INQ00001171 - Transcript (09/07/2024): Post Office Horizon IT Inquiry - Mark Russell [WITN0080] and Robert Swannell [WITN1080]

Evidence on official site

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Tuesday, 9 July 2024

(9.45 am)
MS PRICE: Good morning, sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you very much.

MS PRICE: Can we please call Mr Russell.

MARK FRANCIS RUSSELL (sworn)
Questioned by MS PRICE

MS PRICE: Can you confirm your full name, please,

oP

pProrop

Mr Russell?

Yes, Mark Francis Russell.

As you know, my name is Emma Price and I ask questions
‘on behalf of the Inquiry. Thank you for coming to the
Inquiry today to assist it in its work and for providing

a very detailed witness statement in advance of today.
You should have a hard copy of that statement in

a bundle in front of you at tab 2A; do you have that?
Yes, I do.

Itis dated 13 June 2024. If you could turn to page 101
of that statement, please.

Yes.

Do you have a copy with a visible signature.

Yes.

Is that your signature?

Itis.

I understand you have some minor corrections that you'd
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being explored by the Inquiry.

You explain in your statement that you hold a degree
in economics and management science as well as an MBA;
is that correct?

Correct.

Your career has been predominantly in corporate finance.
The last role that you held before joining the

Shareholder Executive in 2004 was at KPMG; is that
right?

Correct.

You were a Corporate Finance Partner in their London and
Frankfurt offices?

Correct.

When you joined the Shareholder Executive in 2004, is it
right that you did so in the role of Director of

Corporate Finance?

That's right.

At that time, the Shareholder Executive sat within the
Department of Trade and Industry?

It did.

So your employment contract was with the Department of
Trade and Industry?

Correct.

What did your role as Director of Corporate Finance
entail?

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9 July 2024

like to make to the statement; is that right?

Yes, yes, please.

Would you like to tell me what those are?

Yes. So on paragraph 55, where the statement says, "The
annual reviews", and then it gives an example of UKGI
disclosure, it should read "The annual reviews

illustrate this focus and level of detail"; and also in
paragraph 55, where the statement says that the date of
Charles Donald's first witness statement is 6 February
2024, it should read 19 February 2024.

Are those all the corrections you'd like to make?

They are, yeah.

With those corrections made, are the contents of that
statement true to the best of your knowledge and belief?
They are.

For the purposes of the transcript, the reference for

Mr Russell's statement is WITN00800100.

Mr Russell, your witness statement is now in
evidence and will be published on the Inquiry's website
in due course. As such, I will not be asking you about
every aspect of that statement this morning, just about
certain specific issues which are addressed within it.

I would like to start, please, with your
qualifications, professional background and the roles

you have held which are of relevance to the matters
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Well, if I go back to the purpose of the Shareholder
Executive, when it was established in 2002, I think, it
was -- as we stated, it was professionalise Government's
management of its shareholdings, typically its
commercial and economic shareholdings and a number of
those shareholdings eventually were sold, so
shareholdings such as British Energy and Royal Mail.
And that governance role then expanded into the
governance of Government's larger arm’s-length bodies,
not necessarily bodies that would be sold. So there was
a definite change of emphasis.

In 2005, there was a desire, from the centre of
Government, for the Shareholder Executive to expand its
remit into essentially providing a corporate finance
capability to Whitehall, and it was on the back of that
that I was recruited to essentially establish that unit.

The individuals who formed that unit already sat in the
DTI so I basically moved them over into the Shareholder
Executive, and that started the corporate finance
function of Whitehall.

As to what it - what does corporate finance really
mean? It's predominantly, in a Government setting,
about asset realisations and investments. That's -- and
fund-raisings. But I would say predominantly our work

has been about asset realisations and, as I've said in
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my witness statement, I saw the developing focus on what
we would call distressed situations, so private sector
organisations of strategic interest to Government that
potentially could collapse and, where Government might
choose to intervene, we started to engage on those sorts
of situations, more to determine: was there a way of

a private sector solution to avoid Government having to
intervene, but be prepared for Government to intervene.

My sort of first big case of that was MG Rover, and
you may remember that situation. The Government at the
time felt this was a strategic asset but it wasn't
prepared to support it, unless there were ultimately
some private sector investors that would come in. So
the very initial job I did on that was to work out
whether there were going to be some private sector
investors, as the company unfortunately ran out of cash,
and our conclusion was that there weren't going to be
any and so went into insolvency.

That was a very -- that was the first big example of
distressed intervention, which became a particular
feature of the corporate finance part of the Shareholder
Executive, through the late 2000s.

In 2007, you say you were appointed as Deputy Chief
Executive of the Shareholder Executive. Was this in

addition to your role as Director of Corporate Finance?
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You stepped down in 2019 to become Vice Chair and
subsequently a senior adviser for UKGI?
Correct.
\s it right that you are still a senior adviser with
UKGI?
Itis.
But you also hold the role of Chair of the Ministry of
Defence's procurement organisation, Defence Equipment
and Support --
Yes.
-- and Chair of Angel Trains, a privately owned train
rolling stock company --
Correct.
-- as well as to holding a temporary non-executive
position on an arm's-length body of the Department for
Energy Security and Net Zero?
Yeah.
I'd like to turn, please, to Government oversight of,
and responsibility for, Post Office Limited. You
explain at paragraph 12 of your statement that Post
Office Limited is wholly owned by the Government,
operated as an arm's-length body. Can you help, please,
with why an arm’s-length body model might be chosen for
a delivery activity of Government, instead of insourcing
or contracting out the delivery activity?

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Yes, it was.

How did your role change when you took up this
additional responsibility?

To be honest, not significantly. Basically, I was there
to deputise for the Chief Executive, who was then
Stephen Lovegrove, so -- but in terms of the nature of
my work, it didn't change very much. I still -- my main
remit was still the corporate finance part of the
Shareholder Executive.

It was in this role in 2012 that you became involved in
the Royal Mail asset sale process; is that right?
Correct, correct.

Was that the first time you had involvement in Post
Office Limited matters?

Well, in Royal Mail matters, yes. Yes, that's correct.

In February 2013, you were appointed Interim Chief
Executive Officer of the Shareholder Executive; is that
right?

That's right.

In April 2013, you became the Chief Executive Officer?
Correct.

In 2016, when the Shareholder Executive combined with UK
Financial Investments to form UK Government Investments,
you became CEO of UKGI; is that right?

Correct.

Yeah. So there are -- the principal reason you might
have an arm's-length body is if you have an activity,

a -- what I call the specialist delivery activity -

such as the Post Office, such as HS2, such as Network
Rail - a delivery activity that is owned by Government
but would, with difficulty, be managed by Government,
difficulty managing that by Whitehall. So -- and the
reason for that is those sort of activities, they

involve a particular skillset that probably isn't

available within Whitehall.

They also ideally have a governance framework around
it, again, would not be available within the core of
Whitehall.

So if you have that sort of activity, the question
is: is there an alternative to insourcing it? As I say,
the trouble with insourcing it is it isn't always clear
that you can attract the right sort of human capability,
human resource, to be able to do that. It's not clear
that Whitehall itself can provide adequate oversight to
a specialist delivery activity. So the alternative
would be potentially to outsource the activity and,
indeed, that has happened in a number of cases. You
either -- you privatise the activity or you, in some
way, contract with a private sector management team to

manage the organisation. Those are your basic options.
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But the key to specialist delivery is specialist
human resource and the key feature of that is typically

a remuneration regime that, again, you wouldn't -- which
would be incompatible with Whitehall.

So that is one very key reason why you would adopt
the arm's-length body model. The other key reason, as
I say, is one of oversight. If you have a specialist
activity, a specialist delivery activity, then you
really need specialists to hold the executive to
account, and this very much follows the corporate
governance that we see in the private sector. Quite
difficult for individual shareholders to provide that
sort of challenge and oversight. You need specialist
Non-Executive Directors to be able to do that.

So there are various reasons why Government might
adopt an arm's-length body model but the two key
reasons, I would suggest, are to ensure that they can
get the prototype of human resource and capability, and
that often goes to the fact that they need financial
freedoms to be able to do that, and, secondly, adequate
oversight on behalf of the shareholder through the
corporate governance structure of a board.

I mean, a further reason would be arm's-length
bodies can adopt operating flexibilities that just

wouldn't be compatible or available within Whitehall.
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You refer at paragraph 12 of your statement to ALBs
typically being given freedoms to carry out delivery
activities free from operational interference from
Central Government and you explain the rationale behind
this at paragraph 25. If we could have that on screen,
please, it's page 10. Thank you. You say:
"It is not simply a consequence of being a Public
Corporation [and we'll come on to what that is in
a moment] that neither the Secretary of State, nor the
Department for Business and Trade, nor the Minister, nor
the [Shareholder Executive]/UKGI, acting on their
behalf, has direct responsibility for [Post Office
Limited] day-to-day operational or contractual matters.
This is instead a specific objective. It is a safeguard
against central Government micromanagement which is
likely to lack the necessary expertise and experience
and be vulnerable to potential conflicts of interest."
Would you agree, notwithstanding what you say here,
that there may be times when the way in which an ALB
conducts itself at an operational level can concern
ministers at a policy level?
Yeah, I would.
Indeed, you address in number of places in your
statement the fact that there are times when Central

Government will become more involved, to use your words,
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You've already referenced the function of holding to
account and you describe at paragraph 13 that it is best
practice for arm's-length bodies, such as Post Office
Limited, to adopt governance regimes similar to private
sector companies. Could we have on screen, please,
paragraph 13 of Mr Russell's statement, that is page 5.

In the second half of this paragraph, you explain
why the use of boards is important and you say this:

"This reflects the fact that Departments (and the
[Shareholder Executive/UK Government Investments] which
act on the behalf of Departments) are not resourced to
be able effectively to scrutinise the work of
a specialised Executive and to hold them to account",
and you discuss that further below.

You go on in the next paragraph to say:

"although [arm's-length bodies] are operated at
arm's length from Departments, Ministers retain
responsibility and accountability for the activity of
ALBs."

So although the ALB model foresees delegation of
certain matters to the ALB Board, in this case the Post
Office Limited Board, the ultimate responsibility and
accountability for the ALB activity rests with
ministers; is that right?

Correct.

and looking in paragraph 14 of the statement in
particular, please, that's page 5, about six lines down,
you say this:

“Importantly, although Ministers and Departments
will maintain a distance from operational matters ...
there will be instances where both will seek to become
more involved, especially if issues are concerning
enough for direct engagement, but not judged so severe
to warrant the removal of Executives or the Board. In
my experience, however, these instances are rare.”

You give two examples in this paragraph of these
rare instances: one is security matters concerning
nuclear decommissioning and the other is ministerial
involvement in Post Office Limited concerning Horizon,
as ultimately happened.

So, even with a public, non-financial corporation,
such as Post Office Limited, which you describe at
paragraph 22 of your statement as the "most independent
version of an arm’s-length body’, is it right that, in
appropriate circumstances, Central Government will
become involved in operational matters?

Yes, absolutely.
Thank you. That document can come down now.
Can you help, please, with why Post Office Limited

was designated a public non-financial corporation?
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I think there's quite a technical reason for that., to

do with, in particular, the amount of revenue that it
generates from third parties, ie not government revenue.
I'm not absolutely sure but I think the measure is, if

it's over 50 per cent, then that can trigger

a classification of a public corporation.

Do you think that the objective applicable generally to
public corporations, which we've looked at at
paragraph 25 of your statement, that is safeguarding
against Government micromanagement, was a valid
objective for Post Office Limited?

Yes, I do.

Can you explain why?

Well, I think -- I don't think the Post Office was any
different to a number of delivery arm's-length bodies,
where the default should be that Government Whitehall
ministers shouldn't be involved in day-to-day
operations, and it goes back to the point about
capability. Whitehall ministers, the civil servants,
wouldn't necessarily have the capability to get involved
and there may be issues of conflicts of interest as

well. So I think, as a model, it was appropriate.

Given that it is ministers who are ultimately
accountable and responsible for ALBs, would you agree

that they need to receive adequate information about the
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150 people?

Yeah.

They were a mixture of individuals from the private
sector, typically with a background in finance and the
Civil Service, employed either full time or on
secondment?

Correct.

At that stage, the shareholder was advising, you saying
your statement, on approximately 20 organisations in its
shareholder role, and you describe the Shareholder
Executive, and later UKGI, as a "pan-Whitehall resource,
with the group working for most of the 15 main
departments"?

Yeah.

You stress at paragraph 33 of your statement the
importance of departments regarding Shareholder
Executive and UK Government Investments staff working on
their assets and projects as though they were staff of
their own department, with similar rights to

information, and the ability to advise ministers.

directly via submissions or in person.

(The witness nodded)

With that in mind, is it correct that the Shareholder
Executive officials were civil servants bound by the

Civil Service Code?
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operation of the ALB in question?
They need to be satisfied, and the primary source of
that satisfaction should be the Board, they need to be
satisfied that the operations are being managed
properly, yeah. And I should say, the -- this is
a theme not just for the Post Office but elsewhere --
the -- it's almost the length of the arm, and I have to
say my view on this is there are very legitimate reasons
why Central Government should not operationally
interfere, why ministers shouldn't operationally
interfere in these types of organisations.

But there, for sure, are going to be instances where
they definitely need to interfere. So the kind of ~
I don't -- I've never accepted a position where,
regardless of what the constitutional position of
an arm's-length body is, you can't escape from the fact
that ministers are ultimately responsible to Parliament
for the conduct of those organisations. So they must be
free, in extremis, to intervene if they need to.
Dealing, then, with the mechanisms in place to ensure
that the appropriate information is provided to
ministers, and starting, please, with the information
sharing and advisory role of the Shareholder Executive,
later UKGI, is it right that when you became CEO in

2013, the Shareholder Executive employed approximately
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Indeed.
So was there, therefore, a requirement that they carry
out their role with a commitment to the Civil Service
and its core values?
Yes, absolutely.
Those core values are integrity, honesty, objectivity,
and impartiality -
Yeah.
-- is that right?

Would you agree that this includes basing any advice
and decisions on rigorous analysis of the evidence?
Yeah.

Were and are UK Government Investments’ employees bound

by the same standards?

They are. I think technically they're public servants

not civil servants but, to all intents and purposes,

I think they upheld the same standards.

Can you help with what was and is the system for
informing UKGI employees of the standards expected of
them?

Well, the Civil Service Code is widely available and
almost certainly will be -- or it will be on our

website. At the point of induction to the extent that
people are coming in from the private sector, they would

be given that and talked through it. I think
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occasionally in letters of appointment the Code is even
attached.

So it features fairly prominently and I don't know
if you're familiar with it but it's quite an accessible
set of criteria. So it should be quite understandable.
What was and is the enforcement mechanism, if anyone
fell short of the standards?
Disciplinary action: dismissal, at the extreme.
You say at paragraph 34 of your statement that, at the
time you were Chief Executive Officer, each shareholder
‘or corporate finance activity was overseen by
a Shareholder Executive or UKGI Director --
Correct.
-- is that right?
Correct.
In 2013, you say in your statement that there were
approximately 30 Executive Directors or Deputy Directors
and four Directors, all being at senior Civil Service
level and overseeing the 40 or so shareholder and
corporate finance activities?
Correct.
You explain that, as CEO, you would get involved in
a few of those 40 activities --
(The witness nodded)

~- and you say that was mainly where you had the
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ratios.
(The witness nodded)
Can you help with why that would mean you could operate
in a relatively delegated manner?
Well, practically, it’s probably the only way you can do
it because the activities will often be in a variety of
departments. Unless you have adequate delegation, then
your ability to add value, to be flexible with the
Department, would be quite limited. Going back to the
point you made earlier, what was and is very important
is that officials from UKGI/Shareholder Executive were
treated in the same way as civil servants within
a department because I always felt it was very important
that those individuals would have the same access rights
to the senior stakeholders within a department, in
particular ministers, and that necessarily has to be at
a delegated level.

So it would just be impractical, if you've got 40
activities, for everything to come up through the
system, and that the ultimate sign-off was me or one of
my four directors. That's not to say -- there has to be
common sense for issues that are difficult, sensitive;
then, of course, I'd want escalation.
You deal at paragraph 41 of your statement with the

Shareholder Executive Board. Could we have that on
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relevant expertise and experience?

Correct.

You say your personal involvement was normally driven by
instances of technical complexity and complex
stakeholder management.

(The witness nodded)

Would you be able to give us an example of those
features that might lead to your involvement as a CEO?
The privatisation of Royal Mail would be an example:
technically quite difficult, enormous stakeholder
management, very high profile. The establishment, under
the Coalition Government, of the Green Investment Bank
and the British Business Bank, those would all be
examples where I would get more involved.

As CEO, you say you engaged with other departments
frequently; do you mean other Government departments?
Correct.

Typically at Permanent Secretary level?

Yes, not exclusively, but I would certainly be very

familiar with the Permanent Secretaries and the Director
Generals who report to them.

You describe the Shareholder Executive and then UK
Government Investments as operating in a relatively
delegated manner and you say this was made possible by

high senior Civil Service to non-senior Civil Service
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screen, please, it's page 17 of the statement. You
describe the Board, its composition and functions in
this way, you say:

"The [Shareholder Executive] Board formally came
into existence in 2019. It met six times a year and
initially comprised three executives and six
non-executives, including the Chair. The Chair reported
jointly to BIS and HMT Ministers. The non-executives
reported to the Chair. Two of the executives reported
to the CEO and the CEO, in turn, reported to the BIS
Permanent Secretary. [The Shareholder Executive] was
not a company, and so its Board was not a corporate
board (and its Directors did not have fiduciary duties
under the Companies Act 2006). Its key functions were
helpfully set out in a Board note", and you give the
reference for that.

You summarise those functions as:

"... overseeing the work of the Shareholder
Executive; setting strategic direction in light of
Ministerial objectives; periodically reviewing the
delivery of objectives as set out in the Business Plan:
and considering any specific issues referred to it by
the Executive Committee."

You add that the AO -- is that the Accounting

Officer?
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(The witness nodded)
The AO for the Shareholder Executive was the BIS
Permanent Secretary?

Yes.

As Chief Executive Officer of the Shareholder Executive,
did you sit on the Shareholder Executive Board?

Yes.

Is it right that the Shareholder Executive Board was
disbanded and joined with the former board of UK
Financial Investments to form the board of UK Government
Investments in 2016?

Correct.

You describe your reporting responsibilities as CEO of
UKGI at paragraph 48 of your statement. Can we go to
that, please, it's page 20. You say:

"As CEO of UKGI, I was a member of the Board and
reported to the Chair of UKGI. I would provide CEO
Reports to the Board of UKGI which would provide
a high-level overview of key workstreams. These reports
would refer to and be accompanied by the dashboard for
each of the Shareholder/Corporate Finance or other
workstreams. The dashboards would include summary risk
assessments for each workstream."

We will come shortly to oversight and risk

management of Post Office Limited specifically but this
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these. So I did want some mechanism to ensure that
a senior person did have responsibility and
accountability for each activity. So that was another
key reason for the dashboard.

And I suppose a third one was a mechanism at a very
high level to summarise the risk profile, the
relationships, the profitability, the balance sheet
position of our various assets. And going right back to
the start of the Shareholder Executive, which pre-dated
me, they established what they called the sort of
traffic light mechanism that just gave, against seven or
eight different criteria, an idea of what an asset
looked like in terms of risk profile, in terms of
balance sheet, in terms of profitability, shareholder
relationship, et cetera. Those traffic lights
continued, they still continue, and were incorporated
into the dashboard.

So I wouldn't say it was a very -- and you'll have
seen copies of it -- it's not a massively detailed
document and, of course, like any of these high-level
documents, they're only as good as how well people are
summarising activities, scoring traffic lights, and
often those aren't particularly good.

But what the traffic -- what the dashboard did do

was give everybody a good sight as to what it is we're
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is probably a convenient point at which to ask you to
explain, in general terms, how you compiled your reports
to the UKGI Board?
So the dashboards, if I start with those, these,
I think, came into existence in 2015, partly driven by
my desire to make sure we accurately recorded the
activity that we were engaged in. The Shareholder
Executive was set up and remained, and UKGI remained,
essentially a Whitehall resource and one that quite
deliberately was a flexible resource. It sought to meet
the occasional demands of departments and I think that
has been one of the great features: it is very flexible.
As and when issues arise within the departments, we can
potentially turn our hand to help. But there is
a balance. What you also need is some sort of oversight
as to what are the activities -- what are the core
activities that were we're undertaking, so these 40
activities: 20 corporate finance, 20 portfolio
activities?

And that we can socialise that, socialise that
within the group, within the Executive Committee, within
the Board. So they have a good side as to what are the
activities that we're actually doing.

Secondly, I was very conscious, taking over as Chief

Executive, that I couldn't possibly be across all of
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doing and what our activity is. So that was a key
document.

I suppose the other documents, key documents, would
be risk registers, which, as I say in my statement,
developed -- indeed continued to develop -- from the
start of the Shareholder Executive. Typically risk
reporting in the early days was into the department --
into the department's risk registers, depending on what
the asset and activity was. But, increasingly, we
thought it quite important to take a holistic view, and
a kind of consistent view of risk across our portfolio
of both corporate finance activity and shareholder
activity.

So risk reporting was a further way of monitoring
and then I suppose the other point to note would be the
regular cycle of board papers, which again would give
another snapshot at any particular time of what the
activity of the Shareholder Executive was, not always
comprehensive but these always started, as you'll see in
most corporate boards, they always started with a piece
from the Chief Executive, which I always thought was
very important, that although it may not be wholly
comprehensive, it gives a good picture to board members
as to what is on the mind of the Chief Executive.

So I think I'd probably point to those three series
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of documents.

Focusing on the CEO reports, which provided a high-level
overview of key workstreams, how often did you report in
that way to the UKGI Board?

Sorry, the --

So the reports you refer to here at paragraph 48, which
you say provided a high-level overview of key work
streams, was that a regular identifiable report, or are
you talking in general terms?

Yes, this would feature in every Board report.

So every single Board meeting would involve a report by
you --

Correct.

-- as to the high-level overview of key workstreams?
Correct.

Did you report in the same way to the Shareholder
Executive Board before this, when you were CEO?
Sorry, can you repeat the question?

Did you report in the same way to the Shareholder
Executive Board, prior to the UKGI Board?

Yes, I think so. I'm pretty sure that the Board papers

for the Shareholder Executive followed a similar pattern
and had a Chief Executive summary at the start. Again,
common with practically any Board.

You say in the penultimate sentence at paragraph 48 that
25

Accounting Officer reporting to Her Majesty's Treasury's
Principal AO, although AO responsibilities only covered
UKGI and its operations --

Correct.

-- and you had no AO responsibility for any other
Government entity that UKGI involved; is that right?
That's right. I mean, a very important point which

I hope comes out of my statement is that shareholdings/
arm's-length bodies are owned by secretaries of state,
secretaries of state of individual departments. The
Shareholder Executive/UKGI never had ownership of any
asset, as far as I'm aware. We were essentially

advising the shareholder. So if you don't have
‘ownership, then it’s unlikely the Accounting Officer
responsibility would follow.

Was the AO role new when you became CEO of UKGI or did
you hold an AO role when you were CEO of the Shareholder
Executive as well?

No, it was new, because UKGI was constituted as

a fiduciary, as a company, and Government requires
companies to have Accounting Officer responsibility.

But, in essence, and I think I explained, that

essentially was about the stewardship of the resources
of the Shareholder Executive -- sorry, UKGI, and, if

I've got my numbers correctly, our revenue, which was
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you were ultimately accountable for this internal
reporting but also accountable for external departmental
reporting.

Again, we will come on to external reporting in
relation to Post Office Limited specifically but, in
general terms, what was the process by which you
discharged your external departmental reporting
function?

Well, I think it varied. It depended on what the
department whose activity -- either shareholding or
corporate finance activity, depend -- it very much
depending on what their needs were. So there was not
necessarily a consistent way of reporting to each of the
departments.

Whitehall remains a very federated structure,
departments do things quite different ways and part of
what we had to do was make sure -- and continue to have
to do -- was to make sure we feed in, in a way that is.
useful to a particular department but it is rarely
consistent.

Was there any difference in the way you discharged your
external departmental reporting function as you being
CEO of the Shareholder Executive, and later UKGI?

Not really, no. Not in substance.

You explain at paragraph 49 that you also became
26

essentially from the Treasury, but it might be from some
departments as well, was of the order of 20 million and
‘our expenditure would be something like 18 million on
wages, and about a million on accommodation.

You know, that is the -- so it was not a -- and as
Accounting Officer, I was responsible for making sure
that the propriety of those numbers -- not complicated,
in fact quite simple, but it sort of illustrates the
fact that we're actually quite a small and contained
organisation.

Turning then, please, to Post Office Limited specific
oversight by the Shareholder Executive and UK Government
Investments, could we have on screen, please,

paragraph 23 of Mr Russell's statement, that's page 9.
Scrolling down a little, please, after paragraph 23, you

say this:

"Under [Post Office Limited's] updated Articles of
Association dated 2 April 2012, the Secretary of State
was the sole shareholder of [Post Office Limited] and
had certain rights, including to receive information
from [Post Office Limited], and to appoint or remove
[Post Office Limited's] directors, including CEO and
chair. The Secretary of State is also ultimately
accountable and responsible for [Post Office Limited].

Going over the page, please, towards the bottom,
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paragraph 26, you deal here with how the Secretary of
State is supported in the task of accountability, and
responsibility for Post Office Limited, and you say:
the Secretary of State is supported in this
task by other Ministers in the Department, and the
Permanent Secretary for the Department is their
principal policy advisor. The Secretary of State,
Ministers and Department are aided by internal reporting
from UKGI, which includes reporting on [Post Office
Limited]. This was also the case at the times relevant
to this Inquiry", and you deal with that further below.

Is this a reference to the internal reporting from
UKGI, for which you were responsible?
Sorry, you're referring to?
So if we go back, please, to the bottom of the last
page, you deal with two ways here that the Secretary of
State is supported in the task, and one is the support
from the department, the Secretary of State's
department --
Yeah.
-- and the other is being aided by internal reporting
from UKGI. So my question is whether this is the
internal reporting, the external departmental
reporting -
Yes.

29

statement. Without putting that up on the screen, is it

a fair summary of the position that this was not common
practice when the Shareholder Executive was established,
as ministers felt this could interfere with the autonomy
of the arm’s-length body model but, after instances of
arm's-length bodies not engaging sufficiently with the
wishes of ministers and departments, this practice
became more common?

Yes.

You describe two benefits to this practice in your
statement. Again, is it a fair summary of those

benefits that, first, it ensured that ALBs understood

and acted in accordance with the objectives and wishes
of ministers and their departments -- if you can just

say, yes, for the transcriber's benefit?

Yes.

Thank you. Second, it brought a greater understanding
of what was being discussed at Board level?

Correct.

Having eyes and ears on the Post Office Limited Board
should, in theory, have permitted the Shareholder
Executive and the UK Government Investments actively to
seek out and receive adequate relevant information on
risk, should it not?

Correct.
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-- that you said you were accountable for as CEO?
Yes, yes.
You deal in the next paragraph with the Shareholder
Executive and UKGI representation on the Post Office
Limited Board. Is it right that it was not until April
2012, when Post Office Limited separated from Royal
Mail, that the Shareholder Executive had a seat on the
Post Office Limited Board?
Correct.
But, since then, the Secretary of State has appointed
an official from the Shareholder Executive, then UKGI,
to the Board of Post Office Limited as a Non-Executive
Director?
Correct.
Since 2014 -- you cover this at the bottom of
paragraph 27 -- the Shareholder Executive/UKGI
Shareholder Non-Executive Director on the Post Office
Limited Board has been the Head of the Shareholder
Executive/UKGI shareholder team; is that right?
Correct.
That document can come down now. Thank you.

You deal with the rationale behind a Shareholder
Executive/UKGI official being appointed as
a Non-Executive Director on the board of a Government

asset in general terms at paragraph 15 of your
30

Combined with the Shareholder Executive/UKGI external
departmental reporting process, it made the Shareholder
Executive and UKGI the key source of information
relating to Post Office Limited risks, didn't it?

Correct.

Looking, please, to paragraph 16 of Mr Russell's
statement -- that's page 6, please -- you say here:

“The appointment of Shareholder NEDs complements but

does not replace the primary points of Departmental
contact. In the case of [Post Office Limited], the key
contacts were between the [Post Office Limited] CEO and
(i) the Minister and (ii) the Permanent
Secretary/Accounting Officer. Such meetings provide
senior members of the Department with a direct line of
sight into the ALB, and are a key mechanism for
reinforcing departmental objectives for the ALB."

Are you saying here that the Minister and the
Permanent Secretary, rather than the Shareholder
Executive or UKGI officials, were the primary or key
contacts for Post Office Limited, or are you simply
saying that there were occasions on which the Post
Office Limited's CEO would meet directly with the
Minister and the Permanent Secretary?

Yes, it depends on the circumstances and it depends on

the Minister and Permanent Secretary. So, particularly
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for a large organisations like the Post Office, we've
always felt having direct contact with the senior people
of organisations, with the principal Accounting Officer,
so typically the Permanent Secretary, and with
ministers, is really important. It complements anything
they might be hearing from us. It might actually throw
up something that is different but -- so it depends on
the circumstance and it depends on the organisation.
If you look at Post Office and, in particular,
Horizon, you will know that increasingly ministers got
directly engaged themselves, not Secretaries of State
but the ministers responsible for the Post Office, and
that is absolutely as we'd want the system to work,
particularly in circumstances where there were fine
judgements to be made. We always take the view
ministers should hear directly to the extent that they
can.
So was this, in essence, providing a different form of
insight into --
Yes.
-- the affairs of the arm's-length body?
Yes, yes.
But you're not saying here that these contacts were
primary, in the sense that they were more important in

some way than the UKGI official information?
33

here -- Royal Mail, of which Post Office was part, was
a very independent arm's-length body. I mean, if you
were to ask me what was the most independent I'd ever
seen it would be the Royal Mail. And what does that
mean? It means it resisted Whitehall engagement as much
as it could, in part because it felt it could do its
work better unhindered by civil servants.

There was no member of the Shareholder Executive on
the Board of Royal Mail, and I'm absolutely confident
that they would have resisted it tooth and nail.

Now, ultimately, ministers decide and they could
have forced it if they had wanted, but that situation
never happened.

So that's the context where we have the Post Office
spinning out from Royal Mail, an institutional
reluctance to have a member of the Civil Service on the
Board and I'm sure, as part of that, an institutional
reluctance to have Board papers shared. Now, some of
that reluctance would have been legitimate, for
instance, as you're aware, there were two or three
‘occasions where there were some significant funding
negotiations that took place between the Post Office and
the Government and, for a Shareholder Executive Director
sitting on the Board, that's a difficult place to be.

In those sort of situations there would be, on the face
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In general no, on occasion, yes.
In terms of access of the Shareholder Executive and UKGI
to Board level information, could we have on screen,
please, paragraph 92 of Mr Russell's statement. That is
page 42 and four lines down in this paragraph you say:

"I do not think that I knew, then, that Susannah
Storey had been prohibited from sharing Board papers
with [the Shareholder Executive] and I cannot say how
much that prevented the flow of information from [Post
Office Limited] to the shareholder team."

Susannah Storey was the Shareholder Executive
Non-Executive Director sitting on the Board from April
2012 to March 2014; is that right?

Correct.

You say you were not aware at the time. Did you
subsequently become aware that Susannah Storey had been
prohibited from sharing Board papers with the
Shareholder Executive?

Yes, yes.

How did you become aware?

I can't remember. I think I'd have been told by

Susannah or by her successor or by the shareholder team.
Can you help at all with when you became aware of that?
When? I -- the answer is I can't remember when I became

aware. What I ~ and, again, the context is important
34

of it, a conflict of interest.

So you could see, in certain circumstances, why they
might be reluctant to have a Shareholder Executive on
the Board.

I -- sorry, to answer your question when precisely
I became aware, as I've said, I don't know. What I did
know was the reluctance of Post Office to have anyone on
the Post Office Board from the Shareholder Executive and
I think it was the sort of two-step approach, well,
I think the Secretary of State was very clear he wanted
somebody from the Shareholder Executive on the Board.
I think probably what was agreed was -- and these would
have been legitimate concerns of POL, I'm sure. It
would have been agreed that the Board papers wouldn't be
shared.

I say legitimate because I think they probably did
have legitimate concerns about potential conflicts of
interest. But, eventually, that unwound, and I have to
say, personally, I didn't have any time for this - and
we had other instances of this where shareholder --
where Board papers weren't shared with the shareholder
team.

To the extent that there was ever a potential
conflict of interest, then my view was you always deal

with that at the time, and you would -- the director
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would have recused themselves, or whatever.

Did you ever come to understand who in particular had
been responsible for the prohibition on the sharing of
Board papers?

I think saying "prohibition" is wrong because they can't
prohibit; the Secretary of State can demand. Who was
nervous about it? I think it was the first Chair, Alice
Perkins.

Did this cause you any concern at all when you found
out?

Not significant concern, in part because it was unwound
pretty quickly and the shareholder teams did get the
Board papers. Indeed, I can't just remember how long it
took for those papers to be available to the shareholder
team. It may not actually have been very long.

To your knowledge, did the Shareholder Executive inform
ministers or the Department about barriers, perceived or
real, to sharing Board-level information?

No, I can't remember that being shared. That doesn't
mean to say it wasn't shared but I can't remember it
having been shared.

Can you recall why it was not considered necessary to
share that?

Because I don't think it was considered particularly

significant and I think that a danger we overdo this ~
37

You refer in a number of places in your statement to
the Shareholder Executive and UKGI unusually holding
both the shareholder role and the policy role for Post
Office Limited and you say that was a situation which
persisted until 2018. Can you explain, please, who
would usually hold the policy role?

The owning department.

How would you define the policy role?

Well, the -- providing the primary advice on to

ministers on the policy objectives for the asset,

I suppose that's the task number 1. And then also
typically providing stakeholder liaison, particularly

with respect to Parliament. I'd say those are probably
the two key tasks of a policy team.

Why is it better practice for the shareholder and policy
roles to be held separately?

Why is it? I think probably two reasons why it's
important: one is there can be a tension between policy
objectives and commercial objectives, and I think in one
of the documents you've seen written by Anthony Odgers,
‘one of my Shareholder Executive colleagues, captured
this quite well, that it's quite important where there

is a potential conflict between the policy objective and

a commercial objective, then the issue is exposed.

I mean, it's ultimately for ministers to decide what
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I think the shareholder teams would probably say they
were receiving as much information as they need to
receive, absent Board papers. I think they'd probably
have said that. Without knowledge of precisely what
they were receiving and without knowledge of the Board
papers themselves, it's difficult for me to judge.

Was there any pushback at all that you can recall? You
say that this was ultimately resolved. How was it
resolved?

I think there was -- yes, I think there was a healthy
debate but ministers were very clear -- well, ministers
were certainly very clear about board appointments.
They would have been -- and I am answering your last
question, I can't just remember if we said to them the
Board papers aren't being shared but I'm entirely
confident that, had we said that, they'd have said,

“Well, do you want us to tell them?"

You say in your statement, the section that I've just
read out, that you cannot say how much that prevented
flow of information from Post Office Limited to the
shareholder team. Did anyone on the shareholder team
ever raise a concern about not getting enough
information because of it?

Not that I can remember.

That document can come down now, thank you.
38

they want to do but to the extent, for instance, that
a policy objective has a commercial cost, it's very
important that that cost is exposed to ministers and
ministers can make the right decision on the back of it.
So the most obvious example, with respect to the
Post Office, is the policy objective to maintain 3,000
post offices that maybe commercially wouldn't be viable.
I would suggest it's important the cost of that is
understood, up to ministers what they want to do, but --
and you could argue, having separate teams analysing
that, advocating that, is probably a healthy dynamic.
So I'd say that is actually the main reason.
You refer at paragraph 17 of your statement to part of
the reason for the situation persisting until 2018 being
departmental resourcing constraints. What were the
departmental resourcing constraints and how did they
bear upon the decision to keep the dual role as it was?
Well, it won't surprise you, there's resourcing
constraints all the time in every department, so this is
something we have to deal with all the time. I think it
comes down to prioritisation, as decided typically by
the Permanent Secretary. Where did they allocate
resource? I think this situation probably persisted for
longer than we would have wanted because the Permanent

Secretary would have come to the view that, actually,
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the Shareholder Executive was doing this to task
perfectly adequately, and had been doing this task
perfectly adequately. If you remember -- well, if you

go back in history, when the Shareholder Executive
inherited the Royal Mail activity, they took the whole
team, which substantially included the policy people as
well. So things like activities, such as Parliamentary
engagement, et cetera, that all came into the
Shareholder Executive, which was unusual for us because
we wouldn't typically do that sort of thing.

That knowledge and experience, was that Royal Mail level
knowledge and experience?

Knowledge and experience of the policy role? It would
have been -- it would have developed there, that is
correct. But remember, our model is a model of
combining private sector people and civil servants, and
absolutely key to the model working is that we had

a regular flow of civil servants. So, at any one time,
there would be a cadre of civil servants who may have
been acting in other departments who would absolutely
understand what a policy role was.

Aside from departmental resourcing constraints, what
were the other reasons why the dual role was maintained
until 2018, if there are any over and above --

Yeah, I don't think there are. I think -- I don't think
41

a difference. And do remember, even if we had a policy
team that, as indeed we do now -- it is a fairly small
team it's couple of people, so one -- if that. So we
shouldn't inflate the importance of that, I don't think.
Finally on that point, is it fair to say that, in the

same way departmental civil servants and ministers do
not have the expertise to deal with or oversee the
operational affairs of a company like the Post Office,
the Shareholder Executive and UKGI officials were not
experts in public policy issues?

Well, is that fair? We had civil servants who were very
experienced in doing policy work. So I don't think you
can make that observation.

I'd like to deal next, please, with the individuals with
responsibility for Post Office Limited or Royal Mail,
from 2013. You explain at paragraph 51 of your
statement that the teams within the Shareholder
Executive and UKGI responsible for Post Office Limited
and Royal Mail were distinct. To the best of your
understanding, had this always been the case?

Yes.

Could we have on screen, please, paragraph 52 of

Mr Russell's statement, that's page 21. You explain
here that:

"From December 2013, Anthony Odgers became the
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it was seen to be a particular priority. I should say,
I did say there was potentially two reasons you would
want to split the two, and this has become very clear as
a result of Horizon. It does potentially provide

another set of eyes on the situation. I mean, I would
absolutely acknowledge that and, had we split the team
earlier, it might have been the case that that other set

of eyes was quicker to the issue than we were.

We will come in due course to your reflections on that

in your statement.

You explain in your statement at paragraph 74 that
in April 2018 UKGI assessed Post Office Limited as Red,
using the traffic light system, for departmental
relationship and you say that was on the basis that you
were increasingly anxious for the policy role for Post
Office Limited to return to the Department. Are the
consequences which may have flowed from the failure to
separate out these roles sooner, that which you've
already referred to, the situation where you don't --
you don't have two eyes from the policy and the
shareholder side of things, and the potential conflict?
Are those the two main things?

Yes, I mean, would it have made a difference? I just
don't know. It might have made a difference but

I certainly couldn't definitively say it would have made
42

[Shareholder Executive] Director with responsibility for
[Post Office Limited] and for the Government's remaining
RM shareholding. In October 2015, this responsibility
passed to Justin Manson and, in January 2018, to Tom
Cooper. ED [is that Executive Director] responsibility

for Post Office Limited (reporting to [Royal Mail]
Directors) was Richard Callard (January 2013-April
2018), and Tom Aldred (May 2018-February 2020).”

You go on to explain that on separation from Royal
Mail in April 2012, Susannah Storey joined the Post
Office Limited Board. We've covered that already, that
she was the Non-Executive Director from the Shareholder
Executive on the Board and she remained on it until
March 2014:

"From this point, [the Shareholder Executive]
Shareholder NED had responsibility for [Post Office
Limited's] shareholder team within UKGI. These
positions were occupied by Richard Callard ... from
April 2014, and Tom Cooper ... from March 2018."

You deal with who line managed Susannah Storey at
paragraph 54 and you explain that she reported to
Stephen Lovegrove up to March 2013, at which point she
reported to you on her Post Office Limited position but
continued to be line managed by Stephen Lovegrove on

other matters; is that right?
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Yeah.

Given that Susannah Storey reported to you from March
2013 on her Post Office Limited position, was she

a direct source of information for you when you were
compiling reports covering the Post Office Limited for
the Shareholder Executive and later UKGI Board?

Yes. But the primary source would be the shareholder
team.

Did the fact that you line managed her make any
difference to the information flow?

No, no.

In terms of lines of responsibility, is it right that

the relevant Executive Director was responsible to the
Shareholder Executive Director for delivering the
shareholder role --

Yeah.

-- and the director was in turn responsible to you as
CEO?

Correct.

Within the Shareholder Executive, is it right that the
Executive Committee was the committee comprising the
senior members of the Shareholder Executive responsible
for day-to-day running of the organisation?

Correct.

Could we have on screen, please, paragraph 60 of
45

sufficient."

How would the Executive Committee be informed about
a significant issue or event?
In part through the risk register, in part the directors
who ultimately had responsibility for every strand of
activity would all be members of ExCo, so partly through
the directors themselves, raising issues with other ExCo
members. I think those would probably be the two major
ways and, of course, I would be sighted on particular
issues and I would socialise them at the ExCo. So there
would be multiple ways of information feeding to the
ExCo.
It may follow from your answer but who would decide
whether an issue or event warranted report to the
Executive Committee?
There would be no clear decision. I mean -- and your
question suggests slightly more rigour than perhaps
there would be. The whole point of an Executive
Committee is that it should be a forum where you air
issues, concerns. There would be a pattern of reporting
through the dashboard, through the risk registers, which
of course is a formal way of sighting ExCo members but
a good Executive Committee wouldn't just be bound by
those. They'd be listening to what colleagues were

saying, even if they're somewhat ad hoc. That really is
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Mr Russell's statement, that's page 24. Is this
paragraph, paragraph 60 -- and if we can just scroll up,
please, to see the paragraph before, so paragraph 59
deals with the Executive Committee and going down,
please, to paragraph 60.

Is paragraph 60 still addressing the Executive
Committee?

Sorry, if you can just give an answer for the
transcriber?

Sorry, please ask your question again.

Is paragraph 60 continuing to discuss the Executive
Committee?

Itis.

Here you say:

"There was discussion on specific portfolio and
transaction matters if there was a significant issue or
event, especially if there was a need to socialise the
matter. With respect to [Royal Mail] and [Post Office
Limited], [the Executive Committee] would be aware of
major strands of activity and any associated problems
and issues. It would also regularly review the Traffic
Lights/Dashboard entries relevant to [Post Office
Limited]. Absent particular issues of concern, the
[Executive Committee's] primary focus would be the

resourcing of our governance and whether this was
46

the point of the Executive Committee.

Just while we are on this paragraph, you've used the
term "socialising" a number of times in your oral
evidence and in your statement.

Yeah.

Can you just explain for clarity what you mean by that?
It means sharing the issue, yeah. And when we -- if we
come on to risk registers, it's I think a very important
feature of risk registers.

MS PRICE: Sir, I have finished one topic. Perhaps that

might be a convenient moment for the first morning
break.

SIR WYN WILLIAMS: Yes, certainly. What time shall we

resume?

MS PRICE: 11.15, I think, would be ten minutes.
SIR WYN WILLIAMS: All right, fine.

MS PRICE: Thank you, sir.

(11.07 am)

(A short break)

(11.17 am)
MS PRICE: Hello, sir. Can you still see and hear us?
SIR WYN WILLIAMS: Yes, I can thank you very much.
MS PRICE: I'd like to turn, please, Mr Russell to process

for risk identification and management. You explain at

paragraph 65 of your statement that the Shareholder
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Executive oversaw Post Office Limited through its

portfolio review process and its risk management

processes. You describe this as being in addition to

overall supervision of the Shareholder Executive

Director portfolio reviews, project monitoring,

performance management and risk processes.
Starting, please, with the traffic light monitoring

mechanism, is it right that this was established early

in the life of the Shareholder Executive?

Correct.

Can you explain, please, the thinking behind it?

I think nothing more sophisticated than giving

a snapshot to other senior colleagues as to the kind of

state of a portfolio organisation, along certain key

metrics.

Traffic light assessments were produced on a quarterly

basis by the asset shareholder teams?

Yes.

It appears that the traffic light analysis was included

in some of the quarterly reviews the Inquiry has seen.

Yes.

By way of example, could we have on screen, please,

UKGI00041969. This is the April 2012 Post Office

Limited quarterly review and, going to page 5, please,

we can see the traffic light analysis here. On this
49

The wider document we have here, the quarterly
review, is five pages long. Is this a portfolio review
of the type you describe at paragraph 67 of your
statement, or is it something different?
I'm not absolutely sure. We -- I think the answer is
yes. On a quarterly basis, we tended -- and I don't
know if this is a quarterly review -- on a quarterly
basis we --
Apologies, if we can go back to page 1, it might just
help you.
Yes, quarterly review. These tended to be more high
level than the annual review.
You describe the quarterly reviews, the quarterly
portfolio reviews, as providing considerably more detail
‘on performance objectives and risk than the traffic
light assessment alone.
Yeah.
So going, please, to page 2 of this document and just
scrolling, please, to page 3 and page 4. So we can see,
just going back to page 2, please, that the quarterly
update spans two pages there, with a number of different
topics that are being addressed.
Correct. You'll see these developed even further. So
I think quarterly reviews two years on were more

detailed than this.
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particular traffic light analysis, would you agree that
there's fairly limited information recorded next to the
colours, the "Green" and “Amber” to the right?

Yes, I would, but that is a feature of traffic light

analysis. It is very high level, and I should also say

itis rarely accurate. It very much depends on a view
being taken as to -- because a lot of these measures are
highly subjective -- a view being taken by the
shareholder team. And the accuracy of it actually
bothered me less because I like to get discussion behind
these and that people have thought about them. So you
will find there's some inconsistencies that go through
and, ideally, you wouldn't have inconsistencies, but we
shouldn't pretend that these are an exact science. They
are absolutely not an exact science. I am far more
interested in the conversation they prompt.

There are six different criteria or things that are

being assessed by the traffic lights there. Are those

set and unchanging?

I think so, yes, and I think we still use these, yeah.

So those are: first, shareholder relationship; second,
implementation of shareholder model; third, quality of
management team and Board; fourth, strategy; fifth,
financial performance; and, sixth, balance sheet and

risk.
50

Yes. This is quite an early review in the piece --

Yeah.

- putting it in the context of separation. Who, within
the Shareholder Executive, considered the portfolio
reviews, the quarterly reviews?

Do you mean who were they presented to?

Yes.

So we would have portfolio review sessions and one of
the purposes, probably the key purpose of those
sessions, would be what I'd call peer review. So it
would be senior -- actually, not necessarily senior. We
certainly would want senior people there but more junior
colleagues would be encouraged to come as well. It
would be a way -- I go back to the phrase "socialise" —-
a way to socialise some of the issues of a particular
organisation and also for the shareholder team to be
challenged on issues by their peers.

Would you, as CEO, consider the quarterly portfolio
reviews when you were reporting to the Board at that
high level, across-all-work-streams report?

Possibly, but remember we've -- we may have 20 of these.
So considered is probably the -- is probably right but
we certainly wouldn't include all of these.

As a matter of practice, did you read all of the --

No.
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-- quarterly reviews -—-
No.

-- before reporting to the Board?

No.

It simply wouldn't have been manageable?

Correct, and this is the point of having Delegation
Directors, Executive Directors, to do that.

That document can come down now, thank you. You refer
in your statement at paragraph 67 to there also being

an annual review which was intended to provide a more
in-depth view of the asset and you say that this annual
review included commentary on the asset's long-term
strategy and objectives for the upcoming year.

Again, taking an example of an annual Post Office
Limited review, can we have on screen, please,
UKGI00017385. This is a much more detailed document,
and the traffic light analysis is also more detailed in
this one. The document itself runs to some 60-odd
pages. If we can go to page 58, please.

Apologies, I should just say, before we go, this is
the annual review for December 2012.

Going to page 58, please, the traffic light analysis
is a section, it's section 9, and there we have the
shareholder relationship, implementation of shareholder

model, those same six things being addressed.
53

that something that isn't present in this review because
the Shareholder Executive had not been told? Do you
know the answer to that?

I am pretty sure the shareholder team would have been
aware of the appointment of the Second Sight. Just as
they'd be aware as to the reason why Second Sight was
appointed, but they wouldn't have considered it of
sufficient importance to be putting into the traffic

light analysis.

That document can come down now. Thank you. As with
the quarterly portfolio reviews, who received the annual
reviews?

Well, they're available to all members of ExCo. In

fact, they're available to anybody in the Shareholder
Executive who wants to read them. But the primary
recipient would be the portfolio review, whenever that
was taking place. So attendees would receive that
document.

So would that be the Shareholder Executive Director?
It would -- well, the Director would be there, the whole
team would be there. But other Shareholder Executive
colleagues would be there. That's, as I say, the
purpose of it, and they —-

So you're referring to the review meeting itself?

Correct. So they'd all be recipients of that, yeah.
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We can see by the "Shareholder Relationship" this
summary:

"There is a good and constructive relationship with
the new Chair and a strong relationship with the CEO who
has demonstrated her clear commitment to [Post Office
Limited's] strategic plan. The new NEDs are challenging
management, and this has been further improved by the
recent appointment of Tim Franklin (who brings with him
Financial Services and mutual experience).”

There is no mention that I can find, either in this
traffic light analysis, or anywhere else in this review,
to any challenges to the integrity of the Horizon
system. This is December 2012. Second Sight had been
instructed to conduct its investigation in July 2012,
some five months before. Do you find it in any way
surprising that there is no reference in this document,
in its 60-odd pages, to challenges to Horizon integrity?
Yeah - no, is the answer. I don't find it surprising
because, at the time, we absolutely didn't understand
the significance of the Horizon issue and this is
a theme I'm sure we'll come back to, but it doesn't
surprise me at all that it isn't in there.

Are you saying that the Shareholder Executive was aware
that Second Sight had been instructed but didn't

understand the significance of that instruction, or is
54

You describe the addition in 2015 of dashboard reports
to the risk documents at paragraph 68 of your statement.
Could we have that on screen, please, it's page 27. At
paragraph 68, you say this:

"In addition, from 2015, Dashboard reports were
produced, to support the UKGI Board and ExCo in tracking
the performance of [the Shareholder Executive]/UKGI's
main activities, and in challenging teams for individual
assets as required. These included a summary of the top
priorities for each asset, their Traffic Light
assessment, and the relevant extract from the
[Shareholder Executive] risk register. The Board and
ExCo would receive regular Dashboard updates as part of
their briefing packs."

Were these dashboard reports the dashboard reports
you referred to earlier as being the documents which
would accompany your report to the Board with your
overview?

Correct. They were a mechanism to pull all of this
together.

Taking one Shareholder Executive dashboard by way of
example, again, could we have on screen, please,
UKGI00020145. This is a January 2016 Shareholder
Executive dashboard. Going to page 2, please, we can

see here a mission statement. Is that general to the
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work of the Shareholder Executive?
Yeah.
Then on page 3, please, we can see the information
provided about Post Office Limited. So in the middle of
the page, the "Asset" is identified on the left, then
there is "Governance -- Top Priorities", and there are
six bullet points there. Then we see the assessment: is
that the traffic light assessment, the third column.
there?
Sorry?
\s that the traffic light assessment?
It is, itis.
Okay. We see the "Lead" person, is that the lead person
involved with Post Office Limited?
Correct. Justin Manson, yeah.
Okay, was that the Executive Director?
No, that was the Director.
Okay. So in terms of the top priorities that are
recorded here, we have:
“Ensure [Post Office Limited] on track to break even

“Reconfirm timescales for consultation with
Ministers and SpAds by end [of 2026]
"Conclude the Network Transformation Programme

before March 2018 ...
57

lost?

Completely.

Is that something you consider was necessary because of
the need for an overview or is that something, looking
at it now, that you think was not right?

It's a trade-off, isn’t it? I mean, I still think

there's merit in trying to flush out the key issues of

a portfolio organisation because, if we go back to what
we're tying to achieve here, we're trying to socialise
what the key objectives are for colleagues who perhaps
aren't particularly involved. So necessarily we must
summarise but we can do that badly.

Is this all the information -- and just to confirm, the

text beneath which is marked as "Irrelevant" does not
relate to the Post Office -- is this all the information
which the dashboard being provided to the Shareholder
Executive, and later the UKGI Board, would contain for
each asset?

No, they'd see also risk registers and --

We'll come on in due course to the overarching
Shareholder Executive risk register.

Yeah.

But just in terms of the dashboard that you've referred
to as going with your report to the Board, this was the

kind of level of information being provided?
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"Protect 3,000 rural branches as per the
Government's manifesto commitment.

"Minimise HMG and POL exposure (financial and
reputational) to alleged Horizon IT issues

So this dashboard was communicating in one bullet
the issue of Horizon IT issues and the challenges or the
allegations in relation to that: minimise HMG and Post
Office exposure. Was that the shareholder objective or
was that the policy objective?

Well, I don't know that it was -- I would say it was

an objective. As you can see at the top it says, "Top
Priorities", in terms of governance. So I think that is
probably what it is: a priority of governance.

And what I comment on this, I mean, two things: one
is, as you've said, these are summaries and necessarily,
they won't be capturing everything; but more important,
even at this stage, which I think was early 2016, the
Horizon risk was not properly understood and I don't
think we can shy away from that. It was not properly
understood by the Shareholder Executive.

So, for sure, knowing what we know now, this would
have been written differently.

Is there a risk that in reducing the governance top
priorities to a handful of bullet points in this way,

the significance of things, and of potential risk, is
58

It was. Sorry and just to answer your question, was

this all they were seeing, they were seeing this, they

were seeing risk registers, they were seeing Board

reports, as well, which would include my CEO summary and
ad hoc reports on particular assets.

That document can come down now. Thank you.

SIR WYN WILLIAMS: Before it does, can you just explain to

A.

me what I should understand by the use of the word
"exposure" in bullet point 5?
Um, "exposure". Well, I didn't, Sir Wyn, write this.

SIR WYN WILLIAMS: No, no.

A

‘SIR WYN WILLIAMS:

A.
‘SIR WYN WILLIAMS:

I presume what was meant was that it didn't directly
involve the Department and ministers on the day-to-day
basis. I think that's probably what they're trying to

get at there.

I understand that if it stopped at "HMG"
but it goes on to say "and Post Office Limited". So I'm
struggling, really, to make sense of what it means.

Sorry, can we put it back up again?

I mean, on a simplistic level, once
you've got it back, it could mean to minimise publicity
about these things; is that what it means?

Yes, I think there must be an element of that and,

again, I think this Inquiry is showing that there was

acconcern about publicity around the Horizon system,
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completely misguided but on the basis that we had
an organisation who had complete faith in this and felt
that great publicity around its faults would be
damaging. I don't think we can deny that. That
definitely was happening.
‘SIR WYN WILLIAMS: All right, thank you very much. It's
back now but I think we've -- I've at least had answers
to the questions I've asked there, Mr Russell. Thank
you.
MS PRICE: Thank you, sir.
Mr Russell, was there anything you wanted to add now
that is back up on the screen?
A. No. Thank you.
Q. That can come down again now.
You have set out some key steps in the evolution of
the Shareholder Executive and later UKGI's risk
reporting management at paragraph 69 of your statement.
The first of these was reintroducing a group risk
register in January 2013. Can you explain the rationale
behind that, please?
A. Yes. I think -- I can't just remember but I think,
prior to this point, most of the risk reporting went up

through the Departments whose assets we were engaged on

or whose corporate finance activities we were engaged

on. As I think I explained earlier, every department
61

the system of regular reporting, to be able to just
focus on something that one of our colleagues might want
more explanation behind.

Q. Who is the lady, the "she" that you were referring to?

Fiona-Jane MacGregor.

Q. The Risk and Assurance Committee reported to the
Executive Committee on the outcome of the group's
discussions; is that right?

A. Correct.

Q. You say the Risk and Assurance Committee would conduct
deep dives into the project once or twice a year,
bringing the outcomes to the Executive Committee for
review?

>

A. Correct.

Q. Can you recall being aware of any deep dives into Post
Office Limited during the time that you were CEO?

A. I can't recall individual instances -- well, I can
recall one, which was a deep dive into the management
capability, and I think I was present at that particular
committee. I can't recall other individual deep dives
but I'm pretty sure there were some.

Q. As far as you're aware, were challenges to the integrity
of Horizon, Post Office prosecutions or debt recovery
actions covered ever by such a deep dive?

A. Not that I can remember.
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would have their own way of doing things. I think in
2012/2013, we came to the view that we needed

a Shareholder Executive consistent view across all our
portfolio activities, across all our corporate finance
activities, so we were better able to judge the relative
issues between the portfolio organisations and the
corporate finance activity, otherwise it's quite

difficult.

You go on to explain that the Shareholder Executive Risk
and Assurance Committee was established in July 2013 and
that was chaired by the Chief Operating Officer of the
Shareholder Executive?

Correct.

Is it right that the purpose of the Risk and Assurance
Committee was to review key risk across the portfolio
and ensure consistency of approach?

Yes. The other thing I was very keen on was that
somebody fairly independent, and the person who was
chairing that, had a deep background in portfolio
management in the private sector. I was very keen that
she had the ability to just call things out. If she saw
something she didn't like, or wanted more explanation
for, she could just call in a review.

Sorry, who is --

So it also provided that kind of ad hoc ability, outside
62

In terms of risk registers, is it right that

an individual risk register template was created in
February 2014 for use in relation to each asset?

Yes, I think this was the introduction of heatmaps, is
that --

So we can deal with it in your statement. Paragraph 69,
it's page 29 of the statement, please. Subparagraph (e)
at page 29. So you describe here in February 2014 that
the Executive Committee agreed a new risk review process
template and it seems to be saying that was for the
purpose of ensuring consistency in approach across all
assets but they were for use for each individual asset;

is that correct?

Correct.

Each individual risk register was aggregated into

an overarching Shareholder Executive risk register?
Yeah.

This overarching risk register, you say, included

a summary heatmap?

Yeah.

That showed the risk across the portfolio on one page?
Correct.

Again, by way of example, could we have on screen,
please, UKGI00016850. Is this front page here a heatmap

for all Shareholder Executive assets?
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Yes, it looks like it, it is.
You'll see "GRO" appearing in all the bubbles apart from
Post Office Limited. So if you look towards the top of
the page in the top squares there, in the middle, you'll
see "Post Office Limited", and then the others are all
redacted in terms of the names of the other assets?
Yeah.
But is this the one-page heatmap showing all assets
across the portfolio?
Yeah, and maybe just a minute on why we had the system,
and I seem to remember this idea of heatmaps, we did get
a couple of people from private sector organisations to
give us some advice on what is the best way of capturing
risk register. The trouble with risk register -- risk
registers for organisations are very important because
they alert people to where we should be focusing
attention and, going back to my word, they get
individuals to think hard about the risks in their
portfolio, they are a mechanism to socialise the risks,
so we all know about them, and they're a mechanism to
demonstrate how you're mitigating against those risks.
So risk registers in all organisations are really
important. But the trouble with risk registers is they
become process, and people just see them as -- and

I have lots of experience of seeing this in private
65

include; can you help with that?

I think this is the risk register -- well, it is the

risk register of the Post Office itself -- sorry, our
version of it, it's not put together by the Post

Office -- and it's designed to capture what the team
believed were the key risks within the Post Office.

And putting each of those things in a location on the
heatmap, again to show what is more risky as an area
than another?

Yes, and, as I'm sure you know, essentially it's

a matrix of where people try to score what is the
probability of one of these risks occurring against the
impact, should it occur.

Looking down below the heatmap, we can see a list of
items and topics being addressed. Looking, please, at
item 11, we can see reference here to Project Sparrow,
can't we? It's a little difficult to read all of the

wording but, if we click on column D, I think that does
show the full text. In this column it's recorded:

"The Working Group is unable to progress cases and
the process is publicly criticised by applicants and the
JFSA."

If it helps to scroll up, what was that column
addressing?

I think that was the definition of the risk or the
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sector organisations. So you need a way to get
individuals constantly engaged with, and see that this
isn't just process, this is something active. And

I remember when we introduced this, looking down our
floor, because we're all on one space and seeing many of
the screens with this on, and I thought, "Well, we're

doing our job here because people are engaging with this
process".

So this was not a -- the aim of this was something
that was very active, it wasn't a passive bit of process
and, most important, we wanted teams to engage with it
and, of course, most important, it was only as good as
what was being produced by the teams.

So I would maintain this was a good system but it
didn't capture one of our biggest risks, as we'll come
on to.

So this front page has the heatmap on and then the
individual risk registers are incorporated, aren't they,
into this overarching document?

Yeah.

So we can see the tabs at the bottom and one of those
tabs is Post Office?

Yeah.

So we click on that, please. We can see here that there

is another heatmap and this time what does the heatmap
66

characterisation of the risk.
So if we can just scroll up, so we can see the headings,
please. So we have "Risk Overview" then "Impact of
Risk", the "Type of Risk" and, as you've described
there, both probability and impact being identified in
the percentages, and "Mitigation Overview", "Mitigation
Ratings", "Further Mitigating Actions" and "Current
Status". So scrolling back down, please, to item 11,
you can see in column E there's identification of
reputational and brand risk due to perception that Post
Office Limited has not supported subpostmasters with
accusation from JFSA that the process was flawed and not
sufficiently transparent.

We can see "Probability" is assessed as 1 there.
That's 1 out of --
5, I think.
"Impact" is assessed as 4. So does that essentially
mean the probability is low but the impact would be
high?
Correct.
Then we can see in the next box:

"Shareholder Executive is ensuring Post Office
Limited engages with members of the Working Group and
seeks to address issues over the operation of the

Working Group if they arise."
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Then going, please, to column P we have:

"Provide robust responses to queries about the
Working Group stating the findings of the initial review
that there are no systemic issues and that that there is
an independent Chair. Caution needs to be exercised to
ensure that the independence of the Chair is not
undermined."

Then the final column there:

"Terms of reference have been agreed by the Working
Group, which is independently chaired but Second Sight
are unable to process cases and JFSA wish to exit the
group. An interim report published in July 2013 found
there was no systemic issues with the Horizon."

I don't know whether it's missing a word there but
it seems to end on "Horizon", if we can see in the long
readout of the box.

Yes.

Was this the Post Office Limited risk register, which

you deal with at paragraph 124 of your statement, which
you say was considered at the Shareholder Executive Risk
and Assurance Committee on the 19 February 2014?

While we're on this risk register, can we have on
screen, please, UKGI00042124. These are said to be the
minutes of a meeting on 19 February 2014. It appears to

have been specifically convened to consider the
69

this stage that Project Sparrow and the issues raised
there in response to the query should be raised
specifically with the Shareholder Executive Board?
I don't believe we did.
Can you help with why?
Well, I think because we didn't consider -- and weren't
we wrong -- we didn't consider this to be a significant
risk. I think it's as simple as that.
That document can come down now. Thank you.
Sorry, I say a "significant risk": a significant risk
that the system was at fault.
What part did the assurances given at that meeting play
in you not considering it a risk that the system was at
fault?
I can't remember but I am sure the shareholder team were
there, so they would have given us some assurances on
that.
In general terms, you address what risk register
information went to the Shareholder Executive Board at
paragraph 69(f) of your statement. Could we have that
‘on screen, please, it's page 29.

That's 69(f). So, from what you say here, is it
right that the whole overarching Shareholder Executive
risk register was not provided to the Board, so we see

here:
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Shareholder Executive's major risks in relation to Post
Office Limited; is that right?
That's right.
We can see you were at the meeting, along with
Fiona-Jane MacGregor, the Chair, Guy Mason and Tim
Martin, and the presenting team was Richard Callard,
Katrina Lidbetter and Tim McInnes?
Correct.
Much of the meeting, if we scroll down, appears to be
dedicated to discussions about the performance of the
CEO of Post Office Limited but going, please, to the
bottom of page 2, paragraph 14, we have this:

"The committee asked what Project Sparrow was --
Risk 11. TMc explained that this is with regard to
a financial system that is used by subpostmasters. Some
of whom have received criminal convictions for misuse,
however the subpostmasters are suggesting that the
actual system was at fault. All the [Post Office
Limited] investigations so far have shown that the
system is working correctly. However, the risk is that
if the system were to show up as defective then
potentially the criminal convictions could be overturned
and compensation from [Post Office Limited] sought."

So this was in February 2014.

Did you or anyone else at this meeting suggest at
70

"By May 2014, Risk Registers were included as

a standing item on the [Shareholder Executive] Board

agenda. Risk updates included the overall [Shareholder

Executive] Heatmap, and a summary of each asset's

‘Overall Risk’ rating and 'Reputational Risk’ rating.

The top risks for each project continued to be included

in the core pack as part of project updates and

discussed during ‘deep dives' conducted by the Board
So is this in essence saying that the whole risk

register did not go to the Board, ie not each individual

risk register, but higher level information instead did?

Correct, and it illustrates, amongst other things, the

danger of, like, the bullet points of summarisation.

But then, the counter to that is you do want Board

members to engage on it and, if you provide them with 60

sheets, the chances are they won't.

The top risks you refer to, are those the ones contained

in the dashboards?

Sorry are they the ones?

Contained in the dashboards; are they the bullet points

we see in the dashboards?

Yes, that's what I was referring to, yes.

The deep dives you refer to, are those separate deep

dives conducted by the Board or are those the same deep
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dives done by the Risk and Assurance Committee?
No, I think conducted by the Board. That's certainly
what I've got there.

Do you recalll the Board conducting a deep dive into
matters at Post Office Limited?

Not at that time, no. Possibly later but not at that

time.

You deal in your statement at paragraphs 69(g) and (h)
with further changes to the approach to risk management
in 2016 and then again in 2018 at paragraph 69(i). The
change in approach in 2018 led to the Board focusing
their risk discussions on those assets with risks in the
top right hand corer of the heatmap and with any
significant changes in reputational or delivery risk;
that's how you describe it, is that right?

Correct.

Was there a risk, which we've touched on already,
inherent in this approach in focusing on the top
right-hand corner of the heatmap in that it relied too
much on the ability of the heatmap to flag up where the
focus should lie?

For sure.

In terms of your external reporting to the Department,
you deal with this at paragraph 71 of your statement.

Could we go to that, please. It's page 32.
73

More generally, as set out in the 2007 Shareholder
Executive handbook, is it right that governance of
government-owned business should, wherever possible,
reflect commercial best practice?
Yes.
The Corporate Governance Code for Central Government
departments, you say would have been applicable?
Yeah.
Is it also right that you did not believe there were any
material differences between governance in a publicly
listed company and a publicly owned company, other than
the latter is accountable to the Minister, who is
accountable to Parliament?
Correct.
That can come down now, thank you.

Turning now to oversight of specific issues with
Post Office Limited, and starting with oversight of Post
Office Limited pre-separation. You explain in your
statement that your direct role in oversight of Post
Office Limited before its separation from Royal Mail,
was very limited. Although you were at various meetings
where matters relating to Royal Mail and Post Office
Limited were discussed, including Shareholder Executive
Board meetings.

Yeah.
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Without taking you through it all, can you explain,
please, the reporting process and, in particular, what
information from the various reviews and risk registers
went through to the Department?
Yes. I'm -- the Department did have its own risk
register, which we would definitely have fed into, to
the extent it was a Business Department related risk.
There was then, for the Business Department, there was
delivery reports, which were pretty high-level reports
that focused in particular against -- again, very high
level -- the key goals of each department and so of each
asset. But for something like Post Office, it would be
very high level.
Lastly, before we turn to oversight of specific issues
for Post Office Limited, I'd like to deal, please, with
the applicable governance principles, and you deal with
this at paragraph 72 in your statement, if you need to
refer to it.

Am I correct in summarising the position in this
way; although Post Office Limited was not formally
required to report on its compliance with the UK
Corporate Governance Code, it was treated as a benchmark
for reporting on corporate governance by the Post Office
Limited Board.

Correct.
74

You recall the most prominent issues concerning Royal
Mail and Post Office Limited in 2010, relating to the
privatisation of Royal Mail; is that right?

Correct.

You refer at paragraph 77 of your statement to

a Shareholder Executive Board Briefing on Royal Mail,
which was sent to you in June 2010, and it had

a relatively short section on Post Office Limited. If

we could have that on screen, please, the reference is
UKGI00041941 -- forgive me, I think I may have the wrong
reference there.

If we could have UKGI00041943, please. So we can
see there "Royal Mail -- [Shareholder Executive] Board
Briefing’. This paper sets out the history of the 2008
Hooper Review, which recommended introducing a private
sector strategic partner to inject private capital into
Royal Mail, whilst keeping Post Office Limited in public
‘ownership.

If we go to page 3, please, about halfway down the
page, the penultimate bullet point there in section 7:

“Although the Post Office will remain in public
‘ownership, we need a strong creditable story,
underpinned by funding, on the Government's commitment
to the network. Public concern about the impact on

local post offices has derailed previous efforts to sell
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[Royal Mail].”

So the focus here was on what was necessary to
ensure that public concern about the impact upon local
post offices was allayed, given that this had derailed
previous efforts to sell Royal Mail; is that a fair
summary?

Yes.

Shareholder Executive resourcing is dealt with in the
next section down and, as you say, in your statement,
the Shareholder Executive Post Office Limited team was
made up of one senior Civil Service grade, one grade 6,
‘one grade 7, one fast streamer and one higher executive
officer with ongoing recruitment for a further G7 and
higher executive officer.

The view expressed in the paper was that the Royal
Mail, Bill Team and the Post Office Limited team were
probably adequately resourced. Was this a view with
which the Shareholder Executive Board agreed?
I can't remember. I have no reason to think they
wouldn't have agreed with that.

Is it right that you were not directly involved in the
work being done to enable Post Office Limited's
separation from Royal Mail, although you received
updates through the Shareholder Executive Board?

Correct. My involvement with Royal Mail only -- apart
77

Yes.

Why were you not surprised?

I think at the time, there was -- I mean it was clear

that Post Office was going to be independent, it was
going to remain owned by Government. It was inheriting
a management team. So I don't think any of the senior
people, as it became independent, had been recruited in
to the Post Office, post-separation. So I think there

was a strong desire to ensure that the Board, which
would be a new Board, was a strong, independent, new set
of eyes on the organisation.

Was there any particular concern which NED appointments
were intended to address?

Not that I'm aware of, no. Other than the kind of

strategic challenges at the organisation were pretty
enormous and, you know, two things in particular was
driving the -- or increasing the revenue, increasing the
Transformation Programme, making it a more commercial
organisation. I think commercial skills was certainly
something we were very conscious of.

You have noted at paragraph 78 of your statement, in the
context of the Royal Mail and Post Office Limited
Shareholder Executive teams in place in 2010, that the
Shareholder Executive had no role in overseeing the

conduct of prosecutions by Post Office Limited or Royal
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from the sale of the pension assets, my involvement in

Royal Mail only really commenced when I became Chief

Executive and, in that capacity, I was very involved in

the privatisation.

You deal with preseparation plans for Post Office

Limited governance from paragraphs 83 to 87 of your

statement. That document can come down now. Thank you.
You described the intention, as proposed by Anthony

Odgers, for the Shareholder Executive to take a more

significant direct role in the Government governance of

Post Office Limited, including by selecting a new Chair

of the Post Office Limited Board and taking a seat on

the board; is that right?

That's right.

By November 2011, at the point of the Shareholder

Executive Post Office Limited Annual Review, the

strategy was said to be to strengthen the Post Office

Limited Board, including a new Chair and Non-Executive

Directors to give increased levels of oversight and

challenge, and you also say that you do not think you

had any direct involvement in the NED appointments?

No.

But you say you were not surprised that the Shareholder

Executive had highlighted this as a priority, that is

the appointment of Non-Executive Directors?
78

Mail. Why was that?

Because it was -- I think we would absolutely have taken
the view it was an operational matter for the Post

Office and Royal Mail.

If there were operational problems which impacted risk,
shouldn't those operational problems be on the
Shareholder Executive's radar?

If - yes, if they were considered significant.

But how would the Shareholder Executive come to know
there were problems, if there was no oversight of those
operational matters?

Well, I think while Post Office was part of Royal Mail,

we wouldn't really have much sight. I think that sight
only came when Post Office became independent. Just as
‘our visibility on Royal Mail was limited and we had no
seat on the Board of Royal Mail.

Prior to separation, were you personally aware that
private prosecutions were being brought against
subpostmasters, their staff and Post Office employees?
I don't believe I was.

When do you think you became aware of that?

I'm not sure. I think it was -- certainly it would be
post-our shareholder NED (unclear) Susannah Storey, but
I would guess -- when exactly after that, I don't know.

But it wouldn't have been before that.
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Q. We've seen the minutes of the meeting in February 2014,
which made reference to criminal prosecutions, criminal
convictions. So, presumably, you were aware by that
point; is that right?

A. I don't know. I -- that's a fair presumption but
I can't absolutely be certain I was aware then.

Q. Do you draw a distinction between knowing that there
were convictions and knowing that there were private
prosecutions?

A. Yes.

Q. Again, prior to separation, were prosecutions discussed
at the Shareholder Executive Board level to the best of
your recollection?

A. No, I can't remember them having been discussed.

Q. Do you recognise an inherent risk in bringing private
prosecutions against its agents and staff, the Post
Office being simultaneously victim, investigator and
prosecutor?

A. For sure I do now.

Q. Is that something that you appreciated at the time when
you became aware of the history of prosecutions?

A. I don't think I did and I know I definitely -- and one's
memory of these things, because it's a decade ago,
I definitely remember taking clearly false comfort in

the fact that independent courts were coming to views on
81

be the only two mechanisms.

Q. At paragraph 88 of your statement you address the extent
to which the Shareholder Executive exercised oversight
of the pilot or rollout of Horizon Online. You say that
you did not oversee this and that you do not think that
the Shareholder Executive would have been closely
involved, as this was an operational matter that would
be left to Post Office Limited and Royal Mail to
implement in line with the ALB model?

A. Correct.

Q. Again, if there were operational problems which impacted
risk, wouldn't that put an operational issue on the
Shareholder Executive's radar?

A. Well, in theory, yes. But I am not familiar with the
Royal Mail reporting in to the Shareholder Executive.
This was absent a board member. I'm not familiar with
the detail of that reporting. I would like to think
that there was risk reporting and that big operational
issues would be picked up, but I can't be sure of that.

MS PRICE: Sir, I wonder if that might be a convenient
moment for our second morning break, just for ten
minutes until 12.30, please?

SIR WYN WILLIAMS: Yes, certainly.

MS PRICE: Thank you.

(12.20 pm)
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prosecution of subpostmasters. But did I see the --
‘once I knew about the ability or the practice of Post
Office to privately prosecute, did I see the risk of
false prosecutions? I don't know, is the answer.

Q. Because this was a risk which could eventuate going
forwards, wasn't it, even if prosecutions, at the point
you were considering it, were no longer proceeding?

A. Yes.

Q. Is that something you can remember discussion of at all
at any point?

A. No, I can't. I can't. And, sorry, I was going to say,
when -- of course, one knows a lot more about the
situation now, but I -- when the Board, in 2013,
effectively came to a decision to cease prosecutions or
at least look at the policy for prosecutions, I don't
think I was aware of that.

Q. With no Shareholder Executive Non-Executive Director on
the Board, what mechanisms existed prior to separation
for ensuring that the Shareholder Executive was alerted
to risks such as this arising from operational matters?

A. Well, the reporting regime of Royal Mail to the
Shareholder Executive, and so the Department, that would
be the only mechanism, or that mechanism and individual
conversations that would be taking place with officials

in the Department and with ministers. I think those can
82

(A short break)

(12.30 pm)

MS PRICE: Hello, sir. Can you still see and hear us?

SIR WYN WILLIAMS: Yes, thank you.

MS PRICE: Turning, please, Mr Russell to oversight
post-separation. You say you became aware that the
Horizon IT System had actual technical faults, later
named bugs, errors and defects, at around the time you
became aware of the Second Sight Interim Report. In
your statement you say you cannot say exactly when that
‘was, so I just want to try and place that in time
alittle, if I may.

You became permanent CEO of the Shareholder
Executive in April 2013. The Interim Second Sight
Report was published on 8 July 2013. Were you provided
with the Second Sight Interim Report in 2013 when it was
published?

A. I can't remember that I was. I think, though, I'd have
been provided with a summary of it.

Q. That was going to be my next question. Do you think you
were ever provided with the full Interim Report?

A. I can't remember having been provided with it.

Do you recall who the summary of it came from?

A. Well, I don't even -- there's no document that shows the

summary. So I think it was probably an oral summary
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and, even that, I'm not certain of but I'd have seen

there'd have been references to it in submissions. I'm
sure I'd have been aware of it.

How soon after becoming CEO in April 2013 do you think
you were made aware of the Interim Second Sight Report:
within the year, within months?

Yes, within months, probably.

The Interim Report confirmed that two Horizon bugs had
led to erroneous branch accounts and it made number of
other criticisms of Post Office Limited. Do you think

that this should have been flagged up to you, as CEO of
the Shareholder Executive, immediately?

Well, knowing what we know now, yes. What we knew then,
in terms of the significance of those conclusions,

I don't know that it was obvious. I mean, clearly over

the course of this Inquiry, I've looked pretty carefully

of these documents and, if you read paragraph 8.2 of the
Second Sight Interim Report, you don't come away
thinking there's a profound problem here.

Now, we know there was and we know that the
reference to bugs was a significant point. Would the
reader then have known that and would that then have
been escalated to me? I don't know. I don't think it's
obvious.

Do you consider that the detail of that report should
85

Could we have on screen, please, POL00381730.

Starting on page 2, please. There is an email dated
16 September 2013. from Jorja Preston to Alice Perkins.
The middle paragraph of this reads:

"I asked Martin Edwards for a briefing re your
meeting with Mark Russell but Martin just wanted to know
if there is anything specific you need included in the
brief please? I was hoping to get it to you Wednesday
morning when you are here but Martin and Paula are
seeing Will G Wednesday afternoon so it might be
sensible for Martin to send a few bullets after that
meeting should anything come from it you need to be
aware of? Are you happy...”

So it appears from this there was a discussion in
this email ahead of a meeting planned between Alice
Perkins and you. Going back, please, to the bottom of
page 1, and Alice Perkins says:

"Hi Jorja,

"My main question [relates to] Strategy and
Funding?"

There's reference here:

"I also need to be on top of the industrial action
so I'll have another look at the presentation for the
Board Deep Dive."

So there's some suggestion there that there was
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have been discussed at Board level within the
Shareholder Executive Board in 2013?

Well, it could have been. I'm pretty sure it never was.

Do you think it should have been?

Well, what -- on the basis of what we know now, yes. At
the time, no, I don't think it was obvious at all.

2013 was also the year in which the Simon Clarke Advices
brought a halt to prosecutions because the Fujitsu

expert who had been providing reports could no longer be
relied upon. You say you were not aware of the Clarke
Advice until after the GLO; is that right?

That's right.

Again, is this something you should have been made aware
of, as CEO?

Yes.

Something that should have been discussed at Shareholder
Executive Board level?

Yes.

Where do you consider the fault lies for that not

reaching you and the Shareholder Executive Board?

Well, from what I can see, the Board of POL weren't made
aware of it. So I'd certainly expect them to be aware

of it and for them to inform us.

Also in 2013, there was discussion of what should and

should not be included in the Royal Mail prospectus.
86

a deep diver into industrial action:

"Also the update on where we are on Second Sight
etc. And the latest on the [Royal Mail] prospectus. So
basically all the current hot topics."

Were you aware at the time that the Royal Mail
prospectus was being viewed as a "hot topic"?
I can't remember that, no, and, actually, I can't
remember any of this. I'm not particularly surprised
I can't remember it because, in the scheme of things,
I was very involved in the Royal Mail privatisation,
this would not feature very high up the list.

Could we have on screen, please, UKGI00002057. Starting

towards the bottom of page 3, please, the email from

Alex Dunn to Jonathan Lewis, 18 September 2013, and the

subject is "Prospectus -- [Post Office Limited]

comments", and we can see there in the middle paragraph:
I will look through your mark-up in detail but

please note that the Horizon point was raised

specifically by one of the Non-Executive Directors who

was adamant that a reference to this must appear in the

prospectus. We had drafted the revised paragraph so

that it was consistent with the report and [Post Office

Limited's] press release. [Post Office Limited] have

reviewed this section and had no comments on it (as it

is now drafted) so I am surprised that it should now be
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of concern to the [Post Office Limited] team within BIS.
I think that is will need to stay as drafted."

Then the reply to this above, it says:

"Tim -- I explained to S&M the POL points and sent
the attached mark-up. Please see the two emails below
from S&M setting out the [Post Office Limited's]
position. Could you look at these and let me know your
thoughts? With the strength of this opposition, given
it is RM's prospectus after all, there is only a limited
amount of further pushing I think we can actually do.
From a legal perspective, I would not advise pushing
further."

Then the email above this, the email is sent to Tim
Mclnnes from the Shareholder Executive, this time, also
on 18 September 2013. It says -- apologies, this is
from Tim McInnes to Jonathan Lewis.

I'm sorry, we're too high up in the email, so if we
can scroll down a little, please.

So that email below is from Jonathan Lewis to Tim
McInnes in ShEx, then going up again, please:

“Thanks for this and for fighting our corner. I'm
not sure I agree with any of their points -- in
particular certainly not around [Post Office Limited]
signing off any wording ..."

There are number of emails which follow on page 1
89

appear to have offered some assistance in relation to
Deloitte. We can see the section of the email that is
set out there. I won't read through that all now,
unless you need me to.

In relation to Deloitte, you deal with this at
paragraph 127. You explain here that you don't have any
recollection of the meeting with Ms Perkins but, with
reference to that paragraph, what were you offering in
relation to Deloittes work on Project Zebra?

Well, as I say, I don't have a memory of this but it
appears -- and this would seem logical -- that Alice
Perkins was at the stage of hoping for a Deloitte report
that was fairly positive, and wanting this to be capable
of being put into the public domain and it appears
Deloittes, at that stage, weren't prepared to do that
and I could only deduce that they weren't prepared
either because, as is almost certainly the case, they
wanted to do further work on the system or what often is
a reason is that, in the original engagement letter, it
isn't clear that a report is going to be publicised, and
professional services firms like Deloittes hate these
things coming up at a later time.

What was I offering? I think just to test Deloittes
as to whether they wouldn't attach their name.

At paragraph 129, a little further down the page, you
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and, please, towards the bottom of page 1, we have Tim
McInnes to Will Gibson:

"Yes. And I just had Martin on the phone ... Alice
is properly up for a fight. I've bought some time but
let's see what Emma can set up."

Then the email above from Will Gibson to Tim
McInnes. Then we can see there discussion, again, of
that issue.

Going up again -- apologies, going further down --
that email which is highlighted:

“Alice coming in to see Mark tomorrow -- this will
be raised.”

Can you remember being made aware that Alice Perkins
was properly up for a fight over the wording of the RM
prospectus?

No, I can't remember that.

Can you recall being aware that there was any issues or
dispute about the wording of the Royal Mail prospectus,
vis a vis Horizon issues?

I can't remember it. This suggests I was aware but

I can't remember it.

Could we have on screen, please, paragraph 126 of

Mr Russell's statement, that's page 56. Here you deal
with a meeting which appears to have taken place between

you and Alice Perkins on 3 June 2014, at which you
90

make the observation that it appears that the
reassurance that was given to the Board by Deloitte
meant that, regrettably, the full Project Zebra report

was not scrutinised by the Board or by the Shareholder
Executive; is that right, is that your understanding?

Yes.

So you personally didn't see the Project Zebra report;

is that right?

No.

You say at paragraph 203 of your statement that you did
not know until the GLO that Fujitsu could insert data

into branch accounts without the consent of
subpostmasters --

Correct.

-- or that Fujitsu may be able to delete and replace
Horizon audit files containing transaction data?

Correct.

Where do you think the fault for this state of affairs

lies?

Well, this should have been known by the Board, I would
say. Even though, you know, my subsequent understanding
is Deloittes didn't do a detailed analysis of the

system. They -- in one of their reports, they clearly

had raised this issue. That should have been

communicated clearly to the POL Board and the POL Board
92

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should have communicated it to us.

In relation to testing the option of bringing in

alternative investigators, which was referred to in that
email?

Yeah.

That is alternative investigators to Second Sight: is.

that right?

Correct.

Did you tell Alice Perkins that you were interested in

the option of bringing in different investigators?

Again, I can't just remember how the discussion went.
My memory of Second Sight was -- and when I first heard
that Second Sight were involved in this review my first
question was: are these the sort of people who can do
this type of work? Are they resourced correctly? I'd
never heard of Second Sight and, as time went on, what
I did hear, principally through my Shareholder Executive
colleagues, was the complaint that they were struggling
in terms of dealing with the various cases.

Now, this may not be an accurate summary of what the
problem was but that was certainly what I was hearing.
So I presume this conversation with Alice reinforced
that point, that they were losing confidence in Second
Sight and in their ability and capability to progress

this bit of work. I think I'd have been of the view
93,

Executive]/UKGI colleagues, through my relationships

with the Chair and CEO of [Post Office Limited] and

thorough the shareholding Department and its Ministers."
Put simply, do you wish now you had been more

involved in Horizon issues?

Yes.

There is a lot of information you were not aware of at

the time, as is evident from your statement. Do you

think that the information you were aware of should have

prompted you to become more involved than you were?

Well, possibly, but I think you can say that about

a number of people, if we'd understood the significance

of what we were seeing.

Going, please, to paragraph 211 over the page. You deal

here with some specific moments when there could have

been more probing and persistence and you list the

Deloitte Project Zebra report, the final Second Sight

Report, the Panorama whistleblowing allegations and the

Parker review. Are these moments that you think, on

reflection, the Shareholder Executive and UKGI should

have become more involved and questioned the Post Office

Limited narrative further?

Yes, I do. I do. And it is those specific instances.

You know, I go back to the Interim Second Sight Report,

which people still attach a lot of importance to, and
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that the work was important and the suggestion of Grant
Thornton would have simply been, as I think I say, my
first port of call would have been get one of the Big

Four professional services firms more directly involved.
But, at the time, I was quite focused on the fact that,
almost from a policy point of view, Government should
try to get more Big Four type work into the next layer
down and I think that's why I would have suggested Grant
Thornton.

Did you personally have any reason to think that there
was a problem with either the quality of Second Sight's
work or the speed at which it was being produced or were
you reliant and on what others told you?

Completely on what others told me.

I'd like to come, please, to your detailed reflections,
which are set out at paragraphs 208 to 227 of your
statement. Starting, please, with paragraph 208 on

page 92. You say here:

my involvement in the Horizon issues, and how
these issues were addressed during my time as CEO of the
[Shareholder Executive}]/UKGI, was not material, and not
nearly as material as I wish now it had been. As CEO of
the [Shareholder Executive]/UKGI, various levers were
available to influence (and, where appropriate, direct)

actions to be taken, either through my [Shareholder
94

I look at, as I say, paragraph 8.2 and I think after
a year, after a year of work, if those are the
conclusions, this not sort of earth shattering. So it
was the final report -- again, not particularly well
presented, I would suggest -- it was the final report
that had quite a lot in it that absolutely should have
been raising alarm bells.
Did you ever feel a sense from within the Shareholder
Executive or from the Department or ministers that it
was too difficult to contemplate subpostmasters being
right, the consequences of that being too catastrophic?
Emphatically not. Emphatically not. I'd go so far as
to say I'd have relished -- we would have relished --
uncovering this.
At paragraphs 212 to 2014 you discuss UKG''s failure as
an organisation to appreciate the scale and the
significance of the Horizon problem and you discuss the
initial focus on what you believed were major issues,
such as long-term financial and commercial
sustainability. Then five lines up from the bottom you
say this:

"Critically, I was not aware (and to the best of my
knowledge nor were the [Shareholder Executive]/UKGI
Board or ExCo) of the cumulative number of prosecutions

and convictions until well into the GLO. I also didn't
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understand the significance [and, again, you don't
believe the Board and ExCo understood the significance]
of [Post Office] led prosecutions. Finally, neither
[you] nor the [Shareholder Executive]/UKGI board and
ExCo were aware of the many and fundamental failings of
the way in which [Post Office Limited] conducted its
prosecutions."

Going down, please, to 214, you deal with where you
took comfort but you say:

"Wrongly, I did not consider the risk of unsafe
convictions as a result of failings in the Horizon
system to be significant, in large part because of the
repeated and categorical assurances that [Post Office
Limited] had provided to [the Shareholder
Executive]/UKGI and others about the Horizon system."

If you had known the true position in respect of
bugs, errors and defects in the Horizon system and the
scale of the prosecutions and other action taken against
subpostmasters, their staff, and Post Office employees,
what would you have done differently?
I -- what would I have done differently? I think lots
of things differently. I think I'd have escalated it to
our Board, to -- I'd have had conversations within the
Department, I'd have gone to see ministers. I think

there's a variety of things I'd have done.
97

clearly as to why we didn't.
You describe at 217 the strong assertions made to
ministers in submissions around the integrity of Horizon

as being wrong and making for uncomfortable reading now.

Can you explain what the submissions should have done
but did not, and why this was important?
I think they should have been clearer that -- and they
were clearer in some, but really not all of them. They
should have been clearer that this was information that
we were receiving from the Post Office, and I think the
way it reads is this was a kind of balanced view, which
clearly it wasn't. Now, there was an absence of other
detailed data points to counteract that and there was
clearly a very active campaign by the subpostmasters
but, beyond that, I think we should have just been
clearer as to where the information was coming from and
the veracity of that information.

I mean, in part, it is the reason why we were very
glad when ministers engaged directly in this because
these were difficult judgements to make. So the fact
that Baroness Neville-Rolfe, who you will hear from,
engaged absolutely directly on some of this, I think --
I'm very glad that happened. Of course, we all would
have liked to have engaged much earlier on it but that

was an indication of the difficulty in producing
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At paragraph 215 over the page, you deal again with the
assurances that you were given and at 216 you say:

"In spite of the above, had we had more scepticism
and curiosity on our own part, such that we interrogated
further, we might have concluded that a much fuller
investigation of the system should have taken place
sooner. The fact that [Post Office Limited] was
a relatively autonomous ALB would not have stopped us
recommending a comprehensive, independent investigation
if we had felt this to be necessary albeit that this
would have signalled a loss of confidence in the POL
Management and Board.”

Can you help with why the Shareholder Executive and
UKGI did not have more scepticism and curiosity at the
time?
I don't think easily. I mean, this is clearly
a hindsight point and you crawl over the -- I wouldn't
even say they were necessarily red flags but indications
that we could have latched on to, and I don't have any
easy explanation as to why we didn't latch on to them,
other than they, at the time, didn't appear significant,
profound, and we had -- you know, we had such strong
assurances from the Post Office itself, and from the
Board, who we had no -- actually no reason to doubt.

Sorry, I don't think I can answer your question
98

balanced submissions. It was -- you had to hear the
evidence yourself and make your own judgements.

In terms of governance, does it remain your view that
the arm's-length body model for Post Office Limited is
not the problem, the issue is the execution of that
model?

Absolutely. Absolutely.

The Inquiry may hear evidence that it would be
appropriate to legislate to create a new form of
government-owned entity, outside the strictures of the
Companies Act, conferring a discretion on ministers to
intervene directly where necessary. What is your view
of that suggestion?

Well, I'd want to see the detail. Ministers can

intervene directly now and they do. The question is:
what are the triggers to do that? And the argument that
we've got, particularly in an organisation like this,
"We've got very restricted shareholder rights", is, to

my mind, a red herring. It is very clear the Government
owns this business and it wouldn't -- to the extent
ministers or officials feel there needs to be greater
‘operational involvement, they can do that and they
almost certainly don't need to remove boards to do that.
The Inquiry may also hear evidence that it may be

appropriate to give ministers or their direct
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representatives observer status in the board meetings of
government-owned companies. Do you agree, in whole or
in part, with that suggestion, or not?

A. Not really. I think observer status is a very weak way
of attending a board. I think you should be either
a director or not.

That said, I mean, an important point that hasn't
really come out is this point about us putting our own
directors onto boards. It really is important to
understand, we don't do that, or very rarely do that, on
the basis that we are putting a particular skillset on
to the board. We don't have that sort of capability.

We do it so that the arm's-length bodies understand
that -- what ministers priorities are and we do it so we
get information back again. But I don't see any
advantage at all in weakening the director role to

an observer role.

MS PRICE: Sir, those are my questions for Mr Russell.
There are some questions from Core Participants, which
I think we'll now need to deal with after the lunch
break.

SIR WYN WILLIAMS: Right.

MS PRICE: I wonder whether, looking over at the transcriber
we could come back at 1.50 rather than at 2.00 to ensure

we get through those questions and our next witness
101

morning that it's your view that the arm's-length model

of governance was not a bar to ministerial intervention,
and you have given examples, for example, with the
Nuclear Decommissioning Authority the Government would
intervene because it is important to do so.

What our client are particularly interested to know,
is what mechanisms within the arm's-length body
governance mechanism were there for detecting and
dealing with situations such as, in this case, where
senior executives acted in bad faith and covered up
matters?

A. I think the principal answer to that has to be the Board
because -- the Board of the Post Office.

Q. The Post Office Board?

A. Correct, because they are our oversight, they are our --
they have the time, they have the capacity, they have
the knowledge and their function is to hold the
executive to account. If they miss it, then we might
just catch it but I have to say it's sort of luck, if
we, you know, if we can pick up on something like this.
I mean, that said, we have missed things here and it was
a catastrophe.

Q. We've heard there were mechanisms in place?

A. Yes.

Q. Shareholder Executive non-Executive Directors sitting on
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today.

‘SIR WYN WILLIAMS: What is the transcriber indicating to
you, Ms Price.

MS PRICE: There is a nod.

SIR WYN WILLIAMS: = Thank you very much, especially to the
transcriber, for facilitating the Inquiry in this way.

So we'll resume at 1.50.

MS PRICE: Thank you, sir.

(1.02 pm)

(The Short Adjournment)

(1.50 pm)

MS PRICE: Good afternoon, sir.

SIR WYN WILLIAMS: Good afternoon.

MS PRICE: We have questions from Ms Page, Mr Jacobs and
Mr Chapman. Ms Page will be ten minutes, Mr Jacobs five
minutes and Mr Chapman five minutes.

SIR WYN WILLIAMS: Fine, thank you.

MS PRICE: Thank you.

MR JACOBS: Sir, I think I'm going first.

‘SIR WYN WILLIAMS: All right.

Questioned by MR JACOBS

MR JACOBS: Good afternoon, I ask questions on behalf of
a large number of subpostmasters who are Core
Participants in this Inquiry.

I think we have established from your evidence this
102

the Post Office Board, risk registers, traffic light
analysis --

A. Yes.

Q. -- heatmaps, the Shareholder Executive's Risk and
Assurance Committee. With these checks and balances,
why was it missed and who do you blame; what individuals
do you blame for not bringing that to your attention?

A. I -- it's really not for me to blame individuals but
I go back to the point that we do have these various
mechanisms but you then remember the scale of what it is
we're looking after here: 20 organisations, some of them
really complex organisations, 20 in corporate finance
but, you know, corporate finance project might be the
privatisation of Royal Mail. Big, big things. So no
matter how good we are, for us to pick up something like
this by ourselves, without any prompting from people
closer to the organisation, of course it could happen
and I deeply regret it didn’t happen.

But the reason we promulgate the idea of
an arm's-length body, as I go back to what I was saying
this morning, is in part because of the governance
structure of a board. They have the time, capacity to
be able to dig in in areas that are definitely more
difficult for us. You know, my interaction with the

Executive over six years, six meetings, maybe. You
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know, I would need to be a genius perhaps -- well,
perhaps not -- but, I mean, I would certainly need to be
pretty lucky to pick up on some of these points. So
there has to be a reliance on other systems.
Well, isn't this the very reason why the Shareholder
Executive put Non-Executive Directors on the Post Office
Board, to pick these very things up?
Only in part, and I go back to the point that the reason
we populate these boards with subject matter experts is
so they can dig in to a financial issue, perhaps an IT
issue -- although on the Post Office Board we didn't
have anybody particularly steeped in IT. We have people
reasonably experienced in IT but not steeped in IT. We
don't put people on our Board -- we don't put our people
on boards with particular subject matter experience.
They're there, as I explained earlier, primarily to do
the function of making sure the organisation doesn't
drift off and start doing things that the Department
doesn't want and to make sure we've got full sight of
the discussion.

Yes, of course they are still full board members and
they are part of -- to the extent that there has been
a failure of board governance, they're a part of that.
You can't get away from that.

Thank you. You answered questions from Ms Price before
105

because, as we know, this was far more than just the
system: it was the treatment of subpostmasters, it was
the way people were being dealt with. That was the
missed opportunity.

Now, could it have been done later? Of course it
could have been done later. And would it have bothered
me if I'd known the significance of this, that, you
know, I might have had Post Office or even the Board
saying, "This isn't necessary"? Not at all. If we
thought this was necessary, we would have done it.
Well, we would have done it, we'd have instructed the
Post Office to do it.
I think you've accepted, haven't you, there was
a failure in governance here?

Yes.

I think your answer is that a professional services firm
would have been a check that could have been inserted?
Well, I mean given how long it took the GLO to really
uncover the issues here, I don't think there'd have been
any alternative to something like that because, of
course, we wouldn't -- we couldn't possibly have wanted
to have gone through all that litigation, it would have
been far better to have got to the bottom of it. And
because it was very complex, in so many respects, you

have to have someone in who is capable of getting to it.
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lunch when you say, referring to paragraph 211 of your
statement, that there was information that the
Shareholder Executive knew about or ought reasonably to
have known about, the Parker review, the Second Sight
final report, and you said that you would have, if you'd
been more curious, if you'd taken it as a critical
issue, you would have escalated it to the Board, you
said, you would have had conversations within the
Department and you'd have gone to see ministers.

What our clients are interested to know is when
a government-owned body goes rogue, as has happened
here -- and this can be any other organisation could do
the same thing, Nuclear Decommissioning, for example --
Yes.
-- what can the Government actually do? Would it go in,
would it dismiss the board? Would it take over? How do
you deal with the sort of crisis that we've got here?
So what was the missed opportunity here? The missed
opportunity, I believe, and of course this is hindsight,
this is having learnt about this in so much detail,
post-the event, the missed opportunity was -- back in
2013 was not putting a big professional services firm
into the organisation in place of Second Sight, to have
done a complete review of the system, not just the

computer system the software system, but everything
106

I think -
I don't know of any other solution.
Thank you for that. I think I'm about to or I have
exceeded my time. I just have one other point.
Yes?
You said, in answer to questions from Ms Price before
lunch, that you weren't aware of the sort of Post Office
prosecuting in circumstances where it was the victim,
the investigator and the prosecutor.
Yes.
Ron Warmington of Second Sight gave evidence on 18 June
this year and one of his criticisms of the way that the
investigation was governed, effectively, was that the
Post Office was the principal subject of the
investigation but it was also the paymaster.
Yes.
He said that Andrew Bridgen, I think, raised that and he
said the Treasury said "We haven't got any money and
therefore the Post Office is going to have to pay for
it, and it was a daft decision", which is what the
witness said.

Why didn't the Government spot that, and deal with
it at the time?
I don't know, is the answer. I don't know. Because

although I've been slightly disparaging of certainly
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the -- part of the interim report, clearly Second Sight
did get on to some fundamental points there but we
didn't pick them up.

MR JACOBS: I think I have come to the end of my time. I'm
just going to have if I have any more questions to ask?

I don't, so that’s all from me. Thank you.

A. Thank you.

SIR WYN WILLIAMS: Ms Page?

Questioned by MS PAGE

MS PAGE: Thank you, sir. Mr Russell, oversight involves
the balance of support and challenge: do you agree?

A. Yes.

Q. What I want to look at is you team's approach towards
POL, Post Office, and whether there was really anything
like challenge in the attitudes that you brought towards
your task. So if we could start, please, by going to
UKGI00042124. This is a document that you looked at
with Ms Price but I want to ask you some different
questions on it. If we could go, please, to page 2 when
we get there. This is the February 2014 ARC meeting
note when you were in attendance.

A. Yes.

Q. Mr Tim McInnes gave a summary of Project Sparrow. So,
if we go down to paragraph 14, please, and if we just go

cover what it says there:
109

overseeing may have wrongfully convicted its trusted
business partners and sent them to jail. That was
obvious at the time, that's not just a hindsight
observation; that's something that any person of
integrity should have been able to identify from what
was being expressed there by Mr McInnes. Do you accept
that?

A. I completely accept that.

Q. Now, you tell us that you and your team would have
relished uncovering the fact that the subpostmasters
were right. Why do you think that this transparently

somewhat misguided summary about compensation didn't get

you thinking, didn't get you wondering: why is nobody
wondering about the possibility that the postmasters
have been sent to prison wrongly?

A. I think the answer to that is we had no idea of the
scale of what was going on here.

Q. It doesn't matter the scale, if one person has gone to
prison wrongly, that is a miscarriage of justice.

A. Itis a matter of -- no, I completely agree with that.
I completely agree with that. But I'd say itis, in
part, scale. I agree, just one person going -- being
convicted wrongly is a matter of serious concern and I'd
acknowledge that that -- and, you know, I can't remember

the discussion, I was there. But that, in itself,
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"[Tim McInnes] explained that this is with regard to
a financial system that is used by subpostmasters. Some
of whom have received criminal convictions for misuse,
however the subpostmasters are suggesting that the
actual system was at fault. All the [Post Office]
investigations so far have shown that the system is
working correctly. However, the risk is that if this
system were to show up as defective then potentially the
criminal convictions could be overturned and
compensation from [Post Office] sought."

Now, what I want to ask you about is this: at one
level, this summary of Project Sparrow is very incisive
because it doesn't have any of the flummery that we
sometimes get from Post Office that was really just, one
might argue, a distraction to do with mediation, to do
with support for subpostmasters and those other issues
because really it focuses very, very tightly on the
criminal convictions. What it says is that, if the
system proves to be at fault, then they may be
overturned.

Now, that is a matter, surely, of very, very high
importance because what we're talking about here and
what actually is missed here is that the risk, the real
risk, is not whether compensation may be sought; the

real risk is that the organisation that you're
110

I completely agree, we should have jumped on that.
I can only say, in mitigation, if this had been -- if
the indication had been that (a) this was likely,
right -- so this is an allegation at the moment -- if
this was likely and it was on any scale at all, I would
like to think we would have jumped on it. But your
point is well made. Just one incidence, we should have
jumped on it.
Thank you. That document can come down. If we could
have a look, please, at UKGI00006883. This is one of
the risk registers which uses the heatmap, and you've
explained that for us, so I won't dwell on that. What
I'd like to look at is some of the wording in the way
that the risk is described. Thank you, if we could go
to tab 2 and look at risk 6, which is the Project
Sparrow risk. A little further down, please. If you
could just keep going up a little to 6. There we go.

I don't know how well you can read that but it says
on the left "Project Sparrow" and what we can see in
column D is a description that I think we may have seen
similarly before, so if we go across to E, what it says
there is:

"Post Office's reputation and brand are damaged by
accusations, costs spiral out of control, particularly

if legal action is taken. Government risks being drawn
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closer into the scheme or our level of involvement being
made public."

Then if we go a bit further across to K, it says:
"Responsibility rests with Post Office to manage

both the Mediation Scheme and stakeholders generally.
Post Office Chair undertaking review with independent
QC. We are managing ministers’ involvement with the
intention of keeping the issue independent of
Government.”

Then, finally, across to the one before Q, it
doesn't have a heading:

"Ensure Post Office are proactively managing
interests and noise and are aware of ministers’
expectations. Manage interest and wobbles from
ministers or the centre, including preparing fallback
options if current arm's-length position becomes
untenable."

Now, what that says, surely, is the arm's-length
stance was something of a sham?

No, I don't think that's right. I mean, I've a number

of comments on this. First of all, and this is common

to all our risk registers on Horizon Sparrow, the risk
was not properly articulated. The real risk was there
was a problem in the system and that was not captured.

This is primarily ~ and my memory is the concern of the
113

No. Sorry, couldn't have ended up -- entered into a --
The sort of expensive, ruinous litigation that Post

Office entered into, in a private company, the owners of
that business would have been all over it, not leaving

it at an arm's length and hoping to be able to get away
with that?

Yes. I mean, I don't think the Post Office entered into
the litigation on the basis of, well, it doesn't really

much matter because the Government will be there to bail
us out. I think there was a very big concern the
Government wouldn't be there to bail them out. You
know, my memory of this is they entered into that
litigation absolutely certain that right was on their

side.

I'm not so concerned about their position. I'm
concerned, really, about the Government Shareholder
position, in which it's being -- the risk is being
articulated as, "Well, we'll only get involved if our
arm's-length stance becomes untenable", and, surely,
that just doesn't take responsible ownership of the
business?

Well, I don't know if I agree with that. I think the
Mediation Scheme that the greatest chance of success if
the Government was on the sidelines of that, ie not

involved, not trying to arbitrate, not coming up with
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team was that the mediation process was given its best
possible chance. You know, if you go back, there was
always some sort of process going on to try to resolve
this, and we can argue about the adequacy of the
process, but there was always some sort of -- Second
Sight, Mediation Scheme, Parker.

And I think there was a legitimate concern here that
either if Government got too close to the Mediation
Scheme or it proposed something alternative, then that
was the end of the Mediation Scheme.

We know, in the end, the Mediation Scheme did
collapse and that is one of the reasons that led to the
Parker Review. But I think there was a legitimate
concern here of the team against the background that the
risk was not properly the -- captured here but, in terms.
of the risk of the Mediation Scheme falling over,
I think there's something quite right here, that the
Mediation Scheme depended upon Government keeping at
a distance, and there being no alternative, you know,
judicial investigation or whatever that would absolutely
have cut the Mediation Scheme dead.

Q. A private company couldn't have entered into the sort of
expensive ruinous litigation that the Post Office did
without a great deal of challenge from its owners, could
it?

114

its own decision. So I think it was appropriate, as
an arm's-length structure.

MS PAGE: Well, thank you, Mr Russell, I've taken up my time
so I'll end there.

THE WITNESS: Thank you.

SIR WYN WILLIAMS: = Thank you, Ms Page.

Mr Chapman?
Questioned by MR CHAPMAN

MR CHAPMAN: Mr Russell, I have a handful of questions on
behalf of the Department of Business and Trade
concerning the Post Office's arm's-length status and the
Government's powers to step in and issue directions or
otherwise exert its powers.

To set the scene, earlier today Ms Price took you to
paragraph 23 of your witness statement, which refers to
the 2012 model of the Articles of Association, where you
explain that the articles give the Secretary of State
particular rights, including the right to receive
information from POL, and the power to appoint or remove
the Post Office's directors including its Chair or the
Chief Executive.

In paragraph 193 of your statement you discuss the
Government's reaction to the Common Issues judgment and
specifically the Government's reaction to POL's response

to the judgment, so the recusal application, and so on.
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You say at paragraph 193 -- there's no particular need
to get it up on screen, I'll read it out:

"I have reflected on whether the Government could or
should have stepped in to insist that the recusal
application was not made. This would have been a very
serious step to take and would have risked either
resignations or dismissals of Board members and possibly
others. The Board had received legal advice supporting
a recusal application from extremely eminent legal
figures, including a former president of the Supreme
Court. In those circumstances, I do not think that it
would have been realistic to have expected the
Government to have stepped in to prevent the
application.”

So the necessary implication of that is that, in
your view, the Government that the powers to step in and
prevent the application from being made. You said in
your evidence shortly before lunch words to the effect
that you have no doubt that ministers, as effectively
the shareholder, had the power to step in if they wanted
to.

First question: so far as you know, was that
understanding shared by both ShEx and ministers?

That they could step in if they needed to?

Could step in?
117

the Board of a body like POL would have been at that
time?

Well, it would be a pretty high-profile event. I can't
think of any instance -- I can't think of any instance
where Government has dismissed the board of

an arm's-length body, so it would have been a pretty
rare event.

Are there downsides? Well, you'd have to find a new
board, for sure, that may not be straightforward. But
no, not -- I mean, if ministers felt strongly enough
about it, and my understanding was they did feel
strongly, but they respected the -- what the directors
believed were their own duties at the time. They
respected that point and were not prepared to, you know,
take the nuclear option of replacing the Board.

So for ministers at that time it was really

an all-or-nothing?

Well, as I say, there's this practical point that you
could go to the Chair and say, "We want this stopped
and, if you don't stop it, we're going to remove you",
and the chances are they will stop it.

Now, in March 2020 new Articles of Association were
adopted for the Post Office, which, for the first time,
gave the Secretary of State a power to issue directions

to the Post Office. We don't need to turn it up. Were
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Yes, I think so. I mean, by stepping in, ultimately,
you can remove a board. The ministers knew that.
That's my next question. What do you mean by "stepping
in" and what are the specific powers, as at this time,
mid-2019, for ministers to step in, short of dismissing

the Board?

Well, the actual part is dismissal of the Board. The
practical power is the threat to dismiss the Board.

Right. Now, were you aware in 2019, at the time of the
proposed recusal application and the appeal thereof,

that ShEx officials had calls with ministers and the

Secretary of State --

Yeah.

-- at which the Secretary of State and ministers made
very clear their distaste for the idea of a recusal
application being made, of an appeal being made,

et cetera, et cetera; was that communicated to you?

I think so, yes. Yes.

Were you aware, thereafter, that the Secretary of State
asked for advice on the various options available to him
to stop the Board from carrying through on this idea and
in particular on the nuclear option of, in fact,

dismissing the entire POL Board?

That's right, I don't think I was aware of that.

Could you explain now what the downside to dismissing
118

you aware of that?

To be honest, I can't remember. I can't remember.
Would that --

This is in the new Articles?

This is in the March 2020 Articles?

Articles, yeah, yeah.

Would that sort of halfway-house provision have been the
sort of provision that could have enabled Government to
step in to prevent the application, short of --

Without threatening the nuclear option? Yes, I think it
probably would be and, indeed, I think this is probably
the solution. You have -- as I say, I don't think you
should be constituting a new type of company. I think,
if anything, what you should be doing is you should be
extending the rights of the Shareholder so that you
don't have to threaten the nuclear option. I happen to
think that's probably the answer.

To conclude that circle, are there also potential risks

to threatening the Board or the Chair with removal?
Yes, yes, yes. You need to exercise that very

carefully, and we have already seen from some of the --
the way ministers look at this, I think there were
certainly ministers who absolutely understand the need
to have mechanisms in place to ensure that it is

actually quite difficult for ministers to get involved,
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ie the bars are quite high. So all of this is
a balance.

MR CHAPMAN: Thank you very much. Those are all my
questions.

SIR WYN WILLIAMS: Thank you, Mr Chapman. Is there anyone
else, Ms Price?

MS PRICE: No, sir. That's it.

‘SIR WYN WILLIAM: Well, thank you, Mr Russell, for making
your detailed witness statement and for answering
questions from a variety of people this morning and this
afternoon. I'm very grateful to you.

THE WITNESS: § Thank you, sir.

SIR WYN WILLIAMS: = Right. So I will remain online while you
do some manoeuvring, Ms Price?

MS PRICE: Thank you, sir. Yes, it's Mr Swannell next.

SIR WYN WILLIAMS: Yes. Well, I'll just remove myself from
the video, but I'm still here, so to speak.

MS PRICE: Thank you, sir.

(Pause to change witnesses)

MR STEVENS: Sir, can you see and hear us?

SIR WYN WILLIAMS: Yes, thank you very much.

MR STEVENS: Thank you. If I can call Mr Swannell, please.

ROBERT WILLIAM ASHBURNHAM SWANNELL (sworn)
Questioned by MR STEVENS

MR STEVENS: Thank you, please can you state your full name?
121

We think that that same dashboard was shown to the
November 2015 Board but we haven't been able to verify
it. In any event, the dashboard dated January 2016 went
to the January Board meeting and the wording is exactly
the same in the October 2015 dashboard that I saw in
November, as the January 2016.

Q. Inessence, in this paragraph at 87 you refer to
a dashboard which includes the quote there, "minimising
HMG and POL's financial and reputational exposure to the
alleged Horizon IT issue", and what you're saying today
is that you found an email dated 28 October 2015, which
effectively included a dashboard with that line in it.

A. Correct, and the dashboard is dated October 2015.

Q. Sir, for the purpose of the record, the URNs to which
Mr Swannell has just referred are UKGI00045534 and
UKGI00045535.

If we could turn to page 38, please, and at
paragraph 97, it says “on 8 November 2017", I understand
you wish to correct that to 7 November 2017 --

A. Correct. The meeting was on the 7th. My note of the
meeting was on the 8th.

Q. Thank you. If! could ask you to turn to page 67 of the
statement, the statement on the screen can come down; do
you see a signature?

A. Ido.
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Robert William Ashburnham Swannell.
Thank you for attending the Inquiry today and thank you
for preparing a written statement, which I want to turn
to now. For the record, the statement is Unique
Reference Number WITN10800100.
Do you have that statement in front of you?
Ido.
Now, before we turn to the signature, there are two
corrections which we need to address. Firstly, could we
turn, please, and have on screen page 34, paragraph 87.
Thank you. At paragraph 87 you refer to the first
reference you have been able to find to Horizon, as it
appears in the ShEx dashboard within the pack produced
for the UKGI board meeting on 27 January 2016.
I understand, since signing this statement, you've
come across some other documents and wish to clarify
that position?
Correct. These are all documents that the Inquiry
already has but the first reference I would have seen in
a ShEx dashboard to a reference to Horizon came via
an email dated 28 October, to which was appended the
October 2015 dashboard for a meeting on 3 November, with
the incoming members of the UKFI Board, who were then
going to come on to the UKGI Board. So that meeting

happened on 3 November.
122

Is that your signature?

Itis.

Are the facts stated in that statement true to the best
of your knowledge and belief?

They are.

I. am going to ask you some questions about that
statement, which will be shortly published on the
website, but I'll start with your background. Your
career history is set out in your witness statement, so
I'm going to take this relatively quickly. I understand
you initially qualified as a chartered accountant before
being called to the Bar?

Correct.

You then spent nearly 30 years in investment banking?
Certainly more than 30 years.

From 1999, you acted as a Non-Executive Director for
several listed companies?

While I was an investment banker, correct.

You were the Chairman of Marks & Spencer between January
2011 and September 2017?

Correct.

You joined the Shareholder Executive as a Non-Executive
Director in January 2014?

Correct. That was my first Board meeting, yes.

You became Chair of the Shareholder Executive in
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September 2014?
Correct.
Were you given a briefing on the Post Office as.
a business when you joined the Shareholder Executive?
Not that I recall.
I want to first look at the role of the Shareholder
Executive. Please can we bring up UKGI00045953. Thank
you. This is a draft letter in November 2013 from
Patrick O'Sullivan, who was then Chairman of the
Shareholder Executive, to you, with your appointment as
a Non-Executive Board Member and attached to it, we see
at page 3, are the Shareholder Executive Board's terms
of reference.

Can we please then go to page 4 and down to the
bottom, it says:

"The designated purpose of the [Shareholder
Executive Board] is to act as an Advisory Board,
providing assistance and support to the CEO and helping
him assure that the Shareholder Executive adopts best
practice with regards to governance."

There's then split three main areas of activities,
effectively. You see we have "Strategy’, the first
point is:

"To monitor strategic operational risks faced by

[Shareholder Executive] in relation to all its
125

a result of that, the shape of the -- from that first

Board meeting -- the shape of the ShEx, as it then was,
risk register, changed.

We'll come to those in due course. The first bullet
point is:

"To assess individual high priority and/or high risk
transactions, projects or other situations where ShEx is
actively involved ..."

So that's slightly different, isn't it? Is that
where the Board takes a deep dive into a particular
asset?

Correct.

Was that to ensure that the asset was being
appropriately overseen by the executive of ShEx?

It was particularly where the risk register showed that
there were particular high risks, either in impact or
probability, or mainly -- or both, that the Board of

ShEx but more particularly UKGI -- because I think the
governance of UKGI progressed a good deal from the
Advisory Board at ShEx, had a good handle on what was.
going on within the organisation.

So I think this is a point you made repeatedly in your
witness statement, that those deep dives would be driven
by what was included in the risk register?

Exactly.

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activities ..."

Then if we could go over the page, please
“Leadership of specific projects". Now, the reference
to specific projects here would include shareholding
business such as managing the shareholder function for
Post Office?

Of course.
We see there are two bullet points there, which I want
to take in reverse order. The first is:

"To consider and regularly review the ShEx Risk
Register, responsibility for which lies with the CEO."

So that requires the Board to look at the overall
risk register for ShEx, yes?

Correct.

Where it says "responsibility for which lies with the
CEO", was it the Board's responsibility to hold the CEO
accountable in respect of the risks that were included
on the risk register?

It was to ensure that the processes in place were
sufficient to provide risk registers that recognised the
underlying risks --

You --

-- and I think you'll find, in my statement, that in my
first Board I specifically honed in on the nature of the

risk register, and I think I'm right in saying that, as
126

But when a deep dive was then carried out, was that to
ensure that the Executive of the Shareholder Executive
were appropriately overseeing the asset?

Well, I think the best illustration of that is the point

at which I became aware that everything we'd been told
about Horizon was incorrect, which was in March 2019.
At that point, you will see that the cadence of deep
dives into POL is extraordinary, and it goes from, as it
was, not being high on the risk register, to being the
focal point of the Board's attention.

And you'll see, I think, four deep dives which is
way more than any other organisation, if you think there
are 20-plus of them, plus a whole lot of other projects.
I mean, remember, at the same time, I think during this
process we were undertaking about £50 billion worth of
disposals for the Government.

So alongside those projects, the Post Office had
become the most critical aspect and that's exactly when
you saw the Board do precisely what it should be, which
is taking a high-risk project and having a succession of
deep dives.

As I say, those deep dives -- and the reason in March
2019 onwards there were the deep dives, was so that the
Board could satisfy itself -~

Correct.
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-- that the shareholding interest was being
appropriately managed?
Correct.
The Board included very senior civil servants, including
the Permanent Secretary to the predecessor departments
to the Department of Business and Trade?
Correct, and the Second Permanent Secretary of the
Treasury and, as an observer, the Permanent Secretary of
the Cabinet Office.
So the risks or deep dives that were discussed at Board
meetings would be considered by civil servants at the
highest level?
Correct.
They could be very instrumental in shaping Government
action in respect of the individual assets?
Indeed, and were.
Can we look, please, at UKGI00044314 and go to page 2,
please. This is a document that Mark Russell describes
in his statement as the ShEx handbook, published in
2007. If we can go further down the page, please, thank
you it says under "The Shareholder Executive model of
corporate governance":

"The Government intents to operate as an intelligent
and informed shareholder."

Then over the page, please. If we can go down,
129

it can be further away at points and more involved in
some decisions at others?

Yeah, and again, if you want to turn them up, I think
you can see this in my -- the three last meetings I had
with Tim Parker as Chairman of Post Office. I think
you'll see from those notes of meetings that, in each of
the meetings, he says that the UKGI Non-Exec is being
too interventionist and I'm telling him that he's got to

be dreaming and that, in the circumstances in which he
now found himself, he should expect the length of the
arm to be shortened.

We'll come to those -- well, we may come to those
meetings --

I am trying to make the point to you.

I appreciate that. Can we turn the page, please, of
this document. It says "What Government expects of its
businesses" and:

"Principle 1. Businesses should seek an honest,
‘open and ongoing dialogue with the Government as
shareholder.

"Principle 2. Businesses should operate a 'no
surprises’ policy ensuring that the government as
shareholder is informed well in advance of anything
potentially contentious in the public arena."

So as an intelligent and informed shareholder,
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please, thank you. So under the title of "How the
Government intends to operate as shareholder”, there's
the box, "The Basic Shareholder Model", and the very
last point there is that:

"The shareholder monitors the performance of the
business to satisfy itself that the strategic plan is on
track and ensure that any interventions requiring are
well informed and appropriate.”

The Post Office was managed as an arm's-length body,
wasn't it?

Correct.

This morning, Mr Russell agreed that ultimate
accountability and responsibility for the activity of

an arm's-length body rests with ministers; would you
agree?

I would.

You say at various points of your witness statement that
the level of government intervention in the operations
of an arm's-length body can vary depending on the
circumstances?

Correct.

So here, where it says, "and ensure that any
interventions are required, are well informed and
appropriate”, is that obliquely referring to this

position of the Government and arm's-length bodies that
130

should the Government have taken steps to satisfy itself
that the businesses it owned were following those
principles?

I believe that that's exactly what they were doing. We
can come on to whether that was achieved or not --

But as a matter of principle, it's something that the
Government should have been doing?

Of course.

We know the Post Office pursued criminal prosecutions
and carried out work in relation to post-conviction
disclosure as part of the operation of its business,

yes?

I didn't get the last part.

I'm so sorry. I'll break it down into two questions.

We know that the Post Office pursued criminal
prosecutions --

Correct.

-- against subpostmasters.

Correct.

We also know that I carry out work in respect of
post-conviction disclosure, so whether or not documents
should be disclosed to subpostmasters who had been
convicted of criminal offences?

I'm not sure what the question is. I know that now but

I had no idea of any of that at that time.
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So when did you become aware of that?

The second part?

Yes.

During preparation for this Inquiry. I've said that in

my statement. But that's a sort of compendium. Are you
referring to the Clarke Advices, that sort of --

No, I'm not referring to that yet. I'm just asking, as

a matter of generality, you're aware of those two --

Well, I'm aware of the first point but I had no
conversation nor was I aware of what I think is the
second part of your question.

Do you think that both of those matters were serious
matters of which the Government ought to have been given
adequate information by the Post Office?

Of course.

I want to look at your role as Chair now, please. Can

we bring up UKGI00045955.

Unusually, this is a letter from you to Mr Russell
on 25 September. But, if we go to page 3, as it's been
provided, it sets out your terms of reference as
Chairman of ShEx. In paragraph 4, please, if we could
have that in shot, it says:

"As Chairman, your key role will be to provide high
level strategic direction to the Shareholder Executive."

The first point is:
133

up, if you like -- I placed -- and there was a real
purpose to this -- I placed risk as being one of the

first items to be discussed at every UKGI board. So
that the Board meeting would start with the Chief
Executive's report, there would be a people report
because people were at the heart of what UKGI did -- it
was a small organisation with a very particular culture
that needed to be nurtured -- and then there was risk.

And the risk part of the UKGI Board would be every
risk that over the previous month had changed in
character, would be highlighted for the Board, and then
the whole of the risk register, the composite risk
register, would be set out for the UKGI Board.

And I did that because I saw that as the best way,
in an organisation looking after a whole portfolio of
interests, that you can best direct the Board's time to
the things that have been flagged, hopefully
appropriately as the highest risk aspect. That's why,
post-2019, when we appreciated what we had been told was
incorrect by the Post Office, it became the overriding
aspect of the UKGI Board's time.

Well, let's look at some stages on that as you've
described it, as a continuum from ShEx to UKGI. Can we
start, please, with UKGI00016718. It's a Shareholder

Executive Board meeting on 16 July, chaired by Patrick
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"Lead the Board of Directors, ensuring their
effectiveness in all aspects of their advisory role ..."

Then fourth:

"Develop a constructive, frank and open relationship
with the Chief Executive, holding him/her accountable
with the effective implementation of decisions."

In respect of risk management and the completion of
the risk register, what did you see your role as being
in overseeing the Chief Executive?
I think there's the formal and there's the informal. As
far as the formal is concerned and, again, if you don't
mind, I think we should continue the ShEx through UKGI
because it was a continuum -- I mean, if you recall, the
start of UKGI was only nine months after my --
thereabouts, my appointment as Chairman of ShEx, so if
we can sort of treat them as a continuum.

As far as the risk process was concerned, that was
something that, within UKGI, was the prime
responsibility of the Risk and Assurance Committee, and
we made sure there were frequent conversations about
those processes and, indeed, about the underlying risks.

As far as the UKGI Board is concerned, again, as
a continuum, you will see that, actually, I placed risk
right at the heart of the UKGI Board and, in my

memorandum of February 2018, you'll ~ you can bring it
134

O'Sullivan. You're in attendance, it would be as

a Non-Exec Director. If we can go down, please, to risk
registers. Paragraph 2.1 significant improvements to

a risk register and Patrick O'Sullivan is recorded as
saying that he:

summarised that the key aim of the risk
registers should be to provoke questions and cautioned
against making further significant changes.

"RS [that's you] agreed that it was key that the
registers were used to challenge teams as to their
understanding of identifying relevant risks and their
mitigants and added that it [would] be helpful to
identify other organisations with a similar risk profile
and to learn how they recorded risks.”

So from this, is it your position that one of the
uses of a risk register is actually to challenge the
Executive Team on whether or not it is identifying the
appropriate risks?

Correct. In fact, just to go to 2.1, the revisions is

what I was referring to earlier. So I've been on the
Board now since January and, hopefully, we've already
got a better risk register. I don't know why it said,

"RS agreed". I don't know what I was agreeing to,

I think I said.

That document can come down now. Thank you. Moving
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forward to 24 November 2014, I think that's your first
Board meeting as Chair. When I say Board meeting, Board
meeting of Shareholder Executive. Can I, at that stage
ask a couple of questions about your knowledge of
various matters. Can you remember if you were aware of
Second Sight's Interim Report?

Absolutely not.

Were you aware about the Post Office and governance
announcements in relation to the Mediation Scheme?

I wasn't.

Were you aware that the CCRC had been corresponding with
Post Office regarding past convictions?

I wasn't.

I was about to ask about a review of past convictions

and disclosure. You've already said you weren't aware

of that?

(The witness shook his head)

Do you think you should have been made aware of those
matters?

I think, to say that I should have been aware -- made
aware -- means that you have to have assessed that the
people who should have made me aware were themselves
aware or should have been aware. And, obviously, it's
quite difficult for me, looking back to 2014, to know

whether those people should have been aware or, if they
137

culture that was not in the business of giving
information. I can't tell you whether information was
withheld deliberately or whether they simply didn't give
it but, whatever the reason, there was -- there were
a whole range of things that should have been known to
the Board of the Post Office and then, therefore, to the
ShEx/UKGI Board member and, as a result of that, to the
UKGI Board and, had it happened, you would have seen
exactly what you saw in March 2019. We would have been
onit, in spades.

And, sorry, the second point is curiosity, and I'm
afraid that when an incomplete curiosity, if I can put
it that way, meets a toxic culture, bad things happen.
When you say lack of curiosity, do you mean in the Post
Office alone?
I didn't say a lack of it; I said incomplete.
Okay, the criticism you have regarding curiosity is your
criticism solely of Post Office or is it internal within
ShEx as well?
Well, it's of the -- it's of the Post Office, but we
have to acknowledge that ShEx had a member on the Post
Office Board.
Well, we'll explore those matters as we go through the
timeline as well. So as we go to the 24 September Board

meeting, can I look at the spreadsheet, please, which
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weren't aware, should have made themselves aware.

I mean, I can give you a longer answer to this because
it's right at the heart of the whole issue. But how you
want to --

Let's break it down. The first question is: if everyone

in the chain from is acting in the way they should have
been acting from the Post Office Executive Team to the
Board, should you have been made aware?

Yes.

Yes. Where do you think the problem that led to you not
being aware of that issue?

I think -- if you ask me about what I think went wrong,
you'll hear this -- these two words mentioned a number
of times. I think it was a mixture of culture and

curiosity and, by culture, I mean, in my view -- and
again, if you look at all of the Board discussions of

UKGI after the period that we had really got stuck into
this, because we became aware of it after the March 2019
judgment, there is a lot of discussion about culture,

and there's even a discussion between me and Tim Parker
at one of our sessions about culture. It's clear to

me -- it was clear to us then, and by then, I mean in
2019 -- that the culture at the Post Office was

shocking.

And, by that, I mean that it was a closed, defensive
138

I think is UKG100016864.

Sorry, I say I think it's a spreadsheet, some of
these are spreadsheets as documents, that's why it might
take some time to get them on screen.

We see in the very top left this is a document for
the ShEx Board, 24 September 2014. It's been zealously
redacted. I think if you don't see the redactions here,
what you see is on the heatmap, as it were, there will
be other UKGI or ShEx assets listed at various points of
the register; is that right?

Correct.

When you refer to the risk register at the Board in your
statement, are you referring to a document like this?
Correct. I'm quite surprised, looking at that one, at
the absence in the top right-hand corner. It must have
been a particularly good month.

What we see left is, we have a scale of impact. What
does that measure?

The impact of whatever the risk is.

The bottom is probability --

Correct.

- so that's the likelihood of it happening?

Yeah.

If we can zoom in, please, on the narrative box at the

sort of bottom left centre. Thank you. So it says
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"[Post Office] Overall Risk Profile, RA", that's
Red/Amber. It says:

"If not managed successfully -- collectively the
risks have potential to significantly impact the
commercial strategy and financial sustainability of
[Post Office Limited], jeopardising the long-term policy
objectives of transformed network, reduced [Her
Majesty's Government] funding and mutualisation."

So this says what the potential effects of risk are
broadly but it doesn't expressly identify what the risks
are, does it?

No.

From reading this, the potential risks do seem
significant?

Well, not especially, in the way that it's positioned in
the risk register matrix, no. I mean, it's clearly much
less of a risk with impact than many other of the ShEx
entities.

Pausing there, on that point, is it fair to say that
Shareholder Executive managed -- the assets it managed
were, generally, high-risk assets?

They were, by definition, normally high-risk assets,
because assets that were in a steady state, like

Companies House, went back to the department from which

they'd come.
144

I'm afraid, 10 years later, I can't answer that.

That can come down, thank you.

I suppose the only point I'd add to that is that -- and
there's no question that we improved the governance of
UKGI over the period from there, which is my first --

I think that -- was that before the --

Your first as chair.

My first board as chair, to the period where we started

to focus more particularly on Post Office and risk, and
you can see it -- I mean the discussion of risk would
have been explicit because of the way each of the Board
papers on risk were set out, so it would have been
almost impossible to have such a, if you like,

imprecisely described risk in the new regime.

Can we just look, please, at UKGI00016783. This a board
pack for a UKGI Board meeting on 16 May 2018.

Yeah.

Could we look at page 23, please. It's another case of
zealous redactions. We see on the left, "UKGI
Reputational Risk" and on the bottom "UKGI Delivery
Risk". Is that delivery --

Delivery of the policy objectives.

Just as a broad point, how does the human impact issues
of allegations of unsafe convictions fit on to a scale

such as this?
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Is there a problem with focusing on the relatively
highest-risk assets within that pool, because assets
which, by ordinary standards, would be high risk, aren't
given attention?
Not really. I think all of the assets in the ShEx
portfolio got attention.
Under "Reputational Risks", it says:

"There is a significant political interest in the
Post Office Network and there are number of policy
objectives in connection with the network which need to
be delivered by the end of the current Parliament. The

ShEx POL team are aware of the pressures and are working

collaboratively with Post Office Limited to manage the
risks away."

Again, this doesn't identify any risk expressly,
does it?
No, it doesn't.
It doesn't say how the Post Office team are mitigating
the risks?
It doesn't.
So does this risk register raise more questions than it
actually answers, in respect of Post Office's risk?
It certainly raises questions, yes.
Were questions asked about Post Office's risk at this

board meeting?
142

Sorry, the UKGI -- that is delivery of the objective of

the underlying entity.

Yes, and my question is, if UKGI were presented with the
risk of Post Office Limited having secured unsafe
convictions --

Well, it would be about a 10 on reputational risk.

So that would be a reputational risk?

Well, and a delivery risk. I mean, delivering the Post
Office objectives and convicting wrongly subpostmasters
is clearly not compatible, is it?

In your witness statement, you refer to this document --
we don't need to turn it up, it's page 39 of your
statement, paragraph 101:

"This is showing the new format of the Board pack
with a more prominent risk register shown in its new
position."

This is the document you're talking about?

No, I'm talking about the Board paper, which, if you
scroll, up you'll find.

Is that the narrative Board paper which sets out when
risks change?

It's the Board paper that comes at about item 4 on the
Board agenda and introduces changes in risk, or any
‘other comment on risk, if you want to turn to it.

Well, we'll come back to that shortly. There's
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a significant amount of redaction in it, but we'll

double check where it is and come back to that?

It is quite important because this, actually -- May

2018 -- is the first implementation of the new style of
Board agenda.

We will come to that. Can we please turn over the page,
please. And, again, if we can zoom in on the Post

Office box. So you've got the delivery risk profile,

and the reputational risk profile. Reading those,

again, those don't identify expressly what the risks to
Post Office are?

That is true but you have to take this also in the

context of the Board reports that would have been coming
to the Board about POL. I think I'm right in saying

that, between the time that I went on the Board of ShEx
and the March 2019 turning point, there were eight times
in which POL was referenced in the Chief Executive's
report. So you've -- this isn't in isolation. There

would have been discussion and information about POL in
other ways.

And --

And, by the way, all of -- pretty much all of those

eight references in Board papers were about the funding
and commercial agreement arrangements, which were, at

that point pivotal -~ well, they were existential for
145

SIR WYN WILLIAMS: Yes.
MR STEVENS: I want to go to the Board briefing pack point,

ro

POPS

2

please, and if you can go to UKGI00016783 at page 4.
I was asking you questions about the risk register that
the Board were relying on. This is the contents of the
pack and we see at 6 the Chief Financial Officer's
update; 7, Risk Register review; eight, NDA -- Project
review.

The Risk Register review is said to be page 23. If
we turn to page 23, that is the document we were just
looking at. What other document were you referring to?
It would be about a three or four-page document which
would set out the -- any particular issues that needed
to be highlighted and any changes to the risk rating of
any of the underlying entities. So if you go back to
the agenda --

Page 4, please.

-- you will see that it's a -- well, in this case it's

a three-page document.

As you see, if we go back to page 23 --

I can't --

That is the --

I've got -- I mean, I've looked over the last weeks at
lots of --

Let me ask it in another way. Can we go to
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the Post Office.

Q. Yes, and, of course, your evidence is that the Horizon
related risks weren't included on the risk register for
the Board until 20197

A. Correct.

MR STEVENS: Sir, with the transcriber in mind and the early
start, I think it's probably a good time to take our
afternoon break there.

SIR WYN WILLIAMS: Yes. Save for this, Mr Swannell, by
2018, the Group Litigation was actually in being. So
I was just wondering whether there was any separate
process by which your Board, if I can call it that, was
being informed of what was occurring in the Group
Litigation?

A. It wasn't.

SIR WYN WILLIAMS: So you knew nothing. Fine, okay.

Yes, we'll have our break now. What time shall we
resume again, Mr Stevens?

MR STEVENS: If we could say 3.15, please, sir.

SIR WYN WILLIAMS: Yes, yes.

MR STEVENS: § Thank you.

(3.05 pm)
(A short break)
(3.18 pm)
MR STEVENS: Can you see and there us?
146

UKGI00045959. This is --
That's it.
So that's data for 29 November 2018.
Yeah.
Just so we're clear, we can figure out what documents
went where on the documents themselves?
Right.
But that is the type of document you're referring to?
A. Exactly and I don't know how long that one is but
they're normally two to four pages.
Q. If we look at page -- well, let's just look at this.
It's 29 November 2018, so just before the Common Issues
trial. Sorry, the Common Issues trial is effectively
upon Post Office. If we look at page 4, please, right
at the bottom --
A. I think I refer to it in my witness statement, the --
I think the risk was reduced for POL.
Q. Yes. We're just going to look at that now. It says:
"Post Office: Director -- Tom Cooper.
"Delivery Risk: Red/Amber (No change).
"Reputational Risk: Medium (Decreased from High).
"Change due to improved performance making [Post
Office Limited] profitable and therefore increasingly
self-sufficient financially.”

Again, this document wasn't highlighting expressly
148

prop

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what the risks to Post Office were, was it?
Correct. I think I made that plain in my witness
statement, that the first reference to Horizon is in
January 2019.
Yes. That document can come down. Thank you.

Why did the Board think that that type of
information was sufficient to challenge the Executive on
whether it was identifying risks appropriately?
Sorry, I don't know exactly what -- normally, there
would be some narrative in the reference to the changing
of the risk. You took it down before I saw anything.
Was there nothing there?
Well, we can bring the back up, please. It's
UKGI00045959. Page 4, please, at the bottom, and then
if we can go over the page, please. It's been marked as
"Irrelevant".
I can't answer that. I can't recall why that would have
been sufficient or what the context was at the time or
what was said at the meeting. I think it's a perfectly
fair question.
But you can't assist us with --
I can't, no.
Just so we can pin down what the Board actually had,
please could we bring up UKGI00002488. This is an email

at the bottom we see from Emma Lee to James Baugh and
149

preparation for this Inquiry.

If we could scroll down, please, to risk 11. It says
Project Sparrow. At the time, would the words "Project
Sparrow" have meant anything to you?

No.

We see it says "Risk Overview":

"The Working Group is unable to progress cases and
the process is publicly criticised by applicants and the
JFSA."

If we look at "Mitigation Overview":

"ShEx is ensuring POL closely engages with members
of the Working Group and seeks to address issues over
the operation of the Working Group if they arise."

"Further mitigating actions”:

"Provide robust responses to queries about the
Working Group stating the findings of the initial review
that there are no systemic issues ..."

That's referring to the Horizon Interim Report.
and that there's an independent Chair. Caution
needs to be exercised to ensure that the independence of
the Chair is not undermined."

Do you think that ShEx's involvement in issues like
the Mediation Scheme should have been raised with the
Board?

I think, with the benefit of hindsight and all that we
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Richard Callard cc'd in. It says:

"We are now commissioning updated registers from all
teams for September. I have attached your latest risk
register for you to update.”

It says:

"Please forward me the update file by close of play
on Friday, 3 October."

Now, earlier I was talking about a Board meeting,
your first Board meeting as Chair on 24 September 2014.
So this forwarding a Post Office Limited risk register
that was in play before your first Board meeting as
Chair. I don't suggest you've seen this email before
but it's just to place it.

I've seen it when you disclosed it a few days ago.
Sorry, I'll rephrase that. You haven't seen it at the
material time?

No.

Can we bring up the attachment to that email, please,
it's UKGI00002489. Mr Russell's evidence this morning
was that this type of detailed register was not provided
to the Board?

Correct.

Would you have ever seen a detailed register such as
this for Post Office Limited?

No, the first time I saw this or anything like it was in
150

know about what was not known at the time, clearly the
answer is yes.

Earlier, Mr Russell was discussing the fact that the

risk that wasn't recognised was with the IT system
itself, and the risk of unsafe convictions.

Correct.

Do you think that should have been identified as a risk
by Shareholder Executive at this time?

Again, I think you're asking me to put myself in the
mind of somebody 10 years ago to know what they should
have known and/or did know. I mean, all I'm telling you
is, today, looking at the facts that we do know, we
should have known about this.

At this stage, information about the Interim Report and
the Mediation Scheme and ShEx's involvement in that,
what do you think would have happened at Board level if
that had been raised?

Exactly the sort of thing that you saw raised from March
2019 onwards.

So a deep dive?

A succession of deep dives. Had we known all of the
facts -- I mean, the truth is, as far as I can see --

and this is what I talk about in complete curiosity --
nobody at any point in this had ever come to

a conclusion on the totality of the Horizon system, and
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so when I talk about incomplete curiosity, I include in
that not following through to a conclusion as to whether
or not Horizon could or should have been relied on.

So if this had been raised to your attention at this

time, when the Working Group was in action, would you
have counselled to see it through, as you describe it,

or to try to come to a final conclusion?

Look it sounds very clever after the event for me to say
that but I would have wanted to know that there was

a conclusion and whether I would have commissioned
a further -- asked for the commissioning of a further
independent report, I simply can't tell you, but that
would be the natural thing to see through. And that, as
far as I can see, is what did not happen here. So,
again, I've sort of shorthanded for you the issue of
culture and curiosity, but that's part of the incomplete
curiosity.

I want to move on slightly now. We've looked at what
documents the Board had before it. We'll come back to
that in due course but just to creep things
chronological, I want to look at some meetings you had
with chairs of Post Office. In your statement, you said
that you would meet with the Chair of Post Office once
a year, roughly?

Sometimes more but roughly, yeah.
153

four headings: Board Review; Future Challenges Facing
Post Office; CEO and Management Capability; and Post
Office's Relationship with Government. The bold text

sets out matters on which you might ask questions, for
example, "Board Review’, you might consider asking Alice
about her views of the evaluation.

This briefing goes beyond merely this being
a meeting for you to ask how UKGI officials are
performing?

Of course.

So this was an opportunity, was it not, for you to
discuss business issues with --

Of course. I mean, it would be extraordinary to go into
a meeting with the Chair of the Post Office and say,
“Hows our person doing?", and then end the
conversation.

If we look at paragraph 1.2, it says:

“After almost four years as Chair Alice will be
leaving in July. It would be useful to ask her for her
honest reflections on the challenges going forward,
including what she would like her successor to address

In your statement -- we don't need to call it up but
it's page 32, paragraph 82 -- you say:

"I do not recall any of my meeting with Alice but
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You say that you would not describe it as part of
an oversight role. You say it was explicitly intended

to get feedback on UKGI performance in its role as
shareholder?

Correct.

In your experience of acting as Chair or Non-Executive
Director of other businesses, have you ever had a role
like that?

Like what?

As a Chair in meeting other -- well, meeting members of
a business you're overseeing, purely to see how someone
you're responsible for was performing?

No, because I've never had a role that occasioned it --
Could we, please --

-- and, by the way, the only experience that I could
possibly have is as the Senior Independent Director of

3i Group, and 3i Group was a venture capital and private
equity organisation with many underlying investments.
The Chair of 3i would never have met any of those
underlying investments ever. So, in a sense, this is
over and above that.

I want to turn to your meeting with Alice Perkins on

8 April 2015 and, if we look at your briefing first,

it's UKGI00045533. So if we can just get all of the

points considering raising aspect in. We see there are
154

I think it is unlikely we would have discussed Horizon."
Correct. I think this is the only meeting where I don't
have a meeting note after the meeting, and I regret

that, I also, actually, regret that the follow-up

meeting that I had suggested never happened and I set
that out in my witness statement.

So the Chair of Post Office and the Chief Executive,
Paula Vennells, had just two months before this meeting
appeared before a Select Committee to discuss matters
appearing from Horizon. Why do you think it's unlikely
that you wouldn't have discussed Horizon or she wouldn't
have raised it?

Because I think I would remember it -- well I think I'd
remember it if she had but, I mean, in truth, I can't
remember. So I can't categorically tell you.

Can we look, please, at another one of the more detailed
risk registers. It's UKGI00004686. This is first

an email.

By the way, the reason that I surmised, I think I said

in my witness statement, that I hadn't talked about
Horizon is because Horizon wasn't mentioned in the
briefing note and, therefore, there was no particular
trigger for it but that's the best I can do.

This is an email from James Baugh to Richard Callard and

others on 25 June 2015. It says:
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"We have been asked to provide an updated [Risk
Register] by 3 July."

The latest copy is attached.

We see attached is "Risk Register_June15". If we
could open that risk register, it's UKGI00004687.

If we could go to page 2, please, we have the same
detailed risk register as before and I understand you
wouldn't have seen this at the time. If we can go,
please, to risk 11. We have Project Sparrow, if we
could make that line bigger, so we can read it. Thank
you. It says:

"Increase the tact from JFSA against Post Office and
alleged faults with Horizon system including attempts to
derail of the Mediation Scheme set up to address
individual cases."

Then on "Mitigation Actions":

"Shareholder Executive is ensuring Post Office
Limited addresses issues as they arise and is seen to
take the lead on this matter. Important that the
Mediation Scheme remains independent of Government."

You'll see at the "Further Mitigating Actions":

"Respond to queries, especially for MPs and
Parliament, maintaining scheme's independence from
Government and the fact that no systemic issues with

Horizon have been identified.”
157

I think I can only give you the answer that I gave to

the question that you asked of the previous risk
register, is that, if we -- if we had known what we know
now, or if the people compiling this had known what
they -- what we know now, then clearly this should have
come to the Board. And I say that -- I mean, I say that
explicitly in my witness statement.

Well, yes, this is referring to the CCRC being involved,
so involving the investigations into whether convictions
were unsafe. Serious issues that are raised, and the
probability and impact score has been 4 for each. Now,
you've reviewed the documents, as you say, and you've
produced a witness statement to help with lessons
learned. In your reflections looking back, what do you
think went wrong that meant these risks, quantified

at 4, for impact and probability, weren't raised with

the Board?

Well, I'm just trying to understand this. There's
probability -- it's -- I'm finding it quite difficult to

read the writing, but isn't that a 3 in the risk?

No, we can go to the top to show, it's on the left-hand
side, there's 4 and 4, and then the right, 3 and 3?

I think the simple answer to your question is if --

I mean, if you're asking me do I think that, if the

scale of the issues then confronting the Post Office had
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Then it refers to the CCRC, it says:

"Take legal advice on CCRC investigation and ensure
all relevant documents are saved."

We see the risk rating for reputation and finance,
the probability and impact is 4 each, you see in the
middle. Can you translate that for us as to what that's
saying, with a risk rating of 4?

It's 80 per cent of the highest.

Would you have expected this report to be submitted to
the audit committee of Shareholder Executive?

Again, I think it would depend -- it would depend -- it
would depend on the knowledge of the people compiling
this at that time. Are you saying because it's a four

by four, that it should have been discussed?

Well, that's my question, yes.

I'm not sure necessarily with the Audit and Risk
Committee. The Audit and Risk Committee was responsible
for setting the processes and agreeing the processes by
which the Risk Registers were compiled. Actually,
although, perhaps not in this -- which year is this?

Sorry, this is June 2015.

I mean, there wasn't -- obviously, there wasn't a Board
in 2015 with a -- an Audit and Risk Committee. So
actually, these issues would come to the Board if they

were thought to be of sufficient severity and -- I mean,
158

been known to this team, that they should have escalated
it in the risk register? The answer is yes and that's,

I hope, what I've said in my witness statement.

Yes, and --

I think I said "could or should".

My question is, having reviewed this in detail, as you
have, can you help us with, in terms of the process, why
it wasn't raised when, on the face of it at the time,

the unmitigated risk on the left was assessed at 4 for
probability and impact?

I can't. I can't help you, no. I can't put myself in

their minds.

Do you think the Board could have taken more steps to
ensure that risks such as this were appropriately raised
to it?

No, because I think the answer is the processes that
were in place were -- which is a monthly -- and, again,
I'm happy to go through it -- but a monthly evaluation
of the risk register was as good a process as you could
have, and I think is as good a process as any company
that I've seen. What is missing here is either the
knowledge or the judgement to put that risk in context
and that's why I've said in my witness statement,

I think quite clearly, "could or should have been drawn

to the attention of the UKGI Board".
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When you say knowledge and judgement, whose knowledge
and judgement are you referring to there?

Those who were exercising the judgement on these
matters. But I can't - looking back, I can't put

myself into what their knowledge was, and I can't tell
you in a sort of mathematical way whether every risk
that is rated at that number should be escalated to the
UKGI Board. If you ask me the question, if you knew
that there was a serious risk of wrongful prosecution of
one or more subpostmasters then, of course, that's

a matter that should have been raised with the UKGI
board.

Please can we look at a different document which is
UKGI00020145. So this is a Shareholder Executive
dashboard. It's from January 2016. Earlier in your
evidence, you refer to it being sent to you in October
2015?

Correct.

It's neither here nor there for these purposes, really.

If we look at, please, page 3 we see the Post Office
“Governance -- Top Priorities", and some bullet points
here. For you as Chair, for what purpose did you use
this document?

Well, as I say in my witness statement, I didn't use it

to calibrate the risks. What I used it for was as
161

particularly explicit, nor did that give rise to
conversation. But, again, remember that the context for
this -- I think I've said already -- there would have
been eight Chief Executives’ report before we get to
2019, referencing POL but not referencing Horizon.
Can we look, please, at UKGI00020297. I want to look
now at some of the meetings you had with Tim Parker.
This for a briefing for your meeting with Tim Parker on
9 July 2016. UKGI have provided metadata for this
document, suggesting it was dated 6 July 2016. At
page 3 of the briefing, please, it says:

"Tim may mention legal action being brought against
[Post Office] in respect of its IT system Horizon and
the claims that it wrongfully prosecuted/sacked a small
number of agents. Tim has undertaken to review the
matter for the Minister, but in the face of High Court
proceedings now being launched they may need to
reconsider."

Knowing what you know now, do you think that
accurately reflects the status of the litigation?
I mean, the answer has to be, knowing all that I know
now, no.
In your witness statement, you refer to a briefing with
Laura Thompson, Richard Callard, Justin Manson and Tim

Mclnnes on 13 July 2016, yes?
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a very handy way of looking at what the underlying
issues were in the 20 plus entities and many more
projects that were being undertaken by UKGI.

We looked at the risk registers earlier which didn't set

out the risks in any great detail, so when you read, we
see, "Minimise HMG and POL exposure (financial and
reputation) to Horizon IT issues", what did that mean to
you?

I can't tell you exactly I what it meant to me in

January 2016 but, clearly -- well, actually, I say

clearly -- I don't think by then I had been briefed for

any Chair meeting, including references to Horizon. So
I'm not sure what it would have meant to me, and I have
to say, I mean, obviously I look at it now, and I wonder
whether it should have -- and I reference this again in

my witness statement -- whether this should have had
prompted me to ask many more questions but, on the face
of it, it didn’t. And, by the way, it didn't fool one

of the most experienced Boards that I've had the

privilege to work with, including three Permanent
Secretaries.

That was my next question. At any stage up to this

point, had the Permanent Secretaries asked any questions
at Board level about Horizon issues?

No, nor did that one line which isn't, you know, isn't
162

Correct.

At that meeting or briefing, can you recall discussing
the Horizon IT System?

I've no idea, I'm sorry.

Do you think before this you were aware of the
allegation that Post Office had wrongly prosecuted/
sacked a small number of agents?

Again, I'm sorry but it's very difficult for me to
remember precisely when, in a period over the last eight
years, I knew. I say in my witness statement that

I have to assume that I knew at this point because
that's the earliest that I probably could have done.
Whether I did or not, I don't know.

With you being aware of this allegation, can you explain
why you didn't take steps to see that this allegation of
wrongful prosecution, why that wasn't included on the
risk register?

I can't explain, no. I think I would say that this is

a three-page note and this is the last item on it, and
that puts it in some context.

Well, it says it's an allegation of wrongful
prosecution; that's a serious matter, isn't it?

It is, if I understood what wrongful prosecution meant.
And it's -- I can't tell you whether I knew at that

point that the Post Office was a prosecuting authority
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or not. I can't tell you.
Would you accept, based on being on notice of there
being claims of wrongful prosecution, that you should
have done more to see that this allegation was put on
the risk register?
Look, I address that full on in the witness statement.
It's hard to know, in the context of all of the other
things within UKGI, whether this is the one that
I should have alighted on and didn't. Obviously, with
the benefit of hindsight, as I say, I would wish that
I had; I didn't.
Could we go, please, to UKGI00016783. We went to this
document earlier, it was the Board papers.
Yeah.
Could we look at page 101, please. There we see it's
the UKGI dashboard, April 2018. If we can go, please,
to 105, and I think it's third bullet point down. It
refers to:

"Civil litigation judges that [Post Office Limited]
has acted inappropriately or [I think that will be
illegally] on the ‘Horizon case'."

Can you recall whether this risk on the dashboard
was picked up by the Board?
It wasn't, or it would have been mentioned in the

minutes. But remember the dashboard was not presented
165

Correct.

There's a ‘for information’ piece which provides a bit

of detail on some of the risks; do you agree?

lagree.

Was it not a failing of the Board to fail -- to not spot

this and to see that the civil litigation and the

underlying issues were put on to the risk register?

I mean, I can tell you that the Board did not, and if

you -- it was a very experienced Board. If you want to
say that was a failing, that's a matter, obviously, for
judgement by the Inquiry.

Can we have a look at another meeting you had, please,
with Tim Parker. It's UKGI00008374. You see at the top
it says, "Briefing for meeting with Tim Parker,

11 September 2018". Under "Challenges and
opportunities", it refers to the litigation, and the

final sentence of that paragraph says:

"UKGI have not yet been satisfied that the business
has done enough to identify, assess and manage the
risks."

Do you recall your thoughts when you read that?
I don't recall my thoughts when I read that, no.
I mean, I can -- I've put some context about this in my
witness statement, if you want me to refer to that?

Well, we have your witness statement. I ask you
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for discussion at the Board; it was presented for
information and, as I've said to you and I have made
clear in the witness statement, it would have been
inconceivable to me that a matter referenced at, I think
you say, page 100 as a ‘for information’ item in the
dashboard would not have been included in the risk
register if it was a matter of deep concern.

We looked at this document and saw what was in the risk
register didn't actually identify what the risks were,
yes?

What I'm saying to you is that, for the Board, the Board
was given two documents. One at page 100 is the
dashboard and, secondly, is the risk register. And it
would have been inconceivable to me -- looking back,
clearly I was wrong -- it would have been inconceivable
to me at the time that a matter that was of deep concern
and a grave risk should be mentioned in the dashboard
but not drawn out in the risk register and positioned in
the risk matrix.

Well, it's right, isn't it, that one of the Board's

roles is to challenge the executive and see that the
appropriate risks are being identified?

Correct.

The risk register we went to earlier didn't expressly

set out what the risks were?
166

directly: what do you think you would have thought,
having read that, the fact that UKGI were not satisfied
that the Post Office had done enough to identify, assess
and manage the risks of the litigation?

Well, I was aware, by this point, that Tom Cooper, who
was the new Director on the Board, as a result of the --
sorry, when I say I was aware, I was aware that there
was a much greater degree of engagement by Tom Cooper in
relation to this litigation, of which, of course, I was
aware, at this point.

So if we look at the bottom, is that what this is

referring to:

“While we have a strong relationship with both Tim
and [Post Office's] CEO (Paula Vennells) there has been
some recent tension with specific individuals pushing
back at what they see as undue interference."

Yes.

Do you know who the individuals pushing back were?

No. Well, I can only assume that Tim must have been one
of them because in -- whether in that meeting or the two
or three subsequent, I think, at various points, he

talked about trampling over the undergrowth or
excessively executive behaviour of Tom Cooper and

I increasingly pushed back on that.

Are you effectively being asked here to step in and
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assist with UKGI satisfying itself as to whether Post
Office has identified, assessed, and managed the risks?
I don't think so, no. Do you want -- can I see the end
of the paragraph?

Over the page, yes, of course.

No, I mean, at the end oft, it says, "It would be good
to get Tim's take on this", so I'm being invited to get
Tim's take. Not step in, I think.

Did you consider at that point it to be a significant

risk to UKGI that it had not satisfied itself as to

POL's identification of the risks in the litigation?

I was aware of the escalating view from Tom Cooper and,
again, I couldn't precisely tell you when, that POL were
not sufficiently engaging in contingency planning and,
in particular, for the possibility of loss.

Could we look, please, at UKGI00045945. This is your
email of the note of the meeting with Tim Parker.
Yeah.

Was there no discussion of the litigation at this
meeting?

I can't tell you. All I can do is refer to the note.

I'm afraid my memory doesn't go beyond that.

So your best recollection is -- well, sorry -- you're
limited to this note?

When was the meeting? I can't recall.
169

I don't and, again, I think it's surprising but probably

just an error that there was no reference in the risk
paper to the change in the rating of the risk.

Was there any discussion at the Board of the addition of
the litigation case on the risk register?

No, and, again, as I said in my witness statement,

I think, again, that was -- it was a very unusual Board.
The entire Board of UKGI had gone to Sellafield for that
meeting. The great preponderance of the meeting was
about the Nuclear Decommissioning Authority, as you
would expect, and there was another major item on the
agenda. And I think it's probably the only time in

my -- that I can recollect, where I don't
go to the minutes to be clear, but I don't think the

risk register was taken in its normal order and context,
because it was, in fact, in my entire time at UKGI, the

‘only Board meeting that took place outside the offices

of UKGI at Sellafield.

We then get to March 2019 and that's when Common Issues

- I'd have to

is handed down. In your witness statement, you say
that:

"From that point onwards, Post Office and the issues
surrounding the Horizon IT System became a top priority
for the UKGI Board and also for me as Chai

I want to look at a lessons learned document that
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The meeting was 11 September?
So it’s three days later. It's my best recollection.
That document can come down. Thank you.

Please could we --

But, again, you see his gripe is about the interference.
Please can we turn to UKGI00016800. It's the Board pack
for the meeting on 29 January 2019. If we turn, please,
to page 55. Actually, can we start with page 50,

please, actually. We see this one of the risk register
review papers I think you were referring to earlier.

And if we just scroll down the page, as -- well, you can
take it from me, it's all marked as irrelevant, that

paper.

Okay.

There's none of relevance in there. Can we then turn to
page 55.

We see that's the risk register with Post Office
Limited towards the top right. Then, if we turn,
please, to page 61. Under "Reputational Risk", we now
see that it says:

"There is an ongoing [Post Office] litigation case
which could potentially generate a high level of
negative coverage.”

Do you recall what had happened that led to this

being included in the risk register?
170

you refer to in your statement prepared by UKGI, the
reference is UKGI00048173.

We see it's a draft of the document created 28 June
2021, and I understand that you agree with the
recommendations within the report; is that right?
I was instrumental in its preparation, yes, and in its
discussion.

Can we look, please, at page 2, paragraph 2.4. At the
bottom of 2.4 it says:

"The degree of control and oversight that the
Government has over a Public Corporation should be both
reasonable and proportionate to the public corporation's
functions and risk profile. Accordingly, what is
appropriate in terms of oversight is subject to change;
as POL's risk profile has increased so too has the
degree of oversight exercised by government."

Which I think is the point you made at the start of
your evidence. We have seen that the underlying risks
of the litigation have been shown by the Shareholder
Executive for years; would you agree?

Correct.

Would you accept that the handing down of the common
issues was an example of a risk materialising?

It was -- for me, it was more than that. It was --

again, I haven't referred to it because, as far as I can
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in my witness statement and now, I have tried to rely
almost exclusively on written evidence because I find it
very difficult to know at what particular point in
a ten-year period that you knew something. So it's
better rely on written evidence. But, for me, the
Common Issues judgment -- and I'm making a person
statement here -- provoked an utterly visceral reaction.
I had heard, for the previous 'n' years, there is
nothing wrong with Horizon, 6 million transactions
happen every year, there are 11,500 branches where
mostly it happens, there is never a problem with the
Crown. Again, I'm giving you anecdotal stuff here, not
evidence by writing but I can tell you that's what I'd
heard.

And I suddenly see this Common Issues judgment, and
again, I can show that it's visceral because, as you
know, I got this email about the Common Issues judgment
at 8.00 on a Friday when I was on holiday and I replied
to it by 9.21, saying what my views on it were. And
I can tell you -- and anybody who has worked with me
understand this -- when I start an email saying, "This
does not look at all good", it means a great deal more
than that in the sort of language that I tend to use.

I then go into a series of issues about whether

lessons had been learned from the Magnox episode and,
173

Do you mean was it background noise in looking at the
risk register? I'm sure it would have been. But,

again, I can't tell you exactly. So you showed me the
risk register in 2015 and you've shown me the risk
register in 2016. I can't tell you at which point

I knew or heard a particular thing. It might have been

in 2018. I really don't know.

At any stage before the handing down of Common Issues,
were you told of the allegation that Fujitsu could
remotely access --

Never.

-- branch accounts?

Never heard that. Had no reference to it at all.

Do you recall having any conversation about criminal
convictions with anyone in UKGI or ShEx prior to Common
Issues beings handed down?

Criminal convictions? I knew -- I must have known there
were prosecutions.

Earlier we referred to wrongful prosecutions --

Correct.

-- but, aside from that meeting I took you to, can you
recall any other conversation?

No.

In your witness statement, you say that it's significant

to note that the role of the shareholder changes when
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from that moment on, including the recusal, I was
absolutely on it and I could almost say obsessively.

In your evidence, you were explaining the visceral
reaction because -- and you've referred to being told --
the transcript has gone but I think you said for years
that Horizon was okay, it processed 6 million
transactions. In what context did you receive that
information?

Look, I was Chairman of UKGI. Again, I've tried in my
witness statement only to set forward evidence that is
backed by writing but, of course, as Chairman of UKGI,
as I set out in my witness statement, I spent a lot of
time in the organisation listening, and it would be
impossible over that period not to pick up some of that
background noise. I can't tell you precisely which
years I would have heard that but I did hear it and,
actually, the one thing of all of them that's stuck in

my mind that I would have been told at some point,

I can't recall when, was the view of the National
Federation, and, again, I can't tell you when that was,
but at some point before 2019.

Did you rely on what you were being told about Horizon
being okay and it processing 6 million transactions in
deciding whether or not the Horizon related issues

should go on the risk register?
174

the underlying company has effectively betrayed the
trust that its shareholder has put in it.

What role does trust have in a shareholding
relationship?
Ithhas a huge role, in assessing -- I mean, that's why
I started by talking about culture and curiosity.
Culture in an organisation, and your feel for it, is
utterly pivotal in how you behave as a Board member, and
I've been being fortunate enough to be involved in a lot
of Boards, either as a Board member or as an adviser to
a Board and you can -- with experience, you can quite
quickly get to an understanding of culture and therefore
on trust.

And that's why I think those -- the trust that
a Board has with its chief executive and a shareholder
has with its Board obviously changes over time. What
I can't tell, because I have no experience of it, is
what sense of trust the POL Board felt about the
executives who were reporting to it and, in turn,
because my connection with the POL Board was
a once-a-year meeting with the Chairman, it's pretty
difficult for me to give a view on whether there should
be trust between the shareholder and the Board but trust
is utterly fundamental to the relationship. When trust

goes, everything changes.
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I think it's important we cover some of the
recommendations with you. So there are some factual
parts of your witness statement which I'm not going to
cover but let's turn to look at some issues to do with
recommendations. Can we please bring up your witness
statement at page 22, paragraphs 54 to 55. In fact, if
we just get up 55 -- thank you -- you say that:

"[Youl believe that [arm’s-length bodies] have
an important part to play in the governance of state
assets. It allows [His Majesty's Government] to set
policy objectives and appoint a Board of suitably
qualified people to achieve those objectives. Clarity
of purpose can be achieved through a framework document
and Chairman's later. Oversight on good governance can
be achieved through the role of [His Majesty's
Government] as shareholder and with the framework
document, articles of the entity, and through
representation on the relevant Board. The most
important tools for [His Majesty's Government] in this
arrangement are approval of keyboard appointments and
ensuring that the Chair and CEO are rigorously and
regularly assessed against their objectives.”

Who within Government was responsible for the
rigorous and regular assessment of the Chair and CEO of

POL?
177

financial objectives. So it would be officials from
ShEx/UKGI and from the business department.
Looking back as you have done, do you think that the
setting of objectives and monitoring was satisfactory?
It's quite difficult for me. I mean, the answer is the
‘outcome was clearly wholly unsatisfactory. What I can't
do is put myself in the position of all of the

information known to people at the time. I mean, my
assumption has to be no, in relation to this aspect that
we're talking about.

If we turn over the page, please, to page 66,
paragraph 169, the last sentence, you say:

“In my view the most important lesson to be learned
is how to properly train Boards and their members to
ensure continual curiosity and to develop a culture to
allow that curiosity to make a difference in Board
effectiveness."

Can we infer from this that your view is the core
issues here was a lack of skills or training on the part
of the Directors of Post Office Limited?

Well, I've -- again, let me just go a bit deeper into

this. My view, again, and I repeat it because I think
it's utterly fundamental to this, is the culture at the
Post Office and on its Board was not good. The result

of that was that information flow was imperfect, to put
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Amongst other, ShEx/UKGI would have been.

Was that a clearly understood role within the
Shareholder Executive?

It would have been part of the arrangements, yes.

Are you aware of what systems were in place to ensure
that there were rigorous and regular assessments?
Yes, and they reported to the Board, as I've set out in
my witness statement.

From your position looking back, do you think there are
any changes that need to be made to those processes?
I can't tell you because I haven't seen, and wouldn't
expect to see, the appraisal of the Chair or Chief
Executive of the underlying entity, and what came out of
that and what the consequences were.

Can we look, please, at page 65 of your witness
statement, paragraph 167. It says:

"The most effective control of any arm’s-length body
is through very clear policy objectives and through
framework documents and agree strategic plans and agreed
objectives/priorities that set out very clearly the way
in which the bottom is to operate at arm's length and
how its governance should work."

Who was responsible for setting the objectives and
monitoring whether Post Office met them?

It would be a range, I guess, of both policy and
178

it mildly. I can't express a view on quite how
imperfect it was but it clearly was imperfect and,
again, I go back to the central point on curiosity and
follow through that, ultimately, the issue here is that
nobody ever ultimately bottomed whether or not Horizon
was as it had been stated to be, even though there were,
as I now know -- although was not aware of any of them
at the time -- there were many studies that looked and
talked about things in probably quite imprecise ways
that people didn't fully understand, like systemic, and
I could go into more detail.

I think I'd add one other thing, and we haven't
touched on it, but the truth is that, once the Post
Office had got into the position where it was faced with
this very complex piece of litigation, I think they
were -- they, as would many Boards, were not well
equipped both to understand the technical and legal
aspects of that litigation and, if you recall, we
haven't touched on it today, but one of the other things
I did immediately after the settlement in December 2019
was to get a further litigation protocol put in place
because I thought that was so important.

Now, it isn't often that Boards are faced with
a piece of litigation that's quite so existential but my

observation is they weren't well equipped to deal with
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it.

Q. On this point here, you've identified an important
lesson to be learned on properly training boards and
developing a culture to allow curiosity to make
a difference. In your reflections, have you thought of
any practical steps --

A. Yes.

-- that could -- what are they?

A. Putting culture at the heart of every organisation.

It's no accident -- and I'm sorry to sound a bit
passionate about this, but I am. The first Board
meeting of UKGI in January 2016, item 1 on the agenda
was culture, and the reason for that is I thought it was
so important, and if I talked about culture and
openness, ten times, I talked about it a thousand times.
I took every opportunity at UKGI to talk about it, and
there's no reason why every board and every company
shouldn't put it at the heart of what it does.

Again, it's no accident that before every UKGI Board
meeting the newest recruits to the organisation came to
the Board just with the Non-Executives on their own, and
talked about why they were there, what they hoped to
achieve, what they'd found good, what they'd found bad,
and allowed us to talk about culture.

2

‘And, you know, I've been going on about this for
181

to DBT to UKGI being accountable to the Treasury, yes?

A. (No audible answer)

Q. Do you think anything different would have happened if
the body managing the shareholding interest for the Post
Office -- so UKGI -- was accountable directly to DBT or
its predecessor?

A. Well, in respect of its work with Post Office, it was
accountable to DBT. I don't think the shareholding of
HMT made any difference in that and, throughout, the
Permanent Secretary of DBT was on the UKGI Board. So
Alex Chisholm -- or before that, Martin Donnelly -- Alex
Chisholm and then Sarah Munby.

MR STEVENS: Thank you, sir. Those are all the questions
have.

I'll just check in the room if there are ...
No. No questions from Core Participants, sir.
SIR WYN WILLIAMS: Well, then, thank you very much,
Mr Swannell, for taking the time and trouble to write
a detailed witness statement and for answering questions
this afternoon at the Inquiry. I'm very grateful to
you.

THE WITNESS: Thank you, sir.

SIR WYN WILLIAMS: So we'll resume again tomorrow morning at
9.45 with Mr Cooper; is that right?

MR STEVENS: That's correct, sir.
183

ONOaARWN

©

1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

a decade now, in various different guises and
organisations and it's fundamental to how boards work
and, without it, even good curiosity isn't always
successful.
You, in your witness statement, you advocate to keep the
model of arm's-length bodies as a model for assets such
as the Post Office. The Inquiry is going to hear from
a number of witnesses in the coming weeks who make
various suggestions on how that may be changed. One
suggestion would be that a minister should be empowered
to become directly involved in the decision making of
a Board and direct the Post Office Board on how to make
a certain decision. What would be your view of that?
Again, I may not have the precise technicalities right,
but it would surprise me that a minister didn't feel
able to get their point of view across, under the
current architecture, either by putting it within the
framework document or simply by exerting the power that
the 100 per cent shareholder of any entity has.

I mean, put it this way: I don't think that
Blackstone or KKR would feel the need for legislation to
let their underlying entities know what was going to
happen.
Finally, when Shareholder Executive became UKGI, the

responsible department transferred from the predecessor
182

‘SIR WYN WILLIAMS: Fine.
(4.28 pm)
(The hearing adjourned until 9.45 am the following day)

184

(46) Pages 181 - 184
The Post Office Horizon IT Inquiry 9 July 2024

INDEX
MARK FRANCIS RUSSELL (sworn) ...

Questioned by MS PRICE .....

Questioned by MR JACOBS ..... 102
Questioned by MS PAGE 109
Questioned by MR CHAPMAN ..... 116

ROBERT WILLIAM ASHBURNHAM SWANNELL 121
(sworn)

Questioned by MR STEVENS . 121

185

(47) Pages 185 - 185
MR CHAPMAN: [2]
116/9 121/3

MR JACOBS: [3]
102/19 102/22 109/4
MR STEVENS: [10]
121/20 121/22 121/25]
146/6 146/19 146/21
146/25 147/2 183/13
183/25

MS PAGE: [2]
109/10 116/3

MS PRICE: [23] 1/3
1/5 1/8 48/10 48/15
48/17 48/21 48/23
61/10 83/20 83/24
84/3 84/5 101/18
101/23 102/4 102/8
102/12 102/14 102/18
1241/7 121/15 121/18
SIR WYN WILLIAMS:
[31] 1/4 48/13 48/16
48/22 60/7 60/11
60/16 60/20 61/6
83/23 84/4 101/22
102/2 102/5 102/13
102/17 102/20 109/8
116/6 121/5 121/8
121/13 121/16 121/21
146/9 146/16 146/20
147/1 183/17 183/23
184/1

THE WITNESS: [3]
116/5 121/12 183/22

‘deep [1] 72/8

“for [2] 166/5 167/2
"Horizon [1] 165/21
'n' [1] 173/8

"no [4] 131/21
"Overall [1] 72/5
‘Reputational [1]
72/5

/
JUKGI [7] 11/11

94/21 94/23 95/1
96/23 97/4 97/15
JUKGI's [1] 56/7

1

1.02 [1] 102/9

1.2 [1] 155/17

1.50 [3] 101/24 102/7
102/11

10 [3] 11/6 144/6
152/10

10 years [1] 143/1
100 [3] 166/5 166/12
182/19

101 [3] 1/18 144/13
165/15

105 [1] 165/17

11 [5] 67/16 68/8
70/14 151/2 157/9
11 September [1]
170/1

11 September 2018
[1] 167/15
11,500 [4] 173/10
11.07 [4] 48/18
11.15 [1] 48/15
11.17 [1] 48/20

12 [2] 7/20 11/4
12.20 [1] 83/25
12.30 [2] 83/22 84/2
124 [1] 69/19

126 [1] 90/22

127 [1] 91/6

129 [1] 91/25

13 [2] 10/2 10/6
13 July [1] 163/25
13 June [1] 1/18
14 [3] 12/1 70/12
109/24

15 [1] 30/25

15 main [1] 15/12
150 [1] 15/1

16 [4] 32/6

16 July [1] 135/25
16 May [1] 143/16
16 September [1]
87/3

167 [1] 178/16
169 [1] 179/12

17 [2] 20/1 40/13
18 June [1] 108/11
18 million [4] 28/3
18 September [2]
88/14 89/15

19 February [3] 2/10
69/21 69/24

193 [2] 116/22 117/1

1999 [1] 124/16

2

2 April [4] 28/18

2.00 [1] 101/24
2.1 [2] 136/3 136/19
2.4 [2] 172/8 172/9
20 [8] 15/9 21/15
22/18 22/18 52/21
104/11 104/12 162/2
20 million [1] 28/2
20-plus [1] 128/13
2000s [1] 5/22
2002 [1] 4/2

2004 [2] 3/8 3/14
2005 [1] 4/12

2006 [1] 20/14
2007 [3] 5/23 75/1
129/20

2008 [1] 76/14
2010 [3] 76/2 76/7
79/23

2011 [2] 78/15

124/20

2012 [10] 6/10 28/18
30/6 34/13 44/10
49/23 53/21 54/13
54/14 116/16

2012/2013 [1] 62/2

2013 [25] 6/16 6/20
14/25 17/16 43/16
43/25 44/22 45/3
61/19 62/2 62/10
69/12 82/13 84/14
84/15 84/16 85/4 86/2
86/7 86/24 87/3 88/14
89/15 106/22 125/8

2013-April [1] 44/7

2014 [20] 30/15
34/13 44/14 44/19
64/3 64/8 69/21 69/24
70/24 72/1 81/1 90/25)
96/15 109/20 124/23
125/1 137/1 137/24
140/6 150/9

2015 [15] 22/5 44/3
56/1 56/5 122/22
123/2 123/5 123/11
123/13 154/23 156/25}
158/21 158/23 161/17I
175/4

2016 [15] 6/22 21/11
56/23 58/17 73/10
122/14 123/3 123/6
161/15 162/10 163/9
163/10 163/25 175/5
181/12

2017 [3] 123/18
123/19 124/20

2018 [19] 39/5 40/14
41/24 42/12 44/4 44/8
44/19 57/25 73/10
73/11 134/25 143/16
145/4 146/10 148/3
148/12 165/16 167/15}
175/7

2018-February [1]
44/8

2019 [19] 7/1 20/5
118/5 118/9 128/6
128/23 135/19 138/18}
138/23 139/9 145/16
146/4 149/4 152/19
163/5 170/7 171/19
174/21 180/20

2020 [3] 44/8 119/22
120/5

2021 [1] 172/4

2024 [4] 1/1 1/18
2/10 2/10

2026 [1] 57/23

203 [1] 92/10

208 [2] 94/16 94/17
21 [1] 43/23

211 [2] 95/14 106/1
212 [1] 96/15

214 [1] 97/8

215 [1] 98/1

216 [1] 98/2

217 [1] 99/2

22 [2] 12/18 177/6
227 [1] 94/16

23 [7] 28/14 28/15
116/15 143/18 147/9
147/10 147/20

24 [2] 46/1 139/24
24 November [1]
137/1

24 September [2]
140/6 150/9

25 [2] 11/5 13/9
25 June [1] 156/25
25 September [1]
133/19

26 [1] 29/1

27 [2] 30/16 56/3
27 January [1]
122/14

28 June [1] 172/3
28 October [2]
122/21 123/11

29 [3] 64/7 64/8
71/21

29 January [1] 170/7
29 November [2]
148/3 148/12

2A [4] 1/16

3

3 June [1] 90/25

3 November [2]
122/22 122/25

3 October [1] 150/7
3,000 [2] 40/6 58/1
3.05 [1] 146/22
3.15 [1] 146/19
3.18 [1] 146/24

30 [3] 17/17 124/14
124/15

32 [2] 73/25 155/24
33 [1] 15/15

34 [2] 17/9 122/10
38 [4] 123/17

39 [4] 144/12

3i [3] 154/17 154/17
154/19

4

4.28 [1] 184/2

40 [4] 17/19 17/23
19/18 22/17

41 [1] 19/24

42 [1] 34/5

48 [3] 21/14 25/6
25/25

49 [1] 26/25

5

50 [1] 170/8
50 billion [1] 128/15
50 per cent [1] 13/5

51 [1] 43/16
52 [1] 43/22
54 [2] 44/21 177/6
55 [6] 2/4 2/8 170/8
170/16 17/6 177/7
56 [1] 90/23
58 [2] 53/19 53/22
59 [1] 46/3

6

6 February [1] 2/9
6 July [1] 163/10

6 million [3] 173/9
174/6 174/23

60 [6] 45/25 46/2
46/5 46/6 46/11 72/16
60-odd [2] 53/18
54/17

61 [1] 170/19

65 [2] 48/25 178/15
66 [1] 179/11

67 [3] 51/3 53/9
123/22

68 [2] 56/2 56/4

69 [6] 61/17 64/6
71/20 71/22 73/8
73/10

7

7 November [1]
123/19

74 [4] 73/24
72 [1] 74/17
74 [1] 42/11

77 [A] 76/5

78 [1] 79/21
7th [1] 123/20

8

8 April [1] 154/23
8 July [1] 84/15

8 November [1]
123/18

8.00 [4] 173/18
8.2 [2] 85/17 96/1
80 per cent [1] 158/8
82 [4] 155/24

83 [4] 78/6

87 [4] 78/6 122/10
122/11 123/7

88 [1] 83/2
8th [1] 123/21
9

9 July [1] 163/9
9.21 [1] 173/19
9.45 [2] 1/2 183/24
9.45 am [1] 184/3
92 [2] 34/4 94/18
97 [1] 123/18

A

ability [7] 15/20 19/8
62/21 62/25 73/20

(48) MR CHAPMAN: - ability
A
ability... [2] 82/2
93/24
able [14] 8/18 9/14
9/20 10/12 18/7 62/5
63/1 92/15 104/23
111/5 115/5 122/12
123/2 182/16
about [95] 2/20 2/21
4/23 4/25 12/2 13/18
13/25 27/23 28/4
36/17 37/7 37/17
38/12 38/22 47/2
50/11 57/4 60/22
60/25 65/18 65/20
69/2 70/10 76/19
76/24 77/3 82/2 82/12
90/18 95/11 97/15
101/8 106/3 106/4
106/20 108/3 110/11
110/22 111/12 111/14}
114/4 115/15 115/16
119/11 124/6 128/6
128/15 134/20 134/21
137/4 137/8 137/14
137/14 138/12 138/19
138/21 142/24 144/6
144/17 144/18 144/22)
145/14 145/19 145/23}
147/4 147/12 150/8
151/15 152/1 152/13
152/14 152/23 153/1
155/6 156/20 162/24
167/23 168/22 170/5
171/10 173/17 173/24}
174/22 175/14 176/6
176/18 179/10 180/9
181/11 181/14 181/15
181/16 181/22 181/24}
181/25
above [6] 41/24 89/3
89/13 90/6 98/3
154/21
absence [2] 99/12
140/15
absent [3] 38/3 46/23
83/16
absolutely [22] 12/22)
13/4 16/5 33/13 35/9
41/17 41/20 42/6
50/15 51/5 54/19 80/2
81/6 96/6 99/22 100/7
100/7 114/20 115/13
120/23 137/7 174/2
accept [4] 111/6
111/8 165/2 172/22
accepted [2] 14/14
107/13
access [3] 19/14
34/2 175/10
accessible [1] 17/4
accident [2] 181/10
181/19

accommodation [1]
28/4
accompanied [1]
21/20
accompany [1] 56/17
accordance [1]
31/13
Accordingly [1]
172/13
account [4] 9/10 10/2
10/13 103/18
accountability [5]
10/18 10/23 23/3 29/2
130/13
accountable [12]
13/24 26/1 26/2 28/24
30/1 75/12 75/13
126/17 134/5 183/1
183/5 183/8
accountant [1]
124/11
Accounting [7] 20/24
27/1 27/14 27/21 28/6
32/13 33/3
accounts [3] 85/9
92/12 175/12
accuracy [1] 50/9
accurate [2] 50/6
93/20
accurately [2] 22/6
163/20
accusation [1] 68/12
accusations [1]
112/24
achieve [3] 59/9
177/12 181/23
achieved [3] 132/5
177/13 177/15
acknowledge [3]
42/6 111/24 139/21
across [14] 22/25
24/11 52/20 62/3 62/4
62/15 64/11 64/21
65/9 112/21 113/3
113/10 122/16 182/16)
across-all-work-stre
ams [1] 52/20
act [4] 10/11 20/14
100/11 125/17
acted [4] 31/13
103/10 124/16 165/20)
acting [5] 11/11
41/20 138/6 138/7
154/6
action [8] 17/8 87/22
88/1 97/18 112/25
129/15 153/5 163/12
actions [6] 63/24
68/7 94/25 151/14
157/16 157/21
active [3] 66/3 66/10
99/14
actively [2] 31/22
127/18

activities [19] 8/8
11/3 17/20 17/23 19/6
19/19 22/16 22/17
22/18 22/19 22/23
23/22 41/7 56/8 61/24
62/4 62/5 125/21
126/1

activity [28] 7/24
7/25 8/2 8/3 8/5 8/14
8/20 8/21 8/23 9/8 9/8
10/18 10/23 17/11
22/7 23/3 24/1 24/9
24/12 24/13 24/18
26/10 26/11 41/5
46/20 47/6 62/7
130/13

actual [4] 70/18 84/7
110/5 118/7

actually [28] 22/23
28/9 33/6 37/15 40/12
40/25 50/9 52/11 88/7
89/10 98/24 106/15
110/23 120/25 134/23
136/16 142/22 145/3
146/10 149/23 156/4
158/19 158/24 162/10
166/9 170/8 170/9
174/17

ad [3] 47/25 60/5
62/25

ad hoc [2] 47/25
62/25

adamant [1] 88/20

add [5] 19/8 20/24
61/11 143/3 180/12

added [1] 136/12

addition [5] 5/25 49/3}
56/1 56/5 171/4

additional [1] 6/3

address [10] 11/23
68/24 71/18 79/13
83/2 122/9 151/12
155/21 157/14 165/6

addressed [5] 2/22
51/22 53/25 67/15
94/20

addresses [1] 157/18)

addressing [2] 46/6
67/24

adequacy [1] 114/4

adequate [6] 8/19
9/20 13/25 19/7 31/23
133/14

adequately [3] 41/2
41/3 77/17

adjourned [1] 184/3

Adjournment [1]
102/10

adopt [4] 9/5 9/16
9/24 10/4

adopted [1] 119/23

adopts [1] 125/19

advance [2] 1/14
131/23

advantage [1] 101/16
advice [7] 16/10 39/9
65/13 86/11 117/8
118/20 158/2
Advices [2] 86/7
133/6
advise [2] 15/20
89/11
adviser [3] 7/2 7/4
176/10
advising [2] 15/8
27/113
advisor [1] 29/7
advisory [4] 14/23
125/17 127/20 134/2
advocate [1] 182/5
advocating [1] 40/11
affairs [3] 33/21 43/8
92/18
afraid [3] 139/12
143/1 169/22
after [19] 28/15 31/5
80/24 85/4 86/11
87/11 89/9 96/1 96/2
101/20 104/11 134/14}
135/15 138/17 138/18
153/8 155/18 156/3
180/20
afternoon [7] 87/10
102/12 102/13 102/22}
121/11 146/8 183/20
again [61] 8/12 9/3
24/16 25/23 26/4
31/11 34/25 46/10
53/14 56/22 60/19
60/24 61/14 64/23
67/8 73/10 74/10
81/11 83/11 86/13
89/20 90/7 90/9 93/11
96/4 97/1 98/1 101/15)
131/3 134/11 134/22
138/16 142/15 145/7
145/10 146/18 148/25}
152/9 153/15 158/11
160/17 162/15 163/2
164/8 169/13 170/5
1714/1 171/6 171/7
172/25 173/12 173/16}
174/9 174/20 175/3
179/21 179/22 180/3
181/19 182/14 183/23}
against [15] 11/15
13/10 23/11 65/21
67/12 74/10 80/18
81/16 97/18 114/14
132/18 136/8 157/12
163/12 177/22
agenda [6] 72/3
144/23 145/5 147/16
171/12 181/12
agents [3] 81/16
163/15 164/7
aggregated [1] 64/15
ago [3] 81/23 150/14

152/10
agree [18] 11/18
13/24 16/10 50/1
89/22 101/2 109/11
411/20 111/21 111/22!
112/1 115/22 130/15
167/3 167/4 172/4
172/20 178/19
agreed [10] 36/12
36/14 64/9 69/9 77/18I
77/20 130/12 136/9
136/23 178/19
agreeing [2] 136/23
158/18
agreement [1]
145/24
ahead [1] 87/15
aided [2] 29/8 29/21
aim [2] 66/9 136/6
air [1] 47/19
alarm [1] 96/7
ALB [9] 10/20 10/21
10/23 11/19 14/1
32/15 32/16 83/9 98/8I
albeit [1] 98/10
ALBs [4] 10/19 11/1
13/24 31/12
Aldred [1] 44/8
alert [1] 65/16
alerted [1] 82/19
Alex [3] 88/14 183/11
183/11
Alice [15] 37/7 87/3
87/15 87/17 90/3
90/11 90/13 90/25
91/11 93/9 93/22
154/22 155/5 155/18
155/25
alighted [1] 165/9
all [79] 2/11 16/16
17/18 18/13 22/25
34/23 37/9 38/7 40/19
40/20 41/8 47/6 48/16
52/20 52/23 52/24
54/22 55/13 55/25
56/19 59/13 59/15
60/2 61/6 62/3 62/4
64/11 64/25 65/2 65/5)
65/8 65/20 65/22 66/5
67/17 70/18 74/1 82/9I
86/6 88/4 89/9 91/3
99/8 99/23 101/16
102/20 107/9 107/22
109/6 110/5 112/5
113/21 113/22 115/4
119/17 121/1 121/3
122/18 125/25 134/2
138/16 142/5 145/22
145/22 150/2 151/25
152/11 152/21 154/24I
158/3 163/21 165/7
169/21 170/12 173/22)
174/17 175/13 179/7
183/13

(49) ability... - all
A

allayed [1] 77/4
allegation [7] 112/4
164/6 164/14 164/15
164/21 165/4 175/9
allegations [3] 58/7
95/18 143/24
alleged [3] 58/4
123/10 157/13
allocate [1] 40/22
allow [2] 179/16
181/4
allowed [1] 181/24
allows [1] 177/10
almost [9] 14/7 16/22)
91/17 94/6 100/23
143/13 155/18 173/2
174/2
alone [2] 51/16
139/15
along [2] 49/14 70/4
alongside [1] 128/17
already [10] 4/17
10/1 42/19 44/11
73/17 120/21 122/19
136/21 137/15 163/3
also [31] 2/7 7/7 8/11
22/15 26/2 26/25
28/23 29/10 39/11
46/21 50/5 52/16 53/9)
53/17 59/19 62/25
75/9 78/20 86/7 86/24,
87/22 88/2 89/14
96/25 100/24 108/15
120/18 132/20 145/12)
156/4 171/24
alternative [7] 8/15
8/20 93/3 93/6 107/20
114/9 114/19
although [13] 10/16
10/20 12/4 24/22 27/2
74/20 75/21 76/21
77/23 105/11 108/25
158/20 180/7
always [13] 8/16
19/13 24/18 24/19
24/20 24/21 33/2
33/15 36/24 43/20
114/3 114/5 182/3
am [14] 1/2 38/13
48/18 48/20 50/15
55/4 71/15 74/19
83/14 88/25 124/6
131/14 181/11 184/3
Amber [3] 50/3 141/2
148/20
amongst [2] 72/13
178/1
amount [3] 13/2
89/10 145/1
analysing [1] 40/10
analysis [11] 16/11
49/19 49/25 50/1 50/5)

53/17 53/22 54/11
55/9 92/22 104/2
Andrew [1] 108/17
anecdotal [1] 173/12
Angel [1] 7/11
announcements [1]
137/9
annual [9] 2/5 2/6
51/12 53/10 53/11
53/14 53/21 55/11
78/16
another [11] 23/3
24/17 42/5 66/25 67/9
87/23 143/18 147/25
156/16 167/12 171/11
answer [27] 34/24
36/5 46/8 47/13 51/5
54/18 55/3 60/1 82/4
98/25 103/12 107/16
108/6 108/24 111/16
120/17 138/2 143/1
149/17 152/2 159/1
159/23 160/2 160/16
163/21 179/5 183/2
answered [1] 105/25
answering [3] 38/13
121/9 183/19
answers [2] 61/7
142/22
Anthony [3] 39/20
43/25 78/8
anxious [1] 42/15
any [74] 5/18 13/14
16/10 20/22 23/20
24/17 25/24 26/21
27/5 27/11 36/19 37/9)
38/7 41/18 41/24 45/9)
46/20 54/12 54/15
63/15 73/13 75/9
78/21 79/6 79/12
82/10 88/8 89/22
89/24 90/17 91/6
94/10 98/19 101/15
104/16 106/12 107/20)
108/2 108/18 109/5
110/13 111/4 112/5
119/4 119/4 123/3
128/12 130/7 130/22
132/25 142/15 144/23}
146/11 147/13 147/14)
147/15 152/24 154/19)
155/25 160/20 162/5
162/12 162/22 162/23}
171/4 175/8 175/14
175/22 178/10 178/17)
180/7 181/6 182/19
183/9
anybody [3] 55/14
105/12 173/20
anyone [6] 17/6 36/7
38/21 70/25 121/5
175/15
anything [11] 33/5
61/11 87/7 87/12

109/14 120/14 131/23}
149/11 150/25 151/4
183/3
anywhere [1] 54/11
AO [7] 20/24 21/2
27/2 27/2 27/5 27/16
27/17
apart [2] 65/2 77/25
apologies [4] 51/9
53/20 89/15 90/9
appeal [2] 118/10
118/16
appear [3] 88/20 91/1
98/21
appeared [1] 156/9
appearing [2] 65/2
156/10
appears [9] 49/19
69/24 70/9 87/14
90/24 91/11 91/14
92/1 122/13
appended [1] 122/21
applicable [3] 13/7
74/16 75/7
applicants [2] 67/21
151/8
application [8]
116/25 117/5 117/9
117/14 117/17 118/10
118/16 120/9
appoint [3] 28/21
116/19 177/11
appointed [5] 5/23
6/16 30/10 30/23 55/7
appointment [7] 17/1
32/8 54/8 55/5 78/25
125/10 134/15
appointments [4]
38/12 78/21 79/12
177/20
appraisal [1] 178/12
appreciate [2] 96/16
131/15
appreciated [2]
81/20 135/19
approach [7] 36/9
62/16 64/11 73/9
73/11 73/18 109/13
appropriate [12]
12/20 13/22 14/21
94/24 100/9 100/25
116/1 130/8 130/24
136/18 166/22 172/14]
appropriately [6]
127/14 128/3 129/2
135/18 149/8 160/14
approval [1] 177/20
approximately [3]
14/25 15/9 17/17
April [13] 6/20 28/18
30/5 34/12 42/12 44/7
44/10 44/19 49/23
84/14 85/4 154/23
165/16

arbitrate [1] 115/25
ARC [1] 109/20
architecture [1]
182/17

are [149] 2/3 2/11
2/12 2/13 2/15 2/22
2/25 7/4 8/1 8/25 9/15)
9/17 10/11 10/16
11/24 12/7 12/10
13/23 14/4 14/8 14/12)
14/17 16/6 16/13
16/15 16/24 19/22
22/16 22/16 22/22
23/21 25/8 27/9 29/8
32/15 32/17 32/20
39/13 41/24 41/25
42/16 42/22 48/2 50/7
50/14 50/15 50/17
50/17 50/18 50/21
51/22 54/6 54/23 57/6
57/18 58/15 59/10
65/5 65/15 65/19
65/22 66/7 66/18 69/4)
69/11 69/23 70/17
72I17 72/18 72/20
72/21 72/24 72/25
87/9 87/9 87/13 88/2
89/25 93/14 93/15
94/16 95/19 96/2
100/16 101/11 101/14}
101/18 101/19 102/23
103/6 103/15 103/15
104/15 104/23 105/21
105/22 106/10 110/4
112/23 113/7 113/12
113/13 118/4 119/8
119/21 120/18 121/1
121/3 122/8 122/18
123/15 124/3 124/5
125/12 126/8 128/13
130/7 130/23 130/23
133/5 140/3 140/13
141/9 141/11 142/9
142/12 142/12 142/18)
145/11 150/2 151/17
154/25 155/8 158/3
158/13 159/10 161/2
166/22 168/25 173/10
177/2 177/20 177/21
178/5 178/9 180/23
181/8 183/13 183/15
area [1] 67/8

areas [2] 104/23
125/21

aren't [5] 23/23 38/15
59/11 66/18 142/3
arena [1] 131/24
argue [3] 40/10
110/15 114/4
argument [1] 100/16
arise [4] 22/13 68/25
151/13 157/18
arising [1] 82/20
arm [2] 14/7 131/11

arm's [39] 4/9 7/15
7/22 7/23 8/2 9/6 9/16}
9/23 10/3 10/16 10/17
12/19 13/15 14/16
27/9 31/5 31/6 33/21
35/2 100/4 101/13
103/1 103/7 104/20
113/16 113/18 115/5
115/19 116/2 116/11
119/6 130/9 130/14
130/19 130/25 177/8
178/17 178/21 182/6
arm's-length [24] 4/9
9/6 9/23 10/3 10/16
13/15 27/9 31/5 31/6
33/21 35/2 100/4
101/13 103/1 103/7
113/16 113/18 115/19)
116/11 130/9 130/25
177/8 178/17 182/6
around [6] 8/11
60/25 61/3 84/8 89/23)
99/3
arrangement [1]
177/20
arrangements [2]
145/24 178/4
articles [8] 28/17
116/16 116/17 119/22)
120/4 120/5 120/6
A77N7
articulated [2]
113/23 115/18
as [280]
ASHBURNHAM [3]
121/23 122/1 185/12
aside [2] 41/22
175/21
ask [20] 1/11 22/4
35/3 46/10 102/22
109/5 109/18 110/11
123/22 124/6 137/4
137/14 138/12 147/25)
155/4 155/8 155/19
161/8 162/17 167/25
asked [10] 61/8
70/13 87/5 118/20
142/24 153/11 157/1
159/2 162/23 168/25
asking [6] 2/20 133/7
147/4 152/9 155/5
159/24
aspect [6] 2/21
128/18 135/18 135/21
154/25 179/9
aspects [2] 134/2
180/18
assertions [1] 99/2
assess [3] 127/6
167/19 168/3
assessed [8] 42/12
50/18 68/14 68/17
137/21 160/9 169/2
177/22

(50) allayed - assessed
A

assessment [6]

57/11 177/24
assessments [3]
21/23 49/16 178/6
asset [20] 4/23 4/25
5/11 6/11 23/12 24/9
27/12 30/25 39/10
49/17 53/11 56/10

74/12 127/11 127/13
128/3

asset's [2] 53/12
72/4

assets [22] 15/18
23/8 56/9 60/5 61/23

73/12 78/1 129/15
140/9 141/20 141/21
141/22 141/23 142/2
142/2 142/5 177/10
182/6

assist [3] 1/13
149/21 169/1
assistance [2] 91/1
125/18

associated [1] 46/20
Association [3]
28/18 116/16 119/22
assume [2] 164/11
168/19

assumption [1]
179/9

Assurance [8] 62/10
62/14 63/6 63/10
69/21 73/1 104/5
134/19

71/16 97/13 98/2
98/23

assure [1] 125/19
at [283]

at 4[1] 159/16

at page 22 [1] 177/6
attach [2] 91/24
95/25

attached [6] 17/2
89/5 125/11 150/3
157/3 157/4
attachment [1]
150/18

attempts [1] 157/13
attendance [2]
109/21 136/1
attendees [1] 55/17
attending [2] 101/5
122/2

attention [7] 65/17
104/7 128/10 142/4
142/6 153/4 160/25
attitudes [1] 109/15

assessing [1] 176/5

51/16 56/11 57/7 57/8

57/5 59/18 64/3 64/12

64/12 64/25 65/6 65/8

assurances [5] 71/12)

attract [1] 8/17
audible [1] 183/2
audit [5] 92/16

158/23
authority [3] 103/4
164/25 171/10

autonomy [1] 31/4
available [9] 8/10
8/12 9/25 16/21 37/14
55/13 55/14 94/24
118/20
avoid [1] 5/7
aware [75] 27/12
34/15 34/16 34/20
34/23 34/25 35/20
36/6 46/19 54/23 55/5)
55/6 63/15 63/22
79/14 80/17 80/21
81/3 81/6 81/21 82/16
84/6 84/9 85/3 85/5
86/10 86/13 86/22
86/22 87/13 88/5
90/13 90/17 90/20
95/7 95/9 96/22 97/5
108/7 113/13 118/9
118/19 118/24 120/1
128/5 133/1 133/8
133/9 133/10 137/5
137/8 137/11 137/15
137/18 137/20 137/21
137/22 137/23 137/23)
137/25 138/1 138/1
138/8 138/11 138/18
142/12 164/5 164/14
168/5 168/7 168/7
168/10 169/12 178/5
180/7
away [6] 58/19 85/18
105/24 115/5 131/1
142/14

back [45] 4/1 4/15
13/18 19/9 23/8 29/15
40/4 41/4 51/9 51/20
52/14 54/21 59/8
60/19 60/21 61/7
61/12 65/17 68/8
87/16 95/24 101/15
101/24 104/9 104/20
105/8 106/21 114/2
137/24 141/24 144/25)
145/2 147/15 147/20
149/13 153/19 159/14)
161/4 166/14 168/16
168/18 168/24 178/9
179/3 180/3

backed [1] 174/11
background [7] 2/24
15/4 62/19 114/14
124/8 174/15 175/1
bad [3] 103/10

158/10 158/16 158/17,

autonomous [1] 98/8

139/13 181/23
badly [1] 59/12
bail [2] 115/9 115/11
balance [6] 22/15
23/7 23/14 50/24
109/11 121/2
balanced [2] 99/11
100/1
balances [1] 104/5
Bank [2] 18/12 18/13
banker [1] 124/18
banking [1] 124/14
bar [2] 103/2 124/12
Baroness [1] 99/21
barriers [1] 37/17
bars [1] 121/1
based [1] 165/2
basic [2] 8/25 130/3
basically [3] 4/18 6/4
88/4
basing [1] 16/10
basis [9] 42/14 49/17
51/6 51/8 60/14 61/1
86/5 101/11 115/8
Baugh [2] 149/25
156/24
be [223]
bear [1] 40/17
became [26] 5/20
6/10 6/20 6/24 14/24
26/25 27/16 31/8
34/23 34/24 36/6
43/25 78/2 79/7 80/14
80/21 81/21 84/6 84/9
84/13 124/25 128/5
135/20 138/18 171/23
182/24
because [68] 19/6
19/13 27/19 35/6
36/16 37/5 37/11
37/24 38/23 40/24
41/9 50/7 50/10 54/19
55/1 59/3 59/8 65/15
66/5 66/7 71/6 80/2
81/23 82/5 86/8 88/9
91/17 97/12 99/19
103/5 103/13 103/15
104/21 107/1 107/20
107/24 108/24 110/13}
110/17 110/22 115/9
127/18 134/13 135/6
135/14 138/2 138/18
141/23 142/2 143/11
145/3 154/13 156/13
156/21 158/13 160/16
164/11 168/20 171/16
172/25 173/2 173/16
174/4 176/17 176/20
178/11 179/22 180/22
become [13] 7/1
11/25 12/6 12/21
34/16 34/20 42/3
65/24 95/10 95/21
128/18 133/1 182/11

becomes [2] 113/16
115/19
becoming [1] 85/4
been [135] 3/6 4/25
22/12 30/18 34/7
34/16 34/21 35/19
36/13 36/14 37/3
37/15 37/21 38/13
41/2 41/14 41/20 42/7)
43/20 53/5 54/7 54/13
54/24 55/2 55/4 58/22)
69/9 69/25 75/7 79/7
80/25 81/14 83/6
84/19 84/22 85/2 85/3)
85/11 85/23 86/1 86/3
86/4 86/9 86/13 86/16
92/20 92/24 93/25
94/2 94/3 94/22 95/4
95/16 96/7 99/7 99/9
99/15 105/22 106/6
107/5 107/6 107/17
107/17 107/19 107/23}
108/25 111/5 111/15
112/2 112/3 115/4
117/5 117/12 119/1
119/6 120/7 122/12
123/2 128/5 132/7
132/22 133/13 133/19}
135/17 135/19 136/20}
137/11 137/18 137/20}
137/23 137/25 138/7
138/8 139/5 139/9
140/6 140/16 143/11
143/12 145/13 145/19}
149/15 149/18 151/23
152/7 152/17 153/3
153/4 157/1 157/25
158/14 159/11 160/1
160/24 161/11 162/11
163/4 165/24 166/3
166/6 166/14 166/15
167/18 168/14 168/19)
172/19 173/25 174/18}
175/2 175/6 176/9
178/1 178/4 180/6
181/25
before [33] 3/7 25/17
46/3 53/3 53/20 54/15)
57/25 60/7 74/14
75/20 80/25 105/25
108/6 112/21 113/10
117/18 122/8 124/11
143/6 148/12 149/11
150/11 150/12 153/19}
156/8 156/9 157/7
163/4 164/5 174/21
175/8 181/19 183/11
behalf [6] 1/12 9/21
10/11 11/12 102/22
116/10
behave [1] 176/8
behaviour [1] 168/23
behind [6] 11/4 30/22
49/11 50/10 61/20

63/3
being [77] 3/1 11/2
11/7 14/4 17/18 26/22)
29/21 30/23 31/18
37/19 38/15 40/14
49/3 50/7 50/8 50/18
51/22 53/9 53/25
56/16 59/16 59/25
63/15 66/13 67/15
68/5 77/22 80/18
81/17 88/6 90/13
90/17 91/14 94/12
96/10 96/11 99/4
107/3 111/6 111/22
112/25 113/1 114/19
415/17 115/17 117/17
118/16 118/16 124/12)
127/13 128/9 128/9
129/1 1314/7 134/8
135/2 138/11 146/10
146/13 155/7 159/8
161/16 162/3 163/12
163/17 164/14 165/2
165/3 166/22 168/25
169/7 170/25 174/4
174/22 174/23 176/9
183/1
beings [1] 175/16
belief [2] 2/14 124/4
believe [7] 71/4 75/9
80/20 97/2 106/19
132/4 177/8
believed [3] 67/6
96/18 119/13
bells [1] 96/7
below [5] 10/14
29/11 67/14 89/5
89/19
benchmark [1] 74/22
beneath [1] 59/14
benefit [3] 31/15
151/25 165/10
benefits [2] 31/10
31/12
best [16] 2/14 10/2
43/19 65/13 75/4
81/12 96/22 114/1
124/3 125/19 128/4
135/14 135/16 156/23}
169/23 170/2
betrayed [1] 176/1
better [6] 35/7 39/15
62/5 107/23 136/22
173/5
between [13] 32/11
35/22 39/18 39/23
62/6 75/10 81/7 87/15
90/24 124/19 138/20
145/15 176/23
beyond [3] 99/15
155/7 169/22
big [9] 5/9 5/19 83/18
94/3 94/7 104/14
104/14 106/22 115/10}

(61) assessing - big
B

bigger [1] 157/10
biggest [1] 66/15
Bill [1] 77/16

billion [4] 128/15
BIS [4] 20/8 20/10
21/2 89/1

bit [6] 66/10 93/25
113/3 167/2 179/21
181/10

Blackstone [1]
182/21

blame [3] 104/6
104/7 104/8

board [256]

Board's [6] 125/12
126/16 128/10 135/16}
135/21 166/20
Board-level [1] 37/18
boards [13] 10/8
24/20 100/23 101/9
105/9 105/15 162/19
176/10 179/14 180/16
180/23 181/3 182/2
bodies [12] 4/9 4/10
9/24 10/3 10/16 13/15}
27/9 31/6 101/13
130/25 177/8 182/6
body [22] 7/15 7/22
7/23 8/2 9/6 9/16
12/19 14/16 31/5
33/21 35/2 100/4
103/7 104/20 106/11
119/1 119/6 130/9
130/14 130/19 178/17)
183/4

bold [1] 155/3

both [12] 12/6 24/12
39/3 68/5 113/5
117/23 127/17 133/12)
168/13 172/11 178/25
180/17

bothered [2] 50/10
107/6

bottom [20] 28/25
29/15 30/15 66/21
70/12 87/16 88/13
90/1 96/20 107/23
125/15 140/20 140/25
143/20 148/15 149/14}
149/25 168/11 172/9
178/21

bottomed [1] 180/5
bought [1] 90/4
bound [3] 15/24
16/13 47/23

box [5] 68/21 69/16
130/3 140/24 145/8
branch [3] 85/9
92/12 175/12
branches [2] 58/1
173/10

brand [2] 68/10

112/23
break [11] 48/12
48/19 57/20 83/21
84/1 101/21 132/14
138/5 146/8 146/17
146/23
Bridgen [1] 108/17
brief [1] 87/8
briefed [1] 162/11
briefing [14] 56/14
76/6 76/14 87/5 125/3
147/2 154/23 155/7
156/22 163/8 163/11
163/23 164/2 167/14
bring [7] 125/7
133/17 134/25 149/13}
149/24 150/18 177/5
bringing [5] 63/12
81/15 93/2 93/10
104/7
brings [1] 54/8
British [2] 4/7 18/13
broad [1] 143/23
broadly [1] 141/10
brought [5] 31/17
80/18 86/8 109/15
163/12
bubbles [1] 65/2
bugs [4] 84/8 85/8
85/21 97/17
bullet [11] 57/7 58/5
58/24 60/9 72/14
72/21 76/20 126/8
127/4 161/21 165/17
bullets [1] 87/11
bundle [1] 1/16
business [21] 11/10
18/13 20/21 74/7 74/8)
75/3 100/20 111/2
115/4 115/21 116/10
125/4 126/5 129/6
130/6 132/11 139/1
154/11 155/12 167/18)
179/2
businesses [5]
131/17 131/18 131/21
132/2 154/7
but [184] 4/24 5/8
5/11 6/6 7/7 8/6 9/1
9/16 12/8 13/4 14/6
14/12 16/16 17/4
18/19 21/25 22/14
23/24 24/9 24/19 26/2
26/5 26/19 27/22 28/1
28/8 30/10 31/5 32/8
33/7 33/12 33/23
35/12 36/18 37/20
38/11 38/15 40/1 40/9)
41/15 42/24 44/23
45/7 47/13 47/22 50/4
50/13 52/12 52/21
52/22 54/21 54/24
55/7 55/15 55/21
58/16 59/12 59/23

60/17 61/1 61/7 61/21
63/21 64/12 65/8
65/23 66/14 67/18
68/18 69/10 69/14
70/11 71/15 72/12
72/15 73/6 74/12
78/23 80/9 80/23
80/25 81/5 82/1 82/13)
83/14 83/19 85/1 87/6
87/9 88/17 90/4 90/20
91/7 91/10 93/21 94/5)
95/11 97/9 98/18 99/6
99/8 99/15 99/24
101/15 103/19 104/8
104/10 104/13 104/19}
105/2 105/13 106/25
108/15 109/2 109/18
111/21 111/25 112/6
112/18 114/5 114/13
114/15 119/9 119/12
121/17 122/19 123/2
124/8 127/18 128/1
132/6 132/24 133/5
133/9 133/19 138/3
139/4 139/20 141/10
145/1 145/12 148/8
148/9 149/21 150/13
153/9 153/12 153/16
153/20 153/25 155/23
155/25 156/14 156/23
159/20 160/18 161/4
162/10 162/17 163/2
163/5 163/16 164/8
165/25 166/18 170/5
1741/1 171/14 173/5
173/13 174/5 174/11
174/16 174/21 175/2
175/21 176/23 177/4
180/2 180/13 180/19
180/24 181/11 182/15}

c

Cabinet [1] 129/9
cadence [1] 128/7
cadre [1] 41/19
calibrate [1] 161/25
call [10] 1/5 5/2 8/3
52/10 62/21 62/23
94/3 121/22 146/12
155/23

Callard [6] 44/7
44/18 70/6 150/1
156/24 163/24
called [2] 23/10
124/12

calls [1] 118/11
came [10] 20/4 22/5
41/8 62/2 80/14 82/14
84/23 122/20 178/13
181/20

campaign [1] 99/14
can [195]

can't [65] 14/16
34/21 34/24 37/5

37/13 37/19 37/20
38/14 61/21 63/17
63/20 67/17 71/15
77/19 81/6 81/14
82/11 82/11 83/19
84/18 84/22 88/7 88/7,
88/9 90/16 90/20
90/21 93/11 105/24
111/24 119/3 119/4
120/2 120/2 139/2
143/1 147/21 149/17
149/17 149/21 149/22)
153/12 156/14 156/15}
160/11 160/11 160/11
161/4 161/4 161/5
162/9 164/18 164/24
165/1 169/21 169/25
174/15 174/19 174/20}
175/3 175/5 176/17
178/11 179/6 180/1
cannot [3] 34/8 38/19)
84/10
capability [9] 4/15
8/17 9/18 13/19 13/20)
63/19 93/24 101/12
155/2
capable [2] 91/13
107/25
capacity [3] 78/3
103/16 104/22
capital [2] 76/16
154/17
capture [2] 66/15
67/5
captured [3] 39/21
113/24 114/15
capturing [2] 58/16
65/13
career [2] 3/6 124/9
carefully [2] 85/16
120/21
carried [2] 128/1
132/10
carry [3] 11/2 16/2
132/20
carrying [1] 118/21
case [12] 5/9 10/21
29/10 32/10 42/7
43/20 91/17 103/9
143/18 147/18 170/21
171/5
case’ [1] 165/21
cases [6] 8/22 67/20
69/11 93/19 151/7
157/15
cash [1] 5/16
catastrophe [1]
103/22
catastrophic [1]
96/11
catch [1] 103/19
categorical [1] 97/13
categorically [1]
156/15

cause [1] 37/9
Caution [2] 69/5
151/19
cautioned [1] 136/7
cee'd [1] 150/1
CCRC [4] 137/11
158/1 158/2 159/8
cease [1] 82/14
cent [3] 13/5 158/8
182/19
central [7] 11/4 11/15]
11/24 12/20 14/9 75/6)
180/3
centre [3] 4/12
113/15 140/25
CEO [40] 6/24 14/24
17/22 18/8 18/15
20/10 20/10 21/13
21/16 21/17 25/2
25/17 26/23 27/16
27/17 28/22 30/1
32/11 32/22 45/18
52/18 54/4 60/4 63/16
70/11 84/13 85/4
85/11 86/14 94/20
94/22 95/2 125/18
126/11 126/16 126/16
155/2 168/14 177/21
177/24
certain [9] 2/22 10/21
28/20 36/2 49/14 81/6
85/1 115/13 182/13
certainly [21] 16/22
18/19 38/12 42/25
48/13 52/12 52/23
73/2 79/19 80/22
83/23 86/22 89/23
91/17 93/21 100/23
105/2 108/25 120/23
124/15 142/23
cetera [4] 23/15 41/8
118/17 118/17
chain [1] 138/6
chair [42] 7/1 7/7
7/11 20/7 20/7 20/9
21/17 28/23 37/7 54/4
69/5 69/6 70/5 78/11
78/18 95/2 113/6
116/20 119/19 120/19}
124/25 133/16 137/2
143/7 143/8 150/9
150/12 151/19 151/21
153/23 154/6 154/10
154/19 155/14 155/18)
156/7 161/22 162/12
171/24 177/21 177/24I
178/12
chaired [3] 62/11
69/10 135/25
chairing [1] 62/19
Chairman [9] 124/19
125/9 131/5 133/21
133/23 134/15 174/9
174/11 176/21

(62) bigger - Chairman
Cc

Chairman's [1]
177/14

chairs [1] 153/22
challenge [9] 9/13
78/20 109/11 109/15
114/24 136/10 136/16
149/7 166/21
challenged [1] 52/17
challenges [8] 54/12
54/17 58/6 63/22
79/15 155/1 155/20
167/15

challenging [2] 54/6
56/8

chance [2] 114/2
115/23

chances [2] 72/17
119/21

change [10] 4/11 6/2
6/7 73/11 121/19
144/21 148/20 148/22)
17113 172/14
changed [3] 127/3
135/10 182/9
changes [9] 73/9
73/14 136/8 144/23
147/14 175/25 176/16}
176/25 178/10
changing [1] 149/10
Chapman [6] 102/15
102/16 116/7 116/8
121/5 185/10
character [1] 135/11
characterisation [1]
68/1

Charles [1] 2/9
chartered [1] 124/11
check [3] 107/17
145/2 183/15
checks [1] 104/5
chief [22] 5/23 6/5
6/16 6/20 17/10 21/5
22/24 24/21 24/24
25/23 62/11 78/2
116/21 134/5 134/9
135/4 145/17 147/6
156/7 163/4 176/15
178/12

Chisholm [2] 183/11
183/12

choose [1] 5/5
chosen [1] 7/23
chronological [1]
153/21

circle [1] 120/18
circumstance [1]
33/8

circumstances [8]
12/20 32/24 33/14
36/2 108/8 117/11
130/20 131/9

civil [23] 13/19 15/5

15/24 15/25 16/3
16/16 16/21 17/18
18/25 18/25 19/12
35/7 35/16 41/16
41/18 41/19 43/6
43/11 77/11 129/4
129/11 165/19 167/6
claims [2] 163/14
165/3

clarify [1] 122/16
clarity [2] 48/6
177/12

Clarke [3] 86/7 86/10
133/6

classification [1]
13/6

clear [18] 8/16 8/18
36/10 38/11 38/12
42/3 47/16 54/5 79/3
91/20 100/19 118/15
138/21 138/22 148/5
166/3 171/14 178/18
clearer [4] 99/7 99/8
99/9 99/16

clearly [21] 81/24
85/15 92/23 92/25
98/16 99/1 99/12
99/14 109/1 141/16
144/10 152/1 159/5
160/24 162/10 162/11
166/15 178/2 178/20
179/6 180/2

clever [1] 153/8
click [2] 66/24 67/18
client [1] 103/6
clients [1] 106/10
close [2] 114/8 150/6
closed [1] 138/25
closely [2] 83/6
151/11

closer [2] 104/17
113/1

Coalition [1] 18/12
Code [5] 15/25 16/21
17/1 74/22 75/6
collaboratively [1]
142/13

collapse [2] 5/4
114/12

colleagues [9] 39/21
47/24 49/13 52/13
55/22 59/10 63/2
93/18 95/1
collectively [1] 141/3
colours [1] 50/3
column [8] 57/8
67/18 67/19 67/23
68/9 69/1 69/8 112/20
combined [2] 6/22
32/1

combining [1] 41/16
come [51] 5/13 11/8
12/23 19/19 21/24
26/4 30/21 37/2 38/25)

40/25 42/9 48/8 52/13
53/8 54/21 55/10
59/20 60/6 61/14
66/15 71/9 75/15 78/7
80/9 85/18 87/12
94/15 101/8 101/24
109/4 112/9 122/16
122/24 123/23 127/4
131/12 131/12 132/5
136/25 141/25 143/2
144/25 145/2 145/6
149/5 152/24 153/7
153/19 158/24 159/6
170/3
comes [3] 27/8 40/21
144/22
comfort [2] 81/24
97/9
coming [9] 1/12
16/24 81/25 90/11
91/22 99/16 115/25
145/13 182/8
commenced [1] 78/2
comment [2] 58/14
144/24
commentary [1]
53/12
comments [3] 88/16
88/24 113/21
commercial [10] 4/5
39/19 39/24 40/2 75/4
79/18 79/19 96/19
141/5 145/24
commercially [1]
40/7
commissioned [1]
153/10
commissioning [2]
150/2 153/11
commitment [4] 16/3
54/5 58/2 76/23
committee [31]
20/23 22/21 45/21
45/21 46/4 46/7 46/12
46/19 47/2 47/15
47/19 47/23 48/1
62/10 62/15 63/6 63/7
63/10 63/12 63/20
64/9 69/21 70/13 73/1
104/5 134/19 156/9
158/10 158/17 158/17
158/23
Committee's [1]
46/24
common [15] 19/22
25/24 31/2 31/8
113/21 116/23 148/12)
148/13 171/19 172/22
173/6 173/15 173/17
175/8 175/15
communicated [3]
92/25 93/1 118/17
communicating [1]
58/5

companies [7] 10/5
20/14 27/21 100/11
101/2 124/17 141/24
company [13] 5/16
7/12 20/12 27/20 43/8
75/11 75/11 114/22
115/3 120/13 160/20
176/1 181/17
compatible [2] 9/25
144/10
compendium [1]
133/5
compensation [4]
70/23 110/10 110/24
111/12
compiled [2] 22/2
158/19
compiling [3] 45/5
158/12 159/4
complaint [1] 93/18
complements [2]
32/8 33/5
complete [3] 61/2
106/24 152/23
completely [7] 59/2
61/1 94/14 111/8
111/20 111/21 112/1
completion [1] 134/7
complex [4] 18/4
104/12 107/24 180/15}
complexity [1] 18/4
compliance [1] 74/21
complicated [1] 28/7
composite [1]
135/12
composition [1] 20/2
comprehensive [3]
24/19 24/23 98/9
comprised [1] 20/6
comprising [1] 45/21
computer [1] 106/25
concern [17] 11/20
37/9 37/11 38/22
46/23 60/25 76/24
77/3 79/12 89/1
111/23 113/25 114/7
114/14 115/10 166/7
166/16
concerned [5]
115/15 115/16 134/11
134/17 134/22
concerning [5] 12/7
12/12 12/14 76/1
116/11
concerns [3] 36/13
36/17 47/20
conclude [2] 57/24
120/18
concluded [1] 98/5
conclusion [5] 5/17
152/25 153/2 153/7
153/10
conclusions [2]
85/14 96/3

conduct [4] 14/18
54/14 63/10 79/25
conducted [4] 72/8
72/25 73/2 97/6
conducting [1] 73/4
conducts [1] 11/20
conferring [1] 100/11
confidence [2] 93/23
98/11

confident [2] 35/9
38/16

confirm [2] 1/8 59/13
confirmed [1] 85/8
conflict [4] 36/1
36/24 39/23 42/21
conflicts [3] 11/17
13/21 36/17
confronting [1]
159/25

connection [2]
142/10 176/20
conscious [2] 22/24
79/20

consent [1] 92/12
consequence [1]
11/7

consequences [3]
42/17 96/11 178/14
consider [11] 52/18
59/3 69/25 71/6 71/7
85/25 86/19 97/10
126/10 155/5 169/9
considerably [1]
51/14

considered [8] 37/22
37/24 52/4 52/22 55/7I
69/20 80/8 129/11
considering [4]
20/22 71/13 82/7
154/25

consistency [2]
62/16 64/11
consistent [5] 24/11
26/13 26/20 62/3
88/22

constantly [1] 66/2
constituted [1] 27/19
constituting [1]
120/13
constitutional [1]
14/15

constraints [4] 40/15
40/16 40/19 41/22
constructive [2] 54/3
134/4

consultation [1]
57/22

contact [2] 32/10
33/2

contacts [3] 32/11
32/20 33/23

contain [1] 59/17
contained [3] 28/9
72/18 72/21

(63) Chairman's - contained
Cc

containing [1] 92/16
contemplate [1]
96/10
contentious [1]
131/24
contents [2] 2/13
14715
context [13] 34/25
35/14 52/3 79/22
145/13 149/18 160/22
163/2 164/20 165/7
167/23 171/15 174/7
contingency [1]
169/14
continual [1] 179/15
continue [3] 23/16
26/17 134/12
continued [4] 23/16
24/5 44/24 72/6
continuing [1] 46/11
continuum [4]
134/13 134/16 134/23
135/23
contract [2] 3/21
8/24
contracting [1] 7/25
contractual [1] 11/13
control [3] 112/24
172/10 178/17
convened [1] 69/25
convenient [3] 22/1
48/11 83/20
conversation [7]
50/16 93/22 133/10
155/16 163/2 175/14
175/22
conversations [4]
82/24 97/23 106/8
134/20
convicted [3] 111/1
111/23 132/23
convicting [1] 144/9
conviction [2] 132/10)
132/21
convictions [17]
70/16 70/22 81/3 81/8
96/25 97/11 110/3
110/9 110/18 137/12
137/14 143/24 144/5
152/5 159/9 175/15
175/17
Cooper [8] 44/5
44/19 148/19 168/5
168/8 168/23 169/12
183/24
copies [1] 23/19
copy [3] 1/15 1/21
157/3
core [9] 8/12 16/4
16/6 22/16 72/7
101/19 102/23 179/18)
183/16

corner [4] 73/13
73/19 89/21 140/15
corporate [29] 3/6
3/11 3/16 3/24 4/14
4/19 4/21 5/21 5/25
6/8 9/10 9/22 17/11
17/20 20/12 21/21
22/18 24/12 24/20
26/11 61/24 62/4 62/7
74/22 74/23 75/6
104/12 104/13 129/22)
corporation [5] 11/8
12/16 12/25 13/6
172/11
corporation's [1]
172/12
corporations [1] 13/8)
correct [96] 3/4 3/5
3/10 3/13 3/23 6/12
6/12 6/15 6/21 6/25
7/3 7/13 10/25 15/7
15/23 17/13 17/15
17/21 18/2 18/17
21/12 25/13 25/15
27/4 30/9 30/14 30/20
31/19 31/25 32/5
34/14 41/15 45/19
45/24 49/10 51/23
53/6 55/25 56/19
57/15 62/13 63/9
63/14 64/13 64/14
64/22 68/20 70/8
72/13 73/16 74/19
74/25 75/14 76/4
77/25 83/10 92/14
92/17 93/8 103/15
122/18 123/13 123/19)
123/20 124/13 124/18)
124/21 124/24 125/2
126/14 127/12 128/25)
129/3 129/7 129/13
130/11 130/21 132/17,
132/19 136/19 140/11
140/14 140/21 146/5
149/2 150/22 152/6
154/5 156/2 161/18
164/1 166/23 167/1
172/21 175/20 183/25)
corrections [4] 1/25
2/11 2/13 122/9
correctly [4] 27/25
70/20 93/15 110/7
corresponding [1]
137/11
cost [3] 40/2 40/3
40/8
costs [1] 112/24
could [88] 1/18 5/4
10/5 11/5 19/3 19/25
28/13 31/4 34/3 35/6
35/6 35/11 36/2 40/10)
43/22 45/25 49/22
56/3 56/22 60/21
62/23 64/23 70/22

71/20 73/25 76/9
76/12 82/5 86/3 86/9
87/1 88/12 89/7 90/22
91/16 92/11 95/15
98/19 101/24 104/17
106/12 107/5 107/6
107/17 109/16 109/19}
110/9 112/9 112/14
112/17 114/24 117/3
117/24 117/25 118/25)
119/19 120/8 122/9
123/17 123/22 126/2
128/24 129/14 133/21
143/18 146/19 149/24
151/2 153/3 154/14
154/15 157/5 157/6
157/10 160/5 160/13
160/19 160/24 164/12
165/12 165/15 169/16}
170/4 170/22 174/2
175/9 180/11 181/8
couldn't [6] 22/25
42/25 107/21 114/22
115/1 169/13
counselled [1] 153/6
counter [1] 72/15
counteract [1] 99/13
couple [3] 43/3 65/12
137/4
course [28] 2/20
19/23 23/20 42/9 47/9}
47/22 59/20 66/12
82/12 85/16 99/23
104/17 105/21 106/19}
107/5 107/21 126/7
127/4 132/8 133/15
146/2 153/20 155/10
155/13 161/10 168/9
169/5 174/11
Court [2] 117/11
163/16
courts [1] 81/25
cover [3] 30/15 177/1
177/4
coverage [1] 170/23
covered [4] 27/2
44/11 63/24 103/10
covering [1] 45/5
crawl [1] 98/17
create [1] 100/9
created [2] 64/2
172/3
creditable [1] 76/22
creep [1] 153/20
criminal [12] 70/16
70/22 81/2 81/2 110/3
110/9 110/18 132/9
132/15 132/23 175/14
175/17
crisis [1] 106/17
criteria [3] 17/5
23/12 50/17
critical [2] 106/6
128/18

Critically [1] 96/22
criticised [2] 67/21
1
criticism [2] 139/17
139/18

criticisms [2] 85/10
108/12

Crown [1] 173/12
culture [19] 135/7
138/14 138/15 138/19}
138/21 138/23 139/1
139/13 153/16 176/6
176/7 176/12 179/15
179/23 181/4 181/9
181/13 181/14 181/24}
cumulative [1] 96/24
curiosity [17] 98/4
98/14 138/15 139/11
139/12 139/14 139/17,
152/23 153/1 153/16
153/17 176/6 179/15
179/16 180/3 181/4
182/3

curious [1] 106/6
current [5] 68/7 88/4
113/16 142/11 182/17}
cut [1] 114/21

cycle [1] 24/16

D

daft [1] 108/20
damaged [1] 112/23
damaging [1] 61/4
danger [2] 37/25
72/14

dashboard [32]
21/20 23/4 23/17
23/24 46/22 47/21
56/1 56/5 56/13 56/15)
56/15 56/21 56/24
58/5 59/16 59/23
122/13 122/20 122/22}
123/1 123/3 123/5
123/8 123/12 123/13
161/15 165/16 165/22
165/25 166/6 166/13
166/17

dashboards [5]
21/22 22/4 72/19
72/21 72/22

data [4] 92/11 92/16
99/13 148/3

date [1] 2/8

dated [9] 1/18 23/9
28/18 87/2 122/21
123/3 123/11 123/13
163/10

day [9] 11/13 11/13
13/17 13/17 45/23
45/23 60/13 60/13
184/3

days [3] 24/7 150/14
170/2

DBT [4] 183/1 183/5

183/8 183/10
dead [1] 114/21
deal [30] 19/24 29/1
29/11 29/16 30/3
30/22 36/24 40/20
43/7 43/14 44/20 64/6
69/19 73/8 73/24
74/15 74/16 78/5
90/23 91/5 95/14 97/8
98/1 101/20 106/17
108/22 114/24 127/19)
173/22 180/25
dealing [3] 14/20
93/19 103/9
deals [1] 46/4
dealt [2] 77/8 107/3
debate [1] 38/11
debt [1] 63/23
decade [2] 81/23
182/1
December [4] 43/25
53/21 54/13 180/20
decide [3] 35/11
39/25 47/13
decided [1] 40/21

decision [8] 40/4
40/17 47/16 82/14
108/20 116/1 182/11
182/13

decisions [3] 16/11
131/2 134/6

decommissioning [4]

12/13 103/4 106/13
171/10

Decreased [1]
148/21

dedicated [1] 70/10

deduce [1] 91/16

deep [25] 62/19
63/11 63/15 63/18
63/20 63/24 72/24
72/24 72/25 73/4
87/24 88/1 127/10
127/23 128/1 128/7
128/11 128/21 128/22!
128/23 129/10 152/20)
152/21 166/7 166/16

deeper [1] 179/21

deeply [1] 104/18

default [1] 13/16

defective [2] 70/21
110/8

defects [2] 84/8
97/17

Defence [1] 7/8

Defence's [1] 7/8

defensive [1] 138/25

define [1] 39/8

definite [1] 4/11

definitely [6] 14/13
61/5 74/6 81/22 81/24I
104/23

definition [2] 67/25

(54) containing - definition
D
definition... [1]
141/22
definitively [1] 42/25
degree [4] 3/2 168/8
172/10 172/16
delegated [3] 18/24
19/4 19/17
delegation [3] 10/20
19/7 53/6
delete [1] 92/15
deliberately [2] 22/10
139/3
delivered [1] 142/11
delivering [2] 45/14
144/8
delivery [19] 7/24
7/25 8/3 8/5 8/20 9/1
9/8 11/2 13/15 20/21
73/14 74/9 143/20
143/21 143/22 144/1
144/8 145/8 148/20
Deloitte [5] 91/2 91/5
91/12 92/2 95/17
Deloittes [5] 91/9
91/15 91/21 91/23
92/22
demand [1] 37/6
demands [1] 22/11
demonstrate [1]
65/21
demonstrated [1]
54/5
deny [1] 61/4
department [41] 3/19
3/21 7/15 11/10 15/19)
19/9 19/13 19/15 24/7
26/10 26/19 29/5 29/6
29/8 29/18 29/19
32/14 37/17 39/7
40/19 42/16 60/13
61/25 73/23 74/4 74/5
TAIT 74/8 74/11 82/22
82/25 95/3 96/9 97/24
105/18 106/9 116/10
129/6 141/24 179/2
182/25
department's [1]
24/8
departmental [12]
26/2 26/7 26/22 29/23
32/2 32/9 32/16 40/15
40/16 41/22 42/13
43/6
departments [21]
10/9 10/11 10/17 12/4
15/13 15/16 18/15
18/16 19/7 22/11
22/13 26/14 26/16
27/10 28/2 31/7 31/14
41/20 61/23 75/7
129/5
depend [4] 26/11

158/11 158/11 158/12)
depended [2] 26/9
114/18

depending [3] 24/8
26/12 130/19
depends [5] 32/24
32/24 33/7 33/8 50/6
depth [1] 53/11
deputise [1] 6/5
Deputy [2] 5/23
1717

derail [1] 157/14
derailed [2] 76/25
77/4

describe [16] 10/2
12/17 15/10 18/22
20/2 21/13 31/10 49/3
51/3 51/13 56/1 64/8
73/15 99/2 153/6
154/1

described [5] 68/4
78/8 112/14 135/23
143/14

describes [1] 129/18
description [1]
112/20

designated [2] 12/25
125/16

designed [1] 67/5
desire [3] 4/12 22/6
79/9

detail [11] 2/7 51/14
83/17 85/25 88/17
100/14 106/20 160/6
162/5 167/3 180/11
detailed [14] 1/14
23/19 51/25 53/16
53/17 92/22 94/15
99/13 121/9 150/20
150/23 156/16 157/7
183/19
detecting [1] 103/8
determine [1] 5/6
develop [3] 24/5
134/4 179/15
developed [3] 24/5
41/14 51/23
developing [2] 5/1
181/4
dialogue [1] 131/19
did [70] 3/15 3/20
3/24 5/14 6/2 20/13
21/6 23/1 23/2 23/24
25/3 25/16 25/19
27/16 34/15 34/20
36/6 36/16 37/2 37/9
37/12 37/16 38/21
40/16 40/22 42/2 45/9
52/24 65/11 70/25
71/4 71/12 72/11
72/12 74/5 75/9 81/22
82/1 82/3 83/5 92/10
93/9 93/17 94/10 96/8
97/10 98/14 99/6

109/2 114/11 114/23
119/11 133/1 134/8
135/6 135/14 149/6
152/11 153/14 161/22
162/7 162/25 163/1
164/13 167/8 169/9
174/7 174/16 174/22
180/20

didn't [37] 6/7 32/4
36/19 54/19 54/24
60/10 60/12 62/22
66/15 71/6 71/7 92/7
92/22 96/25 98/20
98/21 99/1 104/18
105/11 108/22 109/3
111/12 111/13 132/13}
139/3 139/16 161/24
162/4 162/18 162/18
164/15 165/9 165/11
166/9 166/24 180/10
182/15

difference [8] 26/21
42/23 42/24 43/1
45/10 179/16 181/5
183/9

differences [1] 75/10
different [14] 13/15
23/12 26/16 33/7
33/18 50/17 51/4
51/21 93/10 109/18
127/9 161/13 182/1
183/3

differently [4] 58/22
97/20 97/21 97/22
difficult [17] 9/12
18/10 19/22 35/24
38/6 62/8 67/17 96/10
99/20 104/24 120/25
137/24 159/19 164/8
173/3 176/22 179/5
difficulty [3] 8/6 8/7
99/25

dig [2] 104/23 105/10
direct [12] 11/12 12/8
32/14 33/2 45/4 75/19
78/10 78/21 94/24
100/25 135/16 182/12
direction [2] 20/19
133/24

directions [2] 116/12
119/24

directly [14] 15/21
32/22 33/11 33/16
60/12 77/21 94/4
99/19 99/22 100/12
100/15 168/1 182/11
183/5

director [32] 3/15
3/24 5/25 17/12 18/20
30/13 30/17 30/24
34/12 35/23 36/25
44/1 44/5 44/12 45/13)
45/14 45/17 49/5
55/19 55/20 57/16

57/17 82/17 101/6
101/16 124/16 124/23}
136/2 148/19 154/7
154/16 168/6
directors [22] 9/14
17/17 17/17 17/18
19/21 20/13 28/22
44/7 47/4 47/7 53/7
53/7 78/19 78/25
88/19 101/9 103/25
105/6 116/20 119/12
134/1 179/20
disbanded [1] 21/9
discharged [2] 26/7
26/21
Disciplinary [1] 17/8
disclosed [2] 132/22
150/14
disclosure [4] 2/6
132/11 132/21 137/15]
discretion [1] 100/11
discuss [7] 10/14
46/11 96/15 96/17
116/22 155/12 156/9
discussed [12] 31/18
72/8 75/23 81/11
81/14 86/1 86/16
129/10 135/3 156/1
156/11 158/14
discussing [2] 152/3
164/2
discussion [17]
46/15 50/10 82/9
86/24 87/14 90/7
93/11 105/20 111/25
138/19 138/20 143/10)
145/19 166/1 169/19
171/4 172/7
discussions [4] 63/8
70/10 73/12 138/16
dismiss [2] 106/16
118/8
dismissal [2] 17/8
118/7
dismissals [1] 117/7
dismissed [1] 119/5
dismissing [3] 118/5
118/23 118/25
disparaging [1]
108/25
disposals [1] 128/16
dispute [1] 90/18
distance [2] 12/5
114/19
distaste [1] 118/15
distinct [1] 43/19
distinction [1] 81/7
distraction [1]
110/15
distressed [2] 5/2
5/20
dive [7] 63/18 63/24
73/4 87/24 127/10
128/1 152/20

diver [1] 88/1

dives [14] 63/11
63/15 63/20 72/24
72/25 73/1 127/23
128/8 128/11 128/21
128/22 128/23 129/10)
152/21

dives’ [1] 72/8

do [116] 1/16 1/17
1/21 8/18 9/14 9/20
13/2 13/7 13/12 18/16)
19/5 23/24 26/16
26/17 26/18 34/6 35/6I
38/17 40/1 40/9 41/10)
43/1 43/2 43/6 52/6
53/7 54/15 55/2 59/12I
72/15 73/4 78/20
80/21 81/7 81/15
81/19 83/5 84/20
84/23 85/4 85/10
85/25 86/4 86/19
89/10 91/15 91/18
92/18 92/22 93/14
95/4 95/8 95/23 95/23}
100/15 100/16 100/22)
100/23 101/2 101/10
101/10 101/13 101/14}
103/5 104/6 104/7
104/9 105/16 106/12
106/15 106/16 107/12)
109/11 110/15 110/15)
1114/6 111/11 117/11
118/3 121/14 122/6
122/7 123/23 123/25
128/19 133/12 137/18)
138/10 139/14 141/13)
161/22 152/7 152/12
152/16 155/25 156/10)
156/23 159/14 159/24)
160/13 163/19 164/5
167/3 167/21 168/1
168/18 169/3 169/21
170/24 175/1 175/14
177/4 178/9 179/3
179/7 183/3
document [45] 12/23
23/20 24/2 30/21
38/25 51/1 51/18 53/8)
53/16 53/18 54/16
55/10 55/18 60/6
66/19 71/9 78/7 84/24)
109/17 112/9 129/18
131/16 136/25 140/5
140/13 144/11 144/17)
147/10 147/11 147/12)
147/19 148/8 148/25
149/5 161/13 161/23
163/10 165/13 166/8
170/3 171/25 172/3
177/13 177/17 182/18)
documents [19]

23/21 24/3 24/3 25/1
39/20 56/2 56/16
85/17 122/16 122/18

(65) definition... - documents
D

documents... [9]
132/21 140/3 148/5
148/6 153/19 158/3
159/12 166/12 178/19
does [18] 4/21 32/9
35/4 42/4 59/14 60/7
66/25 67/18 68/17
100/3 140/18 141/11
142/16 142/21 143/23)
173/22 176/3 181/18
doesn't [15] 37/19
54/21 105/17 105/19
110/13 111/18 113/11
115/8 115/20 141/10
142/15 142/17 142/18
142/20 169/22
doing [12] 22/23 24/1
41/1 41/2 43/12 62/1
66/7 105/18 120/14
132/4 132/7 155/15
domain [1] 91/14
don't [80] 13/14
14/14 17/3 27/13 36/6)
37/24 41/25 41/25
42/19 42/20 42/24
43/4 43/12 51/6 54/18)
58/10 58/18 61/4
69/14 71/4 79/6 80/20}
80/24 81/5 81/22 82/4
82/15 84/24 85/15
85/18 85/23 85/23
86/6 91/6 91/10 97/1
98/16 98/19 98/25
100/23 101/10 101/12)
101/15 105/14 105/14}
107/19 108/2 108/24
108/24 109/6 112/18
113/20 115/7 115/22
118/24 119/20 119/25)
120/12 120/16 134/11
136/22 136/23 140/7
144/12 145/10 148/9
149/9 150/12 155/23
156/2 162/11 164/13
167/22 169/3 171/1
171/13 171/14 175/7
182/20 183/8
Donald's [1] 2/9
done [16] 73/1 77/22
97/20 97/21 97/25
99/5 106/24 107/5
107/6 107/10 107/11
164/12 165/4 167/19
168/3 179/3
Donnelly [1] 183/11
double [1] 145/2
doubt [2] 98/24
117/19
down [50] 7/1 12/2
12/23 28/15 30/21
34/5 38/25 40/21 46/4,
53/8 55/10 60/6 61/14

66/4 67/14 68/8 70/9
71/9 75/15 76/19 77/9)
78/7 89/18 90/9 91/25)
94/8 97/8 109/24
112/9 112/16 123/23
125/14 129/20 129/25)
132/14 136/2 136/25
138/5 143/2 149/5
149/11 149/23 151/2
165/17 170/3 170/11
171/20 172/22 175/8
175/16

downside [1] 118/25
downsides [1] 119/8
draft [2] 125/8 172/3
drafted [3] 88/21
88/25 89/2

draw [1] 81/7

drawn [3] 112/25
160/24 166/18
dreaming [1] 131/9
drift [4] 105/18
driven [3] 18/3 22/5
127/23

driving [1] 79/17

DTI [1] 4/18

dual [2] 40/17 41/23
due [7] 2/20 42/9
59/20 68/10 127/4
148/22 153/20

Dunn [1] 88/14
during [5] 63/16 72/8
94/20 128/14 133/4
duties [2] 20/13
119/13

dwell [1] 112/12
dynamic [1] 40/11

E

each [20] 17/10
21/21 21/23 23/3
26/13 56/10 59/18
64/3 64/12 64/15 67/7
72/4 72/6 72/11 74/11
74/11 131/6 143/11
158/5 159/11

earlier [16] 19/10
42/7 56/16 61/25
99/24 105/16 116/14
136/20 150/8 152/3
161/15 162/4 165/13
166/24 170/10 175/19)
earliest [1] 164/12
early [5] 24/7 49/8
52/1 58/17 146/6
ears [1] 31/20

earth [1] 96/3

easily [1] 98/16

easy [1] 98/20
economic [1] 4/5
economics [1] 3/3
ED [1] 44/5
Edwards [1] 87/5
effect [1] 117/18

effective [2] 134/6
178/17
effectively [9] 10/12
82/14 108/13 117/19
123/12 125/22 148/13}
168/25 176/1
effectiveness [2]
134/2 179/17
effects [1] 141/9
efforts [2] 76/25 77/5
eight [6] 23/12
145/16 145/23 147/7
163/4 164/9
either [14] 8/23 15/5
26/10 54/10 91/17
94/11 94/25 101/5
114/8 117/6 127/16
160/21 176/10 182/17
element [1] 60/23
else [3] 54/11 70/25
121/16
elsewhere [1] 14/6
email [21] 87/2 87/15
88/13 89/13 89/13
89/17 89/19 90/6
90/10 91/2 93/4
122/21 123/11 149/24)
150/12 150/18 156/18}
156/24 169/17 173/17
173/21
emails [2] 89/5 89/25
eminent [1] 117/9
Emma [3] 1/11 90/5
149/25
emphasis [1] 4/11
Emphatically [2]
96/12 96/12
employed [2] 14/25
15/5
employees [4] 16/13
16/19 80/19 97/19
employment [1] 3/21
empowered [1]
182/10
enable [1] 77/22
enabled [1] 120/8
encouraged [1]
52/13
end [10] 57/23 69/15
109/4 114/10 114/11
116/4 142/11 155/15
169/3 169/6
ended [1] 115/1
Energy [2] 4/7 7/16
enforcement [1] 17/6
engage [3] 5/5 66/11
72/16
engaged [9] 18/15
22/7 33/11 61/23
61/24 66/2 99/19
99/22 99/24
engagement [5] 12/8
35/5 41/8 91/19 168/8
engages [2] 68/23

151/11

engaging [3] 31/6
66/7 169/14
enormous [2] 18/10
79/16

enough [6] 12/8
38/22 119/10 167/19
168/3 176/9

ensure [21] 9/17
14/20 23/1 57/20
62/16 69/6 77/3 79/9
101/24 113/12 120/24}
126/19 127/13 128/2
130/7 130/22 151/20
158/2 160/14 178/5
179/15

ensured [1] 31/12
ensuring [8] 64/11
68/22 82/19 131/22
134/1 151/11 157/17
177/21

entail [1] 3/25
entered [5] 114/22
115/1 115/3 115/7
115/12

entire [3] 118/23
171/8 171/16
entirely [1] 38/15
entities [4] 141/18
147/15 162/2 182/22
entity [6] 27/6 100/10
144/2 177/17 178/13
182/19

entries [1] 46/22
episode [1] 173/25
Equipment [1] 7/8
equipped [2] 180/17
180/25

equity [1] 154/18
erroneous [1] 85/9
error [1] 171/2
errors [2] 84/8 97/17
escalated [5] 85/23
97/22 106/7 160/1
161/7

escalating [1] 169/12
escalation [1] 19/23
escape [1] 14/16
especially [5] 12/7
46/17 102/5 141/15
157/22

essence [4] 27/22
33/18 72/10 123/7
essentially [8] 4/14
4/16 22/9 27/12 27/23)
28/1 67/10 68/17
establish [1] 4/16
established [6] 4/2
23/10 31/3 49/8 62/10)
102/25
establishment [1]
18/11
et [4] 23/15 41/8
118/17 118/17

et cetera [4] 23/15
41/8 118/17 118/17
etc [1] 88/3
evaluation [2] 155/6
160/18

even [16] 12/16 17/1
43/1 47/25 51/23
57/20 58/17 82/6
84/24 85/1 92/21
98/18 107/8 138/20
180/6 182/3

event [8] 46/17 47/3
47/14 106/21 119/3
119/7 123/3 153/8
eventually [2] 4/6
36/18

eventuate [1] 82/5
ever [12] 35/3 36/23
37/2 38/22 63/24
84/21 96/8 150/23
152/24 154/7 154/20
180/5

every [15] 2/21 25/10
25/11 40/19 47/5
61/25 135/3 135/9
161/6 173/10 181/9
181/16 181/17 181/17
181/19

everybody [1] 23/25
everyone [1] 138/5
everything [5] 19/19
58/16 106/25 128/5
176/25

evidence [18] 2/19
16/11 48/4 100/2
100/8 100/24 102/25
108/11 117/18 146/2
150/19 161/16 172/18}
173/2 173/5 173/13
174/3 174/10
evident [1] 95/8
evolution [1] 61/15
exact [2] 50/14 50/15
exactly [12] 80/24
84/10 123/4 127/25
128/18 132/4 139/9
148/9 149/9 152/18
162/9 175/3
example [13] 2/5
5/19 18/7 18/9 40/5
49/22 53/14 56/22
64/23 103/3 106/13
155/5 172/23
examples [3] 12/11
18/14 103/3
exceeded [1] 108/4
excessively [1]
168/23

exclusively [2] 18/19
173/2

ExCo [11] 47/6 47/7
47/10 47/12 47/22
55/13 56/6 56/13
96/24 97/2 97/5

(56) documents... - ExCo
E

Exec [2] 131/7 136/2
execution [1] 100/5
executive [237]
Executive's [6] 70/1
80/7 83/13 104/4
135/5 145/17
Executive/UK [1]
10/10
Executive/UKGI [5]
27/11 30/16 30/19
30/23 32/1
executives [8] 12/9
20/6 20/7 20/8 20/9
103/10 176/19 181/21
Executives’ [1] 163/4
exercise [1] 120/20
exercised [4] 69/5
83/3 151/20 172/16
exercising [1] 161/3
exert [1] 116/13
exerting [1] 182/18
existed [1] 82/18
existence [2] 20/5
22/5

existential [2] 145/25)
180/24

exit [1] 69/11
expand [1] 4/13
expanded [1] 4/8
expect [4] 86/22
131/10 171/11 178/12)
expectations [1]
113/14

expected [3] 16/19
117/12 158/9
expects [1] 131/16
expenditure [1] 28/3
expensive [2] 114/23
115/2

experience [13]
11/16 12/10 18/1
41/11 41/12 41/13
54/9 65/25 105/15
154/6 154/15 176/11
176/17

experienced [4]
43/12 105/13 162/19
167/9

expert [1] 86/9
expertise [3] 11/16
18/1 43/7

experts [2] 43/10
105/9

explain [28] 3/2 7/20
10/7 11/4 13/13 17/22
22/2 26/25 39/5 42/11
43/16 43/23 44/9
44/21 48/6 48/24
49/11 60/7 61/19 62/9)
74/1 75/18 91/6 99/5
116/17 118/25 164/14}
164/18

explained [7] 27/22
61/25 70/14 89/4
105/16 110/1 112/12
explaining [1] 174/3
explanation [3] 62/22!
63/3 98/20

explicit [2] 143/11
163/1

explicitly [2] 154/2
159/7

explore [1] 139/23
explored [1] 3/1
exposed [2] 39/24
40/3

exposure [6] 58/3
58/8 60/9 60/10 123/9
162/6

express [1] 180/1
expressed [2] 77/15
111/6

expressly [5] 141/10
142/15 145/10 148/25)
166/24

extending [1] 120/15
extent [8] 16/23
33/16 36/23 40/1 74/7
83/2 100/20 105/22
external [7] 26/2 26/4I
26/7 26/22 29/23 32/1
73/23

extract [1] 56/11
extraordinary [2]
128/8 155/13
extreme [1] 17/8
extremely [1] 117/9
extremis [1] 14/19
eyes [5] 31/20 42/5
42/8 42/20 79/11

F

face [4] 35/25 160/8
162/17 163/16
faced [3] 125/24
180/14 180/23
facilitating [1] 102/6
Facing [1] 155/1
fact [20] 9/19 10/9
11/24 14/16 28/8 28/9)
45/9 55/14 81/25 94/5
98/7 99/20 111/10
118/22 136/19 152/3
157/24 168/2 171/16
177/16

facts [3] 124/3
152/12 152/22
factual [1] 177/2
fail [1] 167/5

failing [2] 167/5
167/10

failings [2] 97/5
97/11

failure [4] 42/17
96/15 105/23 107/14
fair [8] 31/2 31/11

43/5 43/11 77/5 81/5
141/19 149/20

fairly [5] 17/3 43/2
50/2 62/18 91/13
faith [2] 61/2 103/10
fallback [1] 113/15
falling [1] 114/16
false [2] 81/24 82/4
familiar [4] 17/4
18/20 83/14 83/16
far [15] 27/12 50/15
63/22 70/19 96/12
107/1 107/23 110/6
117/22 134/11 134/17
134/22 152/22 153/14
172/25

fast [1] 77/12

fault [7] 70/18 71/11
71/14 86/19 92/18
110/5 110/19

faults [3] 61/3 84/7
157/13

feature [6] 5/21 9/2
25/10 48/9 50/4 88/11
features [3] 17/3
18/8 22/12
February [12] 2/9
2/10 6/16 44/8 64/3
64/8 69/21 69/24
70/24 81/1 109/20
134/25

fed [1] 74/6
federated [1] 26/15
Federation [1]
174/20

feed [1] 26/18
feedback [1] 154/3
feeding [1] 47/11
feel [6] 96/8 100/21
119/11 176/7 182/15
182/21

fell [1] 17/7

felt [9] 5/11 19/13
31/4 33/2 35/6 61/2
98/10 119/10 176/18
few [3] 17/23 87/11
150/14

fiduciary [2] 20/13
27/20

fifth [1] 50/23

fight [2] 90/4 90/14
fighting [1] 89/21
figure [1] 148/5
figures [1] 117/10
file [1] 150/6

files [1] 92/16

final [7] 69/8 95/17
96/4 96/5 106/5 153/7
167/17

finally [4] 43/5 97/3
113/10 182/24
finance [23] 3/6 3/11
3/16 3/24 4/14 4/19
4/21 5/21 5/25 6/8

15/4 17/11 17/20
21/21 22/18 24/12
26/11 61/24 62/4 62/7,
104/12 104/13 158/4
financial [17] 6/23
9/19 12/16 12/25
21/10 50/24 54/9 58/3)
70/15 96/19 105/10
110/2 123/9 141/5
147/6 162/6 179/1
financially [1] 148/24
find [9] 50/12 54/10
54/15 54/18 119/8
122/12 126/23 144/19}
173/2
finding [1] 159/19
findings [2] 69/3
151/16
fine [5] 33/14 48/16
102/17 146/16 184/1
finished [1] 48/10
iona [2] 63/5 70/5
Fiona-Jane [2] 63/5
70/5
firm [2] 106/22
107/16
firms [2] 91/21 94/4
first [41] 2/9 5/9 5/19
6/13 31/12 37/7 48/11
50/21 61/18 93/12
93/13 94/3 102/19
113/21 117/22 119/23}
122/11 122/19 124/24}
125/6 125/22 126/9
126/24 127/1 127/4
133/9 133/25 135/3
137/1 138/5 143/5
143/7 143/8 145/4
149/3 150/9 150/11
150/25 154/23 156/17}
181/11
Firstly [1] 122/9
fit [1] 143/24
five [5] 51/2 54/15
96/20 102/15 102/16
flag [1] 73/20
flagged [2] 85/11
135/17
flags [1] 98/18
flawed [1] 68/12
flexibilities [1] 9/24
flexible [3] 19/8
22/10 22/12
floor [1] 66/5
flow [5] 34/9 38/20
41/18 45/10 179/25
flowed [1] 42/17
flummery [1] 110/13
flush [1] 59/7
focal [1] 128/10
focus [8] 2/7 5/1
46/24 63/2 73/21 77/2)
96/18 143/9
focused [2] 74/10

94/5

focuses [1] 110/17
focusing [5] 25/2
65/16 73/11 73/18
142/1

follow [5] 27/15
47/13 89/25 156/4
180/4

follow-up [1] 156/4
followed [1] 25/22
following [3] 132/2
153/2 184/3

follows [1] 9/10

fool [1] 162/18
forced [1] 35/12
foresees [1] 10/20
forgive [1] 76/10
form [4] 6/23 21/10
33/18 100/9

formal [3] 47/22
134/10 134/11
formally [2] 20/4
74/20

format [1] 144/14
formed [1] 4/17
former [2] 21/9
117/10

fortunate [1] 176/9
forum [1] 47/19
forward [4] 137/1
150/6 155/20 174/10
forwarding [1]
150/10

forwards [1] 82/6
found [6] 37/9 69/12
123/11 131/10 181/23)
181/23

four [12] 17/18 19/21
34/5 94/4 94/7 128/11
147/12 148/10 155/1
155/18 158/13 158/14I
four-page [1] 147/12
fourth [2] 50/23
134/3

framework [5] 8/11
177/13 177/16 178/19}
182/18

FRANCIS [3] 1/6 1/10
185/2

frank [1] 134/4
Frankfurt [1] 3/12
Franklin [1] 54/8
free [2] 11/3 14/19
freedoms [2] 9/20
11/2

frequent [1] 134/20
frequently [1] 18/16
Friday [2] 150/7
173/18

front [4] 1/16 64/24
66/17 122/6

Fujitsu [4] 86/8 92/11
92/15 175/9

full [9] 1/8 15/5 67/19

(57) Exec - full
F

165/6

fuller [1] 98/5
fully [1] 180/10
function [7] 4/20
10/1 26/8 26/22
103/17 105/17 126/5
functions [4] 20/2
20/14 20/17 172/13
fund [1] 4/24
fund-raisings [1]
4/24

109/2 176/24 179/23
182/2

funding [5] 35/21
76/23 87/20 141/8
145/23

further [26] 9/23
10/14 24/14 29/11
51/23 54/7 68/7 73/9
77/13 89/10 89/12
90/9 91/18 91/25
95/22 98/5 112/16
113/3 129/20 131/1
136/8 151/14 153/11
153/11 157/21 180/21
Future [1] 155/1

G

G7 [1] 77/13
gave [5] 23/11

159/1
general [7] 22/2 25/9

71/18

generality [1] 133/8
generally [4] 13/7
75/1 113/5 141/21
Generals [1] 18/21
generate [1] 170/22
generates [1] 13/3
genius [1] 105/1
get [37] 9/18 13/20
17/22 18/14 37/12
50/10 60/15 65/11
65/17 66/1 87/8 94/3
94/7 101/15 101/25
105/24 109/2 109/20
110/14 111/12 111/13)
115/5 115/18 117/2
120/25 132/13 140/4
154/3 154/24 163/4
169/7 169/7 171/19
176/12 177/7 180/21
182/16

getting [2] 38/22
107/25

Gibson [2] 90/2 90/6
give [15] 12/11 18/7

full... [6] 84/21 92/3
105/19 105/21 121/25

fundamental [5] 97/5

108/11 109/23 119/24}

26/6 30/25 34/1 56/25

20/15 23/25 24/16
46/8 65/13 78/19
100/25 116/17 138/2
139/3 159/1 163/1
176/22

16/25 45/2 71/12
71/16 77/4 89/8 92/2
98/2 103/3 107/18
114/1 125/3 133/13
142/4 166/12

gives [2] 2/5 24/23
giving [3] 49/12
139/1 173/12

glad [2] 99/19 99/23
GLO [4] 86/11 92/11
96/25 107/18

go [61] 4/1 10/15

50/12 51/9 52/14

72/11 73/25 76/19
95/24 96/12 104/9
104/20 105/8 106/15

112/14 112/17 112/21
113/3 114/2 119/19
125/14 126/2 129/17

136/2 136/19 139/23
139/24 147/2 147/3

149/15 155/13 157/6
157/8 159/21 160/18

179/21 180/3 180/11
goals [1] 74/11

goes [7] 9/19 13/18
60/17 106/11 128/8
155/7 176/25

going [47] 5/15 5/17
14/12 19/9 23/8 28/25
46/4 49/24 51/18
51/20 53/22 56/24
59/24 65/17 69/1
70/11 79/4 79/5 82/5
82/11 84/20 87/16
89/20 90/9 90/9 91/20)
95/14 97/8 102/19
108/19 109/5 109/16
111/17 111/22 112/17)
114/3 119/20 122/24
124/6 124/10 127/21
148/18 155/20 177/3
181/25 182/7 182/22
gone [6] 97/24 106/9
107/22 111/18 171/8
1741/5

good [26] 1/3 22/22
23/21 23/23 23/25
24/23 47/23 54/3
66/12 66/14 102/12
102/13 102/22 104/15)

given [17] 11/2 13/23

21/14 29/15 41/4 44/9

53/19 53/20 59/8 62/9)

109/19 109/24 109/24)

129/20 129/25 133/19)

147/15 147/20 147/25,

165/12 165/16 169/22,
171/14 173/24 174/25)

146/7 160/19 160/20
169/6 173/22 177/14
179/24 181/23 182/3

got [20] 19/18 27/25
33/10 60/21 73/3

114/8 131/8 136/22
138/17 142/6 145/8

governance [34] 4/8
4/9 8/11 9/11 9/22

58/13 58/23 74/16

75/10 78/6 78/10
100/3 103/2 103/8
104/21 105/23 107/14
125/20 127/19 129/22)
137/8 143/4 161/21
177/19 177/14 178/22
governed [1] 108/13
government [82]
4/13 4/22 5/3 5/4 5/7
5/8 5/10 6/23 7/18
7/21 7/24 8/5 8/6 9/15
10/10 11/4 11/15
11/25 12/20 13/3
13/10 13/16 14/9
15/17 16/13 18/12
18/16 18/23 21/10
27/6 27/20 28/12
30/24 31/22 35/23
75/3 75/6 78/10 79/5
94/6 100/10 100/19
101/2 103/4 106/11
106/15 108/22 112/25}
113/9 114/8 114/18
115/9 115/11 115/16
115/24 117/3 117/13
117/16 119/5 120/8
128/16 129/14 129/23
130/2 130/18 130/25
131/16 131/19 131/22
132/1 132/7 133/13
141/8 155/3 157/20
157/24 172/11 172/16
177/10 177/16 177/19}
177/23
Government's [8]

4/3 4/9 44/2 58/2
76/23 116/12 116/23
116/24
government-owned
[3] 75/3 100/10
101/2

grade [3] 77/11 77/11
77/12

Grant [2] 94/1 94/8
grateful [2] 121/11
183/20

grave [1] 166/17
great [6] 22/12 61/3

127/19 127/20 140/16

100/17 100/18 105/19}
106/17 107/23 108/18

147/23 173/17 180/14

10/4 46/25 57/6 58/12

74/22 74/23 75/2 75/6

114/24 162/5 171/9
173/22

greater [3] 31/17
100/21 168/8
greatest [1] 115/23
Green [2] 18/12 50/3
gripe [1] 170/5
GRO [1] 65/2
group [18] 15/12
22/21 61/18 67/20
68/23 68/25 69/3
69/10 69/12 146/10
146/13 151/7 151/12
151/13 151/16 153/5
154/17 154/17
group's [1] 63/7
guess [2] 80/24
178/25
guises [1] 182/1
Guy [1] 70/5

H

had [110] 6/13 17/25
25/23 26/17 27/5
27/11 28/20 30/7 34/7,
34/16 35/12 36/20
37/2 38/16 41/2 41/17,
42/6 43/1 43/11 43/20)
44/16 47/5 54/13
54/24 55/2 61/1 61/2
61/7 62/19 62/21
65/10 76/7 77/4 78/21
78/24 79/7 79/24
80/15 84/7 85/8 86/9
88/21 88/24 90/3
92/24 94/22 95/4 96/6
97/14 97/16 97/23
98/3 98/3 98/10 98/22,
98/22 98/24 100/1
106/8 107/8 111/16
112/2 112/3 117/8
117/20 118/11 127/20}
128/17 131/4 132/22
132/25 133/9 135/10
135/19 137/11 138/17,
139/8 139/21 149/23
152/17 152/21 152/24}
153/4 153/19 153/21
154/7 154/13 156/5
156/8 156/14 159/3
159/4 159/25 162/11
162/16 162/19 162/23
163/7 164/6 165/11
167/12 168/3 169/10
170/24 171/8 173/8
173/25 175/13 180/6
180/14

hadn't [1] 156/20
half [1] 10/7

halfway [2] 76/19
120/7

halfway-house [1]
120/7

halt [1] 86/8

hand [5] 22/14 73/13
73/19 140/15 159/21
handbook [2] 75/2
129/19

handed [2] 171/20
175/16

handful [2] 58/24
116/9

handing [2] 172/22
175/18

handle [1] 127/20
handy [1] 162/41
happen [7] 104/17
104/18 120/16 139/13)
153/14 173/10 182/23)
happened [11] 8/22
12/15 35/13 99/23
106/11 122/25 139/8
152/16 156/5 170/24
183/3

happening [2] 61/5
140/22

happens [1] 173/11
happy [2] 87/13
160/18

hard [3] 1/15 65/18
165/7

has [44] 3/6 4/25
8/22 11/12 19/16
19/21 22/12 30/10
30/18 40/2 42/3 49/20
54/5 54/7 66/17 68/11
76/25 103/12 105/4
105/22 106/11 111/18)
119/5 122/19 123/15
159/11 163/15 163/21
165/20 167/19 168/14
169/2 172/11 172/15
172/15 173/20 174/5
176/1 176/2 176/5
176/15 176/16 179/9
182/19

hasn't [1] 101/7

hate [1] 91/21

have [345]

haven't [8] 107/13
108/18 123/2 150/15
172/25 178/11 180/12)
180/19

having [14] 5/7 31/20)

33/2 37/21 40/10 53/6I

81/14 84/22 106/20

128/20 144/4 160/6

168/2 175/14

he [8] 36/10 108/17

108/17 131/7 131/9

131/10 136/5 168/21

he's [1] 131/8

head [2] 30/18

137/17

heading [1] 113/11

headings [2] 68/2

155/1

healthy [2] 38/10

(68) full... - healthy
H

hear [13] 1/3 33/16
48/21 84/3 93/17
99/21 100/1 100/8

174/16 182/7

103/23 173/8 173/14
174/16 175/6 175/13
hearing [3] 33/6
93/21 184/3
heart [5] 134/24
135/6 138/3 181/9
181/18
heatmap [14] 64/19
64/24 65/8 66/17
66/25 66/25 67/8
67/14 72/4 73/13
73/19 73/20 112/11
140/8
heatmaps [3] 64/4
65/11 104/4
held [3] 2/25 3/7
39/16
Hello [2] 48/21 84/3
help [13] 7/22 12/24
16/18 19/3 22/14
34/23 51/10 67/1 71/5
98/13 159/13 160/7
160/11
helpful [1] 136/12
helpfully [1] 20/15
helping [1] 125/18
helps [1] 67/23
her [12] 27/1 34/22
44/23 45/3 45/9 54/5
134/5 141/7 155/6
155/19 155/19 155/21
here [58] 11/18 25/6
29/1 29/16 32/7 32/17
33/23 35/1 43/24
46/14 49/25 51/1
56/25 57/19 59/9 64/8
64/24 66/7 66/24
67/16 71/22 71/25
77/2 85/19 87/9 87/21
90/23 91/6 94/18
95/15 103/21 104/11
106/12 106/17 106/18}
107/14 107/19 110/22)
110/23 111/17 114/7
114/14 114/15 114/17)
121/17 126/4 130/22
140/7 153/14 160/21
161/19 161/22 168/25
173/7 173/12 179/19
180/4 181/2
herring [1] 100/19
Hi [1] 87/18
high [32] 18/11 18/25
21/19 23/6 23/20 25/2
25/7 25/14 50/5 51/11

healthy... [1] 40/11

100/24 121/20 138/13}

heard [8] 93/12 93/16

52/20 68/19 74/9
74/10 74/13 88/11
89/17 110/21 119/3
121/1 127/6 127/6
127/16 128/9 128/20

142/3 148/21 163/16
170/22

high-level [3] 23/20
25/14 74/9

high-risk [2] 141/21
141/22
higher [3] 72/12
77/12 77/14
highest [4] 129/12
135/18 142/2 158/8
highest-risk [1]
142/2
highlighted [4] 78/24
90/10 135/11 147/14
highlighting [1]
148/25
highly [1] 50/8
him [5] 54/8 118/20
125/19 131/8 134/5
him/her [1] 134/5
himself [1] 131/10
hindsight [5] 98/17
106/19 111/3 151/25
165/10
his [7] 108/12 129/19
137/17 170/5 177/10
177/115 177/19
history [4] 41/4 76/14
81/21 124/9
HMG [5] 58/3 58/7
60/16 123/9 162/6
HMT [2] 20/8 183/9
hoc [3] 47/25 60/5
62/25
hold [8] 3/2 7/7 9/9
10/13 27/17 39/6
103/17 126/16
holding [4] 7/14 10/1
39/2 134/5
holiday [1] 173/18
holistic [1] 24/10
honed [1] 126/24
honest [4] 6/4 120/2
131/18 155/20
honesty [1] 16/6
Hooper [1] 76/15
hope [2] 27/8 160/3
hoped [1] 181/22
hopefully [2] 135/17
136/21
hoping [3] 87/8 91/12!
115/5,
Horizon [55] 12/14
33/10 42/4 54/12
54/17 54/20 58/4 58/6
58/18 60/25 63/23
69/13 69/15 83/4 84/7

133/23 141/21 141/22

high-profile [1] 119/3)

85/8 88/18 90/19
92/16 94/19 95/5
96/17 97/11 97/15
97/17 99/3 113/22
122/12 122/20 123/10}
128/6 146/2 149/3
151/18 152/25 153/3
156/1 156/10 156/11
156/21 156/21 157/13}
157/25 162/7 162/12
162/24 163/5 163/13
164/3 171/23 173/9
174/6 174/22 174/24
180/5
hot [2] 88/4 88/6
house [2] 120/7
141/24
how [38] 6/2 22/2
23/21 25/3 29/1 34/8
34/20 37/13 38/8
38/19 39/8 40/16 47/2
65/21 73/15 80/9 85/4
93/11 94/19 104/15
106/16 107/18 112/18}
130/1 136/14 138/3
142/18 143/23 148/9
154/11 155/8 176/8
178/22 179/14 180/1
182/2 182/9 182/12
How's [1] 155/15
however [5] 12/10
70/17 70/20 110/4
110/7
HS2 [1] 8/4
huge [1] 176/5
human [5] 8/17 8/18
9/2 9/18 143/23

l address [1] 165/6
lagree [4] 89/22
111/22 115/22 167/4
also [2] 87/22 96/25
l always [2] 19/13
24/21

lam [9] 38/13 50/15
55/4 71/15 83/14
88/25 124/6 131/14
181/11

I appreciate [1]
131/15

lask [3] 1/11 102/22
167/25

lasked [1] 87/5

I aware [1] 133/10

I basically [1] 4/18

I became [4] 34/24
36/6 78/2 128/5

I believe [2] 106/19
132/4

I call [1] 8/3

Ican [22] 48/22
54/10 63/17 63/25
98/25 112/2 121/22

138/2 139/12 146/12
153/14 156/23 159/1
167/8 167/23 168/19
169/21 171/13 172/25}
173/13 173/16 173/20
Il can't [59] 34/21
34/24 37/13 37/19
37/20 38/14 61/21
63/17 63/20 71/15
77/19 81/6 81/14
82/11 82/11 83/19
84/18 84/22 88/7 88/7
88/9 90/16 90/20
90/21 93/11 111/24
119/3 119/4 120/2
120/2 139/2 143/1
147/21 149/17 149/17]
149/22 156/14 156/15)
160/11 160/11 160/11
161/4 161/4 161/5
162/9 164/18 164/24
165/1 169/21 169/25
174/15 174/19 174/20}
175/3 175/5 176/17
178/11 179/6 180/1
I cannot [1] 34/8
I certainly [1] 42/25
I comment [1] 58/14
I completely [4]
111/8 111/20 111/21
112/1
I correct [1] 74/19
I could [5] 91/16
123/22 154/15 174/2
180/11
I couldn't [2] 22/25
169/13
I deeply [1] 104/18
I definitely [2] 81/22
81/24
I did [11] 5/14 23/1
36/6 42/2 81/22 93/17
97/10 135/14 164/13
174/16 180/20
I didn't [6] 36/19
60/10 132/13 139/16
161/24 165/11
Ido [10] 1/17 13/12
34/6 81/19 95/23
95/23 117/11 122/7
123/25 155/25
I don't [59] 13/14
14/14 17/3 36/6 37/24,
41/25 41/25 43/4
43/12 51/6 54/18
58/10 58/18 61/4
69/14 71/4 79/6 80/20
80/24 81/5 81/22 82/4
82/15 84/24 85/15
85/23 85/23 86/6
91/10 98/16 98/19
98/25 101/15 107/19
108/2 108/24 108/24
109/6 112/18 113/20

4115/7 115/22 118/24
120/12 136/22 136/23)
148/9 149/9 150/12
156/2 162/11 164/13
167/22 169/3 171/1
171/13 171/14 182/20)
183/8

l explained [4] 27/22
61/25 89/4 105/16

I find [1] 173/2

I first [1] 93/12

Igo [7] 4/1 52/14
95/24 104/9 104/20
105/8 180/3

I got [1] 173/17

I guess [1] 178/25

I had [7] 131/4
132/25 133/9 156/5
162/11 165/11 173/8
I hadn't [1] 156/20

I happen [1] 120/16
Ihave [18] 14/7
36/18 65/25 77/19
97/21 103/19 108/3
109/4 109/5 116/9
117/3 150/3 162/13
164/11 166/2 173/1
176/17 183/14

I haven't [2] 172/25
178/11

I hope [2] 27/8 160/3
linclude [1] 153/1
lincreasingly [1]
168/24

I just [2] 42/23 84/11
I knew [6] 82/2
164/10 164/11 164/24)
175/6 175/17

I know [3] 81/22
132/24 163/21

like [1] 50/10

I look [3] 96/1 139/25
162/14

I made [1] 149/2

I may [3] 76/10 84/12
182/14

I mean [49] 9/23 27/7
35/2 39/25 42/5 42/23)
47/16 58/14 59/6
60/20 79/3 85/15
98/16 99/18 101/7
103/21 105/2 107/18
113/20 115/7 118/1
119/10 128/14 134/13)
138/2 138/15 138/22
138/25 141/16 143/10)
144/8 147/23 152/11
152/22 155/13 156/14)
158/22 158/25 159/6
159/24 162/14 163/21
167/8 167/23 169/6
176/5 179/5 179/8
182/20

I might [1] 107/8

(69) healthy... - I might
I must [1] 175/17

I now [1] 180/7

I offering [1] 91/23

I placed [3] 134/23
135/1 135/2

I presume [2] 60/12
93/22

I probably [1] 164/12
lread [1] 167/22
really [1] 175/7
Irefer [1] 148/16

l reference [1]
162/15

I regret [1] 156/3

I remember [1] 66/4
l repeat [1] 179/22
lreplied [1] 173/18

I said [5] 136/24
139/16 156/19 160/5
171/6

I saw [5] 5/1 123/5
135/14 149/11 150/25
I say [19] 8/15 9/7
24/4 36/16 55/22
91/10 94/2 96/1
119/18 120/12 128/22
137/2 159/6 159/6
161/24 162/10 164/10)
165/10 168/7

I see [2] 82/1 82/3

I seem [1] 65/11

I set [2] 156/5 174/12
I should [7] 14/5 42/1
50/5 53/20 60/8
137/20 165/9

I simply [1] 153/12

I specifically [1]
126/24

I spent [1] 174/12

I start [2] 22/4 173/21
I started [1] 176/6

I still [1] 6/7

I suddenly [1] 173/15
I suppose [5] 23/5
24/3 24/15 39/11
143/3

I surmised [1]

156/19

I talk [2] 152/23
153/1

I talked [2] 181/14
181/15

Itend [1] 173/23
Ithen [4] 173/24

I think [172] 4/2 13/1
13/4 13/14 13/22
16/15 16/17 16/25
22/5 22/11 24/25
25/21 26/9 27/22
34/21 36/9 36/10
36/12 36/16 37/5 37/7
37/25 38/1 38/3 38/10

38/10 39/17 39/19
40/20 40/23 41/25
47/8 48/8 48/15 49/12
50/20 50/20 51/5
51/24 58/12 58/17
60/14 60/23 60/24
61/7 61/21 61/21
61/25 62/1 63/19 64/4
67/2 67/18 67/25
68/16 71/6 71/8 73/2
76/10 79/3 79/8 79/19)
80/2 80/12 80/13
80/22 82/25 84/18
84/25 89/2 89/10
91/23 93/25 94/2 94/8
95/11 96/1 97/21
97/22 97/24 99/7
99/10 99/15 99/22
101/4 101/5 101/20
102/19 102/25 103/12!
107/13 107/16 108/1
108/3 108/17 109/4
111/16 112/20 114/7
114/13 114/17 115/10)
115/22 116/1 118/1
118/18 120/10 120/11
120/13 120/22 126/23}
126/25 127/18 127/22)
128/4 128/11 128/14
131/3 131/5 133/10
134/10 134/12 136/24)
137/1 137/20 138/12
138/12 138/14 140/1
140/2 140/7 142/5
143/6 145/14 146/7
148/16 148/17 149/2
149/19 151/25 152/9
156/1 156/2 156/13
156/13 156/19 158/11
159/1 159/23 159/24
160/5 160/16 160/20
160/24 163/3 164/18
165/17 165/20 166/4
168/21 169/8 170/10
1741/1 171/7 171/12
172/17 174/5 176/14
177/1 179/22 180/12
180/15
I thought [3] 66/6
180/22 181/13
I took [2] 175/21
181/16
l understand [7] 1/25
60/16 122/15 123/18
124/10 157/7 172/4
I understood [1]
164/23
used [4] 161/25
want [12] 109/13
109/18 122/3 125/6
126/8 133/16 147/2
153/18 153/21 154/22)
163/6 171/25
Iwas [41] 4/16 6/4

21/16 22/24 28/6
62/17 62/20 63/19
72/23 78/3 80/20 81/6
82/11 82/16 84/18
87/8 88/10 90/20
93/21 94/5 96/22
104/20 111/25 118/24
124/18 136/20 136/23
137/14 146/11 147/4
150/8 166/15 168/5
168/7 168/7 168/9
169/12 172/6 173/18
174/1 174/9
I wasn't [2] 137/10
137/13
I went [1] 145/15
I what [1] 162/9
I will [3] 2/20 88/17
121/13
I wish [1] 94/22
I won't [2] 91/3
112/12
I wonder [3] 83/20
101/23 162/14
I would [30] 4/24
9/17 11/22 18/14
18/19 21/17 40/8 42/5}
47/9 47/10 50/4 58/10
66/14 80/24 83/17
92/20 94/8 96/5 105/1
105/2 112/5 122/19
130/16 153/9 153/10
156/13 164/18 165/10
174/16 174/18
I wouldn't [2] 23/18
98/17
I'd [34] 7/18 19/23
24/25 34/21 35/3
39/13 40/12 43/14
48/23 52/10 74/15
84/18 85/1 85/3 86/22
93/15 93/25 94/15
96/12 96/13 97/22
97/23 97/24 97/25
100/14 107/7 111/21
111/23 112/13 143/3
156/13 171/13 173/13
180/12
I'll [8] 87/23 116/4
117/2 121/16 124/8
132/14 150/15 183/15}
I'm [60] 13/4 25/21
27/12 35/9 35/17
36/13 38/15 51/5
54/21 60/17 63/21
67/10 74/5 79/14
80/22 83/16 85/1 85/2
86/3 88/8 89/17 89/21
99/23 102/19 108/3
109/4 115/15 115/15
121/11 121/17 124/10
126/25 131/8 132/14
132/24 133/7 133/7
133/9 139/11 140/14

143/1 144/18 145/14
152/11 158/16 159/18}
159/19 160/18 162/13}
164/4 164/8 166/11
169/7 169/22 173/6
173/12 175/2 177/3
181/10 183/20
I've [33] 4/25 14/14
27/25 36/6 38/18 61/7
61/8 73/3 85/16 90/4
108/25 113/20 116/3
133/4 136/20 147/23
147/23 150/14 153/15}
154/13 160/3 160/21
160/23 162/19 163/3
164/4 166/2 167/23
174/9 176/9 178/7
179/21 181/25
idea [8] 23/12 65/11
104/19 111/16 118/15)
118/21 132/25 164/4
ideally [2] 8/11 50/13
identifiable [1] 25/8
identification [3]
48/24 68/9 169/11
identified [7] 57/5
68/5 152/7 157/25
166/22 169/2 181/2
identify [8] 111/5
136/13 141/10 142/15}
145/10 166/9 167/19
168/3
identifying [3]
136/11 136/17 149/8
ie [4] 13/3 72/11
115/24 121/1
ie not [3] 13/3 72/11
115/24
ie the [1] 121/14
if [178] 1/18 4/1 8/2
8/14 9/7 11/5 12/7
13/4 14/19 17/4 17/6
19/18 22/4 27/13
27/24 29/15 31/14
33/9 35/2 35/12 38/14
41/3 41/3 41/24 43/1
43/3 46/2 46/8 46/16
46/17 47/25 48/7 51/7
51/9 53/19 59/8 60/16
62/21 65/3 67/18
67/23 68/2 68/25
69/15 70/9 70/21
72/16 74/17 76/8
76/12 76/19 80/5 80/8)
80/8 80/10 82/6 83/11
83/20 84/12 85/17
87/7 89/17 95/12 96/2
97/16 98/10 103/18
103/19 103/20 106/5
106/6 107/7 107/9
109/5 109/16 109/19
109/24 109/24 110/7
110/18 111/18 112/2
112/2 112/4 112/9

112/14 112/16 112/21
112/25 113/3 113/16
114/2 114/8 115/18
115/22 115/23 117/20)
117/24 119/10 119/20)
120/14 121/22 123/17)
123/22 126/2 128/12
129/20 129/25 131/3
133/19 133/21 134/11
134/13 134/15 135/1
136/2 137/5 137/25
138/5 138/12 138/16
139/12 140/7 140/24
141/3 143/13 144/3
144/18 144/24 145/7
146/12 146/19 147/3
147/9 147/15 147/20
148/11 148/14 149/15)
151/2 151/10 151/13
152/16 153/4 154/23
154/24 155/17 156/14)
157/4 157/6 157/8
157/9 158/24 159/3
159/3 159/4 159/23
159/24 159/24 161/8
161/8 161/20 164/23
165/16 166/7 167/8
167/9 167/24 168/11
170/7 170/11 170/18
177/6 179/11 180/18
181/14 183/3 183/15
ii [1] 32/12
illegally [1] 165/21
illustrate [1] 2/7
illustrates [2] 28/8
7213
illustration [1] 128/4
immediately [2]
85/12 180/20
impact [17] 67/13
68/3 68/5 68/17 68/18
76/24 77/3 127/16
140/17 140/19 141/4
141/17 143/23 158/5
159/11 159/16 160/10}
impacted [2] 80/5
83/11
impartiality [1] 16/7
imperfect [3] 179/25
180/2 180/2
implement [1] 83/9
implementation [4]
50/22 53/24 134/6
145/4
implication [1]
117/15
importance [5] 15/16
43/4 55/8 95/25
110/22
important [33] 10/8
19/10 19/13 24/10
24/22 27/7 33/5 33/24)
34/25 39/18 39/22
40/3 40/8 48/8 58/16

(60) I must - important
65/15 65/23 66/11

101/9 103/5 145/3
157/19 177/1 177/9

181/2 181/14
Importantly [1] 12/4
impossible [2]
143/13 174/14
impractical [1] 19/18
imprecise [1] 180/9
imprecisely [1]
143/14

improved [3] 54/7
143/4 148/22
improvements [1]
136/3
inappropriately [1]
165/20

incidence [1] 112/7
incisive [1] 110/12
include [6] 21/22

153/1

included [18] 41/6
49/19 53/12 56/9
64/18 72/1 72/3 72/6
86/25 87/7 123/12
126/17 127/24 129/4
146/3 164/16 166/6
170/25

includes [3] 16/10
29/9 123/8
including [16] 20/7
28/20 28/22 75/23
78/11 78/18 113/15
116/18 116/20 117/10}
129/4 155/21 157/13
162/12 162/20 174/1
incoming [1] 122/23
incompatible [1] 9/4
incomplete [4]
139/12 139/16 153/1
153/16
inconceivable [3]
166/4 166/14 166/15
inconsistencies [2]
50/12 50/13
incorporated [2]
23/16 66/18
incorrect [2] 128/6
135/20

Increase [1] 157/12
increased [2] 78/19
172/15

increasing [2] 79/17
79/17

increasingly [5] 24/9
33/10 42/15 148/23
168/24

indeed [9] 8/22 11/23

important... [18]
66/12 94/1 99/6 101/7

177/19 179/13 180/22)

52/23 60/4 67/1 126/4

16/1 24/5 37/13 43/2

independence [3]
69/6 151/20 157/23
independent [17]

69/5 79/4 79/7 79/10
80/14 81/25 98/9
113/6 113/8 151/19

independently [1]
69/10
indicating [1] 102/2
indication [2] 99/25
112/3
indications [1] 98/18
individual [14] 9/12
27/10 56/8 63/17
63/20 64/2 64/12
64/15 66/18 72/11
82/23 127/6 129/15
157/15
individuals [10] 4/17
15/3 19/14 43/14
65/18 66/2 104/6
104/8 168/15 168/18
induction [1] 16/23
industrial [2] 87/22
88/1
Industry [2] 3/19
3/22
infer [1] 179/18
inflate [1] 43/4
influence [1] 94/24
inform [2] 37/16
86/23
informal [1] 134/10
information [43]
13/25 14/21 14/22
15/20 28/20 31/23
32/3 33/25 34/3 34/9
37/18 38/2 38/20
38/23 45/4 45/10
47/11 50/2 57/3 59/13
59/15 59/25 71/19
72/12 74/3 95/7 95/9
99/9 99/16 99/17
101/15 106/2 116/19
133/14 139/2 139/2
145/19 149/7 152/14
166/2 174/8 179/8
179/25
information’ [2]
166/5 167/2
informed [7] 47/2
129/24 130/8 130/23
131/23 131/25 146/13}
informing [1] 16/19
inherent [2] 73/18
81/15
inherited [1] 41/5
inheriting [1] 79/5
initial [4] 5/14 69/3
96/18 151/16

120/11 129/16 134/21

12/18 35/2 35/3 62/18

153/12 154/16 157/20)

initially [2] 20/6
124/11
inject [1] 76/16

85/16 100/8 100/24
102/6 102/24 122/2
122/18 133/4 151/1
167/11 182/7 183/20
Inquiry's [1] 2/19
insert [1] 92/11
inserted [1] 107/17
insight [1] 33/19
insist [1] 117/4
insolvency [1] 5/18
insourcing [3] 7/24
8/15 8/16

instance [4] 35/20
40/1 119/4 119/4
instances [9] 12/6
12/10 12/12 14/12
18/4 31/5 36/20 63/17
95/23

instead [3] 7/24
11/14 72/12
institutional [2]
35/15 35/17
instructed [3] 54/14
54/24 107/11
instruction [1] 54/25
instrumental [2]
129/14 172/6
integrity [6] 16/6
54/12 54/17 63/22
99/3 111/5
intelligent [2] 129/23
131/25
intended [3] 53/10
79/13 154/2
intends [1] 130/2
intention [2] 78/8
113/8
intents [2] 16/16
129/23
interaction [1]
104/24
interest [10] 5/3
11/17 13/21 36/1
36/18 36/24 113/14
129/1 142/8 183/4
interested [4] 50/16
93/9 103/6 106/10
interests [2] 113/13
135/16
interfere [4] 14/10
14/11 14/13 31/4
interference [3] 11/3
168/16 170/5
interim [14] 6/16
69/12 84/9 84/14
84/16 84/21 85/5 85/8
85/18 95/24 109/1
137/6 151/18 152/14
internal [6] 26/1 29/8

Inquiry [18] 1/12 1/13
3/1 29/11 49/20 60/24

29/12 29/21 29/23
139/18
interrogated [1] 98/4
intervene [7] 5/5 5/8
5/8 14/19 100/12
100/15 103/5
intervention [3] 5/20
103/2 130/18
interventionist [1]
131/8
interventions [2]
130/7 130/23
into [44] 4/8 4/14
4/18 5/18 20/5 22/5
23/17 24/7 24/8 32/15)
33/19 41/8 55/8 63/11
63/15 63/18 64/15
66/19 73/4 74/6 76/16)
88/1 91/14 92/12 94/7
96/25 106/23 113/1
114/22 115/1 115/3
115/7 115/12 127/10
128/8 132/14 138/17
155/13 159/9 161/5
173/24 179/21 180/11
180/14
introduced [1] 66/4
introduces [1]
144/23
introducing [1] 76/15
introduction [1] 64/4
investigation [7]
54/14 98/6 98/9
108/13 108/15 114/20
158/2
investigations [3]
70/19 110/6 159/9
investigator [2]
81/17 108/9
investigators [3]
93/3 93/6 93/10
investment [3] 18/12
124/14 124/18
investments [12]
4/23 6/23 6/23 10/10
15/17 18/23 21/10
21/11 28/13 31/22
154/18 154/20
Investments’ [1]
16/13
investors [2] 5/13
5/16
invited [1] 169/7
involve [3] 8/9 25/11
60/13
involved [28] 6/10
11/25 12/7 12/21
13/17 13/20 17/22
18/14 27/6 57/14
59/11 77/21 78/3 83/7
88/10 93/13 94/4 95/5)
95/10 95/21 115/18
115/25 120/25 127/8
131/1 159/8 176/9

182/11
involvement [13]
6/13 12/14 18/3 18/8
77/25 78/1 78/21
94/19 100/22 113/1
113/7 151/22 152/15
involves [1] 109/10
involving [1] 159/9
irrelevant [3] 59/14
149/16 170/12
is [475]
isn't [18] 8/9 8/16
54/22 55/1 59/6 66/3
91/20 105/5 107/9
127/9 145/18 159/20
162/25 162/25 164/22!
166/20 180/23 182/3
isolation [1] 145/18
issue [23] 39/24 42/8
46/16 47/3 47/14 48/7)
54/20 58/6 83/12 90/8I
92/24 100/5 105/10
105/11 106/7 113/8
116/12 119/24 123/10)
138/3 138/11 153/15
180/4
issues [64] 2/22 12/7
13/21 19/22 20/22
22/13 43/10 46/21
46/23 47/7 47/10
47/20 52/15 52/17
58/4 58/6 59/7 62/6
68/24 69/4 69/13 71/1
74/14 75/16 76/1
83/19 90/17 90/19
94/19 94/20 95/5
96/18 107/19 110/16
116/23 143/23 147/13}
148/12 148/13 151/12)
151/17 151/22 155/12)
157/18 157/24 158/24)
159/10 159/25 162/2
162/7 162/24 167/7
171/19 171/22 172/23)
173/6 173/15 173/17
173/24 174/24 175/8
175/16 177/4 179/19
it [554]
it's [101] 4/22 8/18
11/6 13/5 14/7 17/4
19/5 20/1 21/15 23/19)
27/14 38/6 39/17
39/22 39/25 40/2 40/8
43/3 48/8 53/23 56/3
59/6 61/6 62/7 64/7
67/4 67/5 67/10 67/17
67/19 69/14 71/8
71/21 73/25 81/23
85/23 103/1 103/19
104/8 115/17 121/15
132/6 133/19 135/24
137/23 138/3 138/21
139/20 139/20 140/2
140/6 141/15 141/16

(61) important... - it’s
144/12 144/22 146/7

157/5 158/8 158/13

161/19 164/8 164/21
164/24 165/7 165/15

170/2 170/2 170/6
170/12 1714/4 171/42
17213 173/4 173/16
175/24 176/21 177/1
179/5 179/23 181/10
181/19 182/2

item [8] 67/16 68/8
72/2 144/22 164/19
166/5 171/11 181/12
item 1 [1] 181/12
item 11 [2] 67/16
68/8

its [45] 1/13 4/4 4/4
4/13 15/9 16/4 20/2
20/12 20/13 20/14

27/3 35/6 49/1 49/2

74/21 75/20 81/16
95/3 97/6 111/1 114/1
114/24 116/1 116/13

132/11 144/15 154/3
163/13 171/15 172/6
172/6 176/2 176/15
176/16 178/22 179/24)
183/6 183/7
itself [13] 8/19 11/20
53/18 55/24 67/3
98/23 111/25 128/24
130/6 132/1 152/5
169/1 169/10

J

Jacobs [4] 102/14
102/15 102/21 185/6
jail [1] 111/2
James [2] 149/25
156/24

Jane [2] 63/5 70/5
January [16] 44/4
44/7 56/23 61/19
122/14 123/3 123/4
123/6 124/19 124/23
136/21 149/4 161/15
162/10 170/7 181/12
jeopardising [1]
141/6

JFSA [5] 67/22 68/12
69/11 151/9 157/12
job [2] 5/14 66/7

it's... [48] 143/18

147/18 147/18 148/12)
149/13 149/15 149/19)
150/13 150/19 154/24}
155/24 156/10 156/17)
159/19 159/21 161/15)

165/17 166/20 167/13)

items [2] 67/15 135/3

54/14 54/17 61/3 74/5

116/20 125/25 131/16)

joined [5] 3/14 21/9
44/10 124/22 125/4
joining [1] 3/7
jointly [1] 20/8
Jonathan [3] 88/14
89/16 89/19
Jorja [2] 87/3 87/18
judge [2] 38/6 62/5
judged [1] 12/8
judgement [5]
160/22 161/1 161/2
161/3 167/11
judgements [3]
33/15 99/20 100/2
judges [1] 165/19
judgment [6] 116/23
116/25 138/19 173/6
173/15 173/17
judicial [1] 114/20
July [11] 1/1 54/14
62/10 69/12 84/15
135/25 155/19 157/2
163/9 163/10 163/25
July 2024 [1] 1/1
jumped [3] 112/1
112/6 112/8
June [7] 1/18 76/7
90/25 108/11 156/25
158/21 172/3
June15 [1] 157/4
junior [1] 52/12
just [76] 2/21 9/24
14/6 19/18 23/11
31/14 37/13 38/14

47/23 48/2 48/6 51/9
51/18 51/20 53/20
55/5 59/13 59/23 60/1
60/7 61/21 62/21
62/23 63/1 65/10
65/24 66/3 68/2 80/14
83/21 84/11 87/6 90/3
91/23 93/11 99/15
103/19 106/24 107/1
108/4 109/5 109/24
110/14 111/3 111/22
112/7 112/17 115/20
121/16 123/15 133/7
136/19 143/15 143/23)
146/11 147/10 148/5
148/11 148/12 148/18)
149/23 150/13 153/20)
154/24 156/8 159/18
170/11 171/2 177/7
179/21 181/21 183/15)
justice [1] 111/19
Justin [3] 44/4 57/15
163/24

K

Katrina [1] 70/7
keen [2] 62/17 62/20
keep [3] 40/17
112/17 182/5

38/18 42/23 46/2 46/8)

keeping [3] 76/17
113/8 114/18

key [30] 9/1 9/2 9/5
9/6 9/16 20/14 21/19
23/4 24/1 24/3 25/3

32/15 32/19 39/14

59/10 61/15 62/15
67/6 74/11 133/23
136/6 136/9
keyboard [1] 177/20
kind [7] 14/13 24/11
49/13 59/25 62/25
79/14 99/11

KKR [1] 182/21
knew [13] 34/6 82/2
85/13 106/3 118/2
146/16 161/8 164/10
164/11 164/24 173/4
175/6 175/17

know [80] 1/11 17/3
28/5 33/10 36/6 36/7
42/24 51/7 55/3 58/10)
58/21 65/20 67/10
69/14 79/16 80/9
80/24 81/5 81/22 82/4
85/13 85/15 85/20
85/20 85/23 86/5 87/6
89/7 92/11 92/21
95/24 98/22 103/6
103/20 104/13 104/24
105/1 106/10 107/1
107/8 108/2 108/24
108/24 111/24 112/18}
114/2 114/11 114/19
115/12 115/22 117/22
119/14 132/9 132/15
132/20 132/24 136/22
136/23 137/24 148/9
149/9 152/1 152/10
152/11 152/12 153/9
159/3 159/5 162/25
163/19 163/21 164/13
165/7 168/18 173/3
173/17 175/7 180/7
181/25 182/22
knowing [6] 58/21
81/7 81/8 85/13
163/19 163/21
knowledge [16] 2/14
37/16 38/4 38/5 41/11
41/12 41/13 96/23
103/17 124/4 137/4
158/12 160/22 161/1
161/1 161/5

known [15] 85/22
92/20 97/16 106/4
107/7 139/5 152/1
152/11 152/13 152/21
159/3 159/4 160/1
175/17 179/8

knows [1] 82/12
KPMG [1] 3/8

25/7 25/14 32/3 32/10

41/17 49/14 52/9 59/7

L

139/16 179/19

lady [1] 63/4
language [1] 173/23
large [3] 33/1 97/12
102/23

larger [1] 4/9

last [10] 3/7 29/15
38/13 130/4 131/4
132/13 147/23 164/9
164/19 179/12
Lastly [1] 74/14
latch [1] 98/20
latched [1] 98/19
late [1] 5/22

later [14] 14/24 15/11
26/23 45/6 59/17

107/5 107/6 143/1
170/2 177/14

latest [3] 88/3 150/3
157/3

latter [1] 75/12
launched [1] 163/17
Laura [1] 163/24
layer [1] 94/7

lead [5] 18/8 57/13
57/13 134/1 157/19
Leadership [1] 126/3
learn [1] 136/14
learned [5] 159/14
171/25 173/25 179/13}
181/3

learnt [1] 106/20
least [2] 61/7 82/15
leaving [2] 115/4
155/19

led [6] 73/11 85/9
97/3 114/12 138/10
170/24

Lee [1] 149/25

left [9] 57/5 83/8
112/19 140/5 140/17
140/25 143/19 159/21
160/9

left-hand [1] 159/21
legal [7] 89/11
112/25 117/8 117/9
158/2 163/12 180/17
legislate [1] 100/9
legislation [1] 182/21
legitimate [7] 14/8
35/19 36/13 36/16
36/17 114/7 114/13
length [41] 4/9 7/15
7/22 7/23 8/2 9/6 9/16)
9/23 10/3 10/16 10/17)
12/19 13/15 14/7
14/16 27/9 31/5 31/6
33/21 35/2 100/4
101/13 103/1 103/7
104/20 113/16 113/18

lack [4] 11/16 139/14

61/16 73/6 84/7 91/22,

1415/5 115/19 116/2
116/11 119/6 130/9
130/14 130/19 130/25)
131/10 177/8 178/17
178/21 182/6
less [2] 50/10 141/17
lesson [2] 179/13
181/3
lessons [3] 159/13
171/25 173/25
let [4] 89/7 147/25
179/21 182/22
let's [5] 90/5 135/22
138/5 148/11 177/4
letter [3] 91/19 125/8
133/18
letters [1] 17/1
level [36] 2/7 11/20
11/21 17/19 18/18
19/17 21/19 23/6
23/20 25/2 25/7 25/14!
31/18 34/3 37/18
41/11 50/5 51/12
52/20 59/25 60/20
72/12 74/9 74/11
74/13 81/12 86/1
86/17 110/12 113/1
129/12 130/18 133/24}
152/16 162/24 170/22)
levels [1] 78/19
levers [1] 94/23
Lewis [3] 88/14
89/16 89/19
liaison [1] 39/12
Lidbetter [1] 70/7
lie [1] 73/21
lies [4] 86/19 92/19
126/11 126/15
life [1] 49/9
light [18] 20/19 23/11
42/13 49/7 49/16
49/19 49/25 50/1 50/4)
51/16 53/17 53/22
54/11 55/9 56/10 57/8}
57/11 104/1
lights [4] 23/15 23/22
46/22 50/18
Lights/Dashboard [1]
46/22
like [40] 2/1 2/3 2/11
2/23 7/18 23/13 23/20I
28/3 33/1 41/7 43/8
43/14 48/23 50/10
62/22 65/1 72/14
74/12 74/15 83/17
91/21 94/15 100/17
103/20 104/15 107/20}
109/15 112/6 112/13
119/1 135/1 140/13
141/23 143/13 150/25]
151/22 154/8 154/9
155/21 180/10
liked [1] 99/24
likelihood [1] 140/22

(62) it's... - likelinood
L

likely [3] 11/16 112/3
112/5
limited [108] 6/14
7/19 7/21 10/4 10/22
11/13 12/14 12/17
12/24 13/11 19/9
21/25 26/5 28/11
28/19 28/21 28/24
29/3 29/10 30/5 30/6
30/8 30/12 30/18
31/20 32/4 32/10
32/11 32/20 34/10
38/20 39/4 42/12
42/16 43/15 43/18
44/2 44/6 44/11 44/23)
45/3 45/5 46/19 46/23
49/1 49/24 50/2 53/15
57/4 57/14 57/20
60/17 63/16 65/3 65/5)
68/11 68/23 69/18
70/2 70/11 70/19
70/23 73/5 74/15
74/20 74/24 75/17
75/18 75/20 75/21
75/23 76/2 76/8 76/17)
77/10 77/16 78/6
78/11 78/12 78/16
78/18 79/22 79/25
80/15 83/8 85/10
88/15 88/23 89/1 89/9
89/23 95/2 95/22 97/6
97/14 98/7 100/4
141/16 142/13 144/4
148/23 150/10 150/24}
157/18 165/19 169/24}
170/18 179/20
Limited's [8] 28/17
28/22 32/22 44/17
54/6 77/22 88/23 89/6
line [8] 32/14 44/20
44/24 45/9 83/9
123/12 157/10 162/25)
lines [4] 12/2 34/5
45/12 96/20
list [3] 67/14 88/11
95/16
listed [3] 75/11
124/17 140/9
listening [2] 47/24
174/13
litigation [22] 107/22
114/23 115/2 115/8
115/13 146/10 146/14}
163/20 165/19 167/6
167/16 168/4 168/9
169/11 169/19 170/21
171/5 172/19 180/15
180/18 180/21 180/24
little [7] 28/15 67/17
84/12 89/18 91/25
112/16 112/17
local [2] 76/25 77/3

location [1] 67/7
logical [1] 91/11
London [1] 3/11
long [9] 37/13 37/15
51/2 53/12 69/15
96/19 107/18 141/6
148/9
long-term [3] 53/12
96/19 141/6
longer [4] 40/24 82/7
86/9 138/2
look [47] 33/9 65/3
82/15 87/23 88/17
89/7 96/1 109/13
112/10 112/13 112/15)
120/22 125/6 126/12
129/17 133/16 135/22)
138/16 139/25 143/15)
143/18 148/11 148/11
148/14 148/18 151/10)
153/8 153/21 154/23
155/17 156/16 161/13)
161/20 162/14 163/6
163/6 165/6 165/15
167/12 168/11 169/16)
171/25 172/8 173/22
174/9 177/4 178/15
looked [9] 13/8 23/13
85/16 109/17 147/23
153/18 162/4 166/8
180/8
looking [20] 12/1
32/6 59/4 66/4 67/14
67/15 101/23 104/11
135/15 137/24 140/14)
147/11 152/12 159/14)
161/4 162/1 166/14
175/1 178/9 179/3
looks [1] 65/1
losing [1] 93/23
loss [2] 98/11 169/15
lost [1] 59/1
lot [9] 50/7 82/12
95/7 95/25 96/6
128/13 138/19 174/12)
176/9
lots [3] 65/25 97/21
147/24
Lovegrove [3] 6/6
44/22 44/24
low [1] 68/18
luck [1] 103/19
lucky [1] 105/3
lunch [4] 101/20
106/1 108/7 117/18

MacGregor [2] 63/5
70/5

made [35] 2/13 18/24
19/10 32/2 33/15
42/23 42/24 42/25
77/11 81/2 85/5 85/9
86/13 86/21 90/13

99/2 112/7 113/2
117/5 117/17 118/14
118/16 118/16 127/22
134/20 137/18 137/20
137/22 138/1 138/8
149/2 166/2 172/17
178/10 183/9
Magnox [1] 173/25
Mail [44] 4/7 6/11
6/15 18/9 30/7 35/1
35/4 35/9 35/15 41/5
41/11 43/15 43/19
44/6 44/10 46/18
75/20 75/22 76/2 76/3
76/6 76/13 76/17 77/1
77/5 77/16 77/23
77/25 78/2 79/22 80/1
80/4 80/12 80/15
80/16 82/21 83/8
83/15 86/25 88/3 88/5
88/10 90/18 104/14
main [7] 6/7 15/12
40/12 42/22 56/8
87/19 125/21
mainly [2] 17/25
127/17
maintain [3] 12/5
40/6 66/14
maintained [1] 41/23
mai ining [1]
157/23
Majesty's [5] 27/1
141/8 177/10 177/15
177/19
major [5] 46/20 47/8
70/1 96/18 171/11
make [19] 2/1 2/11
22/6 26/17 26/18 40/4
43/13 45/9 60/18 92/1
99/20 100/2 105/19
131/14 157/10 179/16
181/4 182/8 182/12
making [9] 28/6
79/18 99/4 105/17
121/8 136/8 148/22
173/6 182/11
manage [6] 8/25
113/4 113/14 142/13
167/19 168/4
manageable [1] 53/5
managed [11] 8/6
14/4 44/20 44/24 45/9
129/2 130/9 141/3
141/20 141/20 169/2
management [19]
3/3 4/4 8/24 18/5
18/11 21/25 48/24
49/2 49/6 50/23 54/7
61/17 62/20 63/18
73/9 79/6 98/12 134/7
155/2
managing [5] 8/7
113/7 113/12 126/5
183/4

manifesto [1] 58/2
manner [2] 18/24
19/4
manoeuvring [1]
121/14
Manson [3] 44/4
57/15 163/24
many [9] 66/5 97/5
107/24 141/17 154/18
162/2 162/17 180/8
180/16
March [15] 34/13
44/14 44/19 44/22
45/2 57/25 119/22
120/5 128/6 128/22
138/18 139/9 145/16
152/18 171/19
mark [8] 1/6 1/10
87/6 88/17 89/5 90/11
129/18 185/2
mark-up [2] 88/17
89/5
marked [3] 59/14
149/15 170/12
Marks [1] 124/19
Martin [7] 70/6 87/5
87/6 87/9 87/11 90/3
183/11
Martin Donnelly [1]
183/11
Mason [1] 70/5
massively [1] 23/19
material [4] 75/10
94/21 94/22 150/16
materialising [1]
172/23
mathematical [1]
161/6
matrix [3] 67/11
141/16 166/19
matter [22] 46/18
52/24 80/3 83/7
104/15 105/9 105/15
110/21 111/18 111/20}
111/23 115/9 132/6
133/8 157/19 161/11
163/16 164/22 166/4
166/7 166/16 167/10
matters [23] 2/25
6/14 6/15 10/21 11/13}
12/5 12/12 12/21
44/25 46/16 73/5
75/22 80/11 82/20
103/11 133/12 133/13}
137/5 137/19 139/23
155/4 156/9 161/4
may [30] 5/10 11/19
13/21 24/22 37/15
41/19 42/17 44/8
47/13 52/21 72/1
76/10 84/12 92/15
93/20 100/8 100/24
100/24 110/19 110/24}
111/14 112/20 119/9

131/12 143/16 145/3
163/12 163/17 182/9
182/14
maybe [3] 40/7 65/10
104/25
MBA [1] 3/3
Mcinnes [10] 70/7
89/14 89/16 89/20
90/2 90/7 109/23
110/1 111/6 163/25
me [46] 2/3 19/20
23/10 35/3 38/6 50/10
54/22 60/8 76/10
85/23 89/7 91/4 94/14)
104/8 107/7 109/6
137/22 137/24 138/12
138/20 138/22 147/25)
150/6 152/9 153/8
159/24 161/8 162/9
162/13 162/17 164/8
166/4 166/14 166/16
167/24 170/12 171/24)
172/24 173/5 173/20
175/3 175/4 176/22
179/5 179/21 182/15
mean [62] 4/22 9/23
18/16 19/3 27/7 35/2
35/5 37/20 39/25 42/5I
42/23 47/16 48/6 52/6)
58/14 59/6 60/20
60/21 68/18 79/3
85/15 98/16 99/18
101/7 103/21 105/2
107/18 113/20 115/7
1418/1 118/3 119/10
128/14 134/13 138/2
138/15 138/22 138/25]
139/14 141/16 143/10}
144/8 147/23 152/11
152/22 155/13 156/14)
158/22 158/25 159/6
159/24 162/7 162/14
163/21 167/8 167/23
169/6 175/1 176/5
179/5 179/8 182/20
means [6] 35/5 48/7
60/18 60/22 137/21
173/22
meant [7] 60/12 92/3
151/4 159/15 162/9
162/13 164/23
measure [2] 13/4
140/18
measures [1] 50/7
mechanism [12] 17/6
23/1 23/5 23/11 32/15}
49/8 56/19 65/19
65/20 82/23 82/23
103/8
mechanisms [7]
14/20 82/18 83/1
103/7 103/23 104/10
120/24
mediation [16]

(63) likely - mediation
110/15 113/5 114/1
114/6 114/8 114/10

114/21 115/23 137/9

157/20

Medium [1] 148/21
meet [3] 22/10 32/22
153/23

meeting [63] 25/11

87/12 87/15 90/24
91/7 109/20 122/14
122/22 122/24 123/4

127/2 135/4 135/25
137/2 137/2 137/3

149/19 150/8 150/9

154/22 155/8 155/14
155/25 156/2 156/3
156/3 156/5 156/8
162/12 163/8 164/2

169/17 169/20 169/25
170/1 170/7 171/9
171/9 171/17 175/21
176/21 181/12 181/20)
meetings [12] 32/13
75/21 75/24 101/1
104/25 129/11 131/4
131/6 131/7 131/13
153/21 163/7

meets [1] 139/13
member [9] 21/16
35/8 35/16 83/16
125/11 139/7 139/21
176/8 176/10
members [15] 24/23
32/14 45/22 47/6 47/8
47/22 55/13 68/23
72/16 105/21 117/7
122/23 151/11 154/10)
179/14
memorandum [1]
134/25

memory [6] 81/23
91/10 93/12 113/25
115/12 169/22
mention [2] 54/10
163/12

mentioned [4]

138/13 156/21 165/24}
166/17

merely [1] 155/7
merit [1] 59/7

met [3] 20/5 154/19
178/24

metadata [1] 163/9

mediation... [16]

114/11 114/16 114/18)

151/23 152/15 157/14}

55/24 69/24 70/4 70/9
70/25 71/12 81/1 87/6

123/20 123/21 124/24}

139/25 142/25 143/16}

150/11 154/10 154/10)

167/12 167/14 168/20)

metrics [1] 49/15
MG [1] 5/9
micromanagement
[2] 11/15 13/10
mid [1] 118/5
mid-2019 [1] 118/5
middle [5] 57/4 65/4
87/4 88/16 158/6
might [25] 5/4 7/23
8/1 9/15 18/8 28/1
33/6 33/6 36/3 42/7

83/20 87/10 98/5
103/18 104/13 107/8
110/15 140/3 155/4
155/5 175/6

mildly [1] 180/1
million [6] 28/2 28/3
28/4 173/9 174/6
174/23

mind [7] 15/23 24/24
100/19 134/12 146/6
152/10 174/18
minds [1] 160/12
minimise [4] 58/3
58/7 60/21 162/6
minimising [1] 123/8
minister [9] 11/10
32/12 32/17 32/23
32/25 75/12 163/16
182/10 182/15
ministerial [3] 12/13
20/20 103/2
ministers [59] 10/17
10/24 11/21 12/4
13/17 13/19 13/23
14/10 14/17 14/22
15/20 19/16 20/8 29/5)
29/8 31/4 31/7 31/14
33/5 33/10 33/12
33/16 35/11 37/17
38/11 38/11 39/10
39/25 40/3 40/4 40/9
43/6 57/23 60/13
82/25 95/3 96/9 97/24
99/3 99/19 100/11
100/14 100/21 100/25)
101/14 106/9 113/15
117/19 117/23 118/2
118/5 118/11 118/14
119/10 119/16 120/22)
120/23 120/25 130/14)
ministers’ [2] 113/7
113/13

Ministry [4] 7/7
minor [1] 1/25
minute [1] 65/10
minutes [9] 48/15
69/24 81/1 83/22
102/15 102/16 102/16)
165/25 171/14
miscarriage [1]
111/19

misguided [2] 61/1

42/24 48/11 51/9 63/2

111/12

miss [1] 103/18
missed [7] 103/21
104/6 106/18 106/18
106/21 107/4 110/23
missing [2] 69/14
160/21

mission [1] 56/25
misuse [2] 70/16
110/3

ants [4] 136/12
mitigating [5] 65/21
68/7 142/18 151/14
157/21

mitigation [5] 68/6
68/6 112/2 151/10
157/16

mixture [2] 15/3
138/14

model [20] 7/23 9/6

41/15 41/15 41/17
50/22 53/25 83/9
100/4 100/6 103/1
116/16 129/21 130/3
182/6 182/6
moment [5] 11/9
48/11 83/21 112/4
174/1

moments [2] 95/15
95/19

money [1] 108/18
monitor [1] 125/24
monitoring [5] 24/14
49/5 49/7 178/24
179/4

monitors [1] 130/5
month [2] 135/10
140/16

monthly [2] 160/17
160/18

months [5] 54/15
85/6 85/7 134/14
156/8

more [53] 5/6 11/25
12/7 18/14 31/8 33/24]
47/17 49/12 50/15
51/11 51/14 51/24
52/12 53/10 53/16
53/17 58/16 62/22
63/3 67/8 75/1 78/9
79/18 82/12 94/4 94/7
95/4 95/10 95/16
95/21 98/3 98/14
104/23 106/6 107/1
109/5 124/15 127/18
128/12 131/1 142/21
143/9 144/15 153/25
156/16 160/13 161/10
162/2 162/17 165/4
172/24 173/22 180/11
morning [11] 1/3
2/21 48/11 83/21 87/9
103/1 104/21 121/10

9/16 10/20 13/22 31/5

most [14] 12/18

61/22 66/11 66/12
76/1 128/18 162/19

mostly [1] 173/11
move [1] 153/18
moved [1] 4/18
Moving [1] 136/25
MPs [1] 157/22

Mr [45] 1/5 1/9 2/17
2/18 10/6 28/14 32/6
34/4 43/23 46/1 48/23)
61/8 61/11 84/5 90/23
101/18 102/14 102/15)
102/15 102/16 102/21
109/10 109/23 111/6
116/3 116/7 116/8
116/9 121/5 121/8
121/15 121/22 121/24}
123/15 130/12 133/18}
146/9 146/18 150/19
152/3 183/18 183/24
185/6 185/10 185/15
Mr Chapman [4]
102/15 102/16 116/7
121/5

Mr Cooper [1]
183/24

Mr Jacobs [2] 102/14!
102/15
Mr McInnes [1] 111/6)
Mr Russell [15] 1/5
1/9 2/18 48/23 61/8
61/11 84/5 101/18
109/10 116/3 116/9
121/8 130/12 133/18
152/3

Mr Russell's [9] 2/17
10/6 28/14 32/6 34/4
43/23 46/1 90/23
150/19

MR STEVENS [3]
121/24 146/18 185/15}
Mr Swannell [5]
121/15 121/22 123/15}
146/9 183/18

Mr Tim [1] 109/23
MS [16] 1/7 91/7
102/3 102/14 102/15
105/25 108/6 109/8
109/9 109/18 116/6
116/14 121/6 121/14
185/4 185/8

Ms Page [4] 102/14
102/15 109/8 116/6
Ms Perkins [1] 91/7
MS PRICE [9] 1/7
102/3 105/25 108/6
109/18 116/14 121/6
121/14 185/4

much [26] 1/4 6/7
9/10 26/11 34/9 35/5

130/12 150/19 183/23)

15/12 24/20 35/3 40/5}

177/18 178/17 179/13)

38/2 38/19 48/22 50/6
53/16 61/6 70/9 73/20}
80/13 98/5 99/24
102/5 106/20 115/9
121/3 121/21 141/16
145/22 168/8 183/17
multiple [4] 47/11
Munby [1] 183/12
must [7] 14/18 59/11
60/23 88/20 140/15
168/19 175/17
mutual [1] 54/9
mutualisation [1]
141/8

my [87] 1/11 5/1 5/9
6/7 6/7 12/10 14/8
19/21 22/6 24/4 27/8
27/25 29/22 36/24
39/21 60/4 65/17
77/25 78/1 84/20
87/19 92/21 93/12
93/13 93/17 94/2
94/19 94/20 94/25
95/1 96/22 100/19
101/18 104/24 108/4
109/4 113/25 115/12
116/3 118/3 119/11
121/3 123/20 124/24
126/23 126/23 131/4
133/5 134/14 134/15
134/24 138/15 143/5
143/8 144/3 148/16
149/2 155/25 156/6
156/20 158/15 159/7
160/3 160/6 160/23
161/24 162/16 162/22)
164/10 167/22 167/23)
169/22 170/2 171/6
171/13 171/16 173/1
173/19 174/9 174/12
174/18 176/20 178/8
179/8 179/13 179/22
180/24

myself [5] 121/16
152/9 160/11 161/5
179/7

N

nail [1] 35/10

name [4] 1/8 1/11
91/24 121/25

named [1] 84/8
names [1] 65/6
narrative [4] 95/22
140/24 144/20 149/10)
National [1] 174/19
natural [1] 153/13
nature [2] 6/6 126/24
NDA [1] 147/7
nearly [2] 94/22
124/14

necessarily [9] 4/10
13/20 19/16 26/13
52/11 58/15 59/11

(64)

mediation... - necessarily
N

necessarily... [2]
98/18 158/16
necessary [9] 11/16
37/22 59/3 77/2 98/10
100/12 107/9 107/10
117/15
NED [4] 44/16 78/21
79/12 80/23
NEDs [2] 32/8 54/6
need [35] 9/9 9/13
9/19 13/25 14/2 14/3
14/13 14/19 22/15
38/2 46/17 59/4 66/1
74/17 76/22 87/7
87/12 87/22 89/2 91/4
100/23 101/20 105/1
105/2 117/1 119/25
120/20 120/23 122/9
142/10 144/12 155/23}
163/17 178/10 182/21
needed [4] 62/2
117/24 135/8 147/13
needs [4] 26/12 69/5
100/21 151/20
negative [1] 170/23
negotiations [1]
35/22
neither [3] 11/9 97/3
161/19
nervous [1] 37/7
Net [1] 7/16
network [6] 8/4 57/24)
76/24 141/7 142/9
142/10
never [11] 14/14
27/11 35/13 86/3
93/16 154/13 154/19
156/5 173/11 175/11
175/13
Neville [1] 99/21
Neville-Rolfe [1]
99/21
new [19] 27/16 27/19
54/4 54/6 64/9 78/11
78/18 79/10 79/10
100/9 119/8 119/22
120/4 120/13 143/14
144/14 144/15 145/4
168/6
newest [1] 181/20
next [12] 10/15 30/3
43/14 50/2 68/21 77/9
84/20 94/7 101/25
118/3 121/15 162/22
nine [1] 134/14
no [94] 26/24 27/5
27/19 34/1 35/8 37/19)
45/11 45/11 47/16
52/25 53/2 53/4 54/10
54/16 54/18 57/17
59/19 60/11 60/11
61/13 69/4 69/13 73/2

73/6 77/19 78/22
79/14 79/24 80/10
80/15 81/14 82/7
82/11 82/17 84/24
86/6 86/9 88/7 88/24
90/16 92/9 98/24
98/24 104/14 111/16
111/20 113/20 114/19)
1415/1 117/1 117/19
119/10 121/7 132/25
133/7 133/9 141/12
141/16 142/17 143/4
144/18 148/20 149/22)
150/17 150/25 151/5
151/17 154/13 156/22)
157/24 159/21 160/11
160/16 162/25 163/22)
164/4 164/18 167/22
168/19 169/3 169/6
169/19 171/2 171/6
175/13 175/23 176/17)
179/9 181/10 181/17
181/19 183/2 183/16
183/16

nobody [3] 111/13
152/24 180/5

nod [1] 102/4
nodded [5] 15/22
17/24 18/6 19/2 21/1
noise [3] 113/13
174/15 175/1

non [25] 7/14 9/14
12/16 12/25 18/25
20/7 20/8 30/12 30/17)
30/24 34/12 44/12
78/18 78/25 82/17
88/19 103/25 105/6
124/16 124/22 125/11
131/7 136/2 154/6
181/21

Non-Exec [1] 131/7
non-Executive [12]
7/14 9/14 30/17 34/12
44/12 78/18 78/25
82/17 88/19 103/25
105/6 154/6
non-executives [3]
20/7 20/8 181/21
non-financial [2]
12/16 12/25
non-senior [1] 18/25
none [1] 170/15

nor [9] 11/9 11/10
11/10 96/23 97/4
133/10 161/19 162/25)
163/1

normal [1] 171/15
normally [4] 18/3
141/22 148/10 149/9
not [176] 2/20 4/10
6/4 8/12 8/18 10/11
11/7 12/8 13/3 13/4
14/6 14/9 16/16 18/19)
19/21 20/12 20/12

20/13 23/19 24/18
24/22 26/12 26/24
26/24 28/5 28/7 30/5
31/2 31/6 31/24 32/9
33/11 33/23 34/6
34/15 37/11 37/15
37/22 38/22 38/24
43/7 43/9 50/15 51/5
52/11 55/2 58/18
58/19 59/5 59/14
63/25 66/9 67/4 68/11
68/12 69/6 71/13
71/24 72/11 72/11
73/6 73/6 74/20 75/9
77/21 78/20 78/23
79/2 79/14 80/22 83/5
83/5 83/14 83/16 85/1
86/10 86/19 86/25
88/8 88/11 89/11
89/22 89/23 92/4
92/11 93/20 94/21
94/21 95/7 96/3 96/4
96/12 96/12 96/22
97/10 98/8 98/14 99/6
99/8 100/5 101/3
101/4 101/6 103/2
104/7 104/8 105/2
105/13 106/22 106/24
107/9 110/24 111/3
113/23 113/24 114/15)
115/4 115/15 115/24
115/25 115/25 117/5
117/11 119/9 119/10
119/14 125/5 128/9
132/5 132/21 132/24
133/7 136/17 137/7
138/10 139/1 141/3
141/15 142/5 144/10
150/20 151/21 152/1
153/2 153/3 153/14
154/1 155/11 155/25
158/16 158/20 162/13}
163/5 164/13 165/1
165/25 166/6 166/18
167/5 167/5 167/8
167/18 168/2 169/8
169/10 169/14 173/12
173/22 174/14 174/24
177/3 179/24 180/5
180/7 180/16 182/14
note [12] 20/15 24/15
88/18 109/21 123/20
156/3 156/22 164/19
169/17 169/21 169/24
175/25
noted [1] 79/21
notes [1] 131/6
nothing [5] 49/12
119/17 146/16 149/12
173/9
notice [1] 165/2
notwithstanding [1]
11/18
November [11] 78/15)

122/22 122/25 123/2
123/6 123/18 123/19
125/8 137/1 148/3
148/12

now [68] 2/18 12/23
30/21 35/11 35/18
38/25 43/2 53/8 55/10)
58/21 59/5 60/6 61/7
61/11 61/14 71/9
75/15 75/16 78/7
81/19 82/13 85/13
85/20 86/5 88/25
88/25 91/3 93/20
94/22 95/4 99/4 99/12)
100/15 101/20 107/5
110/11 110/21 111/9
113/18 118/9 118/25
119/22 122/4 122/8
126/3 131/10 132/24
133/16 136/21 136/25)
146/17 148/18 150/2
150/8 153/18 159/4
159/5 159/11 162/14
163/7 163/17 163/19
163/22 170/19 173/1
180/7 180/23 182/1
nuclear [8] 12/13
103/4 106/13 118/22
119/15 120/10 120/16)
171/10

number [21] 4/5 8/22
11/23 13/15 39/1
39/11 48/3 51/21 85/9)
89/25 95/12 96/24
102/23 113/20 122/5
138/13 142/9 161/7
163/15 164/7 182/8
number 1 [1] 39/11
numbers [2] 27/25
28/7

nurtured [1] 135/8

Oo
O'Sullivan [3] 125/9
136/1 136/4
objective [11] 11/14
13/7 13/11 39/23
39/24 40/2 40/6 58/8
58/9 58/11 144/1
objectives [22] 20/20
20/21 31/13 32/16
39/10 39/19 39/19
51/15 53/13 59/10
141/7 142/10 143/22
144/9 177/11 177/12
177/22 178/18 178/20
178/23 179/1 179/4
objectives/priorities
[1] 178/20
objectivity [4] 16/6
obliquely [1] 130/24
observation [4]
43/13 92/1 111/4
180/25

observer [4] 101/1
101/4 101/17 129/8
obsessively [1]
174/2
obvious [5] 40/5
85/15 85/24 86/6
111/3
obviously [6] 137/23
158/22 162/14 165/9
167/10 176/16
occasion [1] 34/1
occasional [1] 22/11
occasionally [1] 17/1
occasioned [1]
154/13
occasions [2] 32/21
35/21
occupied [1] 44/18
occur [1] 67/13
occurring [2] 67/12
146/13
October [8] 44/3
122/21 122/22 123/5
123/11 123/13 150/7
161/16
odd [2] 53/18 54/17
Odgers [3] 39/20
43/25 78/9
off [4] 19/20 59/6
89/24 105/18
offences [1] 132/23
offered [1] 91/1
offering [2] 91/8
91/23
Office [218]
Office's [7] 112/23
116/11 116/20 142/22)
142/24 155/3 168/14
officer [14] 6/17 6/20
17/10 20/25 21/5 27/1
27/14 27/21 28/6
32/13 33/3 62/11
77/13 77/14
Officer's [1] 147/6
offices [5] 3/12 40/7
76/25 77/4 171/17
official [3] 30/11
30/23 33/25
officials [9] 15/24
19/11 32/19 43/9
82/24 100/21 118/11
155/8 179/1
often [6] 9/19 19/6
23/23 25/3 91/18
180/23
okay [8] 57/13 57/16
57/18 139/17 146/16
170/14 174/6 174/23
on [323]
once [6] 60/20 63/11
82/2 153/23 176/21
180/13
one [64] 9/5 9/7
12/12 19/20 22/9

(65) necessarily... - one
[e)

one... [59] 22/12 23/5
29/17 39/18 39/19
39/21 41/18 43/3
48/10 52/8 53/18
56/21 58/5 58/14 63/2
63/18 64/21 65/8 66/5
66/15 66/21 67/12
77/11 77/11 77/12
7712 77/12 82/12
88/19 92/23 94/3
108/4 108/12 110/11
110/14 111/18 111/22)
112/7 112/10 113/10
114/12 135/2 136/15
138/21 140/14 148/9
156/16 161/10 162/18}
162/25 165/8 166/12
166/20 168/19 170/9
174/17 180/12 180/19}
182/9
one's [1] 81/22
one-page [1] 65/8
ones [2] 72/18 72/20
ongoing [3] 77/13
131/19 170/21
online [2] 83/4
121/13
only [23] 19/5 23/21
27/2 66/12 77/25 78/2
80/14 82/23 83/1 89/9
91/16 105/8 112/2
115/18 134/14 143/3
154/15 156/2 159/1
168/19 171/12 171/17)
174/10
onto [1] 101/9
onwards [3] 128/23
152/19 171/22
open [3] 131/19
134/4 157/5
openness [1] 181/15
operate [5] 19/3
129/23 130/2 131/21
178/21
operated [2] 7/22
10/16
operating [3] 9/24
18/23 62/11
operation [4] 14/1
68/24 132/11 151/13
operational [17] 11/3
11/13 11/20 12/5
12/21 43/8 80/3 80/5
80/6 80/11 82/20 83/7
83/11 83/12 83/18
100/22 125/24
operationally [2]
14/9 14/10
operations [4] 13/18
14/4 27/3 130/18
opportunities [1]
167/16

opportunity [6]
106/18 106/19 106/21
107/4 155/11 181/16

opposition [1] 89/8

option [6] 93/2 93/10

118/22 119/15 120/10;

120/16
options [3] 8/25
113/16 118/20
or [132] 7/25 8/23
9/25 11/13 12/9 15/5
15/21 16/22 17/11
17112 17/17 17/19
19/20 21/21 23/11
25/8 26/10 27/16
28/21 32/19 32/19
32/20 34/22 34/22
35/20 37/1 37/17
37/17 43/7 43/15
46/16 47/3 47/14
50/17 51/4 54/11
54/25 58/6 58/8 59/4
61/24 62/22 63/11
63/23 67/25 70/25
72/25 73/14 79/17
79/25 82/2 82/14
82/23 83/4 90/17
91/18 92/4 92/15
94/12 94/12 96/9 96/9)
96/24 100/21 100/25
101/2 101/3 101/6
101/10 106/3 107/8
108/3 113/1 113/15
114/9 114/20 116/12
116/19 116/20 117/3
117/7 119/17 120/19
127/16 127/7 127/16
127/17 127/17 129/10)
132/5 132/21 136/17
137/23 137/25 139/3
139/18 140/9 144/23
147/12 149/18 149/18)
150/25 152/11 153/3
153/3 153/7 154/6
156/11 159/4 160/5
160/22 160/24 161/10)
164/2 164/13 165/1
165/20 165/24 168/20)
168/21 168/22 174/24)
175/6 175/15 176/10
178/12 179/19 180/5
182/18 182/21 183/5
183/11
oral [2] 48/3 84/25
order [3] 28/2 126/9
171/15
ordinary [1] 142/3
organisation [28] 7/8
8/25 28/10 33/8 45/23
49/14 52/16 59/8 61/2
79/11 79/15 79/19
96/16 100/17 104/17
105/17 106/12 106/23}
110/25 127/21 128/12)

135/7 135/15 154/18
174/13 176/7 181/9
181/20
organisations [15]
5/3 14/11 14/18 15/9
33/1 33/3 62/6 65/12
65/15 65/22 66/1
104/11 104/12 136/13
182/2
original [1] 91/19
other [50] 9/6 12/13
18/15 18/16 21/21
24/3 24/15 27/5 29/5
29/21 36/20 41/20
41/23 42/7 44/25 47/7
49/13 55/21 62/17
63/20 65/6 72/13
75/11 79/14 85/10
97/18 98/21 99/12
105/4 106/12 108/2
108/4 110/16 122/16
127/7 128/12 128/13
136/13 140/9 141/17
144/24 145/20 147/11
154/7 154/10 165/7
175/22 178/1 180/12
180/19
others [7] 65/5 94/13
94/14 97/15 117/8
131/2 156/25
otherwise [2] 62/7
116/13
ought [2] 106/3
133/13
our [39] 4/24 5/17
16/22 22/14 23/8 24/1
24/11 27/25 28/3
41/15 46/25 62/3 62/4
63/2 66/4 66/7 66/15
67/3 80/15 80/23
83/21 89/21 97/23
98/4 101/8 101/25
103/6 103/15 103/15
105/14 105/14 106/10
113/1 113/22 115/18
138/21 146/7 146/17
155/15
ourselves [1] 104/16
out [46] 5/14 5/16
7/25 11/2 16/3 20/15
20/21 27/8 31/23
35/15 37/10 38/19
42/18 59/7 61/15
62/21 68/15 75/1
76/14 89/6 91/3 94/16
101/8 112/24 115/10
115/11 117/2 124/9
128/1 132/10 132/20
133/20 135/13 143/12
144/20 147/13 148/5
155/4 156/6 162/5
166/18 166/25 174/12
178/7 178/13 178/20
outcome [2] 63/7

179/6
outcomes [1] 63/12
outside [3] 62/25
100/10 171/17
outsource [1] 8/21
over [33] 4/18 13/5
22/24 28/25 41/24
68/24 85/15 90/14
95/14 98/1 98/17
101/23 104/25 106/16}
109/25 114/16 115/4
126/2 129/25 135/10
143/5 145/6 147/23
149/15 151/12 154/21
164/9 168/22 169/5
172/11 174/14 176/16
179/11
overall [4] 49/4 72/3
126/12 141/1
overarching [5]
59/20 64/16 64/18
66/19 71/23
overdo [1] 37/25
overriding [1] 135/20
oversaw [1] 49/1
oversee [2] 43/7 83/5)
overseeing [7] 17/19
20/18 79/24 111/1
128/3 134/9 154/11
overseen [2] 17/11
127/14
oversight [23] 7/18
8/19 9/7 9/13 9/21
21/24 22/15 28/12
74/14 75/16 75/17
75/19 78/19 80/10
83/3 84/5 103/15
109/10 154/2 172/10
172/14 172/16 177/14}
overturned [3] 70/22
110/9 110/20
overview [10] 21/19
25/3 25/7 25/14 56/18
59/4 68/3 68/6 151/6
151/10
own [9] 15/19 62/1
74/5 98/4 100/2 101/8I
116/1 119/13 181/21
owned [11] 7/11 7/21
8/5 27/9 75/3 75/11
79/5 100/10 101/2
106/11 132/2
owners [2] 114/24
115/3
ownership [5] 27/11
27/14 76/18 76/22
115/20
owning [1] 39/7
owns [1] 100/20

Pp

pack [7] 72/7 122/13
143/16 144/14 147/2
147/6 170/6

packs [1] 56/14
page [98] 1/18 10/6
11/6 12/2 20/1 21/15
28/14 28/25 29/16
32/7 34/5 43/23 46/1
49/24 51/9 51/18
51/19 51/19 51/20
53/19 53/22 56/3
56/24 57/3 57/5 64/7
64/8 64/21 64/24 65/4I
65/8 66/17 70/12
71/21 73/25 76/19
76/20 87/2 87/17
88/13 89/25 90/1
90/23 91/25 94/18
95/14 98/1 102/14
102/15 109/8 109/9
109/19 116/6 122/10
123/17 123/22 125/12)
125/14 126/2 129/17
129/20 129/25 131/15)
133/19 143/18 144/12)
145/6 147/3 147/9
147/10 147/12 147/17)
147/19 147/20 148/11
148/14 149/14 149/15)
155/24 157/6 161/20
163/11 164/19 165/15)
166/5 166/12 169/5
170/8 170/8 170/11
170/16 170/19 172/8
177/6 178/15 179/11
179/11 185/8
page 1 [4] 51/9 87/17
89/25 90/1
page 10 [1] 11/6
page 100 [2] 166/5
166/12
page 101 [2] 1/18
165/15
page 17 [1] 20/1
page 2 [9] 51/18
51/20 56/24 70/12
87/2 109/19 129/17
157/6 172/8
page 20 [1] 21/15
page 21 [1] 43/23
page 23 [4] 143/18
147/9 147/10 147/20
page 24 [1] 46/1
page 27 [1] 56/3
page 29 [3] 64/7 64/8
71/21
page 3 [8] 51/19 57/3
76/19 88/13 125/12
133/19 161/20 163/11
page 32 [2] 73/25
155/24
page 34 [1] 122/10
page 38 [1] 123/17
page 39 [1] 144/12
page 4 [5] 51/19
125/14 147/3 148/14
149/14

(66) one... - page 4
P

page 42 [1] 34/5
page 5 [3] 10/6 12/2
49/24

page 50 [1] 170/38
page 55 [2] 170/8
170/16

page 56 [1] 90/23
page 58 [2] 53/19
53/22

page 6 [1] 32/7

page 61 [1] 170/19
page 65 [1] 178/15
page 66 [1] 179/11
page 67 [1] 123/22
page 9 [1] 28/14
page 92 [1] 94/18
pages [5] 51/2 51/21
53/19 54/17 148/10
pan [1] 15/11
pan-Whitehall [1]
15/11

Panorama [1] 95/18
paper [7] 76/14 77/15]
144/18 144/20 144/22)
170/13 171/3

papers [17] 24/16
25/21 34/7 34/17
35/18 36/14 36/21
37/4 37/13 37/14 38/3
38/6 38/15 143/12
145/23 165/13 170/10)
paragraph [91] 2/4
2/8 7/20 10/2 10/6
10/7 10/15 11/1 11/5
12/1 12/11 12/18 13/9)
15/15 17/9 19/24
21/14 25/6 25/25
26/25 28/14 28/15
29/1 30/3 30/16 30/25)
32/6 34/4 34/5 40/13
42/11 43/16 43/22
44/21 45/25 46/2 46/2)
46/3 46/3 46/5 46/6
46/11 48/2 48/25 51/3)
53/9 56/2 56/4 61/17
64/6 69/19 70/12
71/20 73/10 73/24
74/17 76/5 79/21 83/2
85/17 87/4 88/16
88/21 90/22 91/6 91/8
91/25 92/10 94/17
95/14 96/1 98/1 106/1
109/24 116/15 116/22)
117/1 122/10 122/11
123/7 123/18 133/21
136/3 144/13 155/17
155/24 167/17 169/4
172/8 178/16 179/12
paragraph 1.2 [1]
155/17

paragraph 101 [1]
144/13

paragraph 12 [2]
7/20 11/1
paragraph 124 [1]
69/19

paragraph 126 [1]
90/22

paragraph 127 [1]
91/6

paragraph 129 [1]
91/25

paragraph 13 [2]
10/2 10/6
paragraph 14 [3]
12/1 70/12 109/24
paragraph 15 [1]
30/25

paragraph 16 [1]
32/6

paragraph 167 [1]
178/16
paragraph 169 [1]
179/12
paragraph 17 [1]
40/13

paragraph 193 [2]
116/22 117/1
Paragraph 2.1 [1]
136/3

paragraph 2.4 [1]
172/8

paragraph 203 [1]
92/10

paragraph 208 [1]
94/17

paragraph 211 [2]
95/14 106/1
paragraph 215 [1]
98/1

paragraph 22 [1]
12/18

paragraph 23 [3]
28/14 28/15 116/15
paragraph 25 [2]
11/5 13/9
paragraph 26 [1]
29/1

paragraph 27 [1]
30/16

paragraph 33 [1]
15/15

paragraph 34 [1]
17/19

paragraph 4 [1]
133/21

paragraph 41 [1]
19/24

paragraph 48 [3]
21/14 25/6 25/25

paragraph 49 [1]
26/25

paragraph 51 [1]
43/16

paragraph 52 [1]
43/22

paragraph 54 [4]
44/21

paragraph 55 [2] 2/4
2/18

paragraph 59 [1]
46/3

paragraph 60 [5]
45/25 46/2 46/5 46/6
46/11
paragraph 65 [1]
48/25
paragraph 67 [2]
51/3 53/9
paragraph 68 [2]
56/2 56/4
paragraph 69 [4]
61/17 64/6 71/20
73/10
paragraph 71 [1]
73/24
paragraph 72 [1]
7417
paragraph 74 [1]
42/11

paragraph 77 [1]
76/5

paragraph 78 [1]
79/21

paragraph 8.2 [2]
85/17 96/1
paragraph 82 [1]
155/24
paragraph 87 [2]
122/10 122/11
paragraph 88 [1]
83/2

paragraph 92 [1]
34/4

paragraph 97 [1]
123/18

paragraphs [5] 73/8
78/6 94/16 96/15
17716

paragraphs 208 [1]
94/16

paragraphs 212 [1]
96/15

paragraphs 54 [1]
177/16

paragraphs 69 [1]
73/8

paragraphs 83 [1]
78/6

Parker [11] 95/19
106/4 114/6 114/13
131/5 138/20 163/7
163/8 167/13 167/14
169/17

Parliament [5] 14/17
39/13 75/13 142/11
157/23
Parliamentary [1]
41/7

part [35] 5/21 6/8

26/16 35/1 35/6 35/17
37/11 40/13 47/4 47/4
56/13 71/12 72/7
80/12 97/12 98/4
99/18 101/3 104/21
105/8 105/22 105/23
109/1 111/22 118/7
132/11 132/13 133/2
133/11 135/9 153/16
154/1 177/9 178/4
179/19

Participants [3]
101/19 102/24 183/16}
particular [34] 5/20
8/9 12/2 13/2 19/16
24/17 26/19 33/9 37/2
42/1 46/23 47/9 50/1
52/15 60/5 63/19 74/2,
74/10 79/12 79/16
89/23 101/11 105/15
116/18 117/1 118/22
127/10 127/16 135/7
147/13 156/22 169/15]
173/3 175/6
particularly [17]
23/23 32/25 33/14
37/24 39/12 59/11
88/8 96/4 100/17
103/6 105/12 112/24
127/15 127/18 140/16}
143/9 163/1

parties [1] 13/3
partly [2] 22/5 47/6
partner [2] 3/11
76/16

partners [1] 111/2
parts [1] 177/3
passed [1] 44/4
passionate [1]

181/11

passive [1] 66/10
past [2] 137/12
137/14

Patrick [3] 125/9
135/25 136/4

pattern [2] 25/22
47/20

Paula [3] 87/9 156/8
168/14

Pause [1] 121/19
Pausing [1] 141/19
pay [1] 108/19
paymaster [1]

108/15

peer [1] 52/10

peers [1] 52/17
pension [1] 78/1
penultimate [2]

25/25 76/20

people [33] 15/1
16/24 23/21 33/2 41/6}
41/16 43/3 50/11
52/12 65/12 65/16
65/24 66/7 67/11 79/7

93/14 95/12 95/25
104/16 105/12 105/14)
105/14 107/3 121/10
135/5 135/6 137/22
137/25 158/12 159/4
177/12 179/8 180/10
per [4] 13/5 58/1
158/8 182/19
perceived [1] 37/17
percentages [1] 68/6
perception [1] 68/10
perfectly [3] 41/2
41/3 149/19
performance [8] 49/6)
50/24 51/15 56/7
70/10 130/5 148/22
154/3

performing [2]
154/12 155/9
perhaps [7] 47/17
48/10 59/10 105/1
105/2 105/10 158/20
period [6] 138/17
143/5 143/8 164/9
173/4 174/14
periodically [1] 20/20)
Perkins [10] 37/8
87/3 87/16 87/17
90/13 90/25 91/7
91/12 93/9 154/22
permanent [19]
18/18 18/20 20/11
21/3 29/6 32/12 32/18)
32/23 32/25 33/4
40/22 40/24 84/13
129/5 129/7 129/8
162/20 162/23 183/10}
permitted [1] 31/21
persisted [2] 39/5
40/23

persistence [1]
95/16

persisting [1] 40/14
person [10] 15/21
23/2 57/13 57/13
62/18 111/4 111/18
111/22 155/15 173/6
personal [1] 18/3
personally [4] 36/19
80/17 92/7 94/10
perspective [1]
89/11

phone [1] 90/3
phrase [1] 52/14
pick [6] 103/20
104/15 105/3 105/7
109/3 174/14

picked [2] 83/19
165/23

picture [1] 24/23
piece [5] 24/20 52/1
167/2 180/15 180/24
pilot [1] 83/4

pin [1] 149/23

(67) page 42 - pin
Pp

pivotal [2] 145/25
176/8

place [18] 14/20
35/22 35/24 55/17
79/23 82/24 84/11
90/24 98/6 103/23
106/23 120/24 126/19
150/13 160/17 171/17)
178/5 180/21

placed [3] 134/23
135/1 135/2

places [2] 11/23 39/1
plain [1] 149/2

plan [3] 20/21 54/6
130/6

planned [1] 87/15
planning [1] 169/14
plans [2] 78/5 178/19
play [4] 71/12 150/6
150/11 177/9

please [140] 1/5 1/8
1/19 2/2 2/23 7/18
7/22 10/5 11/6 12/2
12/24 14/22 20/1
21/15 28/11 28/13
28/15 28/25 29/15
32/6 32/7 34/4 39/5
43/14 43/22 45/25
46/3 46/5 46/10 48/23)
49/7 49/11 49/22
49/24 51/18 51/19
51/20 53/15 53/19
53/22 56/3 56/22
56/24 57/3 61/20 64/7
64/24 66/24 67/15
68/3 68/8 69/1 69/23
70/11 71/21 73/25
74/2 74/15 76/9 76/12
76/19 83/22 84/5 87/1
87/2 87/8 87/16 88/12
88/13 88/18 89/5
89/18 89/20 90/1
90/22 94/15 94/17
95/14 97/8 109/16
109/19 109/24 112/10}
112/16 121/22 121/25)
122/10 123/17 125/7
125/14 126/2 129/17
129/18 129/20 129/25}
130/1 131/15 133/16
133/21 135/24 136/2
139/25 140/24 143/15}
143/18 145/6 145/7
146/19 147/3 147/17
148/14 149/13 149/14
149/15 149/24 150/6
150/18 151/2 154/14
156/16 157/6 157/9
161/13 161/20 163/6
163/11 165/12 165/15}
165/16 167/12 169/16)
170/4 170/6 170/7

170/9 170/19 172/8
177/5 178/15 179/11
plus [3] 128/13
128/13 162/2
pm [7] 83/25 84/2
102/9 102/11 146/22
146/24 184/2
point [67] 13/18
16/23 19/10 22/1
24/15 24/25 27/7 43/5
44/15 44/22 47/18
48/1 53/6 60/9 61/22
76/20 78/15 81/4 82/6)
82/10 85/21 88/18
93/23 94/6 98/17
101/7 101/8 104/9
105/8 108/4 112/7
119/14 119/18 125/23)
127/5 127/22 128/4
128/7 128/10 130/4
131/14 133/9 133/25
139/11 141/19 143/3
143/23 145/16 145/25)
147/2 152/24 162/23
164/11 164/25 165/17)
168/5 168/10 169/9
171/22 172/17 173/3
174/18 174/21 175/5
180/3 181/2 182/16
points [17] 32/9 57/7
58/24 72/14 72/21
89/4 89/22 99/13
105/3 109/2 126/8
130/17 131/1 140/9
154/25 161/21 168/21
POL [24] 36/13 58/3
86/21 89/4 92/25
92/25 98/11 109/14
116/19 118/23 119/1
128/8 142/12 145/14
145/17 145/19 148/17)
151/11 162/6 163/5
169/13 176/18 176/20)
177/25
POL's [4] 116/24
123/9 169/11 172/15
POL00381730 [1]
87/1
policy [30] 11/21
29/7 39/3 39/6 39/8
39/10 39/14 39/15
39/18 39/23 40/2 40/6
41/6 41/13 41/21
42/15 42/20 43/1
43/10 43/12 58/9
82/15 94/6 131/22
141/6 142/9 143/22
177/11 178/18 178/25)
political [1] 142/8
pool [1] 142/2
populate [1] 105/9
port [1] 94/3
portfolio [23] 22/18
24/11 46/15 49/2 49/5)

49/14 51/2 51/14 52/4
52/8 52/18 55/11
55/16 59/8 62/4 62/6
62/15 62/19 64/21
65/9 65/19 135/15
142/6
position [20] 7/15
14/14 14/15 23/8 31/2
44/23 45/3 74/19 89/7
97/16 113/16 115/15
115/17 122/17 130/25}
136/15 144/16 178/9
179/7 180/14
positioned [2]
141/15 166/18
positions [1] 44/18
positive [1] 91/13
possibility [2] 111/14
169/15
possible [3] 18/24
75/3 114/2
possibly [7] 22/25
52/21 73/6 95/11
107/21 117/7 154/16
post [234]
post-2019 [1] 135/19
post-conviction [2]
132/10 132/21
post-our [1] 80/23
post-separation [2]
79/8 84/6
post-the [1] 106/21
postmasters [1]
111/14
potential [10] 11/17
36/17 36/23 39/23
42/21 58/25 120/18
141/4 141/9 141/13
potentially [9] 5/4
8/21 22/14 42/2 42/4
70/22 110/8 131/24
170/22
power [5] 116/19
117/20 118/8 119/24
182/18
powers [4] 116/12
116/13 117/16 118/4
practical [3] 118/8
119/18 181/6
practically [2] 19/5
25/24
practice [9] 10/3 31/3}
31/7 31/10 39/15
52/24 75/4 82/2
125/20
pre [2] 23/9 75/18
pre-dated [1] 23/9
pre-separation [1]
75/18
precise [1] 182/14
precisely [6] 36/5
38/4 128/19 164/9
169/13 174/15
predecessor [3]

129/5 182/25 183/6
predominantly [3]
3/6 4/22 4/24
preparation [3] 133/4)
151/14 172/6
prepared [6] 5/8 5/12
91/15 91/16 119/14
172/1
preparing [2] 113/15
122/3
preponderance [1]
171/19
present [2] 55/1
63/19
presentation [1]
87/23
presented [5] 52/6
96/5 144/3 165/25
166/1
presenting [1] 70/6
preseparation [1]
78/5
president [1] 117/10
press [1] 88/23
pressures [1] 142/12
Preston [1] 87/3
presumably [1] 81/3
presume [2] 60/12
93/22
presumption [1] 81/5)
pretend [1] 50/14
pretty [13] 25/21
37/12 55/4 63/21 74/9)
79/15 85/16 86/3
105/3 119/3 119/6
145/22 176/21
prevent [3] 117/13
117/17 120/9
prevented [2] 34/9
38/19
previous [5] 76/25
77/5 135/10 159/2
173/8
PRICE [10] 1/7 1/11
102/3 105/25 108/6
109/18 116/14 121/6
121/14 185/4
primarily [2] 105/16
113/25
primary [8] 14/2 32/9
32/19 33/24 39/9 45/7,
46/24 55/15
prime [1] 134/18
principal [6] 8/1 27/2
29/7 33/3 103/12
108/14
principally [1] 93/17
principle [3] 131/18
131/21 132/6
principles [2] 74/16
132/3
prior [6] 25/20 61/22
80/17 81/11 82/18
175/15

priorities [8] 56/10
57/6 57/18 58/12
58/24 101/14 161/21
178/20
prioritisation [1]
40/21
priority [5] 42/1
58/13 78/24 127/6
171/23
prison [2] 111/15
111/19
private [21] 5/2 5/7
5/13 5/15 8/24 9/11
10/4 15/3 16/24 41/16)
62/20 65/12 65/25
76/15 76/16 80/18
81/8 81/15 114/22
115/3 154/17
privately [2] 7/11
82/3
privatisation [5] 18/9
76/3 78/4 88/10
104/14
privatise [1] 8/23
privilege [1] 162/20
proactively [1]
113/12
probability [11]
67/12 68/5 68/14
68/18 127/17 140/20
158/5 159/11 159/16
159/19 160/10
probably [29] 8/9
19/5 22/1 24/25 36/12)
36/16 38/1 38/3 39/13
39/17 40/11 40/23
47/8 52/9 52/22 52/22
58/13 60/14 77/17
84/25 85/7 120/11
120/11 120/17 146/7
164/12 171/1 171/12
180/9
probing [1] 95/16
problem [9] 85/19
93/21 94/11 96/17
100/5 113/24 138/10
142/1 173/11
problems [5] 46/20
80/5 80/6 80/10 83/11
proceeding [1] 82/7
proceedings [1]
163/17
process [24] 6/11
26/6 32/2 48/23 49/2
64/9 65/24 66/3 66/8
66/10 67/21 68/12
69/11 74/2 114/41
114/3 114/5 128/15
134/17 146/12 151/8
160/7 160/19 160/20
processed [1] 174/6
processes [8] 49/3
49/6 126/19 134/21
158/18 158/18 160/16

(68) pivotal - processes
Pp

178/10
processing [1]
174/23
procurement [1] 7/8
produced [6] 49/16
56/6 66/13 94/12
122/13 159/13
producing [1] 99/25
professional [5] 2/24
91/21 94/4 106/22
107/16
professionalise [1]
A4I3
profile [10] 18/11
23/6 23/13 119/3
136/13 141/1 145/8
145/9 172/13 172/15
profitability [2] 23/7
23/14
profitable [1] 148/23
profound [2] 85/19
98/22
Programme [2]
57/24 79/18
progress [3] 67/20
93/24 151/7
progressed [1]
127119
prohibit [1] 37/6
prohibited [2] 34/7
34/17
prohibition [2] 37/3
37/5
project [21] 49/5
63/11 67/16 70/13
71/1 72/6 72/7 91/9
92/3 92/7 95/17
104/13 109/23 110/12)
112/15 112/19 128/20
147/7 151/3 151/3
157/9
projects [7] 15/18
126/3 126/4 127/7
128/13 128/17 162/3
prominent [2] 76/1
144/15
prominently [1] 17/3
prompt [1] 50/16
prompted [2] 95/10
162/17
prompting [1] 104/16
promulgate [1]
104/19
properly [9] 14/5
58/18 58/19 90/4
90/14 113/23 114/15
179/14 181/3
proportionate [1]
172/12
proposed [3] 78/8
114/9 118/10

processes... [1]

propriety [1] 28/7
prosecute [1] 82/3
prosecuted [2]
163/14 164/6
prosecuted/sacked
[1] 163/14
prosecuting [2]
108/8 164/25
prosecution [6] 82/1
161/9 164/16 164/22
164/23 165/3
prosecutions [21]
63/23 79/25 80/18
81/2 81/9 81/11 81/16
81/21 82/4 82/6 82/14)
82/15 86/8 96/24 97/3
97/7 97/18 132/9
132/16 175/18 175/19)
prosecutor [2] 81/18
108/9
prospectus [8] 86/25
88/3 88/6 88/15 88/21
89/9 90/15 90/18
Protect [1] 58/1
protocol [1] 180/21
prototype [1] 9/18
proves [1] 110/19
provide [13] 8/19
9/12 21/17 21/18
32/13 42/4 53/10 69/2
72/16 126/20 133/23
151/15 157/1
provided [16] 14/21
25/2 25/7 57/4 59/16
59/25 62/25 71/24
84/15 84/19 84/21
84/22 97/14 133/20
150/20 163/9
provides [1] 167/2
providing [8] 1/13
4/14 33/18 39/9 39/12
51/14 86/9 125/18
provision [2] 120/7
120/8
provoke [1] 136/7
provoked [1] 173/7
public [16] 11/7
12/16 12/25 13/6 13/8
16/15 43/10 76/17
76/21 76/24 77/3
91/14 113/2 131/24
172/11 172/12
publicised [1] 91/20
publicity [3] 60/21
60/25 61/3
publicly [4] 67/21
75/10 75/11 151/8
published [6] 2/19
69/12 84/15 84/17
124/7 129/19
pull [1] 56/19
purely [1] 154/11
purpose [10] 4/1
52/9 55/23 62/14

64/11 123/14 125/16
135/2 161/22 177/13
purposes [4] 2/16
16/16 52/9 161/19
pursued [2] 132/9
132/15

pushback [1] 38/7
pushed [1] 168/24
pushing [4] 89/10
89/11 168/15 168/18
put [22] 60/19 67/4
83/12 91/14 95/4
105/6 105/14 105/14
139/12 152/9 160/11
160/22 161/4 165/4
167/7 167/23 176/2
179/7 179/25 180/21
181/18 182/20

puts [4] 164/20
putting [9] 31/1 52/3
55/8 67/7 101/8
101/11 106/22 181/9
182/17

Qu
QC [1] 113/7
qualifications [1]
2/24

qualified [2] 124/11
177/12

quality [2] 50/22
94/11

quantified [1] 159/15
quarterly [16] 49/16
49/20 49/24 51/1 51/6
51/7 51/7 51/11 51/13}
51/13 51/20 51/24
52/5 52/18 53/1 55/11
queries [3] 69/2
151/15 157/22

query [1] 71/2
question [28] 8/14
14/1 25/18 29/22 36/5
38/14 46/10 47/17
60/1 84/20 87/19
93/14 98/25 100/15
117/22 118/3 132/24
133/11 138/5 143/4
144/3 149/20 158/15
159/2 159/23 160/6
161/8 162/22
questioned [11] 1/7
95/21 102/21 109/9
116/8 121/24 185/4
185/6 185/8 185/10
185/15

questions [28] 1/11
61/8 101/18 101/19
101/25 102/14 102/22
105/25 108/6 109/5
109/19 116/9 121/4
121/10 124/6 132/14
136/7 137/4 142/21
142/23 142/24 147/4

155/4 162/17 162/23

quicker [1] 42/8
quickly [3] 37/12
124/10 176/12
quite [30] 9/11 13/1
17/4 17/5 18/10 19/9

28/9 39/22 39/22 52/1

120/25 121/1 137/24
140/14 145/3 159/19
160/24 176/11 179/5
180/1 180/9 180/24
quote [1] 123/8

R

RA [4] 1414/1

radar [2] 80/7 83/13
Rail [1] 8/5

raise [2] 38/22
142/21

raised [16] 71/1 71/2
88/18 90/12 92/24
108/17 151/23 152/17}
152/18 153/4 156/12
159/10 159/16 160/8
160/14 161/11
raises [1] 142/23
raising [3] 47/7 96/7
154/25

raisings [1] 4/24
ran [1] 5/16

range [2] 139/5
178/25

rare [3] 12/10 12/12
119/7

rarely [3] 26/19 50/6
101/10

rated [1] 161/7
rather [2] 32/18
101/24

rating [6] 72/5 72/5
147/14 158/4 158/7
17113

Ratings [1] 68/7
rationale [3] 11/4
30/22 61/19

ratios [1] 19/1

re [1] 87/5

reaching [1] 86/20
reaction [4] 116/23
116/24 173/7 174/4
read [16] 2/6 2/10
38/19 52/24 55/15
67/17 85/17 91/3
112/18 117/2 157/10
159/20 162/5 167/21
167/22 168/2

reader [1] 85/22
reading [3] 99/4
141/13 145/9
readout [1] 69/16
reads [2] 87/4 99/11

183/13 183/16 183/19)

22/9 24/10 26/16 28/8)

62/7 94/5 96/6 114/17,

real [5] 37/18 110/23
110/25 113/23 135/1
realisations [2] 4/23
4/25
realistic [1] 117/12
really [26] 4/21 9/9
26/24 33/5 47/25
60/18 65/22 78/2
80/13 99/8 101/4
101/8 101/9 104/8
104/12 107/18 109/14)
110/14 110/17 115/8
115/16 119/16 138/17)
142/5 161/19 175/7
reason [23] 8/1 8/8
9/5 9/6 9/23 13/1 23/4
40/12 40/14 55/6
77/19 91/19 94/10
98/24 99/18 104/19
105/5 105/8 128/22
139/4 156/19 181/13
181/17
reasonable [1]
172/12
reasonably [2]
105/13 106/3
reasons [7] 9/15 9/17
14/8 39/17 41/23 42/2)
114/12
reassurance [1] 92/2
recall [24] 37/22 38/7
63/15 63/17 63/18
63/20 73/4 76/1 84/23)
90/17 125/5 134/13
149/17 155/25 164/2
165/22 167/21 167/22)
169/25 170/24 174/19)
175/14 175/22 180/18}
receive [8] 13/25
28/20 31/23 38/3
55/17 56/13 116/18
174/7
received [5] 55/11
70/16 77/23 110/3
117/8
receiving [3] 38/2
38/5 99/10
recent [2] 54/8
168/15
recipient [1] 55/16
recipients [1] 55/25
recognise [1] 81/15
recognised [2]
126/20 152/4
recollect [1] 171/13
recollection [4]
81/13 91/7 169/23
170/2
recommendations
[3] 172/5 177/2
177/15
recommended [1]
76/15
recommending [1]

(69) processes... - recommending
R

98/9

Reconfirm [1] 57/22
reconsider [1]
163/18

record [2] 122/4
123/14

recorded [6] 22/6
50/2 57/19 67/19
136/4 136/14
recovery [1] 63/23
recruited [2] 4/16
79/7

recruits [1] 181/20
recusal [6] 116/25
117/4 117/9 118/10
118/15 174/1
recused [1] 37/1
red [5] 42/12 98/18
100/19 141/2 148/20
Red/Amber [2] 141/2
148/20

redacted [2] 65/6
140/7

redaction [1] 145/1
redactions [2] 140/7
143/19

reduced [2] 141/7
148/17

reducing [1] 58/23
refer [20] 11/1 21/20
25/6 39/1 40/13 53/8
72/18 72/24 74/18
76/5 122/11 123/7

169/21 172/1
reference [26] 2/16
20/16 29/12 54/16
67/16 69/9 76/9 76/11
81/2 85/21 87/21
88/20 91/8 122/5
122/12 122/19 122/20
125/13 126/3 133/20
149/3 149/10 162/15
171/2 172/2 175/13
referenced [3] 10/1
145/17 166/4
references [3] 85/2
145/23 162/12
referencing [2] 163/5
163/5

referred [9] 20/22
42/19 56/16 59/23
93/3 123/15 172/25
174/4 175/19
referring [17] 29/14
55/24 63/4 72/23
106/1 130/24 133/6
133/7 136/20 140/13
147/11 148/8 151/18

recommending... [1]

recruitment [1] 77/13]

140/12 144/11 148/16)
161/16 163/23 167/24)

159/8 161/2 168/12
170/10

refers [4] 116/15
158/1 165/18 167/16
reflect [1] 75/4
reflected [1] 117/3
reflection [1] 95/20
reflections [5] 42/9
94/15 155/20 159/14
181/5

reflects [2] 10/9
163/20

regard [2] 70/14
110/1

regarding [3] 15/16
137/12 139/17
regardless [1] 14/15
regards [1] 125/20
regime [3] 9/3 82/21
143/14
regimes [1] 10/4
register [70] 47/4
56/12 59/21 61/19
64/2 64/15 64/16
64/18 65/14 65/14
67/2 67/3 69/18 69/22
71/18 71/24 72/11
72/12 74/6 126/11
126/13 126/18 126/25)
127/3 127/15 127/24
128/9 134/8 135/12
135/13 136/4 136/16
136/22 140/10 140/12)
141/16 142/21 144/15)
146/3 147/4 147/7
147/9 150/4 150/10
150/20 150/23 157/2
157/4 157/5 157/7
159/3 160/2 160/19
164/17 165/5 166/7
166/9 166/13 166/18
166/24 167/7 170/9
170/17 170/25 171/5
171/15 174/25 175/2
175/4 175/5
registers [25] 24/4
24/8 47/21 48/8 48/9
59/19 60/3 64/1 65/15
65/22 65/23 66/18
72/1 74/3 104/1
112/11 113/22 126/20)
136/3 136/7 136/10
150/2 156/17 158/19
162/4
regret [3] 104/18
156/3 156/4
regrettably [1] 92/3
regular [7] 24/16
25/8 41/18 56/13 63/1
177/24 178/6
regularly [3] 46/21
126/10 177/22
reinforced [1] 93/22
reinforcing [1] 32/16

reintroducing [1]
61/18
relate [1] 59/15

174/24

relates [1] 87/19
relating [3] 32/4
75/22 76/2
relation [13] 26/5
58/7 64/3 70/1 91/1

132/10 137/9 168/9
179/9

relationship [12]
23/15 42/14 50/21
53/24 54/1 54/3 54/4
134/4 155/3 168/13
176/4 176/24
relationships [2]
23/7 95/1

relative [1] 62/5
relatively [6] 18/23

142/1

release [1] 88/23
relevance [2] 2/25
170/15

relevant [9] 18/1
29/10 31/23 45/13
46/22 56/11 136/11
158/3 177/18
reliance [1] 105/4
reliant [1] 94/13

153/3

relished [3] 96/13
96/13 111/10
reluctance [4] 35/16
35/18 35/19 36/7
reluctant [1] 36/3
rely [3] 173/1 173/5
174/22

relying [1] 147/5

100/3 121/13
remained [3] 22/8
22/8 44/13
remaining [1] 44/2
remains [2] 26/15
157/20

remember [43] 5/10
34/21 34/24 37/13
37/19 37/20 38/14
38/24 41/3 41/15 43/1
52/21 61/21 63/25
65/11 66/4 71/15
77/19 81/14 81/24
82/9 84/18 84/22 88/7
88/8 88/9 90/13 90/16
90/20 90/21 93/11
104/10 111/24 120/2
120/2 128/14 137/5
156/13 156/14 156/15}
163/2 164/9 165/25

related [3] 74/7 146/3I

91/5 91/9 93/2 125/25)

19/4 76/8 98/8 124/10

relied [3] 73/19 86/10

remain [4] 76/21 79/5

remit [2] 4/14 6/8
remotely [1] 175/10
removal [2] 12/9
120/19

remove [6] 28/21
100/23 116/19 118/2
119/20 121/16
remuneration [1] 9/3
repeat [2] 25/18
179/22

repeated [1] 97/13

rephrase [1] 150/15
replace [2] 32/9
92/15

replacing [1] 119/15
replied [1] 173/18
reply [1] 89/3
report [43] 18/21
25/3 25/8 25/10 25/11
25/16 25/19 47/14
52/20 56/17 59/24
69/12 74/21 84/9
84/15 84/16 84/21

88/22 91/12 91/20

109/1 135/5 135/5
137/6 145/18 151/18
152/14 153/12 158/9
163/4 172/5
reported [10] 20/7
20/9 20/9 20/10 21/17
44/21 44/23 45/2 63/6)
178/7

reporting [32] 21/13
24/7 24/14 26/2 26/3
26/4 26/7 26/13 26/22,
27/1 29/8 29/9 29/12
29/21 29/23 29/24
32/2 44/6 47/20 52/19
53/3 61/17 61/22 63/1
73/23 74/2 74/23
82/21 83/15 83/17
83/18 176/19
reports [17] 21/18
21/19 22/2 25/2 25/6
45/5 56/1 56/5 56/15
56/15 60/4 60/5 74/9
7AI9 86/9 92/23
145/13
representation [2]
30/4 177/18
representatives [1]
101/1

reputation [3] 112/23
158/4 162/7
reputational [11]

58/4 68/10 73/14
123/9 142/7 143/20
144/6 144/7 145/9
148/21 170/19
required [3] 56/9

repeatedly [1] 127/22)

85/5 85/8 85/18 85/25)

92/3 92/7 95/17 95/18
95/24 96/4 96/5 106/5I

74/21 130/23
requirement [1] 16/2
requires [2] 27/20
126/12
requiring [1] 130/7
resignations [1]
117/7
resisted [2] 35/5
35/10
resolve [1] 114/3
resolved [2] 38/8
38/9
resource [7] 8/18 9/2
9/18 15/11 22/9 22/10I
40/23
resourced [3] 10/11
TTIMN7 93/15
resources [1] 27/23
resourcing [6] 40/15
40/16 40/18 41/22
46/25 77/8
respect [11] 39/13
40/5 46/18 97/16
126/17 129/15 132/20)
134/7 142/22 163/13
183/7
respected [2] 119/12
119/14
respects [1] 107/24
Respond [1] 157/22
response [2] 71/2
116/24
responses [2] 69/2
151/15
responsibilities [2]
21/13 27/2
responsibility [23]
6/3 7/19 10/18 10/22
11/12 23/2 27/5 27/15)
27/21 29/3 43/15 44/1
44/3 44/5 44/16 45/12
47/5 113/4 126/11
126/15 126/16 130/13}
134/19
responsible [17]
13/24 14/17 28/6
28/24 29/13 33/12
37/3 43/18 45/13
45/17 45/22 115/20
154/12 158/17 177/23)
178/23 182/25
restricted [1] 100/18
rests [3] 10/23 113/4
130/14
result [6] 42/4 97/11
127/1 139/7 168/6
179/24
resume [4] 48/14
102/7 146/18 183/23
retain [1] 10/17
return [1] 42/16
revenue [4] 13/2 13/3)
27/25 79/17
reverse [1] 126/9

(70) recommending... - reverse
R

49/2 49/24 51/2 51/2

52/8 52/10 53/10
53/12 53/15 53/21
54/11 55/1 55/16
55/24 62/15 62/23

78/16 93/13 95/19
106/4 106/24 113/6

147/7 147/8 147/9
151/16 155/1 155/5
163/15 170/10
reviewed [3] 88/24
159/12 160/6
reviewing [1] 20/20
reviews [14] 2/5 2/6
49/5 49/20 51/13

52/19 53/1 55/11
55/12 74/3

revised [1] 88/21
revisions [1] 136/19
Richard [6] 44/7
44/18 70/6 150/1
156/24 163/24

3/17 6/11 6/18 6/19
6/24 7/4 8/17 10/24
12/19 14/24 16/9

17/14 21/8 23/8 27/6

40/4 44/25 45/12

63/8 64/1 70/2 70/3
71/23 73/13 73/15
73/19 75/2 75/9 76/3
77/21 78/13 78/14

92/8 93/7 96/11
101/22 102/20 111/11
112/4 113/20 114/17
115/13 116/18 118/9
118/24 121/13 126/25)
134/24 138/3 140/10
140/15 145/14 148/7
148/14 159/22 166/20)
170/18 172/5 182/14
183/24

right-hand [2] 73/19
140/15

rights [6] 15/19
19/14 28/20 100/18
116/18 120/15
rigorous [3] 16/11
177/24 178/6
rigorously [1] 177/21
rigour [1] 47/17

rise [1] 163/1

risk [224]

review [42] 46/21

51/7 51/11 51/12 52/1

63/13 64/9 69/3 76/15

114/13 126/10 137/14)

51/14 51/24 52/5 52/5)

right [79] 2/1 3/9 3/15]

27/7 30/5 30/19 34/13

45/20 48/16 49/8 50/3
52/22 59/5 61/6 62/14,

81/4 86/11 86/12 92/5

Risk' [2] 72/5 72/5
risked [1] 117/6

65/19 65/21 66/15
67/6 67/12 70/1 72/6
72/18 73/12 82/20

136/14 136/18 141/4
141/10 141/13 142/7

145/10 146/3 149/1
149/8 159/15 160/14
161/25 162/5 166/9
166/22 166/25 167/3
167/20 168/4 169/2
169/11 172/18

risky [1] 67/8

RM [2] 44/3 90/14
RM's [1] 89/9
ROBERT [3] 121/23
122/1 185/12
robust [2] 69/2
151/15

rogue [1] 106/11
role [42] 3/7 3/15

TIT 14/23 15/10 16/3

41/21 41/23 42/15
45/15 75/19 78/10
79/24 101/16 101/17
125/6 133/16 133/23
134/2 134/8 154/2
154/3 154/7 154/13
175/25 176/3 176/5
177/15 178/2

roles [4] 2/24 39/16
42/18 166/21

Rolfe [1] 99/21
rolling [1] 7/12
rollout [1] 83/4

Ron [4] 108/11

room [1] 183/15
roughly [2] 153/24
153/25

Rover [1] 5/9

Royal [44] 4/7 6/11
6/15 18/9 30/6 35/1
35/4 35/9 35/15 41/5
41/11 43/15 43/19
44/6 44/9 46/18 75/20
75/22 76/1 76/3 76/6
76/13 76/17 77/1 77/5)
77/15 77/23 77/25
78/2 79/22 79/25 80/4
80/12 80/15 80/16
82/21 83/8 83/15
86/25 88/3 88/5 88/10)
90/18 104/14

RS [2] 136/9 136/23
ruinous [2] 114/23

risks [47] 32/4 65/18

112/25 120/18 125/24)
126/17 126/21 127/16)
129/10 134/21 136/11

142/14 142/19 144/21

3/24 4/8 5/25 6/2 6/10

27/16 27/17 39/3 39/3
39/6 39/8 40/17 41/13

115/2

running [1] 45/23
runs [1] 53/18

rural [1] 58/1
Russell [20] 1/5 1/6
1/9 1/10 2/18 48/23
61/8 61/11 84/5 87/6
101/18 109/10 116/3
116/9 121/8 129/18
130/12 133/18 152/3
185/2

Russell's [9] 2/17
10/6 28/14 32/6 34/4
43/23 46/1 90/23
150/19

s

164/7

safeguard [1] 11/14
safeguarding [1]
13/9

said [36] 4/25 30/1

38/16 58/15 69/23
78/17 101/7 103/21
106/5 106/8 108/6

108/21 117/17 133/4

139/16 147/9 149/19
153/22 156/19 160/3
160/5 160/23 163/3
166/2 171/6 174/5
sale [2] 6/11 78/1
same [14] 16/14
16/17 19/12 19/14
25/16 25/19 43/6
53/25 72/25 106/13
123/1 123/5 128/14
157/16

Sarah [1] 183/12
sat [2] 3/18 4/17
satisfaction [1] 14/3
satisfactory [1]
179/4

satisfied [5] 14/2
14/4 167/18 168/2
169/10

satisfy [3] 128/24
130/6 132/1
satisfying [1] 169/1
Save [1] 146/9
saved [1] 158/3
saw [10] 5/1 62/21
123/5 128/19 135/14
139/9 149/11 150/25
152/18 166/8

say [122] 4/24 5/23
8/15 9/7 10/8 10/15
11/6 11/18 12/3 14/5
14/8 17/9 17/16 17/25
18/3 18/15 18/24
19/21 20/3 21/15

sacked [2] 163/14

36/6 38/4 38/14 38/16

108/17 108/18 108/18}

136/22 136/24 137/15)

38/18 38/19 39/4

42/14 42/25 43/5
46/14 50/5 53/11
53/20 55/22 56/4
58/10 60/17 63/10
64/18 69/20 71/10

84/10 84/10 86/10
91/10 92/10 92/21

98/18 103/19 106/1
111/21 112/2 117/11

128/22 130/17 137/2

140/2 141/19 142/18
146/19 153/8 154/1
154/2 155/14 155/24
159/6 159/6 159/12
161/1 161/24 162/10

165/10 166/5 167/10
168/7 171/20 174/2
175/24 177/7 179/12
saying [20] 15/8
32/17 32/21 33/23
37/5 47/25 54/23
64/10 72/10 104/20
107/9 123/10 126/25
136/5 145/14 158/7
158/13 166/11 173/19
173/21

says [41] 2/4 2/8
58/11 87/17 89/3
89/15 109/25 110/18
112/18 112/21 113/3
113/18 123/18 125/15)
126/15 129/21 130/22}
131/7 131/16 133/22
140/25 141/2 141/9
142/7 148/18 150/1
150/5 151/2 151/6
155/17 156/25 157/11
158/1 163/11 164/21
167/14 167/17 169/6
170/20 172/9 178/16
scale [10] 96/16
97/18 104/10 111/17
111/18 111/22 112/5
140/17 143/24 159/25)
scene [1] 116/14
scepticism [2] 98/3
98/14

scheme [16] 88/9
113/1 113/5 114/6
114/9 114/10 114/11
114/16 114/18 114/21

23/18 24/4 25/7 25/25)
28/16 29/3 31/15 32/7,
34/5 34/8 34/15 36/16)
36/19 37/20 38/1 38/8

39/13 40/12 42/1 42/2

71/22 75/7 77/9 78/20)
78/23 82/11 83/4 84/6

94/2 94/18 95/11 96/1
96/13 96/21 97/9 98/2

119/18 119/19 120/12)

137/20 139/14 139/16}

162/14 164/10 164/18)

115/23 137/9 151/23
152/15 157/14 157/20)
scheme's [1] 157/23
science [3] 3/3 50/14
50/15
score [2] 67/11
159/11
scoring [1] 23/22
screen [24] 10/5 11/5
20/1 28/13 31/1 34/3
43/22 45/25 49/22
53/15 56/3 56/22
61/12 64/23 69/23
71/21 76/9 87/1 88/12)
90/22 117/2 122/10
123/23 140/4
screens [1] 66/6
scroll [8] 46/2 67/23
68/2 70/9 89/18
144/19 151/2 170/11
scrolling [3] 28/15
51/19 68/8
scrutinise [1] 10/12
scrutinised [1] 92/4
seat [3] 30/7 78/12
80/16
second [33] 10/7
31/17 50/21 54/13
54/24 55/5 55/6 69/10)
83/21 84/9 84/14
84/16 85/5 85/18 88/2
93/6 93/12 93/13
93/16 93/23 94/11
95/17 95/24 106/4
106/23 108/11 109/1
114/5 129/7 133/2
133/11 137/6 139/11
secondly [3] 9/20
22/24 166/13
secondment [1] 15/6
secretaries [6] 18/20
27/9 27/10 33/11
162/21 162/23
Secretary [31] 11/9
18/18 20/11 21/3
28/18 28/23 29/1 29/4
29/6 29/7 29/16 29/18)
30/10 32/13 32/18
32/23 32/25 33/4
36/10 37/6 40/22
40/25 116/17 118/12
118/14 118/19 119/24)
129/5 129/7 129/8
183/10
Secretary/Accountin
g [1] 32/13
section [8] 38/18
53/23 53/23 76/8
76/20 77/9 88/24 91/2I
sector [14] 5/2 5/7
5/13 5/15 8/24 9/11
10/5 15/4 16/24 41/16)
62/20 65/12 66/1
76/16

(71) review - sector
Ss

secured [1] 144/4
security [2] 7/16
12/12
see [99] 1/3 9/11
24/19 36/2 46/3 48/21
49/25 51/19 51/23
54/1 56/25 57/3 57/7
57/13 58/11 59/19
65/2 65/5 65/24 66/2
66/21 66/24 67/14
67/16 68/2 68/9 68/14
68/21 69/15 70/4
71/24 72/22 76/13
82/1 82/3 84/3 86/21
88/16 89/5 90/5 90/7
90/11 91/2 92/7 97/24
100/14 101/15 106/9
112/19 121/20 123/24
125/11 125/22 126/8
128/7 128/11 131/4
131/6 134/8 134/23
140/5 140/7 140/8
140/17 143/10 143/19}
146/25 147/6 147/18
147/20 149/25 151/6
152/22 153/6 153/13
153/14 154/11 154/25)
157/4 157/21 158/4
158/5 161/20 162/6
164/15 165/4 165/15
166/21 167/6 167/13
168/16 169/3 170/5
170/9 170/17 170/20
172/3 173/15 178/12
seeing [8] 60/2 60/2
60/3 60/3 65/25 66/5
87/10 95/13
seek [3] 12/6 31/23
131/18
seeks [2] 68/24
151/12
seem [3] 65/11 91/11
141/13
seems [2] 64/10
69/15
seen [20] 23/19 35/4
39/20 42/1 49/20 81/1
85/1 112/20 120/21
122/19 139/8 150/12
150/14 150/15 150/23)
157/8 157/18 160/21
172/18 178/11
Select [1] 156/9
selecting [1] 78/11
self [1] 148/24
self-sufficient [1]
148/24
sell [2] 76/25 77/5
Sellafield [2] 171/8
171/18
send [1] 87/11
senior [19] 7/2 7/4

17/18 18/25 18/25
19/15 23/2 32/14 33/2
45/22 49/13 52/11
52/11 52/12 77/11
79/6 103/10 129/4
154/16
sense [6] 19/22
33/24 60/18 96/8
154/20 176/18
sensible [1] 87/11
sensitive [1] 19/22
sent [6] 76/7 89/4
89/13 111/2 111/15
161/16
sentence [3] 25/25
167/17 179/12
separate [4] 40/10
42/18 72/24 146/11
separated [1] 30/6
separately [1] 39/16
separation [10] 44/9
52/3 75/18 75/20
77/23 79/8 80/17
81/11 82/18 84/6
September [12] 87/3
88/14 89/15 124/20
125/1 133/19 139/24
140/6 150/3 150/9
167/15 170/1
series [2] 24/25
173/24
serious [6] 111/23
117/6 133/12 159/10
161/9 164/22
servants [13] 13/19
15/24 16/15 16/16
19/12 35/7 41/16
41/18 41/19 43/6
43/11 129/4 129/11
Service [9] 15/5
15/25 16/3 16/21
17/18 18/25 18/25
35/16 77/11
services [5] 54/9
91/21 94/4 106/22
107/16
sessions [3] 52/8
52/10 138/21
set [27] 17/5 20/15
20/21 22/8 42/5 42/7
50/19 61/15 75/1
79/10 90/5 91/3 94/16
116/14 124/9 135/13
143/12 147/13 156/5
157/14 162/4 166/25
174/10 174/12 177/10)
178/7 178/20
sets [4] 76/14 133/20
144/20 155/4
setting [6] 4/22 20/19
89/6 158/18 178/23
179/4
settlement [1]
180/20

seven [1] 23/11
several [1] 124/17
severe [1] 12/8
severity [1] 158/25
shall [2] 48/13
146/17
sham [1] 113/19
shape [2] 127/1
127/2
shaping [1] 129/14
share [1] 37/23
shared [8] 35/18
36/15 36/21 37/19
37/20 37/21 38/15
117/23
shareholder [233]
Shareholder/Corpora
te [1] 21/21
shareholders [1]
9/12
shareholding [8]
26/10 44/3 95/3 126/4
129/1 176/3 183/4
183/8
shareholdings [5]
4/4 4/5 4/6 4/7 27/8
sharing [6] 14/23
34/7 34/17 37/3 37/18
48/7
shattering [1] 96/3
she [13] 44/12 44/13
44/21 44/22 45/3
62/21 62/21 62/22
62/23 63/4 155/21
156/11 156/14
sheet [3] 23/7 23/14
50/24
sheets [1] 72/17
ShEx [30] 89/20
117/23 118/11 122/13
122/20 126/10 126/13
127/2 127/7 127/14
127/18 127/20 129/19}
133/21 134/12 134/15]
135/23 139/7 139/19
139/21 140/6 140/9
141/17 142/5 142/12
145/15 151/11 175/15}
178/1 179/2
ShEx's [2] 151/22
152/15
ShEx/UKGI [3] 139/7
178/1 179/2
shocking [1] 138/24
shook [1] 137/17
short [8] 17/7 48/19
76/8 84/1 102/10
118/5 120/9 146/23
shortened [1] 131/11
shorthanded [1]
153/15
shortly [4] 21/24
117/18 124/7 144/25
shot [1] 133/22

should [90] 1/15 2/6
2/10 13/16 14/3 14/5
14/9 17/5 31/21 31/24}
33/16 42/1 47/19 50/5
53/20 60/8 65/16
67/13 71/2 73/21 75/3)
85/11 85/25 86/4
86/13 86/16 86/24
86/25 87/12 88/25
92/20 92/24 93/1 94/6
95/9 95/20 96/6 98/6
99/5 99/7 99/9 99/15
101/5 111/5 112/1
112/7 117/4 120/13
120/14 120/14 128/19}
131/10 131/18 131/21
132/1 132/7 132/22
134/12 136/7 137/18
137/20 137/22 137/23}
137/25 138/1 138/6
138/8 139/5 151/23
152/7 152/10 152/13
153/3 158/14 159/5
160/1 160/5 160/24
161/7 161/11 162/15
162/16 165/3 165/9
166/17 172/11 174/25]
176/22 178/22 182/10}
shouldn't [6] 13/17
14/10 43/4 50/14 80/6
181/18
show [6] 67/8 67/19
70/21 110/8 159/21
173/16
showed [3] 64/21
127/15 175/3
showing [3] 60/24
65/8 144/14
shown [6] 70/19
110/6 123/1 144/15
172/19 175/4
shows [1] 84/24
shy [1] 58/19
side [4] 22/22 42/21
115/14 159/22
sidelines [1] 115/24
sight [28] 23/25
32/15 54/13 54/24
55/5 55/6 69/10 80/13
80/13 84/9 84/14
84/16 85/5 85/18 88/2,
93/6 93/12 93/13
93/16 93/24 95/17
95/24 105/19 106/4
106/23 108/11 109/1
114/6
Sight's [2] 94/11
137/6
sighted [4] 47/9
sighting [1] 47/22
sign [1] 19/20
sign-off [1] 19/20
signalled [1] 98/11
signature [5] 1/21

1/23 122/8 123/24
124/1

significance [9]
54/20 54/25 58/25
85/14 95/12 96/17
97/1 97/2 107/7
significant [21] 35/21
37/11 37/25 46/16
47/3 71/7 71/10 71/10)
73/14 78/10 80/8
85/21 97/12 98/21
136/3 136/8 141/14
142/8 145/1 169/9
175/24
significantly [2] 6/4
141/4

signing [2] 89/24
122/15

similar [4] 10/4 15/19
25/22 136/13
similarly [41] 112/21
Simon [1] 86/7
simple [3] 28/8 71/8
159/23

simplistic [1] 60/20
simply [8] 11/7 32/20
53/5 94/2 95/4 139/3
153/12 182/18
simultaneously [1]
81/17

since [4] 30/10 30/15
122/15 136/21

single [1] 25/11

sir [25] 1/3 48/10
48/17 48/21 60/10
61/10 83/20 84/3
101/18 102/8 102/12
102/19 109/10 121/7
121/12 121/15 121/18)
121/20 123/14 146/6
146/19 183/13 183/16
183/22 183/25

Sir Wyn [1] 60/10

sit [1] 21/6

sitting [3] 34/12
35/24 103/25

situation [8] 5/10
35/12 39/4 40/14
40/23 42/5 42/19
82/13

situations [5] 5/2 5/6
35/25 103/9 127/7

six [8] 12/2 20/5 20/6
50/17 53/25 57/7
104/25 104/25

sixth [1] 50/24

skills [2] 79/19
179/19

skillset [2] 8/9
101/11

slightly [4] 47/17
108/25 127/9 153/18

small [5] 28/9 43/2
135/7 163/14 164/7

(72) secured - small
Ss

snapshot [2] 24/17
49/13
so [228]
socialise [8] 22/20
22/20 46/17 47/10
52/14 52/15 59/9
65/19
socialising [1] 48/3
software [1] 106/25
sold [2] 4/6 4/10
sole [1] 28/19
solely [1] 139/18
solution [3] 5/7 108/2!
120/12
some [57] 1/25 5/13
5/15 8/23 22/15 23/1
28/1 33/25 35/18
35/21 49/20 50/12
52/15 53/18 54/15
61/15 63/21 65/13
70/15 71/16 87/25
90/4 91/1 95/15 99/8
99/22 101/19 104/11
105/3 109/2 109/18
110/2 112/13 114/3
114/5 120/21 121/14
122/16 124/6 131/2
135/22 140/2 140/4
149/10 153/21 161/21
163/7 164/20 167/3
167/23 168/15 174/14}
174/18 174/21 177/1
17712 1771/4
somebody [3] 36/11
62/18 152/10
someone [2] 107/25
154/11
something [27] 28/3
33/7 40/20 51/4 55/1
59/3 59/4 62/22 63/2
66/3 66/9 74/12 79/20
81/20 82/9 86/13
86/16 103/20 104/15
107/20 111/4 113/19
114/9 114/17 132/6
134/18 173/4
sometimes [2]
110/14 153/25
somewhat [2] 47/25
111/12
soon [1] 85/4
sooner [2] 42/18
98/7
sophisticated [1]
49/12
sorry [31] 25/5 25/18
27/24 29/14 36/5 46/8
46/10 57/10 60/1
60/19 62/24 67/3
71/10 72/20 82/11
89/17 98/25 115/1
132/14 139/11 140/2

144/1 148/13 149/9
150/15 158/21 164/4
164/8 168/7 169/23
181/10
sort [31] 5/9 8/8 8/14
8/17 9/13 22/15 23/10)
28/8 35/25 36/9 41/10
93/14 96/3 101/12
103/19 106/17 108/7
114/3 114/5 114/22
115/2 120/7 120/8
133/5 133/6 134/16
140/25 152/18 153/15)
161/6 173/23
sorts [1] 5/5
sought [4] 22/10
70/23 110/10 110/24
sound [1] 181/10
sounds [1] 153/8
source [4] 14/2 32/3
45/4 45/7
space [1] 66/5
spades [1] 139/10
SpAds [1] 57/23
spans [1] 51/21
Sparrow [11] 67/16
70/13 71/1 109/23
110/12 112/16 112/19)
113/22 151/3 151/4
157/9
speak [1] 121/17
specialised [1] 10/13
specialist [7] 8/3
8/20 9/1 9/1 9/7 9/8
9/13
specialists [1] 9/9
specific [14] 2/22
11/14 20/22 28/11
46/15 74/14 75/16
87/7 95/15 95/23
118/4 126/3 126/4
168/15
specifically [7] 21/25
26/5 69/25 71/3 88/19)
116/24 126/24
speed [1] 94/12
Spencer [1] 124/19
spent [2] 124/14
174/12
spinning [1] 35/15
spiral [1] 112/24
spite [1] 98/3
split [3] 42/3 42/6
125/21
spot [2] 108/22 167/5
spreadsheet [2]
139/25 140/2
spreadsheets [1]
140/3
squares [1] 65/4
staff [5] 15/17 15/18
80/19 81/16 97/19
stage [9] 15/8 58/17
71/1 91/12 91/15

137/3 152/14 162/22
175/8
stages [1] 135/22
stakeholder [3] 18/5
18/10 39/12
stakeholders [2]
19/15 113/5
stance [2] 113/19
115/19
standards [5] 16/14
16/17 16/19 17/7
142/3
standing [1] 72/2
start [15] 2/23 22/4
23/9 24/6 25/23
105/18 109/16 124/8
134/14 135/4 135/24
146/7 170/8 172/17
173/21
started [6] 4/19 5/5
24/19 24/20 143/8
176/6
starting [6] 14/22
49/7 75/17 87/2 88/12
94/17
state [23] 11/9 27/9
27/10 28/18 28/23
29/2 29/4 29/7 29/17
30/10 33/11 36/10
37/6 49/14 92/18
116/17 118/12 118/14]
118/19 119/24 121/25)
141/23 177/9
State's [1] 29/18
stated [3] 4/3 124/3
180/6
statement [120] 1/14
1/15 1/19 2/1 2/4 2/8
2/9 2/14 2/17 2/18
2/21 3/2 5/1 7/20 10/6
11/1 11/24 12/1 12/18
13/9 15/9 15/15 17/9
17/16 19/24 20/1
21/14 24/4 27/8 28/14
31/1 31/11 32/7 34/4
38/18 39/1 40/13
42/10 42/11 43/17
43/23 46/1 48/4 48/25
51/4 53/9 56/2 56/25
61/17 64/6 64/7 69/19
71/20 73/8 73/24
74/17 75/19 76/5 77/9
78/7 79/21 83/2 84/10
90/23 92/10 94/17
95/8 106/2 116/15
116/22 121/9 122/3
122/4 122/6 122/15
123/23 123/23 124/3
124/7 124/9 126/23
127/23 129/19 130/17
133/5 140/13 144/11
144/13 148/16 149/3
153/22 155/23 156/6
156/20 159/7 159/13

160/3 160/23 161/24
162/16 163/23 164/10}
165/6 166/3 167/24
167/25 171/6 171/20
172/1 173/1 173/7
174/10 174/12 175/24}
177/3 177/6 178/8
178/16 182/5 183/19
stating [2] 69/3
151/16
status [5] 68/8 101/1
101/4 116/11 163/20
stay [1] 89/2
steady [1] 141/23
steeped [2] 105/12
105/13
step [11] 36/9 116/12
117/6 117/16 117/20
117/24 117/25 118/5
120/9 168/25 169/8
Stephen [3] 6/6
44/22 44/24
stepped [3] 7/1 117/4I
117/13
stepping [2] 118/1
118/3
steps [5] 61/15 132/1
160/13 164/15 181/6
STEVENS [3] 121/24
146/18 185/15
stewardship [1]
27123
still [12] 6/7 6/8 7/4
23/16 46/6 48/21
50/20 59/6 84/3 95/25
105/21 121/17
stock [1] 7/12
stop [3] 118/21
119/20 119/21
stopped [3] 60/16
98/8 119/19
Storey [7] 34/7 34/11
34/16 44/10 44/20
45/2 80/23
story [1] 76/22
straightforward [1]
119/9
strand [1] 47/5
strands [1] 46/20
strategic [10] 5/3
5/11 20/19 54/6 76/16)
79/15 125/24 130/6
133/24 178/19
strategy [6] 50/23
53/13 78/17 87/19
125/22 141/5
streamer [1] 77/12
streams [2] 25/8
52/20
strength [1] 89/8
strengthen [1] 78/17
stress [1] 15/15
strictures [1] 100/10
strong [7] 54/4 76/22

79/9 79/10 98/22 99/2
168/13
strongly [2] 119/10
119/12
structure [4] 9/22
26/15 104/22 116/2
struggling [2] 60/18
93/18
stuck [2] 138/17
174/17
studies [1] 180/8
stuff [1] 173/12
style [1] 145/4
subject [5] 88/15
105/9 105/15 108/14
172/14
subjective [1] 50/8
submissions [5]
15/21 85/2 99/3 99/5
100/1
submitted [1] 158/9
Subparagraph [1]
64/7
subpostmasters [19]
68/11 70/15 70/17
80/19 82/1 92/13
96/10 97/19 99/14
102/23 107/2 110/2
110/4 110/16 111/10
132/18 132/22 144/9
161/10
subsequent [2]
92/21 168/21
subsequently [2] 7/2
34/16
substance [1] 26/24
substantially [1] 41/6
success [1] 115/23
successful [1] 182/4
successfully [1]
141/3
succession [2]
128/20 152/21
successor [2] 34/22
155/21
such [21] 2/20 4/7
8/4 8/4 8/4 10/3 12/17
32/13 41/7 63/24
82/20 96/19 98/4
98/22 103/9 126/5
143/13 143/25 150/23)
160/14 182/6
suddenly [1] 173/15
sufficient [7] 47/1
55/8 126/20 148/24
149/7 149/18 158/25
sufficiently [3] 31/6
68/13 169/14
suggest [5] 9/17 40/8I
70/25 96/5 150/12
suggested [2] 94/8
156/5
suggesting [3] 70/17
110/4 163/10

(73) snapshot - suggesting
Ss

suggestion [5] 87/25
94/1 100/13 101/3
182/10
suggestions [1]
182/9
suggests [2] 47/17
90/20
suitably [1] 177/11
summaries [1] 58/15
summarisation [1]
72/14
summarise [3] 20/17
23/6 59/12
summarised [1]
136/6
summarising [2]
23/22 74/19
summary [18] 21/22
25/23 31/2 31/11 54/2
56/9 60/4 64/19 72/4
77/6 84/19 84/23
84/25 84/25 93/20
109/23 110/12 111/12)
supervision [1] 49/4
support [7] 5/12 7/9
29/17 56/6 109/11
110/16 125/18
supported [4] 29/2
29/4 29/17 68/11
supporting [1] 117/8
suppose [5] 23/5
24/3 24/15 39/11
143/3
Supreme [1] 117/10
sure [31] 13/4 14/12
22/6 25/21 26/17
26/18 28/6 35/17
36/13 51/5 54/21 55/4
58/21 63/21 67/10
71/15 73/22 80/22
81/19 83/19 85/3 86/3
89/22 105/17 105/19
119/9 132/24 134/20
158/16 162/13 175/2
surely [3] 110/21
113/18 115/19
surmised [1] 156/19
surprise [3] 40/18
54/22 182/15
surprised [5] 78/23
79/2 88/8 88/25
140/14
surprises’ [1] 131/22
surprising [3] 54/16
54/18 171/1
surrounding [1]
171/23
Susannah [8] 34/6
34/11 34/16 34/22
44/10 44/20 45/2
80/23
sustainability [2]

96/20 141/5
Swannell [8] 121/15
121/22 121/23 122/1
123/15 146/9 183/18
185/12
sworn [4] 1/6 121/23
185/2 185/13
system [38] 16/18
19/20 33/13 42/13
54/13 60/25 63/1
65/10 66/14 70/15
70/18 70/20 70/21
71/11 71/13 84/7
91/18 92/23 97/12
97/15 97/17 98/6
106/24 106/25 106/25)
107/2 110/2 110/5
110/6 110/8 110/19
113/24 152/4 152/25
157/13 163/13 164/3
171/23
systemic [5] 69/4
69/13 151/17 157/24
180/10
systems [2] 105/4
178/5

T

tab [2] 1/16 112/15
tab 2 [1] 112/15
tab 2A [1] 1/16
tabs [2] 66/21 66/22
tact [1] 157/12
take [18] 24/10 33/15
78/9 106/16 115/20
117/6 119/15 124/10
126/9 140/4 145/12
146/7 157/19 158/2
164/15 169/7 169/8
170/12
taken [13] 50/7 50/8
80/2 90/24 94/25
97/18 98/6 106/6
112/25 116/3 132/1
160/13 171/15
takes [1] 127/10
taking [10] 22/24
53/14 55/17 56/21
74/1 78/12 81/24
82/24 128/20 183/18
talk [4] 152/23 153/1
181/16 181/24
talked [7] 16/25
156/20 168/22 180/9
181/14 181/15 181/22)
talking [7] 25/9
110/22 144/17 144/18)
150/8 176/6 179/10
task [7] 29/2 29/5
29/17 39/11 41/1 41/2
109/16
tasks [1] 39/14
team [36] 8/24 30/19
34/10 34/22 36/22

37/15 38/21 38/21
39/14 41/6 42/6 43/2
43/3 44/17 45/8 50/9
50/23 52/16 55/4
55/21 67/5 70/6 71/15
77/10 77/16 77/16
79/6 89/1 111/9 114/1
114/14 136/17 138/7
142/12 142/18 160/1
team's [1] 109/13
teams [11] 37/12
38/1 40/10 43/17
49/17 56/8 66/11
66/13 79/23 136/10
150/3

technical [4] 13/1
18/4 84/7 180/17
technicalities [1]
182/14

technically [2] 16/15
18/10

tell [22] 2/3 38/17
93/9 111/9 139/2
153/12 156/15 161/5
162/9 164/24 165/1
167/8 169/13 169/21
173/13 173/20 174/15}
174/20 175/3 175/5
176/17 178/11

telling [2] 131/8
152/11

template [2] 64/2
64/10

temporary [1] 7/14
ten [5] 48/15 83/21
102/15 173/4 181/15
tend [1] 173/23
tended [2] 51/6 51/11
tension [2] 39/18
168/15

term [4] 48/3 53/12
96/19 141/6

terms [26] 6/6 22/2
23/13 23/13 23/14
25/9 26/6 30/25 34/2
45/12 57/18 58/12
59/23 64/1 65/6 69/9
71/18 73/23 85/14
93/19 100/3 114/15
125/12 133/20 160/7
172/14

test [1] 91/23

testing [1] 93/2

text [3] 59/14 67/19
155/3

than [22] 32/18 33/25}
40/24 42/8 47/17
49/12 51/12 51/15
51/25 67/9 75/11
79/14 95/10 98/21
101/24 107/1 124/15
128/12 141/17 142/21
172/24 173/23

thank [62] 1/4 1/12

11/6 12/23 30/21
31/17 38/25 48/17
48/22 53/8 55/10 60/6)
61/6 61/8 61/10 61/13
71/9 75/15 78/7 83/24
84/4 102/5 102/8
102/17 102/18 105/25}
108/3 109/6 109/7
109/10 112/9 112/14
116/3 116/5 116/6
121/3 121/5 121/8
121/12 121/15 121/18}
121/21 121/22 121/25}
122/2 122/2 122/11
123/22 125/7 129/20
130/1 136/25 140/25
143/2 146/21 149/5
157/10 170/3 177/7
183/13 183/17 183/22
Thanks [1] 89/21
that [963]

that I [5] 34/6 38/24
125/5 132/20 159/1
that's [66] 3/17 4/23
6/15 6/19 12/2 19/21
27/7 28/14 32/7 35/14,
35/24 39/11 43/23
46/1 55/22 60/14
68/15 70/3 71/22
72/23 73/2 73/15
78/14 81/5 86/12
90/23 94/8 109/6
111/3 111/4 113/20
118/3 118/24 120/17
121/7 127/9 128/18
132/4 133/5 135/18
136/9 137/1 140/3
140/22 141/1 148/2
148/3 151/18 153/16
156/23 158/6 158/15
160/2 160/23 161/10
164/12 164/22 167/10
170/17 171/19 173/13}
174/17 176/5 176/14
180/24 183/25

their [37] 3/11 11/11
15/18 15/19 16/3
26/12 29/6 31/14
52/17 56/10 56/14
62/1 65/18 73/12
80/19 89/22 91/24
92/23 93/24 97/19
100/25 103/17 115/13
115/15 118/15 119/13}
134/1 134/2 136/10
136/11 160/12 161/5
177/22 179/14 181/21
182/16 182/22
them [29] 4/18 10/13
16/20 18/21 38/14
38/17 47/10 50/11
55/15 65/20 65/24
72/16 81/14 86/22
86/23 98/20 99/8

104/11 109/3 111/2
115/11 128/13 131/3
134/16 140/4 168/20
174/17 178/24 180/7
theme [2] 14/6 54/21
themselves [7] 33/11
37/1 38/6 47/7 137/22)
138/1 148/6
then [78] 2/5 4/8 6/5
9/8 13/5 14/20 18/22
19/7 19/23 24/15
27/14 28/11 30/10
30/11 34/6 36/24
39/11 39/24 57/3 57/5I
57/7 65/5 66/17 68/3
68/21 69/1 69/8 70/21
72/15 73/10 74/8 81/6I
85/13 85/22 85/22
89/3 89/13 89/20 90/6
90/7 96/20 103/18
104/10 110/8 110/19
113/3 113/10 114/9
122/23 124/14 125/9
125/14 125/21 126/2
127/2 128/1 129/25
134/3 135/8 135/11
138/22 138/22 139/6
149/14 155/15 157/16)
158/1 159/5 159/22
159/25 161/10 162/11
170/15 170/18 171/19}
173/24 183/12 183/17)
theory [2] 31/21
83/14
there [210]
there'd [2] 85/2
107/19
there's [27] 13/1
40/18 50/2 50/12 59/7
68/9 84/24 85/19
87/21 87/25 97/25
114/17 117/14 119/18
125/21 130/2 134/10
134/10 138/20 143/4
144/25 151/19 159/18)
159/22 167/2 170/15
181/17
thereabouts [1]
134/15
thereafter [1] 118/19
therefore [6] 16/2
108/19 139/6 148/23
156/22 176/12
thereof [1] 118/10
these [48] 12/10
12/11 14/11 21/19
22/4 22/17 23/1 23/20
24/19 33/23 36/12
42/18 44/17 50/7
50/11 50/14 50/20
51/11 51/23 52/21
52/23 56/9 56/15
58/15 60/22 61/18
67/12 69/23 81/23

(74) suggestion - these
T

these... [19] 85/17
89/7 91/21 93/14
94/20 95/19 99/20
104/5 104/9 105/3
105/7 105/9 122/18
138/13 140/3 158/24
159/15 161/3 161/19
they [124] 2/12 2/15
8/8 8/11 9/17 9/19
13/25 14/2 14/3 14/13)
14/18 14/19 15/3
15/18 16/2 16/15
16/17 16/24 22/22
23/10 23/10 23/16
24/20 33/6 33/16
33/24 35/10 35/11
35/12 36/2 36/16 37/5
38/1 38/2 38/5 38/13
40/1 40/9 40/16 40/22
41/5 50/14 50/16 52/6)
55/7 55/23 56/19
58/16 60/2 60/2 60/2
60/3 64/12 65/16
65/17 65/19 65/23
66/18 68/25 71/16
72/17 72/20 72/21
77/19 80/8 91/16
91/17 91/24 92/23
92/23 93/15 93/18
93/23 98/18 98/21
99/7 99/7 99/8 100/15)
100/22 100/22 103/15
103/15 103/16 103/16
103/16 103/18 104/22)
105/10 105/21 105/22)
110/19 115/12 117/20}
117/24 117/24 119/11
119/12 119/13 119/21
124/5 129/14 132/4
136/14 137/25 138/6
139/3 141/22 145/25
151/13 152/10 157/18)
158/24 159/5 160/1
163/17 168/16 178/7
180/15 180/16 180/25)
181/8 181/22 181/22
they'd [9] 38/3 38/16
47/24 55/6 55/25
59/19 141/25 181/23
181/23
they're [10] 16/15
23/21 47/25 55/13
55/14 60/14 65/20
105/16 105/23 148/10
thing [8] 41/10 62/17
106/13 152/18 153/13}
174/17 175/6 180/12
things [30] 26/16
A1/7 42/21 42/22
50/17 53/25 58/14
58/25 60/22 62/1
62/21 67/7 72/13

79/16 81/23 88/9
91/22 97/22 97/25
103/21 104/14 105/7
105/18 135/17 139/5
139/13 153/20 165/8
180/9 180/19
think [239]
thinking [3] 49/11
85/19 111/13
third [5] 13/3 23/5
50/22 57/8 165/17
this [346]
Thompson [1]
163/24
Thornton [2] 94/2
94/9
thorough [1] 95/3
those [71] 2/3 2/11
2/13 4/6 5/5 8/8 8/25
14/18 16/6 17/23 18/7)
18/13 19/14 20/17
22/4 23/15 23/23
24/25 28/7 31/11
35/25 37/14 39/13
42/22 47/8 47/24
50/18 50/21 52/9
53/25 65/21 66/21
67/7 72/18 72/24
72/25 73/12 80/6
80/10 82/25 85/14
95/23 96/2 101/18
101/25 110/16 117/11
121/3 127/4 127/23
128/17 128/22 131/6
131/12 131/12 132/2
133/8 133/12 134/21
137/18 137/25 139/23
145/9 145/10 145/22
154/19 161/3 176/14
177/12 178/10 183/13)
though [4] 15/18
84/18 92/21 180/6
thought [10] 24/10
24/21 50/11 66/6
107/10 158/25 168/1
180/22 181/5 181/13
thoughts [3] 89/8
167/21 167/22
thousand [1] 181/15
threat [1] 118/8
threaten [1] 120/16
threatening [2]
120/10 120/19
three [11] 20/6 24/25
35/20 125/21 131/4
147/12 147/19 162/20)
164/19 168/21 170/2
through [34] 5/22
9/21 16/25 19/19 47/4
47/6 47/21 47/21 49/1
50/12 61/23 74/1 74/4
77/24 88/17 91/3
93/17 94/25 95/1
101/25 107/22 118/21

134/12 139/23 153/2
153/6 153/13 160/18
177/13 177/15 177/17
178/18 178/18 180/4
throughout [1] 183/9
throw [1] 33/6
tightly [1] 110/17
Tim [23] 54/8 70/5
70/7 89/4 89/13 89/16
89/19 90/1 90/6
109/23 110/1 131/5
138/20 163/7 163/8
163/12 163/15 163/24
167/13 167/14 168/13
168/19 169/17
Tim's [2] 169/7 169/8
time [72] 3/18 5/11
6/13 15/5 17/10 24/17,
34/15 36/19 36/25
40/19 40/20 41/18
48/13 54/19 63/16
66/25 73/6 73/7 79/3
81/20 84/8 84/11 86/6
88/5 89/14 90/4 91/22
93/16 94/5 94/20 95/8)
98/15 98/21 103/16
104/22 108/4 108/23
109/4 111/3 116/3
118/4 118/9 119/2
119/13 119/16 119/23
128/14 132/25 135/16}
135/21 140/4 145/15
146/7 146/17 149/18
150/16 150/25 151/3
152/1 152/8 153/5
157/8 158/13 160/8
166/16 171/12 171/16
174/13 176/16 179/8
180/8 183/18
timeline [1] 139/24
times [9] 11/19 11/24
20/5 29/10 48/3
138/14 145/16 181/15}
181/15
timescales [1] 57/22
title [1] 130/1
TMc [1] 70/14
today [8] 1/13 1/14
102/1 116/14 122/2
123/10 152/12 180/19}
together [2] 56/20
67/4
told [10] 34/21 55/2
94/13 94/14 128/5
135/19 174/4 174/18
174/22 175/9
Tom [8] 44/4 44/8
44/19 148/19 168/5
168/8 168/23 169/12
tomorrow [2] 90/11
183/23
too [7] 73/19 89/17
96/10 96/11 114/8
131/8 172/15

took [11] 6/2 35/22
37/14 41/5 97/9
107/18 116/14 149/11
171/17 175/21 181/16}

tools [1] 177/19

tooth [1] 35/10

top [20] 56/9 57/6
57/18 58/11 58/11
58/23 65/3 65/4 72/6
72/18 73/13 73/18
87/22 140/5 140/15
159/21 161/21 167/13}
170/18 171/23

topic [2] 48/10 88/6

topics [3] 51/22
67/15 88/4

totality [4] 152/25

touched [3] 73/17
180/13 180/19

towards [7] 28/25
65/3 88/13 90/1
109/13 109/15 170/18}

toxic [1] 139/13

track [2] 57/20 130/7

tracking [1] 56/6

trade [6] 3/19 3/22
11/10 59/6 116/10
129/6

traffic [22] 23/11
23/15 23/22 23/24
42/13 46/21 49/7
49/16 49/19 49/25
50/1 50/4 50/18 51/15)
53/17 53/22 54/11
55/8 56/10 57/8 57/11
104/1

train [2] 7/114 179/14

training [2] 179/19
181/3

Trains [1] 7/11

trampling [1] 168/22

transaction [2] 46/16
92/16

transactions [4]
127/7 173/9 174/7
174/23

transcriber [5] 46/9
101/23 102/2 102/6
146/6

transcriber's [1]
31/15

transcript [2] 2/16
174/15

transferred [1]
182/25

Transformation [2]
57/24 79/18

transformed [1]

141/7

translate [1] 158/6

transparent [1] 68/13}

transparently [1]
111/11

Treasury [4] 28/1

108/18 129/8 183/1
Treasury's [1] 27/1
treat [4] 134/16
treated [2] 19/12
74/22
treatment [1] 107/2
trial [2] 148/13
148/13
tried [2] 173/1 174/9
trigger [2] 13/5
156/23
triggers [1] 100/16
trouble [4] 8/16
65/14 65/23 183/18
true [4] 2/14 97/16
124/3 145/12
trust [8] 176/2 176/3
176/13 176/14 176/18)
176/23 176/23 176/24)
trusted [1] 111/1
truth [3] 152/22
156/14 180/13
try [5] 67/11 84/11
94/7 114/3 153/7
trying [6] 59/7 59/9
60/14 115/25 131/14
159/18
Tuesday [1] 1/1
turn [27] 1/18 7/18
20/10 22/14 45/17
48/23 74/14 119/25
122/3 122/8 122/10
123/17 123/22 131/3
131/15 144/12 144/24)
145/6 147/10 154/22
170/6 170/7 170/15
170/18 176/19 177/4
179/11
turning [4] 28/11
75/16 84/5 145/16
twice [1] 63/11
two [30] 9/16 12/11
20/9 29/16 31/10
35/20 36/9 39/14
39/17 42/2 42/3 42/20}
42/22 47/8 51/21
51/24 58/14 79/16
83/1 85/8 89/5 122/8
126/8 132/14 133/8
138/13 148/10 156/8
166/12 168/20
two-step [1] 36/9
tying [1] 59/9
type [8] 51/3 68/4
93/15 94/7 120/13
148/8 149/6 150/20
types [1] 14/11
typically [10] 4/4 9/2
11/2 15/4 18/18 24/6
33/4 39/12 40/21
41/10

U
UK [11] 6/22 6/23

(75) these... - UK
U

UK... [9] 10/10 15/17
16/13 18/22 21/9
21/10 28/12 31/22
74/21
UKFI [1] 122/23
UKGI [110] 2/5 6/24
7/2 715 11/11 14/24
15/11 16/19 17/12
19/11 21/14 21/16
21/17 21/18 22/3 22/8
25/4 25/20 26/23 27/3
27/6 27/11 27/16
27/19 27/24 29/9
29/13 29/22 30/4
30/11 30/16 30/19
30/23 32/1 32/3 32/19
33/25 34/2 39/2 42/12
43/9 43/18 44/17 45/6)
56/6 59/17 94/21
94/23 95/1 95/20
96/23 97/4 97/15
98/14 122/14 122/24
127/18 127/19 1314/7
134/12 134/14 134/18)
134/22 134/24 135/3
135/6 135/9 135/13
135/21 135/23 138/17)
139/7 139/8 140/9
143/5 143/16 143/19
143/20 144/1 144/3
154/3 155/8 160/25
161/8 161/11 162/3
163/9 165/8 165/16
167/18 168/2 169/1
169/10 171/8 171/16
171/18 171/24 172/1
174/9 174/11 175/15
178/1 179/2 181/12
181/16 181/19 182/24)
183/1 183/5 183/10
UKGI's [3] 56/7 61/16
96/15
UKGI/Shareholder [1]
19/11
UKGI00002057 [1]
88/12
UKGI00002488 [1]
149/24
UKGI00002489 [1]
150/19
UKGI00004686 [1]
156/17
UKGI00004687 [1]
157/5
UKGI00006883 [1]
112/10
UKGI00008374 [1]
167/13
UKGI00016718 [1]
135/24
UKGI00016783 [3]
143/15 147/3 165/12

UKGI00016800 [1]
170/6
UKGI00016850 [1]
64/24
UKGI00016864 [1]
140/1
UKGI00017385 [1]
53/16
UKGI00020145 [2]
56/23 161/14
UKGI00020297 [1]
163/6
UKGI00041941 [1]
76/10
UKGI00041943 [1]
76/12
UKGI00041969 [1]
49/23
UKGI00042124 [2]
69/23 109/17
UKG100044314 [1]
129/17
UKGI00045533 [1]
154/24
UKG100045534 [1]
123/15
UKGI00045535 [1]
123/16
UKGI00045945 [1]
169/16
UKGI00045953 [1]
125/7
UKGI00045955 [1]
133/17
UKGI00045959 [2]
148/1 149/14
UKGI00048173 [1]
172/2
ultimate [3] 10/22
19/20 130/12
ultimately [13] 5/12
12/15 13/23 14/17
26/1 28/23 35/11 38/8
39/25 47/5 118/1
180/4 180/5
Um [1] 60/10
unable [3] 67/20
69/11 151/7
unchanging [1]
50/19
unclear [1] 80/23
uncomfortable [1]
99/4
uncover [1] 107/19
uncovering [2] 96/14
111/10
under [9] 18/11
20/14 28/17 129/21
130/1 142/7 167/15
170/19 182/16
undergrowth [1]
168/22
underlying [12]
126/21 134/21 144/2

147/15 154/18 154/20}
162/1 167/7 172/18
176/1 178/13 182/22
undermined [2] 69/7
151/21
underpinned [1]
76/23
understand [20] 1/25
37/2 41/21 54/19
54/25 60/8 60/16 97/1
101/10 101/13 120/23
122/15 123/18 124/10
157/7 159/18 172/4
173/21 180/10 180/17
understandable [1]
17/5
understanding [8]
31/17 43/20 92/5
92/21 117/23 119/11
136/11 176/12
understood [8] 31/12
40/9 58/18 58/20
95/12 97/2 164/23
178/2
undertaken [2] 162/3
163/15
undertaking [3]
22/17 113/6 128/15
undue [1] 168/16
unfortunately [1]
5/16
unhindered [1] 35/7
Unique [1] 122/4
unit [2] 4/16 4/17
unless [3] 5/12 19/7
91/4
unlikely [3] 27/14
156/1 156/10
unmitigated [1]
160/9
unsafe [5] 97/10
143/24 144/4 152/5
159/10
unsatisfactory [1]
179/6
untenable [2] 113/17
115/19
until [11] 30/5 39/5
40/14 41/24 44/13
83/22 86/11 92/11
96/25 146/4 184/3
unusual [2] 41/9
171/7
unusually [2] 39/2
133/18
unwound [2] 36/18
37/11
up [59] 6/2 19/19
22/8 31/1 33/7 40/9
44/22 46/2 60/19
61/12 61/22 67/23
68/2 70/21 73/20
77/11 83/19 85/11
88/11 88/17 89/5

89/17 89/20 90/4 90/5
90/9 90/14 91/22
96/20 103/10 103/20
104/15 105/3 105/7
109/3 110/8 112/17
115/1 115/25 116/3
117/2 119/25 125/7
131/3 133/17 135/1
144/12 144/19 149/13
149/24 150/18 155/23}
156/4 157/14 162/22
165/23 174/14 177/5
177/17

upcoming [1] 53/13
update [5] 51/21 88/2)
147/7 150/4 150/6
updated [3] 28/17
150/2 157/1

updates [4] 56/13
72/3 72/7 77/24
upheld [1] 16/17
upon [5] 40/17 77/3
86/10 114/18 148/14
URNs [1] 123/14

us [25] 1/3 18/7 33/6
38/17 41/9 48/21
65/13 71/16 84/3
86/23 93/1 98/8 101/8I
104/15 104/24 111/9
112/12 115/10 121/20}
138/22 146/25 149/21
158/6 160/7 181/24
use [9] 10/8 11/25
50/20 60/8 64/3 64/12
161/22 161/24 173/23
used [5] 48/2 70/15
110/2 136/10 161/25
useful [2] 26/19
155/19

uses [2] 112/11
136/16
using [1] 42/13
usually [1] 39/6
utterly [4] 173/7
176/8 176/24 179/23

Vo
valid [1] 13/10

value [1] 19/8
values [2] 16/4 16/6
varied [1] 26/9
variety [3] 19/6 97/25
121/10

various [14] 9/15
23/8 74/3 75/21 93/19
94/23 104/9 118/20
130/17 137/5 140/9
168/21 182/1 182/9
vary [1] 130/19
Vennells [2] 156/8
168/14

venture [1] 154/17
veracity [1] 99/17
verify [1] 123/2

version [2] 12/19
67/4
very [83] 1/4 1/14
5/14 5/19 6/7 9/5 9/10
14/8 18/11 18/19
19/10 19/13 22/12
22/24 23/5 23/18
24/22 26/11 26/15
27/7 35/2 36/10 37/15
38/11 38/12 40/2 42/3}
43/11 48/8 48/22 50/5)
50/6 61/6 62/17 62/20
65/15 66/10 74/10
74/13 75/21 78/3
79/20 88/10 88/11
99/14 99/18 99/23
100/18 100/19 101/4
101/10 102/5 105/5
105/7 107/24 110/12
110/17 110/17 110/21
110/21 115/10 117/5
118/15 120/20 121/3
121/11 121/21 129/4
129/14 130/3 135/7
140/5 153/8 162/1
164/8 167/9 171/7
173/3 178/18 178/20
180/15 183/17 183/20)
via [2] 15/21 122/20
viable [1] 40/7
Vice [1] 7/1
victim [2] 81/17
108/8
video [1] 121/17
view [31] 14/8 24/10
24/11 33/15 36/24
40/25 50/6 50/8 53/11
62/2 62/3 77/15 77/17
80/3 93/25 94/6 99/11
100/3 100/12 103/1
117/16 138/15 169/12)
174/19 176/22 179/13}
179/18 179/22 180/1
182/13 182/16
viewed [1] 88/6
views [3] 81/25 155/6}
173/19
vis [2] 90/19 90/19
visceral [3] 173/7
173/16 174/3
visibility [1] 80/15
visible [1] 1/21
vulnerable [1] 11/17

Ww

wages [1] 28/4

want [33] 19/23 23/1
33/13 38/17 40/1 40/9)
42/3 52/12 63/2 72/15
84/11 100/14 105/19
109/13 109/18 110/11
119/19 122/3 125/6
126/8 131/3 133/16
138/4 144/24 147/2

(76) UK... - want
Ww

want... [8] 153/18
153/21 154/22 163/6
167/9 167/24 169/3
171/25
wanted [11] 35/12
36/10 40/24 61/11
62/22 66/11 87/6
91/18 107/21 117/20
153/9
wanting [1] 91/13
wants [1] 55/15
Warmington [1]
108/11
warrant [1] 12/9
warranted [1] 47/14
was [481]
wasn't [17] 5/11
37/20 66/10 82/6
99/12 130/10 137/10
137/13 146/15 148/25)
152/4 156/21 158/22
158/22 160/8 164/16
165/24
way [50] 5/6 8/24
11/19 19/5 19/12 20/3
24/14 25/4 25/16
25/19 26/13 26/18
26/21 33/25 43/6
47/22 49/22 52/14
52/15 54/15 56/21
58/24 62/1 64/23
65/13 66/1 74/20 97/6
99/11 101/4 102/6
107/3 108/12 112/13
120/22 128/12 135/14}
138/6 139/13 141/15
143/11 145/22 147/25
154/15 156/19 161/6
162/1 162/18 178/20
182/20
ways [6] 26/16 29/16
47/19 47/11 145/20
180/9
we [356]
we'd [4] 33/13 95/12
107/11 128/5
we'll [15] 11/8 54/21
59/20 66/15 101/20
102/7 115/18 127/4
131/12 139/23 144/25)
145/1 146/17 153/19
183/23
we're [16] 22/17
22/23 23/25 28/9 59/9
59/9 66/5 66/6 69/22
89/17 104/11 110/22
119/20 148/5 148/18
179/10
we've [14] 13/8 33/1
44/11 52/21 61/7
73/17 81/1 100/17
100/18 103/23 105/19

weak [1] 101/4
weakening [1]
101/16
website [3] 2/19
16/23 124/8
Wednesday [2] 87/8
87/10
weeks [2] 147/23
182/8
well [99] 3/3 4/1 6/15
7/14 13/14 13/22
16/21 19/5 23/21 26/9)
27/18 28/2 36/9 38/11
38/17 39/9 39/22
40/18 41/3 41/7 43/11
52/13 55/13 55/20
58/10 60/4 60/10
63/17 66/6 67/2 71/6
80/12 82/21 83/14
84/24 85/13 86/3 86/5)
86/21 91/10 92/20
95/11 96/4 96/25
100/14 105/1 105/5
107/11 107/18 112/7
112/18 115/8 115/18
115/22 116/3 118/7
119/3 119/8 119/18
121/8 121/16 128/4
130/8 130/23 131/12
131/23 133/9 135/22
139/19 139/20 139/23)
139/24 141/15 144/6
144/8 144/25 145/25
147/18 148/11 149/13)
154/10 156/13 158/15)
159/8 159/18 161/24
162/10 164/21 166/20)
167/25 168/5 168/19
169/23 170/11 179/21
180/16 180/25 183/7
183/17
went [14] 5/18 61/22
71/19 74/4 93/11
93/16 123/3 138/12
141/24 145/15 148/6
159/15 165/12 166/24}
were [203]
weren't [12] 5/17
36/21 71/6 86/21
91/15 91/16 108/7
137/15 138/1 146/3
159/16 180/25
what [203]
whatever [4] 37/1
114/20 139/4 140/19
when [70] 3/14 4/2
6/2 6/22 11/19 11/24
14/24 22/13 25/17
27/16 27/17 30/6 31/3
34/23 34/24 34/24
36/5 37/9 41/4 45/4
48/7 52/19 66/4 78/2
80/14 80/21 80/24

106/17 136/21 153/18)

81/20 82/12 82/13
84/10 84/16 87/9
93/12 95/15 99/19
106/1 106/10 109/19
109/21 125/4 128/1
128/18 133/1 135/19
137/2 139/12 139/14
140/12 144/20 150/14
153/1 153/5 160/8
161/1 162/5 164/9
167/21 167/22 168/7
169/13 169/25 171/19
173/18 173/21 174/19]
174/20 175/25 176/24
182/24
whenever [1] 55/16
where [46] 2/4 2/8
5/4 12/6 13/16 14/12
14/14 17/25 18/14
33/14 35/14 35/21
36/20 36/21 39/22
40/22 42/19 47/19
65/16 67/11 73/20
75/22 86/19 88/2
92/18 94/24 97/8
99/16 100/12 103/9
108/8 116/16 119/5
126/15 127/7 127/10
127/15 130/22 138/10
143/8 145/2 148/6
156/2 171/13 173/10
180/14
wherever [1] 75/3
whether [35] 5/15
29/22 46/25 47/14
69/14 91/24 101/23
109/14 110/24 117/3
132/5 132/21 136/17
137/25 139/2 139/3
146/11 149/8 153/2
153/10 159/9 161/6
162/15 162/16 164/13}
164/24 165/8 165/22
168/20 169/1 173/24
174/24 176/22 178/24
180/5
which [115] 2/22
2/25 5/20 9/3 10/10
11/15 11/19 12/17
13/8 21/18 22/1 23/9
24/4 24/16 24/21 25/2
25/6 26/6 27/7 27/25
29/9 29/13 32/21 35/1
39/4 41/6 41/9 42/17
42/18 44/22 47/21
53/10 56/16 58/17
59/14 59/16 60/4
63/18 69/10 69/18
69/19 73/17 74/6 74/9
76/7 76/15 77/18 79/9
79/12 80/5 81/2 82/5
83/3 83/11 86/7 89/25
90/10 90/24 90/25
93/3 94/12 94/16

95/25 97/6 99/11
101/19 108/20 112/11
112/15 115/17 116/15)
118/14 119/23 122/3
122/9 122/21 123/8
123/11 123/14 124/7
126/8 126/11 126/15
128/5 128/6 128/11
128/19 131/9 133/13
139/25 141/24 142/3
142/10 143/5 144/18
144/20 145/17 145/24}
146/12 147/12 155/4
158/19 158/20 160/17}
161/13 162/4 162/25
167/2 168/9 170/22
172/17 174/15 175/5
177/3 178/21
while [6] 48/2 69/22
80/12 121/13 124/18
168/13
whilst [1] 76/17
whistleblowing [1]
95/18
Whitehall [14] 4/15
4/20 8/7 8/10 8/13
8/19 9/4 9/25 13/16
13/19 15/11 22/9
26/15 35/5
who [47] 4/17 6/5
13/23 18/21 37/2 37/6
39/5 41/19 41/20
43/11 44/20 47/5
47/13 52/3 52/6 54/4
54/8 55/11 55/15
59/10 61/2 62/18
62/24 63/4 75/12
84/23 86/9 88/19
93/14 98/24 99/21
102/23 104/6 107/25
120/23 122/23 125/9
132/22 137/22 161/3
168/5 168/18 173/20
176/19 177/23 178/23}
182/8
whole [11] 41/5
47/18 55/20 71/23
72/10 101/2 128/13
135/12 135/15 138/3
139/5
wholly [3] 7/21 24/22
179/6
whom [2] 70/16
110/3
whose [4] 26/10
61/23 61/24 161/1
why [45] 7/23 9/5
9/15 10/8 12/24 13/13}
14/9 14/10 19/3 36/2
37/22 39/15 39/17
39/17 41/23 55/6
65/10 71/5 79/2 80/1
94/8 98/13 98/20 99/1
99/6 99/18 104/6

105/5 108/22 111/11
111/13 135/18 136/22)
140/3 149/6 149/17
156/10 160/7 160/23
164/15 164/16 176/5
176/14 181/17 181/22)
idely [1] 16/21
wider [1] 51/1
will [36] 2/19 2/20
11/25 12/5 12/6 12/6
12/20 16/22 16/22
19/6 21/24 26/4 33/10}
42/9 50/12 76/21
87/10 88/17 89/2 90/2I
90/6 90/11 99/21
102/15 115/9 119/21
121/13 124/7 128/7
133/23 134/23 140/8
145/6 147/18 155/18
165/20
WILLIAM [3] 121/23
122/1 185/12
wish [6] 69/11 94/22
95/4 122/16 123/19
165/10
wishes [2] 31/7
31/13
withheld [1] 139/3
within [35] 2/22 3/18
8/10 8/12 9/25 19/12
19/15 22/13 22/21
22/21 22/21 43/17
44/17 45/20 52/3 67/6)
85/6 85/6 85/7 86/1
89/1 96/8 97/23 103/7
106/8 122/13 127/21
134/18 139/18 142/2
165/8 172/5 177/23
178/2 182/17
without [9] 31/1 38/4
38/5 74/1 92/12
104/16 114/24 120/10}
182/3
WITN00800100 [1]
217
WITN10800100 [1]
122/5
witness [46] 1/14 2/9
2/18 5/1 15/22 17/24
18/6 19/2 21/1 101/25)
108/21 116/15 121/9
124/9 127/23 130/17
137/17 144/11 148/16
149/2 156/6 156/20
159/7 159/13 160/3
160/23 161/24 162/16)
163/23 164/10 165/6
166/3 167/24 167/25
171/6 171/20 173/1
174/10 174/12 175/24I
177/13 177/5 178/8
178/15 182/5 183/19
witnesses [2] 121/19
182/8

(77) want... - witnesses
Ww

wobbles [1] 113/14
won't [5] 40/18 58/16
72/17 91/3 112/12
wonder [3] 83/20
101/23 162/14
wondering [3]
111/13 111/14 146/11
word [3] 60/8 65/17
69/14
wording [6] 67/18
89/24 90/14 90/18
112/13 123/4
words [4] 11/25
117/18 138/13 151/3
work [27] 1/13 4/24
5/14 6/7 10/12 20/18
25/7 33/13 35/7 43/12
52/20 57/1 77/22 91/9
91/18 93/15 93/25
94/1 94/7 94/12 96/2
132/10 132/20 162/20
178/22 182/2 183/7
worked [1] 173/20
working [16] 15/12
15/17 41/17 67/20
68/23 68/25 69/3 69/9
70/20 110/7 142/12
151/7 151/12 151/13
151/16 153/5
workstream [1]
21/23
workstreams [4]
21/19 21/22 25/3
25/14
worth [1] 128/15
would [241]
wouldn't [25] 9/3
9/25 13/20 23/18
36/14 40/7 41/10
47/23 50/13 52/23
53/5 55/7 77/20 80/13,
80/25 83/12 91/24
98/17 100/20 107/21
115/11 156/11 156/11
157/8 178/11
write [2] 60/10
183/18
writing [3] 159/20
173/13 174/11
written [5] 39/20
58/22 122/3 173/2
173/5
wrong [8] 37/5 71/7
76/10 99/4 138/12
159/15 166/15 173/9
wrongful [6] 161/9
164/16 164/21 164/23)
165/3 175/19
wrongfully [2] 111/1
163/14
wrongly [6] 97/10
111/15 111/19 111/23}

144/9 164/6
Wyn [1] 60/10

Y

yeah [42] 2/12 7/17
8/1 11/22 14/5 15/2
15/14 16/8 16/12
29/20 41/25 45/1
45/16 48/5 48/7 50/20
51/17 52/2 54/18
55/25 57/2 57/15
59/22 64/17 64/20
65/7 65/10 66/20
66/23 75/8 75/25 93/5)
118/13 120/6 120/6
131/3 140/23 143/17
148/4 153/25 165/14
169/18
year [13] 20/5 53/13
63/11 85/6 86/7 96/2
96/2 108/12 153/24
158/20 173/4 173/10
176/21
years [12] 51/24
104/25 124/14 124/15)
143/1 152/10 155/18
164/10 172/20 173/8
174/5 174/16
yes [126] 1/4 1/10
4/17 1/20 1/22 2/2 2/2
2/4 6/1 6/15 6/15 7/10
12/22 13/12 16/5
18/19 21/4 21/7 25/10
25/21 29/25 30/2 30/2
31/9 31/15 31/16
32/24 33/20 33/22
33/22 34/1 34/19
34/19 38/10 42/23
43/21 45/7 48/13
48/22 49/18 49/21
50/4 50/20 51/6 51/11
52/1 52/7 60/23 61/21
62/17 64/4 65/1 67/10
69/17 72/23 72/23
74/5 75/5 77/7 79/1
80/8 81/10 82/8 83/14
83/23 84/4 85/7 85/13
86/5 86/15 86/18 90/3
92/6 95/6 95/23
103/24 104/3 105/21
106/14 107/15 108/5
108/10 108/16 109/12)
109/22 115/7 118/1
118/18 118/18 120/10)
120/20 120/20 120/20)
121/15 121/16 121/21
124/24 126/13 132/12)
133/3 138/9 138/10
142/23 144/3 146/2
146/9 146/17 146/20
146/20 147/1 148/18
149/5 152/2 158/15
159/8 160/2 160/4
163/25 166/10 168/17)

169/5 172/6 178/4
178/7 181/7 183/1
yet [2] 133/7 167/18
you [736]
you'd [6] 1/25 2/11
106/5 106/6 106/9
119/8
you'll [12] 23/18
24/19 51/23 65/2 65/4
126/23 128/11 131/6
134/25 138/13 144/19]
157/21
you're [18] 17/4
29/14 33/23 35/20
55/24 63/22 65/21
110/25 123/10 133/8
136/1 144/17 148/8
152/9 154/11 154/12
159/24 169/23
you've [22] 10/1
19/18 39/20 42/18
48/2 58/15 59/23
60/21 68/4 107/13
112/11 122/15 135/22
137/15 145/8 145/18
150/12 159/12 159/12
174/4 175/4 181/2
your [155] 1/8 1/23
2/14 2/18 2/23 3/2 3/6
3/21 3/24 5/25 6/2
7/20 8/25 11/1 11/23
11/25 12/18 13/9 15/9
15/15 17/9 17/16 18/3
18/8 19/8 19/24 21/13
21/14 22/2 26/7 26/21
30/25 31/10 36/5
37/16 38/13 38/18
39/1 40/13 42/9 42/10
42/11 43/16 43/19
46/10 47/13 47/16
48/3 48/4 48/25 51/3
53/9 56/2 56/17 56/17,
59/24 60/1 61/17 64/6
69/19 71/20 73/8
73/23 73/24 74/17
75/18 75/19 76/5 77/9
78/6 79/21 81/13 83/2
84/10 87/5 88/17 89/7
92/5 92/10 94/15
94/16 95/8 98/25
100/2 100/3 100/12
102/25 103/1 104/7
106/1 107/16 109/16
111/9 112/6 116/15
116/22 117/16 117/18}
121/9 121/25 124/1
124/4 124/8 124/8
124/9 125/10 127/22
130/17 133/11 133/16
133/20 133/23 134/8
136/15 137/1 137/4
139/17 140/12 143/7
144/11 144/12 146/2
146/12 150/3 150/9

150/11 153/4 153/22
154/6 154/22 154/23
155/23 159/14 159/23}
161/15 163/8 163/23
167/21 167/25 169/16
169/23 171/20 172/1
172/18 174/3 175/24
176/7 177/3 177/5
178/9 178/15 179/18
181/5 182/5 182/13
yourself [1] 100/2

r4

zealous [1] 143/19
zealously [1] 140/6
Zebra [4] 91/9 92/3
92/7 95/17

Zero [1] 7/16
zoom [2] 140/24
145/7

(78) wobbles - zoom