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The Post Office Horizon IT Inquiry
Wednesday, 19 June 2024
(9.45 am)
MR STEVENS: Good morning, sir.
SIR WYN WILLIAMS: = Morning.
MR STEVENS: Can you see and hear me?
SIR WYN WILLIAMS: Yes.
MR STEVENS: Thank you, sir. Before we hear from
Mr Christou, I should just say that we will be having
the usual fire alarm at 10.00.
SIR WYN WILLIAMS: Yes.
MR STEVENS: As usual, I propose we just sit through that.
SIR WYN WILLIAMS: Yes, of course.
MR STEVENS: If I can call Mr Christou.
RICHARD CHRISTOU (sworn)
Questioned by MR STEVENS
MR STEVENS: Please could you state your full name?
A. Richard Christou.
Q. Mr Christou, thank you very much for attending the
Inquiry today and thank you for the two witness
statements you have provided. I want to turn to those
first. You should have a bundle of documents in front
of you. Could I ask you to open that and have the first
witness statement in front of you.
A. Ido.
Q. Thank you. Is that dated 20 March 2023?
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you please to turn to page 27 of your statement.
The second witness statement?
The second witness statement, sorry, yes, thank you.
Yes?
Is that your signature?
Yes.
prporpe>
Are the contents of both of those statements taken
together true to the best of your knowledge and belief?
Yes.
oP
Thank you very much. Now, those witness statements now
stand as evidence in the Inquiry. They will be
published on the website in due course. I have some
questions for you about them but not all issues that you
raise within them. I want to look at an exhibit in your
witness statement first, if I may, and that's -- if we
can bring up the first statement, please, and page 30.
A. I'm looking at the wrong statement.
Q. Yes, it will be on the screen shortly, as well. So this
is a CV that you've annexed to your witness statement.
If we could go to the bottom of the page, please, we see
that you qualified as a solicitor in 1969 --
A. Yes.
Q. -- and, thereafter, from 1970 to 1990, you held various
roles in the companies listed in the middle column.
A. Yes.
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Yes.
For the record, that has Unique Reference Number
WITNO03840100. Could I ask you please to turn to
page 29.
Yes.
Is that your signature?
Itis.
Could I ask you then to turn to your second witness
statement, dated 9 May 2024.
Yes.
For the record, that is reference number WITN03840200.
Now, before I ask to turn to your signature, there's one
correction I believe you want to make --
Yes.
-- which is at page -- bear with me sorry -- page 21,
paragraph 103.
That's correct.
I'll just wait for that to come up on the display.
There we are. So, as I understand it, it's the last
sentence of paragraph 103 and the correction should be
in schedule A02 to change the paragraph number to 4.1.8.
That's correct.
Is it the same for schedule A4?
Yes.
Thank you. With that correction in mind, could I ask
2
Now, of those roles were you acting as an in-house
solicitor for -- where it says legal adviser, is that
akin to in-house solicitor?
Yes.
We see from 1982, the two roles you had with, first with
STC Telecommunications and then with Solaglas (UK)
Limited you acted as company secretary?
That's correct.
Finally, from 1987 to 1990, it says, "Director,
Commercial & Legal Affairs" of STC Plc. Did you sit on
the Board of that company?
No, it was what I described as a courtesy title.
I want to now look at your roles from 1990 onwards, and
from that point you worked within the ICL Group?
Yes.
When you joined in 1990, I understand that Fujitsu --
l'lljust use the single term without going into the
precise legal entities -- was a majority shareholder in
the ICL Group?
Yes.
ICL, at that time, continued to have its own branding as
ICL --
Correct.
-- but, in 2002, the brand changed from ICL to Fujitsu?
Yes.
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Could we look, please, in your second statement at
page 3, paragraph 10.
Yes.
So it's been some time since the Inquiry has considered
the corporate structure for Fujitsu, so I think it's
helpful to go over it. You helpfully here set out the
key or relevant companies within the ICL Group, at
paragraphs (a) to (e), on the left, with the name before
the change of brand in 2002, and, on the right, when it
became a Fujitsu-branded company?
That's correct, yes.
So at the top of the corporate pyramid, as it were, we
have ICL Plc, which was the ultimate holding company for
the group?
Yes.
We see that became Fujitsu Services Holdings Ple in
2002.
Yes.
Beneath that (b) there's International Computers
Limited, which was a wholly-owned subsidiary of ICL Plc?
Correct.
International Computers Limited carried out ICL Group's
UK operations; is that right?
That's correct, yes.
That became Fujitsu Services Limited --
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-- for being a PFI deal, initially. For today's
purposes, from 1996 onwards, wholly owned by ICL --
Correct.
-- International Computers Limited?
Correct.
Thank you. The final company we see there is (d), the
ICL Global Investments Limited. Now, I understand that
that was a subsidiary of the overall parent company ICL
Plc?
That's correct.
ICL Global Investments Limited dealt with the ICL
Group's non-UK business?
That's correct.
Let's turn, then, to look at your roles. You were
appointed as Director of Commercial and Legal Affairs of
International Computers Limited in 1990?
Yes.
We don't need to turn it up but, in your first witness
statement, paragraph 5, page 2, you say that you were
responsible for the provision of legal and commercial
advice in connection with the participation of the ICL
Group in the tender for the Horizon IT System.
Yes, that's correct.
So, in that role, and when dealing with the tendering
process and the Horizon IT System, which teams reported
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Yes.
-- which from roughly 2002 onwards it became the
contracting party for the Horizon contract?
Yeah, precisely in April 2003 is when the change was
made but, yes, now it is, yes.
Yes, 2003, sorry, you're quite right. What we see at
(c) is ICL Pathway Limited. Now, Pathway, when the
Horizon Programme was being tendered for, it was
referred to as the Pathway Programme?
Yes.
ICL Pathway Limited was set up as a company in order to
tender for and deal with the Pathway Programme?
Yes, yes, that's correct.
That, in itself, was a wholly-owned subsidiary of
International Computers Limited?
It started off as a consortium, there were two other
shareholders. From recollection, it was Girobank and De
La Rue but, shortly after, I think about a year after --
1996 maybe -- ICL and the other two consortium members
parted company quite amicably and it then became
a wholly-owned subsidiary of ICL -- sorry, of
International Computers Limited.
I think you're quite right, the De La Rue and Girobank
consortium was of sort of historic interest --
Historic.
to you?
Only legal personnel, no other persons at that stage.
There would have been some commercial people as well but
that's all. There were no operational people reporting
to me at all.
Do you recall who operational people reported to?
They would have reported either directly or indirectly,
and I think directly, to Keith Todd at that stage.
Could you explain where Keith Todd sat in relation to
you in the management structure?
I reported to Keith Todd. He was the Chief Executive.
Now, at that stage, were you part of any management or
Executive Committee this within ICL -- sorry
International Computers Limited?
There was a Fujitsu -- sorry, it would have been ICL at
that stage -- ICL Management Committee, I suppose you'd
call it -- which met once a week, and we -- all of the
reports of the Chief Executive would sit round the table
and you'd discuss whatever matters came up.
For the purposes of those management committees, was
there a hard line difference between, say, ICL Plc and
International Computers Limited?
I don't think people thought of it like that.
(Pause for fire alarm test)
I say with trepidation that I think that's the end of
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it.
We can carry on.
Just for clarity, I was asking you about management
committees.
Right.
The question I asked before we had the fire alarm was:
was there a hard line difference between the management
committees of, say, ICL Plc and International Computers
Limited?
As I said, I don't think people thought of it like that.
If you look at the composition of that management
committee, the people on it, of which I was one, were
probably called director of this and director of that
but none of them, except the Chief Executive, was on the
Board of ICL Plc. So, in that sense, yes, there was
a hard line, I suppose you could call it a hard line,
between them. But whatever went on there, it was the
Chief Executive's job, in due course, as a member of the
Board to produce his report to the Board.
So in your role you would attend the Management
Committee --
Yes.
-- every week. You weren't a member of the Board of ICL
Plc --
No.
Can you recall who else attended those Board meetings,
in particular who from an IT background or an
‘operational background attended?
Let's think. The only one that springs to mind -- well,
of course, there was the Managing Director of Pathway,
who was then Mr Bennett, I think Mr Coombs attended as
well. I don't recall any other operational people.
Mostly, it was the Board originally, with some of the
representatives of Girobank and De La Rue, and they
actually stopped on for some time afterwards because
there were subcontracts with them.
Let's turn then to your -- before I do that actually,
I should say, in your first statement, you go into, as
requested by the Inquiry -- an amount of detail in
relation to the Benefits Agency withdrawing from the
agreement. Those are Phase 2 issues that I don't
propose to cover with you today.
Right.
You became Acting Chief Executive and, shortly after,
Chief Executive of ICL Ple in 2000?
That's correct, yes.
Whilst you were Chief Executive, I understand you were
also a director of International Computers Limited?
When I was Chief Executive, I would have been a director
of ICL Plc in that sense. I mean, nobody really looked
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-- but would you be asked to attend on occasion?
I actually can't recall an occasion when I was asked to
attend.
I've asked there about management committees of ICL Plc
and International Computers Limited; what about ICL
Pathway Limited: did that have a separate management
structure?
That had a separate management structure because,
‘obviously, it was originally set up as a consortium
agreement. They had their Board, and it was managed,
I suppose, quite a lot in the early stages, via the
Board. The Chief Executive would report to that Board
but, in practice, the Chief Executive reported to --
well, he was called Managing Director -- reported to the
Chief Executive of ICL, who would have been Keith Todd.
So would that mean the Managing Director of ICL Pathway
Limited came to the Management Committee meetings which
you attended for ICL - sorry, International Computers
Limited?
Frankly speaking, I can't recall but I don't think so.
But I don't recall actually seeing him at a meeting.
Whilst you were in your position as Director of Legal
and Commercial, did you attend the Board meetings of ICL
Pathway Limited?
Yes, I did.
at International Computers Limited as a separate
company, whether it's correct or not, it was, if you
like, all mixed together and the Board that, if you
like, was controlling the whole thing was the Board of
ICL Plc and yes, I would have sat on that when I was
Chief Executive as a Board member.
In terms of the responsibility for overseeing the
Horizon IT System, at the time when you became Chief
Executive in 2000 at Board level, was that
a responsibility of ICL Pathway Limited, ICL Plc or
both?
I think at different levels it was both because,
clearly, ICL Pathway was executing the contract and
looking at it on a -- obviously, a day-to-day basis,
hourly, probably. But ICL Plc, obviously, as the
ultimate Board had responsible for the whole business,
including Pathway -- or Horizon, I'm sorry.
This is quite a broad question but would you say that
the identification, analysis and management of risk is
important to the running of a company?
Of course it is.
Would you accept that ICL Plc or the Board of ICL Pic
was responsible for overseeing how the Group or the
company, either ICL Plc or ICL Pathway Limited,
identified, analysed and managed risk?
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Only in the broadest sense.
Can you expand on that, please?
Yes, sure. If you look at a company the size of this,
it is not possible for every level of detail to be
surfaced to the Board. If every single document about
every single contract was surfaced to the Board, they
would not have time or capacity to understand it or to
consider it, even. So what is necessary is a filter
system, whereby overall the Board has to be satisfied --
and this is what I've described in the second witness
statement, that there are flows of information in place
but one has to manage by exception, and people further
down in the organisation -- in this case the Managing
Director and the other responsible people in Pathway --
had to deal with day-to-day matters.
And levels of a certain granularity, complexity,
would not come to the Board. The Board would have
certain reports and they would be satisfied with the
overall conduct of the business but precise details, no.
The filters you've described, presumably the purpose of
those is to ensure that any serious matters that ought
to have the attention of the board, either of ICL
Pathway Limited or ICL Plc, ensure that those
significant issues make it to the Board?
Yes, I think that's correct. I'm saying ensure they
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would have dealt with it.
So I think, overall, I'm responsible -- and I accept
that -- for setting up the systems but it's people lower
down in the organisation who have to operate them.
That's talking about responsibility for ensuring things
are working. I want to ask a slightly different
question about accountability. Would you accept that,
as Chief Executive, you were ultimately accountable for
the operations of the ICL Group?
I don't accept that. That's too broad.
In terms of your accountability then, for the ICL Group
and its operations, what would you say your level of
accountability was?
What I was responsible for was that, as so far as
possible, to see that the operations of ICL were carried
out legally, were carried out profitably and to report
to my shareholders, Fujitsu Limited, various issues
insofar as it was necessary.
If you mean that I was responsible for the
miscarriage of justice then I don't accept that. It's
not to mitigate the miscarriage of justice, I hasten to
add, I think it's a gross miscarriage of justice,
I really feel for the subpostmasters and the postmasters
who are involved, but talking about accountability is
a different matter and, certainly, I knew nothing about
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reached the Board provided people further down operate
the system properly, then they will reach the board.
They were issues that were serious -- in my second
witness statement, I refer to the red alert system --
and those things did come to the Board. So details,
certain details, would not have come to the Board
because they were too complex, technical and too
detailed.
Would you accept that, as Chief Executive, you had
a responsibility to exercise care to see that those
filters were working properly and people in lower down
executive levels were filtering information up
appropriately?
I'd accept that I had responsibility to set up the
systems, a lot of those systems were already set up
before I became Chief Executive. One has to delegate
and delegation in the organisation requires that people
further down make those decisions. It's necessary to
see that appropriate personnel are appointed and, at
various levels, that is always done. I should point out
that all of our employees are required, through the HR
system, to go through assessments as to capability,
et cetera, et cetera, on a regular basis and these are
filtered up and, if there were any concerns about the
competence of a person, the next level of management
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it.
We'll come back to specific facts as we go. Before
moving on to look at the restructure, I just want to
ask, when you were Chief Executive, who did you report
to?
I will first have -- well, apart from the Board, in
actual fact, I reported to a Mr Naruto in Tokyo, he was
a very senior member of the IC -- sorry, Fujitsu Limited
Board, and he was the person who oversaw the purchase of
ICL by Fujitsu in 1990. After that, I reported to
a Mr Kurokawa, who was later president of Fujitsu, and
I reported to him for a long time, and following that
I would have reported to the next president and the next
president.
In terms of as Chief Executive, your reporting lines,
who reported to you directly, who had responsibility for
the oversight of the Horizon IT System?
Very initially, and I'm talking about the 2000, Mike
Stares, I presume, would have reported -- he reported to
me. From July 2001, a Chief Operations Officer,
Mr David Courtley, was appointed and, from then on, he
was responsible for all of the operations within ICL, as
it was then, and all of the operation departments,
including Pathway, reported to him; he reported to me.
I kept the functional departments at that time, so
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things like HR, Marketing and Legal.
We, actually, I'll go slightly out of order, on the
matter of Mr Courtley. In April 2004, you became
Executive Chairman of what was then Fujitsu Services
Holdings Plc but had been ICL Plc?
That's correct, and he became Chief Executive.
Now, you remained employed by the company on a full-time
basis, I understand?
Yes, that's why they called it "executive". I mean, we
know it has no legal significance, you're Chairman or
you're not Chairman, but that's what Fujitsu wanted to
use because that's what they thought it meant.
Did your responsibilities change upon becoming Chairman?
Yes. They were much more focused outward, dealing, for
instance, with particular customers, a lot of them
overseas, because Mr Courtley had his hands full,
reorganising and dealing with the operating divisions
within what was then International Computers Limited.
So, to give you a small example, I went with the
president to Russia at one stage to look at their
operations there; I went to Finland; a bit later on,
I was on some Boards of Fujitsu America; and so on.
I mean the role grew, much more widely.
The functional elements that you said you kept when
Mr David Courtley became Chief Operating Officer in July
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We had our offices next door to each other. We'd
have coffee together and chat. If there was anything
that was concerning him, he would have raised it with
me.
You say in your witness statement you had regular weekly
meetings with all your direct reports, including
Mr Courtley?
Yes, yes.
Did that continue when you were Executive Chairman?
No, not in the same way. I would have had -- the weekly
meetings I would have had would have been with
Mr Courtley and with the functional people. But not
with the operational people underneath, that was for
Mr Courtley to deal with, including Horizon.
Aside from the matters that you raise in your witness
statement, such as various red and amber alerts, can you
recall Mr Courtley expressing any concerns to you as to
the adequacy of the Horizon IT System?
No.
I want to look at the restructure now, it's jumping
back, I appreciate. Please could we bring up
FUJ00003693.
Yeah.
This is set of minutes for ICL Pathway Limited --
Yes.
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2002, did you pass those functions down to
Mr Courtley --
Yes.
Yeah.
Sorry, I shouldn't cut you off. Yes, the answer is.
I was going to say when you became Executive Chair?
Yes, yes, exactly.
What was your working relationship like with
Mr Courtley?
Very good. I'd known him for some time, actually. He
worked previously for EDS and we first came across each
other in a kind of contract dispute, as it happens,
between ICL and EDS, and we had a great mutual respect.
I thought he was a -- first of all, he was more of
a technician than I. He actually had a degree in
mathematics. That's what you got in those days if you
were going to be a computer scientist. So he was much
more technically oriented than me and he was also what
I'd describe as better at growing the business than me.
I was, if you like, clinical and the turnaround
I did in ICL, during those first years, was something
that needed a really clinical, objective view of the
issues. He was concerned much more with growing the
business and this was one of the reasons why he was
employed.
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-- so the specific company, 15 August 2000?
Mm-hm.
At this time you were Acting Chief Executive, I believe?
That's correct. That -- just about, yes.
We see you are chairing the meeting.
Mm.
If we go down slightly, further down, please. Thank
you.
Sir, I should just say, at this point, when looking
at minutes, you may see the Post Office highlighted at
various points -- you'll see it there -- that wasn't on
the original minutes. That's something that's added
afterwards.
Okay.
So just a point of clarification.
Yeah.
So you've got various things of headcount requirements
for testing, and then we have the Managing Director's
report.
Mm.
Go over the page, please. We see there quite a detailed
report from the Managing Director --
Yes, yes.
-- on various parts.
Yes.
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(b) CSR+ -- that's Core Systems Release Plus -- was
a significant issue?
Yes.
It provides detail; (c) we have detail on the rollout;
and (d), weekly service performance is still a key
issue.
Mm.
Was this typical of the type of oversight that the Board
of ICL Pathway Limited would give to the delivery of the
Horizon contract?
Yes, I think that's -- yes, I mean, obviously, it varies
with time but this is the sort of report that we got,
yes.
In fairness, this is rollout, so it's a busy time for
the company?
No more busy than in the development. I think, in
a sense, once they got through the acceptance test,
which I'm -- they would have done by then, I think,
rollout is a logistics issue, rather than a -- it's much
more straightforward in a sense. There's a lot of
planning to do but it’s a logistics issue, mainly.
Can you recall how often the Board of ICL Pathway
Limited would meet?
No.
Can we look at your witness statement now, please,
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Is it incorporated in Japan?
Oh, yes, yes.
So do I understand you to say that this decision was
made by that company in Japan not an ICL Group or UK
Fujitsu?
No, no, they -- I mean, it's a practical matter that
they wanted to look at the business as a whole, and
there are a lot of Japanese directors and observers
coming in all the time and to have three separate
meetings just wasn't efficient. So we dealt with
everything at one meeting and the meetings would go on
all day.
So when you discuss efficiency, you're using it in the
sense of the word from the holding company above Fujitsu
Services Holdings, their efficiency, really.
Yeah.
-- they come in and have fewer meetings?
Well, yes, but it didn’t impact on the consideration of
issues, it was just that we had a very long meeting on
one day.
Could we just then turn to page 12 of your statement,
paragraph 55. Sorry, second statement.
Yes --
For context, in this you're talking about quarterly
business reviews, and you say:
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page 4, paragraph 15. So you discuss here part of the
restructure --
Yeah.
and say:
"In order to make Board meetings of all three
companies more efficient ..."
When you say “all three companies" there, you're
referring to the ultimate parent company, Fujitsu
Services Holdings, Fujitsu Services Limited, the sort of
intermediate company --
Yes, there's those two.
-- and then the other -- I think the third company is
the one responsible for non-UK business?
That's correct. It was all three of those.
The Board decide to delegate the oversight of all of the
companies to a single management, known as the Fujitsu
Services Management Committee?
That's correct, it was a Fujitsu Limited decision.
When you say Fujitsu Limited, can you just explain the
corporate identity of Fujitsu Limited?
Yes, Fujitsu Limited is the ultimate holding company of
Fujitsu. It's quoted on the Tokyo and, I think, the
New York Stock Exchanges. It's an interesting company
because it's not only a holding company but it also runs
all of the operations in Japan as well.
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"For a complete set of meetings comprising this
cycle [the corporate business review cycle, I think] see
the four FSMC [so Fujitsu Services Management Committee]
meetings in 2005 ..."
So do we take it from that that the plan was for the
FSMC to meet four times a year or quarterly?
That's correct. It fit in with Fujitsu's quarterly
reporting obligations as a quoted company, and I can
expand if you wish but that's the answer to the
question.
So the follow-up question I have is: from the
perspective of, say, a director on ICL Plc, when this
change was made, did it result in fewer Board meetings
each year?
No.
So before the change, it was --
It was exactly -- it was following exactly the same
schedule from 1990 because, from 1990 onwards, Fujitsu
Limited had the same reporting requirements as it did in
2000. In fact, when ICL was taken over, it had to
change its accounting year to correspond with the
Fujitsu accounting year, so that the system would work.
So this is a long-established tradition.
That document can come down, please.
Can we please look at FUJ00003704. We see these are
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minutes of the Fujitsu Services Management Committee on
29 May 2002.
Yes.
In your witness statement, you say that this is the
first meeting of the FSMC.
Yes, because it took place -- we switched the brand, if
you'll remember, on 1 April 2002, again to coincide with
Fujitsu's financial year. Everything happens at the
beginning of the financial year with Fujitsu, and that
was the first meeting that we held.
We see that, at this point, that one of the companies
included in this isn't what was ICL Pathway Limited?
No, that's correct and it wouldn't be because it was
just an operation, just like a lot of other operations,
and you've got Mr Courtley there, who is responsible for
all those operations. So it wouldn't be appropriate.
If we can go down, please, we see at the bottom we have
your CEO report, and you're talking about the financial
year and about the restructuring.
Yes.
If we can go to page 3, please, the CFO report?
Yes.
Just scrolling down, we don't need to read all of this,
but we see quite a detailed report which continues until
page 8 -
25
say the "extension", you mean the extension of the date
for termination of --
Exactly.
-- the Horizon contract --
Yes.
-- and it then extended to 2010?
Precisely.
At this stage then, so we're in 2002, can you recall
what, if any, Board meetings were held by ICL Pathway
Limited?
No, is the answer. I may have attended some but,
without you showing me documents at this minute, I don't
recall.
Is it fair to say from your perspective at this stage
you saw the responsibility as being on Mr Courtley to
present any issues with the Horizon project to the
FSMC --
That's exactly correct.
- or that --
Well, or to me.
Or to you in the -
Yes, and then I would have presented it but that's
correct.
That document can come down. Thank you.
Do you think the restructure had any effect on the
27
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Yes.
-- and we have here Mr Courtley presenting the new
organisational model.
Yes.
In terms of the new organisational model, and I'm only
really focusing on oversight of Horizon here, what
changes were made to the management structure that
affected the oversight of the Horizon IT System?
In actual fact, none at this stage. You see the one
that says, "Large projects, reporting direct to
Mr Courtley"?
Yes.
Well, one of those large projects was, at that time,
Pathway -- I've forgotten what it would be called now,
ICL Pathway Limited, I suppose -- and what happened,
just to -- if I may, to finish it -- in 2003, when we
entered into the extension agreement, it was agreed with
the Post Office that we would shut down the actual
Pathway company, it would become dormant, and large
projects would then comprise a division within Fujitsu
Services Limited, which comprised the Horizon project,
and that division became one of the five large projects,
each of which had a division, if you like, reporting to
Mr Courtley.
The only thing, I think, just to clarify there, when you
26
level of oversight that ICL Pathway, then Fujitsu
Services Holdings limited, had on the Horizon IT System?
I think it would have had a beneficial effect because
what you have now is Mr Courtley, who has great
experience in IT, he's much more technically oriented
than me, and I believe it would have been, let's say,
a more -- more piercing oversight is the word I would
use, yes.
Before I move on to look at a couple of specific topics,
just for the purposes of the timeline, I want to
complete your sort of career history. In April 2007,
you became Corporate Senior Vice President and Head of
Fujitsu EMEA Regional Operations for Fujitsu Limited?
Yes.
So that's the overall parent company incorporated in
Japan?
Yes.
Did you remain a director or involved in Fujitsu
Services Limited or Fujitsu Services Holdings Plc?
I would still, from my recollection, be chairing the
FSMC. That's the limit of it. So, from that stage
‘onward, anything that I really knew about operations
within that group of companies would have come via the
FSMC meetings.
And at that stage, would you have had -- sorry, I'll
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rephrase that question.
Did Mr Courtley report to you directly or indirectly
once you became Corporate Senior Vice President?
I'm trying to think. I'm thinking very carefully about
the answer so I can give it to you. It would have been
directly, in a sense. There was still a line but that
line would have been fairly tenuous. I mean, at that
stage, he was acting like any Managing Director or Chief
Executive of a subsidiary, reporting to what I described
as a holding company. So there was a line but he was
running the business as he saw fit, I had confidence in
him and that was it. Yeah.
I was ultimately responsible, I think is the way
I will put it, for the way in which he managed the whole
of the business but that's like a normal Chairman of
a Board, in my view.
What reporting line, if any, did you have to Mr Duncan
Tait?
Duncan Tait was -- I've got to think about this --
I think -- and I'm saying I think -- that he came on
board -- he came from Unisys as a director -- courtesy
title -- of I think the commercial business unit in
those days, which I think had Pathway in it. He would
have reported to David Courtley. So it's a very
indirect line, as far as I'm concerned and, by the
29
frankly, at 67 this was becoming a bit too much for me,
and I spent a year -- Fujitsu Limited tends to give its
directors a kind of sabbatical before they retire, is
the way it works, and I took my sabbatical in Singapore,
I was kind of a corporate executive adviser but I didn't
really do anything much and then I left, returned to
England, and that was the end of it.
Sorry, I can stop.
Before I --
Yes?
-- move on, do you recall at any point Mr Tait advising
you of any concerns he had about the Horizon IT System?
The only connection that I had with him in this issue is
the document which you showed me, I can't remember the
name of it, an exchange of emails, in which he wanted to
set up --
Well, if that’s your only recollection --
That's the only -- I can't remember whether it happened
or not, to be honest.
We'll come to that shortly.
Yes, yes. But that's all. Nothing else.
We're going to move to a different topic now. Can we
please bring up your first witness statement, at
page 22, paragraph 67, so you write at paragraph 67
that:
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time -- don't forget, by the time he came on board,
I was practically based in Tokyo. I mean, I went to
live in Tokyo in 2010 so, yes, I knew him.
I had a lot of respect for his competence.
Mr Courtley left in 2009, I think. There was a short
interim period when I just sort of held the reins.
I don't know if -- I wouldn't say I was overseeing
anything in particular. I appointed Roger Gilbert for
a short time as Chief Executive of what was then Fujitsu
Services Limited. We had broken -- I've got to go back
to this, but we broke up the original group once we were
reorganising as a global business group and what was
there was Fujitsu Services Limited. ICL Plc was -- it
was a legal entity but it was not really managing, in
any sense of the word.
So Duncan Tait was in charge of commercial unit.
Pathway was in it. There came a time in 2010 when we
wanted to make a more permanent Chief Executive for
Fujitsu Services Limited. There were two people who
were candidates and about my last executive decision, if
you like, was with the consent of Fujitsu Limited, my
colleagues on the Board as it would have been in these
cases, I appointed Duncan Tait as Chief Executive of
Fujitsu Services Limited. That's 2011.
At that stage, I retired, in effect, because,
30
"I have been asked whether or not Horizon could be
considered a robust system. In all my experience of
‘over 40 years working in the Telecommunications and IT
industry I have never across the use of the word
‘robust' as a contractual term. With respect, I think
it is a subjective term without any precise legal
meaning. I believe that the only pertinent questions in
relation to the Horizon system are, (a) did the system
pass the acceptance tests, and (b) was it delivered in
accordance with the contract. Both of these conditions
were satisfied at the end of rollout in 2002."
So, effectively, as I understand it, you're saying,
from your perspective, the key questions are: (i) the
product produced by Fujitsu and delivered to the Post
Office, did it pass the contractual acceptance test?
Yes.
Secondly, in respect of the ongoing obligations, was
Fujitsu delivering those in accordance with the
contractual standards that had been agreed between the
parties?
Yes.
Could we please look at page 26, paragraph 79. You say:
"My objectives in negotiating the Codified Agreement
Now, pausing there, the Codified Agreement was the
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The Post Office Horizon IT Inquiry
agreement entered into between Post Office -- then Post
Office Counters Limited -- and ICL Pathway Limited in
1999?
Yes.
So the objectives in negotiating that were:
"to create a detailed specification and precise
acceptance criteria."
When you say “detailed specification", is that
referring to a specification of the services that ICL
Pathway were to provide to Post Office?
That specification that I was focusing on was
a specification of the system.
Okay. So -
Because that's what's passing the acceptance tests.
So, when we're seeing a detailed specification, is that
referring to a set of contractual clauses that set out
the specification for the system that ICL were supposed
to deliver to Post Office under the contract?
Yes, it was in a schedule to the Codified Agreement.
You say you:
"... focused on the main provisions of the Codified
Agreement, in order to achieve the above objectives.
I had little involvement in the preparation of the
schedules and appendices of the Codified Agreement,
which I never read."
33
Sorry.
We see defined terms, as is standard, are capitalised,
so things like Contractor --
I'm sorry, I'm lost here. Just tell me again?
I'm so sorry. It's 103.3 (sic).
I'm not seeing that on the screen.
Ah, right. 101.3, I've done the same again.
You want me to look at 101.3?
101.3, yes?
Okay.
Can you see that now?
Yes, now I can, yes.
It would help if I said the right clause. That would be
of assistance.
For example, it says "The Contractor", capitalised,
and, throughout this agreement, defined terms tend to be
capitalised —-
Yes.
-- as standard.
Yes.
So, in order to understand this agreement, you would
presumably accept that you need to be familiar with
Schedule A1?
This is the interpretations?
Yes.
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Yes.
I want to look at the Codified Agreement now.
Okay.
It's FUJ00000071. This is a document of over 900 pages,
so it may be we need to catch up a little bit with the
computer system but this is the Codified Agreement. Can
we turn to page 12, please.
‘SIR WYN WILLIAMS: I'm sorry, what's the reference for that
again: 71 at the end? Thank you.
MR STEVENS: Yes, FUJ00000071.
‘SIR WYN WILLIAMS: = Thanks.
MR STEVENS: If we could go to clause 102.1, please. So
>
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that's an interpretation clause, which is standard in
these contracts.
Yes, yeah.
It says:
“As used in this Codified Agreement:
"the terms and expressions set out in Schedule A1
shall have the meanings ascribed [to them] ..."
Yes.
As is standard, for example, at 103.3, we see -- no,
sorry --
Which one?
Sorry, if we could go up slightly. I misspoke, sorry.
101.3.
34
Yes.
So --
In that sense, I did read it, yes.
I was going to say, putting yourself back, whilst you
may not have been au fait with everything in the
schedules you well have had some familiarity?
That's fine but I'm talking about the whole 900 pages.
Yes, of course. Could we go, please, to page 17. If we
could go down to the bottom there. Thank you. We have
"Part 2: Performance of [Post Office Counters Limited]
Services and Supply of Products". Clause 201.2 says
this:
"Subject to clause 201.6 the Contractor shall be
responsible for meeting the requirements specified in
schedule A15 in accordance with the Solutions specified
in Schedule A16 by performing the Core System Services
referred to in Clause 201.3."
So, breaking that down, what we have here is,
firstly, there was a schedule A15, which set out Post
Office, it says, requirements for the contract.
Well, those particular specifications with the solutions
specified, yes.
Yes.
Mm.
There were solutions specified, as you say, in schedule
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A16?
Yes.
Now, when you were involved in the negotiation and the
tender, would you have been involved in considering the
requirements and solutions for the products?
No.
The clause here then says that, in order to meet the
requirements, ICL Pathway had to perform the Core System
Services referred to in Clause 201.3. So, if we could
look at 201.3, please, which is on the next page. Thank
you:
"Subject to Clause 201.6 the Contractor shall
perform the following Core System Services in accordance
with all applicable provisions hereof..."
So this is essentially setting out what ICL is
supposed to do under the contract --
Yes.
~ or part of it, I should say?
Part of it, yes.
So this is a very important clause in the contract;
would you agree?
Yes. Yeah.
Would you agree that it's fundamental to the
specification of the product and services to be
provided?
37
authorising commencement of National Rollout of the Core
System and subject to Clause 201.6, the Contractor
shall, from the date of [Core System Release]
Acceptance, perform the following operational Services."
Now, these obligations effectively kick in after
acceptance?
Yes, after acceptance, and the way I think of these are
service provision and service provision obviously can't
start until you've got something rolled out that you can
provide the service for. So it develops progressively
as rollout takes place. Yes, yes.
You say that you were involved in drafting precise
acceptance criteria for the --
When I say I was involved, what I was involved in was
ensuring that the technical people actually did it
because one of the biggest failings in IT contracts is,
when they come down to it, they end up without
a specification and without acceptance criteria, I was
taught this from 1975.
As part of that, you would have presumably needed to
review the contract and see what services or what
specification was being agreed?
No. It's not something that I would have looked at
because this was dealt with by people who were
responsible providing it, and they will produce the
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Well, it describes what they are and then you have to
look at the definition. So I suppose so, yes.
We'll look at two of them. Paragraph 201.3.1 says that
ICL were to provide the development services pursuant to
clause 403 --
Yes.
-- and 201.3.3, also the operational services pursuant
to clause 405.
Can we look, please, at page 26, and go to
clause 403. So this is the clause that defines the
development services?
Yes, yes, yes, and it has loads of schedules attached to
it, so far as I can see, which would give you the
specification of the development.
Yes.
Yes.
At 403.2, it says, "development of EPOSS", that refers
to the Electronic Point of Sale System --
Yes, yes.
-- "as described in the Schedule F1".
Yes.
Then if we can go over the page, I think, to clause 405,
we have the "Performance of Operational Services", and
it says:
"Subject to the Release Authorisation Board
38
necessary services. I wouldn't want to go beyond what's
in clause 405, and even that needed input from, if you
like, technical people who knew what to write in
clause 405. What I was concerned with was that it
happened, not with its content, and I wouldn't pretend
to be competent to criticise that content.
So is your evidence that, in terms of internal lawyers
within ICL at this point, was -- well, I won't say “is
your evidence", I'll ask you. In terms of internal
lawyers within ICL at this point, were there any
lawyers, that you're aware of, who were monitoring or
reading what was in the schedules?
This would have been done by Masons. I'm sorry if we
are -- they're now Pinsent Masons, I think. These were
long-time solicitors. First of all, for STC, actually,
I knew them, and there was a person called lain Monaghan
who was the head of a team of lawyers who was looking at
all of this and working with the technical people. It
wasn't done by lawyers within ICL, as it was in those
days, I suppose, but it was done by a properly qualified
Legal Team and Masons were expert in dealing with IT
matters. I used them on many occasions.
But, presumably, someone within ICL would want to know
precisely the nature of the obligations that ICL was
signing up to?
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The Post Office Horizon IT Inquiry 19 June 2024
A. Of course they would but they will be the technical
people who would then consult on the drafting with
Masons.
Q. So your evidence is, in terms of the lawyers, the
lawyers wouldn't have read the schedule F1 --
A. No, no, I'm not saying the lawyers wouldn't. Masons
would have done, people in Masons. They had a whole
team, and they would have worked with the technical
people in ICL. I was there with Stuart Sweetman to
oversee that things happened and to look at any real
points of conflict in the main agreement, and I don't
think there were very many, actually.
Q. Well, let's look at schedule F01, it's page 587. So
this is the "EPOSS Service Definition" to which those
clauses we just looked at referred.
A. Yes.
Q. Itsays:
"This schedule details all the requirements relating
to the EPOS Service which the Contractor shall provide."
A. Yes.
Q. So your evidence is, as I understand it, that -- did you
not consider this to be a document that someone internal
to ICL or a lawyer internal to ICL would need to read to
understand the specification of the product that was
being provided?
41
A. Well, it's quite clear that I never saw that and I can't
comment further.
Q. Is your evidence that the -- well, let me ask it another
way.
What was your understanding of the adequacy of
the -- or let me rephrase, sorry.
What was your understanding of what Fujitsu were
required to provide to Post Office in terms of the
adequacy of the EPOSS product?
A. I don't think I had any particular understanding, I know
what an EPOS product, is, point of sale, basically.
I had assumed there would be a specification for it and
that it would be supplied to that specification.
Q. I take it from your evidence that these types of matters
of whether the product was robust didn't arise in your
management discussions with your reports?
A. No.
MR STEVENS: Sir, that's probably a good time to take the
morning break.
SIR WYN WILLIAMS: Very well. What time shall we resume?
MR STEVENS: If we could say 11.10, please.
SIR WYN WILLIAMS: All right, thank you.
THE WITNESS: Thank you.
(11.00 am)
(A short break)
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A. The point is that there had to be competent legal advice
surrounding it. This was done by Masons and it was done
in accordance with what the technical people were
negotiating on both sides, Post Office and ICL. So what
would happen is there would be a lot of technical
discussions, they would be writing it and Masons would
look at this and turn it into, if necessary, rather more
legal wording. But, at the end of the day, the
substance which is provided in these schedules has to
come from the technical people on both sides, this is
how they worked it out, and there's nothing that I could
personally add to that.
Q. If you look down we see "Scope", and then it sets out
the four service boundaries. Further down, please, it
says, "Constraints", and we've got various paragraphs
there. We see, in the brackets, "R808" referring to the
requirements which we went to earlier?
A. Yeah.
Q. Can we go, I think, it's two pages, I think there may be
a blank page on the next page. Thank you. Just further
down, please. 3.8 says:
"EPOSS shall be a robust" --
A. Ah, well, there you are.
Q. --"POCL Service, including features to", and then it
goes on to set that out.
42
(11.11 am)
MR STEVENS: Good morning, sir, can you still see and hear
me?
SIR WYN WILLIAMS: Yes, thank you.
MR STEVENS: Thank you, I'll carry on. I want to now look
at some specific examples of the management of the
contract. Please could we look at FUJ00080690.
This is a document the Inquiry has seen before,
particularly in Phase 2. The title is "Report on the
EPOSS PinICL Taskforce".
The date in the top, 14 May 2001, but we can see in
the abstract that it is referring to a task that
happened between 19 August and 18 September 1998.
A. Yes.
Q. Firstly, the distribution list: T Austin, M Bennett,
M McDonnell (sic); do you recognise those names?
A. Yes, both of them reported -- well, certainly Martyn
Bennett reported to the Managing Director of Pathway and
he was responsible for, I think, Quality and Customer
Services, from recollection. Terry Austin, I'm not
quite sure whether he reported directly to the Managing
Director or not. I don't really recall McDonnell.
Q. So did you ever have any direct interactions with
Mr Austin or Mr Bennett?
A. No, not that I can recall.
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If we turn the page, please, just for assistance with
dating the document, we can see version 0.1,
18 September '98 and then, on 14 May 2001, raised to
Version 1, "Administrative catch-up".
Could we go, please, to page 4., I'm just going to
go through a few bits of this document. I should ask
first, sorry: before you were sent this document by the
Inquiry, had you seen it before?
No.
So in the "Introduction", it says:
"During the week commencing 17 August the EPOSS/
Counter PinICL Stack Reduction Team, known as the
Taskforce, was established. The objectives, current
workload, composition, outline process and targets were
presenting to the team on Tuesday, the 18th with
a formal start date of Wednesday, 19 August.”
It goes on to describe the presenting the outcome of
the activity and:
identifies factors which prevented the original
target (zero or near to zero residual PinICLs) being
met. During the course of the Taskforce it became clear
that there are significant deficiencies in the EPOSS
product, its code and design, and these are also
presented in this report."
Can we look then at page 7. There's a section on
45
instance, you say it's bad code: I've got no idea if
it's bad or good.
Well, if you don't have technical competence, you
presumably need to rely on technical people?
Well, I would also point out to you that there's second
document which mentioned the CSR+, which you also sent
to me as the additional documents, and I looked at that,
and I can only give you my impressions because I've not
seen either of these documents, but I'm happy to do so:
the first is that was in 1998, before the Codified
Agreement. So water had flowed under the bridge for
almost a year in terms of the development.
And the second point is, if you look at the action
points in the CSR+ document, it talks about this, and --
We'll come to that shortly.
You'll come to that.
Yes.
Okay, that's fine. I'm just saying you have to look at
both of them in context.
I want to look at this one in context at the time that
it was drafted, as you say, in '98?
Yes.
You've read this document, I've taken you to extracts
from it; do you accept that it's describing a serious
issue in the EPOSS code?
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the EPOSS Code. It says:
“It is clear that senior members of the Taskforce
are extremely concerned about the quality of code in the
EPOSS product."
We don't need to read it all but we see the last
paragraph in that section says:
"Lack of code reviews in the development and fix
process has resulted in poor workmanship and bad code."
Then if we could turn to page 17, please. At the
bottom, section 7.3., we see Example 1, and it gives
an extract of some code that's designed to reverse the
sign of a number and is equivalent to the command.
Fortunately, we don't need to concern ourselves with the
code itself, but over the page, it says:
"Whoever wrote this code clearly has no
understanding of elementary mathematics or the most
basic rules of programming."
So you say you hadn't read the document before?
I've never seen it.
Never seen it. Were you made aware of the issues that
this document describes?
No.
Do you accept that these are serious issues being
described by the document?
I'm not technically competent to say. I mean, for
46
It's describing an issue which has got to be corrected
and that's what they're talking about. How serious it
is, I couldn't tell you.
Why do you think that the issue being described in this
document was not raised with you at the time?
It's a technical issue and it's not something that would
have been raised at board level. That's what, I think.
I think this was too detailed for the Board.
Well, this is going, really, isn't it, to the heart of
the product that's being produced by ICL. Do you accept
that?
I can hypothesise many reasons but I'm telling you that
it wasn't, and I can also say the reason that it wasn't,
so far as I understand these things, and I think
Mr Muchow -- I think he's called -- said much the same
thing in his evidence, not at that level of granularity,
and I'd agree with it.
So your evidence is that this type of issue is something
that should be just dealt with at management level and
it shouldn't concern the Board?
It's a technical issue, which should be dealt with at
a technical level and, when we come on to the CSR+
document, which you're coming on to, I think that's
clear to me.
Well, let's look at that now. I think we're talking
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about the same document. It's WITN04600104, please. We
have here a "Schedule of Corrective Actions, [Core
System Release Plus] Development Audit"; is this the
document you were referring to?
Yes, and you can see it's gone up to the Managing
Director, Stares, and Mike Coombs, and they're all down
here: Bennett, Jeram, Austin. Yes.
Did you see this document at the time?
No.
I think you said that you didn't?
No, I didn't.
Can we please turn to page 4. The "Introduction" says:
"This document presents the Corrective Action Plan
that emerged from a post-audit meeting following the
audit of the operation of the CSR+ Development."
Yes.
At page 6, we see the start of various report
observations and then, on the penultimate column, action
points --
Yes.
-- which I think you were referring to earlier?
Yes.
Could we turn, please, to page 9. So we see in the
“Report Observation/Recommendation” it says:
"The audit identified that EPOSS continues to be
49
do with error and printer error handling?
Yes.
"Daily meetings instigated. TPA ..."
Does that refer to Mr Austin?
The answer is it might do or I don't know if he had
a"P" in his name.
"TPA is of the view that while original code had not
been good it would be difficult to justify the case for
rewriting now."
There's then what appears to be copied from an email
from TPA:
"We have not formally closed down the recommendation
that we re-engineer the EPOSS application due to its
inherent instability."
It goes on in the final paragraph on this page:
"We will, of course, continue to monitor the PinICL
stack for the next few months and, if necessary,
re-evaluate this decision."
They say would -- close this issue formally, whoever Jan
is, "Would Jan please close this issue formally".
Then if we turn the page, please, so that was
25 November '99.
Yes.
We're now into December and then into 2000. On 10 May,
it says:
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unstable. PinICL evidence illustrated the numbers of
PinICLs raised since the 1988 Taskforce and the rate of
their being raised.
"The EPOSS Solutions Report made specific
recommendations to consider the redesign and rewrite of
EPOSS, in part or in whole, to address the then known
shortcomings. In light of the continued evidence of
poor product quality these recommendations should be
reconsidered."
Now, before we look at the action points, can I ask
whether you recall any discussion that you were involved
with where management of ICL were considering or raising
rewriting the EPOSS application?
No.
If we look in the "Agreed Action" points, 25/11 --
Hold on, yes.
-- it says, "Work on" -- sorry --
The one above, isn't it?
Yes, "Work on Al298", that's referring to an Acceptance
Incident, isn't it?
Yes, and it's something -- well, I understood this
because I've read the various documents. So far as
I can see, it's something to do with printer error and
printer handling, whatever that is, yeah.
Well, 80 per cent of problems, this was saying, were to
50
"Following response received from MJBC.
Is that Mike Coombs?
Yes, it is Mike Coombs.
“As discussed, this should be closed. Effectively as
a management team we have accepted the ongoing cost of
maintenance rather than the cost of a rewrite. Rewrites
of this product will only be considered if we need to
reopen the code to introduce significant changes in
functionality. We will continue to monitor the code
quality (based on product defects) as we progress the
through the final passes of testing", and it continues
to closing the ticket?
Right. Yes.
Now, there, when it says, "The management team", who is
being referred to there?
Mike Coombs would have been referring to all the people
that you saw on that CSR¢ list, I presume -- the
management attempt within Pathway.
Would you accept that what's being discussed here is
a significant decision as to whether or not to incur the
costs of rewriting the EPOSS application or accept the
costs of maintaining it in the state it's in?
I mean, I've seen this before but -- in some of the
witness statements or the questions. But I don't think
this is the issue. When you look at this, yes, there is
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a cost to maintaining it and, if you like, there's
a penalty in that. But I've seen this many times with
software engineers. It's a bit like lawyers when they
review cases. Everybody has got their own opinion.
Software engineers always say -- some of them do --
"Oh I could rewrite this and it's better". Well, maybe
they can and maybe they can't but, under the
circumstances of this contract, what the management team
decided -- and it's a technical decision, and they're
accepting, in my view, a cost penalty to do this because
it's safer to keep with the EPOSS, which is the thing
that you know, monitor it, and they say it's been
improved since 1998, we've moved on two years now,
nearly. It's a complete step into the unknown, to start
rewriting and if you rewrite a program from scratch,
you've got no idea is it going to work better; is it
going to work worse; will it fit in with everything
else?
From my opinion, it's a technical decision. Let's
suppose that they'd showed this to me or they'd showed
it to the Board. What would have been said was, "Well,
this is a technical decision, what do you advise?", and
that's what they advised. Nobody saw this outside of
them, but that's -- outside of Pathway but I don't think
it makes any difference.
53
Right, and they advised that it was better to go ahead
with the -- not to go ahead with the rewrite but to go
ahead with that. I can't question that decision and
I didn't know about it.
But would you not accept that the Board, in order to
understand whether or not its legal obligations are
being complied with, should be advised of serious
concerns in the product that's being delivered?
Not if the incident was closed.
So is it your evidence that, once the technical people
have decided that this doesn't need to go to the Board,
that's it?
Yes.
The end of it?
That's exactly what I think.
In your view, what role, then, does the Board have in
‘overseeing the quality of the product that is being
produced or delivered to the Post Office in this
circumstance?
Right, the Post -- I'm sorry, not the Post Office. The
Board has to have overall responsibility for seeing that
there are properly qualified people who are doing
defined jobs in connection with the implementation of
the project. That's what I believe is the job. Their
second job is to trust those people and, when
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Well, let's stand back. ICL have contracted with Post
Office to provide a system on certain terms.
Yes.
We saw earlier one of those terms was that it's robust?
Yes, we don't know -- and I insist on this -- we don't
know -- there's not a legal definition of robust that
I'm aware of. Maybe you have one, I don't know. But --
whether it means -- comes, I think, from Latin, robur
strong, or something like that, able to withstand shots.
Well, we'll come back to that point. The point is the
parties agreed that a robust system would be delivered:
is that fair?
It's in the contract.
It's not for the technical people to determine whether
or not the ICL are acting in compliance with legal
obligations to Post Office, is it?
I think that's true but it's the technical people who
would, in the end, have to produce some opinions.
I think Adrian Montague did, at one stage, and said the
system was robust, whatever that means. But the
technical people would have to tell you. I can tell you
what definitions of robust -- I can look it up in the
dictionary but whether it applies to the system —
The technical people can provide you advice on the
application itself.
54
appropriate, through the mechanisms that I talk about in
the second witness statement, to review progress on the
project, like all other projects. The Board is
dependent upon the reporting channels which provide
information to them, which, ultimately, via the QVRs and
all these other things we've described, turns up as the
Financial Officer's report and the Chief Executive's
report, which the Board considers.
I've also not talked about -- and I imagine you'll
come to that -- the particular Japanese oversight of
this but that's a different matter. It's in my witness
statement.
So do I take it from your evidence that you're not
critical -- or, no, let me put it another way.
Are you critical of the management team for not
raising this with the Board?
No.
What steps did you take, or the Board take, after
appointing the management team to monitor Pathway, to
ensure that they were doing a proper job?
I've told you. The reporting structures that I've
described --
Well, if you pause there. If the reporting structures
rely on the management team to flag problems to you, how
did the Board satisfy itself that problems were
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appropriately being flagged?
Because they would question the Chief Executive. The
Chief Executive would, in the initial case, talk to the
COO and, later on, it would have been just the Chief
Executive. He would have had quarterly business reviews
with Pathway -- that's not Board meetings, this is
management meetings -- and those management meetings
would have surfaced to him anything that he thought
appropriate to report in his Chief Executive's report to
the Board.
And, I have to say, that when you talk about the
Board, you must remember that the Board is a majority of
Japanese directors, and I've talked -- I don't know
whether you want to come on to this -- about the flows
of information which actually existed outside of the
Board meeting reports to the Japanese directors in
Japan. And I can assure you, these were very detailed
dealt with by people who were on the ground within
Pathway.
I told you that we had a large team of software
engineers from Japan win the development at that time
that you're talking about.
So that's a flow of information directly to Fujitsu
Limited?
The way it works -- and, if I may, I'd like to expand on
57
and inside it what you get is the answer to all the
possible questions that you could raise, or might raise,
when you go to a Board meeting.
Now, I'm not saying the English directors had this
but I'm saying that the Japanese directors, who were
a majority on the Board, who controlled the Board, had
it, and I can't believe that between all of this, if
there were serious issues that the Japanese were
concerned with, they would not have raised it through
that chain, as opposed to the standard reporting chain
that went up to the Board inside Fujitsu. That's all
Ican say. But I know how detailed it is because I've
lived in Tokyo and I've been a recipient of it.
So that's looking at a reporting line from what's
happening in ICL Pathway through to Fujitsu Limited,
incorporated in Japan?
Precisely. I mean, it was outside -- it's outside the
normal system. Nothing wrong with it. I'm not saying
it shouldn't have happened but I'm just saying it's at
least as important.
I want to ask about -- we've discussed the Board of ICL
Pathway/ICL Plc. In terms of what sat below that -- so
the Management Committee, which we discussed
previously -- are you critical of the management team
that we referred to earlier in relation to the CSR+
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this because it is actually, in my view, really
critical -- the way Fujitsu worked was they had software
engineers embedded in the development, and there were
a large team of them. I can't remember the number.
There was actually a legal adviser from Japan. He was
a chap called Yasui, who I knew very well. He was
an interesting chap, he was qualified in the New York
bar and as an English solicitor. So you also had people
who -- well, there's the Chief Finance Officer, Adachi,
he reported direct to the Chief Finance Officer in
Japan.
All of this stuff is a huge amount of information,
which is what Japanese like, and it all went through
this overseas office, which is about 40 people in Tokyo,
and their job is to sit and collate all this information
and brief each Fujitsu director before that person gets
to the Board meeting. And I know this because when
I was in Tokyo, I was recipient of the same thing.
And I'll just tell you this and then I'll stop, I'm
sorry, but I talk too long -- they give you what's
called a "temochi" -- "te" means hand, "mochi" means
hold, and actually it means two things, something you
hold in your band, a handbook, or something that holds
your hand and looks after you, and what you get is an AS
book, about an inch thick -- it's literally like this --
58
release, are you critical of them for not raising this
at the Management Committee?
You mean an FSMC, a Fujitsu Services Management
Committee?
No, in the start of your evidence, we discussed the
Board and how often that met, and then I understood what
you said was there was a weekly Management Committee
meeting within ICL?
When it was -- and this is before my time, this
weekly -- let me be specific. In the times of ICL,
there was an ICL Management Committee. We talked about
that and I said that, at that time, the Pathway MD, or
whatever, did not attend that Management Committee.
When we are talking about my tenure, there was a weekly
management meeting. The Pathway would not have attended
that meeting, it would have been other people and,
particularly, once Courtley was there, no operational
people would have attended.
Where I could criticise -- and this is hypothetical
because I don't know -- is whether this was ever
surfaced during the preparations for the quarterly
business reviews and that I can't tell you but,
certainly, the quarterly business reviews that fed into
the board didn't contain that. I say maybe they should,
maybe they shouldn't, but I don't know.
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Q. Let's break this down.
Yeah.
Q. Before 2000, so before you're Chief Executive, at ICL
Plc level, are there weekly management meetings?
A. No, these were -- there were operational meetings at the
Group level yes. I suppose you'd call it that. Nobody
really thought about ICL Plc; they just thought about
ICL.
Q. So at the Group level?
At the Group level, yes.
Just to be clear on the timeline, at that point, was the
Managing Director of Pathway attending the group level
management meetings?
No --
How --
>
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-- not so far as I can recall. That's all I can say.
From your recollection, so we're clear on this, how were
issues regarding Pathway raised at the ICL Group level?
They were raised by the Chief Executive -- Keith Todd,
in that case -- reporting to the Board.
Q. So the reporting line would be Managing Director of ICL
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A. Yes.
Q. -- reports to Keith Todd --
A. Yes.
61
MR STEVENS: Let's look at another specific example, then.
It's FUJ00088036. It's another document the Inquiry has
seen.
A. I produced this in my second witness statement, I think.
I think this was more recently provided to you.
A. Yes, I haven't seen it before, I actually asked Morrison
Foerster to give me some more information on this and
that's where I saw it. I didn't see it -- I haven't
2
seen it before.
Didn't see it at the time?
No, no. No.
So it's 2 August 2002 is the date.
Yes.
At this point, you're Chief Executive?
Yes.
If we look at the originator department and the
contributors, do you recall working with any of those
people?
A. They frankly -- let's have a look. No, none of --
I don't recall knowing any of those people.
Q. This document describes -- let's look at page 9, please.
It says, "SFS", which I --
A. I don't know who they are.
The Security Functional Specification.
A. Okay.
pPrPororyp
2
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Q. -- and then it's Keith Todd's responsibility to consider
whether to pass that on to the Management Committee?
A. That's correct, yes.
Q. Atthat stage --
SIR WYN WILLIAMS: Excuse me, rather than deal with this in
the abstract, can we just go back to this particular
issue relating to EPOSS, to which the Inquiry has
devoted a significant amount of time.
Is it your view, Mr Christou, that the issues
relating to EPOSS were appropriately -- in inverted
commas -- "managed" by the team that took the decision
or is it your evidence that the team that took the
decision should have reported it upwards to someone?
A. No, my evidence and my belief is that they took the
appropriate action, and that was the end of it.
‘SIR WYN WILLIAMS: Right. You would not have expected them
to have gone any higher than they did, in effect?
A. No, I wouldn't.
SIR WYN WILLIAMS: Right. Okay. I understand. Because it
seems to me, with respect to you both, that, whether or
not something goes higher, must relate to the specific
topic under consideration, rather than a general
discussion, if I can put it in that way.
MR STEVENS: Yes, sir, thank you.
A. Yes.
62
Q. It describes there a form of remote administration,
a tool called Tivoli Remote Console?
A. Yeah.
Q. Itgoes on to say that:
"This has led over time to BOC [Belfast Operations
Centre] personnel relying heavily on the use of
unauthorised tools (predominantly Rclient) to remotely
administer the live estate. Its use is fundamental for
the checking of errors. The tool does not however
record individual user access to systems but simply
record events on the remote box that Administrator
access has been used. No other information is provided
including success/fail so it is not possible to simply
audit failures. The use of such technique puts Pathway
in contravention of such contractual undertakings to the
Post Office."
Were you made aware of that the concerns raised in
that in particular, that Pathway was in contravention of
contractual undertakings to the Post Office?
A. No, I've never seen this document.
Q. Is this a type of document, or maybe not -- let me
rephrase that. The issue that's being described, in
particular "the use of such technique puts Pathway in
contravention of contractual undertakings to the Post
Office", is that a type of issue that you would have
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expected to be raised to you as Chief Executive?
It depends whether the Post Office had made any -- if
the Post Office had made a formal complaint, a breach of
contract notice, for instance, then I would have known
about it.
I read this in conjunction with another document,
which you showed me, which you may come to later, which
is Gareth Jenkins writing earlier about the Secure:
Shell, whatever it is, the SSH, which is designed to, as
it says here, provide an acceptable and agreed level,
which I presume must be agreed with the Post Office, of
secure access. So reading this, what I see is, well,
there was a problem, maybe it was a breach of contract,
maybe it wasn't, I don't know. The Post Office appear
to have known about it because it says, "acceptable and
agreed”, so it must be agreed with somebody or other,
and it was remedied with this Secure Shell. Whether
it's a correct remedy, again, I'm not competent to say,
but that's what it looks like to me.
Well, let's look in more detail at the problem. It's
page 15, please, and it describes "Third line and
operational support"?
Yes.
It describes controls, so:
“Individuals involved in the support process undergo
65
specialists who are very carefully vetted, who are
system administrators, but there has to be somebody who
can be a system administrator and there aren't very many
of them.
Would you accept that what this is saying is that some
people have unaudited, privileged access --
Not --
-- with system administration access to all systems --
What I'd accept is --
-- including Post Office Counters --
I'm sorry, I beg your pardon. I beg your pardon.
What I would accept is that, at that time, there was
an issue and they improved the security systems, on the
advice of Gareth Jenkins on his previous document. And,
don't forget, we've only just, at this stage, got to
complete rollout.
So here, where we have an issue that's being raised that
is said by the technicians to be -- it's warning of
a breach of contractual obligations, your evidence is
this didn't -- you're not critical of it not being
raised with you?
If there were no solution to it, or if there had been
a formal complaint by the Post Office, I would then have
been critical because, if there had been a formal
complaint, then that was something that definitely
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more frequent security vetting checks."
Yes.
“Other than the above controls are vested in manual
procedures, requiring managerial sign-off controlling
access to post office counters where update of data is
required. Otherwise, third line support has:
“Unrestricted and unaudited privileged access
(systems admin) to all systems including post office
counter PCs ..."
The risks are highlighted further down -- sorry, if
you stay there, please -- sorry. It says:
"This exposes Fujitsu Services/Pathway to the
following potential risks:
"Opportunity for financial fraud;
“Operational risk -- errors as a result of manual
actions causing loss of service to outlets;
“Infringements of the Data Protection Act."
I mean, this, is, would you accept, a very
significant problem going to the heart of ICL's
contractual obligations?
No, I think all he's saying is we need to beef up our
security systems and we're doing it. That's the way
I read this. But, as I say, I'd never seen the document
but this is how I read it: yes, there is a risk. I'm
sure you understand that third line support are a few
66
should be looked at. What I'm seeing here is
a technical person who is identifying improvements in
the security which will prevent some issues, and every
contract for the development of software is always
trying to improve its security. We know nowadays that
the most important thing for fixes -- you know if you've
got your PC or your smart phone, every so often you get
a security update to protect it from outside
interference, and this is a more technical and more
sophisticated way of doing things with this system.
I don't -- I'm not critical of them. I would be
critical if the Post Office had sent a letter, that's
a different matter, and maybe that should have been
surfaced. But I haven't seen a letter.
Why is it relevant or why should it come to you if the
Post Office raise it?
If the Post Office raised a formal breach of contract,
then that would become a matter that, certainly, we'd be
looking at because the first thing would be doing would
be going and talking to Stuart Sweetman to find out what
it was about.
As part of the responsibility of the Chief Executive in
respect of the lawfulness of the company’s operations,
do you not accept that, actually, where such a serious
contractual issue is raised, that should come to you at
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the highest level?
No, I don't, because I think the problem has been solved
at a technical level.
Could we move on to Horizon Online, please. It's
FUJ00095628. This is an email to which you referred
earlier.
Oh, yes, I know about this.
If we can go to the second page, please. So it's
an email from Duncan Tait, you're not in copy. I assume
you wouldn't have seen this at the time?
No, no. Not at all. This is an issue for Duncan Tait,
not for me.
It refers to meetings between Post Office and Fujitsu --
Mm.
-- and it talks about:
"Their confidence has been knocked due to:
[Firstly] Ongoing issues with Oracle stability
impacting HNG-x stability ...
"[2] The data centre outage
"[3] An outage caused by ‘Fujitsu operator error’
last week which caused a 45-minute loss of service."
We then get some requests from Post Office: (1) is
to look at P&L for the account to make sure it's
sustainable and asking for an open book arrangement; (2)
is for an independent review; and then (3):
69
POL00028838.
Yes.
It's a document well known to this Inquiry. Firstly,
can I ask when you first saw this document?
When you sent it to me, which would have been some time
in May.
So looking at the attendance list --
Right, let's have a look.
It's not dated but the Inquiry understands it's in
October 2010. Were any of those people in the
attendance list reporting directly or indirectly to you
at that stage?
No. Could I ask one question about this, please? When
I read it, I wasn't clear who originated the document.
It looked to me like the Post Office did, but they talk
about "we", and so on. Can you tell me that or?
Well, I'll ask you questions about if you saw it or if
you didn't and --
Oh, right, okay, but I never saw it, and the only name
I know, because of all the fuss about it, is Gareth
Jenkins. None of these reported to me.
Do you know Gareth Jenkins when you were working at
Fujitsu?
Not that I can recollect. He wouldn't be somebody that
I would have had direct contact with.
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"Finally, he wants Dave Smith to have some dialogue
with Richard C ..."
I assume that refers to you?
Yes, it does, yes.
"... So they can test the Japanese Board's commitment to
the account and programme ..."
Mm.
Firstly, can you recall whether you were aware of the
issues described in this email?
No, the answer is I wasn't and I've never seen the
email. I mean, it would be for Duncan to talk to you
about that.
So you're saying then you can't recall Duncan Tait
passing on or discussing these issues with you?
No, well, let me be clear about this. The only one
I think he would have passed on to me was the dialogue
with Dave Smith about the Japanese Board. Remember at
this time I was living in Tokyo and I was responsible
for the global business group as a whole. I don't
remember whether we ever had that call, that's all I can
tell you. But if I had have done, I mean, what the
purpose was, to talk about the Japanese Board's
commitment; it wasn't about things like an Oracle
outage, or whatever it was. That's all I can say.
I want to look at another document now, please. It's
70
Now, this document describes what we now know as the
receipts and payments mismatch bug.
Yes.
Were you ever given any information on the bug described
in this document that you've now read?
No.
That document can come down. Thank you.
Just before this -- that was 2010 -- in May 2009,
Computer Weekly ran an article on the Post Office
prosecuting subpostmasters and allegations as to the
adequacy of the Horizon data to support those
prosecutions were raised. Were you aware of that
Computer Weekly article at the time?
No, I wasn't.
I want to look now, then, at prosecutions, please. Can
we bring up your second witness statement, page 21, it's
paragraph 101. You say:
“As already stated in my first witness statement,
I had no knowledge of this issue, and I do not recall it
being raised at any Board meeting when I was present,
(see paragraphs 75 onwards)."
Yes.
If we just scroll down slightly, please -- thank you --
you say:
“I would now, however, like to comment more
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specifically on this point, in the light of further
documents not known to me at the relevant time, which
have since been provided to me by Morrison Foerster (at
my request) for the purposes of completing this
statement."
So everything that follows, where, for example, you
say, "My understanding is that the requirement in the
Codified Agreement”, that's your understanding today?
Now, yes. That's correct.
Not at the time?
Not at the time.
Could we please go to FUJ00000071, again, and could we
turn to page 196, please. We referred to this earlier,
it's schedule A15, setting out requirements, and we see
a number there of various requirements?
Yes, yes.
If we turn, please, to -- apologies.
If we can go, please, to 291.
291.
Page 291, please. Thank you. Schedule A16 is the
"Solutions". So these are the response, in effect, from
ICL Pathway. Could we look, please, at page 363. If we
go down to that, please.
I think I may have an incorrect reference here,
sorry. If we can go up, please, to reference 393,
73
So this is a "Service Description for Implementation and
maintenance of security policy and procedures" dated --
Yes.
-- 6 January 2003.
Yes.
In your statement, you say that, to the best of your
belief, this document contained the first contractual
requirement on Fujitsu to provide witness evidence in
litigation.
Yes.
Again, I understand that's your knowledge now but not at
the time?
It's my knowledge now. Can I just amplify that.
I never regard PACE as necessarily requiring witness.
It required a certification with the potentiality for
a witness but, when I look at this, it seems to me
different to PACE.
Well, let's -- at the time, did you have any awareness
of PACE certification --
No, no. At the time, I didn't know about PACE --
I mean, I've said that in my witness statement --
because I didn't read that schedule.
Can we turn, please, to page 17?
Yeah, the litigation.
If we can have "Litigation Support", please. So we see
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I think.
(Sotto voce) English and Welsh.
Just bear with me, I will just find that reference.
393, please. Page 393, that's it. If you can go up,
I got my requirements and page numbers mixed up.
Ah, here we are, yes.
If we could go up, please, so we can see the start of
the reference. You see there reference 829, and this
refers to Pathway. It says:
"Pathway confirms it will ensure that all relevant
information produced at the request of POCL [Post Office
Counters Limited] shall be evidentially admissible and
capable of certification in accordance with the Police
and Criminal Evidence Act 1984 and the Police and
Criminal Evidence (Northern Ireland) Order 1989 ..
Yes.
It goes on to say about data volumes.
When you were involved in the tendering process,
would you have been involved in dealing with this
response or --
I've got no idea whether it was even in the tendering.
I mean, this is from the Codified Agreement and I never
read this.
Could we look, please, at FUJ00001743.
Oh, yes.
74
here that it refers to Post Office submitting Audit
Record Queries or Old Format Queries, essentially
a request for ARQ data, as we know it?
Yes.
It says (a), to present the record of transactions but:
"b) subject to the limits set out below:
"(i) analyse:
"the appropriate Fujitsu Services’ Helpdesk records
for date range ...
"branch non-polling reports for the branch in
question; and
“fault logs for the devices from which the records
of transactions were obtained ..."
Yes.
Then, if we go down -- thank you -- we see:
"... request and allow the relevant employees of
Fujitsu Services to prepare witness statements of fact
in relation to that query ..."
Yes.
Now, this contractual agreement for Fujitsu employees to
prepare witness evidence of fact, as a contractual
service being offered by ICL, or Fujitsu Services
Limited, do you consider that that should have gone to
the Board to determine whether it was something that ICL
or Fujitsu Services Limited wanted to offer or should
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agree to provide?
I think this is a -- I think this is the most serious
question of all and it comes back to some of the things
that I said in my witness statement. There was no
requirement for this particular document to be approved
by the Board. If you look at the beginnings, I think it
goes as far as Martyn Bennett. When one looks at it by
hindsight -- and I'm not saying this to mitigate what
I think -- and I've said before -- is a miscarriage of
justice, it was not raised to the Board.
Should it have been raised to the Board? I think
the problem with this document is that the requirement
for witness statements shouldn't have been dealt with by
Security personnel and, in the midst of a security
document, should it have been raised to the Board? It
wasn't.
What I say in hindsight is I wish it had but that's
hindsight. There are many issues you could have raised
to the Board but it chose not to do so.
Would you accept that this contractual service that's
being agreed in this document is outside of the normal
course of business for Fujitsu?
No, I wouldn't. No, I think that's not -- well, it's
not our business to provide witnesses, certainly we
don't provide, or we didn't, in my day, provide expert
77
something that we would have provided to a customer. We
would have said, "Go and get an expert and get them to
do it".
So I don't think this is out of the ordinary course
of business but, if you went beyond a statement of fact,
here's the document, this is what I took off, and you
can examine it with all the bits and pieces that are in
the earlier section", but that's fact.
Expert opinion, no. That, definitely not. We're
not in that business. That's what I think.
Well, when it says, looking here, "Subject to the limits
below, analyse’, it's analysing "fault logs for the
devices from which the records of transactions were
obtained in order to check the records of transactions
extracted by that query” —-
In order to check the integrity of records.
Integrity of records. Where there's analysis of fault
logs, what's your view on that --
Okay, I looked at this, and the fact that the fault log
is there is a statement of fact and, when you look at
it, you see that there are various faults, so you have
to describe them. I think it's important to talk about
checking the integrity of the records. I've -- you said
this elsewhere in my statement but, in my view,
integrity means uncorrupted, whole and complete, but it
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witnesses. That's absolutely true. When I looked at
this, one of the problems, as I understand it, is, of
course, that PACE was repealed in -- Section 69 was
repealed ~
I'll come back to the question, sorry.
Yes.
Is what is being agreed here, the provision of witness
statements by Fujitsu employees, outside of the normal
course of Fujitsu's business at that time?
If it was only a witness statement of fact, that this is
a document that we've got off the computer, I wouldn't
have thought so. I mean, I'm sure that that was
something that happened in other contracts. I don't
know but, as long as it was a statement of fact,
I wouldn't particularly have had a problem with it, you
know, “This is the document, this what I took off, there
it is. Make of it what you will", as long as it was
fact.
So is it your evidence that, if it's a witness statement
of fact, you didn't think it needed to come to the
board?
No, I wouldn't. If it was an expert -- let me be clear
about this: if somebody was saying, "We want a Fujitsu
witness to be an expert witness, speaking about all
sorts of things about the system", that was not
78
doesn't mean accurate, which is what we're coming down
to: the question of whether there were discrepancies in
the cash account.
And I think this is the word that was used,
integrity, earlier on when they were in these this other
systems specifications, when they were talking about
security. It's all about security, not tampered with.
I understand you've listened to some of the evidence of
the Inquiry?
Some of them here, not all, by any means, but I tried to
prepare myself as best I could.
Have you heard, for example, of the Clarke Advice of the
15 July 2013 --
No, I'm sorry, I haven't. No.
-- referring to Post Office's use of Gareth Jenkins as
an expert witness?
Well, that surprises me and it's not something that
I would have expected Fujitsu to do.
If a Fujitsu employee was being used to provide expert
evidence, my understanding is you think that something
like that should have gone to the Board?
Definitely, and I would have made sure in those -- or
me, but what I would expect is that that expert witness
would have been properly advised by an independent
solicitor.
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Q. Can you explain why, in this case or in this time, the
use of Fujitsu witnesses, such as Gareth Jenkins, wasn't
raised at a Board level?
A. As I've said, because -- when you say “at this time" do
you mean 2013?
Q. No, I'm so sorry, at the time of this document, 20 --
A. Right, what I'm saying is that I don't think that
witness statements of fact would have been necessary and
I don't think -- I'm not critical of that. I'm very
critical of the use of a Fujitsu employee as an expert
witness if they're not properly advised by
an independent legal counsel.
Q. Can you offer a view on why that latter issue didn't
come to the Board of Fujitsu?
A. Well, I don't know when it started, so I can't tell you.
But I suspect it's more ignorance than anything else.
I doubt that the Security people that you're talking
here really understood the difference. Their mind is
always on integrity, untampered with, not corrupted;
it's not about being an expert witness.
Q. Could we turn the page, please. It referred to
limits --
A. Yes.
Q. We see at (iv) and (v):
“Fujitsu Services’ obligations ... in (i) and (ii)
81
SIR WYN WILLIAMS: But I think you do agree with Mr Stevens
that such activity, if it were to be approved, should
have been approved by the Board?
A. Ido, yes.
SIR WYN WILLIAMS: Fine. Thank you.
MR STEVENS: The matters to which the Chair was just
referring, who within your reporting line would have
been responsible for oversight of this Litigation
Support?
A. Martyn Bennett, I think, is the correct one. I mean,
he's a long way down because -- I don't know whether he
was still there in that time, 2005.
Q. In 2003, is the reporting line from either Martyn
Bennett or his replacement through David Courtley?
A. Yes, yes. Through the Managing Director of Pathway to
Courtley to me. Yes.
Q. Could we, please, look at FUJ00003534, and this is my
last topic.
A. Yeah.
Q. These are actually draft minutes but I want to take you
to a part of them. It's on 20 August 2002, a meeting of
the FSMC. Could we look at page 14, please. If we
could go down to "Relationship with the UK Government":
"Mr Christou reported that the Government was our
biggest customer and it was essential that we had a good
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above shall be limited, in aggregate, to dealing with
a maximum of 150 (in aggregate) Record Queries ..."
A. Yes.
Q. The Inquiry has heard evidence about Fujitsu's
remuneration in respect of witness evidence produced.
Did you have any knowledge of that remuneration?
A. No.
Q. That document can come down. Thank you.
SIR WYN WILLIAMS: Well, just before we do, Mr Stevens,
I just want to be clear, Mr Christou, one can haggle
about the interpretation of contractual clauses, and
I would just like your help, as a very senior person in
Fujitsu, as to two matters.
First of all, in your opinion -- and I stress "in
your opinion" -- does the clause that we just looked at
oblige Fujitsu to provide a witness to give opinion
evidence?
A. No.
SIR WYN WILLIAMS: Right. So have you got any idea how it
came to be, if it is the case, that, from approximately
the mid-2000s, that is around 2004/2005, a Fujitsu
employee -- and we all know who it is, Mr Jenkins -- was
making witness statements which included opinion
evidence?
A. I do not know, sir. I do not know.
82
relationship with them. Renegotiating Libra had been
very stressful
Just to pause there, that's nothing to do with the
Post Office, I understand, Libra?
A. No, this isn't. Nothing to do with the Post Office at
all.
Q. "... and all the Permanent Secretaries were aware of the
negotiation that had taken place. During the last year
we had, again, been the topic of conversation as the
Pathway and HMCE contracts were being renegotiated.
"While these negotiations were ongoing it was
important not to be too friendly or else we risked
weakening our position. However, we were now able to
build on relationships. Mr Christou had visited all the
permanent secretaries and he had also joined them on
a training weekend. Consequently, although there was
room for improvement, we are on good terms with them and
they are, by and large, all satisfied with the service
Fujitsu Services provide.”
A. Yes.
Q. When you say “all the Permanent Secretaries", there is
that every Permanent Secretary to each Government
department or just those to which Fujitsu had contracted
with?
A. No, I mean the ones that we were dealing with, yes.
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Q. You go on to say:
"Mr Christou added that the relationship with the
DTI was good. He was having talks with representatives,
both in his capacity as a member of various DTI
committees, and also as a service provider."
A. Yes.
Q. How often did you meet with representatives of the
Department for Trade and Industry?
A. Actually, quite often because there were various fora,
you know, they used to get all the IT people together
for instance, and we met on numerous occasions. I had
the Minister's name -- Patricia something, in those
days? I can't remember the last name but I used to
spent quite a lot of time with her.
Q. Patricia Hewitt.
A. That's right, Patricia Hewitt, and there was a Permanent
Secretary. I'm afraid I can't remember the name. But
we used to visit them quite regularly because we had
Elgar with them, which was a very large project.
Q. Atany point when you met with representatives of DTI,
did you discuss the actual adequacy of the Horizon IT
System?
A. No, it was never the topic of discussion. We were
always talking about our contract with them.
Q. From 2003 onwards, did you ever meet with
85
shorthand-writer whether she'd like a break before
Ms Page asks questions, or whether she would prefer to
have a maximum of ten minutes and then have a lunch
break, in effect.
MR STEVENS: We're fine to continue, sir.
SIR WYN WILLIAMS: Fine. Then sorry to impose a ten-minute
time limit on you, Ms Page, but I think that's
reasonably fair in the circumstances.
MS PAGE: No difficulty at all, sir. Thank you very much.
Questioned by MS PAGE
MS PAGE: I want to ask you a few questions, please, about
whistleblowing.
The Bates litigation established as fact that there
were bugs, errors and defects in the Horizon system
which could and did cause errors in Post Office branch
accounts. Now, you don't appear to accept that that
means that Fujitsu failed to deliver a product to Post
Office, an accounting system, that was fit for purpose
but, nevertheless, there might be those who do. Do you
understand what I'm saying there?
A. Iunderstand where you're coming from. I mean, what I'm
saying is not to mitigate. I've said this before but
I'll say it again. I do not mitigate the seriousness of
the miscarriage of justice; that's the first point. But
the issue to me is, first of all, fitness for purpose
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representatives of the Shareholder Executive?
A. Could you be more -- the Shareholder?
Q. Sorry, the Shareholder Executive, a Government agency
that managed the Government shareholding interest in
companies, including Post Office Limited?
A. No, I didn't know anything about that. No.
Q. Standing back, having examined the documents that you've
seen today, do you consider there to have been, in your
view, any relevant management failings within Fujitsu
that was relevant to the prosecution of subpostmasters?
A. I think the issue comes down to this question of -- I'm
sorry to keep on mentioning Gareth Jenkins -- how he
came to be an expert witness and I can't answer that
question but I think that's the nub of it.
I've always felt that it was the processes of
information flow that led to the prosecutions that were
the cause to of the problem, rather than, if you like,
bugs in the system itself but I can't answer that.
MR STEVENS: Sir, those are all the questions I have.
Before I turn to see if there are any from Core
Participants, do you have any questions?
SIR WYN WILLIAMS: No, I'm fine, thank you.
MR STEVENS: Ms Page, I think that's it. Five or ten
minutes’ worth of questions.
SIR WYN WILLIAMS: Well, then, can we ask the
86
was never part of the Codified Agreement; it was
specifically excluded. What we did was to agree
a specification, agree acceptance tests with the Post
Office, and that was the basis of the contract.
We accept -- I mean, I accept now, having heard
everything in the appeals against the cases, there were
bugs. I don't believe that it was the bugs that caused
the issue. The issue is that these discrepancies
weren't properly presented in evidence. That's what,
I think. Why it happened I'm not competent to say but
that's my view.
Q. Allright, well, what I want to ask you about is
Mr David McDonnell, who gave evidence to this Inquiry,
about the shockingly bad development of the EPOSS code
and Mr Stevens this morning has taken you to the
documents dealing with how that was managed within
Pathway, both in 1998 and in 2000.
Now, I don't need to go back over what you've said
already. You don't criticise the way that, what you
say, the technical issue was managed. Nevertheless, at
the time and subsequently, Mr McDonnell was deeply
critical of the way that that was managed and he gave
evidence about the fact that he was sidelined, as
a result, moved into a different role. So what I want
to ask you about is what process was there for him to
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blow the whistle at the time? What process was there
for him to take his concerns higher when the management
of Pathway refused to accept what he was saying?
Well, in those days, there was certainly no
whistleblowing procedure. That's the first thing, and
I don't think people thought about it in those days.
What I will say to you is that I never shut the door
to my office. If he had felt sufficiently strongly, he
could have come and seen me. That's all I can say.
I don't actually know him but, if somebody had come and
seen me, then I would have investigated, it might not
have meant a different decision, but he didn't. So
that's all I can tell you.
A different area but still on whistleblowing. The
Inquiry has now seen ample evidence that Fujitsu support
teams were effectively able to tamper with branch
accounts, without the subpostmaster knowing, and that
wasn't for a short period, that was over many, many
years. So, in effect, the security designs put in place
just didn't stand up to the reality test: the support
teams were given privileged access on what we've seen
revved to as a needs-must basis and that continued not
only thorough your time, but also for many years
subsequently, really all the way through until the Group
Litigation.
89
I'm not mitigating that there is a gross miscarriage of
justice and, if you think I don't feel for the
postmasters and the subpostmasters, you're wrong, I do
feel. And I also feel aggrieved that what I felt was
a good system has been put into such disrepute. But I'm
not responsible for it and I've told you before —-
sorry, perhaps I shouldn't say it like this, perhaps
with more respect -- I've said before that the real
issue is the way the prosecutions were handled and the
flows of information.
Why there were no whistleblowers and what they would
have told me if there were any, I don't know, and I'm
sorry about that but I can't help you further.
Let me just ask you this final question: when concerns
first started to be raised about the possibility that
Fujitsu could insert transactions -- if you don't like
"tamper", that's what they were doing -- could insert
transactions into branch accounts without postmasters
knowing, when those concerns first started to be raised,
why was there no concerted effort by Fujitsu management
to find out the truth?
I don't know when they were raised and you're assuming
that there was none, and you're insisting on the word
“tampered”, so I'm afraid my answer is I don't know.
25 MSPAGE: Thank you.
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It was really only the testimony of a Panorama
whistleblower, who then became a whistleblower in the
Bates litigation, Mr Richard Roll, that actually started
the process of finding out the truth. Obviously, in all
of that time, there were many employees within the
Fujitsu support team who knew what was going on and knew
about the ability to tamper with branch accounts and,
indeed, there were many concerns raised from the
mid-2000s onwards about it.
So, again, why were there no Fujitsu whistleblowers:
what happened: why did nobody come forward?
Well, I'll make two points to you. First of all,
I don't like the word "tamper", that's a pejorative
term. Secondly, my understanding is -- and I knew
nothing about this particularly at the time -- that
these alterations were made in conjunction with the Post
Office, in order to correct various issues. That's what
I saw coming out of the evidence.
Why were there no whistleblowers coming forward?
You'd have to ask the potential whistleblowers in
Fujitsu. All I'm saying to you is that nobody came to
me and blew any whistles.
You don't take any responsibility?
No, I'm not --
So you don't --
90
Those are my questions, sir.
SIR WYN WILLIAMS: = Thank you, Ms Page.
Is that it, Mr Stevens?
MR STEVENS: Yes, sir, that's it.
Yes, that's it from the Core Participants and
Mr Christou's evidence.
SIR WYN WILLIAMS: Yes.
So Mr Christou, thank you very much for making two
statements -- written statements, that is -- and for
giving evidence to the Inquiry this morning. I'm
grateful to you.
I think we'll now adjourn, shall we, and take our
lunch break so what time shall we resume?
MR STEVENS: 1.30, please, sir.
SIR WYN WILLIAMS: Fine, see you all then at 1.30.
(12.30 pm)
(The Short Adjournment)
(1.30 pm)
MR BLAKE: Good afternoon, sir, can you see and hear me?
SIR WYN WILLIAMS: I can, thank you.
MR BLAKE: I Sir, this afternoon we're going to hear from
Mr Tait.
SIR WYN WILLIAMS: Yes.
MR BLAKE: As we are starting at 1.30 we are likely to have
two afternoon breaks today.
92
(23) Pages 89 - 92
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SIR WYN WILLIAMS: Yes, certainly.
MR BLAKE: Thank you very much. Can you give your full name
o>
>
pProProp
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DUNCAN ANDREW TAIT (sworn)
Questioned by MR BLAKE
please?
My name is Duncan Andrew Tait.
Mr Tait, you should have in front of you a witness
statement dated 21 May 2024; is that correct?
That's correct.
Can I please ask you to turn to page 67 and confirm that
that is your signature.
Itis.
Thank you. Is that statement true to the best of your
knowledge and belief?
Itis.
Thank you, That statement has a Unique Reference Number
of WITN03570100 and that will be uploaded onto the
Inquiry's website. Just to begin, by way of a little
bit of background, you started your career at BAE
Systems in around 1985; is that correct?
That is true.
You worked for a number of different firms, largely in
IT related roles?
That is true.
You joined Fujitsu in 2009?
93,
Thank you. From April, you were CEO for UK & Ireland.
Then, over time, you took more and more countries,
I think, in 2014, you were CEO for Europe, Middle East,
India and Africa --
That's right.
-- including the UK at that time?
Including the UK.
2015, you were appointed to the Board?
Of Fujitsu in Japan, yes.
And 2016, you became responsible for the Americas. Is
that in addition to EMEIA and --
That is in addition to those.
So your portfolio expanded and expanded as the years
went by?
It did.
When did you leave Fujitsu?
I left at the end of July 2019.
Thank you. During your time at Fujitsu, how significant
was the Post Office as a customer?
Well, Fujitsu was one -- sorry, Post Office was one of
the larger clients within the Private Sector Division,
and formed a reasonable part of Fujitsu, UK & Ireland.
Obviously, the further you go up the company then it
becomes a smaller part but nonetheless important.
Thank you. Perhaps we could start with a presentation
95
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\ did.
I think you came in straight at Managing Director
level --
\ did.
-- in what was then the Private Sector Division?
Yeah.
In very simple terms, where did that division fall
within the overall hierarchy of Fujitsu?
So the Private Sector Division reported directly to the
UK & Ireland's CEO, and there were a number of other
divisions, there was a Government Business Division, and
then I think there were two or three divisions that
delivered services into those so, for instance, there
was a CORE Division and an Applications Division, where
the bulk of the people in the business worked.
I think you've said in your witness statement that the
Post Office business fell within the Private Sector
Division because the intention was for it to go private?
Yes, that was my understanding when I joined.
Thank you. When you were Managing Director, you
reported directly to the CEO, who was, at that time,
Roger Gilbert; is that right?
That's true.
In 2011, you became CEO?
I did, in April 2011.
94
by your predecessor as CEO, if we could turn to
FUJ00116969. It is a business update that was produced
by Roger Gilbert. You would have been Managing Director
at the time that this was produced.
Okay.
Do you recall this document from your time at Fujitsu?
I don't recall it precisely but some of the things -- in
reading it prior to arriving here today, some of the
concepts in there I'm familiar with.
If we scroll down, please, and over to page 3. Thank
you very much. One of the objectives in 2011 seems to
have been to increase the number of 30 million plus
accounts, and we see there a chart separating out
private sector and Government. We see "RMG", would that.
be the Royal Mail Group?
Yes.
Would the Post Office fall within that category?
It would.
So am I right to understand from this chart that, at
least as at 2011, the Royal Mail Group was one of the
biggest clients, one of the largest in terms of the
amount of money?
Yes, it would. This was a -- if I understand the chart
correctly, this is accounts with revenues of more than
£30 million per annum.
96
(24) Pages 93 - 96
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There are a relatively small number, we see it separated
it by private sector and Government, so in the private
sector, there aren't that many?
Yes.
They're not in alphabetical order. Are we to read into
that that the Royal Mail Group was the most significant
in terms of income, or is there some other reason, do
you think?
I don't know the reason for choosing the order of those
accounts, there would also have been one with Thompson
Reuters there, which also would have been very
significant at the time but I don't understand the order
of those.
Thank you. Who were your main points of contact at the
Post Office, both when you were Managing Director and
then, subsequently, as CEO?
When I first joined, my main point of contact would have
been the Chief Operating Officer, who was Mr Mike Young.
Then, when I was promoted to become CEO of Fujitsu, UK &
Ireland then there would have been number of people --
I think Lesley Sewell at some point, there would have
been Ms Vennells -- and, for a period of time after
that, there would also have been -- Mike Young would
still have been in the company for a period of time
after I became CEO.
97
Executive Committee, and I would imagine a member of the
legal community as well.
Thank you. So likely a General Counsel or equivalent
would also attend those?
I think so.
Thank you. Can we please turn to your witness statement
and paragraph 73, it's on page 24. There's no need for
you to turn to it; it should come up on the screen.
It's WITNO3570100. Thank you. It's page 24 that I'd
like to start with. I'm just going to take you to two
passages from your witness statement. The first is
paragraph 73. You say there:
"I recall being made aware of subpostmasters' claims
regarding Horizon's lack of data integrity shortly after
joining Fujitsu. My understanding at the time was that
these claims were unfounded, that Post Office had been
involved in some proceedings against subpostmasters, and
that Fujitsu had assisted Post Office with these
proceedings on occasion. I do not know the details of
[those] proceedings."
Paragraph 75, please, which is on page 27. If we
scroll down, just to the next paragraph, please -- thank
you -- you say there:
"While I became aware of subpostmasters' claims
shortly after joining Fujitsu, I did not understand that
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So was your liaison/your relationship when you were CEO,
largely with your equivalent CEO or perhaps COO?
I would say -- it wasn't that rigid from a hierarchical
perspective. I would have spoken to the CEO and to
other members of the Executive Committee.
Thank you. That document can come down. Can you assist
us with the committees within Fujitsu that might look
into risks arising from your relationship with the Post
Office? What were the key committees that you would be
involved in?
In terms of formal statutory committees, there was
a corporate governance committee that I recall. There
was also an Audit and Risk Committee. Then there were
a number -- if you think about those being statutory
committees, those were the two.
Thank you. Would the Post Office be a standing item on
those committees or would they just be raised on an ad
hoc basis?
Well, the process of managing risk in the company was.
both top-down and bottom-up, so wherever there was risk,
you would have expected those to be reflected on the
risk registers.
Who typically sat on those committees?
It would have been the chairman of whichever statutory
entity it was and key members of probably of the
98
Fujitsu was assisting Post Office in proceedings against
its subpostmasters on a regular basis until later.
Indeed, I do not recall being aware that Post Office was
being assisted by Fujitsu until at a meeting Ms Vennells.
asked me to thank my team for its assistance with the
prosecutions. I did not reveal that I was not aware of
this assistance. I do not recall the date of this
meeting.”
You started in 2009, you left in 2019.
Yes.
When, approximately, during that period did you become
aware, first of all, that any prosecutions were taking
place that Fujitsu had a role in?
I think the word "prosecutions" is very specific, as
I now understand, and I think probably around the time
Ms Vennells mentioned it to me, at the time you just
referenced a few moments ago. However, there is
a document from 2009 when I first joined, which I think
would also be quite useful to see.
Yes. Well, we'll go to that document and I'm going to
take you chronologically.
Okay.
But you say here, "! don't recall the date of the
meeting". So it seems as though it certainly became
prominent to you at a meeting with Ms Vennells, and
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really my question is: when, approximately, would that
meeting have taken place?
I can't recall when that meeting -- I mean, clearly it
must have been after Ms Vennells was appointed CEO of
the Post Office but I don't recall exactly when that
meeting was.
Very approximate? We've got a 10-year period to cover.
It must have been around 2012 or '13.
Thank you. Do you recall when, if at all, the issue of
prosecutions was raised at Board level within your firm?
I'm not sure it was.
Not even until 2019?
Do you mean Fujitsu Board in -- I'm know I'm not
supposed to ask --
You assist me. At any level of the various Boards that
we've already heard about, do you think that
prosecutions were raised?
I don't think so.
Let's go chronologically and we're going to start with
your first few months at Fujitsu. Could we turn to
FUJ00174184, please. We're going to start in October
2009. I'm going to start with the bottom email. There
is an email from Suzie Kirkham, I believe she was the
Royal Mail Group Account Manager at Fujitsu; is that
something you recall?
101
Fujitsu has twice appeared in court to support Post
Office. Only once has Post Office conceded its case,
and this was at a time when the audit trails were too
short to positive sufficient evidence to refute
a subpostmaster’s claims.
"In recent weeks a number of subpostmasters are
again querying the data integrity of Horizon and are
claiming that they are owed money by the Post Office due
to inaccurate branch accounts. These subpostmasters are
talking to the press (London News) and trying to gain
some momentum to support their case -- it's even
rumoured that the BBC is considering a Watchdog
programme on the subject. Post Office is trying to head
off this possible escalation of interest by preparing
a stock of simple responses to possible questions from
the media, or from interest groups. I have summarised
below the timeline that details when Post Office asked
Fujitsu for assistance in compiling this information."
She then goes on to give a timeline and we see there
the bottom two bullet points on the page, it refers to
aconference. She says:
"During the conference call [the Post Office]
requested from Fujitsu a short paper to describe how
Horizon maintains the integrity of the branch accounts
when certain issues affect the branch, [for example]
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Ido.
Gavin Bounds, can you assist us with who he because we
see his name on quite a few of these emails.
So Mr Bounds was a senior executive who was responsible
for the Post Office Account, he was what was known as
a Business Unit Director and would have worked directly
for me.
What was your relationship with him?
I was his immediate line manager.
In terms of your personal relationship; did you get on
well, did you have a free and frank exchange?
Yes, I would say so.
She says as follows:
"I have detailed below a brief summary of
a subpostmaster claim that Horizon fails to maintain the
integrity of branch accounts if the branch experiences
technical issues.
"Horizon has been running ..."
She produces a response. We can see, in fact, the
subject is "Horizon Data Integrity publicity -- briefing
summary". She says:
"Horizon has been running for around 10 years,
during which time Post Office has had to handle a number
of legal cases surrounding system integrity, mostly from
apparently disgruntled or fraudulent subpostmasters.
102
blue screen, hardware failure. Report requested to be
given to Dave Smith by 2 October."
Then it refers to Gareth Jenkins. Just pausing
there, was Gareth Jenkins somebody who you knew
personally?
No. I don't believe I've ever met Gareth Jenkins.
Was he somebody who you ever emailed directly or
corresponded with directly?
I don't believe so, no.
"[Fujitsu architect] spent the best part of one day
completing the report. The finished report was passed
[and it gives the name] before being sent to Dave Smith.
Report was sent to Dave Smith on 2 October late morning
just prior to the second conference call."
If we could scroll down, thank you very much:
"I spoke to Andy McLean on 5 October", et cetera.
That's where it ends, on 5 October.
The final paragraph says:
“In summary, our body of evidence is mature, so
we're well-placed to help Post Office today. But when
‘Horizon Online’ is installed in 2010, much of our
existing material will become irrelevant, so allegations
of system failures in the future may take more work in
preparing evidence or explanations.”
So a body of work has been gathered and put together
104
(26) Pages 101 - 104
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in order, it seems, to rebut or answer allegations of,
for example, system failures.
We see, if we scroll to the top of the first page,
please, it's sent to you by Gavin Bounds, and he says:
"Duncan
"A heads up, in case questions from Roger and/or the
client:
"I asked Suzie, RMG [account manager], to summarise
our involvement insisting [the Post Office] rebut
subpostmasters' allegations (made public) of flawed data
integrity caused by Horizon -- leading to inaccurate
accounts and thus monies owed. Please see below."
Do you recall receiving this?
I don't recall seeing it, I recall some of the things
coming from it but I've largely relied on the document
provided to me by the Inquiry.
Relatively early on in your time at Fujitsu, do you
recall somebody bringing to your attention concerns that
are being raised by subpostmasters about flawed data
integrity caused by Horizon?
Could you repeat the question again, please?
Absolutely. Even if you don't remember this specific
email, the general topic, complaints from subpostmasters
relating to data integrity issues and Horizon, was that
something that you were aware of?
105
scenarios, and descriptions as to how those measures
apply in each case."
Were you aware that Fujitsu was providing
information to the Post Office that related to Horizon
data integrity?
I think I was generally aware that Fujitsu was assisting
the Post Office.
Thank you. Page 7, we can see the "Scenarios" are set
out in this document. It says as follows:
"It should be noted that these scenarios are all to
do with equipment failures, and these will always be
visible to Fujitsu through the event logs which are
retained.
So it's not a document that, in any way, goes into
what we know as bugs, errors and defects; it only
relates to equipment failures at this particular time.
Okay.
So this isn't a report that you were aware of?
No.
No, Could we please turn to FUJ00156064. Can I just
clarify, in relation to your earlier answer, were you
aware that Fujitsu was at least providing some degree of
assurance to the Post Office with regards to the
reliability of Horizon data?
If I go to the email you showed me, the Suzie Kirkham
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I must have been aware because I have this email in
front of me but it was not a topic of conversation in
the meetings I was involved with in my early days in
Fujitsu.
I'm going to take you, very briefly, to the report
that's referred to from Gareth Jenkins in this email.
That's at FUJ00080526. This is the report that's
referred in to in that summary, it's entitled "Horizon
Data Integrity". It's by Gareth Jenkins, we see there
at the top it has both Post Office and Fujitsu logos.
Do you recall that being quite a common thing for both
parties’ logos to be placed on documents?
I think it would have been normal practice for whichever
customer Fujitsu was engaging with.
Thank you. If we scroll down to the bottom we can see
the date at the very bottom. It has there, this
particular version, 2 October 2009. If we turn over to
page 5, please, it explains the "Purpose":
"This document is submitted to Post Office for
information purposes any and without prejudice. In the
event that Post Office requires information in support
of a legal case Fujitsu will issue a formal statement.
"This document is a technical description of the
measures that are built into Horizon to ensure data
integrity, including a description of several failure
106
email, it is clear in there there is some type of
assistance being provided.
Yes, relating to the Horizon system?
Yes.
That is something that you would have been aware of in
your early days/months, as Managing Director?
I think, Mr Blake, having that -- I clearly received
that email, so I must have read that email.
Thank you. If we could start on page 2 of this
document, please, the bottom email in the chain, this is
an email from Suzie Kirkham to Gavin Bounds. Now, this
is the same substance but is actually slightly updated,
so I think the first one we saw was called, I think it
may have been referred to as a draft, or something along
those lines. It's clear that, by 7 December, there has
been some small amendments to that form of words?
If we scroll down, please, over the page, you'll see
that I took you to the bullet points before and
5 October was the final bullet point. There's now one
more bullet point, which says as follows, it says:
"I spoke with Dave Smith on 3 December and he
mentioned that the Data Integrity issue had reappeared.
It has been taken up by a Welsh MP who also happens to
be a Barrister. He is threatening to bring an Early Day
Motion in the House. Dave is meeting him in Parliament
108
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on Thursday, 10 December but at this stage didn't feel
he needed any attendance by Fujitsu. However, he was
alerting us to the fact that this has reappeared.”
So in that timeline, amongst other things referring
to the Gareth Jenkins integrity report, we're now told
that issue has been raised, not only, I think, there was
earlier reference to newspapers but now also
Parlimentarians; is that something you would have been
aware of?
Could you just scroll back up, please?
Absolutely. In fact, it may assist, if we go up
a little bit more, we can see the chain. So it seems as
though the same document, the same briefing has been
sent to you again, the updated version, because you
respond there on 9 December, saying:
"Okay, are you on top of this?”
So it seems as though you've been sent the updated
version and are following that up.
Yeah.
Is that something you recall?
So I'm not sure I would have had read the email. It
looked like the previous email I've received, and then
I reply all on here to ask are they on top of it.
Yes. Can we scroll up, please, and I'm going to read
you the rest of the chain. Ann Sinclair replies,
109
this is hotting up -- so we need to be in sync and both
using aligned/supporting messages. Suzie -- can
facilitate your introductions here."
This is the response from Ann Sinclair, sent to
Gavin Bounds and also Suzie Kirkham. She says:
"Gavin -- following discussions with our press folks
and Suzie on Monday we have agreed that:
“We need to downplay this situation as much as
possible, we don't want to get too drawn in to the
debate as we are only a supplier.
"There is a document that addresses all the
technical questions that was produced for [the Post
Office] for a meeting with MPs last week.
"We should not contact [the Post Office] Press
Office.
"If press contact us, we will send them on to the
[Post Office] Press Office and not comment [but]
"We will flag to Grayling, (our Public Affairs
agency) to get them to keep their ears open for
Parliamentary questions etc.
"We'll keep an eye on this and if it looks like the
situation is changing and/or becoming higher profile
obviously we will review with you."
Was that approach something that you knew about at
the time?
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sending to you, and she says as follows:
"Gavin -- I'll brief the Press Office. We should
prepare an FAQ/statement to have in our back pocket if
required, and I also want to explore doing some
proactive work with them too, [for example] getting some
positive stories out there, building some bridges with
the journalists who might pick this up.”
Then above that, Mr Bounds emails Suzie Kirkham and
he says:
"Suzie -- can you liaise with Ann please."
That's Ann Sinclair; who was Ann Sinclair?
I think Ann Sinclair was the Marketing Manager for the
Private Sector Division.
Thank you. So within your division, you would have been
her ultimate manager?
She had a dotted line to me and worked a hard line to
the UK & Ireland Marketing Leader.
Thank you. At this stage, you're now not copied into
this correspondence?
(The witness nodded)
I'd like to read the above two emails, so the first one
directly above says:
"Ann.
"Can we also have our Press Office hook up with the
[Post Office] Press Office team on this too -- I think
110
No, it was not.
Was it something, as the Managing Director of Fujitsu,
should have been run past you, that kind of a strategy?
Mr Blake, we put in place, to run each of these
businesses, senior executives and we expect them to be
able to run their businesses accordingly.
Who is the senior executive that would be responsible
for this kind of a policy?
The Business Unit Director for Post Office was
Mr Bounds.
Mr Bounds, Gavin Bounds?
Yes.
He would ultimately report to you?
Indeed.
But it's your evidence that, in terms of this kind of
a strategy, downplaying the situation, it would be him
who makes the call on that?
Indeed. I mean, I'm not copied so it's difficult to say
what they're trying to downplay here.
Yes. The email to you, though, that additional bullet
point that I took you to, brings in a Member of
Parliament is now concerned. Wouldn't issues such as
that -- so matters affecting the press, Parliament --
wouldn't they be matters to raise with the Managing
Director?
112
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Probably. I'm not convinced I read that email as it
looked exactly like the first email that I'd received.
Yes, but it's clear that Ann Sinclair has read that
email and come up with a strategy and discussed it with
Suzie Kirkham. Is that not something, given that it
related to, for example, a Parliamentarian, something
that -- involving one of your biggest customers -- that
should have reached your level?
I think it depends on the situation.
Looking at this situation, what is your view?
The situation from reading the email is that there is --
there are no hints in here that the data integrity
issues raised are real. There's a reference that
Ms Kirkham makes in her email to say that we have
a strong body of evidence and there is a document
produced to show how integrity is maintained in Horizon.
Yes. We also have London News being interested,
a Watchdog programme potentially on the horizon and also
an MP interested. In those kinds of circumstances, we
have your evidence that it didn't ultimately go to you
in terms of the strategy but, in terms of whether it
should or shouldn't have gone to you, what is your view?
Depends on the situation, if the situation -
I'm telling you the situation.
If the situation is very, very serious and the team
113
I would just like to read some of the content to you and
see if you are familiar. Are you familiar with this
particular document it all, other than it being provided
by the Inquiry?
I don't think I've ever seen this but I can see it from
information you've provided.
Looking at the circulation list, who is the person that
you would have liaised with the most out of all of those
people or perhaps who is the most senior of the
distribution list?
Maz Kostuch is probably the most senior person on that
list.
Did they have a direct line of reporting to you?
I think Maz did at that time, yes.
If we scroll down, I'm just going to read to you a few
paragraphs. So it begins with the terms of reference:
"Following the occurrence of a transaction being
duplicated on the HNG-X branch database, Stuart Rye and
Paul Roberts were asked to review the counter
application architecture and design and ensure that it
fully supports the need to protect the integrity of
financial transactions.
"The scope is focused on the integrity of the
Counter Application in relation to financial
transactions captured at the Counter. It does not
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believes that they need my involvement in that, then
I would expect them to escalate it. If they believed
that there was no integrity issues and that then
therefore this is something at play in the media but has
no substance, then I don't -- there would be no need to
involve me in that.
Thank you. I'm going to move on now to early 2010, and
the Horizon Online pilot. In 2010 you were still
Managing Director?
Yes.
Were you quite closely involved in the rollout of
Horizon Online and the pilots of Horizon Online?
There were several accounts that needed my attention
during that period when I joined as Managing Director,
and Post Office was certainly one of them.
Yes, I mean, compared to, for example, being the CEO and
your increasing role in wider regions, when you were
just Managing Director, just of the private company
area, would you have been relatively involved in the
pilot?
Yes, I think that's fair.
Could we, please, turn to FUJ00093031. We're going to
see that is a review that took place on the integrity
of -- we refer to it as Horizon Online, HNG-X. You're
not on the circulation list, you're not an author, but
114
extend to data migration or other transient issues
caused by the switch from Horizon to HNG-X."
The "Background":
"The objective of the [Horizon Online] programme is
to develop a system with structural and operational
characteristics that substantially reduce ongoing
support and maintenance costs with respect to the
current Horizon system."
Just pausing there, were you aware that one of the
objectives, or a key objective, of Horizon Online was,
essentially, to save costs in the everyday operation?
Yes, I was.
Thank you.
"A key component of Horizon Online is the Counter
Application. In [reference] to the Horizon Counter
Application, the [online] version retains operational
data, (eg Reference Data) and business logic, but
transactional information is stored directly in the Data
Centre.”
I'll take you to the next paragraph, it says:
It is currently in pilot with nine branches.”
So, at this time, 2010, it was only in 12 branches.
Mm-hm.
"On 28 January 2010, the Data Reconciliation Service
process detected an error in a banking transaction.
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Subsequent investigations revealed that the branch
database had two transactions with different [Journal
Sequence Numbers] but the same [Session Sequence Number]
for a specific counter on that day but the third party
banking system only had one transaction. The clerk did
not know that a duplicate transaction had been created."
So reading that, it seems as though the person
‘operating the Horizon platform would not have known that
there was this error:
"An analysis of the database has revealed one other
‘occurrence, again at Derby, but on a different day and
involving a different clerk. This had not been detected
by the [Data Reconciliation Service] as it did not
contain a banking component and there there is no other
business reconciliation which might have spotted it.
"The net effect would be that the Post Office and
the branch records would not match. Where this happens,
the Post Office investigates the branch and postmaster,
with a view to retraining or even uncovering fraud. It
would seriously undermine Post Office credibility and
possibly historic cases if it could be shown that
a discrepancy could be caused by a system error rather
than postmaster/clerk action. [More] importantly, the
central database as the system of record would be called
into question."
117
Office but also for individuals, any individuals, who
are, for example, investigated by the Post Office?
Oh, without question, yes.
Can we turn to FUJ00094392. If we start on the bottom
email, please, and if we go over the page slightly, we
can see this is an email from Jean-Philippe Prénovost;
were you aware of who that was?
No.
So he was legal counsel, it seems, within Fujitsu, so
internal lawyer. He emails Alan D'Alvarez and he says
as follows:
"Hi Alan
“Further to our discussion of Friday, please find
below the two comments I had raised ...”
This is commenting on the document we've just
seen --
Okay.
-- and he says as follows:
"First paragraph, page 2 -- The following section is
potentially problematic [and he quotes there]: 'It would
seriously undermine Post Office credibility and possibly
historic cases if it could be shown that a discrepancy
could be caused by a system error rather than
postmaster/clerk action. Most importantly, the central
database as a system of record would be called into
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Were you aware, in broad terms, of issues cropping
up in the rollout that had the potential to call into
account the accounting integrity?
No.
Were you aware of the potential for an issue with
accounting integrity to affect, as we see there, Post
Office Investigations?
No.
Again, as the new Managing Director, why wouldn't this
have been brought to your attention?
I don't know. What I do know is other issues were
bought to my attention during the rollout but this was
not.
Reading that final paragraph, that is quite
a significant paragraph, isn't it --
It seems to be.
-- both for your relationship with the Post Office and
also in relation to those complaints that we had heard
about in that earlier correspondence?
So my understanding, Mr Blake, is this is about HNG-X
and not about Horizon.
Yes. Irrespective of whether this relates to Horizon
Online or what we know as Legacy Horizon, the statement
that is contained in that final paragraph is quite
significant both for your relationship with the Post
118
question’.
So that's the bit I just took you to. He says as
follows:
“As discussed, there is no need to paint this in the
worst possible light. I would suggest the following as
being accurate without being unduly alarmist: 'If it
could be shown that a discrepancy could be caused by
a system error rather than a postmaster/clerk action, it
could potentially call into question the effectiveness
of the central database as a system of record’."
Quite significantly changing the meaning of that
sentence; do you agree with that?
Yes. I've not seen this document prior to being shared
by the Inquiry but —~
Yes. You're not copied in. If we scroll up above,
there's an answer from Mr D'Alvarez and he says as
follows:
"After review with legal (see email below) two
amendments have been made to the documents and, in both
cases, the sections referred to have been removed as
they do not materially add to the primary purpose of the
review which is to determine whether the solution, as
designed would protect data integrity.”
As I say, you're not on this email chain.
Mm-hm.
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Were you aware of a sensitivity within the business
about these issues?
No.
Again, would it surprise you, as Managing Director, not
to be aware of these sensitivities?
With hindsight, yes, but that was not shared with me at
the time.
Looking at the recipients here, who would you have
expected to have shared it with you?
So it's largely -- from what I can see -- I don't
recognise all of the names -- it's largely a technical
team. I would say probably Maz Kostuch, as I said
before, is probably the most senior person.
Were they on any of the kinds of committees that we've
been speaking about?
Not to my knowledge.
Could we please turn to FUJ00174290 and it's the bottom
email I'd like to take you to. We're still with the
pilot and rollout of Horizon Online, 6 April 2010.
Thank you. So it's the bottom half of page 1, please.
Mr Bounds sends you a list of issues arising at that
time. He says, as follows:
"Duncan, the new [Post Office] CEO, Dave Smith,
started today. Mike Young mentioned before he went away
that if/when the new CEO arrived he would likely be
121
up slightly that, in terms of the report on operations,
you now have underway a report that's being written by
somebody called Rachel Daka. I think you've said in
your witness statement that she wasn't independent, in
the sense that she wasn't external to Fujitsu; you chose
to pursue that internally?
That's right.
What was the reason for that?
My understanding was the Post Office Account team wanted
to bring someone in with experience in Fujitsu who was
independent of the team that was deploying Horizon
Online and Rachael was -- well, you can see here -- the
Operations Director for our Retail Business Unit.
Number 3, there is reference there to Belfast data
centres suffering a power surge and then we come to
a list of things that are to be moved to red alert; can
you assist us with what red alert was please?
As I recall, red alert was an internal process that
account teams could engage with to bring more of the
company's resources to bear on the particular issue they
were facing.
There's reference there to two major incidents, one with
Horizon Network banking issues, another with MoneyGram
issues. Below that, we also have other major incidents,
debit card authorisation agent failed in a resilient
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reaching out to Richard in his first few days in the
role.
"By way of a briefing for Richard, please review the
following:
"[Horizon Online] pilot was progressing well and
moved into day 1 of high volume pilot (to 215 branches)
on Thursday, 25 March. 208 branches were successful
rolled out -- a good outcome.”
It then says:
"Then began a catalogue of outages/issues as follows
It has a table of different issues: for example the
first one we see in that middle column:
"Two [Horizon Online] service outages affecting all
branches."
If we look at the bottom entry there, there's
reference to a client meeting:
"The client stated at a meeting on 1 April that they
would not allow High Volume Pilot to move ahead until:
"a. They had seen the findings of an independent
report on our CS operations -- giving them assurance
that we were correctly resourced and had our events
reporting under control [also]
"b. Fixes were deployed [for various issues]."
We see in the right-hand side of that, if we scroll
122
pair; horizon Network banking issue; proxy radius server
issue affecting ISDN sites.
I just want to read to you the paragraph two
paragraphs below. He says:
"The above reflects significant issues we've
experienced over a short time span."
Just pausing there, were you aware of those kinds of
issues being experienced in relation to the rollout of
Horizon Online?
I would have been aware of, I think, most of these
issues.
"Relationships with the Post Office leadership are tense
and we are clearly on the back foot. Dave Smith (as in
the CIO that has just retired from [the Post Office])
takes with him a maturity of approach and firsthand
experience of the original rollout of Horizon, his
council to Mike Young and the [Post Office] ET was
[that's ‘Executive Team’, I think] was that there were
many large issues back then and that these should be
expected now ..."
Were you aware, we've had a whole phase looking at
the original rollout, were you aware of significant
issues during the original rollout of Legacy Horizon?
No. I was not. Not at this time.
It looks as though Dave Smith was trusted because he had
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experienced the first rollout and was likely to be more
accepting of issues this time round. Is that -- was
that your understanding?
I'd never met Mr Smith, no.
I think this was an email sent to you; did you have any
thoughts on that at the time?
No, I did not.
The reference to relationships with the Post Office
leadership being tense, what was your understanding at
that time?
I would -- I think that's about right. We were in the
middle of a major rollout. That rollout was already
significantly delayed and then we have all of these
technical issues.
Then it says:
"However, we do have a strong supporter in Andy
McLean, the [Post Office] Service Director -- whilst not
pleased with where we are he advocates a logical
cooperative ethic to overcome issues and is concerned by
some of the more emotional reactions he is seeing within
[the Post Office].”
What did you understand by "Emotional reactions"?
Well, had I have sat in the shoes of either
a subpostmaster impacted by this, or on the Post Office
side, when the rollout is in progress, I would have ~
125
that Mr Young did raise the view with us that he would
rather cancel the Horizon Online programme and he would
go back to the previous version of Horizon. He did not
want his operation messed up.
Thank you. I'm actually going to take you to that
correspondence now. Could we start with the
FUJ00095628, please, and we'll start on page 2. Thank
you. There's an email from yourself to Roger Gilbert
and Gavin Bounds, and you say as follows:
"I spoke to Mike Young on Friday morning, he was in
good spirits but remains very concerned about [Horizon
Online].
Mr Young has made two points. The first is:
"The programme was reviewed at Group level ... with
Mike Young, Dave Smith and the Group Legal counsel and
FD discussing options. The legal counsel admitted they
have few ‘levers’ to pull but want some reassurance.
The Group input was based on the issues and experience
they had with CSC."
Are you able to assist us with CSC?
That would be Computer Science Corporation, now known as
DXC."
Thank you:
"Mike gave a balanced view of Fujitsu -- good
relationship, excellent track record of stability,
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I would have had a similar emotional reaction to it.
"Dave Smith (from Parcelforce) started today, and has
met with the [Horizon Online Post Office] team. Our
contacts tell us that he is likely to take a more
cautious stance towards restarting the pilot. The
National Federation of SubPostmasters will not allow any
more of their members’ branches to be migrated to
[Horizon Online] for the time being. The likely way
forward is that [the Post Office] will look to deploy
[Horizon Online] to all their Crown Offices first, to
prove that the system works and to persuade the
Federation to continue."
So it seems as though there were real tensions at
this point about even whether Horizon Online was going
to be rolled out to various subpostmasters around the
country?
So I would agree with the significant tensions. I think
the question was, when do you -- at what point do you
roll out Horizon to branches, as opposed to do you only
partially roll out the new version of Horizon?
Was that ever a threat from the Post Office, though,
that they wouldn't proceed full stop with Horizon
Online?
So I remember meetings and correspondence with Mr Young
and certainly some documents provided by the Inquiry,
126
positively engaging with [Post Office] and made
a difference to the business making its numbers that is
years. However, he has doubts about our ability to
wrestle the programme to the ground and they remain
worried about the later releases of the software as they
relate directly to [Post Office's] ability to grow
revenue. His words to me were that he has pressure on
him to consider a plan B."
Is Plan B what you were talking about before that,
potentially, he may pull the plug on the whole thing?
He never made that clear. It was, I would say, a threat
that was left dangling in the air.
"Their confidence has been knocked due to:
"Ongoing issues with Oracle stability ...
"The data centre outage.
"An outage caused by ‘Fujitsu operator error’ last
week .
"Mike has asked for the following:
"1. Based on advice from Group Legal counsel Mike
feels he wants some assurance that the [profit and loss]
for the account is sustainable over the short and long
term so they can see what we invest and provide the
resources necessary to get the problems fixed. This
will look like some form of an ‘open book’ arrangement.”
What do you understand by "open book arrangement"?
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For Fujitsu to reveal every last cost item that there is
assigned to the programme, and I think to the whole
account.
"2. He wants an independent review of the processes,
tools and resource on the programme to assure themselves
we are genuinely up to it.
"3. Finally, he wants Dave Smith to have some
dialogue with
I think that's Richard Christou?
Yes.
"... so they can test the Japanese Board's commitment to
the account and programme (conference call or [video
conference] would work).
"My view is it would be difficult, based upon where
we are now, for us to resist 1 and 2 although there is
some risk in those areas."
So the initial discussions have taken place and your
initial view is that, in fact, those first two would be
difficult to resist. So the open book and the
independent review; is that right?
That's fair, yes.
If we scroll up, please, to the first page. The very
top of that at page, please. We see an email from Guy
Wilkerson. Who was Guy Wilkerson?
I think he was a hybrid legal commercial person on the
129
But do you recall any reluctance to carry out any form
of independent review at that stage?
So -- well, I should be clear. My understanding of
this, it was an independent review of the programme and
not of data integrity, which I think is important, if
I understand this correctly. Then, in terms of our
concern, the concern would, certainly in terms of open
book, have been another opportunity for Post Office to
try to reduce Fujitsu's fees or costs into them, which
was a consistent theme of the conversations between the
two organisations.
The other risk, I think, for us at the time, was the
most important thing to do was resolve the Oracle issue
and, diverting resources from the programme, then into
an independent review, might have reduced their focus on
what was the most important thing, which was the
successful rollout, of the HNG-X programme.
Let's look at the subsequent correspondence between you.
It starts at FUJO0095658. This is a letter to you from
Mike Young, 10 May 2010, I will read to you a few
passages. The second paragraph starts by saying:
"It was recognised during this review process that
our relationship with Fujitsu is of long standing, has
thus far proved fruitful to both parties and continues
to play a pivotal role in the successful delivery of
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Post Office Account.
He says and he's responding there to Vince Fullwood, who
I think has forwarded the earlier chain. He says:
"As discussed, this isn't really a great surprise
and I'm sure we'd be doing the same thing if things were
reversed. As they suggest, they are not entitled
formally to an Open Book Review in my opinion but this
would be a confidence measure rather than a contractual
arrangement on their part.
"They are hyper-sensitised to the stability issue
He then refers to the open book review wasting a lot
of time, and it's this final sentence that I want to ask
you about. He says:
"An independent review will throw up all sorts of
detail issues that can only delay the programme."
Were you aware internally of concerns about carrying
out an independent review at this stage?
So this is an independent review of the account's
financials, Mr Blake, if I read this email correctly.
What do you think it's limited to that? I mean, if
I take you to the discussion -- in fact, I'll take you
to the actual correspondence of Mr Young, so we can look
at that.
Okay.
130
Post Office's products and services."
But he then goes on, in the next paragraph, to talk
about his requests in relation to the Horizon Online
programme. He says:
"We would very much like to see the executive
correspondence within Fujitsu related to the recent Red
Alert. This, we feel, would give us an understanding of
how the Executive Management within Fujitsu are aware
and responding to some of the problems we have seen in
rollout.”
So one of his requests is a bit more transparency
from Fujitsu. The second, he says:
“Additionally, we would like you to consider
bringing in a qualified independent party and asking
them to review and audit how the current programme is
being run ..."
This last half of the sentence is important, in the
context of what you've just been saying:
as well as testing resource and skill levels
both on the programme itself and other key initiatives
that we have under way with Fujitsu."
So it's both looking at resources and skills of
those who are running the programme as well as the
overall programme itself; is that right?
That's fair.
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Q. Yes. Then your response is FUJ00096312. If we start on
page 2, please -- thank you -- this is your response to
that letter. So "Thank you for your letter", it starts.
Three paragraphs down, it says:
"Since your letter, I am extremely pleased with the
progress that has been made. We have located the source
of the troubles and taken steps to rectify the issues
and we have now recommenced the pilot.”
Next paragraph:
"The cause of the issues that delayed High Volume
Pilot was deficiencies with the Oracle product code."
You've explained a lot about the Oracle issue in
your witness statement, I'm not going to deal with that
today. You say, at the end of that paragraph:
“At this crucial phase of the programme, we can see
no benefit and will not be pursuing a third party
review."
So you are rejecting the proposal for an independent
review at that stage.
Yes, it is, and my understanding is, between Mr Young's
letter and this, that between Post Office and Fujitsu,
there had been an attempt to agree a review with a third
party but it had not come to conclusion.
Was that because of concerns within Fujitsu that
an independent review would, in the words of
133
concerns around the programme, including the Daka review
during that period of time, and that we're now back --
and it was clear, the real issue with this is the Oracle
code and that's now resolved and we're able to deploy
the pilot -- sorry, deploy into high-volume rollout.
Could we turn to page 1, please, and we have his
response. He says:
“It won't surprise you to learn that I am somewhat
disappointed that it took so long to formally reply to
my correspondence of 10 May and with the apparent 'sea
change’ on approach to some of our concerns. As my
letter intimated, these letters of concern were brought
to the fore in a Royal Mail Group Review of the current
Horizon contract. My understanding from our weekly
calls was that you had taken advice from KPMG as to how
you could go ‘open book’ with us and therefore didn't
foresee a problem in doing so. On the issue of having
a qualified independent party audit to evaluate Fujitsu
Programme execution, along with staffing levels and
skills base, I had been briefed that you had spoken to
several entities to pursue this endeavour. Indeed,
I was told you were close to agreeing terms with one of
these. Additionally, in our calls you will recall I had
asked whether there was a possibility of the Post Office
‘owning' the terms of reference and again, this was
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Mr Wilkerson, throw up all sorts of detail issues that
can only delay the programme?
I don't believe so.
What was your belief as to the reason why an independent
review at that stage was not to be agreed to?
So during that period you have two things. You have
about six weeks period of time-ish -- you might correct
me -- where, between Fujitsu, Post Office and third
parties to agree a scope and terms of reference, and
that was not possible during that time.
I think the other thing, Mr Blake, is, by the time
that this letter goes back from me to Mr Young, it's
clear what the real issue with the programme was and the
real issue with the programme was the Oracle code, which
has since been fixed.
You then continue in this email:
“You will have seen the tremendous effort from
Fujitsu.
"Thank you for your offer of assistance over Red
Alert ... that has now been lowered", et cetera.
So, effectively, trying to close off the issues that
Mr Young has raised in his letter is that a fair -- or
to say that they have already been addressed or don't
need addressing?
I think that we have taken measures to address the
134
something you were going to strongly consider.
"As it stands now, I feel I have been led down,
a journey on a number of months, just so that you can
now say, ‘no’. This does not reflect well on our
relationship and will not be well received in the next
review. I have as a matter of course, been keeping both
the Post Office Executive and the Group Executive aware
of the progress I was told we were making in these
areas."
Just pausing there, the evidence that you've given
in relation to your response was that things had
changed, problems were over by then --
Mm-hm.
-- and that they weren't necessary. It seems to have
come as quite a surprise to Mr Young; were you aware of
that?
I think -- well, you can see from his -- from his email
to me that he is disappointed that we have, at that
point, pushed back on his requests.
There seems to be somewhat of a gulf between you as to
whether matters are resolved or not resolved?
I would say, Mr Blake, the matters were resolved because
the programme, at that point, was back up and running,
and, as I said, the key area that was causing the issues
in the programme here was the Oracle software code.
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He continues:
"It is now even more imperative that my Managing
Director gets a view from the Japanese Board on just how
they feel this relationship is progressing. We would
like to see if the meeting between Dave Smith and
Richard can be brought forward to a date closer than the
current August date.
"In the meantime can I suggest you and I get
together in person some time next week and talk thorough
where we are."
Were matters ever raised with the Japanese Board
along the lines proposed here?
My understanding is Richard was aware of the issues we
were facing with Post Office and was supportive of
a meeting with Mr Smith and Mr Young.
Are you aware of that taking place?
I vaguely recall that it did.
Can we, please, turn to FUJ00096238. If we scroll down,
please, thank you, we can see Andy McLean. Who was Andy
McLean?
I'm not quite sure.
Okay. He is emailing Gavin Bounds and raises issues
with costs that are being incurred by the overrun. If
we scroll over to the first page, we're in the same time
period -- we're actually slightly back in time now.
137
carefully considered -- [so] you know such a precedent
if set by [the Post Office] to its subpostmasters might
make [the Post Office] liable for compensation to
subpostmasters in all future cases where the service is
interrupted ..."
Just pausing there, it seems as though you've had
a conversation with Mike Young about potentially
providing some sort of compensation or money to those
subpostmasters who were affected by problems in the
rollout; is that right?
So my understanding is that Mr Young and I had
a conversation where we left with different views of the
same -- of the same conversation, and Mike was under the
impression that we would pay compensation directly to
subpostmasters.
Yes. This draft being sent on a without-prejudice
basis, looking at this and looking at the earlier emails
that I've taken you to, it seems as though, in June of
2010, things were quite bad between yourselves and the
Post Office, potentially leading even to litigation. Is
that your recollection?
I don't know if, at that time, it would have been as
tense as earlier on in 2010.
So there was a worse time in 2010?
I think the early part of 2010 was difficult for both --
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Okay.
We're on 18 June. This is American format, so it should
o>
be 18 June 2010, and it's from Mr Bounds to you, and he
says:
"I will be sending this to Andy McLean at [the Post
Office] later today.”
It's headed "Without Prejudice", and he says, for
example:
"We are greatly encouraged by the recent restart on
[the] pilot rollout and we are hopeful that the
programme will now move forward to a successful and
uninterrupted conclusion. Despite this, it is
acknowledged that getting to this point has caused us to
move beyond the period covered by the last arrangements.
made regarding the schedule and, like you, we would like
to discuss this to ensure our financial position is
clear."
I just want to read to you that penultimate
paragraph there. He proposed to say:
"I have had confirmation from Duncan [regarding] his
and Mike Young's conversation, unfortunately no such
agreement was reached. Just to be clear, while I can
sympathise with the intention behind your suggestion,
Fujitsu is not contractually liable in any way, any
measures agreed without prejudice would have to be very
138
was difficult for both organisations and for
subpostmasters.
Again, is that due to issues during the rollout --
Yes.
-- technical issues affecting subpostmasters?
(The witness nodded) Yeah.
MR BLAKE: Sir, I think that's an appropriate time to take
our first afternoon break.
SIR WYN WILLIAMS: Okay.
MR BLAKE: If it could be for ten minutes, please.
SIR WYN WILLIAMS: Yes. So where does that take us to?
MR BLAKE: 2.50, please.
SIR WYN WILLIAMS: Fine, yes.
MR BLAKE: Thank you very much.
(2.38 pm)
rPOoOPrO
(A short break)
(2.51 pm)
MR BLAKE: Thank you, sir, can you see and hear me?
SIR WYN WILLIAMS: Yes, thank you.
MR BLAKE: Excellent.
Mr Tait, just to summarise where we are, we went to
a document in 2009 and I think the position was you
recognised that there were complaints from
subpostmasters relating to integrity and that you were
broadly aware of those, albeit not necessarily paying
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much attention to the particular emails that I took you
to; is that right?
I think that's fair.
Then 2010, we've seen issues with the pilot and the
rollout, and tensions between the Post Office and
Fujitsu in respect of that.
That's also true.
Could we, please, turn now to FUJ00174378. We're still
in 2010 but now we're in the summer of 2010, 22 July
2010, so a month after the documents that we were just
looking at. You are sent an email from Gavin Bounds to
yourself and others, entitled "Channel 4 [documentary]
next week [regarding Post Office] and our Horizon
system -- heads up". It says as follows:
"[Post Office] has just informed us that they are
commenting back to Channel 4 on a documentary to be
aired next [Friday regarding] the plight of a few
subpostmasters who have claimed that Horizon (our
system) was the cause of financial irregularities that
led to them losing their jobs. This appears to be
related to Horizon and not HNG-X and also are not
related to the service interruptions we experienced
during March/April.
"[Post Office] will send us the comments they have
made tomorrow. Verbally [Post Office] has confirmed to
144
point would have been a -- was previously Richard's CFO
and was now in some type of business assurance role;
I don't know who Matsuzawa-san is, Mr Matsuzawa.
So are they based in the Japanese part of Fujitsu or are
they based in the UK?
I think, at that point, Mr Kamata would have been based
in London, Mr Harris would also have been based in
London, I don't know where Matsuzawa-san was, and the
others the other Japanese people I don't know, it looks
like they were based in London. Roger Gilbert was my
boss in London; Steve Clayton was, I believe, Roger's
CFO based in London; Richard Christou, at that point,
was probably on his way to Japan or already being in
Japan; and Philip Oliver, I believe, was also based in
London.
Thank you. The author says:
“Although it is not clear if we are involved in this
matter at this moment, I would like you to work with
Roger and his team to clarify what is going on. This
article has been already picked up by [Fujitsu] Tokyo."
We will scroll down and see what the story is but,
when it says “picked up by [Fujitsu] Tokyo", typically
how would that happen?
I guess Fujitsu Tokyo would either have picked up
something in the media or would have been informed by
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us that these cases are known to them and they see no
cause for concern. In case we are approached -- as
usual -- we should refer all questions back to the [Post
Office] PR team."
Do you recall receiving this email?
I do not.
Do you recall, in general terms, there being a Channel 4
documentary in July 2010?
I didn't watch it.
Do you recall there being a documentary at that time,
learning about it around that time?
I received the email, Mr Blake, so I must have been
aware at the time.
Mr Bounds, he wasn't a technical expert at Fujitsu, was
he?
No.
Could we, please, turn now to FUJ00156195. Very similar
time, we're now on 5 August. If you scroll down to the
bottom of page 2, please. Thank you. We have an email
from Roger Gilbert to you and Mr Bounds asking for you
and Gavin to provide a brief on what follows below. Can
you assist us with who is on the distribution list
below, please, where they are, which office they are in?
Sure. So Mr Kamata was essentially Mr Christou's Chief
Financial Officer; Brian Harris, I think was -- at that
142
Fujitsu in Europe or very occasionally a customer might
have written directly to senior executives in Japan.
Thank you, if we scroll down, we can see that it's
a news article, "Post Office faces legal action over
accounts IT", and it refers there to Accountancy Age.
It says:
"Accountancy Age has learned a group of
subpostmasters have joined together to bring legal
action against the Post Office. Court papers are
expected to be filed in the coming weeks.
"The action originates with the Justice for
Subpostmasters Alliance and is over the use of [Fujitsu]
accounting software made for the Post Office by Fujitsu.
"A number of subpostmasters have lost their
positions over alleged accounting irregularities, while
some have also faced fraud allegations in the courts.
“But the subpostmasters claim that errors in the
system software are to blame.”
If we scroll down to the bottom of that page, it
says:
"The JFSA has expressed concern that the accounts of
any subpostmasters have not been examined for up to
eight years, which it believes would highlight the
system's problems.”
At the bottom of the page, it says:
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"Allegations about Horizon first appeared in October
last year when 30 subpostmasters came forward ..."
Then it has at the bottom, "IN OUR VIEW", so that's
in Accountancy Age's view, if we scroll down to the
bottom of the page, please:
"IN OUR VIEW
"Rarely has there been a more pressing need for
a forensic accountant to audit an accounting system.
With a High Court battle on the cards, and various
smaller courts around the country all calling for
an audit, the Post Office now faces compelling claims to
undertake a serious audit of its IT. The argument is
becoming almost impossible to ignore.”
If we go back to page 2, please. Just below that,
we have the CEO of Fujitsu sending this to you and to
the COO, Gavin Bounds, asking for a brief. Then we
have, on page 1, the brief. I'm going to take some time
to take you through this email. So Mr Bounds has sent
it to you:
“"Roger/Duncaan ..."
So to the CEO and to you:
"Summary -- no cause for immediate concern, this is
the latest in a long line (even preceding automation) of
articles and/or challenges to [the Post Office]
regarding its accounting systems."
145
has been found to be at fault although the judge has
left open the possibility that if there is an error
anywhere, it is only likely to be in the processes which
are Post Office's. The defence counsel is currently
using this to request further system information but the
general view is that he is fishing for problems rather
than having any particular proof of error.”
The next paragraph:
"Post Office is handling the case and all
communications with the public ... [Post Office's]
position (validated yesterday and today) is that they
are not going to respond to this article on the basis
that Accountancy Age only has a small circulation --
although they are also aware that it is on the web.
Their view is that if they respond to every article on
this topic it only as credence to the claim. Post
Office also stated that they are confident that the
integrity of the Horizon system is secure. They will
always investigate every case that is raised by the
subpostmasters and to date they have never found the
system to be flawed. If necessary, Post Office will
fight each individual case through the courts. In all
formal responses to these allegations, Post Office never
mentions Fujitsu unless they are asked to provide an
expert witness."
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He sets out the Fujitsu position:
"Post Office owns relatively few of the actual post
office branches in the UK, most of the branches being
effectively franchises. Postmasters are mainly paid
based on the number of transactions of each type that
they perform. Post Office takes a fairly firm stance
with any accounting discrepancies to prevent fraud but
there is a steady stream of court cases and almost
weekly stories in the minor or local press covering
those cases.
"Fujitsu is obligated to support Post Office, where
requested to do so, by either providing system
information to support the cases or, in some cases,
expert witnesses to testify as to the measures within
the systems to ensure that the data being relied on is
as originally entered. This has been going on for
a number of years with little incident.
"As reported in the article, recently accused
postmasters have become more organised and a case in
West Byfleet is being used to test potential arguments.”
That's the prosecution of Seema Misra.
Yes.
"We have been providing information and an expert
witness at Post Office's direction. The outcome so far
is understood to be that neither Post Office nor Fujitsu
146
I just want to read to you this final paragraph:
"They did recently issue a private statement to
Channel 4..."
So that's the Channel 4 programme --
Okay.
-- that was mentioned in that earlier email:
"after which they withdrew a programme they were
planning on the subject.”
So the Channel 4 notification on the 22 July seems
to have not have taken place --
Okay.
-- it seems to have been withdrawn:
"This is included below and has been released to us
on the basis that we do not circulate this beyond those
executives with an immediate need to know."
This the private statement that was released to
Channel 4:
“As discussed here is a copy of the statement that
was sent to Channel 4 News the other week. I am happy
for you to use this in order to address the concerns of
your executives in Japan ..."
Just pausing there, do you recall concerns being
raised by executives in Japan at this stage?
So I don't know. I'm assuming this refers to the
Japanese people referenced in the email or in
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communication with the Post Office. I don't know.
Did you at this stage have any communications with
executives in Japan about --
I didn't, Mr Blake, but my reporting line was through to
Mr Gilbert, then he reported to Richard Christou and
Richard Christou was on the Executive Committee of
Fujitsu in Japan at that time.
'... however, I need to ask that this doesn't get
circulated around Fujitsu or appear in any way in
internal publications -- this is because [Channel 4]
didn't run the article so our statement [hasn't] been
publicly released."
Their statement said:
"Virtually all the UK's 12,000 post office branches
operate entirely professionally, using the Horizon
system, without any accounting discrepancies and without
accumulating abnormal debts, and it is clearly in the
interests of both our customers and the vast majority of
subpostmasters that in the very few instances where
there is evidence that the finances of a branch are not
properly managed or where money has gone missing, Post
Office Limited must fully investigate, and take
necessary action, including legal action in the last
resort. The decision to prosecute is not taken lightly
and in every case where action has been taken no court
149
Horizon. This is unlikely to prevent similar
investigations into the replacement system at a later
stage."
So bringing everything that we've been looking at
together, within your first year at Fujitsu, you were
aware of complaints from subpostmasters relating to
Horizon integrity, correct?
Yes.
You were aware of publicity in trade magazines and in
other articles as well?
Yes.
You were aware of Fujitsu providing some support to the
Post Office, albeit unclear the extent of that support?
Yes.
It didn't register with you that that included
prosecution support at that stage; is that right?
Also true.
I think in your witness statement, you've said that you
only vaguely recall this particular issue; is that
right?
That is also right.
Given that it’s been raised, picked up by Fujitsu in
Tokyo, given all of the details that we see here, why do
you think it was not a significant issue on your
particular agenda?
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has found evidence to believe that the Horizon system's
integrity to be deficient.”
Just pausing there, we're now in August 2010. By
that stage, were you aware that Post Office was
prosecuting subpostmasters based on Horizon data?
Yeah, I'm not sure I was.
Even on receiving this?
Even on receiving this.
I'll read to you the final paragraph of that statement,
they say:
"We are continuing to upgrade the system to make
sure it meets the growing demands of the financial
services products provided by today’s post offices.
Whilst implementing changes it will inevitably have
caused some inconvenience, it has not in any way
affected the integrity of the system, which is
fundamentally more accurate and less open to abuse than
the old-fashioned paper based systems it replaced’.
"Finally, Post Office does not publish details of
prosecutions of subpostmasters."
Mr Bounds continues, he says:
“It is also worth noting that Horizon is due to be
retired and replaced by [Horizon Online] in the next
month or so -- this is primarily for cost saving reasons
and was not driven by any technical problems with
150
Because, if I go back to the emails when I first joined
the company, it's evident from the Chief Operating
Officer of the Post Office that he says Horizon is
great, stable and the users have nothing but praise for
it. You can see that in some of the documents you've
provided for me. The Suzie Kirkham note is clear that
we have -- that Fujitsu has a strong body of evidence
that there are no integrity issues. And then, when you
get each of these events, like the Channel 4 programme
you referred to and this, it's made clear by senior
executives inside Fujitsu, and I think, also as I said
from the customer, that there is no issue.
In quite a few places in your witness statement you rely
on assurances from the Post Office that there aren't
issues.
Yes.
Isn't that looking at it from the wrong way round?
No, I don't believe it is.
We saw, for example, in 2009 Gareth Jenkins providing
that Fujitsu integrity report. So there's certainly
information going from Fujitsu to the Post Office to
reassure them about the integrity of Horizon. So isn't
saying Post Office didn't raise any problems, isn't that
the tail wagging the dog?
My view, Mr Blake, is system integrity relies on two
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fundamental components: the first one is that the
supplier must do their utmost to make sure that system
works and to monitor it accordingly and, at the same
time, it is the responsibility of the customer also to
take seriously the issues that are raised by their
customers. And when you put those two things together,
as it did for the vast majority of customers that
I engaged with, that worked.
So it is the responsibility of both organisations to
make sure that this system works and to engage with each
‘other genuinely and openly when there are issues.
In terms of your organisation, providing that
reassurance, where were you getting that from?
I was getting that up the line but, if I take a step
back, so I could have been made aware of integrity
issues in a number of ways: so our governance processes,
through escalations up through the line, either the
technical line or the business line that reported to me,
and I was getting blanks from each of those particular
lines, where I could have been alerted, or more to the
point, I was being given a reassurance.
Who by?
Well, you can see some of the names we've discussed so
far, who have been referenced in the documents so far
today.
153
I'm not sure I would call my relationship with Mr Young
close in a chummy way, and you can see from some of the
documentation this morning that it was the opposite of
that at times.
Who was Stephen Long? Can you remind us?
So if my memory serves me correctly, at this point,
Mr Bounds has moved off the Post Office Account,
post-the successful deployment of Horizon Online, and is
doing another role inside the Private Sector Division,
and he has been replaced by Mr Stephen Long.
Thank you. The Inside Out South report is the Nick
Wallis report where it begins with looking at Seema
Misra's case, so the case that we've already seen
referenced in that email.
Yes.
She was in prison at the time, it has her husband crying
in that programme; it then moves on to Jo Hamilton's
case and interviews her; complaints about your product,
the Horizon system; also interviews with Parliamentarian
James Arbuthnot expressing his concerns. I think you've
said in your statement that you don't recall watching
that programme: is that right?
That is right.
Again, the Managing Director of a company that provides
a system that is at the centre of the complaints linked
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We'll look at more but let's say at this stage who, in
particular, are you getting reassured by?
Well, I'd say, so far, principally, you can see two
people. You can see Mr Bounds and you can see Mr Young.
So Mr Bounds from the Fujitsu side and Mr Young from the
Post Office side?
Yes.
Could we please turn to FUJ00174417. We're now in
February 2011. You're still Managing Director, you
haven't yet become CEO at this stage?
That's right.
An email from Mr Young to yourself and also to Stephen
Long and it says:
"Guys
I need you to take a look at this if you haven't
seen the programme already.”
He forwards you the link to the Inside Out South
programme. He says this:
"Undoubtedly, Horizon integrity remains a core to
‘our safe operation and, to date, nothing has surfaced
that suggests there is any evidence that the system is
flawed in any way. Can we briefly just talk through
these latest developments."
Now, first of all, "Guys", quite an informal, close
relationship, it seems?
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to a BBC article -- so not just now a small trade
magazine of any sort, a respected national
broadcaster --
Yes.
-- why is it that you wouldn't have looked at that?
I think it's in that the paragraph, just underneath the
link to the iPlayer, in the second line, you can see --
well, sorry, let me read:
... nothing has surfaced to suggest there is any
evidence that the system is flawed in any way.”
Mr Blake, this isn't from someone relatively junior
in the Post Office; this is the Chief Operating Officer
of the Post Office.
But the reporting is about your product. How is it that
you don't have curiosity about what the BBC are saying
about your own product, irrespective of what the client
is saying?
Mr Blake, I think I showed curiosity in my job day to
day and had this have had a sense in here that I should
have dug further, after being reassured now on several
occasions there were no issues, this does not tell me,
"Duncan, you need to take a deeper look into this".
Particularly, I am being reassured by a very senior
customer.
We saw at the very beginning that chart that showed the
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important customers for Fujitsu, the £30 million plus
customers: a very small number of customers. Was there
regular reporting about your other customers that's
critical of your product?
I would have issues raised to me quite regularly and,
depending on how they came to me and my assessment then
from what I saw, I would intervene. I intervened during
this period of time, personally, on a very serious issue
with Thompson Reuters, which meant that we ended up
between the two of us cancelling our agreement.
I remember another issue with a customer where
there'd been one issue in an account balance in about
10 years that was escalated to me and that was one issue
in 10 years, and we resolved that issue within about
three weeks.
Had those been raised by Computer Weekly, you being
a computer firm; had they been raised by the BBC, the
national broadcaster?
On the second example I gave to you then, no, it hadn't,
because the customer had spotted the issue with
an account balance and brought it to Fujitsu's
attention. On the first matter, I believe the Thompson
Reuters issues were in certain trade press, but I can't
recall.
Here we are, the BBC having an entire episode dedicated
157
a receipts and payments mismatch and also resulted in
discrepancies being lost."
Just pausing there, before you made a distinction
between issues relating to Legacy Horizon and Horizon
Online, now we have an issue with Horizon Online.
Okay.
Rollout has taken place by this time:
"The background to this is the fact that there was
a BBC documentary broadcast on Monday, 7 February 2011
reporting on postmasters being unhappy about being
pursued for losses by postmasters on Horizon.
"It should be noted that the issues described here
relate to [Horizon Online] and that the implementation
of the accounting mechanisms in the two systems is
totally different (but they do produce the same reports
and support the same business process)."
If we go over the page, there is a summary of what
the receipts and payments mismatch is. The first bullet
point says:
"There will be a receipts and payments mismatch
corresponding to the value of discrepancies that were
‘lost’.
“Note that if the user doesn't check their final
balance report carefully they may be unaware of the
issue since there is no explicit message when a receipts
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to the cases of subpostmasters, including one who was
currently in prison. On reflection, was that not a link
that you should have pressed, not just in hindsight, but
simply knowing what you knew at the particular time?
I wished I had looked at this. It might have given me
a different perspective. But, at the time, both through
my -- the line through to me and the line from the
customer to me, and our business assurance systems,
there were no red flashing lights that said I should get
involved any more than I did.
Do you not see that as a lack of curiosity at this time,
given that you were sent that link?
No, because of the sentence that's immediately
underneath the link.
I'm going to take you to some documents that are around
the same kind of time, so we can see what was going on
at Fujitsu around that time. Can we start with
FUJ00081527. So this is 11 February. It's a report
that has been written by Gareth Jenkins on what is known
as the receipts and payments mismatch bug,
“Introduction”:
"The purpose of this note is to document a request
we have had from Post Office in terms of presenting
details of what happened as a result of a bug in
[Horizon Online] in September 2010 which caused
158
and payments mismatch is found on the final balance ..."
Then three bullet points:
"The local suspense will have no knowledge of this
specific discrepancy.
"The opening figures for the discrepancies in the
new period will be zero rather than the actual value of
the discrepancy.
"[Third] The data used for the BTS will also have
a zero value for discrepancies at the end of the period.
When the BTS is produced, this will result in a similar
receipts and payments mismatch."
At the bottom of the page here, it says:
"The problem appears to have affect 62 branches and
details have been provided to Post Office Limited of all
the BTS and SU Rollover Reports for these branches until
they were clear of the issue."
Looking at this, it seems as though certainly
Fujitsu were aware of a bug that affected accounting
integrity in 62 branches; would you accept that?
Yes.
Was this something that you were aware of at the time?
I was not.
Could we please turn to POL00028838. This is an earlier
report from 2010 on the same issue: the receipts and
payments mismatch issue. Can you assist us, in terms of
160
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the attendees, were there any there who were
sufficiently senior to report to you?
No.
We can see for example, Mike Stewart, "Fujitsu SDM"; can
you assist us with what the "SDM" might be?
That I believe stands for Service Delivery Manager.
Thank you. So none of those people would report to you.
Would they in some way be in the reporting line to you,
though?
This is in 2010, I think you were saying.
Yes.
No, the way Fujitsu UK were structured then was that the
technical resources worked for outside of my line, so
they reported -- there were two divisions that I think
were relevant to Post Office. There was the
Applications Division and there was a division called
CORE. This where all the technical and monitoring
people who run the services, they were based in those
two divisions, I run private sector, and those three
divisions report directly to Mr Gilbert. So the
technical people would not report to me until I was made
CEO of Fujitsu.
So up until April 2011, they wouldn't report to you but,
by April 2011, they would all report to you.
That is true.
161
Solution One, and that was:
"Alter the Horizon branch figure at the counter to
show the discrepancy. Fujitsu would have to manually
write an entry value to the local branch account.
"Impact -- When the branch comes to complete next
trading period they would have a discrepancy which they
would have to bring to account.
"Risk -- This has significant data integrity
concerns and could lead to questions of ‘tampering’ with
the branch system and could generate questions around
how the discrepancy was caused. This solution could
have moral implications of Post Office changing branch
data without informing the branch."
Now, this is the 2010 document, and we've also seen
the 2011 document.
Yes.
As Managing Director in 2010, or as CEO in 2011, would
you have expected that the receipts and payments
mismatch issue would have been brought to your
attention?
I would expect discrepancies of this nature to have been
raised up the line inside Fujitsu, yes.
Would you have been expecting them to be raised along
the line to you?
Yes.
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Yes. This is detailed in the other note that I've taken
you to, the later note, but I'll just go through a few
points in this, and this is a document the Inquiry is
very familiar with, "What is the issue’
"Discrepancies showing at the Horizon counter
disappear when the branch follows certain process steps,
but will show within the back end branch account. This
is currently impacting ... 40 branches.”
So in 2010 it was only 40 branches and then the
number seems to have grown on the --
Yes, okay.
Can we go over the page, please, "Impact":
"The branch has appeared to have balanced, whereas
in fact they could have a loss or a gain.
"Our accounting systems will be out of syne with
what is recorded at the branch.
“If widely known could cause a loss of confidence in
the Horizon system by branches.
“Potential impact upon ongoing legal cases where
branches are disputing the integrity of Horizon data.
“It could provide branches ammunition to blame
Horizon for future discrepancies."
If we scroll down, we see there various solutions
that are proposed, and one that the Inquiry has looked
at in quite a lot of detail is that first solution,
162
Is that both in 2010 and in 2011?
Yes.
Why do you think it was that it wasn't raised with you?
1 do not know. And it looks -- and Mr Blake, I can --
just to make sure I understand the document correctly,
this also looks like this is Post Office personnel on
here as well as Fujitsu personnel --
That's correct.
-- and that could have triggered an escalation, either
up the customer organisation or up the Fujitsu line.
Yes, and doesn't appear to have?
No.
We're still looking at exactly the same time period.
Could we please turn to FUJ00156432. You'll recall the
receipts and payments mismatch document from Gareth
Jenkins was 11 February 2011.
Yes.
The first one that I took you to. I'm going to be
sticking to 11 February 2011, and we have there another
report that has been drafted by Gareth Jenkins and this
is in relation to an ongoing court case. It says:
"I have been asked by Post Office Limited to produce
a [report] to ‘Technical expert's report to the court
prepared by Charles McLachlan, a Director of Amsphere
Consulting Limited’, which I received on Thursday,
164
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11 February 2011."
I think it is your evidence that you had no idea, at
this time, that that was going on, that Mr Jenkins was
at assisting in court cases providing evidence,
responding to, in this case, an expert's report.
Yes.
That was the case of McQue. Could we please turn to
POL00329433. We're still on 11 February. It seems
quite a busy day. POL00329433. This is a letter
produced by the Criminal Law Division of the Royal Mail
Group to a defendant in a criminal case, so that's
Ms McQue, Carlisle Crown Court:
"As you are aware when the matter was last before
the court the court ordered a final defence expert
report", et cetera.
If we go down to the bottom of the page, it makes
clear in this letter that:
"Although the prosecution and defence experts have
endeavoured to produce a joint report this cannot be
agreed.”
So the experts have produced their reports and
they're in disagreement about the Horizon system?
Yes.
Could we please turn to FUJ00156443. We're still on
11 February. I'm not suggesting you saw this particular
165
it's your evidence that you weren't aware of that?
That is also true.
Could we turn to FUJ00153750. This is all -- even this
email, the end of this chain, is the same date --
11 February 2011.
Okay.
So this is still while you are Managing Director of the
private part of Fujitsu --
Yes.
-- with Post Office as one of your main clients?
Yes.
If we please turn to page 3., back to 7 February, so the
day of the BBC broadcast, and this Penny Thomas; did you
know Penny Thomas?
No, I did not.
No? She, if we scroll down, was a Security Analyst at
Fujitsu. She is emailing colleagues. If we scroll up
we can see to Gareth Jenkins, and others. We have
already seen Jean-Philippe Prénovost's name, I think he
was a lawyer. Do you recognise any of those names at
all?
I think the only name that would have been somewhat
familiar at the time would be Guy Wilkerson.
Why would his name have been familiar?
I think he was based in London.
167
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document at all. This is Post Office --
Okay.
-- correspondence, a Royal Mail correspondence.
Again, more Royal Mail correspondence, this time in
the case of Humphrey, same date. The letter says as
follows:
"Both defendants pleaded guilty on 11 December 2009,
however the calculation of the total loss was disputed
and the case proceeded to a Trial of Issue ..."
That finally came before the court and it outlines
there the sentence that was imposed. So Mr Humphrey was
sentenced to 27 months’ imprisonment; Mrs Humphrey was
sentenced to 18 months’ imprisonment. If we scroll down
please, we can see in the letter the lawyer from Royal
Mail says:
"This is another case where Horizon was challenged
which resulted in a considerable amount of additional
work by Gary Thomas. His efforts, together with those
of Gareth Jenkins (Fujitsu), are evidenced by the
successful outcome in this case."
So it’s very clear that on 11 February, or on or
around 11 February, there is direct assistance from
Fujitsu
Yes.
-- in relation to criminal prosecutions, and I think
166
Penny Thomas says as follows, she says:
"All
"There was an interesting article featured on the
local radio station, BBC Surrey, this morning and
I listened while travelling to work.
"Misra, a convicted subpostmistress, now pregnant
and serving a jail sentence in Bronsville [sic] Prison
for theft and false accounting from the West Byfleet
Post Office and 55 other subpostmasters/mistresses are
planning to take civil action against the Post Office
because of the flawed accounting system used at the Post
Office outlets. There are to be 6 test cases, South
Warnborough was identified as one.
"There was an emotional interview with Davinder
Misra (the husband) who stated that the system was
losing money right from the beginning, they couldn't
find the problem, and neither could the auditor who was
sent from the post office.
"A spokesperson from the Post Office stated that the
Horizon system was ‘absolutely accurate and reliable and
all times’. Robust testing procedures had been
undertaken.
"Jonathan Lord, MP for Woking is concerned and will
ensure a full financial investigation, absolutely
independent, is carried out. He stated that the
168
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processes which the Post Office employed where
discrepancies arose should be fair, and conducted in
a prompt and proper way; these Post Office procedures
are to be looked at closely."
If we scroll up we can see that Jean-Philippe
Prénovost has sent that on to David Jones, who was,
I think, the Head of Legal at Fujitsu; is that right?
I think the Head of Legal at that time would have been
David Roberts and Mr Jones would have reported directly
to him, I think.
Thank you. He says:
“Further to Penny's email below, we've been informed
that [the Post Office] are making noises about
commissioning an independent evaluation of the Horizon
system with a view, presumably, to putting all integrity
issues to bed once and for all.
"The team is not at all inclined to accept this
request (especially bearing in mind that the system is
now defunct) but they have sought official guidance on
how they should deal with the request. Given the link
with ongoing/potential litigation, are there any
particular issues you will be concerned about and would
like to raise at this stage?”
So Penny Thomas, from this, a security analyst, has
heard the BBC report.
169
"Hi David,
"The suggestion (I understand it has not been
officially requested) has come directly from Mike Young
(the highest level of engagement).
"We are of course aware of the contractual
obligations and, as this does not form part of them, the
team would be more interested in any other
considerations."
So it seems as though the request has come directly
from Mike Young, he was one of your direct liaisons,
wasn't he?
Yes.
So how is it that you were not aware of that at this
time?
I don't know.
I mean, something seems to have gone fundamentally wrong
at Fujitsu for this level of information not to be
provided to you, hasn't it?
I would have expected Mike to come to me or the then
leader of the Post Office Account from Fujitsu with that
request.
\s it likely that he did go to the leader of the Post
Office Account and it simply hasn't, for some reason,
been raised with you?
There is a possibility of that but I just don't know.
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Yeah.
I think you said you weren't even aware of the report,
other than the link being sent to you; is that right?
That is right.
Were you aware, at this stage, of the Post Office making
noises about commissioning an independent evaluation of
the Horizon system?
I was not.
Is that surprising, given that you were the Managing
Director of a division where Post Office was one of your
key clients?
I had regular meetings with Post Office, as I think the
Inquiry can see, and I would have imagined they would
have brought that up with me.
Is it strange that a lawyer within Fujitsu would be
aware of that but you would not be?
I just -- I don't know, Mr Blake. You'd have to ask
them.
If we scroll up, please, email from David Jones, saying:
"Hi -- have you looked at the contract and our
security service obligations? I expect there will be
some cooperation obligations ...
"Who is making the request from [the Post Office]
and is it at the right level of engagement?"
If we scroll up above:
170
If we scroll up, the response is:
"You are aware that we have or had a banking
indemnity in place that would mean, if I recall it
properly, that if the outcome of the investigation were
adverse that Fujitsu might have some liability to [the
Post Office]."
Pausing there, as Managing Director, would it not
have been important for you to have been aware that
potentially Fujitsu was on the line for some liability
in respect of these issues?
I think our view, or certainly my view, would have been,
if there was an issue with the software that's causing
counter balance issues, which then leads to people being
prosecuted, it didn't matter what the consequences were;
we should have got to the root cause of that.
Why, as at 11 February 2011, do you think that wasn't
happening?
I do not know.
Then he raises clause 16, and 16.3, says:
"Fujitsu Services shall offer all reasonable
assistance to Post Office in preventing fraudulent use
of the services, the HNG-X development, the Associated
Change Development, the Horizon Service Infrastructure,
and the PostShop infrastructure by Post Office's
employees and agents.
172
(43) Pages 169 - 172
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"Surely this means we can't refuse their request in
any event..."
So it certainly looks as though, within the Legal
Team, they think that if the Post Office are requesting
an independent investigation, you couldn't refuse that
request.
If we scroll up, there's just a discussion of
whether or not that means that Fujitsu can refuse.
Okay. Mr Blake, I think around this time, if I may,
I was also involved in a negotiation with another
customer that did involve Fujitsu exiting an account,
and cost about £38 million. It was the right thing to
do for both the customer and for Fujitsu. It generally
takes a more rounded view to come up and -- to
a conclusion on a purely legal view.
What is the relevance of that?
Well, the relevance of that is that, where there were
issues, Fujitsu faced up to them.
But it seems, from your account, you weren't aware of
the issues?
I was not aware of -- I was not aware of this --
I mean, we've seen --
-- on Post Office -.
-- article, after article, after article, how can it be
that, at this stage, you weren't aware; what went wrong?
173
FUJ00174418 is simply a covering email from Charles
Matcham, who was within your division; is that correct?
Yes, he was.
“Draft Letter to Paula":
"Needs work but you get the idea ..."
It was sent to you and others. I'd like to take
you -- so that's same day, 11 February 2011, so the same
day as all of these other things that I've been showing
you --
Yes.
-- were going on. A day when Gareth Jenkins wrote those
two reports that we've seen?
Yes.
‘A day when there's various discussions going on about
an independent investigation being carried out and
whether that has to take place. The day when Royal Mail
is drafting memos about success being down to, amongst
other things, Gareth Jenkins’ efforts from Fujitsu.
Okay.
Let's look at the draft letter. That's FUJ00174419:
"Dear Paula,
"I thought the timing was appropriate to write to
you and inform you of our plans and objectives for the
account and take the opportunity to introduce the two
senior executives appointed to support your business and
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It is difficult to -- it's difficult to say -- for me to
comment. We had good governance in place, we had good,
open lines of communication with the customer, we had
the opportunity to escalate up and down the
organisation, so difficult for me to say.
You've got here people who were actually involved in the
prosecution of subpostmasters, so we've got Gareth
Jenkins, Penny Thomas, all in this email chain, all
aware of the BBC reporting. So they had been involved
in Seema Misra's case, as an example?
Right.
How can it be that somebody from that team didn't raise
it up to the Managing Director?
I do not know how it did not come to my attention, nor
up the other line to the then CEO of Fujitsu, to Roger's
attention either.
We've looked at a lot of correspondence from
11 February. I'm going to stay with 11 February and
I want to look at correspondence that was actually going
to Paula Vennells at the Post Office.
Okay.
So could we start with FUJ00174418. Alll this is is
a covering email. You've seen the draft letter to Paula
Vennells, you address it in your witness statement.
Okay.
174
lead on behalf of Fujitsu."
It continues, I won't read it all, but perhaps we'll
look at the paragraph that begins:
“Back in August 2010 I attended a video conference
with your predecessor ... Amongst other important
matters, a paper previously submitted to David was
discussed and endorsed. The brief document set out the
principles of working jointly to explore the mutual
benefits of developing our existing Horizon Online
contract to ensure future alignment to Post Office
strategic plan."
So discussing potential future avenues of business.
Yes.
".., Fujitsu has proactively invested in the development
of a compelling proposal through a dedicated team
working out of our Centre of Excellence in Slough. Our
intention is to present our proposition to you in early
March and gain your agreement ...
"To facilitate this Fujitsu has assigned two senior
executives ..."
Then it goes into or proposes a brief summary of
their experience and expertise, as set out.
If we scroll over the page you can see it's been
drafted in your name.
I think you say in your witness statement that you
176
(44) Pages 173 - 176
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recall sending a letter along these lines.
A. Ido.
Q._ Yes. The focus in that letter is on future work
together, isn't it?
A. itis.
Q._ There's nothing in there about recent press reporting of
the type that we've just been seeing?
A. agree.
Q. There's nothing in there about complaints from
subpostmasters about accounting integrity or anything
along those lines; is that right?
A. That is right.
Q. Nothing in there about prosecution support?
A. That is also right.
Q. Could we please turn to POL00017555. I'm sticking now
with what you might call general picture at the time.
You're not copied into this email, this isn't something
you would have seen at the time, but just to see the
kind of work that, on 14 February -- so a few days
later -- Gareth Jenkins was involved in. We're still on
the case of McQue and he is referring to the expert
reports. He says:
"That is the information I have given to Charles
about Callendar Square."
Were you aware of the Callendar Square bug at this
177
SIR WYN WILLIAMS: Mr Blake, I'm getting a bit anxious about
when the second break is --
MR BLAKE: Yes, that is actually a convenient time. So we
could take it now.
SIR WYN WILLIAMS: Yes.
MR BLAKE: Could we come back just before 4.00?
SIR WYN WILLIAMS: Yes.
MR BLAKE: Yes, 3.57, please. I need those three minutes,
if that's okay.
(3.47 pm)
(A short break)
(3.57 pm)
MR BLAKE: Thank you.
Mr Tait, I'm going to move to 2012, so about a year
into your time as CEO. Could we please look at
FUJ00168511. 13 April 2012. Gavin Bell, who is,
I think, a member of the client Executive Team; is that
right?
A. Yes.
Q. He has met Paula Vennells on the train and spoke about
number of points and it's the third point I'd like to
draw your attention to. He says:
"She then asked about some of the recent systems
incidents and transaction integrity. I have provided
a very high level response of how the Reconciliation
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time?
No.
“I have not sent him anything further since it is
irrelevant to this case (as he accepts). However his
point is that if we had an accounting discrepancy in
Callendar Square, then that implies that it is possible
to have an accounting discrepancy in Rinkfield", which
is the particular branch.
Okay.
"I have to accept that that is possible. However the
Callendar Square issue as such is irrelevant in
Rinkfield and this is accepted by Charles."
So an acceptance there by Mr Jenkins that the bug in
Callendar Square is essentially relevant, insofar as it
implies that it's possible to have an accounting
discrepancy elsewhere, even if that particular bug is
not the one in play.
Okay.
Okay. But these weren't issues that you were in any way
aware of in 2011?
You are right.
Could we turn, please, to POL00017555.
Sorry, actually, I'm going to move on to -- so you
became CEO in April of that year?
OF 2011, yes.
178
Service we provide catches any issues and offered her
and Lesley Sewell a visit to Bracknell to meet [the]
team. She then went on to say that she has had
enquiries from Oliver Letwin MP ... and James Arbuthnot
... about system outages and a [Freedom of Information]
request on a particular subpostmaster. She said that
she might invite Duncan to a meeting with these MPs when
she meets them next."
Do you recall that, within that time during the
first year of your time as CEO, the key client was
raises issues to do with Horizon integrity?
If that question, Mr Blake, is do I recall this
conversation with Mr Bell, I do.
Did that make you take any additional steps? We've
heard that no investigation had taken place at Fujitsu
up until that point. Did that trigger any particular
investigations?
Again, I think if you read the second sentence in that
paragraph, it's "I provided a very high level response
about how the Reconciliation Service catches any
issues". So I think, from reading that, that sentence,
that doesn't say to me that we need to take any further
investigation.
But, if your key client raises in that particular
conversation, issues to do with transaction integrity,
180
(45) Pages 177 - 180
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was that not something, given all the history we've been
through already, something to look into a bit further at
that stage?
If Ms Vennells was not satisfied with Mr Bell's response
to her questions, I believe they were on the train, then
she could have come directly to me.
Can we turn to FUJ00168523. We're in June 2012 at the
bottom email, please. "Urgent Post Office BBC". You
email Simon Carter; who was Simon Carter?
By then, I believe Simon Carter would have been the head
of marketing for Fujitsu UK.
"... there's an article on BBC regarding Post Office and
concerns over the Horizon system. It's an old
allegation which I believe is totally false, however, it
is on the news.
"Can you alert the IB ..."
What was IB?
That was the -- Fujitsu was split in -- essentially
then, into Japan and outside of Japan, and the bit
outside of Japan was called International Business or
IB.
"Can you alert the [International Business] and Japanese
teams please. I suggest we ensure that we are aligned
with [Post Office] press team and also have a drawer
statement ready to go."
181
you to Helen Lamb. Who was Helen Lamb?
Helen Lamb, at that point, would have been running
a division called Business and Application Services,
which is where the Horizon code would have been run out
of.
"Helen, what's this POL stuff about please?”
Do you recall the answer to that?
I don't recall the answer. I vaguely recall sending the
email but don't recall the answer.
In your statement, and today, Ill read a few passages
from your statement.
Okay.
You know the evidence you've given today but you said,
for example, "I received repeated assurances", Post
Office was confident internally, and Post Office
reassured you?
Yes.
We've seen here article, after article, after article,
mentions of Members of Parliament, BBC, Computer Weekly,
you being a computer company. Did you ever, in that
period, seek to investigate whether there was any
substance in those reports: a significant investigation,
not just reassurance from an individual?
Yes. Mr Blake, I'd go back to what I said before, that
when I joined, I had the Kirkham email that brought --
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Drawer statement, is that not suggesting something
new, but a standard statement?
I think it is a pre-prepared statement, is the way
I understand drawer statements.
"It is an old allegation which I believe is totally
false ..."
Did you, at that point, instigate any new
investigations internally?
I don't believe, as a result of this, no.
That's another BBC report, national report, on Horizon
integrity. I'm going to take you to another report, six
months later. Can we please turn to FUJ00174576. News
Summary, if we scroll down, sticking to that page,
Wednesday, 2 January:
"Computer Weekly -- Post Office admits that the
Horizon system needs more investigation.
... Years of struggle from campaign groups has
forced the Post Office to look again at a computer
system which has been blamed for subpostmasters being
wrongly accused of false accounting. Despite numerous
complaints the Post Office has consistently stated that
there is no fault with the Horizon system. But
[subpostmasters] claim problems with the technology
could be generating unexplained losses."
We see at the top of the page, please, an email from
182
stated no issues. The recollection -- the email from
Mr Bounds after his meeting with Mr Young, that said
Horizon was great, stable and that the users only had
praise for it. And then when each of these media events
happened during 2010/early 2011, you can see in those --
in each one of those, it is no cause for concern, no
cause for immediate concern, no flaws in the software
from Mr Young's email to me in early 2011. It would
have been unusual, I think, to have conducted further
research at that point when you had that level of
reassurance.
Why would the national media be so wrong about it?
I mean it's like Groundhog Day. It's year, after year,
after year, exactly the same thing comes up. There's
a national report about Horizon integrity, and all there
is is an email with a line that says everything is okay.
Why wouldn't you, as Managing Director, and then CEO,
not actually put in place a significant investigation
into that issue?
Mr Blake, we had good governance in place. We had
delivery assurance in place. We had assurance teams to
govern new customer opportunities and the extensions of
Horizon over time. We had Audit and Risk Committees in
place and each one of these could have brought to the
attention of the -- to Fujitsu's CEO prior to me and
184
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during my period, that we needed to do something about
it. Now, with hindsight, we absolutely should have done
something about it because the media were absolutely
spot on.
Could we please turn to FUJ00168649. That summer, there
was a meeting with Paula Vennells:
"Detailed below is a readout from the meeting
between Duncan and Paula last night.”
I don't need to take you into any detail in that.
I mean, there's no mention there of Horizon integrity
issues. Is that likely, is that your recollection of
those kinds of discussions you had with Paula Vennells?
Yes. Yes, what you're saying is true.
Again, it's very much focused on new initiatives,
looking forward, rather than looking back at past
problems.
Pretty much. I think in the operations section, you can
see that Paula praised the high quality of our
operational performance, so that is a here-and-now
comment, not about the future.
Can you turn to FUJ00174662, and this the briefing note
for that meeting. There's a section on business as
usual operations. If we scroll down, new initiatives,
scroll down, CSR. There's a section on risk over the
page. Priorities and then risks. Nothing in the risks
185
This goes back, Mr Blake, to what would have happened
with other customers, that if they'd had concerns over
integrity that would have been a very sensible thing to
do. I mean, I don't recall the exact details of the
conversation but that Fujitsu would provide assistance
as necessary.
Can we turn to FUJ00174708, please. It's the bottom of
the page. We're now in July 2013, and there is a report
from your meeting, it says:
"Duncan met Paula Vennells this morning to discuss
the role of Horizon in [the Post Office]'s future
strategy and the IPR issue.
“As part of that Duncan shared the contents of his
brief [including]:
"Horizon is an invested and stable platform
"Very low cost ...
"Second Sight has shown it to be safe, secure
“Benchmarked
"We have an industry littered with disasters of
service outages, programmes taking twice as long as
planned with massive costs where organisations have
replaced systems ...
"There was quite a lot of discussion around this and
Paula said ... ‘that all sounds good but why do my team
tell me that working new reference data through the
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section about issues with Horizon integrity or
complaints from politicians or the media. The only
point in this that relates to those kinds of concerns is
the very bottom. We can see at the bottom of the page
there is reference to Second Sight:
"A number of queries have been raised, all of which
have been answered and no irregularities identified.
One allegation is proving more challenging relating to
a suggestion that alterations to the branch database
holding subpostmaster balances could be made on Fujitsu
premises."
So that's the remote access issue:
"We have been asked to provide further details
related to systems controls/access and audit records for
balance corrections. This will be available next week."
So, again, no significant issues being raised in
that meeting. Do you recall any meeting between you and
Paula Vennells at which serious issues relating to
complaints from subpostmasters or relating to the
integrity of Horizon were raised?
The time I recall would have been when Ms Vennells said
that she would -- she had had complaints around
integrity and would have to commission an independent
review.
What was your response to that?
186
system take a long time and the platform is not agile’."
Then it sets out some responses. Just pausing
there. Do you recall ever giving bad news to Paula
Vennells about the integrity of the Horizon system or
bugs, errors and defects with the Horizon system?
I don't think any of my briefs gave me data that that
would have pushed back on Ms Vennells in that regard.
I think you can see, Mr Blake, in other conversations
that Ms Vennells and I had, that they were robust.
As robust as the system? When you say they were robust,
I mean, let's look at that penultimate sentence:
"I'm not sure if this is a difficult task or not but
as you well appreciate we have to respond to this with
some urgency and the story needs to be good."
The suggestion being that one of your most important
clients needs to be told a good story and that there is
some reluctance within the company to share bad news.
Was that something you experienced or not?
No, we had very robust conversations between the two
organisations and my understanding is this here refers
to the agility of the system.
We can see the response. That's at FUJ00174721:
"Paula
"Thank you for taking the time to meet me on
Thursday [this is 8 July] ...
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"Overnight pricing changes are now possible ...
"We also have made good progress ‘opening up
Horizon'."
Then I'll take you to the final paragraph:
"As I followed up on the questions you raised it
became evident to me that close collaboration between
‘our teams is working well. Horizon is evolving at pace
to better position the Post Office for [enhancing]
agility and growth. Therefore, it might be worth
organising a briefing for your key executives on
Horizon's new capabilities and planned enhancements.”
It's again looking to the future and what can be
achieved from Horizon.
Given all the things that we've discussed, all those
newspaper articles, media reports, why do you think it
is that we don't see those kinds of matters being raised
in depth and discussed between you, real concerns, you
reassuring Ms Vennells, for example, about issues of
system integrity; do you think those exist, those
emails?
A. I don't know, Mr Blake. Can I just check the date of
this exchange, please?
Q. This is 8 July 2013.
A. 8 July 2013, and the Second Sight investigation is up
and running at this time?
189
Q. What about the media reporting and those issues that are
raised there, complaints from subpostmasters? Do you
think that was ever discussed in-depth with your -- with
Ms Vennells?
A. I don't believe that was discussed between me and
Ms Vennells.
Q. The various emails we've seen today about bugs, errors
and defects, you've said you weren't even aware of them,
let alone being able to pass those on to Ms Vennells?
A. lagree.
Q. Two very quick topics, the first is prosecution support.
SIR WYN WILLIAMS: Before we get there, Mr Blake, the
8 July, actually, Mr Tait is the date that Second Sight
published its Interim Report. Was that sent to you on
or about that date?
A. I've never seen the report, sir, only a feedback from
members of my team based upon what Post Office
personnel -- I think Ms Sewell -- had given them.
‘SIR WYN WILLIAMS: Right. All right, thank you.
Sorry, Mr Blake. Carry on.
MR BLAKE: Not at all.
Prosecution support. Did you know that Fujitsu
provided what we know as ARQ data, audit data, to the
Post Office?
A. Not until after I left Fujitsu.
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Yes.
And I have the previous month had an email from a James
Davidson, the talks about the initial findings from
Second Sight, and it is another reassurance for me about
how Horizon is working.
But these are all external reassurances. Nothing within
Fujitsu. Nothing has been set in train within Fujitsu
to investigate those various complaints, and nothing
being passed from you to Ms Vennells about reassurances
regarding the system.
I mean, let's look at the response. If we turn to
FUJ00174724. 8 July, this is the response at the bottom
that's been sent on Paula Vennells' behalf. The series
of emails that the Inquiry has seen to date are all
looking at small improvements perhaps, looking at future
work together but there doesn't seem, certainly from
what we've seen so far, to be any detailed
correspondence between you and your equivalent at the
Post Office about these Horizon integrity issues.
Is that, do you think, because they don't exist or
because we haven't yet seen them and do they exist?
What is your recollection of this period of time?
I don't believe there is email correspondence between
Ms Vennells and I regarding integrity issues but I don't
know.
190
What was your understanding of the role of Gareth
Jenkins while you were at Fujitsu?
I was not aware of Mr Jenkins’ role while I was at
Fujitsu.
Could we turn to POL00382242, please. This is a Post
Office document, so I don't expect you to have seen this
document but it is a brief for a meeting with yourself
‘on 11 November 2013. I believe you've only seen it very
recently.
It's the final page I'd like to take you to and the
last two paragraphs. Were you aware of something called
Project Sparrow at the Post Office?
I don't believe so.
Within this brief, it says:
"The Post Office Criminal Law Team needs to find
an independent expert to give evidence about the Horizon
system which was previously provided by Fujitsu's Gareth
Jenkins.
"Lesley and Susan Crichton have raised this with
Fujitsu. The Legal Team have a meeting arranged with
Fujitsu to discuss this requirement, this will happen on
21 November. Following this we will have a better
understanding of Fujitsu's view, any impacts and what
the next steps will be.”
First of all, do you recall a meeting on 11 November
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2013?
I don't, no. I do remember, at the time, we had
an issue with this home phone and broadband contract
that was causing a great deal of tension between Post
Office and Fujitsu.
I think you've said you don't even recall any issues
with Gareth Jenkins. Do you recall, at a meeting,
anybody raising with you the need for a new independent
expert?
I do not.
Remote access, and I can deal with that very briefly.
You address it at paragraph 102 of your witness
statement. I'm not going to turn to that.
Yes.
When did you first become aware of the ability for
Fujitsu to remotely access subpostmasters' branch
accounts?
Mr Blake, I would say, in systems like this, having
a facility called "remote access" or "privileged access"
would have been necessary because problems can occur in
systems like this that would need fixing. So I would
say generally aware from when I first became involved in
Fujitsu.
Can we turn to FUJ00174422. I'm just going to take you
to two documents from 2011.
193
"DT is meeting Paula Vennells and Mike Young on
18 August -- the agenda is the Ernst & Young audit. It
was a key challenge for [Ernst & Young] to audit
a shared service generally. We were really proactive in
helping them through this.”
You recall having a meeting with Paula Vennells to
discuss this issue?
I'm not sure I do but I do recall Ms Vennells raising
the EY audit with me and asking Fujitsu to resolve the
issues prior to her next Board meeting.
I think you say in your statement that you tasked
Mr Bounds with this; is that right?
Yes.
Were you aware of that review actually taking place?
The EY review, or the consequent Fujitsu review?
No, the consequent Fujitsu review.
My understanding is that that review and the actions
were put in place and successfully executed.
Who do you recall carrying out the review?
I do not know who conducted the review.
Did you see the review once it had been completed?
I did not.
Did you check to make sure that it had been undertaken?
\ did.
You did?
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Okay.
This email is 1 June 2011. Do you recall, in 2011,
Ernst & Young recommending a review of what was called
privileged access?
I recall Ms Vennells asking me for our organisation to
take action against the EY audit in preparation for the
next Board meeting.
Yes. So we have, in this email that's sent to you:
"The audit referred to in Mike Young's mail was part
of the annual audit carried out on Post Office by Royal
Mail Group auditors Ernst & Young.”
It sets out the main points. It says:
"In general, Ernst & Young were satisfied with the
robust user management processes for HNG-X system
access. However, observations were made of the user
management processes, specifically with regard to the
segregation of duties between developer and system
administrator roles. It was recommended that a review
of privilege access is undertaken and that the processes
around user management are strengthened."
In your statement, you then refer to another
document, and I'll just take you to that. It's
FUJ00174428, and it's a reference to a meeting with
Paula Vennells. It says, "Info". If we scroll down
slightly, it says:
194
I believe so. I would have managed this by exception
and, if Mr Bounds or the team had not -- had had issues,
then they would have spoken to me about it.
So is it likely that there will be a document in
existence that is around this time, reviewing the issue
of privileged access?
My understanding is there should be some documentation
that shows Fujitsu taking action based upon the EY
report, though I'm not sure I've seen it, Mr Blake.
Thank you. One final document. It's POL00024828. If
we could start on page 5, please. The Inquiry has seen
quite a lot of correspondence about the issue of remote
access in 2014/2015 and we can see, on page 5,
a response from 2014 that had been provided by Fujitsu.
The summary is set out just below. I'll just read out
the first bullet point and that's a summary of Post
Office's understanding of the position based on the
responses that had been provided below from Fujitsu:
"There is no ability to delete or change records
a branch creates in either old Horizon or Horizon
Online. Transactions in both systems are created in
a secure and auditable way to assure integrity, and have
either a checksum ... or a digital signature ... are
time stamped, have a unique sequential number and are
securely stored via the core audit process in the audit
196
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vault."
Were you aware of a dispute between the Post Office
and Fujitsu about the information that Fujitsu had given
relating to remote access?
A. I was not.
Q. If we scroll up, we can see there's an email,
an internal email within Post Office, so, again, you
wouldn't have seen it. It's page 4, the bottom of
page 4. It's an email from Jane MacLeod to Andrew
Parsons, so internal lawyer to external lawyer. She
says as follows:
"Separately, Paula has suggested that she speaks to
the UK CEO of Fujitsu (Duncan Tait), and my suggestion
would be that she:
“Alerts him to the fact and timing of the response
letter ..."
This is a response letter in the litigation.
A. Okay.
Q. "Notes that the question of remote access is still
a live issue and major concern to the claimants
“Notes the work being undertaken by Deloitte to
review access rights and controls
"Expresses the desire that [Fujitsu] (continue to)
work constructively with Deloitte and flags that if the
Deloitte work uncovers a different position to that
197
are all of my questions.
A. Thank you.
MR BLAKE: There are ten minutes of questions from Mr Stein.
Thank you.
Questioned by MR STEIN
MR STEIN: Mr Tait, I'm going to take you to a document
which is FUJ00080526. Can we go straight to page 5,
please, of that document. Thank you.
Now, this document is dated 2 October 2009. It's
drafted by Gareth Jenkins, entitled "Horizon Data
Integrity". Okay?
A. Okay.
Q._ It's a document we know you're familiar with, as you
dealt with it, as you were asked to look at it by the
Inquiry, and you refer to it at page 13, paragraph 36,
of your statement. Okay?
Now, this document had a circulation list that
included Suzie Kirkham who you've mentioned a couple of
times. She's someone that, when you came into your
role, she drew to your attention the fact that there
were issues that were ongoing in the press in relation
to claims --
A. Yes.
Q. - about the integrity of the Horizon system. Okay?
A. Okay.
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which [Fujitsu and Post Office] have publicly stated
‘over the years, then we will need to consider carefully
how to manage the impact ..."
Okay.
Did a conversation ever take place with Paula Vennells
relating to remote access?
I've no recollection of that conversation.
Were you aware at all of the issue of the Post Office
placing blame on Fujitsu for giving an incorrect answer
in relation to the issue of remote access?
Not to my recollection.
My final couple of questions.
The litigation, more broadly: were you aware of
Gareth Jenkins' role in the civil action and the Group
Litigation?
No, I was not.
Did you ever have any discussions with anybody about
whether he should or should not be, for example,
a witness in that litigation?
I did not.
Have you experienced Fujitsu employees being concerned
about being used to give evidence in that Group
Litigation?
No.
MR BLAKE: Thank you. Thank you very much, Mr Tait. Those
p>po>
198
We also know it's a document that is shared between
Fujitsu and the Post Office. All right.
Now, this document, I'll summarise it. At no part
of this document is a mention of software bugs, errors
or defects. It pretty simply says things along the
lines of: if you turn off the system and bring it back
‘on, what happens. It is very technical in that sense.
Okay.
It doesn't deal with software issues or bugs. Now, did
you notice that when you read through this document
after it had been brought to your attention?
So, Mr Stein, you're right: I only saw this in
preparation for the Inquiry, and it seems to be quite
a technical document that describes how integrity is
ensured in Horizon Online. But I had no other
recollection than that.
Right. Well, take it from me: it doesn't refer to
software bugs.
Now, your background work has been in relation to IT
systems; do you agree?
Yes.
Sometime ago, but that's what you've done in the past.
(The witness nodded)
Now, all large-scale systems, such as Horizon have
software bugs, don't they?
200
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They do.
Right. In relation to the Horizon system, Fujitsu
operated a service line at four levels. Part of those
levels were to do with the fixing of software bugs,
issuing patches, notifying the Post Office of those bugs
as it went along; do you agree?
lagree.
Right. So why do you think that this report from
Mr Jenkins does not mention bugs?
I have no idea, Mr Stein. I think it would be
a question for Mr Jenkins.
Right. Well, let's go to the mismatch bug document,
please. The document is familiar to this Inquiry.
POL00028838. Can we go to the bottom of page 3 of that
document. Can we have a look at Solution One. Can we
just refer to that, please.
Now, you'll see it's being said here that there are
three potential solutions to apply to the impacted
branches and then the recommendation is that Solution
Two should be progressed. Now, this is a joint meeting,
as you pointed out to Mr Blake, between the Post Office
and Fujitsu, all right?
Yes.
It's not, as an example, a note of a meeting in a pub
after a few drinks, okay?
201
this as being an option?
No, it is not.
No. Try it the other way round. Are you slightly
surprised about the Post Office considering this as
a possible option in relation to fixing a branch account
for one of their subpostmasters?
I would give you the same answer.
Let's move further up the page, please, to the bottom of
page 2, I think it is, "Impact". Now, let's have
a quick look at the impact section. So this is the
impact of this branch. Now, the mismatch bug, we all
know -- I've described it in earlier questions for other
witnesses -- being a submarine bug. What I mean by that
is it can affect branch accounts and it doesn't appear
to be apparent to the subpostmaster/mistress. So
"Impact":
"The branch has appeared to have balanced, whereas
in fact they could have a loss or a gain.
"Our accounting systems will be out of sync with
what is recorded at the branch.
"If widely known could cause a loss of confidence in
the Horizon system by branches ..."
So this is not good news. Do you agree?
lagree.
Allright. It then goes on to say:
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Okay.
It's a proper meeting between two large organisations:
one a worldwide brand and the other one is a very
well-known UK brand. So let's have a look at the
solutions:
"Solution One -- Alter the Horizon branch figure at
the counter to show the discrepancy. Fujitsu would have
to manually write an entry value to the local branch
account.
"Impact -- When the branch comes to complete next
trading period they would have a discrepancy which they
would have to bring to account.
"Risk -- This has significant data integrity
concerns and could lead to questions of tampering’ with
the branch system and could generate questions around
how the discrepancy was caused. This solution could
have moral implications of Post Office changing branch
data without informing the branch."
All right?
So we can see what's being said here. Let's put it
fairly crudely, if you don't mind. This basically says
‘one of the possible solutions could be, “Let's fix the
branch accounts without telling the branch subpostmaster
and see if we can get away with it". Now, is that what
you expect of Fujitsu staff members, to even consider
202
“Potential impact upon ongoing legal cases where
branches are disputing the integrity of Horizon data
Now, given what we know about this document, which
appears to include a possible fix which, unless I'm very
wrong, would lead to a conspiracy to false account
between two large organisations, what this is saying is
this, isn't it: that, if this gets out, it's going to
muck up legal cases where branches are correctly saying
there's a problem with the system? "We'd better not
tell them", in other words. That's what's being
considered between two important, well-known brands.
How did that happen, Mr Tait, under your lead?
I have no idea, Mr Stein, but this is not how I would
expect either organisation to work.
You've been asked question after question by Mr Blake
here, who has been saying, "Well, what happened? What
happened? Why weren't matters dealt with by your
office? Why didn't you take notice of what was going on
under your leadership?"
Now, there are two answers to this. Either you
failed utterly in your leadership or the staff beneath
you failed utterly to tell you what was going on. Which
answer would you prefer: your failure or your staff's
failure?
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A. I don't think it's a question of which I would prefer.
Well, which was it, Mr Tait?
A. I think, from the documents that were given to me, I was
reassured about Horizon.
2
Q. Reassured by the same people, at least some of the same
people, that were involved in relation to the mismatch
bug and what was going on?
A. I think Fujitsu Executives and Post Office Executives.
MR STEIN: Thank you, Mr Tait.
THE WITNESS: = Thank you.
‘SIR WYN WILLIAMS: I Is that it, Mr Blake?
MR BLAKE: Yes. Yes, it is.
SIR WYN WILLIAMS: = Then, thank you very much, Mr Tait, for
providing your written evidence and for giving oral
evidence during the course of the afternoon. I'm
grateful to you.
THE WITNESS: § Thank you, sir.
SIR WYN WILLIAMS: So tomorrow we have a potentially busy
day again, Mr Blake. I think Mr Ward is first up, and
he is remote; is that correct?
MR BLAKE: That's correct sir, yes.
SIR WYN WILLIAMS: Oh, it is correct. Right. All right,
then. 9.45 in the morning.
MR BLAKE: Thank you very much, sir.
(4.35 pm)
205
INDEX
RICHARD CHRISTOU (sworn) ...
Questioned by MR STEVENS .
Questioned by MS PAGE ... 87
DUNCAN ANDREW TAIT (sworn) . 93
Questioned by MR BLAKE .... 93
Questioned by MR STEIN .. 199
207
19 June 2024
(The hearing adjourned until 9.45 am the following day)
206
(52) Pages 205 - 207
MR BLAKE: [20]
92/19 92/21 92/24
93/4 140/7 140/10
140/12 140/14 140/18}
140/20 179/3 179/6
179/8 179/13 191/21
198/25 199/3 205/12
205/21 205/24
MR STEIN: [2] 199/6
205/9
MR STEVENS: [20]
113 115 1/7 1/11 113
116 34/10 34/12
43/18 43/21 44/2 44/5
62/24 63/1 83/6 86/19
86/23 87/5 92/4 92/14
MS PAGE: [3] 87/9
87/11 91/25
SIR WYN WILLIAMS:
[38] 1/4 1/6 1/10
1/12 34/8 34/11 43/20}
43/22 44/4 62/5 62/16
62/19 82/9 82/19 83/1
83/5 86/22 86/25 87/6
92/2 92/7 92/15 92/20
92/23 93/1 140/9
140/11 140/13 140/19}
179/1 179/5 179/7
191/12 191/19 205/11
205/13 205/18 205/22
THE WITNESS: [3]
43/23 205/10 205/17
"43 [1] 101/8
"98 [2] 45/3 47/21
"99 [1] 51/22
‘absolutely [1]
168/20
‘Executive [1] 124/18
‘Fujitsu [2] 69/20
128/16
"Horizon [1] 104/21
"If [1] 120/6
‘It [1] 119/20
‘levers’ [1] 127/17
‘lost’ [1] 159/22
‘no' [1] 136/4
“open [2] 128/24
135/16
‘opening [1] 189/2
‘owning’ [1] 135/25
‘robust’ [1] 32/5
"s [1] 187/11
"sea [1] 135/10
‘tampering’ [2] 163/9
202/14
‘Technical [1] 164/23
“that [4] 187/24
"We [14] 150/11
-- they [1] 23/17
0
0.1 [1] 45/2
=
1 April [2] 25/7
122/18
1.30 [4] 92/14 92/15
92/18 92/24
10 [1] 5/2
10 December [1]
109/1
10 May [3] 51/24
131/20 135/10
10 years [3] 102/22
157/13 157/14
10.00 [1] 1/9
104 [1] 72/17
101.3 [4] 34/25 35/7
35/8 35/9
102 [1] 193/12
102.1 [1] 34/12
103 [2] 2/16 2/20
103.3 [2] 34/21 35/5
11 [1] 50/15
11 December [1]
166/7
11 February [13]
158/18 164/16 164/19)
165/1 165/8 165/25
166/21 166/22 167/5
172/16 174/18 174/18)
175/7
11 November [2]
192/8 192/25
11.00 [1] 43/24
11.10 [4] 43/21
11.11 [1] 44/1
12 [3] 23/21 34/7
116/22
12,000 [1] 149/14
12.30 [1] 92/16
13 [1] 199/15
13 April [1] 179/16
14 [1] 83/22
14 February [1]
177/19
14 May [4] 44/11
14 May 2001 [1] 45/3
15 [2] 22/1 65/21
15 August 2000 [1]
20/1
15 July [1] 80/13
150 [1] 82/2
16 [1] 172/19
16.3 [4] 172/19
17 [3] 36/8 46/9
75/23
17 August [1] 45/11
18 [1] 166/13
18 August [1] 195/2
18 June [2] 138/2
138/3
18 September [2]
44/13 45/3
18th [1] 45/15
19 [1] 45/16
49 August [1] 44/13
49 June 2024 [1] 1/1
196 [1] 73/13
1969 [1] 3/21
1970 [1] 3/23
1975 [4] 39/19
1982 [1] 4/5
1984 [1] 74/14
1985 [1] 93/20
1987 [1] 4/9
1988 [1] 50/2
1989 [1] 74/15
1990 [8] 3/23 4/9
4/13 4/16 7/16 16/10
24/18 24/18
1996 [2] 6/19 7/2
1998 [4] 44/13 47/10
53/13 88/17
1999 [1] 33/3
2
2 August [1] 63/12
2 January [1] 182/14
2 October [4] 104/2
104/13 106/17 199/9
2.38 [1] 140/15
2.50 [1] 140/12
2.51 [1] 140/17
20 [1] 81/6
20 August [1] 83/21
20 March [1] 1/25
2000 [8] 11/20 12/9
16/18 20/1 24/20
51/24 61/3 88/17
2000s [2] 82/21 90/9
2001 [3] 16/20 44/11
45/3
2002 [11] 4/24 5/9
5/17 6/2 18/1 25/2
25/7 27/8 32/11 63/12,
83/21
2003 [6] 6/4 6/6
26/16 75/4 83/13
85/25
2004 [1] 17/3
2004/2005 [1] 82/21
2005 [3] 24/4 82/21
83/12
2007 [1] 28/11
2009 [11] 30/5 72/8
93/25 100/9 100/18
101/22 106/17 140/22
152/19 166/7 199/9
201.2 [1] 36/11
201.3 [3] 36/17 37/9
37/10
201.3.1 [1] 38/3
201.3.3 [1] 38/7
201.6 [3] 36/13 37/12
39/2
2010 [31] 27/6 30/3
30/17 71/10 72/8
104/21 114/7 114/8
116/22 116/24 121/19}
131/20 138/3 139/19
139/23 139/24 139/25
141/4 141/9 141/9
141/10 142/8 150/3
158/25 160/24 161/10}
162/9 163/14 163/17
164/1 176/4
2010/early [1] 184/5
2011 [25] 30/24
94/24 94/25 96/11
96/20 154/9 159/9
161/23 161/24 163/15)
163/17 164/1 164/16
164/19 165/1 167/5
172/16 175/7 178/20
178/25 184/5 184/8
193/25 194/2 194/2
2012 [4] 101/8
179/14 179/16 181/7
2013 [7] 80/13 81/5
187/8 189/23 189/24
192/8 193/1
2014 [2] 95/3 196/14
2014/2015 [4] 196/13
2015 [2] 95/8 196/13
2016 [1] 95/10
2019 [3] 95/17 100/9
101/12
2023 [1] 1/25
2024 [3] 1/1 2/9 93/8
208 [1] 122/7
21 [2] 2/15 72/16
21 May [1] 93/8
21 November [1]
192/22
215 [1] 122/6
22 [1] 31/24
22 July [2] 141/9
148/9
24 [2] 99/7 99/9
25 March [1] 122/7
25 November [1]
51/22
25/11 [1] 50/15
26 [2] 32/22 38/9
27 [3] 3/1 99/21
166/12
28 January [1]
116/24
29 [4] 2/4
29 May [1] 25/2
291 [3] 73/18 73/19
73/20
3
3 December [1]
108/21
3.47 [1] 179/10
3.57 [2] 179/8 179/12
3.8 [1] 42/21
30 [2] 3/16 145/2
30 million [3] 96/12
96/25 157/1
36 [1] 199/15
363 [1] 73/22
38 million [1] 173/12
393 [3] 73/25 74/4
74/4
4
4.00 [1] 179/6
4.1.8 [4] 2/21
4.35 [1] 205/25
40 [3] 58/14 162/8
162/9
40 years [1] 32/3
403 [2] 38/5 38/10
403.2 [1] 38/17
405 [4] 38/8 38/22
40/2 40/4
5
5 August [1] 142/18
5 October [3] 104/16
104/17 108/19
55 [2] 23/22 168/9
587 [1] 41/13
6 April [1] 121/19
6 January [1] 75/4
62 [2] 160/13 160/19
67 [4] 31/1 31/24
31/24 93/10
69 [4] 78/3
7
7 December [1]
108/15
7 February [2] 159/9
167/12
7.3 [1] 46/10
71 [1] 34/9
73 [2] 99/7 99/12
75 [2] 72/21 99/21
79 [1] 32/22
8
8 July [4] 188/25
189/23 190/12 191/13
8 July 2013 [4]
189/24
80 [1] 50/25
829 [1] 74/8
9
9 December [1]
109/15
9 May [1] 2/9
9.45 [2] 1/2 205/23
9.45 am [1] 206/1
900 [1] 36/7
(63) MR BLAKE: - 900
9
900 pages [1] 34/4
A
A02 [1] 2/21
A1 [2] 34/18 35/23
A15 [3] 36/15 36/19
73/14
A16 [3] 36/16 37/1
73/20
A4 [4] 2/23
AS [4] 58/24
ability [5] 90/7 128/3
128/6 193/15 196/19
able [7] 54/9 84/13
89/16 112/6 127/20
135/4 191/9
abnormal [1] 149/17
about [155] 3/13 6/18
9/3 10/4 10/5 13/5
14/24 15/5 15/7 15/24
15/25 16/18 20/4
23/24 25/18 25/19
28/22 29/4 29/19
30/20 31/12 36/7 46/3
47/14 48/2 49/1 55/4
56/1 56/9 57/11 57/14,
57/22 58/14 58/25
59/21 60/11 60/14
61/7 61/7 65/5 65/8
65/15 68/21 69/7
69/15 70/12 70/15
70/17 70/22 70/23
71/13 71/16 71/17
71/20 74/17 75/20
78/23 78/24 78/25
79/22 80/6 80/7 81/20
82/4 82/11 85/24 86/6
87/11 88/12 88/14
88/23 88/25 89/6 90/7
90/9 90/15 91/13
91/15 98/14 101/16
105/19 111/24 118/19}
118/20 118/21 121/2
121/15 125/11 126/14}
127/11 128/3 128/5
128/9 130/14 130/17
132/3 133/12 134/7
139/7 142/11 145/1
149/3 152/22 155/18
156/14 156/15 156/16}
157/3 157/12 157/14
159/10 165/22 169/13)
169/22 170/6 173/12
175/14 175/17 177/6
177/9 177/10 177/13
177/24 179/1 179/14
179/20 179/23 180/5
180/20 183/6 184/12
184/15 185/1 185/3
185/20 186/1 188/4
189/18 190/3 190/4
190/9 190/19 191/1
191/7 191/15 192/16
196/3 196/12 197/3
198/17 198/22 199/24)
203/4 204/4 205/4
above [11] 23/14
33/22 50/18 66/3 82/1
110/8 110/21 110/22
120/15 124/5 170/25
absolutely [6] 78/1
105/22 109/11 168/24}
185/2 185/3
abstract [2] 44/12
62/6
abuse [1] 150/17
accept [27] 12/22
14/9 14/14 15/2 15/7
15/10 15/20 35/22
46/23 47/24 48/10
52/19 52/21 55/5
66/18 67/5 67/9 67/12
68/24 77/20 87/16
88/5 88/5 89/3 160/19)
169/17 178/10
acceptable [2] 65/10
65/15
acceptance [13]
21/17 32/9 32/15 33/7)
33/14 39/4 39/6 39/7
39/13 39/18 50/19
88/3 178/13
accepted [2] 52/5
178/12
accepting [2] 53/10
125/2
accepts [1] 178/4
access [24] 64/10
64/12 65/12 66/5 66/7)
67/6 67/8 89/21
186/12 186/14 193/11
193/16 193/19 193/19)
194/4 194/15 194/19
196/6 196/13 197/4
197/19 197/22 198/6
198/10
accordance [6]
32/10 32/18 36/15
37/13 42/3 74/13
accordingly [2]
112/6 153/3
account [28] 69/23
70/6 80/3 101/24
102/5 105/8 118/3
123/9 123/19 128/21
129/3 129/12 130/1
155/7 157/12 157/21
162/7 163/4 163/7
171/20 171/23 173/11
173/19 175/24 202/9
202/12 203/5 204/6
account's [1] 130/19
accountability [4]
15/7 15/11 15/13
15/24
accountable [1] 15/8
Accountancy [4]
144/5 144/7 145/4
147/13
accountant [1] 145/8
accounting [22]
24/21 24/22 87/18
118/3 118/6 144/13
144/15 145/8 145/25
146/7 149/16 159/14
160/18 162/15 168/8
168/11 177/10 178/5
178/7 178/15 182/20
203/19
accounts [17] 87/16
89/17 90/7 91/18
96/13 96/24 97/10
102/16 103/9 103/24
105/12 114/13 144/5
144/21 193/17 202/23
203/14
accumulating [1]
149/17
accurate [4] 80/1
120/6 150/17 168/20
accused [2] 146/18
182/20
achieve [1] 33/22
achieved [1] 189/13
acknowledged [1]
138/13
across [2] 18/11 32/4
Act [2] 66/17 74/14
acted [1] 4/7
acting [5] 4/1 11/19
20/3 29/8 54/15
action [19] 47/13
49/13 49/18 50/10
50/15 62/15 117/23
119/24 120/8 144/4
144/9 144/11 149/23
149/23 149/25 168/10}
194/6 196/8 198/14
actions [3] 49/2
66/16 195/17
activity [2] 45/18
83/2
actual [7] 16/7 26/9
26/18 85/21 130/23
146/2 160/6
actually [30] 10/2
10/21 11/10 11/12
17/2 18/10 18/15
39/15 40/15 41/12
57/15 58/1 58/5 58/22
63/6 68/24 83/20 85/9
89/10 90/3 108/12
127/5 137/25 174/6
174/19 178/23 179/3
184/18 191/13 195/14
ad [1] 98/17
Adachi [1] 58/9
add [3] 15/22 42/12
120/21
added [2] 20/12 85/2
addition [2] 95/11
95/12
additional [4] 47/7
112/20 166/17 180/14}
Additionally [2]
132/13 135/23
address [5] 50/6
134/25 148/20 174/24}
193/12
addressed [1]
134/23
addresses [1] 111/11
addressing [1]
134/24
adequacy [5] 19/18
43/5 43/9 72/11 85/21
adjourn [1] 92/12
adjourned [1] 206/1
Adjournment [1]
92/17
admin [1] 66/8
administer [1] 64/8
administration [2]
64/1 67/8
Administrative [1]
45/4
administrator [3]
64/11 67/3 194/18
administrators [1]
67/2
admissible [1] 74/12
admits [1] 182/15
admitted [1] 127/16
Adrian [1] 54/19
adverse [1] 172/5
advice [7] 7/21 42/1
54/24 67/14 80/12
128/19 135/15
advise [1] 53/22
advised [5] 53/23
55/1 55/7 80/24 81/11
adviser [3] 4/2 31/5
58/5
advising [1] 31/11
advocates [1] 125/18
Affairs [3] 4/10 7/15
111/18
affect [4] 103/25
118/6 160/13 203/14
affected [4] 26/8
139/9 150/16 160/18
affecting [4] 112/23
122/14 124/2 140/5
afraid [2] 85/17 91/24I
Africa [1] 95/4
after [28] 6/18 6/18
11/19 16/10 39/5 39/7,
56/18 58/24 97/22
97/25 99/14 99/25
101/4 120/18 141/10
148/7 156/20 173/24
173/24 183/18 183/18}
184/2 184/13 184/14
191/25 200/11 201/25)
204/16
afternoon [5] 92/19
92/21 92/25 140/8
205/15
afterwards [2] 11/10
20/13
again [27] 25/7 34/9
35/4 35/7 65/18 73/12I
75/11 84/9 87/23
90/10 103/7 105/21
109/14 117/11 118/9
121/4 135/25 140/3
155/24 166/4 180/18
182/18 185/14 186/16)
189/12 197/7 205/19
against [6] 88/6
99/17 100/1 144/9
168/10 194/6
Age [3] 144/5 144/7
147/13
Age's [1] 145/4
agency [3] 11/15
86/3 111/19
agenda [2] 151/25
195/2
agent [1] 123/25
agents [1] 172/25
aggregate [2] 82/1
82/2
aggrieved [1] 91/4
agile' [1] 188/1
agility [2] 188/21
189/9
ago [2] 100/17
200/22
agree [18] 37/21
37/23 48/17 77/1 83/1
88/2 88/3 120/12
126/17 133/22 134/9
177/8 191/10 200/20
201/6 201/7 203/23
203/24
agreed [15] 26/17
32/19 39/22 50/15
54/11 65/10 65/11
65/16 65/16 77/21
78/7 111/7 134/5
138/25 165/20
agreeing [1] 135/22
agreement [23]
10/10 11/16 26/17
32/23 32/25 33/1
33/19 33/22 33/24
34/2 34/6 34/17 35/16I
35/21 41/11 47/11
73/8 74/22 76/20 88/1
138/22 157/10 176/18)
Ah [3] 35/7 42/23
74/6
ahead [4] 55/1 55/2
55/3 122/19
AI298 [1] 50/19
air [1] 128/12
aired [1] 141/17
(54) 900 pages - aired
A
akin [1] 4/3
Alan [2] 119/10
119/12
alarm [3] 1/9 8/24 9/6)
alarmist [1] 120/6
albeit [2] 140/25
151/13
alert [8] 14/4 123/16
123/17 123/18 132/7
134/20 181/16 181/22)
alerted [1] 153/20
alerting [1] 109/3
alerts [2] 19/16
197/15
aligned [2] 111/2
181/23
aligned/supporting
[1] 111/2
alignment [1] 176/10
all [128] 3/13 8/4 8/5
8/17 12/3 14/21 16/22
16/23 18/14 19/6 22/5
22/7 22/14 22/15
22/25 23/9 23/12
25/16 25/23 31/21
32/2 37/14 40/15
40/18 41/18 43/22
46/5 49/6 52/16 56/3
56/6 58/12 58/13
58/15 59/1 59/7 59/11
61/16 66/8 66/21 67/8
69/11 70/20 70/24
71/20 74/10 77/3
78/24 79/7 80/7 80/10)
82/14 82/22 84/6 84/7
84/14 84/18 84/21
85/10 86/19 87/9
87/25 88/12 89/9
89/13 89/24 90/4
90/12 90/21 92/15
100/12 101/9 107/10
109/23 111/11 115/3
115/8 121/11 122/14
125/13 126/10 130/15
134/1 139/4 142/3
145/10 147/9 147/22
149/14 151/23 154/24}
160/14 161/17 161/24
166/1 167/3 167/21
168/2 168/21 169/15
169/16 169/17 172/20)
174/8 174/8 174/22
175/8 176/2 181/1
184/15 186/6 187/24
189/14 189/14 190/6
190/14 191/19 191/21
192/25 198/8 199/1
200/2 200/24 201/22
202/19 203/11 203/25
205/22
allegation [3] 181/14
182/5 186/8
allegations [7] 72/10
104/22 105/1 105/10
144/16 145/1 147/23
alleged [1] 144/15
Alliance [1] 144/12
allow [3] 76/16
122/19 126/6
almost [3] 47/12
145/13 146/8
alone [1] 191/9
along [8] 108/14
135/19 137/12 163/23}
177/1 177/11 200/5
201/6
alphabetical [1] 97/5
already [12] 14/15
72/18 88/19 101/16
125/12 134/23 143/13)
143/20 154/16 155/13}
167/19 181/2
also [55] 11/23 18/18
22/24 38/7 45/23 47/5)
47/6 48/13 56/9 58/8
84/15 85/5 89/23 91/4
97/10 97/11 97/23
98/13 99/4 100/19
108/23 109/7 110/4
110/24 111/5 113/17
113/18 118/18 119/1
122/23 123/24 141/7
141/21 143/7 143/14
144/16 147/14 147/17)
150/22 151/17 151/21
152/11 153/4 154/12
155/19 159/1 160/8
163/14 164/6 167/2
173/10 177/14 181/24}
189/2 200/1
Alter [2] 163/2 202/6
alterations [2] 90/16
186/9
although [6] 84/16
129/15 143/17 147/1
147/14 165/18
always [8] 14/20 53/5]
68/4 81/19 85/24
86/15 107/11 147/19
am [9] 1/2 43/24 44/1
96/19 133/5 135/8
148/19 156/23 206/1
amber [1] 19/16
amendments [2]
108/16 120/19
America [1] 17/22
American [1] 138/2
Americas [1] 95/10
amicably [1] 6/20
ammunition [1]
162/21
amongst [3] 109/4
175/17 176/5
amount [5] 11/14
58/12 62/8 96/22
166/17
ample [1] 89/15
amplify [1] 75/13
Amsphere [1] 164/24
analyse [2] 76/7
79/12
analysed [1] 12/25
analysing [1] 79/12
analysis [3] 12/19
79/17 117/10
analyst [2] 167/16
169/24
ANDREW [4] 93/2
93/6 197/9 207/8
Andy [5] 104/16
125/16 137/19 137/19
138/5
Ann [8] 109/25
110/10 110/11 110/11
110/12 110/23 111/4
113/3
annexed [1] 3/19
annual [1] 194/10
annum [1] 96/25
another [17] 43/3
56/14 63/1 63/2 65/6
70/25 123/23 131/8
155/9 157/11 164/19
166/16 173/10 182/10
182/11 190/4 194/21
answer [19] 18/5
24/9 27/11 29/5 51/5
59/1 70/10 86/13
86/18 91/24 105/1
107/21 120/16 183/7
183/8 183/9 198/9
203/7 204/24
answered [1] 186/7
answers [1] 204/21
anxious [1] 179/1
any [86] 8/12 11/7
13/21 14/24 19/17
27/9 27/16 27/25 29/8
29/17 30/15 31/11
31/12 32/6 40/10
41/10 43/10 44/23
50/11 53/25 62/17
63/17 63/20 65/2
71/10 72/4 72/20
75/18 80/10 82/6
82/19 85/20 86/9
86/20 86/21 90/22
90/23 91/12 100/12
101/15 106/20 107/14]
109/2 119/1 121/14
125/5 126/6 131/1
131/1 138/24 138/24
144/22 146/7 147/7
149/2 149/9 149/16
150/15 150/25 152/23
154/21 154/22 156/2
156/9 156/10 158/10
161/1 167/20 169/21
171/7 173/2 178/19
180/1 180/14 180/16
180/20 180/22 182/7
183/21 185/9 186/17
188/6 190/17 192/23
193/6 198/17
anybody [2] 193/8
198/17
anything [9] 19/2
28/22 30/8 31/6 57/8
81/16 86/6 177/10
178/3
anywhere [1] 147/3
apart [1] 16/6
apologies [1] 73/17
apparent [2] 135/10
203/15
apparently [1]
102/25
appeals [1] 88/6
appear [5] 65/14
87/16 149/9 164/11
203/14
appeared [4] 103/1
145/1 162/13 203/17
appears [4] 51/10
141/20 160/13 204/5
appendices [1] 33/24]
applicable [1] 37/14
application [9] 50/13
51/13 52/21 54/25
115/20 115/24 116/15}
116/16 183/3
Applications [2]
94/14 161/16
applies [1] 54/23
apply [2] 107/2
201/18
appointed [8] 7/15
14/19 16/21 30/8
30/23 95/8 101/4
175/25
appointing [1] 56/19
appreciate [2] 19/21
188/13
approach [3] 111/24
124/15 135/11
approached [1]
142/2
appropriate [8] 14/19]
25/16 56/1 57/9 62/15
76/8 140/7 175/22
appropriately [3]
14/13 57/1 62/10
approved [3] 77/5
83/2 83/3
approximate [1]
101/7
approximately [3]
82/20 100/11 101/1
April [13] 6/4 17/3
25/7 28/11 94/25 95/1
121/19 122/18 141/23}
161/23 161/24 178/24}
179/16
April 2011 [1] 161/24
Arbuthnot [2] 155/20
180/4
architect [1] 104/10
architecture [1]
115/20
are [147] 2/19 3/7
11/16 13/11 14/19
14/21 14/23 15/6
15/24 20/5 23/8 24/25
32/8 32/13 35/2 38/1
39/7 40/14 42/23
45/22 45/23 46/3
46/23 54/15 55/6
55/22 55/22 56/15
59/24 60/1 60/14 61/4
63/23 66/3 66/10
66/25 67/1 67/1 73/21
74/6 77/18 79/7 79/21
83/20 84/17 84/18
86/19 86/20 92/1
92/24 92/24 97/1 97/5I
103/6 103/7 103/8
103/9 105/19 106/24
107/8 107/10 107/12
109/16 109/18 109/23)
111/10 113/12 113/13)
115/2 115/2 119/2
123/16 124/12 124/13}
125/18 127/20 129/6
129/15 130/6 130/10
132/8 132/23 133/18
136/21 137/10 137/16)
137/23 138/9 138/10
140/21 141/11 141/15)
141/21 142/1 142/2
142/23 142/23 143/4
143/4 143/17 144/9
144/18 146/4 147/4
147/12 147/14 147/17)
147/24 149/20 150/11
152/8 153/5 153/11
154/2 156/15 157/25
158/15 162/20 162/24}
165/13 166/19 167/7
168/9 168/12 169/4
169/13 169/21 171/5
172/2 173/4 178/21
181/23 189/1 190/6
190/14 191/1 194/20
196/21 196/23 196/24)
199/1 199/3 201/17
203/3 204/2 204/9
204/21
area [3] 89/14 114/19
136/24
areas [2] 129/16
136/9
aren't [3] 67/3 97/3
152/14
argument [1] 145/12
arguments [1]
146/20
arise [1] 43/15
arising [2] 98/8
(65) akin - arising
A
arising... [1] 121/21
arose [1] 169/2
around [20] 82/21
93/20 100/15 101/8
102/22 126/15 135/1
142/11 145/10 149/9
158/15 158/17 163/10
166/22 173/9 186/22
187/23 194/20 196/5
202/15
ARQ [2] 76/3 191/23
arranged [1] 192/20
arrangement [4]
69/24 128/24 128/25
130/9
arrangements [1]
138/14
arrived [1] 121/25
arriving [1] 96/8
article [17] 72/9
72/13 143/20 144/4
146/18 147/12 147/15
149/11 156/1 168/3
173/24 173/24 173/24}
181/12 183/18 183/18
183/18
articles [3] 145/24
151/10 189/15
as [244]
as though [2] 100/24
160/17
ascribed [1] 34/19
Aside [1] 19/15
ask [27] 1/22 2/3 2/8
2/12 2/25 15/6 16/4
40/9 43/3 45/6 50/10
59/21 71/4 71/13
71/17 86/25 87/11
88/12 88/25 90/20
91/14 93/10 101/14
109/23 130/13 149/8
170/17
asked [18] 9/6 10/1
10/2 10/4 32/1 63/6
100/5 103/17 105/8
115/19 128/18 135/24}
147/24 164/22 179/23}
186/13 199/14 204/16
asking [7] 9/3 69/24
132/14 142/20 145/16)
194/5 195/9
asks [1] 87/2
assessment [1]
157/16
assessments [1]
14/22
assigned [2] 129/2
176/19
assist [9] 98/6
101/15 102/2 109/11
123/17 127/20 142/22)
160/25 161/5
assistance [10]
35/14 45/1 100/5
100/7 103/18 108/2
134/19 166/22 172/21
187/5
assisted [2] 99/18
100/4
assisting [3] 100/1
107/6 165/4
Associated [1]
172/22
assume [2] 69/9 70/3
assumed [1] 43/12
assuming [2] 91/22
148/24
assurance [7] 107/23
122/21 128/20 143/2
158/8 184/21 184/21
assurances [2]
152/14 183/14
assure [3] 57/17
129/5 196/22
at [343]
attached [1] 38/12
attempt [2] 52/18
133/22
attend [6] 9/20 10/1
10/3 10/23 60/13 99/4
attendance [3] 71/7
71/11 109/2
attended [8] 10/18
11/1 11/3 11/6 27/11
60/15 60/18 176/4
attendees [1] 161/1
attending [2] 1/18
61/12
attention [14] 13/22
105/18 114/13 118/10}
118/12 141/1 157/22
163/20 174/14 174/16)
179/22 184/25 199/20)
200/11
au [1] 36/5
audit [24] 49/3 49/14
49/15 49/25 64/14
76/1 98/13 103/3
132/15 135/18 145/8
145/11 145/12 184/23)
186/14 191/23 194/6
194/9 194/10 195/2
195/3 195/9 196/25
196/25
auditable [1] 196/22
auditor [1] 168/17
auditors [1] 194/11
August [11] 20/1
44/13 45/11 45/16
63/12 83/21 137/7
142/18 150/3 176/4
195/2
Austin [5] 44/15
44/20 44/24 49/7 51/4
author [2] 114/25
143/16
authorisation [2]
38/25 123/25
authorising [1] 39/1
automation [1]
145/23
available [1] 186/15
avenues [1] 176/12
aware [71] 40/11
46/20 54/7 64/17 70/8
72/12 84/7 99/13
99/24 100/3 100/6
100/12 105/25 106/1
107/3 107/6 107/18
107/22 108/5 109/9
116/9 118/1 118/5
119/7 121/1 121/5
124/7 124/10 124/21
124/22 130/17 132/8
136/7 136/15 137/13
137/16 140/25 142/13}
147/14 150/4 151/6
151/9 151/12 153/15
160/18 160/21 165/13}
167/1 170/2 170/5
170/16 171/5 171/13
172/2 172/8 173/19
173/21 173/21 173/25]
174/9 177/25 178/20
191/8 192/3 192/11
193/15 193/22 195/14]
197/2 198/8 198/13
awareness [1] 75/18
away [2] 121/24
202/24
back [35] 16/2 19/21
30/10 36/4 54/1 54/10)
62/6 77/3 78/5 86/7
88/18 109/10 110/3
124/13 124/19 127/3
134/12 135/2 136/19
136/23 137/25 141/16
142/3 145/14 152/1
153/15 162/7 167/12
176/4 179/6 183/24
185/15 187/1 188/7
200/6
background [6] 11/2
11/3 93/19 116/3
159/8 200/19
bad [7] 46/8 47/1
47/2 88/14 139/19
188/3 188/17
BAE [1] 93/19
balance [6] 157/12
157/21 159/24 160/1
172/13 186/15
balanced [3] 127/24
162/13 203/17
balances [1] 186/10
band [1] 58/23
banking [6] 116/25
117/5 117/14 123/23
124/1 172/2
bar [1] 58/8
Barrister [1] 108/24
base [1] 135/20
based [20] 30/2
52/10 127/18 128/19
129/14 143/4 143/5
143/6 143/7 143/10
143/12 143/14 146/5
150/5 150/18 161/18
167/25 191/17 196/8
196/17
basic [1] 46/17
basically [2] 43/11
202/21
basis [10] 12/14
14/23 17/8 88/4 89/22}
98/18 100/2 139/17
147/12 148/14
Bates [2] 87/13 90/3
battle [1] 145/9
BBC [14] 103/12
156/1 156/15 157/17
157/25 159/9 167/13
168/4 169/25 174/9
181/8 181/12 182/10
183/19
be [176] 1/8 2/20
3/11 3/18 10/1 13/4
13/9 13/18 18/17
25/13 25/16 26/14
28/20 31/19 32/1 34/5)
35/13 35/16 35/22
36/13 37/24 40/6 41/1
41/22 42/1 42/5 42/6
42/19 42/22 43/12
43/13 48/1 48/19
48/21 49/25 50/8 51/8)
51/10 52/4 52/7 54/11
55/7 60/10 61/11
61/21 65/1 65/11
65/16 67/2 67/3 67/18
68/1 68/11 68/18
68/19 68/20 70/11
70/15 71/24 74/12
77/5 78/22 78/24 82/1
82/10 82/20 83/2
84/12 86/2 86/13
87/19 91/15 91/19
93/17 96/15 98/9
98/16 98/17 98/21
100/19 104/1 106/12
107/10 107/11 108/24,
4111/1 112/5 112/7
112/16 112/24 114/5
117/16 117/21 117/22}
117/24 118/16 119/22
119/23 119/25 120/7
120/7 121/5 121/25
123/16 124/19 125/1
126/7 126/15 127/21
129/14 129/18 130/5
130/8 131/3 133/16
134/5 136/5 136/20
137/6 138/3 138/5
138/22 138/25 140/10)
141/16 141/20 144/10)
146/25 147/1 147/3
147/21 150/2 150/22
159/12 159/20 159/24)
160/6 161/5 161/8
162/15 163/23 164/18)
165/19 167/23 168/12)
169/2 169/4 169/22
170/15 170/16 170/21
171/7 171/17 173/24
174/12 182/24 184/12)
186/10 186/15 187/17)
188/14 188/16 189/9
189/12 190/17 192/24)
196/4 196/7 197/14
198/18 200/13 201/10)
201/20 202/22 203/15]
203/19
bear [3] 2/15 74/3
123/20
bearing [1] 169/18
became [25] 5/10
5/16 5/25 6/2 6/20
11/19 12/8 14/16 17/3)
17/6 17/25 18/6 26/22)
28/12 29/3 45/21 90/2I
94/24 95/10 97/25
99/24 100/24 178/24
189/6 193/22
because [50] 10/8
11/10 12/12 14/7
17/12 17/16 22/24
24/18 25/6 25/13 28/3}
30/25 33/14 39/16
39/24 47/8 50/22
53/10 57/2 58/1 58/17
59/12 60/20 62/19
65/15 67/24 68/19
69/2 71/20 75/22 81/4I
83/11 85/9 85/18
94/18 102/2 106/1
109/14 124/25 133/24I
136/22 149/10 152/1
157/20 158/13 168/11
185/3 190/20 190/21
193/20
become [8] 26/19
68/18 97/19 100/11
104/22 146/19 154/10)
193/15
becomes [1] 95/24
becoming [4] 17/13
31/1 111/22 145/13
bed [1] 169/16
beef [1] 66/21
been [160] 5/4 8/3
8/15 10/15 11/24 17/5I
19/11 28/6 29/5 29/7
30/22 32/1 32/19 36/5I
37/4 40/13 48/7 51/8
52/16 53/12 53/21
57/4 59/13 60/16
(66) arising... - been
B
been... [136] 64/12
67/22 67/24 67/24
68/13 69/2 69/16 71/5
73/3 74/19 77/11
77/13 77/15 80/24
81/8 83/3 83/8 84/1
84/9 86/8 91/5 96/3
96/12 97/10 97/11
97/18 97/20 97/22
97/23 97/24 98/24
99/16 101/4 101/8
102/18 102/22 104/25}
106/1 106/13 108/5
108/14 108/16 108/23
109/6 109/8 109/13
109/17 110/14 112/3
114/19 117/6 117/12
118/10 120/19 120/20
121/15 124/10 128/13}
131/8 132/18 133/6
133/22 134/15 134/20
134/23 135/20 136/2
136/6 139/22 142/12
143/1 143/6 143/7
143/20 143/25 144/22)
145/7 146/16 146/23
147/1 148/12 148/13
149/11 149/25 151/4
151/22 153/15 153/20
153/24 155/10 157/12)
157/16 157/17 158/19)
160/14 163/19 163/21
163/23 164/20 164/22
167/22 167/24 168/21
169/8 169/12 171/2
171/24 172/8 172/8
172/11 174/9 175/8
176/23 177/7 181/1
181/10 182/19 183/2
183/4 184/9 186/6
186/7 186/13 186/21
187/3 190/7 190/13
193/20 195/21 195/23
196/14 196/18 200/11
200/19 204/16 204/17
before [43] 1/7 2/12
5/8 9/6 11/12 14/16
16/2 24/16 28/9 31/3
31/9 44/8 45/7 45/8
46/18 47/10 50/10
52/23 58/16 60/9 61/3
61/3 63/6 63/9 72/8
77/9 82/9 86/20 87/1
87/22 91/6 91/8
104/12 108/18 121/13
121/24 128/9 159/3
165/13 166/10 179/6
183/24 191/12
beg [2] 67/11 67/11
began [1] 122/10
begin [1] 93/18
beginning [3] 25/9
156/25 168/16
beginnings [1] 77/6
begins [3] 115/16
155/12 176/3
behalf [2] 176/1
190/13
behind [1] 138/23
being [81] 6/8 7/1
27/15 39/22 41/25
45/20 46/23 48/4
48/10 50/3 52/15
52/19 55/7 55/8 55/17
57/1 64/22 67/17
67/20 72/20 76/22
77/21 78/7 80/19
81/20 84/10 98/14
99/13 100/3 100/4
104/12 105/19 106/11
108/2 113/17 114/16
115/3 115/17 120/6
120/6 120/13 123/2
124/8 125/9 126/8
132/16 137/23 139/16
142/7 142/10 143/13
146/3 146/15 146/20
148/22 153/21 156/20)
156/23 157/16 159/2
159/10 159/10 170/3
172/13 175/15 175/17)
182/19 183/20 186/16
188/15 189/16 190/9
191/9 197/21 198/21
198/22 201/17 202/20)
203/1 203/13 204/11
Belfast [2] 64/5
123/14
belief [5] 3/8 62/14
75IT 93/14 134/4
believe [27] 2/13
20/3 28/6 32/7 55/24
59/7 88/7 101/23
104/6 104/9 134/3
143/11 143/14 150/1
152/18 157/22 161/6
181/5 181/10 181/14
182/5 182/9 190/23
191/5 192/8 192/13
196/1
believed [1] 114/2
believes [2] 114/1
144/23
Bell [2] 179/16
180/13
Bell's [1] 181/4
below [18] 59/22
76/6 79/12 102/14
103/17 105/12 119/14)
120/18 123/24 124/4
142/21 142/23 145/14)
148/13 169/12 185/7
196/15 196/18
Benchmarked [1]
187/18
beneath [2] 5/19
204/22
beneficial [1] 28/3
benefit [1] 133/16
benefits [2] 11/15
176/9
Bennett [8] 11/6
44/15 44/18 44/24
49/7 77/7 83/10 83/14
best [5] 3/8 75/6
80/11 93/13 104/10
better [7] 18/19 53/6
53/16 55/1 189/8
192/22 204/10
between [36] 8/21
9/7 9/17 18/13 32/19
33/1 44/13 59/7 69/13
131/10 131/18 133/20
133/21 134/8 136/20
137/5 139/19 141/5
157/10 159/4 185/8
186/17 188/19 189/6
189/17 190/18 190/23
191/5 193/4 194/17
197/2 200/1 201/21
202/2 204/7 204/12
beyond [4] 40/1 79/5
138/14 148/14
biggest [4] 39/16
83/25 96/21 113/7
bit [11] 17/21 31/1
34/5 53/3 93/19
109/12 120/2 132/11
179/1 181/2 181/19
bits [2] 45/6 79/7
BLAKE [31] 93/3
108/7 112/4 118/20
130/20 134/11 136/22
142/12 149/4 152/25
156/11 156/18 164/4
170/17 173/9 179/1
180/12 183/24 184/20
187/1 188/8 189/21
191/12 191/20 193/18}
196/9 201/21 204/16
205/11 205/19 207/10}
blame [3] 144/18
162/21 198/9
blamed [1] 182/19
blank [1] 42/20
blanks [1] 153/19
blew [1] 90/22
blow [1] 89/1
blue [1] 104/1
board [88] 4/11 9/15
9/19 9/19 9/23 10/10
10/12 10/12 10/23
11/1 11/8 12/3 12/4
12/6 12/9 12/16 12/22
13/5 13/6 13/9 13/17
13/17 13/22 13/24
14/1 14/2 14/5 14/6
16/6 16/9 21/8 21/22
22/5 22/15 24/13 27/9
29/16 29/21 30/1
30/22 38/25 48/7 48/8
48/20 53/21 55/5
55/11 55/16 55/21
56/3 56/8 56/16 56/18
56/25 57/6 57/10
57/12 57/12 57/16
58/17 59/3 59/6 59/6
59/11 59/21 60/6
60/24 61/20 70/17
72/20 76/24 77/6
77/10 77/11 77/15
77/19 78/21 80/21
81/3 81/14 83/3 95/8
101/10 101/13 137/3
137/11 194/7 195/10
Board's [3] 70/5
70/22 129/11
Boards [2] 17/22
101/15
BOC [1] 64/5
body [4] 104/19
104/25 113/15 152/7
book [7] 58/25 69/24
128/25 129/19 130/7
130/12 131/8
book’ [2] 128/24
135/16
boss [1] 143/11
both [32] 3/7 12/11
12/12 32/10 42/4
42/10 44/17 47/19
62/20 85/4 88/17
97/15 98/20 106/10
106/11 111/1 118/17
118/25 120/19 131/24,
132/20 132/22 136/6
139/25 140/1 149/18
153/9 158/6 164/1
166/7 173/13 196/21
bottom [29] 3/20
25/17 36/9 46/10
98/20 101/22 103/20
106/15 106/16 108/10}
119/4 121/17 121/20
122/16 142/19 144/19}
144/25 145/3 145/5
160/12 165/16 181/8
186/4 186/4 187/7
190/12 197/8 201/14
203/8
bottom-up [1] 98/20
bought [1] 118/12
boundaries [1] 42/14
Bounds [25] 102/2
102/4 105/4 108/11
110/8 111/5 112/10
112/11 112/11 121/21
127/9 137/22 138/3
141/11 142/14 142/20)
145/16 145/18 150/21
154/4 154/5 155/7
184/2 195/12 196/2
box [1] 64/11
brackets [1] 42/16
Bracknell [1] 180/2
branch [43] 76/10
76/10 87/15 89/16
90/7 91/18 102/16
102/16 103/9 103/24
103/25 115/18 117/1
117/17 117/18 149/20)
162/6 162/7 162/13
162/16 163/2 163/4
163/5 163/10 163/12
163/13 178/8 186/9
193/16 196/20 202/6
202/8 202/10 202/15
202/17 202/18 202/23}
202/23 203/5 203/11
203/14 203/17 203/20
branches [22]
116/21 116/22 122/6
122/7 122/15 126/7
126/19 146/3 146/3
149/14 160/13 160/15)
160/19 162/8 162/9
162/18 162/20 162/21
201/19 203/22 204/2
204/9
brand [5] 4/24 5/9
25/6 202/3 202/4
branded [1] 5/10
branding [1] 4/21
brands [1] 204/12
breach [4] 65/3 65/13)
67/19 68/17
break [10] 43/19
43/25 61/1 87/1 87/4
92/13 140/8 140/16
179/2 179/11
breaking [1] 36/18
breaks [1] 92/25
Brian [1] 142/25
bridge [1] 47/11
bridges [1] 110/6
brief [11] 58/16
102/14 110/2 142/21
145/16 145/17 176/7
176/21 187/14 192/7
192/14
briefed [1] 135/20
briefing [5] 102/20
109/13 122/3 185/21
189/10
briefly [3] 106/5
154/22 193/11
briefs [1] 188/6
bring [11] 3/16 19/21
31/23 72/16 108/24
123/10 123/19 144/8
163/7 200/6 202/12
bringing [3] 105/18
132/14 151/4
brings [1] 112/21
broad [3] 12/18
15/10 118/1
broadband [1] 193/3
broadcast [2] 159/9
(67) been... - broadcast
B
broadcast... [1]
167/13
broadcaster [2]
156/3 157/18
broadest [1] 13/1
broadly [2] 140/25
198/13
broke [1] 30/11
broken [1] 30/10
Bronsville [1] 168/7
brought [9] 118/10
135/12 137/6 157/21
163/19 170/14 183/25)
184/24 200/11
BTS [3] 160/8 160/10
160/15
bug [12] 72/2 72/4
158/20 158/24 160/18
177/25 178/13 178/16}
201/12 203/11 203/13,
205/7
bugs [14] 86/18
87/14 88/7 88/7
107/15 188/5 191/7
200/4 200/9 200/18
200/25 201/4 201/5
201/9
build [4] 84/14
building [1] 110/6
built [1] 106/24
bulk [1] 94/15
bullet [8] 103/20
108/18 108/19 108/20
112/20 159/18 160/2
196/16
bundle [1] 1/21
business [43] 7/12
12/16 13/19 18/19
18/24 22/13 23/7
23/25 24/2 29/11
29/15 29/22 30/12
57/5 60/22 60/23
70/19 77/22 77/24
78/9 79/5 79/10 94/11
94/15 94/17 96/2
102/6 112/9 116/17
117/15 121/1 123/13
128/2 143/2 153/18
158/8 159/16 175/25
176/12 181/20 181/22)
183/3 185/22
businesses [2] 112/5
112/6
busy [4] 21/14 21/16
165/9 205/18
but [179] 3/13 4/24
6/5 6/18 7/18 8/3 9/14,
9/17 10/1 10/13 10/20
10/21 12/15 12/18
13/12 13/19 15/3
15/24 17/5 17/11
19/12 21/12 21/21
22/24 23/18 24/9
25/24 27/11 27/22
29/6 29/10 29/15
30/11 30/14 31/5
31/21 34/6 36/7 40/20
40/23 41/1 42/8 44/11
46/5 46/14 47/9 48/12
52/23 52/24 53/2 53/7
53/24 53/24 54/7
54/17 54/20 54/23
55/2 55/5 56/11 58/20
59/5 59/12 59/19
60/22 60/25 64/10
65/19 66/23 66/24
67/2 68/14 70/21 71/9
71/15 71/19 75/14
75/16 76/5 77/17
77/19 78/14 79/5 79/8
79/24 79/25 80/10
80/23 81/16 83/1
83/20 85/13 85/17
86/14 86/18 87/7
87/19 87/22 87/24
88/10 89/10 89/12
89/14 89/23 91/5
91/13 95/24 96/7
97/12 100/23 101/5
104/20 105/15 106/2
108/12 109/1 109/7
111/17 112/15 113/3
113/21 114/4 114/25
115/5 116/17 117/3
117/4 117/11 118/12
119/1 120/14 121/6
127/11 127/17 130/7
131/14 132/2 133/23
141/9 143/21 144/17
146/7 147/5 149/4
152/4 153/14 154/1
156/14 157/23 158/3
158/6 159/15 161/23
162/2 162/7 169/19
170/16 171/25 173/19)
175/5 176/2 177/18
178/19 180/24 182/2
182/22 183/9 183/13
187/5 187/24 188/12
190/6 190/16 190/24
192/7 195/8 200/15
200/22 204/14
Byfleet [2] 146/20
168/8
c
calculation [1] 166/8
call [13] 1/13 8/17
9/16 61/6 70/20
103/22 104/14 112/17)
118/2 120/9 129/12
155/1 177/16
called [19] 9/13
10/14 17/9 26/14
40/16 48/15 58/6
58/21 64/2 108/13
117/24 119/25 123/3
161/16 181/20 183/3
192/11 193/19 194/3
Callendar [5] 177/24
177/25 178/6 178/11
178/14
calling [1] 145/10
calls [2] 135/15
135/23
came [15] 8/19 10/17
18/11 29/20 29/21
30/1 30/17 82/20
86/13 90/21 94/2
145/2 157/6 166/10
199/19
campaign [1] 182/17
can [164] 1/5 1/13
3/16 9/2 11/1 13/2
19/16 21/22 21/25
22/19 24/8 24/24
24/25 25/17 25/21
27/8 27/24 29/5 31/8
31/22 34/6 35/11
35/12 38/9 38/13
38/22 39/9 42/19 44/2
44/11 44/25 45/2
45/25 47/8 48/12
48/13 49/5 49/12
50/10 50/23 53/7
54/21 54/22 54/24
57/17 59/12 61/16
61/16 62/6 62/23 67/3
69/8 70/5 70/8 70/20
70/24 71/4 71/16
71/24 72/7 72/15
73/18 73/25 74/4 74/7
75/13 75/23 75/25
79/7 81/1 81/13 82/8
82/10 86/25 89/9
89/13 92/19 92/20
93/4 93/10 98/6 98/6
99/6 102/2 102/19
106/15 107/8 107/20
109/12 109/24 110/10
110/24 111/2 115/5
119/4 119/6 121/10
123/12 123/16 128/22
129/11 130/16 130/23
133/15 134/2 136/3
136/17 137/6 137/8
137/18 137/19 138/22
140/18 142/21 144/3
152/5 153/23 154/3
154/4 154/4 154/22
155/2 155/5 156/7
158/16 158/17 160/25
161/4 161/4 162/12
164/4 166/14 167/18
169/5 170/13 173/8
173/24 174/12 176/23
181/7 181/16 181/22
182/12 184/5 185/17
185/21 186/4 187/7
188/8 188/22 189/12
189/21 193/11 193/20)
193/24 196/13 197/6
199/7 201/14 201/15
201/15 202/20 202/24,
203/14
can't [21] 10/2 10/20
31/14 31/18 39/8 43/1
53/7 55/3 58/4 59/7
60/22 70/13 81/15
85/13 85/17 86/13
86/18 91/13 101/3
157/23 173/1
cancel [1] 127/2
cancelling [1] 157/10
candidates [1] 30/20
cannot [1] 165/19
capabilities [1]
189/11
capability [1] 14/22
capable [1] 74/13
capacity [2] 13/7
85/4
capitalised [3] 35/2
35/15 35/17
captured [1] 115/25
card [1] 123/25
cards [1] 145/9
care [1] 14/10
career [2] 28/11
93/19
carefully [5] 29/4
67/1 139/1 159/24
198/2
Carlisle [1] 165/12
carried [6] 5/22
15/15 15/16 168/25
175/15 194/10
carry [4] 9/2 44/5
131/1 191/20
carrying [2] 130/17
195/19
Carter [3] 181/9
181/9 181/10
case [31] 13/13 51/8
57/3 61/20 81/1 82/20
103/2 103/11 105/6
106/22 107/2 142/2
146/19 147/9 147/19
147/22 149/25 155/13
155/13 155/18 164/21
165/5 165/7 165/11
166/5 166/9 166/16
166/20 174/10 177/21
178/4
cases [19] 30/23
53/4 88/6 102/24
117/21 119/22 120/20
139/4 142/1 146/8
146/10 146/13 146/13}
158/1 162/19 165/4
168/12 204/1 204/9
cash [1] 80/3
catalogue [1] 122/10
catch [2] 34/5 45/4
catch-up [1] 45/4
catches [2] 180/1
180/20
category [1] 96/17
cause [11] 86/17
87/15 133/10 141/19
142/2 145/22 162/17
172/15 184/6 184/7
203/21
caused [15] 69/20
69/21 88/7 105/11
105/20 116/2 117/22
119/23 120/7 128/16
138/13 150/15 158/25)
163/11 202/16
causing [4] 66/16
136/24 172/12 193/4
cautious [1] 126/5
cent [1] 50/25
central [3] 117/24
119/24 120/10
centre [6] 64/6 69/19
116/19 128/15 155/25}
176/16
centres [1] 123/15
CEO [29] 25/18 94/10)
94/21 94/24 95/1 95/3
96/1 97/16 97/19
97/25 98/1 98/2 98/4
101/4 114/16 121/23
121/25 145/15 145/21
154/10 161/22 163/17)
174/15 178/24 179/15)
180/10 184/17 184/25)
197/13
certain [7] 13/16
13/18 14/6 54/2
103/25 157/23 162/6
certainly [16] 15/25
44/17 60/23 68/18
77/24 89/4 93/1
100/24 114/15 126/25]
131/7 152/20 160/17
172/11 173/3 190/16
certification [3]
74/13 75/15 75/19
cetera [5] 14/23
14/23 104/16 134/20
165/15
CFO [3] 25/21 143/1
143/12
chain [9] 59/10 59/10
108/10 109/12 109/25}
120/24 130/3 167/4
174/18
Chair [2] 18/6 83/6
chairing [2] 20/5
28/20
chairman [7] 17/4
47/10 17/11 17/13
19/9 29/15 98/24
challenge [1] 195/3
challenged [1]
166/16
(68) broadcast... - challenged
Cc
challenges [1]
145/24
challenging [1] 186/8)
change [9] 2/21 5/9
6/4 17/13 24/13 24/16
24/21 172/23 196/19
change’ [1] 135/11
changed [2] 4/24
136/12
changes [4] 26/7
52/8 150/14 189/1
changing [4] 111/22
120/11 163/12 202/17)
Channel [10] 141/12
141/16 142/7 148/3
148/4 148/9 148/17
148/19 149/10 152/9
Channel 4 [9] 141/12
141/16 148/3 148/4
148/9 148/17 148/19
149/10 152/9
channels [1] 56/4
chap [2] 58/6 58/7
characteristics [1]
116/6
charge [1] 30/16
Charles [4] 164/24
175/1 177/23 178/12
chart [4] 96/13 96/19
96/23 156/25
chat [1] 19/2
check [5] 79/14
79/16 159/23 189/21
195/23
checking [2] 64/9
79/23
checks [1] 66/1
checksum [1] 196/23
Chief [42] 8/11 8/18
9/14 9/18 10/12 10/13
10/15 11/19 11/20
11/22 11/24 12/6 12/8)
14/9 14/16 15/8 16/4
16/15 16/20 17/6
17/25 20/3 29/8 30/9
30/18 30/23 56/7 57/2
57/3 57/4 57/9 58/9
58/10 61/3 61/19
63/14 65/1 68/22
97/18 142/24 152/2
156/12
choosing [1] 97/9
chose [2] 77/19
123/5
Christou [16] 1/8
1/13 1/14 1/17 1/18
62/9 82/10 83/24
84/14 85/2 92/8 129/9
143/12 149/5 149/6
207/2
Christou's [2] 92/6
142/24
chronologically [2]
100/21 101/19
chummy [1] 155/2
CIO [1] 124/14
circulate [1] 148/14
circulated [1] 149/9
circulation [4]
114/25 115/7 147/13
199/17
circumstance [1]
55/19
circumstances [3]
53/8 87/8 113/19
civil [2] 168/10
198/14
claim [4] 102/15
144/17 147/16 182/23)
claimants [1] 197/20
claimed [1] 141/18
claiming [1] 103/8
claims [6] 99/13
99/16 99/24 103/5
145/11 199/22
clarification [1]
20/15
clarify [3] 26/25
107/21 143/19
clarity [1] 9/3
Clarke [1] 80/12
clause [20] 34/12
34/13 35/13 36/11
36/13 36/17 37/7 37/9)
37/12 37/20 38/5 38/8)
38/10 38/10 38/22
39/2 40/2 40/4 82/15
172/19
clause 102.1 [1]
34/12
clause 16 [1] 172/19
Clause 201.2 [1]
36/11
Clause 201.3 [2]
36/17 37/9
clause 201.6 [3]
36/13 37/12 39/2
clause 403 [2] 38/5
38/10
clause 405 [4] 38/8
38/22 40/2 40/4
clauses [3] 33/16
41/15 82/11
Clayton [1] 143/11
clear [25] 43/1 45/21
46/2 48/24 61/11
61/17 70/15 71/14
78/22 82/10 108/1
108/15 113/3 128/11
131/3 134/13 135/3
138/17 138/22 143/17)
152/6 152/10 160/16
165/17 166/21
clearly [6] 12/13
46/15 101/3 108/7
124/13 149/17
clerk [5] 117/5
117/12 117/23 119/24
120/8
client [7] 105/7
122/17 122/18 156/16}
179/17 180/10 180/24
clients [5] 95/21
96/21 167/10 170/11
188/16
clinical [2] 18/20
18/22
close [7] 51/19 51/20
134/21 135/22 154/24
155/2 189/6
closed [3] 51/12 52/4
55/9
closely [2] 114/11
169/4
closer [1] 137/6
closing [1] 52/12
code [19] 45/23 46/1
46/3 46/7 46/8 46/11
46/14 46/15 47/1
47/25 51/7 52/8 52/9
88/14 133/11 134/14
135/4 136/25 183/4
Codified [12] 32/23
32/25 33/19 33/21
33/24 34/2 34/6 34/17
47/10 73/8 74/22 88/1
coffee [1] 19/2
coincide [1] 25/7
collaboration [1]
189/6
collate [1] 58/15
colleagues [2] 30/22
167/17
column [3] 3/24
49/18 122/13
come [42] 2/18 13/17
14/5 14/6 16/2 23/17
24/24 27/24 28/23
31/20 39/17 42/10
47/15 47/16 48/22
54/10 56/10 57/14
65/7 68/15 68/25 72/7
78/5 78/20 81/14 82/8
89/9 89/10 90/11 98/6
99/8 113/4 123/15
133/23 136/15 171/3
171/9 171/19 173/14
174/14 179/6 181/6
comes [6] 54/8 77/3
86/11 163/5 184/14
202/10
coming [8] 23/9
48/23 80/1 87/21
90/18 90/19 105/15
144/10
command [1] 46/12
commas [1] 62/11
commencement [1]
39/1
commencing [1]
45/11
comment [5] 43/2
72/25 111/17 174/2
185/20
commenting [2]
119/15 141/16
comments [2]
119/14 141/24
commercial [8] 4/10
7/15 7/20 8/3 10/23
29/22 30/16 129/25
commission [1]
186/23
commissioning [2]
169/14 170/6
commitment [3] 70/5
70/23 129/11
committee [20] 8/13
8/16 9/12 9/21 10/17
22/17 24/3 25/1 59/23
60/2 60/4 60/7 60/11
60/13 62/2 98/5 98/12,
98/13 99/1 149/6
committees [13]
8/20 9/4 9/8 10/4 85/5)
98/7 98/9 98/11 98/15
98/17 98/23 121/14
184/23
common [1] 106/11
communication [2]
149/1 174/3
communications [2]
147/10 149/2
community [1] 99/2
companies [8] 3/24
5/7 22/6 22/7 22/16
25/11 28/23 86/5
company [35] 4/7
4/11 5/10 5/13 6/11
6/20 7/6 7/8 12/2
12/20 12/24 13/3 17/7I
20/1 21/15 22/8 22/10
22/12 22/21 22/23
22/24 23/4 23/14 24/8)
26/19 28/15 29/10
95/23 97/24 98/19
114/18 152/2 155/24
183/20 188/17
company's [2] 68/23
123/20
compared [1] 114/16
compelling [2]
145/11 176/15
compensation [3]
139/3 139/8 139/14
competence [3]
14/25 30/4 47/3
competent [5] 40/6
42/1 46/25 65/18
88/10
compiling [1] 103/18
complaint [3] 65/3
67/23 67/25
complaints [13]
105/23 118/18 140/23}
151/6 155/18 155/25
177/9 182/21 186/2
186/19 186/22 190/8
191/2
complete [7] 24/1
28/11 53/14 67/16
79/25 163/5 202/10
completed [1]
195/21
completing [2] 73/4
104/11
complex [1] 14/7
complexity [1] 13/16
compliance [1] 54/15]
complied [1] 55/7
component [2]
116/14 117/14
components [1]
153/1
composition [2] 9/11
45/14
comprise [1] 26/20
comprised [1] 26/21
comprising [1] 24/1
computer [12] 18/17
34/6 72/9 72/13 78/11
127/21 157/16 157/17)
182/15 182/18 183/19)
183/20
Computers [14] 5/19
5/22 6/15 6/22 7/4
7/16 8/14 8/22 9/8
10/5 10/18 11/23 12/1
17/18
conceded [1] 103/2
concepts [1] 96/9
concern [11] 46/13
48/20 131/7 131/7
135/12 142/2 144/21
145/22 184/6 184/7
197/20
concerned [11]
18/23 29/25 40/4 46/3)
59/9 112/22 125/19
127/11 168/23 169/22!
198/21
concerning [1] 19/3
concerns [23] 14/24
19/17 31/12 55/8
64/17 89/2 90/8 91/14)
91/19 105/18 130/17
133/24 135/1 135/11
148/20 148/22 155/20)
163/9 181/13 186/3
187/2 189/17 202/14
concerted [1] 91/20
conclusion [3]
133/23 138/12 173/15)
conditions [1] 32/10
conduct [1] 13/19
conducted [3] 169/2
184/9 195/20
conference [6]
(59) challenges - conference
Cc
conference... [6]
103/21 103/22 104/14}
129/12 129/13 176/4
confidence [6] 29/11
69/16 128/13 130/8
162/17 203/21
confident [2] 147/17
183/15
confirm [1] 93/10
confirmation [1]
138/20
confirmed [1] 141/25
confirms [1] 74/10
conflict [1] 41/11
conjunction [2] 65/6
90/16
connection [3] 7/21
31/13 55/23
consent [1] 30/21
consequences [1]
172/14
consequent [2]
195/15 195/16
Consequently [1]
84/16
consider [11] 13/8
41/22 50/5 62/1 76/23
86/8 128/8 132/13
136/1 198/2 202/25
considerable [1]
166/17
consideration [2]
23/18 62/22
considerations [1]
171/18
considered [5] 5/4
32/2 52/7 139/1
204/12
considering [4] 37/4
50/12 103/12 203/4
considers [1] 56/8
consistent [1]
131/10
consistently [1]
182/21
Console [1] 64/2
consortium [4] 6/16
6/19 6/24 10/9
conspiracy [1] 204/6
Constraints [1]
42/15
constructively [1]
197/24
consult [1] 41/2
Consulting [1]
164/25
contact [5] 71/25
97/14 97/17 111/14
111/16
contacts [1] 126/4
contain [2] 60/24
117/14
contained [2] 75/7
118/24
content [3] 40/5 40/6
115/1
contents [2] 3/7
187/13
context [4] 23/24
47/19 47/20 132/18
continue [7] 19/9
51/16 52/9 87/5
126/12 134/16 197/23)
continued [3] 4/21
50/7 89/22
continues [7] 25/24
49/25 52/11 131/24
137/1 150/21 176/2
continuing [1]
150/11
contract [25] 6/3
12/13 13/6 18/12
21/10 27/4 32/10
33/18 36/20 37/16
37/20 39/21 44/7 53/8
54/13 65/4 65/13 68/4
68/17 85/24 88/4
135/14 170/20 176/10)
193/3
contracted [2] 54/1
84/23
contracting [1] 6/3
Contractor [6] 35/3
35/15 36/13 37/12
39/2 41/19
contracts [4] 34/14
39/16 78/13 84/10
contractual [17] 32/5
32/15 32/19 33/16
64/15 64/19 64/24
66/20 67/19 68/25
75/7 76/20 76/21
77/20 82/11 130/8
17115
contractually [1]
138/24
contravention [3]
64/15 64/18 64/24
contributors [1]
63/17
control [1] 122/23
controlled [1] 59/6
controlling [2] 12/4
66/4
controls [4] 65/24
66/3 186/14 197/22
controls/access [1]
186/14
convenient [1] 179/3
conversation [11]
84/9 106/2 138/21
139/7 139/12 139/13
180/13 180/25 187/5
198/5 198/7
conversations [3]
131/10 188/8 188/19
convicted [1] 168/6
convinced [1] 113/1
COO [3] 57/4 98/2
145/16
Coombs [5] 11/6
49/6 52/2 52/3 52/16
cooperation [1]
170/22
cooperative [1]
125/19
copied [5] 51/10
110/18 112/18 120/15}
177/17
copy [2] 69/9 148/18
core [13] 21/1 36/16
37/8 37/13 39/1 39/3
49/2 86/20 92/5 94/14
154/19 161/17 196/25}
corporate [8] 5/5
5/12 22/20 24/2 28/12
29/3 31/5 98/12
Corporation [1]
127/21
correct [39] 2/17
2/22 4/8 4/23 5/11
5/21 5/24 6/13 7/3 7/5
7/10 7/13 7/23 11/21
12/2 13/25 17/6 20/4
22/14 22/18 24/7
25/13 27/18 27/23
62/3 65/18 73/9 83/10
90/17 93/8 93/9 93/20)
134/7 151/7 164/8
175/2 205/20 205/21
205/22
corrected [1] 48/1
correction [3] 2/13
2/20 2/25
corrections [1]
186/15
Corrective [2] 49/2
49/13
correctly [7] 96/24
122/22 130/20 131/6
155/6 164/5 204/9
correspond [1] 24/21
corresponded [1]
104/8
correspondence [16]
110/19 118/19
126/24 127/6 130/23
131/18 132/6 135/10
166/3 166/3 166/4
174/17 174/19 190/18}
190/23 196/12
corresponding [1]
159/21
corrupted [1] 81/19
cost [8] 52/5 52/6
53/1 53/10 129/1
150/24 173/12 187/16
costs [7] 52/21 52/22
116/7 116/11 131/9
137/23 187/21
could [104] 1/16 1/22
2/3 2/8 2/25 3/20 5/1
8/9 9/16 19/21 23/21
32/1 32/22 34/12
34/24 36/8 36/9 37/9
42/11 43/21 44/7 45/5
46/9 49/23 53/6 59/2
60/19 69/4 71/13
73/12 73/12 73/22
TAIT 74124 77/18
80/11 81/21 83/17
83/22 83/23 86/2
87/15 89/9 91/16
91/17 95/25 96/1
101/20 104/15 105/21
107/20 108/9 109/10
114/22 117/21 117/22}
119/22 119/23 120/7
120/7 120/9 121/17
123/19 127/6 135/6
135/16 140/10 141/8
142/17 153/15 153/20}
154/8 160/23 162/14
162/17 162/21 163/9
163/10 163/11 164/9
164/14 165/7 165/24
167/3 168/17 174/22
177/15 178/22 179/4
179/6 179/15 181/6
182/24 184/24 185/5
186/10 192/5 196/11
202/14 202/15 202/16
202/22 203/18 203/21
couldn't [3] 48/3
168/16 173/5
council [1] 124/17
counsel [7] 81/12
99/3 119/9 127/15
127/16 128/19 147/4
counter [12] 45/12
66/9 115/19 115/24
115/25 116/14 116/15)
117/4 162/5 163/2
172/13 202/7
counters [5] 33/2
36/10 66/5 67/10
74/12
countries [1] 95/2
country [2] 126/16
145/10
couple [3] 28/9
198/12 199/18
course [16] 1/12 3/12)
9/18 11/5 12/21 36/8
41/1 45/21 51/16
77/22 78/3 78/9 79/4
136/6 171/5 205/15
court [12] 103/1
144/9 145/9 146/8
149/25 164/21 164/23
165/4 165/12 165/14
165/14 166/10
courtesy [2] 4/12
29/21
Courtley [22] 16/21
17/3 17/16 17/25 18/2)
18/9 19/7 19/12 19/14)
19/17 25/15 26/2
26/11 26/24 27/15
28/4 29/2 29/24 30/5
60/17 83/14 83/16
courts [3] 144/16
145/10 147/22
cover [2] 11/17 101/7
covered [1] 138/14
covering [3] 146/9
174/23 175/1
create [1] 33/6
created [2] 117/6
196/21
creates [1] 196/20
credence [1] 147/16
credibility [2] 117/20
119/21
Crichton [1] 192/19
criminal [6] 74/14
74/15 165/10 165/11
166/25 192/15
criteria [3] 33/7
39/13 39/18
critical [13] 56/14
56/15 58/2 59/24 60/1
67/20 67/24 68/11
68/12 81/9 81/10
88/22 157/4
criticise [3] 40/6
60/19 88/19
cropping [1] 118/1
Crown [2] 126/10
165/12
crucial [1] 133/15
crudely [1] 202/21
crying [1] 155/16
CS [1] 122/21
CSC [2] 127/19
127/20
CSR [8] 21/1 47/6
47/14 48/22 49/15
52/17 59/25 185/24
curiosity [3] 156/15
156/18 158/11
current [5] 45/13
116/8 132/15 135/13
137/7
currently [4] 116/21
147/4 158/2 162/8
customer [17] 44/19
79/1 83/25 95/19
106/14 144/1 152/12
153/4 156/24 157/11
157/20 158/8 164/10
173/11 173/13 174/3
184/22
customers [10]
17/15 113/7 149/18
153/6 153/7 157/1
157/2 157/2 157/3
187/2
(60) conference... - customers
Cc
cut [1] 18/5
cv [1] 3/19
cycle [2] 24/2 24/2
D
D'Alvarez [2] 119/10
120/16
Daily [4] 51/3
Daka [2] 123/3 135/1
dangling [1] 128/12
data [42] 66/5 66/17
69/19 72/11 74/17
76/3 99/14 102/20
103/7 105/10 105/19
105/24 106/9 106/24
107/5 107/24 108/22
113/12 116/1 116/17
116/17 116/18 116/24}
117/13 120/23 123/14}
128/15 131/5 146/15
150/5 160/8 162/20
163/8 163/13 187/25
188/6 191/23 191/23
199/10 202/13 202/18
204/2
database [7] 115/18
117/2 117/10 117/24
119/25 120/10 186/9
date [19] 27/1 39/3
44/11 45/16 63/12
76/9 100/7 100/23
106/16 137/6 137/7
147/20 154/20 166/5
167/4 189/21 190/14
191/13 191/15
dated [6] 1/25 2/9
71/9 75/2 93/8 199/9
dating [1] 45/2
Dave [14] 70/1 70/17
104/2 104/12 104/13
108/21 108/25 121/23)
124/13 124/25 126/2
127/15 129/7 137/5
David [10] 16/21
17/25 29/24 83/14
88/13 169/6 169/9
170/19 171/1 176/6
Davidson [1] 190/3
Davinder [1] 168/14
day [25] 12/14 12/14
13/15 13/15 23/12
23/20 42/8 77/25
104/10 108/24 117/4
117/11 122/6 156/18
156/19 165/9 167/13
175/7 175/8 175/11
175/14 175/16 184/13}
205/19 206/1
day 1 [1] 122/6
days [10] 18/16
29/23 40/20 85/13
89/4 89/6 106/3 108/6
122/1 177/19
days/months [1]
108/6
De [3] 6/17 6/23 11/9
deal [10] 6/12 7/1
13/15 19/14 62/5
133/13 169/20 193/4
193/11 200/9
dealing [8] 7/24
17/14 17/17 40/21
74/19 82/1 84/25
88/16
dealt [10] 7/11 15/1
23/10 39/24 48/19
48/21 57/18 77/13
199/14 204/18
Dear [1] 175/21
debate [1] 111/10
debit [1] 123/25
debts [1] 149/17
December [6] 51/24
108/15 108/21 109/1
109/15 166/7
decide [1] 22/15
decided [2] 53/9
55/11
decision [13] 22/18
23/3 30/20 51/18
52/20 53/9 53/19
53/22 55/3 62/11
62/13 89/12 149/24
decisions [1] 14/18
dedicated [2] 157/25
176/15
deeper [1] 156/22
deeply [1] 88/21
defects [6] 52/10
87/14 107/15 188/5
191/8 200/5
defence [3] 147/4
165/14 165/18
defendant [1] 165/11
defendants [1] 166/7
deficiencies [2]
45/22 133/11
deficient [1] 150/2
defined [3] 35/2
35/16 55/23
defines [1] 38/10
definitely [3] 67/25
79/9 80/22
definition [3] 38/2
41/14 54/6
definitions [1] 54/22
defunct [1] 169/19
degree [2] 18/15
107/22
delay [2] 130/16
134/2
delayed [2] 125/13
133/10
delegate [2] 14/16
22/15
delegation [1] 14/17
delete [1] 196/19
deliver [2] 33/18
87/17
delivered [6] 32/9
32/14 54/11 55/8
55/18 94/13
delivering [1] 32/18
delivery [4] 21/9
131/25 161/6 184/21
Deloitte [3] 197/21
197/24 197/25
demands [1] 150/12
department [3] 63/16
84/23 85/8
departments [2]
16/23 16/25
dependent [1] 56/4
depending [1] 157/6
depends [3] 65/2
113/9 113/23
deploy [3] 126/9
135/4 135/5
deployed [1] 122/24
deploying [1] 123/11
deployment [1]
155/8
depth [2] 189/17
191/3
Derby [1] 117/11
describe [4] 18/19
45/17 79/22 103/23
described [14] 4/12
13/10 13/20 29/9
38/20 46/24 48/4 56/6
56/22 64/22 70/9 72/4
159/12 203/12
describes [8] 38/1
46/21 63/21 64/1
65/21 65/24 72/1
200/14
describing [2] 47/24
48/1
description [3] 75/1
106/23 106/25
descriptions [1]
107/1
design [2] 45/23
115/20
designed [3] 46/11
65/9 120/23
designs [1] 89/19
desire [1] 197/23
Despite [2] 138/12
182/20
detail [9] 11/14 13/4
21/4 21/4 65/20
130/16 134/1 162/25
185/9
detailed [13] 14/8
20/21 25/24 33/6 33/8
33/15 48/8 57/17
59/12 102/14 162/1
185/7 190/17
details [12] 13/19
14/5 14/6 41/18 99/19)
103/17 150/19 151/23}
158/24 160/14 186/13}
187/4
detected [2] 116/25
117/12
determine [3] 54/14
76/24 120/22
develop [1] 116/5
developer [1] 194/17
developing [1] 176/9
development [16]
21/16 38/4 38/11
38/14 38/17 46/7
47/12 49/3 49/15
57/21 58/3 68/4 88/14
172/22 172/23 176/14}
developments [1]
154/23
develops [1] 39/10
devices [2] 76/12
79/13
devoted [1] 62/8
dialogue [3] 70/1
70/16 129/8
dictionary [1] 54/23
did [82] 4/10 10/6
10/23 10/25 14/5 16/4}
17/13 18/1 18/21 19/9}
24/13 24/19 28/18
29/2 29/17 32/8 32/15
36/3 39/15 41/21
44/23 49/8 54/19
56/18 56/25 60/13
62/17 71/15 75/18
82/6 85/7 85/21 85/25)
87/15 88/2 90/11 94/1
94/4 94/7 94/25 95/15
95/16 99/25 100/6
100/11 102/10 102/11
115/13 115/14 117/5
117/13 125/5 125/7
125/22 127/1 127/3
137/17 148/2 149/2
153/7 158/10 167/13
167/15 171/22 173/11
174/14 180/14 180/16}
182/7 183/20 191/22
193/15 195/21 195/22,
195/23 195/24 195/25}
198/5 198/17 198/20
200/9 204/13
didn't [30] 23/18 31/5
43/15 49/10 49/11
55/4 60/24 63/8 63/10)
67/20 71/18 75/20
75/22 77/25 78/20
81/13 86/6 89/12
89/20 109/1 113/20
135/16 142/9 149/4
149/11 151/15 152/23}
172/14 174/12 204/19}
difference [5] 8/21
9/7 53/25 81/18 128/2
different [19] 12/12
15/6 15/25 31/22
56/11 68/13 75/17
88/24 89/12 89/14
93/22 117/2 117/11
117/12 122/12 139/12)
158/6 159/15 197/25
difficult [10] 51/8
112/18 129/14 129/19)
139/25 140/1 174/1
174/1 174/5 188/12
difficulty [1] 87/9
digital [1] 196/23
direct [8] 19/6 26/10
44/23 58/10 71/25
115/13 166/22 171/10)
direction [1] 146/24
directly [23] 8/7 8/8
16/16 29/2 29/6 44/21
57/23 71/11 94/9
94/21 102/6 104/7
104/8 110/22 116/18
128/6 139/14 144/2
161/20 169/9 171/3
171/9 181/6
director [49] 4/9 7/15
9/13 9/13 10/14 10/16I
10/22 11/5 11/23
11/24 13/14 20/22
24/12 28/18 29/8
29/21 44/18 44/22
49/6 58/16 61/12
61/21 83/15 94/2
94/20 96/3 97/15
102/6 108/6 112/2
112/9 112/25 114/9
114/14 114/18 118/9
121/4 123/13 125/17
137/3 154/9 155/24
163/17 164/24 167/7
170/10 172/7 174/13
184/17
Director's [1] 20/18
directors [6] 23/8
31/3 57/13 57/16 59/4I
59/5
disagreement [1]
165/22
disappear [1] 162/6
disappointed [2]
135/9 136/18
disasters [1] 187/19
discrepancies [12]
80/2 88/8 146/7
149/16 159/2 159/21
160/5 160/9 162/5
162/22 163/21 169/2
discrepancy [14]
117/22 119/22 120/7
160/4 160/7 163/3
163/6 163/11 178/5
178/7 178/16 202/7
202/11 202/16
discuss [8] 8/19 22/1
(61) cut - discuss
D
discuss... [6] 23/13
85/21 138/16 187/10
192/21 195/7
discussed [15] 52/4
52/19 59/21 59/23
60/5 113/4 120/4
130/4 148/18 153/23
176/7 189/14 189/17
191/3 191/5
discussing [3] 70/14
127/16 176/12
discussion [7] 50/11
62/23 85/23 119/13
130/22 173/7 187/23
discussions [7] 42/6
43/16 111/6 129/17
175/14 185/12 198/17)
disgruntled [1]
102/25
display [1] 2/18
dispute [2] 18/12
197/2
disputed [1] 166/8
disputing [2] 162/20
204/2
disrepute [1] 91/5
distinction [1] 159/3
distribution [3] 44/15)
115/10 142/22
diverting [1] 131/14
division [20] 26/20
26/22 26/23 94/5 94/7
94/9 94/11 94/14
94/14 94/18 95/21
110/13 110/14 155/9
161/16 161/16 165/10
170/10 175/2 183/3
divisions [6] 17/17
94/11 94/12 161/14
161/19 161/20
do [119] 1/24 8/6
11/12 21/21 23/3 24/5)
27/25 31/6 31/11
37/16 44/16 46/23
47/9 47/24 48/4 48/10
50/23 51/1 51/5 53/5
53/10 53/22 56/13
63/17 68/24 71/22
72/19 76/23 77/19
79/3 80/18 81/4 82/9
82/25 82/25 83/1 83/4)
84/3 84/5 86/8 86/21
87/19 87/19 87/23
91/3 96/6 97/7 99/19
100/3 100/7 101/9
101/13 101/16 102/1
105/13 105/17 106/11
107/11 118/11 120/12)
120/21 125/16 126/18
126/18 126/19 128/25}
130/21 131/1 131/13
142/5 142/6 142/7
142/10 146/12 148/14)
148/22 151/23 153/2
158/11 159/15 164/3
164/4 167/20 172/16
172/18 173/13 174/14}
177/2 180/9 180/11
180/12 180/13 180/25)
183/7 185/1 186/17
187/4 187/24 188/3
189/15 189/19 190/20)
190/21 191/2 192/25
193/2 193/7 193/10
194/2 195/8 195/8
195/19 195/20 200/20;
201/1 201/4 201/6
201/8 203/23
document [90] 13/5
24/24 27/24 31/14
34/4 41/22 44/8 45/2
45/6 45/7 46/18 46/21
46/24 47/6 47/14
47/23 48/5 48/23 49/1
49/4 49/8 49/13 63/2
63/21 64/20 64/21
65/6 66/23 67/14
70/25 71/3 71/4 71/14
72/1 72/5 72/7 75/7
77/5 77/12 77/15
77/21 78/11 78/16
79/6 81/6 82/8 96/6
98/6 100/18 100/20
105/15 106/19 106/23)
107/9 107/14 108/10
109/13 111/11 113/15)
115/3 119/15 120/13
140/22 158/22 162/3
163/14 163/15 164/5
164/15 166/1 176/7
192/6 192/7 194/22
196/4 196/10 199/6
199/8 199/9 199/13
199/17 200/1 200/3
200/4 200/10 200/14
201/12 201/13 201/15)
204/4
documentary [5]
141/12 141/16 142/8
142/10 159/9
documentation [2]
155/3 196/7
documents [17] 1/21
27/12 47/7 47/9 50/22
73/2 86/7 88/16
106/12 120/19 126/25)
141/10 152/5 153/24
158/15 193/25 205/3
does [12] 51/4 55/16
64/9 70/4 82/15
115/25 136/4 140/11
150/19 156/21 171/6
201/9
doesn't [10] 55/11
80/1 149/8 159/23
164/11 180/22 190/16)
200/9 200/17 203/14
dog [1] 152/24
doing [10] 55/22
56/20 66/22 68/10
68/19 91/17 110/4
130/5 135/17 155/9
don't [104] 7/18 8/23
9/10 10/20 10/21 11/7
11/16 15/10 15/20
25/23 27/12 30/1 30/7
41/11 43/10 44/22
46/5 46/13 47/3 51/5
52/24 53/24 54/5 54/5
54/7 57/13 60/20
60/25 63/20 63/23
65/14 67/15 68/11
69/2 70/19 77/25
78/13 79/4 81/7 81/9
81/15 83/11 87/16
88/7 88/18 88/19 89/6
89/10 90/13 90/23
90/25 91/2 91/12
91/16 91/22 91/24
96/7 97/9 97/12
100/23 101/5 101/18
104/6 104/9 105/14
105/22 111/9 114/5
115/5 118/11 121/10
134/3 134/23 139/22
143/3 143/8 143/9
148/24 149/1 152/18
155/21 156/15 170/17]
171/15 171/25 182/9
183/8 183/9 185/9
187/4 188/6 189/16
189/21 190/20 190/23
190/24 191/5 192/6
192/13 193/2 193/6
200/25 202/21 205/1
done [12] 14/20
21/18 35/7 40/13
40/19 40/20 41/7 42/2
42/2 70/21 185/2
200/22
door [2] 19/1 89/7
dormant [1] 26/19
dotted [1] 110/16
doubt [1] 81/17
doubts [1] 128/3
down [58] 13/13 14/1
14/11 14/18 15/4 18/1
20/7 20/7 24/24 25/17
25/23 26/18 27/24
36/9 36/18 39/17
42/13 42/14 42/21
49/6 51/12 61/1 66/10
72/7 72/23 73/23
76/15 80/1 82/8 83/11
83/23 86/11 96/10
98/6 98/20 99/22
104/15 106/15 108/17]
115/15 133/4 136/2
137/18 142/18 143/21
144/3 144/19 145/4
162/23 165/16 166/13
167/16 174/4 175/17
182/13 185/23 185/24}
194/24
downplay [2] 111/8
112/19
downplaying [1]
112/16
draft [6] 83/20
108/14 139/16 174/23}
175/4 175/20
drafted [4] 47/21
164/20 176/24 199/10}
drafting [3] 39/12
41/2 175/17
draw [1] 179/22
drawer [3] 181/24
182/1 182/4
drawn [1] 111/9
drew [1] 199/20
drinks [1] 201/25
driven [1] 150/25
DT [1] 195/1
DTI [3] 85/3 85/4
85/20
due [8] 3/12 9/18
51/13 69/16 103/8
128/13 140/3 150/22
dug [1] 156/20
Duncan [21] 29/17
29/19 30/16 30/23
69/9 69/11 70/11
70/13 93/2 93/6 105/5)
121/23 138/20 145/20
156/22 180/7 185/8
187/10 187/13 197/13}
207/8
duplicate [1] 117/6
duplicated [1] 115/18)
during [23] 18/21
45/11 45/21 60/21
84/8 95/18 100/11
102/23 103/22 114/14}
118/12 124/23 131/22)
134/6 134/10 135/2
140/3 141/23 157/7
180/9 184/5 185/1
205/15
duties [1] 194/17
DXC [1] 127/22
E
each [16] 18/11 19/1
24/14 26/23 58/16
84/22 107/2 112/4
146/5 147/22 152/9
153/10 153/19 184/4
184/6 184/24
earlier [18] 42/17
49/21 54/4 59/25 65/8
69/6 73/13 79/8 80/5
107/21 109/7 118/19
130/3 139/17 139/23
148/6 160/23 203/12
early [10] 10/11
105/17 106/3 108/6
108/24 114/7 139/25
176/17 184/5 184/8
ears [1] 111/19
East [1] 95/3
EDS [2] 18/11 18/13
effect [8] 27/25 28/3
30/25 62/17 73/21
87/4 89/19 117/16
effectively [6] 32/12
39/5 52/4 89/16
134/21 146/4
effectiveness [1]
120/9
efficiency [2] 23/13
23/15
efficient [2] 22/6
23/10
effort [2] 91/20
134/17
efforts [2] 166/18
175/18
eg [1] 116/17
eg Reference [1]
116/17
eight [1] 144/23
either [15] 8/7 12/24
13/22 47/9 83/13
125/23 143/24 146/12)
153/17 164/9 174/16
196/20 196/23 204/15)
204/21
Electronic [1] 38/18
elementary [1] 46/16
elements [1] 17/24
Elgar [1] 85/19
else [5] 11/1 31/21
53/18 81/16 84/12
elsewhere [2] 79/24
178/16
email [66] 51/10 69/5
69/9 70/9 70/11
101/22 101/23 105/23)
106/1 106/6 107/25
108/1 108/8 108/8
108/10 108/11 109/21
109/22 112/20 113/1
113/2 113/4 113/11
113/14 119/5 119/6
120/18 120/24 121/18)
125/5 127/8 129/23
130/20 134/16 136/17
141/11 142/5 142/12
142/19 145/18 148/6
148/25 154/12 155/14)
167/4 169/12 170/19
174/8 174/23 175/1
177/17 181/8 181/9
182/25 183/9 183/25
184/1 184/8 184/16
190/2 190/23 194/2
194/8 197/6 197/7
197/9
(62) discuss... - email
E
emailed [1] 104/7
emailing [2] 137/22
167/17
emails [11] 31/15
102/3 110/8 110/21
119/10 139/17 141/1
152/1 189/20 190/14
191/7
embedded [1] 58/3
EMEA [1] 28/13
EMEIA [1] 95/11
emerged [1] 49/14
emotional [4] 125/20
125/22 126/1 168/14
employed [3] 17/7
18/25 169/1
employee [3] 80/19
81/10 82/22
employees [7] 14/21
76/16 76/20 78/8 90/5
172/25 198/21
encouraged [1]
138/9
end [14] 8/25 31/7
32/11 34/9 39/17 42/8
54/18 55/14 62/15
95/17 133/14 160/9
162/7 167/4
endeavour [1]
135/21
endeavoured [1]
165/19
ended [1] 157/9
endorsed [1] 176/7
ends [1] 104/17
engage [2] 123/19
153/10
engaged [1] 153/8
engagement [2]
170/24 171/4
engaging [2] 106/14
128/1
engineer [1] 51/13
engineers [4] 53/3
53/5 57/21 58/3
England [1] 31/7
English [3] 58/8 59/4
74/2
enhancements [1]
189/11
enhancing [1] 189/8
enquiries [1] 180/4
ensure [12] 13/21
13/23 13/25 56/20
74/10 106/24 115/20
138/16 146/15 168/24}
176/10 181/23
ensured [1] 200/15
ensuring [2] 15/5
39/15
entered [3] 26/17
33/1 146/16
entire [1] 157/25
entirely [1] 149/15
entities [2] 4/18
135/21
entitled [4] 106/8
130/6 141/12 199/10
entity [2] 30/14 98/25
entry [3] 122/16
163/4 202/8
episode [1] 157/25
EPOS [2] 41/19
43/11
EPOSS [20] 38/17
41/14 42/22 43/9
44/10 45/11 45/22
46/1 46/4 47/25 49/25)
50/4 50/6 50/13 51/13)
52/21 53/11 62/7
62/10 88/14
equipment [2]
107/11 107/16
equivalent [4] 46/12
98/2 99/3 190/18
Ernst [5] 194/3
194/11 194/13 195/2
195/3
error [10] 50/23 51/1
51/1 116/25 117/9
117/22 119/23 120/8
147/2 147/7
error’ [2] 69/20
128/16
errors [9] 64/9 66/15
87/14 87/15 107/15
144/17 188/5 191/7
200/4
escalate [2] 114/2
174/4
escalated [1] 157/13
escalation [2] 103/14
164/9
escalations [1]
153/17
especially [1] 169/18
essential [1] 83/25
essentially [6] 37/15
76/2 116/11 142/24
178/14 181/18
established [3] 24/23
45/13 87/13
estate [1] 64/8
et [6] 14/23 14/23
104/16 124/17 134/20)
165/15
et cetera [4] 14/23
14/23 104/16 165/15
ete [1] 111/20
ethic [1] 125/19
Europe [2] 95/3
144/1
evaluate [2] 51/18
135/18
evaluation [2] 169/14)
170/6
even [19] 13/8 40/2
74/21 101/12 103/11
105/22 117/19 126/14
137/2 139/20 145/23
150/7 150/8 167/3
170/2 178/16 191/8
193/6 202/25
event [3] 106/21
107/12 173/2
events [4] 64/11
122/22 152/9 184/4
ever [15] 44/23 60/20
70/20 72/4 85/25
104/6 104/7 115/5
126/21 137/11 183/20
188/3 191/3 198/5
198/17
every [11] 9/23 13/4
13/5 13/6 68/3 68/7
84/22 129/1 147/15
147/19 149/25
Everybody [1] 53/4
everyday [1] 116/11
everything [8] 23/11
25/8 36/5 53/17 73/6
88/6 151/4 184/16
evidence [55] 3/11
40/7 40/9 41/4 41/21
43/3 43/14 48/16
48/18 50/1 50/7 55/10
56/13 60/5 62/12
62/14 67/19 74/14
74/15 75/8 76/21
78/19 80/8 80/20 82/4
82/5 82/17 82/24 88/9
88/13 88/23 89/15
90/18 92/6 92/10
103/4 104/19 104/24
112/15 113/15 113/20
136/10 149/20 150/1
152/7 154/21 156/10
165/2 165/4 167/1
183/13 192/16 198/22
205/14 205/15
evidenced [1] 166/19}
evident [2] 152/2
189/6
evidentially [1] 74/12
evolving [1] 189/7
exact [1] 187/4
exactly [10] 18/7
24/17 24/17 27/3
27/18 55/15 101/5
113/2 164/13 184/14
examine [1] 79/7
examined [2] 86/7
144/22
example [23] 17/19
34/21 35/15 46/10
63/1 73/6 80/12
103/25 105/2 110/5
113/6 114/16 119/2
122/12 138/8 152/19
157/19 161/4 174/10
183/14 189/18 198/18
201/24
examples [1] 44/6
Excellence [1]
176/16
excellent [2] 127/25
140/20
except [1] 9/14
exception [2] 13/12
196/1
exchange [3] 31/15
102/11 189/22
Exchanges [1] 22/23
excluded [1] 88/2
Excuse [1] 62/5
executed [1] 195/18
executing [1] 12/13
execution [1] 135/19
executive [51] 8/11
8/13 8/18 9/14 10/12
10/13 10/15 11/19
11/20 11/22 11/24
12/6 12/9 14/9 14/12
14/16 15/8 16/4 16/15}
17/4 17/6 17/9 18/6
19/9 20/3 29/9 30/9
30/18 30/20 30/23
31/5 57/2 57/3 57/5
61/3 61/19 63/14 65/1
68/22 86/1 86/3 98/5
99/1 102/4 112/7
132/5 132/8 136/7
136/7 149/6 179/17
Executive's [3] 9/18
56/7 57/9
executives [12]
112/5 144/2 148/15
148/21 148/23 149/3
152/11 175/25 176/20}
189/10 205/8 205/8
exercise [1] 14/10
exhibit [1] 3/14
exist [3] 189/19
190/20 190/21
existed [1] 57/15
existence [1] 196/5
existing [2] 104/22
176/9
exiting [1] 173/11
expand [3] 13/2 24/9
57/25
expanded [2] 95/13
95/13
expect [8] 80/23
112/5 114/2 163/21
170/21 192/6 202/25
204/15
expected [9] 62/16
65/1 80/18 98/21
121/9 124/20 144/10
163/18 171/19
expecting [1] 163/23
experience [6] 28/5
32/2 123/10 124/16
127/18 176/22
experienced [6]
124/6 124/8 125/1
141/22 188/18 198/21
experiences [1]
102/16
expert [20] 40/21
77125 78/22 78/24
79/2 79/9 80/16 80/19
80/23 81/10 81/20
86/13 142/14 146/14
146/23 147/25 165/14)
177/21 192/16 193/9
expert's [2] 164/23
165/5
expertise [1] 176/22
experts [2] 165/18
165/21
explain [3] 8/9 22/19
81/1
explained [1] 133/12
explains [1] 106/18
explanations [1]
104/24
explicit [1] 159/25
explore [2] 110/4
176/8
exposes [1] 66/12
expressed [1] 144/21
Expresses [1]
197/23
expressing [2] 19/17
155/20
expressions [1]
34/18
extend [1] 116/1
extended [1] 27/6
extension [3] 26/17
27/1 27/1
extensions [1]
184/22
extent [1] 151/13
external [3] 123/5
190/6 197/10
extract [1] 46/11
extracted [1] 79/15
extracts [1] 47/23
extremely [2] 46/3
133/5
EY [4] 194/6 195/9
195/15 196/8
eye [4] 111/21
F
F014 [1] 41/13
F4 [2] 38/20 41/5
faced [2] 144/16
173/18
faces [2] 144/4
145/11
facilitate [2] 111/3
176/19
facility [1] 193/19
facing [2] 123/21
(63) emailed - facing
F
facing... [1] 137/14
fact [26] 16/7 24/20
26/9 76/17 76/21
78/10 78/14 78/18
78/20 79/5 79/8 79/19)
79/20 81/8 87/13
88/23 102/19 109/3
109/11 129/18 130/22)
159/8 162/14 197/15
199/20 203/18
factors [1] 45/19
facts [1] 16/2
fail [1] 64/13
failed [4] 87/17
123/25 204/22 204/23
failings [2] 39/16
86/9
fails [1] 102/15
failure [4] 104/1
106/25 204/24 204/25)
failures [5] 64/14
104/23 105/2 107/11
107/16
fair [9] 27/14 54/12
87/8 114/21 129/21
132/25 134/22 141/3
169/2
fairly [3] 29/7 146/6
202/21
fairness [1] 21/14
fait [1] 36/5
fall [2] 94/7 96/17
false [5] 168/8
181/14 182/6 182/20
204/6
familiar [9] 35/22
96/9 115/2 115/2
162/4 167/23 167/24
199/13 201/13
familiarity [1] 36/6
FAQ [1] 110/3
far [13] 15/14 29/25
38/13 48/14 50/22
61/16 77/7 131/24
146/24 153/24 153/24}
154/3 190/17
fashioned [1] 150/18
fault [6] 76/12 79/12
79/17 79/19 147/1
182/22
faults [1] 79/21
FD [4] 127/16
featured [1] 168/3
features [1] 42/24
February [17] 154/9
158/18 159/9 164/16
164/19 165/1 165/8
165/25 166/21 166/22
167/5 167/12 172/16
174/18 174/18 175/7
177/19
fed [1] 60/23
Federation [2] 126/6
126/12
feedback [1] 191/16
feel [8] 15/23 91/2
91/4 91/4 109/1 132/7
136/2 137/4
feels [1] 128/20
fees [1] 131/9
fell [1] 94/17
felt [3] 86/15 89/8
91/4
few [19] 45/6 51/17
66/25 87/11 100/17
101/20 102/3 115/15
122/1 127/17 131/20
141/17 146/2 149/19
152/13 162/2 177/19
183/10 201/25
fewer [2] 23/17 24/13
fight [1] 147/22
figure [2] 163/2
202/6
figures [1] 160/5
filed [1] 144/10
filter [1] 13/8
filtered [1] 14/24
filtering [1] 14/12
filters [2] 13/20 14/11
final [18] 7/6 51/15
52/11 91/14 104/18
108/19 118/14 118/24)
130/13 148/1 150/9
159/23 160/1 165/14
189/4 192/10 196/10
198/12
finally [5] 4/9 70/1
129/7 150/19 166/10
Finance [2] 58/9
58/10
finances [1] 149/20
financial [12] 25/8
25/9 25/18 56/7 66/14
115/22 115/24 138/16)
141/19 142/25 150/12)
168/24
financials [1] 130/20
find [6] 68/20 74/3
91/21 119/13 168/17
192/15
finding [1] 90/4
findings [2] 122/20
190/3
fine [8] 36/7 47/18
83/5 86/22 87/5 87/6
92/15 140/13
finish [1] 26/16
finished [1] 104/11
Finland [1] 17/21
fire [3] 1/9 8/24 9/6
firm [3] 101/10 146/6
157/17
firms [1] 93/22
first [63] 1/21 1/22
3/15 3/16 4/5 7/18
11/13 16/6 18/11
18/14 18/21 25/5
25/10 31/23 40/15
45/7 47/10 68/19 71/4
72/18 75/7 82/14
87/24 87/25 89/5
90/12 91/15 91/19
97/17 99/11 100/12
100/18 101/20 105/3
108/13 110/21 113/2
119/19 122/1 122/13
125/1 126/10 127/13
129/18 129/22 137/24
140/8 145/1 151/5
152/1 153/1 154/24
157/22 159/18 162/25I
164/18 180/10 191/11
192/25 193/15 193/22
196/16 205/19
firsthand [1] 124/15
firstly [5] 36/19 44/15]
69/17 70/8 71/3
fishing [1] 147/6
fit [4] 24/7 29/11
53/17 87/18
fitness [1] 87/25
five [2] 26/22 86/23
fix [3] 46/7 202/22
204/5
fixed [2] 128/23
134/15
fixes [2] 68/6 122/24
fixing [3] 193/21
201/4 203/5
flag [2] 56/24 111/18
flagged [1] 57/1
flags [1] 197/24
flashing [1] 158/9
flawed [6] 105/10
105/19 147/21 154/22
156/10 168/11
flaws [1] 184/7
flow [2] 57/23 86/16
flowed [1] 47/11
flows [3] 13/11 57/14
91/10
focus [2] 131/15
177/13
focused [4] 17/14
33/21 115/23 185/14
focusing [2] 26/6
33/11
Foerster [2] 63/7
73/3
folks [1] 1114/6
follow [1] 24/11
follow-up [1] 24/11
followed [1] 189/5
following [16] 16/12
24/17 37/13 39/4
49/14 52/1 66/13
109/18 111/6 115/17
119/19 120/5 122/4
128/18 192/22 206/1
follows [18] 73/6
102/13 107/9 108/20
110/1 119/11 119/18
120/3 120/17 121/22
122/10 127/9 141/14
142/21 162/6 166/6
168/1 197/11
foot [1] 124/13
fora [1] 85/9
forced [1] 182/18
fore [1] 135/13
forensic [1] 145/8
foresee [1] 135/17
forget [2] 30/1 67/15
forgotten [1] 26/14
form [5] 64/1 108/16
128/24 131/1 171/6
formal [8] 45/16 65/3
67/23 67/24 68/17
98/11 106/22 147/23
formally [5] 51/12
51/19 51/20 130/7
135/9
format [2] 76/2 138/2
formed [1] 95/22
Fortunately [1] 46/13)
forward [7] 90/11
90/19 126/9 137/6
138/11 145/2 185/15
forwarded [1] 130/3
forwards [1] 154/17
found [4] 147/1
147/20 150/1 160/1
four [4] 24/3 24/6
42/14 201/3
franchises [1] 146/4
frank [4] 102/11
frankly [3] 10/20 31/1
63/19
fraud [4] 66/14
117/19 144/16 146/7
fraudulent [2] 102/25
172/21
free [1] 102/11
Freedom [1] 180/5
frequent [1] 66/1
Friday [3] 119/13
127/10 141/17
friendly [1] 84/12
front [4] 1/21 1/23
93/7 106/2
fruitful [1] 131/24
FSMC [8] 24/3 24/6
25/5 27/17 28/21
28/24 60/3 83/22
FUJ00000071 [3]
34/4 34/10 73/12
FUJ00001743 [1]
74/24
FUJ00003534 [1]
83/17
FUJ00003693 [1]
19/22
FUJ00003704 [1]
24/25
FUJ00080526 [2]
106/7 199/7
FUJ00080690 [1]
44/7
FUJ00081527 [1]
158/18
FUJ00088036 [1]
63/2
FUJ00093034 [1]
114/22
FUJ00094392 [1]
119/4
FUJ00095628 [2]
69/5 127/7
FUJ00095658 [1]
131/19
FUJ00096238 [1]
137/18
FUJ00096312 [1]
133/1
FUJ00116969 [1]
96/2
FUJ00153750 [1]
167/3
FUJ00156064 [1]
107/20
FUJ00156195 [1]
142/17
FUJ00156432 [1]
164/14
FUJ00156443 [1]
165/24
FUJ00168511 [1]
179/16
FUJ00168523 [1]
181/7
FUJ00168649 [1]
185/5
FUJ00174184 [1]
101/21
FUJ00174290 [1]
124/17
FUJ00174378 [1]
141/8
FUJ00174417 [1]
154/8
FUJ00174418 [2]
174/22 175/1
FUJ00174419 [1]
175/20
FUJ00174422 [1]
193/24
FUJ00174428 [1]
194/23
FUJ00174576 [1]
182/12
FUJ00174662 [1]
185/21
FUJ00174708 [1]
187/7
FUJ00174721 [1]
188/22
FUJ00174724 [1]
(64) facing... - FUJ00174724
F
FUJ00174724... [1]
190/12
Fujitsu [220]
Fujitsu's [9] 24/7
25/8 78/9 82/4 131/9
157/21 184/25 192/17)
192/23
full [6] 1/16 17/7
17/16 93/4 126/22
168/24
Fullwood [1] 130/2
fully [2] 115/21
149/22
functional [4] 16/25
17/24 19/12 63/24
functionality [1] 52/9
functions [1] 18/1
fundamental [3]
37/23 64/8 153/1
fundamentally [2]
150/17 171/16
further [21] 13/12
14/1 14/18 20/7 42/14}
42/20 43/2 66/10 73/1
91/13 95/23 119/13
147/5 156/20 169/12
178/3 180/22 181/2
184/9 186/13 203/8
fuss [1] 71/20
future [10] 104/23
139/4 162/22 176/10
176/12 177/3 185/20
187/11 189/12 190/15
G
gain [4] 103/10
162/14 176/18 203/18)
Gareth [28] 65/8
67/14 71/20 71/22
80/15 81/2 86/12
104/3 104/4 104/6
106/6 106/9 109/5
152/19 158/19 164/15
164/20 166/19 167/18)
174/7 175/11 175/18
177/20 192/1 192/17
193/7 198/14 199/10
Gary [1] 166/18
gathered [1] 104/25
gave [5] 88/13 88/22
127/24 157/19 188/6
Gavin [13] 102/2
105/4 108/11 110/2
1114/5 111/6 112/11
127/9 137/22 141/11
142/21 145/16 179/16)
general [7] 62/22
99/3 105/23 142/7
147/6 177/16 194/13
generally [4] 107/6
173/13 193/22 195/4
generate [2] 163/10
202/15
generating [1]
182/24
genuinely [2] 129/6
153/11
get [18] 58/24 59/1
68/7 69/22 79/2 79/2
85/10 102/10 111/9
111/19 128/23 137/8
149/8 152/9 158/9
175/5 191/12 202/24
gets [3] 58/16 137/3
204/8
getting [7] 110/5
138/13 153/13 153/14)
153/19 154/2 179/1
Gilbert [8] 30/8 94/22
96/3 127/8 142/20
143/10 149/5 161/20
Girobank [3] 6/17
6/23 11/9
give [15] 17/19 21/9
29/5 31/2 38/13 47/8
58/20 63/7 82/16 93/4
103/19 132/7 192/16
198/22 203/7
given [20] 72/4 89/21
104/2 113/5 136/10
151/22 151/23 153/21
158/5 158/12 169/20
170/9 177/23 181/1
183/13 189/14 191/18)
197/3 204/4 205/3
gives [2] 46/10
104/12
giving [5] 92/10
122/21 188/3 198/9
205/14
global [4] 7/7 7/11
30/12 70/19
go [62] 3/20 5/6
11/13 14/22 16/2 17/2
20/7 20/21 23/11
25/17 25/21 30/10
34/12 34/24 36/8 36/9
38/9 38/22 40/1 42/19
45/5 45/6 55/1 55/2
55/2 55/11 59/3 62/6
69/8 73/12 73/18
73/23 73/25 74/4 74/7,
76/15 79/2 83/23 85/1
88/18 94/18 95/23
100/20 101/19 107/25)
109/11 113/20 119/5
127/3 135/16 145/14
152/1 159/17 162/2
162/12 165/16 171/22)
181/25 183/24 199/7
201/12 201/14
goes [14] 42/25
45/17 51/15 62/21
64/4 74/17 77/7
103/19 107/14 132/2
134/12 176/21 187/41
203/25
going [50] 4/17 18/6
18/17 31/22 36/4 45/5
48/9 53/16 53/17
66/19 68/20 90/6
92/21 99/10 100/20
101/19 101/21 101/22
106/5 109/24 114/7
114/22 115/15 126/14]
127/5 133/13 136/1
143/19 145/17 146/16
147/12 152/21 158/15
158/16 164/18 165/3
174/18 174/19 175/11
175/14 178/23 179/14
182/11 193/13 193/24]
199/6 204/8 204/19
204/23 205/7
gone [7] 49/5 62/17
76/23 80/21 113/22
149/21 171/16
good [22] 1/3 18/10
43/18 44/2 47/2 51/8
83/25 84/17 85/3 91/5
92/19 122/8 127/11
127/24 174/2 174/2
184/20 187/24 188/14]
188/16 189/2 203/23
got [23] 18/16 20/17
21/12 21/17 25/15
29/19 30/10 39/9
42/15 47/1 48/1 53/4
53/16 67/15 68/7 74/5)
74/21 78/11 82/19
101/7 172/15 174/6
174/7
govern [1] 184/22
governance [4]
98/12 153/16 174/2
184/20
Government [8]
83/23 83/24 84/22
86/3 86/4 94/11 96/14
97/2
granularity [2] 13/16
48/16
grateful [2] 92/11
205/16
Grayling [1] 111/18
great [6] 18/13 28/4
130/4 152/4 184/3
193/4
greatly [1] 138/9
grew [1] 17/23
gross [2] 15/22 91/1
ground [2] 57/18
128/4
Groundhog [1]
184/13
group [34] 4/14 4/19
5/7 5/14 7/22 12/23
15/9 15/11 23/4 28/23
30/11 30/12 61/6 61/9
61/10 61/12 61/18
70/19 89/24 96/15
96/20 97/6 101/24
127/14 127/15 127/18}
128/19 135/13 136/7
144/7 165/11 194/11
198/14 198/22
Group's [2] 5/22 7/12
groups [2] 103/16
182/17
grow [1] 128/6
growing [3] 18/19
18/23 150/12
grown [1] 162/10
growth [1] 189/9
guess [1] 143/24
guidance [1] 169/19
guilty [1] 166/7
gulf [1] 136/20
Guy [3] 129/23
129/24 167/23
Guys [2] 154/14
154/24
H
had [147] 4/5 9/6
10/8 10/10 12/16
13/15 14/9 14/14
16/16 17/5 17/16
18/13 18/15 19/1 19/5}
19/10 19/11 23/19
24/19 24/20 26/23
27/25 28/2 28/3 28/25
29/11 29/23 30/4
30/10 31/12 31/13
32/19 33/23 36/6 37/8
41/7 42/1 43/10 43/12
45/8 47/11 51/5 51/7
57/5 57/20 58/2 58/8
59/4 59/6 65/2 65/3
67/22 67/24 68/12
70/20 70/21 71/25
72/19 77/17 78/15
83/25 84/1 84/8 84/9
84/14 84/15 84/23
85/11 85/18 89/8
89/10 99/16 99/18
100/13 102/23 108/22}
109/21 110/16 117/2
4117/5 11716 117/12
118/2 118/18 119/14
122/20 122/22 124/21
124/25 125/23 126/1
127/19 133/22 133/23}
135/15 135/20 135/20}
135/23 136/11 138/20}
139/6 139/11 156/19
156/19 157/16 157/17]
157/20 158/5 158/23
165/2 168/21 170/12
172/2 174/2 174/2
174/3 174/9 178/5
180/3 180/15 183/25
184/3 184/10 184/20
184/20 184/21 184/23}
185/12 186/22 186/22!
187/2 188/9 188/19
190/2 191/18 193/2
195/21 195/23 196/2
196/2 196/2 196/14
196/18 197/3 199/17
200/11 200/15
hadn't [2] 46/18
157/19
haggle [1] 82/10
half [2] 121/20
132/17
Hamilton's [1]
155/17
hand [3] 58/21 58/24
122/25
handbook [1] 58/23
handle [1] 102/23
handled [1] 91/9
handling [3] 50/24
51/1 147/9
hands [4] 17/16
happen [4] 42/5
143/23 192/21 204/13)
happened [14] 26/15
31/18 40/5 41/10
44/13 59/19 78/13
88/10 90/11 158/24
184/5 187/1 204/17
204/18
happening [2] 59/15
172/17
happens [5] 18/12
25/8 108/23 117/17
200/7
happy [2] 47/9
148/19
hard [5] 8/21 9/7 9/16
9/16 110/16
hardware [1] 104/1
Harris [2] 142/25
143/7
has [110] 2/2 5/4
13/9 13/12 14/16
17/10 28/4 38/12 42/9)
44/8 46/8 46/15 48/1
53/4 55/21 62/7 63/2
64/5 64/12 66/6 67/2
69/2 69/16 82/4 88/15
89/15 91/5 93/16
102/18 102/22 102/23)
103/1 103/2 104/25
106/10 106/16 108/15}
108/23 109/3 109/6
109/13 113/3 114/4
117/10 122/12 124/14)
126/2 127/13 128/3
128/7 128/13 128/18
130/3 131/23 133/6
134/15 134/20 134/22!
138/13 141/15 141/25)
143/20 144/7 144/21
145/3 145/7 145/18
146/16 147/1 147/1
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has... [40] 147/13
148/13 149/21 149/25)
150/1 150/15 152/7
154/20 155/7 155/10
155/16 156/9 158/19
159/7 162/13 162/24
163/8 164/20 169/6
169/24 171/2 171/3
171/9 175/16 176/14
176/19 179/20 180/3
182/17 182/19 182/21
187/17 190/7 190/14
196/11 197/12 200/19)
202/13 203/17 204/17,
hasn't [3] 149/11
171/18 171/23
hasten [1] 15/21
have [354]
haven't [7] 63/6 63/8
68/14 80/14 154/10
154/15 190/21
having [10] 1/8 85/3
86/7 88/5 108/7
135/17 147/7 157/25
193/18 195/6
he [126] 8/11 10/14
16/7 16/9 16/19 16/21
16/24 17/6 18/10
18/14 18/14 18/15
18/17 18/18 18/23
18/24 19/3 29/8 29/10
29/11 29/14 29/20
29/21 29/23 30/1
31/12 31/15 44/19
44/21 51/5 57/5 57/8
58/5 58/6 58/7 58/10
70/1 70/16 71/24
83/11 84/15 85/3
86/12 88/22 88/23
89/3 89/8 89/8 89/12
102/2 102/5 104/7
105/4 108/21 108/24
109/2 109/2 110/9
112/13 119/9 119/10
119/10 119/18 119/20}
120/2 120/16 121/22
121/24 121/25 124/4
124/25 125/18 125/20
126/4 127/1 127/2
127/3 127/10 128/3
128/7 128/10 128/11
128/20 129/4 129/7
129/25 130/2 130/3
130/12 130/14 132/2
132/4 132/12 135/7
136/18 137/1 137/22
138/3 138/7 138/19
142/14 142/15 146/1
147/6 149/5 150/21
152/3 154/17 154/18
155/10 167/19 167/25)
168/25 169/11 171/10)
171/11 171/22 172/19}
175/3 177/21 177/22
178/4 179/20 179/22
198/18 205/20
he's [5] 28/5 48/15
66/21 83/11 130/2
head [6] 28/12 40/17
103/13 169/7 169/8
181/10
headcount [1] 20/17
headed [1] 138/7
heads [2] 105/6
141/14
hear [6] 1/5 1/7 44/2
92/19 92/21 140/18
heard [7] 80/12 82/4
88/5 101/16 118/18
169/25 180/15
hearing [1] 206/1
heart [2] 48/9 66/19
heavily [1] 64/6
held [4] 3/23 25/10
27/9 30/6
Helen [4] 183/1 183/1
183/2 183/6
help [4] 35/13 82/12
91/13 104/20
Helpdesk [1] 76/8
helpful [1] 5/6
helpfully [1] 5/6
helping [1] 195/5
her [8] 85/14 110/15
113/14 155/16 155/18)
180/1 181/5 195/10
here [44] 5/6 22/1
26/2 26/6 35/4 36/18
37/7 49/2 49/7 52/19
65/10 67/17 68/1
73/24 74/6 76/1 78/7
79/11 80/10 81/18
96/8 100/23 109/23
1141/3 112/19 113/12
121/8 123/12 136/25
137/12 148/18 151/23)
156/19 157/25 159/12,
160/12 164/7 174/6
183/18 185/19 188/20)
201/17 202/20 204/17
here's [1] 79/6
hereof [1] 37/14
Hewitt [2] 85/15
85/16
Hi [3] 119/12 170/20
171/1
hierarchical [1] 98/3
hierarchy [1] 94/8
high [8] 122/6 122/19
133/10 135/5 145/9
179/25 180/19 185/18)
high-volume [1]
135/5
higher [4] 62/17
62/21 89/2 111/22
highest [2] 69/1
171/4
highlight [1] 144/23
highlighted [2] 20/10
66/10
him [20] 10/21 16/12
16/24 18/10 19/3
29/12 30/3 31/13 57/8
88/25 89/2 89/10
102/8 108/25 112/16
124/15 128/8 169/10
178/3 197/15
hindsight [6] 77/8
TTT 77/18 12116
158/3 185/2
hints [4] 113/12
his [32] 9/19 17/16
30/4 48/16 51/6 57/9
67/14 83/14 85/4 89/2
102/3 102/9 122/1
124/16 127/4 128/7
132/3 132/11 134/22
135/6 136/17 136/17
136/19 138/20 143/13}
143/19 155/20 166/18}
167/24 178/4 184/2
187/13
historic [4] 6/24 6/25
117/21 119/22
history [2] 28/11
181/1
hm [4] 20/2 116/23
120/25 136/13
HMCE [1] 84/10
HNG [9] 69/18
114/24 115/18 116/2
118/20 131/17 141/21
172/22 194/14
HNG-X [9] 69/18
114/24 115/18 116/2
118/20 131/17 141/21
172/22 194/14
hoc [1] 98/18
hold [3] 50/16 58/22
58/23
holding [6] 5/13
22/21 22/24 23/14
29/10 186/10
Holdings [6] 5/16
17/5 22/9 23/15 28/2
28/19
holds [1] 58/23
home [1] 193/3
honest [1] 31/19
hook [4] 110/24
hopeful [1] 138/10
horizon [141] 6/3 6/8
7/22 7/25 12/8 12/17
16/17 19/14 19/18
21/10 26/6 26/8 26/21
27/4 27/16 28/2 31/12
32/1 32/8 69/4 72/11
85/21 87/14 102/15
102/18 102/20 102/22
103/7 103/24 105/11
105/20 105/24 106/8
106/24 107/4 107/24
108/3 113/16 113/18
114/8 114/12 114/12
114/24 116/2 116/4
116/8 116/10 116/14
116/15 117/8 118/21
118/22 118/23 121/19}
122/5 122/14 123/11
123/23 124/1 124/9
124/16 124/23 126/3
126/8 126/10 126/14
126/19 126/20 126/22}
127/2 127/3 127/11
132/3 135/14 141/13
141/18 141/21 145/1
147/18 149/15 150/1
150/5 150/22 150/23
151/1 151/7 152/3
152/22 154/19 155/8
155/19 158/25 159/4
159/4 159/5 159/11
159/13 162/5 162/18
162/20 162/22 163/2
165/22 166/16 168/20}
169/14 170/7 172/23
176/9 180/11 181/13
182/10 182/16 182/22}
183/4 184/3 184/15
184/23 185/10 186/1
186/20 187/11 187/15
188/4 188/5 189/7
189/13 190/5 190/19
192/16 196/20 196/20)
199/10 199/24 200/15]
200/24 201/2 202/6
203/22 204/2 205/4
Horizon’ [1] 189/3
Horizon's [2] 99/14
189/11
hotting [1] 111/1
hourly [1] 12/15
house [3] 4/1 4/3
108/25
how [39] 12/23 21/22
42/11 48/2 56/24
59/12 60/6 61/15
61/17 66/24 82/19
85/7 86/12 88/16
95/18 103/23 107/1
113/16 132/8 132/15
135/15 137/3 143/23
156/14 157/6 163/11
169/20 171/13 173/24}
174/12 174/14 179/25}
180/20 190/5 198/3
200/14 202/16 204/13
204/14
however [13] 64/9
72/25 84/13 100/17
109/2 125/16 128/3
149/8 166/8 178/4
178/10 181/14 194/15}
HR [2] 14/21 17/1
huge [1] 58/12
Humphrey [3] 166/5
166/11 166/12
husband [2] 155/16
168/15
hybrid [1] 129/25
hyper [1] 130/10
hyper-sensitised [1]
130/10
hypothesise [1]
48/12
hypothetical [1]
60/19
l accept [2] 15/2 88/5
l actually [2] 10/2
63/6
lagree [4] 177/8
191/10 201/7 203/24
also [2] 91/4 110/4
lam [4] 133/5 135/8
148/19 156/23
I appointed [2] 30/8
30/23
l appreciate [1]
19/21
lask [8] 1/22 2/3 2/8
2/12 2/25 50/10 71/4
7113
l asked [1] 9/6
lassume [2] 69/9
70/3
lattended [1] 176/4
I became [3] 14/16
97/25 99/24
I beg [1] 67/11
I believe [14] 2/13
20/3 28/6 55/24
101/23 143/11 143/14)
157/22 181/5 181/10
181/14 182/5 192/8
196/1
I can [28] 1/13 24/8
29/5 31/8 35/12 38/13
44/25 47/8 48/12
48/13 50/23 54/21
54/22 57/17 59/12
61/16 61/16 62/23
70/20 70/24 71/24
89/9 89/13 92/20
115/5 138/22 164/4
193/11
I can't [16] 10/20
31/14 31/18 43/1 55/3}
58/4 59/7 60/22 81/15
85/13 85/17 86/13
86/18 91/13 101/3
157/23
I clearly [1] 108/7
I could [6] 42/11 53/6)
60/19 80/11 153/15
153/20
I couldn't [1] 48/3
(66) has... -I couldn't
I described [2] 4/12
29/9
I did [14] 10/25 18/21
36/3 94/1 94/4 94/25
99/25 100/6 125/7
158/10 167/15 195/22
195/24 198/20
I didn't [9] 31/5 49/11
55/4 63/8 75/20 75/22
86/6 142/9 149/4
Ido [24] 1/24 11/12
72/19 82/25 82/25
83/4 87/23 91/3 99/19
100/3 100/7 102/1
118/11 142/6 164/4
172/18 174/14 177/2
180/13 193/2 193/10
195/8 195/8 195/20
I don't [76] 8/23 9/10
10/20 10/21 11/7
11/16 15/10 15/20
27/12 30/7 41/11
43/10 44/22 51/5
52/24 53/24 54/7
57/13 60/20 60/25
63/20 63/23 65/14
68/11 69/2 70/19
78/13 79/4 81/7 81/9
83/11 88/7 88/18 89/6
89/10 90/13 91/2
91/12 91/22 91/24
96/7 97/9 97/12
100/23 101/5 101/18
104/6 104/9 105/14
114/5 115/5 118/11
121/10 134/3 139/22
143/3 143/8 143/9
148/24 149/1 152/18
170/17 171/15 182/9
183/8 185/9 187/4
188/6 189/21 190/23
190/24 191/5 192/6
192/13 193/2 205/1
I doubt [1] 81/17
l engaged [1] 153/8
lexpect [1] 170/21
Ifeel [1] 136/2
felt [1] 91/4
I first [4] 97/17
100/18 152/1 193/22
I followed [1] 189/5
I gave [1] 157/19
I get [1] 137/8
I go [2] 107/25 152/1
I got [1] 74/5
I guess [1] 143/24
Ihad [19] 14/14
29/11 30/4 31/13
33/23 43/10 43/12
70/21 72/19 85/11
119/14 135/20 135/23)
139/11 158/5 170/12
183/25 188/9 200/15
Ihasten [1] 15/21
Ihave [21] 3/12
24/11 32/1 32/4 57/11
86/19 102/14 103/16
106/1 125/23 136/2
136/6 138/20 164/22
177/23 178/3 178/10
179/24 190/2 201/10
204/14
I haven't [4] 63/6
63/8 68/14 80/14
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linsist [1] 54/5
l intervened [1]
157/7
I joined [3] 94/19
114/14 183/25
Ijust [11] 16/3 30/6
82/10 107/20 120/2
124/3 138/18 148/1
170/17 171/25 189/21
Ikept [1] 16/25
I knew [5] 15/25 30/3
40/16 58/6 90/14
I know [5] 43/10
58/17 59/12 69/7
71/20
I left [3] 31/6 95/17
191/25
I listened [1] 168/5
I look [1] 75/16
I looked [3] 47/7 78/1
79/19
I may [6] 3/15 26/16
27/11 57/25 73/24
173/9
I mean [32] 11/25
17/9 17/23 21/11 23/6
29/7 30/2 46/25 52/23
59/17 66/18 70/11
70/21 74/22 75/21
78/12 83/10 84/25
87/21 88/5 101/3
112/18 114/16 130/21
171/16 173/22 184/13}
185/10 187/4 188/11
190/11 203/13
I misspoke [1] 34/24
I move [1] 28/9
I must [3] 106/1
108/8 142/12
Ineed [3] 149/8
154/15 179/8
I never [6] 33/25 43/1
71/19 74/22 75/14
89/7
I now [1] 100/15
lonly [1] 200/12
I please [1] 93/10
I presume [3] 16/19
52/17 65/11
I produced [1] 63/4
I propose [1] 1/11
I provided [1] 180/19
I read [6] 65/6 66/23
66/24 71/14 113/1
130/20
I really [2] 15/23
28/22
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99/13 105/14 123/18
172/3 180/12 186/21
194/5
I received [3] 142/12
164/25 183/14
refer [1] 14/4
I regarding [1]
190/24
I remember [2]
126/24 157/11
I reply [1] 109/23
I reported [4] 8/11
16/7 16/10 16/12
I retired [1] 30/25
I right [1] 96/19
Irun [1] 161/19
I said [8] 9/10 35/13
60/12 77/4 121/12
136/24 152/11 183/24
I saw [3] 63/8 90/18
157/7
I say [6] 8/25 39/14
60/24 66/23 77/17
120/24
I see [1] 65/12
I should [9] 1/8 11/13
14/20 20/9 37/18 45/6)
131/3 156/19 158/9
I shouldn't [2] 18/5
91/7
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I spent [1] 31/2
I spoke [3] 104/16
108/21 127/10
I stress [1] 82/14
I suggest [2] 137/8
181/23
I suppose [7] 8/16
9/16 10/11 26/15 38/2
40/20 61/6
I suspect [1] 81/16
I take [3] 56/13
130/22 153/14
I talk [2] 56/1 58/20
I think [140] 5/5 6/18
6/23 8/8 8/25 11/6
12/12 13/25 15/2
15/22 21/11 21/16
21/18 22/12 22/22
24/2 26/25 28/3 29/13
29/20 29/20 29/22
29/23 30/5 32/5 39/7
40/14 42/19 42/19
48/7 48/8 48/14 48/15
48/23 49/10 49/21
54/8 54/17 54/19
55/15 63/4 63/5 66/21
69/2 70/16 73/24 74/1
77/2 77/2 77/6 77/9
77/11 77/23 79/10
79/22 80/4 83/1 83/10
86/11 86/14 86/23
87/7 88/10 92/12 94/2,
94/12 94/16 95/3
97/21 99/5 100/14
100/15 100/18 106/13
107/6 108/7 108/13
108/13 109/6 110/12
110/25 113/9 114/21
115/14 123/3 124/10
124/18 125/5 125/11
126/17 129/2 129/9
129/25 130/3 131/5
131/12 134/11 134/25}
136/17 139/25 140/7
140/22 141/3 142/25
143/6 151/18 152/11
155/20 156/6 156/18
161/10 161/14 165/2
166/25 167/19 167/22)
167/25 169/7 169/8
169/10 170/2 170/12
172/11 173/9 176/25
179/17 180/18 180/21
182/3 184/9 185/17
188/8 191/18 193/6
195/11 201/10 203/9
205/3 205/8 205/19
I thought [2] 18/14
175/22
I told [4] 57/20
I took [7] 31/4 78/16
79/6 108/18 112/21
141/1 164/18
I tried [1] 80/10
I turn [1] 86/20
l understand [18]
2/19 7/7 11/22 17/8
23/3 32/12 48/14
62/19 75/11 78/2 80/8)
84/4 87/21 96/23
131/6 164/5 171/2
182/4
I understood [2]
50/21 60/6
lused [2] 40/22
85/13
I vaguely [2] 137/17
183/8
I want [18] 1/20 3/14
4/13 15/6 19/20 28/10
34/2 44/5 47/20 59/21
70/25 72/15 83/20
87/11 88/12 88/24
130/13 174/19
Iwas [50] 9/3 9/12
10/2 11/24 12/5 15/14,
15/19 17/22 18/6
18/20 29/13 30/2 30/7}
31/5 33/11 36/4 39/14
39/14 39/18 40/4 41/9
58/18 58/18 70/18
70/18 72/20 97/19
100/6 102/9 106/3
107/6 116/12 124/24
135/22 136/8 150/6
153/14 153/19 153/21
160/22 161/21 170/8
173/10 173/21 173/21
192/3 192/3 197/5
198/16 205/3
I wasn't [3] 70/10
71/14 72/14
I went [3] 17/19
17/21 30/2
I will [5] 16/6 29/14
74/3 89/7 138/5
I wish [1] 77/17
I wished [1] 158/5
I won't [2] 40/8 176/2
I would [49] 11/24
12/5 16/13 19/10
19/11 27/22 28/7
28/20 39/23 47/5 65/4
67/12 67/23 68/11
71/25 72/25 80/18
80/22 80/23 82/12
89/11 98/3 98/4 99/1
102/12 109/21 114/2
115/1 120/5 121/12
124/10 125/11 125/25)
126/1 126/17 128/11
136/22 155/1 157/5
157/7 163/21 170/13
171/19 193/18 193/21
196/1 203/7 204/14
205/1
I wouldn't [8] 30/7
40/1 40/5 62/18 77/23)
78/11 78/15 78/22
I'd [17] 14/14 18/10
18/19 48/17 57/25
66/23 67/9 99/9
110/21 113/2 121/18
125/4 154/3 175/6
179/21 183/24 192/10)
Ill [22] 2/18 4/17 17/2)
28/25 40/9 44/5 58/19I
58/19 71/17 78/5
87/23 90/12 110/2
116/20 130/22 150/9
162/2 183/10 189/4
194/22 196/15 200/3
I'm [97] 3/17 12/17
13/25 15/2 16/18
21/18 26/5 29/4 29/4
29/20 29/25 34/8 35/4
35/4 35/5 35/6 36/7
40/13 41/6 44/20 45/5
46/25 47/9 47/18
48/12 54/7 55/20
58/19 59/4 59/5 59/18}
59/19 65/18 66/24
67/11 68/1 68/11 77/8
78/12 80/14 81/6 81/7
(67) I described - I'm
I'm... [55] 81/9 81/9
85/17 86/11 86/22
87/20 87/21 88/10
90/21 90/24 91/1 91/5
91/12 91/24 92/10
96/9 99/10 100/20
101/41 101/13 101/13}
101/22 106/5 109/21
109/24 112/18 113/1
113/24 114/7 115/15
127/5 130/5 133/13
137/21 145/17 148/24I
150/6 155/1 158/15
164/18 165/25 174/18]
177/15 178/23 179/1
179/14 182/11 188/12}
193/13 193/24 195/8
196/9 199/6 204/5
205/15
I've [42] 10/4 13/10
26/14 29/19 30/10
35/7 46/19 47/1 47/8
47/23 50/22 52/23
53/2 56/9 56/21 56/21
57/13 59/12 59/13
64/20 70/10 74/21
75/21 77/9 79/23 81/4
86/15 87/22 91/6 91/8
104/6 105/15 109/22
115/5 120/13 139/18
162/1 175/8 191/16
196/9 198/7 203/12
lain [1] 40/16
IB [3] 181/16 181/17
181/21
Ic [1] 16/8
ICL [97] 4/14 4/19
4/21 4/22 4/24 5/7
5/13 5/20 5/22 6/7
6/11 6/19 6/21 7/2 7/7
7/8 7/44 7/14 7/24
8/13 8/15 8/16 8/21
9/8 9/15 9/23 10/4
10/5 10/15 10/16
10/18 10/23 11/20
11/25 12/5 12/10
12/10 12/13 12/15
12/22 12/22 12/24
12/24 13/22 13/23
15/9 15/11 15/15
16/10 16/22 17/5
18/13 18/21 19/24
21/9 21/22 23/4 24/12
24/20 25/12 26/15
27/9 28/1 30/13 33/2
33/9 33/17 37/8 37/15
38/4 40/8 40/10 40/19
40/23 40/24 41/9
41/23 41/23 42/4
48/10 50/12 54/1
54/15 59/15 59/21
59/22 60/8 60/10
60/11 61/3 61/7 61/8
61/18 61/21 73/22
76/22 76/24
ICL Group [3] 4/14
4/19 SIT
ICL Group's [1] 5/22
ICL's [1] 66/19
idea [8] 47/1 53/16
74/21 82/19 165/2
175/5 201/10 204/14
identification [1]
12/19
identified [4] 12/25
49/25 168/13 186/7
identifies [1] 45/19
identifying [1] 68/2
identity [1] 22/20
if [195] 1/13 3/15
3/15 3/20 9/11 12/2
12/3 13/3 13/5 14/24
15/19 18/16 18/20
19/2 20/7 24/9 25/6
25/17 25/21 26/16
26/23 27/9 29/17 30/7
30/20 31/17 34/12
34/24 35/13 36/8 37/9
38/22 40/2 40/13 42/7
42/13 43/21 45/1 46/9
47/1 47/3 47/13 50/15)
51/5 51/17 51/21 52/7,
53/1 53/15 55/9 56/23
56/23 57/25 59/7
62/23 63/16 65/2
66/10 67/22 67/22
67/24 68/6 68/12
68/15 68/17 69/8
70/21 71/17 71/17
72/23 73/17 73/18
73/22 73/25 74/4 74/7,
75/25 76/15 77/6
78/10 78/19 78/22
78/23 79/5 80/19
81/11 82/20 83/2
83/22 86/17 86/20
89/8 89/10 91/2 91/12
91/16 96/1 96/10
96/23 98/14 99/21
101/9 102/16 104/15
105/3 105/22 106/15
106/17 107/25 108/9
108/17 109/11 110/3
111/16 111/21 113/23)
113/25 114/2 115/2
115/15 117/21 119/4
119/5 119/22 120/15
121/25 122/16 122/25)
129/22 130/5 130/20
130/21 131/5 133/1
137/5 137/18 137/23
139/2 139/22 140/10
142/18 143/17 144/3
144/19 145/4 145/14
147/2 147/15 147/21
152/1 153/14 154/15
155/6 159/17 159/23
162/17 162/23 165/16
166/13 167/12 167/16
167/17 169/5 170/19
170/25 172/1 172/3
172/4 172/12 173/4
173/7 173/9 176/23
178/5 178/16 179/9
180/12 180/18 180/24)
181/4 182/13 185/23
187/2 188/12 190/11
194/24 196/2 196/10
197/6 197/24 200/6
202/21 202/24 203/21
204/8
iflwhen [1] 121/25
ignorance [1] 81/16
ignore [1] 145/13
ii [1] 81/25
illustrated [1] 50/1
imagine [2] 56/9 99/1
imagined [1] 170/13
immediate [4] 102/9
145/22 148/15 184/7
immediately [1]
158/13
impact [11] 23/18
162/12 162/19 163/5
198/3 202/10 203/9
203/10 203/11 203/16
204/1
impacted [2] 125/24
201/18
impacting [2] 69/18
162/8
impacts [1] 192/23
imperative [1] 137/2
implementation [3]
55/23 75/1 159/13
implementing [1]
150/14
implications [2]
163/12 202/17
implies [2] 178/6
178/15
important [16] 12/20
37/20 59/20 68/6
79/22 84/12 95/24
131/5 131/13 131/16
132/17 157/1 172/8
176/5 188/15 204/12
importantly [2]
117/23 119/24
impose [1] 87/6
imposed [1] 166/11
impossible [1]
145/13
impression [1]
139/14
impressions [1] 47/8
imprisonment [2]
166/12 166/13
improve [1] 68/5
improved [2] 53/13
67/13
improvement [1]
84/17
improvements [2]
68/2 190/15
inaccurate [2] 103/9
105/11
inch [1] 58/25
incident [3] 50/20
55/9 146/17
incidents [3] 123/22
123/24 179/24
inclined [1] 169/17
include [1] 204/5
included [5] 25/12
82/23 148/13 151/15
199/18
including [16] 12/17
16/24 19/6 19/14
42/24 64/13 66/8
67/10 86/5 95/6 95/7
106/25 135/1 149/23
158/1 187/14
income [1] 97/7
inconvenience [1]
150/15
incorporated [3] 23/1
28/15 59/16
incorrect [2] 73/24
198/9
increase [1] 96/12
increasing [1]
114/17
incur [1] 52/20
incurred [1] 137/23
indeed [5] 90/8 100/3
112/14 112/18 135/21
indemnity [1] 172/3
independent [27]
69/25 80/24 81/12
122/20 123/4 123/11
129/4 129/20 130/15
130/18 130/19 131/2
131/4 131/15 132/14
133/18 133/25 134/4
135/18 168/25 169/14,
170/6 173/5 175/15
186/23 192/16 193/8
India [1] 95/4
indirect [1] 29/25
indirectly [3] 8/7 29/2
71/11
individual [3] 64/10
147/22 183/23
individuals [3] 65/25
119/1 119/1
industry [3] 32/4
85/8 187/19
inevitably [1] 150/14
Info [1] 194/24
inform [1] 175/23
informal [1] 154/24
information [27]
13/11 14/12 56/5
57/15 57/23 58/12
58/15 63/7 64/12 72/4I
74/11 86/16 91/10
103/18 106/20 106/21
107/4 115/6 116/18
146/13 146/23 147/5
152/21 171/17 177/23)
180/5 197/3
informed [3] 141/15
143/25 169/12
informing [2] 163/13
202/18
infrastructure [2]
172/23 172/24
Infringements [1]
66/17
inherent [1] 51/14
initial [4] 57/3 129/17
129/18 190/3
initially [2] 7/1 16/18
initiatives [3] 132/20
185/14 185/23
input [2] 40/2 127/18
Inquiry [27] 1/19 3/11
5/4 11/14 44/8 45/8
62/7 63/2 71/3 71/9
80/9 82/4 88/13 89/15
92/10 105/16 115/4
120/14 126/25 162/3
162/24 170/13 190/14)
196/11 199/15 200/13}
201/13
Inquiry's [1] 93/18
insert [2] 91/16 91/17
inside [7] 59/1 59/11
152/11 154/17 155/9
155/11 163/22
insist [1] 54/5
insisting [2] 91/23
105/9
insofar [2] 15/18
178/14
instability [1] 51/14
installed [1] 104/21
instance [5] 17/15
47/1 65/4 85/11 94/13)
instances [1] 149/19
instigate [1] 182/7
instigated [1] 51/3
integrity [66] 79/16
79/17 79/23 79/25
80/5 81/19 99/14
102/16 102/20 102/24I
103/7 103/24 105/11
105/20 105/24 106/9
106/25 107/5 108/22
109/5 113/12 113/16
114/3 114/23 115/21
115/23 118/3 118/6
120/23 131/5 140/24
147/18 150/2 150/16
151/7 152/8 152/20
152/22 152/25 153/15)
154/19 160/19 162/20)
(68) I'm... - integrity
I
integrity... [23] 163/8
169/15 177/10 179/24}
180/11 180/25 182/11
184/15 185/10 186/1
186/20 186/23 187/3
188/4 189/19 190/19
190/24 196/22 199/11
199/24 200/14 202/13}
204/2
intention [3] 94/18
138/23 176/17
interactions [1]
44/23
interest [4] 6/24 86/4
103/14 103/16
interested [3] 113/17
113/19 1741/7
interesting [3] 22/23
58/7 168/3
interests [1] 149/18
interference [1] 68/9
interim [2] 30/6
191/14
intermediate [1]
22/10
internal [9] 40/7 40/9
41/22 41/23 119/10
123/18 149/10 197/7
197/10
internally [4] 123/6
130/17 182/8 183/15
International [16]
5/19 5/22 6/15 6/22
7/4 7/16 8/14 8/22 9/8
10/5 10/18 11/23 12/1
17/18 181/20 181/22
interpretation [2]
34/13 82/11
interpretations [1]
35/24
interrupted [1] 139/5
interruptions [1]
141/22
intervene [1] 157/7
intervened [1] 157/7
interview [1] 168/14
interviews [2] 155/18
155/19
intimated [1] 135/12
into [36] 4/17 11/13
26/17 33/1 42/7 51/24
51/24 53/14 60/23
88/24 91/5 91/18
94/13 97/5 98/8
106/24 107/14 110/18
117/25 118/2 119/25
120/9 122/6 131/9
131/14 135/5 151/2
156/22 176/21 177/17
179/15 181/2 181/19
184/19 185/9 199/19
introduce [2] 52/8
175/24
Introduction [3]
45/10 49/12 158/21
introductions [1]
111/3
inverted [1] 62/10
invest [1] 128/22
invested [2] 176/14
187/15
investigate [4]
147/19 149/22 183/21
190/8
investigated [2]
89/11 119/2
investigates [1]
117/18
investigation [10]
168/24 172/4 173/5
175/15 180/15 180/23}
182/16 183/22 184/18)
189/24
investigations [5]
117/1 118/7 151/2
180/17 182/8
Investments [2] 7/7
7/11
invite [1] 180/7
involve [2] 114/6
173/11
involved [24] 15/24
28/18 37/3 37/4 39/12
39/14 39/14 50/11
65/25 74/18 74/19
98/10 99/17 106/3
114/11 114/19 143/17,
158/10 173/10 174/6
174/9 177/20 193/22
205/6
involvement [3]
33/23 105/9 114/1
involving [2] 113/7
117/12
iPlayer [1] 156/7
IPR [1] 187/12
Ireland [5] 74/15 95/1
95/22 97/20 110/17
Ireland's [1] 94/10
irregularities [3]
141/19 144/15 186/7
irrelevant [3] 104/22
178/4 178/11
irrespective [2]
118/22 156/16
is [545]
is the [1] 78/16
ISDN [1] 124/2
ish [1] 134/7
isn't [15] 25/12 48/9
50/18 50/20 84/5
107/18 118/15 130/4
152/17 152/22 152/23)
156/11 177/4 177/17
204/8
issue [74] 21/2 21/6
21/19 21/21 31/13
47/25 48/1 48/4 48/6
48/18 48/21 51/19
51/20 52/25 62/7
64/22 64/25 67/13
67/17 68/25 69/11
72/19 81/13 86/11
87/25 88/8 88/8 88/20
91/9 101/9 106/22
108/22 109/6 118/5
123/20 124/1 124/2
130/10 131/13 133/12
134/13 134/14 135/3
135/17 148/2 151/19
151/24 152/12 157/8
157/11 157/12 157/13}
157/14 157/20 159/5
159/25 160/16 160/24
160/25 162/4 163/19
166/9 172/12 178/11
184/19 186/12 187/12
193/3 195/7 196/5
196/12 197/20 198/8
198/10
issues [91] 3/13
11/16 13/24 14/3
15/17 18/23 23/19
27/16 46/20 46/23
59/8 61/18 62/9 68/3
69/17 70/9 70/14
77/18 90/17 102/17
103/25 105/24 112/22
113/13 114/3 116/1
118/1 118/11 121/2
121/21 122/10 122/12)
122/24 123/23 123/24
124/5 124/8 124/11
124/19 124/23 125/2
125/14 125/19 127/18}
128/14 130/16 133/7
133/10 134/1 134/21
136/24 137/13 137/22]
140/3 140/5 141/4
152/8 152/15 153/5
153/11 153/16 156/21
157/5 157/23 159/4
159/12 169/16 169/22
172/10 172/13 173/18
173/20 178/19 180/1
180/11 180/21 180/25)
184/1 185/11 186/1
186/16 186/18 189/18)
190/19 190/24 191/1
193/6 195/10 196/2
199/21 200/9
issuing [1] 201/5
it [584]
it's [132] 2/19 5/4 5/5
12/2 14/18 15/3 15/20
15/22 19/20 21/14
21/19 21/21 22/22
22/23 22/24 23/6
29/24 34/4 35/5 37/23
39/23 41/13 42/19
43/1 47/1 47/2 47/24
48/1 48/6 48/6 48/21
49/1 49/5 50/21 50/23!
52/22 53/3 53/6 53/9
53/11 53/12 53/14
53/19 54/4 54/13
54/14 54/17 56/11
58/25 59/17 59/19
62/1 63/2 63/2 63/12
65/18 65/20 67/18
69/4 69/8 69/23 70/25
7113 71/9 71/9 72/16
73/14 75/13 77/23
78/19 79/12 79/22
80/7 80/17 81/16
81/20 83/21 99/7 99/9
99/9 103/11 105/4
106/8 106/9 107/14
108/15 112/15 112/18
113/3 121/10 121/11
124/17 121/20 130/13
130/21 132/22 134/12
138/3 138/7 144/3
151/22 152/2 152/10
156/6 158/18 166/21
167/1 174/1 176/23
178/15 179/21 180/19
181/13 184/13 184/13
185/14 187/7 189/12
192/10 194/22 194/23}
196/10 197/8 197/9
199/9 199/13 200/1
201/17 201/24 202/2
204/8 205/1
item [2] 98/16 129/1
its [18] 4/21 15/12
24/21 31/2 40/5 45/23
51/13 55/6 64/8 68/5
100/2 100/5 103/2
128/2 139/2 145/12
145/25 191/14
itself [7] 6/14 46/14
54/25 56/25 86/18
132/20 132/24
iv [4] 81/24
jail [1] 168/7
James [3] 155/20
180/4 190/2
Jan [2] 51/19 51/20
Jane [1] 197/9
January [3] 75/4
116/24 182/14
Japan [20] 22/25
23/1 23/4 28/16 57/17
57/21 58/5 58/11
59/16 95/9 143/13
143/14 144/2 148/21
148/23 149/3 149/7
181/19 181/19 181/20}
Japanese [17] 23/8
56/10 57/13 57/16
58/13 59/5 59/8 70/5
70/17 70/22 129/11
137/3 137/11 143/4
143/9 148/25 181/22
Jean [3] 119/6
167/19 169/5
Jean-Philippe [3]
119/6 167/19 169/5
Jenkins [31] 65/8
67/14 71/21 71/22
80/15 81/2 82/22
86/12 104/3 104/4
104/6 106/6 106/9
109/5 152/19 158/19
164/16 164/20 165/3
166/19 167/18 174/8
175/11 177/20 178/13}
192/2 192/18 193/7
199/10 201/9 201/11
Jenkins' [3] 175/18
192/3 198/14
Jeram [1] 49/7
JFSA [1] 144/21
Jo [1] 155/17
job [6] 9/18 55/24
55/25 56/20 58/15
156/18
jobs [2] 55/23 141/20
joined [10] 4/16
84/15 93/25 94/19
97/17 100/18 114/14
144/8 152/1 183/25
joining [2] 99/15
99/25
joint [2] 165/19
201/20
jointly [1] 176/8
Jonathan [1] 168/23
Jones [3] 169/6
169/9 170/19
Journal [1] 117/2
journalists [1] 110/7
journey [1] 136/3
judge [1] 147/1
July [13] 16/20 17/25
80/13 95/17 141/9
142/8 148/9 187/8
188/25 189/23 189/24)
190/12 191/13
July 2010 [1] 142/8
jumping [1] 19/20
June [6] 1/1 138/2
138/3 139/18 181/7
194/2
June 2011 [1] 194/2
junior [1] 156/11
just [102] 1/8 1/11
2/18 4/17 9/3 16/3
20/4 20/9 20/15 22/19)
23/10 23/19 23/21
25/14 25/14 25/23
26/16 26/25 28/10
30/6 35/4 41/15 42/20I
45/1 45/5 47/18 48/19)
57/4 58/19 59/19 61/7
(69) integrity... -just
J
just... [71] 61/11 62/6
67/15 72/8 72/23 74/3
74/3 75/13 82/9 82/10
82/12 82/15 83/6 84/3
84/23 89/20 91/14
93/18 98/17 99/10
99/22 100/16 104/3
104/14 107/20 109/10}
114/18 114/18 115/1
115/15 116/9 119/15
120/2 124/3 124/7
124/14 132/18 136/3
136/10 137/3 138/18
138/22 139/6 140/21
141/10 141/15 145/14
148/1 148/22 150/3
154/22 156/1 156/6
158/3 159/3 162/2
164/5 170/17 171/25
173/7 177/7 177/18
179/6 183/23 188/2
189/21 193/24 194/22
196/15 196/15 201/16}
justice [7] 15/20
15/21 15/22 77/10
87/24 91/2 144/11
justify [1] 51/8
K
Kamata [2] 142/24
143/6
keep [4] 53/11 86/12
111/19 111/21
keeping [1] 136/6
Keith [7] 8/8 8/9 8/11
10/15 61/19 61/24
62/1
kept [2] 16/25 17/24
key [14] 5/7 21/5
32/13 98/9 98/25
116/10 116/14 132/20)
136/24 170/11 180/10
180/24 189/10 195/3
kick [1] 39/5
kind [8] 18/12 31/3
31/5 112/3 112/8
112/15 158/16 177/19
kinds [6] 113/19
121/14 124/7 185/12
186/3 189/16
Kirkham [10] 101/23
107/25 108/11 110/8
111/5 113/5 113/14
152/6 183/25 199/18
knew [12] 15/25
28/22 30/3 40/3 40/16)
58/6 90/6 90/6 90/14
104/4 111/24 158/4
knocked [2] 69/16
128/13
know [71] 17/10 30/7
40/23 43/10 51/5
53/12 54/5 54/6 54/7
55/4 57/13 58/17
59/12 60/20 60/25
63/23 65/14 68/5 68/6
69/7 71/20 71/22 72/1
75/20 76/3 78/14
78/16 81/15 82/22
82/25 82/25 83/11
85/10 86/6 89/10
91/12 91/22 91/24
97/9 99/19 101/13
107/15 117/6 118/11
118/11 118/23 139/1
139/22 143/3 143/8
143/9 148/15 148/24
149/1 164/4 167/14
170/17 171/15 171/25)
172/18 174/14 183/13)
189/21 190/25 191/22)
191/23 195/20 199/13}
200/1 203/12 204/4
knowing [4] 63/20
89/17 91/19 158/4
knowledge [8] 3/8
72/19 75/11 75/13
82/6 93/14 121/16
160/3
known [17] 18/10
22/16 45/12 50/6 65/4
65/15 71/3 73/2 102/5)
117/8 127/21 142/1
158/19 162/17 202/4
203/21 204/12
Kostuch [2] 115/11
121/12
KPMG [1] 135/15
Kurokawa [1] 16/11
L
La [3] 6/18 6/23 11/9
lack [3] 46/7 99/14
158/11
Lamb [3] 183/1 183/1
183/2
large [12] 26/10
26/13 26/19 26/22
57/20 58/4 84/18
85/19 124/19 200/24
202/2 204/7
large-scale [1]
200/24
largely [5] 93/22 98/2
105/15 121/10 121/11
larger [1] 95/21
largest [1] 96/21
last [17] 2/19 30/20
46/5 69/21 83/18 84/8
85/13 111/13 128/16
129/1 132/17 138/14
145/2 149/23 165/13
185/8 192/11
late [1] 104/13
later [11] 16/11 17/21
57/4 65/7 100/2 128/5I
138/6 151/2 162/2
177/20 182/12
latest [2] 145/23
154/23
Latin [1] 54/8
latter [1] 81/13
Law [2] 165/10
192/15
lawfulness [1] 68/23
lawyer [7] 41/23
119/10 166/14 167/20
170/15 197/10 197/10
lawyers [9] 40/7
40/10 40/11 40/17
40/19 41/4 41/5 41/6
53/3
lead [5] 163/9 176/1
202/14 204/6 204/13
leader [3] 110/17
171/20 171/22
leadership [4]
124/12 125/9 204/20
204/22
leading [2] 105/11
139/20
leads [1] 172/13
learn [1] 135/8
learned [1] 144/7
learning [1] 142/11
least [4] 59/20 96/20
107/22 205/5
leave [1] 95/16
led [4] 64/5 86/16
136/2 141/20
left [9] 5/8 30/5 31/6
95/17 100/9 128/12
139/12 147/2 191/25
Legacy [3] 118/23
124/23 159/4
legal [39] 4/2 4/10
4/18 7/15 7/20 8/2
10/22 17/1 17/10
30/14 32/6 40/21 42/1
42/8 54/6 54/15 55/6
58/5 81/12 99/2
102/24 106/22 119/9
120/18 127/15 127/16
128/19 129/25 144/4
144/8 149/23 162/19
169/7 169/8 173/3
173/15 192/20 204/1
204/9
legally [1] 15/16
Lesley [3] 97/21
180/2 192/19
less [1] 150/17
let [10] 43/3 43/6
56/14 60/10 64/21
70/15 78/22 91/14
156/8 191/9
let's [27] 7/14 11/4
11/12 28/6 41/13
48/25 53/19 54/1 61/1
63/1 63/19 63/21
65/20 71/8 75/18
101/19 131/18 154/1
175/20 188/11 190/11
201/12 202/4 202/20
202/22 203/8 203/9
letter [21] 68/12
68/14 131/19 133/3
133/3 133/5 133/21
134/12 134/22 135/12
165/9 165/17 166/5
166/14 174/23 175/4
175/20 177/1 177/3
197/16 197/17
letters [1] 135/12
Letwin [1] 180/4
level [30] 12/9 13/4
14/25 15/12 28/1 48/7I
48/16 48/19 48/22
61/4 61/6 61/9 61/10
61/12 61/18 65/10
69/1 69/3 81/3 94/3
101/10 101/15 113/8
127/14 170/24 171/4
171/17 179/25 180/19}
184/10
levels [8] 12/12
13/16 14/12 14/20
132/19 135/19 201/3
201/4
liability [2] 172/5
17219
liable [2] 138/24
139/3
liaise [1] 110/10
ed [1] 115/8
on [1] 98/1
liaison/your [1] 98/1
liaisons [1] 171/10
Libra [2] 84/1 84/4
light [3] 50/7 73/1
120/5
lightly [1] 149/24
lights [1] 158/9
like [56] 8/23 9/10
12/3 12/4 17/1 18/8
18/20 25/14 26/23
29/8 29/15 30/21 35/3)
40/3 53/1 53/3 54/9
56/3 57/25 58/13
58/25 65/19 70/23
71/15 72/25 80/21
82/12 86/17 87/1
90/13 91/7 91/16
99/10 109/22 110/21
111/21 113/2 115/1
121/18 128/24 132/5
132/13 137/5 138/15
138/15 143/10 143/18}
152/9 164/6 169/23
175/6 179/21 184/13
192/10 193/18 193/21
likely [10] 92/24 99/3
121/25 125/1 126/4
126/8 147/3 171/22
185/11 196/4
limit [2] 28/21 87/7
limited [64] 4/7 5/20
5/22 5/25 6/7 6/11
6/15 6/22 7/4 7/7 7/11
7/16 8/14 8/22 9/9
10/5 10/6 10/17 10/19)
10/24 11/23 12/1
12/10 12/24 13/23
15/17 16/8 17/18
19/24 21/9 21/23 22/9)
22/18 22/19 22/20
22/21 24/19 25/12
26/15 26/21 27/10
28/2 28/13 28/19
30/10 30/13 30/19
30/21 30/24 31/2 33/2I
33/2 36/10 57/24
59/15 74/12 76/23
76/25 82/1 86/5
130/21 149/22 160/14)
164/22
Limited’ [1] 164/25
limits [3] 76/6 79/11
81/22
line [38] 8/21 9/7
9/16 9/16 29/6 29/7
29/10 29/17 29/25
59/14 61/21 65/21
66/6 66/25 83/7 83/13
102/9 110/16 110/16
115/13 145/23 149/4
153/14 153/17 153/18)
153/18 156/7 158/7
158/7 161/8 161/13
163/22 163/24 164/10)
172/9 174/15 184/16
201/3
lines [8] 16/15
108/15 137/12 153/20)
174/3.177/1 177/11
200/6
link [7] 154/17 156/7
158/2 158/12 158/14
169/20 170/3
linked [1] 155/25
list [12] 44/15 52/17
71/7 71/11 114/25
4115/7 115/10 115/12
121/21 123/16 142/22)
199/17
listed [1] 3/24
listened [2] 80/8
168/5
literally [4] 58/25
litigation [14] 75/9
75/24 75/25 83/8
87/13 89/25 90/3
139/20 169/21 197/17)
198/13 198/15 198/19}
198/23
littered [1] 187/19
little [5] 33/23 34/5
93/18 109/12 146/17
(70) just... - little
L
live [3] 30/3 64/8
197/20
lived [1] 59/13
living [1] 70/18
loads [1] 38/12
local [5] 146/9 160/3
163/4 168/4 202/8
located [1] 133/6
log [1] 79/19
logic [1] 116/17
logical [1] 125/18
logistics [2] 21/19
21/21
logos [2] 106/10
106/12
logs [4] 76/12 79/12
79/18 107/12
London [9] 103/10
113/17 143/7 143/8
143/10 143/11 143/12)
143/15 167/25
long [17] 16/12 23/19
24/23 40/15 58/20
78/14 78/17 83/11
128/21 131/23 135/9
145/23 154/13 155/5
155/10 187/20 188/1
long-time [1] 40/15
look [72] 3/14 4/13
5/1 7/14 9/11 13/3
16/3 17/20 19/20
21/25 23/7 24/25 28/9
32/22 34/2 35/8 37/10
38/2 38/3 38/9 41/10
41/13 42/7 42/13 44/5)
44/7 45/25 47/13
47/18 47/20 48/25
50/10 50/15 52/25
54/22 63/1 63/16
63/19 63/21 65/20
69/23 70/25 71/8
72/15 73/22 74/24
75/16 77/6 79/20
83/17 83/22 98/7
122/16 126/9 128/24
130/23 131/18 154/1
154/15 156/22 174/19}
175/20 176/3 179/15
181/2 182/18 188/11
190/11 199/14 201/15)
202/4 203/10
looked [17] 11/25
39/23 41/15 47/7 68/1
71/15 78/1 79/19
82/15 109/22 113/2
156/5 158/5 162/24
169/4 170/20 174/17
looking [26] 3/17
12/14 20/9 40/17
59/14 68/19 71/7
79/11 113/10 115/7
121/8 124/21 132/22
139/17 139/17 141/11
151/4 152/17 155/12
160/17 164/13 185/15)
185/15 189/12 190/15)
190/15
looks [9] 58/24 65/19
77/7 111/21 124/25
143/9 164/4 164/6
173/3
Lord [1] 168/23
losing [2] 141/20
168/16
loss [8] 66/16 69/21
128/20 162/14 162/17)
166/8 203/18 203/21
losses [2] 159/11
182/24
lost [3] 35/4 144/14
159/2
lot [15] 10/11 14/15
17/15 21/20 23/8
25/14 30/4 42/5 85/14
130/12 133/12 162/25)
174/17 187/23 196/12)
low [1] 187/16
lower [2] 14/11 15/3
lowered [1] 134/20
lunch [2] 87/3 92/13
M McDonnell [1]
44/16
MacLeod [1] 197/9
made [28] 6/5 23/4
24/13 26/7 46/20 50/4
64/17 65/2 65/3 80/22
90/16 99/13 105/10
120/19 127/13 128/1
128/11 133/6 138/15
141/25 144/13 152/10)
153/15 159/3 161/21
186/10 189/2 194/15
magazine [1] 156/2
magazines [1] 151/9
mail [12] 96/15 96/20
97/6 101/24 135/13
165/10 166/3 166/4
166/15 175/16 194/9
194/11
main [6] 33/21 41/11
97/14 97/17 167/10
194/12
mainly [2] 21/21
146/4
maintain [1] 102/15
maintained [1]
113/16
maintaining [2]
52/22 53/1
maintains [1] 103/24
maintenance [3]
52/6 75/2 116/7
major [4] 123/22
123/24 125/12 197/20)
majority [5] 4/18
57/12 59/6 149/18
153/7
make [15] 2/13 13/24
14/18 22/5 30/18
69/23 78/17 90/12
139/3 150/11 153/2
153/10 164/5 180/14
195/23
makes [4] 53/25
112/17 113/14 165/16
making [7] 82/23
92/8 128/2 136/8
169/13 170/5 170/23
manage [2] 13/12
198/3
managed [10] 10/10
12/25 29/14 62/11
86/4 88/16 88/20
88/22 149/21 196/1
management [50]
8/10 8/12 8/16 8/20
9/3 9/7 9/11 9/20 10/4
10/6 10/8 10/17 12/19
14/25 22/16 22/17
24/3 25/1 26/7 43/16
44/6 48/19 50/12 52/5
52/14 52/18 53/8
56/15 56/19 56/24
57/7 57/7 59/23 59/24
60/2 60/3 60/7 60/11
60/13 60/15 61/4
61/13 62/2 86/9 89/2
91/20 132/8 194/14
194/16 194/20
manager [6] 101/24
102/9 105/8 110/12
110/15 161/6
managerial [1] 66/4
managing [36] 10/14
10/16 11/5 13/13
20/18 20/22 29/8
30/14 44/18 44/21
49/5 61/12 61/21
83/15 94/2 94/20 96/3
97/15 98/19 108/6
112/2 112/24 114/9
114/14 114/18 118/9
121/4 137/2 154/9
155/24 163/17 167/7
170/9 172/7 174/13
184/17
manual [2] 66/3
66/15
manually [2] 163/3
202/8
many [13] 40/22
41/12 48/12 53/2 67/3
77/18 89/18 89/18
89/23 90/5 90/8 97/3
124/19
March [4] 1/25 122/7
141/23 176/18
March/April [1]
141/23
marketing [4] 17/1
110/12 110/17 181/11
Martyn [4] 44/17 77/7
83/10 83/13
Masons [8] 40/13
40/14 40/21 41/3 41/6)
41/7 42/2 42/6
massive [1] 187/21
match [1] 117/17
Matcham [1] 175/2
material [1] 104/22
materially [1] 120/21
mathematics [2]
18/16 46/16
Matsuzawa [3] 143/3
143/3 143/8
Matsuzawa-san [2]
143/3 143/8
matter [11] 15/25
17/3 23/6 56/11 68/13}
68/18 136/6 143/18
157/22 165/13 172/14}
matters [16] 8/19
13/15 13/21 19/15
40/22 43/14 82/13
83/6 112/23 112/24
136/21 136/22 137/11
176/6 189/16 204/18
mature [1] 104/19
maturity [1] 124/15
maximum [2] 82/2
87/3
may [26] 2/9 3/15
20/10 25/2 26/16
27/11 34/5 36/5 42/19)
44/11 45/3 51/24
57/25 65/7 71/6 72/8
73/24 93/8 104/23
108/14 109/11 128/10)
131/20 135/10 159/24)
173/9
maybe [10] 6/19 53/6
53/7 54/7 60/24 60/25)
64/21 65/13 65/14
68/13
Maz [3] 115/11
115/14 121/12
McDonnell [4] 44/16
44/22 88/13 88/21
McLachlan [1]
164/24
McLean [5] 104/16
125/17 137/19 137/20}
138/5
McQue [3] 165/7
165/12 177/21
MD [1] 60/12
me [97] 1/5 2/15 8/5
16/20 16/24 18/18
18/19 19/4 27/12
27/20 28/6 31/1 31/14)
35/4 35/8 43/3 43/6
44/3 47/7 48/24 53/20)
56/14 60/10 62/5
62/20 63/7 64/21 65/7
65/19 69/12 70/15
70/16 71/5 71/15
71/16 71/21 73/2 73/3
74/3 75/16 78/22
80/17 80/23 83/16
87/25 89/9 89/11
90/22 91/12 91/14
92/19 100/5 100/16
101/15 102/7 105/16
106/2 107/25 110/16
114/6 121/6 128/7
134/8 134/12 136/18
140/18 152/6 153/18
155/6 156/8 156/21
157/5 157/6 157/13
158/5 158/7 158/8
161/21 170/14 171/19)
174/1 174/5 180/22
181/6 184/8 184/25
187/25 188/6 188/24
189/6 190/4 191/5
194/5 195/9 196/3
200/17 205/3
mean [40] 10/16
11/25 15/19 17/9
17/23 21/11 23/6 27/1
29/7 30/2 46/25 52/23}
59/17 60/3 66/18
70/11 70/21 74/22
75/21 78/12 80/1 81/5I
83/10 84/25 87/21
88/5 101/3 101/13
112/18 114/16 130/21
171/16 172/3 173/22
184/13 185/10 187/4
188/11 190/11 203/13}
meaning [2] 32/7
120/11
meanings [1] 34/19
means [10] 54/8
54/20 58/21 58/21
58/22 79/25 80/10
87/17 173/1 173/8
meant [3] 17/12
89/12 157/9
meantime [1] 137/8
measure [1] 130/8
measures [5] 106/24
107/1 134/25 138/25
146/14
mechanisms [2] 56/1
159/14
media [9] 103/16
114/4 143/25 184/4
184/12 185/3 186/2
189/15 191/1
meet [7] 21/23 24/6
37/7 85/7 85/25 180/2
188/24
meeting [49] 10/21
20/5 23/11 23/19 25/5
25/10 36/14 49/14
(71) live - meeting
meeting... [41] 57/16
58/17 59/3 60/8 60/15)
60/16 72/20 83/21
100/4 100/8 100/24
100/25 101/2 101/3
101/6 108/25 111/13
122/17 122/18 137/5
137/15 180/7 184/2
185/6 185/7 185/22
186/17 186/17 187/9
192/7 192/20 192/25
193/7 194/7 194/23
195/1 195/6 195/10
201/20 201/24 202/2
meetings [25] 10/17
10/23 11/1 19/6 19/11
22/5 23/10 23/11
23/17 24/1 24/4 24/13
27/9 28/24 51/3 57/6
57/7 57/7 61/4 61/5
61/13 69/13 106/3
126/24 170/12
meets [2] 150/12
180/8
member [8] 9/18
9/23 12/6 16/8 85/4
99/1 112/21 179/17
members [7] 6/19
46/2 98/5 98/25
183/19 191/17 202/25}
members’ [1] 126/7
memory [1] 155/6
memos [1] 175/17
mention [3] 185/10
200/4 201/9
mentioned [6] 47/6
100/16 108/22 121/24
148/6 199/18
mentioning [1] 86/12
mentions [2] 147/24
183/19
message [1] 159/25
messages [1] 111/2
messed [1] 127/4
met [10] 8/17 45/21
60/6 85/11 85/20
104/6 125/4 126/3
179/20 187/10
mid [2] 82/21 90/9
mid-2000s [2] 82/21
90/9
middle [4] 3/24 95/3
122/13 125/12
Middle East [1] 95/3
midst [1] 77/14
might [17] 51/5 59/2
87/19 89/11 98/7
110/7 117/15 131/15
134/7 139/2 144/1
158/5 161/5 172/5
177/16 180/7 189/9
migrated [1] 126/7
migration [1] 116/1
Mike [24] 16/18 49/6
52/2 52/3 52/16 97/18)
97/23 121/24 124/17
127/10 127/15 127/24I
128/18 128/19 131/20)
138/21 139/7 139/13
161/4 171/3 171/10
171/19 194/9 195/1
million [4] 96/12
96/25 157/1 173/12
mind [5] 2/25 11/4
81/18 169/18 202/21
Minister's [1] 85/12
minor [1] 146/9
minute [3] 27/12
69/21 87/6
minutes [9] 19/24
20/10 20/12 25/1
83/20 87/3 140/10
179/8 199/3
minutes’ [1] 86/24
miscarriage [6]
15/20 15/21 15/22
77/9 87/24 91/1
mismatch [13] 72/2
158/20 159/1 159/18
159/20 160/1 160/11
160/25 163/19 164/15)
201/12 203/11 205/6
Misra [3] 146/21
168/6 168/15
Misra's [2] 155/13
174/10
missing [1] 149/21
misspoke [1] 34/24
mistress [1] 203/15
mistresses [1] 168/9
mitigate [4] 15/21
77/18 87/22 87/23
mitigating [1] 91/1
mixed [2] 12/3 74/5
MJBC [1] 52/1
Mm [10] 20/2 20/6
20/20 21/7 36/24
69/14 70/7 116/23
120/25 136/13
Mm-hm [4] 20/2
116/23 120/25 136/13}
mochi [1] 58/21
model [2] 26/3 26/5
moment [1] 143/18
moments [1] 100/17
momentum [1]
103/11
Monaghan [1] 40/16
Monday [2] 111/7
159/9
money [5] 96/22
103/8 139/8 149/21
168/16
MoneyGram [1]
123/23
monies [1] 105/12
monitor [5] 51/16
52/9 53/12 56/19
153/3
monitoring [2] 40/11
161/17
Montague [1] 54/19
month [3] 141/10
150/24 190/2
months [5] 51/17
101/20 108/6 136/3
182/12
months’ [2] 166/12
166/13
moral [2] 163/12
202/17
more [49] 17/14
17/23 18/14 18/18
18/23 21/16 21/20
22/6 28/5 28/7 28/7
30/18 42/7 63/5 63/7
65/20 66/1 68/9 68/9
72/25 81/16 86/2 91/8
95/2 95/2 96/24
104/23 108/20 109/12
117/23 123/19 125/1
125/20 126/4 126/7
132/11 137/2 145/7
146/19 150/17 153/20
154/1 158/10 166/4
171/7 173/14 182/16
186/8 198/13
morning [12] 1/3 1/4
43/19 44/2 88/15
92/10 104/13 127/10
155/3 168/4 187/10
205/23
Morrison [2] 63/6
73/3
most [14] 46/16 68/6
77/2 97/6 115/8 115/9
115/11 119/24 121/13
124/10 131/13 131/16}
146/3 188/15
mostly [2] 11/8
102/24
Motion [1] 108/25
move [11] 28/9 31/11
31/22 69/4 114/7
122/19 138/11 138/14]
178/23 179/14 203/8
moved [5] 53/13
88/24 122/6 123/16
155/7
moves [1] 155/17
moving [1] 16/3
MP [4] 108/23 113/19
168/23 180/4
MPs [2] 111/13 180/7
Mr [151] 1/8 1/13
1/15 1/18 11/6 11/6
16/7 16/11 16/21 17/3
17/16 17/25 18/2 18/9
19/7 19/12 19/14
19/17 25/15 26/2
26/11 26/24 27/15
28/4 29/2 29/17 30/5
31/11 44/24 44/24
48/15 51/4 62/9 82/9
82/10 82/22 83/1
83/24 84/14 85/2
88/13 88/15 88/21
90/3 92/3 92/6 92/8
92/22 93/3 93/7 97/18
102/4 108/7 110/8
112/4 112/10 112/11
118/20 120/16 121/21
125/4 126/24 127/1
127/13 130/20 130/23}
133/20 134/1 134/11
134/12 134/22 136/15]
136/22 137/15 137/15}
138/3 139/11 140/21
142/12 142/14 142/20}
142/24 142/24 143/3
143/6 143/7 145/18
149/4 149/5 150/21
152/25 154/4 154/4
154/5 154/5 154/12
155/1 155/7 155/10
156/11 156/18 161/20
164/4 165/3 166/11
169/9 170/17 173/9
178/13 179/1 179/14
180/12 180/13 181/4
183/24 184/2 184/2
184/8 184/20 187/1
188/8 189/21 191/12
191/13 191/20 192/3
193/18 195/12 196/2
196/9 198/25 199/3
199/5 199/6 200/12
201/9 201/10 201/11
201/21 204/13 204/14,
204/16 205/2 205/9
205/11 205/13 205/19
205/19 207/4 207/10
207/12
Mr Austin [2] 44/24
51/4
Mr Bell [1] 180/13
Mr Bell's [1] 181/4
Mr Bennett [2] 11/6
44/24
MR BLAKE [30] 93/3
108/7 112/4 118/20
130/20 134/11 136/22)
142/12 149/4 152/25
156/11 156/18 164/4
170/17 173/9 179/1
180/12 183/24 184/20)
187/1 189/21 191/12
191/20 193/18 196/9
201/21 204/16 205/11
205/19 207/10
Mr Bounds [16]
102/4 110/8 112/10
112/11 121/21 138/3
142/14 142/20 145/18
150/21 154/4 154/5
155/7 184/2 195/12
196/2
Mr Christou [9] 1/8
1/13 1/18 62/9 82/10
83/24 84/14 85/2 92/8I
Mr Christou's [2]
92/6 142/24
Mr Coombs [1] 11/6
Mr Courtley [16] 17/3
17/16 18/2 18/9 19/7
19/12 19/14 19/17
25/15 26/2 26/11
26/24 27/15 28/4 29/2I
30/5
Mr D'Alvarez [1]
120/16
Mr David [3] 16/21
17/25 88/13
Mr Duncan [1] 29/17
Mr Gilbert [2] 149/5
161/20
Mr Harris [1] 143/7
Mr Humphrey [1]
166/11
Mr Jenkins [5] 82/22
165/3 178/13 201/9
201/11
Mr Jenkins’ [1] 192/3}
Mr Jones [1] 169/9
Mr Kamata [2]
142/24 143/6
Mr McDonnell [1]
88/21
Mr Mike [4] 97/18
Mr Muchow [1] 48/15)
Mr Richard [1] 90/3
Mr Smith [2] 125/4
137/15
Mr Stein [4] 199/3
200/12 201/10 204/14I
Mr Stephen [1]
155/10
MR STEVENS [6]
1/15 82/9 83/1 88/15
92/3 207/4
Mr Tait [11] 31/11
92/22 140/21 179/14
191/13 198/25 199/6
204/13 205/2 205/9
205/13
Mr Ward [1] 205/19
Mr Wilkerson [1]
134/1
Mr Young [14]
126/24 127/1 127/13
130/23 134/12 134/22!
136/15 137/15 139/11
154/4 154/5 154/12
155/1 184/2
Mr Young's [2]
133/20 184/8
Mrs [1] 166/12
Mrs Humphrey [1]
(72) meeting... - Mrs Humphrey
Mrs Humphrey... [1]
166/12
Ms [26] 86/23 87/2
87/7 87/10 92/2 97/22
100/4 100/16 100/25
101/4 113/14 165/12
181/4 186/21 188/7
188/9 189/18 190/9
190/24 191/4 191/6
191/9 191/18 194/5
195/8 207/6
Ms Kirkham [1]
113/14
Ms McQue [1]
165/12
Ms Page [4] 86/23
87/2 87/7 92/2
Ms Sewell [1] 191/18
Ms Vennells [17]
97/22 100/4 100/16
100/25 101/4 181/4
186/21 188/7 188/9
189/18 190/9 190/24
191/4 191/6 191/9
194/5 195/8
much [26] 1/18 3/10
17/14 17/23 18/17
18/23 21/19 28/5 31/1
31/6 48/15 87/9 92/8
93/4 96/11 104/15
104/21 111/8 132/5
140/14 141/1 185/14
185/17 198/25 205/13
205/24
Muchow [1] 48/15
muck [1] 204/9
must [12] 57/12
62/21 65/11 65/16
89/22 101/4 101/8
106/1 108/8 142/12
149/22 153/2
mutual [2] 18/13
176/8
my [81] 14/3 15/17
28/20 29/16 30/20
30/21 31/4 32/2 32/23
47/8 53/10 53/19
56/11 58/1 60/9 60/14
62/14 62/14 63/4
72/18 73/4 73/7 74/5
75/13 75/21 77/4
77125 79/24 79/24
80/20 83/17 88/11
89/8 90/14 91/24 92/1
93/6 94/19 97/17
99/15 100/5 101/1
106/3 114/1 114/13
118/12 118/20 121/16}
123/9 129/14 130/7
131/3 133/20 135/10
135/11 135/14 137/2
137/13 139/11 143/10
149/4 152/25 155/1
155/6 156/18 157/6
158/7 161/13 172/11
174/14 185/1 187/24
188/6 188/20 191/17
195/17 196/7 197/13
198/11 198/12 199/1
myself [1] 80/11
N
name [16] 1/16 5/8
31/15 51/6 71/19
85/12 85/13 85/17
93/4 93/6 102/3
104/12 167/19 167/22)
167/24 176/24
names [4] 44/16
121/11 153/23 167/20)
Naruto [1] 16/7
national [7] 39/1
126/6 156/2 157/18
182/10 184/12 184/15)
nature [2] 40/24
163/21
near [1] 45/20
nearly [1] 53/14
necessarily [2] 75/14
140/25
necessary [13] 13/8
14/18 15/18 40/1 42/7,
51/17 81/8 128/23
136/14 147/21 149/23)
187/6 193/20
need [31] 7/18 25/23
34/5 35/22 41/23 46/5)
46/13 47/4 52/7 55/11
66/21 88/18 99/7
4111/1 111/8 114/1
114/5 115/21 120/4
134/24 145/7 148/15
149/8 154/15 156/22
179/8 180/22 185/9
193/8 193/21 198/2
needed [7] 18/22
39/20 40/2 78/20
109/2 114/13 185/1
needs [6] 89/22
175/5 182/16 188/14
188/16 192/15
negotiating [3] 32/23
33/5 42/4
negotiation [3] 37/3
84/8 173/10
negotiations [1]
84/11
neither [2] 146/25
168/17
net [1] 117/16
Network [2] 123/23
124/1
never [19] 32/4 33/25
43/1 46/19 46/20
64/20 66/23 70/10
71/19 74/22 75/14
85/23 88/1 89/7 125/4
128/11 147/20 147/23
191/16
nevertheless [2]
87/19 88/20
new [17] 22/23 26/2
26/5 58/7 118/9
121/23 121/25 126/20
160/6 182/2 182/7
184/22 185/14 185/23
187/25 189/11 193/8
New York [1] 22/23
news [9] 103/10
113/17 144/4 148/19
181/15 182/12 188/3
188/17 203/23
newspaper [1]
189/15
newspapers [1]
109/7
next [24] 14/25 16/13
16/13 19/1 37/10
42/20 51/17 99/22
116/20 132/2 133/9
136/5 137/9 141/13
141/17 147/8 150/23
163/5 180/8 186/15
192/24 194/7 195/10
202/10
Nick [1] 155/11
night [1] 185/8
nine [1] 116/21
no [145] 4/12 8/2 8/4
9/25 13/19 17/10
19/10 19/19 21/16
21/24 23/6 23/6 24/15)
25/13 27/11 34/21
37/6 39/23 41/6 41/6
43/17 44/25 45/9
46/15 46/22 47/1 49/9
49/11 50/14 53/16
56/14 56/17 60/5
60/17 61/5 61/14
62/14 62/18 63/11
63/11 63/11 63/19
64/12 64/20 66/21
67/22 69/2 69/11
69/11 70/10 70/15
71/13 72/6 72/14
72/19 74/21 75/20
75/20 77/4 77/23
77/23 78/22 79/9
80/14 80/14 81/6 82/7
82/18 84/5 84/25
85/23 86/6 86/6 86/22
87/9 89/4 90/10 90/19
90/24 91/11 91/20
99/7 104/6 104/9
107/19 107/20 112/1
113/12 114/3 114/5
114/5 117/14 118/4
118/8 119/8 120/4
121/3 124/24 125/4
125/7 133/16 138/21
142/1 142/16 145/22
149/25 152/8 152/12
152/18 156/21 157/19}
158/9 158/13 159/25
160/3 161/3 161/12
164/12 165/2 167/15
167/16 178/2 180/15
182/9 182/22 184/1
184/6 184/6 184/7
185/10 186/7 186/16
188/19 193/2 195/16
196/19 198/7 198/16
198/24 200/3 200/15
201/10 203/2 203/3
204/14
nobody [5] 11/25
53/23 61/6 90/11
90/21
nodded [3] 110/20
140/6 200/23
noises [2] 169/13
170/6
non [3] 7/12 22/13
76/10
non-polling [1] 76/10
non-UK [2] 7/12
22/13
none [6] 9/14 26/9
63/19 71/21 91/23
161/7
nonetheless [1]
95/24
nor [2] 146/25 174/14)
normal [5] 29/15
59/18 77/21 78/8
106/13
Northern [1] 74/15
not [230]
note [7] 152/6 158/22
159/23 162/1 162/2
185/21 201/24
noted [2] 107/10
159/12
Notes [2] 197/19
197/21
nothing [17] 15/25
31/21 42/11 59/18
84/3 84/5 90/15 152/4
154/20 156/9 177/6
177/9 177/13 185/25
190/6 190/7 190/8
notice [3] 65/4
200/10 204/19
notification [1] 148/9
notifying [1] 201/5
noting [1] 150/22
November [4] 51/22
192/8 192/22 192/25
now [102] 2/12 3/10
3/10 4/1 4/13 6/5 6/7
7/7 8/12 17/7 19/20
21/25 26/14 28/4
31/22 32/25 34/2
35/11 35/12 37/3 39/5
40/14 44/5 48/25
50/10 51/9 51/24
52/14 53/13 59/4
70/25 72/1 72/1 72/5
72/15 72/25 73/9
75/11 75/13 76/20
84/13 87/16 88/5
88/18 89/15 92/12
100/15 108/11 108/19}
109/5 109/7 110/18
112/22 114/7 123/2
124/20 127/6 127/21
129/15 133/8 134/20
135/2 135/4 136/2
136/4 137/2 137/25
138/11 141/8 141/9
142/17 142/18 143/2
145/11 150/3 154/8
154/24 156/1 156/20
159/5 163/14 168/6
169/19 177/15 179/4
185/2 185/19 187/8
189/1 199/9 199/17
200/3 200/9 200/19
200/24 201/17 201/20)
202/24 203/9 203/11
204/4 204/21
nowadays [1] 68/5
nub [1] 86/14
number [27] 2/2 2/11
2/21 46/12 58/4 73/15
93/16 93/22 94/10
96/12 97/1 97/20
98/14 102/23 103/6
1417/3 123/14 136/3
144/14 146/5 146/17
153/16 157/2 162/10
179/21 186/6 196/24
Number 3 [1] 123/14
numbers [4] 50/1
74/5 117/3 128/2
numerous [2] 85/11
182/20
fe)
objective [3] 18/22
116/4 116/10
objectives [7] 32/23
33/5 33/22 45/13
96/11 116/10 175/23
obligated [1] 146/11
obligations [12] 24/8
32/17 39/5 40/24
54/16 55/6 66/20
67/19 81/25 170/21
170/22 171/6
oblige [1] 82/16
Observation [1]
49/24
Observation/Recom
mendation [1] 49/24
observations [2]
49/18 194/15
observers [1] 23/8
(73) Mrs Humphrey... - observers
[e)
obtained [2] 76/13
79/14
obviously [8] 10/9
12/14 12/15 21/11
39/8 90/4 95/23
111/23
occasion [3] 10/1
10/2 99/19
occasionally [1]
144/1
occasions [3] 40/22
85/11 156/21
occur [1] 193/20
occurrence [2]
115/17 117/11
October [10] 71/10
101/21 104/2 104/13
104/16 104/17 106/17
108/19 145/1 199/9
off [10] 6/16 18/5
66/4 78/11 78/16 79/6
103/14 134/21 155/7
200/6
offer [4] 76/25 81/13
134/19 172/20
offered [2] 76/22
180/1
office [207] 20/10
26/18 32/15 33/1 33/2
33/10 33/18 36/10
36/20 42/4 43/8 54/2
54/16 55/18 55/20
58/14 64/16 64/19
64/25 65/2 65/3 65/11
65/14 66/5 66/8 67/10)
67/23 68/12 68/16
68/17 69/13 69/22
71/15 72/9 74/11 76/1
84/4 84/5 86/5 87/15
87/18 88/4 89/8 90/17
94/17 95/19 95/20
96/17 97/15 98/9
98/16 99/16 99/18
100/1 100/3 101/5
102/5 102/23 103/2
103/2 103/8 103/13
103/17 103/22 104/20)
105/9 106/10 106/19
106/21 107/4 107/7
107/23 110/2 110/24
110/25 110/25 111/13}
111/14 111/15 111/17)
111/17 112/9 114/15
117/16 117/18 117/20}
118/7 118/17 119/1
119/2 119/21 121/23
123/9 124/12 124/14
124/17 125/8 125/17
125/21 125/24 126/3
126/9 126/21 128/1
130/1 131/8 133/21
134/8 135/24 136/7
137/14 138/6 139/2
139/3 139/20 141/5
141/13 141/15 141/24)
141/25 142/4 142/23
144/4 144/9 144/13,
145/11 145/24 146/2
146/3 146/6 146/11
146/25 147/9 147/17
147/21 147/23 149/41
149/14 149/22 150/4
150/19 151/13 152/3
152/14 152/21 152/23)
154/6 155/7 156/12
156/13 158/23 160/14)
161/15 163/12 164/6
164/22 166/1 167/10
168/9 168/10 168/12
168/18 168/19 169/1
169/3 169/13 170/5
170/10 170/12 170/23}
171/20 171/23 172/6
172/21 173/4 173/23
174/20 176/10 181/8
181/12 181/24 182/15)
182/18 182/21 183/15)
183/15 187/11 189/8
190/19 191/17 191/24)
192/6 192/12 192/15
193/5 194/10 197/2
197/7 198/1 198/8
200/2 201/5 201/21
202/17 203/4 204/19
205/8
Office's [8] 80/15
128/6 132/1 146/24
147/4 147/10 172/24
196/17
Officer [8] 16/20
17/25 58/9 58/10
97/18 142/25 152/3
156/12
Officer's [1] 56/7
offices [3] 19/1
126/10 150/13
official [1] 169/19
officially [1] 171/3
often [5] 21/22 60/6
68/7 85/7 85/9
Oh [7] 23/2 53/6 69/7
71/19 74/25 119/3
205/22
okay [45] 20/14
33/13 34/3 35/10
47/18 62/19 63/25
71/19 79/19 96/5
100/22 107/17 109/16)
119/17 130/25 137/22!
138/1 140/9 148/5
148/11 159/6 162/11
166/2 167/6 173/9
174/21 174/25 175/19)
178/9 178/18 178/19
179/9 183/12 184/16
194/1 197/18 198/4
199/11 199/12 199/16}
199/24 199/25 200/8
201/25 202/1
old [5] 76/2 150/18
181/13 182/5 196/20
old-fashioned [1]
150/18
Oliver [2] 143/14
180/4
on [288]
once [9] 8/17 21/17
29/3 30/11 55/10
60/17 103/2 169/16
195/21
one [69] 2/12 9/12
11/4 13/12 14/16
17/20 18/24 22/13
23/11 23/20 25/11
26/9 26/13 26/22
34/23 39/16 47/20
50/18 54/4 54/7 54/19
70/15 71/13 77/7 78/2
82/10 83/10 95/20
95/20 96/11 96/20
96/21 97/10 104/10
108/13 108/19 110/21
113/7 114/15 116/9
117/5 117/10 122/13
123/22 132/11 135/22
153/1 157/12 157/13
158/1 162/24 163/1
164/18 167/10 168/13
170/10 171/10 178/17
184/6 184/24 186/8
188/15 196/10 201/15}
202/3 202/3 202/6
202/22 203/6
ones [1] 84/25
ongoing [11] 32/17
52/5 69/17 84/11
116/6 128/14 162/19
164/21 169/21 199/21
204/1
ongoing/potential [1]
169/21
online [32] 69/4
114/8 114/12 114/12
114/24 116/4 116/10
116/14 116/16 118/23}
121/19 122/5 122/14
123/12 124/9 126/3
126/8 126/10 126/14
126/23 127/2 127/12
132/3 150/23 155/8
158/25 159/5 159/5
159/13 176/9 196/21
200/15
Online’ [1] 104/21
only [38] 8/2 11/4
13/1 22/24 26/5 26/25}
31/13 31/17 31/18
32/7 47/8 52/7 67/15
70/15 71/19 78/10
89/23 90/1 103/2
107/15 109/6 111/10
116/22 117/5 126/19
130/16 134/2 147/3
147/13 147/16 151/19}
162/9 167/22 184/3
186/2 191/16 192/8
200/12
onto [1] 93/17
onward [1] 28/22
onwards [7] 4/13 6/2
7/2 24/18 72/21 85/25)
90/9
open [11] 1/22 69/24
111/19 128/25 129/19}
130/7 130/12 131/7
147/2 150/17 174/3
opening [1] 160/5
openly [1] 153/11
operate [3] 14/1 15/4
149/15
operated [1] 201/3
operating [6] 17/17
17/25 97/18 117/8
152/2 156/12
operation [6] 16/23
25/14 49/15 116/11
127/4 154/20
operational [15] 8/4
8/6 11/3 11/7 19/13
38/7 38/23 39/4 60/17
61/5 65/22 66/15
116/5 116/16 185/19
operations [19] 5/23
15/9 15/12 15/15
16/20 16/22 17/21
22/25 25/14 25/16
28/13 28/22 64/5
68/23 122/21 123/1
123/13 185/17 185/23}
operator [2] 69/20
128/16
opinion [8] 53/4
53/19 79/9 82/14
82/15 82/16 82/23
130/7
opinions [1] 54/18
opportunities [1]
184/22
opportunity [4] 66/14
131/8 174/4 175/24
opposed [2] 59/10
126/19
opposite [1] 155/3
option [2] 203/1
203/5
options [1] 127/16
or [148] 5/7 8/7 8/12
11/2 12/2 12/10 12/17]
12/22 12/23 12/24
13/7 13/7 13/23 17/10}
23/4 24/6 27/19 27/20)
27/21 28/18 28/19
29/2 29/8 31/19 32/1
37/18 39/21 40/11
41/23 43/6 44/22
44/24 45/20 46/16
47/2 50/6 50/12 51/5
52/20 52/21 52/24
53/20 54/9 54/15 55/6
55/18 56/14 56/18
58/23 59/2 60/12
62/12 62/20 64/21
65/16 67/22 68/7
68/15 70/14 70/24
71/11 71/16 71/17
74/20 76/2 76/22
76/25 76/25 77/25
80/22 81/1 83/14
84/12 84/23 86/23
87/2 94/12 97/7 98/2
98/17 99/3 101/8
102/25 103/16 104/7
104/24 105/1 105/6
108/14 111/22 113/22!
115/9 116/1 116/10
117/19 118/23 125/24)
129/12 131/9 134/22
134/23 136/21 139/8
143/4 143/13 143/25
144/1 145/24 146/9
146/13 148/25 149/9
149/21 150/24 153/18)
153/20 162/14 163/17
164/10 166/21 166/21
171/19 172/2 172/11
173/8 176/21 177/10
181/20 186/1 186/2
186/19 188/4 188/12
188/18 190/20 191/15}
193/19 195/15 196/2
196/19 196/20 196/23}
198/18 200/5 200/9
203/18 204/22 204/24I
Oracle [9] 69/17
70/23 128/14 131/13
133/11 133/12 134/14I
135/3 136/25
oral [1] 205/14
order [16] 6/11 17/2
22/5 33/22 35/21 37/7
55/5 74/15 79/14
79/16 90/17 97/5 97/9
97/12 105/1 148/20
ordered [1] 165/14
ordinary [1] 79/4
organisation [8]
13/13 14/17 15/4
153/12 164/10 174/5
194/5 204/15
organisational [2]
26/3 26/5
organisations [7]
131/11 140/1 153/9
187/21 188/20 202/2
204/7
organised [1] 146/19
organising [1]
189/10
(74) obtained - organising
[e)
oriented [2] 18/18
28/5
original [7] 20/12
30/11 45/19 51/7
124/16 124/22 124/23)
originally [3] 10/9
11/8 146/16
originated [1] 71/14
originates [1] 144/11
originator [1] 63/16
other [50] 6/16 6/19
8/2 11/7 13/14 18/12
19/1 22/12 25/14 56/3)
56/6 60/16 64/12
65/16 66/3 78/13 80/5
94/10 97/7 98/5 109/4
115/3 116/1 117/10
117/14 118/11 123/24
131/12 132/20 134/11
143/9 148/19 151/10
153/11 157/3 162/1
168/9 170/3 171/7
174/15 175/8 175/18
176/5 187/2 188/8
200/15 202/3 203/3
203/12 204/11
others [4] 141/12
143/9 167/18 175/6
Otherwise [1] 66/6
ought [4] 13/21
our [51] 14/21 19/1
66/21 77/24 83/24
84/13 85/24 92/12
104/19 104/21 105/9
110/3 110/24 111/6
111/18 119/13 122/21
122/22 123/13 126/3
128/3 131/6 131/23
135/11 135/14 135/23)
136/4 138/16 140/8
141/13 141/18 145/3
145/6 149/11 149/18
153/16 154/20 157/10
158/8 162/15 170/20
172/11 175/23 176/9
176/16 176/16 176/17)
185/18 189/7 194/5
203/19
ourselves [1] 46/13
out [52] 5/6 5/22
14/20 15/16 15/16
17/2 33/16 34/18
36/19 37/15 39/9
42/11 42/13 42/25
47/5 68/20 73/14 76/6)
79/4 90/4 90/18 91/21
96/13 107/9 110/6
115/8 122/1 122/8
126/15 126/19 126/20
130/18 131/1 146/1
154/17 155/11 162/15)
168/25 175/15 176/7
176/16 176/22 183/4
188/2 194/10 194/12
195/19 196/15 196/15)
201/21 203/19 204/8
outage [5] 69/19
69/20 70/24 128/15
128/16
outages [4] 122/10
122/14 180/5 187/20
outages/issues [1]
122/10
outcome [5] 45/17
122/8 146/24 166/20
172/4
outlets [2] 66/16
168/12
outline [1] 45/14
outlines [1] 166/10
outside [11] 53/23
53/24 57/15 59/17
59/17 68/8 77/21 78/8)
161/13 181/19 181/20)
outward [1] 17/14
over [31] 5/6 20/21
24/20 32/3 34/4 38/22
46/14 64/5 88/18
89/18 95/2 96/10
106/17 108/17 119/5
124/6 128/21 134/19
136/12 137/24 144/4
144/12 144/15 159/17,
162/12 176/23 181/13)
184/23 185/24 187/2
198/2
overall [8] 7/8 13/9
13/19 15/2 28/15
55/21 94/8 132/24
overcome [1] 125/19
Overnight [1] 189/1
overrun [1] 137/23
oversaw [1] 16/9
overseas [2] 17/16
58/14
oversee [1] 41/10
overseeing [4] 12/7
12/23 30/7 55/17
oversight [9] 16/17
21/8 22/15 26/6 26/8
28/1 28/7 56/10 83/8
owed [2] 103/8
105/12
own [3] 4/21 53/4
156/16
owned [4] 5/20 6/14
6/21 7/2
owns [1] 146/2
P
pace [6] 75/14 75/17
75/19 75/20 78/3
189/7
page [98] 2/4 2/15
2/15 3/1 3/16 3/20 5/2
7/19 20/21 22/1 23/21
25/21 25/25 31/24
32/22 34/7 36/8 37/10
38/9 38/22 41/13
42/20 42/20 45/1 45/5
45/25 46/9 46/14
49/12 49/17 49/23
51/15 51/21 63/21
65/21 69/8 72/16
73/13 73/20 73/22
74/4 74/5 75/23 81/21
83/22 86/23 87/2 87/7
87/10 92/2 93/10
96/10 99/7 99/9 99/21
103/20 105/3 106/18
107/8 108/9 108/17
119/5 119/19 121/20
127/7 129/22 129/23
133/2 135/6 137/24
142/19 144/19 144/25I
145/5 145/14 145/17
159/17 160/12 162/12
165/16 167/12 176/23
182/13 182/25 185/25
186/4 187/8 192/10
196/11 196/13 197/8
197/9 199/7 199/15
201/14 203/8 203/9
207/6
page 1 [3] 121/20
135/6 145/17
page 12 [2] 23/21
34/7
page 13 [1] 199/15
page 14 [1] 83/22
page 15 [1] 65/21
page 17 [3] 36/8 46/9
75/23
page 196 [1] 73/13
page 2 [8] 7/19 108/9
119/19 127/7 133/2
142/19 145/14 203/9
page 21 [2] 2/15
72/16
page 22 [1] 31/24
page 24 [2] 99/7 99/9
page 26 [2] 32/22
38/9
page 27 [2] 3/1 99/21
page 29 [1] 2/4
Page 291 [1] 73/20
page 3 [5] 5/2 25/21
96/10 167/12 201/14
page 30 [1] 3/16
page 363 [1] 73/22
Page 393 [1] 74/4
page 4 [5] 22/1 45/5
49/12 197/8 197/9
page 5 [4] 106/18
196/11 196/13 199/7
page 587 [1] 41/13
page 6 [1] 49/17
page 67 [1] 93/10
page 7 [2] 45/25
107/8
page 8 [1] 25/25
page 9 [2] 49/23
63/21
page numbers [1]
74/5
pages [3] 34/4 36/7
42/19
paid [1] 146/4
paint [1] 120/4
pair [1] 124/41
Panorama [1] 90/1
paper [3] 103/23
150/18 176/6
papers [1] 144/9
paragraph [39] 2/16
2/20 2/21 5/2 7/19
22/1 23/22 31/24
31/24 32/22 38/3 46/6)
51/15 72/17 99/7
99/12 99/21 99/22
104/18 116/20 118/14}
118/15 118/24 119/19}
124/3 131/21 132/2
133/9 133/14 138/19
147/8 148/1 150/9
156/6 176/3 180/19
189/4 193/12 199/15
paragraph 10 [1] 5/2
paragraph 101 [1]
727
paragraph 102 [1]
193/12
paragraph 103 [2]
2/16 2/20
paragraph 15 [1]
22/1
Paragraph 201.3.1 [1]
38/3
paragraph 36 [1]
199/15
paragraph 5 [1] 7/19
paragraph 55 [1]
23/22
paragraph 67 [2]
31/24 31/24
paragraph 73 [2]
99/7 99/12
Paragraph 75 [1]
99/21
paragraph 79 [1]
32/22
paragraphs [7] 5/8
42/15 72/21 115/16
124/4 133/4 192/11
paragraphs 75 [1]
72/21
Parcelforce [1] 126/2
pardon [2] 67/11
67/11
parent [3] 7/8 22/8
28/15
Parliament [4]
108/25 112/22 112/23}
183/19
Parliamentarian [2]
113/6 155/19
Parliamentary [1]
111/20
Parlimentarians [1]
109/8
Parsons [1] 197/10
part [22] 8/12 22/1
36/10 37/18 37/19
39/20 50/6 68/22
83/21 88/1 95/22
95/24 104/10 130/9
139/25 143/4 167/8
171/6 187/13 194/9
200/3 201/3
parted [1] 6/20
partially [1] 126/20
Participants [2]
86/21 92/5
participation [1] 7/21
particular [28] 11/2
17/15 30/8 36/21
43/10 56/10 62/6
64/18 64/23 77/5
106/17 107/16 115/3
123/20 141/1 147/7
151/19 151/25 153/19}
154/2 158/4 165/25
169/22 178/8 178/16
180/6 180/16 180/24
particularly [5] 44/9
60/17 78/15 90/15
156/23
parties [4] 32/20
54/11 131/24 134/9
parties' [1] 106/12
parts [1] 20/24
party [6] 6/3 117/4
132/14 133/16 133/23}
135/18
pass [5] 18/1 32/9
32/15 62/2 191/9
passages [3] 99/11
131/21 183/10
passed [3] 70/16
104/11 190/9
passes [1] 52/11
passing [2] 33/14
70/14
past [3] 112/3 185/15
200/22
patches [1] 201/5
Pathway [54] 6/7 6/7
6/9 6/11 6/12 10/6
10/16 10/24 11/5
12/10 12/13 12/17
12/24 13/14 13/23
16/24 19/24 21/9
21/22 25/12 26/14
26/15 26/19 27/9 28/1
29/23 30/17 33/2
33/10 37/8 44/18
52/18 53/24 56/19
57/6 57/19 59/15
(75) oriented - Pathway
P
Pathway... [17] 59/22
60/12 60/15 61/12
61/18 61/22 64/14
64/18 64/23 66/12
73/22 74/9 74/10
83/15 84/10 88/17
89/3
Pathway/ICL [1]
59/22
Patricia [3] 85/12
85/15 85/16
Paul [1] 115/19
Paula [20] 174/20
174/23 175/4 175/21
179/20 185/6 185/8
185/12 185/18 186/18)
187/10 187/24 188/3
188/23 190/13 194/24
195/1 195/6 197/12
198/5
pause [3] 8/24 56/23
84/3
pausing [11] 32/25
104/3 116/9 124/7
136/10 139/6 148/22
150/3 159/3 172/7
188/2
pay [1] 139/14
paying [1] 140/25
payments [10] 72/2
158/20 159/1 159/18
159/20 160/1 160/11
160/25 163/18 164/15
PC [1] 68/7
PCs [1] 66/9
pejorative [1] 90/13
penalty [2] 53/2
53/10
Penny [5] 167/13
167/14 168/1 169/24
174/18
Penny's [1] 169/12
penultimate [3]
49/18 138/18 188/11
people [59] 8/3 8/4
8/6 8/23 9/10 9/12
11/7 13/12 13/14 14/1
14/11 14/17 15/3
19/12 19/13 30/19
39/15 39/24 40/3
40/18 41/2 41/7 41/9
42/3 42/10 47/4 52/16
54/14 54/17 54/21
54/24 55/10 55/22
55/25 57/18 58/8
58/14 60/16 60/18
63/18 63/20 67/6
71/10 81/17 85/10
89/6 94/15 97/20
115/9 143/9 148/25
154/4 161/7 161/18
161/21 172/13 174/6
205/5 205/6
per [2] 50/25 96/25
per annum [1] 96/25
perform [4] 37/8
37/13 39/4 146/6
performance [4] 21/5)
36/10 38/23 185/19
performing [1] 36/16
perhaps [7] 91/7
91/7 95/25 98/2 115/9)
176/2 190/15
period [21] 30/6
89/18 97/22 97/24
100/11 101/7 114/14
134/6 134/7 135/2
137/25 138/14 157/8
160/6 160/9 163/6
164/13 183/21 185/1
190/22 202/11
permanent [6] 30/18
84/7 84/15 84/21
84/22 85/16
person [12] 14/25
16/9 40/16 58/16 68/2
82/12 115/7 115/11
117/7 121/13 129/25
137/9
personal [1] 102/10
personally [3] 42/12
104/5 157/8
personnel [7] 8/2
14/19 64/6 77/14
164/6 164/7 191/18
persons [1] 8/2
perspective [5]
24/12 27/14 32/13
98/4 158/6
persuade [1] 126/11
pertinent [1] 32/7
PFI [1] 7/4
phase [4] 11/16 44/9
124/21 133/15
Phase 2 [2] 11/16
44/9
Philip [1] 143/14
Philippe [3] 119/6
167/19 169/5
phone [2] 68/7 193/3
pick [1] 110/7
picked [4] 143/20
143/22 143/24 151/22)
picture [1] 177/16
pieces [1] 79/7
piercing [1] 28/7
pilot [13] 114/8
114/20 116/21 121/19)
122/5 122/6 122/19
126/5 133/8 133/11
135/5 138/10 141/4
pilots [1] 114/12
PinICL [4] 44/10
45/12 50/1 51/16
PinICLs [2] 45/20
50/2
Pinsent [1] 40/14
pivotal [1] 131/25
place [24] 13/11 25/6
39/11 84/8 89/19
100/13 101/2 112/4
114/23 129/17 137/16
148/10 159/7 172/3
174/2 175/16 180/15
184/18 184/20 184/21
184/24 195/14 195/18}
198/5
placed [2] 104/20
106/12
places [1] 152/13
placing [1] 198/9
plan [5] 24/5 49/13
128/8 128/9 176/11
Plan B [1] 128/9
planned [2] 187/21
189/11
planning [3] 21/21
148/8 168/10
plans [1] 175/23
platform [3] 117/8
187/15 188/1
play [3] 114/4 131/25
178/17
pleaded [1] 166/7
please [127] 1/16 2/3
3/1 3/16 3/20 5/1 13/2
19/21 20/7 20/21
21/25 24/24 24/25
25/17 25/21 31/23
32/22 34/7 34/12 36/8
37/10 38/9 42/14
42/21 43/21 44/7 45/1
45/5 46/9 49/1 49/12
49/23 51/20 51/21
63/21 65/21 66/11
69/4 69/8 70/25 71/13)
72/15 72/23 73/12
73/13 73/17 73/18
73/20 73/22 73/23
73/25 74/4 74/7 74/24
75/23 75/25 81/21
83/17 83/22 87/11
92/14 93/5 93/10
96/10 99/6 99/21
99/22 101/21 105/4
105/12 105/21 106/18}
107/20 108/10 108/17
109/10 109/24 110/10
114/22 119/5 119/13
121/17 121/20 122/3
123/17 127/7 129/22
129/23 133/2 135/6
137/18 137/19 140/10}
140/12 141/8 142/17
142/19 142/23 145/5
145/14 154/8 160/23
162/12 164/14 165/7
165/24 166/14 167/12
170/19 177/15 178/22
179/8 179/15 181/8
181/23 182/12 182/25
183/6 185/5 187/7
189/22 192/5 196/11
199/8 201/13 201/16
203/8
pleased [2] 125/18
133/5
plight [1] 141/17
plug [1] 128/10
plus [4] 21/1 49/3
96/12 157/1
pm [7] 92/16 92/18
140/15 140/17 179/10}
179/12 205/25
pocket [1] 110/3
POCL [2] 42/24
74/11
point [44] 4/14 14/20
20/9 20/15 25/11
31/11 38/18 40/8
40/10 42/1 43/11 47/5
47/13 54/10 54/10
61/11 63/14 73/1
85/20 87/24 97/17
97/21 108/19 108/20
112/21 126/14 126/18}
136/19 136/23 138/13
143/1 143/6 143/12
153/21 155/6 159/19
178/5 179/21 180/16
182/7 183/2 184/10
186/3 196/16
pointed [1] 201/21
points [15] 20/11
41/11 47/14 49/19
50/10 50/15 90/12
97/14 103/20 108/18
127/13 160/2 162/3
179/21 194/12
POL [1] 183/6
POL00017555 [2]
177/15 178/22
POL00024828 [1]
196/10
POL00028838 [3]
71/1 160/23 201/14
POL00329433 [2]
165/8 165/9
POL00382242 [1]
192/5
Police [2] 74/13
7414
policy [2] 75/2 112/8
politicians [1] 186/2
polling [1] 76/10
poor [2] 46/8 50/8
portfolio [1] 95/13
position [9] 10/22
84/13 138/16 140/22
146/1 147/11 189/8
196/17 197/25
positions [1] 144/15
positive [2] 103/4
110/6
positively [1] 128/1
possibility [4] 91/15
135/24 147/2 171/25
possible [16] 13/4
15/15 59/2 64/13
103/14 103/15 111/9
120/5 134/10 178/6
178/10 178/15 189/1
202/22 203/5 204/5
possibly [2] 117/21
119/21
post [210]
post-the [1] 155/8
postmaster [4]
117/18 117/23 119/24)
120/8
postmaster/clerk [2]
117/23 119/24
postmasters [7]
15/23 91/3 91/18
146/4 146/19 159/10
159/11
PostShop [1] 172/24
potential [10] 66/13
90/20 118/2 118/5
146/20 162/19 169/21
176/12 201/18 204/1
potentiality [1] 75/15
potentially [8] 113/18)
119/20 120/9 128/10
139/7 139/20 172/9
205/18
power [1] 123/15
PR [1] 142/4
practical [1] 23/6
practically [1] 30/2
practice [2] 10/13
106/13
praise [2] 152/4
184/4
praised [1] 185/18
pre [1] 182/3
precedent [1] 139/1
preceding [1] 145/23
precise [5] 4/18
13/19 32/6 33/6 39/12)
precisely [5] 6/4 27/7)
40/24 59/17 96/7
predecessor [2] 96/1
176/5
predominantly [1]
64/7
prefer [3] 87/2
204/24 205/1
pregnant [1] 168/6
prejudice [4] 106/20
138/7 138/25 139/16
premises [1] 186/11
preparation [3] 33/23
194/6 200/13
preparations [1]
60/21
prepare [4] 76/17
76/21 80/11 110/3
(76) Pathway... - prepare
Pp
prepared [2] 164/24
182/3
preparing [2] 103/14
104/24
present [4] 27/16
72/20 76/5 176/17
presentation [1]
95/25
presented [3] 27/22
45/24 88/9
presenting [4] 26/2
45/15 45/17 158/23
presents [1] 49/13
president [6] 16/11
16/13 16/14 17/20
28/12 29/3
press [14] 103/10
110/2 110/24 110/25
111/6 111/14 111/16
111/17 112/23 146/9
157/23 177/6 181/24
199/21
pressed [1] 158/3
pressing [1] 145/7
pressure [1] 128/7
presumably [6]
13/20 35/22 39/20
40/23 47/4 169/15
presume [3] 16/19
52/17 65/11
pretend [1] 40/5
pretty [2] 185/17
200/5
prevent [3] 68/3
146/7 151/1
prevented [1] 45/19
preventing [1]
172/21
previous [4] 67/14
109/22 127/3 190/2
previously [5] 18/11
59/24 143/1 176/6
192/17
pricing [1] 189/1
primarily [1] 150/24
primary [1] 120/21
principally [1] 154/3
principles [1] 176/8
printer [3] 50/23
50/24 51/1
prior [5] 96/8 104/14
120/13 184/25 195/10}
Priorities [1] 185/25
prison [3] 155/16
158/2 168/7
private [15] 94/5 94/9)
94/17 94/18 95/21
96/14 97/2 97/2
110/13 114/18 148/2
148/16 155/9 161/19
167/8
privilege [1] 194/19
privileged [6] 66/7
67/6 89/21 193/19
194/4 196/6
proactive [2] 110/5
195/4
proactively [1]
176/14
probably [10] 9/13
12/15 43/18 98/25
100/15 113/1 115/11
121/12 121/13 143/13)
problem [11] 65/13
65/20 66/19 69/2
77/12 78/15 86/17
135/17 160/13 168/17)
204/10
problematic [1]
119/20
problems [15] 50/25
56/24 56/25 78/2
128/23 132/9 136/12
139/9 144/24 147/6
150/25 152/23 182/23)
185/16 193/20
procedure [1] 89/5
procedures [4] 66/4
75/2 168/21 169/3
proceed [1] 126/22
proceeded [1] 166/9
proceedings [4]
99/17 99/19 99/20
100/1
process [15] 7/25
45/14 46/8 65/25
74/18 88/25 89/1 90/4
98/19 116/25 123/18
131/22 159/16 162/6
196/25
processes [8] 86/15
129/4 147/3 153/16
169/1 194/14 194/16
194/19
produce [6] 9/19
39/25 54/18 159/15
164/22 165/19
produced [13] 32/14
48/10 55/18 63/4
74/11 82/5 96/2 96/4
111/12 113/16 160/10)
165/10 165/21
produces [1] 102/19
product [20] 32/14
37/24 41/24 43/9
43/11 43/15 45/23
46/4 48/10 50/8 52/7
52/10 55/8 55/17
87/17 133/11 155/18
156/14 156/16 157/4
products [4] 36/11
37/5 132/1 150/13
professionally [1]
149/15
profile [4] 111/22
profit [1] 128/20
profitably [1] 15/16
program [1] 53/15
programme [38] 6/8
6/9 6/12 70/6 103/13
113/18 116/4 127/2
127/14 128/4 129/2
129/5 129/12 130/16
131/4 131/14 131/17
132/4 132/15 132/20
132/23 132/24 133/15}
134/2 134/13 134/14
135/1 135/19 136/23
136/25 138/11 148/4
148/7 152/9 154/16
154/18 155/17 155/22
programmes [1]
187/20
programming [1]
46/17
progress [6] 52/10
56/2 125/25 133/6
136/8 189/2
progressed [1]
201/20
progressing [2]
122/5 137/4
progressively [1]
39/10
project [6] 26/21
27/16 55/24 56/3
85/19 192/12
projects [5] 26/10
26/13 26/20 26/22
56/3
prominent [1] 100/25)
promoted [1] 97/19
prompt [1] 169/3
proof [1] 147/7
proper [3] 56/20
169/3 202/2
properly [9] 14/2
14/11 40/20 55/22
80/24 81/11 88/9
149/21 172/4
proposal [2] 133/18
176/15
propose [2] 1/11
11/17
proposed [3] 137/12
138/19 162/24
proposes [1] 176/21
proposition [1]
176/17
prosecute [1] 149/24
prosecuted [1]
172/14
prosecuting [2]
72/10 150/5
prosecution [8]
86/10 146/21 151/16
165/18 174/7 177/13
191/11 191/22
prosecutions [11]
72/12 72/15 86/16
91/9 100/6 100/12
100/14 101/10 101/17}
150/20 166/25
protect [3] 68/8
115/21 120/23
Protection [1] 66/17
prove [1] 126/11
proved [1] 131/24
provide [24] 33/10
38/4 39/10 41/19 43/8)
54/2 54/24 56/4 65/10)
75/8 77/1 77/24 7/25)
77/25 80/19 82/16
84/19 128/22 142/21
147/24 162/21 180/1
186/13 187/5
provided [24] 1/20
14/1 37/25 41/25 42/9}
63/5 64/12 73/3 79/1
105/16 108/2 115/3
115/6 126/25 150/13
152/6 160/14 171/18
179/24 180/19 191/23
192/17 196/14 196/18}
provider [1] 85/5
provides [2] 21/4
155/24
providing [11] 39/25
107/3 107/22 139/8
146/12 146/23 151/12)
152/19 153/12 165/4
205/14
proving [1] 186/8
provision [4] 7/20
39/8 39/8 78/7
provisions [2] 33/21
37/14
proxy [1] 124/1
Prénovost [2] 119/6
169/6
Prénovost's [1]
167/19
pub [1] 201/24
public [3] 105/10
111/18 147/10
publications [1]
149/10
publicity [2] 102/20
151/9
publicly [2] 149/12
198/1
publish [1] 150/19
published [2] 3/12
191/14
pull [2] 127/17
128/10
purchase [1] 16/9
purely [1] 173/15
purpose [7] 13/20
70/22 87/18 87/25
106/18 120/21 158/22}
purposes [5] 7/2
8/20 28/10 73/4
106/20
pursuant [2] 38/4
38/7
pursue [2] 123/6
135/21
pursued [1] 159/11
pursuing [1] 133/16
pushed [2] 136/19
188/7
put [11] 29/14 56/14
62/23 89/19 91/5
104/25 112/4 153/6
184/18 195/18 202/20)
puts [2] 64/14 64/23
putting [2] 36/4
169/15
pyramid [1] 5/12
Qo
qualified [6] 3/21
40/20 55/22 58/7
132/14 135/18
quality [6] 44/19 46/3
50/8 52/10 55/17
185/18
quarterly [6] 23/24
24/6 24/7 57/5 60/21
60/23
queries [4] 76/2 76/2
82/2 186/6
query [2] 76/18 79/15
querying [1] 103/7
question [28] 9/6
12/18 15/7 24/10
24/11 29/1 55/3 57/2
71/13 76/11 77/3 78/5I
80/2 86/11 86/14
91/14 101/1 105/21
117/25 119/3 120/9
126/18 180/12 197/19)
201/11 204/16 204/16I
205/1
question’ [1] 120/1
Questioned [8] 1/15
87/10 93/3 199/5
207/4 207/6 207/10
207/12
questions [27] 3/13
32/7 32/13 52/24 59/2
71/17 86/19 86/21
86/24 87/2 87/11 92/1
103/15 105/6 111/12
111/20 142/3 163/9
163/10 181/5 189/5
198/12 199/1 199/3
202/14 202/15 203/12!
quick [2] 191/11
203/10
quite [30] 6/6 6/20
6/23 10/11 12/18
20/21 25/24 43/1
44/21 85/9 85/14
85/18 100/19 102/3
106/11 114/11 118/14
118/24 120/11 136/15)
(77) prepared - quite
Q
quite... [10] 137/21
139/19 152/13 154/24)
157/5 162/25 165/9
187/23 196/12 200/13
quoted [2] 22/22 24/8)
quotes [1] 119/20
QVRs [1] 56/5
R
R808 [1] 42/16
Rachael [1] 123/12
Rachel [1] 123/3
radio [1] 168/4
radius [1] 124/1
raise [10] 3/14 19/15
59/2 59/2 68/16
112/24 127/1 152/23
169/23 174/12
raised [53] 19/3 45/3
48/5 48/7 50/2 50/3
59/9 61/18 61/19
64/17 65/1 67/17
67/21 68/17 68/25
72/12 72/20 77/10
77/11 77/15 77/18
81/3 90/8 91/15 91/19
91/22 98/17 101/10
101/17 105/19 109/6
113/13 119/14 134/22)
137/11 147/19 148/23)
151/22 153/5 157/5
157/16 157/17 163/22
163/23 164/3 171/24
186/6 186/16 186/20
189/5 189/16 191/2
192/19
raises [4] 137/22
172/19 180/11 180/24}
raising [5] 50/12
56/16 60/1 193/8
195/8
ran [1] 72/9
range [1] 76/9
Rarely [1] 145/7
rate [1] 50/2
rather [14] 21/19
42/7 52/6 62/5 62/22
86/17 117/22 119/23
120/8 127/2 130/8
147/6 160/6 185/15
Relient [1] 64/7
re [2] 51/13 51/18
re-engineer [1] 51/13
re-evaluate [1] 51/18
reach [1] 14/2
reached [3] 14/1
113/8 138/22
reaching [1] 122/1
reaction [1] 126/1
reactions [2] 125/20
125/22
read [37] 25/23 33/25
36/3 41/5 41/23 46/5
46/18 47/23 50/22
65/6 66/23 66/24
71/14 72/5 74/23
75/22 97/5 108/8
109/21 109/24 110/21
113/1 113/3 115/1
115/15 124/3 130/20
131/20 138/18 148/1
150/9 156/8 176/2
180/18 183/10 196/15)
200/10
reading [7] 40/12
65/12 96/8 113/11
117/7 118/14 180/21
readout [1] 185/7
ready [1] 181/25
real [8] 41/10 91/8
113/13 126/13 134/13)
134/14 135/3 189/17
reality [1] 89/20
really [18] 11/25
15/23 18/22 23/15
26/6 28/22 30/14 31/6
44/22 48/9 58/1 61/7
81/18 89/24 90/1
101/1 130/4 195/4
reappeared [2]
108/22 109/3
reason [6] 48/13 97/7I
97/9 123/8 134/4
171/23
reasonable [2] 95/22
172/20
reasonably [1] 87/8
reasons [3] 18/24
48/12 150/24
reassurance [6]
127/17 153/13 153/21
183/23 184/11 190/4
reassurances [2]
190/6 190/9
reassure [1] 152/22
reassured [6] 154/2
156/20 156/23 183/16
205/4 205/5
reassuring [1]
189/18
rebut [2] 105/1 105/9
recall [69] 8/6 10/2
10/20 10/21 11/1 11/7
19/17 21/22 27/8
27/13 31/11 44/22
44/25 50/11 61/16
63/17 63/20 70/8
70/13 72/19 96/6 96/7)
98/12 99/13 100/3
100/7 100/23 101/3
101/5 101/9 101/25
105/13 105/14 105/14)
105/18 106/11 109/20)
123/18 131/1 135/23
137/17 142/5 142/7
142/10 148/22 151/19)
155/21 157/24 164/14)
172/3 177/1 180/9
180/12 183/7 183/8
183/8 183/9 186/17
186/21 187/4 188/3
192/25 193/6 193/7
194/2 194/5 195/6
195/8 195/19
receipts [10] 72/2
158/20 159/1 159/18
159/20 159/25 160/11
160/24 163/18 164/15}
received [8] 52/1
108/7 109/22 113/2
136/5 142/12 164/25
183/14
receiving [4] 105/13
142/5 150/7 150/8
recent [5] 103/6
132/6 138/9 177/6
179/23
recently [4] 63/5
146/18 148/2 192/9
recipient [2] 58/18
59/13
recipients [1] 121/8
recognise [3] 44/16
121/11 167/20
recognised [2]
131/22 140/23
recollect [1] 71/24
recollection [12]
6/17 28/20 31/17
44/20 61/17 139/21
184/1 185/11 190/22
198/7 198/11 200/16
recommenced [1]
133/8
recommendation [3]
49/24 51/12 201/19
recommendations
[2] 50/5 50/8
recommended [1]
194/18
recommending [1]
194/3
reconciliation [5]
116/24 117/13 117/15]
179/25 180/20
reconsidered [1]
50/9
record [10] 2/2 2/11
64/10 64/11 76/2 76/5
82/2 117/24 119/25
127/25
record' [1] 120/10
recorded [2] 162/16
203/20
records [10] 76/8
76/12 79/13 79/14
79/16 79/17 79/23
117/17 186/14 196/19]
rectify [1] 133/7
red [8] 14/4 19/16
123/16 123/17 123/18
132/6 134/19 158/9
redesign [1] 50/5
reduce [2] 116/6
131/9
reduced [1] 131/15
Reduction [1] 45/12
refer [8] 14/4 51/4
114/24 142/3 194/21
199/15 200/17 201/16}
reference [23] 2/2
2/11 34/8 73/24 73/25)
74/3 74/8 74/8 93/16
109/7 113/13 115/16
116/15 116/17 122/17]
123/14 123/22 125/8
134/9 135/25 186/5
187/25 194/23
referenced [4]
100/17 148/25 153/24)
155/14
referred [15] 6/9
36/17 37/9 41/15
52/15 59/25 69/5
73/13 81/21 106/6
106/8 108/14 120/20
152/10 194/9
referring [13] 22/8
33/9 33/16 42/16
44/12 49/4 49/21
50/19 52/16 80/15
83/7 109/4 177/21
refers [11] 38/17
69/13 70/3 74/9 76/1
103/20 104/3 130/12
144/5 148/24 188/20
reflect [1] 136/4
reflected [1] 98/21
reflection [1] 158/2
reflects [1] 124/5
refuse [3] 173/1
173/5 173/8
refused [1] 89/3
refute [1] 103/4
regard [3] 75/14
188/7 194/16
regarding [10] 61/18
99/14 138/15 138/20
141/13 141/17 145/25)
181/12 190/10 190/24}
regards [1] 107/23
Regional [1] 28/13
regions [1] 114/17
register [1] 151/15
registers [1] 98/22
regular [5] 14/23
19/5 100/2 157/3
170/12
regularly [2] 85/18
157/5
reins [1] 30/6
rejecting [1] 133/18
relate [3] 62/21 128/6
159/13
related [7] 93/23
107/4 113/6 132/6
141/21 141/22 186/14)
relates [3] 107/16
118/22 186/3
relating [13] 41/18
62/7 62/10 105/24
108/3 140/24 151/6
159/4 186/8 186/18
186/19 197/4 198/6
relation [19] 8/9
11/15 32/8 59/25
76/18 107/21 115/24
118/18 124/8 132/3
136/11 164/21 166/25)
198/10 199/21 200/19}
201/2 203/5 205/6
relationship [16]
18/8 83/23 84/1 85/2
98/1 98/8 102/8
102/10 118/17 118/25)
127/25 131/23 136/5
137/4 154/25 155/1
relationships [3]
84/14 124/12 125/8
relatively [5] 97/1
105/17 114/19 146/2
156/11
release [5] 21/1
38/25 39/3 49/3 60/1
released [3] 148/13
148/16 149/12
releases [1] 128/5
relevance [2] 173/16
173/17
relevant [9] 5/7 68/15)
73/2 74/10 76/16 86/9)
86/10 161/15 178/14
reliability [1] 107/24
reliable [1] 168/20
relied [2] 105/15
146/15
relies [1] 152/25
reluctance [2] 131/1
188/17
rely [3] 47/4 56/24
152/13
relying [1] 64/6
remain [2] 28/18
128/4
remained [1] 17/7
remains [2] 127/11
154/19
remedied [1] 65/17
remedy [1] 65/18
remember [13] 25/7
31/14 31/18 57/12
58/4 70/17 70/20
85/13 85/17 105/22
126/24 157/11 193/2
remind [1] 155/5
remote [12] 64/1
64/2 64/11 186/12
193/11 193/19 196/12!
(78) quite... - remote
R
remote... [5] 197/4
197/19 198/6 198/10
205/20
remotely [2] 64/7
193/16
removed [1] 120/20
remuneration [2]
82/5 82/6
renegotiated [1]
84/10
Renegotiating [1]
84/1
reopen [1] 52/8
reorganising [2]
17/17 30/12
repealed [2] 78/3
78/4
repeat [1] 105/21
repeated [1] 183/14
rephrase [3] 29/1
43/6 64/22
replaced [3] 150/23
155/10 187/22
replaced’ [1] 150/18
replacement [2]
83/14 151/2
replies [1] 109/25
reply [2] 109/23
135/9
report [61] 9/19
10/12 15/16 16/4
20/19 20/22 21/12
25/18 25/21 25/24
29/2 44/9 45/24 49/17
49/24 50/4 56/7 56/8
57/9 57/9 104/1
104/11 104/11 104/13
106/5 106/7 107/18
109/5 112/13 122/21
123/1 123/2 152/20
155/11 155/12 158/18}
159/24 160/24 161/2
161/7 161/20 161/21
161/23 161/24 164/20
164/23 164/23 165/5
165/15 165/19 169/25)
170/2 182/10 182/10
182/11 184/15 187/8
191/14 191/16 196/9
201/8
reported [30] 7/25
8/6 8/7 8/11 10/13
10/14 16/7 16/10
16/12 16/13 16/16
16/19 16/19 16/24
16/24 29/24 44/17
44/18 44/21 58/10
62/13 71/21 83/24
94/9 94/21 146/18
149/5 153/18 161/14
169/9
reporting [28] 8/4
16/15 24/8 24/19
26/10 26/23 29/9
29/17 56/4 56/21
56/23 59/10 59/14
61/20 61/21 71/11
83/7 83/13 115/13
122/23 149/4 156/14
157/3 159/10 161/8
174/9 177/6 191/1
reports [14] 8/18
13/18 19/6 43/16
57/16 61/24 76/10
159/15 160/15 165/21
175/12 177/22 183/22)
189/15
representatives [5]
11/9 85/3 85/7 85/20
86/1
request [14] 73/4
74/11 76/3 76/16
147/5 158/22 169/18
169/20 170/23 171/9
171/21 173/1 173/6
180/6
requested [5] 11/14
103/23 104/1 146/12
1711/3
requesting [1] 173/4
requests [4] 69/22
132/3 132/11 136/19
required [5] 14/21
43/8 66/6 75/15 110/4
requirement [5] 73/7
75/8 77/5 77/12
192/21
requirements [11]
20/17 24/19 36/14
36/20 37/5 37/8 41/18
42/17 73/14 73/15
74/5
requires [2] 14/17
106/21
requiring [2] 66/4
75/14
research [1] 184/10
residual [1] 45/20
resilient [1] 123/25
resist [2] 129/15
129/19
resolve [2] 131/13
195/9
resolved [5] 135/4
136/21 136/21 136/22!
157/14
resort [1] 149/24
resource [2] 129/5
132/19
resourced [1] 122/22
resources [5] 123/20
128/23 131/14 132/22)
161/13
respect [11] 18/13
30/4 32/5 32/17 62/20
68/23 82/5 91/8 116/7)
141/6 172/10
respected [1] 156/2
respond [4] 109/15
147/12 147/15 188/13
responding [3] 130/2
132/9 165/5
response [20] 52/1
73/21 74/20 102/19
111/4 133/1 133/2
135/7 136/11 172/1
179/25 180/19 181/4
186/25 188/22 190/11
190/12 196/14 197/15}
197/17
responses [4]
103/15 147/23 188/2
196/18
responsibilities [1]
17/13
responsibility [13]
12/7 12/10 14/10
14/14 15/5 16/16
27/15 55/21 62/1
68/22 90/23 153/4
153/9
responsible [20]
7/20 12/16 12/23
13/14 15/2 15/14
15/19 16/22 22/13
25/15 29/13 36/14
39/25 44/19 70/18
83/8 91/6 95/10 102/4
112/7
rest [1] 109/25
restart [1] 138/9
restarting [1] 126/5
restructure [4] 16/3
19/20 22/2 27/25
restructuring [1]
25/19
result [6] 24/13 66/15]
88/24 158/24 160/10
182/9
resulted [3] 46/8
159/1 166/17
resume [2] 43/20
92/13
Retail [1] 123/13
retained [1] 107/13
retains [1] 116/16
retire [1] 31/3
retired [3] 30/25
124/14 150/23
retraining [1] 117/19
returned [1] 31/6
Reuters [3] 97/11
157/9 157/23
reveal [2] 100/6
129/1
revealed [2] 117/1
117/10
revenue [1] 128/7
revenues [1] 96/24
reverse [1] 46/11
reversed [1] 130/6
review [43] 24/2
39/21 53/4 56/2 69/25)
111/23 114/23 115/19}
120/18 120/22 122/3
129/4 129/20 130/7
130/12 130/15 130/18}
130/19 1314/2 131/4
131/15 131/22 132/15}
133/17 133/19 133/22}
133/25 134/5 135/1
135/13 136/6 186/24
194/3 194/18 195/14
195/15 195/15 195/16}
195/17 195/19 195/20)
195/21 197/22
reviewed [1] 127/14
reviewing [1] 196/5
reviews [5] 23/25
46/7 57/5 60/22 60/23)
revved [1] 89/22
rewrite [5] 50/5 52/6
53/6 53/15 55/2
Rewrites [1] 52/6
rewriting [4] 50/13
51/9 52/21 53/15
RICHARD [13] 1/14
1/17 70/2 90/3 122/1
122/3 129/9 137/6
137/13 143/12 149/5
149/6 207/2
Richard's [1] 143/1
right [62] 5/9 5/23 6/6)
6/23 9/5 11/18 35/7
35/13 43/22 52/13
55/1 55/20 62/16
62/19 71/8 71/19 81/7,
82/19 85/16 88/12
94/22 95/5 96/19
122/25 123/7 125/11
129/20 132/24 139/10
141/2 151/16 151/20
151/21 154/11 155/22}
155/23 168/16 169/7
170/3 170/4 170/24
173/12 174/11 177/11
177/12 177/14 178/21
179/18 191/19 191/19}
195/12 200/2 200/12
200/17 201/2 201/8
201/12 201/22 202/19)
203/25 205/22 205/22
right-hand [1] 122/25)
rights [1] 197/22
rigid [1] 98/3
Rinkfield [2] 178/7
178/12
risk [14] 12/19 12/25
66/15 66/24 98/13
98/19 98/20 98/22
129/16 131/12 163/8
184/23 185/24 202/13}
risked [1] 84/12
risks [5] 66/10 66/13
98/8 185/25 185/25
RMG [2] 96/14 105/8
Roberts [2] 115/19
169/9
robur [1] 54/8
robust [14] 32/2
42/22 43/15 54/4 54/6)
54/11 54/20 54/22
168/21 188/9 188/10
188/10 188/19 194/14)
Roger [9] 30/8 94/22
96/3 105/6 127/8
142/20 143/10 143/19)
145/20
Roger's [2] 143/11
174/15
Roger/Duncan [1]
145/20
role [16] 7/24 9/20
17/23 55/16 88/24
100/13 114/17 122/2
131/25 143/2 155/9
187/11 192/1 192/3
198/14 199/20
roles [7] 3/24 4/1 4/5
4/13 7/14 93/23
194/18
roll [3] 90/3 126/19
126/20
rolled [3] 39/9 122/8
126/15
rollout [27] 21/4
21/14 21/19 32/11
39/1 39/11 67/16
114/11 118/2 118/12
121/19 124/8 124/16
124/22 124/23 125/1
125/12 125/12 125/25]
131/17 132/10 135/5
138/10 139/10 140/3
141/5 159/7
Rollover [1] 160/15
room [1] 84/17
root [1] 172/15
roughly [1] 6/2
round [4] 8/18 125/2
152/17 203/3
rounded [1] 173/14
Royal [11] 96/15
96/20 97/6 101/24
135/13 165/10 166/3
166/4 166/14 175/16
194/10
Rue [3] 6/18 6/23
11/9
rules [1] 46/17
rumoured [1] 103/12
run [8] 112/3 112/4
112/6 132/16 149/11
161/18 161/19 183/4
running [8] 12/20
29/11 102/18 102/22
132/23 136/23 183/2
189/25
(79) remote... - running
R
runs [1] 22/24
Russia [1] 17/20
Rye [1] 115/18
s
sabbatical [2] 31/3
31/4
safe [2] 154/20
187/17
safer [1] 53/11
said [39] 9/10 17/24
35/13 48/15 49/10
53/21 54/19 60/7
60/12 67/18 75/21
77/4 77/9 79/2 79/23
81/4 87/22 88/18 91/8
94/16 121/12 123/3
136/24 149/13 151/18}
152/11 155/21 158/9
170/2 180/6 183/13
183/24 184/2 186/21
187/24 191/8 193/6
201/17 202/20
sale [2] 38/18 43/11
same [30] 2/23 19/10
24/17 24/19 35/7
48/15 49/1 58/18
108/12 109/13 109/13}
117/3 130/5 137/24
139/13 139/13 153/3
158/16 159/15 159/16}
160/24 164/13 166/5
167/4 175/7 175/7
184/14 203/7 205/5
205/5
san [2] 143/3 143/8
sat [5] 8/9 12/5 59/22
98/23 125/23
satisfied [6] 13/9
13/18 32/11 84/18
181/4 194/13
satisfy [1] 56/25
save [1] 116/11
saving [1] 150/24
saw [17] 27/15 29/11
43/1 52/17 53/23 54/4
63/8 71/4 71/17 71/19
90/18 108/13 152/19
156/25 157/7 165/25
200/12
say [92] 1/8 7/19 8/21
8/25 9/8 11/13 12/18
15/12 18/6 19/5 20/9
22/4 22/7 22/19 23/3
23/25 24/12 25/4 27/1
27/14 28/6 30/7 32/22
33/8 33/20 36/4 36/25)
37/18 39/12 39/14
40/8 43/21 46/18
46/25 47/1 47/21
48/13 51/19 53/5
53/12 57/11 59/12
60/24 61/16 64/4
65/18 66/23 70/24
72/17 72/24 73/7
T4IN7 75/6 77/17 81/4
84/21 85/1 87/23
88/10 88/20 89/7 89/9)
91/7 98/3 99/12 99/23
100/23 102/12 112/18)
113/14 120/24 121/12)
127/9 128/11 133/14
134/23 136/4 136/22
138/19 150/10 154/1
154/3 174/1 174/5
176/25 180/3 180/22
188/10 193/18 193/22
195/11 203/25
saying [32] 13/25
29/20 32/12 41/6
47/18 50/25 59/4 59/5
59/18 59/19 66/21
67/5 70/13 77/8 78/23
81/7 87/20 87/22 89/3
90/21 109/15 131/21
132/18 152/23 156/15)
156/17 161/10 170/19)
185/13 204/7 204/9
204/17
says [90] 4/2 4/9
26/10 34/16 35/15
36/11 36/20 37/7 38/3
38/17 38/24 41/17
42/15 42/21 45/10
46/1 46/6 46/14 49/12
49/24 50/17 51/25
52/14 63/22 65/10
65/15 66/11 74/9 76/5)
79/11 102/13 102/21
103/21 104/18 105/4
107/9 108/20 108/20
110/1 110/9 110/22
111/5 116/20 119/10
119/18 120/2 120/16
121/22 122/9 124/4
125/15 130/2 130/3
130/14 132/4 132/12
133/4 135/7 138/4
138/7 141/14 143/16
143/22 144/6 144/20
144/25 150/21 152/3
154/13 154/18 159/19)
160/12 164/21 166/5
166/15 168/1 168/1
169/11 172/19 177/22)
179/22 184/16 187/9
192/14 194/12 194/24)
194/25 197/11 200/5
202/21
scale [1] 200/24
scenarios [3] 107/1
107/8 107/10
schedule [19] 2/21
2/23 24/18 33/19
34/18 35/23 36/15
36/16 36/19 36/25
38/20 41/5 41/13
41/18 49/2 73/14
73/20 75/22 138/15
schedules [5] 33/24
36/6 38/12 40/12 42/9
Science [1] 127/21
scientist [1] 18/17
scope [3] 42/13
115/23 134/9
scratch [1] 53/15
screen [4] 3/18 35/6
99/8 104/1
scroll [35] 72/23
96/10 99/22 104/15
105/3 106/15 108/17
109/10 109/24 115/15
120/15 122/25 129/22
137/18 137/24 142/18I
143/21 144/3 144/19
145/4 162/23 166/13
167/16 167/17 169/5
170/19 170/25 172/1
173/7 176/23 182/13
185/23 185/24 194/24
197/6
scrolling [1] 25/23
SDM [2] 161/4 161/5
second [26] 2/8 3/2
3/3 5/1 13/10 14/3
23/22 47/5 47/13
55/25 56/2 63/4 69/8
72/16 104/14 131/21
132/12 156/7 157/19
179/2 180/18 186/5
187/17 189/24 190/4
191/13
Secondly [2] 32/17
90/14
secretaries [3] 84/7
84/15 84/21
secretary [3] 4/7
84/22 85/17
section [11] 45/25
46/6 46/10 78/3 79/8
119/19 185/17 185/22
185/24 186/1 203/10
Section 69 [1] 78/3
section 7.3 [1] 46/10
sections [1] 120/20
sector [10] 94/5 94/9
94/17 95/21 96/14
97/2 97/3 110/13
155/9 161/19
secure [6] 65/8 65/12
65/17 147/18 187/17
196/22
securely [1] 196/25
security [17] 63/24
66/1 66/22 67/13 68/3)
68/5 68/8 75/2 77/14
77/14 80/7 80/7 81/17,
89/19 167/16 169/24
170/21
see [116] 1/5 3/20
4/5 5/16 6/6 7/6 14/10)
14/19 15/15 20/5
20/10 20/11 20/21
24/2 24/25 25/11
25/17 25/24 26/9
34/21 35/2 35/11
38/13 39/21 42/13
42/16 44/2 44/11 45/2)
46/5 46/10 49/5 49/8
49/17 49/23 50/23
63/8 63/10 65/12
72/21 73/14 74/7 74/8)
75/25 76/15 79/21
81/24 86/20 92/15
92/19 96/13 96/14
97/1 100/19 102/3
102/19 103/19 105/3
105/12 106/9 106/15
107/8 108/17 109/12
114/23 115/2 115/5
118/6 119/6 120/18
121/10 122/13 122/25}
123/12 128/22 129/23}
132/5 133/15 136/17
137/5 137/19 140/18
142/1 143/21 144/3
151/23 152/5 153/23
154/3 154/4 154/4
155/2 156/7 158/11
158/16 161/4 162/23
166/14 167/18 169/5
170/13 176/23 177/18}
182/25 184/5 185/18
186/4 188/8 188/22
189/16 195/21 196/13
197/6 201/17 202/20
202/24
seeing [8] 10/21
33/15 35/6 55/21 68/1
105/14 125/20 177/7
seek [1] 183/21
seem [1] 190/16
Seema [3] 146/21
155/12 174/10
seems [25] 62/20
75/16 96/11 100/24
105/1 109/12 109/17
117/7 118/16 119/9
126/13 136/14 136/20
139/6 139/18 148/9
148/12 154/25 160/17}
162/10 165/8 171/9
171/16 173/19 200/13}
seen [46] 44/8 45/8
46/19 46/20 47/9
52/23 53/2 63/3 63/6
63/9 64/20 66/23
68/14 69/10 70/10
86/8 89/9 89/11 89/15)
89/21 115/5 119/16
120/13 122/20 132/9
134/17 141/4 154/16
155/13 163/14 167/19
173/22 174/23 175/12
177/18 183/18 190/14I
190/17 190/21 191/7
191/16 192/6 192/8
196/9 196/11 197/8
segregation [1]
194/17
send [2] 111/16
141/24
sending [5] 110/1
138/5 145/15 177/1
183/8
sends [1] 121/21
senior [17] 16/8
28/12 29/3 46/2 82/12)
102/4 112/5 112/7
115/9 115/11 121/13
144/2 152/10 156/23
161/2 175/25 176/19
sense [12] 9/15
11/25 13/1 21/17
21/20 23/14 29/6
30/15 36/3 123/5
156/19 200/7
sensible [1] 187/3
sensitised [1] 130/10
sensitivities [1]
12115
sensitivity [1] 121/1
sent [24] 45/7 47/6
68/12 71/5 104/12
104/13 105/4 109/14
109/17 111/4 125/5
139/16 141/11 145/18)
148/19 158/12 168/18
169/6 170/3 175/6
178/3 190/13 191/14
194/8
sentence [10] 2/20
120/12 130/13 132/17)
158/13 166/11 168/7
180/18 180/21 188/11
sentenced [2] 166/12
166/13
separate [4] 10/6
10/8 12/1 23/9
separated [1] 97/1
Separately [1]
197/12
separating [1] 96/13
September [3] 44/13
45/3 158/25
Sequence [2] 117/3
1417/3
sequential [1] 196/24
series [1] 190/13
serious [13] 13/21
14/3 46/23 47/24 48/2I
55/7 59/8 68/24 77/2
113/25 145/12 157/8
186/18
seriously [3] 117/20
119/21 153/5
seriousness [1]
87/23
(80) runs - seriousness
Ss
server [1] 124/1
serves [1] 155/6
service [29] 21/5
39/8 39/8 39/10 41/14
41/19 42/14 42/24
66/16 69/21 75/1
76/22 77/20 84/18
85/5 116/24 117/13
122/14 125/17 139/4
141/22 161/6 170/21
172/23 180/1 180/20
187/20 195/4 201/3
services [44] 5/16
5/25 17/4 22/9 22/9
22/17 23/15 24/3 25/1
26/21 28/2 28/19
28/19 30/10 30/13
30/19 30/24 33/9
36/11 36/16 37/9
37/13 37/24 38/4 38/7
38/11 38/23 39/4
39/21 40/1 44/20 60/3
66/12 76/17 76/22
76/25 84/19 94/13
132/1 150/13 161/18
172/20 172/22 183/3
Services' [2] 76/8
81/25
Services/Pathway [1]
66/12
serving [1] 168/7
Session [1] 117/3
set [20] 5/6 6/11 10/9
14/14 14/15 19/24
24/1 31/16 33/16
33/16 34/18 36/19
42/25 76/6 107/8
139/2 176/7 176/22
190/7 196/15
sets [4] 42/13 146/1
188/2 194/12
setting [3] 15/3 37/15}
73/14
several [4] 106/25
114/13 135/21 156/20}
Sewell [3] 97/21
180/2 191/18
SFS [1] 63/22
shall [12] 34/19
36/13 37/12 39/3
41/19 42/22 43/20
74/12 82/1 92/12
92/13 172/20
share [1] 188/17
shared [6] 120/13
121/6 121/9 187/13
195/4 200/1
shareholder [4] 4/18
86/1 86/2 86/3
shareholders [2]
6/17 15/17
shareholding [1]
86/4
she [29] 87/2 101/23
102/13 102/19 102/21
103/19 103/21 110/4
110/16 111/5 123/4
123/5 155/16 167/16
167/17 168/1 179/23
180/3 180/3 180/6
180/7 180/8 181/6
she'd [1] 87/1
She's [1] 199/19
Shell [2] 65/9 65/17
shockingly [1] 88/14
shoes [1] 125/23
short [11] 30/5 30/9
43/25 89/18 92/17
103/4 103/23 124/6
128/21 140/16 179/11
shortcomings [1]
50/7
shorthand [1] 87/1
shorthand-writer [1]
87/1
shortly [7] 3/18 6/18
11/19 31/20 47/15
99/14 99/25
shots [1] 54/9
should [49] 1/8 1/21
2/20 11/13 14/20 20/9)
37/18 45/6 48/19
48/21 50/8 52/4 55/7
60/24 62/13 68/1
68/13 68/15 68/25
76/23 76/25 77/11
77/15 80/21 83/2 93/7
99/8 107/10 110/2
111/14 112/3 113/8
113/22 124/19 131/3
138/2 142/3 156/19
158/3 158/9 159/12
169/2 169/20 172/15
185/2 196/7 198/18
198/18 201/20
shouldn't [7] 18/5
48/20 59/19 60/25
77/13 91/7 113/22
show [4] 113/16
162/7 163/3 202/7
showed [7] 31/14
53/20 53/20 65/7
107/25 156/18 156/25)
showing [3] 27/12
162/5 175/8
shown [4] 117/21
119/22 120/7 187/17
shows [1] 196/8
shut [2] 26/18 89/7
sic [3] 35/5 44/16
168/7
side [4] 122/25
125/25 154/5 154/6
sidelined [1] 88/23
186/22 186/22 197/10,
197/12 197/14 199/20)
sides [2] 42/4 42/10
Sight [5] 186/5
187/17 189/24 190/4
191/13
sign [2] 46/12 66/4
in-off [1] 66/4
signature [5] 2/6
2/12 3/5 93/11 196/23
significance [1]
17/10
21/2 45/22 52/8 52/20
62/8 66/19 95/18 97/6
97/12 118/15 118/25
124/5 124/22 126/17
151/24 163/8 183/22
184/18 186/16 202/13
significantly [2]
120/11 125/13
signing [1] 40/25
similar [4] 126/1
142/17 151/1 160/10
Simon [3] 181/9
181/9 181/10
simple [2] 94/7
103/15
simply [6] 64/10
64/13 158/4 171/23
175/1 200/5
since [8] 5/4 50/2
53/13 73/3 133/5
134/15 159/25 178/3
Sinclair [6] 109/25
110/11 110/11 110/12
111/4 113/3
Singapore [1] 31/4
single [4] 4/17 13/5
13/6 22/16
sir [21] 1/3 1/7 20/9
43/18 44/2 62/24
82/25 86/19 87/5 87/9
92/1 92/4 92/14 92/19
92/21 140/7 140/18
191/16 205/17 205/21
205/24
sit [4] 1/11 4/10 8/18
58/15
sites [1] 124/2
situation [10] 111/8
111/22 112/16 113/9
113/10 113/11 113/23
113/23 113/24 113/25)
six [2] 134/7 182/11
size [1] 13/3
skill [1] 132/19
skills [2] 132/22
135/20
slightly [11] 15/6
17/2 20/7 34/24 72/23
108/12 119/5 123/1
137/25 194/25 203/3
Slough [1] 176/16
small [7] 17/19 97/1
108/16 147/13 156/1
significant [21] 13/24I
157/2 190/15
smaller [2] 95/24
145/10
smart [1] 68/7
Smith [15] 70/1
70/17 104/2 104/12
104/13 108/21 121/23}
124/13 124/25 125/4
126/2 127/15 129/7
137/5 137/15
so [262]
software [16] 53/3
53/5 57/20 58/2 68/4
128/5 136/25 144/13
144/18 172/12 184/7
200/4 200/9 200/18
200/25 201/4
Solaglas [1] 4/6
solicitor [5] 3/21 4/2
4/3 58/8 80/25
solicitors [1] 40/15
solution [9] 67/22
120/22 162/25 163/1
163/11 201/15 201/19}
202/6 202/16
solutions [10] 36/15
36/21 36/25 37/5 50/4
73/21 162/23 201/18
202/5 202/22
solved [1] 69/2
some [69] 3/12 5/4
8/3 11/8 11/10 17/22
18/10 27/11 36/6 44/6)
46/11 52/23 53/5
54/18 63/7 67/5 68/3
69/22 70/1 71/5 77/3
80/8 80/10 96/7 96/8
97/7 97/21 99/17
103/11 105/14 107/22}
108/1 108/16 110/4
110/5 110/6 115/1
125/20 126/25 127/17
128/20 128/24 129/7
129/16 132/9 135/11
137/9 139/8 143/2
144/16 145/17 146/13
150/15 151/12 152/5
153/23 155/2 158/15
161/8 170/22 171/23
172/5 172/9 179/23
188/2 188/14 188/17
196/7 205/5
somebody [10] 65/16
67/2 71/24 78/23
89/10 104/4 104/7
105/18 123/3 174/12
someone [6] 40/23
41/22 62/13 123/10
156/11 199/19
something [42]
18/21 20/12 39/9
39/23 48/6 48/18
50/21 50/23 54/9
58/22 58/23 62/21
67/25 76/24 78/13
79/1 80/17 80/20
85/12 101/25 105/25
108/5 108/14 109/8
109/20 111/24 112/2
113/5 113/6 114/4
136/1 143/25 160/21
171/16 177/17 181/1
181/2 182/1 185/1
185/3 188/18 192/11
Sometime [1] 200/22
somewhat [3] 135/8
136/20 167/22
sophisticated [1]
68/10
sorry [43] 2/15 3/3
6/6 6/21 8/13 8/15
10/18 12/17 16/8 18/5)
23/22 28/25 31/8 34/8
34/22 34/24 34/24
35/1 35/4 35/5 40/13
43/6 45/7 50/17 55/20;
58/20 66/10 66/11
67/11 73/25 78/5
80/14 81/6 86/3 86/12)
87/6 91/7 91/13 95/20
135/5 156/8 178/23
191/20
sort [7] 6/24 21/12
22/9 28/11 30/6 139/8
156/2
sorts [3] 78/25
130/15 134/1
Sotto [1] 74/2
sought [1] 169/19
sounds [1] 187/24
source [1] 133/6
South [3] 154/17
155/11 168/12
span [1] 124/6
Sparrow [1] 192/12
speaking [3] 10/20
78/24 121/15
speaks [1] 197/12
specialists [1] 67/1
specific [12] 16/2
20/1 28/9 44/6 50/4
60/10 62/21 63/1
100/14 105/22 117/4
160/4
specifically [3] 73/1
88/2 194/16
specification [16]
33/6 33/8 33/9 33/11
33/12 33/15 33/17
37/24 38/14 39/18
39/22 41/24 43/12
43/13 63/24 88/3
specifications [2]
36/21 80/6
specified [4] 36/14
36/15 36/22 36/25
spent [3] 31/2 85/14
104/10
(81) server - spent
s
spirits [1] 127/11
split [4] 181/18
spoke [4] 104/16
108/21 127/10 179/20
spoken [3] 98/4
135/20 196/3
spokesperson [1]
168/19
spot [1] 185/4
spotted [2] 117/15
157/20
springs [1] 11/4
Square [5] 177/24
177/25 178/6 178/11
178/14
SSH [1] 65/9
stability [5] 69/17
69/18 127/25 128/14
130/10
stable [3] 152/4
184/3 187/15
stack [2] 45/12 51/17
staff [2] 202/25
204/22
staff's [1] 204/24
staffing [1] 135/19
stage [33] 8/2 8/8
8/12 8/16 17/20 26/9
27/8 27/14 28/21
28/25 29/8 30/25
54/19 62/4 67/15
71/12 109/14 110/18
130/18 131/2 133/19
134/5 148/23 149/2
150/4 151/3 151/16
154/1 154/10 169/23
170/5 173/25 181/3
stages [1] 10/11
stamped [1] 196/24
stance [2] 126/5
146/6
stand [3] 3/11 54/1
89/20
standard [6] 34/13
34/21 35/2 35/19
59/10 182/2
standards [1] 32/19
standing [3] 86/7
98/16 131/23
stands [2] 136/2
161/6
Stares [2] 16/19 49/6
start [19] 39/9 45/16
49/17 53/14 60/5 74/7)
95/25 99/10 101/19
101/21 101/22 108/9
119/4 127/6 127/7
133/1 158/17 174/22
196/11
started [9] 6/16
81/15 90/3 91/15
91/19 93/19 100/9
121/24 126/2
starting [1] 92/24
starts [3] 131/19
131/21 133/3
state [2] 1/16 52/22
stated [9] 72/18
122/18 147/17 168/15)
168/19 168/25 182/21
184/1 198/1
statement [68] 1/23
2/9 3/1 3/2 3/3 3/15
3/16 3/17 3/19 5/1
7/19 11/13 13/11 14/4)
19/5 19/16 21/25
23/21 23/22 25/4
31/23 56/2 56/12 63/4
72/16 72/18 73/5 75/6)
75/21 77/4 78/10
78/14 78/19 79/5
79/20 79/24 93/8
93/13 93/16 94/16
99/6 99/11 106/22
110/3 118/23 123/4
133/13 148/2 148/16
148/18 149/11 149/13)
150/9 151/18 152/13
155/21 174/24 176/25)
181/25 182/1 182/2
182/3 183/10 183/11
193/13 194/21 195/11
199/16
statements [12] 1/20
3/7 3/10 52/24 76/17
77/13 78/8 81/8 82/23)
92/9 92/9 182/4
station [1] 168/4
statutory [3] 98/11
98/14 98/24
stay [2] 66/11 174/18
STC [3] 4/6 4/10
40/15
steady [1] 146/8
Stein [6] 199/3 199/5
200/12 201/10 204/14;
207/12
step [2] 53/14 153/14
Stephen [3] 154/12
155/5 155/10
steps [5] 56/18 133/7'
162/6 180/14 192/24
Steve [1] 143/11
STEVENS [6] 1/15
82/9 83/1 88/15 92/3
207/4
Stewart [1] 161/4
sticking [3] 164/19
177/15 182/13
still [17] 21/5 28/20
29/6 44/2 83/12 89/14
97/24 114/8 121/18
141/8 154/9 164/13
165/8 165/24 167/7
177/20 197/19
stock [2] 22/23
103/15
stop [3] 31/8 58/19
126/22
stopped [1] 11/10
stored [2] 116/18
196/25
stories [2] 110/6
146/9
story [3] 143/21
188/14 188/16
straight [2] 94/2
199/7
straightforward [1]
21/20
strange [1] 170/15
strategic [1] 176/11
strategy [5] 112/3
112/16 113/4 113/21
187/12
stream [1] 146/8
strengthened [1]
194/20
stress [1] 82/14
stressful [1] 84/2
strong [4] 54/9
113/15 125/16 152/7
strongly [2] 89/8
136/1
structural [1] 116/5
structure [5] 5/5 8/10)
10/7 10/8 26/7
structured [1] 161/12)
structures [2] 56/21
56/23
struggle [1] 182/17
Stuart [3] 41/9 68/20
115/18
stuff [2] 58/12 183/6
SU [1] 160/15
subcontracts [1]
11/11
subject [9] 36/13
37/12 38/25 39/2 76/6
79/11 102/20 103/13
148/8
subjective [1] 32/6
submarine [1]
203/13
submitted [2] 106/19
176/6
submitting [1] 76/1
subpostmaster [7]
89/17 102/15 125/24
180/6 186/10 202/23
203/15
subpostmaster's [1]
103/5
subpostmaster/mistr
ess [1] 203/15
subpostmasters [41]
15/23 72/10 86/10
91/3 99/17 100/2
102/25 103/6 103/9
105/19 105/23 126/6
126/15 139/2 139/4
139/9 139/15 140/2
140/5 140/24 141/18
144/8 144/12 144/14
144/17 144/22 145/2
147/20 149/19 150/5
150/20 151/6 158/1
168/9 174/7 177/10
182/19 182/23 186/19)
191/2 203/6
subpostmasters'’ [4]
99/13 99/24 105/10
193/16
subpostmasters/mistI
resses [1] 168/9
subpostmistress [1]
168/6
subsequent [2]
4117/1 131/18
subsequently [3]
88/21 89/24 97/16
subsidiary [5] 5/20
6/14 6/21 7/8 29/9
substance [4] 42/9
108/12 114/5 183/22
substantially [1]
116/6
success [2] 64/13
175/17
success/fail [1]
64/13
successful [6] 122/7
131/17 131/25 138/11
155/8 166/20
successfully [1]
195/18
such [13] 19/16
64/14 64/15 64/23
68/24 81/2 83/2 91/5
112/22 138/21 139/1
178/11 200/24
suffering [1] 123/15
sufficient [1] 103/4
sufficiently [2] 89/8
161/2
suggest [5] 120/5
130/6 137/8 156/9
181/23
suggested [1]
197/12
suggesting [2]
165/25 182/1
suggestion [5]
138/23 171/2 186/9
188/15 197/13
suggests [1] 154/21
summarise [3] 105/8
140/21 200/3
summarised [1]
103/16
summary [10]
102/14 102/21 104/19)
106/8 145/22 159/17
176/21 182/13 196/15}
196/16
summer [2] 141/9
185/5
supplied [1] 43/13
supplier [2] 111/10
153/2
Supply [1] 36/11
support [24] 65/22
65/25 66/6 66/25
72/11 75/25 83/9
89/15 89/20 90/6
103/1 103/11 106/21
116/7 146/11 146/13
151/12 151/13 151/16)
159/16 175/25 177/13)
191/11 191/22
supporter [1] 125/16
supporting [1] 111/2
supportive [1]
137/14
supports [1] 115/21
suppose [8] 8/16
9/16 10/11 26/15 38/2I
40/20 53/20 61/6
supposed [3] 33/17
37/16 101/14
sure [21] 13/3 44/21
66/25 69/23 78/12
80/22 101/11 109/21
130/5 137/21 142/24
150/6 150/12 153/2
153/10 155/1 164/5
188/12 195/8 195/23
196/9
Surely [1] 173/1
surfaced [7] 13/5
13/6 57/8 60/21 68/14I
154/20 156/9
surge [1] 123/15
surprise [4] 121/4
130/4 135/8 136/15
surprised [1] 203/4
surprises [1] 80/17
surprising [1] 170/9
Surrey [1] 168/4
surrounding [2] 42/2
102/24
Susan [1] 192/19
suspect [1] 81/16
suspense [1] 160/3
sustainable [2] 69/24
128/21
Suzie [12] 101/23
105/8 107/25 108/11
110/8 110/10 111/2
4111/5 111/7 113/5
152/6 199/18
Sweetman [2] 41/9
68/20
switch [1] 116/2
switched [1] 25/6
sworn [4] 1/14 93/2
207/2 207/8
sympathise [1]
(82) spirits - sympathise
s
sympathise... [1]
138/23
syne [3] 111/1
162/15 203/19
system [104] 7/22
7/25 12/8 13/9 14/2
14/4 14/22 16/17
19/18 24/22 26/8 28/2)
31/12 32/2 32/8 32/8
33/12 33/17 34/6
36/16 37/8 37/13
38/18 39/2 39/3 49/3
54/2 54/11 54/20
54/23 59/18 67/2 67/3
67/8 68/10 78/25
85/22 86/18 87/14
87/18 91/5 102/24
104/23 105/2 108/3
116/5 116/8 117/5
117/22 117/24 119/23)
119/25 120/8 120/10
126/11 141/14 141/19
144/18 145/8 146/12
147/5 147/18 147/21
149/16 150/11 150/16
151/2 152/25 153/2
153/10 154/21 155/19}
155/25 156/10 162/18
163/10 165/22 168/11
168/15 168/20 169/15}
169/18 170/7 180/5
181/13 182/16 182/19
182/22 188/1 188/4
188/5 188/10 188/21
189/19 190/10 192/17)
194/14 194/17 199/24}
200/6 201/2 202/15
203/22 204/10
system's [2] 144/24
150/1
systems [27] 14/15
14/15 15/3 21/1 64/10)
66/8 66/8 66/22 67/8
67/13 80/6 93/20
145/25 146/15 150/18}
158/8 159/14 162/15
179/23 186/14 187/22)
193/18 193/21 196/21
200/20 200/24 203/19)
T
table [2] 8/18 122/12
tail [1] 152/24
Tait [23] 29/18 29/19
30/16 30/23 31/11
69/9 69/11 70/13
92/22 93/2 93/6 93/7
140/21 179/14 191/13}
197/13 198/25 199/6
204/13 205/2 205/9
205/13 207/8
take [49] 24/5 43/14
43/18 56/13 56/18
56/18 83/20 89/2
90/23 92/12 99/10
100/21 104/23 106/5
116/20 121/18 126/4
127/5 130/22 130/22
140/7 140/11 145/17
145/18 149/22 153/5
153/14 154/15 156/22)
158/15 168/10 175/6
175/16 175/24 179/4
180/14 180/22 182/11
185/9 188/1 189/4
192/10 193/24 194/6
194/22 198/5 199/6
200/17 204/19
taken [18] 3/7 24/20
47/23 84/8 88/15
101/2 108/23 129/17
133/7 134/25 135/15
139/18 148/10 149/24)
149/25 159/7 162/1
180/15
takes [4] 39/11
124/15 146/6 173/14
taking [6] 100/12
137/16 187/20 188/24)
195/14 196/8
talk [11] 56/1 57/3
57/11 58/20 70/11
70/22 71/15 79/22
132/2 137/9 154/22
talked [3] 56/9 57/13
60/11
talking [16] 15/5
15/24 16/18 23/24
25/18 36/7 48/2 48/25
57/22 60/14 68/20
80/6 81/17 85/24
103/10 128/9
talks [4] 47/14 69/15
85/3 190/3
tamper [4] 89/16
90/7 90/13 91/17
tampered [2] 80/7
91/24
target [1] 45/20
targets [1] 45/14
task [2] 44/12 188/12
tasked [1] 195/11
Taskforce [5] 44/10
45/13 45/21 46/2 50/2
taught [1] 39/19
te [1] 58/21
team [39] 40/17
40/21 41/8 45/12
45/15 52/5 52/14 53/8)
56/15 56/19 56/24
57/20 58/4 59/24
62/11 62/12 90/6
100/5 110/25 113/25
121/12 123/9 123/11
126/3 142/4 143/19
169/17 171/7 173/4
174/12 176/15 179/17
180/3 181/24 187/24
191/17 192/15 192/20
196/2
Team' [1] 124/18
teams [7] 7/25 89/16
89/21 123/19 181/23
184/21 189/7
technical [40] 14/7
39/15 40/3 40/18 41/1
41/8 42/3 42/5 42/10
47/3 47/4 48/6 48/21
48/22 53/9 53/19
53/22 54/14 54/17
54/21 54/24 55/10
68/2 68/9 69/3 88/20
102/17 106/23 111/12
121/11 125/14 140/5
142/14 150/25 153/18
161/13 161/17 161/21
200/7 200/14
technically [3] 18/18
28/5 46/25
technician [1] 18/15
technicians [1] 67/18)
technique [2] 64/14
64/23
technology [1]
182/23
Telecommunications
[2] 4/6 32/3
tell [15] 35/4 48/3
54/21 54/21 58/19
60/22 70/21 71/16
81/15 89/13 126/4
156/21 187/25 204/11
204/23
telling [3] 48/12
113/24 202/23
temochi [1] 58/21
ten [5] 86/23 87/3
87/6 140/10 199/3
tend [1] 35/16
tender [3] 6/12 7/22
37/4
tendered [1] 6/8
tendering [3] 7/24
74/18 74/21
tends [1] 31/2
tense [3] 124/12
125/9 139/23
tension [1] 193/4
tensions [3] 126/13
126/17 141/5
tenuous [1] 29/7
tenure [1] 60/14
term [5] 4/17 32/5
32/6 90/14 128/22
termination [1] 27/2
terms [36] 12/7 15/11
16/15 26/5 34/18 35/2
35/16 40/7 40/9 41/4
43/8 47/12 54/2 54/4
59/22 84/17 94/7
96/21 97/7 98/11
102/10 112/15 113/21
113/21 115/16 118/1
123/1 131/6 131/7
134/9 135/22 135/25
142/7 153/12 158/23
160/25
Terry [1] 44/20
test [8] 8/24 21/17
32/15 70/5 89/20
129/11 146/20 168/12)
testify [1] 146/14
testimony [1] 90/1
testing [4] 20/18
52/11 132/19 168/21
tests [3] 32/9 33/14
88/3
than [27] 18/15 18/18
18/19 21/16 21/19
28/6 52/6 62/5 62/17
62/22 66/3 81/16
86/17 96/24 115/3
117/23 119/23 120/8
130/8 137/6 147/7
150/17 158/10 160/6
170/3 185/15 200/16
thank [87] 1/7 1/18
1/19 1/25 2/25 3/3
3/10 7/6 20/7 27/24
34/9 36/9 37/10 42/20
43/22 43/23 44/4 44/5)
62/24 72/7 72/23
73/20 76/15 82/8 83/5)
86/22 87/9 91/25 92/2)
92/8 92/20 93/4 93/13
93/16 94/20 95/1
95/18 95/25 96/10
97/14 98/6 98/16 99/3
99/6 99/9 99/22 100/5I
101/9 104/15 106/15
107/8 108/9 110/14
110/18 114/7 116/13
121/20 127/5 127/7
127/23 133/2 133/3
134/19 137/19 140/14}
140/18 140/19 142/19
143/16 144/3 155/11
161/7 169/11 179/13
188/24 191/19 196/10
198/25 198/25 199/2
199/4 199/8 205/9
205/10 205/13 205/17
205/24
Thanks [1] 34/11
that [980]
that's [141] 2/17 2/22
3/15 4/8 5/11 5/24
6/13 7/10 7/13 7/23
8/4 8/25 11/21 13/25
15/5 15/10 17/6 17/9
17/11 17/12 18/16
20/4 20/12 20/12 21/1
21/11 22/14 22/18
24/7 24/9 25/13 27/18
27/22 28/15 28/21
29/15 30/24 31/17
31/18 31/21 33/14
34/13 36/7 43/18
46/11 47/18 48/2 48/7)
48/10 48/23 50/19
53/23 53/24 54/17
55/8 55/12 55/15
55/24 56/11 57/6
57/23 59/11 59/14
61/16 62/3 63/8 64/22)
65/19 66/22 67/17
68/12 70/20 70/24
73/8 73/9 74/4 75/11
T7N7 77/20 77/23
78/1 79/8 79/10 84/3
85/16 86/14 86/23
87/7 87/24 88/9 88/11
89/5 89/9 89/13 90/13
90/17 91/17 92/4 92/5
93/9 94/23 95/5
104/17 106/6 106/7
106/7 110/11 114/21
120/2 123/2 123/7
124/18 125/11 129/9
129/21 132/25 135/4
140/7 141/3 141/7
145/3 146/21 148/4
154/11 157/3 158/13
164/8 165/11 172/12
175/7 175/20 179/9
182/10 186/12 188/22)
190/13 194/8 196/16
200/22 204/11 205/21
theft [1] 168/8
their [28] 10/10 17/20)
23/15 50/3 53/4 55/24
58/15 69/16 81/18
103/11 111/19 112/6
126/7 126/10 128/13
130/9 131/15 141/20
144/14 147/15 149/13}
153/2 153/5 159/23
165/21 173/1 176/22
203/6
them [53] 3/13 3/14
9/14 9/17 11/11 15/4
17/15 34/19 38/3
40/16 40/22 44/17
47/19 53/5 53/24 56/5
58/4 60/1 62/16 67/4
68/11 79/2 79/22
80/10 83/21 84/1
84/15 84/17 85/18
85/19 85/24 110/5
111/16 111/19 112/5
1414/2 114/15 122/21
131/9 132/15 141/20
142/1 152/22 163/23
170/18 171/6 173/18
180/8 190/21 191/8
191/18 195/5 204/11
theme [1] 131/10
themselves [1] 129/5I
(83) sympathise... - themselves
T
then [121] 2/8 4/6
6/20 7/14 11/6 11/12
14/2 15/11 15/20
16/21 16/23 17/4
17/18 20/18 21/18
22/12 23/21 26/20
27/6 27/8 27/22 28/1
30/9 31/6 33/1 37/7
38/1 38/22 41/2 42/13
42/24 45/3 45/25 46/9
49/18 50/6 51/10
51/21 51/24 55/16
58/19 60/6 62/1 63/1
65/4 67/23 67/25
68/18 69/22 69/25
70/13 72/15 76/15
86/25 87/3 87/6 89/11
90/2 92/15 94/5 94/12
95/2 95/23 97/16
97/19 97/20 98/13
103/19 104/3 109/22
110/8 114/1 114/3
114/5 122/9 122/10
123/15 124/19 125/13)
125/15 130/12 131/6
131/14 132/2 133/1
134/16 136/12 141/4
145/3 145/16 149/5
152/8 155/17 157/6
157/19 160/2 161/12
162/9 171/19 172/13
172/19 174/15 176/21
178/6 179/23 180/3
181/5 181/10 181/19
184/4 184/17 185/25
188/2 189/4 194/21
196/3 198/2 201/19
203/25 205/13 205/23,
there [230]
there'd [1] 157/12
there's [31] 2/12 5/19
21/20 22/11 42/11
45/25 47/5 51/10 53/1
54/6 58/9 79/17 99/7
108/19 113/13 120/16}
122/16 123/22 127/8
152/20 173/7 175/14
17716 177/9 181/12
184/14 185/10 185/22)
185/24 197/6 204/10
thereafter [1] 3/23
therefore [3] 114/4
135/16 189/9
these [56] 14/23
24/25 30/22 32/10
34/14 39/5 39/7 40/14
42/9 43/14 45/23
46/23 47/9 48/14 50/8)
56/6 57/17 61/5 70/14
71/21 73/21 80/5
83/20 84/11 88/8
90/16 99/16 99/18
102/3 103/9 107/10
107/41 112/4 121/2
121/5 124/10 124/19
125/13 135/12 135/23
136/8 142/1 147/23
152/9 154/23 160/15
169/3 172/10 175/8
17/1 178/19 180/7
184/4 184/24 190/6
190/19
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10/10 11/9 13/6 13/18
13/25 14/2 14/3 14/7
17/9 17/12 17/14
24/17 21/18 23/6 23/7
23/17 31/3 38/1 39/17
39/17 39/25 41/1 41/1
41/7 41/8 42/6 42/11
51/19 53/3 53/7 53/7
53/12 53/23 55/1
56/20 57/2 58/2 58/20
59/9 60/24 60/25 61/7
61/19 62/14 62/17
63/19 63/23 67/13
70/5 71/15 80/5 80/6
84/18 85/10 91/11
91/17 91/22 98/17
103/8 109/23 112/24
114/14 114/2 115/13
120/21 121/14 122/18
122/20 123/20 126/22I
127/16 127/19 128/4
128/5 128/22 129/11
130/6 130/6 130/10
134/23 136/14 137/4
141/15 141/24 142/1
142/23 142/23 143/4
143/5 143/10 146/6
147/11 147/14 147/15)
147/17 147/18 147/20
147/24 148/2 148/7
148/7 150/10 157/6
157/17 159/15 159/24)
160/16 161/8 161/14
161/18 161/23 161/24)
162/14 163/6 163/6
168/16 169/19 169/20)
170/13 173/4 174/9
181/5 188/9 188/10
190/20 190/21 196/3
200/25 201/1 202/11
202/11 203/18
they'd [3] 53/20
53/20 187/2
they're [8] 40/14 48/2
49/6 53/9 81/11 97/5
112/19 165/22
thick [1] 58/25
thing [17] 12/4 26/25
48/16 53/11 58/18
68/6 68/19 89/5
106/11 128/10 130/5
131/13 131/16 134/11
173/12 184/14 187/3
things [26] 14/5 15/5
17/4 20/17 35/3 41/10
48/14 56/6 58/22
68/10 70/23 77/3
78/25 96/7 105/14
109/4 123/16 130/5
134/6 136/11 139/19
153/6 175/8 175/18
189/14 200/5
think [179] 5/5 6/18
6/23 8/8 8/23 8/25
9/10 10/20 11/4 11/6
12/12 13/25 15/2
15/22 21/11 21/16
21/18 22/12 22/22
24/2 26/25 27/25 28/3
29/4 29/13 29/19
29/20 29/20 29/22
29/23 30/5 32/5 38/22
39/7 40/14 41/12
42/19 42/19 43/10
44/19 48/4 48/7 48/8
48/14 48/15 48/23
48/25 49/10 49/21
52/24 53/24 54/8
54/17 54/19 55/15
63/4 63/5 66/21 69/2
70/16 73/24 74/1 7/2
77/2 T7I6 7719 77/11
77/23 78/20 79/4
79/10 79/22 80/4
80/20 81/7 81/9 83/1
83/10 86/11 86/14
86/23 87/7 88/10 89/6
91/2 92/12 94/2 94/12
94/16 95/3 97/8 97/21
98/14 99/5 100/14
100/15 100/18 101/16
101/18 106/13 107/6
108/7 108/13 108/13
109/6 110/12 110/25
113/9 114/21 115/5
115/14 123/3 124/10
124/18 125/5 125/11
126/17 129/2 129/9
129/25 130/3 130/21
131/5 131/12 134/11
134/25 136/17 139/25I
140/7 140/22 141/3
142/25 143/6 151/18
151/24 152/11 155/20
156/6 156/18 161/10
161/14 164/3 165/2
166/25 167/19 167/22
167/25 169/7 169/8
169/10 170/2 170/12
172/11 172/16 173/4
173/9 176/25 179/17
180/18 180/21 182/3
184/9 185/17 188/6
188/8 189/15 189/19
190/20 191/3 191/18
193/6 195/11 201/8
201/10 203/9 205/1
205/3 205/8 205/19
thinking [1] 29/4
third [10] 22/12
65/21 66/6 66/25
117/4 133/16 133/22
134/8 160/8 179/21
this [439]
Thomas [6] 166/18
167/13 167/14 168/1
169/24 174/8
Thompson [3] 97/10
157/9 157/22
thorough [2] 89/23
137/9
those [92] 1/20 3/7
3/10 4/1 8/20 11/1
11/16 13/21 13/23
14/5 14/10 14/15
14/18 18/1 18/16
18/21 22/11 22/14
25/16 26/13 29/23
32/18 36/21 40/19
41/14 44/16 54/4
55/25 57/7 63/17
63/20 71/10 72/11
80/22 84/23 85/12
86/19 87/19 89/4 89/6
91/19 92/1 94/13
95/12 97/9 97/13
98/14 98/15 98/17
98/21 98/23 99/4
99/20 107/1 108/15
113/19 115/8 118/18
124/7 129/16 129/18
132/23 139/8 140/25
146/10 148/14 153/6
153/19 157/16 161/7
161/18 161/19 166/18
167/20 175/11 177/11
179/8 183/22 184/5
184/6 185/12 186/3
189/14 189/16 189/19)
189/19 190/8 191/1
191/9 198/25 201/3
201/5
though [15] 100/24
109/13 109/17 112/20}
117/7 124/25 126/13
126/21 139/6 139/18
160/17 161/9 171/9
173/3 196/9
thought [10] 8/23
9/10 17/12 18/14 57/8
61/7 61/7 78/12 89/6
175/22
thoughts [1] 125/6
threat [2] 126/21
128/11
threatening [1]
108/24
three [11] 22/5 22/7
22/14 23/9 94/12
133/4 157/15 160/2
161/19 179/8 201/18
through [28] 1/11
14/21 14/22 21/17
45/6 52/11 56/1 58/13)
59/9 59/15 83/14
83/15 89/24 107/12
145/18 147/22 149/4
153/17 153/17 154/22)
158/6 158/7 162/2
176/15 181/2 187/25
195/5 200/10
throughout [1] 35/16
throw [2] 130/15
134/1
Thursday [4] 109/1
122/7 164/25 188/25
thus [2] 105/12
131/24
ticket [1] 52/12
time [132] 4/21 5/4
11/10 12/8 13/7 16/12)
16/25 17/7 18/10 20/3)
21/12 21/14 23/9
26/13 30/1 30/1 30/9
30/17 40/15 43/18
43/20 47/20 48/5 49/8)
57/21 60/9 60/12 62/8
63/10 64/5 67/12
69/10 70/18 71/5
72/13 73/2 73/10
73/11 75/12 75/18
75/20 78/9 81/1 81/4
81/6 83/12 85/14 87/7I
88/21 89/1 89/23 90/5I
90/15 92/13 94/21
95/2 95/6 95/18 96/4
96/6 97/12 97/22
97/24 99/15 100/15
100/16 102/23 103/3
105/17 107/16 111/25)
115/14 116/22 121/7
121/22 124/6 124/24
4125/2 125/6 125/10
126/8 130/13 131/12
134/7 134/10 134/11
135/2 137/9 137/24
137/25 139/22 139/24I
140/7 142/10 142/11
142/13 142/18 145/17)
149/7 153/4 155/16
157/8 158/4 158/6
158/11 158/16 158/17)
159/7 160/21 164/13
165/3 166/4 167/23
169/8 171/14 173/9
177/16 177/18 178/1
179/3 179/15 180/9
180/10 184/23 186/21
188/1 188/24 189/25
190/22 193/2 196/5
196/24
time-ish [1] 134/7
timeline [5] 28/10
61/11 103/17 103/19
109/4
(84) then - timeline
T
times [5] 24/6 53/2
60/10 155/4 199/19
times’ [1] 168/21
timing [2] 175/22
197/15
title [3] 4/12 29/22
44/9
Tivoli [1] 64/2
today [16] 1/19 11/17
73/8 86/8 92/25 96/8
104/20 121/24 126/2
133/14 138/6 147/11
153/25 183/10 183/13)
191/7
today's [2] 7/1
150/13
Todd [6] 8/8 8/9 8/11
10/15 61/19 61/24
Todd's [1] 62/1
together [12] 3/8
12/3 19/2 85/10
104/25 137/9 144/8
151/5 153/6 166/18
177/4 190/16
Tokyo [12] 16/7
22/22 30/2 30/3 58/14
58/18 59/13 70/18
143/20 143/22 143/24}
151/23
told [8] 56/21 57/20
91/6 91/12 109/5
135/22 136/8 188/16
tomorrow [2] 141/25
205/18
too [11] 14/7 14/7
15/10 31/1 48/8 58/20
84/12 103/3 110/5
110/25 111/9
took [15] 25/6 31/4
62/11 62/12 62/14
78/16 79/6 95/2
108/18 112/21 114/23)
120/2 135/9 141/1
164/18
tool [2] 64/2 64/9
tools [2] 64/7 129/5
top [9] 5/12 44/11
98/20 105/3 106/10
109/16 109/23 129/23}
182/25
top-down [1] 98/20
topic [8] 31/22 62/22
83/18 84/9 85/23
105/23 106/2 147/16
topics [2] 28/9
191/11
total [1] 166/8
totally [3] 159/15
181/14 182/5
towards [1] 126/5
TPA [3] 51/3 51/7
51/11
track [1] 127/25
trade [4] 85/8 151/9
156/1 157/23
trading [2] 163/6
202/11
tradition [1] 24/23
trails [1] 103/3
train [3] 179/20 181/5I
190/7
training [1] 84/16
transaction [6]
115/17 116/25 117/5
117/6 179/24 180/25
transactional [1]
116/18
transactions [11]
76/5 76/13 79/13
79/14 91/16 91/18
115/22 115/25 117/2
146/5 196/21
transient [1] 116/1
transparency [1]
132/11
travelling [1] 168/5
tremendous [1]
134/17
trepidation [1] 8/25
Trial [1] 166/9
tried [4] 80/10
trigger [1] 180/16
triggered [1] 164/9
troubles [1] 133/7
true [12] 3/8 54/17
78/1 93/13 93/21
93/24 94/23 141/7
151/17 161/25 167/2
185/13
trust [1] 55/25
trusted [1] 124/25
truth [2] 90/4 91/21
try [2] 131/9 203/3
trying [6] 29/4 68/5
103/10 103/13 112/19)
134/21
Tuesday [1] 45/15
turn [54] 1/20 2/3 2/8
2/12 3/1 7/14 7/18
11/12 23/21 34/7 42/7)
45/1 46/9 49/12 49/23
51/21 73/13 73/17
75/23 81/21 86/20
93/10 96/1 99/6 99/8
101/20 106/17 107/20}
114/22 119/4 121/17
135/6 137/18 141/8
142/17 154/8 160/23
164/14 165/7 165/24
167/3 167/12 177/15
178/22 181/7 182/12
185/5 185/21 187/7
190/11 192/5 193/13
193/24 200/6
turnaround [1] 18/20
turns [1] 56/6
twice [2] 103/1
187/20
two [48] 1/19 4/5
6/16 6/19 22/11 30/19
38/3 42/19 53/13
58/22 82/13 90/12
92/8 92/25 94/12
98/15 99/10 103/20
110/21 117/2 119/14
120/18 122/14 123/22
124/3 127/13 129/18
131/11 134/6 152/25
153/6 154/3 157/10
159/14 161/14 161/19]
175/12 175/24 176/19
188/19 191/11 192/11
193/25 201/20 202/2
204/7 204/12 204/21
two pages [1] 42/19
two years [1] 53/13
type [8] 21/8 48/18
64/21 64/25 108/1
143/2 146/5 177/7
types [1] 43/14
typical [1] 21/8
typically [2] 98/23
143/22
U
UK [19] 4/6 5/23 7/12
22/13 23/4 83/23
94/10 95/1 95/6 95/7
95/22 97/19 110/17
143/5 146/3 161/12
181/11 197/13 202/4
UK Government [1]
83/23
UK's [1] 149/14
ultimate [5] 5/13
12/16 22/8 22/21
110/15
ultimately [5] 15/8
29/13 56/5 112/13
113/20
unaudited [2] 66/7
67/6
unauthorised [1]
64/7
unaware [1] 159/24
unclear [1] 151/13
uncorrupted [1]
79/25
uncovering [1]
117/19
uncovers [1] 197/25
under [10] 33/18
37/16 47/11 53/7
62/22 122/23 132/21
139/13 204/13 204/20}
undergo [1] 65/25
undermine [2]
117/20 119/21
underneath [3] 19/13
156/6 158/14
understand [32] 2/19)
4/16 7/7 11/22 13/7
17/8 23/3 32/12 35/21
41/21 41/24 48/14
55/6 62/19 66/25
75/11 78/2 80/8 84/4
87/20 87/21 96/19
96/23 97/12 99/25
100/15 125/22 128/25
131/6 164/5 171/2
182/4
understanding [26]
43/5 43/7 43/10 46/16
73/7 73/8 80/20 90/14,
94/19 99/15 118/20
123/9 125/3 125/9
131/3 132/7 133/20
135/14 137/13 139/11
188/20 192/1 192/23
195/17 196/7 196/17
understands [1] 71/9)
understood [4] 50/21
60/6 81/18 146/25
undertake [1] 145/12
undertaken [4]
168/22 194/19 195/23
197/21
undertakings [3]
64/15 64/19 64/24
underway [1] 123/2
Undoubtedly [1]
154/19
unduly [1] 120/6
unexplained [1]
182/24
unfortunately [1]
138/21
unfounded [1] 99/16
unhappy [1] 159/10
uninterrupted [1]
138/12
unique [3] 2/2 93/16
196/24
Unisys [1] 29/21
unit [5] 29/22 30/16
102/6 112/9 123/13
unknown [1] 53/14
unless [2] 147/24
204/5
unlikely [1] 151/1
Unrestricted [1] 66/7
unstable [1] 50/1
untampered [1]
81/19
until [13] 25/24 39/9
89/24 100/2 100/4
101/12 122/19 160/15)
161/21 161/23 180/16}
191/25 206/1
unusual [1] 184/9
up [88] 2/18 3/16
6/11 7/18 8/19 10/9
14/12 14/14 14/15
14/24 15/3 19/21
24/11 30/11 31/16
31/23 34/5 34/24
39/17 40/25 45/4 49/5
54/22 56/6 59/11
66/21 72/16 73/25
74/4 74/5 74/7 89/20
95/23 98/20 99/8
105/6 108/23 109/10
109/11 109/18 109/24I
110/7 110/24 111/1
113/4 118/2 120/15
123/1 127/4 129/6
129/22 130/15 134/1
136/23 141/14 143/20)
143/22 143/24 144/22)
151/22 153/14 153/17
157/9 161/23 163/22
164/10 164/10 167/17)
169/5 170/14 170/19
170/25 172/1 173/7
173/14 173/18 174/4
174/13 174/15 180/16)
184/14 189/2 189/5
189/24 197/6 203/8
204/9 205/19
update [3] 66/5 68/8
96/2
updated [3] 108/12
109/14 109/17
upgrade [1] 150/11
uploaded [1] 93/17
upon [7] 17/13 56/4
129/14 162/19 191/17)
196/8 204/1
upwards [1] 62/13
urgency [1] 188/14
Urgent [1] 181/8
us [23] 98/7 102/2
109/3 111/16 123/17
126/4 127/1 127/20
129/15 131/12 132/7
135/16 138/13 140/11
141/15 141/24 142/1
142/22 148/13 155/5
157/10 160/25 161/5
use [14] 4/17 17/12
28/8 32/4 64/6 64/8
64/14 64/23 80/15
81/2 81/10 144/12
148/20 172/21
used [12] 34/17
40/22 64/12 80/4
80/19 85/10 85/13
85/18 146/20 160/8
168/11 198/22
useful [1] 100/19
user [5] 64/10 159/23
194/14 194/15 194/20)
users [2] 152/4 184/3}
using [4] 23/13 111/2
147/5 149/15
usual [4] 1/9 1/14
142/3 185/23
utmost [1] 153/2
(85) times - utmost
U
utterly [2] 204/22
204/23
Vv
vaguely [3] 137/17
151/19 183/8
validated [1] 147/11
value [5] 159/21
160/6 160/9 163/4
202/8
varies [1] 21/11
various [23] 3/23
14/20 15/17 19/16
20/11 20/17 20/24
42/15 49/17 50/22
73/15 79/21 85/4 85/9
90/17 101/15 122/24
126/15 145/9 162/23
175/14 190/8 191/7
vast [2] 149/18 153/7
vault [1] 197/1
Vennells [29] 97/22
100/4 100/16 100/25
101/4 174/20 174/24
179/20 181/4 185/6
185/12 186/18 186/21
187/10 188/4 188/7
188/9 189/18 190/9
190/24 191/4 191/6
191/9 194/5 194/24
195/1 195/6 195/8
198/5
Vennells' [1] 190/13
Verbally [1] 141/25
version [8] 45/2 45/4
106/17 109/14 109/18
116/16 126/20 127/3
very [63] 1/18 3/10
16/8 16/18 18/10
23/19 29/4 29/24
37/20 41/12 43/20
57/17 58/6 66/18 67/1
67/3 81/9 82/12 84/2
85/19 87/9 92/8 93/4
94/7 96/11 97/11
100/14 101/7 104/15
106/5 106/16 113/25
113/25 127/11 129/22)
132/5 138/25 140/14
142/17 144/1 149/19
156/23 156/25 157/2
157/8 162/4 166/21
179/25 180/19 185/14
186/4 187/3 187/16
188/19 191/11 192/8
193/11 198/25 200/7
202/3 204/5 205/13
205/24
vested [1] 66/3
vetted [1] 67/1
vetting [1] 66/1
via [4] 10/11 28/23
56/5 196/25
Vice [2] 28/12 29/3
video [2] 129/12
176/4
view [32] 18/22 29/16
51/7 53/10 55/16 58/1
62/9 79/18 79/24
81/13 86/9 88/11
113/10 113/22 117/19}
127/1 127/24 129/14
129/18 137/3 145/3
145/4 145/6 147/6
147/15 152/25 169/15)
172/11 172/11 173/14)
173/15 192/23
views [1] 139/12
Vince [1] 130/2
Virtually [4] 149/14
le [1] 107/12
[2] 85/18 180/2
visited [1] 84/14
voce [1] 74/2
volume [4] 122/6
122/19 133/10 135/5
volumes [1] 74/17
<
<.
wagging [1] 152/24
wait [1] 2/18
Wallis [1] 155/12
want [33] 1/20 2/13
3/14 4/13 15/6 16/3
19/20 28/10 34/2 35/8
40/1 40/23 44/5 47/20
57/14 59/21 70/25
72/15 78/23 82/10
83/20 87/11 88/12
88/24 110/4 111/9
124/3 127/4 127/17
130/13 138/18 148/1
174/19
wanted [6] 17/11
23/7 30/18 31/15
76/25 123/9
wants [4] 70/1
128/20 129/4 129/7
Ward [1] 205/19
Warnborough [1]
168/13
warning [1] 67/18
was [478]
wasn't [20] 20/11
23/10 40/19 48/13
48/13 65/14 70/10
70/23 71/14 72/14
77/16 81/2 89/18 98/3
123/4 123/5 142/14
164/3 171/11 172/16
wasting [1] 130/12
watch [1] 142/9
Watchdog [2] 103/12
113/18
watching [1] 155/21
water [1] 47/11
way [37] 19/10 29/13
29/14 31/4 39/7 43/4
56/14 57/25 58/2
62/23 66/22 68/10
83/11 88/19 88/22
89/24 91/9 93/18
107/14 122/3 126/8
132/21 138/24 143/13
149/9 150/15 152/17
154/22 155/2 156/10
161/8 161/12 169/3
178/19 182/3 196/22
203/3
ways [1] 153/16
we [402]
we'd [4] 19/1 68/18
130/5 204/10
we'll [11] 16/2 31/20
38/3 47/15 54/10
92/12 100/20 111/21
127/7 154/1 176/2
we're [33] 27/8 31/22
33/15 48/25 51/24
61/17 66/22 79/9 80/1
87/5 92/21 101/19
101/21 104/20 109/5
114/22 121/18 135/2
135/4 137/24 137/25
138/2 141/8 141/9
142/18 150/3 154/8
164/13 165/8 165/24
177/20 181/7 187/8
we've [30] 42/15
53/13 56/6 59/21
67/15 78/11 89/21
101/7 101/16 119/15
121/14 124/5 124/21
141/4 151/4 153/23
155/13 163/14 169/12
173/22 174/7 174/17
175/12 177/7 180/14
181/1 183/18 189/14
190/17 191/7
weakening [1] 84/13
web [1] 147/14
website [2] 3/12
93/18
Wednesday [3] 1/1
45/16 182/14
week [10] 8/17 9/23
45/11 69/21 111/13
128/17 137/9 141/13
148/19 186/15
weekend [1] 84/16
weekly [14] 19/5
19/10 21/5 60/7 60/10}
60/14 61/4 72/9 72/13
135/14 146/9 157/16
182/15 183/19
weeks [4] 103/6
134/7 144/10 157/15
well [78] 3/18 8/3
10/14 11/4 11/7 16/6
22/25 23/18 26/13
27/20 31/17 36/6
36/21 38/1 40/8 41/13)
42/23 43/1 43/3 43/20)
44/17 47/3 47/5 48/9
48/25 50/21 50/25
53/6 53/21 54/1 54/10)
56/23 58/6 58/9 65/12,
65/20 70/15 71/3
7AI17 75/18 77/23
79/11 80/17 81/15
82/9 86/25 88/12 89/4,
90/12 95/20 98/19
99/2 100/20 102/11
104/20 122/5 123/12
125/23 131/3 132/19
132/23 136/4 136/5
136/17 151/10 153/23}
154/3 156/8 164/7
173/17 188/13 189/7
200/17 201/12 202/4
204/12 204/17 205/2
well-known [2] 202/4
204/12
well-placed [1]
104/20
Welsh [2] 74/2
108/23
went [14] 9/17 17/19
17/21 30/2 42/17
58/13 59/11 79/5
95/14 121/24 140/21
173/25 180/3 201/6
were [219]
weren't [10] 9/23
88/9 136/14 167/1
170/2 173/19 173/25
178/19 191/8 204/18
West [2] 146/20
168/8
what [164] 4/12 6/6
10/5 13/8 13/10 15/12
15/14 17/4 17/11
17/12 17/18 18/8
18/16 18/18 25/12
26/6 26/14 26/15 27/9
28/4 29/9 29/17 30/9
30/12 36/18 37/15
38/1 39/14 39/21
39/21 40/3 40/4 40/12
42/3 42/4 43/5 43/7
43/7 43/11 43/20 48/2)
48/7 51/10 53/8 53/21
53/22 53/23 54/22
55/15 55/16 55/24
56/18 58/13 58/24
59/1 59/22 60/6 65/12
65/19 67/5 67/9 67/12
68/1 68/20 70/21 72/1
7718 77/17 78/7 78/16)
78/17 79/6 79/10 80/1
80/23 81/7 87/20
87/21 88/2 88/9 88/12,
88/18 88/19 88/24
88/25 89/1 89/3 89/7
89/21 90/6 90/11
90/17 91/4 91/11
91/17 92/13 94/5 98/9I
102/5 102/8 107/15
112/19 113/10 113/22!
118/11 118/23 121/10)
123/8 123/17 125/9
125/22 126/18 128/9
128/22 128/25 130/21
131/16 132/18 134/4
134/13 142/21 143/19)
143/21 156/15 156/16
157/7 158/4 158/16
158/19 158/24 159/17)
161/5 162/4 162/16
172/14 173/16 173/25]
177/16 181/17 183/24}
185/13 186/25 187/1
189/12 190/17 190/22)
191/1 191/17 191/23
192/1 192/23 194/3
200/7 200/22 202/24
203/13 203/20 204/4
204/7 204/17 204/17
204/19 204/23 205/7
what's [10] 33/14
34/8 40/1 52/19 58/20
59/14 79/18 183/6
202/20 204/11
whatever [7] 8/19
9/17 50/24 54/20
60/13 65/9 70/24
when [107] 4/16 5/9
6/4 6/7 7/24 10/2
11/24 12/5 12/8 16/4
17/24 18/6 19/9 20/9
22/7 22/19 23/13
24/12 24/20 26/16
26/25 30/6 30/17 33/8I
33/15 37/3 39/14
39/17 48/22 52/14
52/25 53/3 55/25
57/11 58/17 59/3 60/9I
60/14 71/4 71/5 71/13)
71/22 72/20 74/18
75/16 77/7 78/1 79/11
79/20 80/5 80/6 81/4
81/15 84/21 85/20
89/2 91/14 91/19
91/22 94/19 94/20
95/16 97/15 97/17
97/19 98/1 100/11
100/18 101/14 101/3
101/5 101/9 103/3
103/17 103/25 104/20)
114/14 114/17 121/25)
125/25 126/18 143/22!
145/2 152/1 152/8
153/6 153/11 159/25
160/10 162/6 163/5
165/13 175/11 175/14)
175/16 179/2 180/7
183/25 184/4 184/10
186/21 188/10 193/15}
(86) utterly - when
Ww
when... [4] 193/22
199/19 200/10 202/10)
where [43] 4/2 8/9
50/12 60/19 63/8 66/5
67/17 68/24 73/6
79/17 87/21 94/7
94/14 104/17 117/17
125/18 129/14 134/8
137/10 139/4 139/12
140/11 140/21 142/23}
143/8 146/11 149/19
149/21 149/25 153/13}
153/20 155/12 157/11
161/17 162/19 166/16
169/1 170/10 173/17
183/4 187/21 204/1
204/9
whereas [2] 162/13
203/17
whereby [1] 13/9
wherever [1] 98/20
whether [35] 12/2
31/18 32/1 43/15
44/21 50/11 52/20
54/8 54/14 54/23 55/6
57/14 60/20 62/2
62/20 65/2 65/17 70/8
70/20 74/21 76/24
80/2 83/11 87/1 87/2
113/21 118/22 120/22)
126/14 135/24 136/21
173/8 175/16 183/21
198/18
which [101] 2/15
5/13 5/20 6/2 7/25
8/17 9/12 10/17 21/18
25/24 26/21 26/23
29/14 29/23 31/14
31/15 33/25 34/13
34/23 36/19 37/10
38/13 41/14 41/19
42/9 42/17 45/19 47/6)
47/6 48/1 48/21 48/23
49/21 53/11 56/4 56/5)
56/8 57/15 58/13
58/14 59/23 62/7
63/22 65/7 65/7 65/7
65/9 65/11 68/3 69/5
69/21 71/5 73/2 76/12
79/13 80/1 82/23 83/6
84/23 85/19 87/15
97/11 99/21 100/18
102/23 107/12 108/20)
117/15 120/22 131/5
131/9 131/16 134/14
142/23 144/23 147/3
148/7 150/16 157/9
158/25 163/6 164/25
166/17 169/1 172/13
178/7 181/14 182/5
182/19 183/4 186/6
186/18 192/17 198/1
199/7 202/11 204/4
204/5 204/23 205/1
205/2
whichever [2] 98/24
106/13
while [9] 51/7 84/11
99/24 138/22 144/15
167/7 168/5 192/2
192/3
whilst [5] 10/22
11/22 36/4 125/17
150/14
whistle [1] 89/1
whistleblower [2]
90/2 90/2
whistleblowers [4]
90/10 90/19 90/20
91/11
whistleblowing [3]
87/12 89/5 89/14
whistles [1] 90/22
who [88] 8/6 10/15
11/1 11/2 11/6 15/4
15/24 16/4 16/9 16/11
16/16 16/16 25/15
28/4 30/19 39/24 40/3
40/11 40/17 40/17
41/2 52/14 54/17
55/22 57/18 58/6 58/9)
59/5 59/6 63/23 67/1
67/1 67/2 68/2 71/14
82/22 83/7 87/19
88/13 90/2 90/6 94/21
97/14 97/18 98/23
102/2 102/4 104/4
104/7 108/23 110/7
110/11 112/7 112/17
115/7 115/9 119/1
119/7 121/8 123/10
129/24 130/2 132/23
137/19 139/9 141/18
142/22 143/3 153/22
153/24 154/1 155/5
158/1 161/1 161/18
168/15 168/17 169/6
170/23 174/6 175/2
179/16 181/9 183/1
195/19 195/20 199/18)
204/17
whoever [2] 46/15
51/19
whole [12] 12/4
12/16 23/7 29/14 36/7,
41/7 50/6 70/19 79/25
124/21 128/10 129/2
wholly [4] 5/20 6/14
6/21 7/2
why [27] 17/9 18/24
48/4 68/15 68/15 81/1
81/13 88/10 90/10
90/11 90/19 91/11
91/20 118/9 134/4
151/23 156/5 164/3
167/24 172/16 184/12)
184/17 187/24 189/15}
201/8 204/18 204/19
widely [3] 17/23
162/17 203/21
wider [1] 114/17
Wilkerson [4] 129/24
129/24 134/1 167/23
will [57] 1/8 3/11 3/18]
14/2 16/6 29/14 39/25}
41/1 51/16 52/7 52/9
53/17 68/3 74/3 74/10)
78/17 89/7 93/17
104/22 106/22 107/11
111/16 111/18 111/23
126/6 126/9 128/24
130/15 131/20 133/16}
134/17 135/23 136/5
138/5 138/11 141/24
143/21 147/18 147/21
150/14 159/20 160/3
160/6 160/8 160/10
162/7 162/15 168/23
169/22 170/21 186/15}
192/21 192/22 192/24
196/4 198/2 203/19
win [1] 57/21
wish [2] 24/9 77/17
wished [1] 158/5
withdrawing [1]
11/15
withdrawn [1]
148/12
withdrew [1] 148/7
within [45] 3/14 4/14
SIT 8/13 16/22 17/18
26/20 28/23 40/8
40/10 40/19 40/23
52/18 57/18 60/8 83/7
86/9 88/16 90/5 94/8
94/17 95/21 96/17
98/7 101/10 110/14
119/9 121/1 125/20
132/6 132/8 133/24
146/14 151/5 157/14
162/7 170/15 173/3
175/2 180/9 188/17
190/6 190/7 192/14
197/7
without [18] 4/17
27/12 32/6 39/17
39/18 89/17 91/18
106/20 119/3 120/6
138/7 138/25 139/16
149/16 149/16 163/13
202/18 202/23
withstand [1] 54/9
WITN03570100 [2]
93/17 99/9
WITN03840100 [1]
2/3
WITN03840200 [1]
2/11
WITN04600104 [1]
49/1
witness [61] 1/19
1/23 2/8 3/2 3/3 3/10
3/15 3/19 7/18 13/10
14/4 19/5 19/15 21/25}
25/4 31/23 52/24 56/2
56/11 63/4 72/16
72/18 75/8 75/14
75/16 75/21 76/17
76/21 77/4 77/13 78/7
78/10 78/19 78/24
78/24 80/16 80/23
81/8 81/11 81/20 82/5
82/16 82/23 86/13
93/7 94/16 99/6 99/11
110/20 123/4 133/13
140/6 146/24 147/25
151/18 152/13 174/24}
176/25 193/12 198/19}
200/23
witnesses [5] 77/24
78/1 81/2 146/14
203/13
Woking [1] 168/23
won't [3] 40/8 135/8
176/2
word [8] 23/14 28/7
30/15 32/4 80/4 90/13
91/23 100/14
wording [1] 42/8
words [4] 108/16
128/7 133/25 204/11
work [21] 24/22
50/17 50/19 53/16
53/17 104/23 104/25
110/5 129/13 143/18
166/18 168/5 175/5
177/3 177/19 190/16
197/21 197/24 197/25
200/19 204/15
worked [11] 4/14
18/11 41/8 42/11 58/2)
93/22 94/15 102/6
110/16 153/8 161/13
working [12] 14/11
15/6 18/8 32/3 40/18
63/17 71/22 176/8
176/16 187/25 189/7
190/5
workload [1] 45/14
workmanship [1]
46/8
works [5] 31/4 57/25
126/11 153/3 153/10
worldwide [1] 202/3
worried [1] 128/5
worse [2] 53/17
139/24
worst [1] 120/5
worth [3] 86/24
150/22 189/9
would [265]
wouldn't [22] 25/13
25/16 30/7 40/1 40/5
41/5 41/6 62/18 69/10)
71/24 77/23 78/11
78/15 78/22 112/22
112/24 118/9 126/22
156/5 161/23 184/17
197/8
wrestle [1] 128/4
write [5] 31/24 40/3
163/4 175/22 202/8
writer [1] 87/1
writing [2] 42/6 65/8
written [5] 92/9 123/2
144/2 158/19 205/14
wrong [8] 3/17 59/18
91/3 152/17 171/16
173/25 184/12 204/6
wrongly [1] 182/20
wrote [2] 46/15
175/11
Y
Yasui [1] 58/6
yeah [20] 6/4 18/4
19/23 20/16 22/3
23/16 29/12 34/15
37/22 42/18 50/24
61/2 64/3 75/24 83/19
94/6 109/19 140/6
150/6 170/1
year [20] 6/18 24/6
24/14 24/21 24/22
25/8 25/9 25/19 31/2
47/12 84/8 101/7
145/2 151/5 178/24
179/14 180/10 184/13)
184/13 184/14
years [14] 18/21 32/3
53/13 89/19 89/23
95/13 102/22 128/3
144/23 146/17 157/13)
157/14 182/17 198/2
yes [267]
yesterday [1] 147/11
yet [2] 154/10 190/21
York [2] 22/23 58/7
you [769]
you'd [5] 8/16 8/19
61/6 90/20 170/17
you'll [7] 20/11 25/7
47/16 56/9 108/17
164/14 201/17
you're [33] 6/6 6/23
47/10 17/11 22/7
23/13 23/24 25/18
32/12 40/11 48/23
56/13 57/22 61/3
63/14 67/20 69/9
70/13 81/17 87/21
91/3 91/22 91/23
110/18 114/24 114/25]
120/15 120/24 154/9
177/17 185/13 199/13}
200/12
you've [32] 3/19
13/20 20/17 25/15
(87) when... - you've
Y
you've... [28] 39/9
47/23 53/16 68/6 72/5)
80/8 86/7 88/18 94/16
109/17 115/6 123/3
132/18 133/12 136/10)
139/6 151/18 152/5
155/20 174/6 174/23
183/13 191/8 192/8
193/6 199/18 200/22
204/16
Young [30] 97/18
97/23 121/24 124/17
126/24 127/1 127/10
127/13 127/15 130/23}
131/20 134/12 134/22
136/15 137/15 139/7
139/11 154/4 154/5
154/12 155/1 171/3
171/10 184/2 194/3
194/11 194/13 195/1
195/2 195/3
Young's [4] 133/20
138/21 184/8 194/9
your [178] 1/16 2/6
2/8 2/12 3/1 3/5 3/8
3/14 3/19 4/13 5/1
7/14 7/18 9/20 10/22
11/12 11/13 15/11
15/12 16/15 17/13
18/8 19/5 19/6 19/15
21/25 23/21 25/4
25/18 27/14 28/11
31/17 31/23 32/13
40/7 40/9 41/4 41/21
43/3 43/5 43/7 43/14
43/15 43/16 48/18
55/10 55/16 56/13
58/23 58/24 60/5
61/17 62/9 62/12
67/11 67/11 67/19
68/7 68/7 72/16 73/8
75/6 75/6 75/11 78/19)
79/18 82/12 82/14
82/15 83/7 86/8 89/23
93/4 93/11 93/13
93/19 94/16 95/13
95/18 96/1 96/6 97/14}
98/1 98/1 98/2 98/8
99/6 99/11 101/10
101/20 102/8 102/10
105/17 105/18 107/21
108/6 110/14 111/3
112/15 113/7 113/8
113/10 113/20 113/22)
114/17 118/10 118/17
118/25 123/4 125/3
125/9 129/17 133/1
133/2 133/3 133/5
133/13 134/4 134/19
136/11 138/23 139/21
148/21 151/5 151/18
151/24 152/13 153/12)
155/18 155/21 156/14)
156/16 157/3 157/4
163/19 165/2 167/1
167/10 170/10 171/10)
173/19 174/24 175/2
175/25 176/5 176/18
176/24 176/25 179/15)
179/22 180/10 180/24)
183/10 183/11 185/11
186/25 187/9 188/15
189/10 190/18 190/22)
191/3 192/1 193/12
194/21 195/11 199/16)
199/19 199/20 200/11
200/19 204/13 204/18)
204/20 204/22 204/24,
204/24 205/14
yourself [5] 36/4
127/8 141/12 154/12
192/7
yourselves [1]
139/19
Zz
zero [4] 45/20 45/20
160/6 160/9
(88) you've... - zero