Official hearing page

6 June 2024 – Alice Perkins

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(9.45 am)

Alice Perkins


Questioned by Mr Beer (continued)

Sir Wyn Williams: Mr Beer.

Mr Beer: Thank you, sir.

Good morning, Ms Perkins.

Alice Perkins: Morning.

Mr Beer: Yesterday we were examining the extent to which some material did not get disclosed to, or summarised for, the Board. I just want briefly to examine whether there were other things going on in the business in relation to Fujitsu that may be relevant to why that disclosure or summary did not occur and to get your assistance on this if possible.

Can we look, please, at POL00297877. If we scroll down, please, this is an email from Tim Franklin to Alwen Lyons, copied to you. Can you help us, Tim Franklin?

Alice Perkins: I haven’t seen this email before – this email exchange before, I don’t think.

Mr Beer: I think you have?

Alice Perkins: You think I have?

Mr Beer: It’s part of the pack, yes.

Alice Perkins: Okay, I’ll take your word for it.

Mr Beer: But anyway.

Alice Perkins: Tim Franklin was one of the Non-Executive Directors on the Board.

Mr Beer: Thank you. He says, “Chris”, which presumably is Chris Day.

Alice Perkins: Yeah, I would think so, yes.

Mr Beer: “… thanks for the updated information relating to the IT Transitional Services Agreement.”

Can you recall what that was?

Alice Perkins: I think this is to do – if I’m right about this, this is to do with the fact that we were – we believed that we were going to be transitioning away from Fujitsu to a different provider but it was going to be difficult to manage that transition and, over the period in question, we had to extend the arrangement with Fujitsu to provide us with, if you like, a kind of bridge to the new arrangements. I think that’s how I would describe it.

Mr Beer: I see:

“I am in agreement with the proposal as I don’t see we have any choice. Horizon is a complex Fujitsu proprietary system and any move other than renewal would present unacceptable risk. I agree with Lesley’s future review and the potential to mitigate our Fujitsu dependency in the future. I do feel like they have us over a barrel, and that they know it. I’m not clear how much we have tried to play hardball with them, but I would hope that these numbers represent our maximum financial exposure, and that we will seek to negotiate below this. If they want a future role in our IT estate, they should want to be less exploitative of us now.”

Is what we read there about the relationship, or Mr Franklin’s view of the relationship, between Post Office and Fujitsu representative or indicative of the Board’s view of the relationship between Post Office and Fujitsu at that time, which is July 2013?

Alice Perkins: Yes, I think so and I would say, you know, over a longer period.

Mr Beer: Did you ever link this, what’s said here, back to your initial discussion with Angus Grant back in September 2011, where he told you, I think, that the relationship was too nice and that the Post Office had been naive or too naive? Was that a constant, essentially, over that period of time, September ‘11 to July ‘13?

Alice Perkins: Absolutely, all the way through, I would say. I think that, as the different non-executives came on Board, they, you know, reached the same view. We all wanted to move away from Fujitsu altogether and, when I left the Post Office in 2015, I believed that that is indeed what would be happening but it subsequently turned out that they were unable to extricate themselves.

Mr Beer: Was this any cause for concern, this understanding of a relationship of dominance or an unequal power relationship in circumstances where the Post Office was continuing to rely on Fujitsu for data and analysis to support its work with Second Sight?

Alice Perkins: So I think the concerns were definitely about an imbalance of power and, yes, I think we were sceptical; we were sceptical about all sorts of aspects of the Horizon – of the relationship with Fujitsu.

Mr Beer: This records that the system was complex and proprietary –

Alice Perkins: Yeah.

Mr Beer: – and that Fujitsu had the Post Office over a barrel. Was that a relationship that the Post Office had essentially inherited from Royal Mail Group?

Alice Perkins: I think so, yes. I mean, certainly, that was how I felt. Whether I would have said they had – I think I might have said they had us over a barrel. I certainly came to that view early on and I now understand that it did – you know, it did go back really from the very, very outset but I didn’t understand that at the time.

Mr Beer: Against that background, how would you assess the executives’ feeling about delivering news to the Board that a Fujitsu expert, who had given evidence, written and oral, in criminal proceedings, was considered to be tainted or an unsafe witness and had breached their duties to the court in a manner which may have caused prosecutions brought by both Royal Mail Group and Post Office to have been undermined?

Alice Perkins: Could you go back to the beginning of the question, sorry?

Mr Beer: Yes. How would the executives have felt about delivering news to the Board –

Alice Perkins: Yes, okay, yes.

Mr Beer: – that a Fujitsu expert witness may have given false evidence to courts?

Alice Perkins: Well, I think that a number of the executives shared the Board’s view about – I mean, obviously they wouldn’t have said they thought that Fujitsu had got them over a barrel but my understanding was that the senior executives were in agreement with the Board that we wanted to move away from Fujitsu. I think everybody shared that aspiration. So –

Mr Beer: What I’m trying to explore is whether this may be a reason or relevant to the non-revelation of information to the Board?

Alice Perkins: So I think what I’m trying to get to here is, since everybody was agreed that we’d rather not have Fujitsu as a very significant IT partner, I’m not sure why that would have – I mean, maybe I’m being really stupid here but I can’t really see why that would affect executives’ ability or willingness to share that information with the Board one way or – in fact, it might be an argument for, you know, “We’re not sure we can trust – this another reason why we’re not sure we can trust them”.

So I think you could argue it either way.

Mr Beer: Thank you. That can come down.

Can I examine a little further the continued fallout from the Second Sight Report –

Alice Perkins: Yes.

Mr Beer: – and, in particular, looking at the Board’s approach as to whether the Second Sight Report opened it up to legal challenge, by looking at POL00344895. Can we start, please, at page 2, and scroll down. An email from you – we’re now March 2014 –

Alice Perkins: Mm-hm.

Mr Beer: – to Paula Vennells and Alwen Lyons, about Sparrow:

“Following our helpful conversation, I am setting out what I would like on this for further substantive discussion at the March Board meeting.

“1) The definitive view on all aspects of insurance ie organisational and personal. What policies do we have; what in practice do we believe they will cover us for; and what have we been doing to fulfil our obligations under our policies?

“2) Are we safe from legal challenge in what we are/have been doing? What is the position both since we became independent and before?

“3) What is the worst case in relation to costs which could result from this”, et cetera.

Now, you’ve been asking, as a Board, I think, questions of insurance coverage for both the organisation and individual members of the Board since mid-2013.

Alice Perkins: Yeah.

Mr Beer: It seems like you hadn’t got an answer, at least a definitive answer, by this time; is that right?

Alice Perkins: Yes.

Mr Beer: If we go, please, to the reply, which is at the foot of page 1, from Alwen Lyons. She says:


“Apart from making sure the business are ready to answer these questions is there anything else you would like me to do.

“The insurance issue is with Chris [Day] and I did push for clarity to be included in the B48 email without success.”

I don’t know what that means. Let’s go up to see what you reply. You said:

“What is B48?!”

Alice Perkins: I’m no wiser.

Mr Beer: Yes:

“Maybe you can help by explaining to everyone what the context is here.

“The position is intrinsically worrying (to put it politely). The [Non-Executive Directors] are really concerned because of the potential costs to the business, the distraction from implementing our strategy (which is demanding enough), the reputational issues, and their personal positions. A bad combination made far worse if the business does not appear to be on top of it. So the paper needs to demonstrate that the Board’s concerns on the latter point [presumably that is their personal positions] – if that is possible. That means it needs to be comprehensive, clear and professional.”

Then there’s an issue about a non-attendance at James Arbuthnot’s meeting.

Alice Perkins: Mm.

Mr Beer: So I think this chain shows us that, by March 2014, you and the Board were still not clear, seemingly, on what the insurance situation was both for the company and for Board members?

Alice Perkins: Yes.

Mr Beer: Were there concerns, essentially, on behalf of Royal Mail that you’re expressing –

Alice Perkins: To be –

Mr Beer: – as well as Post Office?

Alice Perkins: I can’t say that – I can’t remember that there were, if I’m honest.

Mr Beer: Can you help us: the Second Sight Report had, from the Post Office’s perspective, been presented as a positive one?

Alice Perkins: Yes.

Mr Beer: No system-wide, ie systemic, issues had been found, albeit there were some process problems –

Alice Perkins: Yes.

Mr Beer: – concerning, in particular, training and support. Why was there a continuing concern about the individual liability of Board members if there were no problems with the Horizon system?

Alice Perkins: I don’t remember very much about this discussion about the insurance side of things. I think that it was put on the agenda by other non-executives. I can’t remember exactly but I think that Alasdair Marnoch certainly was interested in this subject, at least in part because he was the Chair of the Audit and Risk Committee and that’s the natural place for that to be – you know, the first port of call, I think, for that issue.

And I think, from what I remember, that the thing that was beginning to get in the way for the Non-Executive Directors was actually the delay in answering the questions, rather than the questions themselves, if you see what I mean.

Mr Beer: Not really. Why would you have a continuing concern over the individual liability of Board members, ie their personal positions and the need to nail down insurance as protection, if there wasn’t a belief that individual members of the Board may be open to liability?

Alice Perkins: I think there was a question in people’s minds, some people’s minds, about whether members of the Board might be vulnerable in some way and that question, having been put on the agenda, it was obviously in everybody’s minds and I do remember over a very long period it just wasn’t – didn’t seem to be possible to get definitive advice about this and it became frustration in itself that we couldn’t get clear answers.

Mr Beer: Given the continuing concerns – you first raised personal liability of Board members for civil claims for wrongful prosecution in July 2013 –

Alice Perkins: Yes.

Mr Beer: – and we’re now in March 2014 –

Alice Perkins: Yes.

Mr Beer: – in the interim, had the Board asked any more questions about why there may be claims against them, given the positive – generally positive – outcome of the Second Sight Interim Review?

Alice Perkins: Well, during the intervening period, you’ve got the beginning of the Mediation Scheme and you’ve got – I’m sure we’ll come on to this – something that was called the expectation gap between what it began to emerge subpostmasters and the people representing them thought might be on the table in relation to the Mediation Scheme and what the Post Office thought the outcome of the Mediation Scheme in individual cases might be. And I think that this concern was part of the story.

So you don’t have a situation where the Interim Report has come out and we’ve had the view of that, and then nothing happens. You’ve got a continuing story, if you like, because of the setting up of the Mediation Scheme and what’s beginning to emerge as people make applications to go into that and it becomes clear – clearer what it is they’re hoping to get from it.

Mr Beer: Do I understand you to mean that you didn’t think that there were claims or were not advised that there were claims that had merit, but you were more concerned about claims that lacked merit being brought against the company or the Board?

Alice Perkins: Both, I would say. I think we would always have been concerned that there might be claims that had merit and that we would need to deal with those, but we also, as I’ve said, believed that the Horizon system was sound and we thought that the legal side – the work that ought to be being done, in relation to past prosecutions – was being done and was being done properly.

Mr Beer: I’m just trying to understand how it is that there is this focus on liability of the company and the Board, which seems to be a continuing concern even into March ‘14, in the light of the positive Second Sight Report, when we know that lurking underneath are a series of advices that would expose the company to liability, that may expose Board members to personal liability but they’re not revealed to you. It’s as if two conversations are going on at the same time –

Alice Perkins: Yes.

Mr Beer: – in parallel; do you understand?

Alice Perkins: I understand. That’s very clear, thank you. I do understand.

Mr Beer: What you’re saying in these email exchanges is not motivated by, or a reflection of, you knowing about the other thing that hadn’t been revealed; is that right?

Alice Perkins: Absolutely right, yes.

Mr Beer: So I’m trying to understand what it was that was motivating you to continue to explore the extent of the Board’s own liability and the insurance position?

Alice Perkins: Yes.

Mr Beer: If it wasn’t knowledge of the Jenkins problem, what was it?

Alice Perkins: Well, I’m sorry to repeat myself but, if the Board asked a question or people or somebody on the Board asked a question, then it was important to me that the business answered that question and I – and I think I wasn’t alone in this – I found it very strange that it was taking this amount of time to get the answers to what seemed like relatively straightforward questions.

And I think that, by this time, we were starting to have some reservations about the way in which Chris Day was performing his responsibilities and this was a part of – we just – we didn’t feel, at any rate, that he was on top of this aspect of the job and we didn’t seem to be able to get anybody else to give us the answers, and that was frustrating.

And I think we were, you know – somewhere in people’s minds was always the thought that, you know, we knew that people were interested in bringing claims against us and you never know, when that happens, what the outcome might be. So I think, you know, it was a precaution – on the part of the non-executive members of the Board, it was a precautionary approach.

Mr Beer: If we go back to the document we were just displaying, POL00344895, and look at page 2., and scroll down, your second question:

“Are we safe from legal challenge in what we are/have been doing? What is the position both since we became independent and before?”

Why wasn’t the Board – why weren’t you – asking to see the external lawyers’ advice?

Alice Perkins: Because – well, I think it depends which bit of external lawyers’ advice we’re talking about here.

Mr Beer: Any.

Alice Perkins: So we knew that Brian Altman has – had been asked to give advice and we were given, at various points, some – well, I won’t call them “summaries” because they weren’t – as I now know, they weren’t really summaries. We were given a view of what was in that advice and I’m sorry to say that I believed, and I think the other Non-Executive Directors believed, what we were reading in those papers about what was being said and we could have asked to see that advice, you know, the original documents and, if we had, the story might have been very – well, I think the story would have been very, very different.

But, you know, given what we were being told, we accepted it and we had – I think, if you, you know, if we try to put ourselves back into the shoes who were reading that advice at that time, that wasn’t unreasonable.

Mr Beer: Thank you. Can I move to a new topic. You suggested in your oral evidence yesterday, and suggest in a number of parts in your witness statement, that, in your view, Susan Crichton was substantially to blame for the failure to provide the Board with relevant information and documents?

Alice Perkins: Yes.

Mr Beer: Can we turn to POL00108058. This is an email exchange of August 2013 between you and Paula Vennells.

Alice Perkins: Mm.

Mr Beer: In the email that we can see at the foot of this page here you say:

“Yes. It is the fact that she …”

You’re talking about Susan Crichton here.

Alice Perkins: Mm.

Mr Beer: “… sees so much as beyond her control which made me most worried. It is her alibi. That is why I pushed back and also why I asked her to flag up if there was anything she needed which she couldn’t get.”

Then you go on to talk about another issue. What did you mean by “It is her alibi”?

Alice Perkins: So I was talking there about the subject which we discussed yesterday, which was the fact that we’d got to a position where the Interim Report from Second Sight came not completely out of the blue but came very, very unexpectedly to the Board in the run-up to its publication, and the Board’s concern as to how that had happened, linked with the other issues that the Board was concerned about, the length of time the work was taking, the costs, and so on. So that’s what I was talking about there.

Mr Beer: What do you mean by “alibi”?

Alice Perkins: That –

Mr Beer: An alibi is normally if you’re accused of a crime –

Alice Perkins: Oh, I see what you’re saying, yes, yes.

Mr Beer: – or accused of wrongdoing –

Alice Perkins: Yes, yes, well –

Mr Beer: – you have an excuse or a reason to put yourself somewhere else –

Alice Perkins: Yes, yes.

Mr Beer: – and, therefore, say, “I can’t have committed the crime” –

Alice Perkins: Yes.

Mr Beer: – or “I can’t have undertaken the wrongful conduct”.

Alice Perkins: Yes. So I think an “excuse” would have been a better word. “Alibi” does sound as though – as you say, as those it’s linked to a crime –

Mr Beer: I’m not suggesting that you were here talking about Susan Crichton committing a crime at all. I am just seeking to understand what you meant by the use of the word “It is her alibi”?

Alice Perkins: So what I think I’m saying here is that I didn’t, and the Board didn’t, think that Susan had done that aspect of her job well, that when I had had my conversation with her, she had talked about – she had given me a variety of reasons as to why it hadn’t been possible for her to anticipate in the way that we would have liked what was going to – you know, the events leading up to the publication of the Interim Report and I thought that she was very passive, and I think that’s really what I was trying to say here.

Mr Beer: Does this show contemporaneous knowledge by you of a failure by Susan Crichton to do what she should have done in her job?

Alice Perkins: In that respect. Not in the respect of her having concealed documents from us because –

Mr Beer: That’s what I was going to ask you about.

Alice Perkins: Sorry.

Mr Beer: Did you have any suspicion that she was deliberately not flagging potential concerns to you or to the Board?

Alice Perkins: Absolutely not. I had no idea.

Mr Beer: Thank you. You raise in your witness statement that one of your achievements, I think, in your time at the Post Office, was replacing a large number – in fact, I think every member – of the Executive Committee, except Paula Vennells.

Alice Perkins: Well, actually, it was – the two people on the –

Mr Beer: Kevin Gilliland?

Alice Perkins: I beg your pardon?

Mr Beer: Kevin Gilliland as well?

Alice Perkins: Kevin Gilliland and Nick Kennett, who was the Financial Services Director.

Mr Beer: Can we look, please, at UKGI00042089. These are the minutes of a Post Office Investment Review Committee. Can you see the attendees there?

Alice Perkins: Yes, I can.

Mr Beer: Just looking at that, of what would this be a committee?

Alice Perkins: I never had anything to do with this committee. I probably heard about it at the time. There were various committees inside the Business Department. This looks to me like a Shareholder Executive committee. Richard Callard was, at that time, the Non-Executive Director on the Board representing the shareholder; Roger Lowe was one of his colleagues, possibly his boss; Tim McInnes was, I think, on the Post Office – in a separate part of the Business Department, on the Post Office team; and the other names, some of them I recognise and some of them I don’t. I think they were all officials in the Business Department.

Mr Beer: I see. So we should read this as not a committee of Post Office but a committee either of the Department or of ShEx?

Alice Perkins: Yes. I mean, I may be wrong. It’s possible that there is somebody in this list who was in the Post Office but I don’t think so.

Mr Beer: Thank you. Can we go forwards, please, to page 3 and under “POL Management”:

“The [Shareholder Executive Post Office] Team outlined that certain key vacancies have been filled over the course of the past year and a more appropriate management structure has been implemented. Yet, vacancies have also arisen”, et cetera.

Alice Perkins: Yes.

Mr Beer: Next paragraph:

“The Review Team also discussed the suitability of the current management team (ie capability and capacity) and in particular whether Paula Vennells was the right person to hold the CEO position long term. Questions were raised and it was agreed that a confidential and internal review would be undertaken to assess her suitability.”

Did you know this was going on?

Alice Perkins: I don’t think so.

Mr Beer: Can we look, please, at some slides in the Department’s Audit and Risk Committee from February 2014, so that’s the next month. UKGI00042677. I think this makes it much clearer that this is not the Post Office –

Alice Perkins: Okay, yes. I think so too.

Mr Beer: – this is the Department and the Shareholder Executive.

Alice Perkins: Mm.

Mr Beer: This is the Risk and Assurance Committee, or at least a presentation to it, of February 2014. Can we go to the second page, please, left-hand column underneath number 1:

“Advice from the recent Annual Review suggested that the [Post Office] team give careful consideration to the continued suitability of Paula Vennells as CEO.

“There is a general consensus that Paula is no longer the right person to lead [the Post Office] but justification is anecdotal.

“This short paper aims to examine the options available to [the Shareholder Executive].”

Then, on the right-hand side, under “Why is Paula’s position under review?”, at the bottom, the Committee was told:

“However, the 2010 plan, which admittedly was not hers failed to deliver the expected revenue growth, and the Network Transformation has required politically awkward revisions to remain deliverable.

“Paula has not shone an understanding of political considerations (ie presentation of plan to ministers) or of the detail of the plan, and she has been unable to work with the personalities that provide robust challenge to her.”

Then there is a third point.

Did you know that it was seemingly the view of a team presenting to the Department and the Shareholder Executive that Ms Vennells had been unable to work with people that provided robust challenges to her.

Alice Perkins: I don’t think I did, no. These papers, when I saw them, are complete news to me.

Mr Beer: Was that your view: that Ms Vennells had been unable to work with people who provided robust challenges to her?

Alice Perkins: No, I don’t think that was my view. You know, there was certainly some tension between Susan Barton, whose name appeared on the previous document and Paula. I think their working styles were very different and Susan was – I mean, she was a very, very able person and she did a very, very good job and she was robust, and I think that there was some tension between the two of them. I’m not aware – I’m just trying – let me just think about this for a second as to whether I was aware of that sort of tension with other people in her team.

Mr Beer: I’m really asking you whether it was your view that Ms Vennells preferred to have yes-men and yes-women –

Alice Perkins: No, I don’t think that’s fair.

Mr Beer: – around her, surrounding herself with a coterie of trusted lieutenants: Mark Davies, Angela van den Bogerd, Lesley Sewell, for example?

Alice Perkins: I don’t think that would be a fair characterisation.

Mr Beer: Did you have any concern that she had been unable to work with people that provided robust challenges to her?

Alice Perkins: I didn’t have that concern, no.

Mr Beer: Can we go forwards, please, to page 5. A series of options are outlined, one of which is, essentially, release her from her role now; the next of which is retain but review after a period of time.

Alice Perkins: Mm.

Mr Beer: Then we’ll go on to see that another one is a retain until the natural course of events that she wishes to move on.

“Retain and review”, you’ll see, if you just briefly scan what’s said on that page –

Alice Perkins: The whole of this page?

Mr Beer: Yes, I mean, this is just to give you some context.

Alice Perkins: Okay.

Mr Beer: Given this isn’t a committee of which you were a member.

Alice Perkins: Thank you. (Pause)

Yeah. Thank you.

Mr Beer: Then, over the page, please, moving to the option of “Remove”, on the left-hand side of the page:

“There is a general feeling that Paula is not the optimal person to lead [the Post Office] to deliver its commercial strategy.

“[She] has not been able to establish good working relationships with Jo Swinson …”

That was the Minister at the time.

Alice Perkins: It was.

Mr Beer: “She has been unable to retain key staff.”

Did you hold any of those three views?

Alice Perkins: At this point in time –

Mr Beer: March 2014 – February 2014 –

Alice Perkins: I – sorry?

Mr Beer: February 2014.

Alice Perkins: Yes. In this period in 2014, I did start – and I wasn’t alone in this – to have reservations about Paula’s ability to lead the Post Office in the circumstances which it found itself in.

Mr Beer: Is it right to say those concerns included a doubt as to her personal grip, specifically on Horizon issues?

Alice Perkins: Yes, and it went beyond that. I mean, that was the example – that’s illustrated by the setting of that personal objective, which I’m sure is what you’ve got in mind, but the concern about the grip went wider than that.

Mr Beer: So just to summarise – I’m not going to go to the documents – for the 2014/15 year, you set as one of her objectives for that year a specific personal objective in relation to the need to give priority to Horizon issues?

Alice Perkins: I did.

Mr Beer: You tell us in your witness statement that at this time you had doubts as to her personal grip on Horizon issues and the level of attention that she was giving them?

Alice Perkins: Yes.

Mr Beer: That’s paragraph 180. What were your concerns about the level of attention that Ms Vennells was giving to Horizon issues?

Alice Perkins: I think that I felt that she was relying too much on her colleagues.

Mr Beer: Which colleagues?

Alice Perkins: Executive colleagues, so this –

Mr Beer: Any in particular?

Alice Perkins: Um … well, in this – in the context of Horizon, this would have been IT and Legal, primarily, and that – I’m just trying to find a way of describing what I meant by not having – because you’re asking me about whether I felt she relied too much on other people; that was the question?

Mr Beer: Yes.

Alice Perkins: Yes. I think that I felt that there was too much passing on of other people’s views and that, when she talked, say, to the Board, gave an update to the Board, that what he was relying on were words that other people had written for her, rather than her own words, perhaps that’s the best way of putting it.

Mr Beer: Thank you. On the right-hand side, under “Performance as CEO and delivery of strategy plan”, there is a repetition of the point:

“[The Post Office] failed to deliver its 2010 strategic plan, and refused to keep the Government properly appraised of developments in the [Network Transformation] programme, requiring difficult revisions in 2013. [Paula Vennells] has shown a worrying lack of knowledge about the detail of the new plan.”

Then this:

“Paula’s people management has caused concern as she appears unable to work with personalities and approaches that differ from hers …”

Just stopping there, is that a concern that you shared?

Alice Perkins: I don’t think that was – that wasn’t one of my concerns, other than, as I say, there was this tension between her and Susan Barton, I recognised that.

Mr Beer: Do you know where the department and ShEx would get information, that enables them to reach a view like this, from?

Alice Perkins: Yes, I think they would have got it from a number of sources.

Mr Beer: Being?

Alice Perkins: So Richard Callard, as I’ve already said, was a Non-Executive Director on the Board and, therefore, would have seen Paula operating in the context of the Board, would have heard conversations, would have been party to conversations that I and the other Non-Executive Directors were having because he was one of us, in that sense. There would have been feedback, I’m sure, from the Minister and the Minister’s office, and there would have been interactions with officials at different levels in the department. So I would think those would be the three main sources.

Mr Beer: On that last one, where you say, “there would have been interactions between officials” do you mean officials within the Department and ShEx, on the one hand –

Alice Perkins: Yes.

Mr Beer: – and then Post Office personnel on the other?

Alice Perkins: Exactly, yes.

Mr Beer: I see. The sentence continues:

“… and [she] has failed to build relationships with key Directors.”

Was that a view that you held in February 2014?

Alice Perkins: Other than – I’m sorry, I keep repeating myself. I mean, I was aware of the issue with Susan Barton but I don’t remember there being a – my being aware of this in relation to other directors, no. So I don’t quite understand where that’s coming from.

Mr Beer: Next bullet point:

“Paula’s performance as CEO has been questioned by [the Post Office] Chair, and by members of the Board.”

Had you spoken to the Department or ShEx about Paula’s performance?

Alice Perkins: As I say, Richard was party to this. I would have – I had conversations from time to time with various people in the Department, including Mark Russell, who was the Head of the Shareholder Executive, and I can’t remember – you know, I haven’t got notes of those meetings but I’m sure this would have come – this would have been a topic of conversation on a pretty regular basis because, after all, it was one of my – you know, the key aspects of my role.

Mr Beer: By “other members of the Board”, to your knowledge which other members of the Board had questioned her performance?

Alice Perkins: I think everybody had, by this stage.

Mr Beer: Thank you. That can come down.

Did you ever advise Ms Vennells that, if you wanted an answer to a question, you should tell the person that you were asking the question of the answer that you wanted to hear and then, essentially, get them to either confirm what you said was right or persuade you that you were wrong?

Alice Perkins: I have absolutely no recollection of saying that and it’s not – I simply cannot imagine circumstances in which I would have said that.

Mr Beer: Ms Vennells told us that when she was preparing for the Select Committee, on 3 February 2015, she sent an email which said “What’s the true answer?”, which was about the facility for remote access:

“I hope it is we know that this is not possible and we are able to explain why that is. I need to be able to say no it’s not possible and that we’re sure of this because of XXX.”

She told us that the phrasing of the email, the framing of it, “We need to say this is not possible”, was specifically because you had told her that, if you want to get to the truth and a really clear answer from somebody, you should tell them what it is you want to say very clearly and ask for the information that backs that up. Is that true; did you tell her that?

Alice Perkins: No. I think I might have said to her, you know, if you want to know something is true, you need to be really clear about what the proposition is.

Mr Beer: That’s a very different issue.

Alice Perkins: Yes.

Mr Beer: Thank you. Can we move forward to the Post Office’s conduct during the Mediation Scheme and its attitude –

Alice Perkins: Sorry, could I just say one other thing on that last conversation?

Mr Beer: Yes.

Alice Perkins: I’m – it’s a surprise to me that these sorts of detailed conversations were going on and that nobody told me that they were going on at the time. And I think that is – I just find that rather extraordinary, that, you know, I was aware of these reservations that I and my fellow Board members had, and I would know that Richard would be party to that, and I knew that the Minister had some reservations, but I had absolutely no idea that there was this machinery inside the department that was having these conversations, and I just find that quite surprising.

Mr Beer: Thank you. Can we then turn to Post Office’s conduct during the Mediation Scheme proper and its attitude towards the subpostmasters in the Mediation Scheme. Can we start with some advice that Sir Anthony Hooper says that he gave I think in February 2014, by looking at POL00100335. These are the minutes of a meeting with Sir Anthony Hooper. You can see who is in attendance: you’re not.

Alice Perkins: Yeah.

Mr Beer: If we go down to paragraph 4:

“TH [that’s Sir Anthony Hooper] agreed that [Second Sight] were very resource challenged, and it would be difficult for them to meet the current timetable. That said [Sir Anthony’s] view was that [Second Sight] were trying to be objective and that they had a difficult path to tread … in order to do their job properly (in his view) they would need to express an opinion on the merits of each claim. In [Sir Anthony’s] view, this was something that they found hard to do. Some concern was expressed by [Paula Vennells] and [Chris Aujard] that [Second Sight] had not in their correspondence come across as independent, and may be unduly influenced by the need to satisfy certain MPs.”

Alice Perkins: Mm.

Mr Beer: In his evidence to the Inquiry in relation to this paragraph, Sir Anthony said that he had communicated the following to you and Ms Vennells –

Alice Perkins: Yes.

Mr Beer: – “The Post Office’s case didn’t make sense. It didn’t make sense that reputable subpostmasters, appointed by the Post Office after an examination of their characters, would be stealing these sums of money but it didn’t make sense, in particular, because, in a matter of days of any ‘alleged’ theft, they had to balance the books. It just never made sense. I made that point over and over again.”

Did Sir Anthony make that point to you, whether over and over again, or at all?

Alice Perkins: Not at all.

Mr Beer: Do you recall having conversations with Sir Anthony?

Alice Perkins: I recall I had a meeting with him shortly, very shortly after he’d been appointed, which was a sort of – I hadn’t been part of the selection process, Alasdair Marnoch was the non-executive who was involved with that and, after he was appointed – and I think just after he’d had the very first meeting of the Working Party – he and I met and, as far as I’m aware, that is the only time I ever actually met him.

Mr Beer: He didn’t say, on that occasion, that the Post Office’s case didn’t make sense, in that, on Post Office’s view of the contract, they had to balance the books and make good any shortfalls of any losses within days of the losses occurring?

Alice Perkins: He didn’t say that to me. I would have remembered if he’d said that to me and when we met it was very, very early days, so it would have been surprising if he had come to any sort of clear view. I think we were talking about, you know, as it were, the future, rather than about what he had already found, because it was very early days.

Mr Beer: Then over the page, please, to paragraph 6:

“[Sir Anthony’s] strong contention was that [the Post Office] should take no precipitous action until such time as [Second Sight] had produced, say, 5 reports, and until we had seen their thematic report. He noted the adverse [public relations] consequences of terminating … and offered to make himself available to the Board …

“The quantum of the compensation payments was discussed. [Sir Anthony] noted that the applicant’s CQRs often painted a very distressing picture, where there had been loss of livelihood, and other losses. His view was that, should the evidence show that [the Post Office] that not acted properly, then the amount of compensation payable could be quite material (… this contradicts legal advice obtained by [Post Office] from [Bond Dickinson] which categorically states that the maximum loss [Post Office] could expect … would be limited to 3 months ‘pay’ under the subpostmasters’ contract). It was not entirely clear whether [Sir Anthony] had in mind criminal cases only when he had made these comments.”

Was this passed on to you: that Sir Anthony’s view was that the amount, the quantum of potential compensation, could be material, ie substantial?

Alice Perkins: No.

Mr Beer: Was it ever explained to you that there was a difference of view between the advice Bond Dickinson had given and that being explained by Sir Anthony?

Alice Perkins: No.

Mr Beer: I think, in the next month, Post Office took advice from Linklaters.

Alice Perkins: Yes.

Mr Beer: Can we turn to a Board meeting on 26 March 2014, POL00021523. These are the Board minutes for 26 March 2014. You will see that you’re present. Can we go, please, to page 2 at the foot. Thank you. Under (k):

“The Board agreed that they needed to commission a piece of work, to complement that undertaken by Linklaters, to give them and those concerned outside the Business, comfort about the Horizon system. The Business was asked to revert with the terms of reference and timescale for the work which [would] cover:

“The work undertaken by Angela van den Bogerd explaining how the system works;

“A review of the data integrity aspects of the system;

“A reference to all audits and tests carried out on the system;

“A response to the most significant thematic issues raised by Second Sight.

“These terms of reference should be tested with Linklaters to ensure this work would satisfy them as evidence that Horizon is reliable and then agreed by the Board Sparrow Subcommittee.”

Just go back to the previous page, at the foot – thank you – why did the Board wish to obtain a piece of work to give it, or Linklaters or those concerned outside the business comfort?

Alice Perkins: So, at this time, there were continuing questions about the Horizon system and we – and the Board was unclear about what the level of exposure of the Post Office was to claims, and I referred earlier this morning to the different perceptions of people going into – applying to go in to the Mediation Scheme and the Post Office as to what amounts of money might be payable, and –

Mr Beer: I’m thinking more of the phraseology, Ms Perkins.

Alice Perkins: I am coming to that. So, got – sought this legal advice on what the exposure was. The legal advice was delivered on the basis – needed – in order to deliver their legal advice, Linklaters said that they wanted to be confident about the safety of the Horizon system and they were not happy about the quality or the nature of the work that Second Sight had done. So they were – and we haven’t looked at that – I mean, there are – I think in these minutes there are quotations from the Linklaters partner.

Mr Beer: We’re going to go to the –

Alice Perkins: Yes, I’m, sorry, I’m anticipating.

Mr Beer: Yes.

Alice Perkins: But we had heard at this Board meeting that the Linklaters partner was sceptical about the work that had been undertaken by Second Sight and thought that a different kind of – a different piece of work needed to be done, and that was what we – that’s how we arrived at the decision to commission a further piece of work.

Mr Beer: I’m asking about the phraseology.

Alice Perkins: Right.

Mr Beer: Why is it, when I read a Board minute about commission anything a piece of work about Horizon, it always says something along the lines of “it will give us comfort, it will establish that Horizon is reliable, it will reassure us as to our existing view”. We looked at two of them yesterday.

Alice Perkins: Mm-hm.

Mr Beer: You remember? Why is it always framed in that way?

Alice Perkins: I think because, by this stage, we had had the Second Sight Interim Report, which said that it had so far not found evidence of systemic issues with the Horizon system. That had been interpreted by the Post Office as an assurance of that, and had, actually, as I said yesterday, similarly been interpreted in that way by Lord Arbuthnot and others, and we had no reason to be – to have doubts that that was the case.

But, here we were, being advised by this very well respected legal firm but the evidence that we had was not sufficient for them and, therefore, we should seek some further advice. But I don’t think that, at this point – we did not think that there was anything wrong with the Horizon system at this point. But, if you’re asking me whether what we were doing was simply seeking to commission advice which would give us the answer we wanted, that was absolutely not my position, and I’m completely sure it wasn’t the position of other Board members either.

Mr Beer: Can we display at the same time, please, POL00107317, and page 3 of that document, please. Sorry, I should have rested on page 1 for a bit, just so you can see what it was.

It’s the Linklaters advice of 20 March for this board meeting, okay, and presented by Christa Band. If we go forward to page 3, please, and go to paragraph 2.3, if we can just highlight that, thank you. In the first part of that, there’s some information about Jo Swinson.

Alice Perkins: Mm.

Mr Beer: Then, in the second part of the paragraph, Linklaters say:

“We note that there is, so far as we understand it, no objective report which describes and addresses the use and reliability of Horizon. We do think that such a report [will] be helpful, though there’s a decision to be made about how broad and/or thorough it needs to be.”

That was what was needed, wasn’t it: an objective report describing the use and reliability of Horizon?

Alice Perkins: Yes.

Mr Beer: If you just look at the right-hand side, what that gets translated into:

“… the work should cover:

“The work undertaken by Angela van den Bogerd explaining how the system works …”

Do you know what’s meant by that: the work should cover the work undertaken by Angela van den Bogerd?

Alice Perkins: I can’t help you with that, I’m afraid, now.

Mr Beer: Secondly:

“A review of the data integrity aspects of the system;

“A reference to all audits and tests carried out …”

So was that intended to mean a reference back to previous audits?

Alice Perkins: Yes, I think so, yeah.

Mr Beer: Then:

“A response to the most significant thematic issues raised by Second Sight.”

That’s rather different from what was proposed, wasn’t it: an objective report addressing the use and reliability of Horizon?

Alice Perkins: Well, “an objective report which describes and addresses the use and reliability of Horizon” is a very broad statement.

Mr Beer: That was what was needed, though, wasn’t it?

Alice Perkins: I’m sorry, I don’t think that I can be of much more help on this, I’m afraid.

Mr Beer: Did the Board commission a comprehensive review of the use and reliability of Horizon?

Alice Perkins: The Board commissioned a review by Deloitte, which was a desktop exercise of assurances and controls of the Horizon system.

Mr Beer: So that does that mean: no, it did not?

We’re going to come and look at the Deloitte report with all of its limitations in a moment but what Ms Band was saying was that there is no objective report describing and addressing the use and reliability of Horizon. Did that come as a surprise to you? Did you think “Goodness me, here we are in March 2014. We haven’t got an objective report that addresses the reliability of Horizon”?

Alice Perkins: I think it made me realise that we had gone – probably gone down the wrong road in the work that we had asked Second Sight to do, the case-based review, yes.

Mr Beer: Did you think, “How have we ended up here and what about the times that I’ve said that we have had Horizon independently assured or the times I’ve been present in meetings with Parlimentarians, for example, and said we have had Horizon independently reviewed investigated or assured? What about the Ernst & Young audits? Don’t they count? What about the internal review that was reviewed by Deloitte; doesn’t that count? Have I said things in the past that don’t really stack up?”

Alice Perkins: To be honest, I can’t remember exactly what I was thinking when I was considering this report, other than the fact that the work that had been done so far by Second Sight was not the answer, was not what was required here, and that we needed to commission some more work. I just can’t go back and dig that out of my mind.

Mr Beer: Okay. Was it quite sobering, though –

Alice Perkins: Yes.

Mr Beer: – to realise that in March 2014 –

Alice Perkins: Yes.

Mr Beer: – you were being told by somebody new –

Alice Perkins: Yes.

Mr Beer: – to the process, Linklaters, who were brought in –

Alice Perkins: Yes.

Mr Beer: – to say, in fact “Here we are in March 2014, we haven’t actually got a report that addresses the reliability of Horizon”?

Alice Perkins: Yeah, I think we were surprised by that.

Mr Beer: Thank you. Those documents can come down.

Can we turn then to the Deloitte report. Essentially, the Deloitte Project Zebra Report was a consequence of the decision made at that March 2014 meeting.

Alice Perkins: It was.

Mr Beer: I’m not going to look at the report itself. I want to look, please, at the Board briefing prepared by Deloittes, as a result of their work because that was sent to you directly. For reference, it’s – no need to display – POL00029733, and the document I’m about to show you was emailed to you on 24 June 2014 by the Company Secretary, Alwen Lyons.

Let’s look at that document, then. POL00028069. So this is the Board Briefing, as I say, emailed to you by Alwen Lyons on the very day that it was created. Would you have read this at the time?

Alice Perkins: So this document was disclosed to me after I’d finished the – I had submitted my written statement just before Christmas and, when I first saw it, I had no recollection of having seen it. But there clearly is an email from Alwen, I think not just to me but to fellow Board members, in which she says she attaches this.

Mr Beer: Yes.

Alice Perkins: The email itself doesn’t appear to have the attachment attached to it but I have no reason to think that it wasn’t attached, but I simply don’t remember this.

Mr Beer: So you don’t remember whether you read it or not?

Alice Perkins: If it came to me, I would have read it.

Mr Beer: Okay. Can we look, please, at page 3 and just look at the top paragraph:

“The work we carried out to support our full report, and thus this Board Briefing document, did not constitute an audit or assurance engagement in accordance with UK or international standards. In order to deliver a formal assurance opinion, we would need to have carried out testing to address the scope limitations. Our conclusions and findings are therefore limited to the design of Horizon. They are also subject to the accuracy of the assumptions and limitations in section 3.”

If we just go down the page, “Limitations and Assumptions”:

“Our findings and conclusions are presented in the context of the following limitations:

“[1] As a desktop exercise we have not validated whether Horizon has been implemented or operated as described in the documentation reviewed.

“[2] Our work was limited by significant gaps existing in the information available, relating to both the granularity of information and the existence of Horizon features over the entire timeline of operation of Horizon. The effect of which is there are gaps within what we are able to comment upon over this timeline. Our findings below are written in the context of the information available, which relates to the current system.

“[3] An event occurred in 2010 which required the use of the exceptional Balancing Transaction process in Horizon to correct a subpostmaster’s position from a technical issue. Information has not been provided on the circumstances that [led] to this system say and how the issue was identified. It is assumed that verbal assertions received from Fujitsu that this was the only time that this process has been used hold true.

“[4] We have not had any direct contact with any third parties other than the named contacts that you have provided to us.

“[5] We have not validated or commented on the quality of the documentation supplied to us.”

Were you disappointed to have received a report which was limited and caveated in such a heavy way?

Alice Perkins: Could I scroll – could I go back to the setting for the receipt of this report? So we had had a Board meeting, I think it was in – a few weeks earlier than this, at which the partner from Deloitte, who was responsible for this exercise, he’d come to that Board meeting –

Mr Beer: Yes.

Alice Perkins: – and he had given the Board an extremely positive sense of what Deloitte had found thus far, and that’s recorded in the minutes. So I think it is really, really important to understand that. He had been present at the meeting. He had given a very clear and positive account of what he and his colleagues had seen so far, and there was a discussion about further work that should be done.

This Board Briefing that came in some weeks later, was therefore a follow-up to that and, if we scroll up the page a bit – do you mind going back up?

Mr Beer: The second paragraph from the top?

Alice Perkins: Yes. So –

Mr Beer: I was going to come to that.

Alice Perkins: I’m sorry.

Mr Beer: I just wanted to –

Alice Perkins: I’m sorry.

Mr Beer: – deal with the limitations first.

Alice Perkins: Yes, but I was trying to explain – I think it is really, really important that people understand that, in my mind, and the mind of my fellow Board members, we had had that very clear and positive steer from Gareth James.

Mr Beer: So were you surprised, therefore –

Alice Perkins: Yes.

Mr Beer: – if we scroll back down, to read all of these limitations?

Alice Perkins: So, I think I said a minute ago, I don’t recall seeing this report and, therefore, I don’t recall reading it. I do, however, remember that there was disappointment that Deloitte did not feel able to give us the kind of description of Horizon that we had expected would be forthcoming following Gareth James’ appearance at the Board and that there were, as I understood it from Chris Aujard, a whole lot of reservations about the value of doing further work, the cost of it and the time it would take.

Mr Beer: Thank you. I’ll leave that there for the moment?

Sir, that would be a good time for the morning break.

Sir Wyn Williams: All right.

Mr Beer: Can we say until 11.10. Thank you.

(11.00 am)

(A short break)

(11.11 am)

Mr Beer: Thank you.

Ms Perkins, I was asking you about the Board Briefing prepared by Deloitte –

Alice Perkins: Yes.

Mr Beer: – dated 4 June 2014. Just for the transcript, and for those looking later, the document that shows that it and the attachment was sent to you – or it was sent to you as an attachment, is POL00138401. No need for that to be displayed.

Alice Perkins: No, no.

Mr Beer: That is an email to you and others showing that the document was emailed to you. You were making the point that we’ve got to read the Board Briefing of 4 June in the light of the earlier meeting of the Board on 30 April, at which the partner from Deloittes had made a presentation?

Alice Perkins: Yes.

Mr Beer: So can we look at the two documents alongside each other, then. Firstly, the minutes of that Board meeting, POL00021524 – thank you – and can we go to page 6 of those. Thank you.

Then can we display the Board Briefing, POL00028069, at page 3 of the Board Briefing and, in particular, the bottom part of the page, the “Limitations and Assumptions” – thank you.

So dealing with the document on the right, these are the minutes of the Board meeting of 30 April, which you were mentioning:

“The Board welcomed Lesley Sewell, [CIO], and Gareth James, Partner, Deloitte, to the meeting. Chris Aujard also rejoined the meeting.

“The Chairman thanked Gareth James for his draft report and explained there were a number of people who were sceptical about Horizon. The Board were concerned to know the truth about the reliability of the system. Deloitte’s views would need to be expressed in search a way that they would persuade reasonable lay people.

“Lesley Sewell explained that the first piece of work Deloitte had been asked to undertake was to give assurance that the control framework, including the security and processes for changes in the system, were robust from an IT perspective.

“Gareth James reported that all the work to date showed that the system had strong areas of control and that its testing and implementation were in line with best practice. Work was still needed to assure the controls and access at the Finance Service Centre.

“Chris Aujard explained that several of the subpostmasters who were challenging Horizon had made allegations about ‘phantom’ transactions which were non-traceable. Assurance from Deloitte about the integrity of the system records logs would be very valuable.

“The Board asked what assurance could be given pre-2010 when the different Horizon system was in use. It was agreed that [Gareth Jenkins] would produce and cost a proposal for additional work to enable assurance for the wider system, pre-2010.

“Lesley Sewell, Gareth James and Chris Aujard left the meeting.”

It was that that you were referring to?

Alice Perkins: It was, yes.

Mr Beer: The “strong areas of control” is a reference to the control framework and security and processes for changes in the system in this minute, isn’t it?

Alice Perkins: I have to confess, at this point, that my recollection of these sorts of details from this long ago are not good. I mean, I can’t add much to what we see.

Mr Beer: What was in the minutes?

Alice Perkins: I really can’t, I’m afraid.

Mr Beer: Okay, I understand. It’s clear, reading the minute as a whole, that the Board needed some further work to be done by Deloitte?

Alice Perkins: Yes.

Mr Beer: What we’re reading on the left-hand side is the product of that further work in June?

Alice Perkins: Yes.

Mr Beer: What it says, in the five limitations and assumptions, would you agree, does not really mean that the questions asked by the Board were answered?

Alice Perkins: Yes. I would agree but would it be all right to scroll up –

Mr Beer: Yes.

Alice Perkins: – because there’s one paragraph which we haven’t looked at.

Mr Beer: Second from the top. We’re going to look at that, don’t worry. I’m just looking at the limitations first. Looking at the limitations first.

Alice Perkins: Okay.

Mr Beer: Would you have focused on these limitations?

Alice Perkins: As I said to you before the break, I have a complete blank about this. For a long time, when – so if I could just explain that, when I was putting my written statement together, last year, in the run-up to Christmas, it was a complete mystery to me what had happened following the Board meeting whose minutes we’re looking at now. I simply couldn’t remember what, if anything, the Board had received from Deloitte after that and I was, you know, kind of struggling to – just to work out what had happened, and then this Board briefing and the covering email, which I think I’m right in saying has commentary from Chris Aujard in it – is that right?

Mr Beer: Sorry, the Board Briefing?

Alice Perkins: Yes, the Board Briefing. It’s not covered – that’s just a simple email from Alwen?

Mr Beer: No, there is commentary as well.

Alice Perkins: There is commentary as well?

Mr Beer: Yes.

Alice Perkins: So that came with commentary. Anyway, it wasn’t until that was disclosed to me, that I saw that we had seen this. That was the main reason why I amended my written statement before I signed it.

Mr Beer: Can we go to page 5 in the document on the left, please. The way that it worked was that Deloitte were asked to address, by Post Office, five questions. They’re described as “Matters” here, but five matters. And question 4, you can see it’s been translated into “Matter 4” there, the question was:

“What comfort can be taken that Horizon provides visibility to subpostmasters of all centrally generated transactions processed to their branch ledgers?”

The answer is:

“‘The Horizon Audit Store reports from a complete and unchanged record of all sealed baskets’. From the documentation we have reviewed, it appears that Horizon is designed such that extracts from the Audit Store represent a complete and unchanged record of basket data.”

Reading this, would you be aware that all Deloitte have done is looked at documents; they’ve not seen how Horizon operates in practice?

Alice Perkins: I see that now. Whether I saw that – I can’t answer the question of what I was thinking at the time, as I don’t remember having seen this at the time. But I understand what you’re saying.

Mr Beer: We can go to various parts of the report.

Alice Perkins: Yeah.

Mr Beer: You’ve referred to it as a desktop review in your evidence earlier, which is accurate. By “desktop review”, do you mean essentially looking at documents?

Alice Perkins: Yes.

Mr Beer: Would that be a concern, that where Christa Band had advised that the Post Office lacked an independent objective report on the use and reliability of Horizon, what you’ve ended up with is a heavily caveated desktop review of pieces of paper?

Alice Perkins: Yeah, I see that now. I do see that.

Mr Beer: Wouldn’t it have been obvious at the time that the ask from the lawyer, or the suggestion from the lawyer, was not met with a response that in any way accorded with what was suggested?

Alice Perkins: I think it should have done, yes. But I think it would be relevant to look at what the covering email said because that’s where I would have started and where I am –

Mr Beer: I’ll go to that in a moment, then –

Alice Perkins: – sure the Board members would have started.

Mr Beer: – if we may.

“Matter 5: ‘Horizon provides visibility to subpostmasters of all centrally generated transactions processed to their Branch ledgers’. From the documentation we have reviewed, it appears that Horizon is designed such that subpostmaster has visibility of all centrally generated transactions to their branch ledgers in that accounting period. Central transactions require subpostmaster approval to be processed, except for [Balancing Transactions]. This appears to be an exceptional process performed only by Fujitsu, and asserted by them to have only been used once (in 2010) between 2008 and the time of their assertion in this area (… May 2014). Usage pre-2008 is currently not known.”

If you had read this, what would you have made of a paragraph like that? Is it beyond your technical understanding? What would you have drawn from it?

Alice Perkins: Well, this – as we discussed yesterday, I think, this does not come naturally to me, this area of work. It’s not something that I had or have any background in, so I think, you know, I struggle with it, if I’m completely honest. But, you know, if I – if you read it out to me and I look at it now, I can see that what they’re saying is, “This is how it said it works”, and then it’s making some – towards the end of this paragraph – that there are some reservations I suppose, is how you’d put it.

Mr Beer: So would things like this have occurred to you – and then I’m going to ask about how it may have occurred to the Board – on reading a paragraph like this, “Oh, we don’t know anything, number 1, about pre-2008. That’s maybe a concern. Number 2, Hmmm, we’ve only just really got what Fujitsu are saying here to go by. It’s just an oral assurance that they’ve only done it once, this thing” –

Alice Perkins: Mm.

Mr Beer: – “and, number 3, doesn’t that mean that Fujitsu actually have access to the system without the subpostmaster approving what’s being done to their data?” Would those kind of things leap out to you?

Alice Perkins: I don’t know that – I wouldn’t say that they would have leaped out at me but, if you read this, you know, as you’re reading it to me now, I understand what you’re saying.

Mr Beer: Thinking about the Board more generally, was there anyone on the Board that might, as I’ve just done, read that paragraph –

Alice Perkins: Yeah.

Mr Beer: – admittedly with the knowledge of everything that has happened, and pick out those three things: no assurance pre-2008; we’ve only got Fujitsu’s word that they’ve done this once; and, if they’ve done it once, it means they’ve got the facility to do things to the data without a subpostmaster approving it, that’s a bit worrying?

Alice Perkins: I certainly would have thought that there would have been members of the Board who would have seen that and would have been more naturally – I don’t know what the word is – knowledgeable about looking at this sort of description, yes.

Mr Beer: Okay, can we go back, then, to paragraph 2 on page 3.

Alice Perkins: Thank you.

Mr Beer: Page 3. Second paragraph from the top:

“Based on the desktop review we have performed, except for the lack of monitoring controls and the matters explicitly drawn out in our full report, we have not become aware of anything to suggest that the system as designed would not deliver the objectives of processing of baskets of transactions and keeping copies of them in the Audit Store with integrity.”

So you wanted to draw attention to that, as a comforting paragraph?

Alice Perkins: That it was one of the first paragraphs – one of the first bits of text you come to and there was some comfort in that, which is I think what Chris Aujard said in his covering –

Mr Beer: Which we’re going to come to in a second.

Alice Perkins: – note. Yes.

Mr Beer: It’s still a desktop review?

Alice Perkins: Yes.

Mr Beer: How would a desktop review, ie looking at pieces of paper, actually discover whether the system, as designed, was delivering the objectives of processing data with integrity?

Alice Perkins: It wouldn’t.

Mr Beer: Can we go to the Chris Aujard email, please, POL00029733. If we scroll down, please, it’s, in fact, from Alwen Lyons passing on a message –

Alice Perkins: Yes.

Mr Beer: – from Chris Aujard.

Alice Perkins: Mm-hm.

Mr Beer: I think the point that you made earlier about the email not showing that the Deloitte report was attached is based on your reading of this?

Alice Perkins: Yes, it is.

Mr Beer: Okay, and I’ve given an alternative reference –

Alice Perkins: Okay.

Mr Beer: – that shows that it was attached –

Alice Perkins: Okay, thank you.

Mr Beer: – because, if we scroll up, we can see that Alwen had missed Rod Williams off the email chain –

Alice Perkins: Oh, I see. Got it.

Mr Beer: – she resends it –

Alice Perkins: Yeah.

Mr Beer: – and on this one the Board Briefing is attached.

Alice Perkins: I see, yes, yes.

Mr Beer: But, because this is a chain it doesn’t show attachments of earlier emails.

Alice Perkins: I understand. Thank you, that’s helpful.

Mr Beer: If we scroll down, please, Alwen says:

“Please find below a message from Chris Aujard and Lesley Sewell [attaching the] Briefing …

“Dear All,

“As detailed in the Board update sent last Saturday, please find attached Deloittes final draft ‘Board Briefing’ …”

Then scroll over to the second page:

“The briefing focuses on those features of the Horizon system which operate to provide subpostmasters with full ownership and visibility of their branch ledger which maintain a complete and accurate audit trail. The briefing thus helps address allegations made by the Mediation Scheme Applicants that their branch losses may have been generated by ‘phantom’ Horizon transactions.

“[It] strives to be succinct and intelligible. However, given the subject matter and scope of the review, it remains somewhat technical … it is based on a desktop review of currently available information … It is therefore heavily caveated.

“In the Briefing, Deloitte expressly identify number of limitations and assumptions … The Briefing must be read in this context. That said, its key findings are”, and then it sets them out.

So the covering email, which I think you said you would have focused on –

Alice Perkins: Mm.

Mr Beer: – did actually draw attention to the fact that this is a desktop review –

Alice Perkins: Yes.

Mr Beer: – and it is heavily caveated with limitations and assumptions?

Alice Perkins: Yes.

Mr Beer: I think it’s right that Deloitte refuse to consent to the publication of their report –

Alice Perkins: Yes.

Mr Beer: – and they refuse to consent to the use of their name publicly to assert that the system was working with integrity –

Alice Perkins: Yes.

Mr Beer: – and they refused to do so unless they had undertaken specific testing of the system in operation?

Alice Perkins: Yes, but they, I think, went on to say words to the effect that weren’t sure that there was value in doing the amount of further work that would be required in order to satisfy that.

Mr Beer: Overall, how did you view the Deloitte report, ie taking into account what you’d been told at the meeting on 30 April and in the light of receiving that email and the Board Briefing?

Alice Perkins: Well, as I said, I don’t remember what I felt about the Board Briefing because I didn’t remember seeing it but, clearly, the picture that we had been given at the Board meeting by Gareth James was not borne out by what followed.

Mr Beer: Was that clocked by the Board at the time? Was it realised by the Board at the time?

Alice Perkins: So I think clearly what the Board realised – I’ll try again. At the Board meeting which Gareth James attended, I think the Board had the impression that Deloitte were going to be able to write a report giving, if you like, Horizon a clean bill of health. That’s what we believed that they were – that’s what we believed that they were leading to and that we would be able to publish that, and that was what we had intended we would do.

I did remember that the follow-up to that meant that we couldn’t go down that route, and I did remember that Deloitte had come to a different view after this, in work had been done from the view that they had – that had been expressed at that Board meeting and that that was something which meant that we were not able to go – to follow the plan that we had at the time, and that – yes, I think that was disappointing. That was disappointing to us.

Mr Beer: Did you get the impression that Deloitte were rather wise to the possibility that their name might be associated with a public assertion that the system was working with integrity and, therefore, were uncomfortable with that and refused to allow it to occur?

Alice Perkins: They were clearly refusing to allow that to happen and I think there was some discussion about why they – why they, you know, felt that – that way and I think we got the impression that they weren’t really – they weren’t really interested in doing the additional work.

Mr Beer: Can we move forward to what impact all of this had on the Mediation Scheme and look at POL00106889. This is a draft of a presentation, I think, to be given to you.

Alice Perkins: Mm-hm.

Mr Beer: Is that right?

Alice Perkins: Looks like it.

Mr Beer: It’s a presentation –

Alice Perkins: It does look like it.

Mr Beer: – to you rather than by you?

Alice Perkins: Oh, it’s not a presentation by me.

Mr Beer: If we go, please, to the introduction on page 7, the author wrote:

“What does success look like?

“We bring a close the discussion on the Horizon IT System as there is no evidence that there are systemic issues with it (Independent assurance provided).”

Then skipping over a couple of paragraphs to the fourth:

“In the run up to the election the Horizon issue does not cause the Minister any problems.”

Then skipping over one:

“Limited internal resource (from Chairman to administration)/money spent on Horizon and more on profit-making activity.”

Was this a presentation, in fact, given to you?

Alice Perkins: I don’t remember but probably. I mean, I don’t know.

Mr Beer: This, on its face, is dated as being in draft on 2 February 2014, so a couple of days before receipt of the Board Briefing?

Alice Perkins: Yes.

Mr Beer: Would it be fair to say that, in the light of that Board Briefing, it would not be possible to say, “There is no evidence that there are systemic issues with Horizon and independent assurance has been provided”?

Alice Perkins: That would have had to have rested on the Second Sight Interim Report.

Mr Beer: Not the Deloitte report?

Alice Perkins: Not given what we have just seen dated 4 June, no.

Mr Beer: No. The fourth bullet point:

“In the run up to the election the Horizon issue does not cause the Minister any problems.”

Was the handling of the Horizon issue seen by the Board through the lens of whether it caused or did not cause the Government problems?

Alice Perkins: Not – no, not – the answer to the question is no. I think, in the sense that the Board would never have done anything one way or another about Horizon because of the political fallout, or otherwise. But I think certainly I, because I was very – because of my Government background, would have been sensitive to election – you know, an election period, such as the one we’re now in.

Mr Beer: I mean, ironically at this time, June 2014 –

Alice Perkins: There wasn’t an election, no.

Mr Beer: There wasn’t one; it happened in May 2015.

Alice Perkins: Indeed, you’re right but, presumably, there was some speculation as to when that election might be. I just –

Mr Beer: I’m just interested in the extent to which causing problems for the Minister was a material consideration at the handling of Horizon issues?

Alice Perkins: Well, it certainly wouldn’t have been a material consideration in terms of the – of the substance of doing the right thing, as far as the Board was concerned.

Mr Beer: Thank you. Is it right that the Post Office essentially took control of the Mediation Scheme in June 2014?

Alice Perkins: I can’t remember the exact date but –

Mr Beer: Let’s look at the documents –

Alice Perkins: – but I thought that the Working Group was closed down later than that.

Mr Beer: I want to look at the genesis of that.

Alice Perkins: Okay.

Mr Beer: Can we start, please, by looking at POL00022128. This is a Board pack for the Board meeting of 6 June 2014.

Alice Perkins: Of the subcommittee meeting?

Mr Beer: Yes, I’m so sorry, yes, the Sparrow Sub-Committee –

Alice Perkins: Yes.

Mr Beer: – rather than a full Board.

Alice Perkins: Okay, yeah.

Mr Beer: You’re present?

Alice Perkins: Yes.

Mr Beer: Yes?

Alice Perkins: Yes.

Mr Beer: If we just go to page 5, please, and look at paragraph 3.8. These are amongst the options. If we just scroll up to get the heading – thank you – these are options being considered at this time, “Completing the Post Office investigation in each case and moving the governance and management of the scheme in-house”.

Alice Perkins: Yeah.

Mr Beer: “Under this option we would publish a report on Horizon and the Mediation Scheme setting out the legal position around the contract and liability. The scheme administration and management would be moved under Post Office’s sole control with the Working Group disbanded and Second Sight’s engagement ended.”

Is that essentially what happened in due course?

Alice Perkins: So, in due course, not – no, that’s not quite right. So, in due course, what happened was the Working Group was disbanded. It was decided to give all applicants access to the Mediation Scheme and any applicants who wanted would – the Post Office would fund advice to them from Second Sight. That’s what happened.

Mr Beer: The reasons for this are given in paragraph 3.9, for the taking of that option, as being:

“[It] would substantially reduce administration costs and allow the Post Office to ‘take control’ of the scheme and its associated risks (such as adverse [public relations]). We estimate the whole life cost … at £7.7 million. The option would also release management time as the scheme would conclude more quickly than the other options …

“This could be justified publicly by setting out the case that we are taking action in the absence of any evidence of systemic failures with the Horizon system during the last two years, mounting costs … and clear legal advice around the expectation gap.”

I should say we should go to page 8 and paragraph 7.3 – thank you:

“It is the view of the Programme, Legal and Communications and Corporate Affairs teams that the third option – where the scheme is effectively moved in-house – is the one which is in the best interest of the business in a pure ‘commercial’ sense. There is a weight of evidence to support this view, including value for money, timescales, concerns around the cost and quality of [Second Sight], the diversion of senior management time and the critically important point that in two years of investigation nothing has been uncovered to raise doubts about the issue at the heart of this [system] – the operation of the Horizon computer system.”

Is it right that the subcommittee decided that this option, Post Office taking control of the Mediation Scheme, was the right one?

Alice Perkins: At this meeting, it appears that that was the decision but it wasn’t accepted by the Board.

Mr Beer: Do you know what the adverse public relations risks were that the Post Office was facing in relation to the Mediation Scheme?

Alice Perkins: I think what was meant by this was that there was an increasing – sorry, can you just give me a minute while I find the words?

Mr Beer: Yes.

Alice Perkins: At this stage, with the Mediation Scheme, there was a lot of noise around it, a lot of dissatisfaction with it being expressed publicly, and I think the point here was that it could be seen that the Mediation Scheme, on the current – the then current rate of progress, was going to take very, very, very much longer to conclude than had ever been envisaged and that, as long as that was going on, there would be more of the kind of comment that was being experienced at that time and that that was – that this was seen as unhelpful. I think that’s what that’s saying.

Mr Beer: Thank you. That can come down.

Can I turn to my last topic, then, with you, and it’s essentially the role of Mr Davies, Mark Davies.

Alice Perkins: Yes.

Mr Beer: Can we turn up, please, POL00295386. I’m going to look at a series of emails that you weren’t party to initially and then we’ll look at some when you were. If we go to page 3, please, and if we scroll down to the middle of the page. Thank you.

So this is 21 June 2012, okay –

Alice Perkins: Mm-hm.

Mr Beer: – and that’s a month before Mark Davies joined the business?

Alice Perkins: Right.

Mr Beer: Okay?

Alice Perkins: Yes.

Mr Beer: Ms Vennells writes to him:

“Mark, Alana was going to call you but is in Downing Street.

“My sense is we are doing the right thing in not offering interviews …”

Just in context, that means whether the Post Office should offer interviews before the appointment of Second Sight was announced.

Alice Perkins: Oh, I see. Okay. Thank you.

Mr Beer: “… as that puts us on the defensive and it also gives it more airspace.

“Do you agree – you must say if not [please]!

“Hope all is well.


Then top of the page, next day:

“Paula, sorry to pick this one up late. But I agree – absolutely nothing to be gained in giving the story legs. Best course of action is to hold the (strong) lines and stick with them.”


“All well – last day at Rethink.”

That is the organisation that Mr Davies was working for?

Alice Perkins: Yes.

Mr Beer: “Really looking forward to 9 July!”

That’s his start date.

Alice Perkins: Okay.

Mr Beer: Then if we go up, please. That day, Paula Vennells sends you that exchange:

“Thought you’d like to see this from Mark – [supported] and excited at joining.

“The only coverage this [morning] is the Telegraph which is balanced.”

Then up, please. You reply:

“Thanks. It will great to have him on board. ([By the way] was NL okay about it?)”

Is that a reference to Norman Lamb.

Alice Perkins: I cannot think who else it was a reference to but I don’t know.

Mr Beer: Norman Lamb, at that time, was the Post Office Minister?

Alice Perkins: He was.

Mr Beer: Records suggest that he was the Parliamentary Undersecretary of State for Employment Relations and Postal Affairs, in office between 3 February 2012 and 4 September 2012, so in office at this period. You can’t think of anyone else who “NL” may refer to?

Alice Perkins: No.

Mr Beer: Okay.

If that does, as is suggested, refer to the Minister, why were you concerned that the Post Office Minister might not be okay that the Post Office had appointed Mark Davies?

Alice Perkins: Mark Davies had worked for my husband and –

Mr Beer: He was your husband’s – Jack Straw’s – former Special Adviser, SpAd?

Alice Perkins: He was, yes. One of the new posts which the Post Office needed to create and fill was a Communications Director, following its independence from the Royal Mail. Up until April 2012, when the Post Office was part of Royal Mail, that communications function was exercised through the Royal Mail Group, and so, although there was somebody in the Communications Directorate in the Royal Mail, who was the Post Office person in that team, there wasn’t anybody at the level with the relevant experience to carry out the role for the newly created Post Office, particularly given the agenda that we were trying to implement.

I think that decision had been taken before I came on board. I can’t remember but, anyway, that decision was taken and there was going to be a proper process involving headhunters and a proper selection process.

And I remember that it occurred to me that Mark, who I knew simply through the work that he had done for my husband, was not particularly happy. I’d heard that he was not particularly happy where he was working and I thought that he would be a strong candidate for the post. And I remember thinking at the time – I wondered whether I should even raise that because of the potential conflict that that – you know, it could look –

Mr Beer: It looked too cosy?

Alice Perkins: It looked too cosy and I nearly didn’t suggest it and then I thought that was completely ridiculous because he would so obviously be very good at the role and why on earth would you not put somebody forward who was eminently qualified, both in terms of his experience and also his public service values, to – for that role, just because he’d worked for your husband?

So I did suggest to Paula – or, actually, I can’t remember if I suggested to Paula or I suggested to Mark but, anyway, one way or another, Mark’s name was given to the headhunters and he was then included in the selection process and I had absolutely nothing whatever to do with that.

Mr Beer: Okay, and so you’re checking here that the potential for this to be viewed as a sort of cosy stitch-up –

Alice Perkins: Exactly.

Mr Beer: – hadn’t occurred to, or was operating on, the mind of the Minister?

Alice Perkins: I would have wanted to be absolutely clear, above board, and I would have wanted it to be drawn explicitly to the Minister’s attention for all those reasons.

Mr Beer: Okay, if we then scroll up, please, Ms Vennells replies. If you look at the third paragraph, she says:

“I haven’t mentioned specifically this week to NL.”

We needn’t read the rest of it because she essentially gets the wrong end of the stick. She thinks you’re speaking about have you run past Norman Lamb the issue of whether we should proactively offer interviews before Second Sight, okay?

Alice Perkins: Oh, I see.

Mr Beer: She gets the wrong end of the stick.

Alice Perkins: Okay.

Mr Beer: Then if we go to page 1 at the bottom, you put her right.

Alice Perkins: Right.

Mr Beer: You say:

“My query re [Norman Lamb]” –

Alice Perkins: Yes.

Mr Beer: – “was in relation to Mark’s arrival.”

Alice Perkins: Yes.

Mr Beer: Not the issue of substance?

Alice Perkins: Yes.

Mr Beer: Then if we scroll up, second paragraph is her reply.

Alice Perkins: Okay.

Mr Beer: “[Norman Lamb] was grateful that I mentioned it. I explained the proper process that had been followed and the calibre of the candidates he had been competing with for the role. I had to leave a message but he texted back and said something like: ‘I appreciate the information, thank you, that all sounds fine’. And we had a great time over supper – [he] is good company.”

Then at the top of the page:

“I’m [very] glad you did this [you reply]. Right thing to do and he responded in the right way. I thought he would. I’ve no idea whether we will get any flak about Mark but if we do, we are in a perfect place to handle it.”

Alice Perkins: Yeah.

Mr Beer: So the flak is the cosy stitch-up suggestion?

Alice Perkins: Yeah, absolutely.

Mr Beer: The “perfect place to handle it”, you’re saying that because it’s been run past the Minister?

Alice Perkins: No, I think – well, yes, it had been run past the Minister, that was certainly part of it, but also because, you know, we’d done the proper thing, you know, we’d been scrupulous about it.

Mr Beer: To what extent, following this, did you rely on Mark Davies’ advice as to the substance of decisions to be taken, as opposed to the later presentation and disclosure of such decisions to the media, ie after the decision had been taken?

Alice Perkins: I would have relied on Mark solely for his experience and professionalism around the public relations angle of things.

Mr Beer: So not to contribute to the substance of a decision taken, only to take advice from him on the presentation of the decision after it had been taken?

Alice Perkins: I think when you’re thinking about decisions in a very public environment, one of the factors you want to take into account, you want to be aware of, is, you know, how would this come across? But that’s not a basis on – you take a decision to do the right thing and then you work out how you’re going to communicate it, but it’s helpful to know in advance whether the way you communicate it is going to be a big issue or not.

Mr Beer: To what extent, to your knowledge, did Paula Vennells include Mark Davies in the taking of decisions as opposed to the presentation and disclosure of such decisions after they had been made?

Alice Perkins: I wouldn’t have had visibility of that.

Mr Beer: Do you know the extent to which Ms Vennells relied on Mark Davies to shape and set the direction for the Post Office’s policy and strategy on issues?

Alice Perkins: I don’t know. You know, I can’t really answer that. I mean, he was a trusted member of Paula’s team and the Board was very impressed with him but, as to the extent to which she relied on him for the substance, rather than the presentation, I really don’t know.

Mr Beer: Here, he’s being relied on before he’s joined the company.

Alice Perkins: But for a PR –

Mr Beer: For a PR issue.

Alice Perkins: Yes, for a PR issue, yes, he clearly is. But I didn’t know that at the time, I think.

Mr Beer: Well, I think you did, because you were on this email exchange?

Alice Perkins: Oh, okay, well I didn’t remember that.

Mr Beer: Can we turn, please, to POL00295300, page 2 at the bottom, please. We’re in June 2012 here.

Alice Perkins: Mm-hm.

Mr Beer: There’s an email from Lord Arbuthnot to you and to Ms Vennells about the Second Sight terms of reference.

Alice Perkins: Right.

Mr Beer: “Thank you for sending me your proposed terms of reference – they are most helpful.

“A couple of issues have struck me and I wonder if you might give me your thoughts … The first is that you are proposing that meetings should be held with MPs but not necessarily with the relevant subpostmasters there to put their side of the story. And MPs will not know as much as the subpostmasters will, and so the issue will not be resolved unless the MPs are also given the chance to have their constituents at the meeting. What about the advisers? Surely they ought to be included as well? Since we are trying to clear the matter up in … a robust and transparent manner, it does seem to me that this needs further thought.”

Then if we go to the bottom of page 1, please, there’s Ms Vennells reply:

“Firstly, let me reassure you that Alice and I intend total transparency – as I’m sure you sensed from the meeting we arranged for you and Oliver.

“… the queries you raise are entirely valid … we are dealing with particularly sensitive and personal situations …”

Third paragraph:

“Rather than a blanket approach, we would take each case separately – we are dealing with individuals’ lives and livelihoods.”

Then further up, please. That email is sent on to, amongst others, Glenda Hansen, your Executive Assistant.

Alice Perkins: Mm-hm.

Mr Beer: Ms Vennells says:

“… I will call Alice tomorrow pm or [not], hopefully after meeting James or at least having a time in the diary over the next two days. I shall also have had a chat with Mark Davies by then, which I know we’ll reassure her too.”

So, again, before Mr Davies has even taken up his post at the Post Office, Ms Vennells was expressing a view that you would be assured that she had had a chat with him before speaking to you, yes?

Alice Perkins: Looks like that, yes.

Mr Beer: So a CEO indicating that the Chairman of the company would be assured after she had had a call with the new Communications Lead, than if she had not done so. Was that because she knew that Mr Davies was somebody that you yourself particularly trusted?

Alice Perkins: I don’t know what it – exactly what it was she was going to have a chat with him about. I mean, it clearly is about Lord Arbuthnot’s message, but what aspect of it is not clear from this. I think that, at the time – and I can’t remember the detail of this but there was really almost no communications input into the Post Office top team at that point and I think we were feeling the lack of it. But I don’t remember this email.

Mr Beer: Bearing in mind this was three weeks or so before Mr Davies joined the company, why would Paula Vennells chatting with him give you reassurance?

Alice Perkins: I don’t –

Mr Beer: He’d never worked for you, had he?

Alice Perkins: No, absolutely not. I just – I knew that he had – I knew that my husband had rated him and I knew that he had a very good reputation, both within the Special Adviser community and that he was very much trusted in the media world.

Mr Beer: When he joined the Post Office, did he perform the role of a Special Adviser –

Alice Perkins: No.

Mr Beer: – rather than a Communications Lead?

Alice Perkins: I don’t think so. Look, I don’t know exactly what kind of – you know, all the conversations that Paula had with Mark but, certainly, as far as I was concerned, Mark was there to do the communications role and that’s – you know, when I sought his advice, that’s what I was seeking his advice on.

Mr Beer: Can we turn to POL00317714, bottom of page 1, and over to page 2. We’re now in 2015.

Alice Perkins: Yeah.

Mr Beer: An email from Mr Davies to you directly:

“Hi Alice

“Hope all well and sorry to be bringing Sparrow to you.

“I have drafted note below for colleagues and thought I would let you see the update now: it is still a live situation …”

“I will update the Board fully on [Thursday].”

If we just scroll down, it is essentially a briefing about how the Post Office is going to engage with the planned Panorama programme.

Alice Perkins: Yeah.

Mr Beer: Then if we go back to page 1, and scroll down to see your reply:

“Thanks for updating me Mark. It sounds difficult but I am confident that nobody could be handling it better than you.”

Then you go on to describe the issues of substance.

Was it usual for you, as the Chairman of the company, to have direct access to, or direct communications with, Mr Davies?

Alice Perkins: I would have had direct access to communications with any of the Executive Directors.

Mr Beer: Without going through Ms Vennells, who is not copied in to –

Alice Perkins: No, she’s not copied in. I mean, yes, I think I did sometimes have bilateral conversations or bilateral correspondence with them, but I would, you know, if there was anything new of substance, then I would have raised that with her in one of our weekly meetings or some other time.

Mr Beer: You say:

“Did you know Clare Sumner from the [Ministry of Justice]?”

What’s that about?

Alice Perkins: So I saw this correspondence very recently, I think last week, and I have to say that, with the benefit of hindsight, I don’t think I should entered into this conversation. But Clare Sumner was somebody who had been a civil servant, I had known her particularly from my role in the Cabinet Office because of her position in the Civil Service, and she was by then working at the BBC.

Mr Beer: So the “TH” –

Alice Perkins: The “TH” is Tony Hall.

Mr Beer: The then Chairman of the BBC?

Alice Perkins: No, he was the Director General.

Mr Beer: Director General. Thank you. So what you were doing was proposing to Mark Davies potentially contacting, by reason of a previous connection in government, the then Chief of Staff of the Director General about a programme to be broadcast by Panorama about the Post Office?

Alice Perkins: That was – I was reminding him of her existence and the role that she was in, yes.

Mr Beer: Presumably to exert some influence?

Alice Perkins: I thought – I don’t know what was going through my mind at the time.

Mr Beer: Can you help us?

Alice Perkins: Can I help you in what way?

Mr Beer: With what was going through your mind? “Because of past connections with government, when you were part of government” –

Alice Perkins: Yes.

Mr Beer: – “my husband’s SpAd, did you come into contact with this other person in government, who now occupies a favourable position in the BBC? We’re in dispute with the BBC, maybe you should get in to Clare Sumner”?

Alice Perkins: I knew Clare Sumner in my own right, so that had nothing to do with a connection with my husband. Mark Davies was the person I knew through the connection with my hers. And, yes, I obviously was suggesting – I thought Mark probably would have known her and I was suggesting he might consider getting in touch with her.

Mr Beer: If we scroll up, please. He says:

“I do know Clare. I might drop her a line. I always worry about going too nuclear too early but I think this is getting to that point I think.”

Did the Post Office go nuclear with Panorama?

Alice Perkins: The Post Office was strong with Panorama. I wouldn’t use the word “nuclear”.

Mr Beer: Can we go back a little, please, to December 2014. I think you’re aware of Mr Davies appearing on the BBC Radio 4 Today Programme and referring to subpostmasters who’d been convicted of criminal offences, some of whom had been imprisoned, as experiencing “lifestyle issues”?

Alice Perkins: Yes.

Mr Beer: Were you aware of that at the time it was broadcast?

Alice Perkins: I think I may have heard it. Yes.

Mr Beer: Presumably because this was quite a mainstream media platform: Radio 4 Today Programme?

Alice Perkins: Because Radio 4 Today Programme was on in our house every morning.

Mr Beer: Was this comment that he made drawn to your attention afterwards?

Alice Perkins: I think – I can’t remember. I think I – I mean, I was aware of it and I remember thinking that it was ill judged.

Mr Beer: Can you recall how it was handled, if at all, within the Post Office?

Alice Perkins: No, I don’t remember.

Mr Beer: Was anything done about it?

Alice Perkins: I don’t remember.

Mr Beer: Can we turn to POL00101860. Go down, please, to page 2. Thank you. 14 December, you’re emailing Mr Davies, so this is after the Today Programme, and the second substantive paragraph:

“On Sparrow, the [Financial Times] piece is obviously unhelpful. It made me think about whether it is in our best interests to maintain confidentiality. It probably is but if we haven’t already, perhaps we should just ask ourselves that question? As long as we stick by our rules and they don’t, we will not be able to respond to their allegations about the process. On the other hand, it’s binary. So if we start to play by their rules we could find ourselves giving a running commentary about it.”

Can you remember the context of this, please?

Alice Perkins: I don’t know remember this Financial Times piece at all.

Mr Beer: Can we scroll up to see what Mr Davies replies. He says, second paragraph, so it is back to you with Ms Vennells and Belinda Crowe copied in:

“On Horizon, it is a final balance. The team and I have been working pretty much all weekend on the Parliamentary debate and (frankly) duelling with the BBC over their plans for a further round of broadcasts on Wednesday. A legal letter will go in the morning. Our approach will be to answer any specific points outside confidentiality – they are very serious (such as alleged failure to follow due process) so we must. But I so think we need to maintain confidentiality for the scheme applicants.”

I think that might mean, “But I also think we need to maintain confidentiality for the scheme applicants”:

“I called the BBC editor on Friday to make this point – with every broadcast they are putting a risk in the way of applicants having their cases heard.

“I am calling my team this afternoon to discuss our next steps and will certainly have your points in mind. Part of the challenge here is that the BBC are playing games: and it may well be that if we can’t provide a spokesperson they can’t broadcast it as it would lack balance.”

So do you understand this to mean that refusing to provide a spokesperson would be a tactic used by the Post Office in the hope that the BBC would not broadcast because of a perceived lack of balance?

Alice Perkins: That is what this is saying, yes.

Mr Beer: Was what Mr Davies wrote here your view of what was happening: that the Post Office was duelling with the BBC?

Alice Perkins: I don’t remember exactly what this is about and it would have been – you know, it would have been his view. I wasn’t engaged in this. I’m just listening to what he’s telling me and I am contributing – I’m just contributing some comments.

Mr Beer: Was the Post Office viewing itself as being embroiled in a battle against the campaigning subpostmasters?

Alice Perkins: I think it was, yes. I think it was.

Mr Beer: Were staff fighting to protect the reputation of the Post Office?

Alice Perkins: People were fighting to protect the reputation of the Post Office, as we now know, based on a completely wrong understanding of the facts.

Mr Beer: Is that how the scandal was then viewed internally by Post Office staff: a rather bloody PR battle in which they were entrenched against the campaigning subpostmasters?

Alice Perkins: I wouldn’t use those words. I think that what was going on here was that the Post Office was trying to – we talked a bit about this yesterday – was trying to protect its reputation as an organisation that could be trusted by the public and by its subpostmasters and its employees, under – in a situation where allegations were being made that it couldn’t be trusted.

People within the Post Office, or at least, speaking for myself, I – and I am very confident that my fellow non-executive Board members – our understanding of the situation was that those allegations did not have substance and we were worried about the reputation of the Post Office suffering from allegations that were not substantiated.

Mr Beer: If we scroll up, please, Belinda Crowe replies:

“Happy to join a call …

“I didn’t respond but we are on really dodgy ground if we get into the detail of cases. However, as you know we have some good answers to some of the points raised and provided we can position this in a way that under no [circumstances] can it be construed as commenting on a case we should be in quite a strong position with our statement.

“Keep trying to think of Kipling.”

I think you were familiar with Belinda Crowe; is that right?

Alice Perkins: Yes, I knew – I worked with Belinda at the Post Office, yes.

Mr Beer: Were you responsible for her appointment?

Alice Perkins: I didn’t know Belinda until she joined the Post Office. Her name was, I think, suggested either to me or to Paula as somebody who could be helpful, I think, initially in relation to the work we’d were doing on mutualisation, which was underresourced.

Mr Beer: She refers to getting on to “really dodgy ground” if the Post Office got into the detail of cases. Do you know why, at this time, the Post Office would be on “dodgy ground” if it got into the detail of individual cases?

Alice Perkins: I think she’s referring to the confidentiality point.

Mr Beer: Rather than the substance?

Alice Perkins: Yes. I think what must have been happening here is that either the BBC or the Financial Times or somebody else was – and this does – I’ve seen this happen in other contexts – they start to talk about personal confidential issues about particular cases and the organisation concerned is unable to answer those points because it feels itself bound by confidentiality, which the commentators are not being bound by. So it’s a kind of unequal conversation you’re having.

Mr Beer: She ends, “I am trying to think of Kipling”, which presumably is “If you can keep your head whilst all about you are losing theirs and blaming it on you”.

Alice Perkins: I imagine that that is – I’ve no idea.

Mr Beer: No. Then Mr Davies replies, and I’ll try to do this justice:

“It is not the critic who counts; not the man who points out how the strong man stumbles, or where the doer of deeds could have done them better.

“The credit belongs to the man who is actually in the arena, whose face is marred by dust and sweat and blood; who strives valiantly; who errs, who comes short again and again, because there is no effort without error and shortcoming; but who actually does actually strive to do the deeds; who knows great enthusiasms, with great devotions; who spends himself in a worthy cause; who at best knows in the end of the triumph of high achievement, and who at the worst, if he fails, at least fails while daring greatly, so that his place shall never be with those cold and timid souls who neither know victory nor defeat.”

I’m not sure Theodore Roosevelt quite had in mind a government-owned entity battling its own staff over whether it was complicit in the procurement of wrongful convictions but does this give an insight into what Mr Davies saw as his role at the Post Office?

Alice Perkins: I think that this is a – I mean, did I see this email, this email exchange at the time?

Mr Beer: No. I’m asking you about how Mr Davies was acting –

Alice Perkins: No, I understand, yes.

Mr Beer: – what he saw his role as.

Alice Perkins: I think that he was just, you know, he must have been feeling under a lot of pressure.

Mr Beer: Was it your view that the Post Office team regarded themselves as marred by dust and sweat and blood in a worthy battle against their subpostmasters?

Alice Perkins: I wouldn’t have put it like that.

Mr Beer: Thank you. They’re the only questions I ask you.

Sir, can we take the second morning break until 12.30?

Sir Wyn Williams: Then I understand the plan is to have one set of questioning of Ms Perkins, which will last up to 40 minutes – is that the idea – so we have a late lunch? That’s the plan?

Mr Beer: That’s right, yes. A ten-minute-late lunch.

Sir Wyn Williams: Yes, fine. That’s very good sleight of hand, if I may say so, Mr Beer. Our lunchtime gets less and less in time.

Right, so we will have our ten-minute break and then whoever is first up will have 40 minutes.

Mr Beer: Thank you very much, sir.

(12.19 pm)

(A short break)

(12.32 pm)

Sir Wyn Williams: Who is first up?

Questioned by Mr Jacobs

Mr Jacobs: It’s me, sir. I just need to check the microphone is so you can hear me. How is that?

Thank you, Ms Perkins, I ask questions for subpostmasters, very many who are represented by Howe+Co, most of whom, if not all, are following proceedings this afternoon.

My first question for you is: did you protect the subpostmasters in your role as Chairman of the Board?

Alice Perkins: I did my best to protect subpostmasters.

Mr Jacobs: Did you succeed in protecting them, Ms Perkins?

Alice Perkins: No, obviously not.

Mr Jacobs: Did you consider that the Board was under a duty to protect subpostmasters?

Alice Perkins: The Board – the Board was under a duty to run the company properly and that clearly included looking after the interests of all the people who worked in the company.

Mr Jacobs: So I think your answer is yes?

Alice Perkins: Yes.

Mr Jacobs: You referred this morning to Sir Anthony Hooper’s evidence. You say that you dispute that these conversations happened, but that’s another point for another day. Essentially, the point he was making was that it didn’t make sense that people of good character would all turn to crime at approximately the same time and in circumstances where they were bound to be caught because they had to balance at the end of the balancing period. Wasn’t that a point that was obvious to the Board or should have been obvious to the Board, regardless of whether Sir Anthony had raised it with you?

Alice Perkins: It was a point clearly that was not obvious to the Board because, if it had been obvious to the Board, we would have taken different actions.

Mr Jacobs: Okay. Why do you say it wasn’t obvious? We have large numbers of people selected because they are of good character, suddenly there’s a raft of prosecutions, a raft of allegations, they all claim that the system is to blame, and it appears that large numbers of people, who are otherwise honest, were turning to crime, roughly at about the same time. That was what was being said in the press, Private Eye, Computer Weekly. Surely the Board must have been aware of this?

Alice Perkins: So your question implies that this was happening out of the blue at the time that I and my fellow Board members were there. In fact, this had been happening over a very, very long period –

Mr Jacobs: Yes.

Alice Perkins: – and we became aware of it only slowly. It wasn’t as though there was suddenly a huge implosion of cases. So I think that as a misleading way of putting it.

Mr Jacobs: Well, let’s move on to another issue that no action was taken on. Yesterday, at around 4.10, you were taken to an email that Paula Vennells sent to you on 21 October 2013. We don’t need to put if up but she said:

“My concern re Sparrow currently is our obligations of disclosure re an unsafe witness.”

Then, in brackets:

“The representative from Fujitsu made statements about no bugs which later could be seen to have been undermined by the Second Sight Report. We don’t think it material but it could be high profile. Martin E [Martin Edwards] is briefed if you want more detail. This is just in case.”

Now, you said yesterday you took it at face value and you shouldn’t have done. Did you accept, as Chairman of the Board that this was an enormous issue that potentially rendered convictions unsafe.

Alice Perkins: I’m sorry what was your question?

Mr Jacobs: Didn’t you accept or couldn’t you see from that email that this was an enormous issue that potentially rendered criminal convictions unsafe?

Alice Perkins: I didn’t see it from that email and if I had seen it from that email I would have done something about it.

Mr Jacobs: Well, what you were being told at face value was essentially of the Simon Clarke Advice, that a representative from Fujitsu made statements about no bugs?

Alice Perkins: I was told that it was not material and I was also told that I was being told just in case.

Mr Jacobs: You said in your evidence today that, some time in 2014, you expressed concerns about the Chief Executive, Paula Vennells; is that right?

Alice Perkins: Yes.

Mr Jacobs: Did there come a time when you stopped taking her at face value and started taking the initiative yourself?

Alice Perkins: I think I did take my initiative myself, right at the very, very beginning of this – of my time at the Post Office, when I was the person who decided that the Post Office should undertake a new, independent review of the subpostmasters’ cases.

Mr Jacobs: This issue, the Gareth Jenkins issue, had legal implications; didn’t you think that you should speak to your General Counsel about this?

Alice Perkins: If I had thought I should speak to the General Counsel I would have done so.

Mr Jacobs: During your tenure as Chairman, there were a lot of red flags which the Board should have acted on; do you accept that?

Alice Perkins: During my tenure, there were a lot of what I would describe as clues, I absolutely accept that. But I think that one of the great difficulties that we are in at the moment is that we know the truth of what happened now and we can see it being laid out very plainly, and it’s becoming clearer and clearer as this Inquiry goes on. But, at the time that I and my fellow Board members were in post, that was absolutely not the position.

Mr Jacobs: Very well. Well, let’s take the clues cumulatively: there were the clues that constitute Sir Anthony Hooper’s point; there were the clues in relation to the Gareth Jenkins issue; matters raised by Private Eye, Computer Weekly, the JFSA and Second Sight; there were quite a lot of clues coming together, weren’t there?

Alice Perkins: I was not in receipt of the clue from Sir Anthony Hooper. I think you need to be – I need to be clear about the clues that I was aware of and the clues that I was not aware of.

Mr Jacobs: Well, let’s talk about the matters that you were aware of. Do you accept that the matters that you were aware of were relevant to the reputation of the Post Office as a public institution?

Alice Perkins: Clearly, yes.

Mr Jacobs: Do you accept that the matters that you were aware of may have attracted public interest?

Alice Perkins: Yes.

Mr Jacobs: Do you accept that these matters might have had an impact on the value of the Post Office brand?

Alice Perkins: Yes.

Mr Jacobs: Do you accept that these were matters that were involving prosecution decisions which were material to the interests of the Post Office Group?

Alice Perkins: But we believed that what we were doing was that we – we believed that what we were doing was right because – on the basis of what we believed to be the position.

Mr Jacobs: Well, that’s not the question that I asked. Do you accept that the matters that you knew were matters involving prosecution decisions which were material to the interests of the Post Office Board?

Alice Perkins: Oh, I see, yes.

Mr Jacobs: Sorry, if I am going to a quickly –

Alice Perkins: You are going extremely quickly and I have had a very long morning.

Mr Jacobs: I will slow right down.

Alice Perkins: Thank you, I will appreciate that.

Mr Jacobs: Can I then ask you to look at a document, it is the Board terms of reference, it’s WITN00220103. If we can scroll down. You’ll see your name is there as Chairman of the Board, and the other Non-Executive Directors, Chief Executive, Chief Financial Officer. If we could go down to page 2 of 5, where it says, “Duties and Responsibilities”, it says:

“In addition to its legal duties, the Board has the following specific responsibilities …”

Then if we could scroll down to the next bullet point, which is on the next page:

“Maintenance of the reputation of the Post Office as a public institution, including consideration of new products and activities which may attract public interest or have an impact on the value of the Post Office brand.”

So these issues that the Board was aware of engaged their duties and responsibilities under this bullet point, don’t they?

Alice Perkins: They do, yeah.

Mr Jacobs: If we could scroll down further then, please, to page 3 of 5, “Matters Reserved for Board Decision”, D:

“The following matters are reserved specifically for Board decision. When indicated [with a star], the Board may delegate authority to a Board subcommittee to bring forward a recommendation for approval or to complete a project or task on behalf of the Board.”

If we then go to section D, scrolling down please, sorry, keep scrolling down, please. I think it’s section 5, governance – 6, “Governance”, here we are, and bullet point 5 – the next one down, sorry:

“Decisions on the potential prosecution, defence or settlement of litigation involving potential costs of more than £1 million or being otherwise material to the interests of the Group.”

So these were the matters that the Board knew engaged this part of the terms of reference, don’t they?

Alice Perkins: Sorry, what was your question?

Mr Jacobs: The matters that you say the Board were aware of, the clues –

Alice Perkins: Yes.

Mr Jacobs: – engages this aspect of the terms of reference of the Board, doesn’t it?

Alice Perkins: Yes.

Mr Jacobs: So it was the function of the Board to be proactive in relation to its terms of reference; is that right?

Alice Perkins: Yes, yes.

Mr Jacobs: It was not the function of the Board to sit back and accept everything that its executives were telling it; is that fair?

Alice Perkins: Yes.

Mr Jacobs: In sitting back and accepting, without challenging, what Paula Vennells and others were telling you, do you agree the Board did not act in accordance with its own terms of reference?

Alice Perkins: I think that that’s a big generalisation. So I would say that, first of all, in respect of the Board’s wider responsibilities, which we’re perfectly properly not discussing here, the Board absolutely fulfilled its responsibilities. I think it’s clear from the ground that I’ve covered over the last day and a half that there are quite specific issues where I now think that the Board should have been – have followed things up or should have challenged things in a way that it didn’t at the time and I’ve been very straightforward about that.

Mr Jacobs: You said at the beginning of my questions to you that you agree that the Board had duties towards the subpostmasters?

Alice Perkins: Yes.

Mr Jacobs: At paragraph 51 of your statement – and I’ll just read it out – you say:

“It would not have been appropriate for the Board to be involved in the granular day-to-day operations of the business any more than it would have been for the Board of a large commercial company.”

That’s the wrong approach, isn’t it?

Alice Perkins: Well, if it – if I’d thought it was the wrong approach, I wouldn’t have put it in my witness statement.

Mr Jacobs: Well, we are suggesting that what you put in your witness statement is wrong. That wasn’t the right approach for you to take.

Alice Perkins: It wasn’t – in my view – all Boards have a really difficult line to tread between exercising a strategic – giving the company, the organisation in question, strategic input into their business activities and standing back and being more objective about what’s going on. They also have duties to hold the executives to account and to challenge them. You have, all the time, to be thinking about where is the right place to draw that line because, if, as a board, you get too far into the operational detail, you can’t fulfil your wider responsibilities.

So that’s something that you’re constantly juggling. I think I have – as I said a minute ago, I have already explained where I think we should have been more questioning or should have pursued things in more detail. We did not get that right in every instance.

Mr Jacobs: You remember you said yesterday, “I was prepared to lift the rock and see what was underneath it”.

Alice Perkins: Yes.

Mr Jacobs: Our clients take the view that the Board was asleep at the helm and no one lifted the rock: they accepted, blandly, what Vennells and other people were telling them?

Alice Perkins: If you look at what happened in my early months at the Post Office, you will absolutely see that I lifted the rock and I pretty much did it entirely on my own at that point.

Mr Jacobs: In relation to what you say about a strategic approach in respect of large commercial companies, wasn’t it all the more important for the Board to have been proactive in the subpostmasters’ cases because this was a publicly-owned company that was bringing actions against people that resulted in imprisonment, desperate financial hardship, the breakup of families, health breaking down and real damage to subpostmasters and their families? Shouldn’t you have taken a more compassionate and less corporate approach?

Alice Perkins: I am just in danger of repeating myself. I have already said where I think we should have pursued things more than we did. We acted in the belief that the advice that we had received was correct and we didn’t understand what it was that we had not received.

Mr Jacobs: Well, wasn’t it also the case that the Board saw the subpostmasters and their claims as damaging to the brand and that is why the Board didn’t protect the subpostmasters?

Alice Perkins: The reason that the Board didn’t take a different line in relation to the prosecutions was because we mistakenly believed the position that was being explained to us by the Post Office’s executives.

Mr Jacobs: Which executive?

Sir Wyn Williams: Mr Jacobs, yes, I’m sorry to interrupt. Can I just take one or two minutes from you because I have still got in front of me the terms of reference, and would just like to ask Ms Perkins a question about the bullet point that is highlighted there, which I interpret to mean as follows: that in relation to litigation which has a value of £1 million or more, if you at up the damages or costs, or whatever –

Alice Perkins: Yes.

Sir Wyn Williams: – then the Board itself has to make a decision about what to do about it.

Alice Perkins: That –

Sir Wyn Williams: But then we have this other rather imprecise phrase:

“… or being otherwise material to the interests of the Group.”

Alice Perkins: Mm.

Sir Wyn Williams: Now, forgive me, the interests of the group, is that sort of taken from the time when it was the Royal Mail Group and has just been drafted on, so to speak, or was it a Post Office Group, after separation?

Alice Perkins: There were various iterations of these terms of reference –

Sir Wyn Williams: Right.

Alice Perkins: – at different points and, looking at this now, I can see that the word “Group” does look odd.

Sir Wyn Williams: Anyway, that wasn’t the main point. The main point I wanted to ask you about is how the Board interpreted the phrase “being otherwise material to the interests”, and let’s say of the Post Office? It’s a very, as I say, imprecise phrase.

Alice Perkins: It is a very imprecise phrase.

Sir Wyn Williams: So how did you go about deciding whether or not this should be a Board decision or a decision made by someone else, in effect?

Alice Perkins: I think that we would have been mindful of the effects of these sorts of issues on the shareholder. I think we would have been mindful, as has been discussed at length, of their affect on the Post Office’s reputation and, in addition to this point about costs of more than 1 million, we were also looking at cumulative costs.

Sir Wyn Williams: Would I be right in thinking that the Board itself would only be in a position to make a decision as to who should make the decision if the particular problem was brought before the Board? In other words, you didn’t have an internal mechanism whereby, I don’t know, every three or six months, you checked upon whether there were decisions which the Board, as opposed to Mr X or Ms Y, should be taking?

Alice Perkins: In relation to prosecutions? Yes –

Sir Wyn Williams: Mm.

Alice Perkins: – you are right about that.

Sir Wyn Williams: Yes.

Alice Perkins: Yes.

Sir Wyn Williams: So, effectively, in relation to criminal prosecutions, the Board delegated the responsibility to the relevant executives; is that it, in a nutshell?

Alice Perkins: Yes, it is it, in a nutshell. Can I say a little bit more about that?

Sir Wyn Williams: Yes.

Alice Perkins: I think it’s in my witness statement that when I – very early on when I arrived in the Post Office, Susan Crichton, who was then the General Counsel, explained to me that the Post Office took private prosecutions and that this was handled at arm’s length from the Board, and I accepted that proposition. I think now, knowing everything that I know, we should have really early on taken a paper – there should have been at least a paper to the Board, probably leading to further discussion or briefing, so that we really, really understood what all that meant.

Sir Wyn Williams: Mm-hm.

Alice Perkins: And what happened was that, because we were plunged into the separation negotiations, which were way behind schedule, because I didn’t have – I didn’t inherit a fully functioning Board and I was populating it, for all those other reasons, this was something that we did not get to, which, with the benefit of hindsight, I think it would have made a very big difference if we had got to it early on.

Sir Wyn Williams: Thank you.

Thank you, Mr Jacobs, I will give you an extra minute or two if you need it.

Mr Jacobs: Thank you, sir.

There should always be a system, shouldn’t there, in a Board structure such as the Post Office, of reviewing decisions and recording how advice given by executives was considered and looked at? We don’t see that here, do we?

Alice Perkins: I’m not quite sure what you’re –

Mr Jacobs: There should be an audit system, a risk system, where you look at the advice that the executives are giving you and analyse it, audit it and minute it. Did you just accept what the executives were telling you and not act any further?

Alice Perkins: No, we often questioned what – the advice that we were being given and – and the other thing that I was supported by the Board in trying to get accepted as a kind of way of working was that, when things had gone wrong, that we would look back at them and analyse what had gone wrong so that we could learn lessons for the future.

Mr Jacobs: Yes. Was there a practice in the Post Office whereby the Board would review its own decision and then go back to that decision and see if the decision was properly made?

Alice Perkins: Well, that’s what I’m referring to by talking about introducing the culture of having lessons learned reviews.

Mr Jacobs: Right. You said early on that you were let down by the executives and, at paragraph 82 of your statement, you say that:

“Material information was only summarised in an incomplete way.”

You say:

“The Board didn’t ask questions that might have got to the truth of the matter.”

The question I was going to ask you, Ms Perkins, is which executives, in particular – can you name them – only gave you information in an incomplete way and didn’t give you enough information for you to properly look at the matter?

Alice Perkins: Well, I discussed that with Mr Beer yesterday –

Mr Jacobs: Can you discuss it with me as well, please.

Alice Perkins: – and I said that I thought that both Susan Crichton and Chris Aujard, as General Counsel, had both – had not given us direct access to advice that we should have been given or explained that advice to us clearly and that some of the advice that they received was described in a way that didn’t give a full picture of the truth.

Mr Jacobs: Susan Crichton has said in her evidence that it was unusual for there not to be a lawyer present as a full-time Board member. Do you agree with that? In retrospect, do you think if there had been lawyers on the Board, these issues might have been grasped or understood a bit better?

Alice Perkins: I think there are two aspects to that. There’s the question of whether, had the General Counsel of the day, been present at all Board meetings, these kinds of issues might have been revealed to the Board. I think on the basis of what we’ve seen, I don’t think that we can make that presumption in this instance.

I have said in my witness statement that, reflecting on these events, which I have done at great length, I do think that we lacked – it was a – we lacked having somebody who was a non-executive member of the Board who really had a grasp of the detail of these kinds of issues, and that could have been – it could have been possible to have made the case for an extra Board member, had I seen or had we seen that that skillset was really necessary.

An alternative way of getting that expertise, which I floated in my witness statement but which I’m not completely convinced about, is whether what we should have done is to have gone and got some external advice, which would come directly to the Board on these matters. But one of the reasons why – there are several reasons why I’m not sure that that would have made a difference and it’s very detrimental to the relationship between a Board and its executives to bring in that kind of – can be – to bring in that kind of external advice. It creates tensions in the relationship, which can have adverse consequences.

Mr Jacobs: Do you accept now that, if you had had a lawyer full time on the Board, it would have been less easy for the executives to pull the wool over your eyes?

Alice Perkins: You’re talking about a Non-Executive Director, is that what you’re talking about?

Mr Jacobs: Yes.

Alice Perkins: Possibly, yes. I can’t be sure. It would have depended on – you know, it would have depended on a great many things and one of the other things that we will never know is, had the Board asked more questions than it did, had the Board pursued some of these things that we should have pursued in more depth, now that – you know, now that – we can see that now, knowing what we know now, would it actually have got to the truth? I don’t think we can – I certainly can’t be sure of that.

Mr Jacobs: I want to move on to the question of remote access. You say at paragraph 225 of your statement that you weren’t aware that the question of remote access was an issue that could threaten the integrity of prosecutions and you go on to say you would have expected to have been advised if this was the case, so that the Board could act in the light of all relevant information.

Do you accept, or did you know at the time, that a subpostmaster facing prosecution, if that person knew about the possibility of remote access to a branch, they would be in a position to say there’s scope for doubt that the alleged shortfalls in the system emanated from the system, and not from them.

Alice Perkins: Could you take me to that paragraph in my witness statement?

Mr Jacobs: Yes, of course. It’s 225, which is on page 113 – page 112, I’m sorry. Around about the fifth line:

“As I mentioned I was not aware that this was an issue that could threaten the integrity of prosecutions, and would have expected to be advised if this was the case so that the Board could act in the light of all the relevant information.”

Then you go on to talk about the Ismay Report and having no backdoors. Has that refreshed your memory?

Alice Perkins: So I am saying this in the – I’m saying this in the context of what we were discussing at the Audit and Risk Committee on 23 May 2012, in the context of this Ernst & Young audit.

Mr Jacobs: Yes.

Alice Perkins: That’s where I’m saying that. I’m not saying I never had any idea that remote access was an issue. What I’m saying here is that I didn’t make the connection between the point that was being made in this Ernst & Young audit, about their ability to audit the accounts, and the position of subpostmasters. That’s what I’m saying here.

Mr Jacobs: Were you aware that Post Office knew about the remote access capability from 2010?

Alice Perkins: No, I wasn’t aware of that and it says – absolutely I wasn’t aware of that. If I’d known that, I would have behaved in a different way.

Mr Jacobs: There is a document that’s known to the Inquiry where there was a discussion, a meeting in September 2010, between Fujitsu staff and Post Office staff –

Alice Perkins: In 2010?

Mr Jacobs: – in September 2010 – before your time –

Alice Perkins: Okay.

Mr Jacobs: – before your time –

Alice Perkins: Right.

Mr Jacobs: – in relation to the mismatch bug, and one of the solutions – I’m just going to read it out – was:

“… Alter Horizon branch figure at the counter to show the discrepancy. Fujitsu would have to manually write an entry value to the local branch account.”

Then it said:

“IMPACT – When the branch comes to complete the next trading period they would have a discrepancy which they would have to bring to account.”


“RISK – This has a significant data integrity concern and could lead to questions of tampering with the branch Horizon system and could generate questions around how the discrepancy was caused. This solution could have moral implications for Post Office changing branch data without informing the branch.”

So they knew all about it in 2010 and my question for you is: how is it that this information, the knowledge of the Post Office, never came to the Board’s attention?

Alice Perkins: It was – I’m not the person who can answer that question, I’m afraid.

Mr Jacobs: You had responsibility to protect the interests of subpostmasters. This was a key issue that went to the integrity of prosecutions. All the meetings, all the papers that you read, all the consultations that you had, why did this issue never come up? Why did you never raise this? Why did the Board never raise this?

Alice Perkins: Because we were being given constant repeated assurances that remote access was not possible.

Mr Jacobs: You said yesterday that the problem with the Post Office’s conduct and the points that were missed were that it was because people were not paying attention and you said maybe it was too difficult. You also said, in your words, that “cock-up rather than conspiracy lay behind the failures that led to Post Office defending the Horizon system in the way that it did”.

Do you now accept, looking back, that there was a conspiracy? People were lying to MPs, people were lying to the Board. This was quite deliberate. It wasn’t just not paying attention or it being too difficult. Can you accept that now?

Alice Perkins: I simply do not know, as I said yesterday, why people did not pass on information that they should have passed on to the Board.

Mr Jacobs: Finally, I’m going to ask you about suspense accounts. Now, I know you’ve said that that wasn’t an issue that you had a great deal of knowledge about but there was a paper that the Board received after the Select Committee meeting in February 2015, where the Select Committee said that the Post Office was denying Second Sight access to information about movements in relation to suspense accounts. Do you recall that?

Alice Perkins: I think I covered that in my witness statement.

Mr Jacobs: You did, yes, paragraph 79.2.3.

Alice Perkins: Would you mind putting it up – I can’t remember everything – it’s a long statement.

Mr Jacobs: Of course, it’s a long statement, Ms Perkins. So paragraph 79.2.3, in the witness statement, which is WITN00740100, and it’s page 34. If we could scroll down:

“The Board also received a paper on supplementary evidence which the Post Office was trying as part of the BIS Select Committee investigation, in which the issue of suspense accounts was discussed. I understand from this paper that the BIS Select Committee was informed that the Post Office was denying Second Sight access to information about movements into and out of the suspense account.”

Alice Perkins: “I understand that in June 2014 Second Sight asked the Post Office to explain the operation of its suspense account and the Post Office replied in July 2014.”

Mr Jacobs: Yes. Were you aware at the time why this was being asked? Subpostmasters – who paid money to the Post Office, on account of alleged shortfalls, so they could continue trading and not be prosecuted or have their contracts terminated – physically handed money over to the Post Office and Second Sight believed that that money, the subpostmasters’ own money, was absorbed into Post Office general accounts. Were you aware that that was the nub of the issue here?

Alice Perkins: I think I have explained that I didn’t understand this at the – I didn’t know about the suspense account issue directly and that’s what I’m saying in my witness statement. I’ve got nothing to add to that.

Mr Jacobs: Well, taking suspense accounts out the question, then. What did the Board do to look into what had happened to the money that these people paid; was that something that ever came up?

Alice Perkins: I don’t remember that the Board did look into that.

Mr Jacobs: Are you able to say why it is that, even today, subpostmasters do not know how the money that they paid was accounted for, where it has gone?

Alice Perkins: I can only talk about the things that I knew about when I was in my position.

Mr Jacobs: From your experience, from when you were in your position?

Alice Perkins: I can’t give you –

Mr Jacobs: You can’t answer that question?

Alice Perkins: I can’t answer that question.

Mr Jacobs: I am just going to see if I have any more questions to ask.

I’m asked to ask you, in relation to your opening statement to the subpostmasters yesterday, you said:

“I’m sorry that I cannot say that, despite serious efforts on my part to get to the bottom of what was going on, I did not succeed in doing so during my four years at the Post Office and, therefore, the suffering of those affected was prolonged.”

Those subpostmasters who we represent maintain that your efforts as Chair of the Board were seriously lacking. Can you respond to that, please?

Alice Perkins: I would say that I made some – took some big steps to try and deal with this issue. When I was faced – not faced – when I first heard that Lord Arbuthnot had issues that he wanted to raise in relation to this, I agreed to see him immediately without hesitation. I got the distinct impression from him that he had not been able to get that kind of response from anybody in Royal Mail or Post Office before that.

At my first meeting with him, I suggested that there should be an independent review of those cases. I went back to the Post Office and said that this was what I had suggested. I was told it was a bad idea, that it was unnecessary and that the Post Office didn’t have the capacity to handle that. Absolutely nothing happened about it. I wouldn’t let go. I went back and argued for it. It was then agreed that we should have that review.

I was then pushing, and pushing, and pushing for the terms of reference of that investigation to be broadened and not limited in the ways that were being suggested and, later on, I and the Board, as a whole, were very open/supportive of the idea of doing a second kind of review through Deloitte, which, as I discussed this morning with Mr Beer, was something which was not followed up in the way that I think with the benefit of hindsight, it should have been.

But there were a whole load of steps that were taken by me that made a difference, not in the way anybody would have wanted, but –

Mr Jacobs: Yes.

Alice Perkins: Is that – I would also like to say, since I’m having this thrown at me, that there were a number of other steps that were taken while I was Chair of the Board, which include the fact that we reviewed the prosecutions policy, and I would personally have taken that further and, had I known, and had the Board known, of the first piece of Simon Clarke Advice, I am very, very clear that we would have taken a decision to stop private prosecutions at that point. And we had already been told that, once the Second Sight review was under way, prosecutions based entirely on Horizon evidence were ceased.

Mr Jacobs: Ms Perkins, what blame do you accept, personally?

Alice Perkins: I think we’ve covered a lot of that over the last day and a half. I have talked about instances where I – specific instances where I think, with the benefit of hindsight, I and/or the board should have taken things further.

Sir Wyn Williams: Thank you, Mr Jacobs.

Mr Jacobs: Thank you. I have no further questions.

Sir Wyn Williams: Right, I will take back a few minutes from Mr Beer and we will start again at 2.15 – sorry, 2.10. Can’t take too many minutes back from him!


(1.13 pm)

(The Short Adjournment)

(2.10 pm)

Mr Beer: Sir, it’s Ms Watt on behalf of the NFSP and then Mr Henry.

Sir Wyn Williams: I’m just going to move a little this way so I can see you, Ms Watt.

Questioned by Ms Watt

Ms Watt: Good afternoon, sir. Although, I think if Mr Henry sits there then maybe Ms Perkins can’t see me. Sorry, thank you.

Sir Wyn Williams: We’re fine now.

Ms Watt: Thank you very much.

Good afternoon, Ms Perkins. I ask questions on behalf of the NFSP. At paragraph 4 of your witness statement, I’m not going to turn it up, I’m just going to return to something you say there, you say:

“The failures by the Post Office and the Royal Mail Group prior to the separation of the two companies were considerable and devastating in their impact on the lives of many affected subpostmasters and their families.”

I just wanted to start off by asking if you would expand that to acknowledge that the failures also had a devastating impact on postmaster assistants, Crown Office employees and their families because they were also prosecuted and are also victims?

Alice Perkins: Yes.

Ms Watt: Would you agree that the failures throughout, and that includes the period 2011 to 2015, when you led the Board, also had a considerable impact on the communities that the affected post offices and subpostmasters served?

Alice Perkins: Yes, they must have done.

Ms Watt: I’m sorry, I’m not able to hear you –

Alice Perkins: Sorry, my fault. It’s because I was trying to see you and I moved away from the mic, sorry.

Ms Watt: Thank you. Would you accept that this is a continuing situation, in other words it is the case, isn’t it, that there is a devastating impact on the post offices and subpostmasters of today from the damage done to the reputation of the Post Office and, therefore, to the value of their investment in their businesses?

Alice Perkins: I’m afraid I’m not familiar with how the Post Office is currently faring in that way.

Ms Watt: Do you accept that that is caused or substantially contributed to by the failures of you and your Board at the material time? Just to explain, by “failures”, I mean the failure to notice, question and act on any material piece of information, all as discussed in your evidence these last two days, which might have brought a different outcome to this?

Alice Perkins: I think I have accepted over the last two days that there were specific areas where I think that the Board or I should have pursued things. I have, I think, covered that ground. But, as I have also said, there were a whole number of areas where, either as a consequence of my personal actions or the Board actions, things were done which made – which led to – I mean, the fact that we set up the Second Sight Inquiry, notwithstanding the problems with that, did lead to the unravelling, in the end, of all of this, and there were a number of actions that we took which were very positive in this context.

During the time that I was in the Chair, the number of prosecutions being carried out by the Post Office dropped to zero in two of the years and I think to one or two in one of the years. It was a completely different picture from the picture which I inherited.

Ms Watt: Just picking up on that, you’ve said several times during your evidence that, certainly at the start of your tenure, you lifted the rock to see what was underneath. Can I put it to you that, while that may well be the case at the start, would you accept that what then happened is you put the rock back down and just became part of the corporate reputation protection, which was, at the very least, completely incurious?

Alice Perkins: So I wouldn’t accept that, no. I don’t think there’s really anything that I can add substantively to what I’ve said on this subject.

Ms Watt: Just finally on this part, would you accept that this scandal and your part in it has had an impact on the British taxpayers, who were effectively the source of funding for the Post Office’s legal fees throughout what might be described as a war of attrition in defending the indefensible?

Alice Perkins: Well, it certainly is the case – I mean, I don’t know what the current state of the finances of the Post Office are and to what extent it is dependent on taxpayer subsidiaries. All I can say is that during the period when I was in the chair, we were making real inroads on that subsidy and the Post Office was on the path to breaking even. But, clearly, what’s happened has had a very, very big impact on that. But I can’t, you know, I can’t elaborate on that, I’m afraid.

Ms Watt: Well, just thinking about that financial aspect that you’ve mentioned, at paragraph 36 of your witness statement you say that the Government’s vision for turning the Post Office around was making it sustainable by developing new streams of income, modernising it and, in the process, making it profitable instead of loss-making and, therefore, ready for mutualisation, if you recall that is in your witness statement?

Can I ask you, then, was the Network Transformation programme something that you were aware of/involved in?

Alice Perkins: Yes, I was aware of it.

Ms Watt: How hands on would you say the Government relevant departments and ministers were in relation to the Network Transformation Programme?

Alice Perkins: I think they were well aware of it. It was a central part of their policy in relation to the Post Office.

Ms Watt: Thinking a bit more about the Network Transformation Programme then, can you say what work was done by the Post Office, along with Government and relevant departments to identify and put in place new income streams which would have been required for Network Transformation to actually be profitable for subpostmasters?

Alice Perkins: So you’re talking here about new business for the Post Office; is that what you’re talking about?

Ms Watt: Yes.

Alice Perkins: Yes. So there were, I think, three big streams of income, Mail’s was the biggest, and there was a lot of time and energy spent on the relationship with Royal Mail, and trying to put that partnership on a much better footing, and to deal on the front foot with the increase in online shopping, parcel delivery and all of that, which was very, very, very difficult because the Royal Mail and the Post Office were behind the game, compared to the competition.

There was the Financial Services aspect, which was relatively small when I began in the chair, but we rebooted our relationship with the Bank of Ireland to provide a proper platform on which we could develop the Financial Services offer, and that was going well, and there were very ambitious plans for it, which were not realised in my time.

And then the third aspect, which I suspect may be what you are getting at, was Government business, where we had been told by the Government of the day was a very important part of the – plank in their strategy for growing the Post Office’s revenue, which was a disappointing – it was a disappointment because it wasn’t coming through in the way that had been expected.

Ms Watt: So if we take the way in which the Network Transformation Programme was effectively sold to subpostmasters, is it not the case that, in truth, certainly on the Government business side, if nothing else, there really were no revenue streams and this programme was, effectively, falsely sold to subpostmasters?

Alice Perkins: I don’t think it was falsely sold. I think there was genuine intent to deliver the government services plank of that, alongside the other things. It was not the only thing. But I would agree that, for understandable reasons, that government business was not won by the Post Office because the Post Office was often not commercially the most attractive vehicle for delivering those services. And the Government – in principle, a government could decide that it was so important to maintain a flourishing Post Office Network that you would mandate Government departments to use those outlets for the delivery of those services.

I don’t think that would have been legal, actually, but, in principle, you could make it legal but that was not what was on offer, and it was a personal disappointment to me, that. I put a huge amount of effort into trying to explain to Government departments and to ministers of Government departments what it was the Post Office had to offer Government. But, as so often happens – and I know because I’ve been inside it as well as outside it, Government departments – it’s very, very difficult to get Government departments to collaborate on a Government-wide initiative that doesn’t actually individually benefit an individual department, if you see what I’m saying. So it was disappointing.

Ms Watt: Thank you very much.

Those are my questions, sir.

Sir Wyn Williams: Thank you. You look as if you’re poised, Mr Henry.

Mr Henry: As poised as I’ll ever be, sir.

Sir Wyn Williams: All right okay, I’ll stay in this same position. I can see both of you. Yeah.

Questioned by Mr Henry

Mr Henry: Ms Perkins, can I just ask you, please, prosecutions, you say, were kept at arm’s length from the Board.

Alice Perkins: Yes.

Mr Henry: Now, obviously, that is prosecuting people but litigation risks, in other words civil and criminal appeals which could result in massive damages being awarded against the Post Office, that must have reached Board level?

Alice Perkins: Yes, it did reach Board level.

Mr Henry: Yes. So from the point of view of trying to assess risk and whether or not it could have a material impact on, to use the archaicism, the Group as a whole, or, post-2012, the separated Post Office, that would be something where the Board would obviously work in close conjunction with the Executive Team and also General Counsel?

Alice Perkins: Yes.

Mr Henry: Now, I want to just ask you, please, at paragraph 298 of your witness statement – and there’s no need to get it up – but you refer to a document that was prepared by General Counsel, Mr Aujard, and the reference is WITN00740131. I wonder if we could have a look at that. It’s paragraph 298 of your witness statement, in case you have a hard copy of your witness statement.

Alice Perkins: Unfortunately, I didn’t bring my hard copy witness statement back in with me, I’m sorry. So I would like to look at that, please.

Mr Henry: Well, then I’m afraid, sir, my time is going to be –

Sir Wyn Williams: Don’t worry, we’ll do it quickly, Mr Henry. Let’s have WITN00740100 on the screen, and page 145, paragraph 298, just so that Ms Perkins can refresh her memory about that.

Mr Henry: I’m very grateful.

Alice Perkins: So I’m looking at paragraph 298, is that right?

Mr Henry: Yes.

Alice Perkins: Can we scroll down to the rest of the paragraph, then. Thank you.

Mr Henry: Now, can we go to the actual document WITN00740131. Can we concentrate, please, on paragraph 2.3:

“The headline conclusion of the backward looking report [which is the Altman General Review of October 2013] is that ‘… review (of the cases that had been prosecuted over the last few years) is fundamentally sound’ and that no ‘systemic or fundamental flaws in the review process’ were detected. In addition, a number of relatively small procedural recommendations were made regarding matters such as document retention etc.”

Now, “document retention” is a euphemism for shredding: the unlawful, the unauthorised destruction of documents that ought to be preserved under the Criminal Procedure and Investigations Act. You tell us that your General Counsel, of his own volition, must have decided to use that disgraceful euphemism to mislead you and your fellow Board members.

Alice Perkins: I don’t think I’ve used those words. I don’t remember using words in relation to this sentence.

Mr Henry: Well, you’re saying that it was kept back from you, paragraph 298 – you’ve just read the paragraph. I may be embroidering it but what you’re saying is that this was – and I will put words into your mouth – a disgraceful action by your General Counsel to not fully apprise you of risk, not fully apprise you of what was going on in the business.

Alice Perkins: I think if you look at that last sentence, I mean, obviously, it depends who you are and it depends what else you already know but, to me, that reads like a kind of bland sentence. It could mean anything. To me, that does not mean shredding of documents relating to either past or current actions in relation to prosecutions. I’m really sorry but I simply cannot make – that’s not a connection that I think you would reasonably expect somebody coming to this to see.

Mr Henry: That is not – and you’re a very intelligent woman, that is not the thrust of my question at all. I’m not suggesting that you ought to have read that as “shredding”. What I am suggesting, however, and I will put it to you straight, is that this must have been curated, between you, the Chief Executive and General Counsel, that a sanitised version of the truth was perpetuated in Board documents, as opposed to the unvarnished truth?

Alice Perkins: That is absolutely untrue and I find that question offensive.

Mr Henry: I’m very sorry if you find it offensive but the fact is that you have said that things were “surprising”, “extraordinary”, “disappointing”, “astonishing”; a whole range of epithets have dropped from your lips to apparently excuse the Board’s stupifying ignorance on matters of central importance and I’m suggesting to you that that cannot be right, that you must have been known?

Alice Perkins: You can suggest that to me as often as you would like, in as many different words as you would choose: it is absolutely categorically untrue, and I am on oath and I am a truthful person.

Mr Henry: I want to deal with the issue that Mr Beer took you to very briefly about embedded commands and you deny, or cannot recall, ever teaching Ms Vennells a lesson, but she claimed that you taught her how to craft a question to subordinates with an embedded command, a skill, in other words, that you ask a question in which you mandate the answer you require.

The famous example of that is: is it possible to access the system remotely, et cetera, et cetera. You remember, perhaps, or have read about, her questions before Parliament.

I want to take you now to a document. POL00344895. What I want to suggest to you is that the language that Mr Aujard is using is a reflection of the reality that you wanted to see and hear. That’s why euphemisms are being used in Board documents. It is a reflection of what you desire, your strategy, your vision, which you set for the company. Let’s go to POL00344895 and can we scroll up, please. Mr Beer took you to this morning and:

“The position is intrinsically worrying (to put it politely) [et cetera, et cetera]. The NEDs are really concerned because of the potential costs to the business, the distraction from implementing our strategy (which is demanding enough), the reputational issues and their personal positions. A bad combination made far worse if the business does not appear to be on top of it. So the paper needs to demonstrate that the Board’s concerns on the latter point are unnecessary – if that is possible.”

I suggest to you that the “if that is possible” is a throw away post-hyphen part of the sentence:

“… the paper needs to demonstrate that the Board’s concerns on the latter point are unnecessary …”

This was a reflection of your style of leadership, wasn’t it?

Alice Perkins: I don’t accept the premise of your question and I think, if I may say so, if you look at some of the other documents, amidst the huge quantity of documents that are available, you will see that there are examples of where I have made it absolutely clear to colleagues, to executive colleagues, that I was always ready to face bad news and would deal with it head on. What I didn’t want was apparently bad news that was not properly evidenced and that was my – that was absolutely my position but I do not accept that I ever, either directly or indirectly, encouraged people not to give the full truth.

Mr Henry: Well, let’s just change tack then and deal with that because I suppose a demonstration of that would have been your pushing back against the inertia demonstrated by your colleagues and your fighting really hard to address Mr Arbuthnot’s concerns.

Alice Perkins: Is that a question?

Mr Henry: Yes, that would be an example of you, you know, wanting clarity and candour and wanting to get to the truth, so, as you profess this morning, that you fought really hard to address Mr Arbuthnot’s concerns, as he then was. Do you remember saying that?

Alice Perkins: I did. I did try to do that, yes.

Mr Henry: But you didn’t commission an independent report at any stage, did you?

Alice Perkins: What was the – well, I shouldn’t ask you questions. The Second Sight review was an independent review.

Mr Henry: But I’m talking about a review of the Ismay conclusions, of which you were aware, because you had read the Ismay Report and you were, at one point in your leadership, concerned that, if a proper and full independent review, contrary to Mr Ismay’s conclusions, was not undertaken, then it would look as if the Post Office was unsure of its ground. You never commissioned, did you, a full forensic digital review of the software system?

Alice Perkins: So I think we have covered – have covered this ground already. Lord Arbuthnot raised concerns with me about the subpostmasters’ positions. I offered to look at setting up an independent review. He and I then had some discussions about that and it was important, if we were going to take this initiative, which people in the Post Office didn’t want to take, some people in the Post Office didn’t want to take, that we did this on a basis that he thought he and his colleagues would regard as a proper basis. And there was quite a lot of discussion with him about the best way of doing that.

It was in the light of those discussions that we went down the route of employing Second Sight, rather than going down the Deloitte route. We looked at that yesterday and I spent a certain amount of time, and quite a lot of energy, trying to get the terms of reference of that piece of work as extensive and open as I could.

Now, I have said that, with the benefit of hindsight, I now think that that wasn’t the best – that wasn’t, in retrospect, the best way to have gone about that and I wish that I’d had a fully populated Board by then, and, even though I didn’t have a fully populated Board by then, that I had used the other non-executives who were in position to help me think this through and to put the commissioning of whatever kind of review we decided to go for on the best possible footing, really having gone into what is it that we were trying to achieve here and what would be the best way of doing that and, if need be, if we’d come to the conclusion it would have been better to go down the route of using one of the Big Four, to have that conversation with Lord Arbuthnot.

Mr Henry: Ms Perkins, did you actually read the Deloitte report?

Alice Perkins: Well, we discussed that this morning. If you’re talking about the Board Briefing, I talked about that with Mr Beer this morning. I didn’t, until I saw that report in the disclosures sometime earlier this year, I didn’t remember seeing it.

Mr Henry: So, I mean, it –

Alice Perkins: That doesn’t mean I didn’t see it. I’m just – we’re talking about something that happened 10 years ago.

Mr Henry: That may be right but is your evidence that you cannot say whether you read it or not and –

Alice Perkins: I think I would – since we’ve now established and we have clearly established that it came to me and my fellow Board members, I think I would have read it.

Sir Wyn Williams: So that I’m clear, what you’re acknowledging reading is the briefing report –

Alice Perkins: Yes.

Sir Wyn Williams: – not the full document?

Alice Perkins: Yes, sorry.

Sir Wyn Williams: Right.

Alice Perkins: And, actually, could I just say something about that –

Sir Wyn Williams: Yes.

Alice Perkins: – because, had I seen the full – I mean, I don’t know whether you – anybody here has – well, I’m sure lots of people have seen it – the full report, when I looked at it again earlier this year, has one of those colour ratings, red, amber and green, against the different items and, if you just take one look at that report, you can see that there’s an awful lot of red and an awful lot of amber in there. And, if I had seen that, even if I hadn’t read a word of the text, it would have jumped out at me.

Mr Henry: You’ve said many times that you would have turned over every stone and that you’ve been asked about that, but could I ask you, please, in the light of what was the highly contentious Second Sight Interim Review and the lessons learned, can you explain why, in early September 2013, your Chief Executive Officer resiles from a full Lessons Learned Review, having received advice from Andrew Parsons that it would expose the Post Office to proactive duties of criminal disclosure? Were you aware of that?

Alice Perkins: We discussed this yesterday. I was not aware of it.

Mr Henry: In fact, that reference – no need to take you to it – is POL00146243. But could I ask you, please, now to be shown POL00381706, 11 September 2013.

We can see the heading “Lessons learned [terms of reference]”, PowerPoint for the Audit and Risk Committee, and then if we could scroll up, please, from Ms Vennells to you, 11 September – to Alasdair Marnoch, but copied to you. Then could we scroll up, please. Then we see this, do we not, from Paula Vennells to Alasdair Marnoch – he was, of course, dealing with insurance, wasn’t he?

Alice Perkins: Alasdair Marnoch was the Chair of the Audit and Risk Committee.

Mr Henry: Absolutely but he was also dealing with the notification issue to the insurers, together with Chris Day?

Alice Perkins: In his – yes, he was, yes.

Mr Henry: Yes, copied to you, obviously to the Company Secretary as well, and then could we scroll up, please, and then this:

“Most of the note [so this did come to you] should be self-explanatory, although I should explain the rationale behind our proposed timings. As we discussed last week, there is a choice between proceeding with the review in the near future, while the experiences are still relatively fresh in our memory, or waiting until early 2014 (when we expect [Second Sight] will no longer be involved in the process). Having de-risked the review by narrowing its scope and running it as a short internal exercise, on balance I think it is more important to capture our insights sooner rather than later. We are therefore proposing to commence the process in October (not earlier because it would be more appropriate for both sides to wait until Susan is no longer working in the building).

“Alice and I had chance to discuss at our 121 this morning and we are both comfortable. I would welcome any comments you have.”

Why was it so important for Susan Crichton to be gone?

Alice Perkins: I think – I mean, I don’t remember this, the reasoning behind the change in the scope of the Lessons Learned Review. I have wondered about that in recent weeks myself. I think the key point about Susan was that she had been – I mean, this a Lessons Learned Review about the way in which Second Sight had been appointed to run this review. It was about things such as the absence of an engagement letter, things that we’ve talked about to do with the timetable, the costs, the lack of proper liaison with them, and Susan had been the person who was in charge of that.

Obviously, as long as she was employed in the business, it was going to be a much more sensitive issue in respect of her and her personal position than it would be once she had decided to go. But the need, in my view, to look at how that had been handled and learn lessons from it was just as great, after she had gone, as if she hadn’t gone, because the point was that it was about improving the way the Post Office, in its newly separated state, went about doing things like that.

And I was aware of the fact that this wasn’t – I mean, in a lot of organisations, it’s absolutely normal for people to do lessons learned reviews after something has gone wrong or even when things – important things have gone right, and I didn’t see that happening in the Post Office, and this seemed to be a good example of a way of introducing that.

Mr Henry: No, no, Ms Perkins, this intimately connected to the advice given from Andrew Parsons and also Hugh Flemington, 3 September, about the risk: proactive criminal disclosure. Now, we know that Ms Crichton knew from an early stage, even before the drafting of the Clarke Advice, that she knew about the unsafe witness. I, again, want to ask you, please, why it was so important for Ms Crichton to have left the business before embarking on this de-risked, internal, much narrower in scope Lessons Learned Review.

Alice Perkins: I can’t add anything to what I have already said.

Mr Henry: I see.

Sir Wyn Williams: Can we just look at – I am sorry, I may have missing the threat of this, Mr Henry, it’s my fault.

The reference at the beginning “Most of the note should be self-explanatory”, can I just be sure what the note is that it’s talking about? Is it an attachment to this email or what?

Mr Henry: No, sir.

Sir Wyn Williams: So it’s just that expression that you were exploring?

Mr Henry: Yes, I’m afraid I may be wrong and I would be very happy to be corrected.

Sir Wyn Williams: No, that’s fine. So the position is you are exploring whether this note referred to the document which Mr Parsons may have been the author of, which makes reference to Gareth Jenkins, in effect, whereas Ms Perkins, as I understand it, is reading that as being a note concerned with lessons learned and something different; that’s it, isn’t it?

Alice Perkins: Thank you very much.

Sir Wyn Williams: Fine. As long as I understand what’s going on here.

Alice Perkins: Yes.

Sir Wyn Williams: Fine. Right.

Mr Henry: I mean, the position is that you’re using Susan Crichton as a lightning conductor, aren’t you?

Alice Perkins: No.

Mr Henry: It’s really you and Ms Vennells resolving that this contentious material should not come before the Board because the material is so troubling in its implications that it would have forced the Board to make proactive disclosure to convicted defendants, had it seen it; isn’t that the position?

Alice Perkins: It is absolutely not the position.

Mr Henry: So as a strategy of managing the risk between you and Ms Vennells, geld or downplay the Second Sight Report and keep Gareth Jenkins out of the picture?

Alice Perkins: No.

Mr Henry: I mean, what would have happened on 16 July if – because of course Ms Vennells spoke to Ms Crichton’s report, didn’t she?

Alice Perkins: She did.

Mr Henry: Yes. So, therefore, she must have been apprised of the issues and discussed the matter with Ms Crichton beforehand, otherwise she wouldn’t be able to speak to the report?

Alice Perkins: Well, I don’t think you can necessarily infer that because, as we discussed yesterday, it wasn’t until the morning of the Board itself that, in the light of what had happened over the Non-Executive Directors breakfast, that I took the decision to start the discussion on that paper without Susan being in the room and, as I explained yesterday, that discussion took off in such a way that it became impossible, really, to get into a situation where we could have that discussion with Susan in the room.

But Paula, as she said herself, I think, didn’t know that I was going to ask to kick off that discussion without Susan. I didn’t know that we wouldn’t resume a discussion on the paper without Susan being in the room because it – events just overtook us – overtook me.

Mr Henry: You’re the Chair; events do not overtake the Chair; the Chair sets the scope and the agenda.

Alice Perkins: Yes, that’s absolutely true but, on this occasion – and this does sometimes happen – you’re in a room with a group of people, and they’re human beings, and sometimes things kick off and sometimes it isn’t the right thing to do to try and ram on with what you had previously thought would be what you would do. You do sometimes have to flex things and, as I said yesterday, I now regret that I didn’t, after that Board meeting, after what had happened, think to myself – and I regret that nobody else thought of it either – that we should have arranged a separate discussion on that paper, which Susan would have attended.

But I’m not – having said that, none of us know what would have happened had we done that and we do not know what, if anything, more Susan would have contributed to that discussion than was in the paper.

Mr Henry: It would have been dynamite, wouldn’t it, because not only did you have the paper – and the paper of course, even though she knew about Gareth Jenkins, leaves that out –

Alice Perkins: Yes.

Mr Henry: – but you do have her evidence to the Inquiry that she had informed your Chief Executive Officer that there were likely to be many, many claims for damages based upon what she was aware of. So it would have been dynamite. What I’m suggesting to you is a cordon sanitaire, it was boxed up and never ventilated before the Board for that reason.

Alice Perkins: If it was boxed up, it was not boxed up by me and, if there had been dynamite, we would have dealt with it. That was a group of people who were very independent minded, they were thoughtful people, they had good values. It would have been very difficult but we would have dealt with it.

Mr Henry: One does continue – I mean, one does continue to wonder why significant advices of Mr Altman, Queen’s Counsel, as he then was, did not percolate up to the Board during the period July to October 2013. Can you think of any reason why those significant advices of considerable importance, in fact momentous importance, didn’t percolate their way up to the Board?

Alice Perkins: Mr Beer asked me about this yesterday and I reflected on it. I don’t know why they didn’t. There are all kinds of reasons why they might not have done and I’m not in possession of the facts as to why they didn’t.

Mr Henry: Can you help us, please, though with your contemporaneous knowledge at that time, because, for example, the announcement of the flotation of the Royal Mail Group took place on 10 July 2013, did it not?

Alice Perkins: I don’t remember the exact date but around that time, yes.

Mr Henry: The fact is that the Royal Mail shares were floated on 11 October 2013 at 330p per share but, on the 16th, when they started to trade unconditionally, they were 24 times oversubscribed. That was obviously a matter that was in your mind at the time, wasn’t it?

Alice Perkins: No. Not particularly. I mean, obviously I – from the emails that we – I’ve seen, there was an issue about the Royal Mail prospectus but that was not looming large in my mind at the time. It was just one of those issues that needed to be handled.

Mr Henry: Well, funding must be very, very important for any chair because, of course, you’ve got to fulfil the vision of the Government and the vision of the Government was to turn around the business, eradicate losses, and modernise it and, to do that, you needed Government funding and support, didn’t you?

Alice Perkins: Yes, but I don’t see what the connection is between that and the flotation of Royal Mail.

Mr Henry: Well, the reason why is because, after the flotation, which raised nearly £2 billion – 1.98 – the Government announced 640 million to be invested in the Post Office, and that was on 27 November 2013. I mean, there is a connection, isn’t there?

Alice Perkins: I have no idea. I really don’t see that connection. The fact is that we had been – the Government’s policy in relation to the Post Office, the continuation of the subsidy until the point at which we broke even and the investment made in the Post Office, in order to break even, was something which was being discussed, as far as I was aware, completely separately from the Royal Mail Group flotation.

I never heard anybody make that connection and I had discussions myself with officials in the Treasury and with the Chief Secretary; nobody ever made that connection. I think that there were two completely separate things going on there.

Nobody knew, at the time when the policy in relation to the modernisation of the Post Office was announced, whether Royal Mail would float. I mean, there had not been a very successful history of that, in the past. So I may be completely wrong about this but I personally do not see those two things as being connected in that way.

Mr Henry: From July 2013, the green light was on, because that was the announcement by Vince Cable, the Secretary of State and, of course, that coincided with the perfect storm of Second Sight Interim Review and, also – although I understand your denials on the point – the emergence of Gareth Jenkins as a serious problem for the Post Office. So, I mean, you have seen, surely, the statement to Parliament by the Minister of State, 9 July, which was stressing that none of the issues in the Second Sight Report have any impact on the Royal Mail, which is an entirely separate business: Jo Swinson. You probably also saw the whip’s briefing, which stated that Mr Arbuthnot’s support for the subpostmasters could be distracting to the flotation.

Alice Perkins: I’ve been reminded of those things but you were making a completely – what I thought – I’m sorry if I’ve misunderstood you. I thought you were saying that the Post Office wouldn’t have got its money from the Government if Royal Mail hadn’t floated so successfully. That’s what I was arguing with you about.

Mr Henry: No, no, I’m not saying that, but it’s obvious, however, that, if nearly £2 billion comes in to the Treasury, it makes it a lot easier for 640 million to go out to the Post Office and these things cannot be looked in hermetically sealed boxes, as it were.

But I want to come to this: if you’re saying that Post Office Limited had really absolutely nothing to do with this, then, surely, you must have been extremely concerned by the intervention of your CEO with the prospectus?

Alice Perkins: I’ve seen – recently re-seen those emails, and it wasn’t – I mean, clearly, I was involved in discussions with the CEO about that.

Mr Henry: Yes, “I have earned my keep on this one”. Did it not occur to you – I mean, from the point of view – and I don’t know your experience in this field, although I know that you do coach and lecture on corporate governance – but, surely, the whole issue of a prospectus is that you load the prospectus with risk – you load the prospectus with risk, so that nobody is misled or nobody is, as it were, induced to invest on a false basis. Yet we know for a fact that the Post Office was in the process of notifying its insurers concerning the prospects of civil litigation regarding wrongful convictions.

I mean, do you not see the extraordinary contradiction there with your CEO, who knows about disclosure to the insurers and yet she’s having matters removed from the RMG prospectus?

Alice Perkins: I don’t know the full – I haven’t got the full documentation on this issue. It is, however, clear from the email that this was an issue which had been being discussed, both within the Government machine and within the Post Office, that this prospectus was in draft, representations from various different organisations connected with the Royal Mail would be invited on that draft, and the Post Office had – and the officials in the Business Department were thinking about the way in which this was described and made some representations to the Royal Mail Group about that.

The ultimate – the process of putting a prospectus together is highly regulated. Slaughter & May were in there and, in the final analysis, it was for the Royal Mail Group to decide what was in its prospectus or not within its prospectus.

Mr Henry: The problem, however, cannot be separated from the fact that the Royal Mail Group had been historically responsible for prosecutions before separation, had it not?

Alice Perkins: Yes, it had.

Mr Henry: No need to take you to it, but that was a document that you saw earlier today, and you were enquiring as to liability for the Post Office as well before and after the split. Do you remember that?

Alice Perkins: Would you mind taking me back to that, please?

Mr Henry: Yes, certainly.

Sir Wyn Williams: Does this add to the point, Mr Henry?

Mr Henry: It doesn’t really add to the point.

Those are my questions, sir.

Sir Wyn Williams: Thank you very much.

Now then, I know that Ms Patrick is going to ask some questions.

I understand that Ms Leek wants to ask questions, and I further understand, Ms Leek, that you’re going, please, be about ten minutes, is that right?

Ms Leek: That’s right.

Sir Wyn Williams: Well, let’s have that now, if that doesn’t inconvenience Ms Patrick, and when we can have our afternoon break.

Just for you to know – well, she’ll introduce herself. Why am I speaking?

Ms Leek: Thank you, sir. I think I said 10 to 15 minutes.

Sir Wyn Williams: Well, we’ll see how we go.

Ms Leek: Thank you.

Questioned by Ms Leek

Ms Leek: Ms Perkins, I ask questions on behalf of Paula Vennells. I am Samantha Leek.

I just want to ask about one issue and I want to try and clarify with you when you first knew about the existence of bugs. I’m going to ask Mr Enright to move a little to the left so we can see each other, thank you.

Mr Beer asked you yesterday if the two exceptions or anomalies, to use the preferred language, as he said, regarding Horizon, were not passed on to you at an earlier stage. You will remember that was before 3 July. You said you couldn’t remember if you were irritated, there was a lot going on.

Alice Perkins: Mm.

Ms Leek: I just want to show you a series of emails that suggest that you were told about bugs before 3 July. Can we start with POL00098797. If we go down to the bottom, go down to page 2 – thank you – there’s an email from Alwen Lyons to Paula Vennells on 28 June, and we will have a look at that in a moment but we can see, if we go up a little bit, that that was sent to you by Paula Vennells on the same day, in fact just a couple of minutes after she was sent that email by Alwen Lyons.

Alice Perkins: Can I look at Alwen’s email for a bit longer, please?

Ms Leek: Yes, I’m going to take you through that.

Alice Perkins: Okay.

Ms Leek: The first thing Alwen says here, subject, “next steps on Horizon issues – update”:


“Rod Ismay and Lesley” –

Mr Beer: Can we ask for the thing to be scrolled down?

Ms Leek: I’m so sorry. Could we bring that back up on the screen and scroll down to page 2. Thank you:


“Rod Ismay and Lesley working the detail of the 2 bugs, to understand them and then get them into language that is clear and can be communicated.

“Mark is putting in place expert external comms resource to be dedicated to this issue from Monday …”

If we go down a little, to the bottom bullet point:

“We think [Second Sight] will present the 4 cases, some of which will not be finished, but we are not sure yet. They will also raise the issue of the ‘bugs’ which were outside the cases but which we disclosed to them.”

If we can then scroll up to the email that was forwarded to you from Ms Vennells:

“Alice hi. I do hope your Friday is good.”

We go down to the next paragraph:

“You will see below Alwen’s proposed next steps. It covers all the ground at present. We may update following today’s phone call with [Second Sight] in an hour; and certainly will update post-Alwen’s meeting with Janet on Monday.”

“Alwen and I are staying close (two calls already today) and I’m expecting an update later this [afternoon]. So no need to bother you today.”

If we go to the email above, which is your reply to Ms Vennells within the hour. You say:

“Thanks for the updates. I am glad we have the best people on this.”

We looked at the rest of this yesterday, about Maxwellisation/Salmon letters angle. So it seems clear from this email that you already knew about the bugs at this point because you don’t reply “What are you talking about? What bugs? I’ve no idea what you’re going on about here”; you say, “Thanks for the update”.

Alice Perkins: I do say that but I’m not sure what con – you can’t – I can’t draw a definitive conclusion from that, as to – I don’t recall ever having heard about these bugs before that.

Ms Leek: Had you received an email from Ms Vennells on 28 June, at the point at which you knew Second Sight was about to report, setting out what she has said here about Rod Ismay and Lesley working out the details of the two bugs, surely you would have said, rather than “Thanks for the update”, you would have said, “What are you talking about? I don’t know anything about bugs”?

Alice Perkins: I’m really sorry. I mean, I can see absolutely why you’re saying that but I don’t remember – I’m not sure what I can add to this, I’m afraid.

Ms Leek: Of course. Thank you.

Perhaps we can now go back another six weeks to emails that took place on 16 May 2013, and if we could look at POL00098278. Ms Vennells sent you an email on 16 May:

“Hi Alice, lovely day!

“Just to let you know I haven’t forgotten about Vanquis – I have an approach, which I have sent to Nick and Chris. I should get back to you shortly.

“Also re James Arbuthnot – I have asked for an update on our work plan by the end of this week, to make sure we are [on] track. (JA is away in committee business, so we are meeting post-Whitsun recess.)

“One other issue arose overnight, which I may need to brief you on over the next couple of days, so will try to get a phone slot.”

If we scroll up, you send an email back:

“Fine thanks. I am now unexpectedly freer this afternoon.

“So if someone let’s me know when you are able to talk I’ll try and fit round that.”

Can we then go to POL00029587. By this point, a call has been arranged between you and Ms Vennells for the afternoon and Alwen Lyons sends to Paula “speaking notes for your call with Alice this afternoon”. Can you just scroll up a little – scroll down:

“Paula here are my speaking notes for your call with Alice this afternoon.

“I have a call with James on 23 May, next Thursday at 10.30, when we will discuss how he wants the investigation to continue …”

Just scroll up bit more, please.

“Alwen will …”

We go down to the sixth bullet point – I’m so sorry, the second bullet point:

“… some instances are coming to light where there is evidence that there are bugs in Horizon, which I am being told is normal in any large computer system. But I am still being assured that the system’s integrity is not in doubt.

“Lesley is meeting Fujitsu tomorrow morning to go through the technical assurance that the subpostmaster’s trading statement cannot be changed without their knowledge.

“Alwen is meeting them on Monday to look at with a layman’s eyes and understand what it might have looked like for a subpostmaster using the system.

“The Good News is that where we have found bugs since HNG-X (new Horizon) they have been detected and put right with no also for the subpostmaster, and Fujitsu now monitor the suspense account for any such problems.”

“Alwen will specifically ask on Monday if anything could be happening we do not know about eg too small to register at the office, and old Horizon bugs.

“This is not good Alice, but from what we have seen so far our response to bugs has been effective.

“I have asked for some time in our diaries next week to talk through our approach, and would welcome your counsel before the James meeting.”

Do you recall a conversation that afternoon in which you were told about those bugs?

Alice Perkins: No, I don’t.

Ms Leek: So when you received the email on 28 June, giving you an update about what was going on with the bugs, are you saying that you hadn’t been told about that beforehand or you simply can’t remember?

Alice Perkins: I can’t remember, I’m really sorry. I’ve only – some of this documentation has – only came to me at lunchtime today. So, you know, I have had a look at it but I’m afraid I have absolutely no recall.

Ms Leek: Okay. Thank you.

Sir, I have no further questions.

Sir Wyn Williams: Thank you, Ms Leek.

So we’ll take our afternoon break now, and resume at 3.30 when Ms Patrick will ask her questions and, if they are so advised, your legal representatives may wish to ask a few questions of you but that’s up to them, not me. Then that will be it. All right?

The Witness: Thank you very much.

Sir Wyn Williams: So 3.30.

(3.13 pm)

(A short break)

(3.30 pm)

Questioned by Ms Patrick

Ms Patrick: Good afternoon, Ms Perkins. My name is Angela Patrick and I ask questions on behalf of 86 subpostmasters who were convicted by the Post Office and have since had their convictions overturned, including Mrs Hamilton, who I’m sure you can see is sitting to my left.

Alice Perkins: I do see.

Ms Patrick: We want to cover three topics.

Alice Perkins: Yeah.

Ms Patrick: First, we’re going to look at the Royal Mail Group prospectus, which you’ve just covered briefly with Mr Henry.

Alice Perkins: Yes.

Ms Patrick: Second, Mr Beer has talked to you a little about Mr Davies and publicity around Horizon and I want to come back to one example of the Post Office’s approach to subpostmasters in the media; and, finally, I want to look again at one of the first documents that Mr Beer took you to, and I’m going to call it the Zetter notes if you’ll remember it from yesterday morning.

Alice Perkins: You’ll have to remind me, I’m sorry.

Ms Patrick: I’ll refresh your memory, when we get that far. If we can start with the Royal Mail Group prospectus and Mr Henry has raised the flotation and you’ve talked about it not really being a topic that was looming large but you have mentioned a few emails.

Alice Perkins: Mm-hm.

Ms Patrick: If we can look at a few of those, just to see where you were coming in.

Alice Perkins: Yeah.

Ms Patrick: If we can start with POL00372265, please, and I want to start about halfway down page 1, if we could.

Alice Perkins: Can you say just give me the context of this?

Ms Patrick: I will. This was an email sent on 16 August 2013 and, don’t worry, I was only waiting for it to be on screen –

Alice Perkins: Of course.

Ms Patrick: – so we could look at it together.

Alice Perkins: Okay, great.

Ms Patrick: I won’t leave you hanging as to what we were looking at. There is an email here, you can see, at the top. It’s Paula Vennells to you on 16 August and, if you see, she’s messaging at the top looking for a time when you can have a call. I don’t want to look at the detail but she wants to catch you up on some issues and, if you can see, there’s a list of four?

Alice Perkins: Mm-hm.

Ms Patrick: If we go to the fourth bullet point and, if somebody could expand that, I’d be grateful. It says, “RM Prospectus”; can you see that one?

Alice Perkins: Yes.

Ms Patrick: “… the language in the risks section, which refers to [the Post Office] is very negative. We are on the case – it is being handled through external lawyers, and I have asked for a revised draft by Monday. I am not suggesting we flag this to the Board yet but you need to be in the picture. Susan has picked this up and insisted inaccuracies are removed and the tone improved. However, this is in the risk section, my guess is we may still be uncomfortable with final draft and so I have already asked Susan to flag to Will that we may want to escalate it to HMG. We will need to brief the Board properly at some stage but probably best when we have something to send out.”

Now, I only have a few questions about it.

Alice Perkins: Okay.

Ms Patrick: You were, it appears, being briefed on this as an issue as early as mid-August in 2013?

Alice Perkins: It does look like that, yes.

Ms Patrick: The issue you were being told was arising it risks section of the prospectus.

Alice Perkins: Yes.

Ms Patrick: It was very negative about the Post Office and Susan – I presume that might be Ms Crichton?

Alice Perkins: I can’t think – well, it wouldn’t have been Susan Barton.

Ms Patrick: It wouldn’t have been Susan Barton. Ms Crichton was to flag that it might need to go to HMG, Her Majesty’s Government, and Ms Vennells thought you might need to brief the Board properly at some stage. But she was saying, aside from whether the Board needed to be briefed, she was giving you this information now, wasn’t she?

Alice Perkins: She was.

Ms Patrick: Right. Can we look at the second document, a second email, and it’s POL00419640. This is an email which moves us on a little – and I’ll wait for it to come up – and I want to start at the bottom of page 1, where you’ll see there’s an email from you?

Alice Perkins: Yes.

Ms Patrick: We’re now a little while on, a few weeks on, three weeks on, 9 September 2013.

Alice Perkins: Yeah.

Ms Patrick: You are sort of responding “Thank you for your previous emails”. We don’t need to spend much time on your response, I just want to note what you say to start with:

“… I appreciate no surprises even if the news is unwelcome!”

So that was the first message you were giving to Ms Vennells that day.

Alice Perkins: Yeah.

Ms Patrick: Can we scroll up, the rest I don’t think we need to look at in detail. I want to look at Ms Vennells’ reply above, and it is the last paragraph of Ms Vennells’ reply:

“On the prospectus, now Mark is back I have him, Martin and Hugh meeting this pm and they will speak to BIS today.”

Would that be Mark Davies, Martin Edwards and Hugh Flemington?

Alice Perkins: It could have been. I mean, I don’t know. But that sounds – you know, that sounds a perfectly reasonable suggestion.

Ms Patrick: So they were going to speak to BIS:

“I am still not happy with the content: although it may be legally accurate, it is not helpful reputationally.”

Then she goes on to say, ironically, Post Office has enough branches signed up to cover the distribution of the prospectus and she is going to keep you posted.

I only have a few questions about this one. She’s telling you, even if the content was legally accurate, her concern was primarily reputational risk, wasn’t it?

Alice Perkins: Yes.

Ms Patrick: Whose? Logically, would it follow she was concerned about the reputation of the Post Office?

Alice Perkins: I don’t know what she had in mind but it’s a reasonable interpretation that she’s thinking about the Post Office, yes.

Ms Patrick: Could it be the reputation of the Royal Mail Group?

Alice Perkins: It could be.

Ms Patrick: The Government?

Alice Perkins: No –

Ms Patrick: Anyway?

Alice Perkins: – I –

Ms Patrick: You don’t know, you’re just speculating. Logically, it could be the Post Office?

Alice Perkins: Yes, it could be.

Ms Patrick: If we could scroll up little.

I’m sorry, Mr Henry was trying to attract my attention, sir.

If we could just scroll a little, we see the next section.

Alice Perkins: What do you mean by the “next section”?

Ms Patrick: I apologise, can you see “No I didn’t mean that”, where you reply at the bottom of the part you can see on screen there Ms Perkins, “No I didn’t mean that”; can you see?

Alice Perkins: I didn’t mean what, sorry?

Ms Patrick: I’m just trying to attract your attention. It’s now highlighted in yellow. You reply at 2.11:

“No I didn’t mean that.”

We don’t need to look at the first line, it’s the second line.

Alice Perkins: Okay.

Ms Patrick: “On the content of the prospectus, Will was absolutely clear that this would be and should be properly sorted. You only need to read the Hansard of last week’s Parliamentary debate to see how important that will be politically. So I am sure Jo S would swing into action on this if it were necessary.”

So Will had given you some assurances, was that Will Gibson at ShEx?

Alice Perkins: I should imagine so. I don’t know.

Ms Patrick: “Jo S”, is that likely to be Jo Swinson?

Alice Perkins: I would think so, yes.

Ms Patrick: Thank you. We don’t see any challenge by you, in this message, of Ms Vennells’ view of the issue being reputational and not one of legal or technical accuracy, do we?

Alice Perkins: No, no, you don’t.

Ms Patrick: Your focus was on how important it was going to be politically; getting this sorted for Post Office was politically important wasn’t it?

Alice Perkins: Well, I think we’ve had this discussion a great deal over the last two days, haven’t we, and the inference is often being made –

Ms Patrick: Ms Perkins, can I stop you.

Alice Perkins: Yes, you can.

Ms Patrick: I don’t want you to draw any inference.

Alice Perkins: Okay.

Ms Patrick: I just want you to reflect on what’s in the email –

Alice Perkins: Okay.

Ms Patrick: – that what was being exchanged contemporaneously, here, you were sending a message here that the importance was political, weren’t you?

Alice Perkins: Yes, I – yes, I was.

Ms Patrick: It was so important, you were sure you could rely on the Minister to step in?

Alice Perkins: Yes, well, that I thought she would, yes.

Ms Patrick: Indeed. Now, can we look at the third document. It is POL00381730. Thank you. I want to start at the bottom of page 1 again. Having scrolled to the very bottom, we can see the email that’s from you. Can you see that, Ms Perkins?

Alice Perkins: Yes.

Ms Patrick: We’re on Monday, 16 September now and you’re writing to Jorja Preston, who, I can see at the top there, that’s your PA; is that right?

Alice Perkins: Yes.

Ms Patrick: The subject is “Mark Russell”. We’ve hearing that name earlier; was he the Head of ShEx?

Alice Perkins: He was.

Ms Patrick: Great. You told Mr Beer that you would have regular meetings with him. We’ll see in the message here you’re talking:

“I think my main question is: what should my objective be in talking to him about the Strategy and Funding”, I need to know the position, so that he is aware of the Board and the package and what might be needed to get the Fed on side.

You go on to talking about strategy and funding and a number of other matters, until the second line from the bottom, and you say – sorry, third line from the bottom:

“Also the update on where we are on Second Sight etc. And the latest on the RM prospectus. So basically, all the current hot topics.”

You say:

“I would like to talk to Paula about this at my 1:1 with her.”

This is you, I think, talking about preparing for a meeting with Mr Russell?

Alice Perkins: It looks like it.

Ms Patrick: Is that fair?

Alice Perkins: It does look like that, yes.

Ms Patrick: A number of topics, and the Royal Mail prospectus was a hot topic by this point, wasn’t it?

Alice Perkins: That would be the inference of this, yes.

Ms Patrick: If we can look at the fourth document, please, it’s UKGI00002057, please. This is 18 September and it’s not necessarily a message you would have seen, and you see it’s a series of exchanges between Will Gibson and Tim McInnes.

I would like to look very briefly – it’s a long message, I don’t want to look at a lot of it, I just want to see where you’re mentioned. Can we go to halfway through page 2, please. You can see there there’s a message from Mr Gibson, we’ve heard him mentioned this morning, and I think we’ve heard Tim McInnes mentioned this morning also. But you see there he says:

“… just to echo Tim’s point re sign-off, I have just come from a meeting with POL’s CEO where she was voicing her concerns that not [all] POL’s comments had been picked up and they have definitely not been signed off their wording! That said, we will ensure that we have chapter and verse from POL on what’s outstanding.”

If we can scroll up from there to the bottom of page 1, I’d be very grateful.

We can see there, there’s a message from Mr McInnes back to Mr Gibson:

“Yes. And I just had Martin on the phone … Alice is properly up for a fight. I’ve bought some time but let’s see what Emma can set up.”

Now, if we scroll up again, Mr Gibson replies, and you can say what he says:

“Alice is coming in to see Mark tomorrow …”

That would fit with the timing of your preparation for a meeting, and, above, we can see the message continues. Were you up for a fight, Ms Perkins?

Alice Perkins: I simply don’t remember all of this, and those are not my words. I mean, what you’re getting there is you’re getting Tim McInnes reporting to Will Gibson something that somebody else has said to him.

Ms Patrick: Entirely. I wouldn’t expect you – as I said at the outset, you hadn’t seen this message. But that was, it appears, how your position was being presented by Martin – I presume Martin Edwards – in advance of your meeting with Mark Russell; is that fair?

Alice Perkins: It would appear as though that is how it’s been described but we don’t know what Martin said to Tim McInnes and we don’t know – I mean, we – there’s a lot we don’t know.

Ms Patrick: He may come to give evidence and we may be able to ask him about that and, if we scroll up a little way further, you can see there on the screen – actually, I can see it now, please stop scrolling, it’s now moved to the bottom – the reply there:

“Not unhelpful – I just don’t want things to go nuclear until that’s all we have remaining.”

Does that fit with your recollection of this discussion at the time? Was this discussion on the verge of nuclear status, for the relationship with Royal Mail Group and the Post Office?

Alice Perkins: No, absolutely not. No. I’m sure that it wasn’t. However, I mean, that is just my reaction based on what I know about how I would be thinking about something like this. But, just to be completely clear, until I saw these documents, either earlier today or yesterday, I can’t even remember when I first started seeing this email chain – I had – I simply hadn’t remembered anything about this issue at all.

Ms Patrick: Okay. Well, if we can look at the last document, I just – this is the last one I think I need to take you to, and it may refresh your memory a little bit about what was being discussed. It’s POL00381747. It takes us forward to 20 September, and it’s not, again, a message you would have seen, I just want to see if it will help your memory. It’s a message you can see there from Mr Edwards to Paula Vennells, copied to Mr Davies. Again, it says, “Prospectus update”.

I’m sorry, I’m going to have to bring it up on my screen because that one is a little bit far away for me to read. I apologise. You’ll have to bear with me for a moment. He’s updating Ms Vennells. I won’t read it all but I’m going to read the first bullet point a little. Focusing on the first bullet point:

“Latest draft attached – overall it has improved and addresses some of our concerns, although the risks section still, intrinsically, negative in tone. The ShEx POL team have pushed hard for additional language to be inserted on the strength of the relationship to contextualise these risks, but have received firm push back that this wouldn’t be appropriate for this element of the document. Such language is however covered elsewhere in the document. My sense is we are going to have to accept this position and focus now on making sure the positive story is brought out in the wider comms materials – the marketing materials for the transaction, our own lines to take and Ministers’ statements.”

Now, focusing on that, the first bullet, it seems there were concerns about language in the risks section, but POL, Mr Edwards was saying, could just accept the position and then deal with it in comms; is that a fair summary?

Alice Perkins: I think so, yes.

Ms Patrick: So it would go on Mr Davies’ desk, possibly? He was copied in on them?

Alice Perkins: Yeah.

Ms Patrick: Yeah, and if we scroll down, can we skip to bullet three. It seems – except one issue is outstanding by this point. He writes, in the third bullet:

“I think the one remaining issue we might want to seek to change now is the sentence on the [Second Sight] review, copied below. Ideally this would just be deleted because it is misleading in the context of a section on IT risks, as we discussed before.

“‘In July 2013 [(this is the sentence he’s talking about, the part], an Interim Report was published into alleged problems with [Post Office’s] “Horizon” computer system, which is used to record transactions in its branch network. The report confirmed that no system wide problems had been found in relation to the “Horizon” software, but suggests that [Post Office] should examine its support and training processes for subpostmasters’.”

Now, I read that in full just to see if it helps with your memory but, in summary, Mr Edwards was saying that the Post Office wanted that deleted entirely, ideally; is that right?

Alice Perkins: I think he is saying it would be deleted in the context of a section on IT risks. That’s what he seems to be saying.

Ms Patrick: That ideally this would be deleted. We could skim the rest but we can get to the very bottom, and last four bullet points, I think we can see, he says – and we’ve had this all before, the Inquiry has had this issue raised with Ms Vennells – ShEx had been working on it and he says:

“… we’ve reached the end of the road in terms of ShEx’s ability to influence this”, and he references that the prospectus is essentially going in on the Monday, so it’s imminent.

He says Alwen could pick it up but they were much more likely to listen to – and this is a message to Paula:

“… more likely to listen to you …”

Was this him, at this point, when the prospectus was imminent? Do you recall it being bumped up to Ms Vennells to deal with?

Alice Perkins: I don’t, I’m sorry.

Ms Patrick: Okay. Now, we know and the Inquiry has heard that Ms Vennells later reports to you by email that she thought she had earned her keep on this and she puts it in her review for the key achievements for the year. By this point, we know that when she reports to you it is going to be removed. You’d been involved, ShEx had been involved, you’d mooted something going up to the Minister; Ms Vennells, she did earn her keep on this one, didn’t she?

Alice Perkins: Well, it looks as though she got agreement to what it was that she was proposing. Those are her words; they’re not my words.

Ms Patrick: Okay. No problem. We shall move on to the next topic, then, Ms Perkins, and I think these can be shorter. The next topic I wanted to look at was Horizon publicity.

Now, Mr Beer covered Mr Davies’ appearance on the Today Programme very briefly with you this morning. I remember you saying at home you listened to Radio 4 Today every morning, and we talked about the appearance he made in December 2014. Now, Mrs Hamilton is sitting next to me. She also appeared on that programme that day and she listened live, as Mr Davies pointed to subpostmasters experiencing “lifestyle issues”. Now, when Ms Vennells gave evidence, Mr Moloney asked her about a late evening message she sent later that month, on 17 December, having watched an episode of the One Show.

Alice Perkins: I vaguely remember –

Ms Patrick: Do you recall?

Alice Perkins: Vaguely. Only vaguely.

Ms Patrick: I might be able to refresh your memory. Can we look at POL00150352. If we could start – it’s a multiple-page document, if we could start at page 3, we can find the email from 17 December.

You see there there’s a message from Ms Vennells and it goes to Mark Davies, to Belinda Crowe, Gavin Lambert, Patrick Bourke and it’s cc’d to you and it’s sent in the late evening, at around 9.45.

The Inquiry is very familiar with this. I’m not going to read much more than I need to but I think it is worth repeating. She writes:

“Hi all, I managed to catch The One Show on iPlayer.

“Not denying the fact that it is unhelpful and inaccurate (especially the focus on Horizon – but see below re thoughts on that), Mark has achieved a balance of reporting beyond anything I could have hoped for. The statements stamped across the screen with the [Post Office] sign as a backdrop were really powerful. They emphasised everything we have done, and came across as … fact! Very good.

“The rest was hype and human interest. Not easy for me to be objective but I was more bored than outraged. The MP quoted (who?) was full of bluster, and inaccurate. Jo Hamilton lacked passion and admitted false accounting on TV. [James Arbuthnot] was nowhere to be seen. And the bulletin was too long.

“What I thought was helpful was that it presented Horizon as the problem, which is exactly what [Second Sight] say they haven’t found. And so easier for us to refute. There was nothing about intimidation, poor coaching and the message about not knowing how to use the system, in my eyes made the [subpostmasters] look inadequate.”

Now, we can pause there and we can come back to the language. Mr Moloney asked Ms Vennells if she might have regretted that message the morning after she’d sent it and copied it to you. I’d like to look at the day after. If we could scroll up through this message slowly, I’d be grateful.

We can see the next morning, Belinda Crowe circulates it to Angela van den Bogerd, if we can scroll up. What happens is Mrs van den Bogerd engages with a request from Ms Vennells about one of the subpostmasters who appeared in the programme, not Mrs Hamilton. I’m not suggesting we look at that detail, I just want to see where it goes next.

Can we scroll up a little way. We see Ms Vennells replies. I just want to stop there one moment. I don’t want to look at the detail but I just want to raise a point which Ms Vennells uses about the language she used here. This isn’t copied to you at this moment but it is later. At the very last paragraph of this, she says, “Chris,” and it’s copied to Chris Aujard:

“… If you didn’t see The One Show, please can you watch the clip – again I expect we are best to do nothing at this stage but [references the subpostmasters name] is completely out of order, inaccurate at best, lying at worst.”

This is the part I want to look at, whether it is right or wrong, she says: “

“And has wilfully collaborated to [I presume that’s ‘bringing’] us into disrepute.”

Now, briefly, and we don’t have to look at the detail, is this just another example of the belligerent language we had seen being used in the business when talking about campaigning SPMs? “Wilfully collaborated in bringing us into disrepute”, what do you think of that language?

Alice Perkins: Well, looking at this now, obviously it looks absolutely dreadful.

Ms Patrick: This is language being used by Ms Vennells herself, isn’t it?

Alice Perkins: Yes, in this email it is, yes.

Ms Patrick: You weren’t copied in on this email but, if we can scroll up, we see Thursday, 18 December, 7.24, very early in the morning after the original message:

“Hi Alice, if you get the chance probably worth a view of The One Show. (From both your directorships, actually – the BBC produced a very viewable 5-minute bulletin, pity it is so wrong.)

“The note below refers.”

There’s some personal message: it’s very close to Christmas and she’s talking about some cards getting off.

Now, she writes to you again, directly copying the whole of that thread, including her message from the last night. She sent you her One Show (unclear) twice. Now, if we can turn back to that original message on page 3, just so we have it in front of us. Did you take issue with what Ms Vennells was saying?

Alice Perkins: I don’t – I’m afraid I’m really sorry, but I’ve not – I don’t think I’ve seen this before. I may have done but I simply do not remember this.

Ms Patrick: We’ve seen the first and I’ve read it out, she was congratulating Mark Davies for a job well done. This was a win she wanted you to see, wasn’t it?

Alice Perkins: It would look like it, yes. It would look like it.

Ms Patrick: She was saying Mrs Hamilton lacked passion, subpostmasters looked inadequate. Did this simply reflect the attitude that was being adopted by the Post Office leadership team at that time in late 2014 to the campaigning SPMs, the subpostmasters?

Alice Perkins: I can’t add anything to this, I’m afraid. I mean, it looks – as I’ve just said, it looks absolutely dreadful, given what we know now, and I am – I’m very –

Ms Patrick: I’m going to stop you there, Ms Perkins.

Alice Perkins: Oh, I’m sorry.

Ms Patrick: Not dreadful according to what we know now. Looking back, she sent it to you twice?

Alice Perkins: She sent it to me twice?

Ms Patrick: Yes. She sent it to you on 17 December when she copies you in, she sent it to you the next morning, with the rest of the thread. Did you have any issue with the language she was using at the time? Can you remember taking it up with her? “Oh Paula, what have you done?”, can you remember?

Alice Perkins: I’m terribly sorry, I simply cannot remember any of this. I do remember the Today Programme because I remember hearing it but I don’t remember this.

Sir Wyn Williams: Is there any written response?

Ms Patrick: I haven’t found one, sir.

Sir Wyn Williams: Okay, fine.

Ms Patrick: Looking at Ms Vennells’ language, she says she is “more bored than outraged”. Had the business become bored by the subpostmasters campaign by this point?

Alice Perkins: That’s not how I would describe how I thought about it.

Ms Patrick: Did the business simply just want to move on and get on with the job of making the Post Office sustainable for the future?

Alice Perkins: Well, the business did want to make the Post Office sustainable for the future but, as far as I was concerned and as far as I am aware my Board colleagues were concerned, we weren’t wanting to do anything different from what we’d wanted to do all along, which was to handle the issues properly.

Ms Patrick: Handle the issues properly, but your CEO is “more bored than outraged”.

We can move on. Can we look at the final topic and that is the Zetter note, and I do want to help your memory. Mr Beer started with this very early on yesterday and you said when you were looking at it – you were looking at handwritten notes, if you remember.

Alice Perkins: Oh, yes.

Ms Patrick: You can be sure, of course, that you said in meetings sometimes you’d scribble on the papers and sometimes you’d go back and add a note afterwards to keep your memory fresh.

Alice Perkins: Mm-hm, yeah.

Ms Patrick: Mr Beer took you to a lot of notes, and I just want to look at one scribbled note that he didn’t look at and, if we look at the document, it’s POL00413669, and that should bring us up with the diary page, if you remember, which referred to the Bistrot at The Zetter. If you remember, the date was 19 March, this was yesterday morning Mr Beer brought this up. It’s between your first meeting with James Arbuthnot – I think was 13 March, and you were preparing for a meeting on 28 March, which Paula couldn’t attend, Ms Vennells wouldn’t be able to go to. There was a pack of papers disclosed to the Inquiry behind this diary entry.

I’d like to scroll – we don’t need to scroll, but if we could go to page 5 of the pack, Mr Beer skimmed through this yesterday to get to the main note but this, I think, was described as a meeting prepared by Mr Arbuthnot’s office, as he was then, Lord Arbuthnot.

Alice Perkins: Mm-hm.

Ms Patrick: If we skim through, we see some notes on the side, we see some handwritten notes there, if we scroll up, skim through 6 – I don’t want to go all the way to page 9, which is where Mr Beer took you yesterday. I want to go to page 7 in the little pack. Ah, it may be page 8 but I think it’s page 7.

There’s a page, if we keep scrolling up, you see “Faults with Horizon”, there, somebody has annotated it on the right with a little mark next to it. Scroll up a little further, keep going, please – stop.

We see a little scribbled note there and I want to look at it from the bottom up, it says, I think, there’s a helpline – it says, “There is a helpline available”. It’s underlining there is a helpline available. The Inquiry has heard a lot about the helpline. I don’t want to go to that.

The next one up, “Much cash around”. Now, you told Mr Beer yesterday you’d been taken aback by the fact that there was so much cash in the business.

Alice Perkins: This is not my handwriting.

Ms Patrick: It’s not your handwriting. Is it possibly a note that was scribbled at some point during the meeting?

Alice Perkins: It’s not my handwriting.

Ms Patrick: Not your handwriting. Can we just explore the top message there “Reputation key”?

Alice Perkins: It’s not my handwriting.

Ms Patrick: Can you help with whose handwriting it might be?

Alice Perkins: I’m sorry, I don’t know whose handwriting that was. All I can tell you is that it’s not mine.

Ms Patrick: It’s in a pack of notes behind the same diary entry and with the same notes that you were taking, and you can’t assist us on who took it?

Alice Perkins: Well, it obviously, it could be Paula’s writing. All I can tell you is that it is not my writing.

Ms Patrick: Okay, was this a message you were being given from within the business by Ms Vennells, or somebody else, that reputation was key, even at this time in 2012?

Alice Perkins: I don’t remember this coming up at this meeting. I mean, it is a responsibility of any Board to protect the reputation of the organisation. It’s one of the, you know, it’s one of the many responsibilities a Board has, and I think we have talked a lot in the last two days about why I thought, and other people thought, it was important to protect the reputation of the Post Office business, on the basis that I believed that the Horizon system was sound and that we didn’t – that – and the prosecutions had been properly conducted.

Ms Patrick: We’ve looked reputation in the context to of the RMG prospectus. We’ve looked at fighting – we’ve talked about fighting for the reputation of the Post Office this morning. This is 2012, before your bulk of engagement with James Arbuthnot. I’m going to suggest reputation really was the key question for the business, not just as –

Alice Perkins: Not mine.

Ms Patrick: – a responsibility, it was a goal from the start, and throughout, wasn’t it, Ms Perkins?

Alice Perkins: Not mine. I’ve made absolutely clear what my motivation was in relation to Lord Arbuthnot’s concerns.

Ms Patrick: Thank you.

Alice Perkins: I wanted to set up an independent review to get to the bottom of it and I made it clear in a number of contemporaneous documents that I wasn’t afraid of getting bad news, if bad news were to come.

Ms Patrick: Can we stop and pause there for a minute. Others have talked to you about the future of the Post Office, all the work that was going on, the Network Transformation, the shareholder, the Government’s real goal for the business was to get to profitability and a mutualised Post Office that could stand on its own feet with less dependence on Government subsidy, wasn’t it?

Alice Perkins: It was, yes.

Ms Patrick: Would that be made more difficult if the Post Office was no longer the nation’s most trusted brand but, instead, faced public investigation and opprobrium for the wrongful prosecution of hundreds of its own people?

Alice Perkins: Of course it would but – I’m sorry, I am repeating myself, but this is really, really important.

Ms Patrick: Ms Perkins, I don’t want you to repeat yourself.

Sir Wyn Williams: I think I’ve got this point.

Alice Perkins: Okay, thank you.

Ms Patrick: I just want to ask one last question, sir.

Was this prospect that the Post Office was responsible for wrongfully criminalising people like Mrs Hamilton something that, during your time in the chair, the business simply could not or would not contemplate?

Alice Perkins: Not as far as I was concerned and, as far as I can possibly be aware, that was not the position of my fellow Non-Executive Board Directors.

Ms Patrick: Looking back, do you think the Board might or ought to have been less bored by the subpostmasters and more outraged by the possibility of miscarriages of justice that had ruined hundreds of its own people?

Alice Perkins: The Board was not bored of this issue. I have said on a number of occasions over the last two days that I think that there were inns instances where the Board should have acted differently.

Ms Patrick: Thank you, Ms Perkins. I have no further questions.

Alice Perkins: Thank you.

Mr Beer: I have spoken to Ms Berridge, who represents Ms Perkins, and she said, as long as I deal with one issue, which will take about three minutes; she is content not to ask questions.

Sir Wyn Williams: Fine.

Further Questioned by Mr Beer

Mr Beer: It’s a very small point of detail, and I don’t think it will stop the world turning, but it’s an important point of detail, perhaps.

Can we look, please, for the last three minutes of questions, Ms Perkins, at POL00029587. You remember you were shown this email –

Alice Perkins: Yes.

Mr Beer: – about half an hour ago, an hour ago –

Alice Perkins: Yeah.

Mr Beer: – by Ms Leek?

Alice Perkins: Yeah.

Mr Beer: When she was introducing it to you, she said – and the draft transcript reference is page 148, line 12:

“Alwen Lyons sends to Paula, ‘speaking notes for your call with Alice this afternoon’.”

Alice Perkins: Mm-hm.

Mr Beer: In fact, if we look at the email, we can see that, on the face of the email, it’s not sent to Paula Vennells. It’s sent by Alwen Lyons to Alwen Lyons. Can you see that?

Alice Perkins: Yes, I do see that.

Mr Beer: The first sentence reads:

“Paula, here are my speaking notes for your call with Alice this afternoon.”

So it could be, I suppose, that this is a draft that didn’t get sent. It could be a way of sending something to yourself for printing off and handing over?

Alice Perkins: Mm-hm.

Mr Beer: But, on the face of the document, it wasn’t sent to Paula Vennells, can you see that, as a speaking note, for her –

Alice Perkins: I do see that.

Mr Beer: – conversation with you?

Alice Perkins: Yes.

Mr Beer: We haven’t got any other evidence that this email was sent to Paula Vennells as a speaking note prior to the conference call that had been teed up with you.

Alice Perkins: I see.

Mr Beer: I should say, if we just look lastly at WITN01020100 – this is Ms Vennells’ witness statement –

Alice Perkins: Right.

Mr Beer: – at page 168 –

Alice Perkins: Mm-hm.

Mr Beer: – paragraph 360, she says, “At 13.05”, that’s the time of the email.

Alice Perkins: Right.

Mr Beer: “At 13.05 on 16 May, Alwen sent me a speaking note to use on a call with Alice that afternoon”, and then she gives you the reference –

Alice Perkins: Okay.

Mr Beer: – or gives us the reference to the document we’ve just looked at.

Alice Perkins: I see.

Mr Beer: So it looks like the mistake was made there, as well, that this was a note sent to Paula Vennells at 1.05 pm.

Alice Perkins: But in fact it was Alwen sending it to herself.

Mr Beer: Alwen sent it to herself.

Alice Perkins: Yes, I understand. Thank you. That’s really helpful. I’m sorry, I have got a bit – I think I’m suffering from brain fog.

Mr Beer: Sir, they’re the only questions I ask. Thank you.

Sir Wyn Williams: So that brings an end to the questioning of you, Ms Perkins. I am very grateful to you for having provided a very detailed witness statement, and for giving evidence over the last two days.

The Witness: Thank you very much.

Sir Wyn Williams: Right. So we will adjourn now until Tuesday at 9.45, when we will resume.

Mr Beer: Thank you very much, sir.

(4.12 pm)

(The hearing adjourned until 9.45 am on Tuesday, 11 June 2024)