Official hearing page

10 January 2023 – James McNiven and Kevin Fletcher

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(10.00 am)

Sir Wyn Williams: Good morning, Mr Beer. We’re one short here because Ms Eliasson-Norris is unwell today so she will be following either remotely or catching up, as the case may be, depending on how well she feels.

Mr Beer: Good morning, sir, thank you. Can I call Bruce McNiven, please.

James McNiven


Questioned by Mr Beer

Mr Beer: Good morning, Mr McNiven. My name is Jason Beer and I ask questions on behalf of the Inquiry. Can you give us your full name, please?

James McNiven: My name is James Bruce McNiven.

Mr Beer: Thank you for providing a witness statement to the Inquiry and for attending today. We’re very grateful to you for the assistance that you have given to this investigation and will give to this investigation. Can you look please at the hard copy witness statement that should be in front of you, which, excluding the exhibits, I think, is 12 pages in length. For the transcript, the reference is WITN04120100.

Look at the last page, page 12. Is that your signature?

James McNiven: It is.

Mr Beer: Are the contents of that witness statement true to the best of your knowledge and belief?

James McNiven: They are.

Mr Beer: A copy of that witness statement will be uploaded to the Inquiry’s website, I’m therefore not going to ask you about every part of it. Do you understand?

James McNiven: I do.

Mr Beer: Can I start with some questions about your background and experience. I think you were first employed by the Post Office in 1973; is that right?

James McNiven: That’s correct.

Mr Beer: Did you have a background before then?

James McNiven: A background before then was largely in science-related businesses and then I converted to general management.

Mr Beer: Did you have any qualifications in management or similar?

James McNiven: I was a member of the Institute of what was then Personnel Management, now Human Resources.

Mr Beer: In 1986 I think you became the district manager of for Post Office Counters in Newcastle; is that right?

James McNiven: Correct.

Mr Beer: And in 1993 you became head of the retail network for the north-east area; is that right?

James McNiven: That’s correct.

Mr Beer: In 1996 you became the Deputy Director of the Programme Delivery Authority, known as the PDA, and responsible, therefore, for elements of the delivery of the Horizon System; is that correct?

James McNiven: That is correct.

Mr Beer: Was that a promotion?

James McNiven: Yes, it was.

Mr Beer: Can you tell us the role and purpose of the PDA, please?

James McNiven: The PDA was set up to represent the parties to the contract, DSS and the Post Office, and to interface with ICL Pathway on the delivery of the solution which was contained within that contract.

Mr Beer: How many people worked in the PDA?

James McNiven: In terms of direct employed people probably of the order of 100. The majority, I would say, were from Benefits Agency, some 40 or so staff from Post Office Counters and also a number of contracted people and advisers from outside concerns such as accountancy.

Mr Beer: Who was your line manager or senior within the PDA?

James McNiven: Yes, the PDA director was a chap called Peter Crahan who had been appointed by DSS.

Mr Beer: And that’s C-R-E-H-A-N?

James McNiven: C-R-A-H-A-N.

Mr Beer: He was, as you said, a DSS or Benefits Agency employee; is that right?

James McNiven: That’s correct, yes.

Mr Beer: So would you describe him as your line manager?

James McNiven: Yes, very much so. His title was Director of the Programme Delivery Authority and I was Deputy Director of the Programme Delivery Authority.

Mr Beer: Who was responsible out of the pair of you for reporting back to the Post Office as to the work of the PDA?

James McNiven: We were jointly responsible through the PDA board, which comprised directors from both Benefits Agency and Post Office Counters.

Mr Beer: You tell us in your witness statement – there’s no need to look at it up at the moment (it’s paragraph 6) – that you reported back to the joint BA/PO programme board.

James McNiven: Yes.

Mr Beer: How did the pair of you report back jointly to that programme board?

James McNiven: Peter would take the lead in terms of the overall progress of the solution with Pathway. I would report back on areas within more of my responsibility, such as progress on implementation plans, rollout plans and, generally speaking, the work being done by the Post Office constituent of the PDA.

Mr Beer: Did the BA/Post Office programme board have regular meetings?

James McNiven: Yes, at least monthly.

Mr Beer: Would you report to that board in writing?

James McNiven: There would be a written report to the board and then we would take questions on the day.

Mr Beer: Was there any other reporting mechanism to the board or was that the principal way in which reporting was effected?

James McNiven: That was the principal way in which reporting was effected. I had, obviously, conversations and dotted line responsibility back into Post Office Counters Limited, with whom I would have conversations with people like Paul Rich, et cetera, who might just ask advice on certain aspects.

Mr Beer: That’s what I want to ask you about in particular, what that dotted line consisted of and to whom it went, ie outside of the programme board.

James McNiven: Yes.

Mr Beer: Just sticking with the programme board for the moment, what was the purpose of the programme board?

James McNiven: The programme board was there to confirm that progress was being made relative to the contract with ICL Pathway, to deal with any problems which were arising, particularly around the release of software and the programme behind that release, and to ensure that Benefits Agency were aware of that progress, so that they could modify or accelerate their plans accordingly.

Mr Beer: Was it a decision-making body?

James McNiven: It was a decision-making body in terms of requiring myself or Peter or other members of the PDA to take issues back to ICL Pathway and to resolve them as they felt appropriate.

Mr Beer: Did it have any broader decision-making role than that, ie –

James McNiven: Is this the board still – the board we’re talking about?

Mr Beer: Yes, the board.

James McNiven: I think that the board would exercise – ultimately exercise an authority about the extent to which they were convinced by the progress; they held an authority about whether or not the programme should continue (that would be something done with the joint sponsors); and they had a responsibility for ensuring that ICL Pathway were held accountable for the progress of the programme.

Mr Beer: Who from the Post Office can you recall as being a member of the programme board?

James McNiven: Paul Rich was a member of the programme board. He was a principal member of the programme board.

Mr Beer: Anyone else you can recall now?

James McNiven: Not directly. He would report back to the managing director of Post Office Counters Limited.

Mr Beer: That was the next question: to whom did the programme board report?

James McNiven: The programme board then separately would report back to the sponsor organisations (so Post Office Counters Limited board on one hand, the DSS board on the other) and they would then take, I guess, informed decision-making from them back to the programme development board to instruct us and to instruct Pathway about the process which should then follow and the extent to which progress was being made.

Mr Beer: So was it a reporting board, ie used to pool information from the Programme Delivery Authority and then act as a conduit back to the main boards of each organisation –

James McNiven: Yes, I think that’s –

Mr Beer: – or did it enjoy its own decision-making powers?

James McNiven: I would say a combination of the two. I think the PDA board were conscious that they were representing the two contracted authorities and that the two contracted authorities had the ultimate decision-making. So they would be helping the contracted authorities to understand the extent to which the contract was being moved forward and delivered.

Mr Beer: Had you worked in the delivery of a project with a large company like ICL Pathway or Fujitsu previously?

James McNiven: No. It was a new experience for me.

Mr Beer: Had you worked on the delivery of a large project that involved a Private Finance Initiative contract before?

James McNiven: No, I had not.

Mr Beer: Had anyone on the PDA, to your knowledge?

James McNiven: Not to my knowledge.

Mr Beer: Had anyone within the programme board, to your knowledge?

James McNiven: Not to my knowledge.

Mr Beer: I think you subsequently became general manager of the Horizon implementation team; is that right?

James McNiven: Yes. When the PDA was wound up and responsibility was moved back to the host businesses, I moved back with that title and that responsibility.

Mr Beer: When was that, please?

James McNiven: I think the last PDA board meeting was towards the end of 1998. I would say September 1998.

Mr Beer: Then you became general manager of the Horizon implementation team?

James McNiven: That’s correct.

Mr Beer: Was that a role within the Post Office alone?

James McNiven: Indeed, yes.

Mr Beer: Was that a promotion?

James McNiven: No, that was a sideways move.

Mr Beer: What was the role and purpose of the Horizon implementation team?

James McNiven: The Horizon implementation team largely focused on the actual physical rollout mechanism. So helping to enable the office surveys that had to be proceeded with before an office could be converted, with any physical modifications that were required at those offices, with the actual commissioning going live with individual offices, and playing all that into the joint programme that existed between the Post Office and Pathway.

Mr Beer: How many people were in the Horizon implementation team?

James McNiven: I would say between 40 and 50.

Mr Beer: Who was your line manager or to whom did you report?

James McNiven: Then I would report to Dave Miller.

Mr Beer: Were you, therefore, in charge of the Horizon implementation team?

James McNiven: Yes.

Mr Beer: So you were responsible for the management of that 40 or 50 people?

James McNiven: I was, yes.

Mr Beer: I think your role in relation to the Horizon System ended at some point in 1999; is that right?

James McNiven: That’s correct, yes.

Mr Beer: Can you help us as to precisely when, not necessarily a date but maybe a month?

James McNiven: Yes, I think it was probably December 1999 when arrangements were in place to renew the rollout in January of the following year.

Mr Beer: Why did you move on in December 1999?

James McNiven: I think roles changed. I think on the ground there were people there who had responsibility for the field implementation. Many things were in place to renew the rollout. So, really, the job had transferred into its component parts and the role that I specifically had did not have the same strength of purpose.

Mr Beer: As in nobody took over from you?

James McNiven: Not immediately. A person who worked for me, I think, his role was expanded to the Horizon field implementation role. I think latterly someone else from the business was brought in to perhaps take over some of the former responsibilities I had and to provide a more direct management input to the team.

Mr Beer: Did you report back to the Post Office Board in that role?

James McNiven: No.

Mr Beer: Did you report back to the Post Office Counters Limited board in that role?

James McNiven: Not directly. I reported back to Dave Miller, who was member of the Post Office Counters board, through a Horizon management team that he chaired, of which I was a member.

Mr Beer: How regularly did that body meet?

James McNiven: Latterly, at least a month formally but the same people would be drawn together probably almost on a weekly basis because of the pace of events by that time.

Mr Beer: How did you understand that reports back to the Post Office Counters Limited board were made?

James McNiven: We all made our constituent parts. So I would perhaps write about or contribute to a report about the pace of rollout, the readiness of the Post Office estate, the situation regarding training, et cetera; so I would report back on my individual responsibilities. Other people would do the same and it would be combined into a full report.

Mr Beer: Looking back now, having had the benefit of some years of reflection, what would be your overriding view of the work of the Programme Delivery Authority?

James McNiven: I think the work of the Programme Delivery Authority did as well as it could within the constraints it was working under. I think there was a will to work together. The staff in the PDA, both POCL and BA worked well together, but we were conscious that we were a bit of a forced marriage. We had somewhat different objectives. I think that was always realised. So we were trying to make the best of what we had.

I think as the Programme Delivery Authority developed and just before they split back into their host organisations, it was becoming increasingly difficult, I have to say, because the objectives of each party were beginning to move further and further apart.

Mr Beer: You said that it worked well, given the constrains under which it was working or the constraints it was working under. What were those constraints? Were they only different objectives or were there other constraints?

James McNiven: No, I think they were principally about different objectives which were becoming clearer as time passed. I mean, the other constraints within which it worked was the whole relationship with ICL Pathway, which I think has been rehearsed previously by other witnesses, and that was a constant source of frustration.

Mr Beer: Why was it a source of frustration?

James McNiven: The inability – well, the PFI contract was the primary barrier. The role we had in the PDA was one of assurance, so – and largely documented assurance before we could actually see anything developing. So a set of requirements would be translated by ICL Pathway into a solution. That solution would be recorded and documented and the role we largely had, certainly from a POCL perspective, was to try and understand what they intended to do and to try and assure that their intentions met the requirements.

As I say, often this was a nebulous process based on a document before we could actually see things operating.

So it was frustrating and trying to get behind that to find out a bit more about the processes, the thinking, how that was going to come together, was extremely difficult. Now, I’m talking particularly from a POCL interest here but, working with the Benefits Agency, I was party to their frustrations as well as not seeing how things were developing and the constant requirement for re-plans.

I think my first six months to a year of working at the PDA was almost entirely involved in re-planning exercises as the timescale slipped, so new plans had to then be devised. That had impact onto the implementation and rollout plans of course, of which I had a particular interest, but I think within that first year this happened three times. So that was a very frustrating aspect.

Mr Beer: Any other reflections overall on the way in which the PDA works or how it functioned or the pressures under which you were operating?

James McNiven: Along with Peter Crahan I met frequently with ICL Pathway, normally at their premises, and we would go through a long list of issues that were arising. They were as helpful, I think, as they could be but it was becoming clear that their development processes were lagging behind and all we could do was take back as much information as we could and try to understand how lags in that process were going to impact on the plans which we had developed.

It was difficult. I don’t think through any ill-will. I think Pathway’s perspective on our assurance was probably that we strayed too far into interference and I think that constant tension was always there.

Mr Beer: Given what you’ve mentioned as to the fundamentally different objectives of the two client contracting parties and constant frustrations with the way that ICL was operating and working and delivering, why did, in your view, the project proceed? Why was it not brought to a stop?

James McNiven: Well, it was brought to a stop in terms of its initial condition. I mean, the joint programme was brought to a stop by BA when they essentially withdrew from the programme. So there was a point, I guess, in 1998 where Post Office Counters had to decide whether to continue a relationship with ICL Pathway to get something over the line, which was to the Post Office’s benefit, or to withdraw and there were many, many discussions around this subject.

The decision, obviously, eventually was taken that it was in Post Office’s interest to continue because to stop and try and restart the whole process would put POCL so far behind the momentum of the DSS to move to different payment methods that we would probably never catch up.

They had withdrawn from the card payment process, which is where we had come in. That was seen to be the way ahead for both parties. Very quickly, I think it became apparent that DSS did not favour that solution. I think that position was amplified by a change of Government. I think when the Blair Government came in in May 1997 they had a vision of social inclusion which was about people having bank accounts rather than physical payment methods over a post office counter and I think DSS regarded that as the way ahead.

So what we were trying to develop with Benefits Agency was something which was to preserve the Post Office position for as long as we possibly could until we could adopt a technological solution which would allow us to work alongside those decisions.

So, ultimately, the decision was taken that, without technology and without technology soon and without the technology which had at least in part been developed, the whole future of the Post Office, as it was constituted, was very much in doubt.

Mr Beer: You sat in your position, I think, would this be right, in a space between directors and executives on the one hand – so the very senior management of POCL – and those responsible at a lower level on the ground for actual delivery.

James McNiven: Yes.

Mr Beer: Did you feel any pressures from above to ensure that this project proceeded?

James McNiven: At the point at which I have been talking, when BA withdrew, the pressure was the pressure of continuity, that we had something to deliver, that we had a business at the end, and that was significant and I think people signed up to that concept. As we go further downstream towards the whole process of acceptance of the then ICL Pathway solution for Post Office Counters, I think the pressures changed. I think we still had that pressure to deliver something for the future of the business.

Mr Beer: In what way did the pressures change? We’re talking here from April ‘99 onwards?

James McNiven: Yes. I think as part of – if I can step back, when I was working for the PDA, the impetus was from the PDA to Pathway to get something done. When Post Office took on the contract, very quickly, I think, the impetus changed to being from ICL and Pathway to get this thing over the line as soon as possible because, quite clearly, it was clear to us, there were enormous pressures on Pathway and the people in Pathway to get this delivered because of the pressures on ICL and Fujitsu, given the background and the degree of finance they had put into the project.

Mr Beer: This switch, am I understanding it correctly, to say that it was a move from pressure being placed on ICL to a pressure coming from ICL for contractual and fiscal reasons?

James McNiven: I think, in the broadest sense, that’s probably true. There was still pressure from ourselves in Post Office Counters back to ICL Pathway in terms of this whole aspect of assurance and making sure that what they were delivering was fit for purpose. So we had these competing pressures of ICL Pathway wanting to move this contractually over a line at which they were paid and most of us on the ground in Post Office Counters trying to ensure that what was being delivered was of a satisfactory quality to allow that to happen.

I mean, also I think at the time we were all – we all knew everything else that was happening, the Treasury review, there was a political interest. So, although these things were happening at a different level, at the working level contact with ICL Pathway these were quite apparent.

Mr Beer: In what way –

James McNiven: In –

Mr Beer: – were they tangible?

James McNiven: In the way in which we were – Post Office Counters was under pressure perhaps to accept conditional changes to whatever it was, training or software or whatever, to get to that point of acceptance.

Mr Beer: Just explain what you mean there. I think I understand it but for those that may not. So a pressure to accept conditional changes to get to acceptance?

James McNiven: So the key process as the development with Pathway proceeded, as a Post Office solution, began to focus on contractual acceptance; that is, the conditions under which Post Office Counters would say “Yes, we accept the solution and, because of that, we will meet certain contractual conditions about payment”. So we were aware of that.

The individuals concerned as well, on the Pathway side, were obviously working under pressure to get this done. Again, I think there was goodwill to try and get it done as well as possible and I think that many of my colleagues in Post Office Counters did enormously good work to try and ensure that we had a satisfactory solution and outcome.

Mr Beer: Can we now look at some of the material with that background in mind. There are a large number of documents that might be raised with you concerning your earlier involvement in the project between ‘96 and ‘98. I’m not going to go through all of those because they principally relate to what we call Phase 2 matters, which have already been addressed with other witnesses and, in the interests of proportionality, it’s more important that we concentrate on the Phase 3 issues.

There are a few exceptions to that, which I just want to look at now, please. Can we look at POL00028591. It will come up on the screen.

Thank you very much.

This is a Post Office Counters Limited service management report.

James McNiven: Yes.

Mr Beer: I think you’ll be familiar with the style of the document.

James McNiven: Yes.

Mr Beer: You will see that this one is dated 30 June 1998 and it relates to the period of May 1998. You’ll see the author is Dennis Wong, who, in the bottom left, is described as a Horizon performance analyst, and we can see the distribution list that includes you, first column, fourth down.

James McNiven: Sure.

Mr Beer: So this is before the Benefits Agency withdrew from the project –

James McNiven: Indeed.

Mr Beer: – May ‘98?

James McNiven: Yes.

Mr Beer: Can we look at page 6 of the document, please. We’re dealing here with the Benefit Payment System, so the BA part. Under the sub-heading “Lost Transactions (LT)” the document reads:

“A baseline has been introduced this month to regularly indicate current levels of [lost transactions] in an easily readable form. This has been carried out to reflect TP …”

I think that’s transaction processing; is that right?

James McNiven: That’s correct, yes.

Mr Beer: What was transaction processing?

James McNiven: Transaction processing was a unit within Post Office Counters which derived information from the cash accounts to produce the Post Office accounts.

Mr Beer: Thank you:

“… and Service Management concerns. These concerns are that current levels, while presently manageable, may not be acceptable to the business when large volumes of encashments are returned by newly automating post offices. [Lost transactions] indicate, when extrapolated (for BES only) …”

That’s the Benefit Encashment Service; is that right?

James McNiven: That’s correct.

Mr Beer: “… volumes that may be startling in the live service. It is worth noting however, that caution needs to be exercised when viewing raw figures as there may be variables and arguments that might effect extrapolations.”

That’s a relatively significant warning, isn’t it?

James McNiven: It’s a significant warning from a low level volume of encashments at an early stage of development. But it’s a signal that there is something not right.

Mr Beer: It was essentially being based on what was being seen in the operation of the Horizon System in relation to the Benefit Payment System?

James McNiven: That’s correct.

Mr Beer: We’re here about 18 months or so before national rollout; is that right?

James McNiven: Yes.

Mr Beer: Can we look, please, next at POL00028589, and the same style of document. This one is dated 28 July 1998, I think produced by Mr Turnock, a Horizon performance manager. Did he work under you?

James McNiven: Not directly, no.

Mr Beer: We can see that this relates to the period of June 1998; so the period following the one that we just looked at.

James McNiven: Mm-hm.

Mr Beer: Again, you are on the distribution list.

James McNiven: Yes.

Mr Beer: Again, if we just look at page 6 of the document and you’ll see that under the same heading “Benefit Payment System”, the title of “lost transactions”, as the text says, has been changed to “incomplete transactions”, as:

“This is considered to be a better description of the problem. To date all transactions have been recovered by manual fallback.”

Then the second paragraph:

“It has been agreed both POCL and ICL Pathway that the current levels of incomplete transactions is not acceptable for a system where the primary function is to record and manage transactions.”

Just looking at that, that’s obviously right – something that you would agree with –

James McNiven: It did, yes.

Mr Beer: – that lost or incomplete transactions is not at all acceptable for a system whose raison d’etre is to record and manage transactions?

James McNiven: That’s correct.

Mr Beer: “From a POCL perspective it would seem reasonable to expect that the Horizon System has integral safeguards to protect and preserve transaction data.”

No doubt you would agree with that sentence too? It’s not unreasonable for the Post Office to expect that the Horizon System had safeguards within it, that were integral to it, to protect and preserve transaction data?

James McNiven: Absolutely fundamental, yes.

Mr Beer: “Integrity, consistency and durability are fundamental requirements of any transaction processing IT system.”

Again, I think you would agree with that as a principal, that integrity, consistency and durability are indeed fundamental requirements of a system such as this?

James McNiven: Absolutely.

Mr Beer: “As it is, there seems to be a variety of situations where the system reacts unpredictably and loses data.”

Again, that must have been of significant concern?

James McNiven: Of course it was and these are issues arising in live operation and some of these would be reflected back in the testing arena and I’ve no doubt that they would be being picked up there as well and conversations would be taking place between people in model office testing and ICL about digging underneath the issues that arise here, so that solutions might be found.

Mr Beer: These two documents that we’ve looked at look at the issue of the importance of integrity, consistency and durability from the context of a transaction processing system.

James McNiven: Mm-hm.

Mr Beer: Were you ever aware that one of the core requirements of the system was for data that it produced to be available to support investigations and prosecutions?

James McNiven: Yes, it’s a good question. I mean, I think there is documentation along the way that refers to the role of audit in the process and how audit managers would understand the system, how they could interact and investigate the system. I mean, beyond that, I know that they were part of the training aspect that they received enhanced training about the use of the system and I think there was an additional module about how they could interrogate the system.

But, yes, of course it is important that they had that access.

Mr Beer: Just thinking about the question more directly, were you aware at this time that one of the core requirements of the system was for it to produce data that had sufficient integrity to support investigations and prosecutions?

James McNiven: I don’t think I was conscious of that in the way in which you have expressed it. I was very conscious of the requirement for the whole system to have data integrity. I was not specifically focused on the requirement for that to reflect into the audit process.

Mr Beer: Was that, in your time on the Programme Delivery Authority and then as general manager of the Horizon implementation team, ever discussed, ie the issue looked at from that angle?

James McNiven: Not to my recollection.

Mr Beer: Did you know that the Post Office had the facility to and, indeed, did prosecute its own subpostmasters and other staff for criminal offences?

James McNiven: Yes, indeed. When I was a local manager, I was often involved in the decision taken along that line towards prosecution. Local management were a key component.

Mr Beer: In what way were local management a key component?

James McNiven: Well, if the audit team had been into an office and found discrepancies, that would be reported back to the local management. So, ultimately, dependent upon the decision required, it could reach the head of retail network, who was a senior man in charge of the field force, or when I was district manager I was often involved in decision-making of that sort.

So there was a check process that said, “Yes, audit have found this, this is what we found” and, very often as a manager, I would interview the subpostmaster concerned, and very often they would have the support of the Federation of SubPostmasters’ representative and I would go through the whole thing with them about how this had arisen, what were the issues behind it, were there any mitigating circumstances.

So, at that time, line management had a key role to play in the prosecution decision.

Mr Beer: What role did line management play? You mentioned interviewing and talking it through with the subpostmaster. Did they have a role in decision-making as to prosecution?

James McNiven: Yes.

Mr Beer: What role did they have in relation to decision-making?

James McNiven: Ultimately, they would endorse a decision to prosecute. I mean, it would be taken by the audit people with the legal stream within Post Office Counters but it was, I think, inherently important, and written into the arrangement, that the local manager had sight of and endorsed the decision.

Mr Beer: Do you mean by that that they always endorsed?

James McNiven: Oh no, no, not at all. In fact, again, I recall, as a district manager, there was an arrangement whereby if the Federation representatives felt that the case was wrong, the decision was wrong in district A, there was an appeal process and some of us from district offices outwith that decision-making could be called in to hear appeal.

So we exercised a kind of independent perspective, bringing knowledge from our own experience into that decision-making process and I’m pretty sure from my experience that there were occasions whereby the appeal manager might say “I’m not sure this is right, I’m not sure it’s the right decision, I’m not sure about the degree of the severity of the decision and maybe you should go back and have a look at other aspects”.

So there were checks and balances, I think, is what I’m trying to say.

Mr Beer: With that knowledge that you had and that role that you performed, wouldn’t it have been obvious to you, therefore, when you became Deputy Director of the PDA and then general manager of the implementation team, that the Horizon data would be used for the purpose of investigation and potentially prosecution?

James McNiven: Inevitably it would be used. It was a source of the accounting process. As I said before though, I was not aware of any concerns from the audit community about their engagement with this and, of course, I’m saying all this on the understanding that the system was sufficiently robust to be providing information which was sufficiently supportive of these decisions.

Mr Beer: Why –

James McNiven: That would be my belief.

Mr Beer: On what basis did you reach that understanding, as you called it?

James McNiven: Of what – my view of it?

Mr Beer: Yes. You said that – you were saying it on the understanding that the system was sufficiently robust to produce reliable data. Where did you get that understanding from?

James McNiven: I had no reason to doubt that it had.

Mr Beer: So it was a presumption of rectitude?

James McNiven: It was a presumption of rectitude, at the point at which we reached when acceptance was given to the Horizon System.

Mr Beer: Was that ever tested, the presumption?

James McNiven: The presumption of the information being sufficiently robust to support prosecution?

Mr Beer: Yes.

James McNiven: Not as such. The presumption was that the information was sufficiently robust for business purposes.

Mr Beer: In your role in the PDA and then the HIT, as I am going to call it – Horizon Implementation Team – to your knowledge, was anyone from audit investigation or prosecution involved in discussions as to the requirements of the system in order to produce data that had sufficient reliability and integrity for criminal justice purposes?

James McNiven: I’m afraid not to my knowledge – not within the area in which I was operating.

Mr Beer: If they had had involvement in the design of the system the specification of the requirements and ensuring that they were being delivered, I think in your roles in the PDA and the HIT you would have known about it?

James McNiven: I’m sure that there was a requirement in the requirements index of the contract that referred to this availability in this report but, to be – I really cannot recall it.

Mr Beer: That requirement that you’re referring to, is that something that you now remember because you’ve seen the process of the Inquiry unfold over the last three or four months and seen people ask questions about it?

James McNiven: In any of the roles in which I was involved, I don’t think I was ever at any stage consciously aware of the audit requirement or specifically focused on an audit requirement and ensuring that that was delivered.

Mr Beer: So just looking, sorry, back at this document here and that second paragraph, at the end of it, where it records that there seem to be a variety of situations where the system reacts unpredictably and loses data, you said that that’s the system in operation in live time, not model office testing or other types of testing.

To your knowledge, were these lost or incomplete transactions on the BPS (Benefit Payment System) ever seen as relevant to or a threat to the accounting integrity of the system on the POCL side?

James McNiven: I’m sure they would be. Again, from my recollection and knowledge, I can only presume that it would be. I cannot comment beyond that.

Mr Beer: Can we look on please, moving the story forwards, to POL00090839 and the second page, please. Just give me a moment to catch up in my hard copy.

You will see this is a letter dated 23 August 1999 – top right – from Ernst & Young, the well known auditors and accountants, to David Miller. I think he was the MD of POCL at that time; is that right?

James McNiven: No, I don’t think – no Stuart Sweetman would be the managing director, I believe.

Mr Beer: Yes, quite right.

James McNiven: So Dave Miller would still be director of counter automation.

Mr Beer: You will see the handwriting in the middle of the top of the page, where Mr Miller, it seems, has added a note. Do you see where it says “DWM”, underneath that that is Mr Miller’s signature –

James McNiven: Right.

Mr Beer: – that’s been redacted for data protection reasons and his note is dated 24 August 1999, so the day after the letter. You will see that it addresses the letter to you.

James McNiven: Mm-hm.

Mr Beer: “1. Bruce McNiven

“2. Keith Baines …”

There’s a tick through your name. Would that be done to record that you had been sent it or received it?

James McNiven: I should assume so, yes.

Mr Beer: Thank you. He says:

“… Mr Miller.

“Please ensure that these issues are fully addressed during the remaining acceptance process. Keep me in touch.”

If we look at the letter itself, Ernst & Young say:

“As auditors of The Post Office we have been asked by [POCL] to provide you with our views in respect of certain accounting integrity issues … from tests performed by POCL on Horizon data in the live trial.”

We can skip the next paragraph. Paragraph 3:

“The live trial is limited to 323 outlets. We make our comments on the assumption that this sample of outlets will be representative of the full network of outlets.”

Then paragraph 4, if we scroll down, thank you:

“The following issue, as described to us by POCL gives us concern as to the ability of POCL to produce statutory accounts to a suitable degree of integrity. We understand that POCL has attributed a severity … of “High” to this matter.”

Paragraph 5:

“Incident 376. Data integrity – In order to test the integrity of weekly polling of Horizon cash account transactions, POCL are reconstructing a weekly total by outlet from daily Horizon pollings. At present this control test is showing discrepancies in that certain transactions do not record the full set of attributes and this results in the whole transaction being lost from the daily polling.”

To your knowledge, was that the same or a different issue, this time in relation to the Horizon System being operated by POCL, not the Benefits Agency, that we just looked at?

James McNiven: The one previously was the Initial Go Live offices of which there were relatively few and they were only doing business encashment for child benefit.

Mr Beer: I realise the difference in subject matter.

James McNiven: Sorry, I beg your pardon.

Mr Beer: My question was: was the issue the same, to your knowledge?

James McNiven: To my knowledge, the issue was the same in terms of outcomes, in that, if there was a discrepancy between the two, that was a serious problem.

Mr Beer: But the reasons for it you don’t know – is this right – one way or the other the technical reasons for the outcome are the same or different?

James McNiven: Honestly, I don’t know.

Mr Beer: In the last paragraph – sorry, in the penultimate paragraph on the page, Ernst & Young say:

“We are informed that an incident has also occurred where- transactional data committed at the counter has been lost by Pathway system during the creation of the outlet cash account and has not therefore been passed to TIP in the weekly cash account subfiles.

“Both types of incident result in a lack of integrity on each of the two data streams used by POCL to populate its central accounting systems. We understand that the cash account data stream is the primary feed for POCL’s main ledgers and client reconciliation [purposes].”

Then over the page, similar language used in the second paragraph on the page to the language we have been reading:

“It is a fundamental of any accounting system that it provides a complete and accurate record of all transactions. These discrepancies suggest that the ICL Pathway system is currently not supporting this fundamental.”

Then skipping a paragraph:

“The nature of the gaps in both the cash account and transaction data streams is such that POCL believe that they would not be able readily to explain them, and that significant balances might have to be written off to the profit and loss account.”

Then it goes tong deal with the impact of all of that on the auditors’ opinion on the statutory accounts.

The message being given by Ernst & Young here is very similar to the message being delivered by the analyst the year before.

James McNiven: Yes.

Mr Beer: Never mind from an auditing or accounting perspective, did this letter cause you and the senior management of POCL to stop, take stock and say “Hold on, this system has fundamentally insufficient integrity and ought not to be rolled out”?

James McNiven: Yes, simple answer to that is yes, and this issue and some others became the final focus of the acceptance process, and Keith Baines and the commercial team put in a huge amount of work to try and ensure that the contract, as it existed, as we moved forward, still retained the right of Post Office Counters to ensure that this question of derived cash accounts and office cash accounts actually matched was proven at a point at which acceptance was given and was given conditional to this being one of the conditions that was given to acceptance, and that continuing resolution would carry on and be proven to Post Office Counters Limited before further rollout took place.

So the contract, as I understand it, I’m trying to remember, had various iterations as it went through and, as these things arose, there were codicils or additions put into the contract that said “We still will not accept, we still will not go to rollout, until these conditions are met”. I do believe it was made clear in contractual terms about the seriousness of these issues and the impact that they would have on both acceptance and rollout. Work went on this continuously, beyond my being there, in fairness. Working trying to prove that this would operate properly was still going on.

Mr Beer: Even that point of you leaving in December ‘99?

James McNiven: Yes, beyond that. I think it went into January. When the decision to take the next phase of roll-out, which commenced at the end of January/early February, I think the proof that this was no longer an ongoing issue was still being looked at.

Mr Beer: So, essentially, the answer is, yes, it was realised that this was a fundamental problem, it was addressed through amendments to the contract that introduced acceptance criteria –

James McNiven: That’s correct.

Mr Beer: – that related to it?

James McNiven: Absolutely.

Mr Beer: So, in short, we find the answer in the second and third supplemental agreements. You have referred to them as codicils?

James McNiven: Yes, yes.

Mr Beer: I am not going to take you through, we have been through the second and third supplemental agreements extensively but I just want to look at acceptance, faults and the approach to acceptance and can we start, please, at POL00028429.

You’ll see that on 4 December Andrew Simpkins, said to be of Horizon release management, wrote to a number of key figures in POCL and, indeed, ICL Pathway, I think, on that list.

James McNiven: Yes.

Mr Beer: What was Horizon release management?

James McNiven: As I recall, Horizon release management was looking at it from a POCL perspective about the conditions being put on acceptance and the way in which those conditions were going to be met.

Mr Beer: Was Mr Simpkins in charge of it?

James McNiven: Yes, he was.

Mr Beer: So it was responsible for the management of the acceptance criteria?

James McNiven: As I understand it, yes.

Mr Beer: You see this memo is copied to you just on the right-hand side, underneath the two GRO redactions, and underneath the title of “Horizon Testing and Programme Plan – Current Status”, there’s an abstract:

“This memo summarises progress made in the last week, the agreed next steps, and issues for management attention, and highlights the continuing uncertainty between ourselves and Pathway with regard to the testing plan.”

You’ll see under “Progress this Week”, if you just read that to yourself –

James McNiven: Mmm. (Pause)

Mr Beer: – that it highlights some problems including testing, including in relation to, as we go through the memo, EPOSS and the TIP interface?

James McNiven: Mm-hm.

Mr Beer: It includes problems concerning cash account imbalances and problems with reference data and code problems.

James McNiven: Yes.

Mr Beer: Then if we go to the third page, please, under “Impact on Plan”, and if we look at the third line, Mr Simpkins says:

“We do not have however an understanding of Pathway’s prognosis for fault clearances which would help inform this assessment nor an alternative proposal from them as to how this confidence could be achieved in a faster timescale.”

Then three lines on:

“Our position remains, however, that based on the nature of the business processes involved, we need to see clear evidence of, firstly, a stable accounting and reconciliation position in the outlet followed, secondly, by the transfer of accurate data across the TIP/HAPS/BES and Reference Data interfaces.”

So was this alerting you to known issues arising with TIP and its interface and cash account imbalances on the POCL side of the project?

James McNiven: Yes, I think this is the continuing dialogue about those underlying problems. This is about the underlying problems in relation to entering model office testing and then, from there, into live trials, and I think you are drawing out that it’s a continuing theme. People had seen throughout that this issue was never resolved satisfactorily along the way, until we got to the actual acceptance and, as you say, the conditions on the contract.

Mr Beer: The document is emphasising that both live testing and the acceptance process will be important?

James McNiven: Fundamental, yes.

Mr Beer: Can we move on, please, to POL00028571. We should see that this is a memorandum, an update, from Dave Miller to Stuart Sweetman on Horizon acceptance, dated 8 September 1999, copied to you in the top right. Can you see that?

James McNiven: Yes, I can.

Mr Beer: Its subject is “Horizon Acceptance”, and I’m going to look at some of the headings in here, look at some documents relating to them coming back to this each time, if you understand.

James McNiven: Yes.

Mr Beer: So if we, firstly, look at paragraph 1.1, where it’s noted that you and Ruth Holleran – can you help us as to the role that Ruth Holleran undertook?

James McNiven: Ruth Holleran was in the POCL structure, she took a more commercial perspective on this. So if some of these failures affected the contract or the commercial outcome, she would be involved in that transition.

Mr Beer: So:

“Bruce McNiven and Ruth Holleran have done excellent work squeezing a better training deal out of ICL Pathway. The incident remains at high because of the need to support Training with a better Helpdesk facility. However this will in all likelihood be downgraded today medium incident with an agreed rectification plan and therefore no obstruction to acceptance.”

Can you help us: in what way did ICL Pathway need to be squeezed in order to provide a better training deal?

James McNiven: I think, going right back to the earlier requirements, they eventually said that counter staff had to be trained to a degree that they could confidently, accurately handle the new process, in terms of their interaction with customers, and that managers of the outlet could do that and be able to use the information to produce a satisfactory balance in the office.

It was difficult along the way to get a clear understanding and an acceptable outcome from ICL Pathway that, from our perspective, met those requirements. I think right back at the beginning the proposed training schedule was something like half a day and then workbooks and, essentially, distance learning. So through iterations over months and indeed over a year or a year and a half, we had moved this along to provide a much better classroom training environment, much more appropriate content, a beefing up of the balancing training content and, ultimately, a defined role within POCL to support offices as they went live and, subsequently, on first and sometimes second balancing, which we attributed to failures of the training product, which ICL contested.

So, ultimately, there had to be an agreement, at the end of the day, about how this would operate, how subpostmasters would be supported through training and how they would be supported post training in the live environment.

We did succeed in reaching an agreement, which actually involved the deployment of a large part of the Post Office resource in the retail line into the support mechanism.

Mr Beer: We’re going to come to that a little later but can we look first at the Acceptance Incident relating to training, which is AI218, and look at POL00029130. Look at page 4, please. You will see this is the AI relating to training –

James McNiven: Yes.

Mr Beer: – 218 and under the description of the incident, it records that:

“The Managers Training Course is not acceptable due to deficiencies in the accounting modules. In the live environment the training given did not equip the users to perform the completion of office cash accounts. This is a …”

And I think that should read “basic”:

“… [basic] POCL function that is central to running and accounting for the POCL network.”

So just dealing with the two issues that are being raised there, firstly the managers’ training course is not acceptable due to deficiencies in the accounting modules. Can you recall what the deficiencies in the accounting modules were?

James McNiven: I can’t specifically recall each individual component. The testing of how well it was operating was in the confidence and the accuracy with which a subpostmaster, say, could complete his cash account in his office within a reasonable time scale. So what we were observing was the outcomes, and the outcomes being unsatisfactory.

I think, in terms of content, I can’t remember. I could not go into detail. But there was insufficient time initially given to allow subpostmasters to work with the system to gain that confidence. So that time was expanded and different scripts were written to enforce – to enhance, rather, their experience.

But, honestly, I just cannot remember in terms of individual components of that training script.

Mr Beer: So you couldn’t recall now what was done to address the deficiencies in the accounting modules?

James McNiven: Not individually, apart from the length of time given to it, devoted to it and an increase in the detail. But I was not involved at that granular level.

Mr Beer: Then it says:

“In the live environment which training given did not equip the users to perform the completion of office cash accounts. This is a [basic] POCL function …”

Can you recall whether any work was done to establish, where errors were arising, whether they were due, in fact, to poor training rather than a systematic or structural bug, error or defect in the system?

James McNiven: It’s a key question. From the perspective of training, if we regard the deficiencies as a training issue in that people had not sufficiently understood how to interact with the system. If it subsequently transpired that that was never going to work because of deficiencies in the software, that may have appeared later.

I think we have to remember that it didn’t apply to everybody. Although there were subpostmasters who struggled, there were subpostmasters who succeeded and I think because of that, we regarded it more of a training issue than an underlying software issue.

I honestly – we had concerns about the underlying software but we – in my experience, we did not relate that software issue to –

Mr Beer: Was that consciously addressed, ie we know on the one hand that this system has got quite a significant number of errors, bugs and defects that we know about through a range of measures –

James McNiven: Yes.

Mr Beer: – some of them we are being told about by ICL Pathway, some of them we saw in model office testing, some of them we’re seeing in live testing, some of them we’re seeing as the system is being rolled out: Issue 1. Issue 2: there are problems being reported to us with the adequacy of the training that subpostmasters are receiving and, in particular, they’re struggling to perform basic accounting functions. Is there a connection between the two?

James McNiven: I think it depends on the point in time at which you look at this. In model office testing, where Post Office staff were invited in to run the system as live but in a model office environment, there were deficiencies because things were not working properly. That was early on.

Throughout all this and lying in parallel with all this, was the Pathway process and assurance that, as these issues arose, they were being fixed. So we have what we see, visibility of issues and, alongside it, a reassurance that these things were being fixed. So in model office, I would say, yes, model office was probably about software issues, that it wasn’t working properly.

When it came to live trial, there were two parts to that. This is in May 1999. So there were the Initial Go Live offices which were being upgraded, as it were, from what they did to the full release software and they had a training process there which was not working very well. Again, alongside it, things were being done by Pathway.

When we came to the next batch of live trial offices, the new offices being brought into the process, of which there were about 100, it was observed that the training was – the outcome of the training was better but subpostmasters were saying of that batch that they felt more confident about their ability to complete a balance.

However, there was still sufficient concern that, written back into the acceptance process an additional group of offices – I think about 25 or 26 – were brought into what was a final training product and put through that training product as part of a live trial, in addition to the baseline numbers and, as I recall, the feedback from that was actually quite positive. So we had gone from a position of concern, suspicion and not working over months, to a position of rectification seeming to indicate that the training product was operating and one – this is a leap – but that the basis of the system on which that training process was working was also operating because balances were being maintained and were being reached.

Mr Beer: Was there, to your knowledge, any communication to Post Office auditors, investigators or prosecutors about imbalances and discrepancies that may be being caused by training inadequacies in this early period that should be taken into account in investigatory and prosecutorial decision making?

James McNiven: I’m honestly not aware of any conversations or interactions of that kind.

Mr Beer: Would you agree that it was a logical thing to do?

James McNiven: It may have been done. I’m not aware whether or not it was being done. I know that auditors were being trained alongside.

Mr Beer: Just going back to the question: would you agree that it would be a logical thing to have done?

James McNiven: It would.

Mr Beer: Can we move to page 7 of the same document, please, which is a letter from you dated 10 August ‘99. Scroll to the bottom, please. You’re given the title here “Director Horizon Programme”?

James McNiven: I think that’s wrong. That’s erroneous. I never carried that title.

Mr Beer: No. Then going up to the top of the page, I think we can see that it’s to Mr Dicks at ICL Pathway. Was he your opposite number?

James McNiven: Not really. I think he was brought in to try and resolve this issue.

Mr Beer: The training issue?

James McNiven: The training issue –

Mr Beer: I see.

James McNiven: – because it was a high level incident.

Mr Beer: The title is “Review of Acceptance Incident 218” and you said:

“An analysis of the evaluation against the business impacts identified in the Acceptance Incident is attached.”

I’m not going to go through but there’s a five-page spreadsheet attached:

“Although many of the criteria have been met, it is regarded as significant that the training and Go Live process relies on the deployment of POCL HFSO resource.”

Is that Horizon Field Support Officers?

James McNiven: That’s correct.

Mr Beer: Just explain please what Horizon Field Support Officers were.

James McNiven: Yes, there were two aspects. One was support to the actual Go Live event at an office and the migration of data and then, subsequent to that, they were also deployed to support, as I said before, the first balance and also potentially the second balance, to provide support and confidence to the subpostmasters.

Mr Beer: “On the basis of this evaluation, we are not prepared to reduce the severity rating from ‘high’.

“POCL’s view is that without this resource …”

That’s the HFSO resources:

“… there would have to be a complete revision of the training approach in order to ensure helpdesks were not rendered ineffective by the high level of calls following the first and, to some extent, subsequent balances.”

Just to make clear what you are saying here, you’re saying that “Your training, ICL Pathway, is too heavily reliant on the need for our Field Support Officers to be deployed out on the ground to help subpostmasters balance their accounts”; is that it?

James McNiven: That’s correct, yes.

Mr Beer: So “Your training’s inadequate because it needs us to put people – boots on the ground to actually help subpostmasters do the most basic function, which is balancing their accounts”?

James McNiven: That’s the perspective we are taking there. I think ICL Pathway would say we have fulfilled the obligation for training. We don’t know the competencies that exist out there amongst 18,000 post offices.

Mr Beer: Wasn’t that obvious to them, that there would be some people who were 18 and keen and some people who were 87 and had never switched an electronic device on in their lives?

James McNiven: Yes, I think it might have been obvious to everybody. I don’t think, in fairness, POCL would say they had a clear understanding of the competencies of the estate of subpostmasters and assistants. So I don’t think, coming in, POCL were able to say, “We know who will adapt to this more quickly and we know who won’t adapt to this”. We have an understanding of offices which maybe cause problems, but we don’t really understand the whole estate.

Mr Beer: Just stopping at that point, was thought ever given to taking a sample of SPMs beforehand to gauge the level of competence?

James McNiven: I think you’re going to talk to Kathryn Cook later this week, who was custodian of training within POCL. Kathryn Cook did some work in association with this debate about what competencies we knew about out there.

Now, I know this is downstream, and maybe all that work should have been done as a management of change process and perhaps it would be done if we started again, but I think we were trying to understand this as we went along. But what we were convinced about was the training product did not meet the requirements of every individual and some individuals had to be supported post Go Live.

Mr Beer: Again, if you’re designing a training course, don’t you first establish what the level of existing competence is and the training needs of the likely cohort to whom it is to be delivered?

James McNiven: I think that’s fair comment.

Mr Beer: Just very quickly before the break, if we just look at the headline of the ICL response, that’s at page 12 of this document. I’m not going to read the whole document. It’s on the system that’s available for reading but, in essence, in replying to your letter of the previous day, Mr Dicks, who is the author of this letter, says:

“Pathway is convinced that it has done everything that it can to improve the training and prepare users for Horizon, and that the essence of the remaining issues that you are seeking to address relate to POCL’s own management of change.”

So he’s saying “it’s you, not us” essentially?

James McNiven: Yes, he is. He’s saying that we – the kind of things that you have talked about about understanding levels of competence, and also I think he’s inferring that some of the back-end processes, which we were changing to adapt to Horizon being an office, were contributors to the whole end-to-end training knowledge and that was the position they took.

Mr Beer: Thank you. Sir, might that be an appropriate moment to take a 15-minute break?

Sir Wyn Williams: Yes. Do you want to make it 25 to or 20 to, Mr Beer?

Mr Beer: 25 to is fine. Thank you, sir.

(11.24 am)

(A short break)

(11.38 am)

Mr Beer: Thank you, sir. Mr McNiven, can we go back to POL00028571. You remember we were using this document as our basis for exploring a range of issues and we looked at training. Can we go on, please, to the second page – to the third page, actually. The second page is blank. Thank you.

Under “Summary”, and just see what Mr Miller says:

“Of our six key players (Keith Baines, Ruth Holleran, John Meagher, Bruce McNiven, David Smith, Andy Radka) the first 4 …”

So I think that includes you?

James McNiven: Yes.

Mr Beer: “… would opt (somewhat reluctantly) for conditional acceptance towards the end of September. Andy Radka and David Smith would not accept and seek to use the full period until 15 November to force improved performance from ICL Pathway.”

Can you help us: why did you consider it was preferable to push on with acceptance in circumstances where the criteria had not yet been met?

James McNiven: Conditional acceptance because we did recognise, I did recognise there were issues. I can only reflect on what was being said at the time, that resolution programmes were in place, that the people who understood those felt that the resolution would be effective. People like John Meagher – I knew John Meagher, I had many conversations with John Meagher, and I had faith in his judgement and he was on the technical side. And other people who have been here before were saying that, yes, there are still problems but these problems are reducing and the resolution is effective and we expect that it will be sufficient to go to acceptance with conditions, and the conditions, I think we spoke about before, about some demonstration of that effectiveness continuing beyond the conditional agreement for rollout.

So I just tried to take it in the round. I listened to what is being said, I look at the area that I had most responsibility for, which was the physical infrastructure and rollout and training and, from that perspective, I was reasonably confident. I was very confident about the physical implementation side and I was accepting the judgement of colleagues that it was capable of being fixed. And I suppose, ultimately, I would say that, in all my dealings with ICL, how frustrating they may have been, the battles that may have been involved, this was a world-class IT company and I fundamentally did not think that they would allow over the line a system in which they had no confidence.

Mr Beer: Was the system in front of you at the beginning of September working as a world-class system?

James McNiven: No, fair comment. It was not and that’s why the acceptance process still had significant issues attached to it and those issues would continue until they were resolved.

Mr Beer: This is only four weeks after your letter of 10 August to John Dicks –

James McNiven: Yes.

Mr Beer: – which, in the letter and in the annex to it, set out a full range of issues known to both POCL and to Pathway. What had changed in that four weeks to make you, by this time, in September, reluctantly agreeable for conditional acceptable to proceed?

James McNiven: The letter to John Dicks was specifically about training. I was content that there were procedures in place. There was a new document from ICL Pathway that outlined changes to the whole training process, including an awareness event which had not been there before. We had essentially agreed that there would be post implementation support and, ultimately, that was paid for by ICL Pathway.

So from a training perspective, I was confident it could be done. What more can I say? I accepted advice from the people closer to the technical end that things would be resolved.

Mr Beer: Can we look to the foot of this page, please, under the heading “Where To Go From Here?”

At point 4, Mr Miller says:

“Bruce is preparing the bullet point brief for John Roberts and I will incorporate Acceptance into it.”

So I think John Roberts, at that time he would have been chief executive of Post Office Counters –

James McNiven: Yes.

Mr Beer: – and a member of the board, obviously?

James McNiven: Yes.

Mr Beer: At this point in time, you were obviously a key member of the Horizon Implementation Team. You have moved on from the PDA?

James McNiven: Yes.

Mr Beer: You were the senior member of the Horizon management team.

James McNiven: Of the Horizon field implementation team, yes.

Mr Beer: Thank you. You worked under Mr Miller?

James McNiven: Yes.

Mr Beer: You had a good working relationship with him presumably?

James McNiven: I did.

Mr Beer: He trusted you?

James McNiven: I hope.

Mr Beer: Presumably that’s why he, when he deputed somebody to draw up a bullet point memo for the chief executive officer, he chose you to draft it; is that right?

James McNiven: I would think so.

Mr Beer: At this time, did you understand that this wasn’t simply a transition from a paper books ledger system to a digital accounting system; there was a much broader process of change that the implementation of Horizon brought with it?

James McNiven: It was becoming apparent, yes.

Mr Beer: Was it your view and those around you that the Post Office would, going forwards, not wish subpostmasters to have the facility to challenge the data produced by Horizon?

James McNiven: I really can’t comment on that. I don’t know – I did not know and I do not know, with hindsight, whether they had that opportunity or not.

Mr Beer: Were you not party to any discussions or did you not become aware of the absence of a facility allowing subpostmasters to challenge the data produced?

James McNiven: To my recollection, I can’t remember being aware of that at that time. I have seen subsequent documentation that refers to it.

Mr Beer: Did you understand that this was – had a dual purpose: it was intended to limit or remove the SPM right to challenge but also to reduce the costs and resources expended on the issue at Chesterfield?

James McNiven: I’m totally unaware of that issue.

Mr Beer: Was there any sense in the discussions that you were a party to that automation had the benefit of exercising greater control, central control, over the accounting process by the Post Office, both by the IT and by reason of the contractual terms of subpostmasters?

James McNiven: I think I would have been aware of a movement towards conformance, that things would be done in a coherent and repeatable way by subpostmasters across the whole Post Office estate, which would be to benefit of the Post Office, if that was done and done well.

Mr Beer: Were you aware that the obligation was placed upon subpostmasters to cover any accounting shortfalls with their own money?

James McNiven: As I recall, going back to my previous line management, local management responsibilities, there had always been a provision to that extent and there were mechanisms in place to try and work out, say, how much of a deficit might be accountable to the subpostmasters’ actions. It could be that a subpostmaster just gave someone a double benefit and that then came back to evidence for us and we would then say, “Well, you know, ultimately, that was your doing and therefore you must make that good”.

So there was always a provision of sorts about subpostmasters rectifying financial shortfalls of which they were a part.

Mr Beer: What about a change to irrespective of cause?

James McNiven: I’m not aware and I was not party to any conversations of that type.

I find it now, being faced with that, hard to understand that that would have been an outcome. I would have thought there would always be a management intervention in that decision.

Mr Beer: When the system was being rolled out, does it follow that you weren’t aware that the contractual terms for SPMs required them to make good shortfalls, irrespective of cause?

James McNiven: I’m absolutely not aware of that. My previous experience was a requirement to make shortfalls but there was a decision-making process within it.

Mr Beer: The briefing that you prepared for Mr Roberts, did that just relate to training or did it extend to other things?

James McNiven: I mean, I’ve read that and I’ve seen that I was preparing a bullet point brief. I can’t recall the outcome of that.

Mr Beer: No, we haven’t got it. Can we look at an email that was sent at about the same time as this paper that we’ve been looking at that also concerns a briefing of Mr Roberts. That’s POL00043705. Look at the second page, please. Just wait a moment whilst I catch up.

Sorry, if we go back to the first page, I called it an email. It’s an electronic memo.

Can you see that? Then go to the page afterwards, please. You’ll see this is dated 10 September 1999 and so a couple of days after the document we’ve just been looking at and it’s from Stuart Sweetman – sorry, it’s to Stuart Sweetman from Mr Miller and we can see that you’re copied in on the top right.

James McNiven: Yes.

Mr Beer: It’s an update about acceptance at 10.30 am on Friday, 10 September. In paragraph 1 there’s a full update on Horizon generally being sent, enabling Mr Stuart (sic) to brief Mr Roberts on Monday, and then if we go to the numbered paragraphs under 1:

“Very considerable progress has been made in the joint workshops with ICL Pathway but as of today there were still 2 high incidents (Data integrity across the TIP interface and system stability around screen freezes) which would, in the Post Office view, make it difficult to accept on 24 September.”

Then paragraph 4:

“… if we were to stick rigorously to our agreed process I would not be allowing further rollout.”

So were you a party to the creation of this document or were just a recipient of it?

James McNiven: I think I was only a recipient.

Mr Beer: But overall the document is highlighting that the outstanding incidents aren’t related to training. They include data – or they are data integrity across the TIP interface and system stability.

James McNiven: Yes.

Mr Beer: So this memorandum, I think you’ll agree, makes it clear that these two important issues were being raised with the senior management team closest to the board clearly and in writing?

James McNiven: Yes.

Mr Beer: They were being advised that the decision to go forward with conditional acceptance in September 1999 was a departure from the agreed processes for acceptance.

James McNiven: Strictly speaking, that would be correct.

Mr Beer: Why was that recommended?

James McNiven: I don’t know if this goes on to talk about any more activity on those exceptions but I think that those exceptions still had rectification activities around them.

Mr Beer: It says that in 2, “The two incidents have rectification plans”, but I don’t think there’s anything else about those in the memorandum.

James McNiven: No, I’m only surmising here that it’s taking a view from the previous document about why some people, myself included, felt that, perhaps, we should continue to move forward. There were pressures. I think everyone felt some pressure about continuing to move forward –

Mr Beer: I’m so sorry, where was that pressure coming from?

James McNiven: Three sources, I think. One was the impetus behind rollout. Now, that was something I was immediately involved with. So by the stage the whole process, which went back six or eight months of offices being visited, offices being surveyed, offices being modified, offices being made ready for implementation, there would be, by this stage, some thousands of offices probably ready to go to implementation and a build up of expectation, not least amongst the subpostmasters, that this was going to go ahead and they were going to be part of it.

From a personal perspective, I think it was a pressure I’ve always believed that we should get this done, otherwise, as I said at the outset, we would never catch up again. I think I was aware of and probably responded to external-to-my-own-team pressures about commercial activities, political influences, the Treasury review had given the go ahead and money was committed.

Mr Beer: At a day-to-day level, how did that pressure manifest itself?

James McNiven: I think it manifested itself in terms of our relationship to Pathway. It would be fair to say that we were under pressure from Pathway to move forward. I mean, it talks about workshops. I remember being involved in a number of meetings with ICL Pathway at senior level where they were trying to downgrade incidents to a level which the contract would allow to go ahead. We, myself and colleagues, were in essence trying to say “No, we’re not going to do that, we won’t allow it until we have more proof”.

That level of impasse that translated into a series of workshops between the people most closely involved, working level workshops. They tried to disassemble all the reasons behind these problems not being resolved but they were then being translated into plans to resolve them rather than decisions about not going forward at all. So the impetus was on resolution as opposed to stopping and that’s a pressure in itself, I think.

Mr Beer: Can we turn, please, to move forward in the chronology a little, to POL00090428. We can see, as the edge of the spine tells us, that we’re about to look at the annex to the second supplemental agreement dated 24 September 1999 and we’ll see that this document, which is very long indeed – 218 pages in total – includes very significant detail on the proposed rectification plans. I want to look at AI218 and training in particular.

Can we go to page 65 internally, please. As this is part of the resolution plan for AI218 and, under the third bullet point, it records that:

“The joint workshop on 13 August [that’s 13 August 1999] accepted that not all users within the large population will ‘absorb’ Horizon. This may eventually call for closure of the outlet, replacement of the subpostmaster or training of additional staff. It has been agreed between POCL and ICL Pathway that other steps taken within this resolution plan should minimise the risk of this and that any residual fallout will be handled by POCL. POCL have agreed to review and strengthen the relevant process. This is reflected in the timetable.”

Then if we just go back to the previous page, please, and look at the foot of it, the paragraph right at the bottom:

“Further to the activities above, a workshop took place on 13 August which identified seven specific areas for potential improvement … Commercial consequences of the actions below are agreed in an exchange of letters between [you] and Liam Foley of ICL Pathway …

“These are as follows.”

Then they are set out, including the one that we looked at.

James McNiven: Yes.

Mr Beer: So what is recorded in that third bullet point seems to be the product of an agreement reached between you and Mr Foley in correspondence. Did POCL accept before acceptance that there would be some subpostmasters who would never absorb, in inverted commas, Horizon?

James McNiven: I think we accepted it was possible. I mean, a number of subpostmasters resigned of their own volition, as they became aware of the implications of taking on an automated process in their office. So there was a fallout from that as well. So it was not surprising if there would be a fallout from the training process.

The training process was structured such that there was a competency test – it wasn’t called a competency test from the subpostmasters’ or assistants’ point of view, it was a certificate of competence – but there were some who just would fail the test at the end of training because they were presented with some scenarios to which they had to give answers and, even with some help, there were some that failed.

We managed to then arrange for them to be retrained along the lines of the same module and to be retested. The agreement with ICL was that if people, subpostmasters or assistants, failed a third time then they would return to POCL as our responsibility rather than a Pathway training issue and I suspect from that there were discussions – if it was a suboffice assistant, there was the opportunity for the subpostmaster to train them, to take them under their wing and try to help them a bit more.

If it was a subpostmaster, there was help given in terms of balancing. But there was fallout. There would have been and there was some fallout along the way from people who thought this is – “I’m not going to do this, this is just not for me”, in which case an outlet may have to be closed.

Mr Beer: So the fall out would be closure of the Post Office or replacement of the subpostmaster within the Post Office and did you understand that the means by which subpostmasters, who could not or would not absorb Horizon, would be through their contractual liability for errors?

James McNiven: No, I did not associate the training and the withdrawal with contractual liability for errors.

Mr Beer: How did you think that the non-absorbers would be, as part of a residual rump, removed?

James McNiven: It was often by mutual agreement that the subpostmaster and the local manager said “This is not working”, or the subpostmaster said, “I’m not going to continue with this”. So it was a kind of a voluntary resignation.

Mr Beer: What if it wasn’t voluntary? What was the means by which subpostmasters, who couldn’t absorb Horizon, would be removed?

James McNiven: I’m not aware of any force majeure closures of offices because a subpostmaster had not passed through that phase successfully.

Mr Beer: So how were they going to be removed then? How did POCL intend to remove subpostmasters?

James McNiven: As I say, I think it was a mutual agreement, it was a conversation. But I don’t think we’re talking about a great number in the population here, by that stage, because I think the local management would have – the local management would have a responsibility to the customers of a post office as well as the integrity of the Post Office finances that if – and this is always the case – that if they felt the individual subpostmaster was not performing to the requirements, there would have to be a conversation about what happened next.

Mr Beer: Was any link drawn between the ability of subpostmasters to absorb Horizon with the adequacy or inadequacy of the training with which they were being provided, which I think was a day and a half, wasn’t it?

James McNiven: Yes, I think that goes back to all the support that was then put in place. I mean, I don’t know the numbers and I suspect it would be quite small if we got to that point and I think along the way –

Mr Beer: 20 per cent that failed the – in inverted commas – “competency” test initially; is that right?

James McNiven: Initially, that may be right. You may well be correct. But that’s of all people, assistants and subpostmasters, of course.

But I think I would expect that local managers the whole system, would go as far as they possibly could to help a subpostmaster. It was his business to help him run his business properly, even if that meant line resource, local managers going out there on successive visits to try and help them.

Mr Beer: So the role of the local manager continued to be absolutely central; is that right?

James McNiven: Yes, absolutely, and the field force that was sent out were converted from the normal jobs of managing numbers of outlets to specifically supporting the whole of that balancing/reconciliation help process. So some 350/400 people were put in for that purpose.

Mr Beer: In your time, were you ever aware of the removal of the local manager from the decision-making process in relation to investigation, audit and prosecution?

James McNiven: Can you just say that again so I understand it?

Mr Beer: Yes. In your time, were you ever aware of the removal of the local manager from the decision-making process in relation to audit, investigation and prosecution?

James McNiven: No, I wasn’t.

Mr Beer: Can we turn to the issue of balancing as a part of the training process and acceptance. Can we look, please, at NFSP00000120. It might have been easier if I said NFSP00000120, thank you, and look at page 2, please.

This is a letter addressed to Colin Baker and, if you just scroll down, please, and go over the page and scroll down, from Paul Rich?

James McNiven: Right.

Mr Beer: You are a copy at the foot of the page.

James McNiven: Yes.

Mr Beer: You’ll see, if we go back to the first page, please, that the – sorry, the first page of the letter, the second letter of this clip of correspondence, thank you – that the letter’s dated 4 September 1996. You’ll see in the third paragraph that you are referred to “Bruce McNiven, from the Programme Delivery Authority”. Is that right, in September 1996 you were performing the role of the Deputy Director of the PDA?

James McNiven: That’s correct.

Mr Beer: Then you’ll see in that third numbered paragraph it says that you will be in touch with Mr Baker of the NFSP:

“… separately to notify you of a structural framework we intend for subpostmasters to be involved in both user acceptance testing, and in generating possible solutions to operational problems that might arise. You and Bruce will discuss the NFSP’s part in that to help smooth implementation.”

So the part of the sentence that says “involved in both user acceptance testing”, just explain to the Chair what “user acceptance testing” means?

James McNiven: I should imagine that would encompass two aspects of the process: (1) model office testing where subpostmasters and some directly managed counter staff would be brought into the model office environment and run through the scripts and the process using the equipment as it then was to test how it was operating. And the other one would be the live trial itself, which was, I suppose, a key point within the process where subpostmasters would be introduced to the system.

Mr Beer: So this is an early recognition –

James McNiven: Yes.

Mr Beer: – of the importance of end user, ie SPM, involvement in the process?

James McNiven: Indeed, yes.

Mr Beer: What, if any, steps did you take in 1999 to involve subpostmasters in the acceptance process?

James McNiven: There was no formal process for their involvement. Their experiences in the live trial would inform a view that we were taking about adequacy of various aspects but there was no formal involvement in acceptance.

Mr Beer: Was there any involvement of SPMs or their representatives in the negotiations over acceptance in the autumn to winter period of 1999?

James McNiven: Not to my knowledge, no. I’m pretty sure the answer to that is no.

Mr Beer: Given the early recognition of the importance of the experience of end users, why is the answer no?

James McNiven: End users had been involved in those processes I talked about. We also – I remember vividly we had open sessions with the people involved in live trial to get their feedback in an open meeting. There were two in Bristol with the south-west, which I attended. There were two in the north-east, one of which I attended and Dave Miller attended the second, and I think it’s fair to say we had a hard time – I did – because a number of the subpostmasters at that stage, at that stage of development of the live trial, were unhappy about their experience and they told us and, you know, we accepted it. I should say that there was –

Mr Beer: What were they unhappy about, I’m sorry?

James McNiven: Mostly about the balancing and about the length of time. It was the length of time more than anything else, that it seemed it was taking into them – balancing was usually about a two-and-a-half-hour process, even in manual times, and that was the expectation in automated times.

I think, ultimately, that was achieved for many people but during live trial – I mean, with hindsight, in live trial we exposed a lot of those people to enormous amount of difficulty. To some extent, that might have been expected because it was a live trial. We wanted to know what was happening, we wanted to know their experiences but some of them were unhappy about that experience and they told us.

Mr Beer: So they were struggling, in the language we’ve looked at, to “absorb”; would that be correct?

James McNiven: To absorb and I think it was mostly about the balancing. Their big issue was about balancing, the difficulty of achieving it and the length of time it was taking.

Mr Beer: Can we, in that connection, look, please, to NFSP00000271. Moving on a little bit but still in your role as PDA, this is a letter from you, if you just look at the second page and scroll down. Thank you.

That’s interesting. This is dated 22 September 1998 and you are referred to as the general manager of Horizon implementation. Is that right, you had transitioned to that role by then?

James McNiven: I had transitioned, yes.

Mr Beer: Going back to the first page then 22 September 1998 to Mr Baker, again, of the NFSP, and if we look at the third paragraph, please, you say to him:

“I know you would like a workshop to review in detail the Horizon summarisation and balancing and how this be approached in training. I hope to provide this soon but we are still in the early stages of detail on this part of training and it would be mid to late October before I would be able to set up suitable arrangements.”

Is this in response to or does it appear to be in response to the NFSP flagging the importance of there being training on balancing as early as the autumn of 1998?

James McNiven: Yes, I think so. There may have been – 1998. There may have been some exposure in model office testing by that stage and some subpostmasters may have been involved.

Mr Beer: And balancing or the difficulties with balancing had been pointed up as a problem then?

James McNiven: I would think so.

Mr Beer: Did the workshop there discussed take place?

James McNiven: I honestly don’t know. I cannot recall it – I cannot, sorry, recall it taking place specifically for Federation representatives.

Mr Beer: Can we look, please, at NFSP00000340 and look, please, at the second page. This is essentially a report on Horizon training as relayed by Pam Jervis on 30 April 1999, you can see from the heading at the top, and she reported:

“The first day of training is OK, but the second … is bad because it is rushed. They are not finishing on time, but are rushing to finish before 3.30 … because otherwise they have to buy lunch. Why did they use the most expensive hotels?”

Skipping a paragraph:

“In every training session, nobody had done a main balance, snapshot balances only. Nobody had been trained to do a full balance.

“The trainers are people who have only received the same training that they are giving out. It’s too narrow a [‘field’, I think that is] and no-one can answer questions such as ‘do we use the same form?’

“There were a lot computer problems which were blamed on the fact that computers had to be ferried in and out of vans a lot.”

Do you recall receiving feedback like this?

James McNiven: Yes, I do. This is – 30 April is the early part of bringing offices up to spec for live trial and I suspect that these were offices that were going from Initial Go Live functionality up to the full release functionality. It was a very early run of training, full training for that purpose, and I recognise this. I recognise these problems at that time.

Mr Beer: I skipped over it. This was a fax from Colin Baker, the general secretary, to you, I think.

James McNiven: Yes.

Mr Beer: What did you do with this information?

James McNiven: Well, I mean, this is April. All of this was going into the perspective that we had about training being a high level incident, you know, a pass/fail incident. It was not put right; it was part of acceptance. So it was information that supported the perspective that we were taking.

Mr Beer: In what way?

James McNiven: In the way that we had already expressed to ICL Pathway, that we were not happy with the training product and it had to be modified and improved. Those debates were going on on a very regular basis with Pathway at that time and from that time up to the revised training package that they produced.

Mr Beer: Just look over the page, please, and look at the foot of the page, please. Four paragraphs from the bottom:

“Everyone stressed that all subpostmasters must be told to complete a manual balance if there are problems, or even do a double check. They are told that the balance goes down the line to Horizon, but once that happens, if there is a query, then subpostmasters have no proof of any work that’s been done.”

Do you understand what that’s referring to?

James McNiven: I think you asked earlier about the opportunity for subpostmasters to interrogate the balance once it had been completed and whether or not they could influence that, and I’m sure, I understand, that they did not have that facility. So, at this stage, they were being advised to perhaps do a manual backup.

Mr Beer: What does the manual backup involve?

James McNiven: A manual cash account, as they did before they actually transitioned on to the automated system.

Mr Beer: How would they do a manual cash account?

James McNiven: They would still have a cash account process, a piece of paper that was their cash account that they used to fill in manually and, if it was as difficult as this, they would be probably transposing the work they were doing into that balance manually at the same time as putting it into the system.

So they were replicating what they did before.

Mr Beer: Was that running of a dual or shadow –

James McNiven: That’s correct, yes.

Mr Beer: – system limited to this stage of the process?

James McNiven: I mean, this is quoting someone as saying that that’s what they should do.

Mr Beer: Yes.

James McNiven: That was not official advice. That was people at the training session being told you should do this because it’s difficult to recover things otherwise. I don’t think we ever advised subpostmasters to do a double entry-type system.

Mr Beer: Did you hear about it being done nonetheless?

James McNiven: Only in terms of this.

Mr Beer: Not more widely?

James McNiven: No.

Mr Beer: So there wasn’t a period, for example, during live testing when people were asked to do to what you referred as double-entry bookkeeping?

James McNiven: Absolutely not, no.

Mr Beer: So here, that “Everyone stressed that all subpostmasters must be told to complete a manual balance”, what do you understand – and I appreciate this is a document that was sent to you, and not written by you – what do you understand the “everyone” to refer to?

James McNiven: Everyone … I think they mean … I think the people, from the experience of that training episode, were saying, “From our experience, subpostmasters should be told to complete a manual balance”.

Mr Beer: So we should read this as meaning that –

James McNiven: Subpostmaster to subpostmaster, I think.

Mr Beer: Not trainer to subpostmaster?

James McNiven: No. No.

Mr Beer: And subpostmaster to subpostmaster are saying that it should be trained that subpostmasters should be told to complete this second or shadow account?

James McNiven: I don’t think it came through formally. I think it’s subpostmasters saying to the Federation to say to subpostmasters, “Look, there may be problems and we suggest that you might wish to do a manual balance at the same time as you are doing the Horizon balance, from the experience we have at that point in time”.

I don’t believe it was ever formally adopted or transmitted.

Mr Beer: Was it ever picked up by management as a sensible precaution, given the consistent and repeated problems with weekly balancing?

James McNiven: I don’t believe so.

Mr Beer: To your knowledge –

James McNiven: To my knowledge.

Mr Beer: – was this picked up: whilst we are getting these repeated complaints of an inability to balance, subpostmasters (certainly in the live trials) should be advised to run a mirror on paper of the accounting system?

James McNiven: I was never aware of or party to advice from that nature from a formal perspective.

Mr Beer: Those are the only questions that I ask at the moment. There may be some questions from others. I think Mr Moloney was first on the list.

Sir Wyn Williams: He’s nodding. Over to you, Mr Moloney.

Questioned by Mr Moloney

Mr Moloney: Mr McNiven, I just want to ask you about one topic which is the essential nature of data integrity to the system and the extent to which that was part of the audit process. You’ve mentioned that. You said that you were aware that data integrity was essential to the system, but you weren’t specifically focused on the requirement being part of the audit process.

Is that right?

James McNiven: I think I was saying I wasn’t specifically aware of audit auditors being engaged in the work that we were doing in terms of data integrity.

Mr Moloney: I see. Could I take you to POL00029130. It’s a document you’ve already been taken to. Could I go to the letter at page 7 of the PDF. You have already been taken to this letter.

This is a letter from you, Mr McNiven, dated 10 August 1999 to Mr Dicks at ICL Pathway.

James McNiven: Yes.

Mr Moloney: We can see that you introduce the letter by speaking of an analysis of the evaluation against the business impacts identified in the Acceptance Incidents, and that’s Acceptance Incident 218 that’s attached. In the letter, you raise a number of issues around this acceptance issue 218.

If we could go to the document which is on the next page, page 8, this is essentially what you have described in the letter. Now, before the letter was sent and before the attached document was sent, they deal with a number of issues. Would there have been discussions between POCL and ICL Pathway about these issues, essentially talking them through, and then this is a distillation of what’s gone on in terms of your work on the process?

James McNiven: Yes. I mean, there were continuous conversations on all these issues, training and all the rest, both through myself to people like Liam Foley, et cetera, in ICL Pathway but also through what shots being held people closer to the issues, I would say, on both sides to try and come up with a resolution, to try and produce a solution that meant that the training content was better than we started off with.

It was ongoing, it was continuous, it was sometimes difficult and there were often arguments.

Mr Moloney: This document is essentially a summary of where we are and where we’d like to get to.

James McNiven: Yes.

Mr Moloney: But there were many discussions behind it.

James McNiven: There were many, many discussions behind it. I think, if I just may say, the outcome of that exchange of letters between myself and Mr Dicks was probably such that we, POCL, understood that the deployment of a large part of our field infrastructure was going to be deployed to support subpostmasters during the rollout period.

Mr Moloney: Right.

James McNiven: And that we would give them all that support. There’s a positioning behind this that says, “And we’re not going to pay for it”. There’s a commercial aspect to this and that will come out later on.

Mr Moloney: Sure. Were you involved in the drafting of this document? And I’m not talking about the letter, I mean –

James McNiven: The evaluation?

Mr Moloney: – the attached document?

James McNiven: I don’t think I actually wrote any part of that. It would pass through me.

Mr Moloney: You’d have to approve it?

James McNiven: I’d have to approve it.

Mr Moloney: Was it approved above you in line management before it was sent?

James McNiven: I don’t think so. I think Dave Miller would be well aware of the position that had been talked at the Horizon management meetings and I think he would be – I would have given him an indication of what was going to happen and what I was going to say.

Mr Moloney: Yes, okay. So just to – I only want to look at one aspect of this document but if we just look at the various columns, we can see “business impact” in the first column, “summary of success criteria measure” in the second, and “evaluation” in the third. Could we please go down to I think it’s the next page but it’s number 5. We’ve got 1, 2, 3, 4, 5 down this side. So it’s the next page again. That’s it.

I’ll read through it, if I can, to begin with and then come back to ask you questions about it. At number 5, under “business impact”:

“There is also an impact on TP who are having to process a significant increase in errors on Class and Pivot (up to 3 times as many weekly errors). This is having a significant impact on resources in TP during the live trial. These errors will also raise liability issues between the POCL and subpostmasters, and POCL and client organisations.”

Then we see under summary of success criteria measures, some definition, as it were, of the problems that TP are having to deal with. We return, I think, really here to the receipts and payments mismatches that were apparent throughout the process.

James McNiven: Yes.

Mr Moloney: So we see “reduction”. This is the summary of success criteria measure:

“Reduction in both the number of incidents where receipts do not equal payments and incidents where balance brought forward does not equal balance due to Post Office on previous cash account.”

And then:

“Reduction in the number of errors reported by TP – both class and pivot errors relative to the sample.”

Then evaluation:

“Overall, the incidents of receipts not equal to payments have reduced and the residual causes are under investigation or have been resolved. Criteria met. The level of class errors between 26 May and 21 July has reduced. Without full information, the indications are that pivot errors have also reduced.”

Now, it’s back to the first column that I’d like to take you, if I may, please, Mr McNiven, where it reads at the end of that section:

“These errors will also raise liability issues between the POCL and subpostmasters, and POCL and client organisations”, yes?

James McNiven: (The witness nodded)

Mr Moloney: Is it fair to say that there was an awareness that errors would produce liability issues?

James McNiven: Yes.

Mr Moloney: Yes?

James McNiven: Yes.

Mr Moloney: Was it obvious, really, that if there was a receipt and payments mismatch, then if there was less money than was expected, then it’s potentially going to give rise to liability issues?

James McNiven: Yes. There were always errors. There were always error notices, as they were called, coming from transaction processing, the Chesterfield accounting people, going back to subpostmasters. Previously in the old accounting system, because things came to light after the event, and subpostmasters often had to correct things and understand why it had happened.

What this is saying is there’s more of them – there is more of them than there were previously and that’s an issue, which is absolutely correct.

Mr Moloney: And there were issues of financial liability; that’s what you’re referring to?

James McNiven: Ultimately, there was a conversation we had about financial liability in subpostmasters for losses. It was always a liability.

Mr Moloney: Yes.

James McNiven: Obviously, if there were more issues there would be more questions of liability.

Mr Moloney: Well, precisely. So there could be a question of – debt recovery would be one thing but also, from the experience you had of prosecution decisions that you’ve told the Inquiry about today, you must have been aware of the potential for prosecution.

James McNiven: I was always aware of the potential for prosecution in the event of mis-balances. Everything that was being done was to try and ensure that mis-balances were not a function of the system and that’s what the work was intended to do.

Mr Moloney: Now, this document went to ICL Pathway.

James McNiven: Yes.

Mr Moloney: This document is a distillation of the discussions, the many discussions, that you’d had with ICL Pathway around the acceptance issues. So, so far as you were concerned, ICL Pathway was aware of the liability issues that might arise from the payments and receipts mismatch.

James McNiven: I would expect that to be the case.

Sir Wyn Williams: Mr Beer, are you aware of any other would-be questioners?

Mr Beer: Other people have put in requests –

Sir Wyn Williams: Mr Stein sent me a secret code by saying no –

Mr Beer: Shaking of the head.

Mr Stein: I don’t think Mr Beer can see that because of the wall.

Mr Henry: Sir, I had questions but they’ve all been covered by counsel to the Inquiry. Nothing further.

Sir Wyn Williams: Thank you very much for coming to give evidence to the Inquiry, Mr McNiven.

So I think this afternoon’s witness is remote; is that correct, Mr Blake? Have we got a likely time for start?

Mr Blake: 2.00 pm.

Sir Wyn Williams: So we have an extended lunch break, all right.

(12.37 pm)

(Luncheon Adjournment)

(2.00 pm)

Mr Blake: Good afternoon, sir.

Sir Wyn Williams: Good afternoon.

Mr Blake: Can I call Mr Fletcher, please.

Sir Wyn Williams: Yes.

Kevin Fletcher


Examined by Mr Blake

Mr Blake: Thank you very much. Can you give your full name, please?

Kevin Fletcher: Kevin Joseph Fletcher.

Mr Blake: Thank you for attending remotely today, Mr Fletcher. Do you have in front of you a witness statement?

Kevin Fletcher: Yes, I do.

Mr Blake: Can I ask you to look at that witness statement. Is it dated 16 November 2022?

Kevin Fletcher: Yes.

Mr Blake: Can I ask you to look at the final page. That’s page 17 of 17.

Kevin Fletcher: Yes.

Mr Blake: Is that your signature?

Kevin Fletcher: Yes, it is.

Mr Blake: Can you confirm that the statement is true to the best of your knowledge and belief?

Kevin Fletcher: I can.

Mr Blake: Thank you very much. That statement is now in evidence and will be uploaded onto the Inquiry’s website. WITN06000100. The questions I’m going to ask you today will be supplementary to the evidence that’s in that statement.

I’m going to begin by asking a little bit about your background. You were employed by Her Majesty’s Forces for just over 20 years, between 1972 and 1994; is that right?

Kevin Fletcher: That’s correct, yes.

Mr Blake: Did your role in the Armed Forces include training to some extent?

Kevin Fletcher: Yes, it was quite early on. Like you trained on courses as you’re going through and then, actually, then start to train the courses. I had quite an interest in training so at a fairly early age I got involved in training other soldiers in different things, which culminated in a tour with our junior leaders regiment. I’d come out and did I two and a half years training junior soldiers on all aspects of military and tactical weapons courses, basically.

Mr Blake: Thank you. In 1994 after leaving the Armed Forces you joined Peritas?

Kevin Fletcher: Yes.

Mr Blake: Was it Peritas or KnowledgePool at that stage?

Kevin Fletcher: It was Peritas at that stage and they advertised – as I was finishing in the Forces, they advertised for people who trained on IT systems. I had done quite a lot of IT systems for the juniors and other roles that I had within the Forces. They didn’t say what the job was. They just said that it was a new system to be launched and people could come along for an interview and if successful then attend a course that would then, if you were successful in that, be offered the job.

On arriving there, I found out it was the implementation of the National Lottery system. I was fortunate enough to get the job after the training and very shortly after that they asked if I would then train other trainers.

Mr Blake: So your first role was working on the National Lottery for Peritas?

Kevin Fletcher: Yes, it was.

Mr Blake: Can you tell us the link between Peritas and KnowledgePool and ICL? Were Peritas and KnowledgePool the same thing but different names?

Kevin Fletcher: I mean, KnowledgePool was an autonomous company within the group and it just changed the name, really, from Peritas to KnowledgePool but, as far as I’m aware, the position of the company stayed the same as that autonomous company within the group, which meant they could actually bid for other business outside ICL but were also usually the first choice of training for ICL projects, particularly IT rollout projects.

Mr Blake: It was a subsidiary or linked to ICL, was it?

Kevin Fletcher: It was linked to ICL, yes, but, as I say, it was what they called an autonomous company within the group, as far as I know.

Mr Blake: In September 1998 you were given your first full-time contract. I think you began your initial role not on contract – is that correct – or not as a full-time employee at least?

Kevin Fletcher: The original role was as a contractor and it was some time after that that we were in Liverpool and Stuart Kearns, who was the director at the time, called me and then offered me a full-time role within the company.

Mr Blake: Can you describe very briefly the positions that you held between 1998 and 2002?

Kevin Fletcher: Very briefly, I was a contract trainer to begin with and then I went into to be a trainer on the Lottery system. It wasn’t very long that I had been trainer that they then promoted to a regional manager of training and then I was – after that, I’d finished, the company then wound right down then to just a few people and, all of a sudden, they won the Post Office project and, of course, it started to gear up again. That’s why I was offered full-time work.

From then, I was a training manager and then went to – on a region, I trained the other trainers and to end up, I ended up as director of what was then KnowledgePool.

Mr Blake: Then in 2002, you left and you moved to Manchester City Council, retiring in 2012; is that right?

Kevin Fletcher: Yes, that’s true.

Mr Blake: Thank you. I’m going to ask you about the training that was provided. We will come on in due course and look at various documents that describe them in detail but, by way of an introduction, can you briefly explain what the user awareness event was and what user training was and how they differed from each other?

Kevin Fletcher: Well, the user awareness events, as far as I recall, were to actually give an idea to a larger number of postmasters when their region – what was likely to happen in their regional and when they were likely to come online and what coming online entailed. The user training was actually a number of courses that were given to both counter staff and also to subpostmasters and managers to actually operate the system within their own premises.

Mr Blake: Who was it that would provide that training?

Kevin Fletcher: It would be KnowledgePool who provided the training. Can I just add, though, to that bit that, subsequent until the training, there was also a number of other elements of the training, such as an assistance within that training. So it wasn’t just the courses, it was the documentation and the Helpdesk. There was a number of other parts of the training or the support for the training.

Mr Blake: So you had a lecture-based user awareness course, you had a classroom-based training, and then you had various documents also, such workbooks, to assist with the training. Is that a fair summary?

Kevin Fletcher: That’s correct. Included in that was also – was a training mode within the actual system itself, so in other words they could switch from a live system into a training mode.

Mr Blake: So there was a button on the Horizon system that you could press that would assist you with training?

Kevin Fletcher: Yes.

Mr Blake: Thank you. I want to turn to your statement. I’m just going to take you through a few passages within your statement. Could I ask for it to be brought up on screen. It’s WITN06000100.

Can we look at paragraph 10, which is on page 6. If we could scroll down that page to the second half of the page. This is a section where you talk about classroom training and you say the classroom training – it’s at (f):

“I have no knowledge of why the training medium of classroom based training was chosen for the user training course as I was not involved in that decision process. I do however consider this to be the most appropriate training medium in this case because when it was presented to POCL [that’s Post Office Counters Limited] they signed it off as fit for purpose.”

I’m going to take you through a few similar paragraphs in the statement. Can we look at paragraph 16 on page 8, please. It’s the final line in paragraph 16. This relates to issues identified during the pilot or post pilot events and you say:

“I do believe that any issues identified during or post pilot events would have been rectified in the programme which was final signed off by POCL as fit for purpose.”

You’ll get an idea of why I’m asking this question shortly because the phrase “fit for purpose” is regularly used. Let’s look at paragraph 17 on page 9. This is about the feedback form. You refer to the feedback form and you say, it’s about halfway down that page:

“At the time I did consider it appropriate to have different columns on the feedback form as no questions were raised about the form by POCL and it was approved for use as was.”

Can we look at paragraph 29, page 11. This is about the user awareness event, and you say there:

“The training did not differ at all from the design training programme. Once the training programme was signed off by POCL as fit for purpose it was delivered as is.”

Can we look at page 50, in paragraph 42. This is in reference to the course appraisal forms and you say, halfway through that paragraph:

“At the time I did consider the course appraisal form to be appropriate and this was based on the POCL approval of the form and sign off by POCL as fit for purpose.”

I’m nearing the end of the statement. Let’s look at paragraph 50, page 17. It’s the top of that page. It says:

“The full programme was delivered approved and signed off by POCL and within the allotted timescale.”

Then finally I’m going to read the top of paragraph 52 on that same page, if we could scroll down, thank you. It says:

“In my view this is training programme fully enabled trainees to balance. If this had not been the case then POCL would not have approved and signed off the programme as fit for purpose.”

It’s fair to say that you rely quite heavily in your witness statement on the fact that the Post Office signed off various aspects of the training programme. Do you agree with that?

Kevin Fletcher: Yes, I do. They were very insistent – it could be after several reworks, so we may have submitted a solution or a process, which balanced the manual system against the electronic system and then that would go forward in various stages to POCL and they would then require reworks, and then those reworks would go back, and sometimes two or three times, before they actually were deemed fit for purpose.

Mr Blake: So the Post Office was heave involved in developing the training programme; is that right?

Kevin Fletcher: Absolutely.

Mr Blake: You say “fit for purpose”. I mean, they didn’t sign a piece of paper that said “This is fit for purpose”, is that your way of describing their agreeing to proceed?

Kevin Fletcher: Yes. I mean, once – if there were no more – if there were no more changes to it and they agreed that it was fit for purpose, in other words it fulfilled the task that it was meant to do for that specific part of the processes, whether it be EPOSS or balancing, et cetera.

Mr Blake: Was your measure of success whether or not the Post Office refused or agreed to proceed with something, rather than some sort of internal quality control?

Kevin Fletcher: We had our own internal quality control and sometimes there was – it was a case of we actually went to different post offices, some of us that were involved in the creation of the documentation, and actually watched people doing in a live environment the actual processes.

From those processes, of course, we linked that with what the Post Office was giving us about certain things that it had to do on the system, certain actions on the system. We then wrote up that as an action and then, as I say, it went to the Post Office for sign off and, as I say, it could come back two or three times before it actually – or several times – before it was actually approved.

But once it was approved then that was the process we needed to follow.

Mr Blake: Generally speaking, who was that contact within the Post Office who would sign things off?

Kevin Fletcher: The one I remember mostly was a lady called Sue Smith, and she was to do with the training for POCL. I think she was part of the procurement team but I’m not 100 per cent on that.

Mr Blake: Did you have any involvement with any senior management within the Post Office?

Kevin Fletcher: Again, they came to one or two of the demonstrations that we actually gave. We actually had one session, I do remember, in Stockport where some of the union representatives came to look at the system and several managers – I can’t remember all the managers – but it was widely demonstrated, sections of it were demonstrated to very senior members within POCL.

Mr Blake: You’ve said unions. Is that the National Federation of SubPostmasters? Is it the Communication Workers Union?

Kevin Fletcher: I’m pretty sure it was National Federation of SubPostmasters.

Mr Blake: Thank you. I want to look at the objective of the training programme. Can we look at FUJ00001276, please. This is a very early document. This is dated 1997. There is a later version that we have – I’m not going to bring it up but, just for the purpose of the transcript that’s FUJ00001322 – from July 1999 but it is the same, insofar as the section that I want to take you to, which is on page 5 of this document.

This sets out the “Objective of the Training Programme”. Perhaps we could highlight that 2.2 and blow that up slightly, if possible. Thank you.

I’ll read that to you. It says:

“ICL Pathway have contracted Peritas Limited to provide the training programme in support of the BA/POCL Counter Automation project. The training programme is required by ICL Pathway to meet the following objectives …”

The first:

“Compatibility – the programme must be managed and delivered in a manner consistent with the implementation programme undertaken by ICL Pathway Limited and their other subcontractors.

“Timeliness – No individual is to be trained more than five working days prior to the automation of their normal counter position.”


“… the required scope, which is – ‘To ensure that all staff who work within a post office are competent in the use of the automated platform, are aware of the impact on operational procedures caused by the introduction of the platform and that specialist staff are provided with the appropriate additional information to perform their job role within an automated post office’.”

Then it gives appropriate competence levels. It says:

“The delivered programme is required to ensure that 95 per cent of personnel have a minimum competence that they are capable of processing 90 per cent of all transactions undertaken by their base office correctly.”

Were those objectives that you were aware of?

Kevin Fletcher: Maybe not in exactly the same words but, certainly, that was an aim of the courseware and the training programme.

Mr Blake: We will look in more detail at the training but do you think that those objectives were achieved?

Kevin Fletcher: I believe they were achieved, although the amount of people that were trained, it’s very difficult to put an actual percentage of it. As I said in my own witness statement, there was a wide range of both age groups and IT competency in the Post Office itself and people who worked in the Post Office. I don’t know if it was ever measured to the fact that it was those 90 per cent of all transactions and 90 – 95 per cent of personnel of a minimum competence. They certainly undertook the course as is and, yes, but putting a percentage on it, I couldn’t do that.

Mr Blake: Can we look at FUJ00001280, please. This is a document that you wrote. It is the training and user awareness style guide. I’ll just wait a moment for that to be brought on to screen. I’m not going to take you to detail of this because I don’t think it takes us anywhere but, in terms of the document itself, if we scroll down, we can see that you’re the author of this document. This was – it’s a style guide that sets out, essentially, how training materials should appear. Is that a fair summary?

Kevin Fletcher: Yes, from what I remember of it. As I say, it’s 23 years ago, so remembering exactly what’s in it is difficult. But yes for the main part it was but what would appear and how it should appear. The style guide, again, was – it had to meet both KnowledgePool and POCL standards; in other words, fit in what we normally would produce.

Mr Blake: Can we just quickly scroll through that document just so we can get a flavour of what it contains. If we look at page 18 or 19, for example, it gives examples of workbooks and what they might look like, that kind of thing. Was this the kind of thing that you produced?

Kevin Fletcher: Yes, it was.

Mr Blake: What other documents of this kind do you recall producing?

Kevin Fletcher: Well, actually, this was a style guide for most of the things. You know, there was the actual workbook, there were the quick reference guides, et cetera, that were produced to support the training.

Mr Blake: Did you produce the workbooks themselves?

Kevin Fletcher: Most of them, yes.

Mr Blake: So we’ll come to look at them but some of them have, I think, your name as an example, I think, as an example username in workbook 9. We can look at that in due course, if we need to. But the substance of those workbooks then that were produced for the training, that was something that you produced?

Kevin Fletcher: Yes.

Mr Blake: I want to talk about the early training sessions, starting with what was called the first 14, and was February/March 1999. I’ll bring the document up but can you tell thus background to the first 14?

Kevin Fletcher: These were a number of, if you like, trial courses where it was to give the trainers and delegates, without overlooking – in other words, there wouldn’t a great lot of the senior management at each of – or there wasn’t supposed to be a great deal of senior management that first 14 courses, one, really to give the trainers a chance in not a live environment but an environment with the real postmasters and, another, to give the postmasters a real chance on the system without being overlooked by some of the very senior management and to try to get as honest feedback as we could on the actual course itself and how they felt about it and how the trainers managed over the period of the course.

Mr Blake: Can we bring up on screen POL00039733 and perhaps if we could scroll over to the next page. So this is a report, I think, that you wrote. If we look at the page after that it has you down as the author. Do you remember writing this report?

Kevin Fletcher: No, not outstanding to other reports that I wrote but I have a recollection of it but I wouldn’t be able to tell you exactly what was in it, no.

Mr Blake: Was it the first significant report that you wrote in respect of the effectiveness or otherwise, of the training for the Horizon system?

Kevin Fletcher: Yes, I would say so, particularly with the Post Office staff.

Mr Blake: It’s dated 28 March 1999.

Kevin Fletcher: Yes.

Mr Blake: Can we look at page 5, please, and I’ll read to you section 1 which gives the introduction. It says:

“ICL training services were requested by Pathway/POCL to provide trainers for a series of courses for Counter Assistants and Counter Managers on the Horizon System.”

So pausing there, there are separate training courses for counter assistants and for counter managers; is that correct?

Kevin Fletcher: That is correct.

Mr Blake: “The delegates on the courses were volunteers from POCL.”

They were volunteers. Were they subpostmasters, assistants or something else?

Kevin Fletcher: They were both, I believe. There was postmasters and assistants.

Mr Blake: Do you know how they were selected?

Kevin Fletcher: No. That would have been Post Office who would have gave us the names. We would have had nothing to do with the actual selection of the delegates attending.

Mr Blake: “The aims of these practice courses from an ICL Training Service perspective were as follows:

“1. To give experience to new trainers who had completed the ICL Training Services induction course in November/December 1998 and a recent Horizon update weekend in delivering the Counter Assistant and Counter Managers events.”

Who were those trainers? The new trainers, who were they? Were they people who were employed by Peritas, were they self-employed, were they contractors? Do you know their backgrounds?

Kevin Fletcher: They were mostly contractors but they’d worked on other projects for Peritas and for KnowledgePool – not all of them but some of them.

Mr Blake: Do you have an idea of how many trainers there were at all?

Kevin Fletcher: It was certainly – at its peak there were certainly in the region of 250.

Mr Blake: Thank you.

“2. To receive feed back from delegates on the course content.

“3. To evaluate the Performance Standard Assessment … results.

“4. To evaluate the equipment reliability when used in a training environment.

“Pathway/POCL had agreed to use the courses as an opportunity for new trainers to train in a real environment.”

Now, real environment, what do you understand by that?

Kevin Fletcher: Well, a real environment, for us it wasn’t a live environment; there’s a definite distinction between the two. The systems were stand alone and, therefore, you couldn’t actually link into any short of network. A real environment for us would have been going to a room, whether it be in a hotel or whatever was chosen for the actually training, and there were several different types of room that we did manage to get, and setting up the equipment, getting it all ready to go, laying everything out, and making sure that as, you know, as near as we could to actually make it as though they’d been out on the road, we’d set up a classroom, everything else, and the postmasters and counter assistants came to attend the course.

Mr Blake: Thank you. So it wasn’t in a post office and it wasn’t dealing with real customers?

Kevin Fletcher: No.

Mr Blake: But it was trying to replicate that environment in a classroom?

Kevin Fletcher: Correct.

Mr Blake: In terms of how the training went forward from, say, ‘99/2000 and onwards, was that still the format in terms of it not being within a post office or on live equipment?

Kevin Fletcher: Yes, that’s all we could do. We had to have – everything we did in that, because of the amount of trainers involved, the amount of training in locations the width and breath of the country, we had to have a generic approach to the training. So once we actually got it, you know, as per the course specifications then it was delivered as that each time. But, as far as I know, it was never delivered on a live system.

Mr Blake: This training in February and March 1999, that was very early on. It was almost 12 months before the national rollout began properly. Were you aware at this time that work was still ongoing in relation to the Horizon platform?

Kevin Fletcher: Absolutely. I mean, I used to pay regular visits to Feltham where they were developing new things and actually improving some aspects of the system. So it was – we could test the courseware out but, obviously, it was ongoing, as you say, a year before, before the actual final system would have been signed up.

Mr Blake: So as a company that was linked to ICL, did you have free access to ICL? I mean, you have said that you visited. Could you go when you wanted to, speak to who you want to?

Kevin Fletcher: Yes, I mean, usually if we had – if there was sum issue that I would go there and certainly one of the senior training team would have gone down and actually looked and tried to find out how it was developing and what version we were up to because, of course, everything was version controlled down at Feltham and just to see if it was – how far off it was so that, if we did have a question from Post Office, why that wasn’t actually there yet or being used. In those early stages, we could say “Well, this is that stage it was at at development at Feltham”.

Mr Blake: Can we look at page 6, please, in the bottom of page 6. This looks at the feedback and it has totals there of the feedback in the very final column at the bottom. I’ve added those up. So it’s 9 plus 66 plus 179 plus 137. That makes a total of 391. So does that sound about right, that there were 391 attendees at this first 14 training session?

Kevin Fletcher: Yes, it would be about.

Mr Blake: I’m going to take you through some of the feedback. Can we start on page 7, please. So if we look at page 7, it starts with the Bristol counter managers training and if we look at the remarks below. So some of the – I’m going to give you just some examples of the remarks, I won’t take you to every one and I should say that there are some positive comments within this document but I’m not necessarily going to focus on those. I would like to talk to you about, for example, number 1, “More time required (several comments). A bit further down “Too much information compressed into course”. A little further down “Although trainer was excellent not enough time to cover all topics plus questions”. “Good trainer not enough time allowed”.

The next one is the Bristol counter assistants and if we go over the page – thank you – it says there:

“A lot of information to take in on one day no doubt practice is the best way to learn.”

Scrolling down Bristol counter managers, and we have quite few comments there.

“Not confident not computer literate.

“I will need extra training.

“More time on balancing – error notices.”

Looking down a little bit more it says:

“Second day should be expanded to full day – especially for delegates who have no experience of automated systems.”

I think we said earlier it was one and a half days for managers, wasn’t it?

Kevin Fletcher: Yes, it was.

Mr Blake: If we look at that final paragraph on that page, it says:

“course definitely requires two full days second day is six hours with no lunch break. I feel the course is unsatisfactory because it is very intensive and coverage of important tasks ie balancing is rushed as a result. Bearing in mind a subpostmaster could be asked to do their first balance unsupervised.”

Scrolling over to the next page, 25 February Bristol counter assistants, about halfway down on those comments it says:

“Not yet totally confident – 1 day is not enough.”

So the counter assistants course, was that one day?

Kevin Fletcher: Yes.

Mr Blake: The final comment there it says:

“It would be useful for staff to try more transactions – products not covered.”

Moving on to the Glasgow counter assistants, 5 March, if we could scroll down to the next page:

“More time needed on Reports.”

Third comment says:

“Not confident on end of day procedures practice will help.”

A little further down it says:

“More time needed on training.”

Two persons have said that.

“Not confident at all.”

If we look at the bottom there it says:

“Not very confident.

“Do not have enough information to balance my position at the end of my shift.

“Too much information was crammed into two short a time, the course was too long time-wise.”

Next is the Glasgow counter managers, if we could scroll down on to the next page, some of the feedback there is:

“Balance ran out of time more time required.

“More time daily summaries/balance.”

We move on to the Newcastle counter managers and if we look down the second comment there:

“More on transactions and how to balance.

“How to put things right (more time).”

A bit further down it says:

“More on balancing outputs/actual printouts.”

A little bit further down it says:

“Balance/cash account procedure (more time).”

On to the next page, please, Birmingham counter managers. Again, quite similar concerns being raised there. They say:

“Concerned I feel if you’re not careful in the accounting aspects of Horizon you might find yourself in trouble. You need to know what you’re doing.

“More time needed on balancing procedure. Sped through a lot of information and the course quite intense.

“Balancing (more time).

“Pretty confident with day to day work & procedures, still confused over the balance in relation to comparing it with what I do at present.”

A little further down it says:

“A little longer needed on balancing procedures.”

Near the end there it says:

“Balancing section is a lot to take in within the current format.

“Confident in day 1 content, less confident on the management/balancing section.”

The balancing section, I think, was on the second day, wasn’t it?

Kevin Fletcher: Yes.

Mr Blake: If we keep on scrolling, I think the next page is actually just a photocopy of the first page so we can go over the page again. We are at Newcastle. If we keep on scrolling perhaps through to Birmingham counter assistants and over the page “Remarks general”:

“I need at least 2-3 times more of this training before I can feel confident.

“I need to be training again for the course, as I cannot remember everything that was taught.

“In general it felt a bit rushed. I did feel that the course was a bit rushed. It may be better held over two days.”

Another comment near the bottom “Really needs two days”. That counter assistants, so that’s only the one-day course and they are saying there they need two days.

St Albans counter managers, if we have a little look below that table. Second entry there:

“Balancing needed more time.”

About half way down:

“Having experience of … ECCO and understanding balance periods and CAP helped. Although I feel [half a day] for balancing could be insufficient for offices that do not have this experience.”

There are more entries. I don’t think need to take you to them all. There are undoubtedly some positive comments within this feedback but is it fair to say that there are two themes that really stick out there: one is of not enough time and the second is insufficient information on balancing? Do you agree with that?

Kevin Fletcher: I think whenever I’ve taught IT systems before, I mean, you’re subject to certain restrains. I mean, if you had had it over a week you probably would have got as many comments saying too much time we went over and over it again and, again, it is a thread that runs through a lot of the comments is the amount of time.

It’s very difficult really because, for some people, it wasn’t enough time, for some people with the additional support that they had in the form of the workbooks the quick reference guides and Helpdesk, et cetera, and the chance to actually go on to remedial training then perhaps we should be looking at that, at some of the feedback with relation to that, as opposed to just looking at the feedback of those very early courses, you know, without actually factoring in the other assistance that was available to subpostmasters and the staff.

Mr Blake: We’ll look at the further assistance and we’ll look at some feedback later on but, insofar as this early feedback is concerned, so March 1999, is it a fair comment to say that, looking at those remarks, there are quite a few that said there wasn’t enough time and quite a few that said that there was insufficient information on balancing?

Kevin Fletcher: I agree. The other thing I would actually add into that mix, though, which I think is very relevant, is the fact that some of the postmasters and Post Office staff had been actually balancing in a certain way for many years and took a great pride in it, to be fair to them, and I talked to a lot of postmasters at the time and it was a real pride thing to balance the books as they did it as they’d always done it. So any change to that balancing process and anything that was taken away from them, they were going to be incredibly confident in what they did to something that was new and it didn’t always sit very well. I’m not making that as an excuse but it is a point of fact.

Mr Blake: Can we look at page 20 of this document, and that has the conclusion. The conclusion, I’m going to read it out for the record, it says:

“The trainer appraisals have been very favourable for a first attempt. There’s still room for improvement, particularly in the area of timings, although the timings did improve where a trainer delivered a subsequent event. It would appear from some of the delegate appraisals that they expected balancing on the counter assistants course. The appraisals annotated unsatisfactory on overall level of satisfaction was because of the amount of information to be assimilated and the course content rather than any problem with the trainer’s delivery.”

So the summary conclusion there is that the issue was less with the way that the trainer was delivering the course and more of an issue about the amount of information that attendees needed to assimilate?

Kevin Fletcher: Can I also add from personal experience there that, if you are delivering a training course particularly of that length for the first time, it’s a huge amount for the trainer to remember and it’s not the easiest thing to do. So you usually find, on the first few courses you do, you haven’t got as much judgement of when to actually slow down a little bit or make sure that’s been assimilated. That comes with maybe one or two courses and then you actually feel more confident with the material. So there’s always a little bit of that as well.

So while I accept that more time was a definite thread running through it and the balancing also, there are some other contributory factors as to why it might not have been the slick as it could have been in the first few events.

Mr Blake: Absolutely. But let’s go back to page 12 of this document which looks at a manager’s course, the Birmingham manager’s course in March.

So this is a fair way through this first 14. We’re looking now at 8 and 9 March. Can we just look at some of those comments again. The first is:

“Concerned I feel if you are not careful with accounting aspects of Horizon you might find yourself in trouble. You need to know what you’re doing.

“More time needed on the balancing [process]. Sped through a lot of information and the course is quite intense.

“Balancing (more time).

“Pretty confident [on the] day to day work & procedures, still confused over the balance in relation to comparing it with what I do at present.”

So, I mean, there are a fair few comments there quite a few remarks that address concerns about balancing, rather than simply the amount of time that has been allocated in the course.

Kevin Fletcher: Yes, I accept that but, you see, there I mean, that sort of – where it says there – yes:

“… still confused over the balance in relation to comparing it with what I do at present.”

I mean, that just justifies what I’ve said that there, that some the postmasters for many, many years had taken a pride in balancing as they did manually and it was perfect and they took a great pride in it. To suddenly take that away and give them an electronic system to do it with, which was, in a lot of respects, very different it was quite a culture shock to them on the actual balancing side.

But I’m not decrying the fact that, yes, we would have liked more time, I would have thought – or they would have liked more time and the balancing, yes, was what it was on the system. But there were other support mechanisms available to them.

Mr Blake: If we pause in time there then, so February/March 1999 do you think that the training course was sufficient, insofar as it addressed balancing?

Kevin Fletcher: It addressed balancing within the time restraints that we had to do the course and it certainly went through the balancing process but, again, the trainers and, well, everybody really, encouraged the attendees to actually use the other things that were available to them to actually confirm the knowledge that we’d picked up on course, and certainly the Helpdesk.

From my own personal experience of working in the Post Office during the actual whole event, and that was one in Slough that I worked in, if they needed to resolve anything, the first thing that most postmasters did, in a few offices that I went in, if something was wrong, not with the Horizon System or anything, they picked up the phone and phoned the Helpdesk, and they didn’t seem to – they very rarely seemed to use the documentation, supporting documentation. The Helpdesk was their key. They rang the Helpdesk, the Helpdesk solved the problem and they got on with the end of the day.

Mr Blake: The Helpdesk assists once you are on the system but, presumably, the training before you get on the system is pretty important, isn’t it?

Kevin Fletcher: Oh, absolutely, absolutely. But to get every single bit of what was a fairly complex course into that time and you’d be perfect on it as you finished the courses then I think that was a tall order, to say the least, considering some of the delegates which were attending the courts. And, as I said, the age range was fantastic really and the actual IT knowledge was excellent to none at all.

So it wasn’t just about the actual training itself, it was that sometimes it was the people who actually attended and no disrespect to them but they tried their best but it’s bound to be something new, if you’d never done it before, always seems more complex.

Mr Blake: So let’s say you were a manager and you have a day and a half allocated for training. Your evidence is that there was sufficient training, insofar as balancing was concerned, for a day and a half’s course but do you think a day and a half was sufficient?

Kevin Fletcher: Again, it depended – I come back to it’s depending on the delegates. For some, obviously, it wasn’t because that’s expression they gave and for many it was. You know, so it was striking that balance the two and certainly the courseware and the delivery of the course showed you how to balance. For most – I can’t put a percentage on it, but for a large number of people that was enough and for some people it wasn’t enough.

But when you say you’re a postmaster and you come on a course on balancing, what’s your background to actually doing that, you know, you would have to look at how – you know how au fait were you with IT equipment and using IT equipment to do the sort of functions that were asked on the system.

Mr Blake: Did you take away from this exercise – I mean, looking at those kinds of comments that are on the screen now, did you take away to any extent that more might be needed to be done, insofar as training for balancing was concerned?

Kevin Fletcher: Absolutely. It was trying to make it so that the trainers were as clear as possible on how to – you know, from the actual courseware to actually – to make sure the balancing was right, particularly on the subpostmasters course. And it was a case of you went through it as slowly as you could with some of the people, and I know many of the trainers who didn’t have to finish at that time stayed behind with some of the delegates who were really, you know, who were struggling, some of the older delegates who were struggling to actually run through a bit of it again. I know that happened quite often.

So yes, it would have been nicer to have more time for some delegates but I think it was sufficient time for whatever the percentage was of delegates. But you always want more time on training courses.

Mr Blake: Following this exercise, which the intention of this exercise was to get a snapshot in time in the early stages to try and improve the programme going forward, what concrete steps did you take to improve the training with regards to balancing?

Kevin Fletcher: We went through the balancing and tried to make it as – I can’t say simple because, obviously, there was a system to be followed – sorry, there was a procedure to be followed on the system but the trainers were very aware that this was a very important part of the course.

In fact, the whole course was important but they tried to actually explain it as well as this could explain it and, actually, look out for people who are really struggling on the course, particularly with that element, to actually make sure they got some remedial training.

Mr Blake: So once you received the product of this study, how did you communicate that to the trainers?

Kevin Fletcher: Well, depending if the trainers had actually been on the courses and had finished the courses, although there weren’t that many at that time who had gone through, but it was part of then their induction and when they were doing the three-week induction, we actually made sure that on the last week, where they were delivering elements on the system, a lot of that was on the actual balancing and we had – you know, we were trying to make them aware there that this had to be explained as well as they could and also that they – if they saw somebody struggling then they would actually make note of that and, you know, carry out remedial action where necessary, in other words report it back or point the actual delegate into an area where they could get additional support on balancing.

Mr Blake: Can we go back to the first page of this, which is the fax header. This is sent from Alan Bourne to Kathryn Cook. Are you able to assist us with who they are?

Kevin Fletcher: I will be honest with you, I haven’t got a clue. I’ve not got a clue.

Mr Blake: Do you remember this report being escalated in any way within ICL Pathway, even to the Post Office?

Kevin Fletcher: I can’t remember it being escalated. I do remember actually that the – we were very aware of the timings on the course. I mean, all trainers were made aware that they had to – you know, that there were some things that were generic which were fairly straightforward, such as the EPOS, the Electronic Point of Sale element was fairly generic. But actually the accounting bit, the balancing bit, would be difficult for some delegates, as I say, and we tried to rectify it from a training level.

As far as it being escalated to hierarchy in the Post Office, certainly Stuart Kearns, who was the director at the time, was very aware of it.

Mr Blake: I am going to take you to another document, NFSP00000340. This is a document from one month later. In fact, on the first page, it says 1996 but, actually, if we turn over the page it’s a 1999 document and it’s one that we looked at this morning. It’s comments made by subpostmasters to Pam Jervis from – the cover letter is sent from Colin Baker.

Let’s have a look at those. These are comments that were made to the NFSP:


“The first day of training is OK but the second day is bad because it is rushed. They are not finishing on time, but are rushing to finish before 3.30 pm, because otherwise they have to buy lunch. Why [do you] use the most expensive hotels?

A couple down it says:

“In every training session, nobody had done a main balance, snapshot balances only. Nobody had been trained to do a full balance.”

So this is one month after 30 April 1999. Were you aware of those kinds of comments, even if not those particular comments?

Kevin Fletcher: Certainly, the first one, I don’t understand that at all. I don’t know of any trainers who did that and they were checked regularly. Why they’d use the most expensive hotels, that again was down to a location – you know, to a location thing and to make, obviously, the delegates as comfortable as possible. So, no, I don’t see that top one at all. I’ve never seen this document before, as far as I know, and a lot of it I – you know, certainly on the training there, I don’t recognise.

Mr Blake: But I mean the first comment that it’s rushed, the third comment that nobody had done a main balance and nobody had been trained to do a full balance, those themes were similar to the themes that were picked up in the February/March report, aren’t they?

Kevin Fletcher: Yes, it would appear so. As I say, I don’t actually – I can’t relate to that. I can’t remember the whole balance procedure. I mean, it’s 23 years ago. As far as I know – I mean, as I say, the actual balancing process was signed off by Post Office and from their hierarchy. So I would imagine that it – you know, it was fit for purpose. We carried out the training as it should have been done according to the training documentation and what the Post Office required. I don’t recognise that number 3 at all.

Mr Blake: You don’t recognise it in as much as you didn’t receive it and didn’t see it at the time or you don’t recognise it in that you didn’t receive any complaints about training failing to assist sufficiently with balancing?

Kevin Fletcher: No. I mean, there is always issues on training. There is issues with the courseware and obviously – not so much the courseware but actually what is taught on the course, and you will always get feedback: it’s not long enough, it’s too long, the room was too hot, it was too cold, the tea wasn’t on time. You know, you get lots and lots of feedback.

I’ve already conceded that we would have liked more time on the second day but that wasn’t my decision and it was a case or the two hierarchical elements of the actual training rollout, which was Peritas and also POCL, agreed that’s what we had to do on that day and the trainers and myself and other people involved at that level tried to do the best we could in relation to what we’d been told to do.

Mr Blake: I appreciate it’s some years after now but were they themes that you recall at the time, in the early days at least of training, so February, March, April, themes about there not being enough time, ie that first paragraph, it being a bit rushed, and problems with the balancing, that third paragraph?

Kevin Fletcher: I certainly remember the not enough time but it wasn’t by everybody. I mean, some people would say “Yes, it was spot on” and some people would say “It wasn’t enough time”. I do recognise that certainly and I’ve already conceded that point. We would have liked, certainly as a trainer and trainers are part of the training team, we would have liked more time but we had to go with what we were given and what was agreed at a higher level than ours. So with the time we had, we tried to do the best we could.

Mr Blake: Do you think issues such as timing were raised within ICL? You said you did what you did with the time available. Did you raise it at all with anybody?

Kevin Fletcher: Yeah, I mean, it’s always a concern about the time but, again, as I say, it was known within ICL and coming back again, repeating myself, is the fact that one of the fallbacks to that particular comment was that there was other help and support available. So when it was raised, even if they hadn’t picked up 100 per cent on the course itself, there was other supporting things that could be done to help them with balancing, such as the Helpdesk, the workbook, et cetera, et cetera.

So, although it was a concern, it was felt that it would be addressed by additions to the actual training.

Mr Blake: You said it was raised within ICL. With anyone, in particular?

Kevin Fletcher: Well, certainly Stuart Kearns, by boss, would have known about it and he would be dealing at that level but, as far as me being a part of those meetings or have any say in that, apart from feeding it in to Stuart Kearns, I wouldn’t have been able to do anything else about it.

Mr Blake: Thank you. Can we look at POL00028357. This is a document we looked at this morning. Can we look at page 4, please. This may well not be something that you at the time. This is relating to Acceptance Incident 218. Do you remember anything reference to Acceptance Incidents and Acceptance Incident 218?

Kevin Fletcher: No. Sorry, I have no recollection of that.

Mr Blake: This was a contractual incident that was raised by the Post Office and if we can just have a look at what is says there, it says:

“The Managers Training Course is not acceptable due to deficiencies in the accounting modules. In the live environment the training given did not equip the users to perform the completion of office cash accounts. This is a [I think it means ‘basic’] POCL function that is central to running and accounting for the POCL network.”

That Acceptance Incident was observed, it says, on 19 May 1999. Was anything along those lines ever raised with you at all?

Kevin Fletcher: No, I mean, if anything, the time which it was raised more backwards that when we looked that appraisals that we got from the postmasters and counter assistants actually attending the course, there was quite obviously a lot, as you already pointed out, a lot of comments about the timings, you know, that they weren’t enough time. That was passed up.

But, as far as this particular document and input into this document then, no, it was passed up through Stuart Kearns and the hierarchy of Peritas, and I believe then to ICL but I wouldn’t know, and certainly POCL attended nearly – well, all the development of the training course.

Mr Blake: If we think back to that time period, so we’re talking May – summer of 1999 into the autumn, towards September and during September 1999, do you remember any concrete steps that were taken to improve the training course, particularly in respect of balancing issues?

Kevin Fletcher: Not concrete steps, no. I mean, I don’t believe the course was changed. The course couldn’t really be changed because there was an actual process to balancing. So you can’t – it’s very difficult to then – you can’t change that process because that’s the process needed to balance. So, as far as concrete changes to the system or the way the process was delivered, I don’t remember and don’t recall any what you would call concrete changes.

There was issues about it and obviously these were passed up to the hierarchy, in my particular case anyway. But we have to follow that process and I don’t remember – I don’t remember the system changing, I don’t remember any of the training changing to address those issues. In fact, it wasn’t actually my line of process, it was the timing of the process that may have been an – well, it was an issue, obviously.

Mr Blake: Can we look at FUJ00001356, please. This is the “Counter Managers Course Specification”. It is dated October 1999. You are listed as being on the distribution list. Is this something you remember at all – not word for word but do you remember it as a document?

Kevin Fletcher: No, not particularly, not as a document, no.

Mr Blake: Could we –

Kevin Fletcher: Am I on the distribution for it – I can’t –

Mr Blake: Yes, if we look down – sorry. Your name’s listed in those final few –

Kevin Fletcher: If I was on the distribution I certainly would have seen it. The actual document I don’t particularly remember but, yes, maybe so.

Mr Blake: Can we look over the page, please. So this is the specification for the counter managers’ course and it seems as though, in October 1999, there were amendments made following the evaluation exercise. So that’s, I think, that there was an exercise in July 1999 and then it says:

“Document is based on the courses presented as dry runs to Post Office Counters Limited and signed off by Trevor Rollason in September 1999.”

If we look at page 3, this is the contents of the course. It still seems to be a two-day course or a one and a half day course that’s spread over two days. Is that right, in terms of the time period? That didn’t change?

Kevin Fletcher: No. It is right, sorry. No, it didn’t change.

Mr Blake: If we scroll over to page 5, on page 4 we’re looking that Day 1 training course, and we’re now on page 5, which is still the Day 1 and there is quite a lot of content dealing with the EPOSS system: EPOSS intro, EPOSS continued, EPOSS scales, and then scrolling down it says EPOSS Rems and reversals.

Were you aware, during this period, so October 1999, of any issues with the EPOSS system, any technical issues with the EPOSS system?

Kevin Fletcher: No, I can’t actually say I was. I mean, I think it was all okay. I mean, as I said to you, almost all the way through the initial parts of the project, they were working on different parts of the EPOSS system and it was a fairly generic – the EPOSS sales on the system, if I remember, were very generic. I don’t remember a lot, if any, of the changes on what you’ve shown me there on EPOSS.

Mr Blake: Through your conversations with people at ICL, you have already said how you’re able to visit their premises and talk to people, talk to developers. Did you talk to developers at all during your period of training?

Kevin Fletcher: Yes, I did. One of them, one that I wanted to learn, was barcodes on benefit books, so I worked quite closely with a guy who was actually developing that at Feltham, and he showed me how all that worked and that way then I could answer more in-depth questions if any of the trainers we were training had issues about the barcoding, et cetera, on the benefit books.

So it was thing like that, I went down so I could get a more in-depth knowledge on some things that I could then explain to the trainers, as they were either doing the training or going through the training.

Mr Blake: In any of those conversations that you had, did anybody point out any issues they were having with EPOSS software or any other bugs, errors or defects at that time?

Kevin Fletcher: Well, it’s very difficult really because you actually get the – it depends which version and the version control at Feltham was incredibly tight. There was a lady who ran the version control and she was well renowned for being very tight on which version. So, in other words, as they added a particular function, it could affect another function, so it was – because obviously they were interlinked.

So you could revert back to the previous version and then develop – and it kept going like that. So sometimes a new thing that was added affected some other parts of the system but they wouldn’t actually release that. I think they would actually go back to the drawing board until it didn’t affect the version and then, as the next version was cleared, it would then become, say, version 1, and then it would be version 2 and version 3.

So it was always stable in the last version if that makes sense.

Mr Blake: As somebody who was designing the courses and the materials, we have a day here almost a day dedicated to there EPOSS system. Did anybody point out to you that there will be problems being experienced in the EPOSS system at that time?

Kevin Fletcher: Not really not on the training systems, no. I mean, it seemed fine. I mean, most of the EPOSS was – it was fairly straightforward. Some people some of the delegates said never seen touch screen technology before and things like that, and that was something that, again, we had to go through with some of the delegates but, as far as the actual sales, et cetera, on EPOSS, they seemed to work fine.

I don’t remember there being a problem with those, apart from the fact it depends what version you are looking at. I mean, it was a case of, as a version became released, then it was fine, it had been tested and it was great. It was only the version on from that which might have affected the previous version and that wasn’t released then until it was made right.

Mr Blake: You weren’t working on a live system.

Kevin Fletcher: No.

Mr Blake: So did anybody say “Hang on a minute, although you are working in this environment, when the postmasters get out to the real world, their system might operate slightly different”?

Kevin Fletcher: No. I mean, there’s no reason why it should. I mean, that’s a bit like saying when you put Windows on a computer if you try it stand alone it’s fine but if you try it on a network it won’t work. It should have worked. I have no reason to believe it didn’t work. I don’t remember anybody telling me the EPOSS didn’t work and didn’t work well.

Mr Blake: You have said at the beginning of your evidence today about how much you relied on the Post Office signing off the various training materials. What did you see as the role of ICL in relation to identifying technical issues with Horizon and informing you about those?

Kevin Fletcher: Well, as I say, it was a case of coming back to the Stuart again, as a director of the company. He actually went down several times and talked to high level meetings about any issues that we had. But we were informed if anything was affecting the training or may affect the training through Stuart at the meetings and, as I said, because I sometimes – and others too – wanted more in-depth knowledge about a certain process on the system, that would allow us to maybe train it better. We would actually go down to Feltham and speak to the guys who were developing it – and women, obviously.

Mr Blake: In all of your conversations with people in Feltham, did nobody mention any concerns they had with the Horizon System?

Kevin Fletcher: Thousands but, you know, that’s part of development. They were developing a system. So, you know, there was always some concerns. You know you don’t develop a system like Horizon and not have some concerns. It’s just the way it is. But those concerns would all have to be sorted before that the next version or the stable version was released. So yes, of course there were lots of concerns by various people about various parts of the system until they were rectified and were included in the next version for release.

Mr Blake: Can we look at FUJ00001357, please. This is a document that – the “Training and User Awareness Baseline Document”. Now, you’re not listed on the distribution list of this but is this a document that you recall or you would have seen at the time?

Kevin Fletcher: Again, it’s very difficult to recognise individual documents, even ones I wrote myself after 23 years but if it was to do – if I could have got my hands on it and it was to do with anything training, I would have read it.

Mr Blake: Let’s go through and I see where we get to. The date for this is 29 November 1999, so it’s eight months after the first 14 training that we talked about earlier this afternoon. So we’re eight months down the line now and this is what’s called the baseline document. Can we look at page 9, please. There’s a diagram on page 9and is wonder if we can just blow up the diagram, please. This shows the training solution.

Are you able to tell us what this shows at all? I mean, if we start with, for example “User Awareness” is that that the user awareness course was the first interaction somebody would have with training, that lasting two and a half hours.

Kevin Fletcher: Yes.

Mr Blake: Then you have a specific course depending on who you are: so you have a counter course, which is a day; a manager course, if you are a manager, two and a half days; and then you have specialist training, for example, for auditors, for trainers and for HFSOs. Are those Field Support Officers?

Kevin Fletcher: Yes.

Mr Blake: Their training would be longer. That would be two to five days; is that right? Is that how you remember it?

Kevin Fletcher: Yes, it is. I don’t remember the specifics of that course. I almost certainly did one for the auditors because I actually went down and attended at least one of those courses with the auditors to actually make sure it was you know we were training it right and they were getting all the information they needed because, obviously, to be able to audit, they needed to be, you know, really hot on the system, basically.

Mr Blake: So here we are in November 1999, so eight months after that first report that you wrote and the length of the courses are still the same, aren’t they: the counter course one day; manager course one and a half days. So nothing has changed as far as that’s concerned; is that right?

Kevin Fletcher: That’s true.

Mr Blake: Can we look at page 16, please. Halfway down – thank you – at 5, it describes the User Awareness course. Just so that we can learn a little bit more about what these different courses are, I will just read that second paragraph. It says:

“The User Awareness event is aimed ALL users working within, or providing support to, post offices. The purpose of the event is to provide an understanding of the impact the impending installation and automation programme will have on them as individuals and their outlet as a whole. The overall aim is to elevate concern users may have of the Horizon System and encourage participation during training and installation.”

Was the user awareness course, I think it was a voluntary course; is that correct?

Kevin Fletcher: Yes, it was. They were obviously encouraged by Post Office to attend. As far as I can recollect, it was voluntary but they were usually – the ones that I actually saw were always very well attended because obviously it was going to have a big impact on the business they were in.

Mr Blake: Was that essentially an introduction, a brief introduction, into the system?

Kevin Fletcher: Yes, it was a brief introduction about what the system did. It was where they fitted in in the rollout process and, basically, what it says in that paragraph and they could ask some questions at the end, et cetera, and if that’s all fine, and if not we took them away and fed them back to Post Office and to Peritas to actually get in touch and answer the question.

But mostly it was fairly straightforward. The UAE was a fairly straightforward event.

Mr Blake: Could we look at page 18, please, if we scroll down just a little bit, it has there “Managers” and this describes the managers’ course, so that’s one and a half day contiguous training event delivered over two days to include venue setup and clear down:

“This course will be targeted at staff who are required to understand the full functionality of the automated platform.

“It is understood that all management grades will need this training. It is also understood that other staff may perform these tasks, in some cases as backup, and they will also need the Managers training event.”

So the managers’ training, the one and a half day event, that was for, for example, subpostmasters and also for assistants who would sometimes carry out those subpostmaster tasks?

Kevin Fletcher: Yes.

Mr Blake: Then you had a separate one-day course that we see there for the counter staff. It’s recognised that some of these staff who perform some management functions would attend, as I said, the managers’ course.

Scrolling down, you then have those other courses that were a little longer. You have the “Back Office Audit”, the “POCL Train the Trainer”. So “Train the Trainer” is a five-day course for, I think it’s fair to say, training those who trained?

Kevin Fletcher: Yes.

Mr Blake: Can we look at page 31, please. Scrolling down this again, this goes into a little bit more detail about the managers’ one and a half day course and it mentions balancing there. It says – it’s the fourth bullet down:

“This course would be targeted at staff who are required to understand the full functionality of the automated platform including balancing activities.”

Then scrolling down you have a section on counter assistants. Can we go to page 36, please. This talks about the actual format of the courses. So all courses will start at or before 10 am. There will be a maximum of six staff on each event. Then the final bullet there says:

“The training audience will be a maximum of 72,000 post office staff, subpostmasters and assistants as defined in figure 8.1 overleaf.”

If we scroll down, it has there the numbers. Do you remember those kinds of figures, so managers events you were expecting –

Kevin Fletcher: Sorry.

Mr Blake: Sorry.

Kevin Fletcher: I believe it was the biggest IT training event ever undertaken in the United Kingdom and I think we ran more events on one day than any other training event in the United Kingdom ever. It was a huge undertaking to deliver so many events across the whole of UK, you know, to counter managers and also counter assistants.

Mr Blake: Because you have there 7,004 managers and I think we saw somewhere that you don’t begin the training until, is it, five days before Horizon is provided to them?

Kevin Fletcher: That was true.

Mr Blake: So there was a very short space of time to carry out quite a considerable amount of training?

Kevin Fletcher: It was a huge undertaking. I mean, we were – I realise that there are some things that – we had a very good rapport for the most part with the trainers and postmasters and the staff. The trainers have a very good rapport, from what I remember, and what I’m sure I’ve had to with the postmasters, and both understood it was difficult to train that many people in that time.

So the course had to be very generic and it had to run exactly the same on every event and that is quite a difficult ask when you’ve got so many events running concurrently.

Mr Blake: Can we look at page 41, please, at the bottom of that page.

This is under the heading “Horizon Field Support and Migration Visit” and it says at the bottom:

“It is ICL Pathway’s experience that users require further support after training to help remember topics covered by their training event and build confidence [over the page] in daily use. Therefore the Horizon Field Support visit is part of this document for recommendation purposes only.”

Can you tell us a little bit about the role of the field support officers?

Kevin Fletcher: I can’t actually. It’s not something I remember at all. I mean, my – as it was at this time, when we were delivering so many events, it was a case of – we did all those events and, to the best of my – to the best of my memory – “recollection”, that’s word I was looking for – recollection, I don’t think we missed one event in all those events. So a big part of it for me was making sure the trainers were up to speed and the Horizon field support was it was really not something I had a great deal to do with.

Mr Blake: If we scroll down on that page there’s also reference to additional training. I think this is what you were mentioning earlier, that the additional training function becomes operable when any member of staff fails the competency test. So there was possibility of additional training?

Kevin Fletcher: Well, I lived in a small village in the Fylde actually, and it was a very small village and I knew our local postmaster and postmistress and the postmistress actually passed the course and her husband had to go back to remedial, which she delighted in telling everybody who went into the Post Office. But it just went to show that, you know, there was that additional training there. He was quite a bit older than she was and he undertook the remedial training and, after that – I mean, as far as I can recall again, for a good time afterwards, they had no problem at all with the system.

Mr Blake: Can we look at page 46, paragraph 11. There’s reference there to “New Product and Update Training”. It says:

“ICL Pathway are not currently contracted to provide this service however ICL Pathway will be pleased to deliver this service subject to change control.”

Do you recall was the training for new products? We was that something that was ultimately agreed?

Kevin Fletcher: Not on the rollout, no. Not as far as I can remember. I don’t remember any new products coming online at all during that time. We went with the same version all the way through the training.

Mr Blake: So we’re here, November 1999 is this document. Did you carry out any analysis after the March 1999 report to see if the two complaints that we spoke about earlier, the issues with the length of the course, which remained at one and a half days, and issues with balancing, did you carry out any analysis as to whether the situation had improved insofar as those were concerned?

Kevin Fletcher: I think – you know, coming back to what I said before and I think if you go right up to the end of it, obviously the trainer has got more au fait with it and they probably weren’t as much there because the trainers then would slow down or they’d see people who were struggling with it, they were a lot easier to spot when you are more au fait with the course and they would have to then go up and, as I said to you before, I know trainers that actually stayed behind in their own time and helped a few people who had one particular bit – they would say “Stay behind at the end and I’ll give you a bit more on it”. So probably it did improve.

But on any course you went on there, because of the vast spread of knowledge and age to be – without being ageist – and age, quite a number of them had had no IT experience at all, some of them were quite au fait with IT. So it was – there was no – how can I put it? There was no level playing field between who actually attended the course. So it could be a massive difference. I think there was somebody who well into their 80s was still running the Post Office and not been out of the village for years and never had anything to do at all with IT.

So somebody like that coming on the course, it was a massive – it was a massive culture shock to them.

Mr Blake: So the message to the trainers was “Spend some more time with those who are having some difficulties”, but there was no actual analysis or further report into the broader picture?

Kevin Fletcher: No, they knew that there were some people who were really going to struggle. You know, you do when you’re training, you can see people there. As I say, the trainers that we used, and I can speak for all of them I think, had a great rapport with the postmasters and they wanted to deliver a good session, and if they saw anybody struggling, and I know many that did they would actually, if they could, stay and help that person a bit more if they could.

But they would also, again, go through the supporting documentation where they could get further help, just so that when they did leave they felt a bit more confident.

Mr Blake: As things progressed towards national rollout in January 2000, do you think that those problems, in particular those two – length and issues with balancing – do you think that those had been resolved?

Kevin Fletcher: No, no. Not with everybody. I would say certainly on the course, no they wouldn’t have been resolved. I think the training stayed as was, because it had to be that generic training. I think the Helpdesk got better, from what I remember, and I think the people who were supporting in POCL got better. So I would say the issue on the course was that it was probably felt it was too short but the support with the handbook and the quick reference guides and, as I said, the Helpdesk, they got better.

The Helpdesk was an interesting one, purely because, as I said to you, the culture – and I’ve been to several post offices – anything that went wrong or something they didn’t understand, they immediately phoned the Helpdesk. They had manuals there from Post Office to actually go through procedures but they very rarely used them. It was a case of pick the phone up somebody on the Helpdesk can talk them through it and that was it.

Of course, with Horizon because there was a lot of new material, there were many times where they phoned the Helpdesk, you know, continuously, rather than looking up a simple process in either the quick reference guides or in the handbook, because it was their nature, that’s what they did.

Mr Blake: You said the course had to stay at one and a half days. Why did it have to stay at one and a half days?

Kevin Fletcher: I don’t know why it had to stay at one and a half days; that wasn’t my decision. If they’d have upped it to two days or three days then we would have adapted accordingly. I think it was because of the amount of courses that needed to be carried out. I think it was deemed by both the hierarchy in POCL and KnowledgePool/Peritas that that was enough time to give an understanding of the actual hardware and the processes, and should people not be quite as au fait with it and wanted more time, there was either additional training or there was actually other support available to them.

Mr Blake: Whose call would it have been? You said at ICL and POCL, whose call would it have been that one and a half days was sufficient?

Kevin Fletcher: I think we would have looked that courseware and thought “We could do it in that time”. I think the call would have been mainly POCL and even though – even if somebody like Stuart Kearns had raised it as an issue, there obviously would have been other implications, possibly, I don’t know. I wasn’t privy to those conversations. We were told that was the time we had, we had to cover that courseware in that time. Several times it was expressed it was difficult with some delegates to get them confident in that time but, again, I keep coming back to it but there was other support available to them.

So we did what we were told basically within that timescale. I did not have anything to do with the actual timescale itself.

Mr Blake: I’m going to take you to one more document before we take a short break. That document is POL00028441. Can we look at page 3, please.

Now, this is a Post Office document. Is it a document that you are familiar with at all?

Kevin Fletcher: No.

Mr Blake: It’s dated January 2000 and it’s called the “Christmas Horizon Research Report”. If we turn over the page to page 4 it says:

“This document accompanies the report entitled Christmas Horizon Research, January 2000 by Lorna Green. The report discusses the results of a telephone questionnaire carried in December 1999 with a sample of 335 national rollout post offices and asks questions about various aspects of the Horizon programme. This document contains the actual comments made by each respondent.”

So we’re now looking at December 1999. Can we look please at page 4 – sorry, the next page, page 5. There’s a table of contents and one of the areas that respondents were asked about is training, that’s number 3. Can we look at page 14, which is where we will see those comments. I’m not the going to go through every comment but let’s have a look at that first section.

So there were complaints about not enough training:

“There wasn’t enough training. On the course we were booked to go together and didn’t get the appointment. We needed much more training and more time. Balancing needs looking at. It was completely inadequate. Day and a half was not enough, especially training for balancing was concerned. I am used to computers but some of the training was horrendous. Good but not long enough. I only got one and a half days’ training. We needed more training. It was too rushed. There wasn’t enough training. Not enough training. There wasn’t enough training. It was good but not enough. We need a bit more training. There was not enough. Not enough. We didn’t cover enough. We needed to be taught more on the Horizon System, maybe spread over a week we really needed more training”, et cetera, et cetera.

That’s the first entry, so that’s not enough training. Over the page there’s another section on not enough training on balancing. It says there:

“Training for accounting was very bad. Balancing took hours to sort out, and was kept up until midnight sometimes. Tried to call Helpdesk but it was almost always engaged. But needed more time on balancing. The first day was all right but the quality of the training was not good on the second day because we concentrated on serving customers which was very easy but needed training on balancing in back office. I think it was useless, inadequate, particularly for balancing. They didn’t inform us very much on cash accounts. But not enough time, especially on the balancing side. The training was very inadequate on the accounting side. Did not allow enough time, especially on the balancing side of it. Just inadequate – we were trained to do the counter procedures but not on the office administration side. Balancing training was poor, I taught myself”, et cetera.

Over the page there’s another section on “Not enough time allowed”, and it says there:

“It was trying to cram too much in, in not enough time. Inadequate. Day and a half was not long enough. No time to practise anything. It could ideally have been longer training session. We ended up being left totally confused. There was not enough time.”

So looking at December 1999, just before the national rollout in January 2000, you see those same themes as you saw in the original report, the not enough time theme and the not enough help with balancing theme. Were those concerns raised with you at the time, or anybody in your team, by the Post Office?

Kevin Fletcher: Not by the Post Office. I mean, obviously we knew from delegates on the appraisal feedback form. I would say, looking at those comments there, we never had that many comments of that nature on the feedback forms that we got, you know, from each course. Instead of – it’s how you phrase the question as well. I mean, one of the things I noticed sometimes with Post Office – and I’m not saying there was enough time, I agree that there’s a thread going through that – but it’s a case of if you ask somebody what they didn’t like about something, they tend to actually come up with a particular answer. And I’ve noticed on feedback myself where they actually put up “What did you like about something”, on the board, and then say what didn’t you like, and the people see things they did like and think they have to counter balance it with things they didn’t like.

I agree about the no time, or not enough time, I should say, but it’s a difficult one, really. We did what we could within the time that we had and none of them there have said, “even after, you know, I sought further assistance”. None of them have actually said, as far as I’ve seen so far, none of them sought any further assistance, none of them have talked about the Helpdesk, none of them have talked about supporting documentation. You know, so it’s all about the training.

Yes, the training would have benefited from more time but, actually, nobody’s even mentioned the other support elements that there were to the course, so – having seen the course in just isolation and having seen the course with the other things that were available to them.

Mr Blake: What was it just a coincidence that those same two themes seemed to crop up again in December ‘99, as we saw in March 1999?

Kevin Fletcher: No, I don’t think – I think is no coincidence at all. I think it’s very true, in the fact that some people would see or think or believe, or were actually right, that there probably wasn’t enough time on the balancing stood in isolation, or actually saw it in the system. But what I would say is you have to look at that with regards to the other help that was available and you have to look at balancing that with some of the people that thought it was fine. I mean, all we’ve seen so far is documents mainly that said there wasn’t enough time, and I accept that. I’m not disputing that and I think of any training you will get – particularly when it’s a little bit complex, which it was on the balancing, that it is difficult.

The other thing, as I said earlier, the fact that we were – the actual system took them away from what they’ve been doing, some of them for years and taking a great pride in, to actually doing something completely different and they wanted more time.

Mr Blake: Thank you, sir. That might be an appropriate time to take a mid-afternoon break.

Sir Wyn Williams: How are we doing generally with this witness, Mr Blake?

Mr Blake: I am aiming to finish for 4.30, so if we take a ten-minute break now that should be possible.

Sir Wyn Williams: Fine.

(3.30 pm)

(A short break)

(3.41 pm)

Mr Blake: Mr Fletcher, can you hear and see me?

Kevin Fletcher: Yes, I can hear you.

Mr Blake: Thank you. Can we look at FUJ00119801, please. This is the counter managers’ training pack. Is this a document that’s familiar to you at all?

Kevin Fletcher: Yes, I believe – yes, that one is familiar.

Mr Blake: It says at the bottom it’s version 1. Do you remember at all would this have been consistent in 1999/2000? Were there significant changes to this at all?

Kevin Fletcher: I can’t remember specific changes. What would have happened was there may have been increments to it but the version numbers would have changed. It might have been that changes were made. It would have to go backwards and forwards for approval with POCL and if they did approve any changes that were made then it would have been version 2 or 2.0. So it would be a whole – if it was a whole number at the front, it meant that was the actual document we were using at the time.

Mr Blake: Thank you. Can we look at page 5, please. 5 is the agenda for the first day and then if we turn over the page it’s day 2. Is this agenda familiar to you? Is that the kind of time periods that you dedicated to certain events throughout the training? Let’s look at balancing, for example. We have there 10.00 am to 11.00 am, 11.15 to 12.30, and then there’s “followed by a role play and performance standard assessment”, but it looks as though there were 2 hours 15 minutes on balancing in the second day; is that right?

Kevin Fletcher: I can’t – it must be if it’s on there. That’s what the trainers would have done, yes.

Mr Blake: So the aim – we’ve said a day and a half, so the aim is to finish at 1.30 on day 2?

Kevin Fletcher: Yes.

Mr Blake: Can we look at page 63, please. Thank you. So this is training insofar as balancing is concerned, and can we just scroll on to the next page and over the page again. These are the topics that were covered in that section on balancing. Thank you. Perhaps we could scroll again and again. Thank you.

It seems as though that’s quite a lot of information to fit into that 2 hours 15 minutes; would you agree with that? Quite a lot of different topics to be discussed there?

Kevin Fletcher: Yes, I agree.

Mr Blake: I mean, reflecting on this and reflecting on what we discussed before the break, do you think that a day and a half’s training was adequate?

Kevin Fletcher: For some people, yes. For – some people, obviously, would have benefited from more time. All I can say to you is that, you know, as far as the actual timings went, then that wasn’t an issue for me. I couldn’t affect that at all. Obviously, what it came down to, I don’t know, whether it was the amount of people to be trained, whether it was the cost involved, et cetera, et cetera. But, you know, we were given a day and a half, that was approved by POCL, and we had to get in those topics within that timescale.

Mr Blake: I think it was your evidence before the break that you have to look at things in the round and it’s not just the training itself, it’s also things like the workbooks; is that right?

Kevin Fletcher: Yes. I mean, there were other support available to postmasters and to counter assistants. What I would say to you, from personal experience, I did go round a number of post offices to watch the manual processes, was that they actually very rarely used written documentation when they had an issue. It was nearly always the Helpdesk and this is one thing I did pass back up to both my boss, Stuart Kearns, and to POCL, was that I thought, because the time was reasonably short, that they may get a lot more enquiries to the Helpdesk.

Mr Blake: You said you fed that back to the Post Office. Can you remember a particular name of anybody?

Kevin Fletcher: Well, it would have been – Sue Smith would certainly have been part of it because she was my main contact, really, within the Post Office and she tended to get together any people that would be involved in what we were discussing. So I knew for a fact that the Helpdesk would be under some pressure because, as I say, it was a short amount of time, it was given out to the post offices – sorry, to the postmasters and counter assistants that the Helpdesk would have been trained and quite a lot of them, from what I remember, were quite pleased about that because, of course, we had issues with other things within the Post Office and, of course, that was their first port of call, was to Helpdesk.

Mr Blake: Can we look at POL00090452, please, because I want to ask you about the training workbooks. What were workbooks?

Kevin Fletcher: Training workbooks were something they could actually use. Remember, I said that the actual system had a training mode as part of the system and they could have used the workbooks to explain certain functions to other members of staff or to new members of staff and this could also be used as a reference to an operation on the system.

Mr Blake: Am I right in saying that there were ten separate workbooks?

Kevin Fletcher: Yes, I believe it was 10.

Mr Blake: Would it surprise you to hear that they are, in total, over 480 pages in length?

Kevin Fletcher: No.

Mr Blake: When were subpostmasters and their assistants and others expected to have read this? Was this before the training event, after the training event?

Kevin Fletcher: It would be after the training event but what I would say to you there is that it wasn’t a reading document, it was a reference document for particular functions on the system. So it wasn’t something you sat down at night and read, it was something that, if you needed to train somebody else or you wanted to refresh a process in your mind, you could pick up one of the workbooks or the workbooks and refresh yourself on that process.

Mr Blake: So you had the day and a half’s training, let’s say, if you’re a manager and then you have this 480-page workbook to go through if you had a problem. Were the significant documents like this to read before the training?

Kevin Fletcher: Not as I recall. The other thing, although there’s a lot of pages, as you say, quite a lot of them are diagrammatical because, obviously, there were a lot of screenshots included in the workbooks, as I recall, because, obviously, a picture tells a thousand words, and it was a case of it was a way of showing what would appear on the screen to assist the Post Office staff to actually complete the process.

Mr Blake: Can we look at page 7, please, and near the bottom of page 7. Thank you.

It’s the penultimate paragraph on page 7. It says:

“The workbooks do not cover every possible transaction which you can perform on the Horizon System. If you need further help or if a specific example is not covered, you should consult the Horizon System User Guide.”

Can you tell us briefly what the Horizon System User Guide was?

Kevin Fletcher: They were short guides, as I recall, to actually cover some of the processes and I think some of the processes were fairly generic, as I’ve said before and, certainly, the EPOSS – quite a lot of the EPOSS ones, if you sold one thing on the system, it was the same process for selling something else. It wasn’t a completely different process for everything that you did on EPOSS.

But the workbook – sorry, the Horizon System User Guide, they were also a supplement to this where you could actually – they were more like quick reference guides.

Mr Blake: We have the user guide. I’m not going to take you to it but, for the purpose of the transcript, it’s POL00090227. Would it surprise you to hear that the Horizon System User Guide was 819 pages in length?

Kevin Fletcher: Yes, it would, actually. Perhaps I’ve mixed up there with the quick reference guides. I think maybe I have. I’m not aware of the User Guide but the quick reference guides were a one-page quick reference – as the name would suggest, a quick reference guide to a specific process. I’m not quite sure about the User Guide. I can’t recall exactly what that contained and what it was for.

Sir Wyn Williams: I can’t help it, Mr Blake. In the old days you could have waved the 819 pages around!

Mr Blake: I’m not sure the Inquiry can pay for that much printing!

We have here a 480-page workbook – ten workbooks that comprised 480 pages. They themselves refer to 819-page Horizon System User Guide. Did the length of all these documents – I accept that there were these quick reference guides – but do the length of this workbook and the document that’s referred to there give any indication as to the complexity of the overall system?

Kevin Fletcher: To a point, yes, but I also think that they were there, as the name would suggest, as a reference to a particular action. If it had been you had to read through it all and then actually do things then, fine, I agree with you, it would be far too hefty to do. But if you were looking to complete an individual process, then I would say they were fit for purpose. The other thing, of course, is that POCL would have gone through these and they wouldn’t have got anywhere near the offices unless POCL agreed them and signed them off.

Mr Blake: You gave evidence earlier the a postmaster who may be in their 80s, whose first experience with a computer is having Horizon put into their post office. Do you think that workbooks that are 480 pages in length and refer to a document that’s 819 pages – do you think that that is helpful to those kinds of postmasters?

Kevin Fletcher: That’s a difficult one. I can’t really comment on that. I mean, they were done for a specific purpose and, in my own view, they matched that purpose. I agree with you if somebody had to sit down and read them all, then no they’re not – they would too hefty to actually to do that. What I would say to you is that, from the post offices that I went to on the manual process, there were several large user guides and other guides within the Post Office for the manual system.

So whether you – as I say, as a reference they were fine but as a bedtime reading, no, they weren’t.

Mr Blake: Can we look at page 367, please. This is Workbook 10, which is entitled Balancing Using the Horizon System. This is the section of the workbook that addresses balancing. Could we scroll over the page onto page 369. This Workbook 10 was 115 pages long. Does that sound right to you?

Kevin Fletcher: If you say so. I mean, I can’t recall exactly.

Mr Blake: If we look down, these are all the topics that are covered in the balancing workbook. Can we scroll down a little bit more? Over the page, over to the next page. This is section 2 continued and it goes down there to page 115.

Does number of topics that are covered in that workbook indicate to you that cramming the issue of balancing into that second day, the second half-day of the training, was not sufficient?

Kevin Fletcher: What I would actually say back on that – and I think I’ve already conceded that we would have liked more time – is the fact that, although these may seem foreign to somebody who isn’t a post office person they actually mean, you know, straight away they know what shared stock unit declarations are, they know what declared stock is. You know, so they are not all brand new topics to them. It’s just they are carrying out what they normally did on the paper-based system onto an electronic system.

So it may seem quite daunting if you just read through it and said “Well, that’s a lot to take in” but actually it wasn’t completely foreign to the POCL workers, in my view.

Mr Blake: Can we turn back to page 287. This is training Workbook 8. Training Workbook 8 dealt with Help and Basic Maintenance of the Horizon System. Can we look at page 296 which is within Workbook 8. It says at the top there, section 1, “Horizon System Contingencies”:

“If you have a failure of the complete system or one of its components these are the procedures to adopt.”

Now, when it says “failure of the complete system or one of its components”, am I right in saying that’s something like a power failure or a screen failure; it’s not addressing errors in transactions, software errors in transactions, for example?

Kevin Fletcher: Can you just repeat that. I didn’t quite catch the –

Mr Blake: Absolutely. So this section addresses what’s called “a failure of the complete system or one of its components”, and then it goes on to list nine topics:

(1) power failure; (2) monitor touch screen failure; (3)

Mr Blake: magnetic swipe card reader – these sound very much like hardware issues and not software issues.

Kevin Fletcher: Yes.

Mr Blake: For each of those, apart from scales, the advice seems to be to telephone the Helpdesk. So if we look at “Power Failure”:

“The most likely cause of a complete system failure is a loss power for one reason or another. Telephone the Horizon System Helpdesk as soon as possible.”

The next one “Monitor Touch Screen Failure”, it again says “Call the Horizon System Helpdesk”.

Magnetic swipe card reader failure, again “Call the system Helpdesk”. Smartcard reader, “Call the Horizon System Helpdesk”.

If we scroll down keyboard failure, “Call the Horizon System Helpdesk”.

6, barcode reader failure, “Call the Horizon System Helpdesk”.

Scales failure isn’t dealt with by the Helpdesk but moving onto 8, counter, again “Call the Horizon System Helpdesk”; and 9 multiple equipment failure, “Call the Horizon System Helpdesk”.

Am I right in saying that there isn’t a section in training Workbook 8 on software errors?

Kevin Fletcher: I honestly don’t know. Looking at this now, I think I can’t recall any of this book, I really can’t recall it at all. I thought I did when you first put the thing up. I don’t remember ever seeing this failure part of any book. I think this is a POCL document.

Mr Blake: So I thought you had said that the workbooks you had contributed to. Had you not contributed to those?

Kevin Fletcher: I had contributed to a workbook but I certainly none of these things here I wrote. I can’t recall writing any of those. I can’t recall being involved in any of those at all because surely there would have been an easier way to write that than actually do every single one; do you know what I mean? I certainly didn’t – I may have known about the document. I don’t think I did because I’ve never – I can’t recall seeing this at all.

Mr Blake: It’s called a training workbook. Is this not the document that you recall being provided to those who were trained by yourselves?

Kevin Fletcher: No, no, it isn’t.

Mr Blake: Do you recall any document, in particular, being provided to those who you trained?

Kevin Fletcher: Yes, there was a workbook. There was a system workbook but, as far as I’m aware – and, you know, some things I just think can’t remember but I’m pretty sure that these elements were not in that book.

Mr Blake: I mean, this is – if we look at the top right-hand corner, it’s dated July 1999 so that was a period that you were involved in the training?

Kevin Fletcher: Absolutely.

Mr Blake: The reference is that a reference that you recognise at all?

Kevin Fletcher: No, not at all. It’s a Pathway reference and it’s – I just honestly don’t recall. I don’t recall those failures. If I’d have been involved in it, I certainly wouldn’t have put each one as separate. I would have actually listed the potential failures and put “Call” – it’s a bit monotonous to list every single one and put “Ring the Helpdesk”. It’s just not something I feel I would have done. I don’t remember doing this in any part at all. Whether I did or not, maybe I did I just don’t remember that and it doesn’t sound like I would have been involved in it, looking at it.

Mr Blake: In terms of the documentation that you were involved in or you do recall from training, do you remember there being any documents addressing software errors or what to do in the case of a software error?

Kevin Fletcher: No.

Mr Blake: We’ve heard evidence of, for example, workarounds and a Known Error Log that was held by ICL. Were those things that you were aware of at all, that there were certain procedures that you could use in order to get around a problem, a work around?

Kevin Fletcher: No, not something I did.

Mr Blake: Do you recall things like workarounds being addressed in any way in the training that was provided to postmasters?

Kevin Fletcher: No, I don’t recall at all.

Mr Blake: Can we stay on this document at page 297. You may – in light of the evidence you have given you may not be able to assist with this at all but let’s see where we get to on this. Can we bring up on the same screen another document, and it’s FUJ00117722, page 15. These are two different versions of training Workbook 8. The first version is on the left-hand side and that’s dated 24 July – in fact, it says 24 July 2000 but it’s called Issue 1 and then, on the right-hand side you have 29 July 1999, which is referred to as Issue 2. It’s not clear which of those two is earlier.

But what I want to take you to is that note there, the wording in bold. One of them says:

“Should Post Office counter staff have difficulty in using the Horizon System or the training documentation, they should contact the Horizon System Helpdesk. For problems with the Horizon System User Guide or the balancing with Horizon document, you should contact the Network Business Support Centre.”

Kevin Fletcher: That’s just confirmed it for me. I had nothing to do with that because I would have remembered that. This document is not one that I was involved in.

Mr Blake: Thank you. We’ll stay with the document because I do want to ask you about the Helpdesk and the Network Business Support Centre and your recollection of those. The one on the right simply says:

“Should Post Office Counter staff have difficulty in using the system or the documentation, they should contact the Horizon System Helpdesk. The service hours of the Horizon System Helpdesk are as follows …”

What I wanted to ask you – and you don’t need to refer to this document at all, just to your recollection – is: who were subpostmasters, assistants, et cetera, told to contact if they were having difficulty with the system in a way that affected balancing but that wasn’t, for example, caused by hardware? So who would I call if I had a software issue that was affecting balancing?

Kevin Fletcher: The Helpdesk. As I said to you before, the culture – forget the Horizon System. The culture in every post office I visited is if there was an issue of any sort, whether it be with a customer or whether it be with benefits or anything else, was straight on to the Helpdesk. They very – in fact, I never saw one refer to any of the current Post Office documentation that was in the offices. They had a really good Helpdesk and they were very reliant on it is my opinion and my view of it when I actually went round the offices.

Mr Blake: What is your recollection of the Network Business Support Centre?

Kevin Fletcher: I didn’t know anything about that. I probably heard about it but I didn’t know – I thought it was maybe a subsidiary of the Helpdesk. I had nothing – again, nothing at all to do with the support centre.

Mr Blake: Do you recall postmasters ever being advised to contact the Network Business Support Centre? Was the advice that was given in training always contact the Horizon System Helpdesk?

Kevin Fletcher: It would have been the Helpdesk. I honestly can’t recall, and I would be surprised because it would have been something that would have stuck in my mind. I can’t recall them ever being told to contact the Business Support Centre.

Mr Blake: Thank you very much. I will skip the next question because it asks about the same document.

Do you recall discussing with those who you trained what to do in the case of a software error and a software error, in particular, that had affected balancing?

Kevin Fletcher: The only thing I think that we actually mentioned was, if there was an issue with balancing whether it was something to do with the software, or they were just having trouble with the actual process, was to first of all look at the supporting materials and then actually, if it couldn’t be resolved that way, then obviously to contact the Helpdesk. If they couldn’t balance using the system, they would normally balance manually and that would have been, as far as I’m aware, acceptable to the Post Office because of a system failure.

Mr Blake: Thank you very much. Those documents can be taken down. I have a few further discrete topics to ask you about.

The first is field offices but I think you’ve said that you don’t really recall very much at all about field offices –

Kevin Fletcher: No.

Mr Blake: – is that right?

I do want to show you FUJ00001520. This relates to field offices but it’s actually relevant also to those who you trained in general. It’s FUJ00001520. This is a Horizon Field Support Officer Counter Managers’ Field Specification from the summer of 1999. So July 1999 there seems to have been a proposal to amend the course for counter manager, the support officers. Can we look at page 4, please. Is this a document you remember seeing or a topic that you remember being discussed?

Kevin Fletcher: I would have seen it. Because of the author, I would definitely have seen it.

Mr Blake: So this seems to be a request by the Post Office for an amendment to the two-day counter managers’ course but I don’t believe it’s the counter managers’ course broadly. It seems to be for the Horizon Field Support Officers. Do you remember this at all?

Kevin Fletcher: Not really but I can – the general gist of it maybe, but not in any detail.

Mr Blake: So some of the reasons given for amending that course are given here: increased length of course; two days’ training not enough; no practice time; more training and practice on balancing procedures. A little further down: one-day balancing cash accounting.

And if we turn over the page for a proposed timetable, it seems as though the proposal was to extend the course that was given to the Horizon Field Support Officers and we see there there’s a day 3. So whereas day 2 you have an overview of balancing at 2.15 – can we zoom out slightly. So you have the overview – perhaps zoom in a little bit more, if that’s possible. Thank you very much.

So day 2 you have overview of balancing, overview of balancing processing reports, SU balance, but then moving on to day 3, which is the next column, you have quite a lot more: office balancing and cash account, suspense account.

Is this something you remember at all, this structure of training?

Kevin Fletcher: No, I don’t remember this three-day proposal at all. I probably would have seen it but I can’t – maybe I didn’t see it. It might be something that the author was doing with Stuart or the Post Office.

I mean, I think I agree with what you’ve said earlier on. Everybody would have liked more time. The problem is that you have to work sometimes, even though you raise it as an issue, and it was raised as issues, that you have to work with what the client is proposing and also your own company.

So it’s very easy to say there should be more time and et cetera, et cetera but there’s a number of issues about more time and it’s certainly the time it would take overall, the cost, there’s a lot more than just, “Oh, we’d like an extra day so we’ll put an extra day on.” It wasn’t at my level to make that decision.

Mr Blake: I mean, this particular proposal for the Field Support Offices, it seems to address some of those concerns that we saw earlier this afternoon and throughout this afternoon about not enough time and more on balancing, because it provides an extra day that addresses balancing. Do you think that’s the kind of thing that should have been adopted for all of the managers?

Kevin Fletcher: To be honest with you, it would have – yes, I mean I can’t say, you know, I wouldn’t have liked that. It would have made the course better. It wouldn’t have made it appear to be so rushed. But the problem with it was, was that the fact that it wasn’t our decision. We could make all the suggestions and pass feedback back, and feedback was regular available to both POCL and to KnowledgePool at the time and ICL, and if the course had to be extended they were the ones that would have to decide for it to be extended. I had no sort of control of that at all. They said this had to be covered in a certain amount of time and, to the best of our ability, that’s what we did.

Mr Blake: If we look on the right-hand column, about half-way down, it says “introduce dodgy balance comp”. That might be competition or composition?

Kevin Fletcher: I think what that would have been is that they would have actually had a balance that was – that had mistakes in it and with common mistakes that we can possibly make and the delegates then probably would have had to look and say, “Well, that’s a mistake, that’s a mistake” and look at it in that way. But, again, I’m guessing that because I had no input into this document.

Mr Blake: Is that kind of thing, that kind of balancing common mistakes training, is that the kind of thing that did or didn’t appear in the managers’ training?

Kevin Fletcher: No, it didn’t appear in the managers’ training. It was all the processes to complete balancing, you know, as would normally be done in an actual office. The process is to use on the system to balance the Post Office. The problem with that is of course is that, you know, even on the manual balancing there are discrepancies sometimes or mistakes which doesn’t produce a balance. I mean, I talked to many postmasters that said they’d spent hours and hours on balancing day trying to balance the Post Office where a very simple mistake had been made.

So problems occurred with manual balancing as well as balancing on the system, it would appear, and were there were quite regular issues with the daily balance – sorry, the Post Office balance and the manual system. It wasn’t all just on the automated system. Not every Post Office balanced correctly, that I do know for a fact, and quite a – well, quite a number of them didn’t balance correctly or didn’t balance correctly until we’d done quite a number of hours after they should have balanced trying to find the problem.

Mr Blake: I’m going to move on to training the trainers. I think you’ve told us how many trainers you think there were. Can you tell us their background at all. How were they recruited –

Kevin Fletcher: They came from a various background. There were a few that were ex-military, there were some that were ex-Post Office, there were some that had trained on other systems like the National Lottery. And what we did, at first there was an initial – well, obviously a CV and then an initial interview and, from that initial interview, they were called forward. There was three weeks of training for that particular trainer and it was subsequent to that, if they passed those – at the end of each week, there would be an assessment and if they passed the assessments after every week, so passed the three assessments, then they would be employed as a trainer on the system.

The actual first week was about general training, use of training equipment such as overhead projectors and other things that you would use as a trainer. The second week was doing specific parts of training and obviously dealing with sometimes problems, et cetera. And the third week was all on the system. So they would do elements on the system.

For obvious reasons they couldn’t do every single bit of the training as a test – it would have taken too long – but by that stage you could tell who could actually deliver it on the system and there was assessment there. They had to pass all three assessments before they were employed.

Mr Blake: Did they have any experience in working in a live post office system?

Kevin Fletcher: Yes, quite a few did and I can’t remember exactly but on that many trainers, some of them were ex-POCL – not many. A lot of them had worked on IT systems before. Quite a number were lottery. Like I said, there was a few military.

It was a very arduous role as well. It sounds easy to go to an hotel and set up and everything else but, to be honest with you, they were travelling great distances in between some of the events, and it was quite a physical role as well because you were having to break down the classroom quite often, you know, after one evening – sorry, one day and then travelling during the evening, set up the next day for the next event.

Mr Blake: But in terms of their actual real-life experience in using Horizon, being a new system, had any of them actually used Horizon within a live post office?

Kevin Fletcher: No, no.

Mr Blake: Moving on, can we look at FUJ00078743, please. This is a document from yourself. Is it a document that you recall at all?

Kevin Fletcher: Not in detail again, but I’m sure …

Mr Blake: It’s 12 May 1999 and it relates to the live trial operation plan. If we look over the page, it refers to something called the Cash Account Expert Team. Do you remember that? It seems as though there was an expert team that was put in place on a Wednesday to assist with issues relating to cash accounts.

Kevin Fletcher: No, I’m sorry, I don’t recall that.

Mr Blake: If we look at the bottom of that page, it says:

“D Fletcher will attend the ICL Stevenage site to oversee the activities on the ground and provide a focus for management reporting and work with OSD to determine staffing requirements for Thursday morning.”

Is that anything you are able to assist us with at all?

Kevin Fletcher: No, I’m sorry. The D Fletcher, I probably did meet him but I don’t know him.

Mr Blake: Can we look at FUJ00016958. Can I just say in relation to that previous document, there’s clearly a – it’s been brought to our attention via a request from a Core Participant, but it seems as though that document it’s “D Fletcher” rather than “Kevin Fletcher”, so in fact you may have had nothing to do with that topic whatsoever. Is that right? It’s a different Fletcher.

Kevin Fletcher: It is a different Fletcher but it actually says on the comments, it gave the example of a simple report taking three minutes to print:

“The performance is unacceptably slow and is getting worse with successive” –

Mr Blake: Sorry, sorry, I was talking about the previous document that I just took you to?

Kevin Fletcher: Oh no, no.

Mr Blake: The Cash Account Expert Team. That document –

Kevin Fletcher: It was a different Fletcher –

Mr Blake: – was written by a D Fletcher, so it must be a different Fletcher. This particular document I’ve been asked to ask you about, and it’s an error log which we know is a PinICL, and it has your name there having discussed an issue. It relates, if we look on the top right-hand corner, to a training counter and an error or a difficulty – I think it’s a complaint that it’s unacceptably slow. Is this something you recall at all?

Kevin Fletcher: Yes, very well. It actually was switching over to the training part of the system. It was – I think that contractually it was that there would be a training mode on the system. What in reality at first there was an issue with how long it took to change over from live to – or to change it from what would have been the live system to the training system. So that was in live. It wasn’t on the actual stand-alone system. It was on the actual system itself.

Mr Blake: Were there issues that you experienced with training counters at all?

Kevin Fletcher: No, because of course all our systems were – they were training anyway. They were always in training. What I’m saying to you is in the actual offices when the system was installed, there was a training mode that they could switch to. One of the issues that they had was that to switch from live to training took too long really. It was a long time and it became an issue.

Mr Blake: Was that issue resolved?

Kevin Fletcher: I believe so but I’m not sure. I think it’s still probably today takes a while to – there’s that much information, particularly with benefits and that, that the system is linked to that to actually run in a mode that wouldn’t affect any of that, it takes a long time to change over. I know they improved it quite a lot but how much in the end I couldn’t honestly say.

It didn’t really bother the training, apart from the fact it was an assistance to the training that we gave that we could operate in training mode in the live environment, if that makes sense. But we had to come out of the live system to go into the training system. They do it on a lot of EPOSS systems as well where in supermarkets they can actually quite often, or they can, change over from a live till, if you like, to a training till. This was very much the same which they could change over from a live Horizon system to a training Horizon System in the office.

Mr Blake: Thank you very much, Mr Fletcher. Those are all of my questions.

Mr Stein has identified another version of a workbook. Unfortunately, we’ve implemented a new process which means there’s going to be a difficulty in getting that document onto screen. So we can see where we can get to. We can take a break. It depends on how important that document is, Mr Stein.

Mr Stein: Well, sir, the position in relation to the document I’ve identified is that the witness, Mr Fletcher, referred to workbook 8 as being a possible Post Office document. There is a version of it which has an FUJ, so a Fujitsu reference, which appears to be a Pathway version of workbook 8 and that would deal with the point raised by Mr Fletcher.

Now, in a way, I have made the point by putting forward the difference. I’m happy to leave it at that. I would suggest, sir, that you and the panel peruse workbook 8 in the version from Fujitsu which, for completeness, is FUJ00117722 and it contains the same points which relate to basically “go to the Helpdesk”.

Sir Wyn Williams: Is this ultimately the sort of factual point that can be dealt with by a simple written request to the representative of, say, POL and Fujitsu who would provide the answer, or what do you think?

Mr Stein: Well, I think on the face of the document it answers that particular question.

Sir Wyn Williams: It actually answers it.

Mr Stein: Because it pretty clearly says at the very top of the document where it’s from: ICL Horizon.

Mr Blake: We can in fact bring up precisely a document that makes that point, sir. It’s the second page of this document. If we look over the page –

Sir Wyn Williams: So do you actually have a question for the witness?

Mr Stein: With the explanation I provided, I don’t think so.

Sir Wyn Williams: You’ve given the evidence.

Mr Stein: Exactly.

Mr Blake: Perhaps I could ask Mr Fletcher: Mr Fletcher, if you look on the document that is being brought onto screen, this is training workbook 8 and it says there “Copyright KnowledgePool Limited 1999/2000.” Is this really a document that you wouldn’t have seen or don’t recall seeing? Perhaps we can look at the page before.

Kevin Fletcher: I’d have to look at the pages. It might be that it wasn’t written, you know, by me or I had input to. I did a workbook but the workbook – or my team did a workbook that was the operation of the system. In other words, it showed screenshots that were, you know, if you press this, this came up. It was a very basic one and I don’t recognise it being training workbook 8 at all.

Mr Blake: Might it have been that you produced one of the ten or one or more of the ten workbooks but not these particular ones, Workbook 8 to Workbook 10?

Kevin Fletcher: I was never aware it was part of a series. The one I did was really to support what was done in training. In other words, it was a follow through book; in other words, if you press this, this screen comes up, if you want to do this, you press here, and it had all the icons from the system which made for it easy to follow. It was a real – I don’t know – yes, simple book to follow. It wasn’t – I don’t remember it being part of a set of any workbooks.

Mr Blake: Thank you, Mr Fletcher. It’s perhaps an issue that we can explore with other witnesses in this phase. I don’t believe there are any other questions.

Sir Wyn Williams: All right. Well, thank you very much, Mr Fletcher, for giving your evidence to the Inquiry. I’m very grateful to you.

Kevin Fletcher: Thank you.

Sir Wyn Williams: It’s just one witness tomorrow, is it, Mr Blake, or have I got that wrong?

Mr Blake: We have just one witness.

Sir Wyn Williams: Yes, fine.

Mr Blake: Mr Bansal.

Sir Wyn Williams: That’s it. I’m on track. Thank you very much. So 10.00 tomorrow morning.

Mr Blake: Thank you very much.

(4.24 pm)

(Adjourned until 10.00 am the following day)