Filed on-beharf of

,ffi 3:tHfiil
Statement No.: First
Date Made: 23 August 201 8

THE POST OFFICE GROUP LITIGATION

Claim Nos: HQ16X01238, HQ17X02637 and HQI7X04248

IN THE HIGH COURT OF JUSTICE

QUEEN'S BENCH DIVISION
ROYAL COURTS OF JUSTICE

BETWEEN:

ALAN BATES & OTHERS

Claimants

AND

POST OFFICE LIMITED

Defendant

WITNESS STATEMENT OF ELAINE RIDGE

I, ELAINE RIDGE, of WILL SAY

as follows:

1. I was a Network Contract Advisor for Post Office Limited (Post Office). I am
authorised to make this statement on behalf of Post Office.

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.

3. ln this statement:

3.1 the term Subpostmaster is used to generally refer to agents of Post

Office who operate branches on its behalf, including subpostmasters,
subpostmistresses, franchisees, postmasters and operators; and

3.2 paragraph references are to paragraphs of the lndividual Particulars of

Claim (IPOC) of Lead Claimant Mr Naushad Abdulla (Mr Abdulla),
unless otherwise stated.

INTRODUCTION AND BACKGROUND

4. I started my career with Post Office in 1980 as a counter clerk working in a Crown
branch in London. I to become an Assistant Branch Manager in
progressed
around 1987 and later a Branch Manager in the 1990s. ln the early 1990s, I

AC 151481740
 Claim Nos: HQ16X01238, HQ17X02637 and HQ17X04248

covered a colleague in thei position of an Area Manager, which involved visiting a

large number of branches. I was mainly field based at this point in time.

ln the late 1990s / earty norg'hties I was appointed as a Contracts Advisor. As a

Contracts Advisor, part of my role was to interview applicants for the position of
Subpostmaster. lleft Post Office in 2015.

6. This statement focuses on my interview of the Lead Claimant, Mr Abdulla.

THE INTERVIEW OF MR ABDULLA

7. Around the time of Mr Abdulla's interview, I was carrying out approximately 5 to 6

interviews a week, sometimes several in one day, and so it is difficult to recall the
exact details of each interview.

8. I can see from the documents I have been provided with by Post Office's solicitors

that I carried out Mr Abdulla's interview on 22 November 2006 together with

Christine Adams. Christine was an ex Contracts Manager and was well versed in
carrying out interviews, as I was. At the time of this interview Christine had
changed roles to become a Retail Sales Manager. I would have most likely lead
the interview in the areas where we were discussing contractual topics with the
applicant and Christine would most likely have lead the interview where we were
discussing sales, staffing and training with the relationship, in accordance with our
different roles at Post Office. The interview would have been carried out jointly.

9. After refreshing my memory from disclosed documents, I can recall the branch
that Mr Abdulla was applying to operate, which was located in 10 - 12 Charlton
Church Lane in New Charlton, London. I can recall that the applicant was in the
business of selling pharmaceuticals, although I cannot recall Mr Abdulla
personally.

10. I had a standardised way of carrying out interviews of those applying to be

Subpostmasters, so each interview would have contained the same elements.
The first part of Mr Abdulla's interview would have been focussed on his business
plan. I can recall that Mr Abdulla's parents had run a branch before.

11. I would have run through the standard interview checklist at the end of Mr
Abdulla's interview, as I did in every interview I conducted. I have been shown by
Post Office's solicitors two different versions of the interview checklist {POL-
0031456/2) and Exhibit BAT1/5 which my colleagues at Post Office used at
different interviews. From my recollection, these interview checklists cover the
same areas in the list I would have discussed during Mr Abdulla's interview and

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 Claim Nos: HQ16X01238, HQ17X02637 and He17X04248

cover the same key areas. Using the checklist ensured I had covered all of the
key areas in that interview. I would use this checklist whether the applicant was
applying for a role under the standard Subpostmasters Contract or the Modified
Subpostmasters Contract.

12. Using the checklist for reference, I would have explained to Mr Abdulla that:

12.1 The Subpostmaster's contract was a contract of services not

employment.

12.2 Post Office was unable to guarantee his remuneration as this was
linked to the products and services offered at the branch. I would have
expanded on this to say that his remuneration could go up or down
from the estimated figures that he had been provided with prior to the
interview.

12.3 Post Office could change the products and services offered at any
time.

124 Even if he was not physically present in the branch, he was ultimately
responsible for everything that happened in the branch.

12.5 He was responsible for hiring and training his staff as his assistants
were his employees, not Post Office's.

12.6 He would be required to prepare regular branch accounts and would be

required to make good any losses immediately. I would have given a
standard example that it didn't matter if the loss was fl or f1,000, it
was his responsibility to make good that loss. I would also have briefly
mentioned the possibility of gains.

12.7 The training Mr Abdulla would receive if successful with his application.

12.8 The helpline he would have access to.

12.9 That the contract could be ended at any time by Post Office, and that if
there was anything untoward that happened at the branch, that Post
Office could suspend him or end the contract immediately. I wouldn't
have mentioned the 3 month notice period specifically during the
interview.

13. ln paragraph 9, it is alleged that Post Office did not explain to Mr Abdulla how the
contract worked and how the terms would be applied in practice at the interview
or before he was appointed. I think he is wrong about that. I can see from the

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 Claim Nos: HQ16X01238, HQl7X02637 and HQ17X04248

documents I have been shown by Post Office's solicitors that Mr Abdulla was sent
an invitation to interview letter {POL-0A29779} which enclosed a summary of the
conditions of the Modified contract. I am confident that I would also have run
through a summary of key contractual requirements in relation to the Modified
contract with Mr Abdulla, as running though the key contractual provisions was
something I did at every interview irrespective of the contract type.

14. ln paragraph '10, it is alleged that I represented that Post Office would be working
in partnership with Mr Abdulla. I cannot recall discussing anything like this with
Mr Abdulla. I can see that I wrote on the Assessment lnterview Summary Sheet:
"Feels the partnership between Post Office and subpostmasters benefits both
busrnesses, may be problems if there are conflictissues-" {POL-0029715/2i This
document merely summarizes Mr Abdulla's comments during the interview. I

would not have suggested that Post Office and Mr Abdulla would be working in a
legal partnership as I knew this was not the case. Subpostmasters are agents of
Post Office and not partners.

15. ln paragraph 11, it is alleged that I represented that MrAbdulla needed to provide
personal service. I would not have said this because I knew, and would have
explained to Mr Abdulla, as I did at every interview, that he could employ
assistants and did not even need to be personally present at the branch.

16 ln paragraph '19, it is alleged that Mr Abdulla was not advised to obtain legal
advice. lt is likely that I suggested that Mr Abdulla should take professional
advice if he was unsure about anything, as this was something I would say in
every interview.

17. ln paragraph 30, it is alleged that I encouraged Mr Abdulla to employ the staff of
the outgoing Subpostmaster at the branch. I can see from the documents I have
been shown by Post Office's solicitors that Mr Abdulla employed 5 assistants
whom had previously worked for the outgoing Subpostmaster {POL-0029668} .

Whilst I may have said that under TUPE the assistants may have a right of
employment by him, as a result of the change of ownership, and that this was
something he needed to find out for himself and I would not have encouraged him
as alleged. The choice of assistant was always the decision of the
Subpostmaster subject to vetting checks by Post Office. lt was his choice.

18. ln paragraph 32, it is alleged that Mr Abdulla thought that it was Post Office's
responsibility to train his assistants. I do not know how Mr Abdulla could have
thought this, as I would have explained at his interview that it was his
responsibility to train his assistants. I can also see from my interview notes that

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 Claim Nos: HQ16X01238, HQl7X026S7 and He17X04248

we expressly discussed at interview that he would introdu ce " half an hour training
sessions to support staff increase their knowledge" {pOL-OOZ}TZBIZI .

19. ln paragraph 83, it is alleged that Post office agreed to act as Mr Abdulla's agent.
I certainly would never have agreed to this in an interview. Mr Abdulla was post
Office's agent, not the other way around.

STATEMENT OF TRUTH

this witness statement are true

Signed:

Date: 23 August 2018

AC_1 51481 740