Written evidence submitted by Second Sight Support Services (POH0031)

RAIS I NG CONCERNS WITH HORI ZON

Introduction - The Purpose of t his Document

This is a paper which has been issued by the agreement of Post Office Limited and the Justice for Subpostmasters Alliance (JFSA).

Post Office Limited is concerned to hear about and determined to thoroughly and even-handedly investigate cases where there have been persistent  assertions  that the Horizon system (Horizon) may be the source of unresolved shortages in Post Offices.

Post Office Limited cares about its agents, the thousands of subpostmasters and subpostmistresses (SPMRs) operating branches across the land for the benefit of the community. Post Office Limited is committed to the highest standards of corporate governance, openness, probity and accountability. It is happy to be sensibly challenged and believes this to be a good thing.

Post Office Limited also acknowledges that there may be a concern that some SPMRs might not express their concerns because they feel that speaking up would be detriment al to their position, that they may also fear that they will be harassed or victimised if they speak out, and. that in these circumstances they may  prefer  to ignore their concerns than to report them.

Post Office Limited would like to take this opportunitv to emphasise  that  these fears are unfounded. Although SPMRs are not employees of Post Office Limited, Post Office Limited takes seriously any such allegations.

Therefore Post Office Limited, working with JFSA, is setting out In this document a process where you can raise concerns regarding Horizon, and feel comfortable about doing so. Any investigation of  any concerns  which  you may  raise will not influence or be influenced by any disciplinary or network transformation actions that already affect you.

This process also applies to all Post Office- Limited employees,  contractors  and agency staff working with Horizon for Post Office Limited.

In summary this document alms to:

-  reassure you that you should have no fears about raising any concerns over Horizon, including over victimisation and reprisals;

-   provide you with a process for raising any such concerns;

-   demonstrate to you that your concerns will be taken seriously and that you will get a response to your concerns; and

-   give you options if you are still not satisfied.

However Post Office Limited takes deliberate fraud, dishonesty and Illegal conduct against it very seriously, and has a duty to protect Post Office money and take action if it has reasonable suspicions regarding the same. So you should only raise your concerns through this process in good faith, and not frivolously, maliciously or for personal gain.              ·

How to voice your concerns

There are two steps you can take to voice your concerns.  You  can either contact  JFSA in the first instance (see (A) below), or you can go directly to Second Sight Support Services Limited (Second Sight), an independenthird party which is already undertaking a review of several Horizon cases in consultation with the Right Honourable James Arbuthnot MP (see (B) below).

(A)    Initial Steps you can take with JFSA

1.     You can discuss any concerns with JFSA and/or its advisers (cont act det ails at jfsa.org.uk). JFSA undertakes to treat these  discussions  as  confidential.  It  is then your decision as to whether or not you wish  to  pursue  your  concerns through the Inquiry Route set out in Section B below.

2.     If you decide to discuss your concerns with JFSA, you should make sure you  gather all your evidence together including all relevant documents, transaction references, helpline references, copies of correspondence, contact details and an outline of your concerns and any subsequent discussions with Post Office Limit ed. You should retain all original documents at this time although they  may  be required later.              ·

3.   You should provide JFSA with photocopies or PDF copies of all relevant documents, which will be examined by JFSA and/or JFSA's advisers .

4.    At th is t ime JFSA undertakes that it will keep all information strictly confidential and neither Post Office Limited nor Second Sight will be made aware of any discussions with or submissions to JFSA. ]FSA undertakes not to reveal any details about you, your FAD code or branch location to Post Office Limited until JFSA agrees with you that your concerns will be raised as part of the Inquiry.

(B)    The lnguiry Route - an Overview

1.   The Inquiry will be carried out by Second Sight within a "no blame" framework.

2.    If you are a  Horizon user (whether as a Post Office Limited employee,  contractor or a former or existing subpostmaster), you can submit your experiences of and concerns with Horizon for  consideration  under  the Inquiry  through JFSA  or  by co ntacting . Second Sight at Tythe Farm, Maugersbury, Cheltenham, Gloucestershire GL54 lHR. You must do this by 28 February 2013.

3.    Except In a case where deliberat e fraud, dishonesty or Illegal or unlawful conduct is suspected, no information voluntarily submitted for the Inquiry in good faith will be used for any purpose other than the Inquiry. However, Second Sight may

pass that information to Post Office Limited to enable Post Office Limited to respond to any Issues or questions arising out of the Inquiry.

(C)   The Inquiry - the Detail

Deta.ils  of  the Remit, Conduct and  Output  o_f the Inquiry are set out  in  the Appendix to this document.

Talcinq mattel's furthe1·

If for any reason you are not satisfied with the findings and wish to take matters further, you are of course free to pursue other avenues which JFSA can help you with.

Equally, if Post Office Limited has good reason  to  suspect  that there may  indeed have been fraud, dishonesty or other illegal or unlawful conduct, it may decide to pursue such matters in the civil or criminal courts.

Dated:

Issued by and on behalf of Post Office Limited

Signed-              --              - -  _-,-,-.-              -= =               ·-

APPENDIX

The Second Sight Inquiry - the Detail The Remit of the Inquiry

The rem it of the Inquiry will be to consider and to advise on whether there are any systemic Issues and/or concerns with the "Horizon" system, Including training and support processes, giving evidence and reasons for the conclusions reached.

The I nquiry is not asked to investigate or comment on general improvements which might be made to Horizon, or on any individual  concern raised (see below)  save to the extent that it concludes that such investigation or comment  is  necessary  to address the remit.

The I nquiry is not a mediation or arbitration. It is not intended  to  resolve or  affect  any dispute there may be between any individual Horizon user and Post  Office Limited.

The Conduct of the Inquiry

1. Submission of concerns

As highlighted, you can raise concerns directly with Second Sight. However, you must do so by 28 February 2013.

By submitting a concern you will have agreed that it  may be taken forward Into the I nquiry process, and that as a consequence Post Office Limited may become aware of the content of the concern.              ·

When submitting a concern, you should seek to ensure that you include all of the relevant facts of your experience of Horizon.  You should include  a  written summary  of the concern, all relevant documents, contact details,  transaction  referen ces, helpline references, copies of correspondence, an outline description of the error incident and any subsequent discussions with Post Office Limited .

Second Sight will decide whether it will investigate an individual concern in detail as part of the Inquiry, having regard to the remit. Second Sight may consult JFSA in connection with this decision. The I nquiry will not consider any concern which becomes the subject of a civi l or criminal court case.

2. No Blame Framework

If:

-   your concern Is submitted' in good faith;

-    you honestly and reasonably believe at the time of submission that the facts It contains are substantially true and complete, so far as you know;

-   the concern is. not submitted with the intenfion of making personal gain (for the avoidance of doubt this does not include the SPMR believing or hoping that SPMRs generally rnay benefit from the outcome of the Inquiry); and

-   the concern does not reveal conduct which is or which is likely to amount to  fraud or any other criminal offence, or which may give rise to a civil claim

and subject to there being no overriding public interest to the contrary, Post Office Limited will not subject you to any detriment either as a result of having submitted a concern, or as a result of Post Office Limited becoming aware of any Information contained within a concern, For the avoidance of doubt, information already known to Post Office Limit ed at the time that the concern is submitted may continue to b·e used by Post Office Limited for any purpose.

3. Establishment and conduct of Inquiry

Post Office Limited will pay Second Sight to conduct the Inquiry within a total budget agreed between Post Office Limited and Second Sight. Second Sight wilr be contractually obliged to complete the Inquiry within  the  agreed  total  budget,  and both Post Office Limited and JFSA will co-operate  with Second Sight to  facilitate  this. I f the agreed total budget is or is likely to be reached before a report has been published, Post Office Limited and JFSA will meet to discuss options.

All inform ation received by Second Sight from whatever source in connection with the Inquiry will be held confidentially and will only be used for the purposes of the Inquiry.

JFSA can provide Second Sight with anonymised copies of any or all concerns to enable Second Sight to conduct the Inquiry. Second Sight may provide any such anonymised documents to Post Office Limited so that it can provide input and assistance to the Inquiry,

Post Office Limited may provide Second Sight with its own comments on any or all concerns, and on Horizon generally.

In order to carry out the Inquiry, Second Sight will be entitled to request information related to a concern from Post Office Limit ed,. and if Post Office Limited holds that information, Post Office Limited will provide it to Second Sight.

Post Office Limited will provide Second Sight with such hardware, software and technical information and administratiye support as Second Sight may· reasonably require to carry out the Inquiry.

Second Sight wlll ·determine the process it will follow for the Inquiry  using  its judgment·, after consult ation with Post Office Limited and JFSA.

The Output of the Inquiry

Second Sight will consult with JFSA, Post Office Limited, and/or any other party as it considers necessary before producing any report. No party may Introduce any wholly

new issue or concern at this stage, and the parties will each keep the consultations with Second Sight and their contents confidential.

Second Sight will consider and take into account any comments received from JFSA, Post Office Limited and/or any other consulted party, . and may conduct further Investigations if necessary in light of the comments (having regard to the agreed total budget). Second Sight will then produce the report by a date agreed between Post Office Limited and Second Sight.

The report will report on the remit and If necessary will contain recommendations and/or alternative recommendations to Post Office Limited relating to the Issues and concerns investigated during the Inquiry. The report and recommendations are to be the expert and reasoned opinion of Second Sight in the light of the evidence seen during the I nquiry.

The report may be published. Until it Is published, JFSA (and its advisers), Post Office Limited, and any other party consulted by Second Sight will keep the report and evidence confidential.

Second Sight will prepare the report so that so far as is reasonably  possible,  It  may be published without redaction of personal data and/or information  that  is  confidential or commercially sensitive for Post Office Limited or any Horizon user, bearing In mind the primary need to ensure that the report is reasoned and evidence based.

June 2020