Official hearing page

19 January 2023 – Donald Grey

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(10.00 am)

Ms Kennedy: Good morning, Chair.

Sir Wyn Williams: Good morning.

Ms Kennedy: Our first witness today and only witness today is Mr Donald Grey.

Sir Wyn Williams: Good morning, Mr Grey.

The Witness: Good morning, sir.

Donald Grey


Questioned by Ms Kennedy

Ms Kennedy: Could you confirm your full name, please.

Donald Grey: Yes. Donald Scott Grey.

Ms Kennedy: Mr Grey, do you have a copy of your witness statement in front of you?

Donald Grey: I do, yes.

Ms Kennedy: If you turn to page 25 of that statement, is that your signature there?

Donald Grey: Actually it’s page 24 on my copy.

Ms Kennedy: You are quite right. Is that your signature there?

Donald Grey: It is, yes.

Ms Kennedy: Have you read through this statement recently?

Donald Grey: Yes.

Ms Kennedy: And is it true to the best of your knowledge and belief?

Donald Grey: Indeed.

Ms Kennedy: That statement is now in evidence. Everything that I ask you is supplementary. First, thank you very much for preparing a witness statement and for coming to give evidence today. I’m going to start by asking you a few questions about your background. You joined the Post Office in 1963 as an executive officer; is that right?

Donald Grey: Yes.

Ms Kennedy: From 1986 to June 1993 you were district manager for the Post Office; is that right?

Donald Grey: Yes, that’s right.

Ms Kennedy: What did that role involve?

Donald Grey: That was looking after post offices across four counties in the north Midlands. I can’t remember how many there were at the time, must have been about 300.

Ms Kennedy: In June 1993 you moved to Leeds on business reorganisation and you became regional general manager for the North-east region; is that right?

Donald Grey: Yes. That was later. I did another role before I became regional manager. That was in 1997.

Ms Kennedy: You’re quite right. Then as part of your time in that position you were involved in a live trial on Horizon; is that correct?

Donald Grey: Yes. Some of my officers were actually involved in the early part of Horizon but not right at the outset.

Ms Kennedy: What was your experience of that like?

Donald Grey: It was very much a business-as-usual role in many respects. This was a slightly different take on what we were normally doing in post offices. But clearly there were issues that we had to monitor there to make sure that we were supporting the team in actually rolling out Horizon and learning from the opportunity that this trial gave us.

Ms Kennedy: Did you feel that it was a positive, negative experience or neutral?

Donald Grey: I think it was mixed. I think there was general acceptance that it was an opportunity to modernise the business, but it didn’t come without its problems.

Ms Kennedy: Is that the feedback that you were receiving from subpostmasters at that time?

Donald Grey: Yes, indeed. Yes, it was fairly positive but there were some things that really needed to change to make things better.

Ms Kennedy: In summer 1999 you undertook a project to improve the efficiency of the branch office network; is that right?

Donald Grey: That’s right. That lasted for a few months, yes.

Ms Kennedy: What did that involve?

Donald Grey: It was really working with the unions to try and find a way of reducing the costs that the branch office network was incurring for the business.

Ms Kennedy: In January 2000 you were appointed as Horizon National Roll Out Project Manager. Can you tell us a bit about that role?

Donald Grey: Well, in that particular role I was not responsible for the whole of the Horizon project but just for the preparation, the training and the installation across the network. Others were responsible for the live environment, contract management, software acceptance and business assurance and other aspects.

Ms Kennedy: Then in July 2001 you moved to lead the Business Service Management function; is that right?

Donald Grey: Yes, that’s when the Horizon national rollout project had effectively finished.

Ms Kennedy: What did that role involve?

Donald Grey: That was lead on the provision of supplies and support to the Post Office network, and it included supply management of internal Post Office partners, such as Cashco stores and customer management, as well as the ICL Horizon Helpdesk.

Ms Kennedy: You then retired in March 2003; is that right?

Donald Grey: Yes. It’s the best job I’ve ever had.

Ms Kennedy: When you took over, going back to the role of Horizon National Roll Out Project Manager, did you have a handover from David Miller and his team?

Donald Grey: Not that I recall. I did have quite a lot of discussions with people who were involved in the project directly at that point in time, but I don’t recall any direct discussion with Dave Miller himself.

Ms Kennedy: What did those discussions involve?

Donald Grey: It was really an update on what the situation was to date, because I had been out of the scene as far as Horizon was concerned for a few months and, of course, there was a lot happening at that point in time before the system had been accepted and national rollout could continue.

Ms Kennedy: Were you ever made aware of the project mentors’ report?

Donald Grey: Sorry, the what?

Ms Kennedy: Project mentors’ report. Have you ever heard of it?

Donald Grey: It doesn’t ring any bells, sorry.

Ms Kennedy: When you took over in January 2000, were you aware of any problems with EPOSS or the Electronic Point of Sale?

Donald Grey: Not directly. I knew there were certain Acceptance Incidents that had been the subject of discussion between the Post Office and ICL but not specifically about EPOSS.

Ms Kennedy: If we could turn up the first document, please. That’s POL00090457 – it should come up on your screen in a moment – we can see here that this is an email and you’re on the distribution list. I think you’re halfway down. This is an email from Jonathan Rogers and if we turn over to page 3, we can see that this is a BSM – so that’s a Business Service Management snapshot report. We can see that this is a report setting out issues with cash account balances on Wednesday, 21 July from two live trial outlets. Looking beside the second 9, it says:

“Offices reported losses and gains three of which may have been migration errors”, and it sets out the figures of total loss discrepancy and total gain discrepancy.

Before you took over your role you had received emails setting out that there were issues with discrepancies in terms of cash account balancing; is that right?

Donald Grey: I don’t recall that in fairness, no.

Ms Kennedy: Did you receive a lot of emails like this at the time?

Donald Grey: I can’t recall a number, but it was quite common that we were kept in the loop about things that were happening.

Ms Kennedy: That document can come down, please.

If we could turn up POL00028463, this is another email from September 1999 – so again before you took over as the project manager – and we can again see your name midway through the distribution list. It’s an email from, I think, Keith Hardie which we can see if we turn over to page 2 and looking at that first paragraph. It says:

“As you know, we have been going through the acceptance process for Horizon, while ICL work on some technical issues that emerged during the trial. I am pleased to say progress has been made on these issues and, as a result, we have now been able to agree to installing the equipment in a further 336 offices from 20 September, on top of the 150 offices we had already agreed to. This will bring the total number of offices in the trial to some 810, and I will update you on further news as it is available. Please feel free to communicate this information to your teams if they want an update on the latest position.”

If we scroll down, we can see that you’re given a public line about the reasons for this and if we look at the 5th bullet point, it says:

“If asked about what the issues are, we are going through a difficult phase in the Horizon discussions. As a result it wouldn’t be appropriate for us to discuss the details of the issues publicly, but we are hoping they will be resolved quickly and we will then be able to resume offering the service in all Horizon offices.”

So at this time again there seems to be a lot of discussion about issues that have been identified with the system that you’re being copied into.

Donald Grey: Yes. I think I’d moved off the general manager role at that point, and I was actually doing the branch office efficiency project. So although I was copied into that particular email, it wasn’t of great relevance to me at that point in time.

Ms Kennedy: So did you find that you were being copied in on things that didn’t specifically require your attention at this time?

Donald Grey: I can’t recall, but it wouldn’t surprise me.

Ms Kennedy: Turning forward then to when you take over the role of the project manager in January 2000, if we can turn up NFSP00000261, and if we could turn to page 7. This is the Christmas Horizon Research Report which we’ve turned to a number of times in this Inquiry. It was written by Lorna Green in January 2000. So this is right that time you take over in this role, isn’t it?

Donald Grey: That’s right, yes.

Ms Kennedy: If we turn to page 9, this gives the results of the telephone interviews. As it sets out in the introduction:

“This report gives the results of 330 telephone interviews with staff and agents whose offices have taken part in the Horizon roll out in the autumn of 1999. In these interviews they were asked their opinion on different aspects of the Horizon System, and various types of support available (including manuals and Helpdesks) and their overall satisfaction with the automation programme.”

Under Results and Conclusions, it says:

“Results on almost all aspects of Horizon are mixed. Some staff and subpostmasters are getting to grips with the system and are happy and satisfied while others are struggling and continuously having problems. There are no obvious pattern by office type, IP area, number of counter positions or the length of time since migration.

“However where comparisons have been possible, these results are more favourable than the results from the live trial … last June.”

Looking at the next paragraph, it says:

“The main message coming through is that they are not getting enough training. They are mainly happy with what the one-and-a-half days they received, but the training on balancing is not long enough for their needs.”

Scrolling down to the bottom of that page, it says:

“The other area for concern is Helpdesks. There is confusion over which number to call, which is compounded by them being passed back and forth between Helpdesks. There is a problem getting through to the Horizon system Helpdesk in particular and the service from both appears to be lacking in terms of consistency and … knowledge.”

So there were big issues from the very beginning of your tenure about training and the Helpdesk; is that right?

Donald Grey: Yes, yes, and it’s perhaps not surprising that these situations happened because everybody was learning at the same time as we introduced Horizon into the business.

Ms Kennedy: If we turn to page 13 of that report, the objectives of the report are set out and the objectives of the research. It says:

“The objective of the research was to evaluate how these 1856 offices have found the Horizon System, in order to identify any potential problems before national roll out commences. The major aspects of Horizon were to be covered, including the various types of support available.”

Did you understand or did you speak to anyone before this report was commissioned?

Donald Grey: No, because it had been commissioned and completed before I actually joined the project.

Ms Kennedy: Did you know anything about why this research was done? Were there any particular concerns that people were aware of prior to its commission?

Donald Grey: I suspect there may have been, but this report was really good background information. It gives a benchmark on which to build and to actually identify any issues that were current and needed attention, and there were a number of actions which ensued from this report to actually improve things for everyone.

Ms Kennedy: Turning to page 15, we can see the results of training there. It says:

“Opinion was split on the training with 50 per cent saying that the training was good and 50 per cent saying it was poor. This was similar to the results from the live trial research except that this time there are more respondents in the very poor category.”

So this is really quite concerning, isn’t it, the feedback that you were getting about training at this stage?

Donald Grey: It was and, as a consequence, there were a number of steps that were taken to improve the situation.

Ms Kennedy: Turning over to page 16 and scrolling down, looking at Balancing, it says:

“Nearly a fifth of respondents are finding balancing using Horizon very difficult and a further quarter, 24 per cent, are finding it fairly difficult.”

So balancing again there’s a is a big problem, isn’t it?

Donald Grey: Yes.

Ms Kennedy: Turning to page 20 – it might be helpful to go back over the page to page 19 – and scrolling down, please, this is to do with Helpdesks. It records there’s some confusion over which Helpdesk to call which has deteriorated since the live trial. Back over to page 20, it seems 59 per cent are satisfied with the Helpdesk to some extent.

So again this is quite negative feedback, isn’t it?

Donald Grey: It was and it perhaps supported the fact that one of the Acceptance Incidents that was being debated before I joined the project was related to the performance of the Horizon System Helpdesk.

Ms Kennedy: Turning to page 26, please, and scrolling down, it summarises the conclusions:

“Results on almost all aspects of Horizon are mixed. Some staff and subpostmasters getting to grips with the system are happy and satisfied but others are struggling and continuously having problems.”

Again, the third paragraph, the main message is coming through that they are not getting enough training.

So when you got this report, what did you decide to do in light of it?

Donald Grey: Well, some steps had already been taken. For example, in the second supplementary agreement, there’d been a move to increase the training by providing a user-awareness event, some two to four weeks before they actually went through training itself. This was to really introduce learning as a process rather than as an event, and it became a gradual introduction to Horizon. Beyond that, there were improvements made in the balancing process. We diverted more staff to actually supporting offices during the rollout period and in the weeks thereafter, and we introduced a balancing guide as well which, again, was another tool to actually making balancing easier for them.

As a consequence, we actually took the score from what was 19 per cent on ease of balancing in the live trial right up to 90 per cent within 12 months.

Ms Kennedy: If we could turn to the next document, please, which is POL00028441, this is an email from the author of the report and we can see in the second paragraph of her email, she says:

“I strongly recommend that you take time to browse through the staff and subpostmasters’ own words as it provides insight into their strength of feeling about various aspects of Horizon.”

Was that message heard by you and other people in the Post Office?

Donald Grey: Absolutely. I mean, we didn’t go around with our eyes and ears shut. We were very alert to feedback like this because it was so important to us in trying to get things right.

Ms Kennedy: Turning to 20 January 2000, if we could pick up POL00028509, this is an email from 20 January. This was shortly after you started in the post; is that right?

Donald Grey: That’s right, it is.

Ms Kennedy: And we can see you’re on the distribution list and this is from a Dick Brazear. Then if we can turn over the page, these are the notes of a Horizon Pathway delivery meeting on 14 January and, if we can scroll down, please, it says at paragraph 2:

“Dave Smith summarised the key areas which were at issue for the continuation of roll out on 24 January. These were: the rectification of outstanding data integrity weaknesses, AI 376/3; the clarification and resolution of weaknesses in Helpdesk performance, AI 408/3; the resolution of issues with the management of reference data, and the satisfactory deployment and operation of integrity control.

“He identified that for each of these areas there was now an agreed way forward and that robust checks had been in place to address the original concerns. However there were still further checks to be completed by TIP on the deployment of the integrity control. Further work also needed to be done between Horizon Commercial and ICL Pathway on reaching contractual agreement on the third supplemental agreement.”

So there you are being made aware of the issues with the system and potential data integrity issues, aren’t you?

Donald Grey: Yes.

Ms Kennedy: At this –

Donald Grey: We had those before as well, because they had been part of the communications that I’d received when I was in the regional general manager post.

Ms Kennedy: So, when you were deciding what to do in relation to training, especially in respect of balancing, did you ever think: well, hold on a second, maybe there’s something going wrong with the system rather than subpostmasters not being able to balance properly?

Donald Grey: In fairness, it wasn’t my role to engage with that particular problem. This was a business assurance problem and it was for others to track that and identify it.

Ms Kennedy: So –

Donald Grey: Clearly we had to know about it because we didn’t want to be rolling out a defective system, and at no time did we think we were doing so.

Ms Kennedy: But you didn’t feel it was your role to escalate concerns; that was for someone else?

Donald Grey: No, because I didn’t see those concerns directly. So, as I say, it was for others to pursue those.

Ms Kennedy: That document can come down now.

If we could turn up NFSP00000348, please, this is a letter to the NFSP, the head of the NFSP, Mr Colin Baker, on 1 February 2000, so again shortly after you took up the role. How did you find working with Colin Baker of the NFSP?

Donald Grey: Fine. I had absolutely no problem. We knew each other in the past and we were both very positive about what we were trying to do. Colin was very forthright, like so many others in the Federation of Subpostmasters, but we were always constructive in the way that we tried to resolve things.

Ms Kennedy: Did you find dealing with the NFSP helpful?

Donald Grey: Indeed. I mean, we couldn’t have done this project without their involvement.

Ms Kennedy: If we could look, turning back to the document, if we could scroll down to the second paragraph, it says:

“Since we paused roll out in November we have taken a number of improvements to build on past experiences and provide the robust arrangements we would all like to see to support a programme of around 300 outlets a week coming on stream. I note that Dave Smith has outlined most of these in his letter on 31 January, so I will not repeat here. Suffice to say, if you need more detail on any of these, please let me know.

“Hopefully these improvements will have an evidenced beneficial effect and tackle the problems identified in the pre-Christmas research that was done via 335 telephone interviews with staff and agents who were involved in Horizon roll out during last autumn.”

Picking it further down the paragraph:

“The research also showed [this is the fourth line from the bottom] that many more would like more training and balancing is still difficult for too many. Certainly we will need to continue to monitor the position as we go through the programme and respond to prevailing requirements as appropriate.”

Turning over the page and scrolling down, we can see that there are a number of issues raised about the Helpdesk, and then there are a number of specific issues that have previously been raised by the NFSP; is that right? You can see those at (a) to(e).

Donald Grey: Yes.

Ms Kennedy: Did you feel at this time when you first took over the role the NFSP were raising a lot of problems with the system with you?

Donald Grey: They were raising a lot of problems with rollout rather than the system as such, in fairness.

Ms Kennedy: What problems were they raising about rollout? Are they recorded here?

Donald Grey: Well, for example, item (b) there is about training and that was about scheduling of training, I suspect.

Ms Kennedy: Rather than the quality of the training itself?

Donald Grey: At that point, yes.

Ms Kennedy: Did anyone at the NFSP ever raise any data integrity issues with you?

Donald Grey: Not that I recall, no, because that would have been proper to have dealt with Business Service Management on that one, or transaction processing.

Ms Kennedy: That document can come down, please.

Turning forward slightly, if we could turn up NFSP 00000287 and if we could – thank you. We’ve got an email from a Mike Ingle on 3 February 2000 to you and this concerns losses at Waterloo Road. Who was Mike Ingle?

Donald Grey: Mike Ingle was the retail network manager in the Leeds cluster, and he worked for me when I was regional general manager in the north-east.

Ms Kennedy: Actually, if we just read what this is about, it says:

“The losses at this office were discussed at a review and authorised under our normal procedure for dealing with eight-week requests. From memory two of the losses totalling about 1,100 were known to be awaiting an error notice, and authority to hold these beyond 8 weeks was given. The large loss for about £3,000 was the subject of frequent discussions with the subpostmaster who could not accept that this was a genuine error and not down to Horizon.”

Then picking it up again on the final paragraph, it says:

“It is debatable as to whether this was due to operator error or a glitch in the system. There is no evidence either way. The net result is that most of this large loss was accounted for.”

Why was Mike Ingle bringing this to you?

Donald Grey: I suspect he was responding to an invitation which I issued to everybody that I dealt with, to actually flag up any issues that were of concern to them. There was a recognised route for doing so via the Business Service Management team, but I was also interested in knowing if there were any issues out there. So anything I could do to encourage feedback I did so.

Ms Kennedy: You said a moment ago that you were nothing to do with the system itself. So why were you taking issues or, you know, hearing feedback in relation to the system? Did you not clearly delineate those with the people you were speaking to?

Donald Grey: I was happy for them to come to me, but I always made sure that they were fed into service management so that they could process them in the normal way of things. It certainly was important that we encouraged people to tell us whenever there were suspected issues out there.

Ms Kennedy: Do you remember receiving this email?

Donald Grey: I don’t remember it, to be – in fairness, because, I mean, I must have received a number at the time and it is a long time ago. But it struck a chord when I read it.

Ms Kennedy: Do you remember receiving any other emails like this?

Donald Grey: Oh, I’m sure I did, but I couldn’t begin to tell you what they were at this point in time.

Ms Kennedy: Are there emails about the integrity of the system as opposed to the performance of rollout? Do you think there may have been others?

Donald Grey: There may have been others. As regards what the subject was, I don’t know. The important thing was that we wanted people to share with us any concerns they had, whether it was rollout, whether it was system issues or whatever, because we wanted to get this thing right. The integrity of the business really depended on us doing so.

Ms Kennedy: I appreciate you can’t remember, but what do you think you would have done with an email like this?

Donald Grey: With an email like this, I would have probably passed it to one of my team to follow through, one, to make sure it was on the Business Service Management radar and was being followed to solution and, secondly, to make sure that there was sort of some feedback down the line as well. But the important thing was that we had processes in place which were actually there, designed to actually tackle problems like this whenever they were flagged up to us.

Ms Kennedy: Moving forward to May 2000, if we could turn up FUJ00075726, this is a diary note of the National Federation of Subpostmasters Annual Conference. Did you attend many events with the NFSP?

Donald Grey: Yes, I did do. I mean, not necessarily on a national scale but perhaps on a more local scale. I think this was probably the only time I spoke to their national conference.

Ms Kennedy: Were you the person of contact in relation to the Horizon rollout at Post Office for the NFSP at this time?

Donald Grey: It seemed to be so, yes, yes. I mean, they were encouraged to speak to others in the team and not just to me. It wasn’t a one-man band by any means, and I had four regional teams across the country, so there was many contacts at regional level between the Federation and my team.

Ms Kennedy: Then would those teams then feed back any issues to you? Would they kind of filter up to you as the head of it?

Donald Grey: Sure, if they were relevant to do so. Some of them perhaps could have been sorted out at their level.

Ms Kennedy: Turning back to the document, if we could turn over to page 2 and scrolling down, and down again, we can see that you gave a presentation at this meeting. Do you remember that presentation?

Donald Grey: To be honest with you, I’d forgotten all about the event altogether until Alan Johnson gave his testimony a few weeks ago, but I have seen the transcript of the speech I gave which is the subject of another paper that you sent me.

Ms Kennedy: What can you tell us about this presentation? What was the purpose of giving it?

Donald Grey: The purpose was to give an update on where we were, to give some positive messages, to recognise that there were problems, and to assure them that we were actually dealing with them, but to put it in the context of how important Horizon was for the benefit of the business and subpostmasters.

Ms Kennedy: What was the atmosphere like in your mind at this meeting?

Donald Grey: Well, we started off on a fairly jovial note, and there were some hard-hitting questions as well. I mean, it was quite a relaxed sort of session but, at the same point in time, some very serious business went on.

Ms Kennedy: We can see in bullet point form the presentation that you gave there on the page and, if we turn over, we can see “Training”, and under Training you:

“Reported that postmasters wish to extend managers course to the two days. However, Post Office believe this is not the case. For Don [that’s you] having spoken to postmasters personally during site visits and even the night before, no-one could state why they needed the extra time.”

Do you remember saying words to that effect?

Donald Grey: Well, not entirely, no, but what I would point out – that this is a Fujitsu or ICL version of what I actually said. It would be far more accurate to actually have a look at what I said to the conference, which is the subject of another paper. I think it’s NFSP 00000436 from memory.

Ms Kennedy: But sticking with your memory – we may turn that up in due course – did you feel like subpostmasters were asking for extra time and that this was unnecessary?

Donald Grey: No, I didn’t. No, I mean, I understood the concerns, and we addressed those concerns in what we’d actually put in place earlier in that year.

Ms Kennedy: Turning down to the bottom of the page, you mentioned some of the serious issues that were being raised, and we can see here on the Q and A session, it says:

“When Leeds and Wakefield went live, 44 outlets, they were all promised support officers. 17 did not show, which caused major problems in the first week of balancing. Why offer or promise something and then not delivery?”

Then number 2:

“Mid-Glamorgan is due to go live in June. Two points for reference. Phone call regarding training received before letter, and how to write four letters before receiving confirmation about installation date. Fault is bad communication.”

Third, two points:

“Helpdesk don’t know the answer to questions when the phone is answered, which is not very often, usually just rings and rings, and management of training is appalling. Trainers know nothing about running a post office.”

Turning over the page, we can see some further issues there. How confident did you feel with dealing with some of these concerns that were raised?

Donald Grey: Well, I didn’t duck any of them. Clearly I didn’t know all the detail as well as those who were raising the issues, but it wasn’t surprising that there were problems across the project given the scale of it, and I’m not surprised that some of these things happened.

Ms Kennedy: Turning forward again slightly in time to 18 May 2000, NFSP

Sir Wyn Williams: Before we do that, could you just remind me whose diary note is this?

Ms Kennedy: This diary note is from Fujitsu. We can find that out.

Sir Wyn Williams: Yes. I’d like to know who it was exactly who made this diary note if I could.

Ms Kennedy: Yes. We’ll find that out. Thank you, sir.

Moving on to NFSP 00000332, in this email you’re copied into an email about polling problems. Do you remember what polling problems were?

Donald Grey: Indeed, yes. These were problems when the ICL server couldn’t in fact collect information from the Riposte message store in outlets for it to be then processed by back-end systems and client systems.

Ms Kennedy: How concerned were you about this as a problem?

Donald Grey: I was concerned about it, and it was the subject of discussions that we had with ICL ourselves, even before this problem manifested itself – on this occasion that is. It was a big problem in the sense, particularly with clients who – sorry, customers rather who had actually paid bills and whose record that they’d actually paid that bill was not then being processed by the appropriate client.

Ms Kennedy: It sets out in this letter what the Federation would like to see, if we scroll down. Is this an instance of Colin Baker raising something urgently with you to investigate?

Donald Grey: No, this wasn’t raised with me directly. This was raised by somebody else.

Ms Kennedy: And then copied in to you?

Donald Grey: And then copied in to me, yes.

Ms Kennedy: Is this the kind of thing you would have taken forward?

Donald Grey: Absolutely. We couldn’t have let this one pass by because of the significance of it.

Ms Kennedy: In this email, it mentions the NBSC. We’re coming to the NBSC but can you explain what that was and what your view of the NBSC was.

Donald Grey: The NBSC was the call centre that handled calls from Post Office outlets around transactions and accounting, and any issue which they identified was something that constituted a problem they would create an incident on. These incidents would be then passed to the Business Service Management team who looked after service management issues for them to pursue to a conclusion.

Ms Kennedy: If we could take that document down, please.

During that year of 2000, there was also the development of a software update of the CSR+ release. Could you tell us about that software release, please.

Donald Grey: This is the first major release since I joined the project, and it was designed to improve functionality on a number of matters, for example, smartcards, Quantum gas, links with a logistic (unclear) service and a number of other things, but it also importantly actually reduced the rollover time between cash accounts where was a big thorn in the side of postmasters.

Ms Kennedy: Did you feel like the release was being rolled out or developed quite soon after the project itself was rolled out? Did you have any concerns about how quickly it was being introduced?

Donald Grey: Not really, no. I was more concerned about doing it alongside rollout and also to ensure that it was done properly as well. There was quite a bit of information that had to be digested by subpostmasters, and that was the subject of some training breaks and workbooks.

Ms Kennedy: If we could turn up NFSP00000301, please, this is a letter that you wrote to the NFSP on 3 August 2000, Scrolling down, and under the first heading it says:

“The roll out of Horizon continues to progress well and is currently ahead of schedule. The development of our next software release, CSR+, has also been progressing well against a very stretching plan. This release extends Horizon to include Smartcard capability, a link to distribution systems to enable improved provisioning of cash and stock and significant upgrades to the infrastructure to improve system manageability and security.

“A process of reviewing the outputs of testing and the readiness of both Post Office Network and ICL Pathway to begin a trial of CSR+ in 300 outlets has just been concluded. The objective of the process was to ensure that the software release could be introduced into the business without compromising our day to day operations. Now that Horizon is live in more than half the network, the process is particularly critical.”

Did you feel that you were being put under pressure or there was pressure to roll out this additional release?

Donald Grey: Well, there was obviously pressure of sorts because this was different to the standard work that we were doing. So we had to make sure that it was right and rolled out properly so that there was no compromise to what we were doing.

Ms Kennedy: If we scroll down again it says:

“ICL have identified a number of outstanding faults related to infrastructure enhancements that could create significant problems in the live environment if CSR+ was introduced without them being fixed. They have advised that the start of the pilot should be postponed. We are fully in agreement with this recommendation.”

If we could take that document down and move forward to NFSP00000327. So this is a short time later and, scrolling down again, is this usual for there to have been this much correspondence between yourself and the NFSP at this time?

Donald Grey: It was quite appropriate. I can’t remember the frequency of how much we were in touch. I mean, we spoke a lot by telephone as well as in person. So it wasn’t out the ordinary, but it’s quite appropriate to keep people informed of what’s happening.

Ms Kennedy: Picking it up, it says:

“Since writing to you earlier today we have held our meeting with ICL Pathway to review readiness to begin the pilot on the new software release, CSR+.

“We have taken the decision to proceed with the date centre migration next weekend subject to confirmation from ICL that they have robust plans in place to fix an intermittent problem around preservation of data when swapping faulty kit out on some multi-position counter terminals, and no new issues emerging in remaining tests next week.”

Surely it’s better to have those safeguards in place first before deciding to continue with the release; would you accept that?

Donald Grey: Yes.

Ms Kennedy: Do you feel like this was or this symbolises really the release being pushed through too quickly, or did you feel that this was appropriate?

Donald Grey: No, it wasn’t. I mean, there were certain safeguards there that we wanted to ensure before we agreed for it to go ahead, and that’s in effect what this is saying.

Ms Kennedy: Chair, now may be an appropriate time for a short break.

Sir Wyn Williams: Yes, that’s fine.

Ms Kennedy: 11.00?

Sir Wyn Williams: Yes, certainly. Thanks.

(10.44 am)

(A short break)

(11.00 am)

Ms Kennedy: Good morning, Chair.

Mr Grey, if we could pick up NFSP00000318, thank you, this is a letter dated 25 August 2000 that you sent to subpostmasters I think is that right?

Donald Grey: I believe so, yes.

Ms Kennedy: Did you often write directly to subpostmasters?

Donald Grey: No, no.

Ms Kennedy: Was the reason you were writing subpostmasters in this instance because of the big changes that were going to happen and the big requirements of them?

Donald Grey: That’s right. It was a very significant development, and we needed everybody to be on board with it.

Ms Kennedy: If we scroll down that letter, it says:

“As you may be aware, we are shortly to undertake the next Horizon software release known as CSR+. An inherent change in this release is to make improvements in cash remittances for the benefit of the business and users. The enclosed training package is essential reading to prepare you for these changes and explain the link submission the logistic feeder service.

“As a subpostmaster or office manager, you must complete the whole workbook in advance of the upgrade being released. You will be advised of your upgrade date during the three weeks prior to the event. Please allow two hours for the workbook activity. Once your office has been upgraded, the workbook contains activities which can be undertaken in training mode to consolidate your learning and you will need to allow yourself time to practice these.”

Looking down to the fourth paragraph:

“When training consolidation has taken place please complete and return the enclosed free post addressed response card to confirm that all training, including training briefs 27 and 28 which you will receive separately, have been undertaken by all concerned in your office. This is a mandatory requirement to confirm that all post offices are prepared for this change. The completed card must be returned within five working days of your upgrade.”

So this is a significant change, as you have already said. Did you feel like you were asking a lot of subpostmasters to adapt to this changing computer system?

Donald Grey: No, we didn’t think we were asking a lot of them, but it was important that we actually had them properly prepared for the change, and that’s the significance of this letter.

Ms Kennedy: Did you feel that the Post Office equipped subpostmasters well for this big change?

Donald Grey: Yes. I don’t think there was any great feedback to the contrary.

Ms Kennedy: How did you ascertain whether or not people felt prepared for this change?

Donald Grey: Really by feedback that we actually received by general means, either through the NBSC Helpdesk or by feedback on outlet visits and contacts with NFSP reps.

Ms Kennedy: So you didn’t decide to conduct another research report at this time?

Donald Grey: We did about this point in time, because there was some the further research done in the autumn of 2000. Unfortunately I haven’t been able to see that research other than by referencing to other documents, but I’m not sure that that research was done as a consequence of the CSR+ release. I think it was probably more just ongoing work to make sure we were on the right track.

Ms Kennedy: If we could turn forward to 6 September and it’s POL00104602 and if we look that bottom email, this is an email from you to a group of people including Keith Baines and it attaches an initial draft of the NRO close down report.

If we look over the page to page 2, we can see that this is your kind of draft report. What is this report and how did it come about?

Donald Grey: This is an essential part of ending a particular project to make sure that there’s a proper handover to enable any incomplete work to be conducted by others, and to make sure that the full requirements of the project have actually been fulfilled.

Ms Kennedy: If we turn over to page 5, we can see what you have just said reflected in the introduction:

“The completion of the national roll out of Horizon gives us the opportunity to take stock of achievements and experiences and provide a means of transferring incomplete activity to other functions. This process covers the work to wrap up the project, primarily to prepare input to the project board to obtain its confirmation that the project may close.”

If we scroll down, Outputs, it says:

“The outputs from this paper will be a high-level plan which will define the steps that the NRO project board and management team must undertake to formally close the project.”

Under Project Closure, it says:

“To confirm that the project has delivered what was expected, the NRO project board will be asked to verify that first the Horizon implementation activity is complete and meets needs of the business; second, the satisfactory arrangements exist for the transfer of residual responsibilities to other business units, all project issues are closed or transferred to other functions to follow up [and turning over the page] all relevant project information is secured and archived or handed on as applicable to permit any future audit of the project’s actions and performance; all involved or interested parties are aware that the project is to be closed and resources disbanded.”

Scrolling down a bit further, it says:

“The project manager has responsibility for the process and will maintain a regular dialogue with the project board to ensure there will be no problems with its confirmation of the project closure.

“The key criteria to be applied are:

“Have all the elements of the project initiation document been delivered, subject to any changes that may have been approved during the project life-cycle?

“Are any deviations from the project initiation document addressed in the project close-down report?

“Is the project board still prepared to accept the project closure?

“When appropriate, are any deviations reflected in the follow-on action recommendations?

“Are the project board satisfied that any outstanding project issues have been baton passed to others to pursue?

“Have gaining business units formally agreed to the transfer of residual responsibilities and signalled their readiness to accept the work?

“Are the project resources and support services not being transferred elsewhere no longer required?

“Are there any contractual implications when decommissioning the project?”

So in your mind was this you setting everything up so that it can be assessed whether or not the criteria have been met by the project board?

Donald Grey: Yes.

Ms Kennedy: Who were on the project board? Who would be evaluating whether these things had been completed?

Donald Grey: To be honest, that escapes me now. I just can’t recall that information.

Ms Kennedy: Would it have been someone around your level? Would it have been a different team?

Donald Grey: No, I suspect it was probably director level which was one rung above me on the ladder.

Ms Kennedy: Did you feel at the time that those people would have been qualified to make those calls?

Donald Grey: Yes.

Ms Kennedy: Turning forward to 21 September 2000, NFSP00000299, this is another letter from you to the NFSP. If we look at the first paragraph it says:

“Thank you for your letter of 15 September about Horizon installation activity during December. Whilst I can fully appreciate the sensitivity of this issue I was surprised by the tone given the discussions we have had in recent weeks.”

Was this a time where relationship with the NFSP was fraught or difficult?

Donald Grey: No, I don’t think so. I can’t remember what the letter said on 15 September but, no, I would never describe the situation with the Federation as fraught. We used to speak our minds, but we were always very positive in the way that we tackled issues.

Ms Kennedy: Turning then to 5 October 2000, if we could turn up NFSP00000289, this is an update that you provided to Mr Baker. If we can scroll down, looking at national roll out progress and if we can look that training:

“Training over 60,000 people has not been without its problems. Course scheduling and occupancy levels have been major issues with ICL Pathway over the recent months. Happily their administration of user training events is now within acceptable bounds, but we now find ourselves in the position of training fewer people yet needing more courses than the contract provides for. To address the gap we have developed a number of initiatives including allocating seven delegates to some courses, redistributing training costs including making more prudent use of user awareness events and extending the training window to 10 days before installation. The extension of the distance limit to 25 miles will also have a beneficial effect.”

Did you feel like you had to do the impossible or do a very difficult task in carrying out this training?

Donald Grey: In this particular aspect of the training, yes, because we’re getting towards the end of the project, having completed the first sweep over the country, and we were now faced with a situation where the problems with scheduling the events in the past had caught up with us. So we had to take some actions which we didn’t want to take but had to take to get through the project within the terms of the agreement with ICL.

Ms Kennedy: What was morale like in your team at that time?

Donald Grey: The morale in the team was always good. It was a good team. They were a cheerful bunch, they were very much a can-do bunch, and we just got on and did it.

Ms Kennedy: Turning over to page 2, scrolling down, under Live Environment:

“Helpdesk Performance – although there have been some blips as a result of recent incidents, such as the instruction of the Inland Revenue working families tax credit facility, there has been an improvement on both Network Business Support Centre [the NBSC] and Horizon System Helpdesk performance. The introduction of interactive voice response on the HSH on the two busiest days of the week, namely Wednesday and Thursday, was well received though it did impair the percentage calls answered under 20 seconds as a consequence of the duration of the recorded message. This facility was introduced as a temporary expedient and is to be withdrawn next week now that all HSH operators are fully effective. Average number of weekly calls per outlet to HSH is currently 1.17 compared to 1.4 for the NBSC, which in itself is 5 per cent lower than the regional helpline internal calls. NBSC are now achieving almost all their call handling performance in all dimensions; the latest time to answer performance is 8 seconds with over 75 per cent of calls now being resolved by the initial call handler.”

At this stage did you feel like Helpdesk performance was improving or had improved, and were you happy with it?

Donald Grey: It had improved. We were always watching the performance of the Horizon System Helpdesk particularly, because that had been a problem for some time, and we needed to make sure that it didn’t deteriorate. By comparison, the NBSC at 8 seconds to answer calls was very much gold standard by comparison with call centres these days.

Ms Kennedy: Turning on to page 4, please, it says “Staff and Subpostmaster Feedback”:

“The latest research across a sample of staff and subpostmasters some two or three months after migration to Horizon indicates a better feel-good factor across the network. 94 per cent find the system easy to use, 80 per cent say user training is good and 90 per cent find balancing easier. Results show a significant positive movement on live trial and encouraging improvements on previous research in December 1999. Not surprisingly, subpostmasters find transactions easier than balancing to master. After an intense training course they need time for familiarisation with the system in their own environment. Other feedback from outlet visits, Helpdesk calls and other communications (eg the subpostmaster journal) echoes this feedback.”

So at this time were you happy with the way that that feedback had tracked and that it had become more positive?

Donald Grey: Indeed. I mean, this sort of vindicated the actions we took at the beginning of that year to get results like this and, in fairness, when you look at those kind of percentages, I mean, there would be many retailers these days, if that was about their products, they’d be very satisfied with the situation.

Ms Kennedy: Do you feel that issues with training might have masked data integrity issues? People thought that training issues or Helpdesk problems were the cause of the problem but, in fact, with hindsight it may have been data integrity?

Donald Grey: I don’t know. I don’t feel I’m qualified to answer that particular question.

Ms Kennedy: Is it fair to say at this time in October 2000 you were assuming that the system wasn’t causing balancing problems?

Donald Grey: I wasn’t aware of any balancing problems that were significant and that would cause any particular problem to the project, to the subpostmasters or staff who were involved.

Ms Kennedy: If we could turn up the next document –

Sir Wyn Williams: Sorry, Ms Kennedy, just so that I’m not thinking a false point, could you go back a page, please, on that document.

It’s at the bottom of that page 3. No, sorry, I seem to have – can you start at the … yes, that’s it. “Cash accounts”. Do you see that paragraph which appears to be highlighted? What I wondered was this. If you read that paragraph to yourself, Mr Grey, you’ll see the last sentence in particular:

“The level of errors on Horizon continues to fall but is still not returned to pre-Horizon levels”, and that relates to cash accounts.

I wondered if you could explain to me what that relates to so that I don’t have any misunderstanding of it.

Donald Grey: Indeed. Are we talking specifically about the last sentence, or would you like an explanation about the –

Sir Wyn Williams: The whole paragraph, please, but obviously in the context of that sentence.

Donald Grey: Right. In terms of the unclaimed payments on charge and receipts, these are discrepancies which have been identified and are awaiting error notices.

Sir Wyn Williams: Yes.

Donald Grey: And there were fewer of these in the automated system, as one would expect. In fact, that’s a benefit of automation. In terms of the authorised shortages, these would be amounts which were held in suspense pending further investigation, probably by the transaction processing team in Chesterfield, when the cash accounts were received by them and they were able to match the cash account with the associated documents and correct any problems.

Now, it’s quite conceivable that there will be more or those, because the retail network managers were giving subpostmasters the benefit of the doubt and putting the items into suspense to give the opportunity for these to be properly investigated.

Sir Wyn Williams: Right.

Donald Grey: In terms of the level of errors, I’m not quite clear what I was referring to there, but clearly I’ve had some information where I’ve actually compared it with what happened before.

Sir Wyn Williams: I mean, an interpretation of it is simply that there are user errors on Horizon which are greater than the user errors had been prior to Horizon. But it’s also possible that that is an acknowledgement that there are system errors on Horizon, and I wondered if you could help me with that. Then, secondly, the second part of the sentence:

“An analysis of root causes has led to a number of remedial actions being taken.”

I mean, what were the root causes, and what were the remedial actions?

Donald Grey: I cannot tell you what they are at this point in time.

Sir Wyn Williams: All right.

Donald Grey: But Business Service Management had the responsibility for actually identifying the issues, analysing them and trying to put things right where there was an identified cause. I don’t think the level of errors is anything to worry about unduly. I think that is just a reflection of the fact that there were problems in the system as people got to grips with it. I was not aware of any system errors, so I don’t think that is any undue concern at that particular point in time.

Sir Wyn Williams: All right. Thank you. Sorry, Ms Kennedy. I just wanted to be as clear as I could be about what that paragraph meant.

Ms Kennedy: Thank you, Chair.

If we could turn up the next document then, POL00104482, and this is from April 2001. This is a report that you wrote; is that right?

Donald Grey: Yes.

Ms Kennedy: It’s called the Project Implementation Review Horizon National Roll Out. What was the purpose of writing this report?

Donald Grey: This was really to prepare for the close down of the project, which was a few months away when this was done, and this was a draft document to prepare us for that eventuality.

Ms Kennedy: How did you feel about the project at the time of writing this report? Did you think it had been a success?

Donald Grey: I did, yes. I know it had been accompanied by various problems, but all in all I think the achievement of everybody involved, including subpostmasters, was one that reflected with credit on them.

Ms Kennedy: In this report you go through a number of issues or themes to do with the system. I wonder if we could turn up page 2, please, and scroll down and down again, please.

So at 2.2:

“Satisfactory roll out of Horizon to all outlets taking remedial action to secure business performance by initiating or developing policies/frameworks appropriate.”

So what was this about? What was this heading analysing; do you remember?

Donald Grey: Not specifically. No, this, I think, was just to make sure we could maintain the business having rolled out Horizon to the outlets.

Ms Kennedy: If we go over the page and we look at the first full bullet point, it says:

“The absence of a coherent and robust outlet in product reference system was evident at various times during the project.”

Do you remember what that means or meant?

Donald Grey: Yes, that’s related to the nature of the outlets. Each sub-post office was quite unique. There were no or very rarely two sub-post offices that were identical and what that was relating to was some kind registry, if you like, or what each office looked like and what facilities it had.

Ms Kennedy: If we could turn over to page 5, please, and scroll down, please. You have got “Performance Operational”, and then scrolling down again, please, “Performance Technical”. So were those divided in between the operation of the system on the ground and then technically the detail that’s kind of in the back office or on the computer system itself?

Donald Grey: Sorry, I’m not clear.

Ms Kennedy: What is the difference between performance operational and performance technical?

Donald Grey: Right. Well, operational would be what actually happened out in the field. Technical would be the system and the way it was put together and rolled out.

Ms Kennedy: If we look at Performance Technical, it says:

“Technical oversight and validation of ICL Pathway activities was almost non-existent compared with the preceding live trial and development phase. Although this was not really a problem, it is an area that should not be overlooked either in the Horizon maintenance phase or in future projects.”

What did you mean by that?

Donald Grey: I think that relates to the fact that it had changed from being a sort of a three-party project to a two-party project, and it became a much more commercial contract arrangement, and there wasn’t the same kind of sharing that actually went on when it was a combined project.

Ms Kennedy: Did you feel it would have been helpful if things had stayed the way that they were; it was more co-operative?

Donald Grey: No, I’m not suggesting it should have carried on as they were, but I think there was certainly scope for improved co-operation between ourselves and Pathway. The relationship with ICL was constructive and cordial, but there were times when we felt that we weren’t treated as a valued customer and being given all the information that we felt we had a right to know about.

Ms Kennedy: What information was that that you felt you didn’t have?

Donald Grey: Well, it related to particular problems. There were times when we felt we might be being fobbed off, that there was – either for cultural, commercial or other reasons, we weren’t being told all the information that we should really have been given.

Ms Kennedy: If we turn on to page 6, please, and scrolling down we have “Recommendations”, “Supplier Issues” and, looking at the first bullet point, it says:

“The project understandably for its size and nature had a heavy contractual overlay. Despite best endeavours to establish open, constructive, customer-focused and forward-looking relationships with ICL Pathway directors, we did not succeed in mirroring the relationships which existed at working level. Consequently, consideration ought to be given in similar supplier-dominated projects in future as to how we can secure commercial benefit via a more creative, constructive and less restrained joint working or partnership arrangement at all levels so that both parties secure a win-win position.”

The second bullet point:

“We should never again put ourselves in the position of dependence on either a sole supplier (or, indeed, supplier-dominated project progress information) without first establishing a defined and adequate contingency. At the outset we should assure customer pre-eminence with any future supplier who must commit to identify, agree and deliver to our requirements, including detailed performance metrics and integrated reporting structures. Furthermore, any future supplier must empower their local field teams to mirror the responsibilities we invest in our people.”

So what are you saying there?

Donald Grey: Effectively we’re saying that the customer has got to come first, and we’ve got to make sure that any contractual arrangement we have with any future supplier has got to recognise that, and we build the project around it.

Ms Kennedy: What about the first line:

“We should never again put ourselves in the position of dependence on either a sole supplier …”

So what’s the learning point from dependence on a sole supplier?

Donald Grey: Well, in a sense, because of history on this particular project we were left with effectively no alternative but to go with ICL, and maybe what should have been a preferable route is to have competitive tendering.

Ms Kennedy: Could you turn over to page 8 of that document and scroll down, please. Under “Training”, it says:

“All training courses and training content to go undergo more in-depth development and quality checks prior to delivery to ensure user comfort. Training should be viewed as a process rather than event and ensure it caters for different learning pace, styles and requirements. A one-size-fits-all approach is not always appropriate, especially if an established learning environment does not exist.”

Were you disappointed with the level of training when you first came on board versus by the end of this, after all your efforts?

Donald Grey: I think perhaps it hadn’t been given the attention that perhaps it had deserved but in fairness there was a lot of other issues going on at the same point in time. But, in fairness, we rescued the situation and, whilst there might have been some hiccups along the way, I think we got through pretty well despite.

Ms Kennedy: Even in light of these problems that you flagged in the report, were you optimistic about the continued involvement of ICL going forward?

Donald Grey: I wasn’t particularly optimistic. I mean, it was something that we needed to keep our eye on. Once I got to Business Service Management, it was fairly clear we had to monitor the Horizon System Helpdesk performance on an ongoing basis, because that was still an issue. So we couldn’t take our eye off the ball at all.

Ms Kennedy: Moving forward to 26 November, if we could pull up FUJ00119979. These are the notes of a Horizon Service Review Forum, and we can see there that you were the Chair of this. What was the Horizon Service Review Forum?

Donald Grey: Well, as it says there, in the Purpose towards the bottom of that page, it was to discuss with ICL how they were meeting their performance objectives.

Ms Kennedy: How useful did you find this as a forum?

Donald Grey: To be honest, I’d forgotten we ever had these, but clearly it was a means of actually debating face-to-face the real issues of the day.

Ms Kennedy: How often did these take place; do you remember?

Donald Grey: I think these took place on a monthly basis, though I’ve a feeling about this point in time it actually reduced to two-monthly.

Ms Kennedy: If we turn on to page 2, we can see the notes and we can have the action – we see the action point number the details, date to be completed by, the owner, the actions taken and the action points status. So at these meetings did someone raise an issue, someone made a note of it, and then it was tracked? Is that how that took place?

Donald Grey: Yes.

Ms Kennedy: How were the action points carried forward?

Donald Grey: Well, they were tracked at each meeting. So it was actually being work that was being taken away from the meeting and done offline, so to speak, and the meeting maintained an oversight to make sure that progress was being maintained towards resolution.

Ms Kennedy: Did you find that relationships were good in this forum and that it was useful?

Donald Grey: Yes, I think again there was the issues about the not always sharing information with us but, yes, they were generally useful and, in fairness, I think we got a fair bit done.

There is an example in another document that I’ve seen which relates to the fact that we were working together to have a better service for the post offices by a closer arrangement between the Horizon System Helpdesk and the NBSC.

Ms Kennedy: Turning forward to 1 December 2001, if we could turn up FUJ00120085, this is an ICL document. It’s a customer satisfaction scorecard. So you wouldn’t have seen this at the time, would you?

Donald Grey: Well, I think I must have done because down the bottom there it’s got “Signed by head of BSM”, or there’s space for it anyhow, and I suspect this was something that was actually being pioneered.

Ms Kennedy: So do you remember receiving these on a regular basis and signing them?

Donald Grey: I don’t remember doing so. I don’t know whether this was a prototype which never took off or whether it was something that did in fact become a regular occurrence. I can’t recall honestly.

Ms Kennedy: Turning over to the second page, it says:

“Scorecard quarter ending November 2001”, and it says:

“Don Grey: difficult and thought-provoking exercise. POL comment sometimes reflects ICL Pathway in general.”

Do you have any idea what this is about or do you remember saying this? How would this be recorded?

Donald Grey: Well, this is relating to the score card we’ve just been looking at, and this is what makes me think it might have been a prototype that were actually being suggested by ICL as a means of actually doing on a regular basis. But whether it ever took off regularly, I don’t know.

Ms Kennedy: Did you find it a difficult and thought-provoking exercise?

Donald Grey: I must have done to say that.

Ms Kennedy: If we could then turn up FUJ00080421, this is from 25 September 2002, and this is an agreement about the interaction between the NBSC and the Horizon System Helpdesk. Do you remember how well these two helpline entities were working together at this time?

Donald Grey: Well, I think there is a sense of operating in different silos initially, and this was an attempt to really bring together and to try and make them seamless as far as the post offices were concerned.

Ms Kennedy: So this was produced in recognition of a problem about the fact that two were working in silos and there needed to be greater cooperation?

Donald Grey: Yes, it was more a recognition of an improvement opportunity rather than a problem, I think.

Ms Kennedy: If we turn over to page 7, for example, and scrolling down and down again, please, we can see that the scope of the document is set out:

“How the NBSC and HSH will provide a seamless incident management service to Post Office and agreed POL and Fujitsu Services Pathway Support Groups.”

Looking down that bottom of the page, it says:

“The document defines exceptional event as an event that may cause a 75 per cent increase in call volume and/or is likely to impact the operation of the call management process. Under these circumstances, direct communication will take place between HSH and NBSC.”

Was that the real concern, that both parties should be sharing information on when something is likely to increase call volumes?

Donald Grey: That was one of the issues it was trying to address. The other one was to make sure that people weren’t being passed between call centres unnecessarily.

Ms Kennedy: Was that the feedback that you were receiving at this time, that people were being passed between them?

Donald Grey: No, no, no, but we identified it as the way that we could actually provide a better service together.

Ms Kennedy: If we could turn up page 14, please, we have some diagrams, if we can scroll down. This is the interface between NBSC and HSH. Were these provided to helpline operatives?

Donald Grey: To be honest, I don’t know where these ended up. They were part of this particular document, but I would have expected that they would have been provided to call handlers in a much more understandable way than this document.

Ms Kennedy: By the time you left, how well did you feel these two systems operated co-operating with one another?

Donald Grey: Much better but still scope for improvement.

Ms Kennedy: What did you think that could have been improved?

Donald Grey: There were things that could be improved. I can’t remember what they were specifically, but we could never take our foot off the pedal because we needed to make sure that the performance didn’t falter.

Ms Kennedy: Mr Grey, those are all the questions that I had for you. Chair, do you have any questions at this stage?

Sir Wyn Williams: No, thank you very much, no.

Ms Kennedy: I think Mr Jacobs has some questions, as does Ms Patrick and Mr Henry, starting with Mr Jacobs.

Mr Jacobs: Thank you, sir. Can I just confirm that you can hear me.

Sir Wyn Williams: Yes, I can, yes.

Questioned by Mr Jacobs

Mr Jacobs: Thank you. Mr Grey, good morning. I want to ask you some questions on behalf of the 156 subpostmasters, mistresses, assistants and managers that I represent instructed by Howe+Co and, in particular, some points you make in your statement about the Horizon Helpdesk and the user manual and the Christmas Horizon research Report.

So could we perhaps go to paragraph 4(e) of your statement which deals with the Horizon Helpdesk and that’s at page 7 of 26, WITN05220100.

Just waiting for it on the screen there. So you can see that in that statement you say at the end in relation to the Helpdesk:

“The time to answer and the quality of responses was regularly monitored and improvements were made when required.”

Do you accept that’s what you say about how the Post Office dealt with the Helpdesk?

Donald Grey: Yes.

Mr Jacobs: Now, in your evidence this morning you said, “It was clear that we had to monitor the Horizon System Helpdesk performance as an ongoing issue, so we couldn’t take our eye off the ball at all.” Is that right?

Donald Grey: Mm-hm.

Mr Jacobs: Did you listen to the evidence that was given by subpostmasters in Phase 1 of this Inquiry from February to May 2022?

Donald Grey: No, I haven’t.

Mr Jacobs: I wanted to put to you some of what the subpostmasters whose evidence was uncontested said about the Helpdesk in this Inquiry. We’ve looked at 102 of our clients’ statements. 50 of them gave evidence live, the rest were read into the record. 88 of our clients gave evidence that Horizon staff were incompetent.

Is that something that you knew about, that that was the general view about Helpdesk staff?

Donald Grey: No, not at all. I think we need to distinguish between the two Helpdesks. The Network Business Support Centre I would not describe as incompetent, nor would I do so for the Horizon System Helpdesk. There were resourcing issues and scheduling issues at the Horizon System Helpdesk at certain points in time, and they were addressed after we made some challenges to get them to improve their service.

At what point in time are we actually talking about with those statements a matter of interest?

Mr Jacobs: Throughout the course of the scandal, from rollout through to the litigation, a wide variety of time ranges.

Donald Grey: Right. Well, I’m talking about the time I was actually with the project and with the Business Service Management which ended in early 2003.

Mr Jacobs: Yes, of course, and of course –

Donald Grey: I can’t say.

Mr Jacobs: You can only give evidence from what you experienced. So, in the time that you were involved, our clients, 18 of them say that, when they eventually got through to the helpline, the people who were supposed to be helping them were just reading from a script. Is that something that you are aware of, a complaint that you received?

Donald Grey: It’s not a complaint. I mean, call handlers do work from scripts, and that’s very important to make sure that there’s consistency of message.

Mr Jacobs: Did you see the scripts that the call handlers were working from?

Donald Grey: I must have seen them at some point in time, but I wasn’t involved in vetting them and making sure they were fit for purpose. That was the responsibility of others in the team.

Mr Jacobs: Can you describe what the scripts looked like, what the format was, from the ones that you saw?

Donald Grey: Not from memory I can’t, no.

Mr Jacobs: One of the issues that subpostmasters have raised, 39 of our clients say they were told, expressly told, that they were the only person experiencing problems with the Horizon System. Now, that’s a theme that emerged from the evidence, and we say it can’t be a coincidence.

Are you aware that there was anything to that effect within the scripts themselves?

Donald Grey: Not that I am aware of, and I wouldn’t be too happy about that message actually being given out. Do we know which Helpdesk we’re talking about?

Mr Jacobs: This is the Horizon Helpdesk.

Donald Grey: Right, this is the ICL one?

Mr Jacobs: Yes.

Donald Grey: Right.

Mr Jacobs: 36 of our clients were told, “You have to pay the shortfall because under your contract you are bound to do so.” Is that advice that you recall being given?

Donald Grey: Well, subpostmasters had the responsibility for making good losses – that was part of the contract – and it’s quite conceivable it was something to that effect in the scripts but, as I say, I can’t recall.

Mr Jacobs: If the Inquiry wanted to – and this is a fishing expedition, sir, and I apologise for that – if the Inquiry wanted to find these scripts, do you know who might have them or where they might be located?

Donald Grey: I don’t know where they would be now, but in my day they would be in each of the respective Helpdesks.

Mr Jacobs: You see, our clients say, all of them say, that the Helpdesk service was woeful and that it did not improve. Do you accept that there is a significant disconnect between the uncontested evidence of subpostmasters in this Inquiry, and your evidence that the Post Office monitored it, made sure that there were improvements, and kept their eye on the ball?

Donald Grey: I don’t accept there is that disconnect. I mean, clearly there are people who would not be too happy with the service that may have been provided at various stages in the project, even in basic business-as-usual operations. It’s unfortunate, but those are issues that need to be addressed specifically at the time.

Mr Jacobs: I’m going to move on in a minute, but I just want to take you to your statement again and what you say at paragraph 4.

Sir Wyn Williams: You are very quiet now, Mr Jacobs. Can you address that, please.

Mr Jacobs: Yes, I think that’s a bit closer.

You say at paragraph 4(e):

“The time to answer and the quality of responses was regularly monitored and improvements were made where required.”

In hindsight, in relation to the evidence that this Inquiry has heard and accepted, do you accept that that statement is not correct?

Donald Grey: No, I don’t accept it’s incorrect. We did, in fact, monitor performance of both Helpdesks and we did make improvements.

Mr Jacobs: Well, we’ll move on.

In relation to the user guide or helpbook, you say that the Christmas Research Report said that just over half, that’s 55 per cent, of users found this guide helpful. Not one of our clients –

Donald Grey: Are we talking about the Horizon user guide here?

Mr Jacobs: This is the Horizon user guide or the handbook that you are referring to at 4(f) in your statement:

“All post offices were issued practical user handbook, the Horizon Guide, to explain in some detail Horizon operations and assist their move to the new system.”

It’s that guide I’m referring to.

Donald Grey: Right.

Mr Jacobs: Not one of our clients has said that this guidebook was of any use to them whatsoever. What do you have to say about that?

Donald Grey: Well, there were a number who would prefer to phone the Helpdesk rather than read the guide and that, I think, is also covered in the research.

Mr Jacobs: Do you agree with the benefit of hindsight that the Horizon Christmas Research Report, even though it was relatively negative feedback, nevertheless overstated the usefulness of this guide to subpostmasters when the problems started to materialise?

Donald Grey: No, and I don’t accept that the research report was negative. There was some positive information in there as well, some very really improvement opportunities, but it certainly wasn’t negative in total.

Mr Jacobs: Mr Grey, a large number of my clients and a very large number of subpostmasters were very badly let down by the Helpdesk. Do you have anything that you would like to say to them?

Donald Grey: Well, all I can say is I’m sorry to hear that and, had I known that at the time that I was in charge of the Helpdesks, I would have certainly taken that forward on their behalf.

Mr Jacobs: Finally, a significant number of subpostmasters have said that they were advised by Helpdesk that they were the only ones experiencing problems with the Horizon System. Do you have anything to say to that?

Donald Grey: Again that is not a very helpful comment to make and, had I known that at the time, then that again would have received my attention.

Mr Jacobs: I’m just going to ask if there are any more questions that I have to ask you. No, that’s it, thank you.

Thank you, sir.

Ms Kennedy: Ms Patrick?

Ms Patrick: Thank you. ///

Questioned by Ms Patrick

Ms Patrick: Mr Grey, my name’s Angela Patrick. Can you see and hear me?

Donald Grey: I can indeed, yes.

Ms Patrick: I act for a number of subpostmasters with Mr Moloney KC instructed by Hudgells, and our clients, over 60 of them, were convicted but have since had their convictions quashed. We would like to ask you a few questions about one issue, and I hope you will be glad to hear it’s not about training, and it’s not about the Helpdesk.

Can we look again at the letter that you have been taken to this morning that was sent to you in May 2000. You have seen a lot of documents. I will bring it up so that you can see it. It’s NFSP00000332. If you remember, this was the letter about non-polling. Can you see it now?

Donald Grey: I can, yes.

Ms Patrick: That page is pretty familiar to you because Ms Kennedy has taken you through some of this already and, if you remember, it was about non-polling, which I think you recalled was a significant problem.

Donald Grey: It was a problem – significant perhaps might be going too far but at particular points in time it may have been.

Ms Patrick: I want to look at the second page. If we can turn over, and specifically I want to look at the second paragraph if that could be highlighted for you. If we see there:

“After the meeting this afternoon, I received a phone call from Colin Baker and he tipped me off that the DTI representative at the conference had reported back the problems with polling, and that Alan Johnson, Minister for Competitiveness at the DTI (and responsible for the Post Office) has a asked for a copy of transcript of this part of the conference.”

Now, you said this morning that you were being copied in on a lot of things that really wouldn’t specifically require your attention. Would this, the minister responsible for the Post Office seemingly expressing an interest in or a concern about non-polling, be a significant issue?

Donald Grey: Yes, this coincided with me being at the conference as well and, as I recall, this actually happened while I was either at the conference or in transit from it.

Ms Patrick: This was you essentially being alerted to the minister being aware of these problems, wasn’t it?

Donald Grey: Yes, indeed.

Ms Patrick: It was really something you ought to have been aware of, wasn’t it?

Donald Grey: Yes, indeed, and I was in fact copied in on that correspondence, but what they had actually initiated was an enquiry in my absence to actually identify what had been going on.

Ms Patrick: Can you remember what the Post Office Horizon team did with this information and what happened next?

Donald Grey: I think, if you scroll on in that document or associated document with that, I think there was some indication of what actually happened, that someone had picked this one up and was actually running with it.

Ms Patrick: I think we can see it is – “Can you go back to Colin and reassure him”, and it has a number of bullet points there, but none of them appear to relate to the minister.

Do you know if you contacted the minister or his team?

Donald Grey: I didn’t contact the minister or his team, no, no. I don’t know who had that responsibility, but I wasn’t the only one that was copied in on this letter.

Ms Patrick: Do you know if anybody else in your team may have spoken to him or his team?

Donald Grey: I doubt it but it is possible. Something like this would normally be handled by the public relations people, I suspect.

Ms Patrick: Who was above you in the management line between you and the board at this time?

Donald Grey: Well, David Smith was my boss. He was director of automation and he was actually on the board.

Ms Patrick: I think Stuart Sweetman told us he was director at POCL until November 2001. Is that right?

Donald Grey: Stuart himself, you mean?

Ms Patrick: Stuart Sweetman.

Donald Grey: Yes, Stuart Sweetman was the managing director, as I understand it – I think was his title.

Ms Patrick: You’ve said this morning that you were aware of Mr Johnson giving evidence to the Inquiry. Did you listen to his evidence or did you read it?

Donald Grey: No, I listened to it.

Ms Patrick: Okay. I think, just to refresh your memory, his evidence put briefly was that ministers were really looking to the future for Horizon rather than the technical problems, and he said in his statement:

“No-one was flagging up major concerns. Everyone’s attention was on the new work that Horizon could attract.”

The Inquiry’s seen some examples of is. I’ll bring it up just in case you haven’t seen it. We’ve had it this morning, NFSP0000436, and if we look at the bottom of page 2 in that document, it’s the report of the conference that we’ve been talking about. We can see that there was an address by the minister.

Donald Grey: Yes.

Ms Patrick: We don’t need to look at it all. He talks about his long connection with the Post Office, his admiration for people working for the Post Office, and he describes the institution as “a Methuselah of the public sector”. We don’t need to look at it all – the Inquiry’s seen the evidence before – unless you need to have some of it.

On page 5 he turns to Horizon. I’ll paraphrase. He talks about the Government’s decision to get Horizon back on track, ACT being inevitable, and opportunities for the Post Office in Network Banking and the universal bank. He ends on the Government’s vision, and he talks about the promise of the universal bank, and banks being attracted by the incentive of the Horizon automation platform.

Was that your recollection that ministers, Fujitsu and the Post Office were all at this time all focused first on the opportunities for Horizon?

Donald Grey: That was the bigger picture, but on the ground we were very much focused on making the project work.

Ms Patrick: Yes. For those opportunities to work, first Horizon had to work, didn’t it?

Donald Grey: Indeed.

Ms Patrick: Thank you. I don’t have any other questions for you, Mr Grey.

Ms Kennedy: Mr Henry?

Questioned by Mr Henry

Mr Henry: Hello, Mr Grey. Can you hear, sir?

Donald Grey: I can.

Mr Henry: Good. You’ve already been shown today, so there’s no need for it to be put up on the screen, NFSP00000287. I suggest that it’s apparent from that document that you are trying to drill down and investigate glitches, and you were taken to that document by Ms Kennedy.

But you, of course, were the national roll out manager appointed in January 2000 but, from July 2001, you moved into the BSM function, didn’t you?

Donald Grey: Yes.

Mr Henry: Then of course you retired in March 2003.

Donald Grey: Mm-hm.

Mr Henry: Correct?

Donald Grey: Yes.

Mr Henry: So what I want to sort of try and explore with you is perhaps a change in culture after you left because I’ve been given permission to ask you about events that occurred in 2005. Do you follow?

Donald Grey: Yes.

Mr Henry: Now, you say at various points in your statement – and I’m not going to go to them because you have adopted it – but just for your benefit, sir, and for the Chair’s benefit, your paragraph 10(d) at page 20 of 26 that – and I’m gisting this – BSM would try to resolve issues with root-cause analysis and transparency, good communication, et cetera. You agree that’s what you said?

Donald Grey: Yes.

Mr Henry: Paragraph 11(a), page 21, that bugs, errors and defects they weren’t hidden, they were deal with candour and openness, correct?

Donald Grey: (The witness nodded)

Mr Henry: Then paragraph 13, this is about error reporting, paragraphs 23 to 26, error reporting, essentially there was an open-business culture that people were encouraged to report errors, and errors weren’t being suppressed?

Donald Grey: That’s right.

Mr Henry: Now, sir, have you read – and no criticism if you have not – any of the judgments of Mr Justice Fraser such as the common issues judgment or the Horizon IT judgment?

Donald Grey: No, I haven’t.

Mr Henry: You haven’t. Did it ever come to your attention, directly or indirectly, while you were at the Post Office that subpostmasters were not being told about known errors in the Horizon IT System?

Donald Grey: No. But there was no widespread arrangement to tell subpostmasters but every problem. Where it was important to them, we would actually communicate that to them, but there were times when many of these, if you like, were transparent and not apparent at the outlet level where they were not communicated.

Mr Henry: Where did this no-need-to-know or need-to-know culture originate because it follows, doesn’t it, that somebody is making a judgment about what the end user needs to know about apparent errors in the system?

Donald Grey: Where there was any effect on the users, they were advised about the situation. If it didn’t affect the user, there was no need to know, because there was lots going on in the background about trying to improve issues between ourselves and ICL which had no impact on the local user in terms of them knowing about any potential problems.

Mr Henry: Upon whom were you relying for information about whether this would, to use your words, impact or not affect the end user?

Donald Grey: We were relying on general feedback from the field, from the Helpdesks and from anybody who may have been involved in identifying what the root cause of that particular problem was. There was a long time been a requirement from subpostmasters, that they wanted simpler and fewer messages, and what we didn’t want to do was burden them unnecessarily with communications which had in our view, in the light of the information we received, have any impact on them.

Mr Henry: This is very much, is it not, a sort of patriarchal or patronising approach, in the sense that you are making value judgments about what the children need to know, aren’t you?

Donald Grey: No, I don’t accept that. What we are doing is we are exercising proper judgment and sharing with them as appropriate.

Mr Henry: Can I just ask you to go back to your previous answer to me, because you were saying you were relying on information that was coming in from the field and also the Helpdesk. Do you remember saying that just a short while ago? So it follows that this information that it doesn’t need to be disseminated is coming from among the field, in other words the branches, and also subpostmasters calling the Helpdesk. How could that not affect or potentially affect other postmasters?

Donald Grey: It depends on the nature of the problem. You see, what we’re talking here is quite generally there could be specific problems which were not apparent to subpostmasters which we were actually dealing with ourselves behind the scenes.

Mr Henry: That wouldn’t of course arise from the field or the Helpdesk, would it?

Donald Grey: No, it wouldn’t, but that was one of the other issues that was relevant at the time.

Mr Henry: Just coming back to your immediate last answer, that’s precisely the problem, isn’t it, that postmasters weren’t aware? We’ve seen evidence, for example, of the Helpdesk where – and this was put to Mr Terry Austin, this document. Did you know Terry Austin?

Donald Grey: I don’t know him. I know the name.

Mr Henry: You know the name. Did you have an opportunity to look at his evidence?

Donald Grey: No.

Mr Henry: No. Well, fair enough. Where the Helpdesk is being criticised by Mr Colin Baker because subpostmasters don’t know that these errors are occurring. A number of things are just happening, as it were, without their knowledge, and they are unsighted on these errors.

Donald Grey: Which Helpdesk are we talking about, and what point in time?

Mr Henry: Well, that was not the NBSC; that was the Horizon services Helpdesk.

Donald Grey: Right, which we had no direct responsibility for.

Mr Henry: Of course, but you, being, as it were, the correspondent party, the client, Post Office POCL, you would obviously be very concerned about that, wouldn’t you, or ought to have been?

Donald Grey: Sure, if we were aware of it, yes.

Mr Henry: Can I just ask you this, and this is round about 2000 this document – in fact, it is 2000 – can I just ask you, please, casting your mind back, surely that concern must have been drawn to your attention then?

Donald Grey: I wasn’t aware of it.

Mr Henry: You, of course, were the Horizon National Roll Out Project Manager and you weren’t aware of it?

Donald Grey: But without responsibility for the live environment at that point in time.

Mr Henry: Why, as the National Roll Out Project Manager, did you not have responsibility for the live environment?

Donald Grey: Because that was the responsibility of others. I didn’t have responsibility for all the Horizon project, only for actually the preparation, the training, the installation of the system across the network.

Mr Henry: I see. So with this, as it were, fragmentation of information, with these hermetically-sealed managerial boxes, are you telling the Chair that you did not know about this?

Donald Grey: Yes.

Mr Henry: Do you think that that was an optimal way of rolling out a system?

Donald Grey: Well, it was for others to actually have that responsibility, and it could well be that others knew about it. Clearly, if it had had an impact on the rollout, then I would have liked to have known about it.

Mr Henry: Can I ask you, please, were you aware – and this is both the Horizon Services Helpdesk, so therefore the ICL, but also the NBSC – were you aware that they were advising SPMs to carry on balancing to produce cash accounts in order to roll over; in other words, they couldn’t roll over unless they accepted figures that they disputed?

Donald Grey: I couldn’t answer that question. I wasn’t aware of it, but I have become aware of it having seen some documents and watched the various testimonies to the Inquiry.

Mr Henry: That would have been, in your view, utterly unacceptable, would it not?

Donald Grey: Well, there was a way of actually dealing with situations like this. The amount would have been put into suspense. The account would have been rolled over and that would give more time for the amount in suspense to be properly investigated and reasons found for it.

Mr Henry: Was the suspense function removed from the system during your time at the Post Office or afterwards?

Donald Grey: I think it must have been afterwards. I don’t recall that.

Mr Henry: I see. But anyway without, as it were, offering a solution, I’m just asking you to comment on the problem, and the problem was that they were quite frequently being advised by both HSD and also NBSC to accept and roll over notwithstanding the dispute. I ask you again: that would be wholly irregular, wouldn’t it?

Donald Grey: It would seem to be so, but we had an arrangement where that could have been properly accounted for, and that was established and that should have been followed.

Mr Henry: So it was wholly irregular.

Donald Grey: I wouldn’t like to –

Mr Henry: Why not? Why would you not like to say when you have said that, first of all, that isn’t the right advice and, secondly, there was a potential solution, and that advice that they were given completely ignored that, as you have posited, that potential solution?

Donald Grey: Well, I’m sure you are quite sincere in what you are saying. I would want to find out more information before I could make a statement like that.

Mr Henry: Okay. I’m now going to come to a matter that occurred outside your remit, and I would be very grateful – this document, sir, has been notified to the Post Office, and it’s the evidence of Mr Kelly during the human impact statements on 1 March 2022, and I would like to take it from page 77 of that transcript – page 77 of that transcript, sir, from 1 March.

It was actually in the rule 10 question that we were given permission to ask but, not to worry, I can just go to the gist. Don’t worry about it; I’ll just go to the gist.

This gentleman, sir, long after you had retired, had identified a bug, and it was a bug that would double up; so, in other words, you would enter, let’s say, a £200 British Telecom bill and then the system would think that there were two times £200 British Telecom bills and, similarly, you might put in a £400 deposit, and it would come up as two £400 deposits, and so it would double up deposits and withdrawals and also sometimes liabilities for, let’s say, paying a bill.

Do you follow?

Donald Grey: Yes.

Mr Henry: Now, this gentleman whose –

Donald Grey: Was it a postmaster incidentally?

Mr Henry: This gentleman was a postmaster, but he was also a computer science graduate, and his family had had generations of postmasters, and he just wanted to help his Mum out because she was not particularly well at the time. So he came in and tried to help her out.

He communicated this to both the Post Office helpline and also the Fujitsu helpline, okay; do you follow?

Donald Grey: I do, yes.

Mr Henry: He was told that they were not going to send a memo out to tell people, they were not going to do that, they were just going to let it carry on.

That’s hardly open and transparent, is it?

Donald Grey: I agree.

Mr Henry: Now, if you were in charge then, you would not have let that happen, would you, if that had come to your attention?

Donald Grey: Had I known about it individually, yes.

Mr Henry: Had you known about it – because now I want to explore, from that problem being notified to both the Pathway or Fujitsu at that time Helpdesk and also the Post Office NBSC Helpdesk, how many layers of management were there before it would have got to you, when you were both, first of all, in your role as roll out manager but then head of BSM? How many parts of the hierarchy would it have to ascend before it got to you?

Donald Grey: Probably three or four, but there was a recognised process for dealing with these. An incident like that should have been referred to Business Service Management to actually do an analysis of that particular problem and to issue a solution.

Mr Henry: The upshot of that gentleman’s evidence was that, to his knowledge, no other subpostmasters were alerted to the existence of this bug?

Donald Grey: Well, if he says that, fine. I can’t say what happened after I left the business, though.

Mr Henry: Of course in 2005 you’d been gone for two years, but may I ask you, please, since that time, from information you have read, did you ever become aware of the callendar square bug?

Donald Grey: No.

Mr Henry: You don’t. Well, then I ask you no questions about that. Thank you very, very much, sir, and thank you, sir, for allowing me to ask those questions.

Sir Wyn Williams: So is that all the questions for Mr Grey?

Ms Kennedy: Yes, Chair.

Sir Wyn Williams: Well, thank you very much, Mr Grey, for coming to give oral evidence this morning and answering questions from a number of people. I’m grateful to you.

Donald Grey: Thank you, sir.

Ms Kennedy: Chair, that’s our only witness for today. So we’re back tomorrow at 10 am with Ms Rita Palmer and then Mr Trevor Rollason.

Sir Wyn Williams: Yes, Mr Rollason was due to give evidence today, was he not, but there’s been some difficulty in arranging that? How confident are we that he can give evidence tomorrow, if you know the answer, Ms Kennedy? Sorry to put you on the spot.

Ms Kennedy: Can I put it this way, Chair: reasonably.

Sir Wyn Williams: Reasonably, all right, and the plan is that we start with Ms Palmer and then, because Mr Rollason is remote, he can carry on after she finishes after a suitable break, yes?

Ms Kennedy: Yes, Chair.

Sir Wyn Williams: Thank you. All right then. Until tomorrow, goodbye.

Ms Kennedy: Thank you.

(12.15 pm)

(Adjourned until 10.00 am the following day)