FUJ00152872 - Email from Gareth Jenkins to Penny Thomas re Seema Misra West Byfleet PO. Includes Expert Report by Charles McLachlan dated 19.11.09 with comments by Gareth Jenkins.

Evidence on official site

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Thomas Penny

From: . Jenkins Gareth GI

Sent: 17 December 2009 09:44

To: . Thomas Penny

Subject: : RE: Misra - West Byfleet PO

Attachments: 9c15.misra - 2nd interim technical expert's report 19.11.09.doc

9c15S.misra = 2nd .
interim techn...

Penny,
I attach the Expert Witness statement with my comments. Hope this is OK.

As for Question 3, the simple answer is that the system will behave very differently
in that all the data will be held ina central database and the UI will be very
different. However the basic principles for accounting will be the same, though much
of the detail in terms of error handling etc will change. If more detail is required
hen that really requires a full discussion on how HNG-X works and will get very
-engthy and involved.

If the attached looks OK, then that's it I hope.

Best wishes for Christmas and the New Year. See you in 2010!
Regards

Gareth

Gareth Jenkins

Distinguished Engineer

Applications Architect

Royal Mail Group Account

FUJITSU

Lovelace Road
Tel:

Mobile:
mail:
~-Web: http: //uk. fujitsu.com

P Please consider the environment - do you really need to print this email?

Fujitsu Services Limited, Registered in England no 96056, Registered Office 22 Baker
Street, London, W1U 3BW

This 6-mail is only for the use of its intended recipient. Its contents are subject
to a duty of confidence and may be privileged. Fujitsu Services does not guarantee
that this email has not been intercepted and amended or that it is virusfree.

Original Message
Thomas Penny

: 07 December 2009 12:42

.To: Jenkins Gareth GI

Subject: FW: Misra - West Byfleet PO

Hi Gareth
I hope all is well with, you.

We have some more questions from defence for west Byfleet - Could you please take a
look at question 3) below, as well? Questions 1) and 2) will be addressed by
engineering.
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Penny

Original Messaa
jane.m.owen@ _ GRO
Sent: 02 December 2009 12:59”

To: Thomas Penny

Subject: Fw: Misra - West Byfleet PO

Penny
The investigator in this case has asked for some further information from
Fujitsu

Regards

Jane

Jane Owen
Security Team Advisor
Security Team, Post’ Office Ltd

(Embedded image moved to file:
pic29972.gif)Royal Mail, Clippers
House, 3rd Floor, Clippers Quay,
SALFORD. M50 3NW

aaa Forwarded by Jane M Owen/e/POSTOFFICE on 02/12/2009 12:56 -----

To: Jane M

John Longman

Jwen/e/POSTOFFICE@ POSTOFFICE
02/12/2009 11:34 ce:
Subject: Misra - West Byfleet PO

Jane

The defence have requested some further questions which I think only
Fujitsu can answer. Could you forward them and ask for a response.

1) In light of the above, the statement by Fujitsu that the calls to the
helpline were of a routine nature is not accepted. Please provide a copy
of the log of all calls made to the helpline by West Byfleet Post Office
for a period from 6 months prior to the Defendant becoming sub-post
until the present day. (Date range required - lst Jan 2005 to 30th
November 2009)

2) In the Defence Expert’s interim report reference was made to the need to
have sight of service logs for West Byfleet. Comment has been made as to
the huge cost involved in pursuing this exercise. Please provide details
as to the work involved in this action and why the cost is so high
Depending on the answer provided to this request and others contained in

2
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this document, a decision will then be takén by the defence as-to
whether this action needs to be pursued. (Date range of Transaction
Logs requested Ist Jan 2005 to 30th November 2009. How much would it
cost to produce transaction logs for this period).

3) In light of the Post Office’s stated intention to commence rolling out
thé new computerised accounting system from January 2010, please confirm
what steps are being taken to preserve the end to end architecture of
the Horizon system in general and, in particular, to West Byfleet Post
Office. :

(Embedded image moved to file: picl5839.jpg)

FESS S HEE E ESE SI ISSIR EIS OSG IISISESESIIO GSS IIIS Ee
Royal Mail Group Limited registered in England and Wales registered number
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OHQ :

This email and any attachments are confidential and intended for the
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TOSS U CHEECH CHIE SEIS O SEIS OSES SISSHIGS IIS GEIS ISI I GG
Amsphere Confidential and Privileged

On instruction of Comber Rich Solicitors
Yard House, Basingstoke, RG21 7NX

Re: Seema Misra

2" Interim Technical expert’s report to the Court prepared by
Charles Alastair McLachlan, a Director of Amsphere Consulting
Ltd. ‘

Staple Hall
87-90 Houndsditch
London EC3A, 7AD
- : England

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Amsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG2! 7NX

Contents

1 INTRODUCTION...

2 PRELIMINARY REPORT OF FINDINGS DURING VISITS TO A SUB
I POST OFFICE IN THE MIDLANDS AND WEST BYFLEET....

3. WHAT HYPOTHESES COULD SUPPORT THE DEFENDANT’S CLAIM
THAT THE HORIZON SYSTEM WAS THE SOURCE OF THE
I ACCOUNTING DISCREPANCIES?........

4 WHAT EVIDENCE NEEDS TO BE PROVIDED IN ORDER TO
DETERMINE THE MERITS OF THE DEFENDANT’S CLAIM ?.......

5 MY DUTIES TO THE COURT.......

Charles McLachlan 1
Amsphere Confidential and Privileged

On instruction of Coomber Rich Solicitors
: Yard House, Basingstoke, RG21 7NX

1 Introduction

Ll

L1l

1.1.2

Instructions

a.

I am Charles Alastair McLachlan, a Director of Amsphere Consulting
Limited, London, England specialising in information technology consulting.
Thave 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

questions posed at 1.1.3 hereunder.

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.

I was instructed to visit a sub post office in the Midlands and the sub post
office at West Byfleet to review the operational procedures and IT systems
implemented at the two sites in order to:

Understand the basis upon which standard operational procedures would

provide evidence to identify and resolve discrepancies arising from the use
of the Horizon system.

Understand the elements of the end-to-end IT architecture which could be
the source of discrepancies as a result of defects in the operation of the
software, hardware, network or integration with 3“ party components.

1.2 Qualifications

Charles McLachlan 1

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1.2.1

1.2.2

1.2.4

1.2.5

1.2.6

On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX

I 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

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 became the founding partner of CMJP Associates which delivered
software development services to a wide range of clients using PC and

Client-Server technologies.

Charles McLachlan . 2

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1.2.7

1.2.9

1.2.10

On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21.7NX

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.

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 derivatives (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),

1.2.11

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.

Charles McLachlan 3

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1.2.13

1.2.14

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On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX

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 Quarter 3 2001. Achievements during this

period cover:

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.

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, I Datawarehouse, —_ Technical
Architecture, Active Intelligence™, Anti-Money Laundering, Telco Fraud

Protection.

I was the recognized methodology and risk management expert for software

related technology solutions across Andersen.

Charles McLachlan 4

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1.2.16

1.2.17

1.2.18

1.2.19

1.2.20

On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX

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.

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.

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.

Charles McLachlan 5

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Amsphere

Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG2! 7NX

1.2.21 1am currently working as an IT and Technology Risk consultant as a Director

of Amsphere Consulting Limited.

1.2.22 Recent assignments include:

Advisor to board of advisor to board of interactive satellite broadband

start-up
Recovery of failing project at Big ‘4’ consulting firm

Associate editor Butler Group, ‘the IT’ strategy consulting information

service company.

Design. and implementation of delivery risk management system for an

off-shore software development company
Project delivery for an applications management business

Report on XML related integration and data quality risk for JP “Morgan-
Chase

Expert witness including cross examination in an ICC Arbitration between
3 national banks and an international provider of, banking accounting
software

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.

Expert advisor in action between Geographical Information Systems

provider and off-shore software development services provider.

Charles McLachlan 6

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? On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX

1.2.23 Iam a former Director of UCL Consultants (founded by University College
London) which is responsible for providing professional consulting services

from members of UCL.
1.2.24 I ama Partner of the Transformation Development Partnership LLP.

1.2.25 I was appointed . Visiting Professor of Software Enterprise at University
~ College London in 2005

1.2.26 I have worked with IT organisations of all scales from small businesses to

international global organisations.
1.2.27 I mentor small businesses owners through the Academy for Chief Executives.
1.3 Confidentiality

1.3.1 Thi8 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.

1.4 Legal and factual issues

1.4.1 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.

Charles McLachlan

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Amsphere * Confidential and Privileged
‘On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX “

1.5 Sources of information

1.5.1 In preparing my report, I have read and considered the following documents:

a. Summary of facts prepared in accordance with Rule 21.3(1)(b) of the

Criminal Procedure Rules 2005;

b. The Indictment ~ The Queen v Seema Misra;
c. Witness statement of Keith Noverre 8" January 2009;
d. Witness statement of Elaine Ridge 9" January 2009;
e. Witness statement of Lisa Jane Allen 12" January 2009;
f. Witness statement of Adrian Morris 6" January 2009;
g. Witness statement of Jon Longman 29" May 2009; :
h. Witness statement of Javed Salim Bidiwala 13" April 2006 .
i. The statement under Section 9 of the Criminal Justice Act 1967 of John
Kidd
j. The Audit of Post Office ® West Byfleet branch, FAD. 126023 - Action \

Plan Appendix A

k. The Witness statement of Andrew Paul Dunks 24" June 2009
L The exhibits provided running from pages 1-35 insofar as the copies

provided are legible. ° ;
m. The systems architecture for the end to end process from Point of Sale

terminal to Electronic Funds Transfer for a leading UK retailer

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On instruction of Comber Rich Solicitors
Yard House, Basingstoke, RG21 7NX

1.6 The scope of my work

1.6.1

1.6.1.1

1.6.1.2

1.6.1.3

1.6.1.4

1.6.1.5

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.

I have not -had access to any documentation or test data relating to the

Horizon system

I have attended a sub post office in the Midlands reporting regular cash
discrepancies, interviewed the sub postmistress, reviewed the operating
procedures ‘in the sub post office and reviewed the capabilities of the

Horizon system.

I have attended the sub post office at West Byfleet named in these
proceedings; interviewed one of the attending investigating officers,
reviewed the operating procedures in the sub post office and reviewed the

capabilities of the Horizon system.

Charles McLachlan 9

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On instruction of Coomber Rich Solicitors
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1.7 Independence

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. . .

1.8 The structure of my report is as follows:

At Section 2, I report my preliminary findings following the visits to the two

sub post offices.

At Section 3, I reconsider “What hypotheses could support the Defendant’s

“claim that the Horizon system was the source of the accounting

discrepancies?”

At Section 4 I reconsider “What evidence needs to be provided in order to

- determine the merits of the Defendant’s claim?”

At section 5 my expert’s declaration is recorded.

Charles McLachlan 10

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Atnsphere Confidential and Privileged
On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX

2 Preliminary report of findings during visits to‘a sub post
office in the Midlands and West Byfleet

2.1 Findings during visit to sub post office in the Midlands
2.1.1 Background of sub postmistress

2.1.1.1 The sub postmistress responsible for the’ sub post office we visited in the

Midlands asked that she retain her anonymity at this stage in the process

because she is very fearful of being suspended. However there. are some

relevant details that she was ready to have appear in the report:

2.1.1.2 She has a previous career in banking with a major rétail bank and -had
previous bank teller experience before moving to export/import credit

products.

2.1.1.3. She is familiar with handling detailed and complex documentation from her:

experience at the bank.

2.1.1.4 She has been a sub post mistress for more than 10 years and only. took on
the sub post office in order to be able to have her elderly disabled mother
live whete she worked and in order to be close to her children as they grew

up.

2.1.1.5 She has been recognised by the Post Office for her bravery in her response

to being shot. at by armed robbers on more than one occasion and she

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commented to us “why would J steal money from my own business when I

have already demonstrated that I will put my life at risk to protect it?”
2.1.1.6 Her husband and her children are all qualified graduates.
2.1.2 Background to issues at the sub post office

2.1.2.1. The sub- post office is operated by a husband and wife team together with

their son.

2.1.2.2. The sub post office has 3 counter terminals which are operated on a shared

stock basis

2.1.2.3. The premises housing the sub post office include a small shop selling a
limited range of envelopes, gift card and other post related accessories. The
lottery terminal is on the shop counter. We were advised that sales in the
shop are between £200-£300 per week compared to a monthly transaction
volume ‘at the post office counter of between £200,000 and £300,000 per

month.
2.1.3 Pattern of discrepancies

2.1.3.1. The sub post mistress explained that her experience is that there are almost

no discrepancies that she has to record against the stock.

Charles McLachlan 12

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2.1.3.2

2:1.3.3

2.1.3.4

2.1.3.5

2.1.3.6

Charles McLachlan ° 13

On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG2/ 7NX

There are also almost nodiscrepancies that she has to record against the

physical cash held in the shop.

There are consistently discrepancies arising from the use of debit cards or
post office cash account cards._Not sure I understand what is meant by a

“discrepancy” in this context. My understanding is a discrepancy is where

the system derived value for an item differs from that physically in the

Stock unit and so this only applies to Cash or Stock. The Value of Debit

‘and Credit) Cards and POCA Cards is handled as a “Payment” and should
balance with the corresponding “Receipt” recorded for the goods or Service
that they are used for.

The value of discrepancies has increased as the proportionate value of card

use has increased.

If an “Account Payable” or counter credit is entered the Horizon system
assumes that there is a corresponding receipt (either physical cash, debit
card transaction, Post Office Cash Account card transaction or cleared

cheque). True, and this is ascertained during the Settlement process.

The post mistress used to receive discrepancy reports generated by the Post
Office identifying when there was a mismatch between the counter credit
recorded ‘at the counter and the cleared cheque or debit card amounts
reported to them by their correspondent banks or card merchant provider.
She no longer receives these and concludes that the Post Office function
that provided this service is non-operational or insufficiently staffed to

properly reconcile all of the discrepancies. These discrepancies, if left

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On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG2] 7NX

unresolved, could create a liability for the sub postmistress._ POL to answer.

(Wouldn’t there be Transaction Corrections now for any such discreancies?)

If stock is sold, the Horizon system assumes that there is a corresponding
receipt (either physical cash, debit card transaction, Post Office Cash

Account card transaction).__And it requests the User to specify how it is

settled for and accounts for it accordingly.

If at the end of the monthly period there is a discrepancy between the cash

on hand and the credit balance expected by the Horizon system then the

only way to close the period and start a new period. is to “make good” the

cash discrepancy and declare that the cash on hand has been brought up to
the expected credit balance. There is no mechanism to record the
discrepancy in a suspense account for subsequent investigation and
resolution. The systém imposes a declaration as part of the operating
procedure that the cash is on hand. If the actual reason for the discrepancy
is due to a problem with a non-cash credit (e.g. incorrectly processed card
payment, incorrectly recorded cheque payment) then there is no opportunity
for the sub post mistress to note her concerns on the system:_This was the

requirement made by POL of the system.

The sub post mistress demonstrated the following transactions in which the
use of a debit card could result in a discrepancy in the cash account
(physical + debit card/POCA amounts) at the sub post office:_Cash and

Plastic are handled separately in the accounts.

2.1.3.10 Account Payable. using a Debit Card / POCA card: the customer is seeking

to make a bill payment of council tax using a debit card. The card is

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apparently authorised at the PIN termhinal for the required-amount. The card
receipt is apparently credited to the sub post office account, The council tax
payment is debited from the sub post office account. However, during the
end to end electronic fund transfer process the fund transfer fails. The
central Post Office account never receives the expected electronic funds. It
is supposed that the end of day process identifies that there is no credit
corresponding to the bill payment and therefore there must be a cash

discrepancy._ This needs to be explained more carefully. What exactly was

observed to happen here? The back end settlement between the Merchant
Acquirer and Post Office Ltd is totally separate from the accounting done in
the Local Branch. Provided the Debit Card transaction is Authorised by the

MA, then the Branch Accounts will record the Debit Card payment as the

MoP. However if the MA doesn’t authorise the transaction then_an

alternative MoP is required. What action is taken should the MA fail to

honour the authorised payment and. whether that results in a TC being sent

to the branch to reclaim the funds is a separate issue outside my knowledge.

but POL should be able to clarify that. Note that such rejections are rare. It

is the responsibility of the clerk to ensure that'the Debit Card payment was *

successfully authorised by the MA and to check the response received.

_- (Formatted: Font: Bold
_ (Formatted: Font: Bold

Should they not do so and as:

to clear the basket without looking at the screen, then indeed the system

might record a Cash transaction.
_¢{ Formatted: Indent: Left: 1.5
(ao

In summary, if the Debit Card payment says that it works at the time, then it

it-was processed and touch “Fast Cash” -

is recorded as such in the branch accounts. There is no automatic feedback
into the branch accounts from any subsequent MA rejections.

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On instruction of Coomber Rich Solicitors
Yard ‘House, Basingstoke, RG21 7NX

2.1.3.11 Debit Card/POCA withdrawal: the customer is seeking to receive an over

the counter payment of cash from their debit card or POCA facility. As
above [2.1.3.10] the card is apparently authorised but in fact the fund
transfer fails at some point and the sub post office account is debited with
the cash at the counter terminal but this is not recorded centrally against a
debit card fund transfer. There is therefore an apparent cash shortfall in the
till. The Horizon system only prints a receipt for the customer; there is no
debit voucher for the counter staff to place in their till, At the end of the
day or the end of the week it is not possible to physically reconcile the cash

payments with debit vouchers._There_are clear messages to the clerk

indicating whether or not_any Banking or Debit Card transactions was

authorised. As above there is no subsequent automatic correction due to

any subsequent failures. I accept that there is no Branch Receipt produced

for paper reconciliation purposes. We were specifically requested not to

roduce ore by POL.

2.1.3.12 In either of the two cases above [2.1.3.10], [2.1.3.1] the electronic funds

transfer mechanism duplicates the fund transfer. This could result in the
expected credit balance at the sub post office being higher than it actually is.
The sub post mistress will be expected to make good this discrepancy with

cash._Sorry, but I don’t understand the point being made.

2.1.4 Operating procedures

2.1.4.1

We discussed the operating procedures implemented at the sub post office
in the Midlands in great detail with the sub postmistress. In my opinion, she
demonstrated the trained eye: for detail and procedure that I would expect

from somebody with her professional experience.

Charles McLachlan 16

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On instruction of Coomber Rich Solicitors
Yard House; Basingstoke, RG21 7NX

2.1.4.2. She demonstrated a range of features of the Horizon system that showed

how stock and cash were tightly connected across the system and how the

system had built-in mechanisms to link stock sales with cash receipt.

2.1.4.3 She also demonstrated the weaknesses of the system in relation to the use of
the debit card/POCA terminal:

the lack of counter vouchers, This was a specific POL request

the requirement to record some debit terminal transactions as cash

receipts, This may need to be explored further. I’m not aware of

any such requirement other that in the area of Refunds:

the delays in the system at busy periods, Again I’m not sure what

the relevance of this is. My understanding is that the. response
time for online trasanctions is very good

the lack of certainty as to whether a transaction completes when
there is a break in network connectivity_There should be clear

messages in all cases as to whether the clerk should assume the

transaction was succeful or not. In the case of a comms failure the

assumptions should always be that the transaction has failed.

Recovery processes will allow this to be confirmed afterwards.

2.1.5' Capabilities of Horizon

2.1.5:1 Horizon terminals are capable of working in on-line and off-line mode.

Charles McLachlan

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2.1.5.2

2.1.5.3

2.1.5.4

On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG2] 7NX

The terminals are required to be left on overnight in order to permit two

way data transmission and software updates.

All of the facilities of Horizon are available in off-line mode except
debit/POCA transactions and access to information from the DVLC

required to issue vehicle licences._There-are other exceptions now.

The Horizon system sells postal services, provides foreign exchange,

supports receipts of cash, cheque and debit card/POCA for Accounts -

Payable services ‘and supports payment of cash from. debit card/POCA

accounts._Also other banking online services for A&L and via Link

2.2 Findings during visit to sub post office at West Byfleet

2.2.1

2.2.1.1

2.2.1.2

Operating procedures

I was able to confirm my understanding of the operating procedures from

my visit to the sub post office in the Midlands.

It was clear that there is no standard operating procedure to reconcile
counter credits with the actual amounts recorded. This could give rise to a
range of discrepancies which the sub post mistress would rely on the Post
Office to identify and reconcile. If the Post Office failed to do so then
overstated amounts could give rise to a deficit at the sub post office which
the sub post mistress would be required to make good with cash._Again I’m

not sure what is meant here. POL should comment on their processes.

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On instruction of Coomiber Rich Solicitors
Yard House, Basingstoke, RG2] 7NX

2.2.2 Capabilities of Horizon ,

2.2.2.1 The West Byfleet sub post office is set up to operate with each counter
having a separate stock. Although this assists with stock control and
ensures that stock discrepancies can be localised, it does not provide any
assistance in management of discrepancies in debit/POCA receipts (no
vouchers are automatically printed) or Accounts Payable and counter credit
discrepancies (standard operating procedures do not reconcile these on a

daily basis), Again for POL to respond.

2.2.3 Approach of investigating officers to system issues

-2.2.3.1 On our visit to West Byfleet, we had an opportunity to raise some questions
with one of the investigating officers that attended on the day of the audit

that gave rise to these proceedings.

2.2.3.2. He made it clear that it was Post Office policy that investigating officers

should never consider systems problems as relevant to their enquiries.

2.2.3.3 He agreed that the Horizon system provided no paper record of debit/POCA
vouchers and therefore that a sub postmaster/tistress would not be able to
produce any evidefice that a customer had received a receipt for a
debit/POCA transaction. This info is available in the Audit data which can
be supplied as evidence

2.2.3.4 He accepted that the Horizon system, as supplied, which the sub post

master/mistress was required to use under contract, did not provide the

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Yard House, Basingstoke, RG21 7NX

facility for.the sub post master/mistress to reconcile discrepancies that

might arise in the operation of the system. This is down to PO!

requirements.

2.2.3.5 He accepted that there was no Post Office requirement that le should
understand the operation of the Horizon system in order to properly conduct

his investigations.

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3.

On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX

What hypotheses could support the Defendant’s claim
that the Horizon system was the source of the accounting
discrepancies?

Background

3.1.1 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._Horizon follows this principle.

3.1.2 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._Horizon‘does this.

3.1.3 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 tecorded in the accounting, system.

This _is required as part of the Stock Unit Balancing process which should

happen at least once per month and can be done as often as required. In

particular Cash should be Declared (and variances checked) daily.

3.2 Hypothetical issues with the Horizon system

3.2.1. The User Interface gives rise to incorrect data entry: poor user experience

design and inadequately user experience testing can give rise to poor data

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. ‘On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG2! 7NX

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._I’m not sure what is

meant by UI gives rise to oor data entry. Training matters are down to POL.

The Horizon system fails to properly process transactions: accounting
systems aré 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. Horizon does properly process transactions

and does ensure that double entries are always both committed atomically.

There is no need for a 2 phase commit as such in the branch accounts, but the

design of the interfaces to both the MA and POCA ensure that the view of the
transaction as recorded in the Branch is the “correct” view ther systems

are adjusted (if necessary) to match this view through various reconciliation
processes.

3.3. Comments on Hypothetical issues following site visits

There are opportunities for incorrect data entry (e.g. entry of £2,000 for a
cash credit rather than £200) to give rise to discrepancies in cash recorded on
Horizon versus cash held at the till. The sub post office relies on the
consistent, accurate and timely resolution of these discrepancies by the Post
Office and the operators of the Horizon system. The sub post master/mistress
has no standard operating procedure or local record that protects them from
the failure of the Post Office or the operators of the Horizon system to deal
with the discrepancies. Perversely, the Post Office and the operators of the

Horizon system have no incentive to resolve discrepancies that appear as cash

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On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG2] 7NX

losses ‘at the post office counter because the sub post office contract makes
the sub post master/mistress personally liable._I agree that the system just

records what the user enters, but there is little that can be done to resolve that.

However when cash is deposited messages are displayed requiring the Clerk

to check the amount deposited which should minimise such errors.

The Horizon, system does not appear to be a single monolithic mainframe
based system with computer terminals with no independent processing
capability. Rather the architecture relies on a number of inter dependent
units: the individuals nodes (counter terminals) at the. sub post office each
with its own processing unit with an attached keyboard, touch screen, barcode
scanner, debit card authorisation PIN terminal and printer and a network
router to the wider Horizon system. Each of these components could give
rise to faults that result in discrepancies: either due to problems within the
components or due to problems from interaction between the components. I
accept that currently Horizon does depend on data recorded and held on the
local system which is then replicated to other cunters and the central system.
However I am unclear why this is considered to be a fault.

Within the central Horizon system that is not directly visible to the counter
operators I would expect there to be a set of inter-operating components that
could give rise to malfunctions and discrepancies. In particular, the end to
end dialogue between the counter terminal, the card authorisation terminal,
the network, the core Horizon system, the electronic funds transfer
component, the authorising merchant service and the central’ post office
branch accounting system is a long running transaction with multiple points

of possible failure. Agreed that this is complex. However the key point is

that the end result.as seen at the counter is what is displayed to the clerk and

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On instruction of Coomber Rich Solicitors
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what goes into the accounts. Any hypothetical corruption (and I’m not aware

of any issues in that way) in other systems should not_result_in_any

discrepancies at the Branch. In particular should no response be received,

then the clerk will be advised of this and it must be assumed that the

transaction failed. n

Complex systems of this nature rarely have sufficient capability built in to
deal with all possible failure points and discrepancies are very likely to arise
which require manual intervention based on the reconciliation of paper and
electronic logs at different points in the system. When the end to end system
does not provide the counter staff with access to paper or electronic logs at
the point of use then it is impossible for them to identify whether there is a

system/fault or operator problem._There are full logs, but I agree that they are

not all made directly available to the end user. I suspect that this is trune in

any complex system. There are mechanism by which details of individual
transactions can be printed off from the system if there is some uncertainty
via the “Transaction Log” Reports.

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On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX

4 What evidence needs to be provided’ in order to
determine the merits of the Defendant’s claim?

4.1 Errors in operator data entry are not properly reconciled by the: Post Office

finance function or by the Horizon system.

4.1.1 The first problem with the provision of evidence is that the Horizon system
does not automatically provide a paper voucher for retention at the post office
counter when funds are withdrawn using a debit card or Post Office Cash
Account card. Therefore the sub post office has no mechanism for
reconciling the result of downstream processing by the Horizon system and
the Post Office with what occurred at the sub post office counter either at the
time or when discrepancies are identified at the end of the weekly trading
period. In effect, the Horizon system makes it impossible for the sub post
office to demonstrate an error occurred in the downstream processing. This is

down to Post Office Ltd.

4.1.2. The second problem with the provision of evidence is that the Horizon
system does not automatically provide a paper voucher for retention at the
post office counter when. funds are credited to the sub post office account as
part of a bill payment (Accounts Payable) as a result of a withdrawal using a
debit card or Post Office Cash Account card. Therefore the sub post office
has no mechanism for reconciling the result of downstream processing by the
Horizon system and the Post Office with what occurred at the sub post office
counter either at the time or when discrepancies are identified at the end of
the weekly trading period. In effect, the Horizon system makes it impossible
for the sub post office to demonstrate an error occurred in the downstream

processing. Again this is down to POL.

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4.13

On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX

The third problem with the provision of evidence is that -the standard
operating procedure for post office counter clerks does not include the
reconciliation of bill payment or counter credit slips with the individual
amounts recorded by the counter clerk onto Horizon. In effect, this standard
operation procedure makes it impossible for the sub post office to identify
any failures by the Post Office or the Horizon system in identifying or dealing
with discrepancies arising from incorrect data entry._Again down to POL

Processes.

The investigations identified below will assist in determining whether such

evidence is available.

4.2 The Operation of the System gives rise to incorrect data entry

4.21

There are two elements to this possible cause

The sub post office staff and, in particular, the sub post master/imistress is not
trained in the proper operating procedures~to deal with maintaining an
auditable contemporaneous record that would protect their reputations in the
event that faults in the Horizon system or operator error resulted in
discrepancies between the actual cash position and the centrally recorded

cash position. Horizon does maintain a full audit of what is recorded which

can be made available to POL. I am also aware of at least one case where

this information has been made available directly to a Defence Accountant.

The sub post office staff are not properly trained in the use of the Horizon

system._This is down to POL.

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4.2.3

On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG2! 7NX

In order to understand to what extent sub post office staff are trained in the
necessary operating procedures, it would be necessary to review the course
material provided for counter staff and sub post masters/mistresses and to
review the training and assessment processes implemented by the Post Office.
Finally, it would be necessary to: review to what extent the necessary
operating procedures could feasibly be adopted and were in fact adopted in
getieral operating practice and in the case of Seema Misra in particular,_For

POL to respond.

In order to identify whether Horizon system training is a possible cause, it
would be necessary in the first instance to sit alongside a user operating in
normal Post Office conditions that had only recently completed the standard
systems training and who represented the kind of user engaged by the

Defendant._For POL to respond,

If there is a pattern of incorrect data entry then it would be necessary to
conduct a detailed examination of the kinds of incorrect data entry that occur
and the implications for failure of accounting. Not sure exactly what.is meant
here. I’m aware of work within POL to explore errors in data entry and to

come up with ways to reduce them.

There are two available technologies that could assist in examining cases of

incorrect data entry:

e Screen capture technology installed on the user terminal that keeps a

record of every key press/screen press and the associated screen shot,_This

is not practical. However the Audit trail that Horizon maintains does

provide a fairly comprehensive record of what has happene:

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On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7NX

© Digital camera recording equipment positioned to have a clear view of the
screen continuously recording the screen as it responds to operator entry
This is clearly possible. A similar technique has _also_been used to

benchmark system response times.

4.3. The Horizon system fails to properly process transactions

In order to identify whether this is a possible cause, it would be necessary in
the first instance to examine the operations in normal Post Office conditions
where there is an experience by the branch manager of what they believe to

be incorrect transaction processing.

Further, if there is prima facie evidence of incorrect transaction processing, it
would be necessary to review the technical documentation of the Horizon
system and interview key individuals responsible for the system within. the
Fujitsu team in order to understand the potential source of the incorrect
transaction processing. From my understanding of comparable retail systems
architectures there are a large number: of potential points of failure which
could give rise to the kind of discrepancies reported by Seema Misra and the
sub post mistress in the Midlands. In particular, I have reviewed the
architecture for a national retailer and, identified a series of possible failure
points which are currently addressed by testing, review of error logs and
reconciliation Of discrepancy reports. See Exhibit “Point of Sale — Electronic

Funds Transfer architecture”._I don’t see the relevance of this diagram. It is

nothing like what Horizon does. We could if necessary provide some

documentation and information on Horizon. However I am confident that

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4.3.3

Yard House, Basingstoke, RG2! 7NX

,

there is not a system problem and the issues are due to incorrect actions

(whether deliberately or accidentally) by the user.

Based on the. review of the technical documentation, it should be possible to
identify and examine the various electronic log files maintained by different
components of the systems architecture that are required by the Electronic
Mastercard Visa (EMV) ‘standard or for Payment Card Industry (PCI)
compliarice._These robably available. (I’m not sure how long they are
held and they will probably have had details of Cards Obfuscated for Security
reasons as required by PCL)

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._Again this is possible.

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On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG21 7X
5 My duties to the Court
5.1 T understand that my overriding dity is to the Court, both in preparing reports ‘
and in giving oral evidence. I have complied and will continue to comply with
that duty.
5.2 Ihave 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.
5.3. Ihave 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.
5.4 Ihave drawn to the attention of the Court to all matters, of which I am aware, \

which might adversely affect my opinion.

5.5 Wherever I have no personal knowledge, I have indicated the source of factual

information.

5.6 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. I

5.7. 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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5.8

5.9

5.10.

On instruction of Coomber Rich Solicitors
Yard House, Basingstoke, RG2] 7NX

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.

I understand that this report will be the evidence that I will give under oath,
subject to afiy correction or qualification I may make before swearing to its

3, !
veracity

T 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.

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.

Charles McLachlan

Amsphere Consulting Ltd

Staple Hall

87-90 Houndsditch :
London, EC3A.3AD

England

Thursday, 19 November 2009

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