Official hearing page

1 March 2023 – Elizabeth Allaker and Gayle Peacock

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(10.00 am)

Sir Wyn Williams: Mr Stevens, before you start, I understand the transcriber has Covid but feels well enough to transcribe from home. That’s correct, is it?

Mr Stevens: I think so, yes.

Sir Wyn Williams: So in those circumstances, I think we ought to try to stick fairly rigidly to having a break after about an hour.

Mr Stevens: Yes.

Sir Wyn Williams: I also understand, just for everyone to know that if we proceed in that way with having more but shorter breaks, it may be that we won’t need a long lunch break today and that we’ll finish around about 1.30. That’s not a promise to anyone, but that’s apparently how we might proceed. So I’m just letting everyone know. We’ll resume.

Mr Stevens: Thank you, sir. May I call Ms Allaker.

Elizabeth Allaker


Questioned by Mr Stevens

Mr Stevens: Thank you, Ms Allaker, as you know my name is Sam Stevens and I ask questions on behalf of the Inquiry. Please can you state your full name.

Elizabeth Allaker: Full name is Elizabeth Anne Allaker.

Mr Stevens: Thank you for attending the Inquiry today to give evidence and thank you also for providing a written statement to which I would like to turn now. It should be in the bundle of documents in front of you under tab A. For the record, the reference is WITN06200100. Does that statement run to eight pages?

Elizabeth Allaker: It does, yes.

Mr Stevens: On page 6, the last paragraph should be paragraph 50 –

Elizabeth Allaker: Yeah.

Mr Stevens: – and at the bottom should be a signature, is that your signature?

Elizabeth Allaker: It is, yes.

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

Elizabeth Allaker: They are.

Mr Stevens: That statement now stands as evidence in the Inquiry, I will be asking you some questions on that and other matters as well.

Elizabeth Allaker: Okay.

Mr Stevens: Firstly, in terms of background, you held various roles with the Post Office from 1979 to 2001, including as a counter clerk and an auditor?

Elizabeth Allaker: Yes.

Mr Stevens: I think you were an auditor in, is it, 1998?

Elizabeth Allaker: It was thereabouts, yes, I can’t remember the exact date but I think I put what I thought it was in here.

Mr Stevens: Were you an auditor prior to the introduction of Horizon?

Elizabeth Allaker: Yes.

Mr Stevens: Can you recall at that time where the audit team sat in the Post Office, what department?

Elizabeth Allaker: Do you mean whereabouts in the country or in –

Mr Stevens: No, in the corporate structure.

Elizabeth Allaker: I can’t, actually, no.

Mr Stevens: In general terms, as an auditor, when would you be asked to investigate a sub post office?

Elizabeth Allaker: Well, the audit process was routine anyway, so you try to get round as many offices as you could within whatever the timescales were. On top of that, if they thought there was a risk to funds, if something had flagged up anyway that suggested there might be a risk of funds being lost, then we were asked to attend. Also, for robberies and burglaries, following a robbery and a burglary, there was an audit done of the office to see what any –

Mr Stevens: Sorry, Ms Allaker, can we pause there, there’s a problem with the transcript I believe, sir. Sorry.

Sir Wyn Williams: A problem in the sense of it not appearing on our screens here or a problem with the transcriber?

Mr Stevens: I’m just going to check now sir, I’ll just be a moment.

Thank you.

Sir Wyn Williams: It seems to be general consensus it’s working now, yes?

Mr Stevens: Right. But it’s being – I understand it’s being transcribed it’s simply not –

Mr Jacobs: It’s being transcribed because I’ve got it on own my computer. It’s showing on the screens but it’s stopped, it’s frozen on the Inquiry screens.

Sir Wyn Williams: Well, I think I said this on an earlier occasion, if the problem is simply with our screens here, but there is a transcription occurring, I propose to carry on because we can all read the transcription afterwards.

Mr Stevens: I’m grateful, sir.

I’m told we can refresh the screens in about five minutes, so it should be back on within that period.

Sir Wyn Williams: All right, fine.

Mr Stevens: Thank you. Ms Allaker, I apologise for that. You were just talking about burglaries, I believe, when I asked you to pause. Can you continue your answer?

Elizabeth Allaker: Yes, so there would – if there was a robbery or a burglary, the audit team were asked to attend to assess what shortfall there was following the robbery or burglary. There would also be audits done if an office was transferring from one subpostmaster to another. I think that’s probably it. Oh, if the office was being defunded for any reason, perhaps if there’d been – I don’t know what’s an example – a flood or a fire or something like that, then, at that point, often the audit team would be asked to attend then and make sure everything was packed up and checked off before it was defunded, the stock was taken out and cashed.

Mr Stevens: When you said funds at risk earlier, would that include if there was a discrepancy between – a discrepancy in the account?

Elizabeth Allaker: Yes. Yes, that – if something had flagged up somewhere to suggest that there was a discrepancy, yeah.

Mr Stevens: In practical terms, as a matter of practice, what level of discrepancy would it take to trigger an audit like that?

Elizabeth Allaker: Oh, um, I don’t know. I don’t know whether there would be any particular level. I mean, you’d have – probably things would have been checked first to make sure there was no transaction corrections or anything due or there hadn’t been anything else wrong. It wouldn’t always needed to have been a lot, you know, not talking tens of thousands or hundreds of thousands, or anything like that, it could have just been a few hundred or you know, into the thousands. It didn’t have to be an awful lot of money. It was just the fact that there was a discrepancy there that nobody was getting to the bottom of.

Mr Stevens: Pausing there, I want to pause on this issue of shortfalls. The Post Office contracted with subpostmasters from 1994 on the Standard Subpostmaster Contract.

Elizabeth Allaker: Yes.

Mr Stevens: That was modified on occasion. It was – there were then new terms brought in 2011, the Network Transformation Contract. The questions I’m going to ask now concern the earlier contract, the Standard Subpostmaster Contract. Before I confirm to that, the Inquiry has heard evidence that the Post Office worked on the basis that subpostmasters were required to make good any shortfall that arose in the branch accounts?

Elizabeth Allaker: Yes.

Mr Stevens: Would you agree with that?

Elizabeth Allaker: Yes.

Mr Stevens: Was that always the case during your time at the Post Office?

Elizabeth Allaker: Yes.

Mr Stevens: Where did your basis for that position come from?

Elizabeth Allaker: It was always explained that it was because it was a contract for services, then we – you always referred back to the contract and that was quite clearly written in the contract, that any loss, whether it was loss of by the subpostmaster or their assistants, was to be made good by the subpostmaster, if that was the contract that they’d signed. So that was the basis that we work to.

Mr Stevens: If we could bring that contract up, it’s POL00000254 and page 33, please. Clause 12 deals with losses and it says that:

“The subpostmaster is responsible for all losses caused through his own negligence, carelessness or error, and also for all losses caused by the negligence, carelessness or error of his or her assistants. Deficiencies due to such losses must be made good without delay.”

Reading that, would you accept that what a subpostmaster is responsible for here is a loss, where it’s caused by their own negligence, carelessness or error?

Elizabeth Allaker: Yes.

Mr Stevens: That’s – do you accept that’s different from a subpostmaster being responsible for any loss howsoever caused?

Elizabeth Allaker: I can’t think of any other kind of loss that could be caused.

Mr Stevens: Well, if we take in Horizon the example of a discrepancy caused by the computer system itself.

Elizabeth Allaker: Right, yes.

Mr Stevens: Would you accept that that wouldn’t be caused by negligence, carelessness or error of the subpostmaster?

Elizabeth Allaker: Yes.

Mr Stevens: So that can be taken down, thank you. The message and the position that Post Office considered subpostmasters would be responsible – sorry, subpostmasters would be responsible for all losses, you said that came back to the contract, but was there anyone or anyone in management who was reiterating that position, as that was Post Office’s position?

Elizabeth Allaker: Not necessarily. I mean, because that was the contract. I think probably what I should say here is that, while I worked for the Post Office, whichever role I was doing, that that’s the only clause that I remember, and at that point I don’t think I or anyone else had any reason to believe that there could be any other way that a loss was caused. So the fact that the Horizon System could cause a loss just wasn’t even considered.

Mr Stevens: Moving on, after your counter clerk roles, you took a role in 2001. Could you briefly summarise what that was?

Elizabeth Allaker: 2001 …

Mr Stevens: Sorry, for your reference, it’s paragraph 4 of your statement. You say –

Elizabeth Allaker: It was in Darlington area office?

Mr Stevens: Yes.

Elizabeth Allaker: Yes, that was an administration role, so it was pretty much administrating for – there was an area manager and I can’t remember what all the job titles were at that point but there were a number of people that worked from that office, so it was booking appointments, answering enquiries, that kind of thing.

Mr Stevens: In 2012 you became a contract adviser?

Elizabeth Allaker: Yeah.

Mr Stevens: What did that role involve?

Elizabeth Allaker: That involved managing contractual enquiries, it could have involved interviewing subpostmasters.

Mr Stevens: What would you have interviewed them about?

Elizabeth Allaker: Well, if there’d been a discrepancy at audit for which they’d been precautionarily suspended, I could have interviewed them for that. It could have been in touch with them about sickness, if they needed holiday substitution, that kind of enquiries, that used to come through.

Mr Stevens: So on the interviews, in respect of – it may be interviews in respect of discrepancies?

Elizabeth Allaker: Yeah.

Mr Stevens: You said earlier that you, during this period considered that Horizon couldn’t cause discrepancies.

Elizabeth Allaker: Yeah.

Mr Stevens: Was that a general view held by contract advisers, to the best of your knowledge?

Elizabeth Allaker: It would have been, yes, because my assumption, and I presume everybody else’s, was that although things didn’t always run smoothly in Horizon. There was always some way of recovering or fallbacks to make sure that anything that had gone wrong was put right. So, yes, I would imagine that that would be the case, without speaking for everybody else, but yes.

Mr Stevens: As a contract adviser, were you ever – did you ever encounter a subpostmaster saying “This discrepancy, I believe it’s been caused by the Horizon IT System”?

Elizabeth Allaker: No. Not directly, and certainly not during the period that I was a contract adviser.

Later, down the line, then, yes, they did start to be people who questioned that, if they did have a loss. Not to me directly but I had heard of that being asked, yes.

Mr Stevens: If, as a contract adviser, you – someone had said that to you directly, what would your response have been?

Elizabeth Allaker: I would have – I probably would have done my best to try to make them understand that it wasn’t possible, that, you know, that whatever had gone wrong we’d investigate it and there was no way that it could be the Horizon System because of all the assurances that we got.

Mr Stevens: You say all the assurances you got, can you just expand on that, please?

Elizabeth Allaker: Well, we’ve always been of the impression that anything that did go wrong with Horizon, that somewhere in the background, it was put right. If it had got to the point where a branch had a loss, they would receive a transaction correction for it, or if a branch had a loss that they couldn’t explain, there was an option to put it into the suspense account sometimes to see if a transaction correction came back later down the line.

But any investigation had never – or any, you know, looking into losses, had never thrown up anything to do with the Horizon System having caused the loss, so I presume that, you know, we all just trusted what we were told and that a loss couldn’t be caused by the system itself.

Mr Stevens: Who gave you those assurances?

Elizabeth Allaker: I don’t know whether it was just generally everybody said the same thing. I don’t know that we necessarily even looked at anybody for assurance. It was just that if that came up ever, that’s what we knew: that it must have been mentioned at some point but I cannot honestly point to one person and say they did.

Mr Stevens: As a contract adviser, were you involved in intervention visits?

Elizabeth Allaker: Going out to a branch myself at that point, no, I don’t think I was. I was involved in – I was involved in intervention visits prior to that, I think. Possibly during my time in the area office. I think I would be asked to help out and go out and visit a branch for – it could have been a robbery or a burglary.

Mr Stevens: Did you ever go out for an intervention visit because of a subpostmaster was requesting additional training?

Elizabeth Allaker: No. No.

Mr Stevens: Did you attend an intervention visit to investigate the cause of a discrepancy?

Elizabeth Allaker: Not, I don’t think, during my time as a contract adviser. Only during my time at Audit – in the audit team, I think.

Mr Stevens: So 1998, pre-Horizon?

Elizabeth Allaker: Yeah, yeah.

Mr Stevens: I want to move on in the chronology to October 2013. Please could we bring up POL00043370. This is an attendance note for a meeting on 9 October 2013, it’s on Bond Dickinson headed paper. Are you aware of Bond Dickinson’s role in relation to the Post Office?

Elizabeth Allaker: Yes.

Mr Stevens: And that is?

Elizabeth Allaker: Bond Dickinson were legal representation for the Post Office.

Mr Stevens: We see in the attendance list there are “Legal”, Rodric Williams, head of Post Office legal, was he, at that point?

Elizabeth Allaker: Mm-hm.

Mr Stevens: Martin Smith of Cartwright King. Do you recall his role?

Elizabeth Allaker: I don’t recall his role, no.

Mr Stevens: We see at “Network”, you’re in attendance –

Elizabeth Allaker: Yeah.

Mr Stevens: – and Gayle Peacock as well –

Elizabeth Allaker: Yeah.

Mr Stevens: – Nick Beal. For the NBSC, it says that you’re there on behalf of Kendra Dickinson?

Elizabeth Allaker: Yeah.

Mr Stevens: At this stage in 2013, were you involved with the NBSC?

Elizabeth Allaker: Yes, I used to work quite closely with the NBSC, to try – well, try and make improvements to the way the structure was and to make improvements to – I can’t remember at that point whether the Branch Support Team was still there, but I sort of linked between the two of the teams, the Branch Support Team if they were still there then, they were still part of the Network teams.

Mr Stevens: We’ll come on to that in a moment but, in broad terms, yes involved –

Elizabeth Allaker: Yes.

Mr Stevens: – but as a sort of oversight of what could be improved, rather than taking calls yourself?

Elizabeth Allaker: Yes.

Mr Stevens: If we could just go down on this attendance note to see, it refers to a number of issues in branches, which we don’t need to go into detail, but my question is: what was the purpose of this meeting?

Elizabeth Allaker: I think would this be one of the meetings that were held – I don’t know whether it was monthly – to try to just make sure that anything that was coming in on – that was referenced to the Horizon System or any losses, or anything like that, that they’d had – they didn’t overlap with anything that was going on with the Inquiry? Had the Inquiry started by this point?

Mr Stevens: Not at this stage. There was a Second Sight, this was around the time when Second Sight was –

Elizabeth Allaker: So it would be to make sure – that’s probably what I’m thinking of, then – that we didn’t overlap with any of the cases that were going on in Second Sight and that also were starting to take any learnings from cases that came up to make sure that, if there was things falling through the net anyway, that we were more likely to pick them up. Whether it was to do with the Horizon or looking at this, some of it was more general things anyway.

Mr Stevens: So these were operational issues, discrepancies and the like –

Elizabeth Allaker: Yeah.

Mr Stevens: – which were being discussed in a context with legal representatives at the Post Office –

Elizabeth Allaker: Yes.

Mr Stevens: Do you recall what the – what sort of issues the legal team were interested in?

Elizabeth Allaker: Um, not in detail, no. I mean, if I hadn’t had the documents I would probably have struggled to remember most of the things that were discussed but, looking at some of this, then there was certainly things that, you know, people were starting to say had linked to Horizon then. But, no, not specifics of anything, no.

Mr Stevens: Slightly different question. Do you recall if the legal team gave any advice on operational issues, such as what to do with the loss?

Elizabeth Allaker: Not that I remember. I think their advice was more legally based. But that’s just memory. I’m picking up there.

Mr Stevens: If we can go to a different document, please it’s POL00002276. At the top it says, “Horizon Service Improvements Workshop” and it’s 5 September 2013, so a month before but around the same time as the legal meeting we just saw. Do you recall the purpose of this meeting?

Elizabeth Allaker: Yeah, vaguely. I think this meeting was set up because, by this point, we were starting to get input from – well, the NFSP had mentioned improvements for a number of years and I can’t remember whether we also had the branch user forum set up then, which was a little, small group of subpostmasters who used to attend a meeting quarterly. We’d set that little group up to try to get more input from subpostmasters. They used to go and talk to their own representatives.

So I think the NFSP, the branch user forum and possibly other sources were all saying that there was improvements that they would like to see, and this workshop was to try to kick off some of that with Fujitsu. It was at Bracknell, wasn’t it? Yeah. So it was to try to get them to understand, from the subpostmaster’s point of view, what improvements they wanted going forward.

Mr Stevens: We see there in the attendee list NFSP, Jim Nott, postmaster.

Elizabeth Allaker: Yeah.

Mr Stevens: Do you recall how that postmaster was selected?

Elizabeth Allaker: No, if my memory is correct, there was more than him actually due to attend but, for whatever reason on the day, Jim was the only one that did attend. I don’t know whether there’d been another meeting come up or what had happened, but I’m pretty sure there were other people that were asked on behalf of the NFSP and Jim was the only one that could make it.

Mr Stevens: You’ve mentioned about the NFSP and there being calls for improvements for a while. Can you recall if there was an immediate trigger which caused this meeting to be arranged?

Elizabeth Allaker: Not to my knowledge. Not an immediate trigger.

Mr Stevens: Please can we turn to page 4 and section 1.5. This talks about “Rem Out for End of Day Cheque Processing”. Can you just explain very simply what that is?

Elizabeth Allaker: Yeah, at the end of the day, you used to have to rem your cheques out and a lot of that depended on when the – when your collection was from Royal Mail because they used to have been to be dispatched manually, so you used to have to cut them off and rem them out then, and then I don’t know whether on a balancing day, or – was it every day or just on a balancing day? I’m testing my own memory now – they used to have to be remmed out again or something had to be done, definitely, at balancing.

I think the reason that that one was on the list, for looking at improvements, was because it was a bit of a clunky process, so there seemed to be a number of steps that you could go through and it wasn’t always intuitive, particularly, I suppose, if you were a new subpostmaster. So I think it was there to look at seeing if it could be done any slicker through the system.

Mr Stevens: If we just turn the page, if we can, to the top of the next page, please. It says:

“This is a lengthy process, and unnecessarily runs the report twice. It also increases the potential for the clerk to enter an amount which does not match the report total amount.”

So is what this is saying is that the process increased the risk of discrepancy caused by user error?

Elizabeth Allaker: Yes, it could. Because anywhere that you could just put a number in yourself, there’s always the chance that you’re going to hit a wrong key or, you know, something else could go wrong.

Mr Stevens: If we go down slightly, we see there are some suggested improvements. Do you recall if those were brought in?

Elizabeth Allaker: I can’t, actually, no. I know that we did some more work on that, on the cheque rem out process, but I can’t remember honestly whether improvements did actually come in or not.

Mr Stevens: So things like this, where improvements to make the system easier to use and potentially reduce error, were those findings of where there may be increased risk of user error, were they communicated to anyone in the audit team or the prosecutorial team?

Elizabeth Allaker: Not communicated to, but I would say that the people in the audit team all knew of the processes where – that were a bit clunky, really, that, you know, where it was likely that an error could be, so let’s look there first, to make sure that there’s not anything wrong. So the cheque rem out system would be one of the ones they would look at. They would always look at things like that to make sure that cheques had been remmed out, that they’d been remmed out correctly, et cetera, et cetera.

Mr Stevens: So, in effect, is your evidence that where there were let’s call it design issues, which increased the risk of a user error, the audit team would be well aware of that?

Elizabeth Allaker: I would say so, yes.

Mr Stevens: If we turn to page 6, please, and paragraph 2.4. This relates to “Transaction Correction Print Out”, and it says:

“The postmaster needs to be able to see which Transaction Corrections have been processed and which are outstanding.”

If we can turn the page, the suggested improvement in this case is that:

“This report is already available, and so this improvement is considered to already be present.”

It goes on to discuss revisiting communications on this.

At this stage, were you aware of any subpostmasters who were calling for more access to, say, audit data or transaction data, used by the Horizon IT System?

Elizabeth Allaker: To answer that question I’d probably have to say that, yes, there was always a desire that I’d found from the subpostmasters that I spoke to, that they had improved ways of looking at the system themselves. So whether it was to do with transaction corrections. And I don’t know – when it says “is considered to be already present”, I’m not disputing that.

That opportunity must have – may have been there, but then, clearly, in this case, what we needed to do was recommunicate that here’s a report that you can get. A lot of subpostmasters would want as much information as possible, so would have been asking for – you know, would be asking if they could get a report on X, Y and Z. So, yes.

Mr Stevens: Do you know if that was ever a point of discussion with Fujitsu as to whether that would be a possibility of allowing postmasters access to such data?

Elizabeth Allaker: It was, because I think I have been there when those conversations were had. As a result of this, and then also doing some work on what we ended up calling HORice, which was a tool to investigate certain transactions and reports and things, ultimately, the desire for HORice would have been for subpostmasters to have access to that type of reporting and, I think, at the time, not long before I left, these things were being discussed more often because we were hoping for new technology to be coming in or new systems to be coming in, so that we could get subpostmasters access to more information and it would be more – more of a two-way thing.

Ultimately, what we wanted was for subpostmasters to be able to communicate with us online and I got the impression that that’s what subpostmasters wanted to do as well, and once we’d got to that sort of state, we were hoping that we’d be able to share some of the things that we were starting to build ourselves.

Mr Stevens: I was going to come to HORice later but it makes sense, since you’ve mentioned it now, to go there. HORice is H-O-R-I-C-E, and was that an acronym for something?

Elizabeth Allaker: It was but I can’t remember what it was, if that’s the next question.

Mr Stevens: In paragraph 5 of your statement, you say that you worked on building an enquiry system known as HORice which was to build new reports to try to improve the way information could be obtained from the system to handle enquiries. Presumably the system there is Horizon?

Elizabeth Allaker: Yes.

Mr Stevens: Do you recall when HORice was introduced?

Elizabeth Allaker: No. I can’t. I can’t put a date on it.

Mr Stevens: In broad terms, would it have been earlier or later than, say, 2013?

Elizabeth Allaker: Later, I think.

Mr Stevens: What information was available or stored in HORice?

Elizabeth Allaker: It was all transactional data and report data but it was – what we were trying to do was get reports for things that we hadn’t already had, and I can’t remember – I can’t even tell you what an example would be of one. Just so that if there was a discrepancy or you needed to look for something or you needed to find something more quickly, then you could get a report from this new HORice system that we’d got.

Mr Stevens: So would that include the transaction logs for a particular branch?

Elizabeth Allaker: Well, you could get transaction logs anyway, so subpostmasters did have access to printing off transaction logs, if I remember correctly. But only for a certain length of time, and I think that’s one of the things that we were wanting to change. I don’t know that was directly within HORice. But it was, certainly HORice was asking for stuff to be available for a longer period of time, so that you did have something that you could go back and refer to.

Mr Stevens: What length of time are we talking here?

Elizabeth Allaker: I think HORice was only – the transaction logs were only available in branch, I’m going to say, for a month. Whether that’s right or not I don’t know. If that’s the case, I think we were asking for six months, and possibly even longer than that. Having said that, I think there was – there was going to be a limit to what we could get because of the volume of transactions that went through the system. I don’t know that whatever clouds these things all go to were going to be big enough to hold everything for that length of time.

Mr Stevens: We spoke about transaction logs. Would HORice store things beyond that? So would it include actually just the data in a branch that Horizon used to generate branch accounts?

Elizabeth Allaker: I don’t know. I think what I would say here is that that information was there somewhere, the information that we were asking for in Post Office. So whether it was for the Finance Service Centre, whether it was something that was going to help subpostmasters themselves, whether it was the security team or whoever that was suggesting the types of reports that we were asking to be implemented in HORice, that information was clearly there, otherwise Fujitsu would have said, “We can’t do that because we haven’t got that type of information stored”.

So we were asking for stuff that was there, just either in a better format for a longer period of time or in a different way to allow us to look at our own system.

Mr Stevens: For easier access?

Elizabeth Allaker: Yes.

Mr Stevens: Who was given permission to access HORice?

Elizabeth Allaker: There were only – I think at the time that I left, there were only about 18 licences, if it was that. There was a very small number of licences because I think it was still being trialled.

Mr Stevens: What was the reason for not giving access for subpostmasters to the data relevant to their own branch through HORice?

Elizabeth Allaker: I don’t know. I know that we only had a very small number of licences at that time. Ultimately, discussions were ongoing with Fujitsu to either extend the number of licences or to progress the trial further, but then it was going to be – yeah, I think it was cost after that so it would be, you know, we’ll have to start talking about money for additional licences and how many do you need, and …

Mr Stevens: Moving on from HORice, we’ll go to the Branch Support Programme which I believe you were involved with.

Elizabeth Allaker: Yes.

Mr Stevens: What was your role in that?

Elizabeth Allaker: I’d probably have been doing a number of jobs within the Branch Support Programme. I did use to facilitate the Branch User Forum. Um, I can’t remember any specifics. I did an awful lot of stuff – it was a lot about trying to work with the communication team, work with different parts of the business to try to get, you know, improvements to what we were doing and how we were communicating, so that it was easier for subpostmasters. Just working throughout the business.

Mr Stevens: Let’s take it in stages. Do you remember when this programme started?

Elizabeth Allaker: I can’t remember exactly the date that it started, and because the programmes tended to change names, we did like to have a change of name every now and then and I can’t remember which programme ran into which one now, so sorry.

Mr Stevens: If I suggested around 2013 or ‘14, would that ring true?

Elizabeth Allaker: I wouldn’t be able to argue one way or another.

Mr Stevens: You refer to the Branch User Forum, I understand that is where subpostmasters were invited to provide feedback on the Horizon System and Post Office processes generally.

Elizabeth Allaker: Yeah.

Mr Stevens: How many subpostmasters were involved?

Elizabeth Allaker: In the Branch User Forum?

Mr Stevens: Yes.

Elizabeth Allaker: About six subpostmasters, I think.

Mr Stevens: How were they selected?

Elizabeth Allaker: Um, I think there was – I think it was through the branch focus, the communications team. There was an article went out in that inviting people to apply and then, from the applications, somebody, I don’t know who or how, selected the people that would first use – you first come in on the Branch User Forum but I think it was an annual changeover, so the plan was that it was going to be changed annually and it was people came out and went in.

So you weren’t there indefinitely.

Mr Stevens: Please can we turn to POL00039215. So this is a Branch Support Programme PowerPoint presentation in May 2014. Are you aware of a mediation scheme for subpostmasters who were alleged to have shortfalls caused by like Horizon?

Elizabeth Allaker: I’m aware of it, yes.

Mr Stevens: Were you involved in it?

Elizabeth Allaker: No.

Mr Stevens: Was there any link between the Branch Support Programme and either Second Sight or that Mediation Scheme?

Elizabeth Allaker: The link would be – well, people? I don’t know. I don’t know whether there was any direct link between the people that worked in the Branch Support Programme and the Mediation Scheme. There would – I knew, certainly, the people that worked in the Mediation Scheme. Whether or not they were all part of the Branch Support Programme at the same time or we were all under this same umbrella, I wouldn’t be able to say from memory.

Mr Stevens: Do you know what triggered the Branch Support Programme to be implemented?

Elizabeth Allaker: I think it was probably the ongoing need to have some sort of, I would say, a culture change within Post Office. I think it was more or less along the lines that we weren’t engaging with people as well as we could. It didn’t feel like, at the time, that everybody’s voice could be heard and the Branch Support Programme was probably grown out of that.

Mr Stevens: If we turn to page 3, please – sorry, page 5. No, it was in between. Page 4, sorry.

This refers to – it says one of the issues of the report, which is referring to the interim report of Second Sight – it says the following:

“Lack of timely, accurate and complete information provided to subpostmasters to support them in resolving issues.

“Lack of centralised data or files specific to each branch which hinders a quality investigation from taking place.”

At the bottom we see:

“The investigation undertaken by the Programme highlighted/confirmed the following issues:

“Inconsistent record keeping by internal teams or contact made with branches

“Inconsistent quality of information retained by teams

“Lack of consistent processes or workflows between teams within a process

“Lack of timescales to resolve branch issue, coupled with lack of monitoring of issues

“Inconsistent sense of ‘ownership’ of different issues.”

From this, is it fair to say that the Branch Support Programme wasn’t engaging with subpostmasters on alleged bugs, errors and defects in the Horizon IT System?

Elizabeth Allaker: I think I would say that it’s probably fair to say that no, we weren’t, because bugs, errors and defects were more IT issues. If we’d needed to do anything about that, and I’m not saying that we didn’t because, you know, certainly things did occasionally crop up that were described to me as bugs, errors and defects, that would have been more in Fujitsu’s domain.

Mr Stevens: So outside of your responsibility?

Elizabeth Allaker: Yes, in that it’s not something we would have been able to fix but I suppose, as part of working on HORice and working on the Branch Support Programme, I think it’s probably fair to say that, looking to the future, what we would want is a system, bug, error and defect free, of course, but that’s probably not possible in IT world. So while it wasn’t there on that list, if you like, it would be something in the back of our minds.

Mr Stevens: But I suppose more in terms of the Branch User Forum, which this was involved with, the subpostmasters there, there was no discussion with subpostmasters of branch – sorry, bugs, errors and defects in the context of the Branch User Forum?

Elizabeth Allaker: Not that I recall directly, no.

Mr Stevens: Were you involved in any steps to be taken to address the issues that you identify in this slide?

Elizabeth Allaker: Well, in that, yes, there were number of things that we tried to do within the Branch Support Programme, through either NBSC and Branch Support Team, if they were still around at the time, that would help engage more with subpostmasters. So we did things like we could get reports from NBSC on the number of people that called in to NBSC, what the issues were they called in on. So like which branches called in most often. Which branches didn’t call in at all.

And during the time that the Branch Support Programme ran, and afterwards, we used to make calls to branches from those lists to make sure that, you know, was there anything that we could do to help. So if it was somebody that was ringing in a lot of the time, it was to try to make sure that, if they were new, new subpostmasters, was there any additional help they needed? Was there any more support that we could get them, whether that be through a bit more regular contact from an NBSC adviser or, you know, ultimately we could put a request through perhaps to get a bit more training.

I think we had calls to branches that had never rung in to us at all. So that – because clearly, you know, they were still a valuable part of the Post Office, as far as we were concerned but for years they hadn’t been engaged with, if you like. So they were rung.

Mr Stevens: Shall we look at the NBSC now on that point. If we can turn to POL00090223, which is an email that you sent to Angela van den Bogerd on 6 May 2015. You say you attach a one-pager, it’s actually a two-sided one-pager, on the NBSC employee comments, which we will come to in a moment, it’s feedback. Why were you providing feedback to Angela van den Bogerd at this stage?

Elizabeth Allaker: I don’t know. I think it was this one, all I’d done was pull the information together from my contact with NBSC, who I think that was the – that was where the McKinsey’s feedback had been involved or was referring to. Because I didn’t ever see the McKinsey’s report myself, I’d just heard about it. So I’m guessing, from this, that that all I’d done was pull something together and give it to Angela as a two-pager on something that she’d asked for.

Mr Stevens: Do you recall why she asked for it?

Elizabeth Allaker: I can’t, no.

Mr Stevens: Can we go to the next page, please. We have some comments here and the first one – it says “81 comments in total broken down as follows”:

“Communication – 14 comments. Main theme relates to timely and better communications and also knowledge of what to do when products are launched or when things change or go wrong. This theme was raised with Branch Support Programme and is a theme raised by BUF too.”

“BUF” being?

Elizabeth Allaker: Branch User Forum, yes.

Mr Stevens: So is it fair to say that the feedback you’ve pulled together here was criticising the level of information and communication to the NBSC relating to both changes to Horizon and problems with Horizon?

Elizabeth Allaker: Not necessarily with Horizon, there, no. In fact, I would say probably not with Horizon. It was to do with communications that went out to branches, in the Branch Focus, I think it was called Branch Focus, communication that went out weekly.

NBSC should always have seen – well, I’m saying “always”, there may be things that they didn’t need to see but they should have always had the opportunity to see and comment on the communications that went out to branch before it went out, purely and simply because they were the ones that were going to get the enquiries if the communication wasn’t clear. So they could then, you know, act as the go-between between the Communications Team and subpostmasters, to some extent.

And I think what, from memory, what that would be, would be the advisers in NBSC would be saying, “We’re either not getting them or we’re not getting them quick enough to do something about it” or, you know, maybe “We’ve fed back on this but nobody has picked anything up or not replied to say why they haven’t done anything with our feedback”.

So I think that would be more to do with products and transactions than anything to do with Horizon itself, with the system.

Mr Stevens: And the final sentence says, “AHT”; do you remember what that stands for?

Elizabeth Allaker: Average handling time.

Mr Stevens: So is that the time in which it takes for a member of the team to resolve a call?

Elizabeth Allaker: Yes.

Mr Stevens: So:

“AHT was also raised as an issue by advisers in that they feel they are pressurised to achieve AHT above quality of response to branch.”

Do you recall that being a concern at the NBSC?

Elizabeth Allaker: I recall it being mentioned but I don’t know that that’s a fair comment because I don’t know the context that it was given in.

Mr Stevens: Do you know what the average handle time aim was?

Elizabeth Allaker: No. I’m saying no, I will have heard it in the past, but I can’t remember what it was, and I would imagine that over years, it probably changed anyway, you know, as average handling time it would be if things were improved in NBSC, that if things were quicker for the advisers to get to, then I would imagine that over the years that average handling time would have changed.

Mr Stevens: So in your position, we see that the BUF and the Branch Support Programme looked at the NBSC. Did you have any concerns during that period as to the quality of the advice that the NBSC was able to give to subpostmasters?

Elizabeth Allaker: No.

Mr Stevens: Why not?

Elizabeth Allaker: Because the advice that the NBSC gave to subpostmasters was always given to them so they had a massive Knowledge Base that they could go to, to look at. If – the only thing I would say would have been of concern would have been if there were more than one way that they could get to the answer, for something. So say somebody rang up about Lottery for the sake of picking – and the adviser hadn’t understood exactly what the Lottery question was and had gone into the wrong bit of the Knowledge Base, then that would have been the only thing that would have been a concern. Not the actual – it would be that they’d given the wrong bit of advice for the wrong transaction – for the right transaction, rather than they had any concern about the advice they were given.

What was on the Knowledge Base was right, providing that the advisers went through it to the right bit.

Mr Stevens: Turning to a different topic now, at page 4 of your statement onwards you referring to the Horizon weekly call. Do you remember when this was set up?

Elizabeth Allaker: No.

Mr Stevens: Do you know why it was set up?

Elizabeth Allaker: Yes, again, I think that was the one that was set up so that we weren’t duplicating anything that was going on with the Second Sight branch of –

Mr Stevens: What do you mean “duplicating”?

Elizabeth Allaker: Well, if the branch was in Second Sight or later on, whatever, it went into mediation – I can’t remember exactly what happened when – it was to make sure that we weren’t then trying to do something with that branch that was already going on somewhere else, or if there was an ongoing Inquiry, say within the security team or within the Finance Service Centre, that, you know, they were already aware of, that we weren’t then duplicating something that somebody else was already looking into.

Mr Stevens: Who attended those calls?

Elizabeth Allaker: Horizon weekly call, it would be representatives from Legal, Network, or whatever we were called then, Finance Service Centre, Fujitsu, perhaps Fujitsu, ATOS, by that point as well, and Security, have I mentioned them?

Mr Stevens: Yes.

Elizabeth Allaker: I can’t remember off the top of my head whether there would be anybody else but it was representatives from different parts of Post Office, Fujitsu or ATOS and Legal.

Mr Stevens: Would this call lead to – or lead to action points to be implemented in respect of how subpostmasters, queries or discrepancies needed to be answered?

Elizabeth Allaker: It could, I suppose, if something had cropped up that, you know, say if it had cropped up and it was an action point for me or whoever and somebody else could then answer the question where I couldn’t, then, yes, it would – you know, it would be then used to go back and answer that subpostmaster.

Mr Stevens: Sir, that’s probably a good time to take a break.

Sir Wyn Williams: Certainly. 11.10. Thank you.

(10.59 am)

(A short break)

(11.10 am)

Mr Stevens: Thank you, sir. Please could I bring up POL00002396 and go to page 2. We have an email from Andrew Morley to – well, it’s to the Branch Support Team but we see you pick up the email above, 11 September 2014.

It refers to receiving a call from someone at the branch, and it says:

“He has seen the BBC report concerning the system issues and is claiming that his system is corrupt. He wants all the money pack from previous discrepancies which he has put in so he could balance. He has been to Horizon/ATOS who have checked everything and can find no system issues but he is adamant it’s a system issue.”

Above you say:

“This will be picked up by the Contract Adviser not by an intervention visit.”

Stopping there, can I just ask why that was a contract adviser issue rather than an intervention at this point?

Elizabeth Allaker: I’m guessing that once we’d looked at the branch file on the electronic filing cabinet, that it was something that the contract adviser was already in discussion with this particular subpostmaster about. So again, to avoid duplicating work or avoid NBSC picking up something they didn’t need to, it would be – this was correct for it to go to the contract adviser, the most recent request.

Mr Stevens: Do you recall seeing the BBC report that’s referred to here?

Elizabeth Allaker: I didn’t watch it, no. I remember that it was on but I don’t think I actually watched it.

Mr Stevens: Do you recall any discussion in the Post Office at that point on what that BBC report contained?

Elizabeth Allaker: Um, well, yes. It wouldn’t be fair to say that I didn’t hear anything, but, yes, people were – there was a sort of general what’s going on here, you know. Where’s this coming from. Could any of this be right? But I think we were all still really assured that there was no issue that we need to be worried about.

Mr Stevens: Could we turn to WITN06380101, the email at the bottom, please. It says from Communications Team to Communications Team, and it references “Media coverage on Post Office IT system” on the same day as the previous email we went to:

“You may be aware of some media coverage about the Post Office’s Horizon System, relating to the contents of some confidential documents, and this may prompt questions from postmasters you speak to.

“We are challenging the reporting of this matter as it implies we acknowledge there are systemic faults with Horizon. This absolutely not the case.

“Although we will not comment on the contents of any confidential documents, after two years of investigation it remains the case that there is absolutely no evidence of any systemic issues with the computer system which is used by over 78,000 people across our 11,500 branches and which successfully processes over 6 million transactions every day.”

Do you recall receiving a communication like this?

Elizabeth Allaker: Yes.

Mr Stevens: Was this consistent with the type of messaging or assurances you said you were receiving?

Elizabeth Allaker: Yes.

Mr Stevens: I think your evidence already is you were assured by these sorts of communications?

Elizabeth Allaker: I had absolutely no reason to doubt that, you know, we were doing all the necessary due diligence ourselves and that what we were being told was the case.

Mr Stevens: Do you think that was the same for your colleagues –

Elizabeth Allaker: Yeah.

Mr Stevens: – that they were similarly assured by that?

Elizabeth Allaker: Yes.

Mr Stevens: If you hadn’t received these assurances, do you think that would have changed the way you approached subpostmasters, such as the one we went to before, who were saying, “I’ve got a problem, I think it’s a system issue, look at this BBC report”?

Elizabeth Allaker: Um, I think I would have probably thought a little bit more about it but I still think that, personally, I was quite assured anyway, without being given the reassurance from the Post Office, if you like, because it was a general message that went out. I was quite trustful of the Horizon System anyway, so I don’t know, yes, I would never have doubted that anyone had concerns and I would have done everything I could to alleviate them, but I certainly wouldn’t have been saying “Yes, I think there’s something in what you’re saying here”, because I had no evidence to suggest that there was any.

Mr Stevens: If we go to a different document, please. It’s FUJ00120885. Can we turn to page 3 of that document, please. Thank you. The email at the bottom is from Ian Humphries. Do you recall who he was?

Elizabeth Allaker: Yes.

Mr Stevens: Who was he?

Elizabeth Allaker: He used to work in Service Management, in Post Office Limited, and I think he went across to ATOS.

Mr Stevens: He refers to:

“The Meanwood branch has reported an issue with a Health Lottery transaction that is now preventing the terminal from connecting.

“Fujitsu is requesting for an authorisation for them to remove the Health Lottery [transaction, and then the number] which is preventing successful recovery on counter node 04.”

At this point, what’s your understanding of the problem facing this branch?

Elizabeth Allaker: At this point, if I’d just been reading this, I’d have been wondering exactly what they were talking about. For me, there’s not enough detail there to tell us exactly what’s gone wrong. It might be quite clear to the person looking at it from the other end, I don’t know but I don’t really – I didn’t really understand, then, what the implications of this was, so I didn’t know whether it was having any effect on the branch account, I think, initially.

I wouldn’t have known whether or not the subpostmaster knew anything about it, unless it was one of the ones that had been raised to me by the Branch Support Team, in that they’d got a request through, as well.

Mr Stevens: We see just towards the bottom it says:

“Authorisation is required urgently to enable the postmaster to get the node back online.”

So, in effect, is the Branch Support Team being asked to authorise a deletion of a transaction from the branch accounts?

Elizabeth Allaker: They’d been asked to go to an area manager, who I don’t know what they would mean by an “area manager” at that point, but they’d clearly been asked to – or somebody has been asked to get something authorised to get this – to get the node back online. That’s the, I presume, the counter terminal. So I’m guessing that this would mean that the terminal, that counter position, they wouldn’t be able to use, because of whatever the problem was.

Mr Stevens: If we look at your response at page 2, please. It’s at the bottom. You ask for someone to provide you:

“… with the process that was followed for this type of enquiry prior to Service Integration …”

Elizabeth Allaker: Right.

Mr Stevens: What was “service integration” here?

Elizabeth Allaker: This must have been when Service Management transferred over their work to ATOS. So, for example, Ian and Sharon, there’s another name I remember, Rebecca Barker. They all worked in Service Management but I think they all went across to ATOS, when service integration came in.

Mr Stevens: So those people had dealt with the authorisation before that – they were then TUPE transferred out and is your query now who deals with the authorisation?

Elizabeth Allaker: Yes, but whether or not they’d actually dealt with authorisation before they TUPE’d across, I don’t know. I was just hopping that they would have a process somewhere that would tell me where that sat, because if I’m right I don’t believe that NBSC or Branch Support Team or anybody had a process for sorting out how we will get this back online.

Mr Stevens: If we go to the next page, please, just to finish off. So you say:

“… and who the escalation point(s) were? This type of request has not formerly been managed by the Branch Support Team and if it needs to be embedded into a …”

Is that “business as usual”?

Elizabeth Allaker: Business as usual, yes.

Mr Stevens: “… environment I would prefer to understand the background to the process, where it should sit (based on earlier cases) so that enquiries are dealt with consistently and are fully documented for audit purposes.

“Please provide me with some understanding of how often this happens, root causes, potential solutions, impact to branch/customer and whether there’s any financial implication.”

Are you here asking about the process generally for whenever Fujitsu sought to make amendments to branch accounts?

Elizabeth Allaker: Yes. In – well, I presume that this was – that this issue itself, in this case, hadn’t just come out of the blue, that it wasn’t the first time that it had ever happened. And, even if it was the first time it had ever happened, then surely somebody somewhere would have been able to give me some background and say, “Well, you know, we can’t give you any background on it other than this specific case”. They would have been able to, I presume, give me some sort of root cause, in their words I’ve got used to using, and somebody somewhere would have been able to give us an idea of whether or not there was any impact to the branch as a customer. Because it could be that – if it was a bill – did they say Health Lottery?

Mr Stevens: Health Lottery, yes.

Elizabeth Allaker: In that case, if they’d got that Health Lottery ticket, or whatever it was, was it a prize from the Health Lottery? I don’t know. So were they still out of pocket or was the branch being affected, other than not being able to use that counter terminal, really.

Mr Stevens: Can we go to page 1, please, of this document.

Sir Wyn Williams: Just I think there’s probably a break in the transcription service.

Mr Stevens: Sorry, sir.

Sir Wyn Williams: As I say, provided the transcriber is transcribing, I think in the room we’ll just have to put up with it.

Mr Stevens: Yes, I am told it’s fine.

Sir Wyn Williams: Yes.

Mr Stevens: Thank you.

Here’s an email you sent to Ian Humphries, the second paragraph. You say:

“I’m therefore happy to authorise this session to be deleted so that the kit at the branch can return to BAU state.”

Earlier when you saw the information you had, the transaction detail and what was being required, it’s fair to say that, in terms of the technical aspects of it, you didn’t have a good grasp of that; is that fair?

Elizabeth Allaker: Yes.

Mr Stevens: Did you seek any IT input into whether that was an appropriate decision – appropriate action to take?

Elizabeth Allaker: The IT input then would have come from ATOS. So from Ian or whoever was working on that side of it now in ATOS. That’s where it would have come from and it would have been up to them to go to Fujitsu to get anything more that was needed. We didn’t have, by that point, for day-to-day enquiries, we didn’t have a direct route into Fujitsu, so it was all done through ATOS.

Mr Stevens: Were you responsible for authorising these types of transactions in the future?

Elizabeth Allaker: No, I think at that point, once we’d established that there was no impact to the branch financially or to the customer, that the customer was okay with everything, because there was no clear process and nobody was coming up with one, I think what we did was say, “Right, we’ll authorise it”.

Because it was important for the branch to get that counter position back up and running, (1) so that they had somewhere to serve customers from, if it was – heavens forbid, it wasn’t just a one-position branch, I don’t think. But if it was a two-position branch and they had busy periods, they would clearly need to have that second position up and running. So if that wasn’t up and running correctly, it needed to be, plus they would have to reach a point where they would need to roll that position over properly, I think.

So they would need to be back online to do that, so that information didn’t get lost or fall into the wrong trading period or something like that, whatever could go wrong. So I think what we’ve done is say, “Right, we’ll do this so we can follow the whole thing through and then try and get a BAU process for this, so that we know in future where it needs to go to get authorised”.

Mr Stevens: Right. That BAU process didn’t result in you being the authoriser?

Elizabeth Allaker: No.

Mr Stevens: So is your evidence then that until the ATOS TUPE transfer, there was some sort of process in place for authorising these types of remote access requests. There was then a period of time when there was no BAU process but, after this, something, some procedure was put into place but you weren’t involved with it?

Elizabeth Allaker: Yes, that’s assuming that there had been cases of this beforehand and I still don’t know that I ever got to the bottom of how many of these there was.

Mr Stevens: Right. Please can we bring up FUJ00085864, page 7 of that document, please. This is an email from Katie Austin to Kendra Dickinson and Ibrahim Kizildag, and this refers to what’s now known as the Dalmellington bug or the outreach bug. Is this a fair summary that an outreach service was where there was a core Post Office branch, known as a core branch and there may be a separate sight, an outreach site, which would essentially operate as a satellite for that core post office?

Elizabeth Allaker: Yes, it may have more than one satellite, if you like, but, yes, that’s essentially it.

Mr Stevens: In order to operate those satellite sites, the core branch would rem out cash and stock to the outreach site?

Elizabeth Allaker: Yes.

Mr Stevens: In this case, what’s been described here is a problem where someone would, in this case, rem out £8,000 so that would come out of the core site, so scan that out, go to scan it into the outreach site, but that was duplicated – sorry, it was duplicated several times, so that the outreach site was showing more cash than actually what went across. So in this case, £24,000 rather than £8,000.

Elizabeth Allaker: Yes.

Mr Stevens: Now, if we go up, please – sorry, leave it there for the second, sorry.

We see at the bottom of that explanation that:

“The incident was passed to Fujitsu who have advised that in order to resolve the issue, the branch/NBSC must ‘complete a rem out for the excess to correct the cash holding’ which Fujitsu are unable to do. The NBSC has subsequently advised that they cannot assist as this is an IT issue however Fujitsu are also advising that they cannot assist. As a result, the issue has been passed back and forward for over a week.”

Obviously, this email is 20 October, the issue was raised on 8 October, some 12 days earlier. Do you consider it’s satisfactory for this issue to be bounced between the two teams for 12 days?

Elizabeth Allaker: No.

Mr Stevens: Was this is an issue that regularly happened where subpostmasters’ complaints such as this fell between the cracks?

Elizabeth Allaker: I wouldn’t say regularly, no, and I don’t know, I think this was possibly the first example of this kind of issue that I’d seen. So whether or not, if there’d been any previous ones, at that point I would be wondering what had happened to them beforehand, how, you know, what the cause was, how quickly had they been fixed. What – you know, what the process was to get it sorted out. 12 days, no, because if I’d been the subpostmaster and I was looking at a discrepancy of £24,000, then I’d have been sweating, for 12 days, when really, if it’s a known problem or we can identify what the problem is, it should be easy enough to fix.

Mr Stevens: Is your evidence that this is the first system bug that you were aware of?

Elizabeth Allaker: I don’t know what you mean by system bug.

Mr Stevens: Or a bug in the software system – a bug in the software?

Elizabeth Allaker: Well, possibly it was, yes. I mean, I don’t know whether – I don’t know what the difference is between bugs, glitches and errors, for one. Things that went wrong – I suppose, when things went wrong, if a communication broke down – I’d seen those before where they would end up being a discrepancy, but they were always – you could correct them with fall back and recovery processes. So there would be interruptions to the Horizon System, like there is with your phone or anything else, if you like. Except with the Horizon System, obviously, if that was partway through transaction, then it might freeze something and it would then have to be corrected.

So I’d seen that type of thing and heard of that type of thing happening before but this was the first time that I’d seen it actually cause a shortage like that where they hadn’t really – there was nothing they could do about it, even under fallback and recovery.

Mr Stevens: We can take that document down and move on to another issue in September 2015, so slightly before. Can we bring up POL00002578 and page 4, please. Just for context, at the bottom is the email from Ibrahim Kizildag to the Branch Support Team about Fleckney Post Office, to which we see above you respond?

Elizabeth Allaker: Right.

Mr Stevens: Go down to that email, from Ibrahim Kizildag, please:

“I took a manager call from Fleckney Post Office, branch code is [gives a branch code]. This branch had a Data Centre link error message yesterday evening and PM couldn’t log on to Horizon System this morning. PM said he had a message stated that they are logged on to another SU [stock unit] they only have 2 positions and nobody is logged in. The PM feels that this is a security issue and he said someone could have log on to their system and he is not happy about this message and PM also said he watched Panorama programme and he wants us to escalate this issue. I escalated this issue to Service Desk, if possible can field teams visit this branch regarding this also.”

Your response is at 4:

“The outcome of the call to ATOS is needed before any further action is taken. It might explain what’s happened. Is there a ref number?

There’s a reference to HORice:

“Has HORice user data been checked?

“For info, this may be raised to you if you’re still in contact with Fleckney.

“In brief though the recent comms statements should be used and I’ve no doubt there will be an explanation here that’s nothing to do with Horizon.”

So, again, on what basis did you have no doubt that there was a Horizon issue here?

Elizabeth Allaker: Probably because I’ve ever, ever come across one before and, at that point, I think we could get – you could get reports on who was logged on to Horizon through HORice, I don’t know that we could actually get them anyway. I think there was a user report that you could get off your system and I probably, wrongly, without, you know, knowing all the information and looking at what the postmaster could see myself, assumed that they hadn’t checked to see who was logged on, where and when.

So that’s about as much as I can say on that.

Mr Stevens: In respect of the comms statement, in relation to the Panorama documentary, please could we bring up WITN06380102.

If we could go to the bottom, please. Just up so we can see the date on the email. So it’s Communications Team 14 August 2015, sorry this is below that. From Communications Team, 14 August 2015, to Communications Team, “in the loop – the latest on Panorama”.

Go down, it says:


“I wanted to send a short update on the plans by the BBC’s Panorama to broadcast a programme about the Post Office and its Horizon System on Monday.

“We have spent a great deal of the week dealing with this issue, and making our position clear to the BBC at very senior levels. We do expect, however, that the programme will include a number of unsubstantiated allegations. We have decided against being interviewed as part of the programme and have instead issued a robust statement. This was a very carefully considered decision but the programme wanted us to speak publicly about individual cases and we are not prepared to break the confidentiality commitments we have given about these. Whilst it is difficult to take this position in the face of untrue claims being made in public, we believe it is the right one.”

The next paragraph down says:

“On Monday we will be sending out a note to all Post Office colleagues updating them on the programme. In the meantime, our core points are below. I would welcome your help in ensuring that our key messages are cascaded to colleagues, particularly those who may get questions from customers or postmasters …”

The key points:

“Extremely serious, unsubstantiated allegations about the Post Office and the Horizon System have continued to be repeated over the past few years by a small number of mainly former postmasters.”

It goes on below to say:

“The clear evidence we have in these cases does not support the allegations being made.

“We committed to confidentiality to people who put grievances to us, so we cannot share details about individual cases.

“What we can say is that we do not prosecute people for making innocent mistakes and never have …

“We have demonstrated that Horizon works as it should. It has been shown to be robust and effective in dealing with six million transactions a day, with some 78,000 people using it, and it is regularly audited.”

I’ll leave it there. The rest is in evidence. Was this the messaging you were referring to in that email?

Elizabeth Allaker: It will have been, yes.

Mr Stevens: You were relying on that in respect of how you dealt with enquiries that came into you from subpostmasters?

Elizabeth Allaker: We would. Everybody would have, not just myself. Yes.

Mr Stevens: Thank you, Ms Allaker. I don’t have any further questions for now. Some of the Core Participants may do. Before I do, is there anything else you’d like to say to the Inquiry?

Elizabeth Allaker: No, there’s not.

Mr Stevens: I think Mr Stein has a question.

Questioned by Mr Stein

Mr Stein: Ms Allaker, when Mr Stevens started asking you questions today, he was asking you about your knowledge of the subpostmasters’ contract. I’m going to ask you a question about that. My name is Sam Stein – another Sam – and I represent a large number of subpostmasters and mistresses.

Okay, Mr Stevens referred you to a document which has a Relativity reference of POL00000254. If it is possible, Lawrence, for that to go on the screen, and within that document it’s page 33 on Relativity pagination. This time please, very top of the page, highlighting “Losses” at paragraph 12, if you could expand that and highlight in yellow I would be very grateful. Thank you very much.

So, generally speaking, this is the contractual term that was in place for subpostmasters and mistresses throughout the time of the operation of the Horizon System. It says:

“The Subpostmaster is responsible for all losses caused through his own negligence, carelessness or error …”

That’s the relevant bit you were asked about earlier.

Now, just help us understand a little bit more about what you thought that meant, now meant in terms of who needed to prove negligence, carelessness or error. So there were perhaps two choices. Did the Post Office need to prove that the subpostmaster had been negligent, careless or in error, or was that for the postmaster or mistress to prove that they hadn’t?

Elizabeth Allaker: Probably a little bit of both. If – from my interpretation. Because there was a lot of procedures that you were expected to follow from a security point of view, and so there would be, if you were interviewing somebody, for example, to say, you know, how did this happen, how – what are your general procedures in branch? You would try and make sure that what they were doing was following all the necessary security guidelines, so that access to stock and cash was restricted, that things were locked away appropriately.

So it was up to us to make sure they knew what they were doing and it was up to them to say, “Yes, that’s what we have done”. So I think, in a way, to answer your question, a little bit of both.

Mr Stein: What if the situation was that the subpostmaster couldn’t explain, in other words had no idea where the shortfall came from? Now in that situation, they’re not saying that they are careless, they’re not saying they’re negligent, they’re not saying they’re in error, they’re just saying, “I don’t know”. In that situation, who was it to prove that they had been careless, negligent or in error?

Elizabeth Allaker: In that case, in all honesty, I don’t think you can prove it one way or another. Because if you’ve made a mistake, if you’ve – if something has happened accidentally or even if someone has taken the money and you don’t know anything about it, then in all honesty, you can’t prove anything one way or the other.

So if you’d dropped the money into a postbag or the bin and it had been emptied and gone missing, you don’t know that it’s carelessness, negligence or what’s the last one – error. So I don’t think you can prove it one way or another.

Mr Stein: In a situation whereby the subpostmaster is saying, “Ms Allaker, I really don’t know what’s happened here”, what would be the position from the Post Office? That would still be down to the postmaster or mistress to make good that loss?

Elizabeth Allaker: Yes. Not necessarily all in one lump sum, depending on circumstances, but yes.

Mr Stein: That was the position that was known and operated throughout the team that you worked in and, indeed, you worked within?

Elizabeth Allaker: Yes.

Mr Stein: Excuse me one moment.

Sir, thank you.

Sir Wyn Williams: Anyone else?

Thank you very much for making your witness statement and for coming to give evidence to the Inquiry. I’m grateful to you.

Elizabeth Allaker: Thank you.

Sir Wyn Williams: So no doubt we’ll have a short break while we call another witness, so to speak.

Mr Stevens: I think we need 20 minutes, sir, if that’s okay.

Sir Wyn Williams: All right, fine. 12.05 pm.

Mr Stevens: Thank you, sir.

(11.46 am)

(A short break)

(12.06 pm)

Mr Blake: Thank you, sir. Can we call Gayle Peacock, please.

Gayle Peacock

GAYLE PEACOCK (affirmed).

Questioned by Mr Blake

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

Gayle Peacock: Gayle Anne Peacock.

Mr Blake: Thank you, Ms Peacock. In front of you, you have two bundles, I believe.

Gayle Peacock: Yes.

Mr Blake: Behind one of them, tab A, you have your witness statement. Can I ask you to turn to your witness statement.

Gayle Peacock: Yes.

Mr Blake: Is that statement in front of you dated 31 January of this year?

Gayle Peacock: It is, yes.

Mr Blake: Can I ask you to look at the final page, final substantive page, at page 50. Is that your signature at the bottom?

Gayle Peacock: Yes, it is.

Mr Blake: Is that statement true to the best of your knowledge and belief?

Gayle Peacock: It is.

Mr Blake: Thank you very much. That witness statement is going to go into evidence and it will be published by the Inquiry. For the purpose of the transcript it’s WITN06160100 and the questions I’m going to ask you today are going to be supplementary to that and we will expand on a few areas. I am going to start, though, on your background, which you have detailed in the statement. I just – you’ve been in quite a large number of different areas, a number of different roles, so I’m going to focus on the ones that are relevant for today’s purpose.

Gayle Peacock: Okay.

Mr Blake: You joined the Post Office in 2001 as part of a graduate management trainee scheme; is that right?

Gayle Peacock: It’s correct, yes.

Mr Blake: During that scheme, you used Horizon, I think, when you were seconded to Middlesbrough Post Office?

Gayle Peacock: I did, yes.

Mr Blake: You subsequently held number of positions. I’m going to start with 2006 to 2010, you were the head of network co-ordination. Can you briefly tell us what that involved?

Gayle Peacock: So there was two aspects to the role, really. One was around – they’d set up the outlet intervention team in Maidstone, so this was the escalation point for subpostmaster queries, where they couldn’t get the answer from Network Business Support Centre, anything that couldn’t be answered by the helpline, we had to set that team up to basically deal with those enquiries, so there was that part of the team I managed.

I also managed a team of network co-ordination managers and they interacted mostly with the heads of area and their Retail Line managers to understand some of the issues that branches were facing, whether that be cash management, product and branch accounting, and tried to sort of help postmasters, really.

Mr Blake: Then between 2011 and 2013, you were network conformance standards and policy manager. Can you tell us briefly what that involved?

Gayle Peacock: Yes, so that was – there was a branch standards booklet published, I think, in 2009 and this was basically running the team that would help branches understand how to follow the correct procedures. So I had a team of people that would make telephone interventions to branches, and to talk them about the areas within the booklet. I also had a data team that would look at the results of the different areas, plan the sort of support roles, the intervention the telephone calls.

I had a mails support manager who worked for me, I think, at the time and that was around managing some elements of the Mails Distribution Agreement or some of the complex issues that we had with Royal Mail to resolve. Then I had a multiples service manager and they were responsible for all the conformance elements with the likes of McColls, Co-op, interfacing with those partner groups, really, to drive performance in the areas that we were focusing on with post offices.

Mr Blake: Thank you. 2013 to 2014, head of branch support project. Briefly – we’ll go into it in more detail – but can you tell us what that involved?

Gayle Peacock: Yeah, so I was asked to lead the project on the back of the Second Sight review and some of the issues that were coming – the thematic issues that were part of that review, to really understand what we could do to help postmasters, especially in the likes of training and support, and what we could do differently. So it was really about doing more of a deep dive into some of the themes that were coming out of those spot reviews and the individual cases, and then looking across the business to say “Well, how could we improve things, what would we need to put in place”. That kind of thing, really.

Mr Blake: Finally, between 2015 and 2018 you were head of branch and customer support.

Gayle Peacock: Yeah.

Mr Blake: Now, that was what previously we know as the NBSC; is that right?

Gayle Peacock: It was, yes. Yes, that’s correct.

Mr Blake: You were involved in a number of matters in that role but one of them included managing executive correspondence?

Gayle Peacock: Yes, so that was anybody, it was Members of Parliament, public, postmasters, who would write to the Chief Exec or any member of the Post Office executive team. So it was that team who would get those complaints and manage them, basically, in the business.

Mr Blake: It sounds as though, in broad terms, a lot of your career has focused on support to subpostmasters, whether it be providing that directly or reviewing the support that’s provided to subpostmasters; is that a fair description?

Gayle Peacock: Yes, that’s correct, yes.

Mr Blake: Are there any other roles that you held that I have to failed to mention that you think are relevant to this Inquiry?

Gayle Peacock: Um, I don’t think so. I mean, I did a Retail Line Manager role where it was, you know, I was looking after a patch of branches myself, in my early part of my career but I guess that’s probably not really relevant to the themes out of the Horizon Inquiry as such.

Mr Blake: We’ve heard earlier in this phase about the training that was provided at rollout and it was only a day and a half.

Gayle Peacock: Yes.

Mr Blake: By 2006, in broad terms, what kind of a training package was offered to subpostmasters?

Gayle Peacock: It was a colleague in network services, and I think it was split at the time as Andy Bayfield and Julia Marwood who managed the team. So I think, in terms of the broad level detail, I think at 2006, I think it was a week’s classroom course that they were offered, a transfer balance, which was obviously the incoming and the outgoing postmaster, and then, depending on the size of the branch there could be like five days face-to-face support in branch. And then I think there was a follow-up balance so that the next time the branch needed to do their cash account or branch trading they would attend, and then I think I believe there was what we called post-transfer visits or – I think it was one, three and six months. I think that was what was on offer at the time.

Mr Blake: Thank you. So the amount of training certainly had increased since rollout. You say in your statement that the overall training to postmasters needed to be improved. Can you expand on that a little bit?

Gayle Peacock: I think generally it was – the difficulty you got with a network that size is the volume of postmasters and the one size fits all. So you’ve got your challenge of geography, you had people who couldn’t attend the classroom course for whatever reason, you know, Post Office didn’t pay for a postmaster to actually come and attend them, sometimes the timing wasn’t convenient of the training and then you obviously had the different product mix as well, and then sometimes there would be challenges potentially if you went into a branch and the postmaster wasn’t present or you would train staff.

So – and the other thing is you could be giving training to a postmaster but you would only cover the things that were available during that five days. So if a transaction wasn’t there, for example because it didn’t happen very often, it wasn’t covered because you didn’t have the opportunity to do it, because you might teach the theory but not the actual practice.

So, yeah, I think one of the challenges, I don’t think we understood the effectiveness of the training. You know, it was like that was what you got and that was it. You know, I don’t think there was any kind of training needs assessment with postmasters to go “Do you learn by computers, do you – are you practical?” You know, there just wasn’t the opportunity for that flexibility. There was no online learning packages at that time either, it was literally face-to-face or classroom and that was it. So it probably fell down in a number of ways.

Mr Blake: Can you assist us with the difference in training that was provided to Post Office employees versus subpostmasters?

Gayle Peacock: I think that was managed by central HR teams. When I joined, I got a two-week counter training classroom course that I attended and then obviously that would have followed up in branch. I don’t think there was any kind of formal induction programme for Post Office employees. When you mean “employees”, do you mean like directly managed staff or do you mean the likes of the corporate staff like myself?

Mr Blake: I think somewhere in your statement you say, effectively, that the training that was provided to employees was better than that to subpostmasters, the quality and training was better.

Gayle Peacock: Um … can you point me to where you interpreted that?

Mr Blake: It’s in the statement at different points. It’s not a secret. If you don’t agree with it then that’s absolutely fine as well.

Gayle Peacock: Yeah, I probably disagree with it, actually, because I think it was, you know, I think one of the observations is that sometimes, you know, Post Office employees or colleagues didn’t understand what it was like to be in a branch network because they weren’t exposed to the Horizon terminal, the likes that I had. So it was quite inconsistent and hit and miss so, yeah, that’s not the message I wanted to convey in the statement, if that’s what you were implying.

Mr Blake: You do say in your statement that if there was space, managers and assistants could attend?

Gayle Peacock: Yeah.

Mr Blake: Are you aware of there not being space in certain circumstances?

Gayle Peacock: I can’t recall any. I think it was about six to eight places, potentially available. I don’t know if anybody was tracking, you know, what the take-up was.

Mr Blake: In 2006, you were head of network co-ordination –

Gayle Peacock: Yes.

Mr Blake: – and we’d spoken about that. There was a business reorganisation in 2006.

Gayle Peacock: Yes.

Mr Blake: Can you tell us how that affected the issues that we’re discussing today? So in terms of the offices, you’ve said there were area offices prior to that?

Gayle Peacock: Yeah, so in 2006, I think it was McKinsey’s that did a big – it was a full business restructure and everybody, I think, bar a very small portion of colleagues went through what we call a preference exercise. So they were asked, you know, did you want a job with the business, did you want to take redundancy or whatever. So everybody was asked and then one of the big changes they made in 2006 was, prior to that time, regardless of what size branch you were, where you were located or whatever, you had an area manager tagged to you, and there was a sales and service structure immediately prior to that in 2006.

So one of the big changes of the 2006 restructure was the decision was made that a large portion of the network wouldn’t actually have an area manager tagged to them as a branch and that any enquiry that they had would be tagged to the Network Business Support Centre. So I think it was about 2,000 branches that were given, like – in effect, it was a sales type manager. So they weren’t really supposed to do what we would call the service elements or, you know, the transactional queries, that kind of thing. And then literally everybody else was – that was the decision that was made, was you would be directed to the Network Business Support Centre.

There was about 11 area offices as part of that sales and service structure that was closed. So they all closed and it was left with Maidstone. So one of the jobs that I was tasked with doing was someone in my team was closing all of those area offices, which included things like branch files, we had to relocate them to Leeds and then, obviously, all of those members of staff, they went and everything was closed, and it literally left Maidstone.

Mr Blake: Prior to that reorganisation, if there was a service problem you would have somebody who could physically attend the branch?

Gayle Peacock: Yes, so there was a series of, I think, either area intervention managers or area performance managers. I can’t remember the exact structure because I didn’t work in it but I knew, obviously, colleagues who did. Yeah, they would manage all of what we’d call the non-sales issues, so things like problems balancing, losses, robbery/burglary, relocations, anything like that, then it would be directed to the regional teams, and they would then have a plan for how to support the postmasters within their region.

Mr Blake: How did the change impact on that? Say you had a problem with balancing. Was that no longer available?

Gayle Peacock: So there wasn’t necessarily a person to go to, so the route – one of the things that we had to do when we set up the team in Maidstone was actually understand what all of the processes were that were affected and then decide who was left in the business to pick that piece up and then almost redesign that process. If the Network Business Support Centre couldn’t deal with it then that’s when it came into the outlet intervention team in Maidstone, which I managed and then we would work with the relevant teams to try to sort something out.

So with the balancing enquiry, if they couldn’t resolve it, we would do our own investigation in terms of going through the possibilities that it could be, we would possibly liaise with Product and Branch Accounting to see if there’s any other information that would be available and, worst-case scenario, we would send somebody out to from what we would call the field team, so a trainer or auditor, to see what could actually be done to help the postmaster.

Mr Blake: When was that? Was that 2006 or –

Gayle Peacock: That was 2006.

Mr Blake: At paragraph 66 of your statement, you say that replacing physical support with remote intervention was not enough for some subpostmasters.

Gayle Peacock: I don’t think it was. You know. It assumed that everybody could cope and everyone was at the same level of, you know, competence, I guess, or, you know, if you he had a new subpostmaster, possibly the ones that had been there quite some time were probably okay because they knew how to do things. I don’t think the business knew how people would be affected and didn’t tailor that support in accordingly. It was just assumed that everybody could manage on their own.

Mr Blake: Do you know what the driver was behind the reorganisation?

Gayle Peacock: I wasn’t party to those conversations. I’m making the assumption it was probably cost. You know, there was a big drive that we had to get back to profit as an organisation, the sort of government income from pensions and allowances, the branches were migrating onto card account. You know, in terms of the income that was available to postmasters and Post Office, it was just what – I think it was a cost commercial decision to do that.

They couldn’t see the commercial return on having a physical body going out to a branch and supporting them. They couldn’t translate that into a monetised value.

Mr Blake: I think you mentioned there were 2,000 or so branches which had a different level of service?

Gayle Peacock: Yes.

Mr Blake: Were those the more commercial branches?

Gayle Peacock: Yeah, so the bigger branches. You know, the ones that might have the potential to – because at that time there was sort of the drive to increase Financial Services, so we were moving into car insurance, home insurance, all of those kinds of things and it was felt that actually that those branches had the right demographic, they had the right footfall, they were bigger in remuneration and, therefore, they deserved more support than the smaller ones.

Mr Blake: You’ve said that introducing the pre-2006 position or reintroducing that was not a commercially viable option. Can you expand on that?

Gayle Peacock: So I think – I mean, the background to the branch standards booklet was, I think, you know, in about 2007, they were starting to feel some of the consequences of not having that, you know, immediate support for the branch, and I think and it was just too expensive to re-introduce a physical presence and I think the preferred option was see what you can do remotely from an outbound perspective before you then start introducing area managers back in. I don’t think that was an option for us to consider.

Mr Blake: I think you also said in your statement that resourcing over the phone support was the best, given the financial circumstances?

Gayle Peacock: Yes.

Mr Blake: Do you know who within the company was driving this move?

Gayle Peacock: I think it was just a top-down – you know, it was at board level. So I think one of the strategies, I think it was the Forward 5 to 11 that was launched on the back of – there was the big business restructure, it was, you know, back to profit was the 2006 Forward 5 to 11 strategic – you know, you did Forward 5 to 11 and then the 4 to 11 and then the 3 to 11, so it was very much front and centre driven from the top that actually that was the business strategy that Post Office was going to deploy.

Mr Blake: You’ve said there was no central system to understand who had visited which branches –

Gayle Peacock: No.

Mr Blake: – and that some that never been visited or may never have been visited; is that right?

Gayle Peacock: Yes.

Mr Blake: Yes. Did that change or is there now a central system?

Gayle Peacock: Yeah, so I think over time it definitely did. One of the criticisms is obviously the Second Sight report was obviously there was no central point for recording contact. One of the things that I was involved in 2017 was the introduction of Microsoft Dynamics CRM solution which recorded who was making outbound or receiving inbound interventions from branches so that was rolled across like 25 different teams across Product and Branch Accounting, NBSC, Security, a number of different back office teams, HR, so we could at least track who was having a conversation with who about what.

They then made that into, I think, the branch information tool, which was made available to area managers, so they could at least understand what their branches were, what conversations they were having with certain branches. I don’t think they ever got to the position of, like, physically tracking who was going in and, you know, like you could have a security manager visit one day and an area manager the next. I don’t think they ever implemented that. They may have done since I’ve left. I’m not sure.

Mr Blake: You said at paragraph 25 of your statement and I think you’ve repeated it in your evidence today, that postmasters could request further support from the NBSC?

Gayle Peacock: Yes.

Mr Blake: That’s from the 2006 reorganisation.

Gayle Peacock: Mm-hm.

Mr Blake: Were you aware that in 2010, the Post Office was going to start charging for visits to the branch?

Gayle Peacock: Yes, it was. So that was part of the branch standards change that I was involved in implementing. So it was a contractual change with the postmasters and I think there was – I think there was a charge specifically related to cash holdings, so this was where, if a postmaster failed to regularly declare the cash in branch correctly and, despite any sort of help, intervention and support repeatedly needed to do it, and then somebody had to go out, there was the mechanism in the contract to charge for it if it was deemed appropriate to charge for it.

I think the other one in there was the regulatory compliance training. So the post offices had to do I think it was about 12 modules every year and there were a handful of branches that repeatedly failed to do that training, despite your phone calls, help, so it was seen as a last resort for a minority of branches.

I can’t remember the volume that were involved but we had possibly a handful, every now and again, that were subject to this – to the charge. But given the volume of telephone interventions the compliance training generated usually about 1,000 calls every month to branches to remind them to do it, and then you might potentially be left with two or three who just may have refused, or didn’t do it for whatever reason. In that instance, the postmaster would have been advised beforehand that, you know, “You’ve got the option to do it, if we need to send somebody out, there is the option that we can charge it”. And I think there was a cap on the charge, as well, that it would only be up to a certain amount of money. It was intended to cover the cost of the person that would go out to help.

Mr Blake: Can you tell us briefly what was branch standards? It’s a booklet or something else?

Gayle Peacock: So the branch standards – well, it was a booklet in the team so the branch standards was there to define what the business as a whole deemed to be the important sort of standards that a branch should follow. So there was the booklet and the communication and then there was my team, the branch standards team, that would – we used to send out the scorecard to branches every month to say this is how your performance – how you’re doing against the standards. And then we would make the relevant support interventions as well to branches who we felt needed some help understanding what some of those procedures were.

Mr Blake: I’m going to take you to a document can we look at POL00084464. So you will be familiar with this document.

Gayle Peacock: Yes.

Mr Blake: It says:

“Dear colleague,

“I’m pleased to send you the Post Office Branch Standards booklet.”

So this document and the booklet would go to the Post Office branches?

Gayle Peacock: Yeah, so there was a covering letter, there was a copy of the booklet, because it was a contractual change they would have received a copy of the contractual amendment as well. Yeah, it would have been part of a pack.

Mr Blake: Can we scroll down on this page to the paragraph that says, “Starting in June 2010”, thank you. It says:

“Starting in June 2010, we will pass on to you the cost of any visits to your branch to ensure that compliance training has been completed. We will also pass on the cost of any further training if you are not carrying out your overnight cash or ATM declarations properly, including the cost of visiting your branch to deliver the training. We will also pass on to you the charges we have to pay for missing motor vehicle licence … discs. The details of how these measures could affect you are shown in the ‘Conformance with the branch standards’ booklet included with this letter.”

Do you think at this time there was a hardening of attitudes towards postmasters in trying to charge them for services that had previously not been charged for, for example?

Gayle Peacock: Um, I’m not sure, really. I think there was probably some discussions around what else we could do, so you would try and help branches as much as you can but you – sometimes you were just left with a group that just for whatever reason, didn’t do what everybody else wanted to do. So I think it was almost – well, would this sort of act as a motivation if people thought financially they might be impacted by it? Would it, you know, would it make any difference? I’m not sure generally whether a hardening attitude towards postmasters, I don’t think.

Mr Blake: Well, let’s say if a subpostmaster had a shortfall that they couldn’t explain, we’ve heard that they’d have to pay for the shortfall?

Gayle Peacock: Yeah.

Mr Blake: But now would they also pay for additional support if somebody was required to come and visit them? Would they have to pay?

Gayle Peacock: If you wanted to enforce the contract, then yes.

Mr Blake: We’ve heard also from some witnesses that the training that had been provided to subpostmasters contained some gaps when it came to things like balancing.

Gayle Peacock: Right.

Mr Blake: Would you agree with that?

Gayle Peacock: I would, yes.

Mr Blake: If you needed more training to cover that, would you have to pay for that? Would that be – require a visit that you’d have to pay for, potentially?

Gayle Peacock: No, you wouldn’t have to pay for those ones.

Mr Blake: Are you aware at this time of continued financial difficulties within the Post Office, so 2010? We spoke about 2006 and the reorganisation.

Gayle Peacock: Do you mean postmasters or Post Office?

Mr Blake: No, the company, Post Office.

Gayle Peacock: In what respect?

Mr Blake: Were there financial pressures still. You spoke about them in 2006. Did those continue in 2010?

Gayle Peacock: I think there was always a focus on cost with Post Office, you know, throughout the whole of my career. There was always the emphasis to do things more efficiently, you know, it’s a government funded organisation. It was reduced to tax – the burden on the taxpayer. What could you do? And it was constantly in the culture that what could you do to reduce costs? That was just – you know, that was just part of what it was every year when we had teams. The budget got, just got reduced, and you would have to find a way to manage that. We had numerous reorgs and most of that was driven of what could you do better, what could you stop doing? What could you reduce?

So I think the focus on cost because, you know, it was a commercial organisation that was paid for by the taxpayer, there was that constant need to actually just keep – you know, reduce it, reduce it, reduce it.

Mr Blake: Can we look at POL00084769. This the “Branch Standards” document?

Gayle Peacock: Yes.

Mr Blake: Is that what would have been attached to that document that –

Gayle Peacock: Yes, it was a small A5 booklet, yes.

Mr Blake: Thank you. If we turn over the page, you have an introduction and that introduction is from Paula Vennells, the network director at that stage?

Gayle Peacock: Yes.

Mr Blake: Was she responsible or was she the driving force behind this branch standards document and the change in approach?

Gayle Peacock: Yes, so this was the initiative. So the branch standards were part of the network efficiency programme that was set up, that was ultimately sponsored by Paula, I worked to Lynn Hobbs, Lynn Hobbs worked to Paula and, you know, this was the direction that was given. It was we need to try to find a co-ordinated approach of importing standards with the network. So yeah, Paula was completely aware of what we were doing. She would have had to have signed off this opening introduction as well.

Mr Blake: So it was enforcing standards, but it was also, at the same time, trying to meet the cost pressures that the Post Office was under?

Gayle Peacock: Yes.

Mr Blake: Can we look at page 15, please. Thank you. There’s a section there on “Processing transactions correctly”, on the right-hand side, and I’ll read it. It says:

“Rectifying mistakes is a significant cost to the Post Office. Whilst we understand that mistakes will happen on occasion, we want to minimise them – to reduce our costs and give good customer service. Getting transactions right means that we don’t have to waste time resolving mistakes. It also gives our partners confidence that we can transact their products in the correct way”.

There are suggestions there for “Getting it right every time”:

“Make sure that you and your teams follow the correct procedures for each transaction. This will increase confidence and help prevent transaction errors and corrections.

“If you receive a transaction correction to rectify a mistake, deal with it as soon as possible, and always within the balance trading period.

“If a transaction correction has a monetary value, any discrepancies must be dealt with promptly by contacting Product & Branch Accounting.”

At this period in time, was there a particular focus on mistakes being the fault of the subpostmaster or certainly a belief that the mistakes that were occurring were the fault of the subpostmaster?

Gayle Peacock: I think there was a focus on cost so the view was, you know, you’ve got people in Product and Branch Accounting in Chesterfield who are literally there because they’re sending things backwards and forwards to clients because something has happened in branch. I think there was that.

I think there was also an awareness that some of our transactions weren’t as easy to follow as they could have been. Yeah.

Mr Blake: Were subpostmasters seen as the cause of some unnecessary costs that were impacting the Post Office?

Gayle Peacock: I think probably somewhere but then I think also there was the view that some transactions were potentially difficult. I think it was probably a combination.

Mr Blake: What do you mean by “difficult”?

Gayle Peacock: So, you know, throughout the some of the evidence obviously things like scratchcards, reversals, that kind of thing. I think, you know, a lot of the information within the bundle sort of alludes to the fact that some of this stuff wasn’t as ease as it could have been in terms of the product process.

Mr Blake: How was this assisting, telling subpostmasters to just get it right, to follow the correct procedures?

Gayle Peacock: I mean, in hindsight it’s probably not, is it?

Mr Blake: I’m going to move on to another document that I think accompanied the branch standards. Let’s look at POL00084774. I’m just going to read to you that first paragraph or some of the first paragraph.

Can you just tell us briefly, though, was the document that went alongside –

Gayle Peacock: Yes.

Mr Blake: – it was to be read along –

Gayle Peacock: It would have been like Q&As gone out with it, yes.

Mr Blake: “What type of consequences will there be for not complying with branch standards, including selected standards?

“There will be specific financial consequences for subpostmasters who do not meet the expected level of performance for some branch standards. The amendment to the subpostmaster contract which introduces the financial consequences is also included with the information that will be sent with the booklet.”

So again, my reading is that there’s a hardening towards the subpostmasters of attitude; is that wrong?

Gayle Peacock: I don’t really – yeah, I can’t really give an opinion on that. What from 2006 to 2010 or a specific time period?

Mr Blake: Well, in 2010 you had these branch standards and subpostmasters are being threatened with specific financial consequences. Do you agree that that it has that kind of a tone about it or not?

Gayle Peacock: Yeah, it does have a tone about it. I don’t know whether that changed significantly from 2006 or there was a step change. I’m not sure.

Mr Blake: I mean, we see there, for example, the fourth bullet point:

“If branches fail to complete cash declarations, including those relating to ATMs, and performance doesn’t improve following remote intervention, a member of the Network Support Field Team will visit the branch to conduct further training, which will be at the cost of the subpostmaster.”

Scrolling down:

“The existing contractual consequences for poor application of branch standards remain. This includes the possibility of action being taken under the subpostmaster contract. This could be corrective action with a possibility of contract termination, and/or removal of a product from the branch. If a subpostmaster has a query relating to specific areas of their contract then this query should be raised with the Human Resources Service Centre. Certain breaches of branch standards which involve regulatory bodies may instigate criminal [proceedings].”

In this question and answer document, is there, for example, any mention of how a subpostmaster might dispute a transaction correction?

Gayle Peacock: Within this one or the branch standards one?

Mr Blake: Yes.

Gayle Peacock: I can’t recall, to be honest, Julian.

Mr Blake: How about disputing discrepancy in their figures and their branch trading statement? Were those kind of things addressed in either the branch standards document or the accompanying Q&A?

Gayle Peacock: I don’t think so. I think there was an agent support charter, I think – I can’t remember the time when that came out. I don’t know if that was before or after the branch standards booklet and that was around the service level agreements that Post Office would provide to postmasters. I think that covered it but I can’t remember when that was produced.

Mr Blake: Just while we’re on this document, if we scroll down to page 3, the final page:

“Will new subpostmasters be subject to the same standards and consequences?

“Regardless of how long someone has been a subpostmaster, we expect them to achieve the branch standards.”

The final sentence there:

“Also, any branch losses will be the responsibility of the subpostmaster from the day of taking over the branch.”

Was it assumed during this period that, if there were losses, they were caused by user error rather than any fault with the Horizon System?

Gayle Peacock: Yeah, I think that was just a widespread Post Office assumption, that it was due to what they would call “branch non-conformance” or “user error”.

Mr Blake: Thank you. Thank you. I’m going to move on to a different topic and that’s suspension and appeals.

You’ve explained that at one point you attended audits. I think you were shadowing or something along those lines.

Gayle Peacock: Yes.

Mr Blake: Can you briefly tell us in what capacity that was in?

Gayle Peacock: It was just as a learning exercise, so just to find out what actually happened, what it would involve. So I just attended the branch audit to actually see what happened.

Mr Blake: Did you come across any auditors who were not acting professionally?

Gayle Peacock: No, not in my experience.

Mr Blake: Are you subsequently aware of any unprofessional conduct by auditors?

Gayle Peacock: I think – I can’t remember specific examples but I think, obviously, there were some concerns raised, you know, as part of the Inquiry. But I can’t remember the specific ones. I didn’t have any raised individually to me.

Mr Blake: When you say “Inquiry” do you mean this Inquiry or –

Gayle Peacock: This Inquiry, yes.

Mr Blake: Were you involved in appeals against termination?

Gayle Peacock: I was, yes.

Mr Blake: What role were you –

Gayle Peacock: I was the appeals manager.

Mr Blake: Can you tell us how those took place, what format they were?

Gayle Peacock: So there was a group of people who were selected to be appeals manager. I was one of those. The contracts manager would manage the contractual proceedings or processes with the postmaster. They would make a decision in terms of whether the contract needed to be terminated and on what grounds, relating to the specific part of the contract. The postmaster was then given the opportunity to appeal that decision and then I think they submitted their request to the HR service centre, and then they would be just an appeal manager allocated to that particular case and I was one of those managers that was selected if a postmaster want to actually appeal.

I would then receive the appeal papers relating to that case. So that would be a bundle from the contracts adviser or contracts manager who’d dealt with that case, any information that was relevant to how that decision had been made, any kind of meeting notes, that kind of thing. I would then contact the postmaster and arrange to meet them and they’d have the opportunity to sort of like have that discussion with me, present any new evidence. I’d review the case in terms of what was the evidence provided? Was the decision appropriate? Had the case been handled correctly? And then, ultimately, make the decision around whether it was appropriate to terminate that postmaster’s contract.

Mr Blake: What period of time are we talking now?

Gayle Peacock: So that would have been from, I think – because I think you could only do it when you were classed as a senior manager, so I think it was from 2006 onwards. I think my last postmaster appeal probably would have been about 2018.

There was a period where we didn’t do them because there was a decision made – I can’t remember what time scale it was, but the – there was – as part of one of the business reorganisations, there was a dedicated appeals manager that, rather than try and farm them out to individual senior managers across the business, there was a gentleman called Andy Bayfield who managed or who heard all of the appeals regardless of geography. And then I think that – I think Andy left in about 2010 and then reverted back to individuals across the business.

Mr Blake: I think you said in your witness statement that in the majority cases there was a financial discrepancy that had occurred, that was a contributing factor.

Gayle Peacock: Yes.

Mr Blake: Were subpostmasters represented at these appeals?

Gayle Peacock: Yes, so they had the opportunity – so part of the appeals process is they could bring a friend or a colleague or a member of the National Federation of SubPostmasters. I think everyone bar one that I ever did was always with two people.

Mr Blake: Not legal representatives, though?

Gayle Peacock: No.

Mr Blake: No. What was your understanding of how easy it was to obtain what we know as ARQ files?

Gayle Peacock: So these are the files from Fujitsu. So my understanding was that Post Office as an organisation were allowed so many ARQ files, sort of, per year. I think the number was about 300 or 400 or whatever. That was managed by the security investigations team. I think if you needed access to one for whatever reason, you could request it through of the security investigations team. I don’t think they were made available as a matter of course. You know, for each suspension case.

Mr Blake: I think you’ve mentioned in your statement a few different types of logs. You’ve talked about transaction logs, keystroke logs and ARQ logs.

Gayle Peacock: Yes.

Mr Blake: Do you know the difference between them?

Gayle Peacock: I think the ARQ was almost the keystroke log, so that would record everything in terms of what the user in branch had, you know, allegedly pressed. The transaction log was the log that would be generated from Horizon. So I think anybody with manager access – and it was – it didn’t have everything, so it was like the transaction stamp of the day. You could run a particular time period, so if you had a discrepancy that you could move the transaction log and then print one in branch.

So the transaction log was actually in branch; the ARQ and the keystroke stuff was the bits that were provided by Fujitsu.

Mr Blake: For the ARQ and the keystroke, would you have to go through the security team –

Gayle Peacock: Yes, you would.

Mr Blake: – is that something –

Gayle Peacock: Yes, you would.

Mr Blake: Can you describe the difficulties in obtaining that information?

Gayle Peacock: I never experienced any. I can’t remember instances where I would. I didn’t know if anybody had been refused, obviously until I read the additional bundles that you sent through for the Inquiry.

Mr Blake: As part of the appeals process, though, are you aware of ARQ data being requested, being used, in the appeal?

Gayle Peacock: I would have used, if it was part of the bundle of papers. If – depending on what the postmaster had said at the appeals interview, if I felt that I needed access to that information, I could make that request. I think it would depend on the timescale involved as well, and whether it was still available, but I knew who to go to if I needed one. I couldn’t answer for the other appeals managers. I don’t know if they knew that they could get one. I knew I could get one but I didn’t know if they could.

Mr Blake: Who would you get it from?

Gayle Peacock: So it would have been – well, whoever was running the security investigations team so there was number of people that I would have known to make contact, head of security, who ever was fulfilling that role at the time.

Mr Blake: Who prepared the appeals bundle for you?

Gayle Peacock: It usually got sent by the contracts manager so they would be – it would be bundled up as a file. I think you could get a hard copy file as well, so there was an admin team in Leeds who would post whatever hard copy information you needed to your house or there was an electronic copy as well.

Mr Blake: If the basis of the termination was a financial discrepancy, would ARQ data be provided ordinarily or is that –

Gayle Peacock: I don’t think it was a standard process. I don’t think it was something that – like as part of a checklist that you would do. I don’t think it was – I don’t think it was something that was always included.

Mr Blake: Was it sometimes included, rarely included, often included?

Gayle Peacock: Um, sometimes, I think, from recollection.

Mr Blake: Do you recall any subpostmasters wanting additional data and not being able to receive it?

Gayle Peacock: Um, I can’t recall anybody saying to me that they didn’t get it. What I used to do was, you know, print everything off and send it to them that I was going to consider, that – in advance of that meeting, so that they could see it, so that we could discuss it and then, should anything come across as part of that meeting that you might want to go and look at, so whether you needed access to any remittance slips or anything like that, if there was any information that came subsequently, the postmaster would get hold of it. I think the challenge was if they didn’t know what they could have, would they know to ask, necessarily.

Mr Blake: Do you recall there being information provided to subpostmasters about the availability of that kind of data?

Gayle Peacock: No.

Mr Blake: Briefly before – sir, I was woefully optimistic as usual, so we will certainly go over after lunch.

Sir Wyn Williams: We’ll take a normal lunch.

Mr Blake: We’ll take a normal lunch break but I’ll just ask you a few questions before we break to lunch and that relates to HORice.

Gayle Peacock: Yes.

Mr Blake: We heard a little bit about that this morning. I think that stood for Horizon Information Centre; is that right?

Gayle Peacock: Yes, that’s correct.

Mr Blake: When was HORice introduced?

Gayle Peacock: So that would have been part of the Branch Support Programme, so that was – I think it was towards the tail end of 2014. Yeah, I went on maternity leave in October 2014 and I think it was just starting to be – we were getting towards the end of that particular project. So it would have been not long after that.

Mr Blake: How did that differ to what was available before?

Gayle Peacock: So the main difference with HORice, so if a postmaster rang up and said they had problems balancing or they didn’t know what had gone wrong, or X, Y and Z, it was really difficult for anybody at the end of that phone to actually understand what had been pressed. It was almost like the adviser was working blind and it relied on the postmaster relaying that information.

What HORice enabled a certain number of users to do, it was, in essence, the ARQ data within like I think it was like a 15-minute window. So by making that available, you could actually understand if the postmaster had served in the wrong stock unit or logged off or not done, like, a fallback and recovery process correctly.

More Post Office users had access to, in effect, what was the ARQ data and could see and try and use that data to help try and work out what had happened in that branch to try to rectify any errors or mistakes.

Mr Blake: So that information was available to the subpostmaster or assistant?

Gayle Peacock: We would provide it if it was requested. HORice was the system that was used internally, so it was a licence-based system that I think it started off small, so there was identified users within the Network Business Support Centre, Cash Management, Product and Branch Accounting and the Security Investigations Team as well.

Mr Blake: Did you still have to go through the security team to obtain the information?

Gayle Peacock: No, as I say, it was about widening that up with a limited number of users but in like a controlled environment because, obviously, there was sensitive, you know, information in there. So you had to understand who was using it, and for what purpose. But there wasn’t – you know, if a postmaster saw, for example, when they contacted the Network Business Support Centre and the person helping them – because it was usually like a tier 2 type person because you’d have to like go away, look at it, and then get back to the branch – there was no issue in providing that postmaster with, you know, a copy of that, because that’s what you’d based your conclusion on, really.

Mr Blake: Do you know what triggered the change to HORice?

Gayle Peacock: So my recollection was, so I got called to a meeting by Fujitsu. I think it was Tony Jamasb from service management. So there was myself, Anne Allaker and we went to Bracknell, we got invited to a meeting with Fujitsu where they actually showed us a demonstration of HORice. Myself and Anne were involved in the Branch Support Programme at the time and it was positioned to us as would this – what benefit would this bring the Post Office if you had – if you had access to this system? It was – I think it was based on what they were using to track, like, whether terminals were down and that kind of stuff.

So as part of that exercise I went back and sort of talked to various people within the business, like Angela van den Bogerd and, you know, we looked at, well, what benefit would this give? And then we’d obviously just implemented the project and then deployed it, because it was felt that, actually, it could provide some real help, and try and to resolve some issues and, you know, reduce this reliance on the ARQ but also give postmasters a quicker resolution time in terms of somebody being able to see the data, rather than it just being in a closed shop.

Mr Blake: When it was presented to you by Fujitsu, had they expressed any concerns or frustrations relating to the provision of ARQ data?

Gayle Peacock: Not that I’m aware of. Not as part of that meeting.

Mr Blake: Were you aware of any concerns within the Post Office about the difficulties in obtaining ARQ data?

Gayle Peacock: I think the main concern that I was aware of was the cost, if you wanted – there were additional stuff over the quota. I don’t know whether it was necessarily an issue of not getting hold of the data. I think sometimes there was a question of who would pay for it, if it was needed, because it didn’t fit within the – what you were allowed.

Mr Blake: Okay. Thank you very much.

Sir, that’s an appropriate time –

Sir Wyn Williams: While it’s on our mind, can I just ask one or two more questions about the appeal process?

Gayle Peacock: Yeah.

Sir Wyn Williams: Apart from the time when Mr Bayfield took over all the appeals, you said you were part of a group doing them.

Gayle Peacock: Yes.

Sir Wyn Williams: Approximately how many of you?

Gayle Peacock: Um, I think there was about 15, 20 people.

Sir Wyn Williams: So, in any given year, let’s put it in that way to start with, how many do you think you personally would do?

Gayle Peacock: I think it was about three or four we’d get.

Sir Wyn Williams: Three or four a year?

Gayle Peacock: Yeah.

Sir Wyn Williams: Fine. So as a guesstimate, in the period between 2006, 2018, taking out Mr Bayfield’s time, overall, 20, 30 appeals, that sort of thing?

Gayle Peacock: Yeah, that probably seems about right.

Sir Wyn Williams: Right. Don’t be too legalistic about it but your decision, were you reviewing what the contracts manager had done or were you actually looking at it all afresh and coming to your own decision?

Gayle Peacock: I think you were supposed to do the former, I tended to do the latter.

Sir Wyn Williams: Right, well that’s not entirely surprising. So there was a kind of process which told you what you should do?

Gayle Peacock: Yes.

Sir Wyn Williams: So it was a review, I’ll call it a review.

Gayle Peacock: Mm-hm.

Sir Wyn Williams: But you being you decided to look into it for yourself?

Gayle Peacock: Yeah.

Sir Wyn Williams: Is that it? Okay. How often did the appeal succeed roughly?

Gayle Peacock: Not very often. I never overturned one once.

Sir Wyn Williams: Right. Well, that’s fine.

There was one other short point that’s just eluding me for the moment. Yeah, were the appeals in the main made when someone had had their contract terminated, or were there appeals about other things as well?

Gayle Peacock: Um, it was – the contract ones was usually about – formal appeal would be when the contract was terminated.

Sir Wyn Williams: Yes.

Gayle Peacock: You would get sort of individuals where a decision had been made that, like a transaction correction or something, and there was – you might get asked to review a decision.

Sir Wyn Williams: But of the approximately 30 appeals that you dealt with, were they, the vast majority, where the contract had been terminated?

Gayle Peacock: Yes.

Sir Wyn Williams: Right. Thank you very much. Okay 2.00.

(1.03 pm)

(The Short Adjournment)

(2.00 pm)

Mr Blake: I’m going to move on to the topic of Second Sight. Did you have any direct contact with Second Sight?

Gayle Peacock: No.

Mr Blake: Can we look at POL00106194, please. It’s the final page of that document that I’d like to start with. This is an email chain that is ultimately forwarded to you, or you’re a copy recipient?

Gayle Peacock: Yes.

Mr Blake: But I’m going to start at the back. The penultimate page, page 4. Thank you very much. So there is an email at the bottom there from Antonio Jamasb?

Gayle Peacock: Jamasb. Yeah, Tony Jamasb.

Mr Blake: What was his role?

Gayle Peacock: I think he worked in service management in the IT department.

Mr Blake: Do you know Dave?

Gayle Peacock: Dave Hulbert, yes. So Dave was in managed services so I think he was something to do with the relationship with Fujitsu and IT.

Mr Blake: Thank you. I’ll just read that, it says:

“The NBSC has been provided with no information regarding the Audit Press Release …”

Do you recall what the audit press release was?

Gayle Peacock: I can’t remember the detail. Looking at this email that you’ve presented earlier, I am assuming that some kind of statement was released about the potential review with Second Sight.

Mr Blake: So it says:

“… so I have drafted the following and if you are happy with it I will send it onto NBSC.

“As discussed if we get any enquiries from Branches regarding the recent press release from Post Office regarding the independent audit of the Horizon System please use the following quote …”

So this was a proposal to send this to those who worked on the NBSC.

Gayle Peacock: Yes, because they would have been getting calls from branches asking, you know, they would have seen it in the local press or national press and it would have generated some activity.

Mr Blake: We will see from the later emails but it seems as though the concern is that the NBSC –

Gayle Peacock: They don’t know what to do with it, yes.

Mr Blake: And they have received requests from audits of branches?

Gayle Peacock: Yes.

Mr Blake: The line to take there is:

“The Post Office continues to have absolute confidence in the robustness and integrity of its branch accounting processes.

“Over the past 10 years, many millions of branch reconciliations have been carried out with transactions and balances accurately recorded by more than 25,000 different subpostmasters.”

Was that a line you were familiar with at all?

Gayle Peacock: I think that was what ended up being used quite a lot within the communications.

Mr Blake: Do you know where it was coming from?

Gayle Peacock: I’m not sure where it came from, to be honest, Julian.

Mr Blake: If we go up in this chain and the email on the second page – or third page, sorry. Friday, 22 June, 2.38 – thank you very much. It says there “As discussed”, it’s the italicised part:

“As discussed if we get any enquiries from Branches regarding the recent press release from Post Office regarding the independent audit of the Horizon System please use the following quote …”

That’s the quote. Below the quote, it says:

“However, some branches may request to be involved in this exercise. Advise them that we will forward their details on to the relevant department, but at this time you have no further details.”

Gayle Peacock: Yeah.

Mr Blake: If we could scroll up again in the chain, to the top of the second page, this in email from Kevin Gilliland, is it?

Gayle Peacock: Gilliland, yes.

Mr Blake: It says there – sorry, if we can scroll to the second page. Yes, there we go:

“Please can we be absolutely clear that we should make no reference to the option of the audit unless it is specifically requested. I am sure that all calls will be seeking clarification about the statement and we don’t want to cause unnecessary work and process.”

What do you understand Kevin to have meant in that email?

Gayle Peacock: I think he’s making the assumption that people are just asking the question about the press release and I would interpret it that he doesn’t want to offer the audit unless they ask for it. That’s what I read from that.

Mr Blake: So there’s a press release that it seems to be about Second Sight’s involvement?

Gayle Peacock: The request to be involved I think, yeah.

Mr Blake: Yes. Who was Kevin? Can you remind me, sorry?

Gayle Peacock: Kevin was the network director.

Mr Blake: So the network director at that stage was saying that we don’t want to give people the option of the audit?

Gayle Peacock: Unless they ask for it.

Mr Blake: Yes. If we scroll up to the first page, we have those emails forwarded to yourself. Do you know why you were included in this chain?

Gayle Peacock: Yeah, so I worked for Craig at the time, so people on copy – so you’ve got Tony Jamasb and myself, John Breeden, Lin and I think probably Sue did, so we were part of Craig’s lead team.

Mr Blake: I will just read the second at third paragraphs. It says:

“Taking Kevin’s point, I would hope that we do not get a great number as it should not be ‘offered’ but than you pick up and maintain the request list within your team please?”

Are you aware of there being a list of branches that have called in following this press release?

Gayle Peacock: Yeah, because we had to set up a process on the back of that. So I worked with Pat to understand which branches were actually ringing in and it was then obviously working with Angela to decide what would happen with those branches who’d made that request.

Mr Blake: Are you able to tell us, were those branches offered an audit by Second Sight or offered something that they hadn’t been offered before?

Gayle Peacock: I think Second Sight were made aware of the request to be included. I don’t know what the decision process was about which ones would be included or not. We would have just forwarded the list.

Mr Blake: Are you aware of somebody having that contact with Second Sight to forward the list?

Gayle Peacock: I think that was done through Angela van den Bogerd. I didn’t have any contact with them directly.

Mr Blake: It says:

“I’d like to understand the nature/reason background as would normally when anything is escalated from NBSC. As we always say a physical audit at branch counts how many beans are there at that time, it doesn’t do anything else and certainly doesn’t test the system which is what I believed the independent review is about. Let’s see how it develops.”

Was there an understanding within the Post Office that a physical audit at branch couldn’t really test the system that was being used.

Gayle Peacock: Yeah, I don’t think it was there to decide whether the system, like, was functioning correctly from an IT perspective. It was a verification of stock and assets, stock and cash. You had the financial audit and then the compliance audit. I don’t think there was any provision for an IT audit as such.

Mr Blake: Did you have any further involvement in this particular issue? We’ll get on to some meetings that you had with lawyers, et cetera, but in terms of this specific issue about people calling the NBSC, aware of the Second Sight issue?

Gayle Peacock: Yeah, so I think this was the start of the communications, so this was the list that obviously was then forwarded to Second Sight to include. There was then processes that we put in place on the back of that to record, and make sure we resolved any branches that were raising concerns about Horizon Issues, which then formed part of the weekly call with the various stakeholders, which is part of the agenda that you’ve included in the pack. So this was almost like a precursor to those.

Mr Blake: So we see and we’ll come to those Bond Dickinson notes?

Gayle Peacock: Yes.

Mr Blake: Is that related to this?

Gayle Peacock: It will be. That will be the end part. This was obviously just the start of obviously the processes that were followed. They ultimately ended up in those Bond Dickinson conversations.

Mr Blake: Thank you. Can we look at POL00029744. This is the interim report produced by Second Sight. The date of it is July 2013, so we’re now a year on.

Gayle Peacock: Yes.

Mr Blake: Can we turn to page 5, please. Did you see this report at the time that it was produced?

Gayle Peacock: I can’t recollect. The first time that I think I saw it was when you sent me it.

Mr Blake: Let’s go through a few of their observations and conclusions. Can we look at paragraph 6.4, the bottom of page 5. It says:

“In the course of our extensive discussions with POL over the last 12 months, POL has disclosed to Second Sight that, in 2011 and 2012, it had discovered ‘defects’ in Horizon Online that had impacted 76 branches.”

At this time, was that something you were aware of at all?

Gayle Peacock: No.

Mr Blake: If we go over the page, please, the first defect is referred to as the receipts and payments mismatch problem, paragraph 6.6. The second defect referred to as the local suspense account problem. Paragraph 6.7.

POL was unaware of this second defect until, a year after its first occurrence in 2011, it reoccurred and an unexplained shortfall was reported by [a subpostmaster].”

Paragraph 7.1:

“It has become clear that whereas the Horizon System appears to achieve its intended purpose almost all of the time and operates smoothly for most [subpostmasters] and their staff, some combinations of events can trigger situation where problems occur.”

Had those kinds of issues been brought to your attention at all?

Gayle Peacock: No.

Mr Blake: If we go over the page to page 8, we have the preliminary conclusions because this is, of course, the interim report of Second Sight?

Gayle Peacock: Yes.

Mr Blake: 8.1:

“This is an Interim Report and there is much work still to be done. Any conclusions reached at this point will need to be updated in the light of new information that arises as the Investigation continues.”

Then it lists below that the preliminary conclusions. The first is that:

“We have so far found no evidence of system wide (systemic) problems with the Horizon System;

“We are aware of 2 incidents where defects or ‘bugs’ in the Horizon software gave rise to …”

That’s the errors and bugs that we spoke of before that hadn’t been brought to your attention.

Gayle Peacock: Yeah.

Mr Blake: “Occasionally an unusual combination of events, such as power or communications failure during the processing of a transaction, can give rise to a situation where timely, accurate and complete information about the status of a transaction is not immediately available to a [subpostmaster].”

Is that something that had been brought to your attention?

Gayle Peacock: Not before then, but I think on the back of this they did some work with the – it was called the fallback and recovery process. So I think following this interim report I think there was a recommunication back out to branches because it was quite a complicated process to follow to. If your connection was lost, there were certain transactions that you could recover immediately and ones that you couldn’t. So I think I became aware of that through the subsequent comms that they did on the back of this.

Mr Blake: So your understanding of that at the time was that it was a power cut or something like that would cause a recovery issue?

Gayle Peacock: It’s the power cut or the communication side. So, you know, if the Internet signal cut out mid-transaction, there’d be procedures that the branch would have to follow to recover that transaction.

Mr Blake: Then (d):

“When individual [subpostmasters] experience or report problems, POL’s response can appear to be unhelpful, unsympathetic or simply fail to solve the underlying problem.”

That’s something that we will come on to look at because that’s something that I think you looked at in depth.

Gayle Peacock: Yeah.

Mr Blake: (e):

“The lack of an effective ‘outreach’ investigations function within POL, results in POL failing to identify the root cause of problems and missing opportunities for process improvements.”

Then (f):

“The end of Trading Period processes can be problematic for individual [subpostmasters], particularly if they are dealing with unresolved Transaction Corrections … The lack of a ‘suspense account’ option means that it is difficult for disputed TCs to be dealt with in a neutral manner.”

Now, you say you first saw this report –

Gayle Peacock: When you sent me it.

Mr Blake: In the pack for the Inquiry?

Gayle Peacock: Yeah.

Mr Blake: Let’s look at the Branch Support Programme. What was the purpose of the Branch Support Programme?

Gayle Peacock: So that was set up on the back of I’d received the information second time around, some of the thematic issues that might come through. So, as a result of those conversations the Branch Support Programme was set up, and that’s what I was asked to lead.

Mr Blake: Can we look at POL00039158. Thank you. Is this a document that you are familiar with?

Gayle Peacock: Yes, I think I wrote it because my name is on the top.

Mr Blake: Thank you. If we look at the background, I’ll just read that first paragraph, it says:

“To address the concerns about the Horizon System that have been raised by some subpostmasters over recent years, the Post Office commissioned an independent review of their cases.”

So that’s the Second Sight review.

Gayle Peacock: Yeah.

Mr Blake: “The company that conducted the review issued an interim report on … 8 July 2013. The review made it clear that the Horizon computer system and its supporting provides function effectively across our network.”

Now, having not read the Second Sight report yourself, where was that message coming from?

Gayle Peacock: So that would have been conversations with myself and Angela van den Bogerd.

Mr Blake: So is it something that Angela van den Bogerd had told you?

Gayle Peacock: Yes, as part of our discussions, part of the initiation of the programme.

Mr Blake: Do you think it was unusual to be taking forward a programme that was based on a report that you hadn’t read?

Gayle Peacock: In hindsight, yeah, I should have asked to see the report but I trusted the information that was being told to me.

Mr Blake: Thank you. If we look at the “Scope”, slightly down on the page, it says:

“The interim report identified the following areas of concern which will be included within the scope of the Programme.

“Post Office’s attitude to subpostmasters which is often defensive and unsympathetic …”

So that’s very close to what was written in the report itself.

Gayle Peacock: Yeah.

Mr Blake: “Inadequate Helpdesk support with responses that are script based, coupled with a decrease in overall branch support.

“Lack of timely, accurate and complete information provided to subpostmasters to support them in resolving issues.

“Inexperienced trainers and gaps in training coverage.

“Lack of centralised data or files specific to each branch which hinders the quality investigation from taking place.”

Now, some of those do match what the Second Sight report was saying.

Gayle Peacock: Mm-hm.

Mr Blake: There is, of course, the absence there of the mention of the bugs and defects?

Gayle Peacock: Yes.

Mr Blake: Was that something that anybody mentioned in the context of your programme?

Gayle Peacock: No.

Mr Blake: One other thing, I think, that was missing from this scope was the reference to (f), which was the lack of a suspense account function, in the Second Sight report; do you recall that final reference?

Gayle Peacock: Yeah, I wasn’t asked to look at that.

Mr Blake: Were you aware of that being a concern?

Gayle Peacock: I think at like a higher level, yeah.

Mr Blake: Insofar as those were findings or based on findings from Second Sight, do you agree that those were problems within the Post Office?

Gayle Peacock: Yes.

Mr Blake: Can we turn to page 2, please. Looking there at the “Governance and key stakeholders”, it says:

“Alice Perkins and Paula Vennells have requested the establishment of the Programme which will be led by Angela van den Bogerd. Gayle Peacock will be accountable for running the Programme on an operational level.”

Had Ms van den Bogerd spoken to you about the Second Sight report?

Gayle Peacock: Yes, she will have done, yes.

Mr Blake: Was she the direct channel from which you were getting the summary of that report?

Gayle Peacock: Yes.

Mr Blake: Did you speak to Alice Perkins or Paula Vennells at all?

Gayle Peacock: Never Alice. I think I spoke to Paula once during the programme but my interactions were with Angela.

Mr Blake: Did any of them express any particular opinion on the Second Sight investigation, the quality of that investigation, whether they disagreed or agreed with it?

Gayle Peacock: I was given an indication that they probably weren’t in the same place as Second Sight and the conversations were difficult but that was as far information that was shared with me.

Mr Blake: Who was sharing that information?

Gayle Peacock: That was with Angela.

Mr Blake: If we look down on this table, these are the different key stakeholders. We have there, for example at the bottom, Rod Ismay, Andy Winn from Finance.

Gayle Peacock: Yes.

Mr Blake: Were they people who you discussed problems with Horizon?

Gayle Peacock: Yes, so I’d had, like, working relationships with Rod, and Andy from my days as network co-ordination.

Mr Blake: Did they express any concerns about the operation of Horizon?

Gayle Peacock: I don’t think so.

Mr Blake: If we go over the page to “Key Deliverables”, so:

“The Programme will be responsible for delivering the following:

“Mapping the ‘as is’ process for providing branch support and the various touch points for branches.

“Undertaking a gap analysis for each of the respective areas regarding the concerns raised in the interim report.

“Producing recommendations for how the relevant gaps will be closed, supported by a deployment and resource plan.”

Was the plan, as far as this programme is concerned, to look at things as they then stood rather than look back at historic cases or did you intend to look at historic cases as well?

Gayle Peacock: I think it was as they stood then.

Mr Blake: So the reference to “as is” for example, is that –

Gayle Peacock: Yeah, it’s the current business operating model.

Mr Blake: Are you aware at this time of any consideration being given to how problems that had been identified by Second Sight in their independent report had impacted potentially on historic prosecutions, terminations, suspensions and things like that?

Gayle Peacock: I knew that obviously there was discussions around if the prosecution policy was actually going to continue or not. I didn’t know anything about the individual cases.

Mr Blake: I mean, let’s say those appeals that you had been part of, the termination appeals, did at this stage, knowing at least the information that had been provided to you about the Second Sight report, did that raise any concerns with you about whether people had been unfairly terminated previously?

Gayle Peacock: Not at that stage because the message was that Horizon was generally okay.

Mr Blake: The message from who?

Gayle Peacock: I think it was just generally across the business. That was just the message that was given.

Mr Blake: Where, at that time, did you consider that message was coming from?

Gayle Peacock: I think it was top down, to be honest.

Mr Blake: “Top” being?

Gayle Peacock: Board level.

Mr Blake: Can we look at page 4, please. “Key Performance Indicators and Measures”, you have there, if we scroll down, a mention of branch losses and debt and then mention of system, robustness of the system. Do you recall how these KPIs were being measured at all?

Gayle Peacock: I can’t recall those.

Mr Blake: Then the final, page 5, at the bottom of page 5, 7 August 2013 is version 3 of this document. It says:

“Input from Programme Board to include additional names, Programme approach, definition of what good looks like and confirmation that the Programme will be run by Gayle Peacock.”

Who in particular do you recall inputting into these terms of reference. It says the programme board but was there anyone who was particularly active or particularly involved?

Gayle Peacock: No, I think it would have been shared with all the stakeholders as well, you know, if you’re named in the document you should see it, so I think they would have all seen it plus Paula and Angela.

Mr Blake: Did you ultimately produce a report arising from these terms of reference?

Gayle Peacock: I can’t recall specifically an end report. I know there was reports in terms of some of the measures on a regular basis, so some of the things that you mentioned in the table above in terms of how things were tracking. I remember producing those on a monthly basis. I don’t know what the end, if there was an end report. I finished on maternity leave before the programme actually finished.

Mr Blake: Are you aware of recommendations having been made?

Gayle Peacock: Yeah, so there was a number of recommendations. So there was the Branch User Forum, which was implemented, there was the investigations team which was the – I can’t remember the term that was used but this was like the investigative function to look at the losses. There was the recommendation to implement the case management system. HORice came out of the back of this as well, which we talked about earlier. There was some tactical changes that were made in terms of things like remittance slips were changed because one side didn’t look like – there was a pick list versus what the branch would rem in, which was confusing.

So there were tactical things, there were duplicate receipt changes, so there were a number of things that were done rather than just wait for the end report but I can’t remember the end report as such because I didn’t produce it.

Mr Blake: Do you know who produced it?

Gayle Peacock: I don’t know if there was one.

Mr Blake: Can we look at POL00043369. I am going to start to go through these Bond Dickinson reports.

Gayle Peacock: Okay.

Mr Blake: Can you tell us the context of those reports?

Gayle Peacock: So these were the notes that were taken from a weekly meeting, so there was a number of business stakeholders that took part in the calls. They were chaired by Bond Dickinson and Legal Services, and the purpose was to understand if there was any branches or issues or technical issues that the business actually needed to be aware of. So it was actually, you know, were there any calls coming to NBSC that we were aware of? Was there anything that was being raised to myself or through other channels that the business needed to be aware of and make sure that the branches issue was actually being resolved by the appropriate person.

Mr Blake: Was it triggered by the Second Sight report? Was it triggered by threatened litigation or something else?

Gayle Peacock: I can’t remember why they were initiated. They were just asked to participate obviously with looking at improvements that could be made for that purpose.

Mr Blake: Were you aware, for example, of the Justice for Subpostmasters Alliance around this stage, 2013?

Gayle Peacock: Yeah, in terms of how it was, you know, on the back of the Second Sight work that was being done.

Mr Blake: So this is the 2 October. You’re mentioned there under “Network”.

Gayle Peacock: Yeah.

Mr Blake: If we turn to page 3, please. They all follow a similar layout, so let’s say we have “Nelson” there. What does that mean?

Gayle Peacock: That would have been a particular branch that was Nelson Post Office.

Mr Blake: It says there:

“GP [I think that’s yourself] has provided the discs to Helen Rose.”

Do you recall this at all?

Gayle Peacock: I recall conversations about Nelson Post Office branch. I’m assuming that those were motor vehicle licence discs that had been returned, I think, the only thing that would be discs.

Mr Blake: Do you know who Helen Rose was?

Gayle Peacock: Helen Rose worked in the fraud investigations team.

Mr Blake: Do you remember her writing a report about Horizon?

Gayle Peacock: I have seen it’s referred to in the additional documents. I haven’t seen that report.

Mr Blake: You didn’t see it at the time?

Gayle Peacock: No.

Mr Blake: Then it says:

“GP made the point that the Horizon issues had already been dealt with and those should not have been raised at the visit.”

Do you remember that? Are you able to assist us at all?

Gayle Peacock: Yeah, I think – so this was a case that the business were already communicating with, so I think this was one that like the case review team were looking at in terms of different things that could be causing the discrepancies. I can’t recall what visit that alludes to, I’m assuming that somebody went out to the branch. Yeah, that’s really the only thing I can remember for that.

Mr Blake: We’ll continue going through those documents but before I do I just want to bring to your attention POL00029677 and that is what we know as the Detica report of 1 October 2013?

Gayle Peacock: Yeah.

Mr Blake: So we’re in October. This was a document that was in your pack. Have you ever seen this before?

Gayle Peacock: I can remember reading it because I think, as part of the input it mentions the non-conformance team, which would have been the branch standards team. So I can remember, I think, the Detica team did come and speak to I think it was some of my team in terms of the data sources that we used, particularly for branch standards. So I think I did see this at the time.

Mr Blake: Can we look at page 11. We have there in the top paragraph it summarises the Second Sight report and what they thought of the Second Sight interim report. It says:

“The initial findings of Second Sight were published during the Pilot. The review was prompted by a public campaign by [subpostmasters] who felt they had been traduced by the Post Office following losses at their branches. Several of Second Sight’s observations resonate strongly, notably the disjointed response by the Post Office and the habitual desire to assign responsibility to an individual rather than to conduct root cause analysis to close gaps persisting across the branch network. In order to have a consistent approach across the [subpostmaster] estate, it is vital that Post Office has the ability to robustly identify and monitor anomalous behaviour, so the appropriate corrective action can be taken (whether this is tactical education, enhanced training, process or system redesign or audit/investigation).”

That’s something you would have read at the time.

Gayle Peacock: Mm-hm.

Mr Blake: Again, I mean did that cause you any concern about, for example, having conducted those appeals in relation to terminations? Did you begin to have any concerns about the Horizon System?

Gayle Peacock: Not on the Horizon System itself, no.

Mr Blake: If we can look at page 37 and 7.2.2, “Complex and fragmented systems”:

“Post Office systems are not fit for purpose in a modern retail and financial environment. Our primary concern here relates to difficulty in reconciling information from multiple transaction systems both in terms of timeliness, structure and access.”

Are you aware of this report having caused anyone, for example those who attended those meetings Deloitte – with Bond Dickinson, sorry, any concerns about the Horizon System.

Gayle Peacock: I don’t think so. I don’t think this report sort of highlighted any problems with Horizon.

Mr Blake: So you didn’t read that as being related to Horizon?

Gayle Peacock: Not how Horizon was performing itself. I think there was the acknowledgement that the system integration and the multiple systems wasn’t easy but I don’t think we read that as that undermined Horizon itself.

Mr Blake: The references to the Second Sight report that I took you to earlier and about concerns about not conducting root cause analysis to close gaps persisting across the branch network, and things like that, that didn’t cause any concerns relating to the Horizon System?

Gayle Peacock: No, I don’t think so.

Mr Blake: Can we look at POL00043370. It’s another one of those meetings, 9 October. In that first box we have mention of:

“Helen to see if she can link transactions to specific time. GP to report update in due course.”

Was that Helen Rose again?

Gayle Peacock: Yes, it was, yeah.

Mr Blake: Do you recall what this might be talking about at all?

Gayle Peacock: I think Helen must have been looking to see if there was any investigation that she was doing. I’d have asked her to undertake an investigation for the press brief, to see if there was any information that she could provide.

Mr Blake: If we go over to page 2 and it’s the bottom of page 2 that I’d like to look at. Andy Hayward from Security. Is this the person who was reporting a particular issue?

Gayle Peacock: Yes, it would have been, yes, so the person on the left is the person who is speaking.

Mr Blake: So:

“2004 – Carluke Post Office – Police prosecution believed to have happened. Blaming Horizon at the time. Elaine Doram SPM passed away. Husband blaming Horizon and making noise through Scottish Parliament. Email details to forwarded. No information due to time lapse. No records available. No further enquiries at this stage.”

Was there, at this stage – so we’re still October 2013 – any questioning amongst those who attended these meetings or amongst the senior leadership of the safety of those kinds of prosecutions?

Gayle Peacock: That wasn’t discussed on this call, no.

Mr Blake: It’s referring to a 2004 case, so was it looking back or was it because somebody had called –

Gayle Peacock: The purpose of the call was obviously to – you know, any conversations that were being had, so Andy would have raised that as part of this weekly meeting to say this issue has now been raised and, actually, as the business, you need to be aware that the case from 2004 has now been raised and people are starting to talk about it again.

Mr Blake: Was nobody querying at that meeting or at the series of meetings, any concern about the reliability of convictions?

Gayle Peacock: We didn’t discuss it.

Mr Blake: At this meeting and at many of the meetings you have people from the legal team, so Rodric Williams, Jarnail Singh, Martin Smith of Cartwright King, Kayleigh Harding. You’ll have seen in your pack that there was advice given by a barrister, Simon Clarke, on 15 July 2013 –

Gayle Peacock: Yes.

Mr Blake: – so before these meetings took place. I don’t need it to be brought on screen but, for the purpose of the transcript, it’s POL00006357. That raised serious questions about expert advice that can be given in prosecutions.

Gayle Peacock: Yes.

Mr Blake: Were you aware of that at this time?

Gayle Peacock: I’d never seen that report until you sent it. I was aware that they were stopping the prosecutions but I didn’t know the reason why.

Mr Blake: Martin Smith of Cartwright King, for example, or Jarnail Singh, did any of them ever mention Gareth Jenkins, for example, at any of those meetings?

Gayle Peacock: It was mentioned that he was the expert witness that was often used in prosecutions but, other than that, Gareth wasn’t discussed.

Mr Blake: So there was no mention of any concern about the reliability of his evidence?

Gayle Peacock: No.

Mr Blake: What was the general attitude of those present when things like Carluke Post Office were bought up? Was there some scepticism?

Gayle Peacock: Um, I don’t think so. I can’t –

Mr Blake: The reason I ask is the way it’s phrased here, “Husband blaming Horizon and making noise through Scottish Parliament”. Making noise is a phrase that cropped up a couple of times.

Gayle Peacock: It’s derogatory, yeah, because they don’t believe it, I guess – I don’t know why they would have used that phrase. The notes were written as somebody said it but I can understand how that’s interpreted that, yeah, there’s a cynical view that it’s been made noise.

Mr Blake: How did that kind of language sit with, for example, the Branch Support Programme that had been going on, a more listening approach, perhaps, to branches, the branches’ concerns?

Gayle Peacock: I didn’t pick up on that at the time and I perhaps should have.

Mr Blake: Can we look at POL00043371. 16 October now. So there are lots and lots of meetings. This is a very intense period of –

Gayle Peacock: It was weekly, yeah. I can’t remember for how long but it was every Wednesday for a number of months.

Mr Blake: Do you know who instigated them?

Gayle Peacock: I think it was Security, I think.

Mr Blake: So they had asked for this series of meetings to take place?

Gayle Peacock: Yeah, and I presume it was on the back of obviously having seen the information about the disclosure document in the pack, that this was deemed to be the right forum to make people aware of what was going on in the business.

Mr Blake: When you say disclosure, do you mean the Simon Clarke advice?

Gayle Peacock: Yes.

Mr Blake: So you hadn’t seen the advice?

Gayle Peacock: No.

Mr Blake: Were you aware of it?

Gayle Peacock: No.

Mr Blake: Were you aware of some other purpose for the meetings? You’ve drawn the link between the Simon Clarke advice and the meetings, can you now reflect on it and think that there was a link?

Gayle Peacock: Having now seen the document, I now view it differently to how I did before. Before my view was actually we just needed to get these branch issues resolved, (a) know about them and (b) do something about it. Now, having seen the documents that led to it, it puts a slightly different view on it.

Mr Blake: We have there attending this meeting security Dave Posnett.

Gayle Peacock: Mm-hm.

Mr Blake: Is he someone you knew well?

Gayle Peacock: Yeah, I knew him reasonably well. He worked, I think, in the fraud team in Security.

Mr Blake: If we turn to page 2, about halfway down in the left-hand column you have the name “Martin Griffiths”?

Gayle Peacock: Yes.

Mr Blake: It says there “DP”, that’s presumably Mr Posnett?

Gayle Peacock: Yes.

Mr Blake: “… No further details on Horizon issue. SPM passed away.”

Were you aware that Mr Griffiths was terminated in the summer of 2013 and on 23 September 2013, he committed suicide and on 11 October, so just shortly before this meeting, his life support machine had been turned off.

Gayle Peacock: I think this was – I was aware of – that he’d attempted to commit suicide. I think this was the meeting where it was confirmed that he had passed.

Mr Blake: So there was discussion at these meetings of Mr Griffiths having –

Gayle Peacock: Passed away.

Mr Blake: It says “passed away” there but the actual background, was that discussed. So that the link, for example, to Horizon, was any link drawn between his suicide and Horizon?

Gayle Peacock: We knew that, I think, obviously there was claims being made at the time.

Mr Blake: What was the attitude at this meeting: condolences, concern or business as usual?

Gayle Peacock: Well, it’s obviously condolences as well. It’s never nice when somebody passes away.

Mr Blake: But was that the atmosphere at the meeting? Was there – it may strike people as a significant moment in time, in the history of Horizon. Did it strike anybody on that occasion as significant or not?

Gayle Peacock: I think it would have done, I can’t particularly remember the instances of this particular call.

Mr Blake: If we go down, please, to South Darenth:

“Question as to whether NBSC properly capturing complaint.”

Not in relation to this particular incident but just speaking more broadly, were there concerns that the NBSC weren’t properly capturing complaints?

Gayle Peacock: I think so and that was one of the things that we were looking at as the Branch Support Programme, is how can you get advisers to – because I think it was quite apparent that people were just putting “KB”, so you’d look at like a call log history into the Network Business Support Centre to try to find at what had happened and there were instances where the adviser was putting “KB” which referred to Knowledge Base. So they weren’t actually recording in some instances what had been said to the postmaster and this was the work that we were trying to do with them, because actually when you’re trying to look at a case, KB isn’t a useful piece of information to work out what happened or what was told to the subpostmaster to try and rectify any problem.

Mr Blake: Do you know how long that had been going on for? Is that a historic problem, a long lasting problem?

Gayle Peacock: I think it was fairly historic, yes.

Mr Blake: If we scroll down over the page it says:

“RW – Once Horizon disputed, it needs to be flagged. SPM to be questioned as to where discrepancy exists. To prevent further issues in debt recovery process.”

What do you understand that to mean?

Gayle Peacock: I think Rodric was just reinforcing the fact that, as soon as anybody mentions any concerns, actually we need to know about it.

Mr Blake: If we scroll down on this page, please, there is an entry there with “GP” on the left-hand side at the bottom. It says:

“Rodmill – issues log amalgamated. Complaint sent before Second Sight came into play. Direct to Paula.”

Are you able to tell us what you think that meant?

Gayle Peacock: I think that would have been a complaint that would have gone into Paula before the Second Sight work had actually been commissioned.

Mr Blake: So are you aware – and we will come on to this because I know you were part of the executive correspondence team – but did subpostmasters and others send complaints direct to Paula Vennells?

Gayle Peacock: Yes.

Mr Blake: Where would they go from there, typically?

Gayle Peacock: It would depend on what the complaint was about. So it was usually, depending on the nature of the complaint that it was raised, it would be taken up with the senior manager responsible for that department. So if it was a Post Office kept closing, it would be the regional manager. If it was a stock or cash issue, it would be supply chain. If it was branch accounting, it would go to the head of branch accounting, and they would be responsible for investigating the complaint and then providing a resolution.

Mr Blake: It says:

“Complaint cited many issues with Horizon. Stock reconciliation, numbers do not match and challenged. Recording of 1st and 2nd class label sales. Not clear whether this has been investigated.”

Is this something you remember, this particular incident?

Gayle Peacock: I can’t remember this but I think it would have been triggered by the executive correspondence team. I didn’t manage them at the time but they would have approached us, based on the work we were doing and saying, “You need to have a look at this one because we think that’s got further evidence.”

Mr Blake: If we scroll over the page, it says:

“GP to look into which branches with complaints that have not been dealt with and report back.”

Gayle Peacock: Yeah, so that would have been going through the logs with the executive correspondence team, so they captured all of the complaints that were fed to Paula. So I’m assuming with that it would have been looking back on in any historic records and seeing if there were any similar ones that had been overlooked.

Mr Blake: Thank you.

I’m going to move on to POL00040066. If we could zoom in on the top there, it says:

“Post Office Limited, Initial Complaint Review and Mediation Scheme, Overview of Horizon and Branch trading practices.”

Can you tell us the background to this document?

Gayle Peacock: I can’t remember the document but obviously I must have input it at some point because my name is on there. I think it was produced on – in preparation for the mediation process or there were a number of branches that were going through that process to try to reach an agreement on, you know, how to resolve their case. I think this was various information that was put together to try to give the mediator some knowledge about Post Office branches and the types of issues that they may have.

Mr Blake: Do you remember the period. I don’t think it’s dated, this is a draft?

Gayle Peacock: I think this would have been about 2014, I think.

Mr Blake: Thank you. If we look at page 23, we have there a section entitled “Possible reasons for balance discrepancies”. I’ll wait for it to be bought up on the screen. As you said, it has your name here.

Gayle Peacock: Yeah.

Mr Blake: It seems as though you co-wrote this with Angela van den Bogerd or certainly –

Gayle Peacock: Collated some information or something, yeah.

Mr Blake: Do you know who would have written it or who would have taken the lead with it? Would it have been you or Ms van den Bogerd?

Gayle Peacock: It was possibly me, I think. As I say, I can’t recall writing it but because my name is on there, I must have input it at some point.

Mr Blake: You previously explained that Ms van den Bogerd was – had detailed knowledge of the Second Sight report –

Gayle Peacock: Yes.

Mr Blake: – but at this stage you didn’t?

Gayle Peacock: Yeah, I hadn’t seen it.

Mr Blake: If we look down, these are reported as possible reasons for balance discrepancies. If we scroll down, the first is a “Mis-key” so that’s a staff entering the wrong value. Over the page, “Connectivity”, next, “Cheque handling”. Next, “Staff actions”. There wasn’t, in any of this explanation of possible reasons for discrepancies, any mention of bugs, errors or defects with Horizon?

Gayle Peacock: No.

Mr Blake: Having seen the interim Second Sight report now, are you surprised that that wasn’t mentioned?

Gayle Peacock: Well, yeah, we would have included something – if we’d known there was the possibility of error, it should have been included in there.

Mr Blake: During your discussions with Ms van den Bogerd in relation to this chapter, or whatever we might call it in this document, did she ever mention to you the possibility of bugs, errors and defects as being a possible reason for a balance discrepancy?

Gayle Peacock: No.

Mr Blake: I’d like to look at your statement, please. I don’t have many questions left, just so we’re clear for timing. Your statement is WITN06160100 and it’s paragraph 124, I’m going to give you the page number. Page 42. So 124 you’re talking I think about the HORice system?

Gayle Peacock: Yeah.

Mr Blake: Then 125, you say:

“The processes followed and improvements that I identified were based on the assumption that the Horizon System could not cause discrepancies and cash shortfalls. Had I known then about the issues with the system and the impact it could have had, then this would have completely changed my approach to the processes I was involved with.”

You’re talking here, I think, about 2014 and the work you carried out in 2014.

Gayle Peacock: Yeah.

Mr Blake: So as at 2014, despite working closely with Angela van den Bogerd, you still, at that stage, weren’t aware of the fact that the Horizon System could cause discrepancies –

Gayle Peacock: No.

Mr Blake: – in cash shortfalls. I mean, looking back at that now and considering that in what you now know, are you surprised that you didn’t know and can you come up with an explanation as to why you think you didn’t know and weren’t told?

Gayle Peacock: I don’t know, really. Whether it’s because the Post Office didn’t believe that it could be an issue, so discounted it. I don’t know.

Mr Blake: If we scroll down to paragraph 129, that’s page 43, you say:

“Even when the claims about Horizon started to be known within the business, the messaging coming from the business was that the system was not capable of impacting the accounts. I made the assumption that the business had undertaken the relevant due diligence”, et cetera.

Gayle Peacock: Yeah.

Mr Blake: You refer to the business. Are you able to tell us who in the business you considered that messaging to be coming from?

Gayle Peacock: Well, it was evident in, you know, sort of the way that the group exec was talking. You know, you’ve seen some from the comms from Tony Jamasb, those kinds of statements that was what was just in the business, that was the language that was being used.

Mr Blake: Where in particular do you think that message was coming from? Who in particular was that message coming from?

Gayle Peacock: I would assume that that would be board.

Mr Blake: Anybody particularly? I mean, the board is made of a number of people.

Gayle Peacock: But I don’t think anybody can just do that one message. It’s got to be – the board have got to agree to those messages. You know, when you’re communicating something so serious, I don’t think it can just be one person that says, “This is what it is”. Everybody who is – is communicating that message at the board level needs to sign up to that.

Mr Blake: Anybody in particular within the board that you felt was driving that message?

Gayle Peacock: Well, I think – well, I don’t know. I’ve no evidence to suggest who it would be, you know.

Mr Blake: I’m going to move on to the Branch User Forum. I think you’ve said it was established in 2014 and arose as part of that work that you had been carrying out.

Gayle Peacock: Yes.

Mr Blake: Who formed part of that forum?

Gayle Peacock: So it was group of subpostmasters. So I think there was a communication that went out to branches that invited people to participate, and then they would literally just apply, and a decision was made. Angela chaired it I think the first time it was set up. I think there was about six to seven postmasters, and then in 2017, when Angela moved on to a different role, I took it over. And we invited people to apply again, and took a range of postmasters.

Mr Blake: Do you remember a subpostmaster called Tim McCormack?

Gayle Peacock: I do.

Mr Blake: Do you recall any particular interaction with him?

Gayle Peacock: Yes.

Mr Blake: Can you tell us about it?

Gayle Peacock: So Tim wanted to be part of the Branch User Forum. He was quite vocal. I’d conversations with him. I understood, you know, some of his concerns, some of his frustrations. And we had perfectly decent conversations and I think – I can’t remember what happened, but then I think I stopped communicating with him because the messages to myself became quite aggressive. So I would get texts messages on a Saturday, you know, completely disagreeing with some of the, you know, the information that I was telling him, and then that was the extent that I stopped my communication with him.

Mr Blake: What do you recall of the concerns that he was raising?

Gayle Peacock: I can’t remember the specific time but I think, you know, it was obviously – he wanted to make some improvements to the way the Post Office was operating, which was absolutely fine. I think he’d had an IT background, I think, from what I can recollect, and I think he wanted to make some, obviously, some suggestions and improvements. I think that’s what his general sort of response was about.

Mr Blake: If it’s suggested that he was excluded from the user forum by Angela van den Bogerd, would you agree or disagree with that?

Gayle Peacock: I think I’d probably partially agree. I think if there were some concerns, you know, constructive criticism is absolutely fine. I think there was some – I don’t know, if it was going to be a challenging discussion, you’d want to make some outputs. I think I’d probably agree with that statement.

Mr Blake: Looking back now at how serious everything in fact was, do you think it was a mistake to exclude him from that forum?

Gayle Peacock: I don’t think anybody with – should be excluded if, you know, if they’ve got suggestions to make. I think there was probably some disagreements over behaviours.

Mr Blake: At paragraph 92 of your witness statement you also refer to feedback sessions. Are they separate to the Branch User Forum, or are they something different, or …

Gayle Peacock: Yeah, so this was separate. So on the back of – you know, in order to validate, there was some of the findings. Myself and Anne, who worked with me at the time, in order to sort of gauge what some of the issues were, there was a number of people around the business that we spoke to, and postmasters. So this was on the back of the thematic issues that had come out in terms of training and support. So it was very much about, you know, what could we do differently? What ideas have you got? Et cetera, et cetera.

Mr Blake: You refer to a range of stakeholders. Are you able to tell us – give us a little bit more detail?

Gayle Peacock: Yeah, so it would have been postmasters. Basically anybody who had direct intervention with postmasters. So I spoke to Network Business Support Centre advisers, contracts advisers, field support trainers and auditors, people in Product and Branch Accounting, security advisers, the National Federation of SubPostmasters. People who had that interaction themselves.

Mr Blake: You mentioned the NFSP. Were there any other unions, such as the Communications and Workers Union?

Gayle Peacock: No, it was just the National Federation of SubPostmasters.

Mr Blake: Any reason why it was them in particular?

Gayle Peacock: I think there was discussions internally around, you know, the National Federation of SubPostmasters was the recognised union of the postmasters. I don’t think the Post Office recognised the CWU formally as the union of postmasters, therefore we weren’t encouraged to talk to them.

Mr Blake: The final topic that I have is the Executive Correspondence Team. That seems to be from 2015, I think, when you were head of Branch and Customer Support.

Gayle Peacock: Yeah.

Mr Blake: Can you give us a flavour of the kinds of correspondence that subpostmasters and their assistants or managers made in relation to bugs, errors and defects in Horizon, how early were they corresponding on those issues in your time? How often?

Gayle Peacock: I can’t remember any specifically. I don’t know if there was a process that was set up with Legal Services because of the potential litigation that we almost didn’t deal with those, if that makes sense. I think it was one of those where if that was where it was flagged, I think they were put to the Legal Department. I can’t be 100 per cent sure, but I think that that – based on, obviously, what was going on at the time, I think it had been agreed that that’s the process that would follow. So we didn’t attempt to respond to those ones. That would go to Legal Services.

Mr Blake: Typically, in relation to correspondence, how would you interact with the CEO or other executives? I mean, did you have a direct line to them? Would you raise significant issues with them?

Gayle Peacock: Yeah, you could ask to speak to, you know, anybody at whatever time. They needed to be aware, especially if they’d been written to, because it was usually that person would say “Can you respond to that one?” Because sometimes they would go to their personal email address which they’d pick up, and then it would end up being back with the correspondence team, or it would be via an MP or whatever. But yeah, you could approach any of the board members. And, you know, if there was a particular one that – in the main, they were happy that you were dealing with those issues, but if there was a particularly sensitive one then the door was always open to have that discussion. And especially if you were writing back in somebody’s name, they had to sign that off.

Mr Blake: I think you’ve said that typically, the letters about bugs, errors and defects would go to the legal team?

Gayle Peacock: I think they did, yeah.

Mr Blake: Was that an instruction from somebody?

Gayle Peacock: I think that probably would have come from Legal Services. So Jane MacLeod and her team, I think it probably would have been, at the time.

Mr Blake: So do you recall an instruction from them that if people are communicating about bugs, errors and defects, they should send them to them, rather than to deal with them within your team?

Gayle Peacock: I can’t be 100 per cent sure, but the fact that I can’t remember dealing with any would suggest that that’s what happened. That’s my recollection. But I can’t be a hundred per cent sure.

Mr Blake: Thank you. Finally, could we just have a look at paragraph 146 of your statement so WITN06160100. Page 49. It says:

“My experience of working in the Post Office was that it operated within a strict risk control framework and there were processes in place for making decisions. Any change to policy, approach, request for funding, etc, had to be signed off at the highest levels, sometimes including a shareholder, and it did not appear that individuals could make decisions in isolation or outside of their remit. Before the separation of Post Office from Royal Mail Group, there were internal processes for approvals, and then this would go to the Royal Mail boards for further approval. Once decisions had been made and strategies agreed, this then filtered down into individual objectives at every level in the organisation. It wasn’t an environment where you could just do what you wanted if you felt like it.”

Was it an environment where it was difficult to speak out?

Gayle Peacock: Um, I think it depended on the individual. I personally didn’t feel as though – you know, if I’d an issue, I felt that I could raise it. I think some people felt they couldn’t, for whatever reason. There was the whistleblowing line. There were sensitive cases that people did speak out that, obviously they went to the Executive Correspondence Team, that I was privy to, because obviously it was my team that they were responding to. So people were raising issues. People were encouraged to say what they think. Whether it was agreed with is a different matter, but I, on a personal level, didn’t feel like I could not raise something.

Mr Blake: We’ve looked at, for example, the Second Sight report that wasn’t shared with you. Was there, in respect of bugs, errors and defects, information that was kept from you, do you think, intentionally?

Gayle Peacock: I don’t know. And I’ve reflected on this, obviously, since you sent the information. And, you know, when you’re asked a question in the statement, “Well, why were you selected to do the Branch Support Programme?”, the positive side of me goes: because I thought I had the right skills to do the job. Having seen some of this stuff, the cynical part of me goes: well, was I picked because I would do what I was told? I don’t know. I trusted the people that I worked for. I accepted the information that was in good faith.

So I didn’t – I don’t know what they kept from me. I wouldn’t like to think that we were deliberately doing that, but I couldn’t – unless you asked them. I don’t know.

Mr Blake: Thank you very much, Ms Peacock. I don’t have any further questions.

I think there is a small number of questions.

Sir Wyn Williams: Yes, I am anxious that the transcriber shouldn’t be asked to continue unless it really is just five or ten minutes, maximum. All right.

Mr Jacobs: Sir, I think I’ll be five minutes.

Sir Wyn Williams: Nobody else?

Mr Blake: Ms Page?

Ms Page: I mean, if I were 10 minutes, then – I don’t think I will be but –

Sir Wyn Williams: I think we will just take a few minutes’ break so that the transcriber can just have a short rest, and she’s not very well. We’ll come back again at quarter past, and then we’ll be as swift as we can be. How about that?

Mr Blake: Thank you.

(3.06 pm)

(A short break)

(3.16 pm)

Sir Wyn Williams: Mr Jacobs.

Questioned by Mr Jacobs

Mr Jacobs: Thank you, sir.

Ms Peacock, good afternoon. I represent 156 subpostmasters, who instruct Howe+Co, who instruct me. You told Mr Blake earlier on this afternoon that a lot of your career was spent providing support to subpostmasters; is that right?

Gayle Peacock: Yes.

Mr Jacobs: You also said, when you were asked about unprofessional conduct of auditors, you couldn’t remember any examples?

Gayle Peacock: Not that had been raised to me.

Mr Jacobs: I want to ask you about within of our clients, Shazia Saddiq. I don’t know if you’ve followed the Phase 1 of the hearings when the subpostmasters gave evidence last year?

Gayle Peacock: No.

Mr Jacobs: Well, her evidence was read in to the record on 16 March 2022, and just as a whistlestop summary, she was a subpostmaster with three branches in Newcastle, and she paid over £10,000 in relation to alleged shortfalls. Post Office demanded another £20,000 off her in relation to further alleged shortfalls, and she was a victim of cyber fraud as a result of the Horizon System being vulnerable, she says, to hackers, and the Post Office held her liable for the recovery of that theft by third parties in the sum of £33,000.

Gayle Peacock: Is this the MoneyGram one?

Mr Jacobs: The MoneyGram one.

Gayle Peacock: Right.

Mr Jacobs: Do you remember?

Gayle Peacock: I do, yes. Yes.

Mr Jacobs: Shall we go, then, to Ms Saddiq’s statement, and that is at WITN02230100. Page 7 of 16, please. Thank you. That’s on screen. So if we look at paragraph 32, you’ll see, as you correctly say, the MoneyGram transfer?

Gayle Peacock: Yes.

Mr Jacobs: She was initially told that only her branch was affected but later it was accepted that it affected 11 other branches, she says. My client’s evidence is, at paragraph 34, that the Post Office wrote to her and told her that it would be holding her responsible for the losses calculated at nearly £34,000.

Gayle Peacock: Mm-hm.

Mr Jacobs: So if we could then go to paragraph 35, which is the one I particularly wanted to ask you about. So she says that on 20 August 2014, she met with Rachel Lax and you, and you described yourselves as Post Office internal investigators. You reviewed her personal finances in detail to determine what payments she could afford to make towards this sum of money that was stolen, she said, while at the Horizon System. So do you recall that meeting?

Gayle Peacock: I do, actually. I can’t recall – I think I would have said “I’m investigating the issue.” I don’t think would have said “I’m an investigator”, but I do remember the meeting, yeah.

Mr Jacobs: Well, then, we’ll move on to what Ms Saddiq has to say about the meeting, which is over the page at paragraph 36, please. So she says:

“This was a deeply humiliating experience, as they were looking through all my personal bank and other records. And this was done in a public area of Holiday Inn Hotel. As they looked at my records, they made comments about where I bought my children’s shoes from. This was none of their business. I was also embarrassed as I lived very humbly; I spent as little as I could on myself and maintaining my family, so it was humiliating to have strangers pore over my personal accounts in public and see how little I spent on myself and my children.”

I want to ask you some questions about that. Why was the meeting held in a public area in a hotel?

Gayle Peacock: Because that’s where she requested it to be held.

Mr Jacobs: We understand that this is where you suggested it was to be held?

Gayle Peacock: I didn’t know the area at the time, and I asked to meet at her branch, and this was where she suggested that we meet.

Mr Jacobs: Did you think it was appropriate to ask her to go through personal detail in a public area?

Gayle Peacock: In hindsight, probably not. At the time she didn’t mention it, but then I guess she probably – if she felt that she couldn’t raise it to me. I’m really disappointed that I’ve had that effect on her. I didn’t know that.

Mr Jacobs: If we go to paragraph 37, please, you’ll see she goes on to say:

“At the end of this humiliating meeting where it was made clear that I had no money to pay the Post Office to make up for the crime (the MoneyGram cyber attack) that had been perpetrated against my Post Office, the investigators said they would put a charge on my properties. They said this as though they were doing me a favour.”

Do you recall that?

Gayle Peacock: There was some discussion internally about the whole MoneyGram issue anyway, in terms of the number of branches that were affected. There was sort of a decision around who would be held liable, what the approach would be. We did talk about how her business was performing, and her income levels. I’m not going to deny that. I knew that that was an approach that the Post Office could take. I don’t think we ended up going down that route. That’s not my interpretation of the meeting, but if that’s what she said, then that’s what she said.

Mr Jacobs: You’ve said just now that – and the transcript keeps jumping around – you’ve said that you regret that it had this effect on her?

Gayle Peacock: Mm.

Mr Jacobs: Do you regret the way you and your colleague conducted this meeting, in light of her evidence now?

Gayle Peacock: If that’s how it made her feel, then yes.

Mr Jacobs: Can we go to paragraph 39. She subsequently had a breakdown as a result of the pressure that the Post Office were putting her on.

Gayle Peacock: Okay.

Mr Jacobs: The question that Ms Saddiq wants me to ask is: do you accept that this was insensitive and unprofessional as a way to behave towards a businessperson?

Gayle Peacock: Yes, if that’s the – yeah.

Mr Jacobs: Now, you said earlier on in your evidence that you weren’t aware of any complaints that had been made in relation to audits. I just want to ask you; a number of our clients gave evidence in the Phase 1 hearings and they said that the Post Office adopted a tactic, seemingly, of humiliating them in public. Shahnaz Rashid and Heather Earley talk about surprise audits where auditors marched into their branches that were full of customers, and closed the branches down, and Katherine McAlerney talks about “aggressive questioning” of her in front of her customers.

Are you aware of auditors and investigators adopting these tactics when there investigating subpostmasters?

Gayle Peacock: I think, when we did the review on the Second Sight, I think there was the feedback that some of the security team were maybe being a bit too masculine in the approach, and aggressive in terms of, you know, as you delve into some of the feedback and ask people about their experience, that did come to – you know, there was a feeling, but I didn’t have any specific – I couldn’t give you a branch, for example, to say this one was raised with me.

Mr Jacobs: You, I think, were taken by Mr Blake to paragraph 129 of your statement. I don’t think we need to turn it up. Well, I know you’ve got it, because I can see it there, so perhaps we will turn it up. You say:

“Even when the claims about Horizon started to be known within the business, the message coming from the business was that the system was not capable of impacting the accounts.”

The question that my clients have asked me to ask you is, looking back now – and I know, just interjecting, that you talked about comments where people were saying that subpostmasters were making noise and you said there was a cynical attitude. Looking back, do you accept that the Post Office’s refusal from the top to countenance the possibility of errors led to a high-handed and unprofessional treatment of subpostmasters by auditors and investigators?

Gayle Peacock: I didn’t experience that personally, but I could see how that was correct in some cases.

Mr Jacobs: That the view from the top led to the mindset of the investigators in this way?

Gayle Peacock: Um, yeah, I think it was – you know, a dismissive approach will filter down.

Mr Jacobs: I just need to ask to see if I’ve got any more questions to ask you. Thank you. I haven’t got any further questions.

Sir Wyn Williams: Ms Page?

Questioned by Ms Page

Ms Page: Thank you. I also represent some subpostmasters.

You’ve told us that you were aware of the discontinuance of prosecutions?

Gayle Peacock: Mm-hm.

Ms Page: End of 2013 going into 2014?

Gayle Peacock: Yes.

Ms Page: How did you come to know about that?

Gayle Peacock: That was just discussed as part of the Branch Support Programme, the conversations with Angela. We were obviously working with security and Legal Services quite heavily as part of that – as the programme saw, I was made aware that, you know, it was pausing, given everything else that was going on.

Ms Page: When you say “everything else that was going on”, what do you mean by that?

Gayle Peacock: So, you know, obviously the Second Sight review, the claims that were being made. That kind of stuff. The view that I got was, you know, that it wasn’t appropriate to continue prosecuting, and that was a message which you accepted.

Ms Page: When you said it just now, you said “pausing”. Was that something you understood at the time? Was that the way it was being expressed, or was it going to be stopped completely?

Gayle Peacock: I don’t think anybody had made a decision. I knew we weren’t going to, but I didn’t know – I didn’t get the impression – I didn’t know whether it was permanent at the time, or whether it was pausing, or whether it was stopping.

Ms Page: When you had those conversations, do you remember if that came from Angela or from Security, or both?

Gayle Peacock: I think it came from both.

Ms Page: Now that you’ve seen the documents from Mr Simon Clarke you’ve drawn a line between that and the discontinuance of prosecutions. Can you just help us with your reasoning there and your conclusion? Why have you drawn that line?

Gayle Peacock: What do you mean by “draw the line”?

Ms Page: You said, “Now I’ve seen the documents from Mr Clarke I can see why they stopped the prosecutions”. What makes you say that?

Gayle Peacock: Well, because I think that they hadn’t disclosed the fact that actually bugs could do it. So I can now see the reason why the prosecutions had stopped: because there was the potential that the prosecutions were unsound.

Ms Page: Then, during those conversations with Ms van den Bogerd and the security people – by which you mean presumably Mr Posnett, do you?

Gayle Peacock: No, Mr Scott. It will be John Scott who was head of Security at the time.

Ms Page: John Scott. Did either of them ever mention to you the idea that there might be a litigation risk that needed to be notified to POL’s insurers?

Gayle Peacock: No, I can’t remember that.

Ms Page: Just sticking with Mr Clarke’s advices for a moment, in your pack from the Inquiry – you’ve had two, haven’t you?

Gayle Peacock: Yes.

Ms Page: You’ve had the one which relates to Mr Jenkins and the one which relates to the minuting of the weekly Horizon meetings.

Gayle Peacock: Yes.

Ms Page: That second one, about the minuting of the Horizon meetings, albeit you didn’t see it at the time, were you aware at the time that there was an issue around the minuting and the keeping of the minutes?

Gayle Peacock: I think when, obviously – because I think Bond Dickinson undertook the note-keeper roles. I think there was a paralegal involved in the weekly meetings, and I think when – because it varied week on week. I think it was mentioned at the start why the paralegals had basically to make sure that it was fully documented, and I think that was the extent of which it was introduced.

Ms Page: So you weren’t aware at any time that there was an issue around the keeping of those minutes or the keeping of them securely?

Gayle Peacock: No.

Ms Page: The representatives from security. Second Sight had found at this stage that there was a focus in security on asset recovery solutions without further establishing the underlying root cause of the problem.

Gayle Peacock: Mm-hm.

Ms Page: Is that something you would have recognised at the time if you had have been told about it?

Gayle Peacock: Sorry, what do you mean by that?

Ms Page: If you’d have read that Second Sight report which had that finding in it, is that something that would have chimed for you at the time, knowing the people that you knew from Security, Dave Posnett, Rob King?

Gayle Peacock: Yes.

Ms Page: Then on Mr Griffiths, after that meeting that we’ve looked at the note of, did you hear any more about him from Ms van den Bogerd?

Gayle Peacock: So I think they attended the funeral of Mr Griffiths. I think there was – I can’t remember if Angela attended. I think Anne Allaker did attend on behalf of Post Office. And they were talking to the family. I don’t know the ins and outs of the conversations. And that was the extent of the knowledge on that particular case.

Ms Page: So you didn’t hear anything about a settlement made to the family?

Gayle Peacock: No. I presume it might have gone through mediate – one of the mediation cases, potentially, but I can’t confirm that.

Ms Page: On the Detica report, would you accept it was covering some of the ground that you were given to look at in the Branch Support Programme?

Gayle Peacock: Yes.

Ms Page: Was it given to you with that in mind, as it were?

Gayle Peacock: I think it was. I think it was to sort of – I think the Detica report, it was – they were trying to do a business case to actually progress Detica into the business. And I think I saw it to see if there were themes that we were picking up. But yeah, I think it was just to substantiate some of the issues. Some of the stuff in the Detica report wasn’t surprising.

Ms Page: Would you accept it was quite a critical report?

Gayle Peacock: Yes.

Ms Page: In light of that, is it perhaps a bit surprising that it wasn’t mentioned in any of the Branch Support Programme documentation? It wasn’t discussed more widely?

Gayle Peacock: In what way? The issues? Because the Detica report didn’t seem to have a lot of recommendations.

Ms Page: The issues that they found, the problems that they found?

Gayle Peacock: Um, I think we probably did discuss them. Whether it’s been documented or minuted, I’m not sure, but we were definitely aware of them.

Ms Page: Just finally, with the benefit of hindsight, and I appreciate what you’ve been quite sort of careful about thinking about things in terms of at the time and hindsight, this is specifically a hindsight question. Do you think that, given that the Second Sight review was sort of rather filleted for you, if I can put it that way, that it – the bits that were filleted out and given to you for the Branch Support Programme to look at, do you think that was really a sort of a sop from POL Management, to seem as if they were taking the concerns seriously? To seem as if they were acting on Second Sight’s recommendations whilst actually blocking or impeding those investigations?

Gayle Peacock: I can see how you make that interpretation. I think my perspective of it, I felt, you know, there was a genuine need and requirement to change some of the things that were given to us. I genuinely believed that that wasn’t paying lip-service. I think in some ways, the Second Sight report in that aspect gave momentum to some of the feelings that, you know, were known. I don’t think the issues that we were looking at were actually paying lip-service. I think people, you know, genuinely wanted to change those areas. I don’t think it was as a distraction, not – I don’t know why they didn’t consider the Horizon stuff as seriously as they did, but I genuinely believed that they wanted to change things for the better.

Ms Page: At the time?

Gayle Peacock: At the time.

Ms Page: Looking back?

Gayle Peacock: I don’t … the cynical part of me says yes, maybe a little bit, but I think it was too much hard work for it to completely be, like, dismissed and a sop. I think the genuine – you know, to improve things for postmasters was there. Whether you want to accept that, that’s entirely up to you. I personally believe that the genuine belief was there to do it. Given some of the, you know, not everybody in – those stakeholders mentioned on that agenda I think genuinely did believe that we should change things. I think some of them did pay lip-service to the programme. And part of what we were trying to do, we came across challenging conversations with people to try to get them to believe that. I think we wouldn’t have gone through some of those arguments and disagreements had we not genuinely believed that we absolutely had to change the training and support for postmasters.

Ms Page: Thank you. Those are my questions.

Sir Wyn Williams: Thank you for providing a detailed witness statement. Thank you for coming to give oral evidence.

The Witness: You’re welcome.

Sir Wyn Williams: Right. 10.00 tomorrow morning, Mr Blake.

Mr Blake: Thank you very much, sir.

(3.36 pm)

(The hearing adjourned until 10.00 am the following day)