Filed on behalf of the: Defendant

Witness: Dawn Phillips

Statement No.1
Date Made: 28 September 2018

Claim No: HQ16X01238, HQ17X02637 & HQ17X04248

THE POST OFFICE GROUP LITIGATION
IN THE HIGH COURT OF JUSTICE
QUEEN'S BENCH DIVISION
ROYAL COURTS OF JUSTICE

BETWEEN:

ALAN BATES & OTHERS

Claimant

AND

POST OFFICE LIMTED

Defendant

WITNESS STATEMENT OF DAWN LOUISE PHILLIPS

I, DAWN LOUISE PHILLIPS of No 1 Future Walk, Chesterfield, 849 1PF WILL SAY as
follows:

1. I am employed by Post Office Limited (Post Office) as a Team Leader for Agent
Accounting and Santander Banking. I am authorised to make this statement on
behalf of Post Office.

2. The facts set out in this statement are within my own knowledge, or if they are
outside my knowledge, I have explained the source of my information or belief.

BACKGROUND

3. I was originally employed in August 1999 by Post Office via an employment

agency and during this time was involved in the Agents Accounting Team, Data
Processing Unit and processing Santander transactions errors. In 2013, I then
worked on a specific event contract for a year which involved DVLA and Fleet
activities, before moving to the Former Agent Accounting Team in 2014. The
Former Agent Accounting Team collect debt from former Postmasters. In 2014 I
moved to the Agent Accounting Team and I have been the Team Leader for
Agent Accounting and Santander Banking since November 2016.

4. In my current role I oversee the process of recovering the losses that Postmasters
have declared in branches.

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BALANCING AT THE END OF A TRADING PERIOD ("TP")

5. There are 12 TPs in a year. At the end of a TP Postmasters are required to

perform a balance and complete a branch trading statement (BTS). I understand
from Post Office's solicitors that my colleague David Johnson will be explaining
the balancing process in his witness statement.

6. If a Postmaster declares a discrepancy (either a surplus or a shortfall) at the end

of a TP that is less than £150 they must "make it good" by either removing money
from the till (in the event of a surplus) or adding money to the till (in the event of a
shortfall). As explained in paragraph 9 below, Postmasters can contact the NBSC
helpline to request assistance in identifying the cause(s) of discrepancies.

7. Where the discrepancy is over £150 the Postmaster also has the option to "settle
centrally". My team runs a report every Monday to identify Postmasters that·have
chosen to settle shortfalls centrally. We then write to those Postmasters to make
arrangements for the amount to be paid back or deducted from their
remuneration. An example of this standard form letter can be seen at {POL-
0440085}.

8. The standard letter contains a statement of the shortfall and explains how
payment can be made. It also provides an email address and telephone number
for my team should the Postmaster have any queries or questions about the
shortfall.

8.1 If we do not receive a response within 7 days we send a second letter {POL - {F/1833}
0440086}.

DISPUTED DISCREPANCIES

9. A Postmaster is not able to dispute discrepancies on Horizon or record that they

have raised a dispute on Horizon. However, Postmasters are able to call the
Network Business Support Centre (NBSC) Helpline or my team (Agent
Accounting) and raise a dispute.

10. If a Postmaster calls my team after receiving our request for payment and
explains they are raising a dispute, we will place a block on their account on the
system until the dispute is resolved. If they do this within 7 days we will not send
the second letter referred to in 8.1 above, but a Postmaster can dispute a shortfall
at any stage in the process (not just after the first letter).

11. When a Postmaster disputes a shortfall with my team we gather as much

information as possible from the branch about why they are disputing it. We also
send them a Branch Dispute Form to complete with details of the discrepancy and

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why it is disputed {POL -0440084}. Branches are given seven days to return the {F/1831}
completed form, otherwise we unblock the shortfall and send them another letter
requesting payment. We also make two telephone calls to a branch requesting
payment of the shortfall before we take further action regarding it.

12. The Branch Dispute Form was introduced to capture the key areas of information
we would collect from a branch about a dispute. Whilst the Branch Dispute Form
was only recently introduced at the beginning of 2018, the process of collecting
this key information from the branch has been in place since November 2016 and
this information would usually be collected by telephone, email or letter from the
branch.

13. Postmasters can also contact the NBSC helpline for assistance with identifying
the cause(s) of discrepancies including those that are less than £150.

STATEMENT OF TRUTH

in this witness statement are true

Signed:

Dawn Phillips

Date: .........c?..?.!9-..: !t:?::e.. ~-~:..................................

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