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Wednesday, 3 July 2024
(9.48 am)
MRBEER: Good morning, sir. Can you see and hear us.
SIR WYN WILLIAMS: Yes, thank you very much.
MR BEER: May I call Tim Parker, please?
‘SIR WYN WILLIAMS: Of course.
TIMOTHY CHARLES PARKER (affirmed)
Questioned by MR BEER
MR BEER: Sir, before I ask questions of Mr Parker, I should
say that there is a fire alarm drill today at 10.00 and,
in accordance with our usual practice, we're going to
sit through it.
SIR WYN WILLIAMS: = Sure.
MR BEER: Thank you.
Good morning, Mr Parker.
A. Morning.
MR BEER: My name is Jason Beer and I ask questions on
behalf of the Inquiry. Can you tell us your full name,
please?
A. Myname is Timothy Charles Parker.
Q. Thank you. You've provided kindly a witness statement
for us which is 136 pages long, the URN for that is
WITNO0690100. You should have a hard copy in front of
you there. Can you turn up, please, page 126. Do you
have that?
Chairman of the Post Office from 1 October 2015 until
September 2022 so about seven years; is that correct?
Correct, yes.
Q. You took over after Alice Perkins was Chair of the Post
Office, albeit there was an interim chair?
A. That's correct too.
>
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At the same time, I think you were Chair of Samsonite.
I think you became Chair of Samsonite in 2014; is that
right?
A. I was, in fact, Chair and Chief Executive of Samsonite
from 2008 until 2014 and then I stepped down as CEO and
remained as Non-Exec Chair.
Q. So Chair of Samsonite from 2014 until the present day?
A. Today, yeah.
Q. Yes, and so concurrently with your term in the Post
Office for seven years?
A. Correct.
Q. You were concurrently Chair of the National Trust,
I think, from 2014 to 2022; is that right?
A. That's also correct.
Q. So, again, concurrently with you being the Chair of Post
Office?
A. Indeed.
Q. From April 2018, I think you were Chair of Her
Majesty's -- now His Majesty's -- Courts and Tribunal
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Ido.
Do you see in paragraph 268(iii), it says "POL
appointing a criminal with extensive experience to work
alongside Brian Altman QC"?
Ido.
Should have that have the word "silk" inserted between
the word "criminal" and "with"?
Most certainly.
So that, rather than the Post Office appointing
a criminal, the Post Office would appoint a criminal
silk?
Absolutely. Correct.
Thank you very much. Can we go to the last page,
please, which is page 136. Is that your signature?
Itis.
With that correction brought into account, are the
contents of the witness statement true to the best of
your knowledge and belief?
They are indeed.
Thank you very much. It's a very detailed witness
statement of 136 pages, it will be uploaded to the
Inquiry's website and therefore I'm not going to ask you
questions about all parts of it.
Okay.
Can I start with your background, please. You were
Service until 2022; is that right?
That's also right.
So concurrently with your chairmanship of the Post
Office for a period of four years?
Correct.
Thank you. Can you tell us in general terms your view
of the company, the Post Office Limited, that you
inherited when you took over as Chair in October 2015?
Yeah. The Post Office has a turnover of just under
£1 billion, which makes it a sort of medium-sized
company, but in fact it is an incredibly complex
business: it's complex because it operates a network of
around 11,500 sites; it's complex because it has a very
wide range of products; it's complex also because it
deals with cash, and cash has a big security element to
it; it's complex because it's in the public sector.
So this is an organisation that is incredibly
complicated and at the same time faced some very
significant commercial challenges. Sorry, I'm going on
a bit here but it's quite important that I can set the
scene to the Post Office.
This is a business which had absorbed billions of
pounds of taxpayers money and was still losing money.
It was a business that faced significant challenges
because it had an exclusive arrangement with the Royal
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Mail, and the Royal Mail itself was suffering from
increasing competition in the parcels market and
a declining letters market.
The Post Office had previously had a significant
amount of business from the Government, so driving
licences, benefits, that kind of thing. That had all
moved online and so the Post Office was bereft
a significant chunk of its contribution.
The Post Office had a range of products which it
attempted to sell, with varying degrees of success, and
it also had a very complex structure in terms of its
overheads and management. So when I turned up, I felt
and I believed that I could somehow help to improve
an organisation that was in -- I don't think it's any
exaggeration to say it was in deep crisis.
Thank you. I think it's right that, before you took up
your position, you made enquiries as to the accounts or
figures of the Post Office before accepting the role; do
you remember that?
I don't but I probably would have done.
Let's look at some emails to jog your memory if we can,
please. UKGI00019884. If we look at the second page,
please, and the bottom half of the page. That's it.
This is an email not sent to or by you, but it's about
something that you are said to have said. It's from
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note that Tim Parker expressed an interest in seeing
some more up-to-date figures on Post Office before
accepting the role, if he were to be offered it. We
believe this is just thoroughness on his part -- he
needs to be confident what he is getting into -- and we
are following this up with Post Office and with the
public appointments assessor so that we can answer his
queries ...”
Then I'm not going to read the third paragraph.
Mm, mm.
What were your concerns about the finances of the Post
Office; what were you concerned about getting yourself
into?
Well, as I think I've described to you, it was, I felt,
in a very difficult situation, compounded by the fact
that it relied, obviously, on agreeing financing,
usually on an annual basis, with the Government, and
needed a subsidy really to keep everything in order. So
I mean, I -- I thought it was a difficult situation and
it certainly wasn't going to be very easy but I felt
that, however things turned out, the Government would
obviously need to stand behind the Post Office and so
I would be trying to help the Executive Team tackle
things from the commercial end of the business with the
customer and, at the same time, try to manage the
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Laura Thompson, who was an assistant director within
ShEx, the Shareholder Executive?
Sure.
It's to the, essentially, private office of the then
Secretary of State, Sajid Javid, and you'll see it's
dated 17 June 2015 --
Mm-hm.
-- so three or four months before you took the post?
Mm-hm.
If we just read it:
"We spoke -- Baroness Neville-Rolfe ..."
Who I think you'll remember was the relevant
minister at the time?
Mm-hm.
".., met the two appointable candidates earlier today.
We spoke to the Minister after her meeting. She
confirmed that she would be happy to appoint Tim Parker
to the role but did not feel Simon Burke was suitable --
while he had some very good experience, he did not give
her the confidence that he would be a strong chair, she
felt she would need more support from Government in
steering the business."
Then the second paragraph:
"I would be grateful if you could therefore seek the
Secretary of State's views on the appointment. Please
6
Government and its willingness to finance the Post
Office.
So is this is an oblique reference, then, to whether the
Government would continue properly to subsidise the Post
Office?
Yeah, I believe that post offices are very politically
sensitive and keeping a network is usually of
significant importance to ministers. So I always felt
that, you know --
If you just pause there.
(Pause for fire alarm test)
Mr Parker, you just said:
"I believe that post offices are very politically
sensitive and keeping a network is usually of
significant importance to ministers. So I always felt
that ..."
Yes, and I was going to go on and say so I always felt
that, although there would be some very difficult
discussions, the Post Office would always be there in
some form or another. The challenge was to try to,
essentially, make it more sustainable.
When you were essentially doing this pre-appointment due
diligence, were any concerns expressed to you about the
performance and capabilities of the then CEO?
I don't recall that being expressed to me at the time.
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Can we look, please, at UKGI00042677. This is
a presentation about Post Office Limited Senior
Management to the Risk and Assurance Committee of the
Department for Business, Innovation and Skills and the
Shareholder Executive. You'll see it's dated February
2014, so a year and a half or so before your
appointment?
Mm, mm, mm.
Can we turn, please, to the second page, and do you see
down the left-hand side, underneath the number 1:
"Advice from the recent Annual Review suggested that
the [Post Office] team give careful consideration to the
continued suitability of Paula Vennells as CEO."
Mm.
"There is a general consensus that Paula is no longer
the right person to lead the Post Office but
justification is anecdotal. This short paper aims to
examine the options available to the [Shareholder
Executive]."
Was anything like that brought to your attention
upon your appointment?
Not that I can recall.
Can we go forwards, please, to page 6. Again, on the
left-hand side, I should say there's a series of options
in this paper, one of which is removal of Ms Vennells
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have been 2015, so we're talking nine years ago, I can't
recall a conversation that I had about the capability of
Paula Vennells at the time I became chair.
Would you expect, as the incoming chair, to be told, by
the outgoing chair, that she had questioned the Chief
Executive's performance as Chief Executive?
I think it's obviously of some value if, when you arrive
in a business, you are well appraised of the views of
your key shareholders, whether it's a publicly owned
business or not.
That's a statement in general terms. I'm asking: were
you, in fact, told by or on behalf of the outgoing chair
of this view that is recorded here that she held in
relation to Paula Vennells?
The honest answer to that is I can't remember.
Was there a handover?
I met Alice for lunch before I began.
Was that handover?
As far as I can recall, that was the conversation that
I had with her.
Was there anything more formal than lunch, in terms of
a handover?
Again, I'm sorry not to be of more help but I can't
recall.
When you walked into the company we saw that you did
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and this is the slide that addresses this issue. On the
left-hand side:
"There is a general feeling that Paula is not the
optimal person to lead [the Post Office] to develop its
commercial strategy.
"Paula has not been able to establish good working
relationships with Jo Swinson.
"She has been unable to retain key staff."
Then on the right-hand side, "Performance as CEO and
delivery of strategic plan":
"[Post Office] failed to deliver its 2010 strategic
plan, and refused to keep [Government] properly
appraised of developments in the [Network
Transformation] programme, requiring difficult revisions
in 2013. She has shown a worrying lack of knowledge
about the detail of the new plan.
"Paula's people management has caused concern as she
appears unable to work with personalities and approaches
that differ from hers, and has failed to build
relationships with key Directors.
"Paula's performance as CEO has been questioned by
the [Post Office] Chair, and by members of the Board."
Were you aware of this view held by the department
and/or ShEx when you joined the company?
To be honest, I mean, looking back from here, this would
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some work in the months before your actual appointment.
Did you make any enquiries about this issue, namely the
performance of the CEO and/or the Board's view of her
and/or the shareholders’ view of her?
I can't recall. Can I make a comment on that? Because
it has struck me, and this is something I hope might be
of use to the Inquiry, that whether or not I received
a view or whether I took on board a view, it is very
important that when you take over as chair, that you are
well appraised and you understand, as best as possible,
the views, positive and negative, of the CEO. This,
I think, can help to frame things. As far as I can
recall -- and I've got quite a lot of experience working
with CEOs and I've been a CEO for over 30 years --
I mean, my take was that the business had someone who
needed some help and assistance and coaching on the
commercial front, which is what I aimed to provide
Paula.
My impression, looking back, was that she was quite
well thought of and so much so that, as you probably
know, I mean, a few years later she was made a Non-Exec
Director of the Cabinet Office, and -- you know, so, my
sort of feeling was although -- whatever my own views
were of her ability in terms of running a business,
I didn't get the impression that there was some enormous
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doubt and, you know, the starter for ten was actually
you need to look at Paula.
Okay, that was my next series of questions. When you
did become Chair of the business, was anything like this
raised again with you by Government or the Shareholder
Executive?
Yeah, and, again, I'm sorry at this length of time
I simply cannot confirm anything.
Can we move on, please, by looking at UKGI00005361. At
the moment, I'm just looking at a series of events that
happened before your appointment. If we can go to
page 4, please. This is a series of emails that again
doesn't involve you but there are, within the emails,
comments/views attributed to you and I want to ask you
about them?
Yes.
Below this page, there's a note about an upcoming
Panorama programme and there was a significant Panorama
programme about Post Office and the Horizon system, due
to air on 17 August 2015. If we go to the bottom of
page 3, please, Alwen Lyons to Richard Callard -- that
will be a name familiar to you -- within the Shareholder
Executive, exchange an email copied to Ms Vennells.
"Richard
"Paula and I are [considering] how and when it is
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I have no idea. I mean, at this stage, I'm not sure
what I would have known about Sparrow or indeed what
“pretty robust" actually means. I think probably what
it means is, you know, I obviously had been briefed up
to a point but I wasn't going to say anything negative
or positive at that stage because I was very new, and
maybe that was interpreted as "pretty robust”.
I was about to ask you: on what basis would you have
formed a view two months before you joined the business?
I don't think I would have done.
Because you hadn't read or received any relevant
information, presumably?
I have no idea but, I mean, I'm not a person generally
who takes a pre-disposed view to anything until I, you
know, have had a chance to understand it properly.
If we go up the chain, please, to page 1 and the foot of
the page. Later on the 6th, again, Laura Thompson to
Alwen Lyons and Richard Callard:
"I've just come off the call between the Minister
and Tim Parker. Nothing significant to report.
"On Sparrow, the Minister informed Tim that she
would like him to look at things with fresh eyes when he
arrived, which he was happy with. Tim confirmed he
would be happy to meet MPs, etc, on the matter but once
he was up to speed. The Minister mentioned that
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best to brief Tim on Panorama.
"Would you let me know when Baroness Neville-Rolfe
is planning to speak to him, as she was going to mention
Sparrow. Notification re Panorama would come better
after that, as we could refer her to her conversation
and offer a more immediate brief if he would like one."
Then further up the page, please, the reply:
"BNR [Baroness Neville-Rolfe] is speaking to him
[that's you] at [2.45 today]. I spoke to him ... He is
pretty robust on Sparrow (ie if we have done nothing
wrong then we stuck to our guns), but is happy to agree
for [Baroness Neville-Rolfe] to say to Bridgen and co
that the new chair will of course take a critical and
independent look at the issue. He did also offer to sit
with her in her meeting with Arbuthnot, which was
arranged late yesterday for [the 17th] -- we should all
mull that one.”
So, essentially, consideration is being given as to
how to brief you about an upcoming Panorama programme,
which is very significant for the business. Do you
recall receiving briefings before you formally began
your role a couple of months beforehand?
Candidly not, no.
It's attributed to you that you are "pretty robust on
Sparrow"; was that your view?
14
Panorama was happening but it wasn't discussed."
Then there's another issue about the Audit and Risk
Committee, which I'm not going to ask you about.
Do you recollect the Minister, Baroness
Neville-Rolfe, asking you to look at things,
ie connected to Horizon? That's the shorthand for
Sparrow that the Post Office used.
I don't recall. I mean, I presume this is a fair
reflection of what I might have discussed. I mean,
I think she would have just notified me it was an issue.
Do you have a recollection of going into the job with
a request from the Government to have a fresh look at
Horizon?
I don't recall whether I, as it were, went into the job
but I do know that the letter turned up pretty soon
after I arrived.
So that's the thing that sticks in your memory, the
letter from Baroness Neville-Rolfe?
I got a letter and it was clear, you know, "Have a look
into these issues". Exactly.
Okay, we'll come to that ina moment. Can you recall
anything as to what the concern was in Government about
Horizon?
Not specifically.
Can we move forwards, please, to POL00319054 and if we
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go to page 2, please, and scroll down. This looks like
the genesis of a briefing note for you about Horizon --
again, it's called Sparrow -- in readiness for your
joining.
Mm.
We're going to track through what you were told, and if
we just read some parts to it, this is Mark Davies; do
you remember him?
Ido.
The Corporate and Communications Affairs Director --
Mm.
-- in the Post Office:
"See below ... a first draft of a note for Tim.
"For the last three years [this is the text of the
note] the Post Office has been investigating the cases
‘of a small number of postmasters ..."
Then we see somebody has added "I WOULD ADD HOW
MANY":
who have suggested that the Horizon
used in branches might be faulty.
"They have suggested it may have caused losses in
branch which in some cases led to them being prosecuted
[again added] (AGAIN MIGHT BE WORTH SAYING HOW MANY).
“No evidence has emerged to support these claims:
indeed thorough investigation has underlined that the
17
system
accounting and theft takes place.
"But we only prosecute where there is clear evidence
‘of wrongdoing and we can meet the bar set for bringing
prosecutions: the evidential and public interest tests.
We do not prosecute people for making mistakes. We
prosecute where people dishonestly cover up the loss of
money."
Then keep scrolling, and the fourth paragraph from
the bottom there:
"The campaign has secured the support of some MPs --
with whom the Post Office has engaged at length -- which
has in turn led to Parliamentary and media activity.
"We have been robust in rejecting the serious
allegations made in Parliament and media, particularly
in recent months. The allegations have suggested
wrongdoing by senior management, bullying, deliberate
cover-up and abuse of prosecutor powers.
“A Panorama programme is due to be aired on
17 August. We have challenged the programme at length
but expect it will go ahead. We have provided detail on
every allegation put to us. We are not appearing on the
programme for interview because the programme is
focusing on individual cases and has not provided
evidence to support its allegations."
Is this the kind of note you would expect to receive
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system is efficient and robust.
"It deals with six million transactions every day
and has been used by almost 500,000 people since it was
introduced: the vast majority doing so without
difficulty.
"The Post Office has nonetheless taken its
responsibilities to its people very seriously. It is
very sorry that this small group of people feel they
have been treated unfairly and has gone to enormous
lengths to get to the bottom of their cases.
"It held a review by independent forensic
accountants, set up a Mediation Scheme overseen by
independent mediators and reign investigated every
complaint in huge detail.
"We have also asked our external lawyers to review
all the cases involving prosecutions.
"Throughout all this no evidence has emerged to
support the very serious allegations being made, which
in some cases have stretched to claims that the Post
Office has abused the prosecution process.”
Over the page:
"We do take forward prosecutions where it is right
to do so. Post offices are dealing with public money.
We would be heavily and rightly criticised if we did not
deal with the very small number of cases where false
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as the incoming chair?
I think it's obviously a note that is designed to tell
astory. And what would I say? I mean, it’s a briefing
note obviously told from the perspective of the people
providing the briefing, which is what usually happens
with briefing notes, I have to say.
If we just go forward to page 1, please. Just look
briefly at some of the drafting process, foot of the
page.
Alwen Lyons to Mark Davies and General Counsel, Jane
MacLeod:
"I think this is very clear."
She has added some points in capitals:
"I think this note should come from Jane, or Paula
if she wishes, and be sent via me to start getting him
used [that's you] to that way of communicating and to
make it as 'normal' as Sparrow can ever be!!"
Then scroll up the page:
"We need to send a note to the new chairman and
I have drafted a first go ... and asked ... for
comments.
would now like ... your comments and whoever
is standing in for Rod?
"Clearly this is about the most important note we
will send on this issue in the weeks ahead so [we] want
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it to be spot on!
"Your input very welcome.”
When you were joining, was the Horizon issue, the
Sparrow issue, the most important issue for you?
I've tried to set the background to the Post Office and
I would say I can't prioritise things exactly. I would
say that this is one of, actually, a number of very
significant and pressing issues.
If we go forwards, please, to POL00231055, and if we
just blow that up a little bit, this is a later
iteration of the note --
Mm.
-- after an external lawyer, Andrew Parsons, from Womble
Bond Dickinson -- as I think they were by then -- with
his comments on it. He makes quite limited comments on
the note, we can see one on the right-hand side there.
If we go over to page 2, please -- thank you -- there's
some discussion about destruction of material. The note
said:
"We are not destroying any information that we, and
external lawyers, hold on these cases, as has been
alleged."
Then he commented:
"(The Post Office] has historically destroyed
[information] where it went beyond normal retention
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Then you see the figures have been inserted, 136:
".., that faults in the Horizon computer system were
the cause of losses in their branch. Of these 136
people, 43 have criminal convictions ...
"However, thorough investigation has not produced
any evidence to support the claims: indeed it has
underlined that the system is efficient and robust. In
the cases involving criminal convictions, nothing has
medicine to suggest that any are unsafe.”
Then it continues as per the previous draft.
Again, how would you view a document like this? You
described it earlier as a story --
Mm.
-- which might, to my ears, sound as if you're being
wary as to its authorship and it's setting out
a narrative, rather than be completely objective. Is
that what you were intending by the word "story"?
Not especially. But here's my view, with hindsight,
about one of the main issues with the whole thing, is
that, as I sort of looked at this, it seemed to me that
it was an issue, but of course you ask yourself the
question: well, on how big a scale is this issue? And
of course, what we have here is the Horizon system deals
with 6 million transactions used by 500,000 people. So
it sounds as if you've got a system doing millions of
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periods which means some info is not available for the
CCRC."
Now, of course, you wouldn't see all this
background, would you? You wouldn't see the process by
which the note was created or, indeed, who had
contributed to it, right?
Yes, I mean, absolutely.
You just get the final product?
I get the final product. Exactly.
Let's look at that, then. POL00174396. 11 August 2015,
so nearly two months before you joined the company, from
Alwen Lyons:
"Please find attached a note from Paula, in advance
of the Panorama programme", and then some other
information.
So, ultimately, it's a note from the Chief
Executive --
Mm.
-- being sent to you by Alwen Lyons, the Company
Secretary.
Mm.
If we look at the note itself, POL00174397 -- thank you:
"For the last three years the Post Office has been
investigating claims made by a small number of largely
former postmasters ..."
22
transactions and a few people who are complaining, and
that was the sort of perspective that you're drawn to.
What -- and I say this in the spirit of, you know,
this thing ever happens again -- is had we -- had the
thing been put in the context of not just the people who
are complaining but the totality of the people who had
been prosecuted over, you know, whatever it was,
15 years, that would have put a very different
complexion on the note. So if the note had read, you
know, that we have 43 criminal convictions related to
these losses but, actually, over the last however many
years, so many people have been convicted, that would
have told a slightly different story. And I also think
that there could have been more to this potentially
around how many people had been affected through
potentially, you know, any other sort of employment
related issue.
So it's -- we've looked at the Horizon problem from
the point of view of, well, what was -- you know, did
the computer have bugs or whatever? But, actually,
another way of looking at it might have been to say:
we've got an organisation, over 15 years 900 people have
been convicted, or whatever, how does that look? Does
that look statistically sensible? We've had, you know,
so many people who have been terminated, or whatever,
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how does that look, proportionately? So I looked at
this, to be honest, and not only did we have millions of
transactions but I happened to know over the last -- you
know, there were tens of thousands of postmasters and
assistants. So it looked vaguely credible but there was
a sort of a problem that affected, relatively speaking,
quite a small number of people.
The reflections that you've just given there, are they
things that have occurred to you now in the light of the
events which have happened, rather than things that
‘occurred to you at the time?
Well, I didn't have that information at the time and,
actually, it was quite late in the day, and I think
quite a lot of people at the Post Office were quite
surprised by how many people had been prosecuted. And
if you look at the sort of list of when the prosecutions
occurred, you go back to, I think -- I looked at this
list, and it sort of, from -- I think it was '98 or '99,
the numbers of people being prosecuted suddenly went up,
so it went up from 20 to 50 and, effectively, what
you're looking at is a record, from about 2000, I think,
roughly speaking, until 2012 or '13, something like
that, where roughly speaking 50 people are prosecuted
every year.
So my point is, obviously, that's something that
25
sure I would have adduced that it was him who raised it,
no.
I mean, you were told in the covering email, "This is
a note from Paula"?
I think so, yeah -- yeah.
Would it have surprised you if had been revealed that
the note had been drafted by the communications man?
That's an interesting question to which -- I mean, it's
very hard for me to say now how I would have felt
because, when you're new in an organisation, you're
never quite sure, you know, who's got a handle on what.
So I think, had I had a list of all the executives and,
you know, Mark Davies was identified as the comms man,
I might have wondered a bit.
As it was, you were told this was Paula Vennells' note
in the covering email, as we saw. Can we turn, please,
Mr Parker to the letter you mentioned earlier from
Baroness Neville-Rolfe. POL00102551. This about three
weeks before you joined, 10 September 2015 and I'm going
to read it all:
"I am writing to you ahead of your taking up the
role of Post Office Chairman to confirm our conversation
last month regarding the Post Office Horizon system."
I suspect that's a reference back to that mention we
saw in that email exchange.
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might have raised some question marks. Now, you have to
recognise, as well, that the Post Office, you know, it's
not selling cans of Coke. It's actually an organisation
that deals in cash and so you have to be aware of the
fact that, obviously, when people are dealing with cash,
there are issues with security and there are temptations
to people, and so on and so forth.
Notwithstanding that, I think, had that picture been
evident, it might have sort of made people, certainly
would have made me, look at this in a slightly different
context.
Would other things that may have made you look at this
in a different context include, rather than focusing on
the number of subpostmasters that were presently
alleging faults being only 136, to look back at the
number of subpostmasters over the relevant period that
had alleged faults?
I think that's the point I'm trying to make. It was
quite difficult to frame the scale of the problem.
Or mention of the operation of a series of helplines
which recorded tens of thousands of complaints of fault?
That wasn't dealt with, clearly, in this context.
Did you know at the time that this note had been drafted
by the Post Office's communications man, Mark Davies?
If it didn't have Mark Davies' name on it, then I'm not
26
Mm.
"The issues surrounding the Horizon IT System have not
been resolved. Indeed, some of the MPs concerned have
written to me again following the Panorama programme
pressing the case for an independent investigation.
"The Government takes seriously the concerns raised
by individuals and MPs regarding the Post Office Horizon
system and the suggestions that there may have been
miscarriages of justice as a result of issues with
Horizon. The Government also recognises the commitment
that Post Office have demonstrated to resolving those
issues, including through creating a mediation scheme
and appointing independent investigators to scrutinise
the system.
"As you will be aware, there have been some three
years of scrutiny of Horizon and the Criminal Cases.
Review Commission is considering a number of cases which
have been brought to it by individuals, and the
Government cannot intervene in that independent process.
"As the sole shareholder of Post Office, the
Government wants to make sure that the Post Office
Network is successful and sustainable across the
country. We recognise that the Post Office is
a commercial business and we allow it to operate as.
such, but of course, we expect it to behave fairly and
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responsibly in doing so. I am therefore requesting
that, on assuming your role as Chair, you give this
matter your earliest attention and, if you determine
that any further action is necessary, will take steps to
ensure that happens.
"I look forward to hearing your conclusions and to
working with you to secure the future of the Post Office
Network."
Then Paula Vennells is copied in.
So this letter, if we go back to page 1, draws to
your attention that there were unresolved issues
regarding Horizon --
It does.
-- and that those unresolved issues include potential
miscarriages of justice?
Indeed.
This must be a slightly unusual letter to receive when
taking up a new job?
It's very unusual. I mean, I'm not a lawyer, obviously,
and I think, again, in the spirit of trying to be
helpful to the Inquiry, I've had sort of legal issues to
deal with but nothing, you know, on this sort of scale
that involves activities ultimately that have affected,
you know, people, contracts, going to jail and all of
that. I mean, yeah, it's just not usual in the
29
and perhaps, you know, in a computer system, means
different things to different people and I think you
probably had quite a few people pass through here. And
I think "systemic" became shorthand -- and I was
probably, you know, affected by this as much as anybody
to say, yeah, the system worked fine, and how do you --
what do you mean? It means that there are a few bugs,
they're not very frequent, they're discovered, and, you
know, so basically you've got something that's okay.
That sort of thing.
So you've got no recollection particularly now, as to
where you secured the belief from that Post Office had
a general assumption that there were no systemic issues
with Horizon and it was robust. Presumably, that would
include, however, the briefing note that Mark Davies had
drafted?
Yeah, I mean --
That must have --
I honestly can't -- you know, it's just hard for me to
reflect accurately on a generalised picture that I would
have had at the time. I have probably gone as far as.
I'm able.
You were presented with something of two pictures, then,
would you agree: one a general somebody's within the
Post Office that there were no systemic issues --
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slightest.
Your witness statement -- I'm not going to turn it up,
I'm just going to read from it -- says at paragraph 28:
"When I was appointed as Chair I was aware that
concerns had been raised about Horizon, including those
relating to Fujitsu. I do not believe that I had
detailed knowledge of the specific nature of the
complaints at the time and I do not believe I'd formed
any views on how to handle the Sparrow issues at the
time. However, as I describe below, Jonathan Swift QC
and Christopher Knight were being instructed in relation
to the Swift Review. My recollection is that there was
a general assumption within the Post Office that there
were no systemic issues with Horizon, and that it was
robust, and this is consistent with the statements made
publicly by Post Office at the time"?
Mm.
So, "My recollection is that there was a general
assumption within the Post Office that there were no
systemic issues with Horizon"; where did you get that
belief from?
I can't tell you. I'm looking back, you know, nine
years, trying to sort of assess how I felt at the time
and I think, of course, it comes back to this question
of: what do you mean by systemic? You know, systemic
30
Mm.
-- and the system was robust; and the Government saying
the issues around the Horizon IT System have not been
resolved, we, the Government, take seriously the
concerns that are being raised, and those concerns
include potential miscarriages of justice?
I think that's a fair description, yes.
When you joined the company, were there any specific
discussions that you can now recall -- this is in
October time -- about Horizon issues, whether as part of
an induction or otherwise?
I can't.
Were you provided with the report or reports by Second
Sight, either an interim report of July 2013 or two
final reports in 2014/15?
I can't.
Were any concerns raised with you upon joining, or
immediately thereafter, about the use by the Post Office
of aman called Gareth Jenkins, a Fujitsu employee, as
a witness in criminal prosecutions?
No.
When did you first learn about the issues that there
were -- I'm putting it broadly -- with the use of
Mr Jenkins as a prosecution witness?
Oh, I mean, some -- I mean, way past this sort of
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timescale. I mean, I'm talking -- yeah, I mean, I can't
tell you exactly when but this -- my sort of awareness
of the definitive situation, I think, where -- of
Jenkins and evidence and all of that, that was sometime
afterwards.
In the context of the Group Litigation, or even later
than that as part of the criminal appeals to the Court
of Appeal?
I can't tell you, to be honest.
What did you think upon receiving this letter?
Time to get moving, which I did.
What did you need to move to do?
To find somebody -- because I was certainly not equipped
personally to do this -- but to find somebody to carry
out what I was asked to do.
Was it always your intention from the start that another
person would conduct some form of exercise and that
person would not be you?
Yes, I think so. I think so because there were a lot of
issues here that I wasn't really familiar with. So
I'm -- again, I'm not a legal person, I'm not an IT
person and I'm not somebody who has got a lot of
experience dealing with this sort of, if you like,
non-commercial area. So my first instinct, yes, was,
you know, what sort of person could do this job?
33
'... please see below my starter for ten speaking notes
for your meeting with Tim Parker tomorrow ...
"Draft speaking notes ...
"[Post Office] can't influence or predetermine the
‘outcome of [Tim Parker's] ‘review BUT
"It's reasonable to assume that the findings will be
challenged unless they deliver what [James Arbuthnot]
wants (quashing of convictions and payments of
compensation -- see [James Arbuthnot's] attributed
comments about the CCRC review of [Josephine] Hamilton's
case)
"However, if the purpose of the review is to instil
confidence in BIS ... with the actions taken, it will be
creditable if it is:
"a. undertaken independently from the existing [Post
Office] team;
"b. logical in its approach; AND
“c. delivered against stated objective/s.
"This will help defend any criticism of the work
undertaken (eg that it's just another whitewash’), and
ideally curtail further involvement."
Just stopping there, did you understand that there
were two alternatives to what the review might seek to
achieve; (1) to actually deliver what James Arbuthnot
wanted; or (2) instilling confidence in the Department,
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Can we turn, please, to POLO0065606 and if we scroll to
the email at the foot of the page, again, an exchange
not involving you, from Rodric Williams; do you remember
him?
I remember the name, yes.
A solicitor in Corporate Services —-
Mm.
-- or specialising in Corporate Services within Post
Office Legal. To Jane MacLeod, do you remember her?
I certainly remember --
That's General Counsel?
I certainly remember Jane MacLeod, yes.
Mark Underwood, do you remember him?
The name rings a bell but not a big one.
And Patrick Bourke?
I remember Patrick.
Performing what function, do you remember?
He was in Jane's team. I don't recall specifically what
his role was.
In any event, this is a fortnight or so -- yes, it's
exactly a fortnight -- after that letter of
10 September, and it concerns speaking notes for a Jane
MacLeod and Tim Parker meeting on the 25th, so the next
day. Can you see that?
Mm-hm, mm-hm.
34
principally Baroness Neville-Rolfe?
Mm, I think we're talking about -- I mean, it's just my
take, looking at this, two different things, here.
I mean, if you read (2), it says:
"It's reasonable to assume that the findings will be
challenged unless they deliver what JA wants ..."
So that's an observation about findings, isn't it,
and, you know, finding an assumption that the review
would lead to those findings, whereas (3) is about the
purpose of the review. And it seems to me that it's,
you know, it -- one is in danger of sort of confusing
two things: one is what the review comes to; and the
other is what kind of review. Now, if you hadn't seen
paragraph 2, you might say, well, (3) seems, actually,
it's pretty reasonable.
Was the review to find out the facts, or was its purpose
to instil confidence in the Department?
So, again, if you read (3), it says:
"However, if the purpose of the review is to instil
in BIS (principally ...) with the actions taken ..."
So that's slightly different from just general
confidence. I would see that as -- you know, I could
read that genuine desire to ensure that whatever actions
were taken, they looked to be on the basis of the
a proper independent review.
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What was your purpose in commissioning the review?
So, I had a letter that asked me to look into these
various issues and my purpose, ultimately, was to find
somebody I felt qualified to do that and to agree with
them terms of reference which received to broadly tackle
the challenge laid down in the letter.
If we read on:
"5. Defining the review's scope will be key:
"a. What has [Tim Parker] been asked to do?”
Then over the page:
“If it's unclear, [Tim Parker] should now set out in
writing his understanding of the task (ie rewrite the
exam question).
"b, What will Tim Parker actually do?
"[Tim Parker] should state what he wants to achieve,
ideally by reference to a clear question, eg 'Has Post
Office Limited responded to allegations about the
integrity of Post Office's Horizon system and related
business processes in a manner appropriate for
a business which desires to maintain a reputation for
high standards ..."
Then there's a comment about a paraphrase of 3.4(e)
of the letter of appointment being "clunky":
"[Tim Parker] should be able to demonstrate that he
has addressed his stated aim by reference to a logical
37
Did you ever think that you would perform any role or
were you always of the view this was going to be
subcontracted out to some other person?
Yes, I felt that the task at hand, carried out by
somebody independent, because although potentially
I could be independent, what was quite important here
was to have not only somebody who was independent but
might have a few of the skills around the subject matter
that I lacked.
When you were engaging in discussions with, for example,
Jane MacLeod and Rodric Williams, did you realise that
they may themselves be implicated in the matter to be
investigated?
So I think that's a fair enough observation but here are
two things -- and I suppose quite a lot of this Inquiry
is dealing with this kind of issue, which is, if you are
board member, a chair or chief executive, to what extent
are you entitled to assume that your advice is coming
from people who are, first of all, qualified and,
secondly, competent? And my take, perhaps naively,
because, you know, the one thing that I found in most
businesses is that, although people have got different
points of view, they're generally trustworthy, is that
I was being given advice by people who were qualified on
that basis. And so was my -- you know, was I kind of
39
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method of investigation
"both elements should be matters for Tim Parker in
his sole discretion as Chairman, eg they are NOT for
negotiation with [Post Office, Baroness Neville-Rolfe or
the Department, et cetera]."
We can read (c).
Yes.
"6. Given the volume of material, [Tim Parker] is
likely to need ‘independent professional assistance’:
"He's entitled to this under [his] letter of
appointment ...
.. this could be:
"a solicitor ..
"a barrister ...
"a management consultant ...
"a former civil servant ..."
Then the pros and cons are set out for each of them.
This plan, it seems, was to have you carrying out
the review but assisted by some professional or
professionals; do you agree?
I'm not sure I'd draw that conclusion, actually. If we
go -- I mean, I'm not sure even if this piece of paper
makes it very clear how, as it were, the workload would
be divided between whoever was going to do the
assisting, as it were, and myself.
38
a little -- did I feel that this advice would somehow be
potentially tainted? I don't think I did feel that at
the time, if I'm honest.
Did the thought occur to you or is that a reflection
now, after the event?
It's a reflection after the event. I think, obviously,
after what has happened, it's likely to throw into doubt
quite a lot of the advice that was given and taken in
good faith. I mean, if you go back -- am I allowed to
do this?
Yes, you can do whatever you want.
Well, if you go back to the beginning of this note,
I just want to give you an illustration of that.
Yes, go back to page 1, please --
So --
-- and scroll down.
To move up -- scroll up a little bit -- a little bit
further. I'm not seeing what I wanted to show -- I'm
sorry, I beg your pardon. Just keep scrolling up.
When Mr Parker says scroll up, I think he means scroll
down.
I'm sorry. Yeah. So it's under the "What has TP been
asked to do?", I think. Number 5, if we move on to
that. Okay. So, you know, I mean, without the benefit
of hindsight and with no knowledge of this, you could
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read (b) as actually, you know, a pretty fair-minded
kind of view on what needs to be done. You should, you
know, just read it. It should state what he wants to
achieve, ideally by reference to a clear question, and
so on, and so on, and so on.
And another factor, I suppose, in all of this,
perhaps, you know, wrongly, was that Jane MacLeod joined
the Post Office, I think, in 2015. So, you know, I'm
not sure -- I sort of felt she was a kind of, you know,
she was a fairly new arrival, and she seemed competent,
tome. Yeah.
Are you saying that that first bullet point, "TP should
state what he wants to achieve, eg ...”
Mm.
-- and then the exam question is rewritten, you could
read that in a benevolent way now to be an appropriate
question to ask and to answer, or you could read it as
a reframing of the issue, so as not to look at the
substance of the issues but, instead, to look at the
response of the Post Office to the issues? They're very
different things, aren't they?
No, I understand your point and, with hindsight of
course, you might say, well, the problem with Swift was
that it was really just about the complaints.
I understand that. But, at the time, it seemed to me,
41
I should say this is 9 October 2015:
"I am grateful to Jane [Jane MacLeod's] for the
following brief summary ...
"Sparrow
"The Minister is under pressure to speak to various
parties including representatives Second Sight (forensic
accountants) and Sir Anthony Hooper (former Chairman of
the Working Group). We believe that as part of your
investigation you should meet with each of these
parties, and we have therefore recommended to the
Minister that she should not meet with them until (at
least) the conclusion of your enquiry (I have a call
with her this morning and will recommend that she should
await the conclusion of your enquiry before deciding
whether to meet with them).
"There are number of reasons why we are reluctant
for the Minister to speak to these parties (particularly
Second Sight) at this point:
"By speaking to these parties, the Minister
undermines the rationale for your own independent
investigation. Second Sight are active on social media
and we believe they would make public the fact of any
such meeting. This will only encourage expectation of
some form of government intervention. We now have the
majority of outstanding (non-criminal) cases scheduled
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you know, a reasonable place to go.
Is that distinction, the one that was just drawn, that
what was required by the Minister's letter was to look
at the substance of whether the system had integrity and
whether the prosecutions made on the basis of Horizon
data were safe, is a very different question to
examining the Post Office's response in the past to
allegations?
So I think -- I mean, again, with hindsight, you might
say, well, the Minister's letter was all about the
system and we should have just done an IT check and, you
know, a contract check and everything would have been
fine, but, actually, the way the Minister's letter read,
and the way I interpreted it, and felt we were
interpreting it appropriately, was to look into the
complaints and the issues raised by the complaints and,
essentially, you know, that's where Swift went.
Can we move forwards a little bit to the same part of
the narrative, but post-appointment, to POLO0117516.
Bottom half of the page, please, an email to you
directly from Paula Vennells, sent by her Executive
Assistant:
"Dear Tim
"While you have been away, two matters have arisen
affecting Post Office which you should be aware of.”
42
for mediation. Any expectation of government
intervention is likely to cause Applicants to withdraw
from the Mediation Scheme. I will send you an update
Then the email turns to another topic, like
a mobile, which is something, over the page, about
an entirely different issue.
Mm.
So Paula Vennells was seeking to delay the Minister from
meeting with Second Sight and Sir Anthony until after
your enquiry had concluded; did you have a view as to
this?
If I did, I can't recall it now.
Did you see the two issues as linked, Second Sight and
Sir Anthony, seeing Baroness Neville-Rolfe and the
conduct of your independent investigation?
Knowing me, probably better than anyone, I suppose
I would have at the time said to myself, "Look, this is
all part of a sort of, you know, the public sector type
how do you handle the Minister with this and that?” And
I would have said, "Well, if that's a concern and these
people have been here for some time and it's to do with
these people meeting the Minister, that's the Chief
Executive having a view". And it's probably something
that I would have said "I'm not" -- you know, I'm going
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to focus on what I'm doing and this isn't something I am
going to make a particularly, you know, big fuss about.
Thank you. That can come down.
Ultimately, the person that you asked to conduct the
review was Jonathan Swift QC, assisted by Christopher
Knight, another barrister. Why was a decision taken to
make this a lawyer-led review rather than something more
technical?
I suppose the answer to that is partly around the
framing of the review, back to your previous point about
responding to the complaints, and partly, I think,
because the issues were not exclusively technical and so
the -- what was a QC at the time ended up looking at
four strands to the problem, as it were.
Were the issues to be considered only legal issues?
Well, I think it's fair to say that, out of the Swift
Review, came some recommendations that were not
exclusively legal.
Looking at it at the beginning, rather than at the end,
did you think, when you were deciding, "We're going to
get a lawyer to undertake this task" -- never mind the
personality, in fact, involved -- that the issues
required to be examined were exclusively or
predominantly legal ones?
I don't think I could comment on whether I had
45
help, organise a good sort of report, yeah.
So it was more that they were independent and that the
faculties in order properly to investigate the issues,
rather than answer a series of legal questions?
I think that's a fair reflection.
Can we look, please, at the instructions to counsel.
POL00114270, page 3, please. These are the instructions
to counsel, in fact, initially to advise in consultation
‘on 8 October. So you'd done this quite swiftly,
ie within a week or so of joining the company?
I got on with the job pretty fast, yeah.
If we just see the authors of the instructions, by going
to page 15, foot of the page. We'll see that they are
co-authored by Jane MacLeod and Rodric Williams and,
again, I take it that you wouldn't have seen any issue
with lawyers who were themselves directly involved in
the underlying events being the ones to instruct
Mr Swift?
I've answered that question kind of before. I don't
think I'd have a different view.
In your witness statement -- I'm just going to read it,
rather than getting it up on the screen -- paragraph 40,
you say:
"It seemed to me that Post Office's General Counsel
understood the complexities of the task when identifying
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a specific view but --
Mr Parker, I'm just trying to pick away a little bit at
why a lawyer was chosen.
Okay.
It could be because there were legal issues to be
addressed --
Sol--
-- hold on -- or it could be, "I want somebody with
a first class mind who is independent", and it doesn't
matter whether or not the issues to be examined are
legal?
Yes.
Can you help us?
Yeah, I'll try. I think I had some CVs and, from what
Ican recall, Jonathan Swift had a very broad range of
experience and seemed to be a person who was used to
dealing with a number of different settings and
I believe, from memory too, that Christopher Knight had
quite a lot of experience in the sort of -- you know,
I wouldn't say IT world but he had done work in that
sort of area.
So I wouldn't say the QC was in the frame just
because he was a lawyer. I would say it was a mixture
of things. A lawyer is someone who was used to
investigating and somebody who could, I think, with some
46
suitable candidates. Jonathan Swift QC was a senior
barrister, he had worked as part of the Treasury Counsel
team prosecuting complex cases."
Did you think he was a criminal barrister?
I can't recall.
Presumably, if it's in your witness statement, that is
your current memory: that he was a member of the
Treasury Counsel team that prosecuted cases?
I presume so, yes.
If we go back, please, to page 3, please. There's
an introduction. We'll see a reference in paragraph 2
to the letter from Baroness Neville-Rolfe asking you to:
"... determine whether ‘any further action is
necessary’ ... to respond to the concerns about Horizon
raised by individuals and MPs. These concerns include
that [Post Office's] reliance on Horizon has resulted in
miscarriages of justice.”
Then scrolling down:
"With the assistance of [Post Office's] General
Counsel, Jane MacLeod, the Chairman considers this to be
a request ..."
This was to form the basis of the review, you'll see
the words "review" in brackets afterwards:
"To review the Post Office's handling of the
claimants made by subpostmasters regarding the alleged
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The Post Office Horizon IT Inquiry
flaws in its Horizon electronic point of sale and branch
accounting systems, and determine whether the processes
designed and implemented by Post Office to understand,
investigate and resolve these complaints ... were
reasonable and appropriate."
Looking at that now, can you see a shift from the
‘open question in the letter of 10 September from
Baroness Neville-Rolfe to a question that focuses
instead on the reasonableness of past processes?
I think, with hindsight, it does look that way. At the
time -- and again, I'm sorry to keep reminding you, but
there are a lot of things going on at the Post Office,
and this response to this request at the time seemed to
me to be not unreasonable.
Did you review the instructions at the time?
In what sense? Did I think -- did I -- I mean
I looked --
Did you look at the document we're now looking at?
Oh, I see. Was I aware what the review was about? Yes.
Yeah. And was I aware that these were the terms of
reference and this was the question that was going to be
addressed? Yes.
Is it right that you considered the request in the
Baroness Neville-Rolfe letter of 10 September to mean
what is in inverted commas and italics?
49
date. The Chairman therefore requires the assistance of
Leading Counsel to provide him with advice on:
"1, The scope of the review and how this is framed;
"2. The process by which the review should be
conducted (including what materials should be reviewed
and who should be interviewed); and
"3. The nature of his final report to the
Minister."
Again, looking at that paragraph there, these seem
to be instructions to a barrister to ask him to advise
you on scope of the review, how the review should be
conducted and what the nature of the report finally to
the Minister should be?
Mm.
You're not actually asking him to conduct the review?
Sorry, what's -- I'm being a bit dense here but --
Yes. You could have a set of instructions which say,
"Dear Mr Swift, we would like you to carry out
an independent review"?
Mm.
Or you could have a set of instructions which say, "Can
you provide assistance on the scope of a review and how
this is framed, the process by which the review is
undertaken, and the scope of his [ie your] final
report"?
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So, you know, with hindsight, one is apt to see that
there are forces at play here trying to subtly shift the
emphasis on things and, at the time, at the beginning of
this review, it seemed to me that -- and, again, I'm
probably not a person who is greatly experienced in
setting up reviews -- that a review with a sort of quite
a good general brief was capable of going after quite
a lot of different areas.
If you look at it, you know, out of that particular
group of references, you could see that a good
investigator would cover off most of the key points that
were at issue, and that was my sort of take. I think,
you know, because there's been such a terrible
subsequent situation, it's very easy to look back and
sort of dissect and say, well, could it have been this
or could it have been that? As things looked at the
time -- and perhaps I was a little naive about where the
advice was coming from but I've mentioned, you know,
I've talked about this -- it didn't look a bad set of
terms of -- well, not the terms of reference, but it
didn't look a bad sort of brief, if you see what I mean.
Thank you. If we just continue, paragraph 4:
"In order to be credible, the Review will need to be
carried out independently of the team which has been
managing [Post Office's] response to these concems to
50
I think both. I mean, the way certainly I think we set
this up was to say "Look, Mr Swift, we want to conduct
areview. We'd like you to conduct it and I will work
with you on the terms of reference". And I think --
I mean, I'm skipping ahead a little bit but, subsequent
to this, we met various people and, as a result of those
meetings, the terms of reference were put together.
Can we move forwards, please, to page 15 and under
“Instructions”:
"Leading Counsel is therefore asked to consider
these instructions ... prior to meeting [Post Office's]
General Counsel ...
"The aim of the meeting is to settle the Reviews
scope and agree a process for conducting, concluding and
reporting on the Review within the desired time frame.
A further meeting will then be arranged at which Leading
Counsel would present this scope and process to [Post
Office's] Chairman for his consideration."
By this time, was it always envisaged that Mr Swift,
as well as advising on the process issues, would himself
conduct the review?
I think -- and, again, I'm looking back nine years
ago -- that my starting point on this, as I explained,
was that I'm probably not the person to actually conduct
the review, therefore, you know, it was going to be this
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individual who would actually conduct the review on my
behalf. And that made a low of sense, if you think
about it, because I had a lot of other things to do and
we could actually get the undivided time and attention
of a very well-qualified and senior barrister with his
assistant to go and do the work, essentially.
MR BEER: Thank you.
Sir, it's just coming up to 11.15 now. Can we take
the first morning break between now and 11.25?
SIR WYN WILLIAMS: Yes, of course.
MRBEER: Thank you very much, sir.
THE WITNESS: Thank you.
(11.13 am)
(A short break)
(11.28 am)
MR BEER: Good morning, sir. Can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
MR BEER: Thank you very much, sir.
Before we move on, Mr Parker, to the review report
produced by Mr Swift and Mr Knight itself, can I deal
with an event that happened or may have happened in
between the commissioning of the review and the
production of the report in February 2016?
You've explained to us already your desire, in
particular in the light of Baroness Neville-Rolfe's
53
Q. He says:
"On 15 September 2015, lan [lan Henderson] and
I went to Mr Parker's office there we met with him and
Jonathan Swift."
Do you remember Mr Swift being there?
A. Not precisely.
Q. "The meeting went on far longer than the pre-booked one
hour, Mr Parker having insisted that we stayed longer to
answer more questions.”
Does that trigger any memory?
A. No, but I think it's probably reflective of the fact
that, you know, I wanted to listen to these guys. Yeah.
Q. We have got some emails of 15 December, circulating
within Post Office, saying, "They're still in there,
they're still in the meeting, it's going on longer than
anticipated", and you were going to miss your next
meeting?
A. Okay.
Q. He, Mr Warmington, says:
"We held nothing back at that meeting. Indeed,
[Mr Henderson] later characterised it with the words 'We
gave him both barrels’. In practical terms that meant
that we went through with Mr Parker and Mr Swift all of
the thematic issues that we had covered in our final
report back in April 2015."
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letter of 10 September 2015 to find out information
about Horizon from a wide range of sources.
Mm, mm.
Do you recall meeting Ron Warmington and lan Henderson
of Second Sight in your office in December 2015?
I know I met them. I don't recall the substance of that
meeting, if I'm honest.
Can I just read you what Mr Warmington has said about
it. This is paragraph 85 of his statement, he said:
"In early December 2015 I received a telephone call
from the office of the then relatively new Chairman of
the Post Office, Tim Parker. He invited me to come to
his office to help get him up to speed on the Horizon
matter."
Does that sound likely to be correct?
Likely.
Thank you:
"I later learnt that Baroness Neville-Rolfe had,
following a meeting that lan Henderson and I had had
with her, suggested to Mr Parker that he should meet
with us."
Again, can you help us whether that is likely to be
correct, ie the idea of the meet came from Baroness
Neville-Rolfe?
Possibly.
Does that trigger a memory in you that they were
particularly forceful in what they said to you, ie "We
gave him both barrels"?
I'm sorry not to be of more help but this is nine years
ago: the answer is no.
He continues:
"We made it perfectly clear that the rebuttal report
that Post Office had immediately issued alongside our
final report was utter nonsense and that were he to be
deceived into placing reliance on it or, worse still,
endorsing it, the consequences would likely be very
dire."
Do you remember a meeting of that type, ie you had
two gentlemen who had been independent investigators
coming in and saying words to the effect of "The Post
Office rebuttal report" -- ie the rebuttal to their
final report -- “ought not to be relied on"?
I don't. I think, again, my recollection of this
meeting is just not -- I just don't have a recollection
of it precisely.
Do you recollect a meeting in which it was said that if
he -- ie you -- was to place reliance on what the Post
Office was saying in its rebuttal report, the likely
consequences would be very dire or dire?
I think all I can tell you -- because, you know, the
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question has been asked three times, more or less -- is
that I think Jonathan Swift and I would have listened to
what we were told and he would have taken away a lot of
the remarks that were made by Ron and lan.
I don't think you're in a position to say that what
Mr Warmington has said is incorrect. If he had said
those things, what would be the consequences for you?
I think my mindset at the time was we're in the early
days of putting together this review, I've heard what
these guys have got to say and we'll take the thing
forward. It's not my, you know -- I don't think I would
have jumped to the conclusion that everything they say
is indubitably correct; I think I would have said "Well,
let's do some more work", which is what actually
happened.
le to summarise, you would have seen this as a matter
for Mr Swift to bring into account, rather than for you
to take any particular action?
I think that's slightly false contrast. I think, at
that stage, bearing in mind that I was going to review
the eventual output of Mr Swift, he certainly would take
away the comments of Second Sight, yes.
What would you therefore -- if my suggestion involved
a slight false contrast -- going to do with what you had
been told?
57
when it came to be put together, certainly did not take,
if you like, the house view as the only version of
events. I think quite a lot of the comments of Second
Sight were incorporated into the review itself.
Let's look at the review itself. POLO0006355. I'm not
going to go through every paragraph of it, not least of
which because it's 66 pages long and that wouldn't be
productive. If we could look just a little further
down, we'll see the date of 8 February 2016.
If we go forwards to page 2, and just pan out
a little bit, we will see the structure, the overall
structure, of the report, after some introductions and
passages about the scope of the report. It's divided
into chapters concerning: Post Office, subpostmasters
and the Horizon system; the complaints themselves; the
criminal prosecutions; the Horizon system; support
provided to subpostmasters; investigations, ie the past
scheme investigations; and a summary of recommendations.
If we go forward to page 3, please, and if we just
look at the end of paragraph 2, four lines up:
"These matters have been the subject of
consideration and investigation by and on behalf of
[Post Office] on a number of occasions. The purpose of
this review is to consider whether any further action
could now reasonably be taken by [Post Office] to
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I think my mindset, at that point, was to allow Mr Swift
to do the work and produce the report. I don't think
I took out of that meeting -- because actually, as far
as I'm aware, I didn't do anything immediately --
I don't think I took out of this meeting, "I've heard
from these people, I'm about to go out and do
something"; let's do the report and let's see where it
goes.
le the meeting was held in the context of somebody
undertaking a review and the person undertaking the
review ought to pay regard to what was said, rather than
you do anything independently?
I mean, honestly, I think this is a bit of a hindsight
characterisation of a meeting at the time, where I was
quite early still in the business and would have just
been doing a lot of listening. So I'm not sure, out of
it, you know, I -- yeah, I just moved on with the
review, yeah.
I mean, it can't be every day that you have independent
investigators or consultants, management consultants or
forensic accountants come in, and if they're correct in
what they say, tell you, as a chairman, that you
shouldn't be relying on the public facing document that
your executives have put out?
No, and I think it's fair to say that the Swift Review,
58
address the matters raised by the [subpostmasters]."
Paragraph 3, five lines up from the bottom:
"The Legal Department of [Post Office] has been the
source of most of the information provided to us, but we
have determined what information should be provided."
When the review was being undertaken, did you have
a running commentary essentially on it, or did you set
the terms of reference as we've seen and then wait for
the review to report?
I think it -- I mean, again, without wanting to deliver
a definitive view, I think there was a sort of ongoing
discussion. I don't think it was a sort of, you know,
“Here's the terms of review, give me a ring in five
months’ time", or whatever. You know, I think there was
some kind of ongoing discussion.
You certainly received a draft report in --
I did, yeah ~
-- January?
-- in January, yeah.
Did you know that the Legal Department was the source of
most of the information provided to Messrs Swift and
Knight?
I think I probably did. Yeah.
If we go over the page, please:
"The purpose of this review was originally described
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in the following terms", and then we see the quote from
the briefing paper we read earlier:
“We have been guided by this. But we have
concentrated on whether any further action is reasonable
and necessary in respect of these issues. This has
highlighted two principal questions:
“What has been done in the 2010-2015 period?
"If there are any gaps in the work done, is there
further action that can reasonably now be taken?”
Over the page, please, and look at paragraph 10.
Having set out, in summary, the documentation that the
authors have reviewed, they set out in paragraph 10
those with whom they met: Lord Arbuthnot; Second Sight;
Deloitte; Fujitsu; Angela van den Bogerd; Mr Seller,
Ms Dickinson; and Ms Hailstones and Ms Alexander.
Then, if we go forwards, please, it's getting more
to the substance, to page 34. You can see on pages 34
and 35 the author's view on one of the issues, namely
the sufficiency of evidence to bring charges of theft.
Mm, mm.
I'm just going to read these passages. The allegation:
“As we understand it ... is that [Post Office] has
too readily brought a charge of theft, which is said to
be more serious than false accounting, with the aim or
effect that the [subpostmaster] is pressurised into
61
Over the page:
"We note Brian Altman's advice of 8 March that it is
not a helpful question to ask whether a theft and false
accounting are offences of equal seriousness, both being
dishonesty offences with a maximum sentence of seven
years' imprisonment, because the seriousness is
dependent on the nature of the specific allegation
rather than the charge per se.
“We entirely accept that the decision to plead
guilty is a matter for the defendant alone. Any
concerns they have about the legal advice they received
at the time is a matter only the defendant can pursue
and is not the responsibility of [Post Office] ... it is
always open to the defendant to challenge the
sufficiency of the evidence disclosed to him or her and
seek to have that charge dismissed.
"[Post Office's] position is that its prosecutorial
decisions are always taken in accordance with the
[Code], which requires that there be sufficient evidence
to provide a realistic prospect of conviction, and ...
must be in the public interest. [Post Office] that is
referred us to the Cartwright King disclosure review
exercise, noting that Cartwright King also expressed
views in their advice as to whether [Post Office] should
oppose any appeal brought, suggesting that they must
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pleading guilty to false accounting in the hope that the
theft charge is dropped, and because a theft charge
would more readily enable [Post Office] to recover its
losses. We understand there are approximately 18 scheme
cases in which this, or something similar, occurred. We
have also read the full trial transcript [of] Seema
Misra in which a jury convict the defendant of theft
(following a guilty plea to the charge of false
accounting).
"Whether [Post Office] had sufficient evidence to
bring a charge of theft alongside charges of false
accounting is an accusation raised by number of scheme
applicants, as well as by Lord Arbuthnot ... it has also
been a matter raised by Second Sight
"102. We are aware that the suggestion has gained
particular traction in scheme case M0335 ... In this case
certain documents in the prosecution file indicated that
the initial [Post Office] Investigators could not find
evidence of theft
This the case of Josephine Hamilton, I should say.
Mm, mm.
"... (although there was clear evidence of false
accounting), but theft was nonetheless charged. We have
seen those documents and have noted the absence of clear
documented rationale for charging theft.”
62
therefore have considered the evidence involved. [Post
Office] has also explained to us that because of these
points, and because any review would be carried out with
the benefit of hindsight, it will not be an appropriate
course of action to review now the prosecution files to
reconsider the sufficiency of evidence issue.
"106. We do not agree. We have reached the view
that this issue is one of real importance to the
reputation of [Post Office], and is something which can
feasibly and reasonably be addressed now. It is clear
that it is not an exercise which has been carried out so
far, and Cartwright King were not asked to consider the
sufficiency of the evidence when undertaking their
disclosure review."
Skipping a sentence:
"The allegation that [Post Office] has effectively
bullied [subpostmasters] into pleading guilty to
offences by unjustifiably overloading the charge sheet
is a stain on the character of the business. Moreover,
it is not impossible that [a subpostmaster] would have
felt pressurised into pleading guilty to false
accounting believing it to be less serious when they
might not otherwise have done so; the phenomenon of
false confessions is well known."
I'm going to stop reading there.
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That's quite strong language, isn't it?
Quite strong, yeah.
Is this is an example of what you mentioned, I think, in
passing earlier, that the review did not universally
take on board the Post Office's position?
I think that's right and I think, in a way, because, as
we know the aftermath wasn't necessarily satisfactory,
but at the time, it was a good -- for me, a confirmation
that to have a qualified barrister look at these things
produced a pretty good analysis of the issue, and its
impact, and as -- if we go further, obviously,
recommendations about what to do about it.
You said there that the aftermath wasn't necessarily
satisfactory, we know. Can you tell us what you are
alluding to there?
Alluding to? Well, I don't want to sort of prejudge,
you know, the discussion but, you know, Swift, in my
view, was quite a good report and contained quite a lot
of good material and, as the litigation unfolded, as we
will discover a few months down the line, effectively
Swift was stopped and repurposed.
So this component of Swift, actually -- you know,
again the result with hindsight might not have been
satisfactory, because its scope of investigation was
limited but, you know, Altman did his review and
65
those circumstances, that counsel review the prosecution
file in such cases to establish whether, applying the
facts and law applicable at the relevant time, there was
a sufficient evidential basis to conclude that
a conviction for theft was a realistic prospect such
that the charge was properly brought."
I think you'd agree, they are sensible
recommendations, arising directly from the passages that
we've just read?
Yeah, yeah.
Can we turn then to page 43 at the foot of the page:
"125. ... the Horizon system does occasionally
suffer from bugs which have caused losses in some
branches. Those bugs have been generic in the sense
that they have the potential to affect any branch,
depending on how it is structured. It is often the case
that those bugs are identified when [a subpostmaster]
draws the attention of [Post Office] and Fujitsu to
an odd situation which she cannot explain and which
appears to have had caused a discrepancy. We were told
by [Post Office] that when carrying out their
investigations into scheme cases, investigators were
looking out for unusual or unexplained patterns of
transactions which might have required further technical
examination by Fujitsu to confirm whether there was
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produced his report. So, you know, from the perspective
of "Here's the problem" -- which is, you know, charging
theft potentially with the pressure to get people to own
up to false accounting -- I think Swift more or less got
that but it didn't -- you know, again, it translated
into the Altman work.
So this component, I think, again, moved the thing
forward as you would want it to be moved forward.
Can we turn to the recommendations of Mr Swift's report
and I'm not going to, in the way I've just done there,
track the foundation for the recommendation into the
recommendation on every occasion. That was just one
example.
Yeah, yeah.
Page 38, then, please. The recommendations arising from
that section of the report are:
"(4) [in bold] Legal advice be sought from counsel
as to whether the decision to charge [a subpostmaster]
with theft and false accounting could undermine the
safety of any conviction for false accounting where (a)
the conviction was on the basis of a guilty plea,
following which and/or in return for which the theft
charge was dropped, and (b) there had not been
a sufficient evidential basis to bring the theft charge.
"(2) If such a conviction could be undermined in
66
a wider bug. [Post Office] told us that no instance
arose and Fujitsu were not asked to look at the records
in any case. Fujitsu confirmed to us that they did not
carry out any analysis of scheme records.
"We consider that there is the possibility that
an alternative approach to the transaction analysis
would have provided greater certainty that there was no
bug which had affected some of the scheme branches. We
take this view because [Post Office's] approach was
necessarily ‘bottom up’, in the sense that it started
from and focused on the specific circumstances of the
branch, looking at the transaction logs where necessary
to review a particular complaint, be it general or
specific."
Skipping over:
"A different, but complementary, approach would have
been a ‘top down ‘analysis of the transaction logs of
the scheme branches undertaken by Fujitsu or
an independent qualified party to search for patterns of
unusual behaviour in individual branches, and across
branches, on a purely data-driven analytical basis which
might suggest a wider problem, which could then be
cross-referenced with the branch fact-specific work
carry out by [Post Office] ...
"In our meeting with Deloitte, it was confirmed that
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this type of exercise was something they would have
expected could be carried out across the relevant
dataset (including non-Scheme branches as a control) to
look for oddities or reconciliation errors. We are
mindful that external organisations are more likely to
suggest possible sources of work they could carry out,
but the suggestion aligns with our own view ... which is
at least potentially useful to rule out more
comprehensively the possibility of a system bug,
affecting some scheme cases."
Again, a series of observations or a views that you
would consider reasonable?
I think I probably did at the time, yeah.
If we go forward to 53 -- I should have stopped off on
the way at 51, at paragraph 145, just in passing:
"It seems to us that the Deloitte documents in
particular pose real issues for [Post Office]. First,
both the existence of the balancing transaction
capability and the wider ability of Fujitsu to ‘fake’
digital signatures are contrary to the ... assurances
provided by Fujitsu and [Post Office] about the
functionality of the Horizon system. Fujitsu's comment
we quote above seems ... to be simply incorrect, and
[Post Office's] Westminster Hall Response is incomplete.
To the extent that [Post Office] has sought to contend
69
let's see and let's try and understand this theoretical
ability, how practical is it, in fact, to remotely
access accounts? And that was, you know, what I took
away from this, I suppose.
Did you take away from the fact that Fujitsu and Post
Office's public facing comments had been incorrect and
incomplete?
Yes, I mean, that's something -- I've looked back at
this and I suppose my reaction at the time was
essentially to Swift -- and we'll get on to the legal
privilege thing in a minute -- was, you know: this is
a report, let's -- there are some recommendations, let's
actually get to the recommendations and then my hope and
intention was to, you know, have the outputs of the
report discussed.
Now, we didn't get there, much to my regret, and
I think I was probably a little optimistic about how
quickly we could get on top of some of these issues and
then properly correct the issue, I suppose. But, you
know, it was something I was aware of and, with
hindsight, perhaps we should have jumped up immediately
and said, "Look, you know, there is a theoretical
possibility of remote access". And I was assuming, as
it turned out probably quite wrongly, that we could do
the work on Swift and then say, yes, there is remote
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that branch data cannot be remotely ‘amended’ because
a balancing transaction does not amend existing
transactions but adds a new one, we do not consider this
is a full picture of Horizon’s functionality. The
reality is that a balancing transaction is a remotely
introduced addition to branch records, added without the
need for acceptance by the [subpostmaster], which
affects the branch's balance; that is its express
purpose. [Post Office] has always known about the
balancing transaction capability, although the Deloitte
report suggests the digital signature issue is something
contrary to [Post Office's] understanding.”
Just stopping there as I went past, when you
received the report, did you know about the remote
access issue?
No, I don't think so. I can't be sure but I don't think
\ did.
Did you know that there was a concern that either the
Post Office and/or Fujitsu had a facility remotely to
access branches?
I don't think I did. You know, the remote access issue,
of course, has been quite a big element of this whole
set of problems, and I think my take on it was, in
theory, there is a remote access problem and -- you
know, we'll get to the recommendations in a moment --
70
access and it is theoretically possible, but
practically, it either is likely, less likely, or very
unlikely. That was, I think, where I got to with it.
Where did you get information from that remote access
was only theoretically possible?
I think that's what was said here, essentially. That
was what I took away from it, anyway.
In any event, let's turn to the recommendations on this
part of the report by looking at page 53:
"We recommend ...
"(3) [Post Office] consider instructing a suitably
qualified party to carry out an analysis of the relevant
transaction logs for branches within the scheme to
confirm, insofar as possible, whether any bugs in the
system are revealed by the dataset which caused
discrepancies in the accounting position of any of those
branches.
"(4) [Post Office] instruct a suitably qualified
party to carry out a full review of the use of balancing
transactions throughout the lifetime of the Horizon
system, insofar as possible, independently to confirm
from Horizon system records the number and circumstances
of their use.
"(5) [Post Office] instruct a suitably qualified
expert to carry out a full review of the controls over
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and use of the capability of authorised Fujitsu
personnel to create, amend or delete baskets within the
sealed audit score throughout the lifetime of the
Horizon system, insofar as is possible.”
Those two recommendations, you'll see, are speaking
about the lifetime of the Horizon system. Did you
understand them at the time to mean literally since
Legacy Horizon had started --
Yeah.
-- ie about 2000?
I can't tell you. Of course, with hindsight, the
lifetime thing actually gets to be quite critical
because it turns out that most of the real issues that
people experienced were with Legacy Horizon, but I'm not
sure that really, you know, that really came through to
me as a big thing at the time. Yeah.
[Post Office] seek specialist legal advice from
external counsel as to whether the Deloitte reports, or
the information within them concerning balancing
transactions and Fujitsu's ability to delete and amend
data in the audit store, should be disclosed to
defendants of criminal prosecutions bought by [Post
Office]. This advice should also address whether
disclosure should be made, if it has not been [made], to
the CCRC."
73
"[Post Office] commission forensic accountants to
review the unmatched balances on [Post Office's] general
suspense account to explain the relationship (or lack
thereof) with branch discrepancies and the extent to
which those balances can be attributed to and repaid to
specific branches."
Again, does that fall within the same category that
we just discussed, reasonable and grounded in --
Reasonable and grounded, I agree.
There's one that I've missed out, (7) I think. If we go
forward to page 66, number 7:
"[Post Office] should cross-reference specific
complaints about misleading advice from NBSC call
handlers with the possible employees who provided that
advice and consider their personnel files, where
availability, for evidence at to the likelihood that the
complaint may be well founded.”
So if we just go back to 65 and pan out. The
recommendations 1 to 5 are collected together in
a summary and then, over the page, we see (6), (7) and
(8) collected together.
Overall, would you agree that there was a wide range
of work that required to be done arising from the Swift
Review?
Yes, I think we were talking earlier about, you know,
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Again, upon reading this, you wouldn't have had any
reason to reject the recommendations?
No.
They seem reasonable and sensible --
They seemed reasonable and sensible, yes.
-- and they're grounded in the body of the text --
Yeah.
~- that preceded them?
Absolutely, yeah.
If we go forwards, please, to 64, and paragraph 173:
"There is one issue which potentially relates to the
scheme cases but which has not, so far as we are aware,
been the subject of any specific analysis. That issue
was the one raised by Second Sight in their Part Two
Report ... and relates to the handling by [Post Office]
of unmatched credit balances in its own suspense account
(or similarly named account) in respect of third party
clients (such as Santander or Bank of Ireland). The
point Second Sight raise is that where there are
significant sums in unmatched balances, it is possible
that at least some of that money would reflect
uncorrected transaction discrepancies in particular
branches. We consider that this illogically possible,
and is at least worthy of express investigation and
clarification. Accordingly, we recommend that:
74
the terms of reference and whether it was correctly
structured and -- but, actually, I feel with hindsight,
again, that Swift was not a perfect piece of work but it
wasn't a bad piece of work, and it yielded some good
recommendations.
Would you agree that the review raised significant
reputational issues for the Post Office in the light of
what it uncovered and the recommendations that it made?
I think there were some issues that definitely needed
addressing pretty -- yeah, pretty urgently.
What about my question, Mr Parker?
Yeah, no, I think that's a fair -- these are all matters
with some reputational impact, potentially.
Significant reputational issues for Post Office, was how
I formulated it, if this was publicly disclosed?
Yeah, I'm not going to argue about the language. These
are important matters, yeah.
Sometimes it's important, though, the language.
Yes, no, I think you're absolutely right. Let's say
reputational issues, yeah, matters.
You had a decision to make as to with whom the report
should be shared, correct?
Yes.
When the report landed on your desk -- in your inbox,
more likely -- did you have a view as to with whom it
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should be shared, if anyone?
I -- that's a very interesting question. So to go back
into the history of this thing, it was always envisaged
that the Swift Review would be legally privileged and
I think that was explained -- I haven't got the papers
to hand but, somehow, it was envisaged that it would be
a report from a QC -- at the time -- and it would be
legally privileged.
Just stopping there, the report on its face is not
marked as privileged, is it?
No, no.
The report does not say that it's been provided for the
purpose of any ongoing litigation?
It doesn't, but my --
It doesn't say that it was provided for the purposes of
obtaining legal advice, does it?
No, but whatever was actually on the report, and, you
know, I'm not looking at whether it's got ~
I understood, and was advised by General Counsel, that
it should be legally privileged and I believe that was
understood also by civil servants at the time as well.
I may be wrong but, generally, it was understood that
this would be a piece of legally privileged work with
a view, once the recommendations had been carried
forward, to being shared more widely. That was my
77
recollection is different from Mr Parker's. Although
I agree that I discussed privilege and confidentiality
when I met him, my recollection is that the Senior
Independent Director, Mr McCall, asked a question at
a board meeting as to whether the Board would be briefed
on the findings of the Chairman's review. I believe
that, as a result of that question, I provided an oral
briefing to the Board as to the scope and findings of
the chairman's review, as well as summary of the further
work being undertaken following the Chairman's review.
Although I've not seen any documents which indicate that
the full report was circulated to the Board, my
recollection is that I advised the Board that the full
report was available on request."
Indeed, that's what she put into her witness statement
and I can only say that there's -- I know which
particular document it's in but she advised that the
report should be four copies, I think, none saved to
a hard disk, or whatever, and it was clear. I'm sure
she told me, and my recollection I don't think is wrong,
that this was going to be a legally privileged report
and that's why it was restricted to four copies only
that were held within the Legal Department.
Her comment -- I mean, the other point to make,
I suppose, is because this is of interest, is that, you
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understanding of it.
You said that there was an assumption. Who held that
assumption?
When you say
An assumption that the report would be legally
privileged, was one of the things that you said. Who
held that assumption?
That's quite an interesting question and I'm not sure
I've got a ready answer to it. AllI can tell you is
that my recollection, and certainly what I understood,
was that the report would be legally privileged. That
was the advice that I received at the time.
Was that advice orally or in writing?
I can't confirm whether it was oral or in writing but
I certainly understood that to be the case.
Who gave you the advice?
The General Counsel.
Jane MacLeod?
Yes.
Jane MacLeod, in her witness statement -- no need to
turn it up, it's WITN10010100 at page 100, paragraph
184 -- says:
"I am aware from open source material that Tim
Parker has said that I had advised him not to brief the
Board on grounds of confidentiality and privilege. My
78
know, there was no intention to hide the report as such.
People knew about the report but it was a legally
privileged document. And, again, you know, it's one of
my regrets is that I got that advice and I took it, and
that's essentially how the report was conceived.
So it was advice from the General Counsel, Jane MacLeod,
directly to you, the --
Yes, and that sort of privileged --
Sorry, if I could just finish the sentence.
Yes, I beg your pardon.
That the report, the Swift Report, was a legally
privileged document?
That was certainly my understanding at the time and
I believe, in communications with UKGI, it was also made
clear --
We're going to come to that in a minute.
Yeah.
For you, what were the consequences of being advised
that the report enjoyed legal privilege?
So --
What did that mean for you?
Yeah, so look, here I am. I've had this report
commissioned, right. I've got no history of -- you
know, I wanted to get some kind of result from it. But
then I get this advice and, as I understood it at the
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time, the report would be legally privileged, the GC and
her team, with others, would take forward the
recommendations, and when the recommendations were
completed, the outputs would then be shared. That was
my sort of view and that's what I expected to happen.
The fact that you were advised that the report was
legally privileged, what did you understand as to who
that prevented you from sharing the report with?
Yeah, I think, again, this is one of the slightly
unsatisfactory elements of the whole thing, is that
felt, erroneously, probably, it turns out, that
legally privileged or legal privileged meant that the
report, effectively, was circumscribed to only the
people who were involved in the legal process.
Was that something that you were advised by Ms MacLeod
or was that something which you assumed on the basis of
being told the report is privileged?
I can't tell you for sure but I think the fact that
I was told that the report should only be confined to
four copies, I certainly took away from that that legal
privilege implied that it was a report that would be
held in a very tight knit -- tightly knit group of
people, and these were of the four people and they were
all people who worked in the GC's department.
In practice, did that understanding -- I'l call it ~
81
if that was the issue, perhaps could have been shared.
And it's just one of those things that, at the time,
I was advised and I took the advice. It's one of the
unfortunate aspects to all of this, is the extent to
which perhaps advice taken from specialists turned out
to be something that might have been tested or reviewed
ina different way.
I'll ask you the direct question: did Ms MacLeod tell
you that the fact that the report enjoyed privilege
prevented you from disclosing it to the Board?
That was my understanding.
Did she advise you directly?
I can't confirm one way or another. All I can do is
look back and say, look, what possible motive would
I have had at the time from hiding this report from my
fellow Board members, other than receiving advice that
I shouldn't share it with my fellow Board members? Bear
in mind, I had no axe to grind on this. I had no
vested -- any vested interest in trying to protect the
Post Office or whatever it had done. It was simply the
advice I received and I followed it.
As part of the quote from Ms MacLeod's statement that
I read you, she said:
"My recollection is I advised the Board that the
full report was available on request."
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that you reached, prevent effective discussion from
taking place at the Board of the Post Office if members
of the Board could not see the report?
So I think, whilst being aware of the report, I felt it
certainly did, yeah. I mean, my view at the time was
that -- and perhaps this was somewhat naive -- that the
recommendations would come out pretty quickly and we
would be able to talk about, you know, the report as
completed. But that didn't happen unfortunately.
Did you understand, from what Jane MacLeod advised you,
that you were prevented from sharing the report with
other Board members?
I think that was my understanding, yes.
What did you understand, if you did understand it, to be
the difficulty in sharing a report with other Board
members who themselves would owe a duty of
confidentiality and confidence to the company?
I thought -- and again, perhaps it betokens a certain
lack of experience in this area -- that legal privilege
meant a restriction on the circulation of the report,
and with, you know, what I've read subsequently, was the
report meant for me personally and was it going to be
legally privileged for me personally? Could we have
shared it? I wish we had, in a way.
And I think, you know, a suitably redacted version,
82
Were you present at any Board meeting at which they
were told, "If you want the report, you only have to
ask"?
Well, I presume that, if that's what Jane MacLeod has
said, and she attended Board meetings, and I can only
think of one Board meeting that I missed in the whole of
my time at the Post Office, I probably would have been
there, yes.
Can you recall that being said? It's not reflected in
any of the minutes?
I can't.
What was your understanding as to the fact that the
report was said to enjoy legal privilege, insofar as
distribution of a copy of the report or sharing the
contents of the report with the Minister or Government
was?
I think that was a similar concern and I should say that
the legal privilege thing -- I'm now beginning to
recollect it a little bit more -- was around the Freedom
of Information mechanism. So we had a UKGI Board
member, and one of the concerns was that things that
were distributed that got into the hands of,
essentially, BEIS civil servants, in one form or
another, potentially could be disclosed as part of
a Freedom of Information request. And that whole sort
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of consideration coloured the discussion around Swift
and how it was explained, and how it was kind of
discussed at the time.
Can we look, please, at POL00103108. An email before
the final report is available, it's dated 22 January
2016, between Jane MacLeod and you:
"Tim
"Following our call with Jonathan Swift today, and
ahead of your meeting with Baroness Neville-Rolfe on
Tuesday, I have summarised our progress."
I'm going to skip over, for the moment, "How to take
forward his recommendations", and just look at "Briefing
to the Minister”, if we scroll down:
"We also discussed with Jonathan whether there were
any limitations from his perspective on the content of
your briefing to the Minister. Jonathan confirmed that
there were no limitations from his perspective, although
he noted that if a physical or electronic copy were
provided, this could result in a loss of legal privilege
in connection with the document, recognising that in the
absence of privilege, the report could be disclosable
under a [Freedom of Information] request.”
Is that what you were just referring to?
Yeah.
“Accordingly, our recommendation is that you provide
85
limitations from his perspective", on the content of the
briefing but, "if a physical or electronic copy were
provided this could result in the loss of legal
privilege", did you understand that a choice fell to be
made from that advice?
Yes. I think I probably, to a certain extent -- well,
no, actually, looking at it, I think what I understood
was that something that was physical, if it was -- if
things were put down and written physically or typed
physically, that could be subject to a loss of legal
privilege. And I suppose, perhaps from that, I sort of
conflated, you know, what could I say to the Minister?
I don't, you know, did that mean I could only say to her
what was in a piece of paper? I don't know.
More specifically, did you understand that you had
a choice to make: I can either brief her orally along
the lines set out in those four bullet points; or I can
give her a copy of the report, and that may result in
a loss of privilege?
My recollection, for what it's worth, is that I think we
all, including the Minister's civil servants, were kind
of not assuming, but felt that this was going to be
a document that had legal privilege. So, with
hindsight, you're right, there was potentially
a decision to be made, but we fell into the "It's
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a verbal briefing to the Minister that in response to
the question 'Was there anything further that [Post
Office] should do?’:
"[1] Jonathan has made a series of recommendations
which have been accepted by [the Post Office].
"[2] These recommendations will be followed up as
soon as possible.
"[3] In relation to 2 of the IT related
recommendations, the scope of work required to discharge
the recommend is uncertain, and we will therefore
commission work to determine whether the work is
feasible.
"[4] We will provide you with regular updates on
progress of this work, and you will therefore be able to
provide updates to the Minister in future briefings.
"Once the work is completed, we will need to
consider whether the Minister requires anything in
writing from you and whether any such document would be
made publicly available."
So this is a reflection of a meeting that I think
Jane MacLeod had, or a call that Jane MacLeod had, with
Jonathan Swift, and advice as to how you are to brief
the Minister. Correct?
A. Looks like it, doesn't it? Yeah.
Q. The sentence, "Jonathan confirmed there were no
86
legally privileged so we'll do the verbal briefing
instead".
Q. Did you realise at the time that there was a choice --
I don't think so, if I'm honest.
>
Q. --ie the fact that it was said to be legally privileged
dictated the outcome or the treatment --
A. I'm afraid a lot flowed from that, you know, it was
a legally privileged document, therefore we had to speak
around it, and how it was summarised on paper needed to
be thought about, yes.
SIR WYN WILLIAMS: = Can I ask you, Mr Parker, at the time,
was there any discussion about who enjoyed the privilege
if privilege existed?
A. Sir Wyn, I can't, no.
SIR WYN WILLIAMS: Because it strikes me at least -- and I'm
not pretending I'm an authority on this -- that there
are only two possibilities, aren't there: either you
personally enjoyed the privilege or Post Office Limited
enjoyed it?
A. Again, I have to answer you honestly and say my
knowledge of legal privilege at the time wasn't
sufficiently sophisticated -- is probably the best
description I can give it -- to differentiate between
was it privileged to me or was it privileged to Post
Office? I just kind of took legal privilege to mean it
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was kind of privileged, you know, like, full stop.
SIR WYN WILLIAMS: Yes, and I'm not really asking you to
address your mind to the distinction, as opposed to
whether there was any discussion about that distinction?
A. No, not that I can recall.
‘SIR WYN WILLIAMS: Finally, you'd obviously know from this
Inquiry that it's possible for a party who enjoys legal
privilege to waive that privilege if someone asked them
to, like I asked the Post Office in this Inquiry. Did
anybody, either on the POL Board or in Government or
civil servants, ask you to waive legal privilege, if
this document was indeed privileged?
A. I can't confirm that because I can't remember, is the
honest answer to that question. But the fact that --
Ican only say that, you know, nothing happened in that
regard, and it doesn't stick in my mind as a topic that
was raised at the time.
‘SIR WYN WILLIAMS: So on the state of the evidence at the
moment -- and things may change, obviously, because we
are going to hear from people who may have a view of
this -- but at the moment there's nothing to suggest
that anyone asked that there be a waiver of privilege?
A. For my recollection, the answer to that is no.
‘SIR WYN WILLIAMS: Fine.
MR BEER: A related question to that, Mr Parker: did you
89
MR BEER: Good afternoon, sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
MR BEER: Thank you.
Mr Parker, can we just look at some documents that
were created years later -
Yeah.
-- in 2020 --
Mm-hm.
-- which speak to the issues that we're currently
discussing, starting by looking at UKGI00011785. This
is an email from Tom Cooper, who I think you'll know, to
Sarah Munby, who I also think you'll know. It's dated
Sunday, 19 April 2020. It says the:
information attached contains legally
privileged information.
"Do not forward ....
prop
"Ahead of our meeting to discuss [the Post Office],
which I hope is happening this week, I'm attaching the
key documents for us to consider."
If you scroll down:
"The following documents are attached:
"Copy of the QC's report. Suggest you read the
recommendations which are at the back.
"Copy of Tim Parker's letter to the Minister which
followed delivery of the QC's report.”
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inform Baroness Neville-Rolfe, the Minister, or anyone
else within the Department or ShEx, that you wouldn't be
providing Government with a copy of the report because
that was on the basis of legal advice received, that
doing so could result in a loss of privilege? So not
only was that the reason for acting --
A. Yeah, I understand --
-- that was the explanation given?
A. Yeah, so all I can tell you is that I think -- I'm not
sure what the Minister was told exactly but I have this
report and I have absolutely no reason not to show this
to people. I've got no vested interest and so
I conclude, looking back, that I must have felt that the
advice I'd been given was not to share the report
physically with the Minister.
Q. But you've got no recollection whether that was
explained, in terms?
A. Ihaven't, no.
MR BEER: Thank you.
Sir, it's 12.25. Can we take the second morning
break until 12.35?
SIR WYN WILLIAMS: Yes, of course.
(12.25 pm)
2
(A short break)
(12.36 pm)
90
We're going to look at that ina moment. There was
another document that is redacted.
If we scroll up, please:
"The subject of the meeting is the reporting to
Ministers and Governance in the Company that took place
after Tim Parker was appointed Chairman."
So there's a meeting in 2020 about the reporting by
you and others to ministers, and governance in the
company back in 2015, essentially:
"The Minister at the time was Baroness Neville-Rolfe
who asked him to appoint a QC to review the handling of
the Horizon IT dispute ..."
That's not entirely accurate, is it? She did not
ask you to appoint a QC?
A. No, that's not entirely accurate, you're right.
Q. "... and satisfy himself that issues had been handled
appropriately.”
That's more accurate?
A. That's more accurate.
Q. Then scroll down, "The following documents are
attached". It says in the penultimate paragraph:
"In addition to the above, it seems that neither the
QC's report, nor the existence or conclusions of the
follow-up work commissioned to deal with the QC's report
were known to the Board of the Company or to BEIS."
92
(23) Pages 89 - 92
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The Post Office Horizon IT Inquiry
Is that accurate on your understanding?
Not entirely, I don't think. I think in relation to the
Board, although they didn't see a copy of the swift
report, I'm pretty sure that Paula Vennells summarised
the recommendations.
We're going to come to that in a moment.
I think so, and I think also that, as Jane MacLeod said
in her evidence, she provided a briefing. So I think
it's not quite true to say they were unaware of the
existence or the conclusions of the Board and I would
say BEIS -- well, BEIS certainly knew about the report,
I think. Obviously, they didn't see it, but I think
they were aware of it, yes.
The word "existence" seems to apply to the follow-up
work, rather than the report itself?
"... Nor the existence or the conclusions" --
Of the follow-up work.
-- "of the follow-up work ...”
Oh, I see, I see the point --
It's not talking about the existence --
I understand the point you're making now.
On your understanding, did --
Yeah, so I think that was part of the consequences of
the report being stopped, effectively, later in May or
June, and the work being taken forward under the aegis
93
At what point in time?
At any point in time.
I'm not entirely sure anybody has put this point to me,
actually. I think, certainly when Tom Cooper became
aware of it, I think he probably had a discussion with
Ken McCall, and this was the output of the discussion.
But I can't recall anybody coming up to me in the
corridor and saying, "Hey Tim, looking back nine years,
you made a bit of a decision that was wrong and we
think's a significant error of judgement, you just about
scrape by and cling on to your job here"; no, nobody
said that.
Never mind corridors, was there anything more formal?
No.
It would have been five years, not nine.
Five years.
Was there anything more formal by which you were
chastised essentially, for your decision?
Yes, not that I can recall but sometimes unpleasant
events are put out of one's mind, so I might have got
this wrong but I don't think so.
That's a different issue, whether you got it wrong?
Well, I might have got it wrong, in terms of do
I remember it, is the point I'm making, yes.
I'see. The email continues:
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of the General Counsel in the context of the litigation.
Thank you. Can we look at UKGI00012703. This is
seemingly a meeting later in the year, this email refers
to, again circulating within UKGI on 16 September 2020.
It's not a communication to you but it's about you, and
I want to ask you some questions:
“Ahead of our call this afternoon, this is just to
update you that Ken McCall the [Senior Independent
Director] ..."
I think the SID, is that correct?
Yeah, the SID, yeah.
"... has confirmed that, having spoken to other members
of the Board as he deemed appropriate, he does not think
it appropriate to take any action in relation to Tim
Parker's decision-making around the QC's review in 2015
of POL's handling of the Horizon complaints.
"His rationale is the same as reported previously.
Ken [McCall] believes Tim [you] made a significant error
of judgement in accepting legal advice that the QC's
report and, as a consequence the follow-up work, should
not be shared with the Board."
Firstly, was that put to you, that you had made
a significant error of judgement in accepting advice
that the report and therefore the follow-up work should
not be shared with the Board?
94
he has some sympathy [that's Ken McCall] with
‘the fact that you would have had to take a very strong
position against the legal advice at the initial stage
of his tenure to achieve a different outcome. Overall,
Ken [McCall's] view is that [you have] been a strong
force for positive change in the company while [you
have] been Chairman and it would be
unfair/disproportionate to take action over this
specific issue.
"I haven't asked him to put any of this in writing
or come in to meet Ministers or officials to discuss,
but this is an option if the decision is to take this
further at our call ..."
Was that explained to you, that an option was to
take formal action against you but, on balance,
a decision was taken not to do so because this was early
in your tenure. You would have had to have taken
a strong position to go against legal advice that you
received and that, overall, you have been a positive
force for change?
The answer is -- and, again, I'm searching my
recollection here, because I don't want to give you
an answer that isn't true. I honestly can't remember
having a formal discussion about this.
Can we --
96
(24) Pages 93 - 96
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The Post Office Horizon IT Inquiry
Can I say something about this because --
Yeah, sure.
-- I do feel it's quite a fine hindsight judgement to
have made that this is a significant error of judgement.
I think that Swift was something which produced some
good consequences. The first recommendation, the second
recommendation, the seventh recommendation and,
ultimately, the eighth recommendation were followed
through. The work, which no doubt we will discuss
later, in Bramble, was also substantially followed
through and informed the Post Office's litigation.
And so I fully accept that, had Swift been discussed
at the Board, it may have led to a different approach to
the litigation.
But I should say that it remains my view to today
that, once the litigation has started, or had started,
and although I think we'll see it wasn't necessarily
handled in the best and cooperative manner, the
litigation, the GLO, ultimately proved to be
a comprehensive -- what's the best word I can find?
A comprehensive settlement of a lot of very complex
issues. And I have replayed in my mind, Mr Swift (sic),
what might have happened had we not, you know, had the
GLO and everyone had read Swift and said, "Oh, there's
a problem." the problem is that, you know, our contract
97
wrong, and a very large amount of money is payable to
all concerned. And, unfortunately, it's just taken --
following the ultimate settlement in the trials, it's
just taken far too long.
Sorry to give you an extensive extemporary on all of
that but you can imagine someone who has sat in this
seat looks back and says how could it have been better,
how could it have been different, how could it have been
faster?
‘Are you saying by that answer that it needed a group of
brave and determined subpostmasters to hold the Post
Office to account by bringing the Post Office before
a court, and that the Post Office was incapable often
doing it itself?
I'm aware that the counter-argument to all of this is
that there should -- you know, it should have been
something that was resolved inside the Post Office
without the recourse to the litigation and, with
hindsight, you know, the postmasters, Sir Alan Bates,
should never have been required to mount a Group
Litigation Order. I understand that. All I'm saying is
that, once it was in train, had it been managed a bit
better, then a lot of complex issues might have been
determined without the delay and without the cost. But
a judge review of all these issues, I still think, one
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with the subpostmasters is completely wrong, so we'd
better tear it all up", and somebody had said, "Oh, by
the way the computer system has got a lot of bugs, and
it's unreliable".
And I've replayed in my mind exactly what might have
happened then, which is that we would have gone to our
paymasters, the Government, and said, "We've got
a slight problem. Our contract that we've had for
a long time is not fair. We've got another problem,
which is that our computer system, certainly Legacy
Horizon, you know, anecdotally, it's full of bugs", or
we got somebody to independently apparently suggest
that.
My view is that the debate that would have ensued
between, you know, "So what is a reliable system?" and
"What are the consequences and, therefore, what
compensation is due?" and "The contract isn't fair".
And so we'll go through all of that. I do believe,
whatever the impediments placed in its way -- and maybe
it could have been handled a lot better -- but
a judge-determined settlement of all these issues has,
and should have resulted already, in a comprehensive
compensation settlement for all affected.
And the result of all this should have been -- or in
my view -- that this whole thing has been completely
98
way or another, was the right way to get, you know,
an outcome in the end, yes.
So you are saying that, irrespective of the things that
we're going through now, even if things had been done
differently, it would have always have taken a judge to
hold the Post Office to account?
No, I'm saying -- I think what I'm saying is that
a judge -- of course, holding to account -- you're
absolutely right, the result of any judgment would hold
the Post Office to account. All I'm saying is that it
would have been in my view, practically speaking,
although I can perfectly accept this isn't the right
‘outcome, but, given where we got to, trying to see if
this could have been managed internally to the same
result, I'm not sure.
Can we move forwards, please, to UKGI00019313. This
appears to be, Mr Parker, the culmination of those
meetings that we've just read about happening in the
emails, discussion over what to do with you about your
conduct in 2015/2016, concerning the Swift Review.
It's a letter directly to you from Sarah Munby, then
Permanent Secretary at BEIS:
"Dear Tim ...
"As part of our preparation for the BEIS Select
Committee hearing which had been scheduled for March, we
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The Post Office Horizon IT Inquiry
received from Post Office a copy of the report prepared
by Jonathan Swift QC that was commissioned by you at
Baroness Neville-Rolfe's request after your appointment
as Chair in 2015. We understand from the work done
recently by the company and its advisers to look at the
history of Horizon that the findings and recommendations
by Jonathan Swift were not shared with the rest of the
Post Office Board.
"We understand that you were advised at the time by
the Post Office's General Counsel that for reasons of
confidentiality and preserving legal privilege the
circulation of the report should be strictly
controlled.”
That sentence there accords with what you've told us
today, doesn't it?
I think it does, yes.
"Nevertheless, given the background of Parliamentary
interest, the fact that your review was commissioned by
the Minister responsible for the Post Office and the
potential significance of the recommendations made by
Jonathan Swift, we consider it was a mistake not to have
ensured that the whole Board had an opportunity to see
and discuss the detail of its findings and agree what
any next steps should be. With hindsight, this
information should have been seen by the Board and we
101
from the Horizon cases as well as implementing the
changes needed to ensure that such issues never arise
again", and then a thank you.
So, as far as you're aware, was this the endpoint or
the culmination of the consideration by Government as to
its approach to your decision not to disclose the report
to the Post Office Board back in 2015?
Well, I received this letter -- when is it dated -- at
some point in --
October 2020.
-- in 2020 and I haven't heard anything subsequently so
I think you can conclude from that that the answer is
yes.
That was the end of it?
(The witness nodded)
Okay. Can I just go back to what you and the Chief
Executive, Paula Vennells, did say about the report and
its recommendations at the time, to see, irrespective of
the approach that BEIS and Government took subsequently,
what information was disclosed, first by looking at
POL00158304.
And, by the way, may I say something on this letter
before we move on?
Absolutely.
Can we just --
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are disappointed that it wasn't.”
You mentioned earlier being taken aside in
a corridor and being essentially chastised or told off.
This is the written equivalent to that, isn’t it?
Yes, I think it definitely is, yes.
"As a rule, we think it is quite difficult to envisage
any circumstances where issues of legal privilege or
confidentiality should prevent relevant information
being shared with a company’s Board. You won't need us
to remind you of the importance of effective corporate
governance and that the role of the Board is to ensure
the company’s prosperity by collectively directing the
company's affairs, while meeting the appropriate
interests of its shareholders and relevant
stakeholder:
Then there's a counterbalancing point or paragraph:
"Finally, we also recognise that while you have been
chair and under Nick Read's new leadership, the Board
has instigated a frontally different approach to
handling the grievances bought by postmasters affected
by Horizon as well as initiating significant changes to
the organisation, processes and culture of the
organisation. These are to be welcomed and we continue
to encourage the company to act quickly and decisively
to do what it can to remedy the remaining issues arising
102
Go back to the first page?
-- scroll back to the first page if that's all right.
Then scroll down.
Okay. Let me -- I think again, at the risk of sounding
alittle boring on the subject, I think it's important
to place what I would accept with hindsight was
a misjudgement in context.
Thank you.
So the first point to note is that I'm not a lawyer and
I received very strong legal advice, which I took.
The second point is that I did that in good faith.
I had no reason to deliberately hide this thing or chuck
it into the long grass.
And the third point to make is that it's easy, in
the context of this Inquiry, to imagine that all the
chairman is doing is looking after issues to do with
‘Swift and looking after issues to do with Horizon, and
I have to keep reminding you that that is not the case.
There is an awtul lot going on in this business and
an awful lot of stuff that needs addressing. So having
had, you know, a slap over the wrists from this, I can
perfectly see the response but I think I'd just like you
to bear in mind that there is context to these things,
and that sometimes it's easy to overlook that.
I think that context should include that, when you
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started working as Chairman, you were working for
a minimum of one and a half days a week?
We can get into a discussion about what makes
an effective time allocation --
I was just asking a simple question, Mr Parker. When
you started, you were on a minimum of one and a half
days a week?
Are you asking me that as a question of fact, are you?
Yes.
Yes.
Then also a question of fact, in November 2017, you
asked for that to be reduced to two days a month, didn't
you?
I did. Can I also, as you've asked the question about
time, just explain to you a little bit about the
perspective of being a chair and time, and what makes
an effective chair, based on the experience that I've
had. So being a chair is about a number of different
things and it certainly is about time spent in
a business. But it's also about the capacity to
understand business problems and the capacity to strike
up effective relationships with the key people in
a business, especially the CEO.
So you asked the question, immediately after this,
about time with a slight implication, I suspect -- maybe
105
take these forward to demonstrate the highest possible
standards of rigour and fairness in the handling of the
Horizon related complaints."
Is this the kind of information, to your
recollection, that was provided to the Board, ie the
extent of the information provided to the Board about
the contents and recommendations of the Swift Review?
Mm, I think she also had a table of the recommendations.
But that's it. Yeah.
Was it your view that the report did set out only
a limited number of recommendations?
The way it's put there, it's sort of fairly kind of
benign. I think it's set out eight/nine -- eight
recommendations. I mean, it depends on your language,
doesn't it?
It might be said that underplays the overall outcome --
I think that's a -- you know, it you could say it's
a limited number because there aren't many or you could
say it kind of gives the impression there's not much
going on. Yeah.
Let's just look at what the Minister was told,
UKGI00006482. This is a couple of days later,
26 January 2016. Meeting between you, Baroness
Neville-Rolfe, Laura Thompson and Andrew Smith. Then
"Main points". The first few bullet points concern
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wrongly -- that somehow what happened here was the
result of me not spending enough time at the Post
Office, and I would certainly rebut that suggestion.
I would say that I was a very active, energetic
chair who took a lot of time and spent time with people
to understand the business, and I certainly don't think
the time, one and a half days, or whatever it is, was
the reason why I made this error of judgement, with
hindsight.
Can we go back to the note, please, at POL00158304.
This was the note I was going to move to, to look at
what was said by you and the Chief Executive about the
Swift Review at the time. These are speaking notes for
a Board meeting of 22 January 2016, seemingly a speaking
note of Ms Vennells. Can we go forwards, please, to
page 6, please, and scroll down, please.
Thank you. Just there "Sparrow", "Chairman's
Review".
Remember, this is 22 January 2016, before the final
report was received on 8 February:
"Jonathan Swift and Christopher Knight, the
barristers advising Tim Parker on the adequacy of scheme
processes, shared their draft report with the chairman
last week. The report sets out a limited number of
recommendations and [Post Office] will, where possible,
106
other things, which is reflective of the point you made
a moment ago, Mr Parker, that this wasn't the only
issue. If we look at the penultimate bullet point:
"TP [that's you] updated on the Horizon
investigation. He said that the QC was about to report.
He had found no systemic problem. [Tim Parker] thought
that the issue might have passed its peak interest."
Firstly, did you say that to Baroness Neville-Rolfe?
I have no idea. I think I certainly would have
commented that, as far as the computer system is
concerned, coming back to our previous discussion, and
I think it was reflective, broadly speaking, of what was
in Swift, there wasn't a systemic problem, whatever
"systemic" was understood to mean.
In terms of the second thing, I think I must have
just commented that, in terms of the press, it had at
that point passed peak interest and that might have been
in response to a question, or whatever. But that would
have just been me commenting on that.
Were they truly the takeaways from the Swift report, as
reflected there: no systemic problem, issues passed its
peak interest; rather than he's made eight
recommendations of substance that need taking forwards,
they pose significant reputational issues, to Post
Office?
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Do you know, I don't know. I mean, I'm not sure what
the substance of the conversation is, or why, you know,
why those are the two sentences. I just can't tell you.
I just come back to what I said, which is that it was
a report which I think it was -- it wasn't the final
report at that point, was it? It was —-
No, not by this time.
Yeah.
I think the eight recommendations at this time were as
they were to appear.
They were, yeah, you're right.
Lastly on this, then, before we break for lunch, can we
look at POL00024913. Thank you. This is a formal
letter that you sent to Baroness Neville-Rolfe on
4 March 2016. We were looking previously at a Board
meeting in January and a meeting with Baroness
Neville-Rolfe in January. This is therefore after the
8 February 2016 final report had been provided. You
say:
"At our meeting on 26 January 2016, [that's the one
we just referred to] I provided you with an update on
the work I have undertaken with the assistance of
Jonathan Swift and Christopher Knight, both of 11 [KBW]
Chambers to review the Post Office's handling of
complaints made by subpostmasters about the operation of
109
That's exactly the case. Yeah.
The letter continues:
“lam, of course, aware that once the additional
strands of work I am pursuing are complete, we will need
to find an appropriate method of communicating the
results of my review to a wider audience."
In the first paragraph, you refer to "my initial
findings" and in the second paragraph you refer to “my
review". Had you made any findings and had you
conducted a review?
I think that's a little semantic. I mean, it was
conducted on my behalf and whether I sort of finessed
the thing to suggest it was only me or my review,
I certainly took responsibility for it, which is the
main point, I suspect.
The purpose of asking the question was not to delve into
semantics but was to understand whether you understood
this to be your findings and your review, and whether
you had the opportunity to disagree with anything that
Mr Swift had recommended?
I think it's fair to say that, as I discussed earlier
this morning, I thought the Swift Report was a good
piece of work and it came out with some good, sensible
recommendations which I supported, and I did discuss the
report with Jonathan Swift so, at that point, I'm sure
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the Horizon software system. I now write to set out
further information about the approach to the review,
the scope of work undertaken so far, and my initial
findings. I also outline my plans to bring the work to
a conclusion.
"Before doing so, I wish to stress that this update,
and the work which underpins it, reports on the legal
advice I am currently receiving and is, accordingly,
subject to legal professional privilege and provided in
confidence."
What does that mean, that sentence?
I, again, followed the suggested text around legal
advice, and there was this concern which I've -- I think
I've highlighted around, you know, anything that goes
into the hands of ministers and civil servants is
potentially disclosable under Freedom of Information,
and that seemed to be a concern that generally coloured
discussions of this thing.
In fairness to you, this was a letter drafted for you by
Ms MacLeod and the draft of the letter was itself
reviewed by Mr Swift before it was signed, and I think
you were told by General Counsel that the letter had
been amended to reflect amendments that he had
suggested. You cover that off in your witness statement
at paragraph 65.
110
I felt happy and willing to take ownership of it.
You say under "Scope of the Review", "My objectives were
as follows", and then you set out essentially the term
of reference?
Mm.
Then if we go over the page, please, there is then, over
the course of four pages, a summary of the headline
findings of the review and the recommendations made
against each of them. So, to that extent, the
Government was informed of headline findings -- I'm not
going to go through each of them now -- and the
recommendations made.
If we go to the last page, please, page 4. If we
just scroll through so you and others can see the detail
that was included in the letter going to Government.
Thank you. Stop there. Under "Next steps":
"I have commissioned independent persons to
undertake the necessary work. I am satisfied that they
meet the standards of expertise and independence
appropriate to the tasks.
"I... share your aim that matters should be drawn
to a conclusion as soon as possible consistent with the
need for the work that remains to be done to a high
standard. I hope that you understand that, particularly
in relation to the further testing of the Horizon
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system, this work may take some time", there may be
a report in May.
Then skipping a paragraph, two matters:
as I have noted above, a number of
subpostmasters have made applications to the [CCRC] for
the circumstances of their convictions to be looked into
with a view to those cases being brought back to the
Court of Appeal. That work is ongoing. Second, [JFSA]
is reported to have received funding to instigate civil
proceedings against the Post Office ... at the time of
writing, no claim has been issued nor any Letter of
Claim been received."
A. Mm-hm.
Q. So, overall, you were, I think, advised to write
a letter of this length and detail -- is that right --
A. Yes.
Q. -- and therefore, happy that this information was not
itself information which would lose privilege?
A. That's quite an interesting point and I think the -- my
sense is that this letter was written, yeah, and it's
quite a good summary, I agree. And -- but I think that
it's probably trying to go as far as possible to outline
Swift without necessarily handing the report over.
MR BEER: Thank you.
Sir, it's 1.10. Can we break now, please, until
113
A. Ah, I'm sure we discussed it and, obviously, we ended up
with a selection of different people looking after
different recommendations, as I recall.
Q. Before coming to the issue of who carried some of the
recommendations into effect, was there a person who had
a responsibility for determining whether the
recommendations were taken forward or not?
A. AsI understood it, the General Counsel.
You also said that you thought that all of them were
going to be taken forwards; is that right?
Yes.
2
So she didn't have anything to determine?
I didn't think so, no.
Right.
Yeah.
So your understanding was that all eight recommendations
were going to be taken forwards. What role did the
General Counsel, Jane MacLeod, therefore play?
A. Her role was to work with the relevant parties and
report back to me.
Q. Is that the role that you delegated to her, then ~
A. Exactly.
Q. -- rather than deciding which recommendations were or
were not taken forwards?
A. I see your point. As I recall, there wasn't a debate
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2.00?
SIR WYN WILLIAMS: Yes, of course.
MR BEER: Thank you very much, sir.
THE WITNESS: Thank you.
(1.12 pm)
(The Short Adjournment)
(2.00 pm)
MR BEER: Good afternoon, sir. Can you see and hear us?
SIR WYN WILLIAMS: Yes.
MR BEER: Thank you very much.
Mr Parker can we turn to the recommendations, the
eight of them that Jonathan Swift made in his review.
Who in your view was responsible for determining whether
and to what extent the recommendations should be taken
forwards?
A. So this responsibility I delegated to the General
Counsel.
Q. Why did you delegate responsibility for deciding which
recommendations were to be taken forward to the General
Counsel?
A. I rather assumed that all of the recommendations were
going to be taken forward.
Q. Sol asked whose responsibility was it for determining
which recommendations were taken forward and you said
you delegated that to the General Counsel?
114
about which recommendations but just to take all of them
forward with appropriate parties.
Q. Did it occur to you that the Board ought to play a role
in deciding the extent to which recommendations were
taken forwards and, if so, how they were to be taken
forwards?
A. We hada situation after the report was completed where,
as I think I explained, the report wasn't shared with
the Board and the understanding was the recommendations
would be taken forward, and my plan was to share the
outputs at that stage. So this was something that went
straight from the General Counsel to the relevant
parties, and so the Board was not involved, no.
Q. Was that a product of the legal privilege issue that we
discussed this morning?
A. It was the product of the perception that I had with the
legal privilege issue, yes.
Q. Thank you. Can we look, please, at POL00103190, and the
bottom email, please, 13 May 2016, Jane MacLeod to you:
"Here is my regular fortnightly update on the
progress of your review and the litigation."
Is it right that she provided an update regularly to
you?
A. Yes. I mean, I'm sort of drawing that conclusion from
the first sentence, here.
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Was the relationship between you and Jane MacLeod
essentially one-to-one, ie you saw her as driving the
recommendations forward as appropriate on your behalf?
Yes, I think that's a fair characterisation.
She says -- we can look at these quickly:
"Helpline -- In relation to the allegation that our
Helpline may have provided incorrect advice to the
subpostmasters which resulted in a loss to the accounts,
Bond Dickinson (the external firm conducting the work)
has now completed its investigations. Although some
investigations were limited because certain records are
no longer available and there were inaccuracies in the
information provided by complainants, their draft report
reveals that there is no evidence to support the
allegations that have been made. We are currently
reviewing the report ahead of sharing it with Jonathan
Swift to seek his view as to whether it sufficiently
discharges his recommend in this areas, but we are
confident that it should."
Then:
“Horizon System -- We have had further meetings with
Deloitte in relation to the extent of the work necessary
to discharge Jonathan's 3 recommendations on the testing
of Horizon, and they have begun work on the substantive
phase of that work. Itis, by its nature, an iterative
117
Does that reflect the fact that the report had been
provided to you in draft in January, in final version on
the 8 February, and it was now mid-May, and the work was
inchoate?
I think that's true. That's what I was expressing at
the time.
Did you pick up from the chain that the recommendations
made by Mr Swift were being trimmed?
No. Not especially. Why -- what is behind the --
Altered?
I don't think so.
I mean, to take an example, over the page, "Prosecution
Practice":
Swift has confirmed that [Altman] can limit his
review to 19 cases presenting specific features and then
decide on the basis of those features whether to extend
the exercise."
That wasn't of the initial recommendation. The
recommendation was to review all of the cases, if you
remember the recommendation number 1 and 2.
I see your point. I think I would have taken that at
face value to mean that she had talked to Jonathan Swift
and, between them, they'd taken a view that that was
going to respond to the recommendation adequately.
I hadn't picked up, to be honest, that things were
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process in that, dependent on early results, further
decisions then need to be made on whether or not to
explore further ... I have asked the new [CIO], Rob
Houghton, to review the process undertaken by Deloitte,
to sense check these further decisions.
"Suspense accounts -- ... Deloitte are also
conducting the work, into the existence and nature of
the relationship between [Post Office's] suspense
accounts and specific branch accounts over the relevant
period. This is a materially different exercise to the
IT testing, and I understand that most of the relevant
accounting processes were/are paper-based records and
manual reconciliations
"Prosecution practice -- Jonathan Swift has
confirmed that Brian Altman can limit his initial review
to those 19 cases presenting the specific features of
double charges in question, and decide on the basis of
those findings whether to extend the exercise. That
work is ongoing."
If we go back to the top of the page, page 1, you
say:
"I think there will be frustration at the time this
is taking (indeed I am also beginning to get somewhat
frustrated). So what is now the projected timetable for
completion on the components of the action list?"
118
being, to use your phrase, trimmed, as such.
Can we go forwards, please, to POL00241554. We can see
at the foot of the page your email, "there will ... be
frustration", yes?
Yeah, yeah.
Then top of the page, please. You'll see that Jane
MacLeod forwards the email to -- circulates the email to
a small team of people: Patrick Bourke, Mark Underwood
and Rodric Williams.
The very same people who received the copy of the
original Swift Report.
So it's the same select few?
Exactly.
"Please see email from Tim below.
"I think it would be helpful to be able to respond
with the status of each of the 8(?) actions that were
being carried forward, a description of the remaining
work and the expected completion time.
we should consider the work being done by
Deloitte and how far we want to address the questions
posed by Jonathan."
Just stopping there, was it for this small team to
decide how far "we" -- presumably the four of them --
want to go to address the questions posed by Jonathan
Swift?
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So I think I come back to where I started on this, which
is that I assumed -- perhaps wrongly in retrospect --
but I assumed that the General Counsel's team were (a)
competent, (b) would do things in good faith, and (c)
would respond effectively to the recommendations of the
report.
Now, you know, when you get to see these emails that
are shown to me, or form part of the evidence base which
are what's going on, as it were, behind the scenes, it
kind of puts a different complexion on things, a little
bit. So the reason I mention all of that is that, you
know, I'm expressing to you what seemed to me to be the
case. Behind the scenes, of course, you find that, you
know, the motives for doing things perhaps are not quite
as straightforward as one might have imagined.
There's no suggestion from me, at least, that this email
was provided to you. Was it right for this team to be
seemingly determining whether the recommendations were
taken forwards and, if so, in what way?
So in the world that I normally exist in, I have people
working for me, and they have a job to do, and if I ask
them to do a job they understand and it's correctly
specified. Until I got to the Post Office, I think I'm
right in saying that, throughout my career, I have found
that people went and did what was asked of them with
121
Again, that's a similar point, ie the team
determining value to be obtained from further work, in
part based on the extent to which something can be said
about the results of it. Does the same answer that you
gave a moment ago apply?
I can see your point. If I may make one general
observation about this sort of backward-looking, what
were people doing eight years ago, type of thing, you
can only look at the evidence that you have on a piece
of paper and people write sentences which can or cannot
reflect truly what was going on. So I'm not here to,
you know, doubt what is actually written here. But
sometimes things that are recorded don't exactly reflect
what people were doing at the time. I don't know in
this case but I just think it's worth bearing in mind
that you cannot take every sentence that is written and
that you read as gospel in this context.
That's certainly the case: a number of people have sat
in your chair and said that what they wrote does not
reflect what they meant at all.
Um, very good!
Can we move on to POL00103214. Look at page 2, please,
and just scroll down. Thank you.
It's an email later that month, we were just looking
at 14 May, we're now looking at 27 May, to you, and
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suitable determination and suitable application of their
abilities.
And so you -- in retrospect, you might say, well,
these are not the right people because here we are at
the Post Office. But I can only tell you that, under
normal conditions, they should and would have been the
right people and could well have carried out these
recommendations effectively.
Can I ask you two questions arising from that. Do
I take it from that answer that, if you had known that
this small team had taken upon itself the function of
deciding how far to go to discharge a recommendation,
you would have had something to say about it?
I would have been concerned. I mean, it was
straightforward, "Here are the recommendations", you
know, "Let's go and do something about them".
The second thing is that you didn't, therefore, know at
the time that this subsurface internal debate within
a select team within Post Office was going on?
No.
The email continues:
"Given the litigation, I suspect there is even less
we are going to be able to say about the results of the
further work, so we need to consider the value to be
obtained from each step."
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Ms MacLeod says:
"As flagged at the Board letter this week, I hosted
a call with Jonathan Swift today ask what, in his view,
would be a reasonable course of action for you to take
in relation to his recommendations as to the further
lines of inquiry which could be undertaken, now that the
[Post Office] faces litigation covering essentially the
same ground."
So just stopping there, can you recall who told you
and how about litigation being threatened against the
Post Office on behalf of subpostmasters?
I believe I must have been told, at some point after the
receipt of the letter of claim -- now the letter of
claim I think came in the middle of April or end of
April, something like that.
Can you recall whether you were told that this may have
an impact on the extent to which the eight Swift
recommendations could be carried into effect?
I can't, to be honest. I can't tell you whether this
was the first, you know, glimmer of this happening.
That's essentially what I'm driving at.
Honestly, I can't tell you for sure.
In any event, Ms MacLeod reports:
"In summary, Jonathan felt that Tony (that should be
de Garr Robinson QC] (the barrister retained to advise
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[Post Office] on its defence to the proceedings) should
first be requested to advise [Post Office] whether in
light of the litigation, the various works teams should
be continued, paused or redefined.”
That's essentially telling you that she went off to
Mr Swift, who said, "Don't ask me in the first instance,
go to the person that's conducting the civil litigation,
de Garr Robinson QC, and ask him", yes?
That is exactly as I understood with hindsight is what
happened, yes.
"We will send instructions to [Mr de Garr Robinson]
early next week and expect to have this advice
relatively quickly. Once this advice has been received,
Jonathan has said that he would be happy to discuss with
you how best to take this forward in the context of your
review, as well as considering how to position this with
[Baroness Neville-Rolfe] and others with knowledge of
and interest in the review."
Was this your main means of communication with Jane
MacLeod, ie email, rather than attending the office and
having meetings?
I'm sure we spoke about it. I'm sure she just sent me
an email about it.
You think there was discussion outside of the email as
well?
125
It contained recommendations that went to the issue of
uncovering potential miscarriages of justice?
It did.
It plainly took a long time to research and complete and
it was a comprehensive report, wasn't it?
Mm-hm, indeed.
Given that one of the reasons for undertaking the review
and some of the recommendations from it related to
matters touching on the safety of criminal convictions,
did it occur to you that undertaking the recommendations
through the aegis of civil litigation against the Post
Office was not the right way forwards?
So I think we're back to this question of, in this kind
of situation, which I had very little experience of
hitherto, receiving advice from senior counsel on
a legal matter, very strong advice, apparently, I took
that advice and I assumed -- perhaps erroneously -- that
the General Counsel, who also herself was a lawyer,
would have considered and appreciated any implications,
ramifications of doing this, in terms of how the Swift
Report was carried forward.
So it’s a very difficult question because, you know,
when you look at these things in hindsight, you say,
well, you could have spent some more time discussing it,
or you could have had your own view, or you could have
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I honestly can't confirm that.
Can we go forward to page 1, please, and scroll down.
On 10 June, Jane MacLeod writes further to the email
we've just looked at, and says:
"... we met with Tony [de Garr] Robinson last night
to discuss the Postmaster Litigation. In the course of
that discussion we asked him for his advice as to
whether the work being undertaken for the purposes of
your review should be continued.
"His strong advice was that the work being
undertaken under the aegis of your review should not
continue in the light of the litigation. However, he
also recommended that the subject matter of that work
should continue, provided it is rescoped and
re-instructed for the purposes of the litigation.
"Clearly you will need to inform the Minister and we
will prepare a form of words ..."
Over the page, sign-off from Jane MacLeod.
Then top of the page 1:
“Let us meet to discuss on Thursday."
Yes?
Looks that way, yes.
Now, the Swift Review was a significant piece of work,
wasn't it?
It was.
126
done this. The problem with experts or specialists is,
how do you judge the view of the specialist? Do you get
another specialist to advise you on the specialist or do
you draw the conclusion that your judgement of the
specialist was wrong and the specialist you got is no
good, or that the General Counsel who was advising you
is somehow incompetent, or the whole bunch of them have
somehow, some rather nefarious underhand objective of
potentially holding things up?
I'm not sure. But, at the time, I took at face
value what I thought was good advice and the right
advice from people who apparently were qualified to give
it.
So is a summary of that answer that you thought it
reasonable to rely on the advice of your General Counsel
who had asked the silk the very question that you needed
to be answered, and he had provided an advice which was
said to be very strong?
I am -- all 'm saying -- and you're right, it's not
a bad summary of my 10 or 12 sentences -- that whether
it came from Mr Swift or and with Jane MacLeod, they're
both lawyers, they both understand what's in the report,
they are and were both qualified or -- and certainly he
was -- to give a view. Yes.
Do I take it that it didn't occur at the time that what
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might be in Post Office's narrow interests in the
conduct of the civil litigation might not be in the
wider interests of wrongly convicted subpostmasters?
So I think we're touching on this question of -- with
hindsight, of course, it would appear that there were
motives perhaps underpinning some of the advice or the
direction of this that were not wholly fair or right or
in the interests of people who had been wronged. At the
time, however, it seemed to me that the people giving me
advice should be and were doing this in good faith, and
it was the right thing to do.
Thank you, can we move forwards. POL00242402. If we
can go to page 4, please, this is a chain that you're
not copied in on but it attributes to you and to the
Post Office some beliefs or intentions. So I want to
ask you about them. It's 8 June now, an email from
Andrew Parsons, the partner at the firm of solicitors
that the Post Office was using to defend the threatened
litigation, to Anthony de Garr Robinson, and he says:
"Tony
“I met with the Post Office litigation steering
group yesterday.”
Just stop there: were you a member of the litigation
steering group?
I wasn't.
129
would be ill-advised. Was that a message that came from
you?
You mean this, about magic QC seals and --
No, put aside the magic QC seal. The description of
Post Office are looking to us for reasons not to
complete the recommendations.
Yeah, well, you know, again, as you said at the outset,
this is something that's going on without my knowledge.
That was the question --
Yes.
-- was this going on without your knowledge?
No, and, just to be clear, it was without my knowledge.
So you weren't looking for lawyers to come up with
reasons not to do or undertake the Swift
recommendations?
No.
Do you know who was? It's described here as "POL are
looking to us".
Yes, I see that. I certainly wasn't part of the "Hey,
you know, can you get Tony to give us some reasons why
we should let up on this".
Yes, some top cover --
No.
-- some legal insurance, or some other such phrases I've
heard in my career. That wasn't coming from you?
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Do you know who it consisted of?
Ido. I'd have to have a piece of paper in front of me
but, in summary, it was a collection of Post Office
Executives and specialists and legal people.
"Their approach to [Jonathan Swift's] recommendations
has shifted slightly.
"Tim Parker ... feels that he has made a commitment
to Baroness Neville-Rolfe ... to follow through on the
[Swift] recommendations unless he is presented with
a persuasive case not to do so."
Is that accurate, that you felt at this time that
you'd made a commitment to the Minister to follow
through on the recommendations, unless you were
presented with a persuasive case not to?
Yeah.
So that's accurate. Then:
"[Post Office] are ... looking to us (and quite
frankly you with your magic QC seal!) to give them some
reasons for why Tim completing the [Swift]
recommendations would be ill-advised."
First, Post Office are looking to us, ie to the
lawyers and to Mr de Garr Robinson, to sprinkle some
magic dust on the answer --
Mm.
-- for reasons why completion of the recommendations
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That wasn't coming from me.
Did you know, in any way, that there was a group of
people within the Post Office looking to stifle or end
the carrying into effect of the Swift recommendations?
The answer to that question is no.
If we scroll down:
"... the recommendations we are talking about are",
and then they're set out, 1, 2 and 3:
"My view [that's Mr Parson's view] is that these
three recommendations plainly overlap with the issues in
the litigation. I can see three reasons why Tim should
not ‘conduct’ the above investigations:
"1. We, the litigation team, will need to
investigate these points ... We will probably need to do
this on a different timetable to Tim (we having a degree
of time pressure; Tim under less time pressure). We
will also probably require a more robust investigation
given that these points could be tested in court. Two
parallel reviews would be wasteful and could cause
unknown complications should they reach contradictory
results."
Was any of this reasoning explained to you for not
simply carrying into effect the Swift recommendations?
No. I had certainly not this kind of rationale, no.
"2. If these investigations are conducted by Tim there
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is a greater risk that this work is not privileged ...
It would be much safer for these investigations to be
conducted as part of the litigation."
Was that explained to you?
No. I think the one -- you know, the one sort of view
I had was that this review should be stopped and
repurposed as part of the litigation and, because of the
litigation, the work would continue to be privileged.
"3. Even if the risk in 2 above could be guarded
against (say by classing it as part of the [Jonathan
Swift's] ongoing advice to [Tim Parker] -
questionable???), I cannot see how [Tim Parker] could
disclose the results of these investigations to [the
Department] without a risk of waiving privilege
(particularly where there is a possibility that
[Baroness Neville-Rolfe] may then speak to James
Arbuthnot or [Post Office/BIS] could be the subject of
a [FOIA] request.”
Was that explained to you as a reason for not
carrying into effect the Swift recommendations or any of
them?
No, essentially what I got out of all that was what you
saw in, you know, a couple of papers ago, which is the
strong -- the -- I can't remember the exact description,
but it was something like the "strong advice" ~- on the
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last paragraph implicates you, in the sense that it says
that you would feel empowered to say, on the basis of
legal advice, you are ceasing your review, and that
they, the lawyers, are being asked to provide political
cover for you, neither of those things are things that
you asked for?
No. I got the advice and then used it, you know, used
the advice to essentially communicate with BEIS.
So you weren't --
It wasn't -- I didn't feel empowered myself. I wasn't
aware of being empowered, because, you know, I wanted
a reason to go and tell BEIS the thing was being
discontinued. I received that advice and, as a result
of getting that advice, I went and then communicated it
to the civil servants and onwards to the Minister.
Can we move forward, please, to POL00242552.
If we just go to page 3, please. Just to remind
you, the foot of page 3:
"we met with Tony Robinson [sic] to discuss the
Postmaster Litigation."
Second paragraph:
"His strong advice was that work being undertaken
under the aegis of your review should not continue ...”
Yes ~
Yes.
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strong advice of senior counsel, the work should be
discontinued and repurposed. I can't remember the exact
form of words but that is the advice that I received.
"If we can give [Post Office] a piece of advice that
says [you] should stop any further work, [you] would
then feel empowered to say to [the Department] that, on
the basis of legal advice, he is ceasing his review.
I'm conscious that this feels somewhat unpleasant in
that we are being asked to provide political cover for
[Tim Parker]. However ... shutting down [Tim Parker's]
review is, in my view, still the right thing to do."
The way that last paragraph reads, would you agree,
is it implicates you somewhat in the making of the
request?
Well, I mean, I certainly was not aware of all of this
stuff going on, as it were, and it certainly looks
a little bit like, you know, these guys are marionettes
and I'm doing my little thing in response to bits and
pieces that they're putting forward. And that's, you
know, very disappointing with hindsight because you --
as I was explaining earlier, you expect to get advice
from lawyers in good faith, you know, good motives and
a good rationale, and I assumed that was what I was
getting.
So, directly to answer my point, to the extent that this
134
-- 10 June? Then page 2 at the bottom, please, 14 June,
"See below", that's that chain, and your reply saying,
"Let's discuss on Thursday". Jane MacLeod and Rodric
Williams and Patrick Bourke in email discussion:
"... Any approved messaging we want to get across?”
Did you know that the small select team were
formulating messaging for you?
No.
Up the page, please:
"In terms of messages to Tim and from Tim to
[Baroness Neville-Rolfe], I think we're going to have to
address the issue head on: the litigation makes the
Review irrelevant since the issues to be considered will
be put to a higher standard of testing in the courts
Was that ever explained to you, that the review was
now irrelevant?
I can't remember that it was explained in those terms,
no.
Because of, it is said, a higher standard of testing in
the courts; that wasn't ever explained to you?
I can't be sure. I mean, I think the main reason this
ended up where it did was the advice I referred to
earlier, which is the strong advice from external
counsel.
136
(34) Pages 133 - 136
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Whether or not this was added, you know, as a sort
of rationale, I can't be sure.
The email continues:
to continue would be fruitless since we:
couldn't use its output, senseless in terms of
expenditure, and present unnecessary risk to the
organisation's legal position."
Were those reasons for the review being irrelevant
put to you?
No.
“It is, to my mind, in any event, now clearer than ever
that Review (or indeed any other exercise not involving
a third party adjudicator (not mediator)) just isn't
capable of putting these issues to bed in the minds of
some. That does not need to be pitched as a bad thing:
yes, it frustrates the Review and is 'uncomfortable’,
but it has the clear merit of being independently
determined and final. Indeed, before you joined I was
racking my brain, with others, about how we might find
a way of getting these cases or one of them to the
court. None of this [is] new, but I do think the trick
will be in the ‘sell’. Anyway that's my view ..."
Was it explained to you that the view was irrelevant
because it wasn't capable of putting issues to bed in
the minds of some?
137
a very large volume of contemporaneous material that
explains your conduct and the conduct of those around,
you.
Mm, mm.
Just a few topics, if I may. Firstly, can we look,
please, at the one of the first excursions into court
and the outcome of it, namely the strikeout application,
by looking at POL00103351, and look at the foot of the
page, please. We're now in October 2018. It's an email
to you, copied to others, from Jane MacLeod and she
says:
"I understand Tom Cooper has recommended you read
the judgment from the hearing last week."
It's attached:
"We received the decision on Monday evening and the
decision rejects our application for strikeout of the
significant parts of the evidence [‘contained’, I think
that should say] in the claimants’ witness statements.
"The application was decided on case management
grounds for which the managing judge has considerable
discretion; applying that discretion, the managing judge
set a very high threshold for strikeout, and concluded
that we had not established to the necessary standard
that the claimants’ evidence could never be relevant to
the case, given the number of Common Issues; the
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All of these ruminations which is from -- is it Patrick
Bourke?
Yes, this is --
Patrick Bourke -- you know, I had, as I've explained
twice -- the way it was represented to me was that
de Garr Robinson, who was the senior counsel, advised,
‘on strong advice, that the report should be discontinued
and repurposed. I can't ever remember receiving all of
the -- you know, the product of this kind of thought
piece or whatever, you know, justificatory type logic,
no.
It might not just be a thought piece of justificatory
logic, it might be revelatory of the true reasons
operating on some people's minds for not continuing with
the Swift recommendations and they were instead badged
up to you as needing to be stopped because a silk had
said so in strong terms?
You know, it looks that way, doesn't it?
Thank you very much. They're the only questions I'm
going to ask you about the Swift Review.
Can we turn to a separate topic, please the conduct
of the Group Litigation. You've addressed this in very
considerable detail in your witness statement and,
therefore, I'm not going to ask you about a lot of it
because you have exhibited to your witness statement
138
‘considerable legal analysis' each will require; and
what our case on those issues is ... he confirmed that
he will apply properly the law on admissibility when it
comes to trial, and the November 2018 Common Issues
Trial will not rule on matters which concern Horizon or
whether Post Office actually 'breached' its obligations
to the claimants (matters to which most of the disputed
evidence goes and which will be dealt with in later
trials).
"As previously advised, this is consistent with the
managing judge's approach of wanting to give the
claimants their ‘day in court’ while applying the
orthodox legal position. That said, we lost the
application and can expect the claimants to be awarded
their costs when that question is dealt with on the
first day of the trial (estimated to be £120,000).
"In deciding the application, the managing judge was
critical about conduct of the case (see particularly
paragraphs 55-57), including intimating that we were not
acting go relatively and constructively in trying to
resolve this litigation (which criticism was levelled
equally between the parties); and that we had impugned
the court and its processes by making the application
for improper purposes. This response is extremely
disappointing given the approach that we have been
140
(35) Pages 137 - 140
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adopting, and his challenge as to the purpose which we
had applied for strike out is at odds with comments he
made during the various procedural hearings over the
past year. Nevertheless, we are refining our
preparation for trial -- including our reactive
communications plan -- in the context of the judge's
remarks."
Then back to page 1. You say:
"Thanks ... I've read the judgment, and the judge
does seem to be somewhat negative about our efforts to
take out elements of the evidence, even if he does
acknowledge that both sides have been uncooperative with
each other in the management of the case. My worry is
that some of his points at the end betray what looks
like an inherent dislike of our ‘aggressive’ approach to
the individual claimants as well as an ‘aggressive’
approach to litigation, as well as a rap over the
knuckles regarding what the judge sees as using negative
PR as part of our argument. Interesting to know whether
this initial response from him suggests any change of
tack on our part."
So I think would it be fair to say you were
concerned about the judge's criticism of the Post
Office?
Yes. Was this -- just to be clear, was this the case
141
I was asking the question.
So you say at the end:
"Interesting to know if this initial response from
him suggests any change of tack on our part."
Is that a question back to Jane MacLeod?
Yes. I think -- you know, and obviously -- without
wanting to sort of immediately prod and say, "Look it
looks like you're wrong", I'm inviting a comment.
That leads me to the question: what role did you play,
therefore, in setting or amending the Post Office's
strategy in the Group Litigation?
So I think you'll see, I don't know if there's another
email chain subsequently, where the point is made to
Jane, and there are various responses around a change of
tack, et cetera, et cetera. Somewhere, I think.
I think that's much later.
Is it? I'm sorry, there's so many documents it's hard
to-
Yes.
So I'm not -- I mean, I can't tell you, if we don't have
any documents, exactly what the output of this was. At
this stage, you know, there's obviously some concern,
but -- and the point has been made. I'm not quite sure
what happened as a consequence of me inviting some kind
of response here.
143
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management conference number 2? II'm just trying to, you
know, get the chronology. So we had case management
conference number 1, at which point he was quite
critical of both parties, who he said were being
uncooperative.
I think that was in March '17?
And this is number 2, is it?
I don't think it's CMC number 2. I think's a separate
strikeout application.
Okay, so progressively the judge, as I read things,
became more critical and what began as a sort of fairly
even-handed criticism of both parties, I think, by this
time he, you know, had started to become somewhat
critical of the Post Office, and that's why I suspect
I asked, you know, "So what do people think of this,
actually?"
The words that were reported to you and which appear in
the judgment -- namely that the Post Office had made the
application for "improper purposes" -- are quite strong,
aren't they?
They are, and also, one of our people apparently -- this
is the PR reference -- I think said something like they
felt some of the additional evidence could potentially
damage the reputation. I can't remember what the -- so
I knew what the issues were and that was really why
142
So back to the question of what role did you perform:
you weren't a member of the litigation steering
committee?
Well, by this time, I may be wrong, this is 2018 --
October '18.
-- we had formed the Board subcommittee and so I'm not
quite sure whether this is in the context of the
executives or whether this is something that was going
through the Board committee. I would presume that this
was an exchange between myself and the executives.
Is that because of those that are copied in on it?
I'm assuming that, yeah.
Again, approaching the question from a different
perspective, who determined the Post Office's litigation
strategy?
So, at that point, we had a board subcommittee and the
arrangement was that the executives managed the
day-to-day elements of the litigation and were required
to escalate any significant decisions to the Board's
subcommittee.
Did Government have any role in the strategy that the
Post Office took to the litigation?
Well, Tom Cooper was a member of the Board subcommittee,
and one of the key reasons he was a member of the Board
subcommittee was because he was the BEIS representative
144
(36) Pages 141 - 144
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on the Board.
Can we turn forwards, then, to POL00103352, foot of the
page. Same day, 18 October, 10.30:
"Tim
"Have you seen the judgment from the other day?
It's worth a read."
Then further up the page, your reply, same day, at
2.00:
"I've now read it. Judge is critical of both
parties, but already sense he is not well disposed to
us -- the word ‘aggressive’ is used a couple of times in
connection with us, in relation to the inadmissible
evidence claim, and the treatment of [a subpostmaster].
The tone of his comments on the comments at the end, on
the Common Issues trial, and the purported objection on
our part for PR reasons, is definitely not helpful.
I've asked for an update on whether this ruling and its
tone, suggests any change of tack."
Yes, so that was the chain that I was referring to
earlier, where I think we picked up, you know, the
critical comments of the judge, and at that point was
asking, "So, guys, what are you going to do about this?"
So what happened as a result? You've asked directly
Jane MacLeod, copied to Paula Vennells, does what has
happened on this occasion, resulting in the publication
145
committee as appropriate.
We shouldn't see this kind of communication as the --
a means at which strategy was decided or carried into
effect?
Well, I suppose in a way you've got myself, Tom Cooper
and I'm not sure if, at some juncture, Ken McCall, who.
was the -- another member of the committee -- would have
been involved in this, but, I mean, it at least is being
dealt with and two significant members of the committee
are aware of it.
Thank you. Can we move forwards, please, to March 2019,
to look at the recusal application. Can we start by
looking at POL00023898, and look at page 2, please.
An email of 15 March 2019 from Jane MacLeod to you, Tom
Cooper and Alisdair Cameron. She says:
"As flagged on the Board call on Tuesday, we have
sought further advice on appeals and as to whether we
have grounds to request the judge to recuse himself on
the grounds of bias."
So I think the Board call previously was the Tuesday
of that week:
"We sought advice from Lord Neuberger who stepped
down last year as President of the Supreme Court (and
... was the highest judge in the [United Kingdon]). We
sought his views as to whether the draft judgment
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of this judgment, suggest a change of tack? UKGI have
sent the same judgment to you, saying it's
an interesting read. You've replied saying exactly what
you've done. What happened?
Yeah, so Tom and I were colleagues on this committee and
I don't know if someone can bring it up, but there is
a subsequent email chain and someone has spoken to Jane,
and I think it was Paula Vennells summarised a list of
outputs from that discussion, which -- I can't remember
which document is relevant to this. But there is one.
I will endeavour to search for that whilst other people
ask you some questions because I don't have it at my
fingertips at the moment.
So is the answer, then, that the primary vehicle for
setting the strategy was the subcommittee?
Yes.
But there were back channels of communication, such as
this one, in which members of the subcommittee
communicate?
Yes, I think the broad -- I can't remember the -- there
is a document somewhere with the terms of reference of
the subcommittee and, from memory, it makes fairly clear
that the management of the litigation is by the
subcommittee and executives, who manage the thing on
a day-to-day basis, need to escalate matters to the
146
demonstrated the following grounds for appeal:
"Whether the injured has correctly interpreted and
applied the law as to construction of a document or
application of a principle of law;
"Whether there are grounds to argue that findings
have been made as a result of serious procedural
irregularity (which goes to the admission of, and
reliance on, among other issues, inadmissible evidence);
and
"(most urgently) Whether Mr Justice Fraser
demonstrated grounds on which we could apply for him to
recuse himself.
"The test for recusal is ‘whether the fair-minded
and informed observer, having considered the facts,
would conclude that there is a real possibility that the
[judge] was biased’.
"Attached is Lord Neuberger's preliminary [note]
([the note he refers to is] put together by David
Cavender summarising the key extracts of the judgment
and trial transcript). As you will see in paragraph 5
[he] states that although he has only looked at the
issues very cursorily ‘at least some of them raise quite
significant points on which the [Post Office] has
a reasonable case, and at least on the face of it, some
points on which the [Post Office] has a pretty strong
148
(37) Pages 145 - 148
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case’.
"he suggests that if we wish to rely on the
ground of procedural unfairness at an appeal, then ‘Post
Office has little option but to seek to get the judge to
recuse himself at this stage’ and in paragraph 20 that
if we fail to act promptly ... we ‘risk being held to
have waived [our] rights, or at least weakened our
position on the recusal issue’.”
There is a timetable.
The risks are:
[If] The application is successful and the ...
trial is adjourned ... we proceed with an appeal on the
Common Issues Trial ... and a new judge is put in place
"The application is unsuccessful ... then it is
likely that the judge is further antagonised, however he
will be aware that the Common Issues trial is
progressing which includes ‘procedural unfairness’
assertion. Possible impact in that scenario is that the
judge is more cautious to as behaviours to (possibly)
[Post Office's] benefit."
Over the page:
"The theoretical downside to a recusal application
is that it fails and that Fraser remains the judge at
Trial 3 which will require multiple findings of fact
149
many postmasters had been convicted and, in the same
way, in a funny kind of way, this -- if I had had some
meaningful statistics, I think if all of us had had some
meaningful statistics about how often judges are
recused, we might have looked at this in a slightly
different way because I have a suspicion it isn't very
often.
And I think one of the problems was that, you know,
if you take advice out of the context of the frequency
of the events you're trying to evaluate, you sometimes
end up with a slightly distorted view of things. And
so, you know, my gut feel -- and I'd had something to do
with judges -- was this, you know -- I was a little bit
uneasy. I have to say.
What was the cause of your unease?
Simply the fact that, you know, it's quite a big deal to
get a judge to accept that they had made a judgment that
was wrong on technical grounds.
Can we go forwards, please, to POL00103446, and scroll
down to the foot of that page, please. Thank you.
Slightly difficult to decode exactly what's going on but
it's an email to you of 16 March, and Jane MacLeod says:
"Below is my high level summary of the call today."
If we go to the foot of that page there, where the
summary begins:
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which are more tricky to appeal.
"We should also not proceed with this course of
action unless we are prepared to appeal a decision by
him not to recuse himself.
".. I propose today to brief a further senior silk
(probably Lord Grabiner) to act on the recusal
application ...
"Next steps
"... this is clearly a Board decision and we would
need to give the Board time to consider the options
Then some practical arrangements given that Lord
Neuberger was in Argentina.
Do you recall the issue of the recusal of Mr Justice
Fraser being raised in this way?
Yes.
What was your initial reaction, if you had one, to the
suggestion that the Post Office should apply to a judge
to recuse himself on the grounds that he was apparently
biased?
If I'm honest, an element of unease. In a way, this
is -- it's a bit analogous to what I mentioned at the
outset of today, which is one of the things that would
have held to frame this kind of decision and, indeed,
the decision that were made at the beginning of this
thing, would have been to know, for example, exactly how
150
"Participants: Kelly Tolhurst MP, Tom Cooper (UKGI),
Gavin Lambert (BEIS), [you], Al Cameron, Jane MacLeod
Then the text of Jane MacLeod's high level summary
commences, and it goes over the page, and if we go to
page 3, please, and if we look at the second bullet
point down.
“TP [that's you] replied that we have a Board call
‘on Monday evening at which we will discuss issues around
the judge's bias and how that could impact subsequent
trials. Although his [your] initial reaction is that
this is not something the Board is likely to want to do,
the Board must act in the best interests of the company
so we need to consider that option seriously. If we are
to make the application, we understand that it must be
made urgently and should not be delayed", et cetera.
Firstly, why were you having a meeting or a call
with Kelly Tolhurst MP about, amongst other things, the
judge's recusal?
Well, by that time -- so just to give the background, so
Tom Cooper was a member of the Post Office litigation
subcommittee and, by that time, because not least the
judgment in the Common Issues trial had been received,
and it was so damning, by that time, I think the
department was becoming worried, concerned and wanted
152
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a higher level of involvement. And Kelly Tolhurst was
a relatively new -- because it was a fairly actively
fast resolving door over there -- she was the relatively
new Parliamentary Undersecretary of State at what was
called BEIS at that time, I think.
So the reason she was involved was that, you know,
Tom, I think, felt it was necessary to get the Minister
directly aware and involved in potential decisions that
were being made around the judge's recusal.
What part did Government therefore play in deciding
whether to apply for the judge's recusal?
My assumption is -- and I've no means of telling from
this or indeed where I sit now -- is that Tom Cooper's
role was as the Department's representative on the Board
and this Board subcommittee. As it happens, he recused
himself from the decision because -- I can't remember,
there was, you know, some reason about the executive and
the judiciary, and stuff like that but, essentially, you
know, he would have been the conduit through which
I would have assumed we were getting a departmental
view.
Why did Post Office need a departmental view on whether
to apply for a judge to recuse himself?
Well, I think this was simply an example of where
matters had got very serious. So you have to see things
153
But just to stop there, that was because of your role as
Chair of HMCTS?
AtHMCTS. But, put that to one side, I was there and
I would have been involved in that discussion and, you
know, I'm not trying to back out of this thing. So we
had advice from two sources. We had advice from
Neuberger and we had advice from Grabiner. Grabiner's
advice was pretty strong, actually. I think he said
something along the lines of we had a duty, almost, to
ask for the judge's recusal, and —-
Stopping there, what did you understand -- you're right,
he did say that -- what did you understand him to mean
by that the Post Office was under a duty?
I can't recall the detail exactly but the way the advice
was framed was that, you know, we kind of almost -- to
ensure the -- you know, the business of the
administration of the law required us, where we thought
something had been incorrectly managed, for whatever
reason, we needed to act upon that.
Just stopping there, and can I put two potential
hypotheses to you in terms of the Post Office was under
a duty to apply: one could mean that the Post Office
was, as a matter of company law, its directors, it owed
a duty to make the application in discharge of its
duties to its shareholder?
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in the context of the litigation producing an output
from the first trial that was a loss on virtually every
count, and our sole shareholder beginning to get
concerned, from all sorts of points of view, not least,
I imagine, they could see that there would be
a significant reputation, significant cost, all sorts of
things.
Was it right that your initial reaction, as is recorded
here, is that this, ie applying to recuse the judge, was
not something that the Board was likely to want to do?
For the reasons I was trying to express earlier, I think
most of us -- I'm trying not to be overly complimentary,
Sir Wyn, most of us think that judges usually get it
right and, you know, have an inherent respect for the
judiciary. So it would have excited a certain amount of
unease in most people, I think, to suggest that, you
know, the judge had got it wrong.
And was biased?
Or was -- and/or biased.
What changed, to your understanding, from your unease at
making the application and your reporting that this was
something that the Board was not likely to want to do,
to the making of the application?
So the first point I should make, you know, is that
I also recused myself from the decision --
154
Mm.
Alternatively, it could mean that, if you wished to win
this litigation in the final result, procedurally, you
are under an obligation to take this point now and not
wait until you appeal the substance. Can you recall
whether you formed a view as to in what sense you were
under a duty to make the application?
Honestly, I can't, at this distance. But I think --
I don't want to make too much of this duty thing.
I think we just got advice from two very, very senior
lawyers and felt, on balance, that advice should be
taken.
So, in answer to my question, the thing that changed was
legal advice from two very senior lawyers, one of whom
said that the Post Office was under a duty to make the
application?
That's a fair description of what happened.
Thank you very much.
The last topic, please. You told us earlier that
you were not aware of concerns being raised about the
Fujitsu employee, Gareth Jenkins, giving evidence in
court in Post Office prosecutions that may have been
false or incomplete --
Mm.
-- until much later on?
156
(39) Pages 153 - 156
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Mm.
You couldn't remember when.
Mm, mm.
Can I ask directly, then, that we look at POL00006357.
Thank you.
If we just go to the last page, which is page 14,
and the foot of the page, we can see this is an advice
of 15 July, written by Simon Clarke, in a firm of
solicitors that the Post Office used, Cartwright King,
to advise it on matters relating to the prosecution of
subpostmasters.
Mm.
If we go back to page 1, i's advice on the use of
expert evidence relating to the integrity of the Fujitsu
Services Limited Horizon system.
If we just look at page 13, please, and the author
says:
"What does all this mean? It means that
[Mr Jenkins] has not complied with his duty to the
court, the prosecution or the defence ...
"38. The reasons as to why [Mr] Jenkins failed to
comply with his duty are beyond the scope of this
review. The effects of that failure, however, must be
considered ...
“[1] [Mr] Jenkins failed to disclose material known
157
Lastly:
"Where a convicted defendant or his lawyers consider
that the failure to disclose the material reveals
an arguable ground of appeal, he may seek leave of the
Court of Appeal ...”
When were you first made aware of the existence of
this advice by Simon Clarke concerning Gareth Jenkins?
Oh, well, I mean, probably in reading this in detail,
when I actually got all of the -- I can't remember,
I think it must have been in my bundle, but I mean
certainly years after the event. I mean, one of the
things that struck me was I don't think Swift was shown
this.
Correct.
Yeah, so, you know -- yeah. I mean, I can't tell you
exactly when but, suffice to say, I would imagine,
post-the trials, probably.
By the trial, do you mean the Horizon Issues trial?
Or both -- I mean, you know, the point I am making,
I think, is it -- I would have known about this at the
point at which we were reviewing stuff after the
litigation, yeah.
So, too late for it to matter then?
Too late for it to matter then, yeah.
What was your reaction on being provided with a copy of
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to him but which undermines his expert opinion ... in
plain breach of his duty as an expert evidence.
"Accordingly [his] credibility as an expert witness
is fatally undermined ...
"[3] ... in those current and ongoing cases where
[he] has provided an expert witness statement, he should
not be called upon to give that evidence ...
"[4] Notwithstanding that the failure is that of
[Mr Jenkins] and, arguably, of Fujitsu ... this failure
has a profound effect upon [Post Office] and [Post
Office] prosecutions, not least because by reason of
[Mr] Jenkins’ failure, material which should have been
disclosed to defendants was not disclosed, thereby
placing [Post Office Limited] in breach of their duty as
a prosecutor.
[5] By reason of that failure to disclose, there
are a number of now convicted defendants to whom the
existence of bugs should have been disclosed but was
not. Those defendants remain entitled to have
disclosure of that material notwithstanding their now
convicted status.”
Penultimately:
"Further, there are also a number of current cases
where there has been no disclosure where there ought to
have been."
158
the advice, or having it summarised to you?
Well, this is one of the things where, again, I think,
when you've looked at a lot of the documents that we
have reviewed today, it's hard not to draw the
conclusion that decisions might have been different, had
a lot of these things been known at the time and, you
know, this whole terrible raft of events, I think, in
part, is because, as problems build up over time, the
wall against breaking them down gets higher and higher,
and this was just part of the wall, and it didn’t break
down, really, until we got to the litigation, I suppose.
Can we look, please, at POL00167395. These are minutes
of a Board meeting held on 19 November 2020 by
conference call, and you'll see that you are present.
It's a special meeting concerning the CCRC and
you'll see that there's quite the cast list.
Mm.
If we scroll down, and scroll still further, and then
cover the page. Second paragraph on that page:
"Brian Altman informed the Board that a layer of
complication had been added to the court proceedings
yesterday."
Then scrolling down, please. That paragraph refers
to essentially the disclosure within the proceedings and
outside the proceedings of the Clarke Advice, okay?
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Mm-hm, mm-hm.
That's the earliest that we can see that a reference was
made to the Clarke Advice in any Board meeting.
Mm-hm.
You wouldn't presumably be in a position to say, "No, we
were told about it much earlier"?
No.
I mean, lastly on this point, if we look at
UKGI00017966, thank you, this is a reply of the Post
Office to Tim McCormack, one of his searching Freedom of
Information requests. He says:
"Good to see the new spirit of openness in action
yet again this morning with the publication of redacted
copies of Board Minutes.
"Could you therefore provide me with copies of all
board minutes in which is mentioned the Clarke Advice or
Clarke Review."
So he's after that information.
Yeah.
Then looking at the bottom paragraph there:
"Post Office Limited has conducted reasonable and
proportionate searches and has identified two sets of
minutes in which the ... Clarke Advice was mentioned:
the minutes of a meeting on 19 November", which is the
one that I just took you to.
161
very serious problems which I and the Board were
contending with. The context I give you on this is that
I believe, in 2021, we had 60 Board meetings, something
like that, to do with the fallout from this whole thing.
So whether anything happened as a consequence of
this, I can't tell you for sure. What I can tell you is
that the amount of time and work and effort that I and
other Board members put into trying to essentially
reconstitute this whole business from top to bottom
might have allowed one of these things to sort of, you
know, just evaporate without anything happening as
a consequence.
So I can't tell you for sure what happened but I can
tell you this was an incredibly, incredibly busy time.
You have to remember, if you take an organisation and
within the space of six months you find out that the
whole basis on which your business has been conducted
was wrong, you find out that your -- the whole basis of
how you are somehow operating has to be changed. The
amount of work to try and put things right, correctly
so -- I mean, all of these things needed putting
right -- but the workload was just immense and all time
consuming.
And, whatever, you know, I can tell you the new CEO
and the new team were making strenuous efforts to try to
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Yeah.
"_ and the minutes of a meeting on 4 February”, which
was obviously later in 2021.
So it seems that the Post Office rather agree that
the earliest mention of the Clarke Advice of July '13 to
the Board was 19 November 2020.
Mm-hm.
When it was revealed to the Board, the Clarke Advice,
did anything happen as a result?
That's -- I can't answer that question, I think,
because --
I'm thinking
It's a very -- it's
-- Mr Parker, something like "Well, hold on, I've been
in position now" -- speaking from your perspective --
“for five years or so" -—
And how come I didn't know about --
-- "I commissioned this guy called Jonathan Swift to
look at things" --
All right, I get the gist of your question. Alll right.
So, look, this is 2020 or '21 or something like that.
Yes, November 2020, earliest mention.
Again, I have to put in context some of my answers here.
Previous context I have given you is the Post Office
wasn't just about Horizon. There were a lot of other
162
put things right. So that's the context I would give,
I suppose.
MR BEER: Tim Parker, thank you very much for answering my
questions.
There are some questions from Core Participants.
Could we take those, please, at 3.30, sir.
SIR WYN WILLIAMS: Yes.
MR BEER: Thank you very much, sir.
(3.18 pm)
(A short break)
(3.30 pm)
MR BEER: Good afternoon, sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, I can. Thank you.
MR BEER: I'll just wait for the room to settle down
alittle.
‘SIR WYN WILLIAMS: Mm-hm.
MR BEER: Sir, the questions are, to start with, from
Mr Henry up to 30 minutes; Mr Stein up to 10 minutes,
and then Ms Patrick, up to 10 minutes.
SIR WYN WILLIAMS: All right, thank you.
Questioned by MR HENRY
MR HENRY: Mr Parker, together with Ms Page, I represent
a cohort of Core Participants, including Seema Misra,
and Mrs Oyeteju Adedayo. I want to start off with some
general questions, if I way.
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The first is the Sir Anthony Hooper argument. Did
it ever occur to you that the SPMs who ended up being
prosecuted or milked for shortfalls were hardworking
people trying their best to put food on the table for
their families in their own self-reliant way and
therefore why would they resort to stealing from their
own businesses?
I think the way you put the question, there is -- with
hindsight, it would appear that -- and this was the
scale point I was trying to make earlier, which is that,
if I had seen, I think, at the outset, how many people
had been convicted and how many people had been
terminated or had an employment issue because of
apparent shortfalls, I think the scale of the problem
would have been apparent. And I think part of the lack
of response, or immediate response, partly came from the
apparent scale, if you like, of how many people there
were relative to the population of subpostmasters. But
you're absolutely right, I mean, you know, when do you
start to question whether people are honest or not?
How many people do you need in a population before
you think, well, can't be the case they were all crooks,
or whatever?
Well, I'm going to come to that and, fortuitously, that
was my second point because, when notifying the
165
done and we did all of that, the way the problem
appeared to me was that there were 130 people, I think,
going through mediation or 136, and there were 23 cases
that were going through the CCRC.
What I was trying to say earlier was that I actually
didn't become aware of just how many of these people had
been convicted until quite late in the day and you might
say, well, why didn't you ask? And that is the point
I was trying to make. With hindsight, we could, and
perhaps this question should have been asked: that
I know 23 people are going through the CCRC but can you
tell me, please, how many people have been convicted
over the last 15 years?
And that, you know, might have precipitated
a totally different response to this thing because, as
I was trying to explain earlier as well, you can look at
it through the lens of was the computer system reliable,
or you could look it through the lens of how come so
many people have been convicted, and how does that
compare with the average for people being convicted in
a retail business, for example, which is one of the
questions I ended up asking.
So I know it's an unsatisfactory response to you and
your clients but, if this thing ever happened again and,
you know, the issue was some people have been convicted,
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Government of the liability regarding convicted
subpostmasters -- so not dealing with civil, but purely
criminal -- in your letter to the Secretary of State,
you mention that 959 cases had been identified in which
Horizon evidence had been used to secure a conviction.
Do you remember that letter?
Well, when was that written, please?
Well, we'll put it up on the screen. It's POL00031104,
and you can see it's 29 April 2020.
Yeah.
If we scroll down -- I can never get it right either,
whether it's down or up -- but you'll see that there is
a reference to 959 cases, it's the penultimate line on
the screen.
Yeah.
So I am going to describe it as the epidemic of theft
and false accounting. Do I take it from your answer,
your previous answer, that you never questioned the
conventional wisdom that this huge portion of
subpostmasters was dishonest, and that this
statistically significant number of allegedly dishonesty
subpostmasters did not make sense?
Mm, the point I was trying to make earlier, and maybe
I didn't make it clearly enough, was that when we --
when I tuned up and I asked for the Swift Report to be
166
one of the first questions to ask is, well, out of
a population of how many, and how many other people have
been convicted who aren't complaining, or aren't going
through mediation?
So do I take it, again, that that work, that statistical
analysis, came far too late?
I'd have to agree with you on that.
I want to move on to a different subject and
I appreciate that you were very much, as it appears,
reliant on experts but the recusal decision to unseat
Mr Justice Fraser, did you, notwithstanding the advice
you received, take into account or recognise the impact
that would have had on the subpostmasters' ability to
secure an outcome in their favour? In other words, did
you reflect that, if you had been successful, that would
have killed the claim stone dead?
So I think one of the paradox -- well, it's not
a paradox, exactly, but, as I said at some point today,
it always seemed to me that, had this been managed in
a more cooperative manner, the civil proceedings, it
could have, and perhaps should have, ended up with
a judge-determined set of decisions around the contract
and the reliability of Horizon. Of course, what
happened was it was an adversarial combat and each side
was trying to win, and the recusal was one decision that
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could have stopped your client's case dead, I'm sure
there were other things that, had they lost, would have
ended up with a termination to the claim, for example,
you know, if the judge had decided in the Common Issues
trial substantially not to change the agency
arrangement, that might have changed things as well. So
my take on it is you're right, you know, had that -- had
the recusal thing been successful, it could have stopped
the case dead. I mean, I -- again, it must seem,
perhaps, somewhat naive in retrospect but I -- my
intention, and I had hoped, with these proceedings, that
we would fight, you know, a sort of fair battle, and
I think the -- one of the issues was the legal teams got
into a sort of "we want to win" litigation, without --
at virtually any cost.
And we got into a situation where people were
doubling down and the recusal thing, to me, was
a doubling down thing in retrospect. So, you know, for
me, this is one of the most unsatisfactory aspects of
the whole GLO.
Do I take it that you felt that you had, as Chair, lost
control of the litigation because, obviously, these
things were being done ostensibly, shorthand, in your
name but you appear to, by your answers, suggest that
the lawyers had got out of control and that they doubled
169
because, today, I was toying with making an opening
statement: stand up and say I'm deeply, deeply sorry, as
many people have done. And there ensued a discussion
with people, should I do this, because, you know,
I would like to say sorry. And the response I got was
that, well, you could do this, but actually, you know,
people have got tired of that and it all rings a bit
hollow and you probably are just going to annoy people
more than really give them any sense of your real desire
to say sorry.
And I'm afraid, in these circumstances, it's very
hard to either prove that your sorrow and apology is
genuine, it's hard to find language which, if you
attempt to express it in the extreme, just sounds as if
you're being hyperbolic and simply trying to get effect.
So there is no satisfactory answer to this. There is no
real way to say sorry in a convincing way because the
people who have been affected just feel the damage has
been done, and you're scrambling to sort of fill a small
gap in that sort of failure to accommodate. So I don't
think a good letter could have been written. I don't
think any letter would prove to be satisfactory. And
it's not easy, when you've got a lot of people who are
involved.
So I know that's an unsatisfactory answer, but I'm
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down and it had been adversarial and that you had,
together with your colleagues, nothing to do with it?
So, look, Mr Henry, it's not my intention to release
myself from responsibility for these events. When
you're the Chair, you, you know, the buck stops with me.
So for me to try to characterise this as "Oh, it's all
down to the lawyers and its nothing to do with us",
that's certainly not my intention.
I think what I'm trying to highlight is, in the
balance between the client and the lawyers, sometimes
the shift goes too much in one direction and, instead of
being, you know, the dog, it's the tail that starts to
wag the dog, a bit. And I think the tail was wagging
the dog a bit when we got to this. The recusal thing,
as I said, I think I had misgivings about it at the time
and it's -- again, I tried to make the point. I don't
know how many just are recused but I imagine it isn't
very many.
Now, Mr Parker, moving on again to a separate topic, and
I assure you that there is some purpose to it, when you
sent out letters of apology subsequent to the Horizon
Issues judgment, reflecting on this now, Mr Parker, was
that performative or was that a genuine expression of
contrition?
So, the subject of apologies. It is quite interesting
170
trying to express the reality of the situation.
When you signed those letters, though, did you remain of
the view, even after the Horizon Issues judgment, that
the subpostmasters who had been prosecuted or pursued in
the civil forum were guilty/liable? I mean, I'm trying
to ask you to reflect on how hard it was to let go of
the idea that the subpostmasters who had challenged and
who had taken on the Post Office weren't at it?
I see the point to your question and my view is that,
once we had reached the end of the trials, the game was
up, as it were, and it was time to just, you know --
Ive tried, you know, when you get a business that is so
upside down in terms of its structure and its
relationships, I can see why you're asking the question
but, from my standpoint, you know, I felt the game --
you know, we just needed to change completely and, with
the new Chief Executive and the team, we have tried, or
we did until I left in 2022.
So you don't believe that a mindset of blame still
persists? I know you left in 2022 but you don't believe
that a mindset of blame will persists within the
organisation?
I can't speak for an organisation. I can only speak for
myself and I would say that Nick Read and his team have,
at all levels, made a huge effort. Now, that isn't to
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say that some of the people who were working at the time
of these events are still at the Post Office, because
it's impossible to run an organisation, just clear
everybody out, as I hope, you know, is obvious. But the
mindset has been completely changed and I would say,
when you have such a huge shift in culture to make, it's
never made overnight. I mean, this is -- you have to
appreciate it's one of those slightly irritating aspects
of these sorts of events, is that trying to put them
right is no easy matter. And it requires determination
at the top.
And believe me, after the trials, I and the rest of
my Board, and Nick and his team have done, I feel, as
much as they can. The one area that I simply cannot
speak for is money, because money unfortunately -- once
the fact that there was a huge liability at stake, the
money is no longer a matter for the Post Office, it's
a matter for the shareholder.
I see. Well, I'm going to now go to a specific example
where I suggest, you see, the mindset hasn't changed.
Taking Mrs Adedayo's case, what is your view on the Post
Office's recent written submission to the Inquiry,
effectively branding her a criminal, despite her
conviction having been quashed? I mean, you may not be
aware of it but I can put it up on the screen, if you
173
SIR WYN WILLIAMS: Well, if it helps, Mr Henry, I think it's
fair enough.
MR HENRY: So be it, sir.
Can I go to time, please, now, and I've got, having
dealt with some general questions, some specific issues.
Throughout your tenure, you had many competing
obligations devouring your time and you wouldn't be
human if, from time to time, forgive the expression,
they were distracting you. You would agree?
Actually, I've got a slightly different view to that.
I would say one of the strengths of having multiple
appointments is that you have got exposure constantly to
what is going on in a range of different activities.
And that actually means that you are well acquainted
with the business world and other worlds, actually, in
what's going on. And so I would say -- and I've tried
to explain earlier that, you know, being an effective
chair is partly to do with time but it's also to do with
judgement, and I think one’s judgements and one's
involvement are actually improved by having a range of
different things to do.
That, curiously -- and I'm sure that you weren't
plagiarising it -- was Mr Leighton’s similar explanation
for the competing demands. But you have said yourself
it wasn't just about Horizon. There was an awful lot of
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like. But I quote:
"The Inquiry will be aware that this [that is.
Mrs Adedayo's case] is the sole case study where the
Post Office does not accept that the conviction was
unsafe."
Do you unreservedly reject that victimisation?
First of all, we haven't got the letter yet and,
secondly, unless I have got all the facts at my
disposal, Mr Henry, I don't think you can expect me to,
you know, deliver a black and white response on this.
I'm no longer, obviously, at the Post Office, which
precludes me a little bit from knowing what all the
background is.
Well, Mr Parker, her conviction was quashed and the Post
Office still brand her a criminal. I mean, surely can
you not reflect upon that and distance yourself from it
and repudiate it?
I think I'd love to be able to just say, yes, Mr Henry
it's absolutely right, your client -- you know, I'm
absolutely with you. Honestly, I haven't had the
background and I simply, much as I would love to sit
here right now and say yes, I would prefer to see the
background first before delivering an opinion. And
I hope anybody in my situation would see that's not
unreasonable.
174
stuff going on, awful lot of stuff going on in the
business, and what I'm trying to suggest to you is that,
to reduce your time at this critical stage before the
GLO, must ultimately be viewed as a serious error of
judgement. What do you say to that?
I say, actually, I gave -- and as far as I'm concerned,
Mr Henry, I gave all the time and attention that I could
and needed to at the Post Office and I think if you talk
to colleagues, look at the Board effectiveness reports,
just do a general trawl, go and talk to people at the
Post Office, you will find that I was well acquainted
with what was going on. I was always well briefed.
When I was in a meeting, I paid very close attention to
the facts that were under consideration. I chaired
meetings well. So, no, I don't accept that assertion,
actually.
I'm going to deal with this very quickly, Mr Parker, but
you are familiar with -- and you have seen, of course,
in the pack that was sent to you -- a number of emails
from Mr Tim McCormack?
Mm.
What I'm suggesting to you is that, because of the
enormous burden on your shoulder, not just simply from
the Post Office but other competing demands, this
affected your ability to grip it personally and get
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involved in what he was saying in a meaningful way, and
so, therefore, you were channelling his requests onto
other people who were not serving your interests. In
fact, they were delaying, denying and stonewalling
Mr McCormack. Now, would you like me to deal with the
emails in detail or --
Yeah. I understand because I've read the emails --
You've read the emails?
-- and I understand the point you're making. And I've
tried to explain earlier that, when I joined the Post
Office, and bearing in mind most of these emails were
probably around April 2016 and July, or whatever,
I think that's right, I assumed -- perhaps, with
hindsight, incorrectly -- that the people who were
advising me were honest, you know, were competent,
et cetera. And in virtually every other company I have
been in, when I get a sort of email or letter that which
comes in, which is essentially about a legal matter and
says, you know, in capital letters "I will say, you
know, what's going on, and take it away and give me some
background”.
And I understand the point you're making but I can
honestly tell you, Mr Henry, that whilst, you know, it
might appear that we should have grappled with Tim's
points and really concentrated on them, and it's very
177
Office was being prepared -- I'm going to call it
a grooming pack, prepared by Mark Davies -- that they
were trying to get you on side and that, notwithstanding
your genuine desire to be independent, notwithstanding
the fact that you had no axe to grind, that gradually
you were compromised and, to use the analogy of the
wall, you became immured in prejudice; what do you say:
the institutional prejudice of those people that you
relied upon and trusted who surrounded you?
What I will say is this: behind a set of events that we
have been discussing today are a complex mixture of
interactions between people. Some self-consciously
driven in a particular direction, others not. Others
just being part of it, and so, whilst your
characterisation, I think, probably has some truth to
it, matters are far more complicated than that, and
I would say, in some respects, yes, the wool might have
been pulled over the eyes and, in other respects not,
sometimes happened, and sometimes didn't. But there
isn't -- you know, it is very unsatisfactory but it's
like, you know, here's a set of wrongs, and we put them
right, and how did the wrongs happen and, exactly, you
know, where are the root causes?
And the root causes of this thing of course, at the
end of the day, probably reside in the software. The
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unsatisfactory, looking back, to see that it was handed
‘over to a bunch of people, that we -- you know, arguably
weren't going to handle it well -- those were the
circumstances at the time.
I'm not trying to get out of responsibility here.
Some mistakes in that respect were made but I honestly
wouldn't say that was a function of me not having enough
time, as such.
If it wasn't a function of you not having enough time
then why would you not wish to go to the ends of the
earth to establish whether or not an innocent woman had
been imprisoned?
Because this was an individual case, which I think was
going through the CCRC. I can't quite remember the
context and, actually, I have tried to grapple with this
thing, largely through the collection of issues that
were brought together, and you're right; I mean, perhaps
had one rushed after the Misra case, there might have
been some progress. I can't honestly tell you. But if
what you're implying is that somehow, you know, because
I didn't deal with this thing, we didn't really do
anything, didn't really care about this, didn't try to
resolve it, I don't think that's really fair.
What I'm trying to suggest, you've talked about the wall
being built, we've seen how your reception into the Post
178
root causes of the problems we talked about today reside
in the process of investigation.
The individuals -- and this is the point I was
trying to make, you know -- a lot of the problems that
we have looked at happened between 2000 and 2010, quite
historic, and trying to overcome history in a business,
when history is so damaging, is a tough thing to do.
So --
All the more reason, therefore, for people who feared
what impact that could have on the GLO to keep it
battened down, to keep it hermetically sealed so that
none of that would escape; do you see?
I do, I understand the point you're making and I tried
to express this earlier, which is it's got a slightly
unsatisfactory tinge to it because, of course, it
implied that Sir Alan and the JFSA team had to spend
money and had to get support to mount the GLO. But the
GLO, although one might have a lot of aspects of
dissatisfaction about the way it was run, actually did
end up with a judge making determinations which will
change the Post Office forever and, actually, set up
a situation in which your clients, in time, should be
properly compensated because the -- there's been
an absolute clarity in terms of what -- which -- you
know, what was responsible for what.
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Q. Now, Mr Parker, I have to be brief, and I don't want to
be unfair to you but I've only got couple of minutes
left, so I just want to ask you if you feel that the
answer you gave to Mr Beer about this really had to be
resolved, as it were, adversarially was somewhat
fatalistic and that more could have been done to strive
to see the other side and to strive for settlement,
without having to enter into the quagmire of litigation.
A. Yeah. I mean, look, there's no satisfactory answer to
this. I played out -- so if there had been an early
settlement, I could easily imagine a situation in which
your clients will be worse off because, instead of
waiting until the end when it was absolutely determined
by the judge that Legacy Horizon was not robust and, you
know, Horizon Online wasn't robust, you could have ended
up ina situation where, mm, computer system quite
robust. This is the point I was trying to make earlier,
where I played out -- so the post -- I know -- I'm not
trying to escape, you know, responsibility but if we'd
sort of said, "Well, you know, we think we've got
a problem with the computer system, it's not reliable",
the moment you start to get to a “there could be
miscarriages of justice", "there could be a huge
liability here", then the question starts being asked:
well, what's involved?
181
have been attempting to deliberately somehow undermine
a situation that had been, you know, effectively
determined as a result of the trials. I just don't know
where that comes from, honestly.
Q. Finally, do you recognise the suggestion that the Board
looks at lawyers purely from this perspective: they see
lawyers -- this is Rodric Williams, speaking on behalf
of the Board -- as interchangeable tools for optics,
legal advices, polluted product for the Post Office
because of the High Court litigation; is there any
suggestion that you and your colleagues did see lawyers
as marionettes?
A. Sorry, what's the point you're trying to make?
Q. Well, the Board is reported to have told the lawyers not
to advise on safety and Rodric Williams goes on to say
"the Board sees lawyers as interchangeable and tools for
optics". You said that you didn't see lawyers as
marionettes but, I mean, this suggests that perhaps if
this note is a fair reflection of your point of few,
that you did?
A. Is this a Rodric Williams note, is it? I don't think
Rodric really reflects an awful lot of certainly what
I think or what the Board thinks.
MR HENRY: Okay. I think I've run out of time so I'm going
to stop there.
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Q. Final question, please, and I have to compress two
documents, but there are two documents noted by Peters &
Peters, it would seem, but involving number of lawyers,
and one reference is POL00337435, it's dated 24 January
2020, and so that's long after the Horizon Issues
judgment. You are not present, Mr Parker, but you and
Mr Cooper, it is said, wanted to take pot shots at Seema
Misra. Do you have anything to say about that? Do you
recall any research that have been done on what
claimants, convicted claimants, have said in open source
material to try and traw! to see if they had made
previous inconsistent statements so that their
credibility, even after the Horizon Issues judgment but
before the criminal appeal, could be impugned? Do you
remember anything of that nature?
I don't and, funnily enough, this document appeared
fairly late in my bundle. I did have a look at it, and
it is apparently a sort of abbreviated description,
isn't it, of a barristers' meeting, I think, yes.
Yes.
Well, look, somebody writes "taking pot shots", I don't
know what that means to you but it's a fairly colloquial
sort of -- I don't know what they were trying to express
but I'd love to have Tom Cooper in the room here but
I can assure you, neither of us and -- you know, would
182
Thank you, sir.
THE WITNESS: = Thank you.
SIR WYN WILLIAMS: = Thank you, Mr Henry.
Questioned by MR STEIN
MR STEIN: Mr Parker, my name is Sam Stein. I ask questions
on behalf of a large group of subpostmasters and
mistresses and people that worked in Post Office
branches.
You will recall, having dealings in at least 2019,
with a Mr Swannell. At the time, he was the Chair of
the Shareholder Executive and that was later renamed
into UKGI, which is the UK Government Investments.
Okay.
Now, when you get to the end of 2019, there were
discussions that touched on the question of settlement;
do you recall that?
Mm, mm.
Okay. Now, help us please a little bit with this.
Mr Swannell will be giving evidence next week, I think
on Tuesday, and his recollection is of having had a word
with you, sometime in June 2019, whereby you thought the
estimate of the amount involved in the settlement might
well be something in the order of 100 million.
Mm-hm.
Now, contextually, we know that the settlement was in
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the order of, essentially, 50 million, a bit over.
Yeah, yeah.
Okay?
Yeah.
Now that's quite a big difference?
Yeah, mm.
But the 100 million, was that what you thought it was
worth or was that what you were told this may well come
to?
Honestly, I'd like to see the papers because it's quite
hard for me, 2019/20, 100 million, I'd love to be able
to give you a definitive answer but I can't on that.
But do you have a recollection because it's only his
statement where he refers to this. I'm not sure we have
papers that refer to this. Do you have a recollection
as to whether there was any particular barrier, as
an example, to 100 million or --
Well, okay --
-- that was being discussed?
~ all I will say to you and, again, I'm not trying to
escape responsibility, liability, or whatever, is that
whatever discussions happened post-the litigation, the
whole -- the money only comes from one source and,
therefore, you know, whether the Post Office quotes the
number or there's another number, ultimately, the
185
are subsequently contradicted by someone else, so
I can't give you a definitive answer to this, honestly.
But you're not saying no. What you're saying is you
can't really remember; is that fair?
That's exactly what I'm telling you, yeah.
Okay. I'm going to go, therefore, to a document you've
looked at with Mr Beer a little earlier. Can we go to
POL00174397, please. I'd like to go to page 2, once we
get to the document. So do you recall, quite early on
in the questions being asked by Mr Beer, that he was
discussing with you this note, which is a note that was
meant to have emanated, as you understood it, from Paula
Vennells, okay?
Mm, mm.
It's a briefing document of some type, setting out some
of the concerns at that time. Now, you've said
repeatedly a word you use is context, so let's
understand the context of things. So the context of
this note is you come into a business that's overall in
crisis, you agree?
Yes.
Yes. Fundamentally, this is a problem business, in
terms of needing to be turned around, yes?
Yes.
Okay. You've been chosen over another possible
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decision isn't going to be made really in the Post
Office.
Right. So, essentially, you're saying, by that point --
By that point.
-- it's for the Government, as the shareholder --
The Post Office could not probably run, and I may be --
maybe it can now but, certainly in my time there,
I don't think it could have run as a standalone
business. It needed constant support from the
Government.
All right.
And, therefore, any additional cash requirements was
always going to be an incremental Government decision,
one way or another.
So before I move on to another topic, your recollection
of the figures in relation to the settlement was (1) the
money was always going to have to come from Government.
Yes; is that right?
Ultimately, yes.
And, secondly, Mr Swannell's recollection of discussions
around 100 million and, in fact, it being considerably
less than that, clearly demonstrates that there had been
discussions at potentially quite a bit of a larger
figure at some point?
Look, I don't want you to put words into my mouth that
186
candidate as being the right individual to have a go at
doing that, yes --
Yes.
-- and you wanted to find out more about what's going
on?
Yes.
Agai
right?
Yes. II'm just wondering where this is going.
Well, let's see where it's going in a moment.
Yeah.
We know also from your evidence that you said that the
whole basis of the business and the way it was being
conducted, you've referred to that being questioned in
the litigation, because it's about the Horizon system.
Yes.
you're saying yes, you're agreeing; is that
Okay? So when you came in to the Post Office, in the
role that you took over, you must have realised quite
rapidly that questions regarding the Horizon system
integrity were also questions that were threatening the
whole business; is that fair?
Looking at this, as I've tried to explain, in scale
terms, it didn't look that big, in relation to the
population of subpostmasters, the number of people who
were complaining, the number of people who were
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convicted. And so -- and most of these issues were to
do, obviously, with what you would call historic
Horizon. So, from my perspective, you know, we had
a set of issues that were people who'd had historic
problems with Horizon, and then there was Horizon as
an EPOS system, which operated post offices,
effectively.
And the two things were slightly, you know, one is
sort of business as usual, the other is a whole set of
issues that people had had with the system historically.
So this -- as I tried to explain earlier, this was
‘one of a number of problems.
Right. Now, you've said that a number of times. That's
your context point: number of other problems dealing
with the business. But this is about the Horizon
system. It's questioning the integrity of the system;
you agree with that?
A component of it is, yes.
Let's have a look at how serious this was, then. We can
go perhaps to the bottom of page 2, if we may, please,
I think we're there already, and fourth paragraph from
the bottom. Just go up a little bit. Yeah. We see the
bottom. That's it.
Yes.
Right. We can see that the references here are
189
Yes.
Now, accepting your point, which is that, in your mind,
you've got the problem which is you think may well be
largely historical, may be an older part of the system.
Mm.
Okay, but this is in fact actually questioning the
integrity, not only of the Horizon system but also of
management --
Yeah, yeah.
- at the very time you're coming into it?
Yeah.
So it’s raising the very question that Mr Beer was
talking about with you, which is, well, hang on are the
people around you people that you can trust, right?
Um --
Serious allegations.
Yeah.
In fact, allegations that, if true, would be the death
knell of the business that's already in crisis.
Well, I'm not sure I would go that far but you're right
to highlight that. Yes.
Okay, well, let me highlight then and see if I can be
right about something else. Page 1, third paragraph
down, please. Now, I use the term paragraph, the three
main paragraphs from the top under "Note for Tim
191
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obviously to the JFSA complaint --
Yeah, yeah.
-- we see the BBC Panorama programme --
Yeah.
-- and we see references to MPs that are also engaged.
Yeah.
If we scroll a bit further down, please -- my fault,
let's go up again.
Fourth paragraph from the bottom. Okay, the one
that starts:
"We have been robust in rejecting the serious
allegations made in Parliament ..."
Is that right?
Yeah, yeah.
"... made in Parliament and media, particularly in
recent months."
Then it goes on to talk about the issues that
concern:
the campaign's allegations have grown to.
include suggestions of wrongdoing by senior management
Yeah.
"... bullying, deliberate cover-up and abuse of
prosecutor powers."
Now, these are serious allegations.
190
Parker", okay? So it says this:
"The Horizon system deals with six million
transactions every day and has been used by almost
500,000 people since it was introduced. It is currently
used by 78,000 people working in Post Office branches,
is independently audited and meets or [excels] standard
industry accreditations."
Let's take that apart. Did you receive the
independent audit of the Horizon system at this time?
No.
Did you ask for the independent audit of the Horizon
system at this time?
Which independent audit system are you referring to?
Well, go back to the third paragraph from the top, the
one I read out:
"The Horizon system deals with six million
transactions every day and has been used by almost
500,000 people since it was introduced. It is currently
used by 78,000 people working in post office branches,
is independently audited ..."
So stopping there for the moment. Did you see the
independent audit at this time?
So, essentially, I
It's a bit of a "yes" or a "no" question.
No, can I just finish, please? I think I'm entitled to
192
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that. I understand the question that you're asking.
Essentially, I didn't ask for the independent audit.
This was something, obviously, that's been put into the
brief. Now, I'm not quite sure, can you just explain to
me where you're going? Where --
I'm asking the simple question, I suspect answer is
either yes or no. It looks like it's no. Did you see
the independent audit? The answer appears to be no, you
didn't; is that fair?
Well, you know, if somebody says something is
independently audited, that can mean a number of
different things. It can mean somebody has gone in and
looked at it or it can mean that there's a -- I don't
know, but if you're asking had I got the independent
audit? No.
Did you ask for it?
I don't think I could have done.
All right, why couldn't you have done, Mr Parker?
Do you know --
Is that you saying you didn't have the power to -
No.
-- or are you saying you just didn't?
No, this was a brief that I received, and we've looked
at this Sparrow brief and it's -- you know, earlier.
And this is all about -- so what actions could have been
193
whether that means you didn't have the power to do it or
whether you just didn't do it, which?
I think I could have had the power, in theory,
I suppose, to do many things.
Right.
And we, you know -- as I said, I didn't ask for the
audit and it -- you know, I don't know what this was.
referring to. We moved on to Swift.
Okay. Now, it then goes on to say in this paragraph:
... and meets or exceeds standard industry
accreditations."
Did you ask for those?
I can't tell you right now because, you know, this is
a long time ago.
Do you recall seeing the standard industry
accreditations for the Horizon system?
I don't think anybody plonked them on my desk, no. But
I'm not entirely sure. I don't think so.
Two paragraphs down, "We commissioned’, it starts; do
you see that one there? Further down, "We
commissioned” -- thank you very much -- it's got
a little yellow dash to the left of it:
"We commissioned [past tense] a review by
independent forensic accountants
Okay? Then it goes on:
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taken that might have landed us in a different
direction? And maybe you're right. Maybe there was
an audit. We could have asked for it, I could have
asked for it and it would have said this is okay, and --
or, you know, it would have been something that was
inadequate. I'm not entirely sure. And, with
hindsight, there are many things that we could have
done.
‘Swift, which we discussed extensively, whilst not
being perhaps brilliant and perhaps a bull's-eye and
perhaps spot on, covered off a lot of the bases and, if
the question you're asking is, you know, is there
something that definitively could have been done that
would have pushed us in another direction? I'm not
entirely sure.
Mr Parker, I'm asking about your decision making.
asking about your responsibilities.
Yes.
I'm asking questions that go to whether and to what
degree that you have made mistakes; do you understand
that?
I entirely understand that.
So your answer to my question to the independent audit
was this, "I don't think I could have done". Now, I'm
I'm
trying to find out now, from my follow-on questions,
194
to set up a scheme which, where appropriate,
offered mediation", et cetera.
All right? Now, reminding us of the timing of this,
this is at 2.15, at the time that you're engaged in
dealing with matters, all right? We know that what this
must appear to be is Second Sight, which is back to
2013, so it says:
“We commissioned a review by independent forensic
accountants ..."
Did you ask to see that?
The Second Sight report, we saw as part of the whole
setting up of the Swift Review.
Did you see it as part of this? Did you get this and
say, "I need to see the independent forensic accountant
review"?
I can't tell you exactly when I saw it.
Right. So what we have established, in your evidence
with Mr Beer, first of all, and obviously with me as
well, what we have established is that you came in, you
were given this briefing and then you decided that you
needed to have somebody else look at these issues, and
that was then Mr Swift --
Yes.
-- QC, now KC?
Yeah.
196
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Okay, got it. Do you accept that what you should have
done, have been more hands on, saying, "Let's have
a look at this stuff myself, I want to see it on my
desk, I want to talk to the IT people, maybe talk to
Fujitsu"; do you accept that you could have gone more
into this yourself?
I have tried to explain earlier, I think, that, whilst
you might say the Swift Review was inadequate and we
should have gone straight to the IT system and done
an audit, that is one of a number of possibilities. And
what I tried to do was to get somebody who could look at
the range of issues and the Horizon system was one of
them. So, you know, as -- if had seen, I suppose --
and I mentioned this earlier -- the scale of the thing,
that might have been different but I responded to this,
honestly, in the best way that I thought I could and
I felt Swift was a pretty good response, initially.
Now, we know, with hindsight, we go down a sort of
Sparrow briefing, I can see your point.
You see, one way to look at the difficulty with the
amount of time that you were spending on this, is that
you were part-time and your decisions were part baked.
Yes.
Do you understand that, Mr Parker? You've said
repeatedly that the time issues, this is the same amount
197
of matters it deals with and the number of users it has,
will occasionally discover bugs, errors or glitches in
the way that it works."
Then you continue the quote:
"Some of those bugs may impact on the financial
position of a branch, either positively or negatively.
We do not understand POL or Fujitsu to suggest anything
otherwise."
Now, Mr Parker, we're learning from the Swift Review
that this system, the Horizon system, may in fact cause
negative impacts on the financial position of a branch.
Did you not think to yourself, "Hang on, that sounds
remarkably like the people that had been making all that
noise from the JFSA", and decide there and then to do
something about it?
So Swift, I felt, covered off a range of issues and
covered them off quite comprehensively, and I took away,
perhaps wrongly, that Swift, whilst it wasn't a green
light, was not a red light either, and what you've done
today, I think, has sort of picked up on a number of
points which, with hindsight, we might have gone after.
And this is one of the frustrations and difficulties of
looking at something like this, over a long period of
time, with a great deal of complexity and, you know,
I could reel off a bunch of other things I could have
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of sort of time that you might spend with other
businesses, that the role of the CEO is like that, that
you have a direction, rather than necessarily getting
down to the grips with the nitty-gritty all the time
type role.
Mm, mm.
But this isn't the National Trust, is it, Mr Parker?
This is the Post Office, responsible for prosecuting its
own staff members. Don't you think that more time
should have been spent by you getting to grips with
these very issues?
I don't accept that. I gave sufficient time and
attention to the Post Office, I'm sorry.
Our time is limited now myself, in relation to questions
and I'm --
SIR WYN WILLIAMS: You've already taken double the
allocation, Mr Stein, so one more question.
MR STEIN: Only one more minute. You say this in your
statement, paragraph 59, this is in relation to the
Swift Report or Review and you quote in your statement
part of the Swift Review, where it says this, in
relation to bugs -- so paragraph 59, page 27 of your own
statement -- all right? Swift Review:
"It seems to us entirely unremarkable that the
Horizon system, which is enormous in terms of the range
198
done that would have ended up with probably a quicker
situation.
But I come back to the point I made earlier, which
is that the extent of the issues that we had arrived at
meant that, no matter how unsatisfactory, the ultimate
determination of the reliability of the computer system
and the contractual position with subpostmasters has
facilitated a long-term solution to this problem.
SIR WYN WILLIAMS: All right. Thank you.
MR STEIN: Thank you for your indulgence. No further
questions.
SIR WYN WILLIAMS: That's fine.
Ms Patrick?
Questioned by MS PATRICK
MS PATRICK: = Thank you, sir.
Mr Parker, my name is Angela Patrick. I represent
a number of subpostmasters who were convicted, and have
since had their convictions quashed, including
Mrs Hamilton, who I'm sure you can see sitting beside
me.
Yeah.
You might be glad to hear that I only want to look at
‘one issue. I want to turn back to the follow-up to the
Swift Review and I actually only want to look at one
example, and that's the advice of Mr Altman, then QC now
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KC, produced on 26 July 2016 for the Post Office in
response to the Swift Review.
I want to start, just to look a little bit at what
you say in your witness statement about that advice,
just to refresh your memory. I'm not proposing to turn
your witness statement up, in case you need me to
refresh your memory. If you do, say so.
Yeah.
In your witness statement, you say -- at paragraph 113,
for those following along -- that it's likely you would
have briefed in on that advice from Mr Altman --
Mm.
- but you can't recall now what you would have thought
about it.
Yeah.
Now, just to clarify, do you think you did see a copy of
the advice or is it likely that you didn't?
I mean, I'd like to be able to confirm to you one way or
another, but I honestly can't.
No. But you recall that it's likely you would have been
briefed?
Yes, let's say -- let's work on that principle, if you
want to take your point further.
It's not a principle. I'm going on your evidence from
your witness statement, Mr Parker —
201
You can't, I assume, recall whether the briefing would
have covered whether the review, the advice, had been
narrowed to report only in eight cases?
I can't.
If you had known and you'd been told at that time,
having read the Swift Review and what he'd recommended,
that you go back and look at all the cases, if you'd
read at the time that he was only going to look at eight
cases, in fact he could only analyse three, would that
have caused you any concern?
Well, it's funny you should mention that because I read
through the documents again and I was struck a little
bit that, you know, the case population wasn't enormous.
I did note that.
If you'd seen it at the time, maybe it would have caused
you to ask, "Hang on a minute, can we really rely on
these headline conclusions"?
Well, I've tried to explain that I think one of the core
issues with this thing was putting - was percentages of
the populations of people that were actually looked at.
So, you know, as we've discovered, a huge number of
people --
If I can stop you there, Mr Parker. Whether it was 136
or it was 900-odd, if you were getting, I'd like to say,
probably expensive legal advice --
203
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Yeah.
-- and, in your witness statement, you say you'd
probably have been briefed by General Counsel?
Probably.
Now, elsewhere in the witness statement, you reflect on
the advice, reading it now, having been provided with
it - and you can't remember if you had it at the
time -- and you reflect on the broad conclusions, and
you note that there are some criticisms that Mr Altman
made that went beyond the scope of his instructions.
I just want to ask you about a couple of things, two
things, from the advice.
Yeah.
First, in your witness statement, you note that he
reviewed eight files --
Yeah.
-- and he considered three cases.
Yeah.
Yeah. Now, Mr Beer took you this morning to some
correspondence, which you didn't see, narrowing the
scope of Mr Altman's instructions to cover 19 cases, if
you remember. You hadn't seen that. Did you know at
the time, if you can remember, that the scope of his
advice had been narrowed still, to eight cases?
Honestly, I don't know and I can't tell you.
202
Yeah.
-- from a criminal silk, on the advice of Mr Swift, on
whom you were relying, that all the cases should be
reviewed --
Yeah.
-- and you were being told that only eight cases were
being looked at and, in fact, he was only going to
analyse three, would that not have set up a red flag for
you?
Well, I said I looked back at the advice and it -- you
know, you're right to point it out. At the time, it
seemed relatively reassuring, yes.
But, if you had seen it, would you have not said, "Hang
‘on a minute, we're only looking at eight cases"?
I might have done, yeah.
Okay. Does that help with your memory as to whether you
read it or didn't read it at the time?
Honestly not, no.
Okay. Turning to the second thing I wanted to ask you
about. Now, Mrs Hamilton was one of the three cases.
Yeah.
I only want to look at one part of the advice which
deals with the circumstance of Mrs Hamilton's plea only
being accepted on the condition related to repayment of
money.
204
(51) Pages 201 - 204
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The Post Office Horizon IT Inquiry
Yeah.
It's at POL00022854, and I want to look at page 27. If
it's okay with you, Mr Parker, for time, I'm just going
to take you to the two paragraphs that I want you to
look at. You can trust me that it's the advice. If
somebody can bring that up, I'd be grateful.
I want to look at page 27, and it's paragraphs 106
and 107. Thank you. I'll just take it briefly. I'll
read it so everybody knows what I'm talking about. He
says:
"The proposal here, however, ultimately to invite
the court to order the count be left [that's the count
of theft to be left on the record] on the file as
a condition of repayment was highly unusual if not
exceptional, and was, it seems to me, fraught with
difficulty, despite the judge approving this course.
“First, the effect of the arrangement was that the
prosecution was in effect allowing Mrs Hamilton to buy
her way out of a charge upon which the in-house lawyer
and counsel had advised there was [sufficient] evidence.
Second, the question might be asked why if the
prosecution felt the evidence was sufficient to support
the count of theft it was content to drop it for
repayment of the losses. Third, if Mrs Hamilton did
have a tenable defence to the count of theft (although
205
memory -- can you recall if it recorded any discussion
of any specific matters or criticisms that ought to be
considered for referral to the CCRC?
No, I can't.
You've spoken today about the advice you were given on
privilege in this civil litigation.
Yeah.
Did that briefing, or any advice you can recall being
given around the time of this advice, cover the Post
Office's continuing obligations on disclosure as
a prosecutor?
I can't. I'm sorry.
At this time, when you were being briefed, or when you
read this advice, you would have been aware, I think,
that the rest of the Board wouldn't have read the Swift
Review or its recommendations; is that right?
Possibly. Why?
Well, you knew that they hadn't. Only the four internal
staff had been given it. You had a copy. It was being
controlled. You knew the rest of the Board hadn't seen
the Swift Review; is that right?
I'm sorry, what's the point you're making, though?
I'm asking you a question --
SIR WYN WILLIAMS: Never mind about that, Mr Parker. Just
say "yes" or "no".
207
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3 July 2024
I have seen no defence statement providing any defence,
and doubt a defence statement was ever served) then it
might be argued that the suggestion she should repay the
losses in return for the dropping of the theft count,
which was an idea originating with the prosecution,
placed undue pressure on her, despite the fact that she
was represented, and despite having pleaded guilty to
false accounting."
Now that's an important, serious criticism, isn't
it, Mr Parker?
Yes. I mean, he goes on. I mean, it's quite hard for
me to comment on this. There's a lot going on on this
paragraph. There's a lot going on on the whole page,
and I haven't got the whole document at my disposal. So
to ask me to comment, you know, on a specific case,
I think is -- unless we have proper time, and I'm not --
yeah, go on.
I simply wanted to ask: did you see this at the time or
were you briefed on it; and would you, if you had been,
have considered it a serious matter?
So I can't tell you if I saw it and, before opining on
how serious a matter I would have considered it, I'd
have to look at the whole document again.
Okay. Did your briefing at that time -- I know that you
can't remember it, but just to try to prompt your
206
Okay, yes.
MS PATRICK: Yes, so you knew?
A
Qa
Yes.
So, at that point, nobody else on the Board could have
judged if Mr Altman had or had not done what Mr Swift
had recommended, could they?
Well, I'm not sure who the Altman advice was shared
with, actually. This was one of the outputs of the
Swift Review.
That's why I put the question the way that I did. You
had seen both the Swift Review and were being briefed,
‘or had been shown, a copy of the Altman advice. You
were uniquely placed. Nobody else could compare the two
and say, "Well, Mr Altman has kind of not done what the
Swift Review expected him to do". You were the only
person that was in the position to do that, apart from
staff; is that fair?
Yeah, I think at the time I just took this advice, which
seemed to me to be an adequate response on the first and
second recommendation. I think, you know, I wasn't busy
comparing things, it just looked to me -- and I was --
I think I was told -- I think I was told at the time,
this met the brief.
Well, Mr Parker, I'm not trying to be flippant here but
you said comparing one thing or the other. This is
208
(52) Pages 205 - 208
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The Post Office Horizon IT Inquiry
a very serious question of whether the Post Office had
met its prosecutorial duties to people who it had
convicted of criminal offences.
Mm, mm.
So being the only person on the Board who could assess
whether or not the advice that the Post Office had
commissioned was actually what it sought to obtain, put
you in a particular position. Did that, at the time,
cause you to think that you really ought to be looking
really critically at the advice the Post Office was
being given?
I can't honestly tell you.
Okay. Today you've relied a number of times on a belief
that legal advice given to you was competently given in
good faith. Did you owe any responsibility to the Board
and to the business and the Government Shareholder to
actively question or challenge that advice you were
being given?
I think, as I explained earlier, to challenge advice of
specialists invites the question, you know, how do you
challenge a legal opinion, and I don't have an easy
answer to that.
But, at a minimum, you would have had the responsibility
to at least properly consider the advice you were being
given in good faith; is that fair?
209
INDEX
TIMOTHY CHARLES PARKER (affirmed) ....
Questioned by MR BEER ...
Questioned by MR HENRY ... 164
Questioned by MR STEIN .. 184
Questioned by MS PATRICK ... 200
211
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A. I believe I did, at the time.
Q. You can't recall now if you ever saw a copy of the
Altman advice?
A. I can't for sure.
Q. Can you recall if you asked to read it for yourself?
A. I cannot. I'm sorry.
MS PATRICK: Thank you, Mr Parker.
Thank you, sir. I have no more questions.
SIR WYN WILLIAMS: = Thank you, Ms Patrick. Is that it,
Mr Beer?
MR BEER: Yes, itis, sir.
SIR WYN WILLIAMS: Well, thank you, Mr Parker, for making
a full and detailed witness statement and for answering
questions during the course of today. I'm very grateful
to you.
THE WITNESS: Thank you.
SIR WYN WILLIAMS: We will resume I believe, next Tuesday;
is that correct, Mr Beer?
MRBEER: Yes, 9.45, please, sir.
SIR WYN WILLIAMS: Very well, 9.45 next Tuesday. Thank you.
MR BEER: Thank you, sir.
(4.36 pm)
(The hearing adjourned until 9.45 am
on Tuesday, 16 July 2024)
210
(53) Pages 209 - 211
MR BEER: [25] 1/3
1/5 119 1/14 1/17 53/7I
53/11 53/16 53/18
89/25 90/19 91/1 91/3
113/24 114/3 114/8
114/10 164/3 164/8
164/12 164/14 164/17]
210/11 210/19 210/21
MR HENRY: [3]
164/22 175/3 183/24
MR STEIN: [3] 184/5
198/18 200/10
MS PATRICK: [3]
200/15 208/2 210/7
SIR WYN WILLIAMS:
[29] 1/4 1/6 1/13
53/10 53/17 88/11
88/15 89/2 89/6 89/18
89/24 90/22 91/2
114/2 114/9 164/7
164/13 164/16 164/20}
175/1 184/3 198/16
200/9 200/12 207/24
210/9 210/12 210/17
210/20
THE WITNESS: [4]
53/12 114/4 184/2
210/16
"43 [2] 25/22 162/5
‘47 [1] 142/6
"18 [1] 144/5
"24 [1] 162/21
"98 [1] 25/18
"99 [1] 25/18
‘aggressive’ [3]
141/15 141/16 145/11
‘amended’ [1] 70/1
‘analysis [1] 68/17
‘any [4] 48/13
‘at [1] 148/22
"bottom [1] 68/10
‘breached’ [1] 140/6
‘conduct [1] 132/12
‘considerable [1]
140/1
‘contained’ [1]
139/17
"day [1] 140/12
‘fake’ [1] 69/19
"Has [1] 37/16
‘independent [1]
38/9
‘just [4] 35/20
‘normal’ [1] 20/17
"Post [1] 149/3
‘procedural [1]
149/18
"review' [1] 35/5
"risk [1] 149/6
‘sell’ [1] 137/22
‘top [1] 68/17
‘uncomfortable’ [1]
137/16
"Was [1] 86/2
"We [1] 55/21
‘whether [1] 148/13
~in [4] 141/6
~ that [1] 185/19
4
1 billion [4] 4/10
1 October [1] 3/1
1.10 [1] 113/25
4.12 [4] 114/5
10 [6] 61/10 61/12
128/20 136/1 164/18
164/19
10 June [1] 126/3
10 September [5]
27/19 34/22 49/7
49/24 54/1
10.00 [1] 1/10
10.30 [1] 145/3
100 [1] 78/21
100 million [5]
184/23 185/7 185/11
185/17 186/21
102 [1] 62/15
106 [2] 64/7 205/7
107 [4] 205/8
11 [1] 109/23
11 August [1] 22/10
11,500 [4] 4/13
11.13 [4] 53/13
11.15 [1] 53/8
11.25 [1] 53/9
11.28 [1] 53/15
113 [4] 201/9
12 [1] 128/20
12.25 [2] 90/20 90/23
12.35 [1] 90/21
12.36 [1] 90/25
120,000 [1] 140/16
125 [1] 67/12
126 [1] 1/24
13 [1] 157/16
13 May [4] 116/19
130 [1] 167/2
136 [6] 2/14 23/1
23/3 26/15 167/3
203/23
136 pages [2] 1/22
2/21
14 [1] 157/6
14 June [1] 136/1
14 May [1] 123/25
145 [1] 69/15
15 [3] 32/15 47/13
52/8
15 December [1]
55/13
15 July [1] 157/8
15 March [1] 147/14
15 September [1]
55/2
15 years [3] 24/8
24/22 167/13
16 [1] 210/24
16 March [1] 151/22
16 September [1]
94/4
17 August [2] 13/20
19/19
17 June [1] 6/6
173 [1] 74/10
47th [1] 14/16
18 [1] 62/4
18 October [1] 145/3
184 [1] 78/22
19 [3] 118/16 119/15
202/21
19 April [1] 91/13
19 November [3]
160/13 161/24 162/6
2
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145/8
2.15 [1] 196/4
2.45 [4] 14/9
20 [3] 25/20 149/5
185/11
2000 [3] 25/21 73/10
180/5
2008 [1] 3/11
2010 [2] 10/11 180/5
2010-2015 [1] 61/7
2012 [1] 25/22
2013 [3] 10/15 32/14
196/7
2014 [5] 3/8 3/11
3/13 3/19 9/6
2014/15 [1] 32/15
2015 [19] 3/1 4/8 6/6
14/1 13/20 22/10
27/19 41/8 43/1 54/1
54/5 54/10 55/2 55/25
61/7 92/9 94/15 101/4
103/7
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2016 [13] 53/23 59/9
85/6 100/20 106/14
106/19 107/23 109/15I
109/18 109/20 116/19]
177/12 201/1
2017 [4] 105/11
2018 [4] 3/24 139/9
140/4 144/4
2019 [5] 147/11
147/14 184/9 184/14
184/21
2019/20 [4] 185/11
2020 [12] 91/7 91/13
92/7 94/4 103/10
103/11 160/13 162/6
162/21 162/22 166/9
182/5
2021 [2] 162/3 163/3
2022 [5] 3/2 3/19 4/1
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22 January [3] 85/5
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23 [2] 167/3 167/11
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25th [1] 34/23
26 January [2]
107/23 109/20
26 July [1] 201/1
268 [1] 2/2
27 [3] 198/22 205/2
205/7
27 May [1] 123/25
28 [4] 30/3
29 April [1] 166/9
3
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3.30 [2] 164/6 164/11
3.4 [1] 37/22
30 minutes [1]
164/18
30 years [1] 12/14
34 [2] 61/17 61/17
35 [1] 61/18
38 [2] 66/15 157/21
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4 March [4] 109/15
4.36 [1] 210/22
40 [1] 47/22
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5
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53 [2] 69/14 72/9
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59 [2] 198/19 198/22
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65 [2] 75/18 110/25
66 [1] 75/11
66 pages [1] 59/7
6th [1] 15/17
7
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106/20 109/18 119/3
8 June [1] 129/16
8 March [1] 63/2
8 October [1] 47/9
85 [1] 54/9
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9 October [1] 43/1
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959 [2] 166/4 166/13
A
abbreviated [1]
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abilities [1] 122/2
ability [6] 12/24
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168/13 176/25
able [10] 10/6 31/22
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about [142] 2/23 3/2
5/24 7/11 7/12 8/23
9/2 10/16 11/2 12/2
13/15 13/17 13/19
14/19 15/2 15/8 16/2
16/3 16/22 17/2 20/24I
21/18 23/19 25/21
27/18 30/5 32/10
32/18 32/22 35/10
36/2 36/7 36/9 37/17
37/22 41/24 42/10
44/6 45/2 45/10 48/14)
49/19 50/17 50/19
53/3 54/2 54/8 58/6
59/13 63/11 65/12
65/12 69/21 70/9
70/14 71/17 73/6
73/10 75/13 75/25
76/11 76/16 80/2 82/8)
88/10 88/12 89/4 92/7
93/11 93/20 94/5
95/10 96/24 97/1
100/18 100/19 103/17)
105/3 105/14 105/15
105/18 105/19 105/20}
105/25 106/12 107/6
108/5 109/25 110/2
116/1 122/13 122/16
122/23 123/4 123/7
124/10 125/22 125/23)
129/16 131/3 132/7
137/19 138/20 138/24I
140/18 141/10 141/23)
145/22 151/4 152/18
153/17 156/20 159/20}
161/6 162/17 162/25
170/15 175/25 177/18)
178/22 178/24 180/1
(64) MR BEER: - about
A
about... [20] 180/19
181/4 182/8 188/4
188/15 189/15 190/17
191/13 191/23 193/25
194/16 194/17 199/15)
201/4 201/14 202/11
204/20 205/9 207/5
207/24
above [5] 69/23
92/22 113/4 132/12
133/9
absence [2] 62/24
85/21
absolute [1] 180/24
absolutely [11] 2/12
22/7 74/9 76/19 90/11
100/9 103/24 165/19
174/19 174/20 181/13
absorbed [1] 4/22
abuse [2] 19/17
190/23
abused [1] 18/20
accept [10] 63/9
97/12 100/12 104/6
151/17 174/4 176/15
197/1 197/5 198/12
acceptance [1] 70/7
accepted [2] 86/5
204/24
accepting [5] 5/18
7/3 94/19 94/23 191/2
access [8] 70/15
70/20 70/21 70/24
71/3 71/23 72/1 72/4
accommodate [1]
171/20
accordance [2] 1/11
63/18
accordingly [4]
74/25 85/25 110/8
158/3
accords [1] 101/14
account [10] 2/16
57/17 74/16 74/17
75/3 99/12 100/6
100/8 100/10 168/12
accountant [1]
196/14
accountants [6]
18/12 43/7 58/21 75/1
195/24 196/9
accounting [16] 19/1
49/2 61/24 62/1 62/9
62/12 62/23 63/4
64/22 66/4 66/19
66/20 72/16 118/12
166/17 206/38
accounts [6] 5/17
71/3 117/8 118/6
118/9 118/9
accreditations [3]
192/7 195/11 195/16
accurate [7] 92/13
92/15 92/18 92/19
93/1 130/11 130/16
accurately [1] 31/20
accusation [1] 62/12
achieve [5] 35/24
37/15 41/4 41/13 96/4
acknowledge [1]
141/12
acquainted [2]
175/14 176/11
across [4] 28/22
68/20 69/2 136/5
act [5] 102/24 149/6
150/6 152/13 155/19
acting [2] 90/6
140/20
action [14] 29/4
48/13 57/18 59/24
61/4 61/9 64/5 94/14
96/8 96/15 118/25
124/4 150/3 161/12
actions [5] 35/13
36/20 36/23 120/16
193/25
active [2] 43/21
106/4
actively [2] 153/2
209/17
activities [2] 29/23
175/13
activity [1] 19/12
actual [1] 12/1
actually [47] 13/1
15/3 21/7 24/11 24/20
25/13 26/3 35/24
36/14 37/14 38/21
41/1 42/13 51/15
52/24 53/1 53/4 57/14)
58/3 65/22 71/13
73/12 76/2 77/17 87/7,
95/4 123/12 140/6
142/16 155/8 159/9
167/5 171/6 175/10
175/14 175/15 175/20)
176/6 176/16 178/15
180/19 180/21 191/6
200/24 203/20 208/8
209/7
ADD [1] 17/17
added [6] 17/17
17/23 20/13 70/6
137/1 160/21
addition [2] 70/6
92/22
additional [3] 111/3
142/23 186/12
address [6] 60/1
73/23 89/3 120/20
120/24 136/12
addressed [5] 37/25
46/6 49/22 64/10
138/22
addresses [1] 10/1
addressing [2] 76/10
104/20
adds [1] 70/3
adduced [1] 27/1
Adedayo [1] 164/24
Adedayo's [2] 173/21
174/3
adequacy [1] 106/22
adequate [1] 208/19
adequately [1]
119/24
adjourned [2] 149/12
210/23
Adjournment [1]
114/6
adjudicator [1]
137/13
administration [1]
155/17
admissibility [1]
140/3
admission [1] 148/7
adopting [1] 141/1
advance [1] 22/13
adversarial [2]
168/24 170/1
adversarially [1]
181/5
advice [116] 9/11
39/18 39/24 40/1 40/8
50/18 51/2 63/2 63/11
63/24 66/17 73/17
73/23 75/13 75/15
77/16 78/12 78/13
78/16 80/4 80/6 80/25
83/3 83/5 83/16 83/21
86/22 87/5 90/4 90/14
94/19 94/23 96/3
96/18 104/10 110/8
110/13 117/7 125/12
125/13 126/7 126/10
127/15 127/16 127/17
128/11 128/12 128/15}
128/17 129/6 129/10
133/11 133/25 134/1
134/3 134/4 134/7
134/21 135/3 135/7
135/8 135/13 135/14
135/22 136/23 136/24]
138/7 147/17 147/22
151/9 155/6 155/6
155/7 155/8 155/14
156/10 156/11 156/14]
157/7 157/13 159/7
160/1 160/25 161/3
161/16 161/23 162/5
162/8 168/11 200/25
201/4 201/11 201/17
202/6 202/12 202/24
203/2 203/25 204/2
204/10 204/22 205/5
207/5 207/8 207/9
207/14 208/7 208/12
208/18 209/6 209/10
209/14 209/17 209/19
209/24 210/3
advices [1] 183/9
advise [8] 47/8 51/10
83/12 124/25 125/2
128/3 157/10 183/15
advised [17] 77/19
78/24 79/13 79/17
80/18 81/6 81/15
82/10 83/3 83/24
101/9 113/14 130/20
131/1 138/6 140/10
205/20
advisers [1] 101/5
advising [4] 52/20
106/22 128/6 177/15
aegis [4] 93/25
126/11 127/11 135/23}
affairs [2] 17/10
102/13
affect [1] 67/15
affected [9] 24/15
25/6 29/23 31/5 68/8
98/23 102/20 171/18
176/25
affecting [2] 42/25
69/10
affects [1] 70/8
affirmed [2] 1/7
211/2
afraid [2] 88/7 171/11
after [30] 3/4 6/16
14/5 16/16 21/13
34/21 40/5 40/6 40/7
44/10 50/7 59/12 92/6)
101/3 104/16 104/17
105/24 109/17 115/2
116/7 124/12 159/11
159/21 161/18 172/3
173/12 178/18 182/5
182/13 199/21
aftermath [2] 65/7
65/13
afternoon [4] 91/1
94/7 114/8 164/12
afterwards [2] 33/5
48/23
again [58] 3/21 9/23
11/23 13/5 13/7 13/12,
15/17 17/3 17/23
17/23 23/11 24/4 28/4}
29/20 33/21 34/2
36/18 42/9 47/15
49/11 50/4 51/9 52/22
54/22 56/18 60/10
65/23 66/5 66/7 69/11
74/1 75/7 76/3 80/3
81/9 82/18 88/20 94/4
96/21 103/3 104/4
110/12 123/1 1314/7
144/13 160/2 161/13
162/23 167/24 168/5
169/9 170/16 170/19
185/20 188/7 190/8
203/12 206/23
against [10] 35/18
96/3 96/15 96/18
112/9 113/10 124/10
127/11 133/10 160/9
agency [1] 169/5
ago [8] 11/1 52/23
56/5 108/2 123/5
123/8 133/23 195/14
agree [19] 14/11
31/24 37/4 38/20
52/14 64/7 67/7 75/9
75/22 76/6 79/2
101/23 113/21 134/12)
162/4 168/7 175/9
187/20 189/17
agreeing [2] 7/16
188/7
Ah [1] 115/4
ahead [8] 19/20
20/25 27/21 52/5 85/9I
91/17 94/7 117/16
aim [4] 37/25 52/13
61/24 112/21
aimed [1] 12/17
aims [1] 9/17
air [1] 13/20
aired [1] 19/18
Al [4] 152/2
Alan [2] 99/19 180/16
alarm [2] 1/10 8/11
albeit [1] 3/5
Alexander [1] 61/15
Alice [2] 3/4 11/17
aligns [1] 69/7
Alisdair [1] 147/15
all [82] 2/23 5/6
14/16 18/16 18/17
22/3 27/12 27/20
29/24 33/4 39/19 41/6I
42/10 44/19 55/23
56/25 76/12 78/9
81/24 83/4 83/13
87/21 90/9 98/2 98/18}
98/21 98/23 98/24
99/2 99/5 99/15 99/21
99/25 100/10 104/2
104/15 114/21 115/9
115/16 116/1 119/19
121/11 123/20 128/19)
133/22 134/15 138/1
138/8 151/3 154/4
154/6 157/18 159/9
161/15 162/20 162/20)
163/21 163/22 164/20)
165/22 167/1 170/6
1471/7 172/25 174/7
174/18 174/12 176/7
180/9 185/20 186/11
193/18 193/25 196/3
196/5 196/18 198/4
198/23 199/13 200/9
203/7 204/3
allegation [5] 19/21
(65) about... - allegation
A
allegation... [4] 61/21
63/7 64/16 117/6
allegations [12]
18/18 19/14 19/15
19/24 37/17 42/8
117/15 190/12 190/19
190/25 191/16 191/18
alleged [3] 21/22
26/17 48/25
allegedly [1] 166/21
alleging [1] 26/15
allocation [2] 105/4
198/17
allow [2] 28/24 58/1
allowed [2] 40/9
163/10
allowing [1] 205/18
alluding [2] 65/15
65/16
almost [5] 18/3 155/9
155/15 192/3 192/17
alone [1] 63/10
along [3] 87/16 155/9
201/10
alongside [3] 2/4
56/8 62/11
already [6] 53/24
98/22 145/10 189/21
191/19 198/16
also [40] 3/20 4/2
4/14 5/11 14/14 18/15)
24/13 28/10 62/6
62/13 63/23 64/2
73/23 77/21 80/14
85/14 91/12 93/7
97/10 102/17 105/11
105/14 105/20 107/8
110/4 115/9 118/6
118/23 126/13 127/18)
132/17 142/21 150/2
154/25 158/23 175/18}
188/12 188/20 190/5
191/7
Altered [1] 119/10
alternative [1] 68/6
Alternatively [1]
156/2
alternatives [1]
35/23
although [17] 8/18
12/23 39/5 39/22
62/22 70/10 79/1
79/11 85/17 93/3
97/17 100/12 117/10
148/21 152/11 180/18
205/25
Altman [14] 2/4
65/25 66/6 118/15
119/14 160/20 200/25
201/11 202/9 208/5
208/7 208/12 208/14
210/3
Altman's [2] 63/2
202/21
always [16] 8/8 8/15
8/17 8/19 33/16 39/2
52/19 63/14 63/18
70/9 77/3 100/5
168/19 176/12 186/13)
186/17
Alwen [5] 13/21
15/18 20/10 22/12
22/19
am [19] 1/2 27/21
29/1 40/9 43/2 45/1
53/13 53/15 78/23
80/22 110/8 111/3
111/4 112/18 118/23
128/19 159/19 166/16)
210/23
amend [3] 70/2 73/2
73/20
amended [1] 110/23
amending [1] 143/10
amendments [1]
110/23
among [1] 148/8
amongst [1] 152/18
amount [8] 5/5 99/1
154/15 163/7 163/20
184/22 197/21 197/25)
analogous [1] 150/21
analogy [1] 179/6
analyse [2] 203/9
204/8
analysis [6] 65/10
68/4 68/6 72/12 74/13
168/6
analysis’ [1] 140/1
analytical [1] 68/21
Andrew [3] 21/13
107/24 129/17
anecdotal [1] 9/17
anecdotally [1] 98/11
Angela [2] 61/14
200/16
annoy [1] 171/8
annual [2] 7/17 9/11
another [22] 8/20
16/2 24/21 33/16
35/20 41/6 44/5 45/6
83/13 84/24 92/2 98/9)
100/1 128/3 143/12
147/7 185/25 186/14
186/15 187/25 194/14)
201/19
answer [36] 7/7
11/15 41/17 45/9 47/4
55/9 56/5 78/9 88/20
89/14 89/23 96/21
96/23 99/10 103/12
122/10 123/4 128/14
130/23 132/5 134/25
146/14 156/13 162/10)
166/17 166/18 171/16)
171/25 181/4 181/9
185/12 187/2 193/6
193/8 194/23 209/22
answered [2] 47/19
128/17
answering [2] 164/3
210/13
answers [2] 162/23
169/24
antagonised [1]
149/16
Anthony [5] 43/7
44/10 44/15 129/19
165/1
anticipated [1] 55/16
any [81] 5/14 8/23
12/2 15/11 21/20 23/6}
23/9 24/16 29/4 30/9
32/8 32/17 34/20
35/19 39/1 43/22 44/1
47/15 55/10 57/18
59/24 61/4 61/8 63/10)
63/25 64/3 66/20
67/15 68/3 68/4 72/8
72/14 72/16 74/1
74/13 77/13 79/11
83/19 84/1 84/10
85/15 86/18 88/12
89/4 94/14 95/2 96/10
100/9 101/24 102/7
111/9 113/11 124/23
127/19 132/2 132/22
133/20 134/5 136/5
137/11 137/12 141/20
143/4 143/21 144/19
144/21 145/18 161/3
169/15 171/9 171/22
182/9 183/10 185/16
186/12 203/10 206/1
207/1 207/2 207/8
209/15
anybody [6] 31/5
89/10 95/3 95/7
174/24 195/17
anyone [4] 44/17
77/1 89/22 90/1
anything [24] 9/20
11/21 13/4 13/8 15/5
15/14 16/22 58/4
58/12 86/2 86/17
95/13 95/17 103/11
110/14 111/19 115/12
162/9 163/5 163/11
178/22 182/8 182/15
199/7
anyway [2] 72/7
137/22
apart [2] 192/8
208/16
apologies [1] 170/25
apology [2] 170/21
171/12
apparent [3] 165/14
165/15 165/17
apparently [6] 98/12
127/16 128/12 142/21
150/18 182/18
appeal [12] 33/8
63/25 113/8 148/1
149/3 149/12 150/1
150/3 156/5 159/4
159/5 182/14
appeals [2] 33/7
147/117
appear [7] 109/10
129/5 142/17 165/9
169/24 177/24 196/6
appeared [2] 167/2
182/16
appearing [1] 19/21
appears [5] 10/18
67/20 100/17 168/9
193/8
applicable [1] 67/3
applicants [2] 44/2
62/13
application [21]
122/1 139/7 139/16
139/19 140/14 140/17]
140/23 142/9 142/19
147/12 148/4 149/11
149/15 149/23 150/7
152/15 154/21 154/23}
155/24 156/7 156/16
applications [1]
113/5
applied [2] 141/2
148/3
apply [8] 93/14 123/5
140/3 148/11 150/17
153/11 153/23 155/22)
applying [4] 67/2
139/21 140/12 154/9
appoint [4] 2/10 6/17
92/11 92/14
appointable [1] 6/15
appointed [2] 30/4
92/6
appointing [3] 2/3
2/9 28/13
appointment [10]
6/25 8/22 9/7 9/21
12/1 13/11 37/23
38/11 42/19 101/3
appointments [2] 7/7
175/12
appraised [3] 10/13
11/8 12/10
appreciate [2] 168/9
173/8
appreciated [1]
127/19
approach [14] 35/17
68/6 68/9 68/16 97/13)
102/19 103/6 103/19
110/2 130/5 140/11
140/25 141/15 141/17)
approaches [1]
10/18
approaching [1]
144/13
appropriate [13]
37/19 41/16 49/5 64/4
94/13 94/14 102/13
111/5 112/20 116/2
117/3 147/1 196/1
appropriately [2]
42/15 92/17
approved [1] 136/5
approving [1] 205/16
approximately [1]
62/4
April [7] 3/24 55/25
91/13 124/14 124/15
166/9 177/12
apt [1] 50/1
Arbuthnot [6] 14/15
35/7 35/24 61/13
62/13 133/17
Arbuthnot's [1] 35/9
are [147] 2/16 2/19
5/25 7/6 8/6 8/13 11/8
12/9 13/13 13/25
14/24 18/23 19/21
21/20 23/9 24/1 24/6
25/8 25/23 26/5 26/6
26/6 31/7 32/5 38/3
38/17 39/14 39/16
39/18 39/19 41/12
43/16 43/16 43/21
46/10 47/7 47/13
49/12 50/2 61/8 62/4
62/15 63/4 63/18
65/14 66/16 67/7
67/17 69/4 69/5 69/20)
71/12 72/15 73/5
74/12 74/19 75/19
76/12 76/17 86/22
88/17 89/20 91/21
91/23 92/20 95/20
98/16 99/10 100/3
102/1 102/23 105/8
105/8 106/13 109/3
4111/4 117/11 117/15
117/18 118/6 118/12
121/8 121/9 121/14
122/4 122/4 122/15
122/23 123/13 128/23}
130/17 130/21 1314/5
131/17 132/7 132/7
132/25 134/9 134/17
135/3 135/4 135/5
141/4 142/19 142/21
143/14 144/11 145/22)
147/10 148/5 149/10
150/1 150/3 151/4
152/14 156/4 157/22
158/17 158/23 160/12)
160/14 163/19 164/5
164/17 165/20 167/11
170/17 171/8 171/23
173/2 175/14 175/20
176/18 179/11 179/16
(56) allegation... - are
A
are... [12] 179/23
182/2 182/6 187/1
189/25 190/5 190/25
191/13 192/13 193/22
194/7 202/9
area [4] 33/24 46/21
82/19 173/14
areas [2] 50/8 117/18
aren't [6] 41/21 88/17
107/18 142/20 168/3
168/3
Argentina [1] 150/12
arguable [1] 159/4
arguably [2] 158/9
178/2
argue [2] 76/16 148/5I
argued [1] 206/3
argument [3] 99/15
141/19 165/1
arise [1] 103/2
arisen [1] 42/24
arising [5] 66/15 67/8)
75/23 102/25 122/9
arose [1] 68/2
around [21] 4/13
24/15 32/3 39/8 45/9
84/19 85/1 88/9 94/15)
110/12 110/14 139/2
143/14 152/9 153/9
168/22 177/12 186/21
187/23 191/14 207/9
arranged [2] 14/16
52/16
arrangement [4] 4/25]
144/17 169/6 205/17
arrangements [1]
150/11
arrival [1] 41/10
arrive [1] 11/7
arrived [3] 15/23
16/16 200/4
as [264]
aside [2] 102/2 131/4
ask [43] 1/9 1/17
2/22 13/14 15/8 16/3
23/21 41/17 51/10
63/3 83/8 84/3 88/11
89/11 92/14 94/6
121/21 122/9 124/3
125/6 125/8 129/16
138/20 138/24 146/12)
155/10 157/4 167/8
168/1 172/6 181/3
184/5 192/11 193/2
193/16 195/6 195/12
196/10 202/11 203/16}
204/19 206/15 206/18
asked [39] 18/15
20/20 33/15 37/2 37/9
40/23 45/4 52/10 57/1
64/12 68/2 79/4 89/8
89/9 89/22 92/11
96/10 105/12 105/14
105/24 114/23 118/3
121/25 126/7 128/16
134/9 135/4 135/6
142/15 145/17 145/23)
166/25 167/10 181/24}
187/10 194/3 194/4
205/21 210/5
asking [20] 11/11
16/5 48/12 51/15 89/2
105/5 105/8 111/16
143/1 145/22 167/22
172/14 193/1 193/6
193/14 194/12 194/16)
194/17 194/19 207/23)
aspects [4] 83/4
169/19 173/8 180/18
assertion [2] 149/19
176/15
assess [2] 30/23
209/5
assessor [1] 7/7
assistance [5] 12/16
48/19 51/1 51/22
109/22
assistance’ [1] 38/9
assistant [3] 6/1
42/22 53/6
assistants [1] 25/5
assisted [2] 38/19
45/5
assisting [1] 38/25
assume [4] 35/6 36/5
39/18 203/1
assumed [8] 81/16
114/21 121/2 121/3
127/17 134/23 153/20)
177/13
assuming [4] 29/2
71/23 87/22 144/12
assumption [9]
30/13 30/19 31/13
36/8 78/2 78/3 78/5
78/7 153/12
Assurance [1] 9/3
assurances [1] 69/20)
assure [2] 170/20
182/25
at [324]
at page 2 [1] 123/22
attached [6] 22/13
91/14 91/21 92/21
139/14 148/17
attaching [1] 91/18
attempt [1] 171/14
attempted [1] 5/10
attempting [1] 183/1
attended [1] 84/5
attending [1] 125/20
attention [8] 9/20
29/3 29/11 53/4 67/18
176/7 176/13 198/13
attributed [4] 13/14
14/24 35/9 75/5
attributes [1] 129/14
audience [1] 111/6
audit [14] 16/2 73/3
73/21 192/9 192/11
192/13 192/22 193/2
193/8 193/15 194/3
194/23 195/7 197/10
audited [3] 192/6
192/20 193/11
August [3] 13/20
19/19 22/10
author [1] 157/16
author's [1] 61/18
authored [1] 47/14
authorised [1] 73/1
authority [1] 88/16
authors [2] 47/12
61/12
authorship [1] 23/15
availability [1] 75/16
available [7] 9/18
22/1 79/14 83/25 85/5)
86/19 117/12
average [1] 167/20
await [1] 43/14
awarded [1] 140/14
aware [29] 10/23
26/4 28/15 30/4 42/25
49/19 49/20 58/4
62/15 71/20 74/12
78/23 82/4 93/13 95/5
99/15 103/4 111/3
134/15 135/11 147/10
149/17 153/8 156/20
159/6 167/6 173/25
174/2 207/14
awareness [1] 33/2
away [10] 42/24 46/2
57/3 57/22 71/4 71/5
72/7 81/20 177/20
199/17
awful [5] 104/19
104/20 175/25 176/1
183/22
axe [2] 83/18 179/5
back [51] 10/25
12/19 25/17 26/15
27/24 29/10 30/22
30/24 40/9 40/12
40/14 45/10 48/10
50/14 52/22 55/20
55/25 71/8 75/18 77/2
83/14 90/13 91/23
92/9 95/8 99/7 103/7
103/16 104/1 104/2
106/10 108/11 109/4
113/7 115/20 118/20
121/1 127/13 141/8
143/5 144/1 146/17
155/5 157/13 178/1
192/14 196/6 200/3
200/23 203/7 204/10
background [9] 2/25
21/5 22/4 101/17
152/20 174/13 174/21
174/23 177/21
backward [1] 123/7
backward-looking [1]
123/7
bad [5] 50/19 50/21
76/4 128/20 137/15
badged [1] 138/15
baked [1] 197/22
balance [4] 70/8
96/15 156/11 170/10
balances [4] 74/16
74/20 75/2 75/5
balancing [6] 69/18
70/2 70/5 70/10 72/19)
73/19
Bank [1] 74/18
bar [1] 19/3
Baroness [28] 6/11
14/2 14/8 14/12 16/4
16/18 27/18 36/1 38/4
44/15 48/12 49/8
49/24 53/25 54/18
54/23 85/9 90/1 92/10
101/3 107/23 108/8
109/14 109/16 125/17]
130/8 133/16 136/11
barrels [1] 56/3
barrels' [1] 55/22
barrier [1] 185/16
barrister [8] 38/14
45/6 48/2 48/4 51/10
53/5 65/9 124/25
barristers [1] 106/22
barristers’ [1] 182/19)
base [1] 121/8
based [3] 105/17
118/12 123/3
bases [1] 194/11
basically [1] 31/9
basis [20] 7/17 15/8
36/24 39/25 42/5
48/22 66/21 66/24
67/4 68/21 81/16 90/4
118/17 119/16 134/7
135/2 146/25 163/17
163/18 188/13
baskets [1] 73/2
Bates [1] 99/19
battened [1] 180/11
battle [1] 169/12
BBC [1] 190/3
be [273]
bear [2] 83/17 104/23
bearing [3] 57/20
123/15 177/11
became [6] 3/8 11/3
31/4 95/4 142/11
179/7
because [83] 4/12
4/13 4/14 4/16 4/25
12/5 15/6 15/11 19/22,
27/10 33/13 33/19
39/5 39/21 45/12 46/5I
46/23 50/13 53/3
56/25 58/3 59/7 62/2
63/6 64/2 64/3 65/6
65/24 68/9 70/1 73/13}
79/25 88/15 89/13
89/19 90/3 96/16
96/22 97/1 107/18
117/11 122/4 127/22
133/7 134/20 135/11
136/20 137/24 138/16
138/25 144/11 144/25)
146/12 151/6 152/22
153/2 153/16 155/1
158/11 160/8 162/11
165/13 165/25 167/15)
169/22 171/1 171/4
171/17 173/2 173/15
176/22 177/7 178/13
178/20 180/15 180/23)
181/12 183/10 185/10)
185/13 188/15 195/13}
203/11
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142/13 167/6
becoming [1] 152/25
bed [2] 137/14
137/24
been [178] 10/6 10/8
10/21 11/1 12/14 15/4I
17/15 18/3 18/9 19/13
21/21 22/23 23/1 24/5I
24/7 24/12 24/14
24/15 24/21 24/23
24/25 25/15 26/8
26/23 27/6 27/7 28/3
28/8 28/15 28/18 30/5
32/3 37/9 40/22 42/12I
42/24 44/22 50/13
50/15 50/16 50/24
56/14 57/1 57/25
58/16 59/21 60/3 61/3}
61/7 62/14 64/11
65/23 66/23 67/14
68/17 70/22 71/6
73/24 74/13 77/12
77/24 83/1 83/6 84/7
86/5 90/14 92/16
95/15 96/5 96/7 96/19I
97/12 98/20 98/24
98/25 99/7 99/8 99/8
99/16 99/20 99/22
99/23 100/4 100/11
100/14 100/25 101/25)
102/17 108/17 108/19)
109/18 110/23 113/11
113/12 117/15 119/1
122/6 122/14 124/12
125/13 129/8 140/25
141/12 143/23 147/8
148/6 150/25 151/1
152/23 153/19 155/4
155/18 156/22 158/12!
(67) are... - been
B
been... [64] 158/18
158/24 158/25 159/10)
160/5 160/6 160/21
162/14 163/17 165/12
165/12 165/15 166/4
166/5 167/7 167/10
167/12 167/19 167/25
168/3 168/15 168/19
169/8 170/1 171/18
171/19 171/21 172/4
173/5 173/24 177/17
178/12 178/19 179/11
179/18 180/23 181/6
181/10 182/9 183/1
183/2 186/22 187/25
190/11 192/3 192/17
193/3 193/25 194/5
194/13 197/2 197/15
198/10 199/13 201/20}
202/3 202/6 202/24
203/2 203/5 206/19
207/14 207/19 208/12
BEER [11] 1/8 1/17
181/4 187/7 187/10
191/12 196/18 202/19
210/10 210/18 211/4
before [31] 1/9 5/16
5/18 6/8 7/2 9/6 11/17)
12/1 13/11 14/21 15/9
22/11 27/19 43/14
47/19 53/19 85/4
99/12 103/23 106/19
109/12 110/6 110/21
115/4 137/18 165/21
174/23 176/3 182/14
186/15 206/21
beforehand [1] 14/22
beg [2] 40/19 80/10
began [3] 11/17
14/21 142/11
beginning [7] 40/12
45/19 50/3 84/18
118/23 150/24 154/3
begins [1] 151/25
begun [1] 117/24
behalf [9] 1/18 11/12
53/2 59/22 111/12
117/3 124/11 183/7
184/6
behave [1] 28/25
behaviour [1] 68/20
behaviours [1]
149/20
behind [5] 7/22 119/9
121/9 121/13 179/10
being [81] 3/21 8/25
14/18 17/22 18/18
22/19 23/14 25/19
26/15 30/11 32/5
37/23 39/24 47/17
51/16 55/5 60/6 63/4
77125 79/10 80/18
81/17 82/4 84/9 93/24
93/25 102/2 102/3
102/9 105/16 105/18
113/7 119/8 120/1
120/17 120/19 124/10)
126/8 126/10 134/9
135/4 135/11 135/12
135/22 137/8 137/17
142/4 147/8 149/6
150/14 153/9 156/20
159/25 165/2 167/20
169/23 170/12 171/15)
175/17 178/25 179/1
179/14 181/24 185/19)
186/21 187/10 188/1
188/13 188/14 194/10)
204/6 204/7 204/24
207/8 207/13 207/19
208/11 209/5 209/11
209/18 209/24
BEIS [12] 84/23
92/25 93/11 93/11
100/22 100/24 103/19)
135/8 135/12 144/25
152/2 153/5
belief [4] 2/18 30/21
31/12 209/13
beliefs [1] 129/15
believe [19] 7/4 8/6
8/13 30/6 30/8 43/8
43/22 46/18 77/20
79/6 80/14 98/18
124/12 163/3 172/19
172/20 173/12 210/1
210/17
believed [1] 5/13
believes [1] 94/18
believing [1] 64/22
bell [1] 34/14
below [7] 13/17
17/13 30/10 35/1
120/14 136/2 151/23
benefit [3] 40/24 64/4
149/21
benefits [1] 5/6
benevolent [1] 41/16
benign [1] 107/13
bereft [1] 5/7
beside [1] 200/19
best [10] 2/17 12/10
14/1 88/22 97/18
97/20 125/15 152/13
165/4 197/16
betokens [1] 82/18
betray [1] 141/14
better [6] 14/4 44/17
98/2 98/20 99/7 99/23
between [17] 2/6
15/19 38/24 53/9
53/22 85/6 88/23
98/15 107/23 117/1
118/8 119/23 140/22
144/10 170/10 179/12)
180/5
beyond [3] 21/25
157/22 202/10
bias [2] 147/19
152/10
biased [3] 150/19
154/18 154/19
biased’ [1] 148/16
big [9] 4/15 23/22
34/14 45/2 70/22
73/16 151/16 185/5
188/23
billion [4] 4/10
billions [1] 4/22
BIS [3] 35/13 36/20
133/17
bit [31] 4/20 21/10
27/14 40/17 40/17
42/18 46/2 51/16 52/5
58/13 59/11 84/19
95/9 99/22 105/15
121/11 134/17 150/21
151/13 170/13 170/14
171/7 174/12 184/18
185/1 186/23 189/22
190/7 192/24 201/3
203/13
bits [1] 134/18
black [1] 174/10
blame [2] 172/19
172/21
blow [4] 21/10
BNR [1] 14/8
board [84] 10/22
12/8 39/17 65/5 78/25
79/5 79/5 79/8 79/12
79/13 82/2 82/3 82/12
82/15 83/10 83/16
83/17 83/24 84/1 84/5
84/6 84/20 89/10
92/25 93/3 93/10
94/13 94/21 94/25
97/13 101/8 101/22
101/25 102/9 102/11
102/18 103/7 106/14
107/5 107/6 109/15
116/3 116/9 116/13
124/2 144/6 144/9
144/16 144/23 144/24
145/1 147/16 147/20
150/9 150/10 152/8
152/12 152/13 153/14
153/15 154/10 154/22
160/13 160/20 161/3
161/14 161/16 162/6
162/8 163/1 163/3
163/8 173/13 176/9
183/5 183/8 183/14
183/16 183/23 207/15}
207/20 208/4 209/5
209/15
Board's [2] 12/3
144/19
body [1] 74/6
Bogerd [1] 61/14
bold [1] 66/17
Bond [2] 21/14 117/9
booked [1] 55/7
boring [1] 104/5
both [16] 38/2 52/1
55/22 56/3 63/4 69/18)
109/23 128/22 128/22)
128/23 141/12 142/4
142/12 145/9 159/19
208/11
bottom [14] 5/23
13/20 18/10 19/9
42/20 60/2 116/19
136/1 161/20 163/9
189/20 189/22 189/23
190/9
bought [2] 73/22
102/20
Bourke [5] 34/15
120/8 136/4 138/2
138/4
brackets [1] 48/23
brain [1] 137/19
Bramble [1] 97/10
branch [12] 17/22
23/3 49/1 67/15 68/12
68/23 70/1 70/6 75/4
118/9 199/6 199/11
branch's [1] 70/8
branches [15] 17/20
67/14 68/8 68/18
68/20 68/21 69/3
70/20 72/13 72/17
74/23 75/6 184/8
192/5 192/19
brand [4] 174/15
branding [1] 173/23
brave [1] 99/11
breach [2] 158/2
158/14
break [8] 53/9 53/14
90/21 90/24 109/12
113/25 160/10 164/10}
breaking [1] 160/9
Brian [4] 2/4 63/2
118/15 160/20
Bridgen [1] 14/12
brief [15] 14/1 14/6
14/19 43/3 50/7 50/21
78/24 86/22 87/16
150/5 181/1 193/4
193/23 193/24 208/23}
briefed [9] 15/4 79/5
176/12 201/11 201/21
202/3 206/19 207/13
208/11
briefing [19] 17/2
20/3 20/5 20/6 31/15
61/2 79/8 85/12 85/16)
86/1 87/2 88/1 93/8
187/15 196/20 197/19}
203/1 206/24 207/8
briefings [2] 14/21
86/15
briefly [2] 20/8 205/8
brilliant [1] 194/10
bring [7] 57/17 61/19
62/11 66/24 110/4
146/6 205/6
bringing [2] 19/3
99/12
broad [3] 46/15
146/20 202/8
broadly [3] 32/23
37/5 108/12
brought [8] 2/16 9/20!
28/18 61/23 63/25
67/6 113/7 178/17
buck [1] 170/5
bug [3] 68/1 68/8
69/9
bugs [12] 24/20 31/7
67/13 67/14 67/17
72/14 98/3 98/11
158/18 198/22 199/2
199/5
build [2] 10/19 160/8
built [1] 178/25
bull's [1] 194/10
bullet [5] 41/12 87/17)
107/25 108/3 152/6
bullied [1] 64/17
bullying [2] 19/16
190/23
bunch [3] 128/7
178/2 199/25
bundle [2] 159/10
182/17
burden [1] 176/23
Burke [1] 6/18
business [41] 4/12
4/22 4/24 5/5 6/22
7/24 9/4 11/8 11/10
12/15 12/24 13/4
14/20 15/9 28/24
37/19 37/20 58/15
64/19 104/19 105/20
105/21 105/23 106/6
155/16 163/9 163/17
167/21 172/12 175/15}
176/2 180/6 186/9
187/19 187/22 188/13)
188/21 189/9 189/15
191/19 209/16
businesses [3] 39/22)
165/7 198/2
busy [2] 163/14
208/20
but [188] 4/11 4/20
5/20 5/24 6/18 7/20
9/16 11/23 13/13
14/11 15/5 15/13
15/24 16/1 16/15 19/2)
19/20 23/18 23/21
24/6 24/11 24/20 25/3}
25/5 28/25 29/22 33/2I
33/14 34/14 35/5
38/19 39/7 39/14
(68) been... - but
B
but... [155] 41/19
41/25 42/13 42/19
46/1 46/20 49/11
50/18 50/20 51/16
52/5 55/11 56/4 60/4
61/3 62/23 65/8 65/17
65/25 66/5 68/16 69/7
70/3 70/16 71/19 72/1
73/14 74/12 76/2 76/3
776 77/14 77/47
77/22 78/14 79/17
80/2 80/24 81/18 82/9
87/2 87/22 87/25
89/14 89/21 90/10
90/16 93/12 94/5 95/7
95/19 95/21 96/12
96/15 97/15 98/20
99/6 99/24 100/13
104/22 105/20 107/9
108/18 111/17 113/21
4116/1 117/18 121/3
122/5 123/12 123/15
128/10 129/14 130/3
133/25 134/3 137/17
137/21 143/23 145/10}
146/6 146/10 146/17
147/8 149/4 151/21
153/18 155/1 155/3
155/14 156/8 158/1
158/18 159/10 159/16
163/13 163/22 165/18
166/2 166/12 167/11
167/24 168/10 168/18
169/10 169/24 170/17
17116 171/25 172/15
172/20 173/4 173/25
4174/1 175/18 175/24
176/17 176/24 177/22]
178/6 178/19 179/19
179/20 180/17 181/2
181/19 182/2 182/3
182/6 182/13 182/22
182/24 182/24 183/18]
185/7 185/12 185/13
186/7 187/3 189/15
191/6 191/7 191/20
193/14 195/17 197/15]
198/7 200/3 201/13
201/19 201/20 204/13
206/25 208/24 209/23
buy [1] 205/18
Cc
Cabinet [4] 12/22
call [19] 1/5 15/19
43/12 54/10 75/13
81/25 85/8 86/21 94/7
96/13 124/3 147/16
147/20 151/23 152/8
152/17 160/14 179/1
189/2
Callard [2] 13/21
15/18
called [5] 17/3 32/19
153/5 158/7 162/18
came [12] 45/17
54/23 59/1 73/15
111/23 124/14 128/21
131/1 165/16 168/6
188/17 196/19
Cameron [2] 147/15
152/2
campaign [1] 19/10
campaign's [1]
190/19
can [165] 1/3 1/18
1/24 2/13 2/25 4/6
4/20 5/21 7/7 9/1 9/9
9/22 9/23 11/19 12/5
12/12 12/12 13/9
13/11 16/21 16/25
19/3 20/17 21/16
27/16 32/9 34/1 34/24
38/6 40/11 42/18 45/3
46/13 46/15 47/6 49/6
51/21 52/8 53/8 53/16)
53/20 54/8 54/22
56/25 61/9 61/17
63/12 64/9 65/14 66/9)
67/11 75/5 78/9 79/16
83/13 84/5 84/9 85/4
87/16 87/17 88/11
88/23 89/5 89/15 90/9
90/20 91/1 91/4 94/2
95/19 96/25 97/1
97/20 99/6 100/12
100/16 102/25 103/12)
103/16 103/25 104/21
105/3 105/14 106/10
106/15 109/12 112/14)
113/25 114/8 114/11
116/18 117/5 118/15
119/14 120/2 120/2
122/5 122/9 123/3
123/6 123/9 123/10
123/22 124/9 124/16
126/2 129/12 129/13
131/20 132/11 134/4
135/16 138/21 139/5
140/14 145/2 146/6
147/11 147/12 151/19)
155/20 156/5 157/4
157/7 160/12 161/2
163/6 163/13 163/24
164/12 164/13 166/9
166/11 167/11 167/16)
172/14 172/23 173/14)
173/25 174/9 174/15
175/4 177/22 182/25
186/7 187/7 189/19
189/25 191/14 191/22)
192/25 193/4 193/11
193/12 193/13 197/19)
200/19 202/23 203/16)
203/23 205/5 205/6
207/1 207/8 210/5
can't [71] 11/1 11/15
11/23 12/5 21/6 30/22
31/19 32/12 32/16
33/1 33/9 35/4 44/13
48/5 58/19 70/16
73/11 78/14 81/18
83/13 84/11 88/14
89/13 89/13 95/7
96/23 109/3 124/19
124/19 124/22 126/1
133/24 134/2 136/18
136/22 137/2 138/8
142/24 143/20 146/9
146/20 153/16 155/14
156/8 159/9 159/15
162/10 163/6 163/13
165/22 172/23 178/14
178/19 185/12 187/2
187/4 195/13 196/16
201/13 201/19 202/7
202/25 203/1 203/4
206/21 206/25 207/4
207/12 209/12 210/2
210/4
candidate [1] 188/1
candidates [2] 6/15
48/1
Candidly [1] 14/23
cannot [9] 13/8 28/19
67/19 70/1 123/10
123/16 133/12 173/14]
210/6
cans [1] 26/3
69/19 70/10 73/1
capable [3] 50/7
137/14 137/24
capacity [2] 105/20
105/21
capital [1] 177/19
capitals [1] 20/13
care [1] 178/22
career [2] 121/24
131/25
careful [1] 9/12
carried [12] 39/4
50/24 64/3 64/11 69/2
77/24 115/4 120/17
122/7 124/18 127/21
147/3
carry [8] 33/14 51/18
68/4 68/24 69/6 72/12
72/19 72/25
carrying [5] 38/18
67/21 132/4 132/23
133/20
Cartwright [4] 63/22
63/23 64/12 157/9
case [34] 28/5 35/11
62/16 62/16 62/20
67/16 68/3 78/15
104/18 111/1 121/13
123/15 123/18 130/10}
130/14 139/19 139/25]
140/2 140/18 141/13
141/25 142/2 148/24
165/22 169/1 169/9
173/21 174/3 174/3
178/13 178/18 201/6
203/13 206/15
case’ [1] 149/1
cases [40] 17/15
17/22 18/10 18/16
18/19 18/25 19/23
21/21 23/8 28/16
28/17 43/25 48/3 48/8)
62/5 67/2 67/22 69/10)
74/12 103/1 113/7
118/16 119/15 119/19
137/20 158/5 158/23
166/4 166/13 167/3
202/17 202/21 202/24,
203/3 203/7 203/9
204/3 204/6 204/14
204/20
cash [5] 4/15 4/15
26/4 26/5 186/12
cast [1] 160/16
category [1] 75/7
cause [6] 23/3 44/2
132/19 151/15 199/10}
209/9
caused [7] 10/17
17/21 67/13 67/20
72/15 203/10 203/15
causes [3] 179/23
179/24 180/1
cautious [1] 149/20
Cavender [1] 148/19
CCRC [9] 22/2 35/10
73/25 113/5 160/15
167/4 167/11 178/14
207/3
ceasing [2] 134/7
135/3
CEO [11] 3/11 8/24
9/13 10/9 10/21 12/3
12/11 12/14 105/23
163/24 198/2
CEOs [1] 12/14
certain [5] 62/17
82/18 87/6 117/11
154/15
certainly [33] 2/8
7/20 26/9 33/13 34/10
34/12 52/1 57/21 59/1
60/16 78/10 78/15
80/13 81/20 82/5
93/11 95/4 98/10
105/19 106/3 106/6
108/9 111/14 123/18
128/23 131/19 132/24}
134/15 134/16 159/11
170/8 183/22 186/7
certainty [1] 68/7
cetera [6] 38/5
143/15 143/15 152/16
177/16 196/2
chain [7] 15/16 119/7
129/13 136/2 143/13
145/19 146/7
chair [36] 3/4 3/5 3/7
3/8 3/10 3/12 3/13
3/18 3/21 3/24 4/8
6/20 10/22 11/3 11/4
11/5 11/12 12/9 13/4
14/13 20/1 29/2 30/4
39/17 101/4 102/18
105/16 105/17 105/18}
106/5 123/19 155/2
169/21 170/5 175/18
184/10
chaired [1] 176/14
chairman [15] 3/1
20/19 27/22 38/3 43/7I
48/20 51/1 52/18
54/11 58/22 92/6 96/7
104/16 105/1 106/23
chairman's [4] 79/6
79/9 79/10 106/17
chairmanship [1] 4/3
challenge [7] 8/20
37/6 63/14 141/1
209/17 209/19 209/21
challenged [4] 19/19
35/7 36/6 172/7
challenges [2] 4/19
4/24
Chambers [1] 109/24
chance [1] 15/15
change [11] 89/19
96/6 96/20 141/20
143/4 143/14 145/18
146/1 169/5 172/16
180/21
changed [6] 154/20
156/13 163/19 169/6
173/5 173/20
changes [2] 102/21
103/2
channelling [1] 177/2I
channels [1] 146/17
chapters [1] 59/14
character [1] 64/19
characterisation [3]
58/14 117/4 179/15
characterise [1]
170/6
characterised [1]
55/21
charge [13] 61/23
62/2 62/2 62/8 62/11
63/8 63/16 64/18
66/18 66/23 66/24
67/6 205/19
charged [1] 62/23
charges [3] 61/19
62/11 118/17
charging [2] 62/25
66/2
CHARLES [3] 1/7
(59) but... - CHARLES
Cc
CHARLES... [2] 1/20
211/2
chastised [2] 95/18
102/3
check [3] 42/11
42/12 118/5
chief [9] 3/10 11/5
11/6 22/16 39/17
44/23 103/16 106/12
172/17
choice [3] 87/4 87/16
88/3
chosen [2] 46/3
187/25
Christopher [5]
30/11 45/5 46/18
106/21 109/23
chronology [1] 142/2
chuck [4] 104/12
chunk [1] 5/8
ClO [1] 118/3
circulated [1] 79/12
circulates [1] 120/7
circulating [2] 55/13
94/4
circulation [2] 82/20
101/12
circumscribed [1]
81/13
circumstance [1]
204/23
circumstances [7]
67/1 68/11 72/22
102/7 113/6 171/11
178/4
civil [15] 38/16 77/21
84/23 87/21 89/11
110/15 113/9 125/7
127/11 129/2 135/15
166/2 168/20 172/5
207/6
claim [7] 113/11
113/12 124/13 124/14}
145/13 168/16 169/3
claimants [7] 48/25
140/7 140/12 140/14
141/16 182/10 182/10)
claimants’ [2] 139/18
139/24
claims [4] 17/24
18/19 22/24 23/6
clarification [1]
74/25
clarify [1] 201/16
clarity [1] 180/24
Clarke [9] 157/8
159/7 160/25 161/3
161/16 161/17 161/23}
162/5 162/8
class [1] 46/9
classing [1] 133/10
clear [17] 16/19 19/2
20/12 37/16 38/23
41/4 56/7 62/22 62/24
64/10 79/19 80/15
131/12 137/17 141/25)
146/22 173/3
clearer [1] 137/11
clearly [6] 20/24
26/22 126/16 150/9
166/24 186/22
client [2] 170/10
174/19
client's [1] 169/1
clients [4] 74/18
167/24 180/22 181/12)
cling [1] 95/11
close [1] 176/13
clunky [1] 37/23
CMC [1] 142/8
co [2] 14/12 47/14
co-authored [1]
47/14
coaching [1] 12/16
Code [1] 63/19
cohort [1] 164/23
Coke [1] 26/3
colleagues [4] 146/5
170/2 176/9 183/11
collected [2] 75/19
75/21
collection [2] 130/3
178/16
collectively [1]
102/12
colloquial [1] 182/22
coloured [2] 85/1
110/17
combat [1] 168/24
come [21] 14/4 15/19
16/21 20/14 45/3
54/12 58/21 80/16
82/7 93/6 96/11 109/4
121/1 131/13 162/17
165/24 167/18 185/8
186/17 187/19 200/3
comes [6] 30/24
36/12 140/4 177/18
183/4 185/23
coming [10] 39/18
50/18 53/8 56/15 95/7
108/11 115/4 131/25
132/1 191/10
commas [1] 49/25
commences [1]
152/5,
comment [8] 12/5
37/22 45/25 69/22
79/24 143/8 206/12
206/15
commentary [1] 60/7
commented [3]
21/23 108/10 108/16
commenting [1]
108/19
comments [13]
13/14 20/21 20/22
21/15 21/15 35/10
57/22 59/3 71/6 141/2
145/14 145/14 145/21
commentsiviews [1]
13/14
commercial [6] 4/19
7/24 10/5 12/17 28/24
33/24
commission [3]
28/17 75/1 86/11
commissioned [11]
80/23 92/24 101/2
101/18 112/17 162/18}
195/19 195/21 195/23}
196/8 209/7
commissioning [2]
37/1 53/22
commitment [3]
28/10 130/7 130/12
committee [9] 9/3
16/3 100/25 144/3
144/9 146/5 147/1
147/7 147/9
Common [7] 139/25
140/4 145/15 149/13
149/17 152/23 169/4
comms [1] 27/13
communicate [2]
135/8 146/19
communicated [1]
135/14
communicating [2]
20/16 111/5
communication [4]
94/5 125/19 146/17
147/2
communications [5]
17/10 26/24 27/7
80/14 141/6
company [18] 4/7
4/11 10/24 11/25
22/11 22/19 32/8
47/10 82/17 92/5 92/9)
92/25 96/6 101/5
102/24 152/13 155/23}
177/16
company's [3] 102/9
102/12 102/13
compare [2] 167/20
208/13
comparing [2]
208/21 208/25
compensated [1]
180/23
compensation [3]
35/9 98/17 98/23
competent [4] 39/20
41/10 121/4 177/15
competently [1]
209/14
competing [3] 175/6
175/24 176/24
competition [1] 5/2
complainants [1]
117/13
complaining [4] 24/1
24/6 168/3 188/25
complaint [4] 18/14
68/13 75/17 190/1
complaints [12]
26/21 30/8 41/24
42/16 42/16 45/11
49/4 59/15 75/13
94/16 107/3 109/25
complementary [1]
68/16
complete [3] 111/4
127/4 131/6
completed [5] 81/4
82/9 86/16 116/7
117/10
completely [5] 23/16
98/1 98/25 172/16
173/5
completing [1]
130/19
completion [3]
118/25 120/18 130/25}
complex [10] 4/11
4/12 4/13 4/14 4/16
5/11 48/3 97/21 99/23)
179/11
complexion [2] 24/9
121/10
complexities [1]
47/25
complexity [1]
199/24
complicated [2] 4/18
179/16
complication [1]
160/21
complications [1]
132/20
complied [1] 157/19
complimentary [1]
154/12
comply [1] 157/22
component [3] 65/22
66/7 189/18
components [1]
118/25
compounded [1]
75
comprehensive [4]
97/20 97/21 98/22
127/5
comprehensively [2]
69/9 199/17
compress [1] 182/1
compromised [1]
179/6
computer [10] 23/2
24/20 31/1 98/3 98/10)
108/10 167/17 181/16}
181/21 200/6
conceived [1] 80/5
concentrated [2]
61/4 177/25
concern [12] 10/17
16/22 44/21 70/18
84/17 107/25 110/13
110/17 140/5 143/22
190/18 203/10
concerned [9] 7/12
28/3 99/2 108/11
122/14 141/23 152/25)
154/4 176/6
concerning [5] 59/14
73/19 100/20 159/7
160/15
concerns [15] 7/11
8/23 28/6 30/5 32/5
32/5 32/17 34/22
48/14 48/15 50/25
63/11 84/21 156/20
187/16
conclude [4] 67/4
90/13 103/12 148/15
concluded [2] 44/11
139/22
concluding [1] 52/14
conclusion [9] 38/21
43/12 43/14 57/12
110/5 112/22 116/24
128/4 160/5
conclusions [6] 29/6
92/23 93/10 93/16
202/8 203/17
concurrently [4] 3/15
3/18 3/21 4/3
condition [2] 204/24
205/14
conditions [1] 122/6
conduct [15] 33/17
44/16 45/4 51/15 52/2
52/3 52/21 52/24 53/1
100/20 129/2 138/21
139/2 139/2 140/18
conducted [9] 51/5
51/12 111/10 111/12
132/25 133/3 161/21
163/17 188/14
conducting [4] 52/14
117/9 118/7 125/7
conduit [1] 153/19
conference [3] 142/1
142/3 160/14
confessions [1]
64/24
confidence [7] 6/20
35/13 35/25 36/17
36/22 82/17 110/10
confident [2] 7/5
117/19
confidentiality [5]
78/25 79/2 82/17
101/11 102/8
confined [1] 81/19
confirm [10] 13/8
27/22 67/25 72/14
(60) CHARLES... - confirm
Cc
confirm... [6] 72/21
78/14 83/13 89/13
126/1 201/18
confirmation [1] 65/8}
confirmed [10] 6/17
15/23 68/3 68/25
85/16 86/25 94/12
118/15 119/14 140/2
conflated [1] 87/12
confusing [1] 36/11
connected [1] 16/6
connection [2] 85/20
145/12
cons [1] 38/17
conscious [1] 134/8
consciously [1]
179/12
consensus [1] 9/15
consequence [4]
94/20 143/24 163/5
163/12
consequences [7]
56/11 56/24 57/7
80/18 93/23 97/6
98/16
consider [18] 52/10
59/24 64/12 68/5
69/12 70/3 72/11
74/23 75/15 86/17
91/19 101/21 120/19
122/24 150/10 152/14}
159/2 209/24
considerable [2]
138/23 139/20
considerably [1]
186/21
consideration [7]
9/12 14/18 52/18
59/22 85/1 103/5
176/14
considered [11]
45/15 49/23 64/1
127/19 136/13 148/14}
157/24 202/17 206/20
206/22 207/3
considering [3]
13/25 28/17 125/16
considers [1] 48/20
consisted [1] 130/1
consistent [3] 30/15
112/22 140/10
constant [1] 186/9
constantly [1] 175/12)
construction [1]
148/3
constructively [1]
140/20
consultant [1] 38/15
consultants [2]
58/20 58/20
consultation [1] 47/8
consuming [1]
163/23
contained [2] 65/18
127/1
contains [1] 91/14
contemporaneous
[1] 139/1
contend [1] 69/25
contending [1] 163/2
content [3] 85/15
87/1 205/23
contents [3] 2/17
84/15 107/7
context [26] 24/5
26/11 26/13 26/22
33/6 58/9 94/1 104/7
104/15 104/23 104/25)
123/17 125/15 141/6
144/7 151/9 154/1
162/23 162/24 163/2
164/1 178/15 187/17
187/18 187/18 189/14}
contextually [1]
184/25
continue [9] 8/4
50/22 102/23 126/12
126/14 133/8 135/23
137/4 199/4
continued [3] 9/13
125/4 126/9
continues [6] 23/10
56/6 95/25 111/2
122/21 137/3
continuing [2]
138/14 207/10
contract [5] 42/12
97/25 98/8 98/17
168/22
contracts [1] 29/24
contractual [1] 200/7
contradicted [1]
187/1
contradictory [1]
132/20
contrary [2] 69/20
70/12
contrast [2] 57/19
57/24
contributed [1] 22/6
contribution [1] 5/8
contrition [1] 170/24
control [3] 69/3
169/22 169/25
controlled [2] 101/13
207/20
controls [1] 72/25
conventional [1]
166/19
conversation [5]
11/2 11/19 14/5 27/22
109/2
convict [1] 62/7
convicted [19] 24/12
24/23 129/3 151/1
158/17 158/21 159/2
165/12 166/1 167/7
167/12 167/19 167/20
167/25 168/3 182/10
189/1 200/17 209/3
conviction [9] 63/20
66/20 66/21 66/25
67/5 166/5 173/24
174/4 174/14
convictions [7] 23/4
23/8 24/10 35/8 113/6
127/9 200/18
convincing [1]
171/17
Cooper [10] 91/11
95/4 139/12 144/23
147/5 147/15 152/1
152/21 182/7 182/24
Cooper's [1] 153/13
cooperative [2]
97/18 168/20
copied [6] 13/23 29/9
129/14 139/10 144/11
145/24
copies [5] 79/18
79/22 81/20 161/14
161/15
copy [16] 1/23 84/14
85/18 87/2 87/18 90/3
91/22 91/24 93/3
101/1 120/10 159/25
201/16 207/19 208/12
210/2
core [3] 164/5 164/23
203/18
corporate [4] 17/10
34/6 34/8 102/10
correct [17] 2/12 3/2
3/3 3/6 3/17 3/20 4/5
54/15 54/23 57/13
58/21 71/19 76/22
86/23 94/10 159/14
210/18
correction [1] 2/16
correctly [4] 76/1
121/22 148/2 163/20
correspondence [1]
202/20
corridor [2] 95/8
102/3
corridors [1] 95/13
cost [3] 99/24 154/6
169/15
costs [1] 140/15
could [105] 5/13 6/24
14/5 24/14 33/25
36/22 38/12 39/6
40/25 41/15 41/17
45/25 46/5 46/8 46/25)
50/10 50/15 50/16
51/17 51/21 53/4 59/8
59/25 62/18 66/19
66/25 68/22 69/2 69/6
71/18 71/24 80/9 82/3}
82/23 83/1 84/24
85/19 85/21 87/3
87/10 87/12 87/13
90/5 98/20 99/7 99/8
99/8 100/14 107/17
107/18 122/7 124/6
124/18 127/24 127/25}
127/25 132/18 132/19}
133/9 133/12 133/17
139/24 142/23 148/11
152/10 154/5 155/22
156/2 161/15 164/6
167/9 167/18 168/21
169/1 169/8 171/6
171/21 176/7 180/10
181/6 181/11 181/15
181/22 181/23 182/14
186/6 186/8 193/17
193/25 194/3 194/3
194/7 194/13 194/24
195/3 197/5 197/11
197/16 199/25 199/25}
203/9 208/4 208/6
208/13 209/5
couldn't [3] 137/5
157/2 193/18
counsel [36] 20/10
34/11 47/6 47/8 47/24
48/2 48/8 48/20 51/2
52/10 52/12 52/17
66/17 67/1 73/18
77/19 78/17 80/6 94/1
101/10 110/22 114/17]
114/20 114/25 115/8
115/18 116/12 127/15}
127/18 128/6 128/15
134/1 136/25 138/6
202/3 205/20
Counsel's [1] 121/3
count [6] 154/3
205/12 205/12 205/23)
205/25 206/4
counter [1] 99/15
counter-argument [1]
99/15
counterbalancing [1]
102/16
country [1] 28/23
couple [6] 14/22
107/22 133/23 145/11
181/2 202/11
course [28] 1/6 14/13}
22/3 23/21 23/23
28/25 30/24 41/23
53/10 64/5 70/22
73/11 90/22 100/8
111/3 112/7 114/2
121/13 124/4 126/6
129/5 150/2 168/23
176/18 179/24 180/15)
205/16 210/14
court [14] 33/7 99/13
113/8 132/18 137/21
139/6 140/23 147/23
156/22 157/20 159/5
160/21 183/10 205/12!
court’ [1] 140/12
courts [3] 3/25
136/14 136/21
cover [10] 19/6 19/17
50/11 110/24 131/22
134/9 135/5 190/23
202/21 207/9
cover-up [2] 19/17
190/23
covered [5] 55/24
194/11 199/16 199/17)
203/2
covering [3] 27/3
27/16 124/7
create [1] 73/2
created [2] 22/5 91/5
creating [1] 28/12
credibility [2] 158/3
182/13
credible [2] 25/5
50/23
credit [1] 74/16
creditable [1] 35/14
criminal [21] 2/3 2/7
2/10 2/10 23/4 23/8
24/10 28/16 32/20
33/7 43/25 48/4 59/16I
73/22 127/9 166/3
173/23 174/15 182/14)
204/2 209/3
crisis [3] 5/15 187/20
191/19
critical [9] 14/13
73/12 140/18 142/4
142/11 142/14 145/9
145/21 176/3
critically [1] 209/10
criticised [1] 18/24
criticism [5] 35/19
140/21 141/23 142/12)
206/9
criticisms [2] 202/9
207/2
crooks [1] 165/22
cross [2] 68/23 75/12
cross-reference [1]
75/12
cross-referenced [1]
68/23
culmination [2]
100/17 103/5
culture [2] 102/22
173/6
curiously [1] 175/22
current [3] 48/7
158/5 158/23
currently [5] 91/9
110/8 117/15 192/4
192/18
cursorily [1] 148/22
curtail [1] 35/21
customer [1] 7/25
CVs [1] 46/14
(61) confirm... - CVs
D
damage [2] 142/24
171/18
damaging [1] 180/7
damning [1] 152/24
danger [1] 36/11
dash [1] 195/22
data [4] 42/6 68/21
70/1 73/21
data-driven [1] 68/21
dataset [2] 69/3
72/15
date [3] 7/2 51/1 59/9
dated [6] 6/6 9/5 85/5
91/12 103/8 182/4
David [1] 148/18
Davies [6] 17/7 20/10
26/24 27/13 31/15
179/2
Davies' [1] 26/25
day [17] 3/13 18/2
25/13 34/24 58/19
140/16 144/18 144/18
145/3 145/5 145/7
146/25 146/25 167/7
179/25 192/3 192/17
days [6] 57/9 105/2
105/7 105/12 106/7
107/22
de [7] 124/25 125/8
125/11 126/5 129/19
130/22 138/6
de Garr [5] 124/25
125/8 126/5 129/19
138/6
dead [3] 168/16
169/1 169/9
deal [9] 18/25 29/22
53/20 92/24 151/16
176/17 177/5 178/21
199/24
dealing [8] 18/23
26/5 33/23 39/16
46/17 166/2 189/14
196/5
dealings [1] 184/9
deals [8] 4/15 18/2
23/23 26/4 192/2
192/16 199/1 204/23
dealt [5] 26/22 140/8
140/15 147/9 175/5
Dear [3] 42/23 51/18
100/23
death [1] 191/18
debate [3] 98/14
115/25 122/18
deceived [1] 56/10
December [3] 54/5
54/10 55/13
decide [4] 118/17
119/16 120/23 199/14}
decided [4] 139/19
147/3 169/4 196/20
deciding [8] 43/14
45/20 114/18 115/23
116/4 122/12 140/17
153/10
decision [24] 45/6
63/9 66/18 76/21
87/25 94/15 95/9
95/18 96/12 96/16
103/6 139/15 139/16
150/3 150/9 150/23
150/24 153/16 154/25)
168/10 168/25 186/1
186/13 194/16
decision-making [1]
94/15
decisions [8] 63/18
118/2 118/5 144/19
153/8 160/5 168/22
197/22
decisively [1] 102/24
declining [1] 5/3
decode [1] 151/21
deemed [1] 94/13
deep [1] 5/15
deeply [2] 171/2
171/2
defence [6] 125/1
157/20 205/25 206/1
206/1 206/2
defend [2] 35/19
129/18
defendant [5] 62/7
63/10 63/12 63/14
159/2
defendants [4] 73/22
158/13 158/17 158/19)
Defining [1] 37/8
definitely [3] 76/9
102/5 145/16
definitive [4] 33/3
60/11 185/12 187/2
definitively [1]
194/13
degree [2] 132/15
194/20
degrees [1] 5/10
delay [2] 44/9 99/24
delayed [1] 152/16
delaying [1] 177/4
delegate [1] 114/18
delegated [3] 114/16
114/25 115/21
delete [2] 73/2 73/20
deliberate [2] 19/16
190/23
deliberately [2]
104/12 183/1
deliver [6] 10/11 35/7
35/24 36/6 60/10
174/10
delivered [1] 35/18
delivering [1] 174/23
delivery [2] 10/10
91/25
Deloitte [9] 61/14
68/25 69/16 70/10
73/18 117/22 118/4
118/6 120/20
delve [1] 111/16
demands [2] 175/24
176/24
demonstrate [2]
37/24 107/1
demonstrated [3]
28/11 148/1 148/11
demonstrates [1]
186/22
den [1] 61/14
dense [1] 51/16
denying [1] 177/4
department [13] 9/4
10/23 35/25 36/17
38/5 60/3 60/20 79/23
81/24 90/2 133/14
134/6 152/25
Department's [1]
153/14
departmental [2]
153/20 153/22
dependent [2] 63/7
118/1
depending [1] 67/16
depends [1] 107/14
describe [2] 30/10
166/16
described [4] 7/14
23/12 60/25 131/17
description [7] 32/7
88/23 120/17 131/4
133/24 156/17 182/18I
designed [2] 20/2
49/3
desire [4] 36/23
53/24 171/9 179/4
desired [1] 52/15
desires [1] 37/20
desk [3] 76/24
195/17 197/4
despite [4] 173/23
205/16 206/6 206/7
destroyed [1] 21/24
destroying [1] 21/20
destruction [1] 21/18
detail [10] 10/16
18/14 19/20 101/23
112/14 113/15 138/23
155/14 159/8 177/6
detailed [3] 2/20 30/7
210/13
determination [3]
122/1 173/10 200/6
determinations [1]
180/20
determine [5] 29/3
48/13 49/2 86/11
115/12
determined [9] 60/5
98/21 99/11 99/24
137/18 144/14 168/22
181/13 183/3
determining [5]
114/13 114/23 115/6
121/18 123/2
develop [1] 10/4
developments [1]
10/13
devouring [1] 175/7
Dickinson [3] 21/14
61/15 117/9
dictated [1] 88/6
did [123] 6/18 6/19
11/25 12/2 13/4 14/14)
18/24 24/19 25/2
26/23 30/20 32/22
33/10 33/11 33/12
35/22 39/1 39/11 40/1
40/2 40/4 44/11 44/13
44/14 45/20 48/4
49/15 49/16 49/16
49/18 59/1 60/6 60/7
60/17 60/20 60/23
65/4 65/25 68/3 69/13)
70/14 70/17 70/18
70/21 71/5 72/4 73/6
76/25 80/21 81/7
81/25 82/5 82/10
82/14 82/14 83/8
83/12 87/4 87/13
87/15 88/3 89/9 89/25
92/13 93/22 103/17
104/11 105/14 107/10}
108/8 111/24 114/18
115/17 116/3 119/7
121/25 127/3 127/10
132/2 136/6 136/23
143/9 144/1 144/21
153/10 153/22 155/11
155/12 155/12 162/9
165/1 166/22 167/1
168/11 168/14 172/2
172/18 179/22 180/19}
182/17 183/11 183/20}
192/8 192/11 192/21
193/7 193/16 195/12
196/10 196/13 196/13}
199/12 201/16 202/22}
203/14 205/24 206/18
206/24 207/8 208/10
209/8 209/15 210/1
didn't [39] 12/25
25/12 26/25 50/19
50/21 58/4 66/5 71/16)
82/9 93/3 93/12
105/12 115/12 115/13}
122/17 128/25 135/10
160/10 162/17 166/24}
167/6 167/8 178/21
178/21 178/22 178/22
179/19 183/17 188/23}
193/2 193/9 193/20
193/22 195/1 195/2
195/6 201/17 202/20
204/17
differ [1] 10/19
difference [1] 185/5
different [40] 24/8
24/13 26/10 26/13
31/2 31/2 36/3 36/21
39/22 41/21 42/6 44/7
46/17 47/20 50/8
68/16 79/1 83/7 95/22
96/4 97/13 99/8
102/19 105/18 115/2
115/3 118/10 121/10
132/15 144/13 151/6
160/5 167/15 168/8
175/10 175/13 175/21
193/12 194/1 197/15
differentiate [1]
88/23
differently [1] 100/5
difficult [8] 7/15 7/19
8/18 10/14 26/19
102/6 127/22 151/21
difficulties [1] 199/22!
difficulty [4] 18/5
82/15 197/20 205/16
digital [2] 69/20
70/11
diligence [1] 8/23
dire [3] 56/12 56/24
56/24
direct [1] 83/8
directing [1] 102/12
direction [6] 129/7
170/11 179/13 194/2
194/14 198/3
directly [10] 42/21
47/16 67/8 80/7 83/12
100/21 134/25 145/23}
153/8 157/4
director [5] 6/1 12/22
17/10 79/4 94/9
directors [2] 10/20
155/23
disagree [1] 111/19
disappointed [1]
102/1
disappointing [2]
134/20 140/25
discharge [4] 86/9
117/23 122/12 155/24)
discharges [1]
117/18
disclosable [2] 85/21
110/16
disclose [5] 103/6
133/13 157/25 158/16
159/3
disclosed [8] 63/15
73/21 76/15 84/24
103/20 158/13 158/13}
158/18
disclosing [1] 83/10
disclosure [7] 63/22
64/14 73/24 158/20
(62) damage - disclosure
D
disclosure... [3]
158/24 160/24 207/10)
discontinued [3]
134/2 135/13 138/7
discover [2] 65/20
199/2
discovered [2] 31/8
203/21
discrepancies [3]
72/16 74/22 75/4
discrepancy [1]
67/20
discretion [3] 38/3
139/21 139/21
discuss [11] 91/17
96/11 97/9 101/23
111/24 125/14 126/6
126/20 135/19 136/3
152/9
discussed [13] 16/1
16/9 71/15 75/8 79/2
85/3 85/14 97/12
111/21 115/1 116/15
185/19 194/9
discussing [4] 91/10
127/24 179/11 187/11
discussion [21]
21/18 60/12 60/15
65/17 82/1 85/1 88/12
89/4 95/5 95/6 96/24
100/19 105/3 108/11
125/24 126/7 136/4
146/9 155/4 171/3
207/1
discussions [8] 8/19
32/9 39/10 110/18
184/15 185/22 186/20
186/23
dishonest [1] 166/20
dishonestly [1] 19/6
dishonesty [2] 63/5
166/21
disk [1] 79/19
dislike [1] 141/15
dismissed [1] 63/16
disposal [2] 174/9
206/14
disposed [2] 15/14
145/10
disproportionate [1]
96/8
dispute [1] 92/12
disputed [1] 140/7
dissatisfaction [1]
180/19
dissect [1] 50/15
distance [2] 156/8
174/16
distinction [3] 42/2
89/3 89/4
distorted [1] 151/11
distracting [1] 175/9
distributed [1] 84/22
distribution [1] 84/14
divided [2] 38/24
59/13
do [143] 1/24 2/1 2/2
2/5 5/18 9/9 14/20
16/4 16/11 16/15 17/7
17/9 18/22 18/23 19/5)
30/6 30/8 30/25 31/6
31/7 33/12 33/14
33/15 33/25 34/3 34/9)
34/13 34/17 37/4 37/9)
37/14 38/20 38/24
40/10 40/11 40/23
44/20 44/22 53/3 53/6
54/4 55/5 56/13 56/21
57/14 57/24 58/2 58/4
58/6 58/7 58/12 64/7
65/12 70/3 71/24
83/13 86/3 88/1 91/16)
95/23 96/16 97/3
98/18 100/19 102/25
104/16 104/17 109/1
121/4 121/21 121/22
122/9 122/16 128/2
128/2 128/3 128/25
129/11 130/1 130/2
130/10 131/14 131/17)
132/14 134/11 137/21
142/15 145/22 150/13)
151/12 152/12 154/10)
154/22 159/18 163/4
165/19 165/21 166/6
166/17 168/5 169/21
170/2 170/7 171/4
171/6 174/6 175/18
175/18 175/21 176/5
176/10 178/21 179/7
180/7 180/12 180/13
182/8 182/8 182/14
183/5 184/16 185/13
185/15 187/9 189/2
193/19 194/20 195/1
195/2 195/4 195/15
195/19 197/1 197/5
197/11 197/24 199/7
199/14 201/7 201/16
208/15 208/16 209/20
document [21] 23/11
49/18 58/23 79/17
80/3 80/12 85/20
86/18 87/23 88/8
89/12 92/2 146/10
146/21 148/3 182/16
187/6 187/9 187/15
206/14 206/23
documentation [1]
61/11
documented [1]
62/25
documents [14]
62/17 62/24 69/16
79/11 91/4 91/19
91/21 92/20 143/17
143/21 160/3 182/2
182/2 203/12
does [27] 24/23
24/23 25/1 29/13
49/10 54/15 55/10
56/1 67/12 70/2 75/7
77/12 77/16 94/13
101/16 110/11 119/1
123/4 123/19 137/15
141/10 141/11 145/24
157/18 167/19 174/4
204/16
doesn't [9] 13/13
46/9 77/14 77/15
86/24 89/16 101/15
107/15 138/18
dog [3] 170/12
170/13 170/14
doing [17] 8/22 18/4
23/25 29/1 45/1 58/16
90/5 99/14 104/16
110/6 121/14 123/8
123/14 127/20 129/10
134/18 188/2
don't [68] 5/14 5/20
8/25 15/10 16/8 16/14
34/18 40/2 45/25
47/19 54/6 56/18
56/19 57/5 57/11 58/2
58/5 60/12 65/16
70/16 70/16 70/21
79/20 87/13 87/14
88/4 93/2 95/21 96/22
106/6 109/1 119/11
123/13 123/14 125/6
142/8 143/12 143/20
146/6 146/12 156/9
159/12 170/16 171/20
171/21 172/19 172/20
174/9 176/15 178/23
181/1 182/16 182/21
182/23 183/3 183/21
186/8 186/25 193/13
193/17 194/24 195/7
195/17 195/18 198/9
198/12 202/25 209/21
done [38] 5/20 14/10
15/10 41/2 42/11
46/20 47/9 61/7 61/8
64/23 66/10 75/23
83/20 100/4 101/4
112/23 120/19 128/1
146/4 167/1 169/23
171/3 171/19 173/13
181/6 182/9 193/17
193/18 194/8 194/13
194/24 197/2 197/9
199/19 200/1 204/15
208/5 208/14
door [1] 153/3
double [2] 118/17
198/16
doubled [1] 169/25
doubling [2] 169/17
169/18
doubt [5] 13/1 40/7
97/9 123/12 206/2
down [43] 3/11 9/10
17/1 37/6 40/16 40/21
45/3 48/18 59/9 65/20
68/17 85/13 87/9
91/20 92/20 104/3
106/16 123/23 126/2
132/6 134/10 147/23
151/20 152/7 160/9
160/11 160/18 160/23
164/14 166/11 166/12)
169/17 169/18 170/1
170/7 172/13 180/11
190/7 191/24 195/19
195/20 197/18 198/4
downside [1] 149/23
draft [9] 17/13 23/10
35/3 60/16 106/23
110/20 117/13 119/2
147/25
drafted [5] 20/20
26/23 27/7 31/16
110/19
drafting [1] 20/8
draw [3] 38/21 128/4
160/4
drawing [1] 116/24
drawn [3] 24/2 42/2
112/21
draws [2] 29/10
67/18
drill [1] 1/10
driven [2] 68/21
179/13
driving [3] 5/5 117/2
124/21
drop [1] 205/23
dropped [2] 62/2
66/23
dropping [1] 206/4
due [4] 8/22 13/19
19/18 98/17
during [2] 141/3
210/14
dust [1] 130/23
duties [2] 155/25
209/2
duty [12] 82/16 155/9
155/13 155/22 155/24}
156/7 156/9 156/15
157/19 157/22 158/2
158/14
E
each [9] 38/17 43/9
112/9 112/11 120/16
122/25 140/1 141/13
168/24
earlier [29] 6/15
23/12 27/17 61/2 65/4,
75/25 102/2 111/21
134/21 136/24 145/20}
154/11 156/19 161/6
165/10 166/23 167/5
167/16 175/17 177/10)
180/14 181/17 187/7
189/11 193/24 197/7
197/14 200/3 209/19
earliest [4] 29/3
161/2 162/5 162/22
early [8] 54/10 57/8
58/15 96/16 118/1
125/12 181/10 187/9
ears [1] 23/14
earth [1] 178/11
easily [1] 181/11
easy [7] 7/20 50/14
104/14 104/24 171/23}
173/10 209/21
effect [12] 56/15
61/25 115/5 124/18
132/4 132/23 133/20
147/4 158/10 171/15
205/17 205/18
effective [6] 82/1
102/10 105/4 105/17
105/22 175/17
effectively [10] 25/20
64/16 65/20 81/13
93/24 121/5 122/8
173/23 183/2 189/7
effectiveness [1]
176/9
effects [1] 157/23
efficient [2] 18/1 23/7
effort [2] 163/7
172/25
efforts [2] 141/10
163/25
eg [4] 35/20 37/16
38/3 41/13
eg that [1] 35/20
eg they [1] 38/3
eight [14] 107/13
107/13 108/22 109/9
114/12 115/16 123/8
124/17 202/15 202/24)
203/3 203/8 204/6
204/14
eight/nine [1] 107/13
eighth [1] 97/8
either [11] 32/14
70/18 72/2 87/16
88/17 89/10 166/11
171/12 193/7 199/6
199/19
electronic [3] 49/1
85/18 87/2
element [3] 4/15
70/22 150/20
elements [4] 38/2
81/10 141/11 144/18
else [6] 90/2 187/1
191/23 196/21 208/4
208/13
elsewhere [1] 202/5
(63) disclosure... - elsewhere
E
email [33] 5/24 13/23
27/3 27/16 27/25 34/2
42/20 44/5 85/4 91/11
94/3 95/25 116/19
120/3 120/7 120/7
120/14 121/16 122/21
123/24 125/20 125/23
125/24 126/3 129/16
136/4 137/3 139/9
143/13 146/7 147/14
151/22 177/17
emails [11] 5/21
13/12 13/13 55/13
100/19 121/7 176/19
17716 177/7 177/18
177/11
emanated [1] 187/12
emerged [2] 17/24
18/17
emphasis [1] 50/3
employee [2] 32/19
156/21
employees [1] 75/14
employment [2]
24/16 165/13
empowered [4]
134/6 135/2 135/10
135/11
enable [1] 62/3
encourage [2] 43/23
102/24
end [16] 7/24 45/19
59/20 100/2 103/14
124/14 132/3 141/14
143/2 145/14 151/11
172/10 179/25 180/20
181/13 184/14
endeavour [1]
146/11
ended [9] 45/13
115/1 136/23 165/2
167/22 168/21 169/3
181/15 200/1
endorsing [1] 56/11
endpoint [1] 103/4
ends [1] 178/10
energetic [1] 106/4
engaged [3] 19/11
190/5 196/4
engaging [1] 39/10
enjoy [1] 84/13
enjoyed [5] 80/19
83/9 88/12 88/18
88/19
enjoys [1] 89/7
enormous [5] 12/25
18/9 176/23 198/25
203/13
enough [7] 39/14
106/2 166/24 175/2
178/7 178/9 182/16
enquiries [2] 5/17
12/2
enquiry [3] 43/12
43/14 44/11
ensued [2] 98/14
1711/3
ensure [5] 29/5 36/23
102/11 103/2 155/16
ensured [1] 101/22
enter [1] 181/8
entirely [11] 44/7
63/9 92/13 92/15 93/2
95/3 194/6 194/15
194/22 195/18 198/24)
entitled [4] 38/10
39/18 158/19 192/25
envisage [1] 102/6
envisaged [3] 52/19
77/13 77/6
epidemic [1] 166/16
EPOS [1] 189/6
equal [1] 63/4
equally [1] 140/22
equipped [1] 33/13
equivalent [1] 102/4
erroneously [2]
81/11 127/17
error [6] 94/18 94/23
95/10 97/4 106/8
176/4
errors [2] 69/4 199/2
escalate [2] 144/19
146/25
escape [3] 180/12
181/19 185/21
especially [3] 23/18
105/23 119/9
essentially [29] 6/4
8/21 8/22 14/18 42/17
53/6 60/7 71/10 72/6
80/5 84/23 92/9 95/18)
102/3 112/3 117/2
124/7 124/21 125/5
133/22 135/8 153/18
160/24 163/8 177/18
185/1 186/3 192/23
193/2
establish [3] 10/6
67/2 178/11
established [3]
139/23 196/17 196/19)
estimate [1] 184/22
estimated [1] 140/16
et [6] 38/5 143/15
143/15 152/16 177/16)
196/2
et cetera [5] 38/5
143/15 143/15 177/16)
196/2
etc [1] 15/24
evaluate [1] 151/10
evaporate [1] 163/11
even [9] 33/6 38/22
100/4 122/22 133/9
141/11 142/12 172/3
182/13
even-handed [1]
142/12
evening [2] 139/15
152/9
event [8] 34/20 40/5
40/6 53/21 72/8
124/23 137/11 159/11
events [11] 13/10
25/10 47/17 59/3
95/20 151/10 160/7
170/4 173/2 173/9
179/10
eventual [1] 57/21
ever [11] 20/17 24/4
39/1 136/16 136/21
137/11 138/8 165/2
167/24 206/2 210/2
every [12] 18/2 18/13
19/21 25/24 58/19
59/6 66/12 123/16
154/2 177/16 192/3
192/17
everybody [2] 173/4
205/9
everyone [1] 97/24
everything [3] 7/18
42/12 57/12
evidence [39] 17/24
18/17 19/2 19/24 23/6
33/4 61/19 62/10
62/19 62/22 63/15
63/19 64/1 64/6 64/13)
75/16 89/18 93/8
117/14 121/8 123/9
139/17 139/24 140/8
141/11 142/23 145/13
148/8 156/21 157/14
158/2 158/7 166/5
184/19 188/12 196/17
201/24 205/20 205/22
evident [1] 26/9
evidential [3] 19/4
66/24 67/4
exact [2] 133/24
134/2
exactly [22] 16/20
21/6 22/9 33/2 34/21
90/10 98/5 111/1
115/22 120/13 123/13
125/9 143/21 146/3
150/25 151/21 155/14
159/16 168/18 179/22)
187/5 196/16
exaggeration [1]
5/15
exam [2] 37/13 41/15
examination [1]
67/25
examine [1] 9/18
examined [2] 45/23
46/10
examining [1] 42/7
example [11] 39/10
65/3 66/13 119/12
150/25 153/24 167/21
169/3 173/19 185/17
200/25
exceeds [1] 195/10
excels [1] 192/6
exceptional [1]
205/15
exchange [4] 13/23
27/25 34/2 144/10
excited [1] 154/15
exclusive [1] 4/25
exclusively [3] 45/12
45/18 45/23
excursions [1] 139/6
Exec [2] 3/12 12/21
executive [17] 3/10
6/2 7/23 9/5 9/19 11/6)
13/6 13/23 22/17
39/17 42/21 44/24
103/17 106/12 153/17
172/17 184/11
Executive's [1] 11/6
executives [7] 27/12
58/24 130/4 144/8
144/10 144/17 146/24}
exercise [8] 33/17
63/23 64/11 69/1
118/10 118/18 119/17)
137/12
exhibited [1] 138/25
exist [1] 121/20
existed [1] 88/13
existence [9] 69/18
92/23 93/10 93/14
93/16 93/20 118/7
158/18 159/6
existing [2] 35/15
70/2
expect [8] 11/4 19/20
19/25 28/25 125/12
134/21 140/14 174/9
expectation [2]
43/23 44/1
expected [4] 69/2
81/5 120/18 208/15
expenditure [1]
137/16
expensive [1] 203/25
experience [9] 2/3
6/19 12/13 33/23
46/16 46/19 82/19
105/17 127/14
experienced [2] 50/5
73/14
expert [6] 72/25
157/14 158/1 158/2
158/3 158/6
expertise [1] 112/19
experts [2] 128/1
168/10
explain [11] 67/19
75/3 105/15 167/16
175/17 177/10 188/22,
189/11 193/4 197/7
203/18
explained [17] 52/23
53/24 64/2 77/5 85/2
90/17 96/14 116/8
132/22 133/4 133/19
136/16 136/18 136/21
137/23 138/4 209/19
explaining [1] 134/21
explains [1] 139/2
explanation [2] 90/8
175/23
explore [1] 118/3
exposure [1] 175/12
express [7] 70/8
74124 154/11 171/14
172/1 180/14 182/23
expressed [4] 7/1
8/23 8/25 63/23
expressing [2] 119/5
121/12
expression [2]
170/23 175/8
extemporary [1] 99/5
extend [2] 118/18
119/16
extensive [2] 2/3
99/5
extensively [1] 194/9
extent [14] 39/17
69/25 75/4 83/4 87/6
107/6 112/9 114/14
116/4 117/22 123/3
124/17 134/25 200/4
external [7] 18/15
21/13 21/21 69/5
73/18 117/9 136/24
extracts [1] 148/19
extreme [1] 171/14
extremely [1] 140/24
eye [1] 194/10
eyes [2] 15/22
179/18
F
face [4] 77/9 119/22
128/10 148/24
faced [2] 4/18 4/24
faces [1] 124/7
facilitated [1] 200/8
facility [1] 70/19
facing [2] 58/23 71/6
fact [35] 3/10 4/11
7/15 11/12 26/5 43/22I
45/22 47/8 55/11
68/23 71/2 71/5 81/6
81/18 83/9 84/12 88/5I
89/14 96/2 101/18
105/8 105/11 119/1
149/25 151/16 173/16)
177/4 179/5 186/21
191/6 191/18 199/10
203/9 204/7 206/6
fact-specific [1]
(64) email - fact-specific
F
fact-specific... [1]
68/23
factor [1] 41/6
facts [5] 36/16 67/3
148/14 174/8 176/14
faculties [1] 47/3
fail [1] 149/6
failed [4] 10/11 10/19
157/21 157/25
fails [1] 149/24
failure [7] 157/23
158/8 158/9 158/12
158/16 159/3 171/20
fair [25] 16/8 32/7
39/14 41/1 45/16 47/5
58/25 76/12 98/9
98/17 111/21 117/4
129/7 141/22 148/13
156/17 169/12 175/2
178/23 183/19 187/4
188/21 193/9 208/17
209/25
fair-minded [2] 41/1
148/13
fairly [8] 28/25 41/10
107/12 142/11 146/22
153/2 182/17 182/22
fairness [2] 107/2
110/19
faith [7] 40/9 104/11
121/4 129/10 134/22
209/15 209/25
fall [1] 75/7
fallout [1] 163/4
false [17] 18/25
57/19 57/24 61/24
62/1 62/8 62/11 62/22
63/3 64/21 64/24 66/4
66/19 66/20 156/23
166/17 206/8
familiar [3] 13/22
33/20 176/18
families [1] 165/5
far [19] 11/19 12/12
31/21 55/7 58/3 64/12
74/12 99/4 103/4
108/10 110/3 113/22
120/20 120/23 122/12
168/6 176/6 179/16
191/20
fast [2] 47/11 153/3
faster [1] 99/9
fatalistic [1] 181/6
fatally [1] 158/4
fault [2] 26/21 190/7
faults [3] 23/2 26/15
26/17
faulty [1] 17/20
favour [1] 168/14
feared [1] 180/9
feasible [1] 86/12
feasibly [1] 64/10
features [3] 118/16
119/15 119/16
February [7] 9/5
53/23 59/9 106/20
109/18 119/3 162/2
feel [13] 6/18 18/8
40/1 40/2 76/2 97/3
134/6 135/2 135/10
151/12 171/18 173/13}
181/3
feeling [2] 10/3 12/23
feels [2] 130/7 134/8
fell [2] 87/4 87/25
fellow [2] 83/16
83/17
felt [29] 5/12 6/21
7/14 7/20 8/8 8/15
8/17 27/9 30/23 37/4
39/4 41/9 42/14 64/21
81/11 82/4 87/22
90/13 112/1 124/24
130/11 142/23 153/7
156/11 169/21 172/15)
197/17 199/16 205/22)
few [10] 12/21 24/1
31/3 31/7 39/8 65/20
107/25 120/12 139/5
183/19
fight [1] 169/12
figure [1] 186/24
figures [4] 5/18 7/2
23/1 186/16
file [3] 62/17 67/2
205/13
files [3] 64/5 75/15
202/15
fill [1] 171/19
final [16] 22/8 22/9
32/15 51/7 51/24
55/24 56/9 56/17 85/5)
106/19 109/5 109/18
119/2 137/18 156/3
182/1
finally [4] 51/12 89/6
102/17 183/5
finance [1] 8/1
finances [1] 7/11
financial [2] 199/5
199/11
financing [1] 7/16
find [17] 22/13 33/13
33/14 36/16 37/3 54/1
62/18 97/20 111/5
121/13 137/19 163/16)
163/18 171/13 176/11
188/4 194/25
finding [1] 36/8
findings [17] 35/6
36/5 36/7 36/9 79/6
79/8 101/6 101/23
110/4 111/8 111/9
111/18 112/8 112/10
118/18 148/5 149/25
fine [5] 31/6 42/13
89/24 97/3 200/12
finessed [1] 111/12
fingertips [1] 146/13
finish [2] 80/9 192/25)
fire [2] 1/10 8/11
firm [3] 117/9 129/17
157/8
first [34] 17/13 20/20
32/22 33/24 39/19
41/12 46/9 53/9 69/17,
97/6 103/20 104/1
104/2 104/9 107/25
111/7 116/25 124/20
125/2 125/6 130/21
139/6 140/16 154/2
154/24 159/6 165/1
168/1 174/7 174/23
196/18 202/14 205/17
208/19
Firstly [4] 94/22
108/8 139/5 152/17
five [5] 60/2 60/13
95/15 95/16 162/16
five years [1] 162/16
flag [1] 204/8
flagged [2] 124/2
147/16
flaws [1] 49/1
flippant [1] 208/24
flowed [1] 88/7
focus [1] 45/1
focused [1] 68/11
focuses [1] 49/8
focusing [2] 19/23
26/13
FOIA [4] 133/18
follow [10] 92/24
93/14 93/17 93/18
94/20 94/24 130/8
130/12 194/25 200/23
follow-on [1] 194/25
follow-up [7] 92/24
93/14 93/17 93/18
94/20 94/24 200/23
followed [6] 83/21
86/6 91/25 97/8 97/10
110/12
following [14] 7/6
28/4 43/3 54/19 61/1
62/8 66/22 79/10 85/8
91/21 92/20 99/3
148/1 201/10
follows [1] 112/3
food [1] 165/4
foot [12] 15/16 20/8
34/2 47/13 67/11
120/3 135/18 139/8
145/2 151/20 151/24
157/7
force [2] 96/6 96/20
forceful [1] 56/2
forces [1] 50/2
forensic [7] 18/11
43/6 58/21 75/1
195/24 196/8 196/14
forever [1] 180/21
forgive [1] 175/8
form [8] 8/20 33/17
43/24 48/22 84/23
121/8 126/17 134/3
formal [6] 11/21
95/13 95/17 96/15
96/24 109/13
formally [1] 14/21
formed [4] 15/9 30/8
144/6 156/6
former [3] 22/25
38/16 43/7
formulated [1] 76/15
formulating [1] 136/7I
forth [1] 26/7
fortnight [2] 34/20
34/21
fortnightly [1] 116/20
fortuitously [1]
165/24
forum [1] 172/5
forward [28] 18/22
20/7 29/6 57/11 59/19)
66/8 66/8 69/14 75/11
77/25 81/2 85/12
91/16 93/25 107/1
114/19 114/22 114/24}
115/7 116/2 116/10
117/3 120/17 125/15
126/2 127/21 134/19
135/16
forwards [25] 9/23
16/25 21/9 42/18 52/8
59/10 61/16 74/10
100/16 106/15 108/23}
114/15 115/10 115/17,
115/24 116/5 116/6
120/2 120/7 121/19
127/12 129/12 145/2
147/11 151/19
forwards a [1] 42/18
found [3] 39/21 108/6)
121/24
foundation [1] 66/11
founded [1] 75/17
four [12] 4/4 6/8
45/14 59/20 79/18
79/22 81/20 81/23
87/17 112/7 120/23
207/18
four years [1] 4/4
fourth [3] 19/8
189/21 190/9
frame [5] 12/12 26/19)
46/22 52/15 150/23
framed [3] 51/3
51/23 155/15
framing [1] 45/10
frankly [1] 130/18
Fraser [4] 148/10
149/24 150/14 168/11
fraught [1] 205/15
Freedom [5] 84/19
84/25 85/22 110/16
161/10
frequency [1] 151/9
frequent [1] 31/8
fresh [2] 15/22 16/12
front [3] 1/23 12/17
130/2
frontally [1] 102/19
fruitless [1] 137/4
frustrated [1] 118/24
frustrates [1] 137/16
frustration [2]
118/22 120/4
frustrations [1]
199/22
Fujitsu [18] 30/6
32/19 61/14 67/18
67/25 68/2 68/3 68/18
69/19 69/21 70/19
71/5 73/1 156/21
157/14 158/9 197/5
199/7
Fujitsu's [2] 69/22
73/20
full [11] 1/18 62/6
70/4 72/19 72/25
79/12 79/13 83/25
89/1 98/11 210/13
fully [4] 97/12
function [4] 34/17
122/11 178/7 178/9
functionality [2]
69/22 70/4
Fundamentally [1]
187/22
funding [1] 113/9
funnily [1] 182/16
funny [2] 151/2
203/11
further [36] 14/7 29/4
35/21 40/18 48/13
52/16 59/8 59/24 61/4I
61/9 65/11 67/24 79/9I
86/2 96/13 110/2
412/25 117/21 118/1
118/3 118/5 122/24
123/2 124/5 126/3
134/5 145/7 147/17
149/16 150/5 158/23
160/18 190/7 195/20
200/10 201/23
fuss [1] 45/2
future [2] 29/7 86/15
G
gained [1] 62/15
game [2] 172/10
172/15
gap [1] 171/20
gaps [1] 61/8
Gareth [3] 32/19
156/21 159/7
Garr [7] 124/25 125/8
(65) fact-specific... - Garr
G
Garr... [5] 125/11
126/5 129/19 130/22
138/6
gave [8] 55/22 56/3
78/16 123/5 176/6
176/7 181/4 198/12
Gavin [1] 152/2
GC [1] 81/1
GC's [1] 81/24
general [38] 4/6 9/15
10/3 11/11 20/10
30/13 30/18 31/13
31/24 34/11 36/21
47/24 48/19 SO/7
52/12 68/13 75/2
77/19 78/17 80/6 94/1
101/10 110/22 114/16)
114/19 114/25 115/8
115/18 116/12 121/3
123/6 127/18 128/6
128/15 164/25 175/5
176/10 202/3
generalised [1]
31/20
generally [4] 15/13
39/23 77/22 110/17
generic [1] 67/14
genesis [1] 17/2
gentlemen [1] 56/14
genuine [4] 36/23
170/23 171/13 179/4
get [46] 12/25 18/10
22/8 22/9 30/20 33/11
45/21 53/4 54/13 66/3
70/25 71/10 71/13
71/16 71/18 72/4
80/24 80/25 100/1
105/3 118/23 121/7
128/2 131/20 134/21
136/5 142/2 149/4
151/17 153/7 154/3
154/13 162/20 166/11
171/15 172/12 176/25}
ATTINT 178/5 179/3
180/17 181/22 184/14}
187/9 196/13 197/11
gets [2] 73/12 160/9
getting [12] 7/5 7/12
20/15 47/22 61/16
134/24 135/14 137/20)
153/20 198/3 198/10
203/24
gist [1] 162/20
give [24] 6/19 9/12
29/2 40/13 60/13
87/18 88/23 96/22
99/5 128/12 128/24
130/18 131/20 134/4
140/11 150/10 152/20
158/7 163/2 164/1
171/9 177/20 185/12
187/2
given [25] 14/18 25/8
38/8 39/24 40/8 90/8
90/14 100/13 101/17
122/22 127/7 132/18
139/25 140/25 150/11
162/24 196/20 207/5
207/9 207/19 209/11
209/14 209/14 209/18
209/25
gives [1] 107/19
giving [3] 129/9
156/21 184/19
glad [1] 200/22
glimmer [1] 124/20
glitches [1] 199/2
GLO [7] 97/19 97/24
169/20 176/4 180/10
180/17 180/18
go [77] 2/13 8/17
9/23 13/11 13/20
15/16 17/1 19/20 20/7)
20/20 21/9 21/17
25/17 29/10 38/22
40/9 40/12 40/14 42/1
48/10 53/6 58/6 59/6
59/10 59/19 60/24
61/16 65/11 69/14
74/10 75/10 75/18
77/2 96/18 98/18
103/16 104/1 106/10
106/15 112/6 112/11
112/13 113/22 118/20)
120/2 120/24 122/12
122/16 125/7 126/2
129/13 135/12 135/17,
140/20 151/19 151/24)
152/5 157/6 157/13
172/6 173/19 175/4
176/10 178/10 187/6
187/7 187/8 188/1
189/20 189/22 190/8
191/20 192/14 194/19)
197/18 203/7 206/17
goes [11] 58/8
110/14 140/8 148/7
152/5 170/11 183/15
190/17 195/9 195/25
206/11
going [99] 1/11 2/22
4/19 7/9 7/20 8/17
14/3 15/5 16/3 16/11
17/6 27/19 29/24 30/2
30/3 38/24 39/2 44/25
45/2 45/20 47/12
47/21 49/12 49/21
50/7 52/25 55/15
55/16 57/20 57/24
59/6 61/21 64/25
66/10 76/16 79/21
80/16 82/22 85/11
87/22 89/20 92/1 93/6)
100/4 104/19 106/11
107/20 112/11 112/15)
114/22 115/10 115/17,
119/24 121/9 122/19
122/23 123/11 131/8
131/11 134/16 136/11
138/20 138/24 144/8
145/22 151/21 165/24)
166/16 167/3 167/4
167/11 168/3 171/8
173/19 175/13 175/16
176/1 176/1 176/12
176/17 177/20 178/3
178/14 179/1 183/24
186/1 186/13 186/17
187/6 188/4 188/9
188/10 193/5 201/24
203/8 204/7 205/3
206/12 206/13
gone [7] 18/9 31/21
98/6 193/12 197/5
197/9 199/21
good [35] 1/3 1/15
6/19 10/6 40/9 47/1
50/7 50/10 53/16 65/8
65/10 65/18 65/19
76/4 91/1 97/6 104/11
111/22 111/23 113/21
114/8 121/4 123/21
128/6 128/11 129/10
134/22 134/22 134/23
161/12 164/12 171/21
197/17 209/15 209/25
gospel [1] 123/17
got [60] 12/13 16/19
23/25 24/22 27/11
31/9 31/11 33/22
39/22 47/11 55/13
57/10 66/4 72/3 77/5
77/18 78/9 80/4 80/23}
84/22 90/12 90/16
95/20 95/22 95/23
98/3 98/7 98/9 98/12
100/13 121/23 128/5
133/22 135/7 147/5
153/25 154/17 156/10
159/9 160/11 169/13
169/16 169/25 170/14
1714/5 171/7 171/23
174/7 174/8 175/4
175/10 175/12 180/14
181/2 181/20 191/3
193/14 195/21 197/1
206/14
governance [3] 92/5
92/8 102/11
government [35] 5/5
6/21 7/17 7/21 8/1 8/4
10/12 13/5 16/12
16/22 28/6 28/10
28/19 28/21 32/2 32/4
43/24 44/1 84/15
89/10 90/3 98/7 103/5
103/19 112/10 112/15}
144/21 153/10 166/1
184/12 186/5 186/10
186/13 186/17 209/16)
Grabiner [2] 150/6
155/7
Grabiner's [1] 155/7
gradually [1] 179/5
grapple [1] 178/15
grappled [1] 177/24
grass [1] 104/13
grateful [4] 6/24 43/2
205/6 210/14
great [1] 199/24
greater [2] 68/7
133/1
greatly [1] 50/5
green [1] 199/18
grievances [1]
102/20
grind [2] 83/18 179/5
grip [1] 176/25
grips [2] 198/4
198/10
gritty [1] 198/4
grooming [1] 179/2
ground [3] 124/8
149/3 159/4
grounded [3] 74/6
75/8 75/9
grounds [9] 78/25
139/20 147/18 147/19}
148/1 148/5 148/11
150/18 151/18
group [13] 18/8 33/6
43/8 50/10 81/22
99/10 99/20 129/22
129/24 132/2 138/22
143/11 184/6
grown [1] 190/19
guarded [1] 133/9
guided [1] 61/3
guilty [8] 62/1 62/8
63/10 64/17 64/21
66/21 172/5 206/7
guilty/liable [1] 172/5
guns [1] 14/11
gut [1] 151/12
guy [1] 162/18
guys [4] 55/12 57/10
134/17 145/22
H
had [217]
hadn't [6] 15/11
36/13 119/25 202/22
207/18 207/20
Hailstones [1] 61/15
half [6] 5/23 9/6
42/20 105/2 105/6
106/7
Hall [1] 69/24
Hamilton [5] 62/20
200/19 204/20 205/18,
205/24
Hamilton's [2] 35/10
204/23
hand [7] 9/10 9/24
10/2 10/9 21/16 39/4
77/6
handed [2] 142/12
178/1
handing [1] 113/23
handle [4] 27/11 30/9)
44/20 178/3
handled [3] 92/16
97/18 98/20
handlers [1] 75/14
handling [7] 48/24
74/15 92/11 94/16
102/20 107/2 109/24
handover [3] 11/16
11/18 11/22
hands [3] 84/22
110/15 197/2
hang [4] 191/13
199/12 203/16 204/13}
happen [4] 81/5 82/9
162/9 179/22
happened [24] 13/11
25/3 25/10 40/7 53/21
53/21 57/15 89/15
97/23 98/6 106/1
125/10 143/24 145/23)
145/25 146/4 156/17
163/5 163/13 167/24
168/24 179/19 180/5
185/22
happening [5] 16/1
91/18 100/18 124/20
163/11
happens [4] 20/5
24/4 29/5 153/15
happy [7] 6/17 14/11
15/23 15/24 112/1
113/17 125/14
hard [11] 1/23 27/9
31/19 79/19 143/17
160/4 171/12 171/13
172/6 185/11 206/11
hardworking [1]
165/3
has [103] 4/9 4/13
4/15 10/6 10/8 10/15
10/17 10/19 10/21
12/6 17/15 17/17
17/24 17/25 18/3 18/6I
18/9 18/17 18/20
19/10 19/11 19/12
19/23 20/13 21/21
21/24 22/23 23/5 23/6
23/8 33/22 37/9 37/25I
40/7 40/22 48/16
50/24 54/8 57/1 57/6
60/3 61/5 61/7 61/22
62/13 62/15 64/2
64/11 64/16 69/25
70/9 70/22 73/24
74/12 78/24 84/4 86/4I
94/12 95/3 96/1 97/16)
98/3 98/21 98/25 99/6
102/19 113/11 117/10}
(66) Garr... - has
H
has... [35] 118/14
119/14 125/13 125/14}
130/6 130/7 137/17
139/12 139/20 143/23
145/24 146/7 148/2
148/21 148/23 148/25)
149/4 157/19 158/6
158/10 158/24 161/21
161/22 163/17 163/19)
171/18 173/5 179/15
192/3 192/17 193/12
199/1 199/20 200/7
208/14
hasn't [1] 173/20
have [370]
haven't [7] 77/5
90/18 96/10 103/11
174/7 174/20 206/14
having [23] 44/24
55/8 61/11 94/12
96/24 104/20 125/21
132/15 148/14 152/17
160/1 173/24 175/4
175/11 175/20 178/7
178/9 181/8 184/9
184/20 202/6 203/6
206/7
he [88] 6/19 6/19
6/20 7/3 7/4 7/5 14/6
14/9 14/14 15/22
15/23 15/23 15/25
21/15 21/23 34/18
37/15 37/24 40/20
41/3 41/13 46/20
46/23 48/2 48/4 48/7
54/9 54/12 54/20 55/1
55/19 56/6 56/9 56/22
57/3 57/6 57/21 85/18
94/13 94/13 95/5 96/1
108/5 108/6 110/23
125/14 126/12 128/17)
128/23 129/19 130/7
130/9 134/7 140/2
140/3 141/2 141/11
142/3 142/4 142/13
144/24 144/25 145/10)
148/18 148/21 148/21
149/2 149/16 150/18
153/15 153/19 155/8
155/12 158/6 158/6
159/4 161/11 177/1
184/10 185/14 187/10}
202/14 202/17 203/8
203/9 204/7 205/9
206/11
he'd [1] 203/6
he's [3] 38/10 108/22
161/18
head [1] 136/12
headline [3] 112/7
112/10 203/17
hear [7] 1/3 53/16
89/20 91/1 114/8
164/12 200/22
heard [4] 57/9 58/5
103/11 131/25
hearing [4] 29/6
100/25 139/13 210/23)
hearings [1] 141/3
heavily [1] 18/24
held [12] 10/23 11/13
18/11 55/20 58/9 78/2
78/7 79/23 81/22
149/6 150/23 160/13
help [13] 5/13 7/23
11/23 12/12 12/16
35/19 46/13 47/1
54/13 54/22 56/4
184/18 204/16
helpful [4] 29/21 63/3
120/15 145/16
Helpline [2] 117/6
4117/7
helplines [1] 26/20
helps [1] 175/41
Henderson [4] 54/4
54/19 55/2 55/21
Henry [10] 164/18
164/21 170/3 174/9
174/18 175/1 176/7
177/23 184/3 211/6
her [33] 3/24 6/16
6/20 11/20 12/3 12/4
12/24 14/5 14/5 14/15
14/15 34/9 42/21
43/13 54/20 63/15
78/20 79/15 79/24
81/2 87/13 87/16
87/18 93/8 115/19
115/21 117/2 173/23
173/23 174/14 174/15)
205/19 206/6
here [34] 4/20 10/25
11/13 23/23 31/3
33/20 36/3 39/6 39/14)
44/22 50/2 51/16 72/6
80/22 95/11 96/22
106/1 116/20 116/25
122/4 122/15 123/11
123/12 131/17 143/25)
154/9 162/23 174/22
178/5 181/24 182/24
189/25 205/11 208/24)
here's [4] 23/18
60/13 66/2 179/21
hermetically [1]
180/11
hers [1] 10/19
herself [1] 127/18
Hey [2] 95/8 131/19
hide [2] 80/1 104/12
hiding [1] 83/15
high [6] 37/21 112/23
139/22 151/23 152/4
183/10
higher [5] 136/14
136/20 153/1 160/9
160/9
highest [2] 107/41
147/24
highlight [3] 170/9
191/21 191/22
highlighted [2] 61/6
110/14
highly [4] 205/14
him [30] 14/3 14/8
14/9 15/22 17/8 20/15
27/1 34/4 34/13 51/2
51/10 51/15 54/13
55/3 55/22 56/3 63/15)
78/24 79/3 92/11
96/10 125/8 126/7
141/20 143/4 148/11
150/4 155/12 158/1
208/15
himself [9] 52/20
92/16 147/18 148/12
149/5 150/4 150/18
153/16 153/23
hindsight [28] 23/18
40/25 41/22 42/9
49/10 50/1 58/13 64/4
65/23 71/21 73/11
76/2 87/24 97/3 99/19
101/24 104/6 106/9
125/9 127/23 129/5
134/20 165/9 167/9
177/14 194/7 197/18
199/21
his [53] 3/25 7/4 7/7
21/15 34/19 37/12
37/25 38/3 38/10 51/7
51/24 52/18 53/5 54/9
54/13 65/25 66/1
85/12 85/15 85/17
87/1 94/17 96/4
114/12 117/17 117/18
118/15 119/14 124/3
124/5 126/7 126/10
134/7 135/22 141/1
141/14 145/14 147/25I
152/11 157/19 157/22)
158/1 158/2 158/3
159/2 161/10 172/24
173/13 177/2 184/20
185/13 202/10 202/23
historic [3] 180/6
189/2 189/4
historical [1] 191/4
historically [2] 21/24
189/10
history [5] 77/3 80/23}
101/6 180/6 180/7
hitherto [1] 127/15
hm [14] 6/7 6/9 6/14
34/25 34/25 91/8
113/13 127/6 161/1
161/1 161/4 162/7
164/16 184/24
HMCTS [2] 155/2
155/3
hold [6] 21/21 46/8
99/11 100/6 100/9
162/14
holding [2] 100/8
128/9
hollow [1] 171/8
honest [13] 10/25
11/15 25/2 33/9 40/3
54/7 88/4 89/14
119/25 124/19 150/20}
165/20 177/15
honestly [19] 31/19
58/13 88/20 96/23
124/22 126/1 156/8
174/20 177/23 178/6
178/19 183/4 185/10
187/2 197/16 201/19
202/25 204/18 209/12,
Hooper [2] 43/7
165/1
hope [7] 12/6 62/1
71/13 91/18 112/24
173/4 174/24
hoped [1] 169/11
Horizon [80] 13/19
16/6 16/13 16/23 17/2
17/19 21/3 23/2 23/23}
24/18 27/23 28/2 28/7,
28/10 28/16 29/12
30/5 30/14 30/20
31/14 32/3 32/10
37/18 42/5 48/14
48/16 49/1 54/2 54/13
59/15 59/16 67/12
69/22 72/20 72/22
73/4 73/6 73/8 73/14
92/12 94/16 98/11
101/6 102/21 103/1
104/17 107/3 108/4
110/1 112/25 117/21
117/24 140/5 157/15
159/18 162/25 166/5
168/23 170/21 172/3
175/25 181/14 181/15}
182/5 182/13 188/15
188/19 189/3 189/5
189/5 189/15 191/7
192/2 192/9 192/11
192/16 195/16 197/12}
198/25 199/10
Horizon's [1] 70/4
hosted [1] 124/2
Houghton [1] 118/4
hour [1] 55/8
house [2] 59/2
205/19
how [66] 13/25 14/19
17/17 17/23 23/11
23/22 24/15 24/23
25/1 25/15 27/9 30/9
30/23 31/6 38/23
44/20 51/3 51/11
51/22 67/16 71/2
I actually [2] 159/9
71/17 76/14 80/5 85/2
85/2 85/11 86/22 88/9I
99/7 99/8 99/8 116/5
120/20 120/23 122/12)
124/10 125/15 125/16
127/20 128/2 133/12
137/19 150/25 151/4
152/10 162/17 163/19)
165/11 165/12 165/17
165/21 167/6 167/12
167/18 167/19 168/2
168/2 170/17 172/6
178/25 179/22 189/19)
200/5 206/22 209/20
however [13] 7/21
23/5 24/11 30/10
31/15 35/12 36/19
126/12 129/9 134/10
149/16 157/23 205/11
huge [7] 18/14
166/19 172/25 173/6
173/16 181/23 203/21
human [1] 175/8
hyperbolic [1]
171/15
hypotheses [1]
155/21
200/24
ladvised [2] 79/13
83/24
lagree [3] 75/9 79/2
113/21
laimed [1] 12/17
I allowed [1] 40/9
lalso [5] 24/13 91/12
105/14 110/4 154/25
I always [3] 8/8 8/15
8/17
lam [14] 27/21 29/1
43/2 45/1 78/23 80/22)
110/8 111/3 111/4
112/18 118/23 128/19}
159/19 166/16
land [2] 163/7
173/12
l appreciate [1]
168/9
lare [1] 13/25
larrived [1] 16/16
lask [7] 1/9 1/17
88/11 121/21 122/9
157/4 184/5
l asked [4] 89/9
114/23 142/15 166/25)
l assume [1] 203/1
lassumed [5] 121/2
121/3 127/17 134/23
177/13
l assure [1] 170/20
I aware [2] 49/19
49/20
(67) has... - I aware
I became [1] 11/3
I beg [2] 40/19 80/10
I began [1] 11/17
I believe [10] 8/6
8/13 46/18 77/20 79/6
80/14 124/12 163/3
210/1 210/17
I believed [1] 5/13
Icall [1] 1/5
Ican [36] 4/20 9/22
11/19 12/12 46/15
56/25 78/9 79/16
83/13 84/5 87/16
87/17 88/23 89/5
89/15 90/9 95/19
97/20 100/12 104/21
122/5 123/6 132/11
163/6 163/13 163/24
164/13 166/11 172/14}
172/23 173/25 177/22)
182/25 191/22 197/19}
203/23
I can't [56] 11/1
11/15 11/23 12/5 21/6)
30/22 32/12 32/16
33/1 33/9 44/13 48/5
70/16 73/11 78/14
81/18 83/13 84/11
88/14 89/13 89/13
95/7 124/19 124/19
124/22 133/24 134/2
136/18 136/22 137/2
138/8 142/24 143/20
146/9 153/16 155/14
156/8 159/9 159/15
162/10 163/6 163/13
172/23 178/14 178/19
185/12 187/2 195/13
196/16 202/25 203/4
206/21 207/4 207/12
209/12 210/4
I cannot [2] 133/12
210/6
I certainly [9] 34/10
34/12 78/15 81/20
106/6 108/9 111/14
131/19 134/15
I chaired [1] 176/14
I come [2] 121/1
200/3
I commissioned [1]
162/18
I conclude [1] 90/13
I could [15] 5/13
36/22 39/6 45/25 80/9
87/13 176/7 181/11
193/17 194/3 194/24
195/3 197/16 199/25
199/25
Ideal [1] 53/20
I delegated [1]
114/16
I describe [1] 30/10
I did [13] 33/11 40/2
44/13 60/17 70/17
70/21 104/11 105/14
111/24 182/17 203/14)
208/10 210/1
I didn't [10] 12/25
25/12 58/4 115/13
135/10 162/17 166/24)
178/21 193/2 195/6
I discussed [2] 79/2
111/21
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16/15 17/9 30/6 30/8
97/3 98/18 130/2
137/21 171/4 180/13
I don't [58] 5/14 5/20
8/25 15/10 16/8 16/14
34/18 40/2 45/25
47/19 54/6 56/18 57/5)
57/11 58/2 58/5 60/12)
65/16 70/16 70/16
70/21 79/20 87/13
87/14 88/4 93/2 95/21
96/22 109/1 119/11
123/14 142/8 143/12
146/6 146/12 156/9
159/12 170/16 171/20)
171/21 174/9 176/15
178/23 181/1 182/16
182/21 183/21 186/8
186/25 193/13 193/17)
194/24 195/7 195/17
195/18 198/12 202/25)
209/21
lended [1] 167/22
lentirely [1] 194/22
l expected [1] 81/5
l explained [3] 52/23
116/8 209/19
I feel [3] 40/1 76/2
173/13
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30/23 37/4 39/4 81/11
82/4 112/1 172/15
197/17 199/16
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I formulated [1]
76/15
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I fully [4] 97/12
I gave [3] 176/6
176/7 198/12
I get [4] 22/9 80/25
162/20 177/17
I give [1] 163/2
Igo [4] 175/4
I got [9] 16/19 47/11
72/3 80/4 121/23
133/22 135/7 171/5
193/14
I had [22] 11/20
27/12 30/6 37/2 45/25
46/14 53/3 54/19
78/24 83/18 83/18
104/12 116/16 127/14
132/24 133/6 138/4
151/2 165/11 169/11
170/15 197/13
hadn't [1] 119/25
I happened [1] 25/3
Ihave [31] 15/1
15/13 20/6 20/20
31/21 43/12 83/15
85/10 88/20 90/10
90/11 97/22 104/18
108/9 109/22 112/17
118/3 121/20 121/24
151/6 151/14 162/23
162/24 174/8 177/16
178/15 181/1 182/1
197/7 206/1 210/8
I haven't [6] 77/5
90/18 96/10 103/11
174/20 206/14
I honestly [5] 31/19
96/23 126/1 178/6
201/19
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112/24 173/4 174/24
I hosted [1] 124/2
l imagine [2] 154/5
170/17
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42/14
joined [1] 177/10
I just [15] 40/13 54/8
56/19 58/17 88/25
103/16 109/3 109/4
123/15 161/25 181/3
183/3 192/25 202/11
208/18
I kind [1] 39/25
I knew [1] 142/25
I know [8] 54/6 79/16
167/11 167/23 171/25}
172/20 181/18 206/24
I lacked [1] 39/9
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Heft [4] 172/18
look [1] 29/6
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25/17 49/17 204/10
I made [2] 106/8
200/3
I make [1] 12/5
I may [5] 77/22 123/6
139/5 144/4 186/6
I mean [62] 7/19
10/25 12/15 12/21
15/1 15/13 16/8 16/9
20/3 22/7 27/8 29/19
29/25 31/17 32/25
32/25 33/1 33/1 36/2
36/4 38/22 40/9 40/24
42/9 49/16 52/1 52/5
58/13 58/19 60/10
71/8 79/24 82/5
107/14 109/14 111/11
116/24 119/12 122/14}
134/15 136/22 143/20}
147/8 159/8 159/10
159/11 159/15 159/19)
161/8 163/21 165/19
169/9 172/5 173/7
173/24 174/15 178/17
181/9 183/18 201/18
206/11 206/11
I mention [1] 121/11
I mentioned [2]
150/21 197/14
I met [4] 11/17 54/6
79/3 129/21
I might [5] 16/9 27/14
95/20 95/23 204/15
I missed [1] 84/6
I move [1] 186/15
I must [2] 108/15
124/12
I need [1] 196/14
I normally [1] 121/20
I now [1] 110/1
l obviously [1] 15/4
I only [2] 200/22
204/22
I paid [1] 176/13
I played [2] 181/10
181/18
I presume [3] 16/8
48/9 84/4
I probably [5] 5/20
60/23 69/13 84/7 87/6
I propose [1] 150/5
I provided [2] 79/7
109/21
I put [2] 155/20
208/10
I quote [1] 174/1
Irather [1] 114/21
read [4] 83/23
142/10 192/15 203/11
I recall [2] 115/3
115/25
I received [8] 12/7
54/10 78/12 83/21
103/8 104/10 134/3
135/13
referred [1] 136/23
I remember [3] 34/5
34/16 95/24
l represent [2]
164/22 200/16
I responded [1]
197/15
I said [5] 109/4
168/18 170/15 195/6
204/10
I saw [2] 196/16
206/21
I say [6] 20/3 24/3
87/12 97/1 103/22
176/6
I see [9] 49/19 93/19
93/19 95/25 115/25
119/21 131/19 172/9
173/19
I should [8] 1/9 9/24
43/1 62/20 69/14
84/17 97/15 154/24
I shouldn't [1] 83/17
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173/14 174/21 206/18)
I sit [4] 153/13
I sort [4] 23/20 41/9
87/11 111/12
I spoke [1] 14/9
I start [1] 2/25
I started [1] 121/1
I stepped [1] 3/11
I still [1] 99/25
I suggest [1] 173/20
I supported [1]
111/24
I suppose [14] 39/15
41/6 44/17 45/9 71/4
71/9 71/19 79/25
87/11 147/5 160/11
164/2 195/4 197/13
I suspect [6] 27/24
105/25 111/15 122/22)
142/14 193/6
I take [6] 47/15
122/10 128/25 166/17I
168/5 169/21
I think [207] 3/7 3/8
3/19 3/24 5/16 6/12
7/14 11/7 12/12 15/3
16/10 20/2 20/12
20/14 21/14 25/13
25/17 25/18 25/21
26/8 26/18 27/5 27/12I
29/20 30/24 31/2 31/4I
32/7 33/3 33/19 33/19
36/2 39/14 40/6 40/20
40/23 41/8 42/9 45/11
45/16 46/14 47/5
49/10 49/16 50/12
52/1 52/1 52/4 52/22
55/11 56/18 56/25
57/2 57/8 57/13 57/19
57/19 58/1 58/13
58/25 59/3 60/10
60/11 60/14 60/23
65/3 65/6 65/6 66/4
66/7 67/7 69/13 70/23
71/17 72/3 72/6 75/10}
75/25 76/9 76/12
76/19 77/5 79/18 81/9
81/18 82/4 82/13
82/25 84/17 86/20
87/6 87/7 87/20 90/9
91/11 93/2 93/7 93/7
93/8 93/12 93/12
93/23 94/10 95/4 95/5I
97/5 97/17 100/7
101/16 102/5 103/12
(68) I became - I think
I think... [96] 104/4
104/5 104/22 104/25
107/8 107/13 107/17
108/9 108/12 108/15
109/5 109/9 110/13
110/21 111/11 111/21
113/14 113/19 113/21
116/8 117/4 118/22
119/5 119/21 120/15
121/1 121/23 124/14
127/13 129/4 133/5
136/11 136/22 139/17)
141/22 142/6 142/12
142/22 143/6 143/12
143/15 143/16 145/20
146/8 146/20 147/20
151/3 151/8 152/24
153/5 153/7 153/24
154/11 154/16 155/8
156/8 156/10 159/10
159/20 160/2 160/7
162/10 165/8 165/11
165/14 165/15 167/2
168/17 169/13 170/9
170/13 170/15 174/18}
175/1 175/19 176/8
177/13 178/13 179/15}
182/19 183/23 183/24
184/19 189/21 192/25
195/3 197/7 199/20
203/18 206/16 207/14,
208/18 208/20 208/22
208/22 209/19
Ithink's [4] 142/8
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82/18 111/22 128/11
197/16
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58/5 71/3 72/7 80/4
83/3 104/10 127/16
128/10 199/17
I tried [4] 170/16
180/13 189/11 197/11
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166/25
l understand [12]
41/22 41/25 90/7
93/21 99/21 118/11
139/12 177/7 177/9
177/22 180/13 193/1
l understood [6]
77/19 78/10 80/25
87/7 115/8 125/9
luse [1] 191/24
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46/8 94/6 129/15
164/24 168/8 197/3
197/4 200/23 201/3
205/2 205/4 205/7
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55/12 80/24 135/11
204/19
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15/6 15/8 30/4 30/4
31/4 33/13 33/15
39/24 50/17 57/20
58/14 71/17 71/20
71/23 81/19 83/3
105/5 106/4 106/11
119/5 134/21 134/23
137/18 143/1 145/19
151/13 154/11 155/3
165/10 166/23 167/5
167/9 167/16 171/1
176/11 176/12 176/13)
180/3 181/17 203/12
208/21 208/22 208/22
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33/20 129/25 208/20
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110/6
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7/23 15/2 15/10 17/17
21/6 21/6 27/1 27/9
31/20 36/22 44/18
44/21 46/23 57/2
57/11 57/13 93/10
104/6 106/3 106/4
119/21 122/14 144/9
153/20 155/4 159/16
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179/17 191/20 206/22)
I wouldn't [2] 46/20
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47/20 90/14 104/22
130/2 151/12 168/7
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185/11 187/8 201/18
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I'm [156] 2/22 4/19
7/9 11/11 11/23 13/7
13/10 15/1 15/13 16/3
26/18 26/25 27/19
29/19 30/2 30/3 30/22
31/22 32/23 33/1
33/21 33/21 33/21
33/22 38/21 38/22
40/3 40/18 40/18
40/22 41/8 44/25
44/25 45/1 46/2 47/21
49/11 50/4 51/16 52/5
52/22 52/24 54/7 56/4
58/4 58/6 58/16 59/5
61/21 64/25 66/10
73/14 76/16 77/18
78/8 79/19 84/18
85/11 88/4 88/7 88/15)
88/16 89/2 90/9 91/18
93/4 95/3 95/24 96/21
99/15 99/21 100/7
100/7 100/10 100/15
104/9 109/1 111/25
112/10 115/1 116/24
121/12 121/23 123/11
124/21 125/22 125/22
128/10 128/19 134/8
134/18 138/19 138/24
142/1 143/8 143/17
143/20 143/23 144/6
144/12 147/6 150/20
154/12 155/5 162/12
165/24 169/1 170/9
171/2 171/11 171/25
172/5 173/19 174/11
174/19 175/22 176/2
176/6 176/17 176/22
178/5 178/24 179/1
181/18 183/24 185/14
185/20 187/5 187/6
188/9 191/20 192/25
193/4 193/6 194/6
194/14 194/16 194/16
194/19 194/24 195/18
198/13 198/15 200/19)
201/5 201/24 205/3
205/9 206/16 207/12
207/22 207/23 208/7
208/24 210/6 210/14
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71/8 75/10 78/9 79/11
80/22 80/23 82/21
90/12 98/5 105/17
110/13 110/14 131/24
138/4 141/9 145/9
145/17 153/12 162/14
172/12 175/4 175/10
175/16 177/7 177/9
181/2 183/24 188/22
203/18
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55/2 55/2 57/4
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54/23 108/9 172/7
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67/17 161/22 166/4
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56/16 56/22 57/16
58/9 59/17 73/10 88/5}
107/5 117/2 123/1
125/20 130/21 154/9
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58/9 59/17 88/5 107/5
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14/10 15/16 16/25
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21/9 21/9 21/17 22/22,
23/14 23/25 24/9
25/16 26/25 27/6 29/3
29/10 33/23 34/1
35/12 35/14 36/4
36/13 36/18 36/19
37/7 37/11 38/21
38/22 39/16 40/3 40/9)
40/12 40/23 44/13
44/21 47/12 48/6
48/10 50/9 50/21
50/22 53/2 54/7 56/21
57/6 57/23 58/21 59/2,
59/8 59/10 59/19
59/19 60/24 61/8
61/16 65/11 66/25
69/14 73/24 74/10
75/10 75/18 76/15
77/1 80/9 82/2 82/14
83/1 84/2 84/4 85/13
85/18 87/2 87/8 87/8
88/4 88/13 89/8 89/11
91/20 92/3 96/12
100/4 100/13 104/2
108/3 112/6 112/13
112/13 116/5 118/20
119/19 121/19 121/21
122/10 123/6 129/12
132/6 132/25 133/9
134/4 135/17 139/5
141/11 143/3 143/12
143/20 146/6 147/6
149/2 149/6 149/11
150/16 150/20 151/2
151/3 151/9 151/24
152/5 152/6 152/14
156/2 157/6 157/13
157/16 160/18 161/8
163/15 164/25 165/11
165/17 166/11 167/24,
168/15 169/4 171/13
171/14 173/25 175/1
175/8 176/8 178/9
178/19 181/3 181/10
181/19 182/11 183/18}
189/20 190/7 191/18
191/22 193/10 193/14)
194/11 197/13 201/7
201/22 202/7 202/21
202/23 203/5 203/7
203/15 203/23 203/24I
204/13 205/2 205/5
205/14 205/21 205/24
206/19 206/21 207/1
208/5 210/2 210/5
iii [1] 2/2
ill [2] 130/20 131/1
ill-advised [2] 130/20)
131/1
illogically [1] 74/23
illustration [1] 40/13
imagine [6] 99/6
104/15 154/5 159/16
170/17 181/11
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immediate [2] 14/6
165/16
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32/18 56/8 58/4 71/21
105/24 143/7
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impact [8] 65/11
76/13 124/17 149/19
152/10 168/12 180/10}
199/5
impacts [1] 199/11
impediments [1]
98/19
implemented [1]
49/3
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103/1
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implicates [2] 134/13)
135/1
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105/25
implications [1]
127/19
implied [2] 81/21
180/16
implying [1] 178/20
importance [4] 8/8
8/15 64/8 102/10
important [9] 4/20
12/9 20/24 21/4 39/6
76/17 76/18 104/5
206/9
impossible [2] 64/20
173/3
impression [3] 12/19
12/25 107/19
imprisoned [1]
178/12
imprisonment [1]
63/6
improper [2] 140/24
(69) I think... - improper
improper... [1]
142/19
improve [1] 5/13
improved [1] 175/20
impugned [2] 140/22
182/14
inaccuracies [1]
117/12
inadequate [2] 194/6
197/8
inadmissible [2]
145/12 148/8
inbox [1] 76/24
incapable [1] 99/13
inchoate [1] 119/4
include [7] 26/13
29/14 31/15 32/6
48/15 104/25 190/20
included [1] 112/15
includes [1] 149/18
including [10] 28/12
30/5 43/6 51/5 69/3
87/21 140/19 141/5
164/23 200/18
incoming [2] 11/4
20/1
incompetent [1]
128/7
incomplete [3] 69/24
71/7 156/23
inconsistent [1]
182/12
incorporated [1] 59/4)
incorrect [4] 57/6
69/23 71/6 117/7
incorrectly [2]
155/18 177/14
increasing [1] 5/2
incredibly [4] 4/11
4I17 163/14 163/14
incremental [1]
186/13
indeed [17] 2/19 3/23
15/2 17/25 22/5 23/6
28/3 29/16 55/20
79/15 89/12 118/23
127/6 137/12 137/18
150/23 153/13
independence [1]
112/19
independent [33]
14/14 18/11 18/13
28/5 28/13 28/19
36/25 39/5 39/6 39/7
43/20 44/16 46/9 47/2
51/19 56/14 58/19
68/19 79/4 94/8
112/17 179/4 192/9
192/11 192/13 192/22
193/2 193/8 193/14
194/23 195/24 196/8
196/14
independently [9]
35/15 50/24 58/12
72/21 98/12 137/17
192/6 192/20 193/11
indicate [1] 79/11
indicated [1] 62/17
individual [6] 19/23
53/1 68/20 141/16
178/13 188/1
individuals [4] 28/7
28/18 48/15 180/3
indubitably [1] 57/13
induction [1] 32/11
indulgence [1]
200/10
industry [3] 192/7
195/10 195/15
influence [1] 35/4
info [4] 22/1
inform [2] 90/1
126/16
information [28]
15/12 21/20 21/25
22/15 25/12 54/1 60/4
60/5 60/21 72/4 73/19)
84/20 84/25 85/22
91/14 91/15 101/25
102/8 103/20 107/4
107/6 110/2 110/16
113/17 113/18 117/13)
161/11 161/18
informed [5] 15/21
97/11 112/10 148/14
160/20
inherent [2] 141/15
154/14
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initial [11] 62/18 96/3
110/3 111/7 118/15
119/18 141/20 143/3
150/16 152/11 154/8
initially [2] 47/8
197/17
initiating [1] 102/21
injured [1] 148/2
innocent [1] 178/11
Innovation [1] 9/4
input [1] 21/2
inquiry [10] 1/18 12/7I
29/21 39/15 89/7 89/9
104/15 124/6 173/22
174/2
Inquiry's [1] 2/22
inserted [2] 2/6 23/1
inside [1] 99/17
insisted [1] 55/8
insofar [4] 72/14
72/21 73/4 84/13
instance [2] 68/1
125/6
instead [6] 41/19
49/9 88/2 138/15
170/11 181/12
instigate [1] 113/9
instigated [1] 102/19
instil [3] 35/12 36/17
36/19
instilling [1] 35/25
instinct [1] 33/24
institutional [1]
179/8
instruct [3] 47/17
72/18 72/24
instructed [2] 30/11
126/15
instructing [1] 72/11
instructions [12]
51/10 51/17 51/21
52/9 52/11 125/11
202/10 202/21
insurance [1] 131/24
integrity [6] 37/18
42/4 157/14 188/20
189/16 191/7
intending [1] 23/17
intention [6] 33/16
71/14 80/1 169/11
170/3 170/8
intentions [1] 129/15
interactions [1]
179/12
interchangeable [2]
183/8 183/16
interest [11] 7/1 19/4
63/21 79/25 83/19
90/12 101/18 108/7
108/17 108/22 125/18
interesting [8] 27/8
77/2 78/8 113/19
141/19 143/3 146/3
170/25
interests [6] 102/14
129/1 129/3 129/8
152/13 177/3
interim [2] 3/5 32/14
internal [2] 122/18
207/18
internally [1] 100/14
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42/14 148/2
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intervene [1] 28/19
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43/24 44/2
interview [1] 19/22
interviewed [1] 51/6
intimating [1] 140/19
into [49] 2/16 7/5
7/13 11/25 16/11
16/14 16/20 37/2 40/7I
42/15 56/10 57/17
59/4 59/14 61/25
64/17 64/21 66/6
66/11 67/22 77/3
79/15 84/22 87/25
104/13 105/3 110/15
111/16 113/6 115/5
47/6 47/7 47/12 49/15
118/7 124/18 132/4
132/23 133/20 139/6
147/3 163/8 168/12
169/14 169/16 178/25
181/8 184/12 186/25
187/19 191/10 193/3
197/6
introduced [4] 18/4
70/6 192/4 192/18
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48/11
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59/12
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investigate [3] 47/3
49/4 132/14
investigated [2]
18/13 39/13
investigating [3]
17/15 22/24 46/25
investigation [13]
17/25 23/5 28/5 38/1
43/9 43/21 44/16
59/22 65/24 74/24
108/5 132/17 180/2
investigations [9]
59/17 59/18 67/22
117/10 117/11 132/12}
132/25 133/2 133/13
investigator [1]
50/11
investigators [5]
28/13 56/14 58/20
62/18 67/22
Investments [1]
184/12
invite [1] 205/11
invited [1] 54/12
ites [1] 209/20
inviting [2] 143/38
143/24
involve [1] 13/13
involved [14] 45/22
47/16 57/23 64/1
81/14 116/13 147/8
153/6 153/8 155/4
171/24 177/1 181/25
184/22
involvement [3]
35/21 153/1 175/20
involves [1] 29/23
involving [5] 18/16
23/8 34/3 137/12
182/3
Ireland [1] 74/18
irregularity [1] 148/7
irrelevant [4] 136/13
136/17 137/8 137/23
irrespective [2]
100/3 103/18
irritating [1] 173/8
is [494]
is all [1] 193/25
isn't [16] 36/7 45/1
65/1 96/23 98/17
100/12 102/4 137/13
151/6 170/17 172/25
179/20 182/19 186/1
198/7 206/9
issue [40] 10/1 12/2
14/14 16/2 16/10
20/25 21/3 21/4 21/4
23/21 23/22 24/17
39/16 41/18 44/7
47/15 50/12 64/6 64/8)
65/10 70/11 70/15
70/21 71/19 74/11
74/13 83/1 95/22 96/9I
108/3 108/7 115/4
116/14 116/17 127/1
136/12 150/13 165/13}
167/25 200/23
issue' [1] 149/8
issued [2] 56/8
113/11
issues [90] 16/20
21/8 23/19 26/6 28/2
28/9 28/12 29/11
29/14 29/21 30/9
30/14 30/20 31/13
31/25 32/3 32/10
32/22 33/20 37/3
41/19 41/20 42/16
44/14 45/12 45/15
45/15 45/22 46/5
46/10 47/3 52/20
55/24 61/5 61/18
69/17 71/18 73/13
76/7 76/9 76/14 76/20
91/9 92/16 97/22
98/21 99/23 99/25
102/7 102/25 103/2
104/16 104/17 108/21
108/24 132/10 136/13)
137/14 137/24 139/25)
140/2 140/4 142/25
145/15 148/8 148/22
149/13 149/17 152/9
152/23 159/18 169/4
169/13 170/22 172/3
175/5 178/16 182/5
182/13 189/1 189/4
189/10 190/17 196/21
197/12 197/25 198/11
199/16 200/4 203/19
it [559]
it's [159] 2/20 4/12
4/13 4/14 4/16 4/16
4/20 5/14 5/16 5/24
5/25 6/4 6/5 9/5 11/7
11/9 14/24 17/3 20/2
20/3 22/16 23/15
24/18 26/2 26/3 27/8
29/19 29/25 31/19
34/20 35/6 35/20 36/2I
36/5 36/10 36/15
37/11 40/6 40/7 40/22
44/22 44/24 45/16
(70) improper... - it’s
I
it's... [116] 48/6
50/14 53/8 55/11
55/15 57/11 58/25
59/7 59/13 61/16
76/18 77/12 77/18
78/21 79/17 80/3 83/2
83/3 84/9 85/5 87/20
87/25 89/7 90/20
91/12 93/9 93/20 94/5
94/5 97/3 98/4 98/11
99/2 99/3 100/21
104/5 104/14 104/24
105/20 107/12 107/12)
107/13 107/17 111/21
113/20 113/22 113/25}
120/12 121/22 123/15}
123/24 127/22 128/19)
129/16 131/17 139/9
139/14 142/8 143/17
145/6 146/2 150/21
151/16 151/22 157/13}
160/4 160/15 162/13
162/13 166/8 166/9
166/12 166/13 167/23)
168/17 170/3 170/6
170/12 170/16 171/11
171/13 171/23 173/3
173/6 173/8 173/17
174/19 175/1 175/18
177/25 179/20 180/14}
181/21 182/4 182/22
185/10 185/13 186/5
187/15 188/10 188/15}
189/16 191/12 192/24}
193/7 193/24 195/21
201/10 201/20 201/24
203/11 205/2 205/3
205/5 205/7 206/11
italics [1] 49/25
iteration [1] 21/11
iterative [1] 117/25
its [44] 5/8 5/11 8/1
10/4 10/11 18/6 18/7
19/24 23/15 35/17
36/16 49/1 56/23 62/3,
63/17 65/10 65/24
70/8 74/16 77/9 98/19
101/5 101/23 102/14
103/6 103/18 108/7
108/21 117/10 117/25)
125/1 137/5 140/6
140/23 145/17 155/23}
155/24 155/25 170/7
172/13 172/13 198/8
207/16 209/2
itself [10] 5/1 22/22
53/20 59/4 59/5 93/15)
99/14 110/20 113/18
122/11
Jo
JA [1] 36/6
jail [4] 29/24
James [4] 35/7 35/9
35/24 133/16
Jane [38] 20/10
20/14 34/9 34/12
34/22 39/11 41/7 43/2
43/2 47/14 48/20
78/18 78/20 80/6
82/10 84/4 85/6 86/21
86/21 93/7 115/18
116/19 117/1 120/6
125/19 126/3 126/18
128/21 136/3 139/10
143/5 143/14 145/24
146/7 147/14 151/22
152/2 152/4
Jane's [1] 34/18
January [11] 60/18
60/19 85/5 106/14
106/19 107/23 109/16)
109/17 109/20 119/2
182/4
Jason [1] 1/17
Javid [1] 6/5
Jenkins [9] 32/19
32/24 33/4 156/21
157/19 157/21 157/25)
158/9 159/7
Jenkins’ [1] 158/12
JFSA [4] 113/8
180/16 190/1 199/14
Jo [1] 10/7
job [8] 16/11 16/14
29/18 33/25 47/11
95/11 121/21 121/22
jog [1] 5/21
joined [8] 10/24 15/9
22/11 27/19 32/8 41/7
137/18 177/10
joining [4] 17/4 21/3
32/17 47/10
Jonathan [30] 30/10
45/5 46/15 48/1 55/4
57/2 85/8 85/14 85/16)
86/4 86/22 86/25
101/2 101/7 101/21
106/21 109/23 111/25)
114/12 117/16 118/14)
119/22 120/21 120/24)
124/3 124/24 125/14
130/5 133/10 162/18
Jonathan's [1]
117/23
Josephine [2] 35/10
62/20
judge [31] 98/21
99/25 100/5 100/8
128/2 139/20 139/21
140/17 141/9 141/18
142/10 145/9 145/21
147/18 147/24 148/16)
149/4 149/13 149/16
149/20 149/24 150/17)
151/17 153/23 154/9
154/17 168/22 169/4
180/20 181/14 205/16
judge's [8] 140/11
141/6 141/23 152/10
152/19 153/9 153/11
155/10
judged [1] 208/5
judgement [9] 94/19
94/23 95/10 97/3 97/4
106/8 128/4 175/19
176/5
judgements [1]
175/19
judges [3] 151/4
151/13 154/13
judgment [15] 100/9
139/13 141/9 142/18
145/5 146/1 146/2
147/25 148/19 151/17]
152/23 170/22 172/3
182/6 182/13
judiciary [2] 153/18
154/15
July [7] 1/1 32/14
157/8 162/5 177/12
201/1 210/24
July 2013 [1] 32/14
jumped [2] 57/12
71/21
juncture [1] 147/6
June [7] 6/6 93/25
126/3 129/16 136/1
136/1 184/21
jury [4] 62/7
just [134] 4/9 6/10
7/4 8/10 8/12 13/10
15/19 16/10 17/7 20/7I
20/7 21/10 22/8 24/5
25/8 29/25 30/3 31/19
35/22 36/2 36/21
40/13 40/19 41/3
41/24 42/2 42/11 46/2
46/22 47/12 47/21
50/22 53/8 54/8 56/19)
56/19 58/15 58/17
59/8 59/10 59/19
61/21 66/10 66/12
67/9 69/15 70/13 75/8
75/18 77/9 80/9 83/2
85/12 85/23 88/25
91/4 94/7 95/10 99/2
99/4 100/18 103/16
103/25 104/22 105/5
105/15 106/17 107/21
108/16 108/19 109/3
109/4 109/21 112/14
116/1 120/22 123/15
123/23 123/24 124/9
125/22 126/4 129/23
131/12 135/17 135/17
137/13 138/12 139/5
141/25 142/1 152/20
155/1 155/20 156/10
157/6 157/16 160/10
161/25 162/25 163/11
163/22 164/14 167/6
170/17 171/8 171/14
171/18 172/11 172/16}
173/3 174/18 175/25
176/10 176/23 179/14}
181/3 183/3 188/9
189/22 192/25 193/4
193/22 195/2 201/3
201/5 201/16 202/11
205/3 205/8 206/25
207/24 208/18 208/21
justice [9] 28/9 29/15
32/6 48/17 127/2
148/10 150/13 168/11
181/23
justification [1] 9/17
justificatory [2]
138/10 138/12
K
KBW [1] 109/23
KC [2] 196/24 201/1
keep [8] 7/18 10/12
19/8 40/19 49/11
104/18 180/10 180/11
keeping [2] 8/7 8/14
Kelly [3] 152/1
152/18 153/1
Ken [6] 94/8 94/18
95/6 96/1 96/5 147/6
key [9] 10/8 10/20
11/9 37/8 50/11 91/19)
105/22 144/24 148/19}
killed [1] 168/16
kind [27] 5/6 19/25
36/13 39/16 39/25
41/2 41/9 47/19 60/15
80/24 85/2 87/21
88/25 89/1 107/4
107/12 107/19 121/10
127/13 132/24 138/9
143/24 147/2 150/23
151/2 155/15 208/14
kindly [1] 1/21
King [4] 63/22 63/23
64/12 157/9
Kingdon [1] 147/24
knell [1] 191/19
knew [6] 80/2 93/11
142/25 207/18 207/20}
208/2
Knight [7] 30/11 45/6
46/18 53/20 60/22
106/21 109/23
knit [2] 81/22 81/22
know [240]
knowing [2] 44/17
174/12
knowledge [9] 2/18
10/15 30/7 40/25
88/21 125/17 131/8
131/11 131/12
known [9] 15/2 64/24)
70/9 92/25 122/10
157/25 159/20 160/6
203/5
knows [1] 205/9
knuckles [1] 141/18
L
lack [4] 10/15 75/3
82/19 165/15
lacked [1] 39/9
laid [1] 37/6
Lambert [1] 152/2
landed [2] 76/24
194/1
language [5] 65/1
76/16 76/18 107/14
171/13
large [3] 99/1 139/1
184/6
largely [3] 22/24
178/16 191/4
larger [1] 186/23
last [16] 2/13 17/14
22/23 24/11 25/3
27/23 106/24 112/13
126/5 134/12 135/1
139/13 147/23 156/19)
157/6 167/13
lastly [3] 109/12
159/1 161/8
late [7] 14/16 25/13
159/23 159/24 167/7
168/6 182/17
later [17] 12/21 15/17I
21/10 33/6 54/18
55/21 91/5 93/24 94/3
97/10 107/22 123/24
140/8 143/16 156/25
162/3 184/11
Laura [3] 6/1 15/17
107/24
law [6] 67/3 140/3
148/3 148/4 155/17
155/23
lawyer [10] 21/13
29/19 45/7 45/21 46/3}
46/23 46/24 104/9
127/18 205/19
lawyers [21] 18/15
21/21 47/16 128/22
130/22 131/13 134/22)
135/4 156/11 156/14
159/2 169/25 170/7
170/10 182/3 183/6
183/7 183/11 183/14
183/16 183/17
layer [1] 160/20
lead [3] 9/16 10/4
36/9
leadership [1]
102/18
Leading [3] 51/2
52/10 52/16
leads [1] 143/9
(71) it's... - leads
L
learn [1] 32/22
learning [1] 199/9
learnt [1] 54/18
least [16] 43/12 59/6
69/8 74/21 74/24
88/15 121/16 147/8
148/22 148/24 149/7
152/22 154/4 158/11
184/9 209/24
leave [1] 159/4
led [4] 17/22 19/12
45/7 97/13
left [9] 9/10 9/24 10/2
172/18 172/20 181/3
195/22 205/12 205/13
left-hand [3] 9/10
9/24 10/2
Legacy [4] 73/8
73/14 98/10 181/14
legal [59] 29/21
33/21 34/9 45/15
45/18 45/24 46/5
46/11 47/4 60/3 60/20
63/11 66/17 71/10
73/17 77/16 79/23
80/19 81/12 81/14
81/20 82/19 84/13
84/18 85/19 87/3
87/10 87/23 88/21
88/25 89/7 89/11 90/4
94/19 96/3 96/18
101/11 102/7 104/10
110/7 110/9 110/12
116/14 116/17 127/16}
130/4 131/24 134/7
135/3 137/7 140/1
140/13 156/14 169/13
177/18 183/9 203/25
209/14 209/21
legally [17] 77/4 77/8
77/20 77/23 78/5
78/11 79/21 80/2
80/11 81/1 81/7 81/12
82/23 88/1 88/5 88/8
91/14
Leighton's [1]
175/23
length [4] 13/7 19/11
19/19 113/15
lengths [1] 18/10
lens [2] 167/17
167/18
less [7] 57/1 64/22
66/4 72/2 122/22
132/16 186/22
let [6] 14/2 104/4
126/20 131/21 172/6
191/22
let's [23] 5/21 22/10
57/14 58/7 58/7 59/5
71/1 71/1 71/12 71/12
72/8 76/19 107/21
122/16 136/3 187/17
188/10 189/19 190/8
192/8 197/2 201/22
201/22
letter [41] 16/15
16/18 16/19 27/17
29/10 29/17 33/10
34/21 37/2 37/6 37/23)
38/10 42/3 42/10
42/13 48/12 49/7
49/24 54/1 91/24
100/21 103/8 103/22
109/14 110/19 110/20)
110/22 111/2 112/15
113/11 113/15 113/20)
124/2 124/13 124/13
166/3 166/6 171/21
171/22 174/7 177/17
letters [4] 5/3 170/21
172/2 177/19
level [3] 151/23
152/4 153/1
levelled [1] 140/21
levels [1] 172/25
liability [4] 166/1
173/16 181/24 185/21
liable [1] 172/5
licences [1] 5/6
lifetime [4] 72/20
73/3 73/6 73/12
light [7] 25/9 53/25
76/7 125/3 126/12
199/19 199/19
like [40] 9/20 13/4
14/6 15/22 17/1 20/22
23/11 25/22 33/23
44/5 51/18 52/3 59/2
86/24 89/1 89/9
104/22 124/15 133/25)
134/17 141/15 142/22)
143/8 153/18 162/14
162/21 163/4 165/17
171/5 174/1 177/5
179/21 185/10 187/8
193/7 198/2 199/13
199/23 201/18 203/24)
likelihood [1] 75/16
likely [19] 38/9 40/7
44/2 54/15 54/16
54/22 56/11 56/23
69/5 72/2 72/2 76/25
149/16 152/12 154/10)
154/22 201/10 201/17,
201/20
limit [2] 118/15
119/14
limitations [3] 85/15
85/17 87/1
limited [14] 4/7 9/2
21/15 37/17 65/25
88/18 106/24 107/11
107/18 117/11 157/15)
158/14 161/21 198/14)
line [2] 65/20 166/13
lines [5] 59/20 60/2
87/17 124/6 155/9
linked [4] 44/14
list [6] 25/16 25/18
27/12 118/25 146/8
160/16
listen [1] 55/12
listened [1] 57/2
listening [1] 58/16
literally [1] 73/7
litigation [52] 33/6
65/19 77/13 94/1
97/11 97/14 97/16
97/19 99/18 99/21
116/21 122/22 124/7
124/10 125/3 125/7
126/6 126/12 126/15
127/11 129/2 129/19
129/21 129/23 132/11
132/13 133/3 133/7
133/8 135/20 136/12
138/22 140/21 141/17
143/11 144/2 144/14
144/18 144/22 146/23
152/21 154/1 156/3
159/22 160/11 169/14
169/22 181/8 183/10
185/22 188/15 207/6
little [29] 21/10 40/1
40/17 40/17 42/18
46/2 50/17 52/5 59/8
59/11 71/17 84/19
104/5 105/15 111/11
121/10 127/14 134/17)
134/18 149/4 151/13
164/15 174/12 184/18I
187/7 189/22 195/22
201/3 203/12
logic [2] 138/10
138/13
logical [2] 35/17
37/25
logs [3] 68/12 68/17
72/13
long [10] 1/22 59/7
98/9 99/4 104/13
127/4 182/5 195/14
199/23 200/8
longer [7] 9/15 55/7
55/8 55/15 117/12
173/17 174/11
look [96] 5/21 5/22
9/1 13/2 14/14 15/22
16/5 16/12 16/19 20/7
22/10 22/22 24/23
24/24 25/1 25/16
26/10 26/12 26/15
29/6 37/2 41/18 41/19
42/3 42/15 44/18 47/6
49/10 49/18 50/9
50/14 50/19 50/21
52/2 59/5 59/8 59/20
61/10 65/9 68/2 69/4
71/22 80/22 83/14
83/14 85/4 85/12 91/4
92/1 94/2 101/5
106/11 107/21 108/3
109/13 116/18 117/5
123/9 123/22 127/23
139/5 139/8 143/7
147/12 147/13 152/6
157/4 157/16 160/12
161/8 162/19 162/21
167/16 167/18 170/3
176/9 181/9 182/17
182/21 186/25 188/23
189/19 196/21 197/3
197/11 197/20 200/22)
200/24 201/3 203/7
203/8 204/22 205/2
205/5 205/7 206/23
looked [22] 23/20
24/18 25/1 25/5 25/17,
36/24 49/17 50/16
71/8 113/6 126/4
148/21 151/5 160/3
180/5 187/7 193/13
193/23 203/20 204/7
204/10 208/21
looking [44] 10/25
12/19 13/9 13/10
24/21 25/21 30/22
36/3 45/13 45/19 49/6)
49/18 51/9 52/22
67/23 68/12 72/9
77/18 87/7 90/13
91/10 95/8 103/20
104/16 104/17 109/15]
115/2 123/7 123/24
123/25 130/17 130/21
131/5 131/13 131/18
132/3 139/8 147/13
161/20 178/1 188/22
199/23 204/14 209/9
looks [10] 17/1 86/24
99/7 126/22 134/16
138/18 141/14 143/8
183/6 193/7
Lord [6] 61/13 62/13
147/22 148/17 150/6
150/11
Lord Arbuthnot [1]
61/13
Lord Grabiner [1]
150/6
Lord Neuberger [1]
147/22
lose [1] 113/18
losing [1] 4/23
loss [8] 19/6 85/19
87/3 87/10 87/19 90/5
117/8 154/2
losses [7] 17/21 23/3
24/11 62/4 67/13
205/24 206/4
lost [3] 140/13 169/2
169/21
lot [35] 12/13 25/14
33/19 33/22 39/15
40/8 46/19 49/12 50/8I
53/3 57/3 58/16 59/3
65/18 88/7 97/21 98/3
98/20 99/23 104/19
104/20 106/5 138/24
160/3 160/6 162/25
171/23 175/25 176/1
180/4 180/18 183/22
194/11 206/12 206/13
love [4] 174/18
174/21 182/24 185/11
low [1] 53/2
lunch [3] 11/17 11/21
109/12
Lyons [5] 13/21
15/18 20/10 22/12
22119
M035 [1] 62/16
MacLeod [37] 20/11
34/9 34/12 34/23
39/11 41/7 47/14
48/20 78/18 78/20
80/6 81/15 82/10 83/8
84/4 85/6 86/21 86/21
93/7 110/20 115/18
116/19 117/1 120/7
124/1 124/23 125/20
126/3 126/18 128/21
136/3 139/10 143/5
145/24 147/14 151/22)
152/2
MacLeod's [3] 43/2
83/22 152/4
made [62] 5/17 12/21
18/18 19/14 22/24
26/9 26/10 26/12
30/15 42/5 48/25 53/2
56/7 57/4 73/24 73/24
76/8 80/14 86/4 86/19I
87/5 87/25 94/18
94/22 95/9 97/4
101/20 106/8 108/1
108/22 109/25 111/9
112/8 112/12 113/5
114/12 117/15 118/2
119/8 130/7 130/12
141/3 142/18 143/13
143/23 148/6 150/24
151/17 152/16 153/9
159/6 161/3 172/25
173/7 178/6 182/11
186/1 190/12 190/15
194/20 200/3 202/10
magic [4] 130/18
130/23 131/3 131/4
Mail [2] 5/1 5/1
main [6] 23/19
107/25 111/15 125/19)
136/22 191/25
maintain [1] 37/20
Majesty's [2] 3/25
(72) learn - Majesty's
Majesty's... [1] 3/25
majority [2] 18/4
43/25
make [30] 8/21 12/2
12/5 20/17 26/18
28/21 43/22 45/2 45/7
76/21 79/24 87/16
104/14 123/6 152/15
154/24 155/24 156/7
156/9 156/15 165/10
166/22 166/23 166/24
167/9 170/16 173/6
180/4 181/17 183/13
makes [7] 4/10 21/15
38/23 105/3 105/16
136/12 146/22
making [19] 19/5
93/21 94/15 95/24
134/13 140/23 154/21
154/23 159/19 163/25)
171/1 177/9 177/22
180/13 180/20 194/16
199/13 207/22 210/12)
man [4] 26/24 27/7
27/13 32/19
manage [2] 7/25
146/24
managed [5] 99/22
100/14 144/17 155/18
168/19
management [13]
5/12 9/3 10/17 19/16
38/15 58/20 139/19
141/13 142/1 142/2
146/23 190/20 191/8
managing [5] 50/25
139/20 139/21 140/11
140/17
manner [3] 37/19
97/18 168/20
manual [1] 118/13
many [25] 17/18
17/23 24/11 24/12
24/15 24/25 25/15
107/18 143/17 151/1
165/11 165/12 165/17)
165/21 167/6 167/12
167/19 168/2 168/2
170/17 170/18 171/3
175/6 194/7 195/4
March [7] 63/2
100/25 109/15 142/6
147/11 147/14 151/22)
marionettes [3]
134/17 183/12 183/18
Mark [9] 17/7 20/10
26/24 26/25 27/13
31/15 34/13 120/8
179/2
marked [1] 77/10
market [2] 5/2 5/3
marks [1] 26/1
material [10] 21/18
38/8 65/19 78/23
139/1 157/25 158/12
158/20 159/3 182/11
materially [1] 118/10
materials [1] 51/5
matter [22] 15/24
29/3 39/8 39/12 46/10
54/14 57/16 62/14
63/10 63/12 126/13
127/16 155/23 159/23)
159/24 173/10 173/17)
173/18 177/18 200/5
206/20 206/22
matters [19] 38/2
42/24 59/21 60/1
76/12 76/17 76/20
112/21 113/3 127/9
140/5 140/7 146/25
153/25 157/10 179/16)
196/5 199/1 207/2
maximum [1] 63/5
may [37] 1/5 17/21
26/12 28/8 39/12
53/21 75/17 77/22
87/18 89/19 89/20
93/24 97/13 103/22
113/1 113/1 113/2
116/19 117/7 119/3
123/6 123/25 123/25
124/16 133/16 139/5
144/4 156/22 159/4
173/24 185/8 186/6
189/20 191/3 191/4
199/5 199/10
maybe [9] 15/7 98/19
105/25 166/23 186/7
194/2 194/2 197/4
203/15
McCall [6] 79/4 94/8
94/18 95/6 96/1 147/6
McCall's [1] 96/5
McCormack [3]
161/10 176/20 177/5
me [76] 8/25 12/6
14/2 16/10 20/15
23/20 26/10 27/9 28/4
31/19 36/10 37/2
41/11 41/25 44/17
47/24 49/14 50/4
54/12 60/13 65/8
73/16 79/20 82/22
82/23 88/15 88/24
95/3 95/7 104/4 105/8)
106/2 108/19 111/13
115/20 121/8 121/12
121/16 121/21 125/6
125/22 129/9 129/9
130/2 132/1 138/5
143/9 143/24 159/12
161/15 167/2 167/12
168/19 169/17 169/19)
170/5 170/6 173/12
174/9 174/12 177/5
177/15 177/20 178/7
185/11 191/22 193/5
196/18 200/20 201/6
205/5 205/15 206/12
206/15 208/19 208/21
mean [83] 7/19 10/25
12/15 12/21 15/1
15/13 16/8 16/9 20/3
22/7 27/3 27/8 29/19
29/25 30/25 31/7
31/17 32/25 32/25
33/1 33/1 36/2 36/4
38/22 40/9 40/24 42/9
49/16 49/24 50/21
52/1 52/5 58/13 58/19
60/10 71/8 73/7 79/24
80/21 82/5 87/13
88/25 107/14 108/14
109/1 110/11 111/11
116/24 119/12 119/22)
122/14 131/3 134/15
136/22 143/20 147/8
155/12 155/22 156/2
157/18 159/8 159/10
159/11 159/15 159/18!
159/19 161/8 163/21
165/19 169/9 172/5
173/7 173/24 174/15
178/17 181/9 183/18
193/11 193/12 193/13}
201/18 206/11 206/11
meaningful [3] 151/3
151/4 177/1
means [13] 15/3 15/4
22/1 31/1 31/7 40/20
125/19 147/3 153/12
157/18 175/14 182/22
195/1
meant [7] 55/22
81/12 82/20 82/22
123/20 187/12 200/5
mechanism [1] 84/20
media [4] 19/12
19/14 43/21 190/15
mediation [7] 18/12
28/12 44/1 44/3 167/3
168/4 196/2
mediator [1] 137/13
mediators [1] 18/13
medicine [1] 23/9
medium [1] 4/10
medium-sized [1]
4/10
meet [10] 15/24 19/3
43/9 43/11 43/15
54/20 54/23 96/11
112/19 126/20
meeting [48] 6/16
14/15 34/23 35/2
43/23 44/10 44/23
52/11 52/13 52/16
54/4 54/7 54/19 55/7
55/15 55/17 55/20
56/13 56/19 56/21
58/3 58/5 58/9 58/14
68/25 79/5 84/1 84/6
85/9 86/20 91/17 92/4,
92/7 94/3 102/13
106/14 107/23 109/16
109/16 109/20 152/17}
160/13 160/15 161/3
161/24 162/2 176/13
182/19
meetings [7] 52/7
84/5 100/18 117/21
125/21 163/3 176/15
meets [2] 192/6
195/10
member [9] 39/17
48/7 84/21 129/23
144/2 144/23 144/24
147/7 152/21
members [11] 10/22
82/2 82/12 82/16
83/16 83/17 94/12
146/18 147/9 163/8
198/9
memory [11] 5/21
16/17 46/18 48/7
55/10 56/1 146/22
201/5 201/7 204/16
207/1
mention [8] 14/3
26/20 27/24 121/11
162/5 162/22 166/4
203/11
mentioned [9] 15/25
27/17 50/18 65/3
102/2 150/21 161/16
161/23 197/14
merit [1] 137/17
message [1] 131/1
messages [1] 136/10
messaging [2] 136/5
136/7
Messrs [1] 60/21
Messrs Swift [1]
60/21
met [12] 6/15 11/17
52/6 54/6 55/3 61/13
79/3 126/5 129/21
135/19 208/23 209/2
method [2] 38/1
111/5
mid [1] 119/3
mid-May [1] 119/3
middle [1] 124/14
might [54] 12/6 16/9
17/20 17/23 23/14
24/21 26/1 26/9 27/14,
35/23 36/14 39/8
41/23 42/9 64/23
65/23 67/24 68/22
83/6 95/20 95/23
97/23 98/5 99/23
107/16 108/7 108/17
121/15 122/3 129/1
129/2 137/19 138/12
138/13 151/5 160/5
163/10 167/7 167/14
169/6 177/24 178/18
179/17 180/18 184/22)
194/1 197/8 197/15
198/1 199/21 200/22
204/15 205/21 206/3
milked [1] 165/3
million [10] 18/2
23/24 184/23 185/1
185/7 185/11 185/17
186/21 192/2 192/16
millions [2] 23/25
25/2
mind [16] 45/21 46/9
57/20 83/18 89/3
89/16 95/13 95/20
97/22 98/5 104/23
123/15 137/11 177/11
191/2 207/24
minded [2] 41/1
148/13
mindful [1] 69/5
minds [3] 137/14
137/25 138/14
mindset [6] 57/8 58/1
172/19 172/21 173/5
173/20
minimum [3] 105/2
105/6 209/23
minister [34] 6/13
6/16 15/19 15/21
15/25 16/4 43/5 43/11
43/17 43/19 44/9
44/20 44/23 51/8
51/13 84/15 85/13
85/16 86/1 86/15
86/17 86/23 87/12
90/1 90/10 90/15
91/24 92/10 101/19
107/21 126/16 130/12)
135/15 153/7
Minister's [4] 42/3
42/10 42/13 87/21
ministers [6] 8/8
8/15 92/5 92/8 96/11
110/15
minute [5] 71/11
80/16 198/18 203/16
204/14
minutes [11] 84/10
160/12 161/14 161/16)
161/23 161/24 162/2
164/18 164/18 164/19)
181/2
miscarriages [6]
28/9 29/15 32/6 48/17
127/2 181/23
misgivings [1]
170/15
misjudgement [1]
104/7
misleading [1] 75/13
Misra [4] 62/7 164/23
(73) Majesty's... - Misra
Misra... [2] 178/18
182/8
miss [1] 55/16
missed [2] 75/10
84/6
mistake [1] 101/21
mistakes [3] 19/5
178/6 194/20
mistresses [1] 184/7
mixture [2] 46/23
179/11
mm [67] 6/7 6/9 6/14
7/10 7/10 9/8 9/8 9/8
9/14 17/5 17/11 21/12
22/18 22/21 23/13
28/1 30/17 32/1 34/7
34/25 34/25 36/2
41/14 44/8 51/14
51/20 54/3 54/3 61/20
61/20 62/21 62/21
91/8 107/8 112/5
113/13 127/6 130/24
139/4 139/4 156/1
156/24 157/1 157/3
157/3 157/12 160/17
161/1 161/1 161/4
162/7 164/16 166/23
176/21 181/16 184/17)
184/17 184/24 185/6
187/14 187/14 191/5
198/6 198/6 201/12
209/4 209/4
mm-hm [14] 6/7 6/9
6/14 34/25 34/25 91/8
113/13 127/6 161/1
161/1 161/4 162/7
164/16 184/24
mobile [1] 44/6
moment [14] 13/10
16/21 70/25 85/11
89/19 89/21 92/1 93/6
108/2 123/5 146/13
181/22 188/10 192/21
Monday [2] 139/15
152/9
money [13] 4/23 4/23
18/23 19/7 74/21 99/1
173/15 173/15 173/17,
180/17 185/23 186/17)
204/25
month [3] 27/23
105/12 123/24
months [9] 6/8 12/1
14/22 15/9 19/15
22/11 65/20 163/16
190/16
months’ [1] 60/14
more [44] 6/21 7/2
8/21 11/21 11/23 14/6
24/14 45/7 47/2 55/9
56/4 57/1 57/14 61/16
61/24 62/3 66/4 69/5
69/8 76/25 77/25
84/19 87/15 92/18
92/19 95/13 95/17
127/24 132/17 142/11
149/20 150/1 168/20
171/9 179/16 180/9
181/6 188/4 197/2
197/5 198/9 198/17
198/18 210/8
Moreover [1] 64/19
morning [11] 1/3
1/15 1/16 43/13 53/9
53/16 90/20 111/22
116/15 161/13 202/19)
most [17] 2/8 20/24
21/4 39/21 50/11 60/4
60/21 73/13 118/11
140/7 148/10 154/12
154/13 154/16 169/19)
177/11 189/1
motive [1] 83/14
motives [3] 121/14
129/6 134/22
mount [2] 99/20
180/17
mouth [1] 186/25
move [17] 13/9 16/25
33/12 40/17 40/23
42/18 52/8 53/19
100/16 103/23 106/11
123/22 129/12 135/16)
147/11 168/8 186/15
moved [5] 5/7 58/17
66/7 66/8 195/8
moving [2] 33/11
170/19
MP [2] 152/14 152/18
MPs [6] 15/24 19/10
28/3 28/7 48/15 190/5
MR [119] 1/8 1/9 1/15
8/12 27/17 32/24
40/20 46/2 47/18
51/18 52/2 52/19
53/19 53/20 53/20
54/8 54/20 55/3 55/5
55/8 55/19 55/21
55/23 55/23 57/6
57/17 57/21 58/1
61/14 66/9 76/11 79/1
79/4 88/11 89/25 91/4
97/22 100/17 105/5
108/2 110/21 111/20
114/11 119/8 125/6
125/11 128/21 130/22)
132/9 148/10 150/13
157/19 157/21 157/25)
158/9 158/12 162/14
164/18 164/18 164/21
164/22 168/11 170/3
170/19 170/22 174/9
174/14 174/18 175/1
175/23 176/7 176/17
176/20 177/5 177/23
181/1 181/4 182/6
182/7 184/3 184/4
184/5 184/10 184/19
186/20 187/7 187/10
191/12 193/18 194/16
196/18 196/22 197/24I
198/7 198/17 199/9
200/16 200/25 201/11
201/25 202/9 202/19
202/21 203/23 204/2
205/3 206/10 207/24
208/5 208/5 208/14
208/24 210/7 210/10
210/12 210/18 211/4
211/6 211/8
Mr Altman [5] 200/25
201/11 202/9 208/5
208/14
Mr Altman's [1]
202/21
Mr Beer [8] 181/4
187/7 187/10 191/12
196/18 202/19 210/10
210/18
Mr Cooper [1] 182/7
Mr de Garr [2]
125/11 130/22
Mr Henderson [1]
55/21
Mr Henry [8] 164/18
170/3 174/9 174/18
175/1 176/7 177/23
184/3
Mr Jenkins [3] 32/24
157/19 158/9
Mr Justice [2] 150/13
168/11
Mr Justice Fraser [1]
148/10
Mr Knight [1] 53/20
Mr Leighton's [1]
175/23
Mr McCall [1] 79/4
Mr McCormack [1]
177/5
Mr Parker [40] 1/9
1/15 8/12 27/17 40/20}
46/2 53/19 54/20 55/8
55/23 76/11 88/11
89/25 91/4 100/17
105/5 108/2 114/11
164/22 170/19 170/22
174/14 176/17 181/1
182/6 184/5 193/18
194/16 197/24 198/7
199/9 200/16 201/25
203/23 205/3 206/10
207/24 208/24 210/7
210/12
Mr Parker's [2] 55/3
79/1
Mr Parson's [1]
132/9
Mr Seller [1] 61/14
Mr Stein [4] 164/18
184/4 198/17 211/8
Mr Swannell [1]
184/19
Mr Swannell's [1]
186/20
Mr Swift [19] 47/18
51/18 52/2 52/19
53/20 55/5 55/23
57/17 57/21 58/1
97/22 110/21 111/20
119/8 125/6 128/21
196/22 204/2 208/5
Mr Swift's [1] 66/9
Mr Tim [1] 176/20
Mr Warmington [3]
54/8 55/19 57/6
Mrs [8] 164/24
173/21 174/3 200/19
204/20 204/23 205/18
205/24
Mrs Adedayo's [2]
173/21 174/3
Mrs Hamilton [4]
200/19 204/20 205/18,
205/24
Mrs Hamilton's [1]
204/23
Mrs Oyeteju [1]
164/24
Ms [18] 9/25 13/23
61/15 61/15 61/15
81/15 83/8 83/22
106/15 110/20 124/1
124/23 164/19 164/22)
200/13 200/14 210/9
211/10
Ms Alexander [1]
61/15
Ms Dickinson [1]
61/15
Ms Hailstones [1]
61/15
Ms MacLeod [5]
81/15 83/8 110/20
124/1 124/23
Ms MacLeod's [1]
83/22
Ms Page [1] 164/22
Ms Patrick [3]
164/19 200/13 210/9
Ms Vennells [3] 9/25
13/23 106/15
much [25] 1/4 2/13
2/20 12/20 31/5 53/11
53/18 71/16 107/19
114/3 114/10 133/2
138/19 143/16 156/9
156/18 156/25 161/6
164/3 164/8 168/9
170/11 173/14 174/21
195/21
mull [1] 14/17
multiple [2] 149/25
175/11
Munby [2] 91/12
100/21
must [15] 29/17
31/18 63/21 63/25
90/13 108/15 124/12
152/13 152/15 157/23)
159/10 169/9 176/4
188/18 196/6
my [115] 1/17 1/20
12/15 12/19 12/22
12/23 13/3 23/14
23/18 25/25 30/12
30/18 33/2 33/24 35/1
36/2 37/3 39/20 39/25]
50/12 52/23 53/1
56/18 57/8 57/11
57/23 58/1 65/17
70/23 71/9 71/13
71/16 76/11 77/14
77/25 78/10 78/25
79/3 79/12 79/20 80/4I
80/13 81/5 82/5 82/13)
83/11 83/15 83/17
83/24 84/7 87/20
88/20 89/16 89/23
96/21 97/15 97/22
98/5 98/14 98/25
100/11 110/3 110/4
111/6 111/7 111/8
111/12 111/13 112/2
113/19 116/10 116/20)
121/24 128/20 131/8
131/12 131/25 132/9
134/11 134/18 134/25)
137/11 137/19 137/22!
141/13 146/12 151/12)
151/23 153/12 156/13}
159/10 162/23 164/3
165/25 169/7 169/10
170/3 170/8 172/9
172/15 173/13 174/8
174/24 182/17 184/5
186/7 186/25 189/3
190/7 194/23 194/25
195/17 197/3 200/16
206/14
myself [10] 38/25
44/18 135/10 144/10
1447/5 154/25 170/4
172/24 197/3 198/14
naive [3] 50/17 82/6
169/10
naively [1] 39/20
name [10] 1/17 1/18
1/20 13/22 26/25 34/5)
34/14 169/24 184/5
200/16
named [1] 74/17
namely [4] 12/2
61/18 139/7 142/18
narrative [2] 23/16
42/19
(74) Misra... - narrative
N
narrow [1] 129/1
narrowed [2] 202/24
203/3
narrowing [1] 202/20
National [2] 3/18
198/7
nature [7] 30/7 51/7
51/12 63/7 117/25
118/7 182/15
NBSC [1] 75/13
nearly [1] 22/11
necessarily [6] 65/7
65/13 68/10 97/17
113/23 198/3
necessary [7] 29/4
61/5 68/12 112/18
117/22 139/23 153/7
necessary’ [1] 48/14
need [27] 6/21 7/22
13/2 20/19 33/12 38/9)
50/23 70/7 78/20
86/16 102/9 108/23
111/4 112/23 118/2
122/24 126/16 132/13)
132/14 137/15 146/25}
150/10 152/14 153/22
165/21 196/14 201/6
needed [13] 7/18
12/16 76/9 88/9 99/10
103/2 128/16 155/19
163/21 172/16 176/8
186/9 196/21
needing [2] 138/16
187/23
needs [3] 7/5 41/2
104/20
nefarious [1] 128/8
negative [5] 12/11
15/5 141/10 141/18
199/11
negatively [1] 199/6
negotiation [1] 38/4
neither [3] 92/22
135/5 182/25
network [6] 4/12 8/7
8/14 10/13 28/22 29/8
Neuberger [3]
147/22 150/12 155/7
Neuberger's [1]
148/17
never [10] 27/11
45/21 95/13 99/20
103/2 139/24 166/11
166/18 173/7 207/24
Nevertheless [2]
101/17 141/4
Neville [28] 6/11 14/2
14/8 14/12 16/5 16/18
27/18 36/1 38/4 44/15
48/12 49/8 49/24
53/25 54/18 54/24
85/9 90/1 92/10 101/3
107/24 108/8 109/14
109/17 125/17 130/8
133/16 136/11
Neville-Rolfe [26]
6/11 14/2 14/8 14/12
16/5 16/18 27/18 36/1
38/4 44/15 48/12 49/8)
49/24 54/18 54/24
85/9 90/1 92/10
107/24 108/8 109/14
109/17 125/17 130/8
133/16 136/11
Neville-Rolfe's [2]
53/25 101/3
new [19] 10/16 14/13
15/6 20/19 27/10
29/18 41/10 54/11
70/3 102/18 118/3
137/21 149/13 153/2
153/4 161/12 163/24
163/25 172/17
next [10] 13/3 34/23
55/16 101/24 112/16
125/12 150/8 184/19
210/17 210/20
Nick [3] 102/18
172/24 173/13
night [1] 126/5
nine [7] 11/1 30/22
52/22 56/4 95/8 95/15
107/13
nitty [4] 198/4
nitty-gritty [1] 1938/4
no [106] 9/15 14/23
15/1 15/13 17/24
18/17 27/2 30/14
30/19 31/11 31/13
31/25 32/21 40/25
41/22 55/11 56/5
58/25 68/1 68/7 70/16
74/3 76/12 76/19
T7114 77/11 777
78/20 80/1 80/23
83/18 83/18 85/17
86/25 87/7 88/14 89/5
89/23 90/11 90/12
90/16 90/18 92/15
95/11 95/14 97/9
100/7 104/12 108/6
108/9 108/21 109/7
113/11 115/13 116/13)
117/12 117/14 119/9
121/16 122/20 128/5
131/4 131/12 131/16
131/23 132/5 132/24
132/24 133/5 133/22
135/7 136/8 136/19
137/10 138/11 153/12)
158/24 161/5 161/7
171/16 171/16 173/10}
173/17 174/11 176/15)
179/5 181/9 187/3
192/10 192/24 192/25)
193/7 193/7 193/8
193/15 193/21 193/23}
195/17 200/5 200/10
201/20 204/18 206/1
207/4 207/25 210/8
nobody [3] 95/11
208/4 208/13
nodded [1] 103/15
noise [1] 199/14
non [5] 3/12 12/21
33/24 43/25 69/3
non-commercial [1]
33/24
non-criminal [1]
43/25
Non-Exec [1] 3/12
non-Scheme [1] 69/3)
none [3] 79/18
137/21 180/12
nonetheless [2] 18/6
62/23
nonsense [1] 56/9
nor [3] 92/23 93/16
113/11
normal [2] 21/25
122/6
normally [1] 121/20
not [250]
note [42] 7/1 13/17
17/2 17/13 17/15
19/25 20/2 20/4 20/14
20/19 20/24 21/11
21/16 21/18 22/5
22/13 22/16 22/22
24/9 24/9 26/23 27/4
27/7 27/15 31/15
40/12 63/2 104/9
106/10 106/11 106/15}
148/17 148/18 183/19}
183/21 187/11 187/11
187/19 191/25 202/9
202/14 203/14
noted [4] 62/24 85/18)
113/4 182/2
notes [5] 20/6 34/22
35/1 35/3 106/13
nothing [9] 14/10
15/20 23/8 29/22
55/20 89/15 89/21
170/2 170/7
Notification [1] 14/4
notified [1] 16/10
notifying [1] 165/25
noting [1] 63/23
notwithstanding [6]
26/8 158/8 158/20
168/11 179/3 179/4
November [6] 105/11
140/4 160/13 161/24
162/6 162/22
now [84] 3/25 20/22
22/3 25/9 26/1 27/9
31/11 32/9 36/13
37/11 40/5 41/16
43/24 44/13 49/6
49/18 53/8 53/9 59/25)
61/9 64/5 64/10 71/16
84/18 93/21 100/4
110/1 112/11 113/25
117/10 118/24 119/3
121/7 123/25 124/6
124/13 126/23 129/16}
136/17 137/11 139/9
145/9 153/13 156/4
158/17 158/20 162/15}
170/19 170/22 172/25)
173/19 174/22 175/4
177/5 181/1 184/14
184/18 184/25 185/5
186/7 187/16 189/13
190/25 191/2 191/24
193/4 194/24 194/25
195/9 195/13 196/3
196/24 197/18 198/14
199/9 200/25 201/13
201/16 202/5 202/6
202/19 204/20 206/9
210/2
number [47] 9/10
17/16 18/25 21/7
22/24 25/7 26/14
26/16 28/17 40/23
43/16 46/17 59/23
62/12 72/22 75/11
105/18 106/24 107/11
107/18 113/4 119/20
123/18 139/25 142/1
142/3 142/7 142/8
158/17 158/23 166/21
176/19 182/3 185/25
185/25 188/24 188/25)
189/12 189/13 189/14)
193/11 197/10 199/1
199/20 200/17 203/21
209/13
number 1 [3] 9/10
119/20 142/3
number 2 [2] 142/7
142/8
Number 5 [1] 40/23
number 7 [1] 75/11
numbers [1] 25/19
[e)
objection [1] 145/15
objective [3] 23/16
35/18 128/8
objective/s [1] 35/18
objectives [1] 112/2
obligation [1] 156/4
obligations [3] 140/6
175/7 207/10
oblique [1] 8/3
observation [3] 36/7
39/14 123/7
observations [1]
69/11
observer [1] 148/14
obtain [1] 209/7
obtained [2] 122/25
123/2
obtaining [1] 77/16
obvious [1] 173/4
obviously [24] 7/16
7/22 11/7 15/4 20/2
20/4 25/25 26/5 29/19!
40/6 65/11 89/6 89/19)
93/12 115/1 143/6
143/22 162/3 169/22
174/11 189/2 190/1
193/3 196/18
occasion [2] 66/12
145/25
occasionally [2]
67/12 199/2
occasions [1] 59/23
occur [5] 40/4 116/3
127/10 128/25 165/2
occurred [4] 25/9
25/11 25/17 62/5
October [9] 3/1 4/8
32/10 43/1 47/9
103/10 139/9 144/5
145/3
odd [2] 67/19 203/24
oddities [1] 69/4
odds [1] 141/2
off [13] 15/19 50/11
69/14 102/3 110/24
125/5 126/18 164/24
181/12 194/11 199/16)
199/17 199/25
offences [4] 63/4
63/5 64/18 209/3
offer [2] 14/6 14/14
offered [2] 7/3 196/2
office [199] 2/9 2/10
3/1 3/5 3/16 3/22 4/4
4/7 419 4/21 5/4 5/7
5/9 5/18 6/4 7/2 7/6
7/12 7/22 8/2 8/5 8/19
9/2 9/12 9/16 10/4
10/11 10/22 12/22
13/19 16/7 17/12
17/15 18/6 18/20
19/11 21/5 21/24
22/23 25/14 26/2
27/22 27/23 28/7
28/11 28/20 28/21
28/23 29/7 30/13
30/16 30/19 31/12
31/25 32/18 34/9 35/4
35/16 37/17 38/4 41/8I
41/20 42/25 49/3
49/12 54/5 54/11
54/12 54/13 55/3
55/14 56/8 56/16
56/23 59/14 59/23
59/25 60/3 61/22 62/3
62/10 62/18 63/13
63/21 63/24 64/2 64/9I
64/16 67/18 67/21
68/1 68/24 69/17
(75) narrow - office
[e)
office... [106] 69/21
69/25 70/9 70/19
72/11 72/18 72/24
73/17 73/23 74/15
75/1 75/12 76/7 76/14,
82/2 83/20 84/7 86/3
86/5 88/18 88/25 89/9
91/17 99/12 99/12
99/13 99/17 100/6
100/10 101/1 101/8
101/19 103/7 106/3
106/25 108/25 113/10}
121/23 122/5 122/19
124/7 124/11 125/1
125/2 125/20 127/12
129/15 129/18 129/21
130/3 130/17 130/21
131/5 132/3 133/17
134/4 140/6 141/24
142/14 142/18 144/22)
148/23 148/25 149/4
150/17 152/21 153/22
155/13 155/21 155/22)
156/15 156/22 157/9
158/10 158/11 158/14
161/10 161/21 162/4
162/24 172/8 173/2
173/17 174/4 174/11
174/15 176/8 176/11
176/24 177/11 179/1
180/21 183/9 184/7
185/24 186/2 186/6
188/17 192/5 192/19
198/8 198/13 201/1
209/1 209/6 209/10
Office's [27] 26/24
37/18 42/7 47/24
48/16 48/19 48/24
50/25 52/11 52/18
63/17 65/5 68/9 69/24
70/12 71/6 75/2 97/11
101/10 109/24 118/8
129/1 143/10 144/14
149/21 173/22 207/10
Office/BIS [1] 133/17
offices [4] 8/6 8/13
18/23 189/6
officials [1] 96/11
often [4] 67/16 99/13
151/4 151/7
Oh [7] 32/25 49/19
93/19 97/24 98/2
159/8 170/6
okay [34] 2/24 13/3
16/21 31/9 40/24 46/4
55/18 103/16 104/4
142/10 160/25 183/24}
184/13 184/18 185/3
185/18 187/6 187/13
187/25 188/17 190/9
191/6 191/22 192/1
194/4 195/9 195/25
197/1 204/16 204/19
205/3 206/24 208/1
209/13
older [1] 191/4
on [324]
once [10] 15/24
77/24 86/16 97/16
99/22 111/3 125/13
172/10 173/15 187/8
one [93] 9/25 14/6
14/17 21/7 21/16
23/19 31/24 34/14
36/11 36/12 39/21
42/2 50/1 55/7 61/18
64/8 66/12 70/3 74/11
74/14 75/10 78/6 80/3
81/9 83/2 83/3 83/13
84/6 84/21 84/23
99/25 105/2 105/6
106/7 109/20 117/2
117/2 121/15 123/6
127/7 133/5 133/5
137/20 139/6 142/21
144/24 146/10 146/18)
150/16 150/22 151/8
155/3 155/22 156/14
159/11 160/2 161/10
161/25 163/10 167/21
168/1 168/17 168/25
169/13 169/19 170/11
173/8 173/14 175/11
178/18 180/18 182/4
185/23 186/14 189/8
189/12 190/9 192/15
195/20 197/10 197/12)
197/20 198/17 198/18)
199/22 200/23 200/24I
201/18 203/18 204/20;
204/22 208/8 208/25
one's [3] 95/20
175/19 175/19
ones [2] 45/24 47/17
ongoing [7] 60/11
60/15 77/13 113/8
118/19 133/11 158/5
online [2] 5/7 181/15
only [45] 19/2 25/2
26/15 39/7 43/23
45/15 59/2 63/12 72/5)
79/16 79/22 81/13
81/19 84/2 84/5 87/13
88/17 89/15 90/6
107/10 108/2 111/13
122/5 123/9 138/19
148/21 172/23 181/2
185/13 185/23 191/7
198/18 200/22 200/24I
203/3 203/8 203/9
204/6 204/7 204/14
204/22 204/23 207/18)
208/15 209/5
onto [1] 177/2
onwards [1] 135/15
open [4] 49/7 63/14
78/23 182/10
opening [1] 171/1
openness [1] 161/12
operate [1] 28/24
operated [1] 189/6
operates [1] 4/12
operating [2] 138/14
163/19
operation [2] 26/20
109/25
opining [1] 206/21
opinion [3] 158/1
174/23 209/21
opportunity [2]
101/22 111/19
oppose [1] 63/25
opposed [1] 89/3
optics [2] 183/38
183/17
optimal [1] 10/4
optimistic [1] 71/17
option [4] 96/12
96/14 149/4 152/14
options [3] 9/18 9/24
150/10
or [213]
oral [2] 78/14 79/7
orally [2] 78/13 87/16
order [7] 7/18 47/3
50/23 99/21 184/23
185/1 205/12
organisation [11]
AIT 5/14 24/22 26/3
27/10 102/22 102/23
163/15 172/22 172/23}
173/3
organisation's [1]
137/7
organisations [1]
69/5
organise [1] 47/1
original [1] 120/11
originally [1] 60/25
originating [1] 206/5
orthodox [1] 140/13
ostensibly [1] 169/23
other [35] 22/14
24/16 26/12 36/13
39/3 53/3 79/24 82/12
82/15 83/16 94/12
108/1 131/24 137/12
141/13 145/5 146/11
148/8 152/18 162/25
163/8 168/2 168/14
169/2 175/15 176/24
177/3 177/16 179/18
1814/7 189/9 189/14
198/1 199/25 208/25
others [8] 81/2 92/8
112/14 125/17 137/19}
139/10 179/13 179/13
otherwise [3] 32/11
64/23 199/8
ought [6] 56/17 58/11
116/3 158/24 207/2
209/9
our [37] 1/11 14/11
18/15 27/22 55/24
56/8 68/25 69/7 85/8
85/10 85/25 91/17
94/7 96/13 97/25 98/6)
98/8 98/10 100/24
108/11 109/20 117/6
139/16 140/2 141/4
141/5 141/10 141/15
141/19 141/21 142/21
143/4 145/16 149/7
149/7 154/3 198/14
out [72] 7/21 23/15
33/15 36/16 37/11
38/17 38/18 39/3 39/4I
45/16 50/9 50/24
51/18 54/1 58/3 58/5
58/6 58/16 58/24
59/10 61/11 61/12
64/3 64/11 67/21
67/23 68/4 68/24 69/2
69/6 69/8 71/24 72/12,
72/19 72/25 73/13
75/10 75/18 81/11
82/7 83/5 87/17 95/20
106/24 107/10 107/13}
110/1 111/23 112/3
122/7 132/8 133/22
141/2 141/11 151/9
155/5 163/16 163/18
168/1 169/25 170/21
173/4 178/5 181/10
181/18 183/24 187/15]
188/4 192/15 194/25
204/11 205/19
outcome [8] 35/5
88/6 96/4 100/2
100/13 107/16 139/7
168/14
outgoing [2] 11/5
11/12
outline [2] 110/4
113/22
output [5] 57/21 95/6
137/5 143/21 154/1
outputs [5] 71/14
81/4 116/11 146/9
208/8
outset [3] 131/7
150/22 165/11
outside [2] 125/24
160/25
outstanding [1]
43/25
over [43] 3/4 4/8 12/9)
12/14 18/21 21/17
24/7 24/11 24/22 25/3)
26/16 37/10 44/6
60/24 61/10 63/1
68/15 72/25 75/20
85/11 96/8 100/19
104/21 112/6 112/6
113/23 118/9 119/12
126/18 141/3 141/17
149/22 152/5 153/3
160/8 160/19 167/13
178/2 179/18 185/1
187/25 188/18 199/23)
overall [7] 59/11
75/22 96/4 96/19
107/16 113/14 187/19}
overcome [1] 180/6
overheads [1] 5/12
overlap [1] 132/10
overloading [1]
64/18
overlook [1] 104/24
overly [1] 154/12
overnight [1] 173/7
overseen [1] 18/12
owe [2] 82/16 209/15
owed [1] 155/23
own [10] 12/23 43/20
66/3 69/7 74/16
127/25 165/5 165/7
198/9 198/22
owned [1] 11/9
ownership [1] 112/1
Oyeteju [1] 164/24
P
pack [2] 176/19
179/2
page [88] 1/24 2/13
2/14 5/22 5/23 9/9
9/23 13/12 13/17
13/21 14/7 15/16
15/17 17/1 18/21 20/7)
20/9 20/18 21/17
29/10 34/2 37/10
40/14 42/20 44/6 47/7)
47/13 47/13 48/10
52/8 59/10 59/19
60/24 61/10 61/17
63/1 66/15 67/11
67/11 72/9 75/11
75/20 78/21 104/1
104/2 106/16 112/6
112/13 112/13 118/20)
118/20 119/12 120/3
120/6 123/22 126/2
126/18 126/19 129/13)
135/17 135/18 136/1
136/9 139/9 141/8
145/3 145/7 147/13
149/22 151/20 151/24)
152/5 152/6 157/6
157/6 157/7 157/13
157/16 160/19 160/19)
164/22 187/8 189/20
191/23 198/22 205/2
205/7 206/13
page 1 [10] 15/16
20/7 29/10 40/14
118/20 126/2 126/19
141/8 157/13 191/23
(76) office... - page 1
P
page 100 [1] 78/21
page 126 [1] 1/24
page 13 [1] 157/16
page 136 [1] 2/14
page 14 [1] 157/6
page 15 [2] 47/13
52/8
page 2 [7] 17/1 21/17
59/10 136/1 147/13
187/8 189/20
page 27 [3] 198/22
205/2 205/7
page 3 [7] 13/21 47/7
48/10 59/19 135/17
135/18 152/6
page 34 [1] 61/17
Page 38 [1] 66/15
page 4 [3] 13/12
112/13 129/13
page 43 [1] 67/11
page 53 [1] 72/9
page 6 [2] 9/23
106/16
page 66 [1] 75/11
pages [5] 1/22 2/21
59/7 61/17 112/7
pages 34 [1] 61/17
paid [1] 176/13
pan [2] 59/10 75/18
Panorama [10] 13/18
13/18 14/1 14/4 14/19)
16/1 19/18 22/14 28/4}
190/3
paper [9] 9/17 9/25
38/22 61/2 87/14 88/9
118/12 123/10 130/2
paper-based [1]
118/12
papers [4] 77/5
133/23 185/10 185/15
paradox [2] 168/17
168/18
paragraph [43] 2/2
6/23 7/9 19/8 30/3
36/14 47/22 48/11
50/22 51/9 54/9 59/6
59/20 60/2 61/10
61/12 69/15 74/10
78/21 92/21 102/16
110/25 111/7 111/8
113/3 134/12 135/1
135/21 148/20 149/5
160/19 160/23 161/20)
189/21 190/9 191/23
191/24 192/14 195/9
198/19 198/22 201/9
206/13
paragraph 10 [2]
61/10 61/12
paragraph 113 [1]
201/9
paragraph 145 [1]
69/15
paragraph 173 [1]
74/10
paragraph 2 [3]
36/14 48/11 59/20
paragraph 20 [1]
149/5
paragraph 28 [1]
30/3
Paragraph 3 [1] 60/2
paragraph 4 [1]
50/22
paragraph 40 [1]
47/22
paragraph 5 [1]
148/20
paragraph 59 [1]
198/22
paragraph 65 [1]
110/25
paragraph 85 [1]
54/9
paragraphs [5]
140/19 191/25 195/19)
205/4 205/7
paragraphs 106 [1]
205/7
paragraphs 55-57 [1]
140/19
parallel [1] 132/19
paraphrase [1] 37/22
parcels [1] 5/2
pardon [2] 40/19
80/10
Parker [68] 1/5 1/7
1/9 1/15 1/20 6/17 7/1
8/12 15/20 27/17
34/23 35/2 37/9 37/11
37/14 37/15 37/24
38/2 38/8 40/20 46/2
53/19 54/12 54/20
55/8 55/23 76/11
78/24 88/11 89/25
91/4 92/6 100/17
105/5 106/22 108/2
108/6 114/11 130/7
133/11 133/12 134/10)
162/14 164/3 164/22
170/19 170/22 174/14)
176/17 181/1 182/6
184/5 192/1 193/18
194/16 197/24 198/7
199/9 200/16 201/25
203/23 205/3 206/10
207/24 208/24 210/7
210/12 211/2
Parker's [6] 35/5
55/3 79/1 91/24 94/15)
134/10
Parliament [3] 19/14
190/12 190/15
Parliamentary [3]
19/12 101/17 153/4
Parson's [1] 132/9
Parsons [2] 21/13
129/17
part [35] 7/4 32/10
33/7 42/18 43/8 44/19}
48/2 72/9 74/14 83/22
84/24 93/23 100/24
121/8 123/3 131/19
133/3 133/7 133/10
141/19 141/21 143/4
145/16 153/10 160/8
160/10 165/15 179/14
191/4 196/11 196/13
197/22 197/22 198/21
204/22
part-time [1] 197/22
Participants [3]
152/1 164/5 164/23
particular [11] 50/9
53/25 57/18 62/16
68/13 69/17 74/22
79/17 179/13 185/16
209/8
particularly [9] 19/14
31/11 43/17 45/2 56/2
112/24 133/15 140/18I
190/15
parties [11] 43/6
43/10 43/17 43/19
115/19 116/2 116/13
140/22 142/4 142/12
145/10
partly [4] 45/9 45/11
165/16 175/18
partner [1] 129/17
parts [3] 2/23 17/7
139/17
party [6] 68/19 72/12
72/19 74/17 89/7
137/13
pass [1] 31/3
passages [3] 59/13
61/21 67/8
passed [3] 108/7
108/17 108/21
passing [2] 65/4
69/15
past [7] 32/25 42/7
49/9 59/17 70/13
141/4 195/23
Patrick [12] 34/15
34/16 120/8 136/4
138/1 138/4 164/19
200/13 200/14 200/16
210/9 211/10
patterns [2] 67/23
68/19
Paula [21] 9/13 9/15
10/3 10/6 11/3 11/14
12/18 13/2 13/25
20/14 22/13 27/4
27/15 29/9 42/21 44/9
93/4 103/17 145/24
146/8 187/12
Paula's [2] 10/17
10/21
pause [2] 8/10 8/11
paused [1] 125/4
pay [1] 58/11
payable [1] 99/1
paymasters [1] 98/7
payments [1] 35/8
peak [3] 108/7
108/17 108/22
penultimate [3]
92/21 108/3 166/13
Penultimately [1]
158/22
people [110] 10/17
18/3 18/7 18/8 19/5
19/6 20/4 23/4 23/24
24/1 24/5 24/6 24/12
24/15 24/22 24/25
25/7 25/14 25/15
25/19 25/23 26/5 26/7
26/9 29/24 31/2 31/3
39/19 39/22 39/24
44/22 44/23 52/6 58/6
66/3 73/14 80/2 81/14,
81/23 81/23 81/24
89/20 90/12 105/22
106/5 115/2 120/8
120/10 121/20 121/25}
122/4 122/7 123/8
123/10 123/14 123/18}
128/12 129/8 129/9
130/4 132/3 142/15
142/21 146/11 154/16)
165/4 165/11 165/12
165/17 165/20 165/21
167/2 167/6 167/11
167/12 167/19 167/20}
167/25 168/2 169/16
171/13 171/4 171/7
171/8 171/18 171/23
173/1 176/10 177/3
177/14 178/2 179/8
179/12 180/9 184/7
188/24 188/25 189/4
189/10 191/14 191/14}
192/4 192/5 192/18
192/19 197/4 199/13
203/20 203/22 209/2
people's [1] 138/14
per [2] 23/10 63/8
per se [1] 63/8
percentages [1]
203/19
perception [1]
116/16
perfect [1] 76/3
perfectly [3] 56/7
100/12 104/22
perform [2] 39/1
144/1
performance [5] 8/24I
10/9 10/21 11/6 12/3
performative [1]
170/23
Performing [1] 34/17
perhaps [25] 31/1
39/20 41/7 50/17
71/21 82/6 82/18 83/1
83/5 87/11 121/2
121/14 127/17 129/6
167/10 168/21 169/10)
177/13 178/17 183/18)
189/20 194/10 194/10}
194/11 199/18
period [5] 4/4 26/16
61/7 118/10 199/23
periods [1] 22/1
Perkins [1] 3/4
Permanent [1]
100/22
persists [2] 172/20
172/21
person [18] 9/16
10/4 15/13 33/17
33/18 33/21 33/22
33/25 39/3 45/4 46/16)
50/5 52/24 58/10
115/5 125/7 208/16
209/5
personalities [1]
10/18
personality [1] 45/22
personally [5] 33/14
82/22 82/23 88/18
176/25
personnel [2] 73/2
75/15
persons [1] 112/17
perspective [11]
20/4 24/2 66/1 85/15
85/17 87/1 105/16
144/14 162/15 183/6
189/3
persuasive [2]
130/10 130/14
Peters [2] 182/2
182/3
phase [1] 117/25
phenomenon [1]
64/23
phrase [1] 120/1
phrases [1] 131/24
physical [3] 85/18
87/2 87/8
physically [3] 87/9
87/10 90/15
pick [2] 46/2 119/7
picked [3] 119/25
145/20 199/20
picture [3] 26/8
31/20 70/4
pictures [1] 31/23
piece [12] 38/22 76/3
76/4 77/23 87/14
111/23 123/9 126/23
130/2 134/4 138/10
138/12
pieces [1] 134/19
(77) page 100 - pieces
Pp
pitched [1] 137/15
place [7] 19/1 42/4
56/22 82/2 92/5 104/6
149/13
placed [3] 98/19
206/6 208/13
placing [2] 56/10
158/14
plagiarising [1]
175/23
plain [1] 158/2
plainly [2] 127/4
132/10
plan [6] 10/10 10/12
10/16 38/18 116/10
141/6
planning [1] 14/3
plans [1] 110/4
play [5] 50/2 115/18
116/3 143/9 153/10
played [2] 181/10
181/18
plea [3] 62/8 66/21
204/23
plead [1] 63/9
pleaded [1] 206/7
pleading [3] 62/1
64/17 64/21
please [84] 1/5 1/19
1/24 2/14 2/25 5/22
5/23 6/25 9/1 9/9 9/23)
13/9 13/12 13/21 14/7)
15/16 16/25 17/1 20/7
21/9 21/17 22/13
27/16 34/1 35/1 40/14,
42/20 47/6 47/7 48/10
48/10 52/8 59/19
60/24 61/10 61/16
66/15 74/10 85/4 92/3,
100/16 106/10 106/15
106/16 106/16 112/6
112/13 113/25 116/18)
116/19 120/2 120/6
120/14 123/22 126/2
129/13 135/16 135/17)
136/1 136/9 138/21
139/6 139/9 147/11
147/13 151/19 151/20
152/6 156/19 157/16
160/12 160/23 164/6
166/7 167/12 175/4
182/1 184/18 187/8
189/20 190/7 191/24
192/25 210/19
plonked [1] 195/17
pm [7] 90/23 90/25
114/5 114/7 164/9
164/11 210/22
point [73] 15/5 24/19
25/25 26/18 41/12
41/22 43/18 45/10
49/1 52/23 58/1 74/19)
79/24 93/19 93/21
95/1 95/2 95/3 95/24
102/16 103/9 104/9
104/11 104/14 108/1
108/3 108/17 109/6
111/15 111/25 113/19)
115/25 119/21 123/1
123/6 124/12 134/25
142/3 143/13 143/23
144/16 145/21 152/7
154/24 156/4 159/19
159/21 161/8 165/10
165/25 166/23 167/8
168/18 170/16 172/9
177/9 177/22 180/3
180/13 181/17 183/13)
183/19 186/3 186/4
186/24 189/14 191/2
197/19 200/3 201/23
204/11 207/22 208/4
points [15] 20/13
39/23 50/11 64/3
87/17 107/25 107/25
132/14 132/18 141/14)
148/23 148/25 154/4
177/25 199/21
POL [4] 2/2 89/10
131/17 199/7
POL's [1] 94/16
POL00006355 [1]
59/5
POL00006357 [1]
157/4
POL00022854 [1]
205/2
POL00023898 [1]
147/13
POL00024913 [1]
109/13
POL00031104 [1]
166/8
POL00065606 [1]
34/1
POL00102551 [1]
27/18
POL00103108 [1]
85/4
POL00103190 [4]
116/18
POL00103214 [4]
123/22
POL00103351 [4]
139/8
POL00103352 [4]
145/2
POL00103446 [1]
151/19
POL00114270 [4]
47IT
POL00117516 [1]
42/19
POL00158304 [2]
103/21 106/10
POL00167395 [1]
160/12
POL00174396 [1]
22/10
POL00174397 [2]
22/22 187/8
POL00231055 [1]
21/19
POL00241554 [1]
120/2
POL00242402 [1]
129/12
POL00242552 [1]
135/16
POL00319054 [1]
16/25
POL00337435 [1]
182/4
political [2] 134/9
135/4
politically [2] 8/6
8/13
polluted [1] 183/9
population [5]
165/18 165/21 168/2
188/24 203/13
populations [1]
203/20
portion [1] 166/19
pose [2] 69/17
108/24
posed [2] 120/21
120/24
position [18] 5/17
57/5 63/17 65/5 72/16
96/3 96/18 125/16
137/7 140/13 149/8
161/5 162/15 199/6
199/11 200/7 208/16
209/8
positive [4] 12/11
15/6 96/6 96/19
positively [1] 199/6
possibilities [2]
88/17 197/10
possibility [5] 68/5
69/9 71/23 133/15
148/15
possible [19] 12/10
69/6 72/1 72/5 72/14
72/21 73/4 74/20
74/23 75/14 83/14
86/7 89/7 106/25
107/1 112/22 113/22
149/19 187/25
possibly [3] 54/25
149/20 207/17
post [227]
post-appointment [1]
42/19
post-the [2] 159/17
185/22
Postmaster [2] 126/6
135/20
postmasters [6]
17/16 22/25 25/4
99/19 102/20 151/1
pot [2] 182/7 182/21
potential [7] 29/14
32/6 67/15 101/20
127/2 153/8 155/20
potentially [14] 24/14)
24/16 39/5 40/2 66/3
69/8 74/11 76/13
84/24 87/24 110/16
128/9 142/23 186/23
pounds [1] 4/23
power [3] 193/20
195/1 195/3
powers [2] 19/17
190/24
PR [3] 141/19 142/22
145/16
practical [3] 55/22
71/2 150/11
practically [2] 72/2
100/11
practice [4] 1/11
81/25 118/14 119/13
pre [3] 8/22 15/14
55/7
pre-appointment [1]
8/22
pre-booked [1] 55/7
preceded [1] 74/8
precipitated [1]
167/14
precisely [2] 55/6
56/20
precludes [1] 174/12
predetermine [1]
35/4
predominantly [1]
45/24
prefer [1] 174/22
prejudge [1] 65/16
prejudice [2] 179/7
179/8
preliminary [1]
148/17
preparation [2]
100/24 141/5
prepare [1] 126/17
prepared [4] 101/1
150/3 179/1 179/2
present [6] 3/13
52/17 84/1 137/6
160/14 182/6
presentation [1] 9/2
presented [3] 31/23
130/9 130/14
presenting [2]
118/16 119/15
presently [1] 26/14
preserving [1]
101/11
President [1] 147/23
press [1] 108/16
pressing [2] 21/8
28/5
pressure [5] 43/5
66/3 132/16 132/16
206/6
pressurised [2]
61/25 64/21
presumably [5]
15/12 31/14 48/6
120/23 161/5
presume [4] 16/8
48/9 84/4 144/9
pretending [1] 88/16
pretty [16] 14/10
14/24 15/3 15/7 16/15)
36/15 41/1 47/11
65/10 76/10 76/10
82/7 93/4 148/25
155/8 197/17
prevent [2] 82/1
102/8
prevented [3] 81/8
82/11 83/10
previous [6] 23/10
45/10 108/11 162/24
166/18 182/12
previously [5] 5/4
94/17 109/15 140/10
147/20
primary [1] 146/14
principal [1] 61/6
principally [2] 36/1
36/20
principle [3] 148/4
201/22 201/24
prior [1] 52/11
prioritise [1] 21/6
private [1] 6/4
privilege [33] 71/11
78/25 79/2 80/19
81/21 82/19 83/9
84/13 84/18 85/19
85/21 87/4 87/11
87/19 87/23 88/12
88/13 88/18 88/21
88/25 89/8 89/8 89/11
89/22 90/5 101/11
102/7 110/9 113/18
116/14 116/17 133/14)
207/6
privileged [27] 77/4
77/8 77/10 77/20
77/23 78/6 78/11
79/21 80/3 80/8 80/12
81/1 81/7 81/12 81/12I
81/17 82/23 88/1 88/5I
88/8 88/24 88/24 89/1
89/12 91/15 133/1
133/8
probably [35] 5/20
12/20 15/3 31/3 31/5
31/21 44/17 44/24
50/5 52/24 55/11
60/23 69/13 71/17
71/24 81/11 84/7 87/6
(78) pitched - probably
Pp
probably... [17]
88/22 95/5 113/22
132/14 132/17 150/6
159/8 159/17 171/8
177/12 179/15 179/25)
186/6 200/1 202/3
202/4 203/25
problem [22] 24/18
25/6 26/19 41/23
45/14 66/2 68/22
70/24 97/25 97/25
98/8 98/9 108/6
108/13 108/21 128/1
165/14 167/1 181/21
187/22 191/3 200/8
problems [10] 70/23
105/21 151/8 160/8
163/1 180/1 180/4
189/5 189/12 189/14
procedural [3] 141/3
148/6 149/3
procedurally [1]
156/3
proceed [2] 149/12
150/2
proceedings [7]
113/10 125/1 160/21
160/24 160/25 168/20
169/11
process [13] 18/20
20/8 22/4 28/19 51/4
51/23 52/14 52/17
52/20 81/14 118/1
118/4 180/2
processes [7] 37/19
49/2 49/9 102/22
106/23 118/12 140/23
prod [1] 143/7
produce [1] 58/2
produced [6] 23/5
53/20 65/10 66/1 97/5)
201/1
producing [1] 154/1
product [6] 22/8 22/9
116/14 116/16 138/9
183/9
production [1] 53/23
productive [1] 59/8
products [2] 4/14 5/9
professional [3] 38/9
38/19 110/9
professionals [1]
38/20
profound [1] 158/10
programme [11]
10/14 13/18 13/19
14/19 19/18 19/19
19/22 19/22 22/14
28/4 190/3
progress [4] 85/10
86/14 116/21 178/19
progressing [1]
149/18
progressively [1]
142/10
projected [1] 118/24
prompt [1] 206/25
promptly [1] 149/6
proper [2] 36/25
206/16
properly [9] 8/4
10/12 15/15 47/3 67/6
71/19 140/3 180/23
209/24
proportionate [1]
161/22
proportionately [1]
25/1
proposal [1] 205/11
propose [1] 150/5
proposing [1] 201/5
pros [1] 38/17
prosecute [3] 19/2
19/5 19/6
prosecuted [8] 17/22
24/7 25/15 25/19
25/23 48/8 165/3
172/4
prosecuting [2] 48/3
198/8
prosecution [12]
18/20 32/24 62/17
64/5 67/1 118/14
119/12 157/10 157/20)
205/18 205/22 206/5
prosecutions [10]
18/16 18/22 19/4
25/16 32/20 42/5
59/16 73/22 156/22
158/11
prosecutor [4] 19/17
158/15 190/24 207/11
prosecutorial [2]
63/17 209/2
prospect [2] 63/20
67/5
prosperity [1] 102/12
protect [1] 83/19
prove [2] 171/12
171/22
proved [1] 97/19
provide [10] 12/17
51/2 51/22 63/20
85/25 86/13 86/15
134/9 135/4 161/15
provided [32] 1/21
19/20 19/23 32/13
59/17 60/4 60/5 60/21
68/7 69/21 75/14
77/12 77/15 79/7
85/19 87/3 93/8 107/5)
107/6 109/18 109/21
110/9 116/22 117/7
117/13 119/2 121/17
126/14 128/17 158/6
159/25 202/6
providing [3] 20/5
90/3 206/1
public [9] 4/16 7/7
18/23 19/4 43/22
44/19 58/23 63/21
71/16
publication [2]
145/25 161/13
publicly [4] 11/9
30/16 76/15 86/19
pulled [4] 179/18
purely [3] 68/21
166/2 183/6
purported [1] 145/15
purpose [13] 35/12
36/10 36/16 36/19
37/1 37/3 59/23 60/25
70/9 77/13 111/16
141/1 170/20
purposes [5] 77/15
126/8 126/15 140/24
142/19
pursue [1] 63/12
pursued [1] 172/4
pursuing [1] 111/4
pushed [1] 194/14
put [34] 19/21 24/5
24/8 52/7 58/24 59/1
79/15 87/9 94/22 95/3,
95/20 96/10 107/12
131/4 136/14 137/9
148/18 149/13 155/3
155/20 162/23 163/8
163/20 164/1 165/4
165/8 166/8 173/9
173/25 179/21 186/25}
193/3 208/10 209/7
puts [1] 121/10
putting [7] 32/23
57/9 134/19 137/14
137/24 163/21 203/19}
Q
QC [18] 2/4 30/10
45/5 45/13 46/22 48/1
77/7 92/11 92/14
101/2 108/5 124/25
125/8 130/18 131/3
131/4 196/24 200/25
QC's [6] 91/22 91/25
92/23 92/24 94/15
94/19
quagmire [1] 181/8
qualified [11] 37/4
39/19 39/24 53/5 65/9
68/19 72/12 72/18
72/24 128/12 128/23
quashed [3] 173/24
174/14 200/18
quashing [1] 35/8
queries [1] 7/8
question [69] 23/22
26/1 27/8 30/24 37/13
37/16 41/4 41/15
41/17 42/6 47/19 49/7)
49/8 49/21 57/1 63/3
76/11 77/2 78/8 79/4
79/7 83/8 86/2 89/14
89/25 105/5 105/8
105/11 105/14 105/24}
108/18 111/16 118/17}
127/13 127/22 128/16}
129/4 131/9 132/5
140/15 143/1 143/5
143/9 144/1 144/13
156/13 162/10 162/20
165/8 165/20 167/10
172/9 172/14 181/24
182/1 184/15 191/12
192/24 193/1 193/6
194/12 194/23 198/17]
205/21 207/23 208/10)
209/1 209/17 209/20
questionable [1]
133/12
questioned [12] 1/8
10/21 11/5 164/21
166/18 184/4 188/14
200/14 211/4 211/6
211/8 211/10
questioning [2]
189/16 191/6
questions [30] 1/9
1/17 2/23 13/3 47/4
55/9 61/6 94/6 120/20
120/24 122/9 138/19
146/12 164/4 164/5
164/17 164/25 167/22}
168/1 175/5 184/5
187/10 188/19 188/20}
194/19 194/25 198/14)
200/11 210/8 210/14
quicker [1] 200/1
quickly [6] 71/18
82/7 102/24 117/5
125/13 176/17
quite [55] 4/20 12/13
12/19 21/15 25/7
25/13 25/14 25/14
26/19 27/11 31/3 39/6
39/15 40/8 46/19 47/9)
50/6 50/7 58/15 59/3
65/1 65/2 65/18 65/18
70/22 71/24 73/12
78/8 93/9 97/3 102/6
113/19 113/21 121/14}
130/17 142/3 142/19
143/23 144/7 148/22
151/16 160/16 167/7
170/25 178/14 180/5
181/16 185/5 185/10
186/23 187/9 188/18
193/4 199/17 206/11
quote [6] 61/1 69/23
83/22 174/1 198/20
199/4
quotes [1] 185/24
R
racking [1] 137/19
raft [1] 160/7
raise [2] 74/19
148/22
raised [17] 13/5 26/1
27/1 28/6 30/5 32/5
32/17 42/16 48/15
60/1 62/12 62/14
74/14 76/6 89/17
150/14 156/20
raising [1] 191/12
ramifications [1]
127/20
range [10] 4/14 5/9
46/15 54/2 75/22
175/13 175/20 197/12)
198/25 199/16
rap [1] 141/17
rapidly [1] 188/19
rather [19] 2/9 23/16
25/10 26/13 45/7
45/19 47/4 47/22
57/17 58/11 63/8
93/15 108/22 114/21
115/23 125/20 128/8
162/4 198/3
rationale [6] 43/20
62/25 94/17 132/24
134/23 137/2
re [2] 14/4 126/15
re-instructed [1]
126/15
reach [1] 132/20
reached [3] 64/7 82/1
172/10
reaction [5] 71/9
150/16 152/11 154/8
159/25
reactive [1] 141/5
read [48] 6/10 7/9
15/11 17/7 24/9 27/20
30/3 36/4 36/18 36/23}
37/7 38/6 41/1 41/3
41/16 41/17 42/13
47/21 54/8 61/2 61/21
62/6 67/9 82/21 83/23}
91/22 97/24 100/18
123/17 139/12 141/9
142/10 145/6 145/9
146/3 172/24 177/7
177/18 192/15 203/6
203/8 203/11 204/17
204/17 205/9 207/14
207/15 210/5
Read's [1] 102/18
readily [2] 61/23 62/3
readiness [1] 17/3
reading [4] 64/25
74/1 159/8 202/6
reads [1] 134/12
ready [1] 78/9
real [6] 64/8 69/17
(79) probably... - real
R
real... [4] 73/13
148/15 171/9 171/17
realise [2] 39/11 88/3
realised [1] 188/18
realistic [2] 63/20
67/5
reality [2] 70/5 172/1
really [20] 7/18 33/20
41/24 73/15 73/15
89/2 142/25 160/11
171/9 177/25 178/21
178/22 178/23 181/4
183/22 186/1 187/4
203/16 209/9 209/10
reason [15] 74/2 90/6
90/11 104/12 106/8
121/11 133/19 135/12)
136/22 153/6 153/17
155/19 158/11 158/16}
180/9
reasonable [15] 35/6
36/5 36/15 42/1 49/5
61/4 69/12 74/4 74/5
75/8 75/9 124/4
128/15 148/24 161/21
reasonableness [1]
49/9
reasonably [3] 59/25
61/9 64/10
reasoning [1] 132/22
reasons [15] 43/16
101/10 127/7 130/19
130/25 131/5 131/14
131/20 132/11 137/8
138/13 144/24 145/16)
154/11 157/21
reassuring [1]
204/12
rebut [1] 106/3
rebuttal [4] 56/7
56/16 56/16 56/23
recall [41] 8/25 9/22
11/2 11/19 11/24 12/5)
12/13 14/21 16/8
16/14 16/21 32/9
34/18 44/13 46/15
48/5 54/4 54/6 84/9
89/5 95/7 95/19 115/3
115/25 124/9 124/16
150/13 155/14 156/5
182/9 184/9 184/16
187/9 195/15 201/13
201/20 203/1 207/1
207/8 210/2 210/5
receipt [1] 124/13
receive [3] 19/25
29/17 192/8
received [25] 12/7
15/11 37/5 54/10
60/16 63/11 70/14
78/12 83/21 90/4
96/19 101/1 103/8
104/10 106/20 113/9
113/12 120/10 125/13}
134/3 135/13 139/15
152/23 168/12 193/23}
receiving [6] 14/21
33/10 83/16 110/8
127/15 138/8
recent [4] 9/11 19/15
173/22 190/16
recently [1] 101/5
reception [1] 178/25
recognise [5] 26/2
28/23 102/17 168/12
183/5
recognises [1] 28/10
recognising [1]
85/20
recollect [3] 16/4
56/21 84/19
recollection [22]
16/11 30/12 30/18
31/11 56/18 56/19
78/10 79/1 79/3 79/13
79/20 83/24 87/20
89/23 90/16 96/22
107/5 184/20 185/13
185/15 186/15 186/20)
recommend [5]
43/13 72/10 74/25
86/10 117/18
recommendation
[13] 66/11 66/12
85/25 97/6 97/7 97/7
97/8 119/18 119/19
119/20 119/24 122/12)
208/20
recommendations
[77] 45/17 59/18
65/12 66/9 66/15 67/8
70/25 71/12 71/13
72/8 73/5 74/2 75/19
76/5 76/8 77/24 81/3
81/3 82/7 85/12 86/4
86/6 86/9 91/23 93/5
101/6 101/20 103/18
106/25 107/7 107/8
107/11 107/14 108/23)
109/9 111/24 112/8
112/12 114/11 114/14)
114/19 114/21 114/24)
115/3 115/5 115/7
115/16 115/23 116/1
116/4 116/9 117/3
117/23 119/7 121/5
121/18 122/8 122/15
124/5 124/18 127/1
127/8 127/10 130/5
130/9 130/13 130/20
130/25 131/6 131/15
132/4 132/7 132/10
132/23 133/20 138/15)
207/16
recommended [6]
43/10 111/20 126/13
139/12 203/6 208/6
reconciliation [1]
69/4
reconciliations [1]
118/13
reconsider [1] 64/6
reconstitute [1]
163/9
record [2] 25/21
205/13
recorded [5] 11/13
26/21 123/13 154/8
207/1
records [6] 68/2 68/4
70/6 72/22 117/11
118/12
recourse [1] 99/18
recover [1] 62/3
recusal [15] 147/12
148/13 149/8 149/23
150/6 150/13 152/19
153/9 153/11 155/10
168/10 168/25 169/8
169/17 170/14
recuse [7] 147/18
148/12 149/5 150/4
150/18 153/23 154/9
recused [4] 151/5
153/15 154/25 170/17
red [2] 199/19 204/8
redacted [3] 82/25
92/2 161/13
redefined [1] 125/4
reduce [1] 176/3
reduced [1] 105/12
reel [1] 199/25
refer [4] 14/5 111/7
111/8 185/15
reference [20] 8/3
27/24 37/5 37/16
37/25 41/4 48/11
49/21 50/20 52/4 52/7
60/8 75/12 76/1 112/4
142/22 146/21 161/2
166/13 182/4
referenced [1] 68/23
references [3] 50/10
189/25 190/5
referral [1] 207/3
referred [4] 63/22
109/21 136/23 188/14
referring [4] 85/23
145/19 192/13 195/8
refers [4] 94/3
148/18 160/23 185/14
refining [1] 141/4
reflect [12] 31/20
74/21 110/23 119/1
123/11 123/13 123/20
168/15 172/6 174/16
202/5 202/8
reflected [2] 84/9
108/21
reflecting [1] 170/22
reflection [6] 16/9
40/4 40/6 47/5 86/20
183/19
reflections [1] 25/8
reflective [3] 55/11
108/1 108/12
reflects [1] 183/22
reframing [1] 41/18
refresh [2] 201/5
201/7
refused [1] 10/12
regard [2] 58/11
89/16
regarding [7] 27/23
28/7 29/12 48/25
141/18 166/1 188/19
regret [1] 71/16
regrets [1] 80/4
regular [2] 86/13
116/20
regularly [1] 116/22
reign [1] 18/13
reject [2] 74/2 174/6
rejecting [2] 19/13
190/11
rejects [1] 139/16
related [8] 24/10
24/17 37/18 86/8
89/25 107/3 127/8
204/24
relates [2] 74/11
7415
relating [3] 30/6
157/10 157/14
relation [15] 11/14
30/11 86/8 93/2 94/14)
112/25 117/6 117/22
124/5 145/12 186/16
188/23 198/14 198/19}
198/22
relationship [3] 75/3
1417/1 118/8
relationships [4]
10/7 10/20 105/22
172/14
relative [1] 165/18
relatively [7] 25/6
54/11 125/13 140/20
153/2 153/3 204/12
release [1] 170/3
relevant [14] 6/12
15/11 26/16 67/3 69/2
72/12 102/8 102/14
115/19 116/12 118/9
118/11 139/24 146/10)
reliability [2] 168/23
200/6
reliable [3] 98/15
167/17 181/21
reliance [4] 48/16
56/10 56/22 148/8
reliant [2] 165/5
168/10
relied [4] 7/16 56/17
179/9 209/13
reluctant [1] 43/16
rely [3] 128/15 149/2
203/16
relying [2] 58/23
204/3
remain [2] 158/19
172/2
remained [1] 3/12
remaining [2] 102/25
120/17
remains [3] 97/15
112/23 149/24
remarkably [1]
199/13
remarks [2] 57/4
141/7
remedy [1] 102/25
remember [38] 5/19
6/12 11/15 17/8 34/3
34/5 34/9 34/10 34/12!
34/13 34/16 34/17
55/5 56/13 89/13
95/24 96/23 106/19
119/20 133/24 134/2
136/18 138/8 142/24
146/9 146/20 153/16
157/2 159/9 163/15
166/6 178/14 182/15
187/4 202/7 202/22
202/23 206/25
remind [2] 102/10
135/17
reminding [3] 49/11
104/18 196/3
remote [6] 70/14
70/21 70/24 71/23
71125 72/4
remotely [4] 70/1
70/5 70/19 71/2
removal [1] 9/25
renamed [1] 184/11
repaid [1] 75/5
repay [1] 206/3
repayment [3]
204/24 205/14 205/24
repeatedly [2] 187/17
197/25
replayed [2] 97/22
98/5
replied [2] 146/3
152/8
reply [4] 14/7 136/2
145/7 161/9
report [120] 15/20
32/13 32/14 47/1 51/7I
51/12 51/25 53/19
53/23 55/25 56/7 56/9I
56/16 56/17 56/23
58/2 58/7 59/12 59/13
60/9 60/16 65/18 66/1
66/9 66/16 70/11
70/14 71/12 71/15
72/9 74/15 76/21
(80) real... - report
R
report... [88] 76/24
77/7 7719 77/12 77/17,
78/5 78/11 79/12
79/14 79/18 79/21
80/1 80/2 80/5 80/11
80/11 80/19 80/22
81/1 81/6 81/8 81/13
81/17 81/19 81/21
82/3 82/4 82/8 82/11
82/15 82/20 82/22
83/9 83/15 83/25 84/2
84/13 84/14 84/15
85/5 85/21 87/18 90/3,
90/11 90/14 91/22
91/25 92/23 92/24
93/4 93/11 93/15
93/24 94/20 94/24
101/1 101/12 103/6
103/17 106/20 106/23}
106/24 107/10 108/5
108/20 109/5 109/6
109/18 111/22 111/25
113/2 113/23 115/20
116/7 116/8 117/13
117/16 119/1 120/11
121/6 127/5 127/21
128/22 138/7 166/25
196/11 198/20 203/3
reported [4] 94/17
113/9 142/17 183/14
reporting [4] 52/15
92/4 92/7 154/21
reports [6] 32/13
32/15 73/18 110/7
124/23 176/9
represent [2] 164/22
200/16
representative [2]
144/25 153/14
representatives [1]
43/6
represented [2]
138/5 206/7
repudiate [1] 174/17
repurposed [4] 65/21
133/7 134/2 138/8
reputation [4] 37/20
64/9 142/24 154/6
reputational [5] 76/7
76/13 76/14 76/20
108/24
request [12] 16/12
48/21 49/13 49/23
79/14 83/25 84/25
85/22 101/3 133/18
134/14 147/18
requested [1] 125/2
requesting [1] 29/1
requests [2] 161/11
177/12
require [3] 132/17
140/1 149/25
required [8] 42/3
45/23 67/24 75/23
86/9 99/20 144/18
155/17
requirements [1]
186/12
requires [4] 51/1
63/19 86/17 173/10
requiring [1] 10/14
rescoped [1] 126/14
research [2] 127/4
182/9
reside [2] 179/25
180/1
resolve [3] 49/4
140/21 178/23
resolved [4] 28/3
32/4 99/17 181/5
resolving [2] 28/11
153/3
resort [1] 165/6
respect [4] 61/5
T4I17 154/14 178/6
respects [2] 179/17
179/18
respond [4] 48/14
119/24 120/15 121/5
responded [2] 37/17
197/15
responding [1] 45/11
response [22] 41/20
42/7 49/13 50/25
69/24 86/1 104/22
108/18 134/18 140/24)
141/20 143/3 143/25
165/16 165/16 167/15)
167/23 171/5 174/10
197/17 201/2 208/19
responses [1]
143/14
responsibilities [2]
18/7 194/17
responsibility [12]
63/13 111/14 114/16
114/18 114/23 115/6
170/4 178/5 181/19
185/21 209/15 209/23)
responsible [4]
101/19 114/13 180/25)
198/8
responsibly [1] 29/1
rest [4] 101/7 173/12
207/15 207/20
restricted [1] 79/22
restriction [1] 82/20
result [19] 28/9 52/6
65/23 79/7 80/24
85/19 87/3 87/18 90/5)
98/24 100/9 100/15
106/2 135/13 145/23
148/6 156/3 162/9
183/3
resulted [3] 48/16
98/22 117/8
resulting [1] 145/25
results [6] 111/6
118/1 122/23 123/4
132/21 133/13
resume [1] 210/17
retail [1] 167/21
retain [1] 10/8
retained [1] 124/25
retention [1] 21/25
retrospect [4] 121/2
122/3 169/10 169/18
return [2] 66/22
206/4
revealed [3] 27/6
72/15 162/8
reveals [2] 117/14
159/3
revelatory [1] 138/13
review [134] 9/11
18/11 18/15 28/17
30/12 35/10 35/12
35/23 36/8 36/10
36/12 36/13 36/16
36/19 36/25 37/1
38/19 45/5 45/7 45/10)
45/17 48/22 48/23
48/24 49/15 49/19
50/4 50/6 50/23 51/3
51/4 51/11 51/11
51/15 51/19 51/22
51/23 52/3 52/15
52/21 52/25 53/1
53/19 53/22 57/9
57/20 58/10 58/11
58/18 58/25 59/4 59/5
59/24 60/6 60/9 60/13)
60/25 63/22 64/3 64/5
64/14 65/4 65/25 67/1
68/13 72/19 72/25
75/2 75/24 76/6 77/4
79/6 79/9 79/10 92/11
94/15 99/25 100/20
101/18 106/13 106/18}
107/7 109/24 110/2
111/6 111/9 111/10
111/13 111/18 112/2
112/8 114/12 116/21
118/4 118/15 119/15
119/19 125/16 125/18}
126/9 126/11 126/23
127/7 133/6 134/7
134/11 135/3 135/23
136/13 136/16 137/8
137/12 137/16 138/20
157/23 161/17 195/23
196/8 196/12 196/15
197/8 198/20 198/21
198/23 199/9 200/24
201/2 203/2 203/6
207/16 207/21 208/9
208/11 208/15
review's [2] 37/8
52/13
reviewed [7] 51/5
61/12 83/6 110/21
160/4 202/15 204/4
reviewing [2] 117/16
159/21
reviews [2] 50/6
132/19
revisions [1] 10/14
rewrite [1] 37/12
rewritten [1] 41/15
Richard [3] 13/21
13/24 15/18
right [76] 3/9 3/19 4/1
4/2 5/16 9/16 10/9
18/22 21/16 22/6
49/23 65/6 76/19
80/23 87/24 92/15
100/1 100/9 100/12
104/2 109/11 113/15
115/10 115/14 116/22}
121/17 121/24 122/4
122/7 127/12 128/11
128/19 129/7 129/11
134/11 154/8 154/14
155/11 162/20 162/20}
163/20 163/22 164/1
164/20 165/19 166/11
169/7 173/10 174/19
174/22 177/13 178/17
179/22 186/3 186/11
186/18 188/1 188/8
189/13 189/25 190/13
191/14 191/20 191/23}
193/18 194/2 195/5
195/13 196/3 196/5
196/17 198/23 200/9
204/11 207/16 207/21
right-hand [2] 10/9
21/16
rightly [1] 18/24
rights [1] 149/7
rigour [1] 107/2
ring [1] 60/13
rings [2] 34/14 171/7
risk [7] 9/3 16/2
104/4 133/1 133/9
133/14 137/6
risks [1] 149/10
Rob [1] 118/3
Robinson [8] 124/25
125/8 125/11 126/5
129/19 130/22 135/19}
138/6
robust [15] 14/10
14/24 15/3 15/7 18/1
19/13 23/7 30/15
31/14 32/2 132/17
181/14 181/15 181/17,
190/11
Rod [1] 20/23
Rodric [9] 34/3 39/11
47/14 120/9 136/3
183/7 183/15 183/21
183/22
role [21] 5/18 6/18
7/3 14/22 27/22 29/2
34/19 39/1 102/11
115/17 115/19 115/21
116/3 143/9 144/1
144/21 153/14 155/1
188/18 198/2 198/5
Rolfe [26] 6/11 14/2
14/8 14/12 16/5 16/18)
27/18 36/1 38/4 44/15
48/12 49/8 49/24
54/18 54/24 85/9 90/1
92/10 107/24 108/8
109/14 109/17 125/17)
130/8 133/16 136/11
Rolfe's [2] 53/25
101/3
Ron [2] 54/4 57/4
room [2] 164/14
182/24
root [3] 179/23
179/24 180/1
roughly [2] 25/22
25/23
Royal [2] 4/25 5/1
rule [3] 69/8 102/6
140/5
ruling [1] 145/17
ruminations [1]
138/1
run [5] 173/3 180/19
183/24 186/6 186/8
running [2] 12/24
60/7
rushed [1] 178/18
So
safe [1] 42/6
safer [1] 133/2
safety [3] 66/20
127/9 183/15
said [67] 5/25 5/25
8/12 21/19 44/18
44/21 44/25 54/8 54/9)
56/2 56/21 57/6 57/6
57/13 58/11 61/23
65/13 71/22 72/6 78/2I
78/6 78/24 83/23 84/5I
84/9 84/13 88/5 93/7
95/12 97/24 98/2 98/7I
106/12 107/16 108/5
109/4 114/24 115/9
123/3 123/19 125/6
125/14 128/18 131/7
136/20 138/17 140/13)
142/4 142/22 155/8
156/15 168/18 170/15)
175/24 181/20 182/7
182/10 183/17 187/16)
188/12 189/13 194/4
195/6 197/24 204/10
204/13 208/25
Sajid [1] 6/5
sale [1] 49/1
Sam [1] 184/5
(81) report... - Sam
Ss
same [16] 3/7 4/18
7/25 42/18 75/7 94/17,
100/14 120/10 120/12)
123/4 124/8 145/3
145/7 146/2 151/1
197/25
Samsonite [4] 3/7
3/8 3/10 3/13
Santander [1] 74/18
Sarah [2] 91/12
100/21
sat [2] 99/6 123/18
satisfactory [6] 65/7
65/14 65/24 171/16
171/22 181/9
satisfied [1] 112/18
satisfy [1] 92/16
saved [1] 79/18
saw [9] 11/25 27/16
27/25 117/2 133/23
196/11 196/16 206/21
210/2
say [110] 1/10 5/15
8/17 9/24 14/12 15/5
20/3 20/6 21/6 21/7
24/3 24/21 27/9 31/6
36/14 41/23 42/10
43/1 45/16 46/20
46/22 46/23 47/23
50/15 51/17 51/21
52/2 57/5 57/10 57/12
58/22 58/25 62/20
71/25 76/19 77/12
77/15 78/4 79/16
83/14 84/17 87/12
87/13 88/20 89/15
93/9 93/11 97/1 97/15
103/17 103/22 106/4
107/17 107/19 108/8
109/19 111/21 112/2
118/21 122/3 122/13
122/23 127/23 133/10)
134/6 135/2 139/18
141/8 141/22 143/2
143/7 151/14 155/12
159/16 161/5 167/5
167/8 171/2 171/5
171/10 171/17 172/24
173/1 173/5 174/18
174/22 175/11 175/16)
176/5 176/6 177/19
178/7 179/7 179/10
179/17 182/8 183/15
185/20 195/9 196/14
197/8 198/18 201/4
201/7 201/9 201/22
202/2 203/24 207/25
208/14
saying [26] 17/23
32/2 41/12 55/14
56/15 56/23 95/8
99/10 99/21 100/3
100/7 100/7 100/10
121/24 128/19 136/2
146/2 146/3 177/1
186/3 187/3 187/3
188/7 193/20 193/22
197/2
says [28] 2/2 30/3
36/4 36/18 40/20 55/1
55/19 78/22 91/13
92/21 99/7 117/5
124/1 126/4 129/19
134/5 135/1 139/11
147/15 151/22 157/17)
161/11 177/19 192/1
193/10 196/7 198/21
205/10
scale [8] 23/22 26/19
29/22 165/10 165/14
165/17 188/22 197/14)
scenario [1] 149/19
scene [1] 4/21
scenes [2] 121/9
121/13
scheduled [2] 43/25
100/25
scheme [17] 18/12
28/12 44/3 59/18 62/4
62/12 62/16 67/22
68/4 68/8 68/18 69/3
69/10 72/13 74/12
106/22 196/1
scope [17] 37/8 51/3
51/11 51/22 51/24
52/14 52/17 59/13
65/24 79/8 86/9 110/3
112/2 157/22 202/10
202/21 202/23
score [1] 73/3
scrambling [1]
171/19
scrape [1] 95/11
screen [4] 47/22
166/8 166/14 173/25
scroll [23] 17/1 20/18
34/1 40/16 40/17
40/20 40/20 85/13
91/20 92/3 92/20
104/2 104/3 106/16
112/14 123/23 126/2
132/6 151/19 160/18
160/18 166/11 190/7
scrolling [4] 19/8
40/19 48/18 160/23
scrutinise [1] 28/13
scrutiny [1] 28/16
se [1] 63/8
seal [2] 130/18 131/4
sealed [2] 73/3
180/11
seals [1] 131/3
search [2] 68/19
146/11
searches [1] 161/22
searching [2] 96/21
161/10
seat [1] 99/7
second [32] 5/22
6/23 9/9 32/13 43/6
43/18 43/21 44/10
44/14 54/5 57/22 59/3
61/13 62/14 74/14
74/19 90/20 97/6
104/11 108/15 111/8
113/8 122/17 135/21
152/6 160/19 165/25
196/6 196/11 204/19
205/21 208/20
secondly [3] 39/20
174/8 186/20
Secretary [5] 6/5
6/25 22/20 100/22
166/3
section [1] 66/16
sector [2] 4/16 44/19
secure [3] 29/7 166/5
168/14
secured [2] 19/10
31/12
security [2] 4/15 26/6I
see [106] 1/3 2/2 6/5
9/5 9/9 17/13 17/17
21/16 22/3 22/4 23/1
34/24 35/1 35/9 36/22,
44/14 47/12 47/13
48/11 48/22 49/6
49/19 50/1 50/10
50/21 53/16 58/7 59/9
59/11 61/1 61/17 71/1
73/5 75/20 82/3 91/1
93/3 93/12 93/19
93/19 95/25 97/17
100/13 101/22 103/18}
104/22 112/14 114/8
115/25 119/21 120/2
120/6 120/14 121/7
123/6 131/19 132/11
133/12 136/2 140/18
143/12 147/2 148/20
153/25 154/5 157/7
160/14 160/16 161/2
161/12 164/12 166/9
166/12 172/9 172/14
173/19 173/20 174/22I
174/24 178/1 180/12
181/7 182/11 183/6
183/11 183/17 185/10
188/10 189/22 189/25}
190/3 190/5 191/22
192/21 193/7 195/20
196/10 196/13 196/14]
197/3 197/19 197/20
200/19 201/16 202/20
206/18
seeing [4] 7/1 40/18
44/15 195/15
seek [7] 6/24 35/23
63/16 73/17 117/17
149/4 159/4
seeking [1] 44/9
seem [5] 51/9 74/4
141/10 169/9 182/3
Seema [3] 62/6
164/23 182/7
seemed [14] 23/20
41/10 41/25 46/16
47/24 49/13 50/4 74/5
110/17 121/12 129/9
168/19 204/12 208/19}
seemingly [3] 94/3
106/14 121/18
seems [10] 36/10
36/14 38/18 69/16
69/23 92/22 93/14
162/4 198/24 205/15
seen [18] 36/13
47/15 57/16 60/8
62/24 79/11 101/25
145/5 165/11 176/18
178/25 197/13 202/22}
203/15 204/13 206/1
207/20 208/11
sees [2] 141/18
183/16
select [4] 100/24
120/12 122/19 136/6
selection [1] 115/2
self [2] 165/5 179/12
self-consciously [1]
179/12
self-reliant [1] 165/5
sell [1] 5/10
Seller [1] 61/14
selling [1] 26/3
semantic [1] 111/11
semantics [1] 111/17
send [4] 20/19 20/25
44/3 125/11
senior [13] 9/2 19/16
48/1 53/5 79/3 94/8
127/15 134/1 138/6
150/5 156/10 156/14
190/20
sense [11] 49/16
53/2 67/14 68/10
113/20 118/5 135/1
145/10 156/6 166/22
17119
senseless [1] 137/5
sensible [5] 24/24
67/7 74/4 74/5 111/23)
sensitive [2] 8/7 8/14
sent [9] 5/24 20/15
22/19 42/21 109/14
125/22 146/2 170/21
176/19
sentence [8] 63/5
64/15 80/9 86/25
101/14 110/11 116/25)
123/16
sentences [3] 109/3
123/10 128/20
separate [3] 138/21
142/8 170/19
September [8] 3/2
27/19 34/22 49/7
49/24 54/1 55/2 94/4
series [8] 9/24 13/3
13/10 13/12 26/20
47/4 69/11 86/4
serious [16] 18/18
19/13 61/24 64/22
148/6 153/25 163/1
176/4 189/19 190/11
190/25 191/16 206/9
206/20 206/22 209/1
seriously [4] 18/7
28/6 32/4 152/14
seriousness [2] 63/4
63/6
servant [1] 38/16
servants [6] 77/21
84/23 87/21 89/11
110/15 135/15
served [1] 206/2
Service [1] 4/1
Services [3] 34/6
34/8 157/15
serving [1] 177/3
set [29] 4/20 18/12
19/3 21/5 37/11 38/17)
50/19 51/17 51/21
52/1 60/7 61/11 61/12
70/23 87/17 107/10
107/13 110/1 112/3
132/8 139/22 168/22
179/10 179/21 180/21
189/4 189/9 196/1
204/8
sets [2] 106/24
161/22
setting [6] 23/15 50/6
143/10 146/15 187/15)
196/12
settings [1] 46/17
settle [2] 52/13
164/14
settlement [10]
97/21 98/21 98/23
99/3 181/7 181/11
184/15 184/22 184/25)
186/16
seven [3] 3/2 3/16
63/5
seventh [1] 97/7
share [4] 83/17 90/14)
112/21 116/10
shared [13] 76/22
77/1 77/25 81/4 82/24I
83/1 94/21 94/25
101/7 102/9 106/23
116/8 208/7
shareholder [12] 6/2
9/5 9/18 13/5 13/22
28/20 154/3 155/25
173/18 184/11 186/5
209/16
(82) same - shareholder
Ss
shareholders [2]
11/9 102/14
shareholders’ [1]
12/4
sharing [5] 81/8
82/11 82/15 84/14
117/16
she [43] 6/16 6/17
6/20 6/21 10/8 10/15
10/17 11/5 11/13
12/19 12/21 14/3
15/21 16/10 20/13
20/15 41/9 41/10
41/10 43/11 43/13
67/19 79/15 79/17
79/20 83/12 83/23
84/5 92/13 93/8 107/8
115/12 116/22 117/5
119/22 125/5 125/22
139/10 147/15 153/3
153/6 206/3 206/6
sheet [1] 64/18
ShEx [3] 6/2 10/24
90/2
shift [4] 49/6 50/2
170/11 173/6
shifted [1] 130/6
short [5] 9/17 53/14
90/24 114/6 164/10
shortfalls [2] 165/3
165/14
shorthand [3] 16/6
31/4 169/23
shots [2] 182/7
182/21
should [94] 1/9 1/23
2/6 9/24 14/16 20/14
37/11 37/15 37/24
38/2 41/2 41/3 41/12
42/11 42/25 43/1 43/9)
43/11 43/13 51/4 51/5
51/6 51/11 51/13
54/20 60/5 62/20
63/24 69/14 71/21
73/21 73/23 73/24
75/12 76/22 77/1
77/20 79/18 81/19
84/17 86/3 94/20
94/24 97/15 98/22
98/24 99/16 99/16
99/20 101/12 101/24
101/25 102/8 104/25
112/21 114/14 117/19)
120/19 122/6 124/24
125/1 125/3 126/9
126/11 126/14 129/10}
131/21 132/11 132/20)
133/6 134/1 134/5
135/23 138/7 139/18
150/2 150/17 152/16
154/24 156/11 158/6
158/12 158/18 167/10
168/21 171/4 177/24
180/22 197/1 197/9
198/10 203/11 204/3
206/3
shoulder [1] 176/23
shouldn't [3] 58/23
83/17 147/2
show [2] 40/18 90/11
shown [4] 10/15
121/8 159/12 208/12
shutting [1] 134/10
sic [2] 97/22 135/19
SID [2] 94/10 94/11
side [9] 9/10 9/24
10/2 10/9 21/16 155/3
168/24 179/3 181/7
sides [1] 141/12
Sight [15] 32/14 43/6
43/18 43/21 44/10
44/14 54/5 57/22 59/4
61/13 62/14 74/14
74/19 196/6 196/11
sign [1] 126/18
sign-off [1] 126/18
signature [2] 2/14
70/11
signatures [1] 69/20
signed [2] 110/21
172/2
significance [1]
101/20
significant [27] 4/19
4/24 5/4 5/8 8/8 8/15
13/18 14/20 15/20
21/8 74/20 76/6 76/14
94/18 94/23 95/10
97/4 102/21 108/24
126/23 139/17 144/19)
147/9 148/23 154/6
154/6 166/21
silk [6] 2/6 2/11
128/16 138/16 150/5
204/2
similar [4] 62/5 84/17
123/1 175/23
similarly [1] 74/17
Simon [3] 6/18 157/8
159/7
simple [2] 105/5
193/6
simply [11] 13/8
69/23 83/20 132/23
151/16 153/24 171/15)
173/14 174/21 176/23)
206/18
since [7] 18/3 73/7
136/13 137/4 192/4
192/18 200/18
sir [30] 1/3 1/9 43/7
44/10 44/15 53/8
53/11 53/16 53/18
88/14 90/20 91/1
99/19 113/25 114/3
114/8 154/13 164/6
164/8 164/12 164/17
165/1 175/3 180/16
184/1 200/15 210/8
210/11 210/19 210/21
Sir Alan [2] 99/19
180/16
Sir Anthony [4] 43/7
44/10 44/15 165/1
Sir Wyn [2] 88/14
154/13
sit [4] 1/12 14/14
153/13 174/21
sites [1] 4/13
sitting [1] 200/19
situation [15] 7/15
7/19 33/3 50/14 67/19
116/7 127/14 169/16
172/1 174/24 180/22
181/11 181/16 183/2
200/2
six [4] 18/2 163/16
192/2 192/16
sized [1] 4/10
skills [2] 9/4 39/8
skip [1] 85/11
skipping [4] 52/5
64/15 68/15 113/3
slap [1] 104/21
slide [1] 10/1
slight [3] 57/24 98/8
105/25
slightest [1] 30/1
slightly [14] 24/13
26/10 29/17 36/21
57/19 81/9 130/6
151/5 151/11 151/21
173/8 175/10 180/14
189/8
small [10] 17/16 18/8
18/25 22/24 25/7
120/8 120/22 122/11
136/6 171/19
Smith [1] 107/24
so [258]
social [1] 43/21
software [2] 110/1
179/25
sole [4] 28/20 38/3
154/3 174/3
solicitor [2] 34/6
38/13
solicitors [2] 129/17
157/9
solution [1] 200/8
some [102] 4/18 5/21
6/19 7/2 8/18 8/20
11/7 12/1 12/16 12/25}
17/7 17/22 18/19
19/10 20/8 20/13
21/18 22/1 22/14 26/1
28/3 28/15 32/25
33/17 38/19 39/3
43/24 44/22 45/17
46/14 46/25 55/13
57/14 59/12 60/15
67/13 68/8 69/10
71/12 71/18 74/21
76/4 76/9 76/13 80/24)
91/4 94/6 96/1 97/5
103/9 111/23 113/1
115/4 117/10 124/12
127/8 127/24 128/8
129/6 129/15 130/18
130/22 131/20 131/22}
131/24 131/24 137/15)
137/25 138/14 141/14}
142/23 143/22 143/24]
146/12 147/6 148/22
148/24 150/11 151/2
151/3 153/17 162/23
164/5 164/24 167/25
168/18 170/20 173/1
175/5 175/5 177/20
178/6 178/19 179/12
179/15 179/17 186/24}
187/15 187/15 199/5
202/9 202/19
somebody [18] 17/17I
33/13 33/14 33/22
37/4 39/5 39/7 46/8
46/25 58/9 98/2 98/12)
182/21 193/10 193/12}
196/21 197/11 205/6
somebody's [1]
31/24
somehow [9] 5/13
40/1 77/6 106/1 128/7I
128/8 163/19 178/20
183/1
someone [7] 12/15
46/24 89/8 99/6 146/6)
146/7 187/1
something [51] 5/25
12/6 25/22 25/25 31/9}
31/23 44/6 44/24 45/1
45/7 58/7 62/5 64/9
69/1 70/11 71/8 71/20)
81/15 81/16 83/6 87/8)
97/1 97/5 99/17
103/22 116/11 122/13
122/16 123/3 124/15
131/8 133/25 142/22
144/8 151/12 152/12
154/10 154/22 155/9
155/18 162/14 162/21
163/3 184/23 191/23
193/3 193/10 194/5
194/13 199/15 199/23}
sometime [2] 33/4
184/21
sometimes [8] 76/18
95/19 104/24 123/13
151/10 170/10 179/19}
179/19
somewhat [8] 82/6
118/23 134/8 134/13
141/10 142/13 169/10}
1841/5
somewhere [2]
143/15 146/21
soon [3] 16/15 86/7
112/22
sophisticated [1]
88/22
sorrow [1] 171/12
sorry [21] 4/19 11/23
13/7 18/8 40/19 40/22I
49/11 51/16 56/4 80/9)
99/5 143/17 171/2
171/5 171/10 171/17
183/13 198/13 207/12)
207/22 210/6
sort [55] 4/10 12/23
23/20 24/2 24/16 25/6
25/16 25/18 26/9
29/21 29/22 30/23
31/10 32/25 33/2
33/23 33/25 36/11
41/9 44/19 46/19
46/21 47/1 50/6 50/12
50/15 50/21 60/11
60/12 65/16 80/8 81/5I
84/25 87/11 107/12
111/12 116/24 123/7
133/5 137/1 142/11
143/7 163/10 169/12
169/14 171/19 171/20)
177/117 181/20 182/18)
182/23 189/9 197/18
198/1 199/20
sorts [3] 154/4 154/6
173/9
sought [6] 66/17
69/25 147/17 147/22
147/25 209/7
sound [2] 23/14
54/15
sounding [1] 104/4
sounds [3] 23/25
171/14 199/12
source [5] 60/4 60/20
78/23 182/10 185/23
sources [3] 54/2 69/6
155/6
space [1] 163/16
Sparrow [14] 14/4
14/10 14/25 15/2
15/21 16/7 17/3 20/17)
21/4 30/9 43/4 106/17)
193/24 197/19
speak [9] 14/3 43/5
43/17 88/8 91/9
133/16 172/23 172/23)
173/15
speaking [15] 14/8
25/6 25/22 25/23
34/22 35/1 35/3 43/19
73/5 100/11 106/13
106/14 108/12 162/15)
183/7
special [1] 160/15
specialising [1] 34/8
(83) shareholders - specialising
s
specialist [6] 73/17
128/2 128/3 128/3
128/5 128/5
specialists [4] 83/5
128/1 130/4 209/20
specific [18] 30/7
32/8 46/1 63/7 68/11
68/14 68/23 74/13
75/6 75/12 96/9 118/9
118/16 119/15 173/19
175/5 206/15 207/2
specifically [3] 16/24
34/18 87/15
specified [1] 121/23
speed [2] 15/25
54/13
spend [2] 180/16
198/1
spending [2] 106/2
197/21
spent [4] 105/19
106/5 127/24 198/10
spirit [3] 24/3 29/20
161/12
SPMs [1] 165/2
spoke [4] 6/11 6/16
14/9 125/22
spoken [3] 94/12
146/7 207/5
spot [2] 21/1 194/11
sprinkle [1] 130/22
staff [4] 10/8 198/9
207/19 208/17
stage [7] 15/1 15/6
57/20 96/3 116/11
143/22 176/3
stage’ [1] 149/5
stain [1] 64/19
stake [1] 173/16
stakeholders [1]
102/15
stand [2] 7/22 171/2
standalone [1] 186/8
standard [7] 112/24
136/14 136/20 139/23}
192/6 195/10 195/15
standards [3] 37/21
107/2 112/19
standing [1] 20/23
standpoint [1]
172/15
start [9] 2/25 20/15
33/16 147/12 164/17
164/24 165/20 181/22)
201/3
started [8] 68/10
73/8 97/16 97/16
105/1 105/6 121/1
142/13
starter [2] 13/1 35/1
starting [2] 52/23
91/10
starts [4] 170/12
181/24 190/10 195/19)
state [7] 6/5 37/15
41/3 41/13 89/18
153/4 166/3
State's [1] 6/25
stated [2] 35/18
37/25
statement [30] 1/21
2/17 2/21 11/11 30/2
47/21 48/6 54/9 78/20
79/15 83/22 110/24
138/23 138/25 158/6
171/2 185/14 198/19
198/20 198/23 201/4
201/6 201/9 201/25
202/2 202/5 202/14
206/1 206/2 210/13
statements [3] 30/15
139/18 182/12
states [1] 148/21
statistical [1] 168/5
statistically [2] 24/24
166/21
statistics [2] 151/3
151/4
status [2] 120/16
158/21
stayed [1] 55/8
stealing [1] 165/6
steering [4] 6/22
129/21 129/24 144/2
Stein [5] 164/18
184/4 184/5 198/17
211/8
step [1] 122/25
stepped [2] 3/11
147/22
steps [4] 29/4 101/24
112/16 150/8
stick [1] 89/16
sticks [1] 16/17
stifle [1] 132/3
still [12] 4/23 55/14
55/15 56/10 58/15
99/25 134/11 160/18
172/19 173/2 174/15
202/24
stone [1] 168/16
stonewalling [1]
177/4
stop [8] 64/25 89/1
112/16 129/23 134/5
155/1 183/25 203/23
stopped [7] 65/21
69/14 93/24 133/6
138/16 169/1 169/8
stopping [8] 35/22
70/13 77/9 120/22
124/9 155/11 155/20
192/21
stops [1] 170/5
store [1] 73/21
story [4] 20/3 23/12
23/17 24/13
straight [2] 116/12
197/9
straightforward [2]
121/15 122/15
strands [2] 45/14
111/4
strategic [2] 10/10
10/11
strategy [6] 10/5
143/11 144/15 144/21
146/15 147/3
strengths [1] 175/11
strenuous [1] 163/25
stress [1] 110/6
stretched [1] 18/19
strictly [1] 101/12
strike [2] 105/21
141/2
strikeout [4] 139/7
139/16 139/22 142/9
strikes [1] 88/15
strive [2] 181/6 181/7I
strong [20] 6/20 65/1
65/2 96/2 96/5 96/18
104/10 126/10 127/16
128/18 133/24 133/25I
134/1 135/22 136/24
138/7 138/17 142/19
148/25 155/8
struck [3] 12/6
159/12 203/12
structure [4] 5/11
59/11 59/12 172/13
structured [2] 67/16
76/2
stuck [1] 14/11
study [1] 174/3
stuff [7] 104/20
134/16 153/18 159/21
176/1 176/1 197/3
subcommittee [11]
144/6 144/16 144/20
144/23 144/25 146/15]
146/18 146/22 146/24
152/22 153/15
subcontracted [1]
39/3
subject [11] 39/8
59/21 74/13 87/10
92/4 104/5 110/9
126/13 133/17 168/8
170/25
submission [1]
173/22
subpostmaster [6]
61/25 64/20 66/18
67/17 70/7 145/13
subpostmasters [25]
26/14 26/16 48/25
59/14 59/17 60/1
64/17 98/1 99/11
109/25 113/5 117/8
124/11 129/3 157/11
165/18 166/2 166/20
166/22 172/4 172/7
184/6 188/24 200/7
200/17
subpostmasters' [1]
168/13
subsequent [5]
50/14 52/5 146/7
152/10 170/21
subsequently [5]
82/21 103/11 103/19
143/13 187/1
subsidise [1] 8/4
subsidy [1] 7/18
substance [7] 41/19
42/4 54/6 61/17
108/23 109/2 156/5
substantially [2]
97/10 169/5
substantive [1]
117/24
subsurface [1]
122/18
subtly [1] 50/2
success [1] 5/10
successful [4] 28/22
149/11 168/15 169/8
such [15] 28/25
43/23 50/13 66/25
67/2 67/5 74/18 80/1
86/18 103/2 120/1
131/24 146/17 173/6
178/8
suddenly [1] 25/19
suffer [1] 67/13
suffering [1] 5/1
suffice [1] 159/16
sufficiency [4] 61/19
63/15 64/6 64/13
sufficient [7] 62/10
63/19 66/24 67/4
198/12 205/20 205/22,
sufficiently [2] 88/22
117/17
suggest [14] 23/9
68/22 69/6 89/21
91/22 98/12 111/13
146/1 154/16 169/24
173/20 176/2 178/24
199/7
suggested [7] 9/11
17/19 17/21 19/15
54/20 110/12 110/24
suggesting [2] 63/25
176/22
suggestion [9] 57/23
62/15 69/7 106/3
121/16 150/17 183/5
183/11 206/3
suggestions [2] 28/8
190/20
suggests [6] 70/11
141/20 143/4 145/18
149/2 183/18
suitability [1] 9/13
suitable [4] 6/18 48/1
122/1 122/1
suitably [4] 72/11
72/18 72/24 82/25
summarise [1] 57/16
summarised [5]
85/10 88/9 93/4 146/8
160/1
summarising [1]
148/19
summary [14] 43/3
59/18 61/11 75/20
79/9 112/7 113/21
124/24 128/14 128/20)
130/3 151/23 151/25
152/4
sums [1] 74/20
Sunday [1] 91/13
support [11] 6/21
17/24 18/18 19/10
19/24 23/6 59/16
117/14 180/17 186/9
205/22
supported [1] 111/24
suppose [14] 39/15
41/6 44/17 45/9 71/4
71/9 71/19 79/25
87/11 147/5 160/11
164/2 195/4 197/13
Supreme [1] 147/23
sure [45] 1/13 6/3
15/1 27/1 27/11 28/21
38/21 38/22 41/9
58/16 70/16 73/15
78/8 79/19 81/18
90/10 93/4 95/3 97/2
100/15 109/14 111/25
115/1 124/22 125/22
125/22 128/10 136/22)
137/2 143/23 144/7
147/6 163/6 163/13
169/1 175/22 185/14
191/20 193/4 194/6
194/15 195/18 200/19}
208/7 210/4
surely [1] 174/15
surprised [2] 25/15
27/6
surrounded [1] 179/9I
surrounding [1] 28/2
suspect [6] 27/24
105/25 111/15 122/22!
142/14 193/6
suspense [4] 74/16
75/3 118/6 118/8
suspicion [1] 151/6
sustainable [2] 8/21
28/22
Swannell [2] 184/10
184/19
Swannell's [1]
186/20
swift [103] 30/10
(84) specialist - swift
57/2 57/17 57/21 58/1
58/25 60/21 65/17
65/21 65/22 66/4
71/10 71/25 75/23
76/3 77/4 80/11 85/1
85/8 86/22 93/3 97/5
97/12 97/22 97/24
100/20 101/2 101/7
106/21 107/7 108/13
108/20 109/23 110/21
118/14 119/8 119/14
124/3 124/17 125/6
126/23 127/20 128/21
130/9 130/19 131/14
132/4 132/23 133/20
162/18 166/25 194/9
195/8 196/12 196/22
197/8 197/17 198/20
198/21 198/23 199/9
199/16 199/18 200/24}
201/2 203/6 204/2
207/15 207/21 208/5
208/9 208/11 208/15
Swift's [3] 66/9 130/5
133/11
swiftly [1] 47/9
Swinson [1] 10/7
sympathy [1] 96/1
system [59] 13/19
17/19 18/1 23/2 23/7
23/23 23/25 27/23
28/2 28/8 28/14 31/1
31/6 32/2 32/3 37/18
42/4 42/11 59/15
59/16 67/12 69/9
69/22 72/15 72/21
72/22 73/4 73/6 98/3
98/10 98/15 108/10
110/1 113/1 117/21
157/15 167/17 181/16)
181/21 188/15 188/19
189/6 189/10 189/16
189/16 191/4 191/7
192/2 192/9 192/12
192/13 192/16 195/16
197/9 197/12 198/25
199/10 199/10 200/6
systemic [11] 30/14
30/20 30/25 30/25
31/4 31/13 31/25
108/6 108/13 108/14
108/21
s systems [1] 49/2
swift... [102] 30/12 IT
41/23 42/17 45/5
denie ders azn table [2] 107/8 165/4
48/1 51/18 52/2 52/19
53/20 55/4 55/5 55/23)
101/21 104/17 106/13}
111/20 111/22 111/25}
113/23 114/12 117/17)
119/22 120/11 120/25)
138/15 138/20 159/12)
tack [5] 141/21 143/4
143/15 145/18 146/1
tackle [2] 7/23 37/5
tail [2] 170/12 170/13
tainted [1] 40/2
take [53] 12/9 12/15
36/3 39/20 47/15
50/12 53/8 57/10
68/9 70/23 71/5 81/2
85/11 90/20 94/14
107/14 112/1 113/1
116/1 119/12 122/10
123/16 124/4 125/15
128/25 141/11 151/9
156/4 163/15 164/6
166/17 168/5 168/12
169/7 169/21 177/20
182/7 192/8 201/23
205/4 205/8
takeaways [1]
108/20
taken [37] 18/6 35/13
36/20 36/24 40/8 45/6)
57/3 59/25 61/9 63/18)
83/5 93/25 96/16
96/17 99/2 99/4 100/5)
102/2 114/14 114/19
114/22 114/24 115/7
115/10 115/17 115/24)
116/5 116/5 116/10
119/21 119/23 121/19)
122/11 156/12 172/8
194/1 198/16
takes [3] 15/14 19/1
28/6
taking [7] 27/21
29/18 82/2 108/23
118/23 173/21 182/21
talk [6] 82/8 176/8
176/10 190/17 197/4
197/4
talked [4] 50/19
119/22 178/24 180/1
talking [8] 11/1 33/1
36/2 75/25 93/20
132/7 191/13 205/9
task [4] 37/12 39/4
45/21 47/25
tasks [1] 112/20
taxpayers [1] 4/23
team [22] 7/23 9/12
34/18 35/16 48/3 48/8)
50/24 81/2 120/8
120/22 121/3 121/17
122/11 122/19 123/1
132/13 136/6 163/25
172/17 172/24 173/13}
14/13 18/22 29/4 32/4
57/18 57/21 59/1 65/5)
96/2 96/8 96/12 96/15)
180/16
teams [2] 125/3
169/13
tear [1] 98/2
technical [4] 45/8
45/12 67/24 151/18
telephone [1] 54/10
tell [34] 1/18 4/6 20/2
58/22 65/14 73/11
78/9 81/18 83/8 90/9
109/3 122/5 124/19
159/15 163/6 163/6
206/21 209/12
telling [3] 125/5
153/12 187/5
temptations [1] 26/6
ten [2] 13/1 35/1
tenable [1] 205/25
tens [2] 25/4 26/21
tense [1] 195/23
tenure [3] 96/4 96/17
175/16
term [4] 3/15 112/3
191/24 200/8
terminated [2] 24/25
165/13
termination [1] 169/3
terms [32] 4/6 5/11
11/11 11/21 12/24
37/5 49/20 50/20
50/20 52/4 52/7 55/22,
60/8 60/13 61/1 76/1
90/17 95/23 108/15
108/16 127/20 136/10
136/18 137/5 138/17
146/21 155/21 172/13
180/24 187/23 188/23}
198/25
terrible [2] 50/13
160/7
test [2] 8/11 148/13
tested [2] 83/6
132/18
testing [5] 112/25
117/23 118/11 136/14
136/20
tests [1] 19/4
text [4] 17/14 74/6
110/12 152/4
than [27] 2/9 11/21
23/16 25/10 26/13
33/7 44/17 45/7 45/19
47/4 47/22 55/7 55/15)
57/17 58/11 61/24
63/8 83/16 93/15
108/22 115/23 125/20
137/11 171/9 179/16
186/22 198/3
thank [58] 1/4 1/14
30/22 33/2 33/9 56/25)
124/22 135/12 143/20
163/13 163/14 163/24
167/12 177/23 178/19}
195/13 196/16 202/25
1/21 2/13 2/20 4/6
5/16 21/17 22/22 45/3
50/22 53/7 53/11
53/12 53/17 53/18
54/17 90/19 91/2 91/3,
94/2 103/3 104/8
106/17 109/13 112/16}
113/24 114/3 114/4
129/12 138/19 147/11
151/20 156/18 157/5
161/9 164/3 164/8
164/13 164/20 184/1
184/2 184/3 195/21
200/9 200/10 200/15
205/8 210/7 210/8
210/9 210/12 210/16
210/20 210/21
Thanks [1] 141/9
that [1162]
that I [3] 11/2 90/13
193/23
that's [89] 3/6 3/20
4/2 5/23 11/11 14/9
16/6 16/17 20/16
25/25 26/18 27/8
27/24 31/9 32/7 34/11
36/7 36/21 39/14
42/17 44/21 44/23
47/5 57/19 65/1 65/6
71/8 72/6 76/12 77/2
78/8 79/15 79/22 80/5
81/5 84/4 92/13 92/15
92/18 92/19 95/22
96/1 104/2 107/9
107/17 108/4 109/20
4114/4 111/11 113/49
117/4 119/5 119/5
123/1 123/18 124/21
125/5 125/7 130/16
131/8 132/9 134/19
136/2 137/22 142/14
143/16 152/8 156/17
161/2 162/10 164/1
170/8 171/25 174/24
177/13 178/23 182/5
185/5 187/5 187/19
189/13 189/23 191/19}
193/3 200/12 200/25
205/12 206/9 208/10
theft [21] 19/1 61/19
61/23 62/2 62/2 62/7
62/11 62/19 62/23
62/25 63/3 66/3 66/19
66/22 66/24 67/5
166/16 205/13 205/23}
205/25 206/4
their [25] 18/10 23/3
56/16 63/24 64/13
67/21 72/23 74/14
75/15 106/23 113/6
117/13 122/1 130/5
140/12 140/15 158/14I
158/20 165/4 165/5
114/10 116/18 123/23)
165/5 165/6 168/14
182/12 200/18
them [35] 13/15
17/22 37/5 38/17
43/11 43/15 54/6 73/7)
73/19 74/8 89/8 112/9I
112/11 114/12 115/9
116/1 119/23 120/23
121/22 121/25 122/16
128/7 129/16 130/18
133/21 137/20 148/22)
160/9 171/9 173/9
177/25 179/21 195/17)
197/13 199/17
thematic [1] 55/24
themselves [4] 39/12
47/16 59/15 82/16
then [98] 3/11 6/4
6/23 7/9 8/3 8/24 10/9
14/7 14/11 16/2 17/17
19/8 20/18 21/14
21/23 22/10 22/14
23/1 23/10 26/25 29/9
31/23 37/10 37/22
38/17 41/15 44/5
48/18 52/16 54/11
60/8 61/1 61/16 66/15
67/11 68/22 71/13
71/19 71/25 75/20
80/25 81/4 92/20 98/6
99/23 100/21 102/16
103/3 104/3 105/11
107/24 109/12 112/3
112/6 112/6 113/3
115/21 117/20 118/2
119/15 120/6 126/19
130/16 132/8 133/16
134/6 135/7 135/14
136/1 141/8 145/2
145/7 146/14 149/3
149/15 150/11 152/4
157/4 159/23 159/24
160/18 160/23 161/20)
164/19 178/10 181/24)
189/5 189/19 190/17
191/22 195/9 195/25
196/20 196/22 199/4
199/14 200/25 206/2
theoretical [3] 71/1
71/22 149/23
theoretically [2] 72/1
72/5
theory [2] 70/24
195/3
there [176] 1/10 1/24
3/5 8/10 8/18 8/19
9/15 10/3 11/16 11/21
12/25 13/13 13/18
19/2 19/9 21/16 24/14)
25/4 25/5 25/8 26/6
26/6 28/8 28/15 29/11
30/12 30/13 30/18
30/19 31/7 31/13
31/25 32/8 32/22
(85) swift... - there
T
there... [142] 33/19
35/22 35/22 43/16
46/5 49/12 50/2 51/9
55/3 55/5 55/14 60/11
60/14 61/8 61/8 62/4
62/22 63/19 64/25
65/13 65/15 66/10
66/23 67/3 67/25 68/5
68/7 70/13 70/18
70/24 71/12 71/16
71/22 71/25 74/11
74/19 75/22 76/9 77/9
78/2 80/1 84/8 85/14
85/17 86/2 86/25
87/24 88/3 88/12
88/16 88/17 89/4
89/22 92/1 95/13
95/17 99/16 101/14
104/19 104/23 106/17)
107/12 107/18 108/13)
108/21 110/13 112/6
112/16 113/1 115/5
115/25 117/12 117/14}
118/22 120/3 120/22
122/22 124/9 125/24
129/5 129/23 132/2
132/25 133/15 143/14}
146/6 146/10 146/17
146/20 148/5 148/15
149/9 151/24 153/3
153/17 154/5 155/1
155/3 155/11 155/20
158/16 158/23 158/24
158/24 161/20 162/25}
164/5 165/8 165/17
166/12 167/2 167/3
169/2 170/20 171/3
171/16 171/16 173/16}
175/25 178/18 179/19)
181/10 181/22 181/23
182/2 183/10 183/25
184/14 185/16 186/7
186/22 189/5 189/21
192/21 194/2 194/7
194/12 195/20 199/14}
202/9 203/23 205/20
there's [25] 9/24
13/17 16/2 21/17
37/22 48/10 50/13
75/10 79/16 89/21
92/7 97/24 102/16
107/19 121/16 143/12)
143/17 143/22 160/16)
180/23 181/9 185/25
193/13 206/12 206/13
thereafter [1] 32/18
thereby [1] 158/13
therefore [28] 2/22
6/24 29/1 43/10 51/1
52/10 52/25 57/23
64/1 86/10 86/14 88/8
94/24 98/16 109/17
113/17 115/18 122/17)
138/24 143/10 153/10)
161/15 165/6 177/2
180/9 185/24 186/12
187/6
thereof [1] 75/4
these [70] 16/20
17/24 21/21 23/3
24/11 37/2 43/9 43/17
43/19 44/21 44/23
47/7 48/15 49/4 49/20
50/25 51/9 52/11
55/12 57/10 58/6
59/21 61/5 61/21 64/2
65/9 71/18 76/12
76/16 81/23 86/6
98/21 99/25 102/23
104/23 106/13 107/1
117/5 118/5 121/7
122/4 122/7 127/23
132/9 132/14 132/18
132/25 133/2 133/13
134/17 137/14 137/20)
138/1 160/6 160/12
163/10 163/21 167/6
169/11 169/22 170/4
171/11 173/2 173/9
177/11 189/1 190/25
196/21 198/11 203/17)
they [72] 2/19 17/21
18/8 21/14 25/8 35/7
36/6 36/24 38/3 39/12
41/21 43/22 47/2
47/13 56/1 56/2 57/12
58/22 61/12 61/13
63/11 63/11 63/25
64/22 67/7 67/15 68/3
69/1 69/6 74/4 74/5
81/23 84/1 93/3 93/9
93/12 93/13 108/20
108/24 109/10 109/11
112/18 116/5 117/24
121/21 121/22 122/6
123/19 123/20 128/22)
128/23 132/20 135/4
138/15 142/20 142/21
142/22 151/17 154/5
165/6 165/22 169/2
169/25 173/14 175/9
177/4 179/2 182/11
182/23 183/6 207/18
208/6
they'd [1] 119/23
they're [12] 31/8 31/8
39/23 41/20 55/14
55/15 58/21 74/6
128/21 132/8 134/19
138/19
thing [47] 5/6 16/17
23/19 24/4 24/5 31/10
39/21 57/10 66/7
71/11 73/12 73/16
77/3 81/10 84/18
98/25 104/12 108/15
110/18 111/13 122/17I
123/8 129/11 134/11
134/18 135/12 137/15]
146/24 150/25 155/5
156/9 156/13 163/4
167/15 167/24 169/8
169/17 169/18 170/14
178/16 178/21 179/24
180/7 197/14 203/19
204/19 208/25
things [67] 7/21 7/24
12/12 15/22 16/5 21/6
25/9 25/10 26/12 31/2
36/3 36/12 39/15
41/21 46/24 49/12
50/3 50/16 53/3 57/7
65/9 78/6 83/2 84/21
87/9 89/19 100/3
100/4 104/23 105/19
108/1 119/25 121/4
121/10 121/14 123/13
127/23 128/9 135/5
135/5 142/10 150/22
151/11 152/18 153/25)
154/7 159/12 160/2
160/6 162/19 163/10
163/20 163/21 164/1
169/2 169/6 169/23
175/21 187/18 189/8
193/12 194/7 195/4
199/25 202/11 202/12)
208/21
think [263]
think's [2] 95/10
142/8
thinking [1] 162/12
thinks [1] 183/23
third [7] 7/9 74/17
104/14 137/13 191/23
192/14 205/24
this [438]
Thompson [3] 6/1
15/17 107/24
thorough [2] 17/25
23/5
thoroughness [1] 7/4I
those [39] 28/11
29/14 30/5 32/5 36/9
52/6 57/7 61/13 62/24
67/1 67/14 67/17
72/16 73/5 75/5 83/2
87/17 100/17 109/3
113/7 118/16 118/18
119/16 135/5 136/18
137/8 139/2 140/2
144/11 158/5 158/19
164/6 172/2 173/8
178/3 179/8 195/12
199/5 201/10
though [3] 76/18
172/2 207/22
thought [17] 7/19
12/20 40/4 82/18
88/10 108/6 111/22
115/9 128/11 128/14
138/9 138/12 155/17
184/21 185/7 197/16
201/13
thousands [2] 25/4
26/21
threatened [2]
124/10 129/18
threatening [1]
188/20
three [13] 6/8 17/14
22/23 27/18 28/15
57/1 132/10 132/11
191/24 202/17 203/9
204/8 204/20
threshold [1] 139/22
through [28] 1/12
17/6 24/15 28/12 31/3}
55/23 59/6 73/15 97/9
97/11 98/18 100/4
112/11 112/14 127/11
130/8 130/13 144/9
153/19 167/3 167/4
167/11 167/17 167/18}
168/4 178/14 178/16
203/12
throughout [5] 18/17
72/20 73/3 121/24
175/6
throw [1] 40/7
Thursday [2] 126/20
136/3
tight [1] 81/22
tightly [1] 81/22
Tim [48] 1/5 6/17 7/1
14/1 15/20 15/21
15/23 17/13 34/23
35/2 35/5 37/9 37/11
37/14 37/15 37/24
38/2 38/8 42/23 54/12,
78/23 85/7 91/24 92/6}
94/14 94/18 95/8
100/23 106/22 108/6
120/14 130/7 130/19
132/11 132/15 132/16}
132/25 133/11 133/12
134/10 134/10 136/10}
136/10 145/4 161/10
164/3 176/20 191/25
Tim's [1] 177/24
time [149] 3/7 4/18
6/13 7/25 8/25 11/3
13/7 25/11 25/12
26/23 30/8 30/10
30/16 30/23 31/21
32/10 33/11 40/3
41/25 44/18 44/22
45/13 49/11 49/13
49/15 50/3 50/17
52/15 52/19 53/4 57/8
58/14 60/14 63/12
65/8 67/3 69/13 71/9
73/7 73/16 77/7 77/21
78/12 80/13 81/1 82/5
83/2 83/15 84/7 85/3
88/3 88/11 88/21
89/17 92/10 95/1 95/2I
98/9 101/9 103/18
105/4 105/15 105/16
105/19 105/25 106/2
106/5 106/5 106/7
106/13 109/7 109/9
1413/1 113/10 118/22
119/6 120/18 122/18
123/14 127/4 127/24
128/10 128/25 129/9
130/11 132/16 132/16)
142/13 144/4 150/10
152/20 152/22 152/24)
153/5 160/6 160/8
163/7 163/14 163/22
170/15 172/11 173/1
175/4 175/7 175/8
175/8 175/18 176/3
176/7 178/4 178/8
178/9 180/22 183/24
184/10 186/7 187/16
191/10 192/9 192/12
192/22 195/14 196/4
197/21 197/22 197/25)
198/1 198/4 198/9
198/12 198/14 199/24)
202/8 202/23 203/5
203/8 203/15 204/11
204/17 205/3 206/16
206/18 206/24 207/9
207/13 208/18 208/22I
209/8 210/1
times [4] 57/1 145/11
189/13 209/13
timescale [1] 33/1
timetable [3] 118/24
132/15 149/9
timing [1] 196/3
TIMOTHY [3] 1/7
1/20 211/2
tinge [1] 180/15
tired [1] 171/7
today [20] 1/10 3/14
6/15 14/9 85/8 97/15
101/15 124/3 150/5
150/22 151/23 160/4
168/18 171/1 179/11
180/1 199/20 207/5
209/13 210/14
together [9] 52/7
57/9 59/1 75/19 75/21
148/18 164/22 170/2
178/17
told [31] 11/4 11/12
17/6 20/4 24/13 27/3
27/15 57/3 57/25
67/20 68/1 79/20
81/17 81/19 84/2
90/10 101/14 102/3
107/21 110/22 124/9
124/12 124/16 156/19)
161/6 183/14 185/8
(86) there... - told
T
told... [4] 203/5 204/6
208/22 208/22
Tolhurst [3] 152/1
152/18 153/1
Tom [12] 91/11 95/4
139/12 144/23 146/5
147/5 147/14 152/1
152/21 153/7 153/13
182/24
tomorrow [1] 35/2
tone [2] 145/14
145/18
Tony [5] 124/24
126/5 129/20 131/20
135/19
too [9] 3/6 46/18
61/23 99/4 156/9
159/23 159/24 168/6
170/11
took [27] 3/4 4/8 5/16
6/8 12/8 58/3 58/5
71/3 72/7 80/4 81/20
83/3 88/25 92/5
103/19 104/10 106/5
111/14 127/4 127/16
128/10 144/22 161/25
188/18 199/17 202/19}
208/18
tools [2] 183/8
183/16
top [9] 71/18 118/20
120/6 126/19 131/22
163/9 173/11 191/25
192/14
topic [6] 44/5 89/16
138/21 156/19 170/19
186/15
topics [1] 139/5
totality [1] 24/6
totally [1] 167/15
touched [1] 184/15
touching [2] 127/9
129/4
tough [1] 180/7
toying [1] 171/1
TP [4] 40/22 41/12
108/4 152/8
track [2] 17/6 66/11
traction [1] 62/16
train [1] 99/22
transaction [9] 68/6
68/12 68/17 69/18
70/2 70/5 70/10 72/13,
74/22
transactions [10]
18/2 23/24 24/1 25/3
67/24 70/3 72/20
73/20 192/3 192/17
transcript [2] 62/6
148/20
Transformation [1]
10/14
translated [1] 66/5
trawl [2] 176/10
182/11
Treasury [2] 48/2
48/8
treated [1] 18/9
treatment [2] 88/6
145/13
trial [16] 62/6 140/4
140/5 140/16 141/5
145/15 148/20 149/12)
149/13 149/17 149/25)
152/23 154/2 159/18
159/18 169/5
trials [7] 99/3 140/9
152/11 159/17 172/10}
173/12 183/3
Tribunal [1] 3/25
trick [1] 137/21
tricky [1] 150/1
tried [13] 21/5 170/16
172/12 172/17 175/16)
177/10 178/15 180/13)
188/22 189/11 197/7
197/11 203/18
trigger [2] 55/10 56/1
trimmed [2] 119/8
120/1
true [6] 2/17 93/9
96/23 119/5 138/13
191/18
truly [2] 108/20
123/11
trust [4] 3/18 191/14
198/7 205/5
trusted [1] 179/9
trustworthy [1] 39/23)
truth [4] 179/15
try [10] 7/25 8/20
46/14 71/1 163/20
163/25 170/6 178/22
182/11 206/25
trying [41] 7/23 26/18]
29/20 30/23 46/2 50/2
83/19 100/13 113/22
140/20 142/1 151/10
154/11 154/12 155/5
163/8 165/4 165/10
166/23 167/5 167/9
167/16 168/25 170/9
171/15 172/1 172/5
173/9 176/2 178/5
178/24 179/3 180/4
180/6 181/17 181/19
182/23 183/13 185/20)
194/25 208/24
Tuesday [7] 85/10
147/16 147/20 184/20)
210/17 210/20 210/24;
turn [15] 1/24 9/9
19/12 27/16 30/2 34/1
66/9 67/11 72/8 78/21
114/11 138/21 145/2
200/23 201/5
turned [7] 5/12 7/21
16/15 71/24 83/5
166/25 187/23
Turning [1] 204/19
turnover [1] 4/9
turns [3] 44/5 73/13
81/11
twice [1] 138/5
two [34] 6/15 15/9
22/11 31/23 32/14
35/23 36/3 36/12
39/15 42/24 44/14
56/14 61/6 73/5 74/14
88/17 105/12 109/3
113/3 122/9 132/18
147/9 155/6 155/20
156/10 156/14 161/22
182/1 182/2 189/8
195/19 202/11 205/4
208/13
type [7] 44/19 56/13
69/1 123/8 138/10
187/15 198/5
typed [1] 87/9
U
UK [1] 184/12
UKGI [6] 80/14 84/20
94/4 146/1 152/1
184/12
UKGI00005361 [1]
13/9
UKGI00006482 [1]
107/22
UKGI00011785 [1]
91/10
UKGI00012703 [1]
94/2
UKGI00017966 [1]
161/9
UKGI00019313 [1]
100/16
UKGI00019884 [1]
5/22
UKG100042677 [1]
o/
ultimate [2] 99/3
200/5
ultimately [10] 22/16
29/23 37/3 45/4 97/8
97/19 176/4 185/25
186/19 205/11
Um [2] 123/21 191/15
unable [2] 10/8 10/18
unaware [1] 93/9
uncertain [1] 86/10
unclear [1] 37/11
uncooperative [2]
141/12 142/5
uncorrected [1]
74/22
uncovered [1] 76/8
uncovering [1] 127/2
under [22] 4/9 38/10
40/22 43/5 52/8 85/22)
93/25 102/18 110/16
112/2 112/16 122/5
126/11 132/16 135/23
155/13 155/21 156/4
156/7 156/15 176/14
191/25
underhand [1] 128/8
underlined [2] 17/25
23/7
underlying [1] 47/17
undermine [2] 66/19
183/1
undermined [2]
66/25 158/4
undermines [2]
43/20 158/1
underneath [1] 9/10
underpinning [1]
129/6
underpins [1] 110/7
underplays [1]
107/16
Undersecretary [1]
153/4
understand [42]
12/10 15/15 35/22
41/22 41/25 49/3
61/22 62/4 71/1 73/7
81/7 82/10 82/14
82/14 87/4 87/15 90/7
93/21 99/21 101/4
101/9 105/21 106/6
111/17 112/24 118/11
121/22 128/22 139/12
152/15 155/11 155/12)
177IT 177/19 177/22
180/13 187/18 193/1
194/20 194/22 197/24]
199/7
understanding [13]
37/12 70/12 78/1
80/13 81/25 82/13
83/11 84/12 93/1
93/22 115/16 116/9
154/20
understood [13]
47/25 77/19 77/21
77/22 78/10 78/15
80/25 87/7 108/14
111/17 115/8 125/9
187/12
undertake [3] 45/21
112/18 131/14
undertaken [13]
35/15 35/20 51/24
60/6 68/18 79/10
109/22 110/3 118/4
124/6 126/8 126/11
135/22
undertaking [5]
58/10 58/10 64/13
127/7 127/10
Underwood [2] 34/13
120/8
undivided [1] 53/4
undue [1] 206/6
unease [4] 150/20
151/15 154/16 154/20)
uneasy [1] 151/14
unexplained [1]
67/23
unfair [2] 96/8 181/2
unfair/disproportional
te [1] 96/8
unfairly [1] 18/9
unfairness [1] 149/3
unfairness’ [1]
149/18
unfolded [1] 65/19
unfortunate [1] 83/4
unfortunately [3]
82/9 99/2 173/15
uniquely [1] 208/13
United [1] 147/24
universally [1] 65/4
unjustifiably [1]
64/18
unknown [1] 132/20
unless [7] 35/7 36/6
130/9 130/13 150/3
174/8 206/16
unlikely [1] 72/3
unmatched [3] 74/16
74/20 75/2
unnecessary [1]
137/6
unpleasant [2] 95/19
134/8
unreasonable [2]
49/14 174/25
unreliable [1] 98/4
unremarkable [1]
198/24
unreservedly [1]
174/16
unresolved [2] 29/11
29/14
unsafe [2] 23/9 174/5I
unsatisfactory [8]
81/10 167/23 169/19
171/25 178/1 179/20
180/15 200/5
unseat [1] 168/10
unsuccessful [1]
149/15
until [18] 3/1 3/11
3/13 4/1 15/14 25/22
43/11 44/10 90/21
113/25 121/23 156/5
156/25 160/11 167/7
172/18 181/13 210/23}
unusual [5] 29/17
29/19 67/23 68/20
205/14
up [87] 1/24 5/12
5/16 7/2 7/6 14/7 15/4)
15/16 15/25 16/15
(87) told... - up
U
up... [77] 18/12 19/6
19/17 20/18 21/10
25/19 25/20 27/21
29/18 30/2 40/17
40/17 40/19 40/20
45/13 47/22 50/6 52/2)
53/8 54/13 59/20 60/2
66/4 71/21 78/21 86/6
92/3 92/24 93/14
93/17 93/18 94/20
94/24 95/7 98/2
105/22 115/1 119/7
119/25 128/9 131/13
131/21 136/9 136/23
138/16 145/7 145/20
146/6 151/11 160/8
164/18 164/18 164/19
165/2 166/8 166/12
166/25 167/22 168/21
169/3 171/2 172/11
173/25 180/20 180/21
181/16 189/22 190/8
190/23 196/1 196/12
199/20 200/1 200/23
201/6 204/8 205/6
up' [1] 68/10
upcoming [2] 13/17
14/19
update [7] 44/3 94/8
109/21 110/6 116/20
116/22 145/17
updated [1] 108/4
updates [2] 86/13
86/15
uploaded [1] 2/21
upon [11] 9/21 32/17
33/10 74/1 122/11
155/19 158/7 158/10
174/16 179/9 205/19
upside [1] 172/13
urgently [3] 76/10
148/10 152/16
URN [1] 1/22
us [43] 1/3 1/18 1/22
4/6 19/21 46/13 53/16
53/24 54/21 54/22
60/4 63/22 64/2 65/14)
68/1 68/3 69/16 91/1
91/19 101/14 102/9
114/8 126/20 130/17
130/21 131/5 131/18
131/20 145/11 145/12)
151/3 154/12 154/13
155/17 156/19 164/12
170/7 182/25 184/18
194/1 194/14 196/3
198/24
use [12] 12/7 32/18
32/23 72/19 72/23
73/1 120/1 137/5
157/13 179/6 187/17
191/24
used [16] 16/7 17/20
18/3 20/16 23/24
46/16 46/24 135/7
135/7 145/11 157/9
166/5 192/3 192/5
192/17 192/19
useful [1] 69/8
users [1] 199/1
using [2] 129/18
141/18
usual [3] 1/11 29/25
189/9
usually [5] 7/17 8/7
8/14 20/5 154/13
utter [1] 56/9
Vv
vaguely [1] 25/5
value [5] 11/7 119/22
122/24 123/2 128/11
van [1] 61/14
various [6] 37/3 43/5
52/6 125/3 141/3
143/14
varying [1] 5/10
vast [1] 18/4
vehicle [1] 146/14
Vennells [14] 9/13
9/25 11/3 11/14 13/23
29/9 42/21 44/9 93/4
103/17 106/15 145/24}
146/8 187/13
Vennells' [1] 27/15
verbal [2] 86/1 88/1
version [3] 59/2
82/25 119/2
very [84] 1/4 2/13
2/20 2/20 4/13 4/18
5/11 6/19 7/15 7/20
8/6 8/13 8/18 12/8
14/20 15/6 18/7 18/8
18/18 18/25 20/12
21/2 21/7 24/8 27/9
29/19 31/8 38/23
41/20 42/6 46/15
50/14 53/5 53/11
53/18 56/11 56/24
72/2 7712 81/22 96/2
97/21 99/1 104/10
106/4 114/3 114/10
120/10 123/21 127/14)
127/16 127/22 128/16)
128/18 134/20 138/19)
138/22 139/1 139/22
148/22 151/6 153/25
156/10 156/10 156/14)
156/18 162/13 163/1
164/3 164/8 168/9
170/18 171/11 176/13}
176/17 177/25 179/20)
191/10 191/12 195/21
198/11 209/1 210/14
210/20
vested [3] 83/19
83/19 90/12
via [1] 20/15
victimisation [1]
174/16
view [61] 4/6 10/23
11/13 12/3 12/4 12/8
12/8 14/25 15/9 15/14
23/11 23/18 24/19
39/2 39/23 41/2 44/11
44/24 46/1 47/20 59/2
60/11 61/18 64/7
65/18 68/9 69/7 76/25
77/24 81/5 82/5 89/20
96/5 97/15 98/14
98/25 100/11 107/10
113/7 114/13 117/17
119/23 124/3 127/25
128/2 128/24 132/9
132/9 133/5 134/11
137/22 137/23 151/11
153/21 153/22 154/4
156/6 172/3 172/9
173/21 175/10
viewed [1] 176/4
views [9] 6/25 11/8
12/11 12/23 13/14
30/9 63/24 69/11
147/25
virtually [3] 154/2
169/15 177/16
volume [2] 38/8
139/1
Ww
wag [1] 170/13
wagging [1] 170/13
wait [3] 60/8 156/5
164/14
waiting [1] 181/13
waive [2] 89/8 89/11
waived [1] 149/7
waiver [1] 89/22
waiving [1] 133/14
walked [1] 11/25
wall [4] 160/9 160/10
178/24 179/7
want [37] 13/14
20/25 40/11 40/13
46/8 52/2 65/16 66/8
84/2 94/6 96/22
120/20 120/24 129/15}
136/5 152/12 154/10
154/22 156/9 164/24
168/8 169/14 181/1
181/3 186/25 197/3
197/4 200/22 200/23
200/24 201/3 201/23
202/11 204/22 205/2
205/4 205/7
wanted [10] 35/25
40/18 55/12 80/24
135/11 152/25 182/7
188/4 204/19 206/18
wanting [3] 60/10
140/11 143/7
wants [6] 28/21 35/8
36/6 37/15 41/3 41/13)
Warmington [4] 54/4
54/8 55/19 57/6
wary [1] 23/15
was [575]
wasn't [34] 7/20 15/5
16/1 26/22 33/20 65/7,
65/13 76/4 88/21
97/17 102/1 108/2
108/13 109/5 115/25
116/8 119/18 126/24
127/5 129/25 131/19
131/25 132/1 135/10
135/10 136/21 137/24
162/25 175/25 178/9
181/15 199/18 203/13}
208/20
wasteful [1] 132/19
way [51] 20/16 24/21
32/25 41/16 42/13
42/14 49/10 52/1 65/6
66/10 69/15 82/24
83/7 83/13 98/3 98/19)
100/1 100/1 103/22
107/12 121/19 126/22,
127/12 132/2 134/12
137/20 138/5 138/18
147/5 150/14 150/20
151/2 151/2 151/6
155/14 164/25 165/5
165/8 167/1 171/17
171/17 177/1 180/19
186/14 188/13 197/16
197/20 199/3 201/18
205/19 208/10
we [358]
we'd [3] 52/3 98/1
181/19
we'll [11] 16/21 47/13}
48/11 57/10 59/9
70/25 71/10 88/1
97/17 98/18 166/8
we're [20] 1/11 11/1
17/6 36/2 45/20 49/18
57/8 80/16 91/9 92/1
93/6 100/4 123/25
127/13 129/4 136/11
139/9 189/21 199/9
204/14
we've [14] 24/18
24/22 24/24 60/8 67/9
98/7 98/8 98/9 100/18)
126/4 178/25 181/20
193/23 203/21
weakened [1] 149/7
website [1] 2/22
Wednesday [1] 1/1
week [10] 47/10
91/18 105/2 105/7
106/24 124/2 125/12
139/13 147/21 184/19}
weeks [2] 20/25
27119
welcome [1] 21/2
welcomed [1] 102/23
well [92] 7/14 11/8
12/10 12/20 23/22
24/19 25/12 26/2
36/14 40/12 41/23
42/10 44/21 45/16
50/15 50/20 52/20
53/5 57/13 62/13
64/24 65/16 75/17
77/21 79/9 84/4 87/6
93/11 95/23 102/21
103/1 103/8 122/3
122/7 125/16 125/25
127/24 131/7 134/15
141/16 141/17 144/4
144/23 145/10 147/5
152/20 153/24 159/8
160/2 162/14 165/22
165/24 166/7 166/8
167/8 167/16 168/1
168/17 169/6 171/6
173/19 174/14 175/1
175/14 176/11 176/12)
176/15 178/3 181/20
181/25 182/21 183/14I
184/23 185/8 185/18
188/10 191/3 191/13
191/20 191/22 192/14)
193/10 196/19 203/11
203/18 204/10 207/18)
208/7 208/14 208/24
210/12 210/20
well-qualified [1]
53/5
went [15] 16/14
21/25 25/19 25/20
42/17 55/3 55/7 55/23
70/13 116/11 121/25
125/5 127/1 135/14
202/10
were [218]
were/are [1] 118/12
weren't [6] 131/13
135/9 144/2 172/8
175/22 178/3
Westminster [1]
69/24
what [215]
what's [11] 51/16
97/20 121/9 128/22
151/21 175/16 177/20}
181/25 183/13 188/4
207/22
whatever [22] 12/23
24/7 24/20 24/23
24/25 36/23 40/11
60/14 77/17 79/19
83/20 98/19 106/7
108/13 108/18 138/10)
155/18 163/24 165/23)
177/12 185/21 185/22)
when [71] 4/8 5/12
(88) up... - when
Ww
when... [69] 8/22
10/24 11/7 11/25 12/9)
13/3 13/25 14/2 15/22
21/3 25/16 26/5 27/10
29/17 30/4 32/8 32/22
33/2 39/10 40/20
45/20 47/25 59/1 60/6)
64/13 64/22 67/17
67/21 70/13 76/24
78/4 79/3 81/3 95/4
103/8 104/25 105/5
121/7 127/23 140/3
140/15 157/2 159/6
159/9 159/16 160/3
162/8 165/19 165/25
166/7 166/24 166/25
170/4 170/14 170/20
171/23 172/2 172/12
173/6 176/13 177/10
177/17 180/7 181/13
184/14 188/17 196/16
207/13 207/13
where [51] 18/22
18/25 19/2 19/6 21/25)
25/23 30/20 31/12
33/3 42/17 50/17 58/7
58/14 66/20 68/12
72/3 72/4 74/19 75/15)
100/13 102/7 106/25
116/7 121/1 133/15
136/23 143/13 145/20)
151/24 153/13 153/24
155/17 158/5 158/24
158/24 159/2 160/2
169/16 173/20 174/3
179/23 181/16 181/18
183/4 185/14 188/9
188/10 193/5 193/5
196/1 198/21
whereas [1] 36/9
whereby [1] 184/21
whether [80] 8/3 11/9)
12/7 12/8 16/14 32/10}
42/4 42/5 43/15 45/25)
46/10 48/13 49/2
54/22 59/24 61/4
62/10 63/3 63/24
66/18 67/2 67/25
72/14 73/18 73/23
76/1 77/18 78/14 79/5
85/14 86/11 86/17
86/18 89/4 90/16
95/22 111/12 111/17
111/18 114/13 115/6
417/17 118/2 118/18
119/16 121/18 124/16}
124/19 125/2 126/8
128/20 137/1 140/6
141/19 144/7 144/8
145/17 147/17 147/25}
148/2 148/5 148/10
153/11 153/22 156/6
163/5 165/20 166/12
194/19 195/1 195/2
203/1 203/2 203/23
204/16 209/1 209/6
which [165] 1/22
2/14 4/10 4/22 5/9
9/25 12/17 14/15
14/20 15/23 16/3
17/22 18/18 19/11
20/5 22/1 22/5 23/14
25/10 26/21 27/8
28/17 33/11 37/5
37/20 39/16 42/25
44/6 50/24 51/4 51/17
51/21 51/23 52/16
56/21 57/14 59/7
61/23 62/5 62/7 63/19
64/9 64/11 66/2 66/22
66/22 67/13 67/19
67/19 67/24 68/8
68/21 68/22 69/7 70/7
72/15 74/11 74/12
75/5 79/11 79/16
81/16 83/5 84/1 86/5
91/9 91/18 91/23
91/24 95/17 97/5 97/9
98/6 98/10 100/25
104/10 108/1 109/4
109/5 110/7 110/13
111/14 111/24 113/18)
114/18 114/24 115/23
116/1 116/4 117/8
121/1 121/8 123/3
123/10 124/6 124/17
127/14 128/17 133/23
136/24 138/1 139/20
140/5 140/7 140/8
140/21 1441/1 142/3
142/17 146/9 146/10
146/18 147/3 148/7
148/11 148/23 148/25)
149/18 149/25 150/1
150/22 152/9 153/19
157/6 158/1 158/12
159/21 161/16 161/23
161/24 162/2 163/1
163/17 165/10 166/4
167/21 171/13 174/11
1777 177/18 178/13
180/14 180/20 180/22!
180/24 181/11 184/12!
187/11 189/6 191/2
191/3 191/13 192/13
194/9 195/2 196/1
196/6 198/25 199/21
200/3 202/20 204/22
205/19 206/5 208/18
while [6] 6/19 42/24
96/6 102/13 102/17
140/12
whilst [7] 82/4
146/11 177/23 179/14I
194/9 197/7 199/18
178/11 185/16 185/24;
white [1] 174/10
whitewash [1] 35/20
who [79] 6/1 6/12
12/15 15/14 17/19
22/5 24/1 24/5 24/6
24/25 27/1 33/22 39/7
39/19 39/24 46/9
46/16 46/24 46/25
47/16 50/5 51/6 53/1
56/14 75/14 78/2 78/6
78/16 81/7 81/14
81/24 82/16 88/12
89/7 89/20 91/11
91/12 92/11 99/6
106/5 114/13 115/4
115/5 120/10 124/9
125/6 127/18 128/6
128/12 128/16 129/8
130/1 131/17 138/6
142/4 144/14 146/24
147/6 147/22 165/2
168/3 171/18 171/23
172/4 172/7 172/8
173/1 177/3 177/14
179/9 180/9 188/24
188/25 197/11 200/17)
200/19 208/7 209/2
209/5
who'd [1] 189/4
who's [1] 27/14
whoever [2] 20/22
38/24
whole [22] 23/19
70/22 81/10 84/6
84/25 98/25 101/22
128/7 160/7 163/4
163/9 163/17 163/18
169/20 185/23 188/13}
188/21 189/9 196/11
206/13 206/14 206/23
wholly [1] 129/7
whom [7] 19/11
61/13 76/21 76/25
156/14 158/17 204/3
whose [1] 114/23
why [26] 43/16 45/6
46/3 79/22 106/8
109/2 109/3 114/18
119/9 130/19 130/25
131/20 132/11 142/14
142/25 152/17 153/22
157/21 165/6 167/8
172/14 178/10 193/18}
205/21 207/17 208/10
wide [3] 4/14 54/2
75/22
widely [1] 77/25
wider [5] 68/1 68/22
69/19 111/6 129/3
will [61] 2/21 13/22
14/13 19/20 20/25
28/15 29/4 35/6 35/13)
35/19 36/5 37/8 37/14
43/13 43/23 44/3
50/23 52/3 52/16
59/11 64/4 65/20 86/6
86/10 86/13 86/14
86/16 97/9 106/25
111/4 118/22 120/3
125/11 126/16 126/17]
132/13 132/14 132/17]
136/13 137/22 140/1
140/3 140/5 140/8
146/11 148/20 149/17]
149/25 152/9 172/21
174/2 176/11 177/19
179/10 180/20 181/12}
184/9 184/19 185/20
199/2 210/17
Williams [8] 34/3
39/11 47/14 120/9
136/4 183/7 183/15
183/21
ig [1] 112/1
willingness [1] 8/1
win [3] 156/2 168/25
169/14
wisdom [1] 166/19
wish [4] 82/24 110/6
149/2 178/10
wished [1] 156/2
wishes [1] 20/15
withdraw [1] 44/2
within [23] 6/1 13/13
13/22 30/13 30/19
31/24 34/8 47/10
52/15 55/14 72/13
73/2 73/19 75/7 79/23}
90/2 94/4 122/18
122/19 132/3 160/24
163/16 172/21
without [16] 18/4
40/24 60/10 70/6
99/18 99/24 99/24
113/23 131/8 131/11
131/12 133/14 143/6
163/11 169/14 181/8
WITN00690100 [1]
1/23
WITN10010100 [1]
78/21
witness [25] 1/21
2/17 2/20 30/2 32/20
32/24 47/21 48/6
78/20 79/15 103/15
110/24 138/23 138/25
139/18 158/3 158/6
201/4 201/6 201/9
201/25 202/2 202/5
202/14 210/13
woman [1] 178/11
Womble [1] 21/13
won't [1] 102/9
wondered [1] 27/14
wondering [1] 188/9
wool [1] 179/17
word [8] 2/6 2/7
23/17 93/14 97/20
145/11 184/20 187/17
words [8] 48/23
55/21 56/15 126/17
134/3 142/17 168/14
186/25
work [68] 2/3 10/18
12/1 35/19 46/20 52/3)
53/6 57/14 58/2 61/8
66/6 68/23 69/6 71/25
75/23 76/3 76/4 77/23}
79/10 86/9 86/11
86/11 86/14 86/16
92/24 93/15 93/17
93/18 93/25 94/20
94/24 97/9 101/4
109/22 110/3 110/4
110/7 111/4 111/23
112/18 112/23 113/1
113/8 115/19 117/9
117/22 117/24 117/25]
118/7 118/19 119/3
120/18 120/19 122/24)
123/2 126/8 126/10
126/13 126/23 133/1
133/8 134/1 134/5
135/22 163/7 163/20
168/5 201/22
worked [4] 31/6 48/2
81/24 184/7
working [10] 10/6
12/13 29/7 43/8 105/1
105/1 121/21 173/1
192/5 192/19
workload [2] 38/23
163/22
works [2] 125/3
199/3
world [3] 46/20
121/20 175/15
worlds [1] 175/15
worried [1] 152/25
worry [1] 141/13
worrying [1] 10/15
worse [2] 56/10
181/12
worth [5] 17/23 87/20)
123/15 145/6 185/8
worthy [1] 74/24
would [192] 2/10
5/20 6/17 6/20 6/21
6/24 7/21 7/23 8/4
8/18 8/19 10/25 11/4
14/2 14/4 14/6 15/2
15/8 15/10 15/22
15/24 16/10 17/17
18/24 19/25 20/3
20/22 21/6 21/6 22/4
23/11 24/8 24/12
26/10 26/12 27/1 27/6I
27/9 31/14 31/20
31/24 33/17 33/18
36/9 36/22 38/23 39/1
40/1 42/12 43/22
44/18 44/21 44/25
(89) when... - would
Ww
would... [139] 46/23
50/11 51/18 52/17
52/20 53/1 56/11
56/24 57/2 57/3 57/7
57/11 57/13 57/16
57/21 57/23 58/15
62/3 64/3 64/20 66/8
68/7 68/16 69/1 69/12
74/21 75/22 76/6 77/4
77/6 77/7 77/23 78/5
78/11 79/5 81/1 81/2
81/4 81/21 82/7 82/8
82/16 83/14 84/7
86/18 93/10 95/15
96/2 96/7 96/17 98/6
98/14 100/5 100/9
100/11 104/6 106/3
106/4 108/9 108/18
113/18 116/10 119/21
120/15 121/4 121/5
122/6 122/13 122/14
124/4 125/14 127/19
129/5 130/20 131/1
132/19 133/2 133/8
134/5 134/12 135/2
137/4 141/22 144/9
147/7 148/15 150/9
150/22 150/25 153/19
153/20 154/5 154/15
155/4 159/16 159/20
164/1 165/6 165/9
165/15 168/13 168/15
169/2 169/12 171/5
171/22 172/24 173/5
174/21 174/22 174/24)
175/9 175/11 175/16
177/5 178/10 179/17
180/12 182/3 182/25
189/2 191/18 191/20
194/4 194/5 194/14
200/1 201/10 201/13
201/20 203/1 203/9
203/15 204/8 204/13
206/19 206/22 207/14
209/23
wouldn't [12] 22/3
22/4 46/20 46/22
47/15 59/7 74/1 90/2
161/5 175/7 178/7
207/15
wrists [1] 104/21
write [3] 110/1
113/14 123/10
writes [2] 126/3
182/21
writing [7] 27/21
37/12 78/13 78/14
86/18 96/10 113/11
written [10] 28/4 87/9)
102/4 113/20 123/12
123/16 157/8 166/7
171/21 173/22
wrong [15] 14/11
77/22 79/20 95/9
95/21 95/22 95/23
98/1 99/1 128/5 143/8
144/4 151/18 154/17
163/18
wrongdoing [3] 19/3
19/16 190/20
wronged [1] 129/8
wrongly [6] 41/7
71/24 106/1 121/2
129/3 199/18
wrongs [2] 179/21
179/22
wrote [1] 123/19
Wyn [2] 88/14 154/13
Y
yeah [108] 3/14 4/9
8/6 13/7 27/5 27/5
29/25 31/6 31/17 33/1
40/22 41/11 46/14
47/1 47/11 49/20
55/12 58/17 58/18
60/17 60/19 60/23
65/2 66/14 66/14
67/10 67/10 69/13
73/9 73/16 74/7 74/9
76/10 76/12 76/16
76/17 76/20 80/17
80/22 81/9 82/5 85/24)
86/24 90/7 90/9 91/6
93/23 94/11 94/11
97/2 107/9 107/20
109/8 109/11 111/1
113/20 115/15 120/5
120/5 130/15 131/7
144/12 146/5 159/15
159/15 159/22 159/24)
161/19 162/1 166/10
166/15 177/7 1814/9
185/2 185/2 185/4
185/6 187/5 188/11
189/22 190/2 190/2
190/4 190/6 190/14
190/14 190/22 191/9
191/9 191/11 191/17
196/25 200/21 201/8
201/15 202/1 202/13
202/16 202/18 202/19)
204/1 204/5 204/15
204/21 205/1 206/17
207/7 208/18
year [5] 9/6 25/24
94/3 141/4 147/23
years [23] 3/2 3/16
4/4. 11/1 12/14 12/21
17/14 22/23 24/8
24/12 24/22 28/16
30/23 52/22 56/4 91/5)
95/8 95/15 95/16
123/8 159/11 162/16
167/13
years' [1] 63/6
yellow [1] 195/22
yes [115] 1/4 3/3 3/15,
8/17 13/16 22/7 32/7
33/19 33/24 34/5
34/12 34/20 38/7 39/4
40/11 40/14 46/12
48/9 49/19 49/22
51/17 53/10 53/17
57/22 71/8 71/25 74/5
75/25 76/19 76/23
78/19 80/8 80/10
82/13 84/8 87/6 88/10
89/2 90/22 91/2 93/13
95/19 95/24 100/2
101/16 102/5 102/5
103/13 105/9 105/10
113/16 114/2 114/9
115/11 116/17 116/24
117/4 120/4 125/8
125/10 126/21 126/22)
128/24 131/10 131/19}
131/22 135/24 135/25}
137/16 138/3 141/25
143/6 143/19 145/19
146/16 146/20 150/15}
162/22 164/7 164/13
174/18 174/22 179/17
182/19 182/20 186/18}
186/19 187/21 187/22
187/23 187/24 188/2
188/3 188/6 188/7
188/9 188/16 189/18
189/24 191/1 191/21
192/24 193/7 194/18
196/23 197/23 201/22I
204/12 206/11 207/25}
208/1 208/2 208/3
210/11 210/19
yesterday [3] 14/16
129/22 160/22
yet [2] 161/13 174/7
yielded [1] 76/4
you [1031]
you'd [8] 47/9 67/7
89/6 130/12 202/2
203/5 203/7 203/15
you'll [12] 6/5 6/12
9/5 48/22 73/5 91/11
91/12 120/6 143/12
160/14 160/16 166/12
you're [46] 23/14
24/2 25/21 27/10
27/10 51/15 57/5
76/19 87/24 92/15
93/21 100/8 103/4
109/11 128/19 129/13
143/8 151/10 155/11
165/19 169/7 170/5
171/15 171/19 172/14
177/9 177/22 178/17
178/20 180/13 183/13
186/3 187/3 187/3
188/7 188/7 191/10
191/20 193/1 193/5
193/14 194/2 194/12
196/4 204/11 207/22
you've [29] 1/21
23/25 25/8 31/9 31/11
53/24 90/16 101/14
105/14 138/22 145/23}
146/3 146/4 147/5
160/3 171/23 177/8
178/24 187/6 187/16
187/25 188/14 189/13}
191/3 197/24 198/16
199/19 207/5 209/13
your [165] 1/18 2/14
2/18 2/25 3/15 4/3 4/6)
5/17 5/21 7/11 9/6
9/20 9/21 11/9 12/1
13/11 14/22 14/25
16/17 17/3 20/22 21/2}
27/21 29/2 29/3 29/6
29/11 30/2 33/16 35/2
37/1 39/18 40/19
41/22 43/8 43/12
43/14 43/20 44/11
44/16 45/10 47/21
48/6 48/7 51/24 53/24
54/5 55/16 58/24
76/24 76/24 80/10
84/12 85/9 85/16 89/3,
93/1 93/22 95/11
95/18 96/17 100/19
101/3 101/18 103/6
107/4 107/10 107/14
110/24 111/18 111/18)
112/21 114/13 115/16}
115/25 116/21 117/3
119/21 120/1 120/3
123/6 123/19 125/15
125/19 126/9 126/11
127/25 128/4 128/15
130/18 131/11 135/3
135/23 136/2 138/23
138/25 139/2 145/7
150/16 151/15 152/11
154/8 154/20 154/20
154/21 155/1 159/25
162/15 162/20 163/17,
163/18 166/3 166/17
166/18 167/24 169/1
169/23 169/24 170/2
171/9 171/12 172/9
173/21 174/19 175/6
175/7 176/3 176/23
176/25 177/3 178/25
179/4 179/14 180/22
181/12 183/11 183/19}
186/15 188/12 189/14
191/2 191/2 194/16
194/17 194/23 196/17
197/19 197/22 198/18}
198/20 198/22 200/10)
201/4 201/5 201/6
201/7 201/9 201/23
201/24 201/25 202/2
202/14 204/16 206/24
206/25
yourself [7] 7/12
23/21 174/16 175/24
197/6 199/12 210/5
(90) would... - yourself