Official hearing page

26 September 2024 – Calum Greenhow

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(10.00 am)

Ms Hodge: Good morning, sir, can you see and hear me?

Sir Wyn Williams: (Microphone muted)

Ms Hodge: You appear to be muted, sir. Currently we can’t hear you.

We are just making some enquiries to see why it is that we can’t hear you, sir.

Sir, would you be able to speak so we can check whether we can hear you now? Sir, we’re going to take a short break so we can establish the issue with your connection.

(10.02 am)

(A short break)

(10.12 am)

Ms Hodge: Hello again, sir. Can you see and hear me?

Sir Wyn Williams: I can.

Ms Hodge: Good. I’m pleased to say we can see and hear you again now.

Sir Wyn Williams: Good, thank you very much. Sorry to everyone for the delay.

Ms Hodge: Our witness today is Calum Greenhow. Please can the witness be sworn.

Calum Greenhow

CALUM BRIAN GREENHOW (sworn).

Questioned by Ms Hodge

Ms Hodge: Please give your full name.

Calum Greenhow: Calum Brian Greenhow.

Ms Hodge: You should have in front of you a copy of your witness statement dated 4 September 2024?

Calum Greenhow: I do.

Ms Hodge: That statement runs to 133 pages; is that correct?

Calum Greenhow: Yes.

Ms Hodge: Can I please ask you to turn to page 124 of your statement?

Calum Greenhow: Yes.

Ms Hodge: Do you see your signature there before you –

Calum Greenhow: I do.

Ms Hodge: Is the content of that statement true to the best of your knowledge and belief?

Calum Greenhow: It is.

Ms Hodge: Mr Greenhow, my name is Ms Hodge and I’ll be asking questions on behalf of the Inquiry. Before I do so, I believe there’s a statement you would like to make; is that correct?

Calum Greenhow: If I can. Something rather odd happened yesterday. When my Inquiry counsel and I were heading to an accommodation last night, we came out of Holborn tube station and I literally had to step out of the way of Lord Justice Fraser. And the reason that I mention that is I think it is important that I thank not only the Inquiry but also Lord Justice Fraser for the work that you’ve all done because, without your work, we would not know what we know today.

I approach the Inquiry as a postmaster who has served behind the counter and used Horizon since 1999 and still do today. I wanted to know the truth, the whole truth and nothing but the truth, even if that meant some uncomfortable truths were discovered about the organisation that I lead today.

I’d like to thank those who you were involved, such as Sir Alan Bates, Jo Hamilton, Lord Arbuthnot, et cetera, because it’s their tenacity, their dignity, their courage and their determination that we’re here today. I’d like to offer them all my apologies as the Chief Executive of the NFSP and ask for their forgiveness for the part that the NFSP has played in what they’ve experienced and what they’ve had to endure over that period of time, and I hope that they will accept my apologies in the manner that it is intended. Thank you.

Ms Hodge: Thank you, Mr Greenhow. You are currently employed as the Chief Executive Officer of the National Federation of SubPostmasters; is that correct?

Calum Greenhow: I am.

Ms Hodge: Before we examine the circumstances of your appointment as CEO, I’d like to ask you some brief questions about your background, please. You say that in August 1995 you and your wife purchased the Post Office branch in West Linton, a village located in the Scottish Borders; is that right?

Calum Greenhow: We did.

Ms Hodge: You were appointed the SPM of that branch, which you ran with your wife until your appointment as CEO; is that correct?

Calum Greenhow: Yes.

Ms Hodge: In 2001 you became a member of the NFSP, which at that time was registered as a trade union; is that right?

Calum Greenhow: Yes.

Ms Hodge: You’ve explained in your statement that the NFSP is currently divided into 53 separate branches and ten separate regions; is that correct?

Calum Greenhow: Yes.

Ms Hodge: Does that representation extend to the whole of the United Kingdom, including Northern Ireland?

Calum Greenhow: Yes, it does.

Ms Hodge: Has the number of local branches and regions remained consistent throughout the time covered by this Inquiry?

Calum Greenhow: I don’t think it has but I cannot confirm that. I am giving it from its current basis.

Ms Hodge: Before you were appointed the CEO of the NFSP, you held various different roles within the organisation; is that correct?

Calum Greenhow: Yes.

Ms Hodge: In 2010, you were elected the President of the South of Scotland branch; is that right?

Calum Greenhow: I was.

Ms Hodge: Do you recall how many branches of the NFSP there were in Scotland at that time, roughly?

Calum Greenhow: Seven?

Ms Hodge: Do you know how many Post Office branches were located within the South of Scotland at that time?

Calum Greenhow: I can’t remember offhand. It would be 100/150, I think.

Ms Hodge: What did your role as President of the South of Scotland branch entail?

Calum Greenhow: In essence, I was Chair of the region – of the branch, so if we had our branch meeting it would have been my responsibility to chair the meeting and support the branch secretary but it was the branch secretary who really did most of the work. That would also involve attending regional meetings, and then conference. I attended the NFSP’s annual conference for the first time in 2010.

Ms Hodge: In 2012 you were elected the branch secretary of the South of Scotland branch; is that right?

Calum Greenhow: I was.

Ms Hodge: Please can you describe the role performed by the secretary of the local branch?

Calum Greenhow: In essence, it was to be there as the contact point for members, to distribute information, if any postmaster had a problem or an issue I would be the first port of call. If there was an interview with the Post Office, I may go along to that or it may have been left to others.

Ms Hodge: In 2013 you were elected as the representative for Scotland on the NFSP’s Standing Orders Committee; is that correct?

Calum Greenhow: Yes.

Ms Hodge: In your statement, you say that the committee was responsible for dealing with the motions from branches which would go to the annual conference. Can you please explain what a motion is?

Calum Greenhow: So a motion would be – well, conference, in essence, was a whole series of questions, thoughts, ideas, that were being brought to the attention of the wider NFSP membership, and a motion was an individual request that may go to – it would instruct the Executive Council to do something, and then what would happen is that would be debated at conference by all who attended conference. It would be debated prior to that at a regional meeting, for example, of members, and then a decision by the membership would be taken whether to adopt or not that particular motion.

Ms Hodge: You say that the motion was a request, from whom?

Calum Greenhow: From the members.

Ms Hodge: What function was performed by the Committee in relation to these motions?

Calum Greenhow: So, in essence, we were looking at whether there was motions that came in that had a similar vein to them or similar thought, and we might amalgamate those together; whether that motion had been asked within the last two years and had been rejected, so it would have to carry over for another year. In essence, that was really it.

Ms Hodge: So the Committee was responsible for either permitting motions to go to conference or rejecting them; is that correct?

Calum Greenhow: One of. I was – ultimately the decision was of the Executive Council, I believe but, certainly, we would meet in the March of the calendar year to actually go through those motions and, normally, the President of the NFSP, along with the General Secretary of the NFSP would be present and others, and they would be discussed, and then we would try and put them into themes, et cetera. But, yes, in essence, we were a form of the ability to enable those motions to be brought to conference.

Ms Hodge: But also to filter them; would that be fair?

Calum Greenhow: Yes.

Ms Hodge: In 2016 you were elected to the Board of the NFSP as the Scotland Regional Non-Executive Director; is that correct?

Calum Greenhow: Yes.

Ms Hodge: By that stage, the organisation was no longer registered as a trade union –

Calum Greenhow: Yes.

Ms Hodge: – having, in September 2015, established itself as a private limited company; is that right?

Calum Greenhow: Yes.

Ms Hodge: I’d like to ask you some questions about your decision to seek appointment as the CEO of the NFSP. In your statement, you say that you wished to make the organisation more inclusive and representative of its members; is that correct?

Calum Greenhow: I think that was in relation to me being the Chief Executive.

Ms Hodge: Yes. Forgive me, this is – sorry.

Calum Greenhow: Yes.

Ms Hodge: I’m asking you now about your appointment as Chief Executive?

Calum Greenhow: Oh, sorry, I thought you were talking about the Board. Sorry. Apologies.

Ms Hodge: So, concerning your motivation for seeking appointment as the Chief Executive, one of the points you raise in your statement is that you wished to make the organisation more inclusive –

Calum Greenhow: Yes.

Ms Hodge: – and representative of its members; is that correct?

Calum Greenhow: Yes.

Ms Hodge: You also describe in your statement that you considered your predecessor’s approach to leadership was autocratic; is that correct?

Calum Greenhow: Yes.

Ms Hodge: Can you please explain why you characterised Mr Thomson’s leadership in that way?

Calum Greenhow: Well, I think if anybody who’s been to the Inquiry may have seen just exactly how George acts. If you didn’t agree with him, he would let you know, and he was very much about pushing forward his view, his thoughts, his ideas. I felt that, as an ordinary member and even as a Board member, there was a toxicity within the membership of the NFSP towards him, there was a lot of negative feeling against him, and I think a lot of things that were going on – that people didn’t know what was going on, there wasn’t much communication, and therefore I felt that that was not the right way.

I’m a completely different person. I’m not an exclusive person; I’m an inclusive person and I’ve got nothing to hide in any way, shape or form, so I really want to get out there, engage with my fellow postmaster members, seek their views. You know, their experiences is vast, their knowledge is vast and it’s important to listen to different ideas. It doesn’t necessarily mean to say that, just because someone puts forward a view, that that would be the view that’s taken forward. But it’s important to listen to what people have to say, take it on board, and then make a decision and that’s not what I saw with George.

Ms Hodge: According to your statement, when you were first appointed a member of the board in mid-June 2016, you challenged the stance being taken by the Board and the then CEO, in relation to the integrity of Horizon; is that correct?

Calum Greenhow: Yes, it is.

Ms Hodge: You state that you recall telling the Board at a meeting in mid-June 2016 that Horizon could not be correct 100 per cent of the time; is that right?

Calum Greenhow: Yes.

Ms Hodge: You also stated, you say, that even if there were no systemic issues with the system, there might still be local faults; is that correct?

Calum Greenhow: Absolutely.

Ms Hodge: The Inquiry has been shown the minutes of the meeting to which you refer in your statement. For reference they can be found at NFSP00000500. I think you accept, do you not, that your comments are not recorded in those minutes; is that correct?

Calum Greenhow: Yes.

Ms Hodge: Why is it, do you think, that your comments about the integrity of Horizon were not recorded in the minutes of the meeting?

Calum Greenhow: I don’t think there was any particular reason for it. I think what was recorded was what Peter Montgomery was saying and we were coming at the same sort of issue from a slightly different angle. But so I think Peter’s comments were maybe more valid or more a summation of the debate and the conversation that was going on, so that was all recorded. I don’t think there was any specific reason why my comments were not recorded.

Ms Hodge: There is a reference in the minutes of the meeting to the principle of collective cabinet responsibility. Please can we display the minutes to see that reference in its context. It’s the bottom of page 22 on to page 23, please.

Thank you we see at the first bullet point your colleague Peter Montgomery, who you reference raising the issue of the Group Litigation, and if we go down to the bottom, please, the final bullet point reads:

“The NFSP’s policy has always been that it is a robust system and we have fully confidence in it.”

That being the Horizon system.

If we could scroll down, please:

“Do not believe the system is systematically faulty.

“Most people that blame Horizon for losses are overinflating their cash declarations, false accounting.

“Subpostmasters take money sometimes and members of staff also take money.

“Reminded that members of the Council should adhere to collective cabinet responsibility.”

Did you feel compelled by your membership of the NFSP Board to toe the party line on the integrity of Horizon?

Calum Greenhow: No.

Ms Hodge: You say in your statement that the purpose of raising questions about Horizon’s integrity in the first Board meeting was to try to build some momentum that would be capable of challenging the stance adopted by your predecessor; is that correct?

Calum Greenhow: Yes.

Ms Hodge: What further steps did you take, either at Board level or within the wider NFSP organisation, to build that momentum to challenge his stance on Horizon?

Calum Greenhow: Difficult to remember everything that took place so long ago but, in essence, obviously you can see from Peter’s view, we would regularly go for walks, we would have discussions, I would talk to other individuals, with members within the Federation, other postmasters who had a different view. I felt that it was important to understand the Board, see where the Board were sitting, see, you know, many of them I didn’t necessarily know personally at that point. Get to know them, get to sort of understand them and get to see where they went. And whenever any opportunities arose to actually maybe have different view, I would take that forward.

Ms Hodge: Now, we know that your appointment to the Board took effect in or around June 2016; is that correct?

Calum Greenhow: Yes.

Ms Hodge: Between that time and your appointment as CEO, did you ever raise the issue of Horizon’s integrity again with the Board?

Calum Greenhow: Sorry, say that again?

Ms Hodge: So between your appointment to the Board as a Non-Executive Director –

Calum Greenhow: Oh, sorry.

Ms Hodge: – in June 2016 and your appointment as CEO of the NFSP in 2018, did you ever raise the issue of Horizon’s integrity again at the Board, so far as you recall?

Calum Greenhow: I don’t think I did. Certainly, from what I can see from the minutes and emails, I don’t think it actually came up.

Ms Hodge: I’d like to go back in time, please, to examine when you first became aware of concerns about the integrity of Horizon, in your statement you first date your awareness of issues with Horizon’s integrity to the summer of 2015; is that correct?

Calum Greenhow: Yes.

Ms Hodge: By that stage, you’d held the role of branch secretary since 2012; is that right?

Calum Greenhow: Yes.

Ms Hodge: And you’d been appointed the elected representative for Scotland on the Standing Orders Committee?

Calum Greenhow: Yes.

Ms Hodge: You’ve explained in your statement and in your evidence this morning that, if members of the NFSP had concerns that they wished to raise, their first point of contact would be the branch secretary; is that right?

Calum Greenhow: Yes.

Ms Hodge: Or one of there first points of contact?

Calum Greenhow: Yes.

Ms Hodge: Does it follow that during the time in which you served as Branch Secretary for South of Scotland, that no member ever raised any concerns with you about the reliability of the Horizon system?

Calum Greenhow: Correct, and can I just add to that, actually, as someone who had used and was using Horizon, whilst there may have been issues in relation to it freezing, or problems as far as screen or a printer or a base unit not working, that would be what maybe people would have come to me about. But as far as ascribing losses to Horizon, to my knowledge, no one came to me about that.

Ms Hodge: Looking back, does it surprise you that the problems with Horizon were not brought to your attention in your capacity either as President or Branch Secretary of the South of Scotland branch?

Calum Greenhow: Not really, no.

Ms Hodge: Why is it, do you think, that these problems weren’t reported to you?

Calum Greenhow: I can’t answer that specifically. All I can say is, again, as someone who was using Horizon, I didn’t see Horizon as an issue. We were using it, it was functioning; clearly, for some people, it wasn’t. I can only go on my own personal experience of having used Horizon and, other than it freezing, a scanner not working, I’ve not had any personal experience of faults with the software that have caused – that I believe have caused losses in my own branch and, between 2012 and 2015, no one had raised that sort of issue with me, and as I was going to regional meetings it wasn’t really being raised much there.

What was being raised was more about Network Transformation and other sort of like issues.

Ms Hodge: We know from documents which have been disclosed by the NFSP that some local branches of the organisation were seeking to raise concerns about Horizon –

Calum Greenhow: Absolutely.

Ms Hodge: – in the motions which they submitted for consideration at the annual conference. Please can one of these documents be shown on the screen, it bears the reference NFSP00001037. Thank you. This document appears to contain a list of motions submitted by the Midlands region of the NFSP for consideration at the annual conference held in 2010; is that right?

Calum Greenhow: Yes.

Ms Hodge: The third motion in the list reads as follows:

“This conference mandates the EC …”

That’s a reference to the Executive Council, is it?

Calum Greenhow: Yes, the Executive Council, yes.

Ms Hodge: “… not to accept any changes to the Horizon system (either firmware or software) until fully validated as ‘fit for purpose’ by the Horizon steering group.”

Can you help us, who sat on the Horizon steering group?

Calum Greenhow: This was obviously well before my time. I attended a conference for the first time in 2010. I – as I said in my opening statement, I came in to try and find out, this was something that I found out but, as far as who that Horizon steering group is concerned, I’ve never been able to find out exactly what that was.

Ms Hodge: Please could be scroll down to the sixth motion, thank you, in the list. That reads:

“That this conference mandate the EC to demand that POL retain all historical Horizon data that relate to Horizon failures both firmware & software for a minimum of [12 months].”

Calum Greenhow: Mm.

Ms Hodge: From what you said just now, it appears to be that you were not aware of these motions at the time when they were submitted; is that correct?

Calum Greenhow: No, I – no.

Ms Hodge: You have said, however, that you attended the annual conference of the NFSP for the first time in that year of 2010; is that right?

Calum Greenhow: Yes, I did.

Ms Hodge: Does it follow that these motions were not debated at the annual conference which you attended?

Calum Greenhow: I’m sorry, I can’t answer that question, I don’t – I can’t remember.

Ms Hodge: Who would have been responsible for determining whether or not these particular motions were debated at the annual conference?

Calum Greenhow: I’d imagine – so the Standing Orders Committee and the Executive Council.

Ms Hodge: To be fair to you, you weren’t yet a member of the Standing Orders Committee –

Calum Greenhow: No.

Ms Hodge: – at that time?

Calum Greenhow: No.

Ms Hodge: You took over in 2012 – you joined in 2012?

Calum Greenhow: No, I joined in 2013.

Ms Hodge: Sorry, 2013.

Please could we look at another set of motions, they bear the reference NFSP00001044. Do you know from which region of the NFSP these orders were submitted?

Calum Greenhow: Off the top of my head, no, I don’t.

Ms Hodge: Are you able to tell us to which annual conference they related?

Calum Greenhow: No, I can’t.

Ms Hodge: Could we turn, please, to page 5 of this document. It’s motion number 43. Thank you. It reads:

“That this Conference instructs the Executive Council to negotiate with Post Office Limited that computer generated discrepancies are not the responsibility of the subpostmaster.”

Then it in brackets it reads:

“Subpostmasters not to be responsible for computer generated discrepancies on Horizon.”

Under the heading “Status”, it reads:

“Where evidence exists that the error is not as a result of human input then a claim will not be pursued.”

Who would have been responsible for reporting on the status of this motion?

Calum Greenhow: I would imagine the Executive Council.

Ms Hodge: This entry appears to accept the possibility that discrepancies were generated by Horizon, does it not?

Calum Greenhow: It certainly reads that way, yes.

Ms Hodge: When did this document first come to your attention?

Calum Greenhow: I think, as I – as we were preparing documents for this Inquiry.

Ms Hodge: You mention in your statement that you watched the BBC Panorama programme which was aired in August 2015; is that right?

Calum Greenhow: Yes.

Ms Hodge: In your statement, you say this about the programme:

“When I watched the Panorama programme and saw Hughie Thomas, Jo Hamilton and Seema Misra, I couldn’t see them as people who had stolen money.”

Is that right?

Calum Greenhow: Absolutely.

Ms Hodge: Does it follow that after watching the Panorama programme, you became concerned that the Post Office might have wrongly prosecuted subpostmasters in reliance on data generated by Horizon?

Calum Greenhow: Yes, and, obviously, I’ve provided evidence, or there has been evidence provided to the Inquiry, that shows that.

Ms Hodge: Shortly after watching the programme, you received and read a branch circular from George Thomson, then CEO of the NFSP; is that right?

Calum Greenhow: Yes.

Ms Hodge: Please can that document be shown on the screen. It bears the reference WITN00370126.

Thank you. So this is the “Branch Secretaries’ Circular”. Can you just briefly explain what the purpose of a circular like this is and was?

Calum Greenhow: Yes, so obviously this was before the mass usage of the Internet, as we have, or the various social media channels. So, at that time, providing information from Shoreham to the members came via the Branch Secretary, so we would receive these circulars and it was our duty and our responsibility to distribute that information to members within our particular branch or region.

Ms Hodge: You said that it came from Shoreham?

Calum Greenhow: Yes.

Ms Hodge: By that, you mean the central office of the National Federation of SubPostmasters?

Calum Greenhow: Yes, sorry, the NFSP headquarters in Shoreham, yes.

Ms Hodge: So this circular is dated 18 August 2015. It’s volume 24, addressed to the Branch Secretary, and it bears the heading “Post Office under the Spotlight”. Could we go scroll down to the third paragraph, which addresses the Panorama programme. It reads, the second sentence please:

“Last night’s Panorama BBC1 documentary sought to get underneath the bright shiny exterior of the Post Office and reveal a less palatable side of the business: the longstanding issue of prosecutions of subpostmasters and the alleged [systemic] failings of Horizon looks set to continue for some time yet.

“Over the past few years the NFSP has received thousands of telephone calls from subpostmasters. The majority relate to employment law, contract issues and Network Transformation. The remainder cover …”

ATMs, I assume that’s meant to say.

Calum Greenhow: Yes.

Ms Hodge: “… cash supply and just about every subject you care to mention, including a handful every month on Horizon connectivity and the problems of getting through to ATOS and the Helpdesk.

“Put simply, the NFSP has not received calls from subpostmasters querying Horizon and alleging [systemic] failings. If there was a widespread problem, our subpostmasters would have made us aware of it. As a result, we have no choice but to conclude that Horizon is a fundamentally sound and safe system.”

In your statement you explain that you did not agree with the message conveyed in this circular and that you decided to raise your concerns with the CEO; is that correct?

Calum Greenhow: I think he was General Secretary at that point but yes, yes.

Ms Hodge: You wrote an email to Mr Thomson on 19 August 2015, in which you invited him to consider the possibility that those who were challenging the integrity of Horizon might be correct?

Calum Greenhow: Yes.

Ms Hodge: You invited him to show his support for the SPMs whose cases were being reviewed by Second Sight; is that right?

Calum Greenhow: Yes.

Ms Hodge: For the benefit of the transcript, that email bears the reference POL00162628. I don’t propose to take you to that document, it’s already been shown in this Inquiry but I’m happy to do so if there’s any particular part of it you wish to draw to the Chair’s attention.

Calum Greenhow: I just think, you know, obviously – I mean, it was difficult, so I think as a branch secretary at that point, you know, I just considered myself an honorary postmaster. I just, you know, having watched the Panorama programme, it was really, in essence, me starting to get, to understand, “Hang on a second, maybe there’s something more to this”. Up to that point, you know, we occasionally heard of people being convicted, people admitting their guilt but we hadn’t really heard too much about the possibility that, actually, it could be Horizon, and this was, in essence, me starting to get to question that – you know, a little question mark going “Hang on, is there something more here?”

And I felt this statement was more saying, “There’s absolutely no possibility that there could be anything wrong. You know, Horizon is absolutely sound”, and I just didn’t – I don’t feel that a computer system, as we have seen today, can be 100 per cent, 100 per cent of the time. And, therefore, I felt that it was important for myself to try and reach out to the General Secretary and say, “Could you possibly look at this a different way? Is there a possibility that there is something different to this?”

Ms Hodge: In addition to raising that concern with the General Secretary, you also contacted Paul McBain who was then the Scottish Non-Executive Director; is that right?

Calum Greenhow: Actually, at that time, he was the Regional Secretary.

Ms Hodge: Regional secretary.

Calum Greenhow: He did eventually become Non-Executive Director but at that time he was Regional Secretary.

Ms Hodge: And Donald Ramsay, who was then the Scottish Executive officer; is that right?

Calum Greenhow: Yes.

Ms Hodge: You proposed to Mr McBain that the NFSP conduct its own and fully and independent inquiry into Horizon’s integrity; is that right?

Calum Greenhow: Yes.

Ms Hodge: You requested that the issue be placed on the agenda for the forthcoming regional meeting?

Calum Greenhow: HEXAM||Index2|*|{S.}{TR:5}{P}Yes.

Ms Hodge: That meeting took place on the 2 October 2015; is that correct?

Calum Greenhow: It is.

Ms Hodge: You’ve provided the minutes of that meeting, which bear the reference WITN00370131. Please can that be shown on the screen.

This bears the title “Minutes of meeting of Scotland Regional Council Held Grampian Hotel, Perth on 2 October 2015.”

To clarify, did you attend that meeting on 2 October?

Calum Greenhow: Yes.

Ms Hodge: It lists certain apologies but are you able to confirm who else was in attendance at that meeting?

Calum Greenhow: Sorry, I’m just looking at the Vice President sort of above – so, obviously, Jamil Ahmed was there; the National President, Jim Nott was there; and Laura Hobbins who, from memory, was an employee of Parcelforce; and there would have been other branch secretaries, obviously the Executive Officer, Donald Ramsay, and Paul McBain.

In fact, at that time there would have been two, so there might have been Andrew Gilhooly as well; as I say, other individuals. But beyond that, I can’t remember, specifically.

Ms Hodge: You say Mr Jim Nott was the National President at that time; is that right?

Calum Greenhow: Yes.

Ms Hodge: Please can we turn to page 2 of the minutes where we can see some discussion in relation to Horizon. If we could scroll down, please. In bold there is a heading “BSC 24”, is that a reference to the branch circular we saw on screen a short time ago?

Calum Greenhow: I believe it is.

Ms Hodge: It reads:

“BSC 24 under the spotlight with regards to the Horizon system and what it does or does not do. National President agreed that the Post Office did a lot wrong in the early years but there is no evidence that the systems were at fault.”

What did you understand the National President to mean when he said that the Post Office did a lot wrong in the early years?

Calum Greenhow: I cannot say for definite what that means. It’s not something I can remember discussing with Jim. So I can’t say for definite, sorry.

Ms Hodge: The minutes then say this:

“The National President also explained that the system was checked annually for its robustness and no issues were found by these outsourced companies of which Pricewaterhouse was one.”

Do you know from where the National President obtained that information?

Calum Greenhow: No, I don’t. I can only – if he’s mentioned Pricewaterhouse specifically, I can only assume that he had received some information that had Pricewaterhouse on it.

Ms Hodge: Finally, the minutes record that:

“The agreement with the delegates was to accept the response but believe that the issue would return due to MPs signing an Early Day Motion.”

Now, the reference to the response, shall we understand that to mean the response of the National President or the response of Mr Thomson in the branch circular; are you able to assist?

Calum Greenhow: I think it would have been what was said on the day by the National President.

Ms Hodge: By the National President. These minutes show, do they not, that the delegates at this meeting, of which you were one, agreed to accept the party line on Horizon?

Calum Greenhow: Yeah, I suppose that’s correct.

Ms Hodge: Why did you accept the response of the National President if you believed, by this stage, that the Post Office had wrongly prosecuted subpostmasters?

Calum Greenhow: I think at this stage I was beginning to question, rather than be absolutely certain, that the Post Office were wrongly convicting. I think, at this point, I was starting to think differently but, as far as evidence is concerned, I didn’t have that at that time. I was, you know, watching sort of, obviously, the Panorama programme and thinking something’s not right here. But as far as having absolute evidence and proof, as we now do, I did not have that at the time and neither did any of the other individuals who were attending.

And, again, we were all postmasters, we are all using the system. And whilst we may have had problems with the – as I say, with the screen or with the hardware, as far as understanding that there was potential problems with the software that may have been making falls discrepancies, that the Post Office were maliciously prosecuting those individuals as a result of, I don’t think any of us had that evidence at that time.

But we were – our feeling of the Post Office was not one of – yeah, they’re – well, put this way, sort of I think even all – even I have been stunned by exactly what’s gone on. I still struggle to understand the scale of exactly what’s gone on. As I’ve said elsewhere in my statement, you know, Government, the Civil Service, big business, in terms of Post Office, Fujitsu, Royal Mail, even the legal industry, are involved in this.

Collectively, we all got it wrong. You know, we cannot ignore that there’s 900 cases, that’s 900 prosecutions, 900 defences, 900 judges that were all involved in that. You know, our faith in the legal industry is such that, well, we would hope and expect the legal industry to have investigated this properly, and, if they were convicting, then it must be – there must be something in it. You know, that’s where we were. And, therefore, we didn’t have the evidence to suggest that the scale of the cover-up and the scale of what was going on and the scale of the victimisation was actually present.

Ms Hodge: In your statement you say that you don’t recall taking any further steps after this meeting in October to raise your concerns, to escalate your concerns about Horizon; is that correct?

Calum Greenhow: It is. If I can just say, actually, I can’t find any evidence. I look back in my own personal emails at that time to sort of see if I had done anything. I do highlight that, obviously, I had to make a decision, my wife and I were having to make a decision as far as our own business in relation to Network Transformation and we’d had to make the – or were making the very difficult decision to, in essence, exit the business and what that implication was going to have on our future. I mean, we live above the post office, our post office is attached to the business. If we – if we lost our business, we were going to lose our home. We were going to lose our ability to care for and provide our daughters.

Those were big decisions and, you know, understandably, that’s where my focus was or was at the time. I’d raised it, and other things came in that, you know, demanded my time.

Sir Wyn Williams: Mr Greenhow, what does the last part of the last sentence mean, “believe that the issue would return due to MPs signing an Early Day Motion”; can you translate that for me please?

Calum Greenhow: I can give you what I think it means. I can’t necessarily say that it’s specific. Obviously, an Early Day Motion, to my knowledge within the political field is that an MP will bring a motion, which is called an Early Day Motion –

Sir Wyn Williams: Right, sorry to stop you. So I wondered whether this was something to do with a person MP within the NFSP but it’s not, it’s about an MP raising it –

Calum Greenhow: Yes.

Sir Wyn Williams: – in an Early Day Motion?

Calum Greenhow: Yes, if I may explain, sir. The NFSP does not have any political affiliations. We’re apolitical on that basis. We provide no funds to any political party. So, you know, we do engage, obviously, and we lobby MPs on behalf of postmasters to highlight exactly what’s going on in the network but this may have been done independently of the NFSP or it may have been done as a result of the NFSP lobbying. I don’t know.

Sir Wyn Williams: Right. Thank you.

Ms Hodge: Thank you, Mr Greenhow, I’d like to ask you now about your knowledge of a defect in Horizon Online, known as the Dalmellington bug.

Calum Greenhow: Yes.

Ms Hodge: The existence of this bug was brought to your attention by Tim McCormack, a subpostmaster who, at that time, was a member of the Communication Workers Union; is that right?

Calum Greenhow: Yes.

Ms Hodge: Do you know why Mr McCormack came to you with his concerns about this bug?

Calum Greenhow: Tim and I sort of communicated backwards and forwards. I can’t remember the specifics of it. I can remember obviously dealing with a particular case, and whether I had read something or was aware of something or – I mean, obviously Tim has provided a lot of blogs. Maybe I had read something that he had said in a blog, and contacted him but he certainly wouldn’t have known that I was dealing with this.

So I may have contacted him just to say, you know, “Have you heard of anything along these lines?”, or I may have read something in what he said, which encouraged me to contact him to ask a little bit more because the Dalmellington bug seemed to be similar to what – a situation that I was dealing with on behalf of a colleague.

Ms Hodge: You’ve produced a copy of the email which Mr McCormack sent to you on 9 August 2016, please can that document be shown on the screen. It bears the reference WITN00370129.

Thank you. So halfway down the first page, we can see the email from Mr McCormack to you on 9 August. It reads:

“Hi Calum

“Just had a call from Mark Daniels.”

Who was Mark Daniels, please?

Calum Greenhow: Mark Daniels was a dual member of both the CWU and the NFSP.

Ms Hodge: “We really need to talk about this. You won’t know half of the story surrounding Dalmellington yet but one of the most important points that has come out of it has been [the Post Office’s] refusal to inform the network that this type of problem can occur.

“Seema Misra was sent to prison for falsifying accounts and the Judge specifically noted that if the computer caused the shortfall in the accounts then she should have noticed. Pretty difficult when [Post Office] know about these problems and don’t tell you what to look for.

“Please – this is so important for all remaining [SPMs] and new entrants.”

He then gives his telephone number.

In this email, once again, we see, on this occasion, Mr McCormack alerting you to the risk that subpostmasters had been and were being wrongly held accountable for bugs in Horizon, which the Post Office knew about, but were not willing to disclose; is that fair.

Calum Greenhow: Yes.

Ms Hodge: We can see he asked you to contact him and, in the email above, you say you will do. Did you, in fact, contact Mr McCormack?

Calum Greenhow: I think I did.

Ms Hodge: Do you recall what he told you about the Dalmellington bug?

Calum Greenhow: He described what actually happened. Would you like me to – yes.

Ms Hodge: Yes.

Calum Greenhow: The Dalmellington bug to my understanding is where a postmaster operates what’s known as a core and outreach. Now, the core is a full-time office and an outreach would be a part-time office, where they would go out to a small community, neighbouring community, and they would set up a Post Office, basically they would take the Horizon kit with him, and they would set it all out and then the community could come in and they would be able to serve them and provide them with the services that they require.

What would happen is you would transfer cash and stock from your core office into your outreach office, and take it, obviously, to that location. You may also at times – and I’ve never operated one so I’m going from my understanding – you may want to transfer cash and stock from the outreach back into the core.

My understanding is that you did that in exactly the same way as if we were sending cash and stock back to the Cash Centre, or receiving cash and stock into our post office.

Ms Hodge: Sorry, by Cash Centre you mean the Post Office?

Calum Greenhow: The Post Office, sorry, yeah the Post Office Cash Centre. And my understanding of the Dalmellington bug is that that process could be faulty and could result in double entering or triple entering and, I believe, in Dalmellington, as the person was scanning it, it was creating multiple entries, which was causing it to look as if the – her outreach or her core actually had more cash and stock than it actually had.

Ms Hodge: Having been told this, by Mr McCormack, did you take any action to draw the existence of the bug to the attention of the NFSP Board?

Calum Greenhow: Unfortunately, I don’t think did.

Ms Hodge: Looking back did the existence of this bug not provide you with the ammunition which you needed to challenge the stance being adopted by the then CEO?

Calum Greenhow: Well, it certainly gave me further evidence that maybe something isn’t quite right. But I think – I don’t know if you’ll want to come on to it – obviously, when we had the interview with the Post Office, I documented that I did challenge the Post Office –

Ms Hodge: I’ll come on to that.

Calum Greenhow: Oh okay, sorry.

Ms Hodge: But if we just take it in order –

Calum Greenhow: All right.

Ms Hodge: So you’ve explained in your statement that you later became involved in a case of a subpostmaster who operated an outreach branch in Scotland; is that correct?

Calum Greenhow: Yes.

Ms Hodge: That postmaster had experienced a discrepancy of £39,000 –

Calum Greenhow: From memory, yes.

Ms Hodge: – which related to the transfer of cash and stock between their core and outreach branches?

Calum Greenhow: Yes.

Ms Hodge: You believed, you said, based on the information which you’d been told by Mr McCormack, that the discrepancy might have been caused by the Dalmellington bug; is that right?

Calum Greenhow: Yes.

Ms Hodge: When you accompanied the subpostmaster at his interview, which was conducted by Brian Trotter –

Calum Greenhow: Yes.

Ms Hodge: – the Post Office Contracts Manager in Scotland, you raised the existence of the bug with Mr Trotter; is that correct?

Calum Greenhow: I asked him about if it was possible that the Dalmellington bug could be responsible for the situation here because it had very similar hallmarks to it.

Ms Hodge: How did Mr Trotter respond when you raised this –

Calum Greenhow: He simply said that it couldn’t possibly be because that had been dealt with prior to this happening.

Ms Hodge: Were you satisfied by that explanation?

Calum Greenhow: No.

Ms Hodge: How did the meeting conclude?

Calum Greenhow: As I put in my statement, I believe there was two action points. The Post Office were going to go away and get the evidence and, unfortunately, one of the aspects that, as I was asking for evidence, the Post Office were saying, “Well, that’s not going to be easy, it’s beyond the six months that we keep, we’re going to have to go to Fujitsu”.

Ms Hodge: Sorry, just to stop you. Evidence of what, please?

Calum Greenhow: Evidence of what the Post Office were presenting as potentially the reason why the – well, in fact, they weren’t providing any evidence, to be truthful. They were – the way that they did the interviews is they asked the postmaster why it couldn’t possibly be – how did this discrepancy take place? They weren’t providing any evidence. They weren’t coming in and saying, “On such-and-such a day you did this, this and this”; they were just simply asking, “You’ve got a loss, explain to us how that happened”. So, in other words, it was up to the postmaster to be able to prove how that happened.

So I was challenging the Post Office for the evidence as to how that discrepancy could take place because the postmaster couldn’t possibly get it, because it was beyond – we any have access to three months’ of data within our office. We were talking over a year here. So, therefore, I was asking the Post Office, “You need to go away and provide that evidence and, until you provide that evidence and prove it, we’re not prepared to sort of accept it”.

Ms Hodge: You were saying in relation to your request that they supply that evidence?

Calum Greenhow: Yes, I was asking for them to do that.

Ms Hodge: What was their response?

Calum Greenhow: They would go away and they would provide it and, sadly, they never did.

Ms Hodge: What, if any, steps did you take to follow up on that request that the Post Office produce evidence of how the discrepancy had occurred?

Calum Greenhow: Well, I kept on asking for the evidence to be provided because, again, as I say in my statement, I would be in contact with the postmaster and they hadn’t heard anything. Getting any information out of the Post Office was not easy, they were not great at responding to either phone calls or to emails and, at one point, I discovered that the case was being heard or was being considered before the Senior Contracts Manager at the time.

I had not been informed of that. The postmaster had been. In fact, actually the Post Office didn’t really engage with us on it, which was really a concern to me and it stuck with me ever since. In fact, I think, sort of me bringing up the Dalmellington bug, I’ve always wondered if that had an impact on how the Post Office treated the postmaster, and it’s always been a concern to me if me bringing that up has actually, you know, made things worse. But I never got any information from them unfortunately.

Ms Hodge: How did this particular case conclude?

Calum Greenhow: I eventually contacted the postmaster, I think in December, and he had been notified that his contract had been terminated but I had – as I say, no ever had been provided to me, no further correspondence had taken place with the Post Office, and I felt that that was, you know – was not right.

Ms Hodge: Looking back, do you consider that you could or should have done more to challenge the Post Office’s refusal or failure to provide documentary evidence to support –

Calum Greenhow: I mean, I think it’s difficult, because when you’re – and as I learned with the Post Office, you ask them something they don’t want to say, I call it they go into their “black hole”, and you just don’t get any correspondence from them. You can bang your head against a brick wall until you’ve got a rather sore head and it just doesn’t happen. They just literally withdraw, withdraw, withdraw. And, you know, to be honest I didn’t know what more I could do.

I just continued to believe in the postmaster, support the postmaster and, obviously, when the GLO concluded, I was straight on the phone to the postmaster. When I heard there was the Historic Shortfall Scheme, “You need to get yourself involved in that, I think you’ve got a case”, and it was then that I discovered that he was thankfully part of the GLO.

But as we sit here today, five years after that, he still has not received his redress, which I think is shocking.

Ms Hodge: Thank you, sir. That brings the end to that particular topic I wish to discuss. It may be a convenient time to take a 15-minute break.

Sir Wyn Williams: Yes, by all means, Ms Hodge.

I’ve got it right, have I: the detail which Mr Greenhow has been giving orally, essentially I can find it at paragraphs 99 and 100 of his statement, yes?

Ms Hodge: That’s correct, sir.

Sir Wyn Williams: Yes, thanks very much. Yes.

So we’ll start again at 11.25, is it?

Ms Hodge: Yes, sir.

Sir Wyn Williams: Fine.

Ms Hodge: Thank you.

(11.09 am)

(A short break)

(11.25 am)

Ms Hodge: Good morning, sir. Can you see and hear me?

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

Ms Hodge: Thank you.

I’d like to move on, please, Mr Greenhow, to examine your approach to the Group Litigation brought by Sir Alan Bates and others against the Post Office.

Calum Greenhow: Yes.

Ms Hodge: You say in your statement that you did not share your predecessor’s dismissive attitude towards the Group Litigation; is that correct?

Calum Greenhow: Correct.

Ms Hodge: And that, upon being appointed as the CFO of the NFSP, you wished to demonstrate that your attitude to litigation was different?

Calum Greenhow: Yes.

Ms Hodge: In your written evidence, you say that you attended the first day of the Common Issues trial and that you had hoped to shake hands with Sir Alan Bates but the opportunity did not arise; is that correct?

Calum Greenhow: Maybe just the way I’ve described it. I can’t remember exactly the reason why but, obviously, as you know, the layout of this room, there’s the anteroom, and I was outside, I can’t remember the reason why I was outside, and, all of a sudden, Sir Alan came out of the room and it was only myself and him in this foyer or wherever. I was at one end and he was at the other end, and he quickly disappeared. He may have been going to the toilet or something like that, I honestly don’t know. But I didn’t get the chance but it would have – it would have been lovely to be able to go across, shake his hand and just thank him for what he’s done.

Ms Hodge: So that was an opportunity as you saw it, to express your support privately, to Mr Bates –

Calum Greenhow: Yes.

Ms Hodge: – in respect of –

Calum Greenhow: Yes.

Ms Hodge: – the bringing of the litigation?

Calum Greenhow: Absolutely.

Ms Hodge: Now, please could we bring up paragraph 135 of your statement, in which you address the approach which you adopted publicly, to the Group Litigation. The reference to the statement, please, WITN00370100, thank you, and it’s page 47. Thank you. If we scroll down, please, paragraph 135, thank you very much. You say here:

“The legal process was under way with court dates set when I took on the Chief Executive role in June 2018, and the NFSP was not a party in the [Group Litigation] case. Therefore, I determined it was right to allow the due legal process to take place and allow the courts to determine once and for all what the answer to the Horizon issue was. Added, as someone not experienced or practised in the legal process, I did not think we could get involved at that stage. I certainly had no idea that the NFSP would be a significant focus of the GLO proceedings.”

That can be brought down, thank you very much. A short time ago, you told the Inquiry, that you believed that Hughie Thomas, Jo Hamilton and Seema Misra were not guilty of stealing from the Post Office. Why then did you not speak out the publicly in support of the Group Litigation?

Calum Greenhow: Quite simply, I didn’t think we could. It’s as simple as that.

Ms Hodge: You were given the opportunity to comment and throw your weight behind the litigation, were you not?

Calum Greenhow: (No audible answer)

Ms Hodge: Please can NFSP00000779 be shown on the screen?

The Stenographer: Sorry, was there an answer to the last question?

Calum Greenhow: Sorry, apologies. I wasn’t really giving an answer, sorry. I wasn’t sure.

Ms Hodge: Do you recall whether you were given an opportunity to comment?

Calum Greenhow: Not to my knowledge. You may be about to remind me.

Ms Hodge: Thank you.

This document contains an email from Nick Wallis to the National Federation of SubPostmasters. Mr Wallis reported extensively on the Group Litigation.

Calum Greenhow: He has.

Ms Hodge: If we scroll down to the middle of page 2, please, we can see there, his email, addressed to Amanda Cox, who, from the email, appears to have been the General Official Supervisor and Receptionist; is that correct?

Calum Greenhow: Yes.

Ms Hodge: This email is dated 16 November 2018 and it reads as follows:

“Hi

“I am a journalist covering the Bates v Post Office High Court trial and yesterday, as you may know, the NFSP’s independence was queried in court.

“I have covered this as a reporter and published a separate piece for my blog outlining the NFSP’s historic refusal to get behind claims that Horizon is not fit for purpose.

“My separate piece is a piece of comment and I am very hard on the NFSP – focusing on its contractual inability to criticise the Post Office on this issue and the decision it appears to have taken as an organisation that it is better to let its members hang out to dry if they are having problems with Horizon, in order to protect the integrity of the brand to clients and other subpostmasters (as explained by George Thomson in his evidence to Parliament on 3 February 2015).”

He goes on to say:

“It is both right and fair to offer you the opportunity to have your position acknowledged and incorporated into the piece.

“You could do this in one of two ways – issue a statement or have the right of reply.”

He then goes on to suggest some topics that could be covered if you were to issue a statement and he expressly says, if we go down, please:

“If the CEO of the NFSP would prefer to write a right of reply piece for publication on my blog, he would be more than welcome.”

If we scroll up to the bottom of the first page, please, we can see that that email was forwarded by Ms Cox to you and to Lynn Eccles. What was Ms Eccles’ role within the NFSP.

Calum Greenhow: She was the Communication Director.

Ms Hodge: Thank you. If we could scroll up then please to the top of the first page, Ms Eccles writes to you, it appears, later the same day. She says:

“Thanks Amanda, Calum the ongoing court case line doesn’t entirely stand up because not all of these questions are linked directly to what’s happening in court.

“Still, I don’t think we should provide a detailed comment, it’ll give the discussion around our independence legs. I think there is also a risk if we just step up and defend the NFSP it gives support to the perception that we only really care about the Fed and not the [subpostmasters] which are part of this class action.

“Nick will criticise us for hiding court process but given that we are no longer firmly coming down on one side or the other I think that’s the best we can do for now.

“Suggest something like this:

“Thanks for sharing the blog and giving us the right to reply. We welcome the opportunity for these matters to be explored fully in court and respect the court’s process. We do not wish to contribute to a running commentary on the case and won’t be making any comment until all matters have been aired in the court.”

She then says:

“FYI – he [that is Nick] will come back to us for a comment when it is all done and dusted so you will need to be ready for that.”

Did you agree with the response that was proposed by Ms Eccles?

Calum Greenhow: Yes, I did.

Ms Hodge: Was this not an excellent opportunity to set the record straight and lend your support to the Group Litigation?

Calum Greenhow: Well, as I’ve mentioned in my witness statement, I’m not conversed as far as legal matters are concerned, and I had faith and confidence – well, I do have faith and confidence in the legal process. I didn’t think it was right and appropriate for the NFSP to be making any comment in relation to an ongoing case. I didn’t think that would be – I didn’t know if that could potentially get us into trouble and I felt that the right thing to do was to wait and allow Lord Justice Fraser and the due judicial process to take place and therefore understand exactly what is – the powers of the justice system were far greater than those of the NFSP. So as far as understanding the truth, the whole truth and nothing but the truth, I had confidence in that process.

So I didn’t think we could. So we just sat back, really, waiting for that process to take place. If – sorry, you know, yeah, if I’m wrong in that, you know, I’ll accept that but certainly that’s our mindset at that time.

Ms Hodge: It might be thought that adopting a neutral stance was quite a cynical decision to take, as it allowed the NFSP to back the winning horse after the outcome the case had been determined; is that fair?

Calum Greenhow: I think that would be a cynical view.

Ms Hodge: You had implored your predecessor, had you not, to support the subpostmasters whose cases were being reviewed by Second Sight before you became CEO of the organisation?

Calum Greenhow: Yes.

Ms Hodge: Why, then, did you not, in your role as CEO, support the claimants who were bringing their claims in court?

Calum Greenhow: Because I didn’t think we could. I, you know – I – sorry if that’s – if that was wrong in that way but I honestly didn’t think it was our place. As Lord Justice Fraser made it clear, we were not involved in the court case, so I didn’t think we could make comment. I honestly thought that if we did, that might prejudice it in some way, shape or form. I didn’t want to do that.

Ms Hodge: So are you saying that, so far as you were concerned, there was a fundamental difference between supporting those cases that were being reviewed by Second Sight, even though they might have resulted in a criminal prosecution and therefore a legal process, and supporting the Group Litigation, which was ongoing at that time; is that your evidence?

Calum Greenhow: Sorry, I’m not really understanding it. All I can say is that I just didn’t think that it was our place, we could make comment on an ongoing case. I didn’t think we could, so we didn’t.

Ms Hodge: Please could NFSP00000710 be shown on the screen. This is an external email chain between members of you team discussing whether or not the NFSP should comment publicly on the GLO proceedings. Please could we scroll down to the bottom of page 4. We can see there an email from Jon Follenfont, which has the title “Article for the Magazine”, it’s dated 8 November 2018. It reads:

“Hi

“Two things:

“There is a Forum of [Post Office] people and subpostmasters which meets to outline new proposals, new kit, etc – perhaps a report is needed in the magazine.

“I have been following the initial High Court case about Horizon problems and the disciplinary action taken by [Post Office] over the years – quite interesting and potentially a major issue for the [Post Office] in the future. It must be costing [Post Office] and thus the network a lot of money in legal fees. Whether we can be that critical in a magazine funded by [Post Office] is an interesting point.”

“Regards.

“Jon.”

He raises there a concern that because the SubPostmaster Magazine is ultimately funded by the Post Office, it wouldn’t be appropriate for the NFSP to comment; did you agree with that?

Calum Greenhow: No. Can I just sort of add, I mean this was obviously – Jon is a lovely, lovely gentleman, who cares passionately about the business. He was a postmaster for a good number of years and, thankfully, has only very recently been able to finally retire and, you know, I don’t think he, in any way shape or form, would try to put across a view that would be detrimental to postmasters.

Ms Hodge: If we scroll up to the middle of the third page, please, we can see your response. Thank you very much. So your response of 8 November reads:

“Hi Jon

“My viewpoint is that as individuals with personal interest in this case, we want to know the verdict of the Judge but it would be unwise for us to make any comment at this stage.

“I was present today. I would say that we are still at the opening credits of the case so it is way too early to ascertain which way it will go.

“As Lynn suggests acknowledging that the case is being heard and we await the judgment with interest is the best we should do via the SubPostmaster.”

Now, what you appear to be saying here to your colleagues is that you don’t know which way the case is going to be decided and so it would be in the best interests of the NFSP to hedge their bets; is that fair?

Calum Greenhow: No.

Ms Hodge: Is there anything further you wish to say about this email, before I move on?

Calum Greenhow: Well, I think the very about is important as well. I’d received an email, it’s probably the vilest – I can’t – I tried to find where that email is. I haven’t been able to find it but it gives indication to really some of the stuff that we receive from people, whether they’re postmasters or just interested individuals from the general public.

It was a lot of pressure on us in one way, shape or form. As I say, all we were trying to do is allow the due legal process to take place and here, because we didn’t know, we simply didn’t – we didn’t have the evidence and we hoped that, through the GLO, the evidence would come out and reveal exactly what had gone on in the past.

So that was just our view. We felt that it wasn’t right for us to make comment.

Ms Hodge: Please can NFSP00000707 be shown on the screen. This document contains an email from you to an employee of the Post Office named Rob Houghton. Can you please explain his role and the nature of your relationship with him?

Calum Greenhow: So Rob Houghton was the Chief Information Officer at the Post Office. He wasn’t there long, maybe 2017 to 2019, I don’t think he was there that long, but anyway, that’s who he was.

Ms Hodge: I’d like to ask you about some comments which you make in the second paragraph of this email, thank you. It’s dated 24 April 2018 from you to Rob with the subject “Branch Refresh”. You say:

“There are a number of aspects that I feel I need to highlight with you but most pressing is the growing loss of confidence by colleagues in the system due to both a mixture of hardware and software issues during and after installation of the new system and/or router. Add to this that there have now been 4 system faults over the last month, which have caused nationwide access problems thus I am concerned that we are handing Freeths a stronger case to bring to court in November as ‘the present is a guide to the past’ is a strong argument.”

Now, one possible reading of this email is that you were not as well disposed to the group litigants and their litigation as you are now claiming to be and that you were primarily concerned about maintaining confidence in the Horizon system; would that be fair?

Calum Greenhow: I think it would be fair to say that I was trying to sort of ensure that there was confidence in the Horizon system. I think that’s important, as a postmaster, someone who uses Horizon and, along with the rest of my colleagues, I think it is vitally important that we have confidence in it. But what I was trying to sort of do here, and if I may, sort of, there was this branch refresh that was going on at that time and postmasters were coming to us and saying that they were having problems.

Now, and where it says “It was literally good to bump into you”, that was a little description that I happened to come out of a room within the Post Office, turned a corner and I literally flattened him because I bumped into him and he virtually ended up on the floor. So hence the “it was literally good to bump into you”. But all I’m tying to do here is highlight that there are problems with Horizon today and, if you don’t sort this out, then you’re in essence giving – making it easy for – you know, easier for Freeths as far as their case is concerned. Do something about this.

But I’m not saying I disagree with what’s going on. I’m just trying to make sure that what was happening to postmasters at that time in relation to the new system was problems and eventually what came out of this meeting was we ended up with different suppliers from the Post Office all in a room there I was able to explain to those individuals what postmasters were experiencing because postmasters were not able to trade. They were losing business. That’s what I was trying to sort of do. Not anything – I appreciate how you can read it but that’s not what I was trying to say.

Ms Hodge: I’d like to explore with you what, if any, role the Grant Framework Agreement had in your decision not to speak out in support of the Group Litigation. The Inquiry has heard evidence from your predecessor about the background to the Grant Framework Agreement. I don’t propose to go over the same ground with you, as you were not directly involved in the negotiation which led to it; is that correct?

Calum Greenhow: Yes.

Ms Hodge: You are, however, familiar with its terms as it remained in force when you took over as CEO in June 2018; is that right?

Calum Greenhow: Yes.

Ms Hodge: In your statement, you describe the Framework Agreement in this way, you say:

“The Grant Framework Agreement is an agreement between the NFSP and Post Office to provide funding from the Post Office to enable the NFSP to offer support to postmasters. It was designed so that this support was free at the point of use to all postmasters.”

Is that correct?

Calum Greenhow: Yes.

Ms Hodge: I think you accept that this apparent benevolence of the Post Office came at a certain price; is that right?

Calum Greenhow: Given the type of organisation that the Post Office is, it is very difficult to deal with them in any way, shape or form. I think, when – you know, if you consider the time period that the Inquiry looking at, the Grant Framework Agreement is only in place to the very end of it. That had nothing to do with the activities and viewpoints of the NFSP prior to that.

As far as this situation is concerned, the Grant Framework had nothing to do with the view that I was taking. There was no influence from the Post Office in any way, shape or form to pressurise the NFSP into taking a view or a stance.

So it had nothing to do with it in that way.

Ms Hodge: I’d like, if we can, please, to look at the terms of that agreement. It bears the reference NFSP00001075. Thank you. So the agreement is dated 21 July 2015. The relevant clause can be found at page 10, please, under the heading “General Conditions of the Grant”. So paragraph 5.3:

“The NFSP shall not engage in the following activities or behaviours …”

These being the conditions on which the grant funding is made:

“The NFSP shall not [firstly]:

“[Undertake] any public activity which may prevent [Post Office] from implementing any of its initiatives, policies or strategies;

“[Secondly] undertaking or inducing a third party to undertake media or political campaigns against [the Post Office];

“[Thirdly] organising or inducing a third party to organise public demonstrations, protests or petitions against [the Post Office];

“[Fourthly] organising or inducing a third party to organise boycotts of [Post Office] business;

“[Fifthly] funding or inducing any third party litigation against [Post Office]; and

“[Finally, broad catch-all] other activities or behaviour the effect of which may be materially detrimental to [the Post Office].”

So those are some of the conditions of the Grant. Can we please scroll to page 16 of the document. We see there another related clause, which bears the heading, “Withholding, Suspending and Repayment of Grant”, this is clause number 17. It reads:

“[The Post Office’s] intention is that the Grant will be paid to the NFSP in full. However, without prejudice to [the Post Office’s] other rights and remedies, [it] may at its discretion withhold or suspend payment of the Annual Grant Payment and/or an Individual Grant and/or require repayment of all or part of the Annual Grant … and/or an Individual Grant if there is an Event of Clawback.”

The term “Event of Clawback” is defined on the following page under clause 17.2, and the first such event or circumstance is where:

“… the NFSP commits a breach of any of its obligations under clause 5 … and/or clause 1 …”

Now, you say that you said in your statement and you claim in your evidence today that these clauses had no bearing upon the actions of the NFSP in relation to Horizon; is that your evidence?

Calum Greenhow: No, I don’t think that’s what I’d said. In relation to the GLO, because that’s the question you were asking me, it had no bearing on that and I don’t think that, given the fact that the GFA only came into place in 2016, when all of the criminal prosecutions had stopped by then, had really much to do, because it didn’t really cover the time period, and – when most of the time period that the Inquiry and the GLO was covering, the NFSP was a trade union funded by its members. So, therefore, it couldn’t have anything – really, it didn’t have anything to do with it.

Ms Hodge: Now, you’ve made the point in your statement and this morning that, so far as the period prior to the Grant Framework Agreement is concerned, that could not have been influenced by these provisions because they didn’t come into force until 2015. As you rightly say, I’m asking you about the period after they came into force and your conduct in relation to the Group Litigation.

Now, you’ve explained that you felt sympathy for the group litigants and, indeed, you wished to convey that and to show your support privately to Mr Bates, but you weren’t prepared to do so publicly. Is it your evidence that that decision was not in any way influenced by those provisions?

Calum Greenhow: Absolutely.

Ms Hodge: You were aware though, were you not, that there was a risk that the Post Office might seek to clawback the funding provided to the NFSP if you incited other subpostmasters to bring claims against it?

Calum Greenhow: It’s sort there sort of within the clause, clause 5.3.

Ms Hodge: Let’s take a look, please, at some minutes of the Board at NFSP00000534. This a meeting of the Board in June 2017. By this stage you were a member of the Board of the NFSP. If we could turn please to page 12, we see there recorded a discussion about the Group Litigation, it’s under the heading “Communications”. The third bullet point reads:

“Against express instructions, in the last issue of The SubPostmaster, LBM had taken an advert from Freeths/Justice for Subpostmasters.”

LBM were who, please?

Calum Greenhow: Lewis Business Media, who publish The SubPostmaster magazine.

Ms Hodge: “[Post Office] understandably went ballistic. Emergency meeting held with LBM with [Post Office] in attendance. It was made crystal clear that their actions were totally unacceptable. It made it look like the NFSP were inciting subpostmasters to take the company to court. May need to beef up resources and bring the magazine in-house in the future. That mistake could have cost the NFSP payments from [Post Office] and ultimately finish the organisation. It was really very serious.

Now, we see Ms Eccles mentioned at the top there, was that an update, was that an update from her in her capacity as Director of Communications?

Calum Greenhow: No, I don’t think she had even started at that point. It was more just informing the point that Lynn would be starting.

Ms Hodge: These minutes show, do they not, that the Board of the NFSP at that time was fearful that it would lose its funding from the Post Office, if it were to lend its support to the Group Litigation?

Calum Greenhow: I think at that point it was being – this discussion was being led by George, rather than the Board and George was putting forward his view. I think George’s view on Horizon is pretty clear but that doesn’t necessarily mean to say that that was the view of the whole Board and, anyway, that was George’s view, George’s opinion. But I wasn’t aware – I wasn’t party to the discussion that took place. I don’t know if the Post Office did go ballistic or whether that was George’s interpretation of it. I’ve no idea.

Ms Hodge: These minutes suggest, do they not, that the loss of grant funding would have brought an end to the National Federation of SubPostmasters?

Calum Greenhow: Well, I think so. You know, any business exists on its ability to fund its outgoings. If it’s not able to do that, then it will no longer exist. It’s as simple as that.

Ms Hodge: Having been appointed the new leader of the NFSP, was your primary concern to ensure the survival of the organisation, rather than to obtain justice for subpostmasters who’d been wrongly convicted?

Calum Greenhow: No. I think, you know, we’ve got a – postmasters need a body that represents them. It needs a body that can do that but I think sort of what we really need to take into account here is the culture within the Post Office. I don’t – personally I don’t think the GFA is necessarily the issue. I think the culture within the Post Office is. If the culture within the Post Office is that they act in an honourable manner, then the GFA works. But if you’ve got an organisation that is incapable of doing it that and is going to use every trick in the book and everything that it can to push forward its view and defend its position, then it doesn’t matter what kind of – it doesn’t really matter. It’s not going to work.

The culture in the Post Office is the problem. Sort the culture in the Post Office and we don’t have a problem. What we’ve seen over the last couple of days in relation to the Postmaster Non-Executive Directors is exactly how the Post Office works today. That’s the problem, not the GFA, in my view.

You know, we need something to be able to hold the Post Office to account, and the fact of the matter is, over this period, the Post Office has not been held to account, by – not been able to be held to account by anyone, and it has done everything it possibly can to obfuscate and to push through so it gets its views.

So, obviously, I’m sure you’re wanting to come on to it, is the new GFA and, you can see, sort of straight away, so, like, I’m looking to remove these clauses. Why these clauses were originally in the GFA, I don’t know, I can’t say because I wasn’t sort of party to it. Do I agree with them? No. Should they be removed? Absolutely. And, thankfully, they now have.

Ms Hodge: If, as you say the problem resides not in the GFA but in the culture of the Post Office, why have you, in your words, worked so hard to remove them from the agreement?

Calum Greenhow: Well, is the culture in the Post Office today where it needs to be? No, it’s not. You know, we can see that. This business is in absolute meltdown from the top. It’s Board, it’s senior management, they’re just incapable of working in the right way. What Justice Fraser has pointed to these as clauses that are – were problematic to him, we’ve followed the guidance from Justice Fraser to have those removed. But I still think, if we have the right culture within the business, then we can move forward.

I mean, from what I want, is I want Government, the Civil Service, the Post Office, postmasters, working together in unity and harmony for the good of this business, not a business working for its own benefit. And that’s exactly what the Post Office has been doing, and that’s the problem. And if they were prepared to behave in the right moral manner, we don’t have a problem.

The fact of the matter is, Lord Justice Fraser and this Inquiry have demonstrated, time after time after time, that this business is incapable of acting in the right manner. How difficult has the Inquiry felt, with all the power, authority and influence you have, in getting this business to provide you with the information to engage with this Inquiry in the right manner? You’ve found it virtually impossible. The frustration – I’ve sat here in this room, time after time, experiencing the frustration that the Inquiry has, because the culture in the Post Office simply isn’t there. Get that sorted and I think we have a chance; if the Post Office continues on its current trajectory, in the manner it is, we don’t, and postmasters will suffer as a result, and we’ve got to get it right.

Ms Hodge: It might be suggested, Mr Greenhow, that, in your evidence to this Inquiry, you are seeking to shift the blame away from your organisation’s focus on its own financial interests and are laying blame squarely on the Post Office; would that be fair?

Calum Greenhow: I think that’s taking it a little bit sort of far. I am – you know, the reality is the NFSP, I think, quite in essence, was on the wrong side of right, here. We cannot escape that, and we – I have been open from when I came in, I have offered my apologies, I have been open and straight with people that the NFSP got it wrong. My predecessors put their faith in the Post Office rather than actually in postmasters. They believed the Post Office, rather than believing their own fellow colleagues. The simple reality is they got it wrong.

So I’m not trying to shift responsible at all but I am trying to sort of highlight that the culture within the Post Office is the fundamental problem. They misled everybody.

Ms Hodge: But do you accept that you and your colleagues put the financial interests of your organisation above the interests of its members?

Calum Greenhow: When?

Ms Hodge: In its decision to refuse to support the Group Litigation?

Calum Greenhow: I – no, I don’t think they did but I do think that George’s view of the past was fundamentally wrong and I don’t think – I mean, obviously you’ve had the opportunity to ask George that and, unfortunately, you didn’t get the opportunity to get that out of him, but certainly from – I can’t answer for the past on that basis but I can talk about, from my own part, and I’ve certainly put the financial position of the NFSP before members. In fact, I think the evidence demonstrates that.

Ms Hodge: You’ve explained in your statement that you had not anticipated the NFSP would become a focus of criticism in the litigation?

Calum Greenhow: Yeah.

Ms Hodge: One of the criminals which was made by Mr Justice Fraser, as he then was, in his Common Issues judgment concerned the NFSP’s publication of the Grant Framework Agreement on its website. In summary, the criticism which was made of the NFSP was that, during the Common Issues trial, it had made changes to its website to add a link to the Framework Agreement in circumstances which were highly suspicious. Do you agree that’s a fair characterisation of the criticism that was made –

Calum Greenhow: Yes.

Ms Hodge: – by Mr Justice Fraser. The reasons why these changes to the website appeared suspicious to him at the time were that, firstly, the link to the Framework Agreement had not been present at the start of the Common Issues trial, and the link had been added during the trial in a manner which appeared to support the Post Office’s case. Again, is that a fair summary of what the judge –

Calum Greenhow: That’s what Lord Justice Fraser – however, I think as you know I can –

Ms Hodge: Yes, we’ll come on to your explanation but just –

Calum Greenhow: Yes, yeah –

Ms Hodge: – to place it in context –

Calum Greenhow: – that’s exactly what he said.

Ms Hodge: – that was the nature of the criticism?

I’d like to ask you, please, first, to clarify when it was that the framework agreement was first published on the NFSP’s website.

Calum Greenhow: I can’t answer that. That was before my time.

Ms Hodge: Please can NFSP00000728 be shown on the screen. Thank you. So this is an email chain, an internal email chain –

Calum Greenhow: Sorry, before you go on, can I highlight, so this is just at the top, just for everybody’s benefit, you can see that’s an email Calum Greenhow, 21 September 2023 to Calum Greenhow, that was me in relation to a Rule 9 Request, that was me going through, as information that could – that complied with the Rule 9 Request, and I couldn’t print it off so I was having to email it to myself so that could print it off. So that’s – if you see that, that’s the reason for it.

Ms Hodge: We can see the date there is, of course, September 2023.

Calum Greenhow: Yes, but it’s – you could look at that and go “Oh, its Calum Greenhow at the top, so therefore he must have known about it” but, actually, that’s what I was doing.

Ms Hodge: That, of course, significantly post-dates the actual email?

Calum Greenhow: Yes.

Ms Hodge: So the chain we have there is dated December 2016. It concerned the publication of the GLO. If we could go to the bottom of page 1, please. Thank you. There’s an email from Nick Beal to George Thomson and copied to Jenna Khalfan. Please could you explain Nick Beal’s role there, please? We can see there, at the bottom of the page, he was Head of Agents’ Development and Remuneration?

Calum Greenhow: Yeah.

Ms Hodge: So his email reads, subject “Grant Agreement”:

“Dear George

“Further to the discussions we have had between us since the inception of the Grant Agreement in 2013, I can confirm that we are now in a position to agree publication of the agreement (and associated Novation Agreement).”

Are you able to confirm: what was the purpose of the novation agreement, do you recall?

Calum Greenhow: Well, it was before my time. It may be in the bundle but I can’t remember offhand.

Ms Hodge: “We have decided previously that this would be via NFSP publishing via your website – please proceed with this as soon as possible. I have attached a PDF version of each document – please can you ensure for the GA [Grant Agreement] it was clear that this was the version that was entered into and the date of the agreement (21/7/15).

“Please advise when this has been placed on your website and a copy of the link.”

If we scroll up, please, we can see an email from Jenna Khalfan to George Thomson, so this now 19 December:

“George,

“I’m going to publish the attached grant agreement on the ‘about us’ page on our website. Do I need to publish the deed of novation too?”

So far as you’re aware, is this the best evidence which the NFSP has as to the date on which the Framework Agreement was first published on the website?

Calum Greenhow: To my knowledge, yes.

Ms Hodge: We know that by early October 2018, the GFA had been removed from the website.

Calum Greenhow: That was during the GLO, yeah.

Ms Hodge: Exactly. In your statement you say that the GFA was removed as part some improvements that were being made by the Communications Director; is that right?

Calum Greenhow: Yes.

Ms Hodge: At that stage that would have been Ms Eccles?

Calum Greenhow: Yes.

Ms Hodge: When were these improvements made which resulted in the removal of the GFA?

Calum Greenhow: They were ongoing at that period of time, so late 2018.

Ms Hodge: So after your appointment as CEO?

Calum Greenhow: Yeah, yeah.

Ms Hodge: So they coincided with the Common Issues trial; is that essentially what you’re saying?

Calum Greenhow: They did, yes.

Ms Hodge: But the agreement was removed before the trial commenced?

Calum Greenhow: I don’t know if it was removed before the trial commenced but I’m aware that it obviously was removed, and then subsequently put back up.

Ms Hodge: Why was there any need to remove the agreement from the website?

Calum Greenhow: So Lynn – I mean, in essence, one of the – you know, through conversation that Lynn and I had been having, we just felt that, in essence, I was a different person, I have a different character, I have a different outlook, that there were many aspects of the Federation that were kind of oldie, and we wanted to really give the whole outlook and business a freshen-up, in essence.

So we introduced you to our mission vision in values, we were changing our colour schemes, the logo, our tone of voice. We were doing – going through doing a new website, and Lyn felt that the “About Us” was not the right place for it to be. She was going to put it into a different part of the new website that she was working on, and she had taken it off as she was working on that particular page. That’s certainly what she had told me at the time.

Ms Hodge: Could the GFA, could the agreement, not have remained on the website pending its relocation?

Calum Greenhow: It could have.

Ms Hodge: You go on to explain in your statement that Ms Eccles decided to place the GFA back on to the website but when she discovered that its publication had become the subject of discussion in the Common Issues trial; is that right?

Calum Greenhow: Yes.

Ms Hodge: Did you discuss this decision with her at the time?

Calum Greenhow: Not until afterwards, actually. It wasn’t a case of – she was following Nick Wallis’ live blog, which was very helpful, I was busy dealing with other things and, obviously, she realised that it was there and, as I’ve explained in my statement, she felt that people might go and have a look for it. So she decided to put it back on.

Ms Hodge: It is an odd coincidence that these changes coincided with the Common Issues trial?

Calum Greenhow: Call it a coincidence; these do happen.

Ms Hodge: But you can understand, can you, why the judge at least appeared to think that was something that was quite suspicious?

Calum Greenhow: Yeah, I can understand, given sort of everything that he was hearing, of course, I wasn’t aware of exactly everything he was hearing. I wasn’t aware of all the bundles all the evidence that he was getting but, yes, I could understand it. But, from my perspective, as I was looking at it, I know that there was nothing suspicious about it, there was nothing going on, and we were certainly not trying to bolster the position of the Post Office. I know that for a fact.

Ms Hodge: Was Ms Eccles concerned, based on your discussions with her, to answer the criticisms that were being made in the proceedings about the lack of transparency that the NFSP and the Post Office were showing in relation to the terms of the agreement?

Calum Greenhow: No, I think it was more – it’s being discussed, people might go and look for it, we’d better make sure that it’s there. I don’t think there was anything of any transparent concerns that were going on.

Ms Hodge: I’d like to move on to a new topic, please. This concerns the outcome of the Group Litigation and how the NFSP has responded to the issues raised in the judgment of Mr Justice Fraser. How would you characterise your initial reaction to the Common Issues judgment?

Calum Greenhow: Well, I think there was an email where I – I think I sent to the Board, where I outline that the Common Issues ruling has been handed down, that we need to read it, we need to understand it. It was a long, obviously, ruling, and, again, not I’m not a lawyer, it’s going to be take me a little bit time to actually understand the nuance of it. Obviously, there’s a lot of legal speak, sort of in it which, I – to someone who is not trained might be difficult to understand. So let’s take time to actually fully understand exactly what’s going on.

At the same time, across social media, there were those who have an anti-NFSP feeling, who were using that to challenge the NFSP, undermine the NFSP, criticise the NFSP in front of our peers, and that caused us to have to, in essence, do a bit of a knee-jerk response without really fully understanding exactly what Justice Fraser had said. But, given the fact that they were focusing on those specific aspects of, was it – well, it was clause 574 onwards, and (f), within his ruling, that covered the NFSP. We had to respond to that.

But I think, as – yeah, it’s not what I wanted to do, but I felt I had to say something, and I very quickly – once that was dealt with, very quickly was able to focus on exactly what it was that Justice Fraser said, and I think so that the evidence is there, that we really start to really, you know – the full reality of exactly what the Post Office had done, and the exposure to risk that postmasters, all postmasters and all employees of the Post Office, in essence, anyone who worked behind the counter of a Post Office, was faced.

And we really, you know, with – we really couldn’t believe that the most trusted brand in the Post Office, a government-owned department, could behave in the way they actually did and you can see that sort of from the statements that we were putting out at that time, that there was one statement that we put out that has a bit of a knee-jerk, but the rest of it was very much critical of the Post Office and supportive of the victims of this miscarriage of justice.

Ms Hodge: It might be suggested, Mr Greenhow, that in the explanation you’ve just given, you’re somewhat downplaying the sense of anger and frustration which you expressed at the time, at the judgment of Mr Justice Fraser in the Common Issues trial; is that fair?

Calum Greenhow: Sorry, could you explain just what you’re meaning by that?

Ms Hodge: I’m suggesting that you are downplaying the anger and frustration that you felt at the time about what was said about the NFSP in the Common Issues judgment; is that fair?

Calum Greenhow: No.

Ms Hodge: Please can we look at NFSP00000558. These are the minutes of a Board meeting held in March 2019 at which you gave a presentation to the Board about the Common Issues judgment; is that correct?

Calum Greenhow: Yes.

Ms Hodge: We can see a description of your initial reaction at the top of page 6, please. The third paragraph reads:

“General outrage that the judge should see fit to cast aspersions about the NFSP who played no part in the trial, gave no evidence, were not asked for documentation, or given the right to defend ourselves.”

Does that accurately summarise how you felt about the judgment when it was first handed down?

Calum Greenhow: I think we were surprised, as the – is the reality of it. We – you know, we just felt that in essence, bemused, and again, I appreciate, as a lawyer who is experienced in these things, but to people who are not, we just couldn’t sort of – we didn’t realise that we would be focused – be such a focus and, obviously, there were things that were being said about the NFSP at the time by others that were really making it difficult for us – making it difficult for the NFSP.

You know, the reality sort of was that we were also aware that there were things that he said, ie “highly suspicious”, we knew that wasn’t correct, we had “bolstered the position of the Post Office”, we knew that wasn’t correct and, you know, we were stunned, in one sense.

Ms Hodge: It appears that your initial focus was upon the reputation of the organisation; is that fair?

Calum Greenhow: The immediate sort of aspect, the reputation of the NFSP, yes, of course. The reality is that, you know, as an organisation, you know, we wanted to help postmasters. We wanted to sort of make sure. We are postmasters. You know, at this moment in time, I still own a post office. I want to make sure that this network not just survives but it thrives. I want to make sure that sort of postmasters are able to continue to provide services in their community, and there were those who were really trying to make it difficult for the NFSP and they were using the judgment as a weapon to criticise us. So that’s, in essence, what we were feeling. It wasn’t just about what Lord Justice Fraser had said it was about, sort of, actually, the level of stuff that was being mentioned across social media.

Ms Hodge: Would I be right to say that your initial feelings of anger gave way to a period of reflection and have resulted in changes being made to the organisation –

Calum Greenhow: Oh, absolutely.

Ms Hodge: – and structure of the NFSP

Calum Greenhow: Absolutely, absolutely. I think, if I may, you can sort of see the before the judgment that has come out, that I was trying to make those and, in essence, I could see this – and this might sound wrong, so please forgive me – a little bit of a distraction, and where I felt that I needed to take the business and where the Board needed to take the NFSP, for the good of postmasters, for the benefit of postmasters, that this was going to make it difficult, this was making the journey or the hill steeper and, as I say, there were those who were trying to really weaponise the judgment against the NFSP and, you know, this was kind of taking us back a step or two.

Whether that was going to make it more difficult for us to make the changes within the NFSP that we needed to and, in essence, this has haunted me all of the way through sort of the time I’ve been the Chief Executive of the NFSP.

I know what I need to do in this business. My board knows what we need to do in this business to really take this organisation forward for the good and benefit of postmasters and, you know, people try to weaponise this and it makes the harder. I keep on having to come back to this, and deal with it, rather than being able to do what I need to do, what we need to do to move the NFSP forward for the good of postmasters.

Ms Hodge: The first initiative which I’d like to examine with you relates to the recording and monitoring of members’ concerns.

Calum Greenhow: Yes.

Ms Hodge: Prior to the GLO, is it right that there was no system in place which required local representatives whether Branch Secretaries or Regional Secretaries –

Calum Greenhow: No.

Ms Hodge: – to report to central office the issues which were being communicated by their members?

Calum Greenhow: No.

Ms Hodge: There was also no system in place to enable the central recording and monitoring of such issues; is that right?

Calum Greenhow: I would say to my knowledge, no.

Ms Hodge: Please can you describe the action which you have taken to address this problem?

Calum Greenhow: So one of the things that sort to we’ve tried to put in a place or have put into place is the collation – there’s a spreadsheet that we deal with on a weekly basis. If any branch secretary has received a call from a member, that they fill in a form. They do it on a weekly basis. That sort of automatically comes into the central – into the central NFSP and that is collated onto a central record and then myself and two employees of the NFSP on a monthly basis go through that to ascertain whether there’s any anomalies or any issues that we really need to highlight.

That is then put into data that is provided to the board. We put it into The SubPostmaster so that members are aware of exactly what’s going on.

Ms Hodge: So, in your statement, you’ve mentioned that the spreadsheet is collated and it culminates in a quarterly report to the Board. You’ve explained that the most common issues raised, I think in at least the last year, relate to the Historic Shortfall Scheme –

Calum Greenhow: Yes.

Ms Hodge: – is that correct?

Calum Greenhow: Yes.

Ms Hodge: Please can you describe the nature of the concerns that are still being raised by your members in relation to the scheme?

Calum Greenhow: I – well, lately, what people have – they’ve been receiving the letters in relation to the 75,000, and they’ve thought it was a scam. So they’ve been calling us to say, “Is this right?” We’ve been able to obviously assure them that it is. Others, you know, “Just how long – you know, how long is it taking? How do I fill out the form? Where can I get the form? Can I still apply?” All things like that.

Ms Hodge: It sounds from your description that those are more queries than complaints; is that fair?

Calum Greenhow: Yeah, I would say so, yeah.

Ms Hodge: Now, another method I think you’ve mentioned in your statement for canvassing views of the membership is the use of surveys; is that correct?

Calum Greenhow: Yes.

Ms Hodge: How frequently are they undertaken?

Calum Greenhow: On a monthly basis. We have done two large case member surveys, 2019 and 2021, and on both of those occasions I think we had about 1,000 postmasters that were involved in that, and that was done to quite a – I’m not a statistician or – I don’t know what the term is but anyway – a researcher. So – but they’re done to industry standards and, you know, the information that came back.

So we made sure there was a certain number of local post offices, mains post offices, different contracts, traditional contracts and also spread around the country as well. So there we really got a very broad cross-section, so we had an understanding of exactly what it is the postmasters think.

The monthly ones are just put out and it’s for any postmaster to respond. So it’s not done to the gold standard. It’s just literally a survey that goes out and people respond.

Ms Hodge: Now, I think it’s your evidence that, during the period covered by this Inquiry, there was no formal whistleblowing policy or complaints procedure in place within the NFSP; is that correct?

Calum Greenhow: That’s correct.

Ms Hodge: What action have you taken to address that gap in the procedures?

Calum Greenhow: Well, we’ve done that now and we’ve obviously supplied those to the Inquiry, they’re on our website now and, with the help of our Legal Team, we’ve drafted them, and they are now available.

Ms Hodge: And –

Calum Greenhow: So that’s a whistleblowing, a complaints and also an equality and diversity policy.

Ms Hodge: They’re now all publicly available on your website?

Calum Greenhow: They’re available to the members on our member – so there’s two sides to our website; there’s the members side and then the public side, so they’re available on the members side.

Ms Hodge: Why are they not available on the public side?

Calum Greenhow: It’s for members, so that’s why we’ve put it on that side.

Ms Hodge: The second initiative which I would like to examine with you concerns the provision of training given to those responsible for representing subpostmasters in disputes with the Post Office. You’ve explained in your statement that, when you were appointed a branch secretary in 2012, there was no formal training on the conduct of interviews; is that correct?

Calum Greenhow: That’s correct.

Ms Hodge: You say that you believe this resulted in a lack of consistency in the support which was provided to subpostmasters in the period covered by this Inquiry; is that right?

Calum Greenhow: Would agree with that.

Ms Hodge: You have launched an initiative which you describe as the advocacy representative project?

Calum Greenhow: Yes.

Ms Hodge: Can you please describe that project which you’ve established to address this issue?

Calum Greenhow: So, again, sort of listening to the GLO and listening to – and taking my own experience into account, I felt that, you know, dealing with the Post Office is not an easy – not an easy thing. As far as any policies, procedures, the way the Post Office go about things, they can change and, therefore, I felt that it was right and appropriate that we had properly trained individuals, a small team, that if there was a contractual issue that may result in a suspension or termination, that it wasn’t just anybody who would deal with thats. We would have a small team that could work together, pool their resources together, pool their experience together and, you know, make sure that, if a colleague was in that situation again, as we’ve heard just over the last couple of days just how harrowing that can be, that the NFSP is there to challenge the Post Office appropriately and to make sure that everything is being done to investigate exactly why a discrepancy has taken place, and that it’s not simply, “You’re short, you owe us the money, if you don’t give us the money we’re going to terminate your contract”.

Ms Hodge: You said in your statement you now have six dedicated representatives who are trained in the Post Office’s contracts to represent subpostmasters –

Calum Greenhow: Yes.

Ms Hodge: – interview. Who provided or who provides the training to those representatives?

Calum Greenhow: So it was in-house that we did that. However, we did seek the support and help of our employment professionals, HR:4UK, and they gave us guidance on how to do that. We have continued to reflect and continued to look at that, and we are now engaging with ACAS because they have a mediation service and we’re looking to sort of see if that could be something that would actually sit better for us, so that it would be not only an external, but it would be an accredited qualification. So we’re in the process of looking at that and seeing if that would work and sit with us.

Ms Hodge: How is the performance of these new representatives monitored by the NFSP; do you have any systems in place for that purpose?

Calum Greenhow: Good question. We don’t have any KPIs if that’s what you’re referring to, but I do meet with the two individuals who are responsible for overlooking – for overlooking this and, in essence, you know, going through and ascertaining whether the right decision has been reached. I’ve not, as I’ve looked at things, had any issues or any worries as far as outcomes are concerned. However, I do – we do feel that it would be better for us to have an external accredited qualification to give our members greater confidence in relation to the quality of knowledge and understanding that we have in that area.

Ms Hodge: Thank you. In your statement, you’ve described the current approach that’s adopted by the NFSP when supporting subpostmasters in disputes with the Post Office. That’s at paragraph 273 of your statement, please, at WITN00370100. Thank you. The paragraph can be found at page 94 going onto page 95. Thank you very much. If we scroll down, please, thank you. So that reads:

“Where the NFSP is asked for help, our goal is to ensure that Post Office is respectful, helpful in terms of providing access to any information, carries out a full and thorough investigation and is understanding in terms of any conclusion. In terms of an investigation, Post Office must answer the three questions of

“(a) Is it computer error?

“(b) Has someone made a mistake and why?

“(c) Have the funds of the Post Office been used in the manner they are not intended and by whom?”

You go on to say:

“If Post Office cannot answer these questions factually, then the postmaster should not be held to account. Some of these cases are very complex and are being dealt with by the relevant police authorities.”

Now, earlier in your evidence we examined a case in which the Post Office did not provide the information which you had requested on behalf of a member. What is your organisation doing now to ensure that full disclosure is being provided to subpostmasters as you’ve outlined here?

Calum Greenhow: Well, when it comes to – there are certain – there are certain reports that the Post Office does, and that is the first thing that we sort of ask for and, if we don’t get those, we don’t move forward. It’s as simple as that. But I have to sort of say, Post Office – certainly my understanding is – are far more transparent than they have been in the past, and certainly going back to 2016, if we asked for information, they will usually provide it. There’s not – it’s not been reported to me any concerns and any issues on that.

Ms Hodge: So is it your evidence that these questions that you’ve outlined here, they are now being answered, to your knowledge, satisfactorily by the Post Office in cases in which your members are concerned?

Calum Greenhow: To my knowledge, yes.

Ms Hodge: I’d like to examine with you now the efforts you’ve made to bring about cultural change within the NFSP. You identify in your statement a number of initiatives, which you have adopted to improve the culture of the NFSP and the wellbeing of its members. One of those initiatives is the establishment of a Culture Committee. Can you please explain the background to that?

Calum Greenhow: So we haven’t – that’s not established yet. We’re in the process of doing that. As I highlighted, we had Darren Burns from the Timpson Group come along to the NFSP conference this year. In preparation for Darren coming, I read Sir John Timpson’s book, Upside Down Management, and I came across this within his book and he explained it beautifully, and I thought, “This is exactly what we need. We need to do this”.

As I’ve highlighted sort of before, I’m an inclusive person rather than exclusive person. I want to encourage people, I want to lift people up, I want to encourage them on. I enjoy hearing and listening to different voices, different viewpoints. But I do think that, culturally, as I’ve already highlighted, the Post Office has clearly not moved forward in any way, shape or form since the GLO. I also think that there’s a level of toxicity in the network, as a result of that.

Postmasters are understandably very, very worried about their future and the viability of their business and I think that is – that pressure is causing some to maybe act in a manner that maybe doesn’t quite sort of reach the standards that postmasters should maintain and, therefore, on that basis, I think it’s important that we have postmasters themselves helping us to establish what it is that that standard should be. What is it – you know, we can all sit here and say that subpostmasters are good, honest, decent people, fine, upstanding pillars of the community, which I fundamentally believe that they are, but what’s wrong within the network? And I do believe that it’s very important that we all take a good look at ourselves in the mirror, everyone who has been involved in this, and go, “Where did we get this wrong? How can – you know, where’s our culture part of the problem?” And it’s very easy for us to point the finger of blame at sort of like other people but we’ve got to sort of first and foremost look at ourselves.

And, therefore, what I’m looking for is I’m looking for postmasters to help us make sure that the culture within the network is right, so that we can help take this business forward and make sure that postmasters’ businesses are as viable as they possibly can.

So I don’t want to be prescriptive as to what that is, but I’m looking for ten people across the country, one per region – if there’s more than one person comes forward, they will have a democratic vote on that within the region – but I will be looking, and then, once that Culture Committee has been established, we will sit down and we will look at what is it that the focus of that committee is going to be, what is it that’s going to be the priorities and how are we going to bring that about?

Ms Hodge: Mr Greenhow, in answer to my question about the NFSP’s culture, you said that you don’t believe that the culture of the Post Office has moved on.

Calum Greenhow: Yes.

Ms Hodge: We’ll come on a little later to the culture of the Post Office but I want to test with you whether that’s a fair statement in light of the evidence that you’ve just given about the approach that the Post Office is taking to its investigation as to contractual shortfalls and the disclosure that it’s providing. You’ve just told the Inquiry that, so far as you are aware, proper and adequate disclosure is being provided now by the Post Office in the context of those investigations. So does that not reflect some change of culture and attitude within the organisation?

Calum Greenhow: I would accept that and, actually, I have to sort of say that – and again, I say it in my statement, that, actually, within the branch assurance team, I think there are real major changes there and real efforts to be far more open and transparent as – than what I experienced in the past. Sorry, I was, in essence, highlighting at a senior level that the – you know, and what we’ve heard and what we’ve listened to, certainly in relation to the two Postmaster Non-Executive Directors and what they’ve experienced.

Clearly there are still a long way still to go, but yes, there is – I would say there are some lovely, lovely people within the Post Office who really want to engage in work and have the right attitude. I’m not saying all is bad. There are some aspects that are positive, and I think that comes down to the individuals, and we have to encourage them and support them as they move forward in that, and really try to make that cultural change that is required.

Ms Hodge: Before we move off this topic, please, I’d like to ask you about a recent decision of the NFSP to refuse the application of an individual who wished to be admitted as a member.

So far as the rules governing membership of the NFSP are concerned, you’ve explained in your statement, firstly, that anyone who holds a contract to operate as a subpostmaster may be admitted to the organisation; is that correct?

Calum Greenhow: Correct.

Ms Hodge: That, secondly, the Board of the NFSP has the right, in its reasonable discretion, to refuse to admit an applicant and not to provide its reasons for doing so; is that right?

Calum Greenhow: Yes.

Ms Hodge: And that there is no right of appeal in respect of that decision?

Calum Greenhow: Yes.

Ms Hodge: That’s all provided for in the NFSP’s Articles of Association?

Calum Greenhow: Which were obviously laid down in 2015 when we became a company limited by guarantee.

Ms Hodge: Now I wonder if we could turn, please, to –

Calum Greenhow: Can I just come back to that, if I may. I’d love to change the Articles of Association because I feel there’s a lot in there that we need to shift forward on. It’s a huge piece of work and I’ve tried to do some things, particularly around the branch and regional secretaries, just to give them far greater prominence and position within the NFSP, but there’s a lot that I would like to – but if I may, I haven’t actually sat down with someone who is legally – who would have a legal understanding and gone through it line by line and said, “Yeah, you need to change this, this would be a good idea”, and I do think that allowing an appeal process would be a good thing to introduce.

And it’s something I would like to do in – maybe when this Inquiry is all over. But it’s consumed my life for the last four years, as I’m sure it has yours, and, you know, I feel that I need to deal with this now and then I’ll deal with that then. But there’s a lot in those Articles of Association that I think I would like to change.

But when that happens, it will be done with the help and support of postmasters, the membership of the NFSP.

Ms Hodge: Thank you. Please could we bring up your statement at page 106, please, where we can the explanation that you’ve given and the reasons you’ve given as to why the Board refused that application. Paragraph 299, please. Thank you. You say there:

“In this calendar year, one application was refused. This is the only application I am aware of being refused since I came into post as Chief Executive. This application came from someone who had previously been a member of the NFSP. I have highlighted above the behaviour of some on social media, whether by members or former members, and the mental health impact of that on our employees and [postmasters].”

Just pausing there, please, we haven’t gone to that. Can you describe what you’re referring there, the behaviour on social media and the impact that this had on your employees?

Calum Greenhow: Yeah, so the individual – I’m not sure if I’m allowed – I don’t know if I can talk about the specifics or the generality but let me be general and, if you feel you want me to be specific, I’m more than happy to be.

But there are some within the network who use social media to – and that causes postmaster colleagues and NFSP employees quite considerable mental stress. To give an example, there was – just about ten days ago there was, on a social media site, an encouragement to postmasters to single out and target a member of – an employee of the NFSP, to harass them for a bit of fun.

Obviously, on Monday, Tuesday, the Inquiry heard about, you know, playground, schoolboy antics. I don’t consider that to necessarily fall into that level. To specifically target an individual, to harass them, I again, I don’t think meets the standards of how postmasters should behave. On groups, to encourage people to behave in that way, to me, is not acceptable.

And, therefore, if we are aware of that going on, you know, it’s not how we want – it’s part of the reason why we want to set up the Culture Committee. It’s part of the reason why we want to do that. So that postmasters, whilst we understand people’s frustration, there’s a limit to sort of where that should go and a limit to how that should – you know, there’s below the line and there’s above the line. There’s acceptable and unacceptable. And we just felt that, in this case, the individual had displayed some of that in the past and had caused employees distress and that, by admitting the individual back into the NFSP, that was only inviting or allowing that to happen again.

Therefore, on that basis, we have a duty of care towards not only our postmaster members but our NFSP employees and, therefore, reluctantly – and we deliberated at great length – we decided that, you know, to protect our members, that was the right decision.

It’s not what we want to do but, you know, some people – it doesn’t matter what you say, they’re not prepared to – they think they can do what they want, when they want, how they want and, if you disagree with them, they will use any avenue that they possibly can to call you for whatever. Well, that’s not acceptable. That’s – I personally don’t think that that’s the standard that postmasters should behave in.

Ms Hodge: I just wanted to clarify with you, to make sure I’ve fully understood the reasons. What I understand you to be saying is that this individual applicant had been responsible in the recent past for posting social media posts which were abusive in their content?

Calum Greenhow: Yes.

Ms Hodge: Is that what you’re saying?

Calum Greenhow: And they had specifically hounded an NFSP employee and caused them quite considerable distress.

Ms Hodge: Again, sorry, it was this particular applicant who had targeted –

Calum Greenhow: Yes.

Ms Hodge: – you say, one of your employees –

Calum Greenhow: Yes.

Ms Hodge: – on social media –

Calum Greenhow: Yes.

Ms Hodge: – in a manner that you’ve described as harassment, harassing –

Calum Greenhow: Yes.

Ms Hodge: – is that correct? It was based on the content of the abusive messages and the distress which it caused at least one of your employees that the Board decided not to admit this individual –

Calum Greenhow: Yes.

Ms Hodge: – into the NFSP, is that your evidence?

Calum Greenhow: Yes.

Ms Hodge: Now –

Calum Greenhow: Can I also clarify that they didn’t actually apply in their name, they applied in a pseudonym. So – again, so we felt that that wasn’t – that that was disingenuous, that if you’re not willing to be open and transparent with us as to who you are, that doesn’t really show respect towards the NFSP and, therefore, again, that was also part of the reasons why we declined their membership.

Ms Hodge: Please can WITN00370127 be shown on the screen. Thank you. If we scroll down, please – sorry, if we could go down a little bit further, thank you – this appears to be a draft of the letter which was sent to the applicant refusing his application for membership; is that correct?

Calum Greenhow: Yes.

Ms Hodge: So it’s dated 13 March 2024 and reads:

“Dear Mr Jay

“Thank you for your email and completed NFSP application form dated 6 February 2024.

“I am writing to inform you that a decision has been made by the NFSP’s Board members to decline your application for NFSP membership. The decision will also become applicable if you or any other member applies to nominate you as an Organisational Representative and I refer you to Section 9, Item 9.3 of our Articles of Association [which provide] ‘The council may in its reasonable discretion decline to accept any person as a Member and need not provide its reasons for so doing’.”

Now, in your statement and in your evidence today you’ve given a detailed reason as to why the application was refused. Why did this letter provide no reason to the applicant explaining the grounds for the refusal of his application?

Calum Greenhow: We just thought it was – that’s the decision we had made. We didn’t have to, as per 9.3, provide a specific reason for doing so. We just felt that that was probably the simplest and easiest way to sort of deal with it. I don’t think they, you know, I – knowing the individual, it wouldn’t matter what we put down, I don’t think it would have been accepted. It didn’t matter what we said. It would be used in a manner to undermine the NFSP, you know, because that’s the behaviour – that was the behaviour of the individual, and it’s sad that that’s the case.

I would rather have – as I say, I’m an inclusive person. This is not something that sits easily with me, it’s not something that sits comfortably with me but sometimes I have to make difficult decisions, and this was one of them.

Ms Hodge: The fact that you don’t have a duty to give a reason, of course, doesn’t preclude you from giving a reason to the applicant, does it?

Calum Greenhow: Yeah, but, as I’ve already said, I don’t think any answer that we would have given would have – there’s – I don’t think there was any way that the individual would go “Yeah, fair enough. That’s fair enough. That’s a fair point”. This is not an individual sort of who, you know, has – any conversation, any discourse that we’ve had with him over the period, has ever accepted anything that we’ve said, you know, and as I’ve said, has gone to quite significant lengths, and has caused our employees – some really, really good people – distress.

And despite trying to say, “Look, you know, just tone it down and maybe there’s a different way we can do this, it’s not going to happen”, so, you know, as I say, knowing the individual, it didn’t matter what we said, it was never going to be accepted, so just quote the rules and move on.

Ms Hodge: If you are concerned about the culture on social media –

Calum Greenhow: Very concerned about the culture on social media.

Ms Hodge: – why, then, not explain to the applicant the reasons why you considered their conduct to be unacceptable?

Calum Greenhow: Because I think that’s only just going to invite more, and more, and more, and more. You know, the reality is, this is, as I’ve tried to sort of say, this is not someone who will take – this is someone who believes they can do what they want, when they want, how they want and, if you happen to disagree with them, they will go to extreme lengths to get their way, even if it’s causing people mental distress. That’s of no concern. So, you know, I don’t think that there’s any – sometimes you’ve really just got to go, “Sorry, no, move on”.

Ms Hodge: Do you not think it would help, Mr Greenhow, to be more transparent about your decision making in order to avoid possible misunderstandings or suspicion about the motives of the Board in turning down an application like this?

Calum Greenhow: If you’re dealing with an individual who would be willing to be reasonable on that matter, then, yes, I would agree with you but, as I’ve tried to explain, it doesn’t matter what we said to this individual, they would never take anything that we said as, “All right, okay, fair enough. I’ve overstepped the line. Maybe the language that I’ve used or maybe the things that I’ve done, I’ve gone too far”. He demonstrated that time after time. So, as I say, it was simply, to protect our employees from further potential harassment, we felt that this was the right course of action.

Ms Hodge: Thank you, sir, that brings us to the end of that topic. I’m mindful it’s 12.55. It may be sensible to break now.

Sir Wyn Williams: Yes, by all means.

Ms Hodge: Shall we return, then, at – we can make it 2.00. I don’t think we’re going to take up the whole of the afternoon.

Sir Wyn Williams: Yes, that’s fine.

Ms Hodge: Thank you.

(12.57 pm)

(The Short Adjournment)

(2.00 pm)

Ms Hodge: Good afternoon, sir. Can you see and hear us?

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

Ms Hodge: Thank you.

Mr Greenhow, before I move on, is there anything further you wish to say about the matters we were discussing shortly before the lunch break?

Calum Greenhow: No, that’s okay. Thank you.

Ms Hodge: My next topic is the extent of change which has been brought about within the Post Office.

Calum Greenhow: Sorry, the?

Ms Hodge: Within the Post Office?

Calum Greenhow: No, but change?

Ms Hodge: The extent of change which has been bought about within the Post Office?

Calum Greenhow: Oh, sorry. Thank you.

Ms Hodge: In your statement and in your evidence to the Inquiry this morning, you’ve expressed concern that the culture of the Post Office has not changed; is that correct?

Calum Greenhow: Certainly, at a Board and senior executive level, yes.

Ms Hodge: In your statement, you cite as an example the time which it has taken to negotiate changes to the Grant Framework Agreement –

Calum Greenhow: Yes.

Ms Hodge: – to remove the clauses which restricted the activities of the NFSP

Calum Greenhow: Yeah.

Ms Hodge: – is that correct?

You describe those negotiations as protracted and difficult; is that fair?

Calum Greenhow: Yes.

Ms Hodge: You suggest that, so far as you are concerned, they are evidence of the fact that the leopard has not changed its spots?

Calum Greenhow: Yes.

Ms Hodge: Please can we bring up your statement at paragraph 317, page 113. You say there that:

“Post Office provided the NFSP with a note of novation.”

When was that, please; do you recall?

Calum Greenhow: Yeah, it would be some point in 2019. The exact month I can’t remember but it would be in 2019.

Ms Hodge: You say:

“The legal advice we received said this did not address the specific clauses which were raised by Lord Justice Fraser at paragraphs 590 and 596 of the Common Issues Judgment [those being those] related to clauses 5, 17 and 26.”

You say:

“The advice we received is that the [Grant Framework Agreement] would require significant alteration to comply with the Common Issues judgment.”

You go on to say that an amended note of novation was prepared by your solicitors and presented to the Board of the NFSP in October 2019 and approved prior being sent to Post Office for consideration. You then say this:

“It has taken the best part of five years to get the Post Office to the point of agreeing some of the changes we were proposing.”

Now, I think it’s right to say that you attribute that significant period of delay to the Post Office; is that correct?

Calum Greenhow: Yes.

Ms Hodge: One of the issues you say that acted as a stumbling block was their refusal to acknowledge that they had a duty to act in good faith towards their members; is that correct?

Calum Greenhow: Well, acted – one of the aspects that Lord Justice Fraser talks about is that the Post Office had a duty to act in good faith in relation to postmasters and he makes such a – that is really a central tenet of his ruling, that we felt that it was important that, if that is how the Post Office are supposed to behave towards postmasters, that given the fact that the NFSP is postmasters, then that’s how they should act towards the NFSP as well.

Ms Hodge: If we could look, please, at paragraph 319, onto the next page, please. So you explain there what you’ve just said: that so far as you were concerned, this issue of good faith was a central tenet of the judgment. You say this:

“We proposed that the term ‘good faith’ be placed in the recitals section, but this was … rejected by Post Office. The reality of the Post Office refusing all attempts to include this tenet in the [Grant Framework Agreement] gives voice to concerns that, culturally, Post Office has not changed and that there is an unwillingness by the Post Office to act in good faith towards the NFSP and therefore our Postmaster members.”

Now, a new Grant Framework Agreement has now been signed by both the NFSP and the Post Office; is that correct?

Calum Greenhow: Yes.

Ms Hodge: For the benefit of the transcript, that document bears the reference WITN00370137. Please could that be shown on the screen.

Thank you. If we scroll over the page, please. Thank you and, again, then down to page 1, please. Yes, thank you, the first page of the agreement. So it’s dated 16 September 2024, so very recent.

Calum Greenhow: It is.

Ms Hodge: – since the time that you produced your statement. By way of background, it states this:

“[The Post Office] and NFSP are parties to a Grant Framework Agreement originally entering into between [the Post Office] and the unincorporated association known as the National Federation of SubPostmasters dated 21 July 2015 and novated to the NFSP by a Deed of Novation dated 5 November 2016 …”

You may recall I asked you about the deed of novation. Does that help you as to why there was a deed of novation?

Calum Greenhow: Yeah, but I’ll be honest with you, I can’t explain what the deed of novation was about. Why there was an update, I don’t know.

Ms Hodge: There seems to be a distinction being drawn here between –

Calum Greenhow: Yes.

Ms Hodge: – the NFSP as a unincorporated association and its subsequent incarnation as a private limited company.

Calum Greenhow: So that may be the reason why, then because, certainly when the Certification Officer ruled that we weren’t a trade union, we were unincorporated for a period of time and then – until we actually got ourselves incorporated.

Ms Hodge: It goes on to say this at B:

“Following Alan Bates and Others v Post Office Limited (the Common Issues judgment), the parties have agreed to amend the Original Grant Framework Agreement to address those matters raised in the Common Issues Judgment relating to the original Grant Framework Agreement.

“The parties have therefore agreed to amend and restate the original Grant Framework Agreement as set out in this deed.”

We can see it’s at page 14, please, there’s a new clause 5. This reads “General conditions of the Grant”:

“Both parties shall use reasonable endeavours to identify any issues which will or may create tension between the interests of [the Post Office] and those of Postmasters and use reasonable endeavours to resolve any such issues.

“For the avoidance of doubt, it is hereby acknowledged that the NFSP may:

“[Firstly] represent individual Postmasters;

“[Secondly] discuss and comment on [the Post Office’s] initiatives, policies or strategies with its membership;

“[Thirdly] publicly comment on the same;

“[Fourthly] state and plea ins its opinions on the same, even if not in support of [Post Office]; and

“[Finally] lobby relevant stakeholders such as BEIS and Royal Mail Group Limited on behalf of its members.”

So quite a significant change then, relative to the provisions that we looked at this morning?

Calum Greenhow: Yes, I mean, that’s obviously in line with Lord Justice Fraser’s ruling and why did it take five years to do that? I have no idea.

Ms Hodge: I’d like to must move on, please, if I may to the subject of audits and investigations. You’ve said earlier in your evidence that I think you accept that there has been a change of culture within the Post Office, so far as their conduct of audits and investigations is concerned; is that correct?

Calum Greenhow: Yes, there has and I think that’s down to the individuals involved and I think they have to be congratulated on that. However, that’s not to sort of say that we’re kind of where we need to be. Not – I do feel that we need to do more and I still think the Post Office is acting as judge, jury and executioner in certain aspects, and we need to have something in place that will enable the Post Office to bring its evidence, particularly where there’s a disagreement with the postmaster, and the postmaster can bring their evidences as well, and that can be deliberate on and discussed in a far more open and transparent way rather than, as we have seen, in relation to what took place with one of the Postmaster Non-Executive Directors.

Ms Hodge: Can you please clarify what you mean when you say that, in certain respects, the Post Office is still acting as judge, jury and executioner?

Calum Greenhow: Well, they determine sort of whether there is a shortfall. They’ll obviously – you know, as I’ve said earlier on, there’s the three questions: is it Horizon; is it a mistake and by whom; or has the assets been used in the manner that was not intended? Postmasters are still explaining that they are experiencing losses. They then receive a letter, which isn’t a demand for money but is, “You’ve got a debt”, and, you know, we need to be in a situation where the Post Office are able to bring that to an open and transparent conclusion, rather than it just going on and going on. Some of these cases have been outstanding for years because they can’t be brought to a conclusion.

And I do think we need to be in a situation where we have complete confidence in Horizon as a system. As I’ve highlighted, postmasters are still experiencing shortfalls. We’ve asked the Government for a full, in-depth look at the hardware, the software, the telecommunications, the processes, practices within Fujitsu and also within the Post Office, but there’s a reluctance to do that.

I still think that there’s a belief within the Post Office that Horizon is robust. I had a conversation with officials in the Department of Business and Trade not that long ago where I asked the question, and I was told the Post Office are telling them that the system is robust. However, postmasters are experiencing shortfalls.

So I think we need to – there needs to be something else there that enables both the Post Office and postmasters to come together so that it’s – certainly I can’t remember if it was Saf or – Mr Ismail or Mr Jacobs who were talking about these being done externally. I don’t disagree with that to a point but what we have been saying for a long period of time is that there needs to be another process where the Post Office can bring to an independent body and the postmaster can bring to an independent body if they have concerns about what the conclusion that the Post Office draw.

Ms Hodge: You’ve explained in your statement that the NFSP is aware of four cases in which a subpostmaster has requested support in their defence either of a criminal prosecution –

Calum Greenhow: Yes.

Ms Hodge: – or a civil claim –

Calum Greenhow: Yes.

Ms Hodge: – and that, in one of those cases, the subpostmaster has been exonerated; is that correct?

Calum Greenhow: It was, yes. If I may sort of – this wasn’t something that was done by Post Office. It was actually – it was the police who bought this. I don’t think I should go into maybe the specifics of the case, only on the basis I’m not sure if I can, you know, within this framework or not, but –

Ms Hodge: Well, let me ask you this: in relation to the exoneration, you said that a criminal prosecution was brought?

Calum Greenhow: Yes.

Ms Hodge: At what stage was the subpostmaster exonerated?

Calum Greenhow: I think it went to court and it was thrown out.

Ms Hodge: Okay, so it will be a matter of public record. Did you or any of your colleagues have any concerns about the manner in which that case was investigated or the way in which the prosecution was conducted?

Calum Greenhow: Yes, but, as say it wasn’t done by the police – sorry, it wasn’t done by the Post Office; it was done by the police, and I was concerned as to the way the police were going about it. They seemed to just look at the postmaster as guilty until proven otherwise. Hence, the reason when they came to us, I know we need to get some legal advice here, and I was directed to a solicitor who would be able to help because it was down south and, obviously, my connections are north of the border and obviously a different jurisdiction, and I have to sort of say I was delighted in the way that the solicitor approached it, how they engaged with the NFSP, how they sought the NFSP’s help and guidance in relation to things, and just how they approached the postmaster with the greatest of respect and support right the way through.

And the stress that that postmaster was under was colossal but thankfully, ultimately, the right decision was made.

Ms Hodge: But to be clear, in this particular case, your concerns related to the conduct of the police force –

Calum Greenhow: Yes.

Ms Hodge: – the officers investigating –

Calum Greenhow: Yes.

Ms Hodge: – rather than the Post Office?

Calum Greenhow: Yes, the Post Office really didn’t have anything to do with it, as far as an investigation is concerned.

Ms Hodge: You say in your statement that your relationship, the relationship of the NFSP, with the leadership of the Post Office is very strained?

Calum Greenhow: Yes.

Ms Hodge: You suggest there remains a lack of trust in the senior management and Board of the Post Office –

Calum Greenhow: Yes.

Ms Hodge: – and you cite as an example what you say was a failure by the Post Office to be open and honest with the NFSP about the extent of the problems that were being encountered in the project to replace Horizon; is that correct?

Calum Greenhow: Not just the NFSP but other postmasters who were present.

Ms Hodge: Can you expand, please, on that?

Calum Greenhow: Well, there was another group of postmasters who were present. So there was myself and my Chair, Tim Boothman, who were present at that, and there were other postmasters who were present.

Ms Hodge: At that meeting you were told what?

Calum Greenhow: That there had been problems with the New Business IT, but these had been overcome and that we were on track and we’ve got a strategy ahead.

Ms Hodge: Why do you characterise that as displaying a lack of transparency?

Calum Greenhow: Well, given the fact that the very following day Computer Weekly gave a completely different story, the accurate story, that there are serious, serious concerns within Government in relation to how the programme is being developed, the cost of the programme, not only is it behind schedule it’s being taken in-house, I can’t remember exactly what the department within Government it’s being looked at but it’s all to do with – I do mention it in my statement – but it’s the part of Government that looks after all the major infrastructures like HS2, et cetera, that’s looking after it.

I think there was a Government Audit Team that had looked at it and highlighted grave concerns so there was nothing along those lines.

Kind of ironically, my wife and I had been given tickets to Chitty Chitty Bang Bang, and we were sitting in the theatre and on the break, and I looked at my phone and up came the report from Computer Weekly. I read it, I immediately emailed Nick Read and said, “What the heck’s going on here? This is not what you told us yesterday”. That resulted in a conversation on the Friday with the Head of IT Services within the Post Office and I simply said, “Listen, if I was the new Chair and you had told me what you told me on Wednesday and, on Thursday, I’ve learned what I’ve learned, what do you think the conversation would be today?”

That’s it. I mean, you had the most senior individuals within the Post Office, from an executive point of view in that meeting, bar obviously Al Cameron, who was the Chief Financial Officer, and basically what the NFSP and other postmasters were told was not accurate.

Ms Hodge: In your statement, you say that you believe the problem lies in the governance of the Post Office?

Calum Greenhow: Oh, without question, yes.

Ms Hodge: But you don’t believe that the creation of the Subpostmaster Non-Executive Director is the answer to that problem; is that right?

Calum Greenhow: I think it brings a conflict on the basis that they have their own businesses, potentially directors within their own businesses and, therefore, they have to act in the interests of the business of which they are a director. It is possible, you know, they can’t vote on a number of things, particularly in relation to remuneration? So I don’t think it necessarily is the answer, no, and unfortunately, you know, you have to listen with great empathy and sympathy as to what both those two Postmaster Non-Executive Directors have gone through.

They have tried everything they possibly can to try to help this business turn around but this business is not prepared to listen and it’ll do anything and everything to undermine anybody who threatens its position of power, authority and influence.

Ms Hodge: Your proposed solution to the problem is the establishment of an oversight committee; is that correct?

Calum Greenhow: Yes.

Ms Hodge: Can you please explain briefly what your proposal is in that respect?

Calum Greenhow: So it’s actually quite common on the continent and I – you know, back in 2022, I was sitting thinking, what can we do? I was understanding that the governance was the problem and I really felt that the relationship between Government and Civil Service and Post Office was the fundamental problem that had resulted in this scandal happening and everything was being done just to push it down the line, push it down the line, push it down the line.

So we needed to have a situation where we could have a body that would sit alongside. It’s not to replace, it’s not to slow things down or obfuscate things but actually to sit alongside and hold the Post Office to account.

Because the reality is, in my view, as I look back on it, unfortunately, I don’t think Government have actually held Post Office to account and let me explain why.

Back in 2018 the Post Office Board set a strategy and that strategy was to ensure – to defend the indefensible and ensure that the victims remained guilty and they knew that there was a problem but they still went ahead with it. And that would have been done with the knowledge, in my view, of Government, because there’s a Government representative on the Board.

After everything had taken place, not one Director of the Board was asked to step down or looked at themselves in the mirror and went, “Yeah, we got this wrong”. They all carried on. Indeed, the Chief Executive, whilst she left the business, left with a golden goodbye, a CBE and a job in the Cabinet Office. That’s hardly an indication of the owner of the shareholder thinking that the Board had made the wrong decision and given what came out right across the two – the Common Issues and the Horizon Issues judgments, never mind the recusal.

So I felt that the relationship between Post Office, the Civil Service and Government was where the problem was. And I also think that, as a postmaster, as an – I am an investor – well, I’m not a postmaster now, so apologies, but I am – my postmaster colleagues are investors in this business and, over the last 30 years, I’ve seen decision, after decision, after decision that has resulted in the security in the viability of their businesses being undermined and reduced. Postmasters’ income has declined from – in ‘21 it’s gone from 48 pence in the –

Ms Hodge: Mr –

Calum Greenhow: Sorry. So put all of that together, put all that together, I just feel we need to have another body that can actually hold the Post Office to account and can work alongside it. And it’s quite common, as I say, on the continent. So that’s what we came up with.

Ms Hodge: Okay, so that’s the background. What is your proposal in relation to the composition of this committee?

Calum Greenhow: So Government need to be on there, obviously they’re the shareholder. Obviously those who are the representatives, so Unite, who represent the management of the Post Office; the CWU, who represent the employees of the Post Office; the NFSP who represents postmasters. But I do think it’s also really important we bring on consumer champions because it’s about – you know, the Post Office has a social purpose. So what is it that society needs? What is it that the community needs from the Post Office?

The Government are making decisions that are having a detrimental impact; post offices are closing right around the country; postmasters are no longer able to afford to run their businesses; communities are being left without post offices; services are being taken away; and we need to bring those community champions or those consumer champions on so that Government, when it’s making decisions, actually understand what consumers need, rather than, in essence, decisions being made that actually have a detrimental impact on communities the length and breadth of the country.

Ms Hodge: What I’d like to fix on, Mr Greenhow, is how to you envisage this proposal for an oversight committee bringing about change in the culture of the Post Office, that being your primary concern, underlying a lot of the other matters that you –

Calum Greenhow: Yeah, well, given the fact that Government will be on that committee, then you’re basically saying to the Government, “You’re the shareholder, you own this is business. Here’s the evidence that things are not right. We’ve got to put that right”.

If I go to –

Ms Hodge: Can I just pause you there. What you’ve just said, essentially, is that you would like to have direct access to the Government to be able to communicate the concerns of the organisation and the concerns of your members to ministers; is that the essence of it?

Calum Greenhow: Well, yes, I think what we need to sort of be able to sort of do is there is – to our knowledge, there is no strategy for the Post Office going forward. There isn’t one. And, to our knowledge, there really hasn’t been one for a significant period of time. Now, Post Office might say something different. Just saying that’s our view. And, therefore, I think those who represent the employees and the postmasters, but also consumers, need to be able to work with Government, the shareholder, to ensure that there is a strategy in place for the good of this business. Well, where things are being done wrong, there is a body there that can actually highlight this, and actually bring this to the surface and hold Post Office to account. That was the problem in the past.

All of this was getting done – we talked earlier on about transparency – this was all getting done behind the scenes, between the Government the Civil Service and the Post Office and, as a result of that, this was kicked down the – sorry, the can was kicked down the road. There wasn’t sort of the ability for it to really be brought to the surface. It was suppressed, suppressed, suppressed.

And I think, with an oversight committee, we’ve got the opportunity to – if there is anything like this happens again, it’s going to be brought to the surface, and Government won’t be able to obfuscate it. They won’t be able to just brush it under the carpet.

Ms Hodge: You’ve mentioned in your statement that you’ve contributed to a tripartite working group comprising of the Postal Affairs Minister and his Department, the Post Office and the NFSP; is that correct?

Calum Greenhow: Yes.

Ms Hodge: Does your proposal for an oversight committee reflect a concern that that Working Group is not providing adequate governance of the Post Office or contributing to adequate governance of the Post Office at present?

Calum Greenhow: Well, I mean, we talked just briefly about NBIT. I have been trying to get the Head of IT to come along to that tripartite working group so that they are – he is providing an update within that forum as to how this is progressing. He’s never appeared. He’s never sort of come to it, and I don’t know why. Every single time I ask for NBIT to be on the agenda, but it’s not. I’m asking about what we can do to improve remuneration for postmasters and not seeing anything.

I’m not seeing anything that is giving me confidence that the Government and the Post Office after working for the benefit of postmasters. It’s just – it’s as if – it’s a talking group, it’s a talking shop. There’s nothing there that’s giving me confidence that we are actually working together for the good of the future of this business. And that, I feel, sort of, is indicative of how things have been.

I do believe that, behind the scenes, Government and Post Office are talking and are working and – but I don’t know what it is, I don’t know what they’re doing, I don’t know what plan they have, and I’m worried about it and so are my colleagues.

Ms Hodge: I think you’ve explained in your statement that you brought your proposal for an oversight committee to the Working Group –

Calum Greenhow: Yes.

Ms Hodge: – is that correct? What is the current status of that proposal?

Calum Greenhow: Again, I describe in my statement that the Minister asked us in January to – for the Post Office and the NFSP, to work together and bring it back to him. The very first meeting that I had, I was told by the then Chief Retail Officer that the Post Office has no desire to change its governance whatsoever. Well, that kind of tells you a story. I had to really sort of push back to that individual and I don’t think he’d ever been spoken to in that manner by anyone before, not that I was disrespectful but it was just the fact that I was going, you know, “You’re an employee of this organisation and if the Minister tells you to do something, you’ve got a duty to do that, and going against the wishes of the Minister is not something that a senior employee of the Post Office should be doing”.

Where we are at this moment in time, yes, there are discussions as far as potential governance proposals. Obviously, I wasn’t aware that the Post Office had commissioned Grant Thornton to look into governance of the Post Office. That’s obviously come out now via the Inquiry, and all of this was going on before. So I’ve been trying to push for a change in the governance of the Post Office at least for two years now and it’s good to see that we are starting to make some progress.

If I may, I’m not saying that it’s – the oversight committee is the only way. I’m not saying that if it’s not my way, I’m not playing. But I do think we need to seriously look at the governance of the Post Office because I think that is where it’s fundamentally broken down for – over such a long period of time that has resulted in so many people having their lives ruined.

Ms Hodge: Thank you. My final topic, Mr Greenhow, is the current policies, that is to say the written policies of the Post Office, in relation to audits, investigations, suspensions and other decisions. Now, you say in your statement that the NFSP was invited by the Post Office to comment on drafts of the whole suite of policies governing this whole area, that is to say the conduct of audits –

Calum Greenhow: Yes.

Ms Hodge: – investigations and decision making in relation to the suspension and termination of the subpostmaster’s contract. In your statement you say that you’re – and forgive me, that’s something which you are now doing on an annual basis – is that correct –

Calum Greenhow: Yes.

Ms Hodge: – viewing and providing comments –

Calum Greenhow: Yes.

Ms Hodge: – upon the policies. You –

Calum Greenhow: I have – if I may, although I was personally dealing with it, along with another colleague, obviously the work that I’m doing as far as the Inquiry has taken up so much of my time, I’ve had to step back from that at this moment in time and delegate it to other individuals within the NFSP.

Ms Hodge: You identify in your statement two areas of concern that you have in relation to the existing policies. One relates to what is known as the audit reporting script; is that correct?

Calum Greenhow: Yes.

Ms Hodge: That’s a script, is this right, to be used by the Post Office auditor –

Calum Greenhow: Yes.

Ms Hodge: – to address their first interactions –

Calum Greenhow: Yes.

Ms Hodge: – with the subpostmaster or his staff –

Calum Greenhow: Yes.

Ms Hodge: – at the point at which they come to the –

Calum Greenhow: Yeah.

Ms Hodge: – branch to carry out an audit?

Calum Greenhow: Yeah.

Ms Hodge: Can we look, please, at your statement at paragraph 326, page 117. Thank you. You say there:

“… we have raised concerns about the Audit Reporting Script, we did suggest an alternative script which the postmaster or OIC …”

Can you explain that reference, please?

Calum Greenhow: Officer in charge.

Ms Hodge: Thank you:

“… would be required to sign with a copy retained by the postmaster. Part of the opening script informed the postmaster or [Officer in Charge] that the NFSP was available for help and support. Additionally, we suggested a checklist for the postmaster and [the officer in charge] to follow given the potential stressful situation that may be dealt with. This would enable notes to be taken for reflection afterwards.”

You say:

“Sadly, this was rejected by the Post Office on a number of occasions.”

Were you given reasons as to why your proposals were rejected?

Calum Greenhow: It’s not what they wanted to do.

Ms Hodge: Secondly, in the following paragraph, you mention some reservations you have about the role of the Decision Review Panel; is that correct?

Calum Greenhow: Yes.

Ms Hodge: If we could turn, please, to the Decision Review Policy, that’s contained at POL00088892. Thank you. This is version 2.3. At page 3, please, paragraph 1.3, under the heading “Core Principles” it states:

“A challenge will be heard by a review panel who will have no prior it in the circumstances which led to the termination and the challenge being raised.”

So this a proposal, effectively, for a level of independent review of the decision to terminate the subpostmaster’s contract; is that correct?

Calum Greenhow: My understanding, yes.

Ms Hodge: On page 7, please, at paragraph 2.4. Under the heading “Roles & Responsibilities”, it provides this in relation to the review panel, it will be a panel of:

“… external members, who are responsible for deploying the procedures set out in this policy and for making a final decision on the review requested by the postmaster. The Review Panel will be supported by the Contract Investigation & Resolution manager to:

“[Firstly] apply Post Office’s underpinning behaviours of fairness, transparency and professionalism;

“[Secondly] be fully conversant with this policy and linked policies;

“[Thirdly] gather as much information as possible relating to the background behind the termination;

“[Fourthly] complete a Termination Decision Review Rationale Document before making a decision in consequence of a challenge. The rationale document is a report which includes facts and findings of the investigation, and the rationale used to determine the outcome;

“[Fifthly] to ensure any decision arising from a challenge is made in line with all other Post Office policies …

“[Finally] ensure this policy is adhered to and the postmaster is treated with fairness, transparency and professionalism throughout the process …”

If we could go, please, to page 12, under paragraph 3.2, we see there an explanation of the role of the review panel. It provides:

“It is the role of the Review Panel to ascertain whether the decision to terminate was taken in compliance with the relevant contract and requirement set out in section 3.1.

“Any investigation must be a fair and unbiased method of investigating the issues raised in the challenge. The process of investigation allows the Review Panel to establish facts relating to the issues raised and gives the postmaster the opportunity to identify and answer any points or queries raised by the Review Panel. The Review Panel may have to undertake further enquiries as a result of any new and/or additional information provided as part of the decision review process.”

Just pausing there, the nature of your concern, as I understand it, relates primarily to the composition of that panel; is that correct?

Calum Greenhow: Yes.

Ms Hodge: Now, I don’t believe we see the composition of the panel defined in this policy document. Why are you concerned about Post Office’s proposals in relation to who will sit on this review panel and make a determination?

Calum Greenhow: Yes, well, my understanding is it would consist of two senior Post Office employees, a non-voting chair and a postmaster, and we felt – and we see this in a lot of the processes that the Post Office are putting in place, they’re bringing postmasters into, in essence, a decision-making place, and we feel that that’s placing those postmasters in a potential position of harm, on the basis of, if something did go wrong, the Post Office is then able to turn round and go “Well, we had postmasters there, they said it was okay”.

I don’t think that’s fair, for postmasters who may be entering into these situations in good faith, and I don’t think it’s – you know, the Post Office have still got too much control over it and hence the reason we would prefer to see a proper mediation to the process with CEDR or ACAS, so that, if it gets to that situation, it’s taken out of the Post Office’s hands, in essence, and it’s someone else who is making the decision, just as the Postmaster Non-Executive Directors discussed earlier on this week.

Ms Hodge: So your proposal is for some form of formal mediation –

Calum Greenhow: Yes.

Ms Hodge: – is that correct? Who in your view should be responsible for funding that process?

Calum Greenhow: Well, the Post Office.

Ms Hodge: Thank you. I’ve no further questions for you, Mr Greenhow. If you could remain there –

Calum Greenhow: Thank you.

Ms Hodge: – the Chair may have some questions for you and I believe there are some questions from some of the Core Participants.

Sir Wyn Williams: Well, let’s have the Core Participants, please.

Questioned by Ms Patrick

Ms Patrick: Good afternoon, Mr Greenhow. My name is Ms Patrick and, together with Mr Moloney, we ask questions on behalf of number of postmasters who were convicted and have since had their convictions quashed. You’ll be happy to know I only want to ask you about two documents and two issues.

Calum Greenhow: Yes.

Ms Patrick: The first issue, is about the pre-GFA relationship between the Post Office and the NFSP?

Calum Greenhow: Yes.

Ms Patrick: I want to look at one document, it’s POL00021485. Now, just before it comes up I’ll tell you what it is. It’s not a document we would have expected you to see at the time.

Calum Greenhow: Oh.

Ms Patrick: It’s a Board minute from the Post Office from 2004.

Calum Greenhow: Ah.

Ms Patrick: So before your time. I just want us to have a look at it together. You see on the first page, just to confirm, there’s meetings of the Board, 13 October 2004. The section I want to look at is on page 13, so if we could scroll to page 13 I’d be very grateful.

It’s the section at the bottom half, so if we can go to the bottom half of the page and stop there. If we can scroll a little bit back up, I’d be grateful, thank you. Now can you see that section there headed “Subpostmaster exhibition”?

Calum Greenhow: Absolutely.

Ms Patrick: It says, “David Mills reported”, and there’s a little bit of a conversation there about a subsidiary of Hayes Travel being offered a stand at a subpostmaster exhibition to promote a Bureau de Change product. There’s a little bit about a conflict of interest potentially, and it says:

“The Board agreed that:

“It was both damaging and inappropriate for a direct competitor of Post Office to be accommodated at the exhibition in this way.”

The second bullet point:

“Post Office Limited would reconsider the subsidy provided to the NFSP if they continued to undermine the position of Post Office Limited”, and then they go on with a few other things, the next steps they’re going to take, having suggested their concern.

Now, this suggests that, even in 2004, there were some subsidies being paid by the Post Office to the NFSP, doesn’t it?

Calum Greenhow: It does.

Ms Patrick: As far as the Post Office at least was concerned from this, one of the potential levers the business held was in the manipulation or the use of the subsidies, wasn’t it?

Calum Greenhow: Yes.

Ms Patrick: Now, you’ve said today that the problem lies in the controlling culture of the Post Office and how that’s reflected in its relationship with subpostmasters and with the Federation?

Calum Greenhow: Yes.

Ms Patrick: Is that kind of attitude, that problematic culture, reflected in this minute?

Calum Greenhow: I would say so.

Ms Patrick: Yeah. Is it indicative of that kind of historic problem in the relationship that you’ve told the Inquiry about today?

Calum Greenhow: Well, obviously back in 2004, I was just an honorary member. So I wasn’t really involved in the NFSP in any way, shape or form at that point. However, I would suggest, as I did read this, prior, that this gives an indication of how long the manipulative behaviour of the Post Office has existed.

Ms Patrick: If we can be really frank, this is a relationship between the NFSP and the business, the Post Office?

Calum Greenhow: Yes.

Ms Patrick: That relationship was always going to be one where the interests of the Federation as a whole would be at the forefront of the organisation and perhaps something that would be difficult to put before the interests of a small group of subpostmasters, no matter how catastrophic the damage to that small group might be.

Calum Greenhow: Well, I think if you – and I don’t know where it is actually in my written statement but, when you not – long after this in 2006, there is the evidence in relation to the Green Giros and, at that point, the NFSP threatening to take legal action against the Post Office for its actions against postmasters.

So no, I wouldn’t necessarily agree with you but what I can’t turn round and say at this point in time is, as I’ve indicated before, the simple reality is the NFSP of the past believed the Post Office and put their faith in the Post Office, rather than believing and putting their faith in postmasters.

Ms Patrick: Okay.

Calum Greenhow: It’s particularly in relation to this case, and it is – and, again, I put it in my witness statement – that it’s sad in one sense that, despite the fact that through the branch and regional network, the information came to the Executive of the Post Office who acted upon it, but it doesn’t appear that when it comes to this situation, that that unfortunately happened.

So again, you know, I offer my apologies to those victims.

Ms Patrick: Okay. If we can move on to the second issue, thank you. It’s a point about the position of the NFSP during the GLO, litigation?

Calum Greenhow: Thank you.

Ms Patrick: You’ve gone over the information with the Counsel to the Inquiry at some length; I only want to look at one point. If we can go back, this morning you described attending the first day of trial –

Calum Greenhow: Yes.

Ms Patrick: – and not being able to afford private support to Mr Bates having missed him in the corridor during a break?

Calum Greenhow: Yes.

Ms Patrick: You said your colleagues at the NFSP were following the trial, including daily updates being put online by Mr Wallis on his blog –

Calum Greenhow: Yes.

Ms Patrick: – and, of course, it was important that the organisation was following what was going on, wasn’t it?

Calum Greenhow: Yes.

Ms Patrick: Might you have dipped into the blog yourself?

Calum Greenhow: I did on occasions, yes.

Ms Patrick: Now, I’m just going to have a quick look at the Common Issues judgment for the one point that I want to ask you about it, and it’s POL00112043. If that could be brought up, I’d be grateful, if it can’t, you can trust me that I’m reading from it.

Calum Greenhow: Which paragraph is it within there?

Ms Patrick: It might help you, Mr Greenhow, we’re going to look at the two paragraphs you said that initially you paid particular attention to this morning, paragraph 574 which is on page 185, and I’ll start reading and it may appear, because I think this paragraph and the paragraph after may be very familiar to you. I can see you’ve got the hard copy, which is very helpful.

Calum Greenhow: Yes.

Ms Patrick: It’s under the heading, “The Post Office’s relationship with the NFSP”.

Calum Greenhow: Yes.

Ms Patrick: It says, “subject relevant for the following reasons”, and it’s the first part of 574 I want us to look at:

“The Post Office relied in numerous places, both in its evidence and in its submissions, upon the fact that the NFSP does not support the litigation.”

Calum Greenhow: Mm-hm.

Ms Patrick: It gives an example:

“As an example, in its written opening it is submitted, ‘It should be noted that the National Federation of SubPostmasters, the NFSP, which is the organisation which represents subpostmasters and their interests Nationwide, does not [‘not’ underlined] support this action and does not endorse the factual premises of the claims.”

If we can skip down to the next paragraph, down to 575, it goes on again:

“Public support for a cause or a lack of NFSP support for the claimants does not cut much ice in court.”

Calum Greenhow: Mm-hm.

Ms Patrick: “It plays no part whatsoever in the outcome. I have already referred to public and press interest in this litigation for the reasons explained, and that plays no part either. I’m entirely disinterested in whether the NFSP does or does not support the proceedings. However, for the two reasons identified, and because some of the Post Office witnesses, for example Mr Beal, dealt with NFSP involvement, and it was relied upon by the Post Office, it was of sufficient relevance to permit Mr Green some limited cross-examination on this subject.

“It should also be noted that Mrs van den Bogerd also gave ever that the NFSP has publicly supported the Post Office’s view that Horizon is robust. The Post Office therefore relies upon this support by the NFSP to support its stance in this litigation.”

Now, I just have a few questions for you, having read it, and I’m sorry that it’s not come up on screen for everyone. Did the NFSP have any discussion internally during the trial when it became clear that the Post Office was relying on their lack of support for the GLO claimants?

Calum Greenhow: I don’t think so I think the first time that I became aware of this was when I read it. However, I was present in court when Mr Beal said what he said, and I thought, “Well, that’s strange. Where’s he got that from?” Obviously I’ve learned now, this side of the GLO, exactly where it came from and, obviously, my predecessor was very much supportive of the Post Office’s position but I don’t think that was necessarily indicative of everyone within the NFSP, but certainly was indicative of his viewpoint.

Ms Patrick: You can see there, and you’ve said again, your view points weren’t necessarily indicative of your predecessor. But you were in charge by this time, and here was – perhaps not unsurprisingly – the Post Office relying expressly in the litigation on the publicly repeatedly-expressed position of the NFSP that Horizon was considered to be robust.

When that became clear, did it become clear to you during the trial?

Calum Greenhow: I don’t think it did, no.

Ms Patrick: So had the NFSP taken a position that it was going to be studiously and positively neutral, without a clear appreciation of the case that the business was going to run against its former members?

Calum Greenhow: You know, as I’ve already sort of explained, we just felt – you know, I was new to the role, and we were – we were not involved in the case. We didn’t know what was being said, really, so we didn’t know the inner workings of it. We could sort of see what was being said.

Ms Patrick: Can I just stop you there, Mr Greenhow. The NFSP position really wasn’t really truly neutral was it? You were really just letting the Post Office do what it wished with your name, holding your peace and waiting to see where the chips fell?

Calum Greenhow: Sorry, I don’t agree with that.

Ms Patrick: In the circumstances of what happened, where the Post Office was actively reliant on the lack of support from the NFSP, where your colleagues were monitoring the proceedings in the trial from the blog covering the daily events, where you turned up to court on the first day without expressing any support for those 555 GLO claimants, where you couldn’t manage to reach out to Mr Bates on the day, despite seeing him across the room, can you appreciate that your position was seen by them as very far, far away from neutral?

Calum Greenhow: Yes, I can see that but that honestly wasn’t sort of the case, and I think the evidence that’s been presented, to the kind of viewpoint that I was taken to before, gave an indication that my viewpoint was different to that of my predecessor. But that’s as much as I can say.

Ms Patrick: Did you ever say that on the record, before the judgment was handed down?

Calum Greenhow: I don’t think I did, no.

Ms Patrick: Thank you. No more questions, Mr Greenhow.

Questioned by Mr Stein

Mr Stein: Mr Greenhow, my name is Sam Stein. I represent a large group of subpostmasters who have been affected by the Post Office scandal.

Now, during the evidence this week, we heard the questioning of Mr Ismail, Saf Ismail.

Calum Greenhow: Yes.

Mr Stein: During the course of that, there was discussion regarding a letter written on 17 May this year from Mr Patterson of Fujitsu. Now, that letter – and I’ll quote it from the evidence – states that:

“To be clear, Fujitsu (FSL) will not support the Post Office to act against subpostmasters. We will not provide support for any enforcement actions taken by the Post Office against postmasters, whether civil or criminal, for alleged shortfalls, fraud or false accounting.”

The letter goes on to say:

“It seems that the Post Office may be continuing to pursue permits for shortfalls in their accounts using Horizon data. We would have expected that the Post Office has changed its behaviour in light of the criticisms and is appropriately circumspect with respect to any enforcement actions.”

Then, lastly, Mr Patterson of Fujitsu says this:

“It should not be relying on Horizon data as the basis for such shortfall enforcement.”

I’ll repeat that last bit. So Mr Patterson, middle of May 2024, is saying the Post Office should not be relying on Horizon data as the basis for such shortfall enforcement.

The date of that letter is 17 May 2024. Was the NFSP told about the content of that letter from Fujitsu?

Calum Greenhow: The first time I became aware of it was as it was read out in court and I immediately contacted some colleagues and said “Horizon is no longer reliable, what does that mean in relation to what we do as far as any shortages?” And my – it really concerns me because it shouldn’t be a case that any postmaster, whether it’s 20 quid, when they do their trading period, that they put that 20 quid in. That is a huge question.

Mr Stein: It goes to two issues, doesn’t it: the one you’ve just been speaking about that affects postmasters in their branches –

Calum Greenhow: Yeah.

Mr Stein: – where there is a shortfall –

Calum Greenhow: Yeah.

Mr Stein: – and, as we know from the YouGov report, people are still paying up for shortfalls?

Calum Greenhow: Yes.

Mr Stein: So where there are shortfalls, it should have been made clear, do you agree, immediately –

Calum Greenhow: Absolutely.

Mr Stein: – that the data from Horizon was unreliable and unreliable for the pursuit of shortfalls?

Calum Greenhow: Yes.

Mr Stein: The second part that that particular information in May of this year affects is the question of ongoing investigations into postmasters –

Calum Greenhow: Yeah.

Mr Stein: – for the obvious reason that, if the police are carrying out, at this moment in time, an investigation into any subpostmaster, they should have been informed immediately in May 2024 that the Horizon system was, as ever, unreliable for the purposes of providing data to support investigations; do you agree?

Calum Greenhow: Yes, I do, and if I may to go back to what said earlier on, I’ve tried to get the Government to do a full review of Horizon. But there is a refusal to do that because Post Office are telling Government that Horizon is robust.

Mr Stein: During this Inquiry we’ve considered what’s happened when investigations into individuals, subpostmasters, have been the result of a failure of disclosure. We’ve seen what’s happened.

In May this year, the Post Office was told that Fujitsu’s Horizon system should not be used as the basis for investigations, considerations for shortfalls, yet nobody is told about it; is it same old, same old for the Post Office.

Calum Greenhow: It would appear so in that case, yes.

Mr Stein: Now, I’ll turn to a different point, if I may. You make a point in your statement regarding the question of Network Transformation –

Calum Greenhow: Yes.

Mr Stein: – and its impact upon subpostmasters, branches and, indeed, I think your own branch right?

Calum Greenhow: Yes, we will be losing our branch on 11 October.

Mr Stein: Help us understand a little bit more how that’s connected to Network Transformation because, if we go back in time, Network Transformation is a while ago. Why is that still having an impact; why is that having an impact on your branch and others in terms of closing them?

Calum Greenhow: So Network Transformation was a programme that was – a Government programme that started in 2012 and it ran to 2018. In 2018, when the programme finished, there was about 700 postmasters who were classified as Hard to Place and my own office was one of them, the reason being is that no one was wanting – there was no potential new postmaster who was coming forward to take on the business. As I’ve already explained in 2015, my wife and I had to make the very difficult decision not to sort of carry on – or not convert to the local model, because we felt – sorry, I might be speaking too quickly here – we felt that it was – it would not make financial sense to do that.

Sadly, in 2023, in February 2023, the Post Office came along and they presented good news to me that they were going to shut all of the remaining Hard to Place and at that time there was about 130 of them, and the reason that I was given that was because of the NBIT coming in by March 2025. They did not wish to put that group of postmasters through the training and also the investment, as far as the equipment is concerned. So they were going to be closing those offices, leaving those offices without potential provision.

But they also stated that they were going to change the exit compensation that postmasters would receive from 26 months down to 12 months, which would result in those postmasters losing, on average, £43,000, which is obviously a significant amount of money, depending on the stage of life that you happen to be.

Many of those colleagues were well beyond state retirement age and had underlying health issues that meant that they shouldn’t be working and – but yet the Post Office’s attitude was, “We’ve made our Board decision, that’s what’s happening, and we’re not prepared to shift in any way, shape or form”.

The only concession that we could get was that, at the start of this year, they would put boots on the ground, as they said, and they would go round the remaining offices to see if someone would be willing to take on the office within the community. Unfortunately, I’ve said in my statement there was 30. That is now 40 postmasters who are going to be in a situation, ten have already closed, 30 are in the process of closing, and as I’ve said, my office will close on 11 October.

May I just sort of say this point – and it’s important – because I think it’s important to not just hear but to colleagues who may be listening to this: it’s been said on some social media groups that I may have accepted a deal from the Post Office and I want to make it clear that in no way shape or form have I accepted any financial agreement from the Post Office, that benefits me to the detriment of my fellow colleagues. I would never do that.

Mr Stein: Did Network Transformation, and the issues you’ve discussed, did that have an unfair or unequal impact upon smaller branches, family branches, in rural areas or areas of lower population?

Calum Greenhow: I wouldn’t go as far as to say that but what I would say is that the way that business is being run today, I would say that the new services that are coming on tend to be going to the larger offices. So, for example, Evri that’s coming on, Amazon, DPD, a lot of the banking is actually done within the larger offices and that’s meaning that more rural, urban, post offices are not getting those services. They are losing income. So we are seeing a disproportionate – those who are doing quite well versus those who are struggling.

Mr Stein: Now, the Post Office has a social aspect, in terms of social provision of services within the community.

Calum Greenhow: Absolutely.

Mr Stein: Within the Government funding requirements, there are requirements to ensure that there are certain numbers of branches within given areas and head of population?

Calum Greenhow: Access criteria, yeah.

Mr Stein: Repeat that, please?

Calum Greenhow: Access criteria.

Mr Stein: Now, in terms of the access criteria, where you are looking at a branch in an area perhaps of low population density, which would tend to mean lower footfall within the Post Office branch, is that reflected, that lower income into the branch, is that reflected in the income from the Post Office to the subpostmaster?

Calum Greenhow: Well, yes. What we’ve got is a situation that, if we were to go back to 2013, the average income to a postmaster was about £42,000. It’s now down to about 35,000. That’s the average income to a postmaster. If you take inflation into account, obviously that’s going to be significantly lower.

Mr Stein: But just make sure we understand, and perhaps I missed it because I was being given a piece of information, but in the smaller branches, is there a funding, if you like, bias towards those branches?

Calum Greenhow: Yes.

Mr Stein: Right.

Calum Greenhow: Now, some of them will be, for example, my own office, still receive what’s known as – well, it was known as core tier payment, but it’s now called an assigned office payment, which is, in essence, a basic flat remuneration, and then we get paid a commission on each transaction that we do.

Mr Stein: Right. When was that last reviewed?

Calum Greenhow: It’s that – the review for the assigned office payment is usually done on an annual basis and that is usually linked to inflation, and that is something that the NFSP have negotiated with the Post Office and got in place.

Mr Stein: Okay, and can you just confirm that the DBT are reviewing the National Transformation Scheme?

Calum Greenhow: No, they’re not, and I think they should. As you know, we have launched a campaign, as far as Network Transformation is concerned, because having – you know, having been part of this Inquiry for so long and listening to what is being said, I came to realise, in one sense, two things: that the organisation back in 2012/2015, that was doing everything it possibly could in relation to the Complaints and Mediation Scheme was exactly the same organisation that was implementing Network Transformation.

Too often, I was hearing from colleagues that they felt as if they were being cajoled or forced or bullied into converting to one of the models, and that has led to their financial detriment.

Now, I’ve described in my statement that I am a qualified mortgage adviser, not practising any longer, so I can’t use the – I’m not qualified – I’m not authorised, as you’d say, but I am qualified. And I know under that that you have to be qualified and authorised to give financial advice. Well, did that constitute financial advice? When the Post Office came in and said, “Right, okay, we think’s a good idea for you to move or convert” or whatever, was that constituting financial advice?

So I think the Government should really do a full review, how that review is done, whether that’s a judicial review or legal review, or whatever it is, but do think Government has to look into that and investigate whether the activities and the actions and the culture of the Post Office has led to the detriment of postmasters under the Network Transformation programme.

Mr Stein: Okay. Last topic, should be quite short. Throughout the Inquiry we’ve been pursuing the question of the helplines.

Calum Greenhow: The helplines?

Mr Stein: The helplines, the Post Office helpline and then the Fujitsu helpline. The questions that we’ve been pursuing, as you’re well aware is whether those helplines have actually provided any help at all or are they, in fact, the unhelpful lines, okay? Now, we know through the YouGov report that people are still having difficulties with the Horizon system; people are still experiencing shortfalls; they are still paying off shortfalls, okay? Does the NFSP receive information regarding the helplines, the calls that are being made, the way that they are dealt with and trends being expressed within those helplines?

Calum Greenhow: Not that I’m aware of.

Mr Stein: Why not?

Calum Greenhow: Good question. That’s –

Mr Stein: Have you asked for that?

Calum Greenhow: I’m not aware if we have, actually, to be honest.

Mr Stein: Well, that sounds like a no.

Calum Greenhow: No, okay.

Mr Stein: Do you agree it will be helpful if the NFSP and any other organisation had access to the data and is being provided across the helplines, the scripts, the complaints, the concerns being expressed to those helplines, as far as it is possible to get them cleaned of any confidential information?

Calum Greenhow: Absolutely.

Mr Stein: Is that a matter that you’re going to undertake to take up with the Post Office?

Calum Greenhow: Leave that with me. You can be assured that that will be done.

Mr Stein: One minute.

Thank you.

Questioned by Ms Allan

Ms Allan: Good afternoon, Mr Greenhow. My name is Christie Allan and, as you’re aware, I represent Core Participant Susan Sinclair, who was the first subpostmaster to successfully appeal her conviction in Scotland.

I just have a few questions for you today. At paragraph 174 of your first witness statement, you state that:

“On the back of the mass exoneration legislation proposed by the UK Government earlier this year, the NFSP made several attempts to initiate a meeting with the Scottish Justice Minister and the Lord Advocate but to no avail.”

Calum Greenhow: Yeah.

Ms Allan: Can you please elaborate on your attempts to meet with these individuals: when did you first contact them, what; was the format of your communication; and have you been successful in receiving any kind of response?

Calum Greenhow: Well, we’ve received a response, which I think is within the core bundle and I can’t remember the very specific details of it, but I think you’ll have been able to read that. But as far as, you know, trying to get to the Lord Advocate and the Justice Minister of Scotland has proved difficult. I think they’ve obfuscated that down the line.

I have to say, in contrast, we sent the same correspondence at the same time to the counterparts within Northern Ireland, who very graciously invited us to meet with them and they were very clear about their desire to be included within the new legislation that the Government introduced. But we’ve heard nothing from the Scottish Government or the Lord Advocate on that basis.

Ms Allan: So there’s no proposed meeting at the moment with the Lord Advocate?

Calum Greenhow: No.

Ms Allan: In recent months, the Lord Advocate in Scotland has publicly confirmed that she and the Crown Office in Scotland is committed to addressing all miscarriages of justice and that she to achieving justice for those impacted and that she is committed to reflecting on whether anything could have been done definitely by prosecutors in Scotland?

Is this reflective of the NFSP’s experience of the personal commitment by the Lord Advocate to get to the bottom of the events which gave rise to this scandal in Scotland?

Calum Greenhow: As you know, obviously the process in Scotland is different than it is down here, and it’s something that has kind of perplexed me, I have to sort of say, and again, I’m talking about someone who is non-legal. But much has been made about the fact that the Post Office can do private prosecutions. But coming from Scotland, I’m aware that obviously that can’t be done and, when you look at the proportion of people who have been convicted in Scotland, in comparison to the rest of the country, it’s not disproportionate.

So you kind of have to question what has gone on within Scotland that’s different to down here. Because you would – I would have hoped that, actually, given the fact that the Procurator Fiscal has to take it – and I hope right in saying that – so the evidence is presented to the Procurator Fiscal, who then sort of looks at it and determines whether a case will still be brought, rather than the Post Office being able to obfuscate all of that and bring it. There would have been less people in Scotland, but it doesn’t seem to be the case, and I think that’s a fundamental question that the Lord Advocate needs to sort of like answer, as to why there is as many people within Scotland who have been victimised on a proportional basis as there has been sort of down here.

But I do think it’s really important that, when it comes to exonerating these people and making sure that they get their redress that they deserve, that happens as quickly as possible, and it’s really important that the Scottish Government and the Lord Advocate get that sorted.

Ms Allan: That brings me on to my final question: according to information provided by the Scottish Cabinet Secretary, Angela Constance, earlier this month, only two out of a possible 141 affected subpostmasters have thus far been written to in accordance with the terms of the mass exoneration legislation in Scotland and, indeed, that the Scottish Government is apparently still in the process of assessing the 141 possible cases. In your view, what more should be done in Scotland at this time and by whom?

Calum Greenhow: Ooh, that’s a good question. I don’t know the answer to that one, to be honest. I’m sorry. But I think the Lord Advocate – you know, at the end of the day, the Lord Advocate is the most senior person within the legal industry within Scotland, so you’d have to sort of say the responsibility lies with her. I think it’s a her. So, on that basis, I think that’s where it should start.

I think what is worrying is my understanding is that, when it comes to the number of people – the people who have been convicted, actually they’re not necessarily aware of who the people are. There’s a lot of people that they just don’t know who – they know there’s been convictions but they don’t know who they are or where they are. And that’s really worrying because there could be people sitting at home – and I think this is maybe something – and I hope I’m not talking out of turn here – I am not sure whether we can just exonerate someone, give them some money, “Job’s done, see you later, on you go”.

I don’t think that’s enough because I do think that there are people out there who are broken: emotionally, physically. As a result of that, they have absolutely no trust within the authorities of this country. It has left them broken, and I do think that there has been an attempt – maybe attempt is the wrong word – but there has been, well, a kind of thought process, “Well, if we’d just say sorry, we exonerate them, give them some money, everything is fine. Everything in the garden is rosy”, and I don’t think that’s going to be the case.

I think this is going to live with people for the rest of their lives, irrespective of whether they are exonerated and get compensation.

You know, one of the other things that is going on at this moment in time or has just completed is the infected blood scandal. Okay, so we say sorry, we give them the compensation. You can’t cure hepatitis on that basis. These people unfortunately – and I know people who have sadly – whose families have been impacted by that. You can’t just get away from that.

Ms Allan: So, in short, more work needs to be done in Scotland?

Calum Greenhow: Oh, absolutely without question. Sorry.

Ms Allan: Thank you, Mr Greenhow.

Questioned by Sir Wyn Williams

Sir Wyn Williams: Mr Greenhow, in respect either of Scotland – just Scotland – or in relation to all parts of the United Kingdom, do you think that the NFSP has a role to play in speeding up the exoneration process? I’m not asking you that just in the abstract but, in particular, in relation to providing any information that you may hold about former members who were convicted.

Calum Greenhow: Listen, if there’s anything that we can do to help, we will. I think we’ve shown through this Inquiry just exactly how much time and effort that we have given to this Inquiry. If you’ve asked for any information, we’ve given you the information. We’ve volunteered information, even that we haven’t been asked for. If there’s anything we can do, we will do it. We just –

Sir Wyn Williams: Well, I think this wouldn’t be the Inquiry seeking information from you; this would be if it’s practical. I’m asking you an open-ended question: if it’s practical for the NFSP to search its records for former members who were convicted and provide those names to whichever authority it is, in whichever country of the United Kingdom.

Calum Greenhow: I don’t think we know, actually, that’s the problem.

Sir Wyn Williams: You don’t know either?

Calum Greenhow: We don’t know either, that’s the problem. I mean, one of the aspects and one of the things that sort of concerns me about all of this is, when it came to a conviction, the NFSP were not involved. That’s not – that’s beyond our remit. That’s within, dare I say it, Sir Wyn, within your remit. That’s within the legal industry. That, you know, so –

Sir Wyn Williams: Well, hang on a second –

Calum Greenhow: We didn’t get involved. We didn’t get involved.

Sir Wyn Williams: Hang on a sec. I would have expected, I should say, not imagined, that if a member of the Federation had, in fact, been convicted of an offence related to their work as a subpostmaster, the consequence would be that they’d cease to be a subpostmaster but also cease to be a member of the Federation, and I just wondered whether you’d have any records of that kind?

Calum Greenhow: No, I think we certainly weren’t told the reason why they were no longer a postmaster. So we – I don’t think we know and, certainly to my knowledge, there hasn’t been any correlation work done, at the time, to why someone stopped being a postmaster and whether there was actually a court case was the reason behind it. So, unfortunately, I don’t think we know.

If there’s anything we can do then –

Sir Wyn Williams: That’s fine. Yeah, fine.

Any other questions?

Ms Hodge: Sir, I think that concludes –

Sir Wyn Williams: Well, then thank you very much, Mr Greenhow, for your participation to date, which I’m sure will continue. I think I’m right in saying that you have been seeking to assist the Inquiry throughout all its phases, including the non-statutory phase of it, so I’m very grateful to you for that and, obviously, I’m very grateful for your detailed witness statement and your oral evidence today.

The Witness: Thank you.

Sir Wyn Williams: So Ms Hodge we start again at 10.00 tomorrow morning?

Ms Hodge: I believe so, sir, yes.

Sir Wyn Williams: Fine. All right, thanks very much.

Ms Hodge: Thank you.

(3.20 pm)

(The hearing adjourned until 10.00 am the following day)