A worrying article in the Guardian suggests that Southern’s Revenue Protection Officers (RPOs) may receive up to 5% commission for charging penalty fares. In their response quoted in the article Southern appears to have confirmed that this is indeed the case.
This is very worrying, particularly in an profession that, as far as I know, is unregulated. Consumer Lookout has already raised concerns that passengers may get an unjust, and possibly unlawful, penalty fare if they board at a station with no purchasing facilities.
Giving RPOs a financial incentive may tempt some of them to issue penalty fares that are inappropriate or in breach of the rules, e.g. section 7.3 of the Penalty Fare Rules that prohibits issuing a penalty fare if someone boarded at a station where there is no ticket office/machine. Whilst some RPOs may well have a level of morality and decency that prevents them from giving in to temptation, sadly others may not.
After all, their work may not be heavily monitored to ensure fairness: I have certainly seen occasions where PFOs seemed to be operating alone. Many people who receive a fine of one sort or another don’t bother appealing, perhaps through lack of knowledge, time, or simply thinking there’s no hope of winning the appeal. The same is likely to be true with penalty fares.
Southern did point out that employees are trained to use “discretion when appropriate”. But, in my view, this approach places too much reliance on the honesty and integrity of the individual. Southern also pointed out that RPOs earn commission on ticket sales, so they have no incentive to issue penalty fare over any other form of revenue sales. That misses the point: as well as paying a penalty fare, the passenger also has to buy a ticket for their journey, so it is surely more lucrative for the RPO to charge the penalty fare (commission) and sell a ticket (commission).
Some PFOs probably do exercise discretion by not fining someone who made a genuine mistake or who could not purchase a ticket before boarding … but others may discreetly be building up their wage packet. After all 5% of a £20 penalty is £1: issue 20 penalty fares a day and you could add more than £400 per month to your salary … ker-ching.