Official hearing page

20 September 2023 – Davlyn Cumberland and Andrew Wise

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(10.00 am)

Mr Blake: Good morning, sir.

Sir Wyn Williams: Morning.

Mr Blake: Can I call Ms Cumberland, please.

Sir Wyn Williams: Yes, of course.

Davlyn Cumberland


Questioned by Mr Blake

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

Davlyn Cumberland: Davlyn Cumberland.

Mr Blake: Thank you, Ms Cumberland. You should have in front of you a witness statement with the URN WITN09130100. Do you have that in front of you?

Davlyn Cumberland: Yes.

Mr Blake: Thank you. Can I ask you to look at page 12 of that witness statement. You should see there a signature. Can you confirm that signature is yours?

Davlyn Cumberland: Yes, it is my signature.

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

Davlyn Cumberland: Yes.

Mr Blake: Thank you very much. That witness statement will go into evidence and it will be published on the Inquiry’s website shortly.

I’d like to begin briefly by your background, you started working for the Post Office in 1990 as a counter clerk; is that right?

Davlyn Cumberland: Correct.

Mr Blake: I think you’ve worked in various different positions until 1999, when you became a Horizon Field Support Officer?

Davlyn Cumberland: Yes.

Mr Blake: Is that right? We’ve heard about it in previous phases but can you briefly remind us what a Horizon Field Support Officer was?

Davlyn Cumberland: It was the programme where – the Horizon implementation programme, where Post Office branch accounts were migrated from the old manual accounting system onto the Horizon System, so they were going electronic, and I worked on the field support team, where the accounts would be migrated onto the electronic system.

We would then stay on site with the postmaster or the branch manager, maybe for – I think, it might have been three or four days, and we would come to support them and we would complete the first weekly balance with them.

Mr Blake: Thank you very much. In 2001, you joined a programme called the Retail Line Review trial. Can you tell us briefly what that was and, in particular, how you became involved in something called the Suspense Account team?

Davlyn Cumberland: From what I remember, the Retail Line Review trial was where they centralised all the regional helplines to the Network Business Support Centre, that was then based in Barnsley. The – they had – they separated the network of Post Office branches into commercial branches and rural branches. The rural branches were supported by an area manager and the commercial branches were – I think they were called Retail Line Managers, if I remember rightly.

The Suspense Account team was evolved from this restructure of centralising, managing – I suppose you would call it managing losses and gains. Previously it had been managed locally by the area offices and they were centralising that to the Network Business Support Centre so the Suspense Account team was basically to manage the losses and gains that were held in branch suspense accounts.

Mr Blake: I think you worked in that position from 2001 until 2004?

Davlyn Cumberland: Yes, from what I remember, yes.

Mr Blake: Then you subsequently held a number of different roles in the Post Office and you continue to work in the Post Office –

Davlyn Cumberland: Yes.

Mr Blake: – now. I think you’re involved in on site training or part of the on site training team now; is that correct?

Davlyn Cumberland: Yes.

Mr Blake: That’s nothing to do with Horizon or does it involve Horizon?

Davlyn Cumberland: The team I work on now?

Mr Blake: Yes.

Davlyn Cumberland: Yes, oh yes. I do deliver on site training to newly-appointed subpostmasters and their staff. So we would be training them on the Horizon System.

Mr Blake: So, in fact, from the rollout of Horizon to the present day, you’ve had various roles often involving use of the Horizon System?

Davlyn Cumberland: Correct, yeah.

Mr Blake: I don’t think your background is in computing though, is it?

Davlyn Cumberland: No, no.

Mr Blake: How would you describe your knowledge of computing when it comes to, for example, the identification of bugs, errors or defects in the system?

Davlyn Cumberland: I’m not – no expert with computing. I’m not – in fact, I’m not good with technology at all so I don’t know anything about bugs or anything like that.

Mr Blake: Presumably, back in the early 2000s, you were perhaps even less knowledgeable about computers than you are now?

Davlyn Cumberland: Yes.

Mr Blake: I want to ask you about suspense accounts and what they involve. We’ve heard about suspense accounts in previous phases. They were a facility to temporarily transfer apparent short falls into a separate account. I’d like to take you through a couple of those policies that related to the suspense account, but that’s a fair description of the suspense account?

Davlyn Cumberland: Yes, the suspense account is where either losses or gains would be held awaiting to be cleared.

Mr Blake: Can we look at POL00075026, please. Thank you very much. This is a policy from 2003, so approximate to the period that we’re going to be discussing today. “Accounting Losses Policy for Agency Branches”, can we look at page 4, please. Is this policy familiar to you?

Davlyn Cumberland: Should I be able to see it?

Mr Blake: Yes, you should, sorry. Is it not coming up on the screen in front of you?

Davlyn Cumberland: No.

Mr Blake: Ah, we may have to take a very short break. Can you tell us what is on the screen in front of you?

Davlyn Cumberland: Nothing, it is just blank.

Mr Blake: Okay.

Sir, perhaps we could just take a very short five-minute break to resolve that issue.

Sir Wyn Williams: Yes, of course. Just for you to know, it is on my screen, all right?

Mr Blake: Thank you very much.

(10.09 am)

(A short break)

(10.10 am)

Mr Blake: Sir, can you hear me?

Sir Wyn Williams: Yes, I can. Do you want me to come back on screen?

Mr Blake: Yes, please, thank you very much. The solution it seems, was pressing the “on” button!

Sir Wyn Williams: Okay, fine.

Mr Blake: Thank you.

You should have in front of you – sorry, if we can turn back to the first page. Thank you. This is the “Accounting Losses Policy for Agency Branches”. Is that a policy that’s familiar to you.

Davlyn Cumberland: Yes.

Mr Blake: Thank you. Can we turn to page 4, please. I’ll just read and highlight the second and third paragraphs of this policy, it says:

“Under certain exceptional circumstances losses can be held in the suspense account for a maximum of 8 weeks. These circumstances require the agent to justify the reasons for not making the loss good immediately.”

Pausing there, “agent” is effectively subpostmaster, isn’t it?

Davlyn Cumberland: Yes.

Mr Blake: Yes:

“Before any authority to move a specific loss to the suspense account is given therefore, the agent must have completed their own investigation and be able to show that an error notice is likely to be issued for that loss or an element of the loss.

“Authority to hold an accounting discrepancy must be sought via the National Suspense Account Team at the Network Business Support Centre.”

Is that the team you were working in?

Davlyn Cumberland: Yes.

Mr Blake: “The loss needs to be identified against a known error that has been made and the likelihood that an error notice will be issued. If there is no known error (and, therefore, no error notice likely to be issued), authority will not be given.”

So authority won’t be given unless there’s a known error. That can come down, thank you. Can you assist us with what you understood a known error to be?

Davlyn Cumberland: An accounting error where perhaps they had done a miskey with the transaction, you know, if they’d put through maybe £150 instead of £15 for a bill payment; it could be where they’d put a deposit through as a withdrawal for Girobank; or a withdrawal through the deposit or National Savings Bank; they could maybe have put settled cheques to cash or settled cash to cheque, and sent their cheques off incorrectly. So it would have been a known error in their accounts.

Mr Blake: In fact, in your witness statement I think you describe it as a “known accounting error”?

Davlyn Cumberland: Yes.

Mr Blake: Is that to distinguish it, for example, from a software error?

Davlyn Cumberland: Yes. Not a software error, an actual mistake, where they had actually entered something incorrectly on the system.

Mr Blake: To your knowledge, did, for example, Fujitsu play any part in defining a known error?

Davlyn Cumberland: Not to my knowledge. I wouldn’t have known that, no.

Mr Blake: In terms of software errors then, it seems as though that’s not, on your evidence, covered in that policy?

Davlyn Cumberland: No.

Mr Blake: Were there briefings in your team as to software errors when they were discovered?

Davlyn Cumberland: No.

Mr Blake: To your knowledge, did those who carried out the job of examining whether there were said to be accounting errors, at that stage, have access to Fujitsu’s audit records, what we know as, for example, ARQ reports or Fujitsu’s raw audit data?

Davlyn Cumberland: Not to my knowledge.

Mr Blake: It seems from the policy that the burden was on the subpostmaster to identify the error, the agent to identify the error?

Davlyn Cumberland: Yes.

Mr Blake: It said in that policy that the agent must have completed their own investigation. Typically, what did that involve?

Davlyn Cumberland: Well, we would ask them to check – or back then, if I remember rightly, there would have been – a lot of the accounts were still paper based, so there would have been a docket for every transaction. For example, if there was a banking deposit into Girobank, there would have been a docket, or a giro withdrawal, there would be a docket.

So we would ask them to check all their dockets against what they had entered onto the system. So we would ask them to make – double check their cash, check that they had remitted cash incorrectly, check if they’d sent any cash back to the cash centre, that they’d checked that they’d sent it back correctly, that it matched the figures they had on the docket that they’d sent and that matched what they’d put onto Horizon.

So it was really checking everything that they had in paper form matched what they’d put onto their Horizon System.

Mr Blake: I’m going to look at another policy and that can be found at POL00088867. A similar policy, this is the “Liability for Losses Policy”. Again, it’s a 2003 policy. Is this a policy that’s familiar to you?

Davlyn Cumberland: I think so.

Mr Blake: Perhaps if we turn to page 5, that may assist. This addresses authority to hold losses. Just like the policy before, I’ll read the second and third paragraph there:

“Under circumstances where the exact cause of the loss is known and a compensating error is expected to be returned, losses may be held in the suspense account, with authority, providing that the agent has completed their own investigation [that’s the investigation I think you’ve just been referring to] and is able to show that an error notice is likely to be issued for that loss or an element of that loss (ie the agent must be able to detail a specific error that occurred for a specific client on a specific date and be able to provide documentary evidence eg from the Horizon transaction log).

“Before moving a specific accounting discrepancy to the suspense account, authority must be sought from the Agents Debt Team 3, via the [NBSC]. If there is no clearly defined evidence of a known error (and, therefore, no error notice likely to be issued), authority will not be given.”

Can you recall any situation where an agent provided evidence of a known error when it comes to a software error?

Davlyn Cumberland: No.

Mr Blake: Realistically, was that because a subpostmaster couldn’t be expected themselves to identify what is a complex software matter?

Davlyn Cumberland: I don’t know because software errors weren’t anything that we were involved with at all on our team. Software errors didn’t even – it was never even discussed.

Mr Blake: So if a subpostmaster was saying, “I have money that is held in the suspense account that’s because of a software error, I consider that to be an error that meets the test for authorisation under this policy”, what would happen?

Davlyn Cumberland: Well, that never happened. I never had that conversation with a subpostmaster.

Mr Blake: Can we look, please, at POL00081490_046, thank you very much. This is the witness statement of Elizabeth Morgan in the Lee Castleton case. We’ll come on to Lee Castleton’s case shortly. Can you briefly tell us: who was Elizabeth Morgan?

Davlyn Cumberland: She was a work colleague on the Suspense Account team.

Mr Blake: So if we scroll down on that page, she describes the policy as follows, it’s paragraph 4, the last sentence, and the bullet points below:

“The subpostmaster might be given permission to transfer the shortfall from the Cash Account to the Suspense Account where it could legitimately remain for up to 8 weeks provided either:

“(a) they provided a sufficiently detailed and acceptable explanation for the discrepancy;

  1. they submitted a hardship form which shod that they could not afford to make good the shortfall in the cash account; or …”

Then we have:

“(c) exceptionally, their Retail Line Manager authorised it.”

Is that a fair explanation of the policy so far as you understood it?

Davlyn Cumberland: Yes.

Mr Blake: When it came to a bug, error or defect in Horizon, it seems from (a), (b) and (c) then and the explanation you’ve just given that that simply wouldn’t have been covered?

Davlyn Cumberland: No.

Mr Blake: We know from the High Court proceedings, that during the time you were involved in the Castleton case and the Castleton case was in those early stages of where you were involved, there are a number of bugs, errors or defects in Horizon: Callendar Square bug; reversals bug; data tree build; failure discrepancies; Girobank discrepancies; counter replacement issues; phantom transactions; reconciliation issues; concurrent log-ins; transaction correction issues; bugs, errors or defects introduced by previously applied PEAK fixes. Were those known in your team, the people who were dealing with the suspense account, were those kinds of issues known within that team?

Davlyn Cumberland: No.

Mr Blake: I think, in fact, at paragraph 45 of your witness statement – we don’t need to bring that onto screen – I think you said you simply weren’t aware of any bugs, errors or defects in Horizon?

Davlyn Cumberland: No.

Mr Blake: Looking back, where a subpostmaster experienced what they considered to be an unexplained loss, do you think that there was sufficient investigation, particularly at that technical level, to fully understand the cause of that loss?

Davlyn Cumberland: Sorry, could you repeat that?

Mr Blake: Yes, absolutely. Looking back, where there was a subpostmaster who experienced what they considered to be an unexplained loss, and perhaps they considered it to be a software issue, was there, so far as you could tell, sufficient investigation on a technical level to fully understand the cause of that loss?

Davlyn Cumberland: Well, I never had any conversation with a subpostmaster where it was ever suggested that there was a technical fault. So that scenario didn’t arise because it was never suggested that there was a technical fault. So it didn’t even – never occurred to me.

Mr Blake: If we put to one side the Lee Castleton case, looking back, do you consider that the policies that we’ve just been looking at placed too much of an evidential burden on the subpostmaster, particularly knowing now that there were indeed software issues?

Davlyn Cumberland: Quite possibly, yeah.

Mr Blake: I want to ask you about your involvement in the Lee Castleton case. Can you remember the first involvement that you had with Lee Castleton’s accounts and how you became involved?

Davlyn Cumberland: I’ve no recollection at all of being involved with the Lee Castleton case. I have got – I don’t remember any of it.

Mr Blake: Perhaps I can take you to some documents and that might help refresh your memory. You have set out in your witness statement some recollection based on these documents. Can we look at POL00070758, please. This is a decision paper that was written by Ms Oglesby. Can you assist us with who she was?

Davlyn Cumberland: I think Cath Oglesby at the time was the Retail Line Manager.

Mr Blake: What was your relationship with her?

Davlyn Cumberland: I don’t recall having any relationship with Cath Oglesby. I only know from reading the documents that have been provided to me that she was the Retail Line Manager at the time.

Mr Blake: I’ll just read a few paragraphs from this decision paper. This is following an interview with Lee Castleton on 10 May 2004. She says:

“My thoughts after the interview with Lee are that he could not provide any evidence of a computer problem.”

Next paragraph, she says, final sentence:

“He and his assistant, Chrissie, have said that they spent hours checking transaction logs, but found nothing to back up the claims of computer error.”

Pausing there, would you expect a computer error to be shown just by looking at transaction logs? Do you think that would be sufficient to identify a computer error?

Davlyn Cumberland: Well, I don’t know anything about computer errors but, if I was to hazard a guess, I’d say no.

Mr Blake: So it says:

“Lee would not even listen to the suggestion that a member of his staff may be taking the money. In my opinion, if you know yourself that you haven’t taken anything, it must be someone else. So you would be open to suggestions and not discount anything. Lee has always maintained that it must be a software problem.”

If we scroll down a little bit further, that final paragraph on the screen at the moment:

“Lee has asked for a lot of information, some of which cannot be provided. I have endeavoured to help him and provide as much information as possible. There has been nothing to suggest any problem with the computer system.”

Next paragraph, and this, insofar as your involvement was concerned, is the significant paragraph. She says:

“Lee asked me to explain the discrepancies at the top of the final balance. I have asked for assistance from colleagues for this. Copies have been sent to Liz Morgan and Davlyn Cumberland, they have help me explain the figures on his balance. They did not feel anything was wrong with Horizon.”

Can you tell us, who was Liz Morgan?

Davlyn Cumberland: Liz was a colleague who I worked with on the Suspense Account team.

Mr Blake: The statement there, “They do not feel anything was wrong with Horizon”, we see – and I’ll take you in due course to the various documentation – that, I think, you’ve corrected that in due course, that that, in fact, wasn’t your position; is that right?

Davlyn Cumberland: I don’t have any recollection of this at all. Sorry, I don’t remember this.

Mr Blake: If we go over the page, she says there that:

“To summarise terminate Lee Castleton’s contract for services. Due to large unexplained losses at his office. There is no evidence to support his theory of software problems.”

Can we please look at POL00071073. This is an email from Stephen Dilley, he was a solicitor at Bond Pearce, and you can see there that yourself and Liz Morgan are included in that. I mean, you have refreshed your memory from documents before coming to the hearing today, haven’t you?

Davlyn Cumberland: Yes.

Mr Blake: Yes. Does this jog your memory about the fact that you were involved with a legal case relating to Lee Castleton?

Davlyn Cumberland: No, it doesn’t. I don’t have any recollection of it at all.

Mr Blake: If we look at this document, he says that he acts on behalf of the Post Office. He summarises the case. He says:

“Mr Castleton’s defence is that the apparent shortfalls are nothing more than accounting errors arising from the operation of the Horizon computer system.

“Mr Castleton was suspended on 23 March 2004. On 10 May 2004, Cath Oglesby (then the Retail Line Manager) interviewed Mr Castleton. After the interview, she sent copies of the cash and suspense accounts to you and you confirmed to her that you could not see anything wrong with the way that the computers were working.”

Do you think you would have been in a position to have said one way or another whether there was something wrong with the way that the computers were working?

Davlyn Cumberland: No.

Mr Blake: So although you may not recall this particular incident, reading that, does that sound like something that you would have said to Cath Oglesby?

Davlyn Cumberland: If somebody had asked me to look at the branch accounts, at the cash account as it was then, to have a look over it to see if I could see if there were anything that stood out to say that there’d been an error, I would probably have said – I would probably look at it and, if I could see something, I would say and, if there wasn’t, I would say I can’t find anything. But that doesn’t indicate anything to do with a software problem.

Mr Blake: Perhaps we can look at POL00072707. This is a telephone attendance note that appears to have been written by or on behalf of Stephen Dilley, dated 2 October 2006. He says there:

“I had a telephone conversation with Davlyn Cumberland. She was returning a call I had left on her telephone voicemail in relation to what was meant and it was said that they were unable to finding anything that was ‘wrong’. She meant the word unusual and I have already amended the witness statement to reflect [this]. Saying that I had emailed it to her and asking her to review it, if she is happy with to approve it by printing two copies”, et cetera.

So it seems there that he asked you what you meant by the word “wrong” and that, in fact, you meant the word “unusual”. Does this is you at all?

Davlyn Cumberland: No. I still can’t remember.

Mr Blake: It may assist if I take you to your witness statement from those proceedings. It is LCAS0000566. This is your statement that was provided in the Lee Castleton case. Can we look at paragraph 3, please. This may assist with the role that you undertook in relation to Lee Castleton accounts.

Perhaps I’ll read that paragraph and I’ll take you through it stage by stage. It says:

“In around May 2004 …”

So two and a half years before this statement was actually written:

“… I was asked by my colleague Elizabeth Morgan to examine various Cash Accounts that she had received from Catherine Oglesby (who at the time I am informed was Mr Castleton’s [I think that’s ‘Retail’] Line Manager) for 14 South Marine Drive, [et cetera].

“Given that 2 and a half years have passed since I examined them, I cannot now remember what exactly it was in the Cash Accounts or which weeks that I looked at. However, at the time I was used to carrying out the exercise for [Retail Line Managers], so I believe that I would have reviewed the figures in the Stock, Receipts and Payments in the Cash Accounts and looked for anything unusual such as whether particular figures varied significantly from week to week, or whether they were unusual for the type of transaction concerned.”

Just pausing there, you say, “However, at the time I was used to carrying out the exercise”, I think you said in your witness statement it wasn’t officially part of your role.

Davlyn Cumberland: No, it wasn’t.

Mr Blake: Can you assist us with why you would have been used to carrying out that task and what it may have involved?

Davlyn Cumberland: Well, in fact, it wasn’t something that happened often. It was quite rare, on a few, maybe a handful of occasions where we may have been asked to look at some branch accounts from somebody from the Retail Line. It wasn’t often and I do have a vague recollection of Liz asking me to assist her to look at some branch accounts that had been sent to her but I honestly couldn’t say which Post Office it was for or which subpostmaster it was. I do have a recollection of her asking me to help her look at some branch accounts.

Mr Blake: So, although it says there “I was used to carrying out this exercise”, in fact, it was rare?

Davlyn Cumberland: It was rare and – yeah, it was rare, and it was more done as a favour, you know, “Would you mind casting your eye over this to have a look?” It wasn’t an official part of our role.

Mr Blake: Can you assist us, the words “I was used to carrying out” might that be the words of the solicitor rather than yourself –

Davlyn Cumberland: Well, I don’t have any recollection of – to be honest, when I saw this I was shocked because I had no recollection of it at all and, I mean, clearly I must have done it because it’s there in and it’s legal, so I must have done it but I don’t remember doing it.

Mr Blake: Can you assist us with the actual task, reviewing figures of stock, receipts and payments in the cash accounts. Would that have been reviewing the Horizon printout?

Davlyn Cumberland: Yes. The hard copy printout.

Mr Blake: Yes, so everything you would have been looking at would have been generated by Horizon?

Davlyn Cumberland: Yes.

Mr Blake: If we read on, it says:

“I do remember that we were unable to find anything unusual or anything to suggest that the losses were not real losses.”

Now, the word “unusual” there, we’ve seen from that conversation with Mr Dilley that it seems as though you may have corrected the word “wrong” to the word “unusual”; does that assist you at all? This form of words, does that sound like you?

Davlyn Cumberland: No.

Mr Blake: The words “anything to suggest that the losses were not real losses”, is that a phrase that you understand?

Davlyn Cumberland: I understand it but I don’t remember writing it, or saying it. But, yeah, I understand it.

Mr Blake: Do you think you were in a position definitively to say whether alleged discrepancies were genuine losses for the Post Office?

Davlyn Cumberland: No.

Mr Blake: Perhaps, if we look at the statement of Elizabeth Morgan, I took you to an unsigned version of that statement and perhaps we’ll look at that again. That was POL00081490. Thank you. If we can look at the second page of that statement, at paragraph 9, the unsigned version of that statement says, in the final sentence:

“I do remember asking my colleague Davlyn Cumberland to assist and that we were unable to find anything wrong. I reported this to Catherine Oglesby.”

So that’s the unsigned version and now I’ll take you to the signed version of Ms Morgan’s statement. That is POL00074062.

If we look over the page, please, paragraph 9. She says there, about halfway down:

“However, given that at the time I was used to carrying out this exercise for RLMs, I believe that I would have reviewed the figures in the Stock, Receipts and Payments in the Cash Accounts. I would have looked for anything unusual such as whether particular figures varied significantly from week to week in the Cash Accounts or whether they were unusual for the type of transaction concerned. I do remember asking my colleague Davlyn Cumberland to assist and that we were unable to find anything out of the ordinary or anything that suggested that the losses were not real losses. I reported this to Catherine Oglesby.”

Does this assist you at all in – you’ll see there, for example, that the original wording has been changed, now it reads “anything out of the ordinary” –

Davlyn Cumberland: Yeah.

Mr Blake: – and it includes the words “anything that suggested that the losses were not real losses”. Does that assist you with identifying where that phrase came from at all? I mean, do you think the wording was yours, the solicitors, Ms Morgan’s, or somebody else’s?

Davlyn Cumberland: I don’t know. I’m sorry, I don’t know.

Mr Blake: But it’s not a phrase that you think you would have used?

Davlyn Cumberland: No.

Mr Blake: Can we now look at LCAS0000609, please?

If we go over the page, this is the statement of Catherine Oglesby. If we look at the final page – or penultimate page even, sorry, page 14, if we scroll down we can see that this is the signed statement from 21 January 2006. So that’s before the conversation that appears to have been recorded between yourself and Mr Dilley. Could we, please, look at page 13, paragraphs 42 and 43.

So at 42, she says:

“I explained to Mr Castleton that the Horizon System is a double entry accounting system and that everything I had checked worked through. The evidence does not support Mr Castleton’s theory that the Horizon system went wrong when he entered the stock remittances onto the system.

“Post interview

“43. After the interview, I sent copies of the cash and suspense accounts to Elizabeth Morgan and Davlyn Cumberland in Leeds who were the two people very experienced in dealing with the suspense account. Neither of them could see anything wrong with the way the computers were working.”

As I say, that was signed before your conversation with Mr Dilley but, in light of that subsequent conversation and your evidence today, is it right to say that that, in fact, was not an accurate statement, insofar as you didn’t see anything wrong with the way that the computers were working? Do you think that accurately reflects the position at the time?

Davlyn Cumberland: You mean –

Mr Blake: So this is Ms Oglesby’s statement –

Davlyn Cumberland: Yes.

Mr Blake: – from January 2006, and it says there – it refers to you and Ms Morgan and it says neither of you could see anything wrong with the way the computers were working. Considering the evidence you’ve given and also the email, the note from Mr Dilley, for example, is that an accurate statement, in fact, of –

Davlyn Cumberland: No, probably not.

Mr Blake: You say “probably not”. Why “probably”?

Davlyn Cumberland: Well, because we wouldn’t know if there was a problem with the computers. We wouldn’t have known that.

Mr Blake: If you were – were you aware – it may be that you simply can’t remember this but were you aware of that phrase having been included in a witness statement that –

Davlyn Cumberland: No.

Mr Blake: Do you think you would remember an event like that or is it simply passage of time and you can’t remember –

Davlyn Cumberland: I think it’s just so long ago, I can’t – I’ve no recollection of it whatsoever.

Mr Blake: I want to now ask you about your response to – or the response to various issues with Horizon. Can we look at your witness statement, please. That’s WITN09130100, page 11. It’s paragraph 46. So at 45 you talk about bugs, errors or defects and you say that you weren’t aware of any in the Horizon System.

46, I think you say you did become aware of some subpostmasters taking legal action and then you say this, you say:

“I recall that senior management at the time provided us with a standard response (although I don’t recall the specific wording) to any questions raised by branch staff while we were outperforming our daily roles.”

Can you assist us with – you may not be able to recall the specific wording but can you recall what that standard response was?

Davlyn Cumberland: Yeah, I have got this email somewhere on my laptop but – and I’ve searched for it but I’ve just not been able to find it. It was a response that was – it was more of a dos and don’ts in what we should and shouldn’t be saying, if – the terminology that we should use while we’re out on site, because we work out in the field on site with subpostmasters and their staff and it was, if we should ask – be asked any questions or it was who to refer them to, which was mainly the Network Business Support Centre, which is now the Branch Support Centre.

It was more about what we should never say, what we could and couldn’t say. It was more about that, really. It was a guide. It was to guide us through what potentially could have been quite a difficult time for us, being out on site all the time.

But, strangely, I was never required to use it. So that’s probably why I put it to the back of my mind.

Mr Blake: Can you recall who may have sent it to you?

Davlyn Cumberland: No.

Mr Blake: An approximate time period?

Davlyn Cumberland: It would have been probably around about 2019, I think.

Mr Blake: As late as 2019? Because we see there that you started working for the Post Office again at 2012, I think you took a short break. But your thoughts are that it was as late as 2019?

Davlyn Cumberland: It could have been. It could have been, or it could have been before. I can’t exactly remember. I did try and look for it because I know I wouldn’t have deleted it, and I just couldn’t find it.

Mr Blake: Can you recall any headline points from that as to what you shouldn’t be saying to subpostmasters?

Davlyn Cumberland: It was not – you know, if anybody was to ask about the problems with the Horizon System, we were to refer them to the Branch Support Centre. We weren’t to really get – engage in any kind of conversation about it and it was that – sometimes it was how we spoke to subpostmasters to treat them respectfully and talk to them respectfully, which I’ve always done anyway. It was kind of a guide, really. I can’t think of anything specific.

Mr Blake: Thank you very much. We can ask the Post Office for a copy of that if they hold it. Thank you very much, Ms Cumberland. I don’t have any further questions.

There may be questions from Core Participants and, sir, do you have any questions at all?

Sir Wyn Williams: No, I don’t think I need – yes, I’ll just ask the question.

Questioned by Sir Wyn Williams

Sir Wyn Williams: Ms Cumberland, you made a witness statement in the Lee Castleton case and you’ve given me your evidence about that. My impression is that you didn’t actually give evidence at his trial; is that correct?

Davlyn Cumberland: That’s correct. I think, if I had have given the evidence at the trial, I think I would have remembered it. I think that is something that I would have definitely remembered.

Sir Wyn Williams: Well, that’s the impression I’ve formed but I just wanted to be clear about it. Thank you.

Yes, I have no further questions.

Mr Blake: Thank you. Yes, Ms Page has.

Questioned by Ms Page

Ms Page: Thank you, sir.

Ms Cumberland, I act for a number of the subpostmasters, including Mr Castleton.

Did you sign witness statements often in your roles, any of your roles?

Davlyn Cumberland: No.

Ms Page: So your complete lack of memory of what was a rare event, looking back, do you think it can have been made clear to you that this was an important document?

Davlyn Cumberland: Sorry, could you say that again?

Ms Page: Well, a witness statement for the High Court is an important document and you’ve explained to us that this was a rare event, perhaps even a one-off?

Davlyn Cumberland: Yeah.

Ms Page: Do you think it can have been made clear to you how important this was, given that you don’t remember it at all?

Davlyn Cumberland: Yeah, I can’t remember. I don’t know. I would say it should have probably been made clear to me how important it was but I don’t remember it so I can’t, I don’t know how to answer that, really.

Ms Page: You now feel that some of the phrases within it were not your own and things that you wouldn’t have said. Can you give us any idea how you think that could have come about?

Davlyn Cumberland: I don’t know.

Ms Page: No. All right. Well, can I then ask you just a couple of things that are more about what you would have and could have done. You’ve explained that you didn’t have access to anything other than the Horizon printouts –

Davlyn Cumberland: Correct.

Ms Page: – and all you’d have been able to spot is perhaps something like a large mistake in processing a cheque or a cash transaction?

Davlyn Cumberland: Correct.

Ms Page: If Horizon had failed to record a payment out that had, in fact, been paid, the Horizon figure for cash on hand would, therefore, be higher, wouldn’t it –

Davlyn Cumberland: Yeah.

Ms Page: – than, in fact, the actual quantity of cash –

Davlyn Cumberland: Yeah.

Ms Page: – in the branch, that’s not something your check would have been able to spot?

Davlyn Cumberland: No, no.

Ms Page: No. Similarly, if on receipt of a cheque, Horizon had failed to register the cheque and had perhaps recorded it as cash in error, the system would say that there was more cash in the branch than, in fact, there was, wouldn’t it?

Davlyn Cumberland: Yes.

Ms Page: Indeed, at the end of the day, branch staff needed to reconcile physical cheques with the Horizon list; is that right?

Davlyn Cumberland: Yes.

Ms Page: If the cheque had not registered as a cheque, it wouldn’t be on that list, would it?

Davlyn Cumberland: No.

Ms Page: So the branch staff may have seen that the cheque was not there and entered it again; is that fair to say?

Davlyn Cumberland: Yes, that’s fair to say.

Ms Page: Under those circumstances, the sum of money would have registered both as cash from the mistake earlier on, the Horizon mistake earlier on, and as a cheque, when the branch staff were then going through the cheques list, they see it’s not there, and they enter it as a cheque?

Davlyn Cumberland: Yes.

Ms Page: So you can see how in those circumstances –

Davlyn Cumberland: Yes.

Ms Page: – Horizon may have recorded that sum of money twice?

Davlyn Cumberland: Yes.

Ms Page: Again, that’s not something your check would have been able to identify?

Davlyn Cumberland: No, no, not just by us looking at the branch cash account, no.

Ms Page: Was anyone from your team part of the decision or feeding into the decision to remove local suspense accounts?

Davlyn Cumberland: No.

Ms Page: No?

Davlyn Cumberland: Not to my knowledge.

Ms Page: Presumably, once that was a facility that was removed, your team was disbanded, was it?

Davlyn Cumberland: Yes. Our team was disbanded and I believe they moved – it was moved to Chesterfield and it’s what became known as the Agent Debt Team in Chesterfield.

Ms Page: So it was a rather different operation because it was no longer about suspense accounts, it was about following up debt?

Davlyn Cumberland: I think so. I wasn’t part of that, I actually moved onto a different team before the suspense account was disbanded, so I can’t say.

Ms Page: You’re not entirely sure. All right.

Ms Page: Well, thank you, those are my questions. Thank you, sir.

Sir Wyn Williams: Thank you, Ms Page.

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

Mr Blake: Thank you, sir.

For logistical reasons, could we take a break until 11.30, please, before the next witness? There will be plenty of time for the next witness.

Sir Wyn Williams: Yes. Of course. So 11.30 we’ll resume the hearing.

Mr Blake: Thank you very much.

(10.51 am)

(A short break)

(11.31 am)

Ms Price: Sir, can you see and hear us?

Sir Wyn Williams: Yes, I can, thank you.

Ms Price: May we please call Mr Wise.

Sir Wyn Williams: Yes.

Andrew Wise

ANDREW WISE (sworn).

Questioned by Ms Price

Ms Price: Can you confirm your full name, please, Mr Wise?

Andrew Wise: Andrew Wise.

Ms Price: You should have in front of you a hard copy of a witness statement in your name dated 31 May 2023; have you got that there?

Andrew Wise: Yes.

Ms Price: If you turn to the last page of that, please, that is page 31, do you have a copy with a visible signature?

Andrew Wise: Yes, I do.

Ms Price: Is that your signature?

Andrew Wise: Yes, it is.

Ms Price: Are the contents of that statement true to the best of your knowledge and belief?

Andrew Wise: Yes, they are.

Ms Price: For the purposes of the transcript, the URN is WITN09090100. There’s no need to display that now.

Thank you for coming to assist the Inquiry with its work and for providing the witness statement you have. We are very grateful. As you know, I will be asking questions on behalf of the Inquiry, and today I’m going to be asking you about issues which arise in Phase 4 of the Inquiry, focusing on your involvement in the proceedings brought by the Post Office against Mr Castleton relating to the alleged losses at Marine Drive Post Office branch.

You joined the Post Office in 1991 as a counter clerk in a directly managed branch, also known as the a Crown Office branch; is that right?

Andrew Wise: Yes, that’s right.

Ms Price: You were in that role for eight years?

Andrew Wise: Yes.

Ms Price: You joined the Horizon project in 1999 as a Horizon Field Support Officer; is that right?

Andrew Wise: Yes.

Ms Price: That role involved you migrating Post Office branches from a manual accounting system onto the Horizon System?

Andrew Wise: Yes.

Ms Price: You say at paragraph 3 of your statement that following a branch migration, you would spend the next two days in branch providing support to the subpostmaster and their staff and that involved providing balance support to the branch on their first balance day; is that right?

Andrew Wise: That’s right, yes.

Ms Price: In 2001 you joined the Network Business Support Centre as a Service Support Advisor working on Tier 2; is that right?

Andrew Wise: Yes.

Ms Price: A role you held until 2004?

Andrew Wise: Yes.

Ms Price: That role involved providing support to Post Office branches and their staff when contacting the NBSC with a variety of problems, including problems balancing, using the Horizon System, didn’t it?

Andrew Wise: Yes, that’s right.

Ms Price: Then from 2004 to 2007 you worked in the training delivery team where you were a training manager, providing classroom training to new subpostmasters and their staff?

Andrew Wise: Yes.

Ms Price: Was that training on the Horizon System?

Andrew Wise: It was, yes.

Ms Price: In 2007 you moved to the sales team?

Andrew Wise: Yes.

Ms Price: You were a transitional manager with no specific designated role between 2008 and 2010?

Andrew Wise: Yes.

Ms Price: During that time in 2010, you worked on the Horizon Online project. Can you please clarify what that role involved?

Andrew Wise: I was in charge of a team of schedulers that would schedule the POL resource that attended branches on the day of the migration. So around 300 branches a day would be migrated onto Horizon Online and we had a pool of hundreds of people that would carry out the roles to support branches.

So we would match up the people with the branches based on geography and make sure that every branch being migrated onto Horizon Online had the support and that support involved them turning up in the afternoon, when the Post Office closed, that’s when the branch would be migrated over onto Horizon Online and then they would turn up the next morning and provide a morning’s worth of support and then move on to the next branch that they would support in the afternoon.

So the job of the schedulers were to make sure that the POL resource was in that branch to assist and migrate the branch over.

Ms Price: So is it right to say that was really about the logistics of providing the support?

Andrew Wise: My role was, yes.

Ms Price: In 2011 you joined the Security team as Security Manager; is that right?

Andrew Wise: Yes.

Ms Price: You held that role until you moved into the Security Intelligence Team in 2015 as a Security Intelligence Analyst?

Andrew Wise: Yes, that’s right.

Ms Price: Are you still in that role with the Post Office?

Andrew Wise: I am, yes.

Ms Price: When you joined the Horizon project in 1999, what were you told about the history and the development of Horizon?

Andrew Wise: I don’t think I was told a great deal. I had followed a little bit of the design of it and my understanding was – and I’m not sure where this understanding came from – that the Horizon System was designed around the DWP work for pension books, and that’s why it had such security on it, firewalls and the protection. That was the standard that the DWP wanted, so the system was designed specifically for pensions and allowances, and the DWP, at some point, changed their mind and wanted to move to an online banking where pensions were paid into bank accounts.

So my understanding was we were left with a system that was built for one specific reason but then had to be kept and used because they were so far down the line with that system. I don’t know really a great deal more about the history than that.

Ms Price: Were you aware of any problems during the rollout of Horizon?

Andrew Wise: Not specifically with the actual serving and using the Horizon System. I think there was a lot of challenges in the logistics of setting the system up in branches, so as an HFSO we would turn at 4.00 in the afternoon, the postmaster would balance and then we would migrate all the figures from that balance onto the Horizon System.

Quite often, your work would be what we called “aborted”. You’d get a phone call to say, “You’re not going to that migration because they’ve not been able to put the kit in or there’s been a problem putting the kit in the branch”, so that would fall off your schedule. They’d look for other work for you to do or you might just then have to wait for your next branch that was migrated.

But I wasn’t aware of any problems using the system and I didn’t experience any problems personally but it – there was a lot of migrations cancelled and aborted because of the issues putting the actual system in the Post Office branch.

I’m not aware what those issues were, we’d just get told, “You don’t need to attend this branch” because they’d not got the computer system set up.

Ms Price: In your role on the Horizon project from 1999 to 2001, did you have regular contact with anyone from Fujitsu?

Andrew Wise: I remember there was a team from – well, it was ICL Pathway then, it wasn’t Fujitsu. But there was a team from ICL Pathway that would go out and monitor you doing the migration. Little was understood for why they was there. They’d just stand there and watch you. We didn’t really interact. They didn’t provide support to us, but they was just there.

From a support point of view, we may contact the Horizon System Helpdesk, mainly if a printer wasn’t working, if the computer needed rebooting, if there was a screen freeze, so we may contact the Horizon System Helpdesk frequently but that wasn’t a direct link as an HFSO. That was as a branch location contacting them to report an issue.

Ms Price: What training were you given on the Horizon System before you went out to branches to provide support in relation to migration to the system?

Andrew Wise: We – I’m not 100 per cent sure. I think it’s two weeks. It could have been three weeks but, thinking about it more, I think it was two weeks. We were actually on – I’ll call it an in-house course in Doncaster, so we were two weeks in a hotel. Within that hotel we had the training on Horizon. So we received the equivalent training to what postmasters would receive and then we received additional training on how to actually migrate the branch.

So probably a week of that two-week course was around the actual physically migrating the branch and how to do that.

Ms Price: Given the experience you gained in your role as a Horizon Field Support Officer, would it be accurate to say that you brought a good understanding of the balancing procedures which subpostmaster and branch staff were required to follow when you moved them to the Network Business Support Centre?

Andrew Wise: I would say I had a very good understanding. When I moved on to the Horizon project, I had a good understanding of the balancing process. I’d worked in a Crown Office for eight years. Part of that was manually balancing and then part of that was on the system called ECCO+, and Horizon was relatively similar to – the physical process was similar to ECCO+. So when I joined NBSC I would say I was very familiar with the balancing process.

Ms Price: You’ve set out a summary of the daily and weekly balancing procedures which existed in the early years of Horizon and you say still applied in 2004 in your witness statement to the Inquiry. For the record, the relevant paragraphs are paragraphs 25 to 37 of WITN09090100.

Could we have Mr Wise’s statement on screen, please, that is the reference I’ve just given, at page 9 of that document, please. At paragraph 27, please. This paragraph describes in broad terms the daily reports which needed to be completed as follows:

“Branches had a set of procedures they had to complete daily which involved the account and dispatch of various documentation. This included reports such as the daily cheque listing, Girobank deposits and withdrawals, National Savings deposits and withdrawals, TV licences, personal banking and automated payment transactions. For each of these products the branch would produce a daily report, check the counterfoils, which they have kept in the counter till, agrees with the number and value on the report and then despatch in the relevant envelope. The actual procedure on Horizon would be to go into the counter daily report screen, select the report they wish to look at and then select print. Once the branch was satisfied that they had a counterfoil for each transaction they would select the cut-off option on the Horizon screen. Cutting off the report just meant that it would reset to zero for the next day.”

Going over the page, please, down to paragraph 30. You then deal with the daily cash declaration here. So:

“Another daily procedure was the daily cash declaration. Each branch was required to complete an accurate daily cash declaration each day on the Horizon System as close to closing as possible. This was a mandatory process and enabled the Post Office Cash Management teams to track how much cash was in the network and request excess cash back.”

You then deal with the weekly reports which needed to be completed at paragraph 31 and then starting at paragraph 32 over the page, please, you deal with the actual balance process.

Have I understood correctly that this balance process involved a number of steps which were these, and please correct me if I’m wrong at any stage: once the daily and weekly reports were printed and reconciled, the next step was a check of the physical stock on hand and whether this agreed with the figures on Horizon.

Just pausing there, you deal at paragraph 32 of your statement with what a subpostmaster or branch staff member could do, if that was not the case, don’t you?

Andrew Wise: Yes.

Ms Price: About halfway down there, you say:

“Any differences found in either of these ways should be corrected by either adjusting their stock in the adjust stock screen or making a sale or completing a reversal against the stock item. Making the sale would reduce the system held stock figure (this is where the branch physically has less stock than Horizon shows) add completing a reversal would increase the system held stock figure (this is where the branch physically has more stock than Horizon shows). The last way a branch could check their stock against Horizon would be to make a stock declaration, the branch would type in the value of every stock item they have, and Horizon overwrites the existing stock figures with the newly declared stock figures.”

Then you say this:

“The declare stock option was rarely recommended for branches to do as it could often cause confusion and leave the branch struggling to balance.”

Could you please expand on why the declare stock option could cause confusion?

Andrew Wise: Okay. So Horizon kept a track of all these stock items and, in a particular Post Office branch, they would have dozens and dozens from different types of envelopes, overseas items, philatelic items, First, Second Class stamps, stamp books, so they had, you know, a lot of different stock items. The system would track that, so every time a stock item was sold it would reduce the number of that item and should give that stamp. So if you sell a First Class stamp, Horizon reduces by one and you give a First Class stamp to the customer.

So when you check your stock at the end of the week, what you physically have should agree with what Horizon says and you can check that quite easily by doing a balance snapshot or going into the adjust stock screen.

The function for declare stock was for you to tell Horizon what stock items you had and so it wiped clear everything it thought you had by tracking it, and was just overwriting those figures with what you’ve told it.

So if I forget about a batch of stamp books in my cupboard and I don’t declare them it wipes them completely off the system, which any stock item like that that you delete off the system, it would give you a cash discrepancy, ultimately. So if it were £100 worth of stamp books, you would get a cash discrepancy to say he’s £100 short and he may not understand where that discrepancy has come from.

Another thing that was quite common with the declare stock, a postmaster would go into it, and think “Ooh, I don’t want to be in here”, so he’d confirm it and come out, and that would set everything to zero. So it’s as though he’s told the Horizon System that every single stock item is zero, so if he’s got £10,000 worth of stock that would then translate into a £10,000 loss.

Now, it’s rectifiable and can be resolved but it’s quite a complicated process and subpostmasters get very good at doing what they do every single day, every single week. When they have to do something on Horizon that’s new and they’ve never done before, then that’s when they can experience quite serious problems that will get them into a mess.

Like I said, nothing like that is unresolvable. We could always correct it. But it’s quite difficult, especially over the telephone at NBSC, to talk through a process to get back to a position where the postmaster is balancing. So that’s – so as an HFSO as a trainer, as an NBSC advisor, I would never recommend a branch to declare the stock. It’s one of the pitfalls, as I call it, in the system. You know, it’s the way the system is designed, but it can get that postmaster into a little bit of a mess.

Ms Price: How would subpostmasters or branch staff know that the declare stock option could cause confusion and leave the staff struggling to balance? Were they trained on that? You referenced you as a trainer?

Andrew Wise: Myself as a trainer, I would make it clear in the classroom not to do that and, equally, as an HFSO, I would make it clear not to do that. It’s so much simpler doing it one of the other two ways, rather than declaring stock. Now, the design was around, if you’ve got two stock units, and they were what are called shared stock units and two people with their own supply of stock, each of those two clerks could make a stock declaration for their little bit of stock and the system adds that together and, in theory, it all balances. But, in practice, it just wasn’t that simple.

So it was easier to count my stock and your stock and add the numbers together, and then do a balance snapshot and check the numbers agree.

Ms Price: Was this a common problem, a mismatch between the count for physical stock on hand and the figure generated by the Horizon System, from your experience when you were an advisor on Tier 2?

Andrew Wise: I wouldn’t say common. I would say it happened a notable(?) time, but I wouldn’t say common.

Ms Price: You go on to set out the next step after the physical stock check, which was a stamp declaration, then the foreign currency on hand figure and then finally the cash declaration, which you say involved entering the value of each denomination of note and coin. You deal with this at paragraph 35 of your statement. This is page 12, please.

In the last sentence on this page, you say this:

“It was important that the balance cash declaration was the last thing to be done as making changes in any of the steps before this could alter the system derived cash figure and a new declaration would have to be made.”

You deal with the final stages of the balancing process at paragraph 36 over the page, please. You say this:

“Once the cash declaration is made the branch would make a variance check which would show any discrepancies (this is for shared stock units only, individual stock units would get a message after declaring the cash informing them of any discrepancies). The branch would then proceed to printing the trial balance report, it is at this point that the Horizon System commits any discrepancies, and the loss or gain would show at the top of the trial balance report. The branch would then roll the stock unit over into the next cash account period and a final balance report would be produced.”

That can come down now, thank you.

In 2004, if there was a discrepancy showing at the top of the trial balance report which a subpostmaster or branch staff member wanted to question, what options were available to them?

Andrew Wise: The first thing would suggest they would do was recount the cash and stock before they took any options to contacting anybody. Often cash was miscounted or stock hasn’t been checked correctly, so I would have expected a postmaster to revert to that, first of all. But their option would be to contact the NBSC. NBSC was set up as a single point of contact for branches before Horizon, and before NBSC the helplines were regional. The business brought that together as one centre at Dearne House in Barnsley, and that was the main contact point for branches.

So any queries really like that, they would ring through to NBSC.

Ms Price: Could the branch carry on trading in the next cash account period if they did not roll over the stock unit and commit the trial balance to a final balance report?

Andrew Wise: No. Well, yes, they would be trading in the same cash account period and that couldn’t go on for very long because there was a team, and I’m not sure which team it fell under, but one of the teams as part of NBSC would contact branches that hadn’t rolled over because, I believe, if a branch hadn’t rolled over within – I don’t know whether it was 60 days or 90 days, then that data potentially could be lost. So there was a team specifically to contact branches that hadn’t rolled over and to get them to roll over.

So if a branch chose to carry on serving in the same cash account period they would get that contact from somebody at NBSC.

Ms Price: Moving on to your time at the Network Business Support Centre, there were a number of teams within the NBSC, weren’t there?

Andrew Wise: Yes.

Ms Price: You set those out in your statement but your role was as a Tier 2 Service Support Advisor within one of the service support teams?

Andrew Wise: Yes.

Ms Price: Can you explain the difference between the roles of Tier 1 and Tier 2 advisors, please?

Andrew Wise: The Tier 1 advisor was pretty much a call centre call handler. They would deal with the simple issues. We had branches phoning up just for telephone numbers or asking if they could send certain mail items to certain countries. A Tier 1 advisor had access to all that information via the Knowledge Base and the remedy system, and they could answer those queries relatively quickly.

If the Tier 1 advisor couldn’t find the answer on the Knowledge Base, then generally that would be passed over to Tier 2, and the Tier 2 advisor had more experience, they received more training. A lot of the advisors had come from other areas of the business, such as the old helpline, such as directly managed branches. So they knew more than what the Tier 1 advisor knew. So they could spend more time looking at the problem and finding a resolution for the postmaster.

Ms Price: You’ve mentioned the Knowledge Base. Can you just explain what was covered, broadly speaking, in the Knowledge Base, what type of issues?

Andrew Wise: Every single type of issue you could think of, really. There would be a Knowledge Base article covering off the answer to that query. There was a system in place where, on Tier 2, we had the option to close a call down to own knowledge. So we knew that this was the correct course of action to take. So there’s no Knowledge Base article that covers that but we’ve obtained the answer. It could be by speaking to a member of the product team, it could be speaking to colleagues.

So if a case was closed down to own knowledge and wasn’t linked to a Knowledge Base title, the Knowledge Base team would look at that and look at implementing a page on the Knowledge Base to cover off that question. So every time a new question came up that hadn’t been asked before, that wasn’t on the Knowledge Base, it would then be put on to the Knowledge Base for the other advisors and future calls.

Ms Price: You have explained at paragraph 10 of your statement that the type of queries which the NBSC would deal with ranged vastly from simple questions such as requesting a telephone number for a particular person to more complicated questions, including questions around how to balance.

Were balancing problems generally referred to Tier 2 Support Service Advisors like yourself?

Andrew Wise: Not generally. Tier 1 had the process on the Knowledge Base that gave the basic checklists: have they declared the cash; have they checked the stock? So it would probably be the basic check steps for them to go through and sometimes Tier 1 would resolve that balancing query, so it wasn’t passed through to Tier 2.

If they couldn’t resolve it then, generally, they would always be passed through to Tier 2.

Ms Price: You say at paragraph 19 of your statement to the Inquiry that, on average, Tier 2 advisors would deal with around four or five calls in an hour, whereas the number of calls for Tier 1 advisors would be much higher as their calls were a lot quicker. So is it fair to say that Tier 1 advisors didn’t have very much time to deal with the queries that were coming in?

Andrew Wise: That’s right, and their – Tier 1 and Tier 2 was managed by different companies. So we were all under Royal Mail Group and, part of Royal Mail Group, there was a company called – I think it were Customer Management and they managed all Royal Mail’s contact centres. So Tier 1 were employed by Customer Management whereas Tier 2 were employed directly by Post Office Limited, still under the umbrella of Royal Mail Group. And at Tier 1, they had quite stringent targets to achieve on the calls per hour and the amount of time after a call ends for them to wrap up that call, so it could be typing up the response in the case and closing it down on the system. So their targets were quite strict, compared to what Tier 2 targets were.

But Tier 2 equally had targets and it were averaged out, based on how much time you spent in admin and that’s the time you would spend investigating or finding an answer for a query, how much time in wrap-up, that’s the call – the time immediately after a call has ended where you’re updating the log and putting a resolution in and closing the case down.

And even the amount of time you go for comfort breaks to the toilet, you know, it were all measured through the phone system, so each month you would sit down with your line manager and he’d say “Well, you know, you’ve been in comfort break for five hours this week, what have you been doing”, you know, and it could be you’d forgotten to press the button on the phone system or – you know, so it was monitored and we did have our targets but they certainly wasn’t anywhere near as strict as what Tier 1 was.

Ms Price: Did those limits mean you felt somewhat under pressure to deal with queries quite quickly?

Andrew Wise: Yes and no. At the point of dealing with that call, you was focused on finding a resolution, and you wasn’t focused on, you know, worrying about how much time you were spending on it. You might have a word with your team leader and just say, “Look I’m going to have to spend some time with this”.

On saying that, when you got your monthly figures, and you’re told your admin time is such a percentage above the average for Tier 2 advisors, then that certainly put pressure on you thinking, “Oh, well”, you know, so you might find ways to move it into wrap-up a little bit more, you know, to play the figures, perhaps, to bring your admin time down but you’d push – it’s robbing Peter to pay Paul, you’d push that into wrap-up time, just so that at the end of the month when you have your one-to-one you’re not getting in trouble for being too much or – they measured it on the average time across the Tier 2, so, you know, if you were above that then they would ask you questions on why.

Ms Price: In contrast to the Network Business Support Centre, which was staffed by Post Office employees, the Horizon System helpline was staffed by employees from ICL Pathway, as it was at the time.

Andrew Wise: Yes.

Ms Price: Is that right?

Andrew Wise: Yes.

Ms Price: The Horizon System helpline teams were in a separate location?

Andrew Wise: That’s right.

Ms Price: The Horizon System helpline was the technical support team for Post Office branches to contact with issues relating to the Horizon computer system; is that right?

Andrew Wise: Yes.

Ms Price: It was the Horizon System helpline which dealt with technical issues, such as equipment faults or faults relating to the Horizon System, that’s what you say in your statement?

Andrew Wise: Yes.

Ms Price: You say in your statement to the Inquiry at paragraph 23 that the Network Business Support Centre would interact with the Horizon System helpline and often callers were transferred through from one service to the other. From a Network Business Support Centre point of view, if a caller claimed that they were experiencing issues with their Horizon System, you would transfer them to the Horizon System helpline. That’s what you say in your statement at paragraph 23?

Andrew Wise: Yes.

Ms Price: You deal with this – may we please have the statement back up on the screen, it’s WITN09090100, page 7, please. Could we have paragraph 23, please, towards the bottom. Right at the bottom you say:

“I do recall that [it goes over the page] sometimes callers would get passed backwards and forwards between NBSC and HSH, particularly where a branch had losses and queried where there was an issue with the Horizon System. I do recall that often it was difficult to get HSH to take ownership of calls where branches were experiencing losses as their main criteria for investigating a system issue for a branch was whether they had a receipts and payments mismatch when the branch balanced. From memory I do not recall any branches I dealt with having a receipt and payment mismatch. In situations where callers were passed back and forth, the NBSC advisor would speak to their Team Leader who may in turn speak to their counterpart at HSH to try to get an agreement on who should have ownership of the call.”

That can come down now. Thank you.

Can you explain what you understood at the time by a receipts and payments mismatch?

Andrew Wise: The Horizon System is based on a double entry bookkeeping accounts system. So, in the days of manual balancing, you had a great big ledger document, a daily one and a weekly one, and you had your receipt transactions which, generally speaking, were transactions where money were coming in and payment transactions where money was going out.

So the way Horizon was designed was the double entry bookkeeping, everything would have a counter entry. So if money was coming in, then on the other side cash would go up and, likewise, if money was going out on the other side cash would go down.

So the receipts and payments, when the trial balance is produced, had to agree, because every transaction has its counterpart.

If the receipts and payments mismatched and they didn’t agree, that was an indication that something has happened in the accounts that perhaps shouldn’t have happened. We probably didn’t think of it as a bug, as such, but for want of a better word, we can call it a bug, but it just indicated that there was an issue, something had gone in the accounts to cause that mismatch.

And what would happen from that, the branch wouldn’t be able to roll over and proceed to cash account and they would have to go to Fujitsu to get them to remedy whatever the issue was. So – and if they didn’t ring NBSC, then the process I described earlier about a team ringing branches serving in the same cash account period, they would ring the branch to find out why they’d not rolled over. So it really wouldn’t get missed.

They would either – the branch would ring NBSC at the time they experienced the mismatch or somebody would contact the branch if they’d not done that because they’d be serving in the same cash account period.

But that was the main indicator that something had happened on the system because there were never a scenario where the receipts and payments would not agree.

Ms Price: How did you come to understand that the Horizon System helpline would use this as their main criteria of accepting ownership of a call.

Andrew Wise: I’m not 100 per cent sure. I don’t know if it stems from my days working on the Horizon project or that was what we was told as part of the training package for NBSC. I can’t recall which it was but that was my understanding and my memory was that that was a general understanding across advisors.

Ms Price: In terms of the information that you as a Tier 2 advisor within the Network Business Support Centre had access to, you had access to the Knowledge Base, we’ve touched on that, you also had access, you say in your statement, to all counters operations, manuals and Horizon user and balancing guides?

Andrew Wise: Yeah.

Ms Price: But you say you did not have access to any branch Horizon transactional information; is that right?

Andrew Wise: That’s correct, yes.

Ms Price: So you were reliant on what someone calling you told you over the phone –

Andrew Wise: Yes.

Ms Price: – save that you sometimes asked branches to fax or post paperwork through to you?

Andrew Wise: Yes.

Ms Price: Speaking in general terms, is it right that your evidence to the Inquiry is that when the Network Business Support Centre looked at branch cash accounts to assist a postmaster, you were looking to see if any mistakes became apparent? That’s the wording you’ve used in your statement.

Andrew Wise: Yeah, that’s correct.

Ms Price: You say at paragraph 47 of your statement to the Inquiry – we need not turn that up now – that the Network Business Support Centre would not have been able to identify if there were any issues caused by the Horizon System. This would have to be investigated by the Horizon System helpline?

Andrew Wise: That’s correct.

Ms Price: You say in your statement to the Inquiry at paragraph 56 – again, we need not turn it up for now – while you were at the Network Business Support Centre you dealt with numerous branches who had balancing issues or discrepancies?

Andrew Wise: That’s correct.

Ms Price: Turning then, please, to your involvement in dealing with the calls made by Mr Castleton to the Network Business Support Centre between December 2003 and April 2004. In the statement you provided for the purposes of the litigation brought by the Post Office against Mr Castleton a statement dated 13 October 2006, you provided an overview, didn’t you, of all the call logs from the Marine Drive branch in this five-month period?

Andrew Wise: Yes.

Ms Price: Could we have that statement on screen, please. The reference is LCAS0000110. It’s page 9 of that document, please, paragraph 35. You say here:

“As appears from the above call logs below, there were a total of 88 NBSC call logs relating to the Marine Drive branch for the period December 2003 to April 2004. Out of these 88 calls, 62 calls appear to be concerned with minor issues. Of the remainder for the period from December 2003 to 23 March 2004:

“11 calls [and I won’t go on to specify all those dates] appear to relate purely to the issue of losses;

“11 further calls … appear to relate purely to computer issues of various sorts; and

“4 further calls … appear to raise issues relating to both the losses and computer system.

“None of the call logs themselves revealed the existence of any computer faults, although the subpostmaster did in some calls say that he thought he was having computer problems.”

One of the calls which you categorised as relating purely to the issue of losses was dealt with by you, wasn’t it? The call on 22 January 2004.

Andrew Wise: I believe I dealt with one of the calls. I can’t recall the date. I think I referenced it in my statement.

Ms Price: You deal with this at paragraph 55 of your statement to the Inquiry. We needn’t turn that up now but could we have on screen, please, the table setting out details of the 88 calls made in the relevant period. This was part of the documentation produced for the trial in the case against Mr Castleton and the reference is LCAS0000365, and it’s page 29 of that document, please.

The entry on this page relates to the call that it appears you dealt with on 22 January 2004. In the column in the middle, the incident log column, we can see the call being allocated to “wisea_”; is that you?

Andrew Wise: Yes.

Ms Price: We can see the date in the first column and a brief description which says “Discrepancy”, in the third column. In the “Activity” column, four from the right, we see it says, “Cash Account Discrepancy”.

There’s a more detailed description in the fourth column there:

“PM has a loss of #4000, he was in the office until 11.00 last night and could not find anything.”

Then there’s the resolution in the fifth column. Is this the entry made by you?

Andrew Wise: I can’t see the resolution on the screen.

Ms Price: It’s the fifth column in?

Andrew Wise: Oh, yes. Yeah, I can see that. Yeah, the – what normally happened, Tier 1 would put quite basic information in. So I may well have changed the detailed description to be a little bit more descriptive and the resolution would have been written by myself who closed the call down.

Ms Price: The resolution reads:

“Went through all the balance cheques with PM, he had checked the rems in and out, his cash stock and P&A and he was unable to find the loss. Advised I would pass through to suspense.”

Looking at these notes of the actions you took, what information do you think you had to work with when you were going through this with Mr Castleton?

Andrew Wise: From that call, I believe it would all be verbal over the telephone. So it would be me drawing out information, asking him to check various reports, going into various declarations, asking him to check his cash again. So it would be me talking him through everything on the telephone.

Ms Price: You said you were going to pass through to suspense. Did that mean you were going to refer the case to the suspense team?

Andrew Wise: Yeah, so what would normally happen, I would close this call down because that’s my call and my stat, and then I would create a new call that would be allocated to the suspense account team for them to look at whether they would authorise the loss or not. I’m not sure what their processes were but the main thing was he had a £4,000 loss that probably couldn’t afford to put in, so the suspense account team would look at whether he could hold that loss in his suspense account to give time to see if anything came back from Chesterfield as a transaction correction or to see if anything else came back that would account for the £4,000 loss.

Ms Price: Would the suspense team do analysis further investigation?

Andrew Wise: I’m not entirely sure. I know they’d linked in with the Retail Line Managers because often authorisation would come from the Retail Line Manager to decide whether it could be held in suspense and I think the hardship side of it was driven by the Retail Line Manager. But I’m unsure of any work the Suspense Account team would undertake.

Ms Price: Could we have on screen, please, the document at FUJ00120934. This is a PEAK incident management system log. Who would create these?

Andrew Wise: This would be created at Horizon System Helpdesk.

Ms Price: I understand you’ve recently been provided with a copy of this log; is that right, did this make it through to you?

Andrew Wise: Yes, it did.

Ms Price: Just to be clear, this log does not relate to calls made to the Network Business Support Centre by Mr Castleton but the reporting of this issue to the Horizon System helpline took place on 13 January 2004, shortly before you dealt with the call from Mr Castleton on the 22 January 2004.

I’m looking at the second box down, please, the entry at 15.23, and this is three lines down in the box. We can see:

“Call details have been taken from Andrew Wise at NBSC on telephone number stated above. PM has a discrepancy with his cash account for the last few weeks.”

Then in the box further down, this three lines down again under “Information”:

“The NBSC have been through the checks with the PM feel there is a software error as the PM has negative figures which he would not have been able to enter.”

This is an example, isn’t it, of you considering that a cash account discrepancy might be being caused by a problem with the Horizon System software; is that right?

Andrew Wise: I would pitch it more as there was something in the account that didn’t look usual and I know on the line at 15.25 that it refers to he “can only declare the holding amount or 0 not a negative figure”, so that would indicate that it’s to do with either a cash, stamp or stock declaration that wasn’t doing what you’d expect it to do.

So in that instance, our only course of action would be to pass that over to HSH for them to look at, to come up with a resolution or a fix or whatever that may be.

Ms Price: Had you known of cases prior to this one where a cash account discrepancy had been caused by a problem with the Horizon system?

Andrew Wise: I’m not aware. I’m not sure if it’s a case of I don’t remember or if that never occurred. The problem was so with this particular incident here, once that were passed over to HSH, I would close my call down and move on to the next, so I would never get any feedback to say whether it’s a technical issue or not. We pass it over and they look at it, and I guess this is kind of showing the system working.

We pass it to HSH because we spot something that doesn’t seem normal and we can justify the reason for passing it to them. So, on the previous call we looked at, where it was just a £4,000 loss, that’s all we’ve got. We’ve done our checks and, in those circumstances, it was pretty much next to impossible to get Fujitsu to take that on because there’s no indication of anything going wrong, whereas, in this instance, the reference to the negative figures at declaration is that foot in the door to be able to get HSH to take that on, which they have done and investigated that.

Ms Price: In the situation with Mr Castleton where you also weren’t being presented with information of a user error, did you consider whether the problem might have been caused by the Horizon System?

Andrew Wise: I don’t think I did. I don’t think that was a consideration that had come in. We were focused on solving the problem and the assumption was that it was a mistake. So we’re looking for where that mistake has been made.

Ms Price: Were you told about the outcome of this issue, not Mr Castleton but the one we have on screen at the moment, at the time?

Andrew Wise: No.

Ms Price: Going back to your involvement in the issues being raised by Mr Castleton in early 2004, do you have any independent recollection now of assisting Ms Pennington with analysis of the problems being experienced by Mr Castleton in late January and February 2004?

Andrew Wise: I don’t have any recollection of the specific interaction, no, I don’t.

Ms Price: You addressed this involvement in your statement for the litigation bought against Mr Castleton by the Post Office, that’s the statement dated 13 October 2006, could we have this on screen please. That’s LCAS0000110, at page 7, please. Paragraph 26 here reads as follows:

“Sarah Pennington (who has since left the Post Office) was the Tier 2 advisor who dealt with some of the calls raised by this office at around the end of January 2004. At that time and during these calls she discussed the issues with me. I do not now remember all of the details of this case but had refreshed my memory from reviewing the NBSC call logs and the email dated 20 April 2004 from Andrew Price (NBSC) to Catherine Oglesby (who was then Mr Castleton’s Retail Line Manager) (page 13).”

Did you have an independent recollection of the analysis you did and the conclusions you reached when you provided this statement in October 2006?

Andrew Wise: Honestly, I don’t know because the memory becomes do I remember the event of the trial and knowing I read the email, which refreshed my memory, or – so it kind of gets a bit muddled up to what I’m actually remembering. Am I remembering what happened in 2006 based on what were presented or am I remembering actually the interaction in 2004.

So I’m not sure if at the time I remembered it. It was only two years after the interaction with Sarah Pennington and my memory is generally quite good, so it could be at that time I had a vague recollection of that but the sheer numbers of calls we dealt with, and also being one of the more experienced advisors with balancing, quite a lot of colleagues would come and ask me questions and ask me to review things because they couldn’t find an answer and they knew my experience was greater.

So as well as my own calls that I was dealing with, I were getting asked a lot of questions, as well. So I couldn’t say for sure if I remembered in 2006 what had happened in 2004 or not, unfortunately.

Ms Price: In terms of the provenance of the email you refreshed your memory from, could we go over the page, please, to paragraph 33 of the statement, and towards the bottom of the page now. You say here:

“I can see from the NBSC call logs that on 4 March 2004 Mrs Oglesby asked NBSC for information of calls made to the NBSC from the Marine Drive branch relating to losses when balancing and what investigations were undertaken by NBSC during those calls. I helped Sarah Pennington to prepare an email that Andrew Price (NBSC) could (and did) forward to Mrs Oglesby on 20 April 2004 to explain what investigations had by that time already been carried out.”

Can we look, please, to that email of 20 April 2004, which appears on the last page of this document, page 30, please.

Andrew Price, whose name appears in bold as the sender and at the bottom of this email, says at the start of the email that he asked Ms Pennington and you to provide a form of words and actions taken whilst dealing with the PM at the above branch.

So does it follow that, after the punctuation there – and it’s quite a bad copy but it looks like we have a dash and a colon – is that the wording prepared by you and Ms Pennington?

Andrew Wise: I believe so. It certainly reads like that.

Ms Price: That wording reads as follows:

“When I spoke to the PM at Marine Drive he was unsure what was causing these errors. He told me that he has been using the slave machine for his rems and I assured him that wouldn’t cause a problem as long as he was attached to the correct stock unit.

“The PM thought there would be some errors relating to National Lottery. I phoned the lottery team at Transaction Processing who confirmed that there were some errors relating to Lottery, but for every charge error there was a corresponding claim error, this was due to the lottery figures being entering on Horizon in the wrong CAP.

“PM was also concerned that when entering the lottery figures, it was as though the terminals were not communicating, but if that was the case the PM would have large number of errors on every report and product.

“The PM sent cash account information to NBSC and it was looked at by Andrew Wise, he was unable to find any errors. The only amount questioned was a large amount on the cheques to processing centre which Andrew was able to confirm was a cheque payment for the purchase of Premium Bonds. The PM was advised there was nothing more we could do and we suggested he works a manual system at the side of Horizon to see if any problems were highlighted.

“Also when doing the rems the PM should take a snapshot before and after to see if any problems were occurring when doing a remittance.”

The line underneath this says:

“Andrew Wise and I both feel that the Horizon System is working properly and we are unable to help the PM any further.”

Just to clarify, was this Andrew Price saying that you and he felt that the Horizon System was working properly.

Andrew Wise: I believe so, yes.

Ms Price: Going back to what you said in your statement for the litigation about this email, this is page 8 of the document we’re currently looking at, paragraph 32, about two-thirds of the way down:

“Although I do not now recall it, our email suggests (and I believe) that we concluded that the Horizon System was working properly and did not appear to be the cause of the unauthorised losses incurred.”

Before going into any more detail about the substance of your conclusions there, I’d like to ask you, please, a little bit about the process by which this statement for the litigation was prepared, if I may. You deal with the circumstances in which you came to provide a statement for the litigation at paragraph 50 of your statement to the Inquiry. There’s no need to have that up on screen at the moment.

You were approached by Bond Pearce who were acting for the Post Office in the litigation; is that right?

Andrew Wise: Yes.

Ms Price: Could we have up on screen, please, the document at POL00070822. If we could scroll down, please, the email dated 21 April 2006, this appears to be the first contact made with you by Bond Pearce; is that right?

Andrew Wise: Yes.

Ms Price: This email is from Stephen Dilley, a solicitor with Bond Pearce?

Andrew Wise: Yes.

Ms Price: We see at point 1 a summary of the dispute. Over the page, please, at point 2, a summary of the assertions being made about the computer systems by Mr Castleton. At point 3, further down the page, about halfway through that paragraph, Mr Dilley says:

“I would like to arrange to meet and interview you at Capston House in June to understand what involvement you had at the time and what you make of Mr Castleton’s assertions. Based on our discussions, I will then prepare a short Witness Statement for you to approve and sign.”

After you met with Bond Pearce, is it right that a first draft of the statement was provided to you –

Andrew Wise: Yes, I believe so.

Ms Price: – and there were some further amendments made following correspondence between you and Bond Pearce?

Andrew Wise: Yes.

Ms Price: Was it explained to you at the time you were making the statement the importance of ensuring that everything in the statement was accurate to the best of your knowledge and belief?

Andrew Wise: To be honest, I’m unsure. At that point, I’d never given evidence in court before or never provided a statement before. So I really was in their hands. I don’t recall what advice they give me. I do remember they’d come up to where I worked in the building at Capston House in Salford Quays and I think there were two people that come, one being Stephen and somebody else, but I can’t fully remember.

And I do remember that we sat down together and they asked me questions and I think, from my knowledge of processes, that’s why the statement grew beyond just being about Mr Castleton’s case and growing into processes on balancing, things like that. I think it had become apparent to them that I had quite a good knowledge of processes.

I don’t recall – because I know from the jobs I’ve done subsequently the importance of statements. I’ve attended court. I don’t recall any advice as such around that, but I don’t know if it’s just I don’t remember or a case they didn’t. I can’t answer that, I’m sorry.

Ms Price: You gave evidence at the trial in the Castleton case on 11 December 2006; is that right?

Andrew Wise: Yes.

Ms Price: You confirmed the contents of your written statement for the litigation in oral evidence. Could we have on screen, please, your statement for the litigation at LCAS0000110. It’s page 21 of that document, please. This is your concluding paragraph, at paragraph 115. I think the numbering is somewhat out there because we go from 122 to 115 but, at the bottom of the page, you say this:

“Having reviewed the email dated 20 April 2004, I can see that we did not find anything to suggest that the Horizon System was not working properly or causing the unauthorised losses. The NBSC call logs do not themselves reveal the existence of any computer faults.”

Can we compare this, please, with what you said earlier in your statement at paragraph 32. This is page 8 of the document, please. You say here:

“Although I do not now recall it, our email suggests (and I believe) that we concluded that the Horizon System was working properly and did not appear to be the cause of the unauthorised losses incurred.”

I go back to that not to be repetitious but you do, don’t you, go one step further in paragraph 32 than your concluding paragraph. So you’re saying here that you believe you concluded the Horizon System was working properly and did not appear to be the cause of the unauthorised losses incurred, as opposed to saying, in effect, there was no evidence of a problem.

Andrew Wise: There being no evidence of a problem would logically lead me to the conclusion, you know, that I concluded it was working properly. So I believe one thing would lead to the next. It might be worded different. I think the point of it – trying to make is the same point that I didn’t consider there were an issue with the Horizon System. Worded slightly differently but I think one would lead to the next, if that makes sense.

Ms Price: Can we go, please, to your statement to the Inquiry at WITN09090100. This is page 16, please, paragraph 47, about two-thirds of the way down the page. You say here:

“In the email from Andrew Price dated 20 April 2004 … he writes that ‘Andrew Wise and myself both feel that the Horizon System is working properly and we are unable to help the PM further’. In my witness statement from 2006 … I comment that I did not recall saying that and I still do not recall a conversation with Andrew Price where this was discussed. Generally, when NBSC looked at branch Cash Accounts to assist a postmaster we were looking to see if any mistakes become apparent. NBSC would not have been able to identify if there were any issues caused by the Horizon System, this would have to be investigated by HSH. The only indication for NBSC to establish whether there was an issue with the Horizon System would be a Receipts and Payments mismatch when the branch tries to balance. From reviewing the documentation provided I cannot see any evidence of a receipts and payments mismatch occurring at Marine Drive Post Office, my assumption now would be the lack of a receipt and payment mismatch, would be the basis of the comment in Andrew Price’s email …”

It’s quite an important point, isn’t it, that the Network Business Support Centre would not have been able to identify if there were any issues caused by the Horizon System and that this would have to be investigated by the Horizon System helpline?

Andrew Wise: Yes, it’s important.

Ms Price: Because if that’s right, it would be difficult for the NBSC, as opposed to the Horizon System helpline, to conclude that the Horizon System was working properly?

Andrew Wise: It would be but NBSC would never have sight of the full machine, if you like. We were a small cog and, you know, there were suspense accounts teams, there were Horizon, there were the area managers, there were the other teams that would look at it. We were just a small cog. So within scope of what NBSC could do, I’m answering that, within that scope of what we look at, we can’t identify any losses.

So I’m not giving a blanket statement for the whole business, for the whole HSH, I’m saying within the scope of what I can look at, I cannot see anything that would indicate a Horizon loss. That – like you said, that would have to go to Fujitsu ultimately to determine that.

Ms Price: This caveat, if I can call it that, as to what NBSC could and couldn’t do, doesn’t seem to appear, at least not in these terms, in your statement for the litigation. Can you remember ever suggesting that it was included?

Andrew Wise: I can’t remember suggesting that.

Ms Price: Can you see that, without this caveat, the reader of paragraph 32 of your statement for the litigation might have thought that the network business support centre was in a position to draw the conclusion on its own that there were no issues caused by the Horizon System?

Andrew Wise: Yes, I can see how that could be perceived.

Sir Wyn Williams: Ms Price, would you take the witness back to that paragraph, and the misnumbered 115 again, just for me to be precise in my mind about what they say?

Ms Price: Of course, starting with 115, sir?

Sir Wyn Williams: Yes.

Ms Price: That’s LCAS0000110, page 21, towards the bottom, 115. This is the concluding paragraph, which is in slightly different terms to the paragraph we went to earlier.

Sir Wyn Williams: But on the face of it, Mr Wise – and if I’m taking it out of context please say so – that does appear to me, hopefully reading it objectively, to be an assertion that the Horizon System had not caused any unauthorised losses, which is a very broad statement, is it not?

Andrew Wise: It is quite a broad statement. That was my view based on what we could do at NBSC and that’s –

Sir Wyn Williams: But as was pointed out to you, in your evidence to me you’re making it clear that what you could do at NBSC was much less than that statement might lead a reasonable reader to conclude; would you agree with that?

Andrew Wise: I would agree with that, yes.

Sir Wyn Williams: Thank you. Do you have any recollection of actually drafting those words yourself?

Andrew Wise: I don’t recall drafting the words. I know the statement was written on my behalf and sent to me to read through and I think there were several drafts of it which I read through. The things I tended to look at changing were likely things like processes that were not quite correct that had been put in there.

So having – speaking to the two people that came up to Capston House to see me, they went away and wrote the statement based on that conversation, which I think there were two or three emails to and fro asking questions, or me reading through and changing things that I felt necessary to change.

I don’t think I wrote these words and, looking back at – knowing what I know now, looking back at a statement from 2006 that was written on my behalf, it does make me cringe a little bit, for want of a better word, and I would look at that and think “Well, ooh, I wouldn’t have necessarily pitched it like that”, but that’s with the knowledge I’ve gained over the years and the jobs I’ve done more recently to be able to look at it and think that.

Sir Wyn Williams: I follow. Thank you.

Sorry for interrupting, Ms Price.

Ms Price: Not at all, sir.

Coming back to the level of calls being made by Mr Castleton between December 2003 and April 2004, this was a man, wasn’t it, who was desperately seeking help to understand why he was experiencing discrepancies?

Andrew Wise: Yes.

Ms Price: If we can turn, please, to page 21 of your statement to the Inquiry, so this is WITN09090100, page 21, please, at paragraph 58, a little further down the page, please. You reviewed some of the Horizon System helpline call logs provided to you by the Inquiry and you draw this conclusion in your last sentence:

“Although I am not familiar with the layout of these HSH logs, and I am not familiar with the some of the technical terms and jargon it is clear that Mr Castleton made numerous attempts to request HSH look at his Horizon system as he was experiencing large and frequent losses.”

Then this at paragraph 59:

“As I mentioned earlier in this statement, broadly speaking the Service Support Team in NBSC was responsible for dealing with transaction and process related queries, this included the balancing process and supporting with losses. HSH was responsible for dealing with technical related issues. My memory of my time at NBSC was that it was always difficult to get HSH to investigate balancing type issues as they deemed these NBSC responsibility and unless there was a receipts and payments mismatch, they deemed it an NBSC issue.”

Could we go, please, to page 23 of this document and paragraph 63. You say this:

“Having familiarised myself with the documents provided to me by the Inquiry (importantly the NBSC call logs and Fujitsu call logs) I can see that Mr Castleton (or a member of his staff) repeatedly reached out to both helplines requesting support regarding his balancing and the losses he was experiencing. This was probably on a more frequent level than you would expect from branches although this would not have been known at the time of taking the call as the Service Support Advisor would not have full visibility of all the information.”

You then conclude at paragraph 64 at the bottom of the page:

“However, after reviewing the call logs I do think that Mr Castleton was left out on a limb and numerous calls were concluded by sending him to another team. This meant that Mr Castleton was bounced between NBSC and HSH, which looking back at that now I do not think that was helpful for Mr Castleton.”

These are obviously your reflections on matters now. You say at paragraph 65 that you did not really form any conclusions of causes of losses when assisting branches, so at the time. But at the time you were involved in the litigation as a witness, did you ever question the basis on which the Post Office was pursuing Mr Castleton for the apparent losses in question, in circumstances when Mr Castleton himself had repeatedly sought help from the helplines to get to the bottom of the cause.

Andrew Wise: I think during the litigation in 2006, I was just focused on the evidence I was giving. I wasn’t really exposed to a lot of things that I’d been exposed to since. I understood from my experience that Post Office would go after all losses, you know, postmasters were responsible, and that was the line “You’re responsible for the losses”, and they pursued that, I understood that. I didn’t really give thought – I didn’t have the full picture to think that this poor man, he’s reached out all these times and now we’re going after him for the money.

I was there focusing on my little piece of evidence because it was quite new to me, it were quite daunting. So I didn’t think I had the capacity, if that makes sense, to broaden that at quite a stressful time to go down to London, to go to court, to do all the work with the solicitors.

So I think that was my focus, rather than thinking broader than that.

Ms Price: Did you ever ask yourself whether there was an actual loss to be recovered?

Andrew Wise: No, I don’t think I did.

Ms Price: Reflecting on things now, do you think it was right that the Post Office pursued Mr Castleton for the apparent losses in the litigation in the way it did?

Andrew Wise: It’s a difficult one to answer that. My thinking lately, with everything that’s going on, has been around – the Post Office has had this contract, say, for 300 years. You know, that’s as long as Post Office has existed. It was a very archaic contract and very harsh on postmasters and what I tend to think about is at what point that should have changed. Should that have been in the ’90s? Should that have been in 2006? Should that have been in 2019 when things did change because of the Group Litigation?

So I tend to reflect more on that to try to rationalise in my own head at what point it was appropriate to stop being like that and I don’t know if that was in 2006 when they were pursuing Mr Castleton for this. Certainly, thinking back now, it feels very harsh, you know, and like you said, he was crying out for help. He were making calls in there and, regardless of the reason for the loss, my view, looking back, is Post Office should and could have intervened sooner rather than later, than let it get to where it sat.

So there’s a lot of thoughts around it, and I wouldn’t say I’ve had a thought thinking “Oh, they shouldn’t have gone off after Mr Castleton for the money”, because I don’t think I have. It’s more a broader thought around how Post Office Limited operated, how it treated postmasters and one of my roles was the Business Development Manager role, which was a sales support role and I dealt face-to-face with branches and I had branches who were on the sharp end of Post Office. You know, it might be they cashed a fraudulent green Giro cheque and Post Office were saying “Right, you’ve cashed that, you owe us £300”.

So my thoughts are Post Office is very harsh and was very harsh but I try at to reflect more on when, as a business, that should have changed, similar to smoking. 30 years ago you could sit in a pub and come back smelling of smoke. Now that’s inappropriate. Was that the right time to stop that or should it have been stopped earlier?

And that’s how I view it. At what point should Post Office have looked at its contract with subpostmasters and said “No, this isn’t acceptable in this day and age, we need to change that”?

Ms Price: Sir, those are all the questions I have on the Mr Castleton case. There are some other questions that I have on different issues. Would that be a convenient moment to break for lunch?

Sir Wyn Williams: It would, but let me just ask a question that’s been going around in my mind because it relates to the Castleton case, and then we’ll break, all right?

Ms Price: Of course, sir. Apologies.

Sir Wyn Williams: No, no, that’s fine.

Mr Wise, will you assume for the moment, because there may be a debate about it, but will you assume for the moment that some of the evidence which you gave in writing, in your witness statement for the litigation, and some of the oral answers which you may have given when you gave evidence before the judge was what lawyers call opinion evidence, all right? Were you ever given any advice by any lawyer acting for the Post Office about the duties involved or the duties imposed upon persons who give opinion evidence, as opposed to factual evidence?

Andrew Wise: I don’t think I was, no.

Sir Wyn Williams: All right, thank you.

Let’s have our break. When shall we start again, Ms Price?

Ms Price: We are 12.55 now, so shall we say 2.00, sir?

Sir Wyn Williams: Certainly. That’s fine.

2.00, everyone.

(12.52 pm)

(The Short Adjournment)

(2.00 pm)

Ms Price: Good afternoon, sir.

Sir Wyn Williams: Good afternoon.

Ms Price: Can you see and hear us?

Sir Wyn Williams: I can indeed, yes.

Ms Price: Mr Wise, I’d like to ask you about your move to the Security team in 2011 and becoming a security manager. This was quite a different role to those you had held previously. How did you find the change?

Andrew Wise: I was very conscious of the role and what it undertook and I did think quite hard about particularly the investigation side of that and, you know, dealing with criminality because that’s not something I was used to. You know, my role had always been quite supportive and, thinking about it, I wasn’t sure if that would be the role for me, if that made sense.

So I did think about it but I went for the job because it was out in the network, it were dealing with postmasters. I had a lot of knowledge and experience I could bring to that role and I was successful.

So it was quite different but I had the support of years of knowledge and experience to be able to apply to that role, so I knew I could take that with me and be quite useful in the role.

Ms Price: What training were you given for the role?

Andrew Wise: When we initially started, it was just on the physical aspect of the role for the first few months, which were dealing with branches: robberies, burglaries, crime prevention, things like that. The plan – I think I started in the January and in the March was when the training was booked for the investigation side of the role. So from starting in January up to March, we was given online learning around PACE and the Codes of Practice and other various things that we had to complete online, and we did that on the run up until the course in the March.

And I think it was a three-week residential course which was based down at Coton House in Rugby, which Royal Mail held as like a business centre. We had our own hotel on site and meeting rooms. Everything was done in-house on site.

On the first day of the course we had to sit an exam based on the last three months of learning around PACE and I think it was – we had to achieve 70 per cent or 78 per cent to be able to continue to sit the course. If you didn’t achieve that mark, then you wouldn’t be able to continue on the course. And then it were the – I’m sure it was three weeks because the middle week – the reason I say that is I drove myself the first week, the second week my line manager took me down and I’m sure I drove the third week because Lesley wasn’t available, so that’s why I think it were a three-week course. But I’m thinking back, you know, to 2011 now, so – but that’s the reason I think it was three weeks.

Ms Price: Who provided the training?

Andrew Wise: It was in-house from the Security team. So we had two people who trained us. There was a gentleman called Paul Southin, who was one of the financial investigators within the Security team, and he was supported with an investigator called – he were called Paul, I can’t quite remember his – Paul Whittaker. So it were the two of them who worked within the Security team that delivered the training.

Ms Price: As you have said in your statement for the Inquiry, you had some involvement in the criminal investigation of Grant Allen and Khayyam Ishaq, whose cases the Inquiry will be exploring further in future hearings. You say in your statement provided to the Inquiry that you had some limited involvement in the cases as second officer in the case and attended their interviews. Can you just explain for the Chair what the role of second officer involved in an investigation?

Andrew Wise: Okay. So when a case is raised, it’s assigned to an investigator and it’s the team leader that makes that decision, based on workload and geography. So they would assign the case to that particular investigator and they would be first officer. So they would undertake the investigation. They would have all contact with the subpostmaster and make all arrangements.

Now, that first officer would choose a second officer, again based on workloads. Within the north team there were four of us that worked out of Manchester, it later moved to Bolton. So the lead investigator would decide, you know, who would go along and be second officer.

And that was just really a role for on the day of the interview. So before the interview we would probably get a little bit of prep on the background of the investigation and, you know, the circumstances around why they were being interviewed. It were very much setting up the room, greeting the person and the representatives, you know, making sure everybody were comfortable. During the interview you were there as support, so if you felt there were a question that needed to be asked, you could interject with that question or you would wait for the first officer to open up and ask you if you had anything to add or if you had any questions to add.

So it really was case-by-case dependent how much input you had in the interview, depending on what the first officer had covered off in his question. And the first officer would have an interview which he would share with you so you had an idea of the questioning and the lines it was going to go down.

Ms Price: After you completed your training, was there a period of time when you only did second officer investigation work before you were elevated, so to speak, to being first officer in the investigation?

Andrew Wise: When we finished our training, we were mentored probably, I would say, at least for 12 months, if not for two years and I remember, within two or three months after coming out of the training, I was – I’ll say tentatively given the first officer role but closely monitored by the mentor, who – you know, whereas in a normal investigation the first officer would do the investigation, whereas your mentor, who would generally be the second officer for you, supported in that. So you weren’t left to do it all by yourself.

So I think it was a mix. We were second officer for more than what we were first officer for but there wasn’t a period of solely doing second officer. It was case dependent on the type of case, the complexity of that case, on whether you would be given the first officer for that.

Ms Price: Can you recall now the interviews with either of the individuals that I just referenced?

Andrew Wise: Not specifically. I can recall certain aspects, such as I remember going to Bradford Mail Centre where the interview took place. I think Mr Allen’s interview took place at our actual offices in Salford but I can’t remember specifics of the case or what questions were asked.

Ms Price: You’ve been provided with some further documents relating to their cases fairly recently by the Inquiry. Has that assisted your recollection at all?

Andrew Wise: I’ve briefly looked through them because in the number of documents provided I’ve not been able to, you know, read – you know, spend a particular amount of time reading them. It did prompt a few things. I can remember, when I read it, I think it was the case with Mr Allen where the interview was stopped because he indicated he didn’t want legal representation, then he suggested he might do and, because of that, we had to stop the interview and get agreement from a senior member of the Security team to proceed and I believe I read that that occurred in that.

So it bought back a little bit because I can remember we had to contact – at the time I think it were Dave Pardoe who were the Head of Security Operations to get authority to proceed, because Mr Allen said “Oh no, we will continue, I don’t want legal representative”, but we couldn’t just do that. We had to get sign-off from somebody more senior to allow us to continue because of those circumstances.

I can’t remember much about the case or the loss or what he was accused of and similarly for the other gentleman. I seem to remember the one in Bradford, it were to do with stock, and him adjusting or manipulating his stock figures but, again, it’s all quite vague, to be honest.

Ms Price: To the best of your recollection, did you have any involvement in their cases after the interview stage?

Andrew Wise: No. The only involvement would probably be writing a witness statement to say I was there attending as second officer but I wouldn’t have any other involvement in the progression of that case.

Ms Price: You say in your statement to the Inquiry that you never had any concerns about the criminal cases you were involved in while you were in the Security team. Does that remain your position?

Andrew Wise: I think it does, yeah. I will say my current position is on the fence, if that makes sense, because there’s been an awful lot of talk and evidence coming out about bugs and how flawed, in particular, the original Horizon was. I acknowledge that and I can see that but what’s not happened is the business haven’t come to us and said, “This bug, this branch; here’s the bug, here’s the data, here’s how it materialises in the data”.

So my view is there’s a potential for bugs, which means is it appropriate for convictions to be overturned? Then I would say yes, because that the legal system and if there’s a potential for bugs then that has to be explored but, equally, there’s a potential for it not to be a bug, so I would say I’m on the fence at the moment.

Ms Price: Just in terms of your position at the time, so when you were involved in those cases, does it remain the position that you didn’t at that time have concerns?

Andrew Wise: I didn’t at that time have concerns, definitely.

Ms Price: Could we go, please, to your statement to the Inquiry that is WITN09090100, page 30, paragraph 87, please. On the question of your knowledge of bugs, errors or defects in the Horizon System, you say this:

“I have been asked by the Inquiry whether I had, or was aware of, any concerns regarding the robustness of the Horizon System IT system during my time working for the Post Office. To my knowledge in all my career working for the Post Office I have never witnessed a bug, error or defect while using the Horizon System and I have never had any concerns. When I joined the Post Office Security Team in 2011, I became aware that a group of subpostmasters were claiming that Horizon was responsible for the losses they had suffered in branch. However, the message from the business was always that there were no issues with Horizon and even during the start of the Group Litigation the theme from the business was that POL would be successful in proving there was no issue with the system.”

We’ve talked about receipts and payments mismatch being the main criteria for the Horizon System helpline accepting ownership of a call. We talked about that earlier. Did you understand this to be a reference to a bug, error or defect in the system or not?

Andrew Wise: It’s interpretation on what I mean by bug, error and defect and what other people may mean by bug, error or defect and I liken it to my work laptop. The screen will freeze, I have to log out of Teams and log back in. I have to reboot my computer. I get a blue circle which means my memory’s completely full and I have to get IT to resolve that. They’re glitches that you live with. I wouldn’t phone Microsoft up and say, “What’s going on with my computer? It’s full of bugs”. It happens, it gets resolved, it doesn’t have a detriment on what I’m doing.

So when I refer to bugs, errors or defects, I’m kind of referring to – I may have seen a screen freeze, I may have been in branch and had to reboot the base unit but they’re not what I mean for bugs, errors or defects. I may have seen something at NBSC that doesn’t look quite right or I can’t explain, but that’s passed over to HSH.

That – what I’m saying is that’s not – concerns me, that’s not give me reason to think “Oh, there’s something wrong with Horizon”, because that’s technology and I trusted, and I think we – a lot of people in the Post Office trusted the assurances that Horizon wasn’t doing what we’re saying it’s doing now, you know, and I’ve got to work on that trust from the business. You know, I can only go off what they’re assuring me.

For example, if I buy a new BMW, I’m not going to ring up BMW the day after I pick it up and say, “Can you assure me that my engine is going to turn on when I get in the car? Can you assure me that the lights will come on?” I buy it with that expectation that it’s fit for purpose and that’s what coming down from the business, that Horizon is fit for purpose.

So when I refer to bugs, errors or defects these are the big bugs that I would say is capable of causing a loss and that’s what I mean in I’ve never come across – you know, I may have come across the smaller ones, I may have referred postmasters to HSH because I couldn’t understand what was being presented to me, you know, through that postmaster, but that never gave me any cause to doubt the system and that, coupled with the assurances from the business, you know, it just meant I had no reason to dispute that.

Ms Price: You’ve just referred to whether or not the system could cause a loss. But is it fair to say you knew from your time at the Network Business Support Centre that software issues with Horizon could cause discrepancies on the basis that at least one case we’ve looked at, you referred it with that possible suggestion?

Andrew Wise: I don’t know if I was aware – and still now I’m not aware of a lot of the bugs and how they materialise in the data or in the system and, certainly then, I don’t think I was aware or fully understood whether they could or couldn’t. We would review what was in front of us, and that didn’t follow the pattern to what we would expect. So I didn’t know if that was causing the loss or not and that would be referred over.

So I don’t think I’ve thought about it that deeply then. Everything was on face value. You know, we took what was in front of us and, if we thought something didn’t look right, we would pass it over to HSH.

Ms Price: You talk in your statement, and you’ve mentioned it again just now, of the message from the business being that there were no issues with Horizon, even during the start of the Group Litigation. Can you help the Chair with who this message was coming from?

Andrew Wise: A lot of the time from our Head of Security at the time but, even going wider than that, while the Group Litigation was going on I remember there was quite a large meeting in Chesterfield with some very senior managers, I think one was Julie Thomas, possibly Angela van den Bogerd, and they were assuring us that they expected that they would win on most of the counts at the Group Litigation, and this is at the start of the litigation.

Within the Security team, I think July 2013, when the Second Sight report was published, that’s kind of one of the trigger points from when prosecutions were – we’ll say frozen and, even then, the information coming out of Cartwright King, the legal team, the Head of Security, was we need to get a new subject matter expert. Once we get the new subject matter expert, we will carry on business as usual prosecuting, because that’s the stance they took, “We can still prosecute, there’s no issues with it, we just need to get that new subject matter expert”.

And year after year, meeting after meeting, that subject matter expert never materialised but the message was still the same. All the team meetings, all the meetings with the whole Security team, it was always that message: that we need the subject matter expert and we’ll start prosecuting again. Until that point, the cases were stacked and classed as inactive. I don’t know for a good period of time.

Ms Price: Thank you, Mr Wise. Those are my questions. Sir, do you have any questions for Mr Wise before I turn to CPs?

Sir Wyn Williams: No, thank you, Ms Price.

Ms Price: There may be some questions from Core Participants represented by Hudgells, Howe+Co and HJA? No?

Ms Page? If I can come to you first.

Questioned by Ms Page

Ms Page: Mr Wise, I act for a number of the subpostmasters including Mr Castleton, who sits to my right. When you gave evidence in the trial, Mr Castleton asked you some questions; do you remember that?

Andrew Wise: I have some recollection and I’ve refreshed my memory through the transcripts from the trial.

Ms Page: Well, it may be, then, that we don’t need to go to the transcripts, if you can remember that Mr Castleton asked you whether it was possible to perform transactions on Horizon without first logging in?

Andrew Wise: That’s correct, yeah.

Ms Page: Do you remember that?

Andrew Wise: Yeah.

Ms Page: You confirmed for him that that was not possible?

Andrew Wise: Correct, yes.

Ms Page: That’s obviously still correct, yes?

Andrew Wise: To my belief, yeah. You can’t process a transaction if you’re not logged on or if the system isn’t logged in, yeah.

Ms Page: Can you help with this: if the system had crashed or there had been a screen freeze, which meant that you had to reboot, would you then have to log in again before you could perform any transactions?

Andrew Wise: Yes.

Ms Page: Thank you.

Then turning to another subject and the last one I’ll ask you about, we looked at that cash account issue that you successfully transferred to the Horizon Helpdesk. A little earlier Counsel to the Inquiry put it on the screen for you. You’ll probably be able to take it from me, I hope – I can certainly show you if necessary – that that took place, that call took place on 13 January 2004. What we also saw earlier – and again we can go to it if necessary – is that, when you dealt with Mr Castleton’s call in the March, you and your colleague who had originally dealt with him, Ms Pennington, saw his cash accounts, and they went back to a few weeks earlier, yes?

Andrew Wise: Yes.

Ms Page: Indeed, that first one that it went back to was – or at least the first time he had a problem with a discrepancy, was on 14 January 2004, so in other words within a day of the cash account problem that you referred to the Helpdesk?

Andrew Wise: Yes.

Ms Page: Presumably there was no way for you at the NBSC to put those two things together?

Andrew Wise: No.

Ms Page: So, barring somebody having a miraculous memory, “Oh, I remember that same day I took another call with a cash account discrepancy involving cheques”, those two calls would never be joined up?

Andrew Wise: No, and if I explain, at NBSC, particularly on a Wednesday afternoon into Thursday morning, it was call, after call, after call relating to balancing issues, some with discrepancies, some with issues where they couldn’t achieve a balance because they’d not followed process. So even a day apart, that could be 50 calls apart. So I could try and look at linked calls to Mr Castleton’s branch and see if I can look through to see previous calls, but it would give me everything that Mr Castleton had raised, so I might look through that and try and see if I could see any others. But I certainly couldn’t cross-reference that to another branch.

There’d be no way, unless I – like you said, I thought, “Well, this is very similar to one I dealt with the previous day. But I would say that didn’t happen and was quite unlikely to happen.

Ms Page: Yes, I see. So the fact that in that call that was transferred to the Helpdesk, the fact that there seems to have been an update that came out in the November before that was causing the bug, that’s not something that would have fed back or been shared around other branches experiencing similar problems, is it?

Andrew Wise: Not that I’m aware of, no.

Ms Page: No. Thank you. Those are my questions. Thank you, sir.

Sir Wyn Williams: Thank you, Ms Page. Anyone else?

Ms Price: I think there’s a question or two from Mr Jacobs.

Questioned by Mr Jacobs

Mr Jacobs: Thank you, I have couple of questions for you. I ought to say that I act for 156 subpostmasters in this Inquiry.

Ms Price asked you about paragraph 87 of your statement where you spoke about the message from the business and you say that the position of the business, the message from the business was always that there were no issues with Horizon, and then you go on to say that, even at the start of the Group Litigation, and you mentioned Angela van den Bogerd and I think Julia Thomas reinforcing that.

In relation to “always”, when did you first hear the message from the business that you speak of?

Andrew Wise: I would say from joining security in 2011, because that was the point at which I become aware of the group of subpostmasters that were claiming Horizon had lost their money. So in 2011, I became aware of that but with that was the messages to say, you know, there’s not an issue here, and we were even given instructions from Cartwright King on, if a postmaster raises an issue to do with Horizon, you cover off by asking – I think it were asking what training they’d receive, specifics on the issue. So it were all geared around disproving, if that makes sense.

So those are the types of messages I’m referring to. It’s not an email that says “There is no issues”. It’s more minute than that. It’s lots of things coming through. It’s reading between the lines even, sometimes, that they don’t directly say “There’s no issues with Horizon”, it’s “Right, this is what we’ve got to do to, you know, proceed to prove this”.

So it’s not one message, it’s lots of messages coming from different people within the business, different people within the Security team.

Mr Jacobs: Well, I understand that as a Security Manager you were conducting investigations from 2011 to 2015; is that right?

Andrew Wise: When Second Sight landed in July 2013, investigations still continued but none really progressed to prosecution. So it’s always slightly confusing on the timeline on what happened when but, for me personally, I was an investigator when I started in Security in 2011 after my training until I joined the Intelligence team in 2015.

Mr Jacobs: The point of my question is that you were specifically instructed to be dismissive of subpostmasters’ allegations about the Horizon System in the conduct of your investigations because of the message from the business; is that right?

Andrew Wise: I wouldn’t –

Mr Jacobs: It must be right, surely?

Andrew Wise: I wouldn’t say dismissive. I would say they tried to give us tools to get round those messages from postmasters. So to be able to challenge them. So we were told “You must do this, this and this if a postmaster says there’s an issue with Horizon”, and then that – so, as an investigator, ultimately we are the fact finder.

We pull all the information together. That goes to the Criminal Law Team who ultimately make that decision. So we present the facts as we know it and they make that decision. So I don’t think we were told to be dismissive. I think we were told to be guarded, you know, and cautious when postmasters were raising these issues, but the – as I said, the instruction was to cover off various aspects within the interview, if a postmaster does raise that.

Mr Jacobs: But we know now, don’t we, that the message from the business was untrue, so this message tainted your investigations, didn’t it?

Andrew Wise: It certainly did and, from my point of view, that does cut quite deep because, you know, had the business had been honest and open with what was going on with Horizon, then it could be said that we could address that in the courts appropriately but, as an investigator, we didn’t get opportunity to be able to do that because of the messages that were coming down.

Mr Jacobs: Now, one of the answers that you gave to Ms Price a few moments ago when you were asked who delivered this message from the business, you said, “Our Head of Security at the time”. Now, one of my clients, Mr Kelly, is here today, and he’s very interested to know what individuals were responsible. Can you tell the Inquiry who was your Head of Security in 2011, please?

Andrew Wise: When I joined in 2011, John Scott was Head of Security. Underneath John Scott, who was Head of Security Operations, which was the strand Investigation sits under, it were a gentleman called Dave Pardoe and then, underneath Dave Pardoe, there were the three operational team leaders. They changed so frequently I’m not sure who was team leader when.

I think John Scott left the business in around 2016 and the Security team was broken up and fragmented so Financial Crime went under one directorate, Physical Security went under with the Property teams, and Security Operations fell under the Network team. And the Head of Security from then on was a gentleman called Mark Raymond, who’s the current Head of Security Operations.

Mr Jacobs: Thank you. That’s helpful. You also say that this message was disseminated in team meetings –

Andrew Wise: Yeah.

Mr Jacobs: – and it would appear more than one team meeting. Do you have any written records, memos or agendas of those meetings that the Inquiry could see?

Andrew Wise: Between 2011 and 2013, at least once, possibly twice a year, we had meetings with Cartwright King, who were the Criminal Law Team, to all intents and purposes, and they produced workbooks and, you know, before the meeting, you’d have your handouts and your workbooks. So there is workbooks that have been produced from those meetings with Cartwright King.

I’m not entirely sure – so we’d have those meetings would be purely for the investigators. At least once a year we’d have a big team meeting with the whole of John Scott’s Security team so that were probably 50-odd people. I’m not sure if there’s any agendas, you know, from those type of meetings and then we had our individual team meetings so there were the North team, South team, Midlands team, so we would have a North team meeting with our own team leader and I don’t know if any agendas from that would be available.

But certainly from the meetings with Cartwright King, which were generally held at their offices in Birmingham, they would produce a work booklet for everything that is covered off.

Mr Jacobs: These meetings where the message from the business came out, how many people attended those meetings?

Andrew Wise: Again, the small team meeting would be – so in the North team, probably seven investigators and the team leader. If it was across the whole security operations with Cartwright King, three teams of seven, so 21 people. If it’s a big security meeting and all John Scott’s area, there would be 50 people plus at those meetings.

Mr Jacobs: Okay, well, thank you. I’m just going to ask if there’s anything else I need to ask you.

I don’t have any questions for you. Thank you very much.

Questioned by Sir Wyn Williams

Sir Wyn Williams: Mr Wise, just one more from me, please. By the time you became part of the Security team, I think your evidence is that you then knew that there was a group of subpostmasters who were suggesting that the losses weren’t caused by anything they had done or their staff but was actually caused by Horizon?

Andrew Wise: Yes, that’s correct, yes.

Sir Wyn Williams: I take it from your evidence that, from time to time between 2011 and 2015, you were part of what I will call the interview team, either perhaps as lead investigator or second investigator, who interviewed some postmasters under caution?

Andrew Wise: Correct.

Sir Wyn Williams: Right. First of all, have you got any kind of memory as to the approximate number of interviews under caution you conducted? I don’t want you to be precise but just some kind of feel for it.

Andrew Wise: So my time from 2011 to 2013 – and I use ‘13 because that’s the point at which the prosecutions stopped – I believe I had five cases that led to prosecution. There was probably five or six more that didn’t. So possibly ten cases where I was lead investigator.

Sir Wyn Williams: First of all, in any of those cases, so far as you can remember, did the person who you were interviewing raise as a potential explanation for an apparent loss a defect in Horizon?

Andrew Wise: I can remember one particular case and it wasn’t one that was prosecuted. It didn’t go any further for various reasons but she had issues with the communication of her Horizon system. I don’t think in her area they had ASDL, which was the broadband line. So the branch was run on what we call VSAT, which were a satellite link to the network, and that made communication quite slow, particularly for banking transactions.

So if a customer came in to do a withdrawal out of their card account, it would be a few seconds of the egg timer going round looking at the screen while the Horizon System communicated with the banking engine and back to authorise the withdrawal.

So that particular person, you know, raised that and believed that that was potentially a cause of her losses. I went to the branch and spoke to the staff and I actually witnessed what was happening, which was communication, you know, and a delay in the banking transactions and, although I don’t think it was a bug that caused the losses, there was potential that could cause a small loss if, for example, a customer was withdrawing £200 and the clerk paid out the £200 but, because of the delay in communication, albeit only seconds, if the banking engine does not approve the transaction, it could be declined and the clerk’s paid out money.

So my thoughts were that there were potential that mistakes could be made because of the delay but I didn’t believe that it – the delay in communications would cause the losses that were at the branch. But that’s the only case that comes to mind where they raised issues with Horizon.

Sir Wyn Williams: All right. Thank you for that.

My last question or last follow-up question, then, is this: what instructions were you given, if any, from your superiors in the Security team about how, if at all, you should investigate further if a person in interview under caution raised what I’ll call a software issue about Horizon? What did they tell you to do if that happened?

Andrew Wise: We were told to ask specific questions around the issue. We were told to gather further information, as I said, around what training they’d received. I think there were three points to cover, I can’t quite remember them all.

Part of the process, what we could do is to ask Fujitsu, as part of the ARQ requests, whether they – there’s any issues at that branch over that time period and, when the data comes back, we would ask them to support that with a witness statement, which they would say whether there were any issues at the branch or not.

Sir Wyn Williams: Was that instruction, if that’s the correct word, as to what you should do in written form or was that just discussed with your superiors, or what?

Andrew Wise: I think the instructions around the questions to cover off were quite probably in written form, and issued as an instruction, either in email context or in an actual document, you know, as part of the process.

Sir Wyn Williams: All right. Well, thank you very much for your help, Mr Wise. I’m very grateful to you. Thank you for making your witness statement and thank you for answering a good many questions today.

Ms Price: Sir, I believe there is, in fact, one question on behalf of – well, Mr Moloney has one question, I think.

Sir Wyn Williams: All right, sorry. I was jumping the gun.

Mr Moloney: Not at all, sir. I don’t know if you can – yes, my microphone is on now. It arises from your questions, sir, and it may be that it will assist Mr Wise with his recollection in respect of questions you asked, sir.

Sir Wyn Williams: Certainly.

Questioned by Mr Moloney

Mr Moloney: Thank you, sir.

Do you remember your involvement in the investigation of Elena Herd?

Andrew Wise: Yes, I do.

Mr Moloney: She worked as an assistant at Stockport Crown Office –

Andrew Wise: Yes.

Mr Moloney: – and her conviction was in 2011?

Andrew Wise: Yes.

Mr Moloney: You started in Security in 2011 and you eventually interviewed her on 7 July 2011?

Andrew Wise: Yes.

Mr Moloney: She pleaded guilty to one count of fraud by abuse of position on 5 October 2011?

Andrew Wise: Yes.

Mr Moloney: Then she was sentenced on 11 November to four months imprisonment, suspended for two years, with a requirement to carry out 200 hours of unpaid work?

Andrew Wise: Yes.

Mr Moloney: Her conviction was quashed following a hearing on 27 October 2022 when Post Office formally conceded the appeal and accepted that the reliability of Horizon data was and is essential to her prosecution and conviction?

Andrew Wise: I understand that’s the case. I wasn’t aware until recently but, yeah, I do understand that.

Mr Moloney: Now, the reasons for not opposing the appeal were that, although Ms Herd admitted in interview to falsifying records relating to postage labels – do you remember she said that?

Andrew Wise: Yeah.

Mr Moloney: She had explained at the time that she was only doing it to conceal unexplained shortfalls?

Andrew Wise: Correct, yes.

Mr Moloney: So that pointed to an Horizon issue, didn’t it, of unexplained shortfalls?

Andrew Wise: Not necessarily, no.

Mr Moloney: Could it possibly have pointed to a Horizon issue of unexplained shortfalls?

Andrew Wise: Potentially. I don’t believe it did, but potentially, yes.

Mr Moloney: Yes, well, she was raising unexplained shortfalls?

Andrew Wise: Yeah, she also, in interview admitted to giving customers £200 too much. She admitted to having £1,000 loss because of a mistake she made and, when we went through the interview and worked backwards, we proved at every step that she wasn’t entirely truthful with us. So I didn’t believe that what she was saying was truthful. She was a clerk of 10-years’ experience, who had already approached the line manager because of a loss, so I think it was not reasonable – or it was reasonable to assume that she would have approached the line manager for unexplained losses, instead of covering them up and committing fraud to cover them up.

Mr Moloney: Well, again, she – what Post Office said was that there was no independent evidence of actual shortfalls in the accounts and it seems that there was no investigation of how such losses occurred?

Andrew Wise: I think what you’ve said is the point. There’s no evidence of losses in the account because she was covering them up. She wasn’t declaring losses, so if there’s no loss there to look at, it’s difficult to pinpoint what’s happened and I think one of the questions that was put to her, because she did it in various stock units and one of them were the Bureau de Change stock unit, which was a stock unit shared by a lot of team members, it’s not specific only to her, and when asked why you would do it in that stock unit I think her reply was “Well, I think I were balancing it, so I think there might have been a loss in there”.

So just from my experience of many years working in the Crown and working with Crown staff, for me, it didn’t stand up to what I thought a reasonable clerk – and she had proven herself to be that by raising issues in the past with her line manager, so I – my thoughts were that it wasn’t correct what she’s – it weren’t true what she was saying.

Mr Moloney: Yeah, and you made that very clear to her, you and Mr Bradshaw, didn’t you?

Andrew Wise: Yes.

Mr Moloney: She was raising issues about unexplained shortfalls because she was inflating the value of postage labels as she maintained all the way through to cover shortfalls that she couldn’t explain and she made that clear in the interview, didn’t she?

Andrew Wise: She did. She made it clear that the shortfalls had been snowballing for the last few weeks. So we worked backwards for the last few weeks. In fact, we worked backwards for seven months, so it just undermined everything she was saying. You know, we used the data, we used the reports from the branch to work backwards.

Mr Moloney: You used Credence?

Andrew Wise: Yes.

Mr Moloney: Didn’t get any ARQ?

Andrew Wise: No.

Mr Moloney: You used Credence and you, essentially, worked on the basis that she was guilty. I’ll take you to, if I may, just what you said to Ms Herd during the course of interview. This is you and Mr Bradshaw and the document is POL00011147, please. If we could go to page 8 of this document.

So when Elena Herd has been saying that she’d been inflating the value of postage labels to cover up shortfalls that had been occurring, Mr Bradshaw said to her:

“You see I think you’re just lying to us Elena I think you’re just, whatever you’re saying you’re just saying anything that comes into your mind and you’re not answering the questions and you think that just by giving us any little old answer we’ll just say fine. Unfortunately what Andrew’s shown you needs an explanation and you know just to remind you of the caution you know if the matter does go to a Court and you give a different explanation they’re going to wonder why you didn’t tell us the truth at the beginning. So would you like to tell us the truth now why you rejected these labels and used them [and that’s exactly what she’s saying] ‘cos I don’t believe for one minute and I’m certain Andrew doesn’t believe for one minute that you were having a daily loss of £60 so you just thought, well I’ll reject a few labels and leave the money. I don’t believe that, Andrew doesn’t believe that so would you like to tell us the truth now?”

She said, “That’s the truth.”

Then, so far as that is concerned, Mr Wise, do you think that was – you’ve spoken about things being “harsh” in earlier days, do you think that might have been harsh in any way?

Andrew Wise: An interview under caution isn’t a pleasant experience and we have to ask difficult questions and the answers Elena were giving didn’t make any sense. We were proving her wrong, we were undermining what explanation she were giving, so I believe there Steve was pushing for that explanation.

She maintained throughout that that was the truth and what she was doing, just to explain, because I think you’ve described it a little bit wrong there, she were rejecting postage labels, so when a customer comes into post a Special Delivery letter and you put the label on the item it comes up and says “Did the label print correctly”, and she said “No”, so that rejects the label but she’s got a genuine label to do that and then she were inflating – she was telling the system that she were paying with postage stamps that she were sticking stamps on and then reversing that out at the end of the day. So –

Mr Moloney: And always to cover up shortfalls. Were you dismissive of her there because you said, you weren’t to be dismissive when but simply to work around what the training was, and so on. Were you dismissive of her there, Mr Wise, in any way?

Andrew Wise: I don’t think so because we’d looked at what her discrepancies were. We’d looked whether she were having losses and there were no losses to be seen. In the Crown Offices they have a procedure called the losses and gains policy to manage staff and allow them, you know, to balance and that’s quite a lengthy procedure.

You have to have a lot of losses to kick that procedure off. So there was no reason that Elena wouldn’t raise that with her manager, you know. She didn’t have to put the money in like subpostmasters did. Subpostmasters were forced to make good the loss but Elena worked in a Crown branch and she didn’t have to do that. So it was quite reasonable to expect her to have approached the manager, as she had proven she did in the past with a £1,000 loss.

So I wouldn’t say dismissive; I would say we pushed her on it and we didn’t – we wasn’t convinced by her explanation. We’d looked at the history of losses and they just weren’t there.

Mr Moloney: Of course, that was based on going to her manager but it goes on, if we go on two pages, please, to page 10 of this and we see there you talking about the Bureau, which you’ve already told us about, and Ms Herd said, “No, that has got nothing to do with Bureau”.

Then your comment, second comment down:

“But you’re recollecting labels in the Bureau stock unit. If your loss was in EE why are you rejecting labels in the Bureau stock unit? You see what’s happening here Elena you’re telling us one thing and we’re going back and disproving that so in effect you’re lying to us, you’re telling us one story we’re moving on disproving that and you’re lying again and again. All this is doing is picking holes in your little story that you’re telling us. Did you take the money out of Bureau de Change stock … for these rejected labels?


“Why are you rejecting labels in the Bureau de Change stock unit if your loss is in EE?

“‘Cos Bureau had a loss. Bureau always has a loss I was supposed to balance it that week probably.”

Now, you were raising shortfalls. You didn’t do any ARQ checks, you just relied on her admissions to inflating the labels and you called her a liar during the course of this interview, dismissing her shortfalls explanation, didn’t you, Mr Wise?

Andrew Wise: We explored the shortfalls explanation but we didn’t believe that.

Mr Moloney: No, because she didn’t go to her manager to tell you about it but you didn’t do any ARQ investigations and you did no investigations beyond what you put to her in interview?

Andrew Wise: We didn’t do ARQ, correct, but we did do investigations beyond what was in the interview.

Mr Moloney: To do with Horizon data?

Andrew Wise: We looked at the Credence data –

Mr Moloney: Credence data?

Andrew Wise: – we looked at the transactions that were put through but, if you can’t identify a loss, there’s nothing to – you can’t identify something that’s not there, if there’s no loss there, you can’t look at that and the circumstances around that loss because what she was saying is she was hiding and covering up the losses. So unless she declares a loss and then later makes it good, there would be no footprint in the data, whether it’s Credence data or whether that’s ARQ data.

Mr Moloney: But you rejected Ms Herd’s explanation without going into the further data that was possible and available to you, didn’t you?

Andrew Wise: Yeah, we didn’t proceed to get ARQ data.

Mr Moloney: No, and that encapsulated the approach of your investigation team in this case, didn’t it?

Andrew Wise: No, not necessarily, because we’d done a lot of investigation work before we got to the point of interview. You know, we’d not got the ARQ data but we didn’t deem that necessary because we had the Credence data and we had the supporting reports from the branch going back to the previous December.

Mr Moloney: It was essentially that it had to be the fault of the suspect, barring an obvious explanation or error, wasn’t it?

Andrew Wise: Sorry, just explain –

Mr Moloney: What had happened must be the fault of the suspect, barring an obvious explanation or error?

Andrew Wise: The suspect committed fraud. Whether that were to cover up a loss, now I – there could well have been a loss there, I don’t think it’s a loss that would be generated by Horizon. She’d admitted to making mistakes. So, even if she is making mistakes by giving a pensioner £200 too much, by processing an investment account deposit by £1,000 too much, you know, whatever the mistake is, if it is a mistake, then she’s committed a criminal offence to cover that up.

So my view was and still is, because I’ve not seen anything to disprove that, is that Horizon didn’t cause that loss. You know, we can get the data, we can look at that and go through the ARQ data. It’s still available, so, you know, we can find out from Fujitsu how bugs manifest in the data because they’ve still not told people like me, people who are currently working on Tier 2 investigations within the Branch Support Centre, they’ve not been told how the bugs were manifesting in the data.

But that’s – you know, we’re looking at case studies into branches, let’s get that data and find out from Fujitsu how the bugs would look, you know.

Mr Moloney: So, even without looking at the data, you’re convinced that this couldn’t be a Horizon case?

Andrew Wise: My opinion is, knowing what I know, not, but I’m open to look at that now at this point in time, and I know we didn’t do it then but, at this point in time, we can look at that data now and see. You know, and that’s the same for any case that’s 2007 onwards, ARQ data is still available. We can still request that and we can still look at data.

Mr Moloney: A bit late now for Ms Herd who was convicted and sentenced to a suspended sentence of imprisonment though, Mr Wise?

Andrew Wise: It is late for the ARQ data, yeah, but my view still stands. I’ve not seen anything to change my view on that. But I’m welcome to, you know, have a look at it to see if my view will change with any of them, you know. I’m an analyst. I base it on the data, you know. I can look at that and give my opinion. But, you’re right, we didn’t get it in 2011. We just based it on the Credence data.

Mr Moloney: Right. Thank you, Mr Wise.

Sir Wyn Williams: That concludes the questioning, Ms Price?

Ms Price: Yes, sir, I understand so.

We are back tomorrow morning at 10.00 for Stephen Dilley.

Sir Wyn Williams: Yes, all right, then. 10.00 tomorrow morning.

(2.53 pm)

(The hearing adjourned until 10.00 am the following day)