Guidance

GLO Compensation Scheme: guidance and principles

Updated 27 February 2026

Background

Introduction 

The government announced the ex-gratia Group Litigation Order (GLO) Compensation Scheme (the ‘Scheme’) on 22 March 2022. The objective of this Scheme was to ensure postmasters who were part of the GLO and not eligible to seek compensation from the Post Office have access to fair compensation for their Horizon-related losses. The Scheme will be delivered by the Department for Business and Trade (DBT). This document sets out the underlying principles that will govern the assessment of any claims under the Scheme and provides guidance in relation to such claims.

The central goal, and the key overarching principle, of the Scheme is to deliver compensation to eligible postmasters that is full and fair, restoring them to the position they would have been in had it not been for the Horizon-related actions of the Post Office. Decisions will be taken in the light of established legal principles and the findings from the Common Issues Judgment and the Horizon Issues Judgment. The Scheme will take into account all relevant facts and matters presented in the claims to produce a fair result for the postmaster. Claims can be made for Horizon shortfalls and for consequential losses resulting from them (the definitions for which can be seen in the ‘Definitions’ section).

This guidance sets out bandings and ranges for some non-pecuniary losses. These bands and ranges are not limits on what can be claimed under the Scheme. They should instead be used as an indicative guide for you, your lawyers and the independent panel (as defined in the following sections). The Scheme expects there will be some cases where the facts of the case demand awards significantly higher than the upper figure for the top band. Each case will be looked at in the round and decided on its merits, guided by considerations of fairness. If you cannot agree the amount of compensation bilaterally with DBT, it will be decided by the independent panel.

If you are a GLO claimant and are not currently legally represented, you are strongly urged to engage lawyers as soon as possible. Three firms of lawyers – Freeths, Howe & Co and Hudgells Solicitors – have agreed not to make any charges to claimants for work on the Scheme. They will be paid by government at rates agreed with them, which are set out in a tariff of reasonable costs. Other firms can access the same rates. You should not engage any firm which:

• asks you for money now or later
• offers a ‘no-win, no-fee’, conditional fee or litigation funding agreement

Evidence required

Although it is in your interests that your claim is well evidenced and quantified in respect of each head of loss, the Scheme recognises that this may not always be possible given the circumstances and the length of time which has passed, and that there will be an absence of evidence. As such, DBT will take a proportionate and considerate approach to the availability of evidence although there will be some claims in which expert evidence may be required. We have made this clear in the following guidance.

The evidence base for your claim should include the Schedule of Claimant Information (SOCI) submitted for the High Court case. The Scheme accepts that aspects of these statements will need to be updated and expanded upon to reflect subsequent events or newly available information. Other statements and supporting documentation from that case can also form part of your evidence base. 

The Post Office is undertaking a comprehensive programme of disclosure on terms discussed with your legal advisers. Any evidence obtained by the Scheme from the Post Office will be shared with you at the earliest opportunity. 

You should use any remuneration information provided by the Post Office as evidence. If you need additional information relating to your tax records to support your claim, you may also wish to seek evidence from HM Revenue and Customs (HMRC). You can ask your legal adviser to do this on your behalf with your signed consent (a digital signature is acceptable). 

If you feel that you are unable to engage with this process, you can simply submit your documentation from the High Court, including your SOCI, to the Scheme. This may not produce the optimum outcome but will still allow your claim to be considered.

Benefits

The Compensation Recovery Unit (CRU) of the Department for Work and Pensions (DWP) is responsible for recovering social security benefits paid where a compensation payment has subsequently been made. DBT has received an exemption from this process and will therefore not require disclosure from DWP on personal injury benefits which you may have received. However, personal injury claims may still need to be registered with the CRU, a process for which will be agreed with DWP and claimants’ legal representatives.  

You should include any other income support received in your application for loss of earnings calculations. You do not need to seek disclosure from DWP prior to submitting your application. DBT reserves the right to request disclosure following assessment of the claim, should it be proportionate to do so. 

A benefits capital and income disregard applies to:

• Universal Credit
• Pension Credit
• Housing Benefit
• Housing Benefit for pensioners
• Income Support
• income-based Jobseeker’s Allowance
• income-related Employment and Support Allowance

This benefit disregard applies indefinitely to compensation payments made directly to postmasters.

Where a postmaster has died, payments to beneficiaries may or may not receive the benefits disregard depending on their relationship with the deceased and the specific benefits they are claiming. For those receiving Universal Credit, there is no disregard for compensation payments made to an estate and distributed through the estate to beneficiaries. There is guidance available for decision makers on the benefits disregards. If postmasters are concerned that they have not had the disregard applied accurately, then they can apply to DWP for a mandatory reconsideration which will initiate a review.

Definitions

‘Consequential loss’ means financial or non-financial loss that is not a shortfall loss, but which flows from and was caused by the Horizon shortfall, for example loss of earnings or damage to reputation. 

‘Horizon shortfall’ means a shortfall in stock or cash at a postmaster’s branch compared with the amount of stock or cash indicated on Horizon for that branch, where the shortfall may have been caused by:

• previous versions of Horizon (sometimes referred to as Legacy Horizon, Horizon Online or HNG-X)
• a breach of duty related to such a shortfall by the Post Office (including duties identified in the findings of the Common Issues and Horizon Issues Judgments)

‘Shortfall loss’ means the amount of a Horizon shortfall that the postmaster has paid or is regarded by the Post Office as still owing.

Claim eligibility

In order to be eligible for the GLO Scheme, you must meet the criteria set out in the next 2 paragraphs. 

You must have been a claimant in the action Alan Bates and Others v Post Office Ltd pursued under a Group Litigation Order in 2016 and a party to the Settlement Agreement dated 10 December 2019 with Post Office Limited (‘the 2019 Settlement’). 

Your application and time with the Post Office must not involve or relate to any criminal convictions that relied on evidence from Horizon. Claims from convicted postmasters will be processed by the Post Office or DBT once the conviction has been overturned. If you were prosecuted but not convicted, or you received a caution, you are eligible for the Scheme. Convicted postmasters whose convictions were not dependent on Horizon may be accepted on the Scheme on a case-by-case basis.  

You can apply on behalf of a deceased GLO postmaster or a GLO postmaster who is suffering from capacity issues. If you are making an application on behalf of another person, you must identify your legal authority to act on their behalf. For example:

• executor
• personal representative
• attorney
• deputy of the person on whose behalf you are making the application

You should provide proof of this legal relationship. 

If you were a shareholder or a director of a company or a partner in a partnership which ceased to exist and which was a party to the GLO, you are able to make a claim as the linked individual. If appropriate, an offer of an ex-gratia payment will be made to you and any other shareholders and directors of the company or partners of the partnership, which may have a legitimate interest in that payment. It is your responsibility to seek an agreement with them as to who will be the recipient of the payment and how it should be split between yourselves. If the company or a partnership has ceased to exist, it will not be necessary to restore it except in a limited number of circumstances, for example, when the company is set up as a community interest company.

About the process

Parties involved

An independent advisory board has been established to advise ministers on how best to manage delivery of the Scheme. It will not have any role in individual cases. It will monitor the overall progress of the Scheme, ensuring that the process is working well and identifying any blockages. Its membership comprises:  

• Professor Christopher Hodges, an academic expert in the field of Alternative Dispute Resolution
• Lord Arbuthnot and Lord Beamish, 2 Parliamentarians recognised for their past involvement in pursuing the resolution of the Horizon scandal
• Professor Richard Moorhead, an academic expert in the field of legal ethics

It will be supported by a DBT secretariat and officials.

DBT has appointed:

• Addleshaw Goddard as external legal advisers to advise DBT on individual cases
• Dentons as Alternative Dispute Resolution experts who will be independent claims facilitators supporting the progress of claims and will provide arrangements for making relevant papers transparent to all parties

Dentons has procured: 

• an independent panel comprising legal, accounting, medical and retail experts, depending on the details of the claim (the ‘independent panel’)
• a ‘Reviewer’ – Sir Ross Cranston, a former High Court judge, who will undertake exceptional review of cases
• independent case management – Sir Ross Cranston will provide recommendations and guidance on complex claims to expedite resolution

Registration in Scheme

On 10 February 2023, DBT opened registration for the Scheme. Your legal advisers are invited to fill out the GLO Compensation Scheme: DBT Registration Form. They should return the completed form to glocompensation@businessandtrade.gov.uk as soon as possible.

You should only fill in your registration form if you choose to represent yourself.

Submission of a claim

You or your chosen legal adviser should present all losses in your claim in the application form. You or your legal adviser should also submit all relevant information and evidence to the Scheme. This can be at the same time as submitting your application form or following a request from the Scheme setting out in detail the evidence required for each head of loss. 

The claim should explain in as much detail as possible:

• the particular losses being claimed
• the specific amount of loss being claimed
• how this loss was caused by a Horizon shortfall
• the steps the postmaster took to attempt to reduce this loss and the impact these steps had

Your lawyer will be granted access to the Dentons Direct platform to upload claims. They will also be able to check progress on a user-by-user basis. You will be granted access if you choose not to be legally represented.

If you are legally unrepresented and do not have access to the internet, you can send your application form by post to: 

Horizon GLO Compensation Scheme 
C/O Dentons UK and Middle East LLP 
1 Fleet Place 
London EC4M 7WS 

If you send your application via courier, the following address should be used: 

Horizon GLO Compensation Scheme 
C/O Dentons UK and Middle East LLP 
1 Fleet Place 
London EC4M 7RA 

Include reference ’DSB/RZF/TS/079928.00001’ in all submissions sent by post or courier. 

On submission of a claim, that claim will enter the claims facilitation process conducted by Dentons and a named claims facilitator will be appointed to the case.

Assessment of claim

Consequential loss claims will be assessed against the established legal principles set out in the ‘Established legal principles’ section, in addition to considering what is fair in all the circumstances.

Claims will be considered by DBT, with advice from Addleshaw Goddard, leading to an initial offer. In the event of further progress with the claim as described below, they will reconsider this offer.

If DBT considers that information may be available to you which would help the assessment of your claim for consequential loss, DBT will ensure that your adviser is contacted and request that this information be provided within 28 days.

If DBT is not prepared to accept elements of losses claimed, it will explain why and ask you or your legal adviser for further information. If, following such investigation, DBT does not accept those losses as claimed then it will make an offer (or nil offer) with an explanation for the offer.

Addleshaw Goddard will communicate the DBT offer to you and your legal adviser. This communication will explain the approach adopted when calculating the offer and its justification by reference to the evidence provided in the claim form and the Scheme principles. It will set out the reasons for any divergence from the amount claimed.

Reaching agreement with DBT

Once you have received an offer in respect of a claim, unless you have accepted that offer, the claim will enter the first facilitation period, during which Dentons’ aim will be to promote common understanding and agreement between the parties. As a first step they will invite your legal adviser and DBT to a discussion. They may follow up on this by adopting any of the following approaches:

• requesting further information from your legal adviser
• recommending that expert evidence is sought
• encouraging you and/or DBT to revise your positions
• referring the case to a senior lawyer at Dentons (the ’Senior Dentons Lawyer’) for consideration as to next steps

The claims facilitators will monitor progress in the light of the steps taken. 

The claims facilitators will update the approach described previously as the evidence or the parties’ positions change. Updates will be made available to you and your legal adviser, and it will be open to the parties to comment on them. If parties are not responding within standard timescales (which the claims facilitators will confirm to the parties in writing) the claims facilitators will chase them up. The status of the claim will be updated on the Dentons Direct platform by the claims facilitation team as matters progress. When a status is changed, a notification will be automatically sent from Dentons to you and DBT. 

In adopting any of these approaches the claims facilitators will have regard to proportionality, including the likely costs (including costs to both parties and their own expenditure). Rather than adopt any approach which would involve costs that would exceed the difference between the parties, they should encourage the parties to reconcile their differences. Only if a case is likely to set a precedent for others should this criterion be relaxed.

If the Dentons Senior Lawyer judges that it would assist the parties’ progress towards agreement, they can decide to put a case to the independent panel for a first assessment, based on Dentons’ summary of the case. The Dentons Senior Lawyer will have discretion as to whether a case should be referred to the independent panel. The Dentons Senior Lawyer is unlikely to refer a case to the independent panel in the following circumstances: 

• if there is not a substantial difference between the last offers exchanged by the parties
• further evidence is required
• there is no issue on which it would be helpful to obtain the views of the independent panel

You have the right, subject to the previous paragraph, to have your case considered by the independent panel should compensation not be agreed through this process.  

The independent panel will apply its independent judgement to individual cases, guided by considerations of fairness and using the principles and guidance developed by DBT. It will make an assessment of the issues raised, which may recommend a specific award or request further evidence or analysis.   

If the panel considers that an eligible claim requires further evidence to allow the panel to recommend an outcome, the panel can recommend further evidence is sought in the circumstances described in the following 3 paragraphs (as applicable). Any funding for additional evidence will be considered in accordance with the agreed Tariff of reasonable legal costs. The panel should only request further evidence in exceptional circumstances. Exceptional circumstances include where such evidence is deemed critical to the panel’s ability to recommend an outcome.  

If, in the exceptional circumstance, upon receipt of instructions in relation to an eligible claim, any panel member considers that they are unable to form a view on a head of loss that they have the expertise for without further evidence, the panel member should notify the Dentons Panel and Reviewer Liaison allocated to the claim (the ’P&R Liaison’) as soon as possible. The P&R Liaison will then communicate this to the other panel members allocated to the claim in order to determine whether there are any other heads of loss which any other panel member considers they are unable to form a view on without further evidence and whether the panel can form a view on any heads of loss of the particular claim.

If, in the further exceptional circumstance, it becomes apparent that the panel are unable to form a view on the entirety of the eligible claim without further evidence, the P&R Liaison will write to the panel members constituted for that claim and will seek agreement on the adjournment of the first panel meeting pending receipt of further evidence. If agreement is not reached on the adjournment prior to the first panel meeting, this should be discussed by the panel as the first agenda item during the first panel meeting and if required, a vote should take place on the adjournment of the meeting. Each panel member shall have one vote and the first panel meeting will be adjourned if at least 2 panel members vote to adjourn the panel meeting. If the first panel meeting is adjourned, the claims facilitator will inform the parties and will request that you provide this further evidence by a specified date. The first panel meeting will be adjourned until you have provided the evidence sought or the deadline to provide this information has passed.

If the panel requires further evidence in relation to discrete heads of loss but the panel has sufficient information to form an initial view regarding the other heads of loss, the panel should provide its initial view on the heads of loss it is able to provide a view on and may choose to provide no view in relation to the heads of loss it requires further information in respect of. The claims facilitator will then seek this further evidence from you when providing a summary of the panel’s initial view.  

The claims facilitators will commission the provision of any evidence or analysis requested by the independent panel. This will be in addition to any expert evidence commissioned by you or your legal adviser. They will then continue to promote agreement between the parties.

The independent panel’s initial, non-binding, assessment – including its reasoning – will be recorded in writing and made available to you and your legal adviser.

Best offer per head of loss principle

DBT will honour the best offer per head of loss you receive on the Scheme. This means for each head of loss assessed by Panel, if any assessment is lower than the value of the offer you previously received from DBT for that head of loss, you can revert back to the higher offer.

In limited circumstances, DBT may use an informal process to seek clarification from the panel before making its offer after the Panel’s assessment. This will only happen where DBT believes an assessment has been made for payments it does not have authority to fund. For example:

• where DBT believes there has been a calculation error
• where an award has been made which constitutes double recovery or a claim that falls outside the scope of the Scheme

Facilitation period

DBT will issue an offer in accordance with the panel’s assessment. If the parties do not reach agreement within 4 weeks following receipt of the offer, the case will be referred to the independent panel for a final assessment. This will again be based on Dentons’ summary of the claim and offers, taking account of the parties’ views of the issues. 

If, following the expiry of the 4 week facilitation period after the first independent panel stage, the parties require further time to reach agreement, the parties may agree to extend this facilitation period in order to attempt to reach agreement before the case is referred to the second independent panel stage. Should the parties agree to extend the facilitation period, they should inform the claims facilitator assigned to that claim of this agreement.  

The independent panel’s final assessment will take into account any new evidence provided and will include a specific binding assessment, together with a written explanation of their reasoning. It will be sent to you and your legal adviser as well as to DBT and Addleshaw Goddard.

As in the ‘Best offer per head of loss principle’ section, the best offer principle and clarification process will similarly apply after the Panel’s final assessment.

Review process

You can make an application to the Reviewer for exceptional review if:

• you believe there has been a manifest error, procedural irregularity or substantive error of principle in the independent panel’s final assessment of the claim
• if the panel’s final assessment is substantially inconsistent with the Guidance and Principles (the ‘Review Criteria’)

DBT will have the same right to seek exceptional review of a case. This power would allow DBT to challenge the independent panel’s final assessment if it believed that the independent panel had departed from the established framework for assessing claims which is intended to achieve consistency and fairness when making offers to postmasters.

An independent panel final assessment is ‘substantially inconsistent with the guidance and principles’ if it is obvious or easily demonstrable that in making its final assessment, the independent panel has failed to apply or has misinterpreted the Guidance and Principles in a manner which has had a material effect on the independent panel’s final assessment. For the avoidance of doubt, an independent panel final assessment will be ‘substantially inconsistent with the Guidance and Principles’ where it has failed to deliver full and fair compensation. In determining whether the independent panel’s final assessment has delivered full and fair compensation, the Reviewer will consider whether the compensation awarded by the independent panel in its final assessment puts the postmaster in the position that they would have been in but for the Horizon-related actions of the Post Office.

A ‘manifest error’ is an error that is obvious or easily demonstrable without extensive investigation and which has a material effect on the independent panel’s final assessment. This includes:

• a decision that went beyond the scope of what the independent panel was permitted to assess
• a decision so obviously irrational that no person, acting reasonably, could have made it
• an error on the part of the independent panel in taking account of clearly irrelevant matters or failing to consider clearly relevant matters
• an error in the mathematical calculation of the compensation sum awarded by the independent panel in its final assessment (but not the assumptions on which that calculation was based provided that such assumptions are not factually incorrect or irrelevant)

A ‘procedural irregularity’ is an irregularity in the procedure or decision-making process that the independent panel has adopted while making its final assessment, which made a material difference to that assessment. Circumstances where a procedural irregularity might arise include where the independent panel has not correctly followed the Panel terms of reference or where the independent panel has not properly observed the principles of natural justice in the decision-making process. For the avoidance of doubt, a failure to comply with the timeframes set out in the panel terms of reference is unlikely to amount to a procedural irregularity.

A ‘substantive error of principle’ would arise where the independent panel’s final assessment involved the application of a principle identified in the Guidance and Principles which is:

• obviously inconsistent with generally accepted legal principles (either existing at the time the Guidance and Principles were finalised or after that date)
• where the principles used to assess a case were clearly inappropriate to its circumstances

Any such application must be made within 15 working days of the communication of the independent panel’s final assessment. Any case submitted for the review should be made using the form ‘Template Review Application’ provided by the Dentons claims facilitator and should:

• identify the part of the independent panel’s final assessment that you are seeking a review in respect of
• identify the Review Criteria (set out in the ‘Best offer per head of loss principle’ section) under which the review application is being made
• set out what the independent panel’s final assessment should have concluded, including as to the sum it should have awarded, in the absence of the applicable Review Criteria
• provide reasons for this view (the ’Review Application’)

Upon receipt of a Review Application, the Dentons Senior Lawyer will provide their view to the Reviewer as to whether there is a prima facie case that it meets the Review Criteria. The Reviewer will decide whether such a case exists and will communicate his decision to the P&R Liaison within 10 working days of receipt of the Dentons Senior Lawyer’s view. If the Reviewer concludes that a prima facie case does not exist, the claims facilitator will notify you and DBT accordingly and the independent panel’s final assessment will stand.

If the Reviewer concludes that a prima facie case exists, the claims facilitator will notify you and DBT accordingly and will invite you and DBT to prepare written submissions. The Review Application will be referred to the Reviewer for consideration. The Reviewer will consider the Review Application alongside any comments on it which they may invite from the independent panel and the parties’ written submissions. He may uphold the independent panel’s final assessment or, in the event of finding that the Review Criteria apply, make a revised award of compensation. The Reviewer’s decision will be sent to you and your legal adviser and to DBT and Addleshaw Goddard, together with a written explanation. The Reviewer should provide his decision within 2 weeks of receiving the instruction letter. The Reviewer’s finding will be the final stage to reach agreement between you and DBT on your claim. Following this, DBT will issue an offer based on the Reviewer’s decision. No further offers or changes will be considered after this stage.

Acceptance of all or part of offer

If you propose to accept all or part of an offer and you are not legally represented, it will be referred for independent legal review by the independent panel before it is accepted.

The independent panel’s remit in such cases is to ensure that the offer which you propose to accept is reasonable and the independent panel shall not undertake a full assessment of the claim.

DBT will issue an offer letter and pay you any elements which are agreed or determined by the independent panel or the Reviewer once:

• the parties have agreed in writing on an amount of compensation for some or all heads of claim
• the independent panel has issued a final assessment and it has not been referred for exceptional review within 15 working days
• or the Reviewer has issued a decision

Claim outcome

The Scheme will present the claim outcome to you in a clear, succinct manner, setting out information sufficient to allow you to understand the basis for the conclusion reached by the Scheme in respect of each type of loss. Copies of the key supporting documentation relied upon will be available to you.

Transparency of progress of the Scheme

Information about the progress of the Scheme will be published each month on the GOV.UK website. It will include statistics about the claims submitted, offers made and acceptances, as well as the total amounts paid.

Dentons will convene regular meetings involving your legal adviser and, separately, DBT to identify and resolve any common issues relating to the process.

Key principles of the Scheme

Fairness

The central goal of the Scheme is to deliver compensation to eligible postmasters that is full and fair, restoring postmasters back into the position they would have been in had it not been for the Horizon-related actions of the Post Office.

Burden of proof

The Scheme will decide on the balance of probabilities whether:

• the loss was incurred
• the cause of the loss was due to a Horizon shortfall

Balance of probabilities means a greater than 50% likelihood.

It is therefore important that you provide as much relevant evidence as possible to support your claim. If you are unable to provide supporting evidence, your claim will still be considered and could be accepted if the Scheme considers it to be fair in the circumstances.

Claims which are supported by evidence are more likely to be successful. Guidance on how best to evidence any potential claims for consequential loss follows.

Greater weight will be attached to:

• contemporaneous evidence (documents created at or near the time of the loss)
• factual evidence that is undisputed or verifiable

A shortfall will be presumed to have been a Horizon shortfall where:

• there is evidence that the shortfall in question existed and was paid
• there is no evidence that the shortfall was caused by something other than a potential issue with Horizon

Taxation

Government has enacted secondary legislation, the legal effect of which is that no Income Tax, Capital Gains Tax, National Insurance contributions or Value Added Tax (VAT) will be payable at law by any party in respect of any payment (or any part of a payment). Legislation was also enacted from 9 October 2023 to relieve payments from Inheritance Tax.

Your claimed losses should be quantified net. This means after the deduction of the tax which would have been due at the time. This is to put you back into the same after-tax position you would have been in had there been no breach. If you are unable to work out the net calculation in your application form, you should state that your claim has been made gross of tax and DBT will make the relevant after-tax deductions.

If you would like a tax expert to help you with the calculations, the Scheme will cover the reasonable legal cost of up to £1,000. This request should be facilitated through your legal adviser.

Interest applied to claims will not be subject to any tax deductions.

HMRC will not collect any Income Tax, Capital Gains Tax, National Insurance contributions, Inheritance Tax or VAT which may have been due in respect of any payment (or any part of a payment).

Established legal principles

In considering a claim for any consequential loss, the Scheme will apply the findings in the Commons Issues Judgment and the Horizon Issues Judgment. In making an assessment on whether any consequential loss claimed is on the balance of probabilities, attributable to a Horizon shortfall, the Scheme will consider causation and remoteness.

Causation

The Horizon shortfall must have caused the consequential loss. This means that consequential loss would not have happened but for the Horizon shortfall. If you would have found yourself in the same position in any event, irrespective of the Horizon shortfall, the Scheme will not be able to conclude that the Horizon shortfall caused the consequential losses you may have suffered.

Remoteness

The consequential loss must not be too remote. This means that the consequential loss must have been reasonably foreseeable at the time of the Horizon shortfall.

Mitigation 

The Scheme will consider the extent to which you did or could have reasonably mitigated the consequential loss.

Quantum

The object of the assessment will be, so far as the award of a sum of money can do so, to put you into the position that you would have been in but for the Horizon shortfall.

Double recovery

You cannot recover the same loss twice. The Scheme will assess if any losses overlap with others. Account will also be taken of any payments received in the Initial Complaint Review and Mediation Scheme, under the 2019 Settlement (after the deduction of legal and funder costs), or under the Scheme (for example, interim payments).

The previous information is intended as a guide only. It is not an exhaustive list of the legal principles that may be applicable to any particular claim for consequential loss. The application of the principles will be fact-specific and will depend on your circumstances.

Limitation

Many eligible claims will relate to shortfall losses and consequential losses suffered a significant number of years ago. To draw a line under the issues caused by previous versions of Horizon and treat postmasters who have been affected fairly, the Scheme will not apply the laws of limitation or time bar in its assessment of the shortfall losses or consequential losses.

Interest

Compound interest will be applied in relation to shortfall claims at a standard rate of 3.45%, consistent with the approach taken on the Horizon Shortfall Scheme. You do not need to calculate the interest in your application form. DBT will apply interest to every offer made.

For Horizon shortfalls, interest will be applied from the date of payment, where you or the Post Office records are able to identify a single repayment date.

Where Horizon shortfalls have been repaid over time, interest will run from the mid-point of repayment.

Compound interest will be applied in respect of most consequential losses. There may be certain cases where the facts of the case mean that it is not appropriate for compound interest to be applied. For the following heads of loss, it is less likely that you will have been denied the use of money. Therefore, for the following heads of loss, it is less likely that compound interest would be recoverable:

• reduction in capital value
• stigma or damage to reputation
• malicious prosecution (civil and criminal)
• harassment

For suspension pay awards, interest will generally apply from the mid-point of suspension.

For loss of earnings awards following termination or resignation, interest will generally apply as follows:

• for amounts offered in respect of the contractual notice period, interest is to be calculated from the midpoint of the notice period
• where the Scheme offers a Notional Compensation Amount (outlined in ’loss of earnings’ section) interest will ordinarily run from the date when the contractual notice period expired or would have expired

For other heads of loss, interest will generally run from the date when the relevant loss was incurred, or your cause of action occurred (if a particular date can be identified). If no particular date can be identified, a suitable date will be used based on the information which is available.

What you can claim

Consequential loss

There is no exhaustive list of the types of loss that you can claim as consequential losses (assuming they meet the applicable legal tests and noting that additional losses claimed must be clearly linked back to a Horizon shortfall). Certain examples are detailed in the following paragraphs along with examples of the types of evidence that you should provide to support your claims for consequential loss.

All losses should be quantified net of the tax which would have been payable at the time as outlined in ’Loss of earnings’ section.

Loss of earnings

This may relate to loss of earnings during a period when you were suspended or where your contract with the Post Office was wrongfully terminated or you were forced to resign because of a Horizon shortfall. 

This will require evidence that you were suspended, were forced to resign or had your contract terminated without sufficient notice because of a Horizon shortfall. The Scheme will ask the Post Office to take reasonable steps to identify any relevant information from its own records, but you should provide any documentation which you hold evidencing your suspension, forced resignation or termination related losses, for example:

• suspension letter
• reinstatement letter
• termination letter
• forced resignation related correspondence
• remuneration information for the period of suspension and the period before or after the suspension
• contemporaneous correspondence between you and the Post Office
• an explanation or other evidence as to why your contract was wrongfully terminated or you were forced to resign and that otherwise you would have continued as a postmaster
• in respect of termination, an explanation as to why the notice given to you by the Post Office was insufficient
• your average monthly expenses in running the Post Office branch for the period before the suspension, termination or forced resignation
• if you subsequently obtained employment or earned an income following your suspension or termination or forced resignation, confirmation of the dates and details of the income earned
• if you subsequently received employment benefits following your suspension or termination or forced resignation, confirmation of the dates and details of payments received

You and your legal adviser should demonstrate what you consider most likely to have happened to your earnings but for the alleged wrongful termination by the Post Office of your contract or your forced resignation. 

Cases will be considered on a case-by-case basis, taking into account the extent of evidence presented by you and having regard to what would have happened to your earnings if the Post Office had exercised any right to terminate the contract lawfully at the earliest possible opportunity in a manner which would be least burdensome to it (the ‘minimum performance rule’). 

That will involve consideration of the amount that would have been paid to you had you left under the Network Transformation Programme and received a ’Leaver’s Payment’. In the context of Network Transformation Programme, this payment was the equivalent to 26 months’ Post Office remuneration plus the Post Office remuneration that would have been received in the minimum notice period for the contract (typically 3 or 6 months depending on a contract.) 

In the context of the Scheme, the calculation will not be applied mechanically. It is neither a cap nor a minimum. In the interest of fairness and consistency, DBT may make offers that are higher or lower than the 26 months’ Post Office remuneration should the facts of your case warrant a variation. For example, a lower offer might be appropriate if you had only been in post a short amount of time or were close to retiring. Offers may also depend on your personal circumstances following the contract termination or forced resignation – for example, if you sought and found alternative employment. 

For complex calculations you may require assistance of a forensic accountant. This should be facilitated through your legal adviser, and requests for expert evidence should be submitted to DBT in accordance with the published tariff of reasonable legal costs.

Loss of profits

This may relate to loss of profits from the Post Office branch or any retail shop which you owned which was associated with the Post Office branch.

This will require evidence to show how the profits of the business were impacted by the Horizon shortfall. You should provide all documentation you hold demonstrating the profits made by the business prior to and following the Horizon shortfall, taking into account the cost of any additional measures that had to be put in place because of the Horizon shortfall, for example:

• bank statements
• accounts
• tax returns
• cash flows (historical and forecast)
• business plans (historical and forecast)
• management information (historical and forecast)
• relevant correspondence

You should provide a calculation showing how the amount being claimed has been quantified. You should demonstrate and evidence how long you would have continued to operate the business profitably had your contract been lawfully terminated by the Post Office giving appropriate notice. Where you are unable to show that you could have operated the business profitably beyond expiry of the appropriate notice period, damages will usually be confined to the loss of profits suffered during the relevant notice period.

Inflation will be applied to loss of retail profits using the consumer price index (CPI).

Loss of property or other assets

If, as the result of a Horizon shortfall, you were forced to dispose of an asset (for example a property) at an undervalue or the asset would have been retained and would have a higher value at a later date, a claim for consequential loss may be available.

In order for such a claim to be successful, you will need to provide evidence that the Horizon shortfall (as opposed to other factors) led to the disposal, as well as evidence of the value of the loss suffered as a result, for example:

• an explanation as to why the asset was sold
• relevant correspondence and documents relating to the purchase and sale of the asset
• evidence of the value of the asset (historic and current)
• any relevant accounting documentation

Provide a calculation showing how the amount being claimed has been quantified.

For property valuations, the Nationwide House Price Index can be used for simple valuations to estimate the current value of a property and HM Land Registry can be used for historical sales prices and ownership details, where available.

Similar valuations may be available online for other assets, either historical or by way of current comparator sale prices.

Appropriate adjustments should be made for inflation.

For complex valuations you may require expert property valuation. This should be facilitated through your legal adviser, and requests for expert evidence should be submitted to DBT in accordance with the published tariff on reasonable legal costs.

Loss of opportunity or loss of chance

You may be able to claim a consequential loss for the loss of an opportunity to pursue a course of action that, but for the Horizon shortfall, could have resulted in financial gain. For example, expanding the business or making other investments.

Following Sir Gary Hickinbottom’s report on loss of opportunity, loss of opportunity will be assessed in a 2-step process:

1. DBT will assess the percentage probability that there was a chance or opportunity that you would have exploited but for POL’s misconduct and that you suffered financial loss as a result.
2. DBT will then assess the percentage probability of you profitably exploiting that chance or opportunity.

At step 1, DBT will not require you to prove on the balance of probabilities (meaning a greater than 50% chance) that you would have pursued a chance or opportunity but for the POL’s misconduct and suffered a financial loss as a result. 

Instead, your claim will be assessed by the percentage probability of you pursuing that chance or opportunity. For example:

• a claim assessed at a percentage probability of 10% or less at this stage will be considered speculative and will not result in an award
• a claimed assessed at a percentage probability between 10% and 50% will be assessed and discounted in accordance with that percentage probability
• a claim assessed at a percentage probability of over 50% meets the legal threshold for causation (the balance of probabilities) and is assessed at 100%

At step 2, DBT will ascertain quantum in accordance with the percentage probability of profitably exploiting the relevant chance or opportunity.

The following example is provided to illustrate the steps outlined previously. It is illustrative only.

Scenario

The claim may be that you were intending to open up a sandwich shop business alongside the Post Office. You didn’t because of POL’s conduct, and you have suffered a financial loss as a result. The claim may be that if you had pursued this sandwich shop, you would have generated £10,000 in profit. This claim would be assessed in a number of ways, depending on the level of evidence and the percentage probability at each step.

Assessment 1

If it is found you had a 25% chance of opening the sandwich shop but for POL’s misconduct (step 1), and the shop had 100% chance of generating £10,000 if opened (step 2), you may be awarded £2,500. This applies a 25% discount at step 1 and no discount at step 2.

Assessment 2

If it is found you had a 25% chance of opening the sandwich shop but for POL’s misconduct (step 1), and the shop had a 50% chance of generating £10,000 if opened (step 2), you may be awarded £1,125. This applies a 25% discount at step 1 and a further 50% discount at step 2.

Assessment 3

If it is found you had a 70% chance of opening the sandwich shop but for POL’s misconduct (step 1), and the shop had 100% chance of generating £10,000 if opened (step 2), you may be awarded £10,000. This applies no discount at either stage, to reflect the fact that a claim assessed at a percentage probability of over 50% meets the legal threshold for causation and is assessed at 100%.

Assessment 4

If it is found you had a 70% chance of opening the sandwich shop but for POL’s misconduct (step 1), and the shop had a 50% chance of generating £10,000 if opened (step 2), you may be awarded £5,000. This applies no discount at step 1 and a 50% discount at step 2.

You should provide as much evidence as possible, including your own (or third party) statement. Your evidence should demonstrate a specific opportunity or course of action that you were aware of at the time and had intended to pursue but were prevented from doing so due to the Horizon shortfall. This might include evidence demonstrating:

• the existence of the opportunity
• your knowledge of the opportunity and any plans you had made to exploit the opportunity prior to the Post Office’s conduct
• how you would have exploited and carried out the opportunity and obtained a profit from it
• your financial ability to exploit the opportunity
• your knowledge, skills and experience that would have assisted you in exploiting the opportunity and obtaining a profit from it
• your drive, ambition and resourcefulness which would have assisted you in exploiting the opportunity and obtaining a profit from it
• profits which would have been made from the exploitation of the opportunity – this may require expert evidence
• the time over which the exploitation of the opportunity would have been profitable
• the risks to the profitability ceasing or being reduced early and whether the income would have been replaced, for example by a new venture

What evidence is required will depend on the nature of the specific opportunity said to have been lost, and may include: 

• evidence that you were actively considering the investment opportunity and that it was likely to be pursued (for example, correspondence with banks concerning financial arrangements)
• evidence demonstrating that your inability to invest or pursue the opportunity was caused by the Horizon shortfall (rather than by other intervening events or the fact that you would not have had the funds to avail yourself of the opportunity)
• evidence of what your financial position would have been but for the Horizon shortfall
• expected costs and timeframe for investment or opportunity
• evidence of progress (if any) on the investment or opportunity

As outlined previously, DBT will assess the percentage probability of both the chance or opportunity being pursued but for POL’s misconduct and resulting in financial loss (step 1) and that chance or opportunity being profitably exploited by reference to the evidence you are able to provide (step 2).

It is in your interests to provide as much information as possible. However, we recognise that there will be challenges and therefore our assessment will take into account that evidence may be limited due to: 

• the passage of time since Horizon shortfalls
• the fact that evidence may be unavailable due to the actions of the Post Office, for example exclusion from the Post Office premises
• the fact that evidence availability may be compounded by an unstable life, for example due to loss of stable home
• the fact that difficulties in recollection may be compounded by psychological effects of the Post Office’s wrongdoing

The calculation of the award will also take into account general life events which may impact the profitability of the opportunity so will be dependent on the specific circumstances of the individual case.

Penalties or increased costs of financing

Penalties or increased costs of financing, as a result of the Horizon shortfall, may be recoverable (for example additional interest or loan arrangement fees). You should explain how the Horizon shortfall led to the increased costs and provide any evidence you have to support the level of costs incurred. 

This will require evidence of the purpose of the financing and what your financial position would have been but for the Horizon shortfall. If you claim that the finance was taken out at less advantageous rates than it would otherwise have been as a result of the Horizon shortfall you should provide any supporting evidence of when the finance was taken out and that you had been turned down for other products at more favourable rates.

You should provide a calculation showing how the amount being claimed has been quantified.

Bankruptcy or insolvency

Losses suffered if you underwent bankruptcy or insolvency proceedings as a result of a Horizon shortfall may be claimed as a consequential loss.

For such a claim to be successful you will have to provide evidence that you were bankrupted or declared insolvent (as appropriate), the value of the loss claimed and that the bankruptcy or insolvency was due to the Horizon shortfall (rather than other intervening events, general financial hardship or other factors).

The types of documents that you should provide with your claim if possible include the following:

• copy of bankruptcy order or Individual Voluntary Arrangement (IVA) documentation
• copy of notice of bankruptcy in appropriate newspaper
• financial or accounting evidence to demonstrate that the Horizon shortfall was the reason for the bankruptcy or insolvency
• details of all creditors at the time of bankruptcy or insolvency
• if the bankruptcy or insolvency process has concluded, details of payments made to creditors

Evidence to demonstrate that the Horizon shortfall was the reason for the bankruptcy or insolvency can include:

• bank statements
• accounts
• cash flows (historical and forecast)
• business plans (historical and forecast)
• management information (historical and forecast) 

If you were made bankrupt as a result of the Horizon shortfall, you may be able to claim for: 

• diminution in value to your estate or assets because of the bankruptcy
• other consequential pecuniary loss – for example, if you suffered a financial loss as a result of harm to your credit and reputation by reason of bankruptcy
• general damages (anticipated to be in the range of £20,000 to £60,000)
• the expenses of the bankruptcy (including annulment costs already incurred)
• the statutory interest payable to your creditors

Where the Post Office was the original petitioning creditor in your bankruptcy, aggravated damages may also be claimed. These are anticipated to be in the range of £10,000 to £25,000. 

These ranges are not limits for what can be claimed under the Scheme, but can be used as an indicative guide to help you and your lawyer formulate your claim. Each case will be decided on its merits. 

You should provide a calculation showing how the amount being claimed has been quantified.  

If you would like to seek an annulment, the Scheme will cover the reasonable legal fees associated with you doing so, for example court fees. This request should be facilitated by your legal adviser. You can provide an estimate of the costs in your application form, or if after the submission of your application form, by emailing glocompensation@businessandtrade.gov.uk.

Legal and professional fees

Fees incurred in relation to dealing with a Horizon shortfall at the time may be recoverable. For example, the cost of defending legal proceedings or professional advice about restructuring the postmaster’s business.

This is separate to any legal and professional fees you have incurred in bringing an application to the Scheme.

In order to claim these fees, you should explain and where possible provide evidence of the following:

• why and when the professional was engaged (noting that you should avoid providing any legal advice you have received unless you confirm you are happy to waive privilege over that legal advice)
• details of the engagement (including whether the engagement was by you or a third party)
• the professional’s fees being incurred and paid by you, for example an invoice or receipt

You should provide a calculation showing how the amount being claimed has been quantified.

Stigma or reputation damage

Where you have incurred a financial loss as a result of damage to your reputation as a result of a Horizon shortfall, you may be able to claim consequential loss.

You should explain:

• what action taken by the Post Office, in light of the Horizon shortfall, damaged your reputation
• how those matters became known to others
• why the damage to your reputation caused financial loss

The types of financial loss caused by damage to reputation could include:

• evidence that prospective employers would not hire you as a result of the Horizon shortfall
• evidence that customers stopped supporting your business as a result of the Horizon shortfall

If you claim that your business suffered a downturn in revenue as a result of the damage to your reputation, you should try to provide copies of business accounts before and after the Horizon shortfall became known to others in the community.

You may also claim for the non-financial loss you have suffered as a result of damage to your reputation. Offers for non-financial losses for stigma or damage to reputation will generally be within the range of £1,000 to £10,000. Any offers will be determined according to the relevant facts on a case-by-case basis. The Scheme will look to assess offers by reference to the set of bands.

Band	Impact	Range	Description
Band 1	Moderate impact or loss	£1,000 to £2,500	Distress and humiliation or damage to your self-esteem and confidence caused by general loss of reputation in a wider or local community.
Band 2	Serious impact or loss	£2,501 to £7,500	Distress caused by loss of reputation in a local community, which may include being subject of gossip or rumours and situations where direct comments were made to you or your family (short of verbal abuse).
Band 3	Severe impact or loss	£7,501 to £10,000	Distress caused by significant loss of reputation in a local community, which may include adverse media reports, loss of community positions (for example, Councillor, local charity or sports club leader), being subject of verbal abuse (or verbal abuse directed at family members), feeling of being forced to move out of a local area and being subject of gossip which took years to be forgotten, being unable to explain the position to the community as a result of the Post Office’s reliance on confidentiality duties.
Band 4	Very severe impact or loss	more than £10,000	Exceptionally distressing circumstances – for instance covering an exceptionally prolonged period or an exceptional range of causes.

These bands are not limits for what can be claimed under the Scheme but can be used as an indicative guide to help you and your lawyer formulate your claim. Each case will be decided on its merits in the round, guided by considerations of fairness. The Scheme expects there will be some cases where the facts of the case demand awards significantly higher than the upper figure for the top band.

You should provide a calculation showing how the amount being claimed has been quantified.

Personal injury

You may be able to claim consequential losses for personal injury suffered as a result of a Horizon shortfall. Personal injury can include physical injuries as well as psychiatric harm.

This will require evidence that the personal injury was caused by the Horizon shortfall. You should provide the following information when making a claim for personal injury/harassment:

• a detailed description of your injury including, the symptoms you have experienced, medical treatment you have received, any expenses or financial losses you have suffered and the effect of your injury
• a letter from your GP (or from another medical professional who has treated you) setting out details of matters including the nature and potential causes of the injury
• medical notes and records including copies of the notes and records kept by your GP, any other medical professional who has treated you and any hospital to which you have been admitted
• other relevant information, for example where you are seeking to recover for financial losses (for example, medical expenses or loss of earnings) you should include documents in support of those claims

If you provide medical notes and records, you should only provide records that are relevant to the injury for which you are bringing a claim.

Amounts will be awarded in line with the Judicial College guidelines for personal injury. Your lawyer will be able to access these guidelines. You should set out the amounts being claimed with reference to these guidelines.

If you do not wish to instruct a lawyer who specialises in personal injury to help you with your claim, you should use the below as a guide for claims for psychiatric injury.

For complex claims you may require expert medical evidence. This should be facilitated through your legal adviser, and requests for expert evidence should be submitted to DBT in accordance with the published tariff on reasonable legal costs.

The factors to be taken into account in valuing claims of this nature are:

• your ability to cope with life, education and work
• the effect on your relationships with family, friends and those with who you come into contact with
• the extent to which treatment would be successful
• future vulnerability
• prognosis
• whether medical help has been sought

Categories of severity	Description	Value ranges
Less severe	The level of the award will take into consideration the length of the period of disability and the extent to which daily activities and sleep were affected. Cases falling short of a specific phobia or disorder such as travel anxiety when associated with minor physical symptoms may be found in the Minor Injuries chapter.	£1,540 to £5,860
Moderate	While there may have been the sort of problems associated with the factors listed directly before this table, there will have been marked improvement as at the date of submission of your claim and the prognosis will be good. Cases of work-related stress may fall within this category if symptoms are not prolonged.	£5,860 to £19,070
Moderately severe	In these cases, there will be significant problems associated with the factors listed directly before this table, but the prognosis will be much more optimistic than in severe cases. While there are awards which support both extremes of this bracket, the majority are somewhere near the middle of the bracket. Cases of work-related stress resulting in a permanent or long-standing disability preventing a return to comparable employment would appear to come within this category.	£19,070 to £54,830
Severe	In these cases, the injured person will have marked problems with respect to the factors listed directly before this table and the prognosis will be very poor	£54,830 to £115,730

Harrassment

You may be able to claim consequential losses for the harassment you have suffered as a result of a Horizon shortfall.

Harassment as defined in the Harassment Act 1997 means that the conduct of the Post Office towards you was ‘unreasonable and oppressive’, meaning it was beyond the boundaries of acceptable and reasonable conduct.

This will require evidence that the harassment was caused by the Horizon shortfall. You should provide evidence of:

• what constituted the harassment
• how often it occurred

Offers for harassment will generally to be within the range of £2,500 to £30,000 (in respect of non-pecuniary harm for alarm, fear, anxiety and distress). Any offers will be determined according to the relevant facts on a case-by-case basis. The Scheme will look to assess offers by reference to the set of bands.

Band	Impact	Range	Description
Band 1	Moderate impact or loss	£2,500 to £5,000	Sustained and persistent communication from POL through letters and calls regarding repayment of the alleged shortfalls over a period of time, by means of which it was intended to cause you distress.
Band 2	Serious impact or loss	£5,001 to £10,000	Oppressive and unacceptable conduct by the POL in the investigation of the shortfalls, by means of which it was intended to cause you distress. This may include, for example, oppressive or multiple interviews, house searches or threats of further action including arrest and searches, threats of colleagues being interviewed or threats of court action.
Band 3	Severe impact or loss	£10,001 to £30,000	Invasive or very oppressive conduct by POL in the investigation of the shortfalls, by means of which it was intended to cause you distress and alarm. This may include, for example, multiple or very oppressive interviews, multiple house searches or house searches with seizure of personal items, Proceeds of Crime Act 2002 (’POCA’) proceedings or threats of prosecution and prison.

These bands are not limits for what can be claimed under the Scheme but can be used as an indicative guide to help you and your lawyer formulate your claim. Each case will be decided on its merits in the round, guided by considerations of fairness. The Scheme expects there will be some cases where the facts of the case demand awards significantly higher than the upper figure for the top band.

You should provide a calculation showing how the amount being claimed has been quantified.

Distress and inconvenience

The Scheme may offer discretionary awards for the distress and inconvenience caused to you as a result of the Horizon shortfall. This will be at the discretion of the Scheme and you should therefore not claim for this loss in your application.  

Distress and inconvenience offers are expected to be within the range of £500 to £10,000, although any offers will be determined according to the relevant facts on a case-by-case basis. The Scheme will look to assess offers by reference to the set of bands:  

• band 1 – £0 to £2,500 
• band 2 – £2,501 to £5,000
• band 3 – £5,001 to £7,500
• band 4 – £7,501 to £10,000
• band 5 – in excess of £10,000, in exceptional cases

Relevant factors to determining where along that scale your case will fall may include:

• the amount of money at stake
• the duration of the period this was an issue
• wasted time or effort and inconvenience to you or your branch in dealing with Horizon shortfalls
• other factors, such as allegations of dishonesty made against you or any public humiliation you suffered

Offers for distress and inconvenience will take into account any potential double recovery with offers made to you under other heads of loss, for example stigma.  

These bands are not limits for what can be awarded under the Scheme, and each case will be decided on its merits.

Malicious prosecution (criminal)

If you were prosecuted but not convicted for a Horizon shortfall, you may be able to claim for malicious prosecution. This includes where you received a caution as a result of the Horizon shortfall.

If you were prosecuted but not convicted, you should provide as much evidence and information as possible to show that: 

• you were ‘prosecuted’ by the Post Office
• the prosecution was determined in your favour
• the prosecution was ‘without reasonable and proper cause’
• the prosecution was ‘malicious,’ – this means it was actuated by ‘malice’ on the part of Post Office
• the prosecution has resulted in actionable damage

If you were prosecuted but not convicted or received a caution, you may be able to claim for: 

• pecuniary losses (such as loss of earnings or legal costs)
• mental distress and damage to reputation (anticipated to be in the range of £10,000 to £40,000)
• loss of liberty (anticipated to be in the range of £3,000 to £5,000 where you were held for more than a day, or less where you were held for a matter of hours)
• personal injury (see the ‘consequential loss’ section)
• loss of congenial employment (anticipated to be in the range of £5,000 to £10,000)
• aggravated damages (anticipated to be in the range of £10,000 to £35,000)
• exemplary damages of £75,000

Each case will be considered on its own facts. With the exception of exemplary damages, these ranges are not a minimum or maximum to what offer the Scheme may conclude it is fair to recommend in any particular case. Each case will be decided on its merits.

Pension losses

If you suffered a loss of pension investments as a result of the Horizon shortfall, you may be able to make a claim for the loss of the tax break you would have received.  

For example, if you paid £80 into your pension, being £100 with pension relief, losses will be awarded for the £20 tax relief you would have received.  

You should provide a calculation showing how the amount being claimed has been quantified and provide evidence to support your claim. 

The types of documents that you should provide with your claim (if you can) include the following: 

• other employer contributory pension scheme documents, such as membership documents (showing your chosen investment profile), quarterly investment reports and annual statements, both pre-dating and post-dating your termination and prosecution
• private pension scheme documents such as membership documents (showing your chosen investment profile), quarterly investment reports and annual, statements, both pre-dating and post-dating your termination and prosecution
• wage and salary slips, and tax documents, both pre-dating and post-dating your termination and prosecution, which contain information such as deductions from salary and matching employer contributions paid to a pension scheme
• any other documentary evidence of pension scheme participation and contributions, such as correspondence with a financial adviser, or a pensions and investment adviser
• any documents that evidence your entitlement to auto-enrolment in a mandatory workplace pension scheme, and details of any opt-out
• any documents that evidence your intention to subsequently join and contribute to a pension scheme in the counterfactual scenario – for example retirement planning documents