Triage, Tier 2 and/or Tier 3 investigations (as applicable) do
not conclude that a loss is established, a write-off will be applied. Once
written off, the discrepancy will no longer appear on the Postmaster’s
branch account statement. A Postmaster would be informed by phone and
email or letter (see the email template [POL00448071]). All decisions to
write off are quality assessed.
There are limited exceptions to the above process:
(a) _ If at any point, there is evidence of potential criminal activity or a
Speak Up issue has been raised, the dispute will be immediately
escalated to the A&CI team. The NSRT has a process of how they
will escalate this to the A&CI team see [POL00447943]. In
summary any cases considered for referral to A&CI are discussed
at the manager weekly review. If the decision is to refer then the
automated triage form in Dynamics is completed by the advisor and
emailed to the A&CI Triage team. A&Cl triage email the form back
to the case on Dynamics with the decision to adopt, reject or partial
accept. A tracker is maintained in Excel by the Operations Manager
and progress against those cases adopted/partially adopted will be
discussed at quarterly review committee.
(b) I Where a discrepancy investigation identifies significant breaches of
contract, this will be escalated to the Contract Team for them to take
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the necessary action alongside the necessary discrepancy
investigation in the NSRT [POL00448068].
(c) If a postmaster has exercised the RorD function to dispute a
transaction correction or the Branch Reconciliation Team has
escalated a transaction correction dispute to the NSRT then the
same process as outlined above will be followed. However, the
NSRT has designated Tier 2 support advisors who will review a
transaction correction case.
149 For completeness I note that in terms of who can raise an accounting
dispute (either via BSC or by using the RorD function) the Inquiry will be
aware that some Postmasters operate more than 1 branch, in which case
the Postmaster might not be operating the counter at the branch that
presents a potential discrepancy. Along with a Postmaster, anyone to
whom the Postmaster has assigned back-office rights on Horizon/given
authority to act on their behalf (typically the officer in charge) can also
contact the BSC or utilise the RorD function to report an alleged
discrepancy or dispute a transaction correction. Postmasters are asked to
maintain a record of officers in charge for their branches on Branch Hub.
When an individual contacts the BSC they will be asked to provide the
branch FAD code to ensure the advisor has the correct branch details.
A Postmaster does not have to accept a shortfall to lodge a dispute
150 Postmasters do not have to “accept” a shortfall on the Horizon counter
before using the RorD function.
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151 However, in order for Post Office to track the amount that the Postmaster
is disputing, the review of dispute function, in accounting terms, moves the
balance off the branch Horizon system and transfer it to the Postmaster’s
branch account (as a debit in the case of a shortfall or a credit in the case
of surplus). The amount will remain logged on the Postmaster’s branch
account until the dispute is resolved and, if the loss is to be repaid, for as
long as it remains unpaid
Rule 9(58) question 27: Once a dispute has been raised, please describe the
policies, guidelines and procedures now in place for POL to:
(a) Investigate and respond to concerns or complaints about
discrepancies and shortfalls which were reported to the
Helpline;
(b) investigate discrepancies or shortfalls which could not be
resolved by the Helpline;
(c) undertake enquiries into disputed error notices or transactions
corrections.
152 The relevant policies and processes in accordance with which Post Office
will conduct investigations are outlined above in context in my response to
Rule 9 (58) question 26.
Rule 9(58) question 28: When a dispute is raised, is the debt collection
process is automatically suspended at this stage? If the debt collection
process is not automatic, and a positive step is still required by POL to
remove a dispute amount from recovery, please explain why.
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153
154
155
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Post Office does not currently operate any debt collection process for
cases where the Postmaster disputes the debt. As set out about above,
disputed sums (e.g., arising from a branch discrepancy, transaction
correction or unpaid invoice) will appear on the branch’s statement of
account until the point in time when it has been reviewed, and an outcome
reached. That outcome might be establishing the loss (in which case it will
stay on the statement), writing it off, or issuing a compensating transaction
correction to remove the balance on the statement
lf a Postmaster does not contact the BSC they will be sent a letter and a
branch statement, and the PAST will attempt to phone the Postmaster (see
above at paragraph 122). This is not to seek payment of the discrepancy
but to seek engagement with the Postmaster to investigate it.
As set out above at paragraphs 144, if the loss is established and the
Postmaster agrees with this outcome, the case will be passed to the PAST
and the process will commence between the PAST and the Postmaster to
arrange payment. However, if a Postmaster does not accept or does not
pay the established loss, beyond the PAST attempting to make contact to
ask the Postmaster how they would like to repay, Post Office does not
currently operate a civil enforcement recovery function to recover the
amount (as outlined in the civil recovery section above).
Rule 9(58) question 29: Please provide details of the experience, expertise
and qualifications of those who deal with disputes raised by SPMs,
managers and assistants (or, any minimum level that is required, if any) [to
the extent this has not already been covered by Q.18 above].
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156 As outlined above, the NSRT (including the PAST) is made up of Tier 2
Support Advisors and Tier 3 Case Investigation Resolution experts. See
the NSRT organisation chart [POL00448219]. The experience, expertise
and qualifications required for PAST Support Advisors, Tier 2 Support
Advisors and Tier 3 Case Investigation Resolution Analysts are outlined in
the job descriptions for each of the roles. Please see:
(a) I PAST and Tier 2 job descriptions [POL00039629].
(b) — Tier 3 job descriptions [POL00448081].
(c) Tier 2 and Tier Manager job descriptions [POL00039599].
Rule 9(58) question 30: Please provide details of any key policies, guidance,
training or instructions they have been given. This request includes (but is
not limited to) any policies, guidance, training or instruction concerning:
(a) the length and scope of the investigations or enquiries which ought
to be undertaken;
(b) the circumstances in which an ARQ request for audit data ought to
be made;
(c) the circumstances in which a disputed shortfall or discrepancy ought
to be placed into the central suspense account pending
investigation.
157 I have set out a response to each of the Inquiry’s sub-questions under
corresponding sub-headings.
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a. The length and scope of the investigations or enquiries which ought to _be
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undertaken
158
159
The key guidance and training regarding investigations or enquiries which
ought to be undertaken are:
(a) The Discrepancy Investigation Guidance Note, which is intended to
assist the Tier 2 and Tier 3 teams in investigating branch
discrepancies or transaction correction disputes [POL00448290].
(b) I The team training that is provided to the NSRT is described in
[POL00448289] and the Tier 2 Report writing training which is
provided to the Tier 2 Support Advisors to assist with drafting case
investigation reports is described in [POL00448220]. The training
is provided on induction and there is an annual refresher training on
policy, legal and report writing.
As outlined above in my response to Rule 9(58) question 26, Post Office
has policies, process maps and checklists which outline the length and
scope of investigations and enquiries which ought to be undertaken. See
above at paragraphs 103 and 105.
b. The circumstances in which an ARQ request for audit data ought to be made
160 There is no set policy or process document for this, but I have spoken to
the Head of Network Support and Resolution who has informed me that
this is an infrequent request.
161 Post Office has access to 12 months of data through HORice and
Credence. For data outside of that, Post Office would need to submit an
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ARQ request to Fujitsu from whom the data is sourced. If an ARQ request
is required, it will be discussed at the Weekly Case Review meeting.
162 An ARQ request will be made if the additional data is likely to help identify
the cause of the discrepancy and, as such, support resolution. In the event
an ARQ data request may have evidential value but is not considered a
proportionate step due to the cost of obtaining it, the discrepancy will be
written off with no detriment to the PM. The cost of a given ARQ request
corresponds with the length of period being requested, for example ARQ
data for a 6-month period will cost more than a request for a 3-month
period. Since I joined POL, our department has never had a budget
allocated for ARQ requests, nor has it had a set number of ARQ requests
allocated to it and nor has its cost centre had a sum deducted for the cost
of an ARQ request. In the few times that an ARQ request has been made
by our department to the security team, we have never been declined. I
understand that Post Office will be writing to the Inquiry separately
regarding the present process of making an ARQ request to Fujitsu.
163 Practically, ARQ requests are commenced by filling in a form for the
security team to review. During a NSRT Tier 2 review, the Tier 2 individual
can make a request for the case to go to Weekly Case Review to determine
if an ARQ request should be made. The form that is required to be
completed for an ARQ request is [POL00448281] and that form must be
completed by a Tier 3 Case Investigation Resolution Analyst who refers it
to the appropriate team.
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c. The circumstances in which a disputed shortfall or discrepancy ought to_be
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placed into the central suspense account pending investigation.
164
There are no such policies, procedures or instructions because Post Office
does not place discrepancies into a central suspense account. As set out
at paragraph 122, when a Postmaster uses the RorD function it will clear
the amount from the branch Horizon system and, in accounting terms,
move the disputed balance onto the branch account in the CFS. There is,
however, no assumption that the discrepancy is a liability of the
Postmaster. The burden of proof is on Post Office to establish the loss to
have been caused by the Postmaster’s (or the Postmaster’s assistant's)
negligence, carelessness or error.
Rule 9(58) question 31: Please confirm whether POL maintains a central
record of all disputes raised SPMs, managers or accounts? If it does, please
confirm which department(s) hold responsibility for this record and who
holds responsibility for the management and oversight of that department.
165
166
The central records of all disputes are held on CFS and Dynamics.
Post Office tracks disputes on the retail performance dashboard
[POL00448230] which shows volumes and values (i.e., the number of
discrepancies and transaction corrections monthly, the number and age of
outstanding cases weekly and monthly) and outlines the key drivers of
discrepancies. This report is being amended to provide an additional layer
of detail so that thematic issues across disputes can be identified and
addressed. The Retail Performance Dashboard is shared monthly with the
SEG and quarterly with the Board.
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167
168
169
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The Central Operations Dashboard [POL00448196] also highlights key
metrics relating to the discrepancy process. The data presented in the
visual performance dashboards is sourced from a combination of CFS and
Dynamics.
The individual teams involved in managing the discrepancy or dispute are
responsible for creating and updating the Dynamics cases. The teams are
also responsible for assuring the accuracy of the data in those cases.
In terms of the integrity of any software and systems, and overarching use
of the data in them, that is the shared responsibility of Post Office’s IT team
and Post Office’s Retail Team's Deputy Data Sponsor.
Rule 9(58) question 32: Please provide any key reports, reviews or
investigations (produced by POL or by an external firm on POL’s behalf)
following the findings of Fraser LJ or resulting from evidence arising in the
Inquiry which address the quality of the investigations undertaken into
dispute shortfalls, discrepancies and TC.
170 Please see the following reports regarding the quality of investigations into
disputed shortfalls, discrepancies and transaction corrections.
171. The January 2023 Internal Audit Report regarding Postmaster Issue
Resolution [POL00448322].
172 The internal assurance reports for Shortfalls [POL00448078]; Loss
Prevention [POL00448079]; and Transaction Disputes [POL00448080].
173 The March 2024 Quality Assurance Framework Monthly Report on the
assurance and complex investigations unit [POL00448292].
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174 See also the February 2023 Policy monitoring report for the Postmaster
Accounting Dispute Resolution Policy [POL00448075] and the Network
Transactions Corrections Policy Review [POL00448076].
175 Please also see the following relevant external reports:
176 In January 2021 Deloitte was commissioned to review the "Postmaster
Journey" [POL00448058].
177 The KPMG Target Operating Model report which recommended the target
operating model for the NSRT [POL00448055].
178 The Ernst Young Branch Discrepancies Report [POL00448325]. The
purpose of this review was to examine and document the systems data and
data flows for the interlinked areas that drive discrepancies between Post
Office (PO) and branches. As a result of this review Post Office stood up
the Operational Excellence Programme which is described above at
paragraph 80 and in relation to which see also [POL00448231] for the
latest report to SEG regarding the Operational Excellence Programme.
Rule 9(58) question 33: Since the Horizon Issues Judgment, is audit data
now obtained and considered in every case as part of the dispute resolution
process? If not, please set out how frequently and in what circumstances
audit data is obtained and conside red for resolving a dispute between POL
and SPMs, managers or assistants regarding branch accounts.
179 In terms of audit data that Post Office can access the options include:
Credence, HORice and ARQ data (for requests going back further than 12
months).
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180
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Post Office has direct independent access to transaction data created in
the last 12 months, which is stored on HORice. An important distinction is
that an ARQ data request is only required if more than 12 months of data
is needed. In individual cases if data beyond 12 months is required, Post
Office must make an ARQ request to Fujitsu (please also see the process
outlined above at in my response to Rule 9(58) question 29(b)). The NSRT
made only 24 ARQ requests in the financial year 2023/24.
Rule 9(58) question 34: To what extent is information from management
sought and used in the dispute resolution process? Please set out when
and how frequently information from management is obtained.
181
182
183
184
I understand that the Inquiry's reference to "information from management"
is a reference to Post Office Area Managers (and individuals in similar
roles) who might be able to provide information about Postmasters from
direct knowledge of the relevant Postmasters.
Information from Area Managers is not routinely sought as part of the
discrepancy investigation process.
Where there is a significant discrepancy and the case is complex, input
would be sought from a number of people involved in the relationship with
the Postmaster (including Area Managers, Contracts Team and the
Network Monitoring Team).
In some situations, a particularly complex case or high value or if there are
concerns about the welfare of the Postmaster, the case investigation
reports from Tier 2 and /or Tier 3 review might also be provided to the Area
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Manager and NFSP and Post Office would seek agreement from the
Postmaster before that step is taken.
Rule 9(58) question 36: Please explain the options available on the Horizon
counter (if any) for SPMs, managers and assistants to flag when they’ve
identified a shortfall and describe what relevant changes (if any) have been
made following the findings of Fraser LJ or resulting from evidence arising
in the Inquiry.
185
186
Previously, the Horizon system included a settle centrally function. In
accounting terms, choosing to settle centrally transferred the discrepancy
amount from the branch Horizon system onto the branch account. As
explained above, this remains the case. However, this action was also
previously treated by Post Office as an acceptance of liability for the
shortfall by the Postmaster and a request by the Postmaster for time to
settle the balance [POL00448060].
As noted above, as of 13 May 2021, the settle centrally function was
renamed “Review Dispute” (RorD) on Horizon to signal the change in Post
Office's approach to branch discrepancies. A month prior to the
introduction of the RorD function, in April 2021, Post Office removed the
£150 limit, previously in place, for using the settle centrally option
[POL00448060]. In February 2023, the onscreen display of “Review
Dispute” was changed to “Review Dispute CALL BSC” on Horizon to
emphasise the importance of the Postmaster contacting the BSC in relation
to the discrepancy (see paragraph 123 above) (see [POL00448048] page
5).
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187 The options available to a Postmaster in relation to a discrepancy, whether
shortfall or surplus, are set out in detail at paragraphs 115 to 121
above. Further, as set out in the section called Reduction and Identification
of Potential Discrepancies (see paragraph 96 above), a Postmaster is not
prevented from continuing to trade by virtue of their not having completed
the trading period end accounting process and may continue to do so
without moving into the new trading period on Horizon.
188 As set out above at paragraphs 92 to 95, a Postmaster may choose to
settle in branch without having ever contacted Post Office (for example the
Postmaster may have identified the cause of the discrepancy and chosen
to resolve it without seeking support from Post Office).
189 If the Postmaster does not contact Post Office, Post Office does not take
active steps to identify the cause of a discrepancy that has been settled in
branch, although the volume and value settled in branch is one of the inputs
into the NORM model (see paragraph 76 above) and, as such, forms part
of the Network Monitoring activity referred above at paragraph 73. The
volume and value of discrepancies settled in branch each trading period is
also reported in the Retail Performance Dashboard. There is no way that
Post Office can identify if a Postmaster introduces a cheque or cash to
correct a shortfall prior to completing the branch trading period.
Rule 9(58) question 37: Is it still POL’s position that a dispute
button/function should not be included within the Horizon computer
platform itself? If yes, why?
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190
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Itis not Post Office’s position that a dispute function should not be included
within the Horizon computer platform. Since May 2021, a Postmaster has
been able to raise a dispute through the Horizon platform, using the RorD
function, as well as opting to settle the discrepancy in branch, as set out in
the above paragraphs 185 to 189.
Rule 9(58) question 38: Please explain the current meaning and effect of the
‘settle centrally’ function on Horizon.
191
Purely from an accounting perspective, the settle centrally and RorD
functions within Horizon follow the same process in amending the Horizon
balance and posting the corresponding amount to the branch account in
CFS. However, the way the account balance is treated (in terms of liability),
reviewed and ultimately resolved has fundamentally changed and is now
as set out above in paragraphs 107 to 121, 122 to 151, and 185 to 189.
The emphasis is on supporting the Postmaster and Post Office makes no
assumption of liability for the loss until a full investigation has been carried
out and established that the loss was due to the Postmaster’s (or the
Postmaster’s assistant's) negligence, carelessness or error, and that the
Postmaster has agreed with that outcome.
Rule 9(58) question 39: Please explain whether POL treat the Branch
Trading Statement as a settled account, and set out in what circumstances,
if any, the Branch Trading Statement could or does include disputed
matters.
192 Post Office does not consider a Branch Trading Statement to be a settled
account.
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193
194
195
196
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If a Postmaster chooses to RorD a discrepancy, the value of the
discrepancy is transferred off Horizon and onto the branch account.
Whereas the settle centrally function would previously have led to a
discrepancy, immediately being treated as the Postmaster’s liability a
different process is now in place whereby, following use of the RorD
function, the Postmaster is asked to call the Branch Support Centre’” or
Postmaster Account Support Team to discuss the balance and work
through steps to resolve it. Post Office’s new process is such that a
discrepancy would only be treated as the Postmaster’s debt if it has been
investigated by Post Office and found (with the Postmaster’s agreement)
to be a genuine loss to Post Office which was caused by the Postmaster’s
(or the Postmaster’s assistant's) negligence, carelessness or error
[POL00448257].
For completeness, in the following paragraphs, I set out how Post Office
treats the value of a discrepancy which has been transferred off Horizon
and onto the branch account.
Postmasters are issued a statement of account for their branch only at
trading period ends in which there has been activity on that branch account
(e.g., a discrepancy has been transferred off Horizon into the branch
account). However, a Postmaster can telephone the BSC to request a
statement of account.
Use of the RorD function has the effect of adding the value of the
discrepancy to the branch account and, as such, would trigger a letter
7 See paragraph 186 referring to the change in name of the function button to ‘Review Dispute CALL BSC’ on the
Horizon system,
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accompanied with a statement of account being sent to the Postmaster the
following week. The process of issuing the correspondence to the
Postmaster is initiated by a manual request in CFS to start a batch print
that will print all relevant letters and statements of account. Letters and
statements of account will only be printed when there has been a new
transaction on the branch account in the trading period. In this context, a
new transaction might include the RorD function being used, an invoice
being issued to the Postmaster (e.g. for branch works carried out by Post
Office), or the Postmaster making payment against a previous invoice. The
Post Office’s letter accompanying the branch’s statement of account is sent
from the Postmaster Account Support team. The letter refers to the
discrepancy, on the accompanying statement, which the Postmaster has
asked Post Office to review (by virtue of the Postmaster having used the
RorD function) and invites the Postmaster to telephone the Postmaster
Account Support team so that they may provide more information about
the entries on the accompanying statement and agree the next steps to
resolve the discrepancy. The letter also sets out guidance for the
Postmaster should they wish to investigate the discrepancy without Post
Office’s support, the number to call if they would like help to investigate
how the discrepancy or transaction correction happened and the number
to call if the Postmaster understands and accepts the discrepancy and
would like to discuss payment options [POL00448197].
197 The branch statement of account contains details of all transactions that
have been posted on the branch account. This will include invoices
payable by the Postmaster, for example where a postmaster has agreed
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198
199
200
201
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to share the cost of property improvements to their branch, branch
discrepancies and disputed transaction corrections. The branch statement
of account differentiates the amounts on the schedule by virtue of their
origin under the heading Transaction Detail and using descriptors such as
Invoice, Branch Discrepancy and Customer Payment. Transactions are
also separated based on their descriptor as either Outstanding
Discrepancies, New Discrepancies, Previously Agreed Discrepancies, and
Disputed Discrepancies, which are described further below
[POL00448197].
Outstanding Discrepancy refers to an amount for which the Postmaster has
previously received a letter from the Postmaster Account Support team
(e.g., it may relate to a previous period in which a discrepancy was raised
by the Postmaster using the RorD function on Horizon) and which has not
been blocked (e.g. as would be the case where Post Office has made
contact with the Postmaster following use of RorD).
New Discrepancy refers to a discrepancy about which Post office are
writing to the Postmaster for the first time (i.e., in response to the
Postmaster having in the last week raised a discrepancy using the RorD
function on Horizon).
Previously Agreed Discrepancies are discrepancies the Postmaster has
agreed to repay (either under a repayment plan or a promise to pay) or has
paid in full within that trading period.
Disputed Discrepancies relate to discrepancies that are under investigation
and Post Office (either BSC or the PAST) has had contact with the
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202
203
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Postmaster after the Postmaster initiated RorD on Horizon. Or if the
investigation is complete and the Postmaster disputes the outcome and
has not, therefore, agreed to pay the Shortfall amount.
Any payments made by the Postmaster to Post Office will present under
the appropriate status heading and be identified under the transaction
details as Customer Payment. Post Office does not consider a branch
discrepancy to be a debt owed by a Postmaster until the outcome of the
discrepancy review has established the cause of the discrepancy to be the
Postmaster’s (or the Postmaster’s assistant's) negligence, carelessness or
error and the Postmaster has agreed with this outcome. Upon agreement
with the outcome, the Postmaster is asked to contact the PAST (contact
details for which are provided in the Postmaster Account Support team
letter) and accept the discrepancy and discuss the account balance
[POL00448197].
Post Office recognises that it does not currently provide an explanation, in
its correspondence with Postmasters as to the meaning of the four
descriptors for the amounts referred in the statement of account. Further,
Post Office recognises that the statement of account includes a ‘statement
total’ that totals all amounts in relation to the four descriptors, including
Disputed Discrepancies, which could incorrectly lead a Postmaster to think
that the statement total is the amount owed by the Postmaster to Post
Office. The approach by which Post Office has treated discrepancies for
the purpose of the statement of account has been in place since before the
commencement of the RorD function. However, Post Office recognises
there is a risk of misunderstanding by Postmasters as to the relevance of
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204
205
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the four descriptors. As a result, Post Office intends to update the
statement of account and supporting letters so that information is clearer
and more easily understood by Postmasters, and appropriately reminds
Postmasters that it is for Post Office to prove any discrepancy was caused
by the Postmaster’s (or the Postmaster’s assistant's) negligence,
carelessness or error.’®
Post Office recognises the possibility that a discrepancy may not be
recovered if the balance remains on the branch account 60 days after the
date it was first added to the account, by making a balance sheet provision
for the full value. This process also charges the value to Post Offices profit
and loss account. A balance may remain on a branch account after 60 days
in a number of circumstances: the discrepancy review is still underway, the
discrepancy has been resolved and is awaiting Post Office action to update
the account, or the loss has been established but the Postmaster has not
agreed with this outcome.
Where a Postmaster offers to make payment to Post office in the amount
of the shortfall (negative discrepancy), including by way of instalments, the
discrepancy record on the branch account is updated as such, on Post
Office’s CFS, by the Postmaster Account Support Team. The balance will
still appear on the branch statement of account however it will show under
the heading Previously Agreed Discrepancies along with any payments
made against it. On the basis that the Postmaster has offered to pay the
shortfall amount, the provisioning process described above at paragraph
'® Post Office proposes to frame this information in lay terms and in a manner intended to not causeundue concer to
Postmasters.
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204 is not applied even if it remains unpaid after 60 days. If a Postmaster
were to make payment against a discrepancy that had already been fully
provisioned (i.e., after being unpaid for more than 60 days), the
discrepancy record would then be updated to show payment has been
agreed and, as such, the previously provisioned amount would be credited
back into Post Office’s profit and loss accounts.
In relation to former Postmasters, all accounts are fully provisioned for (as
described above at paragraph 204) when the Postmaster leaves the
branch even if a repayment plan is in existence and the discrepancy is not
yet 60 days old.
Rule 9(58) question 40: To what extent are unresolved discrepancies treated
by POL as debts to be recovered from an SPM, manager or assistant?
207
Post Office understands an unresolved discrepancy to refer to a
discrepancy that is still undergoing investigation (as described above at
paragraph 122 to 139); where a review has taken place but the cause of a
discrepancy has not been able to be established and the balance has been
removed from the account so there is no suggestion that a debt is due; or
where Post Office has established the cause of a discrepancy is as a result
of the Postmaster’s (or the Postmaster’s assistant's) negligence,
carelessness or error, but the Postmaster does not agree with Post Office’s
outcome and is going through the dispute process described in paragraphs
140 to 141 above. As and for the reasons set out in paragraph 191 above,
Post Office does not treat unresolved discrepancies as debts to be
recovered from a Postmaster.
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TRANSACTION CORRECTIONS
Rule 9(58) question 41: Please describe the current process by which
transaction corrections are issued. Please set out any relevant changes
made to the process following the findings of Fraser LJ or resulting from
evidence arising in the Inquiry
208
209
210
Transaction corrections are a method by which Post Office can ask a
branch to correct accounting differences identified through a number of
processes as outlined in paragraphs 212 and 213 below.
The Branch Reconciliation Team is responsible for issuing transaction
corrections and is led by the Head of Network Monitoring and
Reconciliation. The Branch Reconciliation Operations Manager works for
the Head of Network Monitoring and Reconciliation and is accountable for
the day-to-day operations in the Branch Reconciliation Team through 4
Team Managers and 48 Advisors. Advisors are recruited against a set of
core competencies required for the role and provided with specific
induction training based on the product area they will be working with.
Issuing a transaction correction is a process most often used to resolve an
existing discrepancy that the branch has experienced with an identifiable
cause. On average, there are currently around 10,000 transaction
corrections issued each month. The number of transaction corrections had
historically been higher (around 13,000 per month) due to a high number
of transaction corrections being required to reconcile the Camelot (National
Lottery) system. Now that Post Office no longer transacts National Lottery
products through its branches, this has significantly reduced the number of
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212
213
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transaction corrections issued, although data transmission issues with third
party systems could increase the number of transaction corrections issued
in a period.
By far the greatest number of transaction corrections (around 80%) relate
to the handling of cash (either due to errors in cash pouches or at-till
mistakes). Post Office deals with £tens of billions in cash each year.
Approximately two thirds of transaction corrections result in a credit back
to the branch and one third result in a debit being made to a branch account
[POL00448282 and POL00448230].
A transaction correction might be issued for the following reasons:
(a) Following an investigation, correcting a reconciling difference
between the Horizon system and third-party data. The Branch
Reconciliation Team receives two sets of data (typically in Excel
form) each day: one recording Horizon data and the other recording
third-party data. Automated processes detect where there are
mismatches between these two sets of data to identify potential
discrepancies requiring investigation.
(b) To correct an error, for example a mis-key error, that has been
notified to Post Office by a Postmaster, customer, bank, energy
supplier, or another third party.
(c) As a result of a discrepancy review following use of the RorD
process (e.g., to correct a stock discrepancy).
The process of issuing transaction corrections is as follows:
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The Branch Reconciliation Team will collect information from the
relevant parties (most importantly from the Postmaster) in order to
determine the cause of the data mismatch or verify the mis-key and,
where appropriate, a transaction correction can be issued reflecting
the outcome of these inquiries. There are many different scenarios
for data mismatches, some of which might be reconciled by
interrogation of the data itself, but many require contact to be made
with the branch and/or relevant third party to obtain further
information.
For cash pouch errors specifically, before a transaction correction is
issued, the branch is sent a letter from the cash centre informing
them that an error has been identified and notifying them that they
have three weeks to request further information/details about the
error. The letter also notifies the branch of the process to request to
view CCTV footage of the issuing cash centre and/or dispute the
error by telephoning the Branch Support Centre or cash centre. If
there is no contact from the postmaster within three weeks of the
cash centre sending the letter to the branch, the Branch
Reconciliation Team will issue the transaction correction.
Once the need for a transaction correction has been identified, the
transaction correction is issued to the branch with an explanation of
the reason it has been issued and the name and contact details of
the advisor who has issued it (for cash pouch errors the narrative
includes the team name and contact number).
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The majority of transaction corrections are issued for a small
number of similar errors and standard narratives are provided for
the advisors to use when completing the transaction correction
request template. The template also includes the name and contact
number of the Branch Reconciliation Advisor who issued the
transaction correction. This is to enable the Postmaster to contact
the relevant advisor directly to seek any further information or as
one method of commencing the process of challenging the
transaction correction. A sample of transaction correction request
templates is reviewed each month by each advisor’s Team Manager
to check that the documented policies and processes have been
followed and that the transaction correction was issued within those
guidelines.
The majority of transaction corrections are within the approval limits
of the Branch Reconciliation Support Advisor. All transaction
corrections regardless of amount follow an approval and sign off
process with high value transaction corrections, in excess of
£10,000, requiring a secondary Senior Manager sign off.
(f) Transaction corrections are issued to branches on a daily basis and
these can be actioned by the branch at any point during the trading
period. However, all transaction corrections have to be actioned
before a branch can complete its trading period end and move into
the next trading period.
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A Postmaster can choose to accept a transaction correction, which
will update the branch Horizon system and balance off the original
error, or choose to use the RorD function, which will move the
transaction correction value on to the branch account in order to be
reviewed via the transaction correction dispute process described at
paragraphs 106-120. A Postmaster is likely to use the RorD option
either if they disagree with the reason it has been issued and want
this reviewed (the Postmaster might have already spoken to the
branch reconciliation advisor), if they do not have the corresponding
physical cash surplus or deficit in branch or if they are awaiting a
compensating transaction correction as a result of conversations
with the advisor following the issue of the transaction correction.
I have been informed by Post Office’s Head of Network Monitoring
and Reconciliation that circa 3% of transaction corrections are
disputed.
If a discrepancy is identified towards the end of a trading period, the
transaction correction might not be issued until the following trading
period. A branch could therefore have a discrepancy at trading
period end that the Postmaster knows is likely to be corrected in a
future trading period. In this circumstance, the Postmaster could
either settle the discrepancy in branch knowing there will be a
transaction correction issued to correct this or choose to use the
ROD function to initiate an investigation which will identify that a
transaction correction is due to be issued [POL00448082;
POL00448083; and POL00448279].
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214 The current process differs significantly from the historical position where
a Postmaster was unable to roll over into the next trading period without
accepting a transaction correction. There are two key differences that Post
Office has introduced in order to minimise potential postmaster detriment:
(a)
A transaction correction will only be issued where the outcome of
the review/reconciliation exercise, as described in paragraph 131,
has shown Post Office that the transaction correction is necessary
to correct the position in branch. If the review/reconciliation exercise
is unable to verify this no TC is issued and the case is closed without
impacting the branch
A Postmaster now has the option either to accept the transaction
correction or, if they do not agree with why it has been issued or
have not had time to review the additional detail, they can use the
RorD function to prompt a review by NSRT. NSRT will then review
the original case and decide whether to uphold the original
transaction correction or propose another course of action, such as
issuing a compensating transaction correction.
Rule 9(58) question 42: Please confirm whether POL maintains a central
record of all transaction corrections issued, and/or all transaction
corrections disputed by SPMs, managers or accounts? If it does, please
confirm which department(s) hold responsibility for this record and who
holds responsibility for the management and oversight of that department.
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215 Acentral record of all transaction corrections issued will be visible in CFS.
216
217
However, an additional file is maintained by the Branch Reconciliation
Team and updated daily.
The process for updating the central record is as follows:
(a)
(c)
At around 10pm each night, Accenture (one of Post Office’s third-
party IT suppliers) run an automated process to extract the data for
all transaction corrections that took place that day from the CFS.
This data is consolidated onto a single file (in Excel format) and an
automated email attaching the file is created.
The automated email (and accompanying file containing that day's
transaction correction data) is sent to a designated group of people
within the Branch Reconciliation Team.
A member of Branch Reconciliation Team in receipt of the file will
then add the data from the Excel file to a central Excel file containing
all transaction correction data for that calendar year. The process of
updating the central Excel file is typically done by the same member
of the team each day, unless they are away and then the task is
deputised.
The Retail Performance Dashboard also provides a visual summary of: (i)
the volume and value of transaction corrections issued each period; and
(ii) the totals by period for the last 12 months. This summary view also
shows the top 10 products that the transaction corrections have been
issued for, with comparison to previous years. A separate slide within the
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same Retail Performance dashboard is also maintained as a record to
show the total volume and value of transaction corrections that have been
settled to ROD, and a breakdown of individual values [POL00448230].
POSTMASTER COMPLAINTS POLICY
Rule 9(58) question 46: Please consider WITN11190100 paragraph 71(a).
Please provide the Postmaster Complaints Policy and set out:
(a) IThe number of complaints received in accordance with the
policy;
(b) Key themes emerging from the responses; and
(c) I POL’s assessment of the policy’s effectiveness.
218 WITN11190100 was provided by my colleague, John Bartlett, who is Post
Office’s Director of Assurance and Complex Investigations. Paragraph
71(a) of that witness statement states:
“Consideration was given to ensure alignment between the
Whistleblowing Policy, the Postmaster Complaints Policy and the
Group Investigations policy.”
219 I understand from BSFf that Mr Bartlett will respond to Rule 9(58) question
46 insofar as it relates to Post Office’s Speak Up (whistleblowing)
arrangements. However, I, in my capacity as Central Operations Director,
am the person within Post Office with overall accountability to the Board
for the design and implementation of controls to manage Complaints
received from Postmasters as defined in the Postmaster Support Policy:
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Complaint Handling. Accordingly, I am the person with present involvement
in the other matters underlying this question and provide the additional
evidence below.
A copy of the current version of the Complaint Handling policy has been
produced to the Inquiry as [POL00447972].
The first version of the Complaint Handling policy came into effect on 22
January 2021. Postmaster Support policies are reviewed annually. The
current version 4.0 was signed off by ARC in May 2024. Annual completion
of a Postmaster Complaint Handling compliance module is mandatory for
all Post Office staff.
The number of complaints received in accordance with the policy
222
223
The Issues Resolution Team was created in January 2021. Its purpose is
to carry out thorough and effective investigations to resolve Postmaster
complaints. This team consists of 9 Issue Resolution Support Advisors
managed by a Team Manager who reports into the Head of Branch Support
Centre. Prior to January 2021, Postmaster complaints would have been
logged and handled by the Branch Support Centre Advisors.
I have been assisted by Post Office's Head of Branch Support Centre in
collating relevant data and set out in the table below the number of
complaints received by Post Office from Postmasters since the financial
year 2019/20:
Year No. of complaints
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2019/20 2,665
2020/21 3,337
2021/22 4,399
2022/23 4,725
2023/24 4,504
2024/25 (to P4) 1,458
From January 2021, the data in the table above relates to the number of
complaints created in Dynamics by the Issues Resolution Team and
assigned as a Postmaster complaint in the work-flow logging process. This
is irrespective of how the complaint was received (e.g., via a telephone call
into the BSC, via the Branch Hub form or via another Post Office
colleague). The data from prior to January 2021 shows calls logged as a
complaint by the Branch Support Centre Advisor as part of their business-
as-usual role.
Key themes emerging from the responses
225
A Postmaster experience forum is held every month and is chaired by the
Postmaster Experience Director, Mark Eldridge. Subject Matter Experts
from across Post Office attend the meeting as well as Postmasters. One of
the agenda items involves a review of complaints received since the
previous meeting to understand any key themes, possible drivers of
complaints, and seek feedback and insight from attendees on
improvements required to reduce issues in the future.
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226
227
228
229
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Generally, the most common complaint drivers, as documented and
reported to SEG and Board via the monthly Retail Performance
Dashboard, centre around the service provided by Post Office’s main
carriers (Royal Mail, Parcelforce, DPD etc.) and the accuracy of the branch
data accessed by customers through Post Office’s Branch Finder
application.
The Retail Performance Dashboard (produced to the Inquiry as
[POL00448230]) has recently been enhanced to provide additional detail
around the main drivers of Postmaster complaints. That shows that failed
collections are the most common driver for carrier-related complaints and
incorrect opening hours showing on Branch Finder are the most common
driver for complaints relating to Post Office’s Branch Finder application.
The Issues Resolution Team is also currently taking responsibility for
managing more complex cases, such as complaints from current and
former Postmasters relating to situations and circumstances from many
years ago that do not fall within the remit of the Historic Shortfall Scheme.
A piece of analysis was undertaken by Post Office on complaints received
in the first half of the 2023/24 financial year and this has been produced to
the Inquiry [POL00447958]. This document contains statistical data I hope
will assist the Inquiry in further understanding the key apparent themes as
outlined more regularly in the Retail Performance Dashboard discussed in
paragraph 227 above. That analysis showed:
(a) 45% of all Postmaster complaints related either to Parcelforce or
Royal Mail.
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(b) I 97% of the complaints related to Parcelforce related to failed or late
collections in branch.
(c) I The volume of complaints was 16% lower than the equivalent period
(i.e., the first half) in the 2022/23 financial year.
(d) I The top 5 complaints drivers (comprising 67% of all Postmaster
complaints received) were (in order):
(i) Parcelforce;
(ii) Royal Mail;
(iii) I Possible customer complaint (i.e., a complaint incorrectly
logged in Microsoft Dynamics as a Postmaster complaint
when, being a potential customer complaint, it should have
been passed to the Customer Team to investigate );
(iv) I Reversals/refunds; and
(v) Branch Finder services (incorrect branch-level data, such as
relating to trading hours, surfaced to customers via Post
Offices Branch Finder application).
Post Office’s assessment of the policy's effectiveness
230 Before I started working at Post Office, I understand KPMG reviewed the
original version of the Complaint Handling policy. At the time (August
2021), I can see from KPMG’s report [POL00423697] that their
assessment of the Complaint Handling policy view was:
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231
232
233
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“Postmaster complaints have a strong governance framework with
detailed policies and processes that clearly set out the investigation
requirements including the Postmaster complaints response
process and the steps to be followed for each case”.
KPMG identified several areas for improvement, including: introducing a
formal triage process and criteria to identify high risk or priority cases;
clarifying when legal input is required; ensuring independence of
investigators; implementing a training plan; and ensuring investigations
were consistently documented.
In March 2023, the Issues Resolution Team introduced the GE Complaints
inbox through which complaints received directly by Post Office Senior
Leaders should be directed to the Issue Resolution Team. This ensures a
case is created in Dynamics and the complaint is handled consistently and
in line with Complaint Handling policy. These complaints are, more often
than not, relatively complex complaints and using a separate inbox allows
them to be triaged and managed effectively. A weekly complex case review
meeting lead by the Issues Resolution Team’s Team Manager is attended
by members of the Retail Leadership Team to support with sensitive and/or
complex cases.
To recognise the increase in number of relatively complex complaints, the
Head of the Branch Support Centre is in the process of restructuring the
Issues Resolution Team. Day-to-day responsibility for the team will be
through an Operations Manager who will manage both the Team Leader
(responsible for the Issues Resolution Advisors) and 2 new Executive
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234
235
236
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Complaint Manager roles who will take responsibility for managing the
more complex complaints, including understanding if the complaint
requires legal input. The Head of Branch Support Centre is currently
developing the additional training the successful applicants will receive in
recognition of the complexity of the cases they will be dealing with
The Complaint Handling policy has, since August 2021, been subject to
two internal reviews by Post Office Group Assurance; the first in February
2022 and the second in March 2023.
The February 2022 review (Group Assurance’s Policy Monitoring Report is
produced to the Inquiry as [POL00448359)) and was broadly positive in its
assessment of the Complaint Handling policy as it then was. The overall
rating was a “2” (on a five-point scale from “1” down to “5”), which indicates
that the document was considered to be “satisfactory”, with “/ow’ residual
risk (the highest assessment, a “1”, would have indicated an assessment
of “satisfactory” with “insignificant’ residual risk).
The March 2023 review (Group Assurance’s Policy Monitoring Report is
produced to the Inquiry as [POL00448360]) of the Complaint Handling
policy v 3.0 (which was in effect at that time) was less positive. On a four-
point scale (from “satisfactory” to “unsatisfactory’) the Complaint Handling
policy was assessed as “needs significant improvement’). That rating was
“predominantly based on the lack of direct evidence to support the various
risk areas’. In my view, the lower assessment did not reflect a deterioration
in the standard of the policy, but a more rigorous and exacting review.
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Because of that review, six specific improvement actions were assigned to
the Retail Team. I have set these out in the table below along with an
overview of their current status:
Improvement Action
Current Status
Regular meetings between Speak
Up and the Issue Resolution
Manager to be put in place to
ensure the relevant risk is
managed properly
Regular meetings are now in
diaries and the action is now closed
with approval from Post Office
Group Assurance.
Voice of Postmaster meetings to
be reinstated and communications
with Postmasters improved so that
thematic issues can be addressed
properly
Equivalent engagement meetings
have been set up and the action is
now closed with approval from Post
Office Group Assurance.
Risks were to be articulated better
(they were, prior to this point,
articulated primarily as just impacts
rather than hazards and impacts)
The articulation of identified risks
has, I believe, been improved,
although the updates are awaiting
approval from Post Office Group
Assurance.
Risk controls were set out as
processes rather than specific
actions, making it difficult to assess
their effectiveness
Updates have been made to the
required operational standards in
line with the guidance provided by
Post Office Group Assurance,
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238
239
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although the updates are awaiting
approval from Post Office Group
Assurance.
Acomplaint service level needed to I A complaint service level has now
be stated been included with approval from
Post Office Group Assurance.
Service level data needed to be I This is being done and the tracking
tracked to enable recurring I has been approved by Post Office
themes, issues and root causes to I Group Assurance.
be identified
In terms of further indicators of the Complaint Handling policy's
effectiveness, I note that the approved service level is to aim to resolve
complaints within 10 working days. Our current target is to resolve 85% of
complaints in accordance with that service level and, at present, we are
typically meeting or exceeding that target. I believe that most complaints
are resolved materially within that timeframe, however, recognise that the
more complex cases often take longer to investigate and resolve due to the
nature of the complaint. I am also not aware that any Postmaster
complaints have ever been raised about the approach to complaint
handling that is reflected in the policy.
However, as I have been asked by the Inquiry to provide a candid narrative,
I think it is fair to say that, from my perspective as the person accountable
for the implementation of the policy, the Complaint Handling policy works
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very well for the routine complaints that make up most complaints received.
For more complex and unusual complaints, it can be somewhat less
effective and many of the complaints currently outside of the 10-day
resolution expectation are cases of this nature. Improving its effectiveness
in relation to these more complex complaints is a focal point of ongoing
activity.
Statement of Truth
I believe the contents of this witness statement to be true.
Dated: : 22° Ausspad 2O2RY
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Index to First Witness Statement of Melanie Park
WITN11600100
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Exhibit I URN Document Description Control No.
No.
POL00448229 I Postmaster Accounting Dispute
1. Resolution Policy V4.1 POL-BSFF-104-
0000188
POLO00448000 I Postmaster Account Support Pol I POL-BSFF-107-
2. (1) 0000084
POL-BSFF-146-
3. POLO0460566 I Network Transaction Corrections I 0000001
Policy V4.1
POL00448294 I Postmaster Onboarding Policy POL-BSFF-104-
4. V4.1 0000253
POL00448207 POL-BSFF-104-
5. Postmaster Training Policy V4.1 I 0000166
POL00447972 I Postmaster Complaint Handling I POL-BSFF-107-
6. Policy V4.0 0000056
POL00448252 I Network Monitoring and Branch I POL-BSFF-104-
7. Assurance Support Policy V4.1 I 0000211
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Strategic Executive Group
entitled "Loss Recovery Update"
(17 July 2014)
Network Cash and Stock I POL-BSFF-118-
8. I POL00448331 I Management Policy V4.0 0000001
POL00448204 I Postmaster Contract POL-BSFF-104-
9. Performance Policy V5.1 0000163
POL00448254 I Postmaster Contract POL-BSFF-104-
10. Suspension Policy V5.2 0000213
POL00448206 I Postmaster Contract POL-BSFF-104-
11. Termination Policy V5.1 0000165
POL00448205 I Postmaster Contract POL-BSFF-104-
12. Termination Decision Review 0000164
Policy V3.1
POL00448077 I Postmaster Support Guide POL-BSFF-104-
13. 0000036
POL00448058
14, Deloitte's Postmaster Journeys I POL-BSFF-104-
Report (March 2021)
0000017
POL00448362
15. Presentation to Post Office's I POL-BSFF-116-
0000011
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POL00448520
16. Meeting minutes of SEG meeting I POL-BSFF-123-
17 July 2024 0000001
POL00448356
17. Job description for Post Office I POL-BSFF-116-
Operations Support Specialist I 0000005
(July 2024)
POL00448224
18. Branch Assurance team I POL-BSFF-104-
structure (July 2024) 0000183
POL00448357
19. Pro forma Rationale Document I POL-BSFF-116-
0000006
POL00448200
20. Branch Assurance Chapter 2: I POL-BSFF-104-
Performing a Branch Assurance I 0000159
Visit Version 2.7 (July 2024)
POL00448253 I PM Letter Your BA visit today v3
21. POL-BSFF-104-
0000212
POL00448256
22. Branch Assurance Advisor - I POL-BSFF-104-
Induction & Training Programme
Version 4.0 (January 2023)
0000215
WORK\53635620\v.1
104
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Classification: Confidential
WITN11600100
WITN11600100
23.
POL00448201
Branch Assurance Chapter 5:
Robbery & Burglary Branch
Assurance Visits Version 6.1
(June 2024)
POL-BSFF-104-
0000160
24.
POL00448202
Branch Assurance Chapter 6:
Retention of Papers Version 5.0
(May 2024)
POL-BSFF-104-
0000161.
25.
POL00448047
Retail Compliance Team
Meeting: 18 and 19 July 2024
slide deck
POL-BSFF-104-
0000006
26.
POL00448199
Operational Excellence Branch
Assurance Team Charter (May
2024)
POL-BSFF-104-
0000158
27.
POL00448255
Terms of Reference for Branch
Assurance Visit Alignment
Meeting Version 2.0 (March
2024)
POL-BSFF-104-
0000214
28.
POL00448203
Quality Assurance Review Tool
Version 6.5
POL-BSFF-104-
0000162
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105
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Classification: Confidential
WITN11600100
WITN11600100
POL00448231
29. 03.00_POL_GE_Operational POL-BSFF-104-
Excellence Programme Update I 0000190
(20240131)
POL00448190
30. 04.03_POL_GE_Postmaster POL-BSFF-104-
operational excellence I 0000149
incentives (20240117)
POL00448358
31. BUSINESS CASE WATERFALL I POL-BSFF-116-
Operational Excellence - Note I 0000007
Counters PRJcode
POL00448328
32. IADG decision for OE & OE Note I POL-BSFF-116-
Counter PRJ0046222 0000003
POL00448235
33. Stock Autorem Benefits Case POL-BSFF-104-
0000194
POL00448230
34. POL SEG Retail Performance I POL-BSFF-104-
Dashboard P3 2024 0000189
POL00448234
35. Ops Ex One Pgr 2024 I POL-BSFF-104-
(POLCC32-24 V1.0)
0000193
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WITN11600100
WITN11600100
POL00448192
36. POL-BSFF-104-
PM email - remuneration update I 0000151
POL00448193
37. 240319 - BOAP Update Ops I POL-BSFF-104-
Excellence Steerco 1 0000152
POL00448245
38. POL-BSFF-104-
AM JD 2024 0000204
POL00448188
39. Operational Excellence — I POL-BSFF-104-
Review (Nov 2023) 0000147
POL00448361
40. OPERATION_MANUAL POL-BSFF-116-
(20240726) 0000010
POL00448268
41. Ops Training Guide Section 10 I POL-BSFF-104-
END OF DAY V4.0 (July 2023) I 0000227
POL00448272
42. Ops Training Guide Section 14
CASH & STOCK
MANAGEMENT V4.0 (July
2023)
POL-BSFF-104-
0000231
WORK\53635620\v.1
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Classification: Confidential
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WITN11600100
POL00448269
43. Ops Training Guide Section 11
WEEKLY ACCOUNTING V4.0 I POL-BSFF-104-
(July 2023) 0000228
POL00448048
44. POL-BSFF-104-
TP END Screen shots 0000007
POL00448270
45. Ops Training Guide Section 12
MONTHLY ACCOUNTING V4.1 I POL-BSFF-104-
(February 2024) 0000229
POL00448219
46. NS&R Org Chart (Current 15‘ I POL-BSFF-104-
July 2024) 0000178
47. I POL00039629 I Tier 2 & PAST Role Profile I POL-0036113
(Current) - Generic Support
Advisor (PO Grade).
POL00448081
48. Case Investigation and Review I POL-BSFF-104-
Analyst JD Tier 3. 0000040
POL00448070
49. Triage Process Map ("INV- I POL-BSFF-104-
TRI01-Triage process-V2.0").
0000029
WORK\53635620\v.1
108
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Classification: Confidential
WITN11600100
WITN11600100
50.
POL00448072
Escalation Process Map ("INV-
ESC01-Escalation process-
V2.0").
POL-BSFF-104-
0000031
51.
POL00448069
Weekly Case Review Process
Map ("INV-WCRO1 - Weekly
Case Reviews v1.0").
POL-BSFF-104-
0000028
52.
POL00447943
A&Cl Referral Process Map
("INV-CIU01 Clu referral
process v1.1")
POL-BSFF-107-
0000027
53.
POL00448068
Contract Team Referral Process
Map ("INV-CTRO1 Contract
Team Referrals v1.0.").
POL-BSFF-104-
0000027
54.
POL00448191
Investigating Discrepancies
Digital WorkAid for Postmasters
("INVD A4 Digital Work Aid V5.0
March 2024").
POL-BSFF-104-
0000150
55.
POL00448187
Guidance to Postmasters on use
of the Review or Dispute Option
on Horizon (20 February 2023)
POL-BSFF-104-
0000146
WORK\53635620\v.1
109
65113.3
Classification: Confidential
WITN11600100
WITN11600100
("003 CALL BSC One article
(1)").
56.
POL00448073
Email to Postmasters with
guidance on RorD function (24
February 2023) ("007 PM email -
24 February23_OFBEC4CO0-
24DE-4553-B46D-DD32.)
POL-BSFF-104-
0000032
57.
POL00448257
BSC Discrepancies - Knowledge
- Microsoft Dynamics 365
POL-BSFF-104-
0000216
58.
POL00037518
Common Issues Judgement:
Summary of the Effect on
Postmaster Contracts ("Contract
Restatement Summary").
POL-0034453
59.
POL00448295
Script 01 Proactive engagement
for negative discrepancies V1.1
POL-BSFF-104-
0000254
60.
POL00448197
Example Current Postmaster
Discrepancy Letter 1 &
Statement.
POL-BSFF-104-
0000156
WORK\53635620\v.1
110
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Classification: Confidential
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WITN11600100
POL00448186
61. Template Postmaster I POL-BSFF-104-
Discrepancy Letter 1. 0000145
POL00448246
62. Template Postmaster I POL-BSFF-104-
Discrepancy Letter 2. 0000205
POL00448082
63. Template acknowledgement I POL-BSFF-104-
letter to Postmaster _—_re I 0000041
Transaction Correction
investigation.
POL00448223
64. NSRT Triage checklist questions I POL-BSFF-104-
0000182
POL00448365
65. Write Off Suspense Policy V4.4 I POL-BSFF-116-
Mar 2024. 0000014
POL00448059
66. Email Template -— Tier 2 to I POL-BSFF-104-
Investigate. 0000018
POL00448196
67. Central Operations Period I POL-BSFF-104-
Dashboard. 0000155
POL00448218
68. Quality Assurance Checklist. POL-BSFF-104-
0000177
WORK\53635620\v.1
11
65113.3
Classification: Confidential
WITN11600100
WITN11600100
POL00448043
69. Dispute Resolution Review I POL-BSFF-104-
Committee Terms of Reference. I 0000002
POL00448083
70. Template letter to Postmaster I POL-BSFF-104-
following investigation of I 0000042
transaction correction.
POL00448071
71. Email Template - Outcome Write I POL-BSFF-104-
Off. 0000030
72. I POLO0039599 I Service Desk Team Lead JD. POL-0036081
POL00448290
73. Discrepancy Investigation - I POL-BSFF-104-
Guidance Note. 0000249
POL00448289
74. POL Investigations Team I POL-BSFF-104-
Training November 2021. 0000248
POL00448220
75. Tier 2 Report writing Training. POL-BSFF-104-
0000179
POL00448281
76. ARQ Form 2024. POL-BSFF-104-
0000240
WORK\53635620\v.1
112
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Classification: Confidential
WITN11600100
WITN11600100
POL00448322
77. Internal Audit Report - I POL-BSFF-116-
Postmaster Issue Resolution. 0000001
POL00448078
78. ClJ 4 Shortfalls Final report v1.0. I POL-BSFF-104-
0000037
POL00448079
79. ClJ 5 Loss Prevention Final I POL-BSFF-104-
report v1.0 0000038
POL00448080
80. ClJ 6 Transaction Disputes Final I POL-BSFF-104-
report v1.0. 0000039
POL00448292
81. Quality Assurance Report March I POL-BSFF-104-
2024. 0000251
POL00448075
82. Assurance Review Postmaster I POL-BSFF-104-
Accounting Dispute Resolution I 0000034
FINAL DRAFT.
POL00448076 I Network Transaction POL-BSFF-104-
83. Corrections Policy Review 0000035
POL00448055
84. KPMG POL Investigations I POL-BSFF-104-
Target Operating Model Report.
0000014
WORK\53635620\v.1
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Classification: Confidential
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POL00448325
85. Ernst Young Branch I POL-BSFF-116-
Discrepancies 0000002
Recommendations Report.
POL00448060
86. 004 Changing the term Settle I POL-BSFF-104-
Centrally 0000019
POL00448282
87. TC Average Values Request July I POL-BSFF-104-
2024 0000241
POL00448279
88. Transaction Correction Horizon I POL-BSFF-104-
Screenshots 0000238
POL00447958
89. Postmaster Complaints Analysis I POL-BSFF-107-
FY23/24 0000042
POL00423697
90. Project Birch Report 260821 POL-BSFF-
0238515
POL00448359
91. Group Assurance Monitoring I POL-BSFF-116-
Report February 2022 0000008
POL00448360
92. Group Assurance Monitoring I POL-BSFF-116-
Report March 2022
0000009
WORK\53635620\v.1
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Classification: Confidential