POL00169420
POL00169420
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Re: Seema Misra
Technical expert’s report to the Court prepared by Charles Alastair
McLachlan, a Director of Amsphere Consulting Ltd.
90 Fenchurch Street
London EC3M 4BY
England
This report contains 42 pages
POL00169420
POL00169420
Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Contents
1 INTRODUCTION.
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9 APPENDIX E.
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12 APPENDIX H.........s:scsssessssssssssesssssscscscesensesseseassnssesensenenseesessnseneeanensenes 36
13 APPENDIX L.........sssssssssssesessssesessesesssssssessssssenesssseeesesensaeaseseseseasasnseseees 37
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15 APPENDIX K.........s:scsssessssssssssssssssssssseeeesssesesesesnssssensatecseeseensaeananeneoees 39
16 APPENDIX L.
Charles McLachlan
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POL00169420
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On instruction of Coomber Rich Solicitors
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1 Introduction
1.1
Background to to the Horizon system
Accounting systems are usually designed around a ‘double entry’ booking
keeping principle. The double entry book keeping principle means that for
every entry into the system there is an equal and opposite entry that should
maintain the ‘balance’ between the accounts.
So, for example, if somebody at the till sells a stamp for £1 paid in cash then
the stock account would be reduced by £1 value of stock and the cash on hand
account would be increased by £1 — overall the balance between the accounts
would be unchanged.
As part of the process of financial control, it would be normal for the value of
stamps to be physically counted and recorded (stock value) and the value of
cash on hand physically counted and recorded (cash value) and these two
values compared (‘reconciled’) to what is recorded in the accounting system.
The sub post office uses specialised terminals to conduct business using the
Horizon system. This activity is recorded in messages of two types —
transaction messages and event messages. The messages are transmitted to
and from the Horizon data centre managed by Fujitsu.
The Horizon system developed and managed by Fujitsu is integrated to a
number of other systems controlled by Post Office Ltd (POL) and various 3
parties (for example, the Driver Vehicle Licensing Agency (DVLA),
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On instruction of Coomber Rich Solicitors
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merchants services providers for debit card services (such as Link) and E-Top
Up for mobile phone credit). This full set of systems and the operational
processes supporting them, I will refer to as the Post Office Limited
Operating Environment
1.2. Hypothetical issues with the Horizon system
1.1.1 The User Interface gives rise to incorrect data entry: poor user experience
design and inadequately user experience testing can give rise to poor data
entry quality. In cases that users are working under pressure, insufficiently
trained or are using a system presented in a language different from their first
language the problems of data entry can be exacerbated.
1.1.2. The Horizon system fails to properly process transactions: accounting systems
are usually carefully designed to ensure that accounts balance after each
“double entry” transaction. In particular, a database technology referred to as
‘two-phase’ commit is used to ensure that either both entries or neither entry
is recorded on the system.
1.1.3. External systems across the wider Post Office Limited Operating Environment
provide incorrect externally entered information to the Horizon accounts
through system or operator error outside Horizon.
Charles McLachlan
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On instruction of Coomber Rich Solicitors
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2 Summary of findings
2.1 Introduction
My findings are subject to certain limitations in the manner in which I was able to
pursue my investigations and which may have impacted my ability to provide a
complete picture.
2.1.1 Reliance on Fujitsu
For my understanding of the Horizon system and the manner in which it integrated
into the full Post Office Limited Operating Environment, I am completely reliant on
the information provided by Gareth Jenkins of Fujitsu. Gareth Jenkins has provided
every possible assistance subject, however, at all times to the instructions of his
employers and Post Office Ltd.
It should be noted that Fujitsu were originally contracted to design, build and operate
the Horizon system and continue to manage and develop the system under contract to
Post Office Ltd. In addition, I understand that Fujitsu have recently been awarded a
contract by the Post Office Ltd to operate, manage and develop other systems in the
Post Office Limited Operating Environment.
2.2 Although Gareth Jenkins was able to explain the various interfaces to Horizon
vis-a-vis the Post Office Limited Operating Environment, he was not able to
comment on its operation. See Appendix A Horizon Architecture Diagrams
Provided by Gareth Jenkins of Fujitsu.
2.2.1 Independent investigation
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On instruction of Coomber Rich Solicitors
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The Post Office provided no opportunity for independent investigation of the
operation of the Horizon system under test conditions or using video observation in a
live environment.
The Post Office provided no opportunity to observe and review the training of sub
post masters.
The Post Office provided no opportunity to examine the logs of defects, change
requests and outstanding known issues for the Horizon system.
The Post Office provided no opportunity to understand and review the systems and
processes in the Post Office Limited Operating Environment outside Horizon that
could give rise to transactions in Horizon. In particular:
e It was not possible to examine the process for introducing Transaction
Corrections that can give rise to changes in the cash that Horizon records at
the branch
e It was not possible to examine the processes for Remittances (the movement
of cash and stock) into and out of the branch that changes the cash and stock
that Horizon records at the branch
¢ It was not possible to examine the processes for revaluing foreign currency
which could change the value of cash held at the branch.
e It was not possible to examine the processes of reconciliation conducted by
the Post Office that could give rise to Transaction Corrections.
2.2.2. Opportunities for reconciliation
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On instruction of Coomber Rich Solicitors
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In the normal process of investigating the consistent operation of a system, I would
expect to examine the end to end trail of paper vouchers, transaction files, log files
and other electronic records across the Post Office Limited Operating Environment.
The Horizon system has been designed to operate as an accounting system and
therefore is designed to ensure that for every set of credits there is a matching set of
debits. In the set of transaction files I have been provided this design constraint is
met. However, the only way to determine whether it is the correct set of credits or
debts is to reconcile the Horizon transaction with externally held records. In a typical
banking environment this would typically be a set of paper vouchers (debit slips,
paying in slips, cheques, etc.) recorded at thSe counter as the transaction was
conducted. These vouchers may be hand written or may be printed by out at the
counter terminal. The cashier can then ensure that their till is balanced at the end of
the shift and, if for example a cheque has been entered for the wrong value, deal with
the matter immediately.
Unfortunately, the Horizon system has not been designed to automatically provide
these vouchers and it does not appear that Post Office counter staffs are trained to
ensure they retain them. It has not been possible, therefore, to reconcile the Horizon
branch records to the actual transaction undertaken over the counter in the branch.
2.3 Problems of data entry at sub post office.
2.3.1 Incorrectly calibrated touch screen
The Horizon system provides a touch screen for data entry. If when you ‘touch’ the
screen the screen does not respond properly it may be because the screen has not
properly calibrated the position of the ‘touch’ to the representation of the button on
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On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
the screen. The logs provided by Dunks show that Misra asked for guidance on how
to re-calibrate the screen on at least one occasion.
If this gave rise to incorrect entry of cash amounts then this would explain
discrepancies. The Horizon system does not record the recalibration of the touch
screen as a system event so it is not possible to identify how frequently individual
screens were re-calibrated.
The Horizon system does not automatically provide a voucher (i.e. a printed slip) to
be retained at the counter for every transaction so it is not easy for the cashier to
identify such data entry errors either immediately on entry or when seeking to balance
the till at the end of the day.
The Post Office have not provided us with an opportunity to record the use of a
system in a sub post office experiencing problems.
For all of these reasons it has not been possible to assess the impact of poor screen
calibration on data entry.
2.3.2 Poor User Interface Design
Poor user interface design can contribute to poor data entry quality and user errors.
The Post Office have not provided us with an opportunity to conduct a user interface
design audit or record the use of a system in a sub post office experiencing problems.
2.3.3 Use of the FASTCASH button
One of the features of the Horizon branch terminals is that it is possible to complete a
transaction by use of the ‘Fast Cash’ button. When the ‘Fast Cash’ button is pressed,
the value of the basket of items being transacted is added up and then any payment by
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On instruction of Coomber Rich Solicitors
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debit card, cheque or whatever is accounted for. The outstanding balance is
automatically calculated and treated as an over the counter cash payment and then
“clears the basket’ (i.e. completes the transaction and makes the terminal ready for the
next transaction).
It was anticipated that counter staff would use the ‘Fast Cash’ button as a matter of
habit on every transaction in order to clear the basket. The Horizon system does not
log whether the basket is cleared using the ‘Fast Cash’ button or some other method.
Both Jenkins and myself recognised that there could be circumstances in which a debit
card transaction was not authorised but (either because the printer was not working
or because of force of habit) the counter still cleared the basket using the ‘Fast Cash’
button. The result would be that the Horizon system recorded the receipt of an
amount of cash over the counter covering the whole outstanding balance.
The effect of this would be to create a cash discrepancy (shortfall) in the till
I have identified a number of transactions for which the ‘Fast Cash’ button could have
given rise to such a discrepancy (see Appendix B and items in jfalics in the
highlighted sections).
The total value of these transactions is £7,544.09. I have considered Jenkins report
(see Appendix B) and believe that he may have overlooked the transaction of £7,000
on 11-Jan-07 at the bottom of Page 5 of the document ‘Transactions Associated
With Rejected Cards in Appendix I for which I was unable to find a reversal.
Irrespective of the facts in relation to the transaction of £7,000, in my opinion the
relevance of the ‘Fast Cash’ button in this matter is:
¢ the ‘Fast Cash’ button is demonstrated to be a source of data entry error (the
reversals confirm this).
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e the specific circumstances relating to rejected card transactions give rise to a
relatively small value of possible discrepancies during the 13 month period for
which records have been provided compared to the total discrepancy found in
the audit.
e their may be other circumstances in which the use of the ‘Fast Cash’ button
gives rise to discrepancies which have not been identified or investigated
because I was unable to record the live operation of the use of the Horizon
system in a sub post office.
2.3.4 Insufficient training
The activities of a sub post office more properly correspond to those of a retail bank
branch rather than a retailer of stamps and postal services. (A cursory review of
Appendix H shows a transaction throughput of £48m_ recorded in the Horizon
transaction logs in a 13 month period for example). The Post Office were unable to
provide a definitive set of training materials, learning goals and competence
assessments which would make it possible to understand the extent to which Misra
was adequately trained and properly understood how to conduct the operations of a
sub post office.
However, an examination of the transaction and event logs provided by Fujitsu from 1
Dec 06 — 31 Dec 07 shows that:
¢ The Declared Branch position had discrepancies vis-a-vis the Horizon totals at
the end of almost every period.
e The Variance Checks conducted to reconcile the branch position vis-a-vis
Horizon showed a discrepancy on the vast majority of occasions ranging from
18 pence to more than £11,000.
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Such a consistent and pervasive failure to ensure that the tills balanced on a daily basis
can be explained by:
a) Theft and/or fraud that the Post Office failed to investigate for at least 13
months
b) Inability of individual branch counter staff to operate properly
c) Inability of the sub post mistress to train/manage staff and/or conduct end of
day processes.
d) Persistent system failure
I have not been able to conduct the kind of investigation which would exclude
persistent system failure.
2.4 Problems with Horizon
2.4.1 The Calendar Square, Falkirk Problem
Jenkins provides a summary of the problem first identified in proceedings relating to a
sub post office in Calendar Square, Falkirk. (see Appendix C). Unfortunately, as
Jenkins acknowledges, we have not been provided the transactions for the period
prior to March 2006 when we may have been able to independently determine
whether this was an issue for West Byfleet between 30/06/2005 and the bug fix to
Horizon provided in March 2006. Jenkins confirms that the implementation of the
Horizon system at West Byfleet, where each counter terminal is managed as a
separate “stock unit” rather than all the terminals being pooled, is precisely the
circumstances which could give rise to the ‘Calendar Square’ problem.
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On instruction of Coomber Rich Solicitors
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As far as the Calendar Square problem applies in relation to West Byfleet, in my
opinion:
¢ It demonstrates that there have been faults with the Horizon system which
give rise to discrepancies that can cause losses. It is not reasonable to exclude
the possibility of system problems when considering a case such as Misra.
¢ lam unable to determine whether the Calendar Square problem contributed to
the discrepancies at West Byfleet because the Post Office have not provided
the relevant transactions and event logs.
2.4.2 The travellers cheque stock problem
The Horizon system is used to record the stock of travellers cheques held by the sub
post office and account for the transactions when they are sold or encashed. In one of
my branch visits I was shown a sequence of actions that demonstrated how the
Horizon system reported on the stock of travellers cheques in a manner that was
completely confusing and misleading.
Take the example of 10 travellers cheques of value USD 100 at the beginning of the
day. If you run a stock report it will show 10 x USD TC 100 which corresponds to a
value of USD 1,000.
A customer comes in and purchases one travellers cheque at USD100 and pays for it
using a debit card.
If you then run a stock report it will show -90 x USD TC 100 which corresponds to a
value of USD -9,000.
In other words, the report has treated deducted the USD 100 from the travellers
cheque item count of 10 to get -90. Clearly you can’t hold a negative stock of a
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physical item such as a travellers cheque so the report is both meaningless and
completely misleading.
I discussed this with Jenkins and he acknowledge that this is a known feature of
Horizon and that the Post Office have not instructed Fujitsu to change the system to
produce a meaningful stock report. Jenkins assured me that the Horizon system
properly accounted for the travellers cheques in the end of day process but I had no
opportunity to test whether this was true.
In my opinion, this stock report could give rise to counter staff or sub post masters
seeking to correct the perceived problem through manual adjustments leading to real
discrepancies.
2.5 System problems from beyond Horizon
2.5.1 Transaction Corrections
The Post Office Limited Operating Environment encompasses a large number of
systems that use outputs from the Horizon system to conduct other processes to
support Post Office operations. It is from these systems that Transaction Corrections
arise.
Consider this hypothetical example by way of illustration:
At the Post Office counter a cheque was encashed for £50 and a cash payment to a
customer of £50 was recorded on the system. However, as a result of the clearing
process and various reconciliation processes, the face value for the cheque is
identified as £5. This gives rise to a cash discrepancy of £45 which the branch would
be expected to make up. A Transaction Correction would be issued to the branch for
them to acknowledge and the branch accounts would be updated.
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Both myself and Jenkins considered whether Transaction Corrections could be a
source of the branch discrepancies. Jenkins limited his examination to Transaction
Corrections to credit/debit card and banking transactions and identified relevant
Transaction Corrections to the value of £1,840 (Appendix G). I have take a slightly
wider scope of transactions of interest which have a total absolute value of £ -
19,257.21 and absolute value of £ 82,918.35 (Appendix J).
Jenkins acknowledges in his e-mail that he is unable to comment on the integrity of
the processes used by Post Office Limited to create Transaction Corrections or the
operating processes used to generate them.
Unfortunately, the Post Office failed to make anybody available to discuss the
operation of the Post Office Limited Operating Environment and the reconciliations,
error rates, controls and internal audit processes used to ensure integrity.
In my opinion, the value of the Transaction Corrections identified by Jenkins or the
transactions of interest identified by myself is not the issue. What is clear is that
Transaction Corrections are generated from outside Horizon. We have no evidence
as to whether or not:
a) The Transaction Corrections are of the correct value
b) Some Transaction Corrections should be applied at all
c) Some Transaction Corrections are omitted
The Post Office seek to address concerns (a) and (b) by providing the sub post master
with an opportunity to ‘request evidence’ (i.e. challenge) a Transaction Correction.
There is no record of Misra requesting evidence in the transactions provided between
1 Dec 06 and 31 Dec 07.
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However, as discussed above, the Horizon system does not automatically provide the
paper vouchers that would support a dispute over a transaction at the branch.
Further, this process does not address the possibility (c) that some necessary
Transaction Corrections are omitted.
Jenkins appears to assume that the limited value of the Transaction Corrections he has
identified means that they cannot explain the discrepancy in the Misra case. He
overlooks the possibilities that:
¢ The values are incorrect
e There are missing Transaction Corrections which would reduce the cash
balance expected by the Horizon system (i.e. be in favour of Misra).
In my opinion, we have insufficient evidence to exclude in correct or missing
Transaction Corrections as an contributing factor to the discrepancies in the Misra
case.
2.5.2 Remittances
The systems supporting the movement of cash and stock to and from the sub post
office are integrated into Horizon through Remittance transactions (colloquially
referred to as Rems). There is no suggestion in this case that there were problems
with the operation of the Remittance system. However, it should be noted that I am
currently instructed in other cases in which the defendant suggests that the system
gives rise to incorrect cash balances being recorded on the branch system. The Post
Office have not, at this stage, provided me with an opportunity to investigate these
claims.
Charles McLachlan
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It is worth noting that Jenkins has analysed the transactions and identified a pattern or
remittance transactions which is consistent with Misra’s statement that she declared
cash held in remittance pouches in the safe which was not actually present.
2.1.3 If the potential source of the incorrect transaction processing can be identified
then it would be helpful to be able to reproduce the problems under controlled
test conditions in a consistent and reproducible manner. This would require
the assistance of Fujitsu in providing access to the test environments
maintained in support of the Horizon system
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3 Conclusions
3.1
3.3
3.4
It is evident that trial balances (Variance Checks) and period balances (Branch
declarations) showed a continuous pattern of discrepancies through out the
period for which transactions were provided. It appears that no action was
taken by the Post Office to investigate these discrepancies or to ensure that
Misra was competent to prevent them from arising. Instead, Misra removed an
employee under suspicion of theft and implemented independent stock units for
each counter. Neither action appears to have resolved the issue.
The possibility that problems with screen calibration and the use of the ‘fast
cash’ button contributed to the discrepancies at West Byfleet has not been
excluded by the investigations of Jenkins and myself. However, it is difficult to
demonstrate that they are of a magnitude to explain the full amount of the
discrepancy.
The Horizon system has had problems in the past as acknowledged by Jenkins
in relation to Calendar Square. Unfortunately, the Post Office has not provided
us with the opportunity to independently assess the possible impact on West
Byfleet nor have they provided a list of known defects in Horizon. The
‘travellers cheque’ problem is an illustration of the known defects we
independently identified but Jenkins confirmed that Fujitsu maintain a full list
which has not been released.
The Horizon system is a component of the full Post Office Operating
Environment. Other elements of this environment can result in changes to the
cash balances recorded at the branch. Both Transaction Corrections and
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Remittances will act in this way. Jenkins was unable to provide any opinion as
to the integrity of these systems and I was provided with no opportunity to
investigate them. The Post Office has provided no evidence as the integrity of
these systems and the processes used to manage them.
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4 Terms of Reference
4.1 Instructions
4.1.1 Lam Charles Alastair McLachlan, a Director of Amsphere Consulting Limited.
London, England specialising in information technology consulting. I have
been instructed in this matter by Coomber Rich Solicitors, on behalf of their
client, Seema Misra, (“the Defendant”) to assist the court in this matter of
alleged fraudulent accounting in providing expert evidence on the matters
posed at 1.1.3 hereunder.
4.1.2. The allegations arose from the discrepancy between the transactions as
recorded in the Horizon system provided by Post Office Counters Ltd through
a service agreement with Fujitsu and the cash on hand at the defendant’s Post
Office branch.
4.1.3 Iwas instructed to consider:
a. The defendant’s claim that the discrepancy was due to defects in the
Horizon system?
4.2 Qualifications
4.2.1 [have been working in the software industry since my first job at the age of 17
writing software analysing the results from a particle accelerator for the UK
Atomic Energy Authority
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4.2.2
4.2.3
424
4.2.5
4.2.6
42.7
428
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
I obtained an M.A in Computer Science from Cambridge University
matriculating in 1979.
I developed software for environmental control systems for a company on the
Cambridge Science Park while at university.
I was retained by Cambridge University to do undergraduate teaching for
three years.
After University, I worked for the company of the Emeritus Professor of
Computer Science at Imperial College (and founder of IBM UK Hursley
Laboratories), developing PC multi-tasking office automation software. As
the company transitioned to IT consulting, I advised HP on their Unix
Strategy and looked at the potential for hosting Inmos parallel processors in
PC environments. I also built an extensive financial performance analysis
system for the Building Society industry.
In 1987, I become the founding partner of CMJP Associates which delivered
software development services to a wide range of clients using PC and Client-
Server technologies.
A number of these projects included the development of accounting modules
and work for the financial services industry including SG Warburg, GNI (of
the London International Financial Futures Exchange LIFFE).
In 1991 I established a partnership for CMJP Associates to provide expert
advice to the Client Server Centre of Excellence.
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42.9
4.2.10
4.2.11
4.2.12
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
In July 1993 I became the founding Technical Director of Infonet Stystems.
Infonet Systems focused on building leading edge object oriented Client-
Server solutions. Its first success was the delivery of a complete front office
trading platform of financial derivates (repos and bonds) in four weeks. This
was the first NT based client server trading desk in the City of London. While
at Infonet, I developed the Object Oriented Just In Time software
development methodology.
In December 1996, I was recruited by the European headquarters of emerging
internet service provider UUNet (shortly to become part of MCI Worldcom),
to advise on IP billing and customer provisioning systems. A key element of
the assignment was to undertake a critical review of the implementation and
customisation of the GEAC Smartstream ERP solution by Arthur Andersen
Business Consulting.
In August 1997 I was recruited by Arthur Andersen Business Consulting to
provide technology leadership for the new Advanced Technology division.
Over the next five years, I became the international thought leader in the
building of software related services that underpinned the development of
Andersen’s New Media and eBusiness practice. This was recognised by
election to partnership in 2000.
Early identification of the crucial role for Java technologies and ‘just in time’
business and technology development methods, positioned the emerging
Business Consulting (BC) division for rapid growth on the Internet wave to
become 9th globally by Q3 2001. Achievements during this period cover:
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4.2.13 Major systems delivery projects The software development related service
revenues were the fastest growing area of the fastest growing global
consulting organization between 1997 and 2002. My team delivered marquee
projects for key clients including: launch of Sky.com, TimeOut.com,
myTravel.com, Cendant’s Move.co.uk, pan-European systems for Budget-
Rent-a-Car. I was also engaged as a technical delivery expert for major new
systems types including on-line trading exchanges, high throughput customer
services systems, on-line transaction processing systems and content
management systems.
4.2.14 Solution Development: I provided technology leadership for the development
of key global solutions for BC including: eStrategy, eBusiness, Content
Management, Experience Design, Component Based Development, Business
Architecture, Enterprise Integration, Datawarehouse, Technical Architecture,
™
Active Intelligence™, Anti-Money Laundering, Telco Fraud Protection.
4.2.15 I was the recognized methodology and risk management expert for software
related technology solutions across Andersen.
4.2.16 I worked closely with the Computer Risk Management practice in the
Andersen Audit practice to perform technical due diligence, project risk
reviews and advise on project recovery.
4.2.17 Capability Development One of my key strengths was the recruitment,
training, development and motivation of deeply technical teams to perform
successfully in a ‘Big 4’ consulting environment.
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4.2.18
4.2.19
4.2.20
4.2.21
4.2.22
Charles
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX
Operating first as the founding director of Andersen’s Global Software
Engineering Centre of Excellence and then as a member of the Global
Advanced Technology Advisory Team, I became one of a small number of
newly appointed partners building the technology integration skills at the
heart of BC’s growth strategy.
I provided technical leadership for the development of the core component
based rapid implementation methodology and acted as the expert for
methodologies built on this foundation including eBusiness, eMarketplace,
Content Management, Datawarehouse, Business Architecture, Enterprise
Integration and Customer Management.
Other achievements include implementation of the first successful Knowledge
Management Capability Maturity Model for the UK practice; establishing a
global virtual community of 2,000 software developers; developing alliance
relationships with BEA, Microsoft, Sun and a variety of specialist technology
providers; sponsorship of Computing for Business MSc at Imperial College,
development of four technology training courses for global roll-out; delivery
of a technology competency model for all practitioners globally.
I am currently working as an IT and Technology Risk consultant as a Director
of Amsphere Consulting Limited.
Recent assignments include:
e Advisor to board of advisor to board of satellite Broadband Interactive
start-up
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© Recovery of failing project at Big ‘4’ consulting firm
e Associate editor Butler Group, the IT strategy consulting information
service company.
e Design and implementation of delivery risk management system for an off-
shore software development company
e Project delivery for an applications management business
e Report on XML related integration and data quality risk for JP Morgan-
Chase
e Expert witness including cross examination in an ICC Arbitration between
3 national banks and an international provider of banking accounting
software
e Expert witness in a High Court action relating to the quality of software
testing between an international mobile telephone operator and an
established mobile telephony systems integrator.
e Expert advisor in action between Geographical Information Systems
provider and off-shore software development services provider.
e Expert advisor in action between an SAP systems integrator and a provider
of insurance policies for household goods
e Instructed in relation to 5 other cases relating to Post Office sub
postmasters or mistresses.
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4.2.23 I am a former Director of UCL Consultants (founded by University College
London) which is responsible for providing professional consulting services
from members of UCL.
4.2.24 I ama Partner of the Transformation Development Partnership LLP.
4.2.25 I was appointed Visiting Professor of Software Enterprise at University
College London in 2005.
4.2.26 I have worked with IT organisations of all scales from small businesses to
international global organisations.
4.2.27 I mentor small businesses owners through the Academy for Chief Executives
and lecture on the MBA programme at the University of Kent.
4.3. Confidentiality
43.1 This report is strictly private and confidential and has been prepared at the
request of Coomber Rich Solicitors on behalf of their client, for the Court.
4.4 Legal and factual issues
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441
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This report should not be read as expressing any opinion on factual matters
which depend on disputed testimony of the witnesses of fact, or legal issues.
It, however, inevitably reflects my understanding of the position.
4.5 Sources of information
45.1
In preparing my report, I have read and considered the following documents:
Summary of facts prepared in accordance with Rule 21.3(1)(b) of the
Criminal Procedure Rules 2005;
The Indictment — The Queen v Seema Misra;
Witness statement of Keith Noverre 8" January 2009;
Witness statement of Elaine Ridge 9" January 2009;
Witness statement of Lisa Jane Allen 12" January 2009;
Witness statement of Adrian Morris 6" January 2009;
Witness statement of Jon Longman 29" May 2009;
Witness statement of Javed Salim Bidiwala 13" April 2006
The statement under Section 9 of the Criminal Justice Act 1967 of John
Kidd
The Audit of Post Office ® West Byfleet branch, FAD 126023 — Action
Plan Appendix A
The Witness statement of Andrew Paul Dunks 24" June 2009
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The exhibits provided running from pages 1-35 insofar as the copies
provided are legible.
Various witness statements by Gareth Jenkins of Fujitsu
Various e-mails and documents provided by Gareth Jenkins of Fujitsu
Visits to three separate sub post offices with an opportunity to interview the
staff
The Horizon transactions and Events for West Byfleet from 1* December
2006 — 31* December 2007 provided by Fujitsu.
4.6 The scope of my work
4.6.1
47
47.1
47.2
I report as an expert witness, not as a witness of fact. I have reviewed the
documentation provided to me. I have not undertaken an operational review
of the software solution Horizon system nor have I had access to any system
documentation or test data relating to the Horizon system and the associated
Post Office Ltd systems.
Independence
I have prepared an independent and objective report addressed to the Court. I
have had no previous involvement with the Defendant. I have no previous
involvement with Coomber Rich Solicitors.
Amsphere’s fees in this case are not dependent on the result of the
proceedings in this matter.
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4.8 My duties to the Court
48.1
4.8.2
4.8.3
4.8.4
4.8.5
4.8.6
48.7
I understand that my overriding duty is to the Court, both in preparing reports
and in giving oral evidence. I have complied and will continue to comply with
that duty.
I have set out in my report what I understand from those instructing me to be
the questions in respect of which my opinions as an expert are required.
I have done my best, in preparing this report, to be accurate and complete. I
have mentioned all matters that I regard as relevant to the opinions I have
expressed. All of the matters on which I have expressed an opinion lie within
my field of expertise.
I have drawn to the attention of the Court to all matters, of which I am aware,
which might adversely affect my opinion.
Wherever I have no personal knowledge, I have indicated the source of factual
information.
I have not included anything in this report that has been suggested to me by
anyone, including the lawyers instructing me, without forming my own
independent view of the matter.
Where in my view, there is a range of reasonable opinion, I have indicated the
extent of that range in the report
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4.8.8 At the time of signing the report I consider it to be complete and accurate. I
will notify those instructing me if, for any reason, I subsequently consider that
the report requires any correction or qualification.
4.8.9 I understand that this report will be the evidence that I will give under oath,
subject to any correction or qualification I may make before swearing to its
veracity.
4.8.10 I have included in this report a statement setting out the substance of all facts
and instructions given to me, which are material to the opinions expressed in
this report or upon which those opinions are based.
4.8.11 I confirm that insofar as the facts stated in my report are within my own
knowledge I have made clear which they are, and I believe them to be true,
and the opinions that I have expressed represent my true and complete
professional opinion.
Professor Charles McLachlan
Amsphere Consulting Ltd
90 Fenchurch Street
London, EC3M 4BY
England
Thursday, 30 September 2010
Charles McLachlan
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Amsphere
Charles McLachlan
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5 Appendix A
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5.1 Horizon Architecture Diagrams Provided by Gareth Jenkins of Fujitsu
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6 Appendix B
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6.1 Jenkins review of failed transactions for FASTCASH errors
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7 Appendix C
7.1. Summary of Calendar Square Falkirk Problem.
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8 Appendix D
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8.1 Gareth Jenkins Comments on Transaction Corrections
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9 Appendix E
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9.1 Gareth Jenkins information to assist in interpreting Horizon Transactions and
Events
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10 Appendix F
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10.1 Sample Horizon Transaction logs provided by Fujitsu 1 to 31 Dec 06
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11 Appendix G
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11.1 Sample Horizon Event logs provided by Fujitsu 1 to 31 Dec 07
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12 Appendix H
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12.1 Absolute Totals of Activity By Product Number
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13 Appendix I
13.1 Card Product Ids
13.2 Transaction Associated With Reject Cards
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14 Appendix J
14.1 Summary of Transactions of Interest
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15 Appendix K
15.1 Horizon Events without Report Printed
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16 Appendix L
16.1 Declared Discrepancies.
16.2. Variance Check Analysis
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