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The Post Office Horizon IT Inquiry 10 July 2024
Wednesday 10 July 2024
(9.45 am)
MS HODGE: Good morning, sir. Can you see and hear us?
SIR WYN WILLIAMS: Yes, I can, thank you.
MS HODGE: Thank you, sir. Just to remind you, there will
be a fire alarm test today at 10.00 am.
SIR WYN WILLIAMS: Yes, I'll just remain online as usual.
MS HODGE: Thank you, sir. Please could the witness be
sworn.
THOMAS KNUT GLENN COOPER (affirmed)
Questioned by MS HODGE
MS HODGE: Please give your full name.
A. It's Thomas Knut Glenn Cooper.
Q. Thank you, Mr Cooper. As you know my name is Ms Hodge
and I ask questions on behalf of the Inquiry. Thank you
for coming to the Inquiry this morning to answer those
questions and for the detailed witness statement which
you provided in advance. You should have a copy of that
statement in front of you dated 13 June of this year; is
that right?
A. Yeah.
Q. That statement runs to 150 pages. I understand you'd
like to make some minor corrections to the statement; is
that right?
A. That's correct.
refer to the minutes of a further meeting of the Post
Office Board on 10 December 2019. The document you cite
as evidence of that meeting is UKGI00019332. Again, the
same problem arises in that some relevant parts of that,
those meeting minutes have been redacted; is that right?
A. Yes.
Q. You therefore would like to amend the reference to
POL00290368, where we can find an unredacted version of
the same minutes?
A. Yes.
Q. Thank you. Subject to those corrections, is the content
of your statement true to the best of your knowledge and
belief?
A. Itis.
Q. Thank you. I'm going to ask you some brief questions
about your professional background, before you joined UK
Government Investments. You started your career in
accountancy; is that right?
A. Yes.
Q. Moving then to the investment bank UBS where you worked
for 21 years?
A. Yes.
Q. AtUBS you were appointed as Head of European Mergers
and Acquisitions; is that correct?
A. Yes.
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The first of those, I understand, relates to
paragraph 69(i). It's a typographical error in the
third line from the bottom of that paragraph, where it
reads "making better informed contributions to the Board
decisions", should read "discussions"?
Correct.
Thank you. The second correction you'd like to make is
at paragraph 75 of your statement. You refer to
an email from Rodric Williams to Richard Watson, and
Joshua Fox dated 12 February 2018. Should that in fact
be dated 2019?
Yes, it should.
Thank you. Then dealing with some amendments to
document references, at paragraphs 238 and 239 of your
statement you refer to the minutes of a meeting of the
Post Office Board on 17 September 2019. The document
you cite as evidence of that meeting is POL00104327.
However, the relevant part of that document has been
redacted; is that right?
That's correct.
You would therefore like to amendment the reference to
POL00103667, which contains an unredacted version of the
same meeting minutes; is that right?
Yes.
Finally, at paragraphs 253 and 254 of your statement you
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You subsequently worked as Global Co-Chairman of Mergers
and Acquisitions at Deutsche Bank before joining UKGI in
November 2017; is that right?
Yes.
Upon joining UKGI, you became a member of the
Shareholder Team for POL; is that right?
Yes.
Did you immediately take up leadership of that team in
November 2017?
No, not until early 2018.
Who was leading the team at the time when you joined?
It was Richard Callard.
In March 2018, you replaced Richard Callard as the
Shareholder Non-Executive Director on the Post Office
Board and remained in that role until May 2023; is that
right?
Yes.
Is it right that, whilst you were serving as the
Shareholder NED on the Post Office Board, the Post
Office was not the only Government asset for which you
were responsible?
That's correct.
Of the various assets for which you had responsibility,
would it be right to say that the Post Office posed, or
was assessed to pose, the greatest risk to the
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shareholder?
Oh, yes, easily, and it involved by far the greatest
part of my time.
At paragraph 7 of your statement you say that you are
responsible for UKGI's risk reporting for its assets and
projects; is that right?
Yes. Something I took over when -- basically when Mark
Russell left UKGI, which I think was late 2020.
Can you please explain in general terms how UKGI records
and reports on risks relating to its assets?
Yes. So this -- it's basically a bottom-up approach.
So each team involved in a project or an asset completes
a risk register and that then feeds up into essentially
two separate processes. The first is it forms part of
the reporting to the Board, so the Board receives
a summarised version of the risk registers from each of
the teams, and then it also feeds into our portfolio
review and project review processes, which are part of
our oversight of what our teams are doing in relation to
their assets and projects.
I'm speaking about how it works today, rather than
how it worked previously.
My next question was: has there been any material change
in the way in which UKGI reports risk during the time in
which you've worked there?
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understood that Post Office had, for several years, been
engaged in an intractable dispute with a group of
subpostmasters concerning issues with Horizon?
Yes.
You also understood that efforts had been made to
resolve the dispute, which included an investigation by
Second Sight and the establishment of a Mediation
Scheme, but these had not been successful?
Correct.
You were also told, were you not, that the Chairman of
Post Office, Tim Parker, had commissioned a review and
had reported back to the Minister in positive terms?
Yes. At least what I think the team took to be
reassuring terms.
Did you request to see any of the material which
underpinned this briefing?
No. I didn't receive the material until later.
Why did you not request to see any of the material
underpinning the briefing?
I think at that stage I was learning, it was obviously
the very start of my induction into Post Office and, you
know, I took what I was being told at face value.
Having now read that material, do you think it would
have assisted you to have read the reports prepared by
Second Sight and the review commission by the Chair at
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Fundamentally, no. I don't think so. I mean, obviously
I wasn't responsible for this beforehand but I think
what's happened is it's -- the basic process is the
same, it's evolved and it's more -- I think it's more
mature and sophisticated probably than it was five years
ago.
What do you mean by that: more mature and sophisticated?
I think it's more integrated than it was. So, for
example, I'm not sure, historically, that risk registers
were regularly part of the portfolio review and project
review processes and part of the papers that came to
those. Now, they are. So it's things like that.
Refinements, if you like, like that.
Thank you. On joining the Shareholder Team, you were
informed that the Post Office was engaged in ongoing
litigation with the group of subpostmasters; is that
correct?
Yes.
In your statement you describe receiving a high level
briefing about the litigation from your predecessor,
Richard Callard; is that correct?
Yes.
This briefing was given to you orally; is that right?
Correct.
From this briefing, would it be fair to say that you
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that time?
Very much so. I think the Swift Review in particular,
which I read in 2020, I think was a very key document,
and informed -- I think, with hindsight, would have been
hugely helpful with the litigation.
Can you be a little more specific as to why you say
that?
Well, I think the main -- for me, the key thing were the
recommendations at the end, and I think when you read
the -- I think four of the recommendations relate to the
system, and the way I read it, when I did read it, when
you take those four together, it basically is saying the
company had never assured itself properly that the
system actually worked, and I think that would have
given me, you know -- so when the management team or the
lawyers were saying in the context of the litigation,
"Well, the system is fine, it works, you know, there's
no systemic problem", comparing that with the Swift
Review recommendations, it begs the obvious question,
"Well, how do you actually know that?" And I think that
would be the obvious question I would have asked, had
I had the Swift Review earlier.
At the time that you received your briefing from
Mr Callard, did you understand that the Post Office had
assured itself that the system worked properly, or did
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you not address your mind to the question at that stage?
Itwas expressed in many -- you know, in different ways,
but the consistent message from the -- I know you're
asking about Mr Callard but I think he said that -- and
I think his main source for this was the first Second
Sight Report, in saying no systematic errors had been
found. He used the term "smoking gun"; there was no
smoking gun in relation to the system. But this was all
reinforced very heavily by the management team in the
company, who consistently said the system is fine.
I mean, you know, I'm paraphrasing but there were
various forms of language that amounted to that.
At this early stage in your tenure, what did you
understand the nature of the concerns about Horizon to
be?
Well, that the system had caused discrepancies in the
branch accounts which had caused losses for postmasters,
and then there was the question of remote access as
well.
So at that time, you were alive to both of those issues;
is that right?
Yes, I mean, I had watched the Panorama programme which
had an impact on me. I remember watching it and feeling
that there was something real there.
Did you give any consideration at this early stage to
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(Pause for fire alarm test)
I think we are now finished.
Okay, yes.
The question I'd asked was in relation to your
perception that the litigation had become the fastest
way to resolve these issues, whether that was
a perception you had when you received this briefing in
early 2018?
No, not that early. It was -- it evolved over time.
I mean, I was learning about the litigation over the
first several months of being on the Board, so it was
later rather than earlier in that period.
Do you consider that there was an opportunity in that
early phase to explore that option of an alternative to
litigation?
No, I think, even in March 2018 when I joined the Board,
I think the conclusion would have been the same.
You've explained in your statement that it was apparent
to you from the outset that an important part of your
role would be to monitor the progress and conduct of the
Group Litigation; is that right?
Yes.
Presumably the purpose of monitoring the litigation was
to enable you to identify any significant risks and to
take appropriate steps to mitigate them; is that right?
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the possibility of those issues, those questions about
Horizon, being resolved by means other than litigation?
I did, and I think, you know, particularly the Horizon
issues -- to me, and particularly with hindsight,
I think the litigation process was not a particularly
good way of resolving this or getting to the facts.
During the course of my introduction and learning about
the litigation, I did think about what alternatives
there might be and it seemed to me at that point --
because it was only a matter of months before the
hearings were due to begin -- that any other process
would be -- wouldn't produce as definitive an outcome
any more quickly.
You know, the advantage at that point of the Horizon
Issues hearings, it seemed to me, was that both sides
were funded, they had expert witnesses, they would have
the benefit of discovery and, you know, a judge
overseeing it. And it seemed to me, at that point in
time, that was going to be the best way of getting to
the bottom of what had happened.
When you say “at that point in time", are you referring
to early in 2018 --
"18 -- yes, I mean, really during the first half of 2018
because during this period I was still sort of getting
up to speed with -- it's about to ~
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Yes.
Would it be right to say that you initially felt
hampered in your role by the reluctance of the Post
Office to share with you and your colleagues in UKGI
information subject to legal professional privilege?
Yes, absolutely. I think it's worth sort of breaking
the role down into a couple of parts, so the first as
a Non-Executive Director, obviously the oversight of the
litigation was part of my role because I was on the
subcommittee. So I needed to understand it and, if you
like, monitor it from that perspective. But then there
was also clearly a need to inform -- keep the Department
informed as to what was going on, as well, through the
Shareholder Team, which I led, and the key element of
that was getting a protocol in place,
an information-sharing protocol, that was an agreement
that essentially enabled Post Office or gave them the
comfort, as it were, to provide the information to the
Department in a controlled way.
And that document didn't get agreed until June 2018,
you know, even though it had been agreed, I think even
before I joined the Board, that there would be
a protocol.
So by June 2018, an agreement had been reached, in
effect, that enabled UKGI to obtain information and
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documents from the Post Office relating to the substance
of the litigation; is that right?
Yes.
Shortly after the agreement of the protocol, you
obtained a copy of the merits opinion produced by David
Cavender QC in relation to the Common Issues; is that
correct?
Yes.
You also held a meeting with the Post Office's General
Counsel, Jane MacLeod, in which you discussed the Post
Office's approach in relation to the 23 contractual
issues in dispute in the litigation; is that right?
Yes, that was around July, if I recall.
Would it be fair to say that you agreed at that stage
that there was an important point of principle at stake
in relation to the litigation, namely the nature of the
contract between the Post Office and its agents, the
subpostmasters?
Yes, but it wasn't just Jane's view that I took on this.
It was also Richard Watson, because we discussed the
merits opinion together.
Sorry, could you just confirm his role, please?
Oh, Richard Watson was the General Counsel at UKGI. So
he was, really, apart from Post Office's lawyers, the
only source of other legal input I had and he and
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of some of them, and the liability clause I felt was the
standout example of that. But I felt, you know,
particularly in the context of a litigation and
a dispute that had been going on for so long, that on
a lot of these, the companies should be looking for
compromise, rather than disputing everything, just for
the sake of it, effectively.
So one of the 23 clauses was, for example, that Post
Office should agree to provide a computer system that
worked. Well, a working computer system was fundamental
to the whole relationship, so it didn't seem at all
unreasonable to me that Post Office should agree to
provide that. And I couldn't under -- Jane MacLeod's
initial response to this, when we had our first meeting
on it, was to say -- I did ask her, you know, "If Post
Office loses on these points, what's your response going
to be?", and she said, "Oh, we'll appeal everything".
So that didn't really make sense to me. It seemed
completely, you know, inappropriate for a situation that
the company found itself in.
You've mentioned the liability clause. What was the
nature of your concerns about that clause?
Well, I thought it was completely unfair. I mean, that
the postmasters should be responsible for all the losses
whether they were responsible or not seemed, you know,
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I worked very closely together on the litigation all the
way through. But his, you know, obviously his views on
the merits opinion were important for me, and the point
about the relational contract and the good faith
elements that flowed from it were viewed, I think,
consistently, not just by Post Office's lawyers but by
all the other lawyers involved, including HSF when they
were part of the team and, actually, Slaughter and May
when they came in to pitch for the work. All of them
said that this point was unusual and would have
significant implications: effectively, an extension of
the law.
And my own experience in business is that, you know,
business contracts in this country are not good faith
agreements and the reason for that is that the lawyers
who draft them, the parties, want clarity about what the
terms are, and good faith obligations create uncertainty
for all the parties involved. So it was an -- my own
take on it was it was a very unusual thing to have in
a business context.
So although you accepted or agreed that that was
an important point of principle, you felt, did you not,
that some of the points raised by the claimants were
reasonable and ought to be conceded by the Post Office?
Yes, absolutely. Not only - well, certainly in respect
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unfair, unethical and I think actually undermined the
basis of the partnership between postmasters and the
company because, in effect, it let the company off the
hook of doing what it should do in supporting the
relationship. So it just seemed completely at odds with
what the contract should be trying to do.
In your discussions with the Post Office's General
Counsel and its lawyers, you described the position on
the liability clause as defending the indefensible; is
that right?
Yes.
In your statement, you expressed a strong sense of
frustration by this stage about the Post Office's
conduct of the litigation.
Mm.
I wonder, please, if we could look at what you say at
paragraph 119 of your statement, which bears the
reference WITN00200100. You say:
"[Post Office] was robust in its view that it should
continue to defend [the liability clause], arguing that
any other approach to liability was not operationally
possible. I recall feeling a significant degree of
frustration about this issue and thinking that if
I could not persuade [Post Office] on this
straightforward point (as I saw it), I would not be able
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to persuade them of the need to compromise on any of the
other contractual issues on which [Post Office] was
vulnerable, such as training and providing
a fit-for-purpose computer system."
Were you concerned by the late summer of 2018 about
the quality of the legal advice which the Post Office
was receiving?
Yes, I was. Flowing directly out of the conversations
I'd had with Jane MacLeod, the very entrenched position
that the company was taking, both of those, it seemed to
me, were at odds with actually trying to reach
a resolution to the dispute, which in the end, one way
or another, would have to be solved.
Is it right that your concerns about the conduct of the
litigation were heightened when Mr Justice Fraser, as he
then was, dismissed the Post Office's application to
strike out substantial parts of the witness evidence
adduced by the lead claimants?
Yes. It seemed obvious from his comments that Post
Office was not handling the litigation -- whatever the
rights and wrongs of it, it was handling the litigation
in a very cack-handed way.
Could we please take a look at the update you received
from the Post Office's General Counsel, Jane MacLeod, on
16 October 2018. It is UKGI00008532.
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a very high threshold for strikeout, and concluded that
we had not established to the necessary standard that
the claimants’ evidence could never be relevant to the
case, given the number of Common Issues, the
‘considerable legal analysis’ each will require, and
what our case on those issues is.
"However he confirmed that he will apply properly
the law on admissibility when it comes to the trial, and
that the November 2018 Common Issues Trial will not rule
‘on matters which concern Horizon or whether Post Office
actually 'breached' its obligations to the claimants
(matters to which most of the disputed evidence goes and
which will be dealt with in later trials)."
If we could scroll down, please, a little further,
Ms MacLeod reported that:
"In deciding the application, the Managing Judge was
critical of our conduct of the case, including
intimating that we were not acting cooperative and
constructively in trying to resolve this litigation
(which criticism was levelled equally between the
parties); and that we had impugned the court and its
processes by making the application for improper
purposes.
"This response is extremely disappointing given the
approach we have been adopting, and his challenge as to
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If we could please scroll to the bottom of the page.
So at the bottom there, we can see an email from Jane
MacLeod addressed to Richard Watson -- you've confirmed
he was General Counsel at UKGI --
Mm-hm.
-- and Joshua Fox. What was his role, please?
He was a member of the UKGI Shareholder Team, he wasn't
a lawyer.
Sorry, he was --
He's not a lawyer.
Not a lawyer?
Mm.
The email is copied to you and Rodric Williams, a lawyer
at the Post Office. It reads:
"Richard, Josh,
"Further to Rod's emails on 9 and 10 October, the
Managing Judge Mr Justice Fraser has now ruled on our
application to strike out as inadmissible parts of the
claimants’ evidence. We received the judgment late last
night.
"We were not successful on the application:
"The application was decided on case management
grounds which the Managing Judge has considerable
discretion;
“Applying that discretion, the Managing Judge set
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the purpose for which we had applied for strikeout is at
odds with comments he had made during various procedural
hearings over the past year. Nevertheless, we are
refining our preparation for trial -- including our
reactive communications plan -- in the context of the
judge's remarks."
In your statement you describe feeling surprised by
the judge's criticisms of the Post Office -- is that
right --
Yes.
-- and concerned by his reference to impugning the
court?
Yes.
As a result of your concerns, you sought the opinion of
Richard Watson, the General Counsel at UKGI, who
requested a copy of the judgment from the Post Office;
is that right?
Correct.
His response, having reviewed that judgment, can be seen
at the top of the page, please. So halfway down there,
from Richard Watson to you on 17 October, so the
following day. So his initial reaction:
"Tom
"You will see I have asked to see the judgment.
"I am concerned that the judge felt [Post Office]
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had impugned the court and made the application for
improper purposes but need to understand the detail.
"I infer the judge is getting a little tired of the
satellite litigation and wants the parties to focus on
the trial and possible resolution of this case.
"His criticism of the [Post Office's] conduct in
their litigation tactics should not influence the legal
issues he has to decide but may be relevant in decisions
‘on costs, not only of the failed application (which
I assume they will have to pay) but also more widely.
"It is easy to be wise with the benefit of hindsight
but on the assumption that the [Post Office] were
concerned some witness evidence was not relevant to the
issues in the first trial I am a little surprised [Post
Office] were advised to make this application. Judges
are very used to disregarding irrelevant evidence and
submissions about that aspect could have been made at
the start of the trial so he was on notice as to the
[Post Office's] position."
Now, those are his initial thoughts before he has
read the judgment.
Mm.
After reading the judgment, he reports to you feeling
very uncomfortable, from the Post Office's perspective,
about the comments made in it; is that right?
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realistic. To me, what this was signalling was that the
company needed to change. It should change the
substance of what it was doing -- and that goes back to
the discussions I'd had with Jane earlier in the
summer -- but I think realistically at this point, that
was -- it was too late. And so the best one could hope
for here was a change of tone or approach or the way the
hearings themselves were handled by the Legal Team. But
it was clear -- they needed to change what they were
doing. That's what Justice Fraser was communicating.
You've just said now, and you said in your statement,
that you felt, really, a sense of resignation at this
stage --
Mm.
-- and a concern that your advice was falling on deaf
ears; is that fair?
Correct.
Did you report your concerns about the Post Office's
conduct of the litigation to either the CEO or the Chair
of UKGI at that time?
I don't recall. To be honest, I doubt it, actually. My
main concern was that the Department should be sighted
on the litigation and the team and I had spent quite
a lot of effort trying to get this meeting for the
Minister and the Permanent Secretary on 17 -- which
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Yes.
He said that it gave him very considerable cause for
concern about the Post Office's litigation tactics and
handling, not to mention the merits of the case itself.
You explain in your statement that you agreed with the
concerns which Mr Watson expressed; is that right?
Yes.
So his very considerable concerns about the litigation
tactics handling and the merits of the case?
Yes.
As a result of the concerns you both had, you invited
the Chair of Post Office, Tim Parker, to read the
judgment for himself; is that right?
Yes.
And you raised the issue with the CEO, Paula Vennells;
is that correct?
Correct.
You were assured by Ms Vennells that a change of tack
would be implemented but it was your perception that
this would likely result in a change of tone, rather
than substance; is that right?
Yes, I think you need to bear in mind that this was
mid-October and the hearings were due to start in early
November, and so this was sort of one minute to midnight
in relation to the hearings, so it didn't seem
22
finally happened on 17 October. So it was right on top
of the strikeout -- it was just before we knew about the
strikeout application.
And that was my priority -- was to get the
Department sort of properly involved, partly in order so
they understood what was going on but also so that they
could challenge the company on the issue of their
contingency planning, which I felt was, you know, very
inadequate, and that was, I think, the area where I felt
the Department, at that stage, could be most effective
in trying to get change.
Did you communicate to the Department the extent of your
concerns about the Post Office's conduct of the
litigation by this stage?
Not in those terms. I mean, the Department, I think,
was kept updated as to what was going on. I mean, with
hindsight, one of the things I think was missing in the
preparation for the 17 October meeting was a pre-meeting
with the Minister and the Permanent Secretary and that
would have been my opportunity to talk about that issue
and, you know, I remain -- my memory is that we tried to
get a pre-meeting. I haven't been able to stand that up
from the documents but that was -- that is my memory.
But I think, you know, I'm still surprised that the
Minister and the Permanent Secretary went into the
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17 October meeting without hearing, having a pre-meeting
discussion with the people handling it day-to-day, and
I think, you know, these concerns would have come out
then.
When it became apparent that you couldn't have
a pre-meeting, in advance of the briefing on 17 October,
did you give any consideration to putting in writing
your serious concerns about the conduct of the
litigation so that the Department could go into that
meeting informed as to the nature of your concerns?
I didn't because it was so late. I mean, I think the
die was cast at that point, in terms of what was going
to happen in the hearings. And a lot of this, I think
you need to also bear in mind that the real levers for
change here, I think, was, as I saw it, given the
interactions we'd had with the Department, was at the
company level.
The company was running the litigation, the Board
was in control of it, and it was really through that
mechanism that, if change was going to happen, it was.
going to happen in the time frame that was available.
And, you know, I was actually disappointed when I did
raise the liability clause issue, which I thought was
completely obvious, you know, I was -- it was
disappointing to me that I didn't get a lot of support
25
Can you please briefly explain what you were told about
the background to that inquiry?
Yes, so I had a very good briefing from Elizabeth
O'Neill who was our General Counsel at the time -- she
was Richard's predecessor -- and, essentially, what
I was told was that there were some very significant
learnings from the Magnox Inquiry that UKGI was
implementing in relation to major bits of litigation,
where our assets were involved.
And the core elements of that were to make sure that
the Department was properly informed as to what was
going on and what the litigation strategy was, that the
Department would have access to the documents, even
privileged material, and the vehicle by which that would
happen would be the protocol, and that there was enough
communication going on, there was the opportunity for
the Department to have formed its own views as to how
the litigation was being approached, so that they could
express views where they had them.
Do you recall whether your briefing with Ms O'Neill
covered the reporting of risk to the Board of UKGI?
No, I don't think it did.
Were you aware that UKGI had produced a written report
into the lessons learned from the Magnox Inquiry?
I don't think I was. I had, I thought, a very
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from -- or I didn't feel I got much support from my
colleagues on the Board.
What did you understand your responsibilities to be
concerning the reporting of risk which you identified in
the Post Office's conduct of the litigation?
Internally, within UKGI?
Internally and to the Department?
So within UKGI there was a risk register. It identified
the litigation as the top risk. And I think, if you
like, that was the responsibility of the team. I mean,
you know, I also had interactions, obviously, with Mark
Russell and Mark actually was very good in coming to
find me and asked me how things were going. So we did
talk relatively frequently. I have to say, I think
with -- my memory is that most of those conversations
really were about the relationship issues I was having
with the company at the time, rather than necessarily
the litigation. But I think, in terms of risk
reporting, you know, the main vehicle was the risk
register.
Thank you. We will come on to that a little later. You
had been made aware, had you not, on joining UKGI, that
it had recently been involved in a non-statutory inquiry
into the award of the Magnox decommissioning contract?
Yes.
26
comprehensive -- I thought Elizabeth had communicated to
me what I needed to know and what I needed to take away
and actually put into action. So it was the protocol,
it was contingency planning, how do you resolve this
dispute, to get those things firmly on the agenda with
the company and make sure those issues were covered.
And then the merits opinion, as well, was I think the
fourth element, so that everyone was sighted on the
merits of the case.
Could we please take a look at that report that was
produced by UKGI. It bears the reference UKGI00009275.
Its title is "Initial review into UKGI's role in the
competition, award and challenge of the Magnox/RSRL
decommissioning contract”. It's stated to be a draft,
dated 25 October 2017. The section of the report which
is entitled "General lessons learned" commences at
page 26. Could we take a look, please, at some of the
recommendations on page 27 of the report.
Just pausing there, having seen the title to that
report, do you recall whether you were shown a copy of
it at around the time that you joined UKGI?
I actually don't think I've seen this report -- it's the
report itself -- until I received it from the Inquiry.
Thank you. Please could we scroll to the bottom of
page 27, where we can see the final bullet point, which
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reads:
"Use the Non-Executive Director appointed by
Government as a means of obtaining better quality
information.”
So that's the recommendation.
"The forthcoming appointment of a UKGI Director as
an NDA NED is an opportunity for fuller feedback on
board discussions (and the performance of the NDA Board
members). To optimise this, specific guidance should be
provided to NEDs to enable them to fully inform the
shareholder in a way that remains consistent with their
obligations to the NDA."
This is obviously a recommendation specific to
Magnox. Did you receive any guidance when you first
joined UKGI about the sharing of information, which you
would have obtained in your capacity as Shareholder NED
on the Post Office Board?
Well, as I said, I think the main vehicle, as
I understood it, for providing information to the
Department was through the protocols. So that the
Department would get privileged material, the merits
opinion, and so forth. And, you know, Richard was
really my -- you know, I was reliant on Richard,
effectively, to -- as to how that operated. So he was,
if you look at the email chains, for example, usually it
29
happened as frequently as they should have. It was
quite hard to gauge, to be honest, how interested the
Department was in this. You know, they'd received
briefings, quite fulsome briefings, actually, on the
background to the litigation, and no questions came
back. Nothing came back. So, you know, from my
perspective, the action was at the board level. The
action wasn't at the departmental level.
On that topic, we can digress because you've raised it,
you suggest in your statement that, when you first
joined UKGI, there was an insufficient level of
engagement by the Department in matters concerning the
Post Office; is that fair?
Yes, it was partly structural because there wasn't
a policy team in the Department at that time. It's
something I raised with Alex Chisholm, I remember asking
him, you know, "Who do I talk to, Alex, if it's not
you?" And I think at that point the penny dropped and
he quite quickly got a policy team in place and I think
they were there from August.
How did the BEIS policy team interact with the
Shareholder Team in UKGI?
It was an evolving picture because it was a small team
to start with, and so, I think, like all of us with Post
Office, there was quite a learning curve for them. It's
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was the lawyers in Post Office communicating with
Richard, who then passed things on to the Department.
Sorry, just to clarify, Richard Watson?
Richard Watson, yes. Sorry.
No, no, we've got several Richards at UKGI.
Did you consider that there were any obstacles to
you reporting risk you'd identified in the Post Office's
conduct of the Group Litigation.
No, absolutely not. No.
Did you recognise that, in your role as Shareholder
Non-Executive Director and as a member of the Litigation
Subcommittee, that you would be a very important source
of information for UKGI and the Department about the
risks to the Post Office arising from the litigation?
Yes, and, as I say, I felt this at the time but I feel
it even more so now, that I think we would have
benefited by a lot more in-person contact. So things
like the --
With the Department?
With the Department, and I've given one example being
the pre-meeting -- the lack of a pre-meeting before the
October meeting with the company, and, you know, there
were times in 2019 when I tried to reach out to the
Department, particularly the Minister, to talk to her
about it. And, you know, they -- I don't think they
30
a complicated business and set-up. So -- but, you know,
there was clearly a much -- a big step-up in activity
and interest after the Common Issues judgment.
What do you think were the practical consequences of the
Department not having a dedicated policy team in the
first half of 2018?
Well, I think it would have been -- you know,
realistically, access to ministers and Permanent
Secretary level is very hard to come by, they're very
busy people, and the discussions you have with them are
focused. We don't -- as UKGI, we don't have regular
touchpoints with them. So when you can drop in
a comment and say, "Oh have you seen that or seen the
other", the interactions we have aren't like that
because we don't see the ministers and Permanent
Secretary on a day-to-day basis. So a policy team does
have those interactions and so I think it would have
been an opportunity for us to talk through more of the
day-to-day concerns, you know, the things that were
perhaps of concern to us as a team, like some of the
issues around the handling of the litigation, that one
way or another the policy team could then have fed up
through their day-to-day interactions, in addition to
whatever they got formally.
Would it be right to say that you saw the policy team as
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a more effective channel of communication through to
the --
Yes.
-- Minister and senior officials in the Department?
Yes, that's, you know, part of what they're there for.
So leaving to one side then reporting to the Department,
to whom within UKGI did you report your knowledge of
risks relating to the litigation?
That was primarily through the risk register.
But to whom -- forgive me, are you saying that you
inputted your knowledge into the risk register?
Team -- the team did.
So, sorry, to whom in the team did you report your
concerns?
So -- well, Richard, primarily. But members of the team
had signed the protocol, so Josh Scott, for example, Tom
Aldred, who was my number 2, were all quite heavily
involved in the litigation, so they knew what was going
‘on, and the team, you know, drafted the risk register.
I mean, I think, with -- again, with hindsight, there
would have been -- you know, I think I could have talked
more to Mark Russell about this, the fact that I thought
that they were -- I didn't agree fundamentally with the
way the company was approaching the common issues
hearing and its unwilling ~ its unbending approach to
33
Inquiry report. So it's the second bullet point from
the bottom, which reads:
"In holding the NDA [I should have clarified, the
Nuclear Decommissioning Authority] Board to account,
UKGI should utilise its own board and its in-house legal
function on consideration of risks. To assist and
develop its role in holding [I think it should be ‘an']
asset's boards to account, UKGI could make more use of
the UKGI internal risk management process to encourage
discussion and debate of the major identified and
Horizon risks being faced by the assets it manages,
especially by drawing on the expertise of the UKGI Board
and UKGI in-house legal colleagues."
Mm-hm.
Now, were you told, when you joined UKGI, that you
should escalate any major risks which you identified in
the Group Litigation to the Board?
Not in specific terms about the litigation but, I mean,
it's obvious as a general point that, you know,
whereas -- where the Shareholder Team has concerns about
a -- big concerns about an issue, you want your seniors
to be aware of it. That's clearly true. And, on this
recommendation, I think, obviously, the learning about
involving legal colleagues was absolutely implemented.
I mean Richard was fully involved.
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the 23 issues. I really don't think it would have made
any difference at that point.
The focus, I think, was -- in relation to the
Department and the Government side of this, to me, the
critical thing was the contingency planning. What would
happen if the company lost? You know, could branches
stay open, for example? I mean, these were quite
critical questions, not -- you know, setting aside
obviously -- the issues like compensation could be dealt
with afterwards but, if there would be real-world
impacts, potentially, on the provision of services to
the public if the litigation was lost.
So the best example is, if Justice Fraser had said
Horizon doesn't work, the current version of Horizon
doesn't work, what happens? Can the company actually
continue to operate? Will people be able to get money
out of branches? Those kind of things.
And I think, you know, those -- it was action on
that that I was trying to lever, to get the Department
to get the company focused on -- really focused on those
questions. That seemed to me the area where I could
get, if you like, most bang for my buck out of the
Government side.
In terms of managing risk within UKGI, could we look,
please, at a further recommendation made in the Magnox
34
On the issue of reporting to the UKGI Board, is it your
evidence that, whether or not you'd seen this report,
you recognised that might be necessary when dealing with
a major risk?
Yes, yes. I mean, the specific benefit that the UKGI
Board brings is -- I mean, obviously the expertise that
the Non-Executive Directors bring and their experience
and they're very good sounding boards, and I did use --
I did benefit hugely from Robert Swannell's input and
Jane Guyett's input during 2018. But I think the other
key element of the UKGI Board is, because we have
Treasury and, you know, in this case, fortuitously
BEIS -- we had BEIS on the Board through the Permanent
Secretary -- it's a very good vehicle for, if you like,
escalating issues that are of concern on the Government
side and, you know, I've used that vehicle as well,
subsequently.
So you very much saw at the time that there was an open
channel of communication to the UKGI Board, where you
were concerned about a major risk; is that fair?
I felt comfortable reaching out to the Chair and the
Non-Executive Directors. I think I wasn't responsible
for reporting to the Board myself so, you know, the
chain of command, as it were, for that were the team
into the management at UKGI, obviously led by Mark
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Russell, and, you know, they decided what should and
shouldn't be reported to the Board. So I can't really
speak to what was in the Board papers at the time
because I didn't see them and I didn't go to the Board
meetings.
But you did on occasion reach out directly to Board
members; is that right?
Yes, and the particular issue I got the benefit of their
wisdom on was the relationship issues I was having with
the company. You know, I was getting complaints about
how, you know, intrusive I was being.
Yes, thank you. We dealt with that in your statement,
unless there's anything you wish to add at this stage
about that?
Shortly after the dismissal of the Post Office's
strikeout application, you established a possible link,
did you not, between the unfairness of the liability
clause and the Post Office's conduct of past
prosecutions?
Yes.
Please could we look at UKGI00008614. This is an email
from you to several colleagues in UKGI dated 6 November
2018, and it's addressed to Richard Watson and Joshua
Fox. You've explained already their roles. It's also
copied to Tom Aldred and Stephen Clarke. Could you
37
prosecute simply on the basis that some cash was missing
without having proof that it had been stolen). I also
wonder to what extent any coercive behaviour by POL
({for example] in encouraging a guilty plea as
an alternative to a fraud trial) could be relevant to
this argument as well -- the judge in the last ruling
mentioned POL's style in previous correspondence as
being dismissive.”
Just pausing there, from where had you obtained the
idea that the Post Office that acted coercively in its
conduct of past prosecutions?
I'm not sure -- no, I don't think I was talking about
past prosecutions here. I think I was talking about its
coercive behaviour generally, in relation to its
handling of postmasters.
Well, you give an example of encouraging a guilty plea
as an alternative to a fraud trial?
Oh, I see, yes, sorry. Yes. I'm sorry. Where had
I got that from? I honestly can't remember. I'd have
to think about it but I can't remember off the top of my
head.
The email goes on to read:
“Is there a risk that some of the implied
contractual terms being asked for by the complainants
could feed this argument [for example] the implied term
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please confirm their roles within the Shareholder Team?
Yeah, so Tom, as I mentioned, was my number 2, he was
an Executive Director, and Stephen was a more junior
member of the team. Stephen was quite heavily involved
in working with Richard on communicating with the
Department about the litigation but, again, the only
lawyer on this list was Richard.
Thank you. So it reads "Richard", it's addressed to
Richard Watson:
"Is it within the scope of the judge's remit in this
case to express a view that prosecutions for fraud or
false accounting were unsafe? Some of the press ({for
example] the Computer Weekly article) seem to be
pointing this way.
"I'm wondering about the relationship between
contract law (where postmasters take on the liability
for missing cash where there is a discrepancy between
the Horizon system and the actual cash in the till --
this is the agency principle in the contract) and
criminal law (where there usually needs to be intent and
evidence that cash was actually stolen). I'm wondering
whether the complainants can argue that even though
contractually postmasters are responsible for missing
cash, prosecutions should not have been made without
actual evidence of theft (ie it is [sufficient] to
38
requiring losses to be investigated before deeming
postmasters liable."
So that's your email to Richard on 16 October. You
appear in this email to have identified not one but two
possible risks. First, that the complainants, by which
I think you mean the claimants in the Group Litigation,
their convictions might be unsafe because, absent data
from the Horizon system, there was no evidence that
money had been stolen. Would you agree with that?
Yeah, I mean in very simple terms, if you can't
establish a contractual claim, how do you establish
criminal -- a conviction? I mean, in very simple --
much simpler language than this. That was what I was
trying to understand the relationship between those two
things. And it was a question -- I mean, this was very
much a question. I hadn't -- you know, this was me
trying to understand the consequences of the litigation
and adverse judgments in the absence of help on this
from Post Office because, you know -- and it
particularly struck me with hindsight that, in all of
the contingency planning conversations we had with Post
Office at this time, convictions never came up.
In other words, the risks they identified, one of
the risks they -- they didn't identify as a risk that,
if we lose the litigation, there will be unsafe
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prosecutions.
Q. You say they didn't raise that with the Board?
Yeah.
Q. Does it follow that the suggestion that Post Office has
encouraged a guilty plea as an alternative to a fraud
trial was not something which had been suggested to you
by the Post Office --
A. No, it -- this came from --
-- that there was a risk to that effect?
A. Correct, yes. This was something I'd extracted
essentially from commentary, I think external commentary
is my best guess as to where I got this from.
Q. I think, in fairness to you, you're making a connection
which many others hadn't yet made at that time?
A. Well, it certainly hadn't been made by Post Office
within my hearing, that's for sure.
‘SIR WYN WILLIAMS: Had it been discussed in any Litigation
Subcommittee, for example?
A. Not in these terms, Sir Wyn. I think the backdrop to
this on convicted postmasters was that it had very
little profile in any of the discussions we had -- in
the Board at this time or in my discussions with the
management team. There was a very strong sense,
I think -- two things I think I took away from it, and
I can't date when these -- when I got these impressions,
41
>
2
Issues judgment -- was that the company couldn't
establish a claim, a contractual claim, ie the money has
gone but it's not the postmaster's responsibility for it
missing, how can you prosecute them, on what basis? You
don't have the fact that the money is even missing, let
alone whether they intended to steal it.
SIR WYN WILLIAMS: Well, all right, fine. Back to you,
Ms Hodge.
A. I'msorry, I'm possibly not answering your question very
helpfully here but I don't think it came from -- I mean,
this was just my thought process.
‘SIR WYN WILLIAMS: All right.
MS HODGE: You said, Mr Cooper, in your evidence just now
that the consistent advice you received, including from
Brian Altman QC was that a guilty plea really was the
end of the matter.
A. Yeah.
Q. But you seem -- you were raising here the possibility
that that might not be right, if the Post Office had
coerced a subpostmaster into submitting a guilty plea,
in return for dropping a more serious charge?
A. Well, even if they hadn't, I mean, the fundamental point
was, you know, if the money -- if the postmaster wasn't
responsible for missing money, then how could they be
guilty of a crime?
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but the first was that the majority of people who'd been
convicted -- and we had no idea about numbers -- but the
majority had pleaded guilty to the offence concerned
and, secondly, that a guilty plea would, if you like,
trump anything else.
If a postmaster had pleaded guilty, they were guilty
of something and, you know, it didn't -- effectively,
what had happened to get you there and to get the
conviction in place, sort of didn't really matter. And
that view, I have to say, persisted for a very long
time. I remember, you know, when Brian Altman first
came to the Board in early 2020, that was my takeaway
from the first meetings we had with him.
So this was a very strong view.
SIR WYN WILLIAMS: Sorry to cut you off, I'm sure that these
issues became more and more prominent as the litigation
unfolded, and after it, but Ms Hodge is rightly pressing
you about your, if you like, perceptiveness in realising
this problem before the Common Issues trial had even
taken place and we were wondering how you were so
perceptive, in effect.
A. Well, to me, it was a logical question, and it was the
link. As I say, to me what was an obvious question,
which was, if you can't -- if the effect of the Common
Issues judgment would be that - or an adverse Common
42
Q. Did it occur to you at the time that, if the points you
were raising in this email were correct, that a very
serious miscarriage of justice might have occurred?
A. I think so, but I -- this discussion I don't think
developed. From memory, I don't remember receiving
an answer to this email and I think I moved on because
there were other things going on. And I didn't really
come back to it until after the Common Issues judgment
and when we were discussing the appeals strategy.
Q. Does it follow that, when you first identified this
risk, you didn't therefore ask the Post Office for
information about the number of prosecutions which had
been brought against subpostmasters?
A. No. And I -- again, with hindsight, I don't think the
company would have been able to answer the question
because when we did get the information, it took months
to get that, the number. The number of 750, I think it
was roughly, Post Office prosecutions, and 950 in total,
it took the company months, and months, and months to
get that data.
Q. Did you take any steps to bring your concerns to the
attention of your colleagues on the Post Office Board?
A. I don't remember. Like I say, I think this discussion
sort of stopped. It didn't progress and I don't
recollect exactly why.
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Q. Having raised your concerns with Mr Watson, the General
Counsel, what, if any, action did you expect him to take
to manage or mitigate the risk that you'd identified?
A. Well, I think, if we'd followed this on and if he'd
encouraged me, I think I would have raised it at the
Board and really tried to get the company's response to
this, the Legal team's response.
Q._ In terms of your reporting internally within UKGI, did
you report your concerns about a possible miscarriage of
justice to either the CEO or the chair of UKGI at the
time?
A. I think it was identified in, you know, obliquely at
least, in the risk registers, but I didn't raise this
particular issue, as I say, because it didn't really go
anywhere at the time.
MS HODGE: Sir, that may be a convenient point to take our
first morning break. I've come to the end of that
particular line of questions.
SIR WYN WILLIAMS: Yes, can I just clarify with you,
Mr Cooper, my understanding of your evidence up to the
beginning of the Common Issues trial. Summaries can be
deceptively simple, so if you think I'm being too
simple, please say so.
But the impression, the strong impression, I have is
that in relation to what I'll call one of the central
45
the 23 implied terms, a compromise could have been
reached on those so that the liability clause would have
been, you know, fair, and the company would have agreed
to provide a computer system that worked. It seemed to
me those areas were entirely open to compromise and then
you wouldn't have needed the Common Issues hearing. You
could have just focused on the Horizon Issues.
SIR WYN WILLIAMS: Yes, all right. I understand fully.
Thank you, Ms Hodge, for delaying the break so that
I could clear my head. So what time shall we start
again?
MS HODGE: Shall we return at 11.15?
SIR WYN WILLIAMS: Fine.
(11.00 am)
(A short break)
(11.15 am)
MS HODGE: Good morning, sir. Can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you, yes.
MS HODGE: Thank you, sir.
Mr Cooper, I'd like to ask you some questions now
about the risk register which was maintained by UKGI in
relation to the Post Office. You've said earlier this
morning that the risk register was the principal method
by which UKGI recorded and reported significant risks in
relation to each asset; is that right?
47
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issues in the Common Issues trial, namely whether the
contract with subpostmasters was relational, all the
legal advice that you had received, both from Post
Office's lawyers acting in the litigation and from UKGI
lawyers, was that the likelihood was that this was not
a relational contract?
Correct, and --
‘SIR WYN WILLIAMS: But that could only be resolved by
A
litigation because the parties were so far apart.
Correct. I think from --
SIR WYN WILLIAMS: Then, secondly --
A.
Sorry.
SIR WYN WILLIAMS: -- and then you can put your caveats, if
2
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you may, but you thought that some of the issues which
were identified for resolution in the Common Issues
trial ought to have been compromised, in the sense that
the Post Office should have taken a different tack
towards certain specific points and the one you
highlighted is the liability clause?
Yes. I mean, I didn't take it to its logical conclusion
but it seemed to me where -- you could argue that where
the common issues should have ended up, and I think what
I was reaching for, was a scenario where the parties
could have agreed that it wasn't a relational contract,
because that wasn't necessary and was unusual, but that
46
Correct.
Is it right that there was a specific register
maintained in relation to each asset, including the Post
Office?
Yes.
Did you have any direct input into the contents of the
register?
Yeah, as a team we were responsible for it. So I can't
say that I looked at it every word, every time but, you
know, collectively we were responsible for producing the
risk register.
So it was a document that was held and controlled by the
Shareholder Team; is that right?
Correct.
Therefore, circulated amongst the members of the team --
Yes, usually.
-- and from there, where did it go?
Then it fed up into the management at UKGI -- I can't
remember the individuals -- but it then informed the --
the purpose of it -- you know, one of the main purposes,
as I said earlier, was to inform the Board report that
UKGI Board received, so certainly today, and I think it
was true then, the -- effectively, the risk registers
were summarised in the Board reports, so that the key
risks to the individual assets were brought out into the
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Board reporting to the UKGI Board.
Please can we take a look at a copy of the register
dated 29 June 2018, so this is about six months into
your tenure. It bears the reference UKGI00021096.
So this is June, you said?
June 2018.
Okay.
Thank you, that's the covering page. If we could go to
the Post Office tab, please. Thank you. We can see
there, if we scroll to the top, please -- I'm
grateful -- we have the civil litigation risk there at
number 11. But if we just pause here, so there's
several columns. The risks are numbered in the
left-hand column, we can see there "Summarised" in the
next; a risk overview is provided; then an impact; the
type of risk identified; a RAG rating; mitigation;
overview; and mitigation rating; further mitigation
actions; and, finally, comments on the current status.
Can you see those at the top?
Yeah.
If we scroll down then, please, to number 11. So this
is described as “Possible civil litigation against the
Post Office". That's not right, of course by this stage
we're in June 2018 so the litigation is well underway?
Correct.
49
So is it your understanding that text was inherited from
an earlier copy of the register?
I believe so.
It goes on then, in the next column, in terms of the
impact of the risk, to say there's:
"Potential for significant compensation claims if
civil or criminal courts rule against POL. More likely
however, and certainly in the short-term, is that this
continues to be a significant distraction (and cost) to
the business as they defend their actions.”
Now, you've said earlier this morning that you
believe that the risk of criminal convictions being
overturned had been flagged in the register. Is this
entry the one to which you were referring?
Yes, I mean, it says, "acted illegally", and it talks
about criminal courts. So, you know, it's not stated in
perhaps as clear a language as we might like, with
hindsight, but I think it's there.
In relation to the RAG rating, please, this is said to
apply to the legal, reputational and financial risks.
Are you able to explain how the figures shown there were
calculated?
Well, shall I -- is it worth just using a stupid analogy
to explain the two sets of columns in grey? So if you,
for example, think about your house and the risk of why
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Your name is shown there. Do you know why that is?
Probably because I was the main person on the team
involved in the litigation.
So would that mean that you were the primary source of
information or you, in fact, inputted the information
that we see here? Can you --
No, I didn't input the information. I actually think
some of this -- a lot of this wording was inherited from
the previous team and then it evolved over time as there
were more developments in the litigation.
What is the significance of the red text, please, do you
know?
I'm sorry, I've no idea.
If we look, then, first under the column "Risk
overview’, it reads:
"Civil litigation and/or Court of Appeal processes
judge that POL has acted inappropriately or illegally.
Even in the absence of such a finding ongoing risk that
they..."
I think there's some text missing there.
There may -- it's in the top:
"... that they continued to be perceived to have
acted in that way."
"In that way", thank you.
Yeah.
50
fire in your house, the left-hand column is saying,
"What's the chance of my house burning down and what's
the impact of that?", yeah? And then on the right, it's
saying, "After I've taken mitigation", in this case
buying a fire extinguisher or a fire blanket, my
probability is reduced. But, in this case -- so
essentially this is what this is saying: if there wasn't
mitigation, the probability of there being serious
consequences from the litigation is high, that's what
the 4 means in probability, and that reduces to 3 as
a result of the mitigation.
The impact of the event is very high, that's 5, and
it's very high in both cases because the mitigation
doesn't -- in this case, with the litigation, doesn't
reduce the impact of the -- of a negative event.
So far as you were concerned, did that accurately
reflect the impact risks that you perceived in relation
to this litigation?
Yes, I think it was always perceived that -- and if ~
perhaps we could scroll up to the -- would you mind
scrolling up to the top and to the heatmap?
I don't think we have a heatmap on this version of the
risk register.
Oh, okay.
I'll take you to another version --
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But I think it’s important, if you do have another
version with it, it might be helpful to look at it.
The point I was going to make is that this was the
top risk. It was identified as the top risk affecting
Post Office at the time. It was in the top right-hand
corner, it was red, both in terms of probability and
impact and so I think, you know, from a team's
perspective it was clearly identified as, you know ~
and there were many risks attaching to this company.
I mean, as you've seen, there are 12 items listed but it
was the -- you know, it had the potential to be the most
significant issue.
Now, the Inquiry has heard evidence from the chair of
UKGI, Robert Swannell, to the effect that the Board was
first alerted to the risks of the Group Litigation in
January 2019.
Mm.
Given that this was recognised to be one of the greatest
risks relating to the Post Office why is it, do you
think, that it did not reach the Board of UKGI as
a significant risk until January of the following year?
It's very hard for me to say because I -- I think I've
explained this, there's a link in the chain, another
link in the chain between this document and what the
Board sees. So what the Board sees is a summarised
53
That, in fact, occurred in October, is that right,
that meeting?
Well, the meeting with the company, as I think I said.
So a few points on this. So Andrew Griffiths was the
Minister at this time but, obviously, he left quite
quickly, I think, and then Kelly Tolhurst arrived in
July. She actually was the third Minister we'd had in
a period of some months. So that changed and then the
briefings we'd provided, we'd provided a briefing,
I think, by this point, to the Permanent Secretary,
possibly to Andrew Griffiths, as well, I don't recall
but Kelly Tolhurst received the briefing papers,
I think, later on after -- in advance of the October
meeting.
Was the turnover of ministers an issue for UKGI in
relation to its communication reporting of risk?
It's always an issue because you don't have continuity
and, you know, naturally it takes them time to get
appraised of what's going on. They have to do their own
priorities. I mean, you know, it's not -- it really
isn't helpful to try and get good decision making.
The final column, Q, this concerns the current status,
so would be the most sort of up-to-date information as
at June 2018, presumably.
Mm-hm.
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version of these risk registers and, obviously, my team
wasn't involved -- as far as I know, I don't think the
team was involved in preparing those summaries.
So I think what may have gone wrong here is that the
process of summarising these things didn't feed through
properly to the Board paper.
Thank you. Then just before we move on to the next
register, just dealing then with actions taken to
mitigate risk, so in the column K, that is the
"Mitigation Overview", which identifies that the Post
Office have their own external legal advisers employed
on the civil litigation, including a silk, and they
continue to update UKGI. Now, were you -- this is
obviously late June. You began to have some quite
significant concerns, did you not, about the quality of
the legal advice that the Post Office was receiving?
Yeah. But this was before. I mean, if it's June, that
was before I really got into this topic.
Then if we look at column P, which I think bears the
heading "Further mitigation actions”, it confirms that:
"UKGI have briefed the Minister Andrew Griffiths and
will keep ministers, SpAds and the Permanent Secretary
update at key points through the new disclosure
protocol, with POL's legal counsel to provide an oral
briefing on 10 September."
54
It reads:
"POL preparing for the first main hearing in
November to determine scope of contract between Post
Office and postmasters and concurrently the second main
hearing on the integrity of the Horizon IT System. UKGI
has put in place a disclosure protocol with the Post
Office to keep the Permanent Secretary, BEIS and the
Minister updated at key stages while protecting legal
privilege integral to the Post Office's defence. Post
Office's counsel to give a briefing, as we've discussed,
particularly to cover contingency planning."
That's a matter you've raised in you evidence this
morning:
"No inherent increase in risk in this case at this
stage."
Does that reasonably fairly summarise where you were
in late June 2018?
I think so, and I think what -- perhaps we'll talk about
this in the later versions of this, but I think it's
important to understand that this risk register at this
stage, given the information we had, could only
articulate the risks at quite a high level. If you --
another word for contingency planning that we were
asking the company to do is identify the risks, "Please
tell us what the risks are of this going wrong and what
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the consequences are’; it's another version of a risk
register. And that would have -- I think, had we had
good contingency planning from the company, it would
have informed and allowed us, enabled us to produce
a much better risk register that was, you know,
particularly with the benefit of hindsight well
articulated.
Can we please take a look at a later copy of the
register, dated 31 December 2018. So about six months
later. It bears the reference UKGI00015921. So this
register contains the heatmap to which you referred.
Mm-hm.
Was there a particular point you wish to raise in
relation --
I'm hoping, given what I've said, that number 9, which
is in the top right, is the litigation.
I believe it bears the same reference, if we scroll
down, please?
Yeah.
So you're saying here, really it's been flagged on the
map as the most serious risk?
Yeah.
If we look at the summary, beside the register,
please -- sorry, besides the heatmap, it contains an
overview at point 1; at point 2, an overall delivery
57
You've said earlier in your evidence that you're not
sure why the risks relating to the litigation didn't
penetrate up into the UKGI Board until January 2019. Do
you think that the practice of pithy summaries like this
might explain why it didn't necessarily register, absent
a heatmap, as a very serious risk?
Possibly. Possibly. But I think, you know, given that
it's number 9, it's in the top right and there's a much
better explanation below, I don't think it's much of
a leap to identify what's really going on from this.
If we scroll down, please, to page 4, we see the detail
there in relation to risk number 9. So now described as
"Civil litigation against the Post Office". You're no
longer named underneath, it's Stephen Clarke who's
named. Do you know why there was a change of the guard?
I don't.
So the first column is substantially the same as it
appeared in the risk register to which we referred in
June. There's an additional entry under the impact
column, where it reads:
"Even a positive legal outcome is likely to have
considerable comms fallout for Post Office and UKGI.
The complainants have a track record of successfully
airing their grievances through the media."
So picking up again on that interest in the press
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risk; and at point 3, a summary of the reputational
risk. That's registered to be high, and it reads:
"There is significant political risk in the Post
Office Network and there are a number of clear policy
objectives. Risk is mainly centred on these areas but
it can also be linked to executive management and
remuneration issues."
It then deals with the ongoing litigation.
"There is an ongoing [Post Office] litigation case
which could potentially generate a high level of
negative coverage. The UKGI [Post Office] team are
aware of the pressures and are working [collectively]
with Post Office Limited to manage the risks away."
Do you think that accurately reflected the level of
risk at that time; is that a fair summary, do you think?
No, I don't think so. I think the sentence I would
rewrite or should have rewritten at the time, was one
about there is an ongoing litigation case which could
potentially generate a high level of negative coverage.
I mean, I don't think I or the team were thinking about
this from a coverage point of view. What we were
thinking about was the consequences. As I've said, the
primary focus, certainly with the Department, was to get
the contingency planning done. It was what are the
consequences of a negative judgment?
58
reporting, rather than the substance of the litigation;
do you know why that is?
Actually, yes, and I -- again, I repeat what I said
earlier. I think there's too much focus here on
communication, relative to actually what the team was
doing. I also think the word "distraction" in here is
inappropriate as well. I mean, the point that was
trying to be made here is that the absorbed -- it was
absorbing a significant amount of management time, which
obviously diverted them away from doing other things.
But it -- the implication here is that the word
"distraction", I think, has connotations, which I think
again weren't in our mind at the time.
If we go on, the RAG rating remains the same, as it did
in June. We can see there the rating of 20. In the
previous version, I think that wasn't visible, but it is
the same, so 4 for probability; 5 for impact; an overall
rating of 20.
Under column K, the "Mitigation Overview" repeats
that Post Office have external legal advisers including
a silk:
"They continue to update UKGI through the Board
where UKGI's Non-Executive Director [you] sit and
directly to UKGI's legal counsel, under the disclosure
protocol."
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Now, by this stage, we are now in December 2018,
it's right, is it not that you had lost confidence in
the Post Office's Legal Team?
Yes, yes. But I don't think that -- again, I think it's
easy to conflate my personal views with what we were
still hearing from the company, so in December, which
obviously was after the hearing had started but before
the judgment arrived, the company was still, you know,
expressing great confidence in the outcome of both
hearings. So I think it's -- you know, it's important
that one person's perspective doesn't necessarily colour
what goes into these things too much because, you know,
I might have been right, I might have been wrong. And
I think the important thing was to -- here, was to try
to convey, you know, if you like, the expert, the expert
view, as it then was.
Well, starting with you've accepted, I think, that you,
as Shareholder NED, was the primary source --
Yes.
-- of reliable and accurate information about risks
relating to the civil litigation?
Yeah.
This is a register maintained by UKGI of the risks that
it has identified --
Mm-hm.
61
any advice to ministers, maintaining a position that
Government will not comment on an ongoing legal issue
and will work with POL and the Post Office and BEIS
Policy/Comms to review this depending on outcome. First
judgment on first trial expected in January."
So that appears to acknowledge, does it not, that by
this stage BEIS are quite closely involved, in the sense
that their own Legal Team are receiving advice and input
and they're feeding that advice up to their ministers?
Yes, and I mean that had been true for some time, at
this stage.
Because you, I think you expressed earlier in your
evidence a concern about a lack of engagement on the
part of the Department until after the Common Issues
trial. What this appears to be suggesting is that the
Department was already quite actively engaged.
I think what this is conveying is that the Department
was receiving the information. What I was trying to say
earlier was that we weren't getting a lot back. There
weren't many questions coming out of that information.
So we'd provide a briefing, and there was no -- it was
noted or received and -- but we wouldn't get questions
back or we wouldn't say, "This is important, you know,
or interesting, please can we have a meeting to discuss
it?" That was the bit that was missing. So, yes, they
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~ in relation to the civil litigation and it puts
forward, as positive mitigation, that the Post Office
have an external Legal Team and advice from a silk --
Mm-hm.
-- in whom you had, by this stage, lost confidence. Is
that not somewhat inaccurate and misleading and not
reflecting your views as Shareholder Non-Executive
Director about the concerns you had?
I actually think, to bring that out, you would probably
have changed the probability. I'd have -- you know, we
would have probably tried to stay, instead of a 3, it
should be a 4 for probability of losing and, you know,
we've put it as a 4 because Tom Cooper thinks, you know,
the lawyers have got it wrong. Again, I think I --
I don't think that's, you know, yes, that is a possible
argument.
Under column P, this relates to "Further Mitigation
Action" and initially repeats what was recorded in the
earlier risk register in June, in that:
"UKGI is keeping ministers, SpAds and the Permanent
Secretary updated at key points through the disclosure
protocol and POL's legal counsel provided an oral
briefing on 17 October."
It goes on to say:
"BEIS Legal are also up to speed and contributing to
62
were informed but the point I was making earlier about
engagement was there wasn't much coming back.
Under the final column Q, which is "Current Status",
a slightly lengthier entry this time, it reads:
"POL awaits judgment on the first trial to determine
scope of contract [so as previously expected], which is
expected mid to late January and is making contingency
and Government arrangements to deal with a 'bad
judgment and taking a decision on whether to appeal
such a judgment. At the same time POL is preparing for
the second trial in March 2019 on the integrity of the
Horizon IT System. UKGI has put in place a disclosure
protocol with POL to keep the Permanent Secretary, BEIS,
and the Minister updated at key stages whilst protecting
legally privileged information.”
It goes on to confirm that:
"POL's legal counsel briefed the Minister and the
Permanent Secretary on 17 October. UKGI continues to
forward legal updates from POL's counsel to the
Minister."
Forgive me, there's two separate -- thank you:
"POL's Group Communications Director has met BEIS,
(Policy and Comms) and UKGI on 3 January [sorry, will
meet, presumably] to discuss comms ahead of the judgment
and will keep in regular touch. There has been
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considerable media interest so far, Daily Mail,
Telegraph, Financial Times, Computer Weekly, in
particular, while Nick Wallis, freelance journalist with
crowd funding responsible for a Panorama feature in 2015
is covering the case every day through a dedicated
website and regular Tweets. At the request of the
Permanent Secretary, UKGI's legal counsel briefed Her
Majesty's Treasury on the case on 13 November and
discussed the settlement process should this be
required. UKGI will comprehensively review both risk
and mitigations once the first judgment is handed down."
Would you agree that this was quite a process-driven
factual update, which did not offer any real insight
into your own thought processes as shareholder on the
Post Office Board?
Correct. Yeah.
It's right, is it not, that your understanding of the
risks relating to the Group Litigation had changed quite
significantly in the period between June and December
2018?
Yes, from a personal perspective, yes. I was quite
gloomy about the way Post Office was handling it.
I mean, I think -- but, you know, I'm not a lawyer, and
I think you need to just bear that in mind: that my own
personal views were not -- were never the best informed,
65
litigation. One was Common Issues the other was Horizon
Issues, and the Horizon Issues, at least to my way of
thinking, was, in a way, more important than the
contractual issues.
And no one was -- I had no view, and no one was
telling me that -- at that stage, that Post Office was
going to lose on the Horizon Issues. So the fact that
I had strong views about the way the Common Issues was
being handled didn't impact on -- actually, particularly
strongly on the bigger issue, which was what's the
Horizon Issues judgment going to be?
So I don't think -- I mean, this picture and this
scoring, I don't think would change -- even if my views
had been fed in here about the way the Common Issues had
been handled, I don't think actually it would change the
picture in an overall sense in a substantive way,
because the big issue was, you know, whether Horizon
worked or not.
You suggest that was the principal issue. But you had
already established, had you not, a concern about the
liability clause and its link to a potential miscarriage
of justice. So the Common Issues trial itself
potentially gave rise to very, very significant risks,
didn't it?
I agree with that and I had figured that out but, as
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because I'm not a lawyer, and so what this is trying to
be is an objective description of what was going on, and
so on. But I was -- you know, effectively, I was in
a minority of one, here, in terms of -- you know, in
relation to the Post Office. I was the only person on
the pitch who was -- at least it felt that way -- who
was questioning, you know, the litigation and how it was
being handled, and so on.
So I think, you know, if you're going to put in
something that's seeks to be reasonably objective there,
it can't - you can't colour it too much by the opinions
of one person who's not objective -- or sorry, not --
I don't mean not objective -- is not an expert.
It's right, is it not, that the very purpose of your
role as a Shareholder Non-Executive Director on the
Board was to provide oversight --
Mm-hm.
-- and to report back any risks you identified —-
Yes.
-- to UKGI and the Department?
Yes. That's right. But what was the risk I'd
identified? The risk I'd identified was that Post
Office had was -- would -- had missed an opportunity to
solve the Common Issues hearing in a consensual way.
But the -- you know, there were two parts to this
66
I said earlier, it kind of -- it didn't go anywhere, and
again, had I -- had that topic been followed up,
particularly with Richard, if I'd got support and
encouragement for that from Richard, it might well have
appeared in here but, more importantly, it would have
surfaced at the Board, I'd have raised it at the Board,
which is, you know, the place where change could be
affected more quickly than through the UKGI channel.
I'm not saying the UKGI channel didn't matter but
what I'm tying to say is, if you actually want stuff to
change, the place that it was going to happen was at the
Post Office Board.
Is that entirely right? Is it not right that UKGI,
through the Department, had the power to effect change
in the way in which the Post Office was conducting its
litigation?
Yeah, but it's all -- you know, it's slower, for
a start. You need to persuade lots of people. You've
got to persuade your CEO, you've got to persuade your
Board, you've got to persuade the Department, all of
which takes time. It can be very effective but this
is -- you know, this is all happening in short -
a short timescale.
Looking back, do you think that your senior colleagues
in UKGI and the Board of UKGI would have benefited from
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knowing a bit more, or indeed at all, about the very
strong subjective views you had about the conduct of the
Group Litigation?
Possibly, yes. But I -- what the consequences of that
would have been, it's very hard to say. I think it's
very speculative to say that that would have made
adifference. I mean, remember, this is December now.
So it's all happening. It's all happened, you know, the
hearing has started.
I mean, looking back, do you consider that the Post
Office risk register was an adequate tool for recording
and reporting the risks relating to the civil
litigation?
No, I don't agree with that, I'm sorry. I think it's ~
we can discuss the wording and whether it could be
worded better but I think the critical thing, which is
this risk was identified as the key risk, it was in the
top right, it was red, on all counts, I think that
conveyed the key issue. It has the key issue.
I'd like to move on to another topic, please, concerning
your reaction to the Common Issues judgment. You
received an update from the Post Office's General
Counsel on 8 March 2019, in which she confirmed the
outcome of the Common Issues trial; is that right?
Yes.
69
characterises as ‘extraordinarily partisan’
"He struck out the key contractual provisions which
require postmasters to account to Post Office, and
"He has stated that the Branch Trading Statement --
which is the key document on which Post Office relies
for postmasters to account for cash and stock in
branches -- cannot be relied on as a statement of
account."
She goes on to say that the judgment will be handed
down later in the week, possibly the following week,
and, in the meantime, the Post Office are working on
grounds for appeal.
She confirms:
"[The Post Office has] activated contingency
planning in order [to have] communications and detailed
plans available and ready to launch at the point the
judgment is formally handed down."
On receiving this update from the General Counsel,
you requested to see a copy of the draft judgment, did
you not?
Mm-hm, yes.
In your statement, you describe feeling shocked when you
learned the basis on which the Post Office had pursued
certain arguments in the Common Issues trial; is that
right?
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Please could we look at that email, which bears the
reference POL00103411. If we scroll to the bottom of
page 1, please. Thank you. We can see there the very
start of an email from Jane MacLeod on 8 March 2019, and
it reads -- and just to confirm we don't have the
recipients there. To the best of your knowledge, was
the email addressed to the same individuals we see
copied in to your email of 8 March at 4.28 pm?
Yeah, I think this would have been a reply all from me.
Thank you. So if that's the case, it's an email to the
members of the Post Office Board?
Yeah.
It says:
"All
"We received the judgment this morning in the Common
Issues trial. It's 325 pages and very detailed, and as
a result, we've not yet read it completely or fully
understood all the arguments. However a high level
review indicates:
"We have lost on all material points
"The judge has criticised Post Office
comprehensively -- both as to our historic operations
and behaviours and our conduct of the case
"The judge accepts the evidence of the lead
claimants but is sceptical of our witnesses who he
70
Absolutely, yes.
You also state that you agreed with the judge's
characterisation of the Post Office's position in the
litigation as being unrealistic; is that right?
Yes, yes.
Please can we take a look at what you say at
paragraph 167 of your witness statement, please. It's
at page 79. Paragraph 167, thank you. This paragraph
reads:
"I was also shocked by some of the flaws pointed out
by the judge in [Post Office's] processes, including for
example the inability of [subpostmasters] to effectively
dispute items, the unfairness and oppressive effect of
having to ‘settle centrally’ before disputing an item
and the inadequacies of the branch trading statement.
I thought POL's Legal Team would have been more fully
aware of these points in the run-up to the Common Issues
hearing. There were major defects in [the Post
Office's] processes and therefore in [Post Office's]
case. But none of these issues had been brought to the
attention of the subcommittee nor, if they were ongoing
in [Post Office's] business, the [Audit and Risk
Committee] and the Board. I also reflected that these
flaws did not seem to have been brought to light in the
past by any of the safeguards that the company had in
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place, including internal and external audit. It was
also shocking to learn that some of [the Post Office's]
witnesses, particularly Angela van den Bogerd, had been
heavily criticised. Justice Fraser said she had not
been frank and had sought to mislead the court. My
view, which I believe was shared by other members of the
Board, was that the Legal Team had comprehensively
mismanaged the litigation.”
Does that accurately reflect your response at the
time to reading the Common Issues judgment?
Yes.
You make reference in the final sentence to
mismanagement of the litigation by the Legal Team, is
that intended to be a narrow reference to the Post
Office's Legal Team or are you referring more broadly to
the Post Office's wider team of external solicitors and
independent counsel?
Oh, all of them collectively.
A meeting of the Post Office Board was convened on
12 March 2019 to discuss the judgment; is that correct?
Yes.
That meeting took place by telephone and was attended by
David Cavender QC; is that right?
Yes.
When he advised the Board that the Post Office had
73
judgment, you say in your statement that you considered
that he was not considering the judgment sufficiently
objectively; is that right?
Yes, I mean it struck me that there were significant --
on a reading of it, a lot of what Justice Fraser was
saying, it seemed to me, made total sense and I thought
it - personally, I thought it was premature to talk
about appeal when we hadn't actually evaluated the
judgment itself and worked out which parts of it the
company actually agreed with and which parts they really
disagreed with and on what basis they disagreed with
them.
It seemed to me that was an important exercise to go
through first before you started talking about appeal.
So, in a nutshell, your concern was that there was
a knee-jerk reaction --
Yes.
-- by the Legal Team that the judgment needed to be
appealed in its entirety?
Yes.
You received an update from the Post Office's General
Counsel on 15 March, so three days later, concerning
further advice which the Post Office had sought on
bringing an appeal against the judgment; is that
correct?
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strong grounds of appeal, you questioned that advice; is
that right?
Well, I think, if I recall, the preamble -- there was
important preamble to understand what had gone wrong and
I remember challenging Jane MacLeod, for example.
I mean, one of the things that horrified me about the
ruling was the argument that Post Office's counsel had
put forward that -- in relation to contracts, that even
if a subpostmaster had not signed their contract, they
were somehow meant to be bound by a contract that was
left in a cupboard somewhere in the branch by their
predecessor. And I thought this was risible as
an argument.
And I challenged Jane on this in the meeting and
said, "Who advised us -- who advised the company to
argue this?" And she said something like, "Well, if we
hadn't done that the whole Post Office edifice would
have crumbled", and it was at that point that I thought,
you know -- I'd completely lost confidence in the Legal
Team at that point.
So before we got to the appeal part of the
discussion, you know, there was a short post mortem on
the hearing itself.
So far as Mr Cavender's advice is concerned, to the
effect that there were strong grounds to appeal the
74
Yes.
Could we take a look at that update, please, which can
be found at POL00103438. If we could scroll to the
second page, please. Thank you. We see an email from
Jane MacLeod to you and Tim Parker, Chair of Post
Office. It reads:
"Dear Tim and Tom
"As flagged on the Board call on Tuesday, we have
sought further advice on appeals and as to whether we
have grounds to request the judge to recuse himself on
the grounds of bias."
Under the heading "Advice", it reads:
"We have sought advice from Lord Neuberger who
stepped down last year as the President of the Supreme
Court (and as such was the highest judge in the UK). We
sought his views as to whether the draft judgment
demonstrated the following grounds for appeal:
"Whether the judge has correctly interpreted and
applied the law ...
"[Secondly] Whether there are grounds to argue that
findings have been made as a result of serious
procedural irregularity ... and
"(Most urgently) Whether Mr Justice Fraser
demonstrated grounds on which we could apply for him to
recuse himself.
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"The test for recusal is ‘whether the fair-minded
and informed observer, having considered the facts,
would conclude that there is a real possibility that the
[Judge] was biased’.
"Attached is Lord Neuberger's preliminary advice ...
as you will see in paragraph 5 [he] states that although
he has only looked at the issues very cursorily, ‘at
least some of them raise quite significant points on
which the [Post Office] has a reasonable case, and at
least on the face of it, some points on which the [Post
Office] has a pretty strong case’.
“Further however, he suggests ... that if we wish to
rely on the ground of procedural unfairness at
an appeal, then '[Post Office] has little option but to
seek to get the judge to recuse himself at this stage’
and ... that if we fail to act promptly during the
Horizon trial we ‘risk being held to have waived [our]
rights, or at least weakened our position on the recusal
[application]'."
In your statement, you describe your reaction to
reading this email as being one of astonishment.
Yes.
Why is that?
Well, as I said just now, there hadn't even been
a proper post-mortem on the judgment itself and, you
77
"Alex
"The judgment in the first trial is out and it is
adverse to POL. You'll get the briefing by 3.00 pm.
"There are a couple of things I need to brief you on
and on which POL is asking for a quick decision. It's
a high profile decision to do with handling the case
with significant implications for BEIS.
"Do you have time for a call later today or over the
weekend?"
The response you receive back -- so forgive me,
before we look at that, you've obviously copied this
email to Richard Watson, Mark Russell and Gavin Lambert,
and if we scroll up, please, we see a response from
Richard Watson, he's not copied Mr Chisholm or
Mr Lambert. He says:
"Tom
“Not including Alex or Gavin in this email but
copying Patrick and Gareth from BEIS Legal with whom
I have raised the issue about a possible recusal
application on the grounds of bias. I shared with them
Jane's email and the accompanying note from Lord
Neuberger and they have engaged on this issue at a high
level in the Government Legal Department.
"The particular concern here is anything that could
be seen as [Her Majesty's Government] not upholding the
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know, the company’s Legal Team were talking about taking
very extreme action, in my view, without having
considered it properly.
Shortly after receiving the update from Jane MacLeod,
you sought advice from Alex Chisholm, the Permanent
Secretary at BEIS; is that right?
Correct.
I think your request to Mr Chisholm prompted Richard
Watson, General Counsel at UKGI, to send you some advice
about your involvement in the decision as to whether the
Post Office should apply to recuse the judge?
Correct.
Now, you say in your statement that Mr Watson advised
you that it would be inappropriate for you, as
a representative of the Government, to participate in
a decision concerning the recusal of a member of the
judiciary.
Correct.
Is that how you recall?
Yes.
Can we take a look, please, at the email to which you
refer in you statement. It bears the reference
UKGI00009208. If we scroll to the very bottom of that
document, please. We can see your original email to
Alex Chisholm, you say:
78
independence and integrity of the judiciary.
"While we think it is okay for Alex to be informed
we don't not [presumably we've got a double negative
there] consider the shareholder should be involved in
a decision whether or not to make a recusal application.
That is probably a matter for the [Post Office] Board.
I am, of course, happy to assist you as a Director on
the Board in carrying out your role."
Now, just pausing there, we'll come on, because
you've received several pieces of advice, but this first
chain is not concerned with your involvement, is it,
strictly speaking? The advice you're receiving here is
that it wouldn't be appropriate for the Permanent
Secretary or the Department to be involved in the
decision?
No, I didn't read it that way and I don't think that's
accurate. I think the bit -- the bit that I think
matters here is the bit that says, "We don't consider
the shareholder should be involved in a decision whether
or not to make a recusal application", and, you know,
I was the shareholder representative on the Board, so
anything I said in the Board meeting was likely to be
interpreted as the shareholder's view. I mean,
obviously, as Board member, you have two hats, as it
were: one is as the shareholder representative and then
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you're there in your personal capacity as a Director.
But, you know, as you'll see from the subsequent
emails -- and I hope we'll get to it -- this was a case
where there was -- the two would -- were bound to get
conflated.
I think it was, in this situation, impossible for me
to distinguish my personal views from those of the
Department because of the significance, and you'll see
an email that addresses that later on, hopefully.
If we scroll up, please. The next email in the chain is
from Mr Watson to Mr Evans and Mr Kilgarriff. You're
not copied into this email but it is forwarded to you
later in the chain, so it is relevant to you. It reads:
"Gareth, Patrick,
"Would you agree that the UKGI director on [Post
Office's] Board should not be involved in any decision
by the company about a recusal application?
"While I'm not convinced that there is a conflict of
interest I think that given the concern, rightly, that
[Her Majesty's Government] should not be seen as
questioning the independence and integrity of the
judiciary it feels presentationally difficult for
a Director appointed by the shareholder to be involved
in the decision. Put another way it seems preferable
that the UKGI Director is not involved."
81
if you like, a policy, broad policy perspective, and so
I took that away as the first message. And the second
message was the last sentence, which is "you shouldn't
be involved".
So far as you were aware, had the Department ever
brought a recusal application before; did you make any
enquiries as to that?
No, I mean, again, for -- again, remember there was very
little time here. I mean, this was 15 March and this
debate was -- the decision itself was taken on the 20th,
I think there was a weekend in between, I'm not sure.
So I -- I was reliant on the legal input here. How
branches of Government interact with each other was way
cout of my field.
If we scroll up, please, we can see the response that
Mr Watson received from Patrick Kilgarriff, he says:
"Richard, Gareth
"I don't think I would want to say Government NEVER
consider a bias challenge -- but inns sense of never say
never.
"I would have thought the function of the UKGI
Director might be to ensure the Board fully realised the
seriousness of what was proposed including the impact on
the shareholder (and the difficulties of distinguishing
between strategic direction and the operational matters
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So the concern which Mr Watson articulates here is
not that the application would give rise to a conflict
of interest for you as a Non-Executive Director of the
Board; is that fair?
Correct, I don't think it was ever seen as a conflict
issue. It was seen as, if you like, a policy issue
around relationships within the overall context of
Government. At least that was the way Richard saw it
and he's articulated it here. I'm not sure whether --
you know, how far that was discussed in those terms in
the Department. I haven't seen, either then or now,
seen how that issue was discussed in the Department.
But certainly in the Legal Team, in the Department, they
seemed to share that view, and that's what I took away
from these emails.
The concern he articulates here and which he returns to
in a later advice is that it feels presentationally
difficult for you to be involved in that decision; what
did exactly did you understand him to mean by that?
I have no idea, to be honest. I didn't really
understand the word "presentationally". To me, the key
points I took away were, you know, the -- one branch of
Government, ie in this case the Department, should not
be undermining the judiciary, and any action I took in
the Board of supporting such a decision was wrong, from,
82
in Parliament and the media) as well as the wider
litigation strategy on Horizon, that the Board had taken
and properly considered legal advice -- not a step to
take on finely [balanced] merits, and finally had
reflected properly on whether there was a bias or
(painful as it is) inferences drawn ultimately properly
from hearing the evidence expressed in pithy and robust
language. If the UKGI Director has done that, I would
agree that s/he may stand back from the decision to take
the challenge or not."
So it was not suggested by Mr Kilgarriff that you
must not take part in the decision, was it?
Not explicitly, no.
His email suggests that it's a matter of discretion for
the UKGI Director?
Yes, but I think I mentioned earlier there was another
email exchange.
I'll come to that one. So there's one a little later.
In fairness, I think we should look at Mr Evans’
response as well. He expresses himself in slightly
stronger terms.
Well, sorry, before we do that, Mr Watson forwards.
on that advice to you from Mr Kilgarriff, and he says:
"I think Patrick's view is a sensible one, ie flag
the things the Board need to be cognisant of but not to
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be part of the formal Board decision."
So Mr Watson seems to read Mr Kilgarriff's email as
suggesting that, although you have a discretion, the
sensible course to take is not to take part in the
decision.
Correct.
Now, Mr Evans' response is at UKGI00009211. His email
is dated 15 March, we can see Mr Watson forwards that to
you the same day but, in the middle of the page there,
Mr Evans’ email to Mr Watson and Mr Kilgarriff,
following on from the email we've just seen, the advice
from Mr Kilgarriff, who says:
"I agree. Government has to give [the Post Office]
the wider context of any application. That could come
from Alex [Alex Chisholm, the Permanent Secretary] or it
could come from Tom. Tom would be best to deliver that
view but having delivered it he should withdraw.
Crucially, it would be painful if Tom was the casting
vote either way. And that suggests he should not
participate in the decision.”
What did you understand Mr Evans to mean when he
said it would be painful if you were the casting vote
either way?
Well, it comes back to this one branch of Government
undermining another, and his point is that, if the
85
action was not to participate.
You make it clear in your statement that you always.
thought it was a bad idea for the Post Office to apply
to recuse the judge --
Yes.
-- and you explain that you had a discussion about the
recusal application with Alex Chisholm on 15 March = is
that right -—
Yes.
-- prompted by your email that we saw a short time ago.
Please can we look at what you say in your statement
about that discussion. It's at paragraph 185 of
page 88. So it reads:
"In addition to discussions that Richard Watson was
having with BEIS Legal, I had discussed the recusal idea
with Alex Chisholm on 15 March. It was clear that UKGI
and BEIS were both deeply uncomfortable with the
application being made. But it was considered
inappropriate for me, as the Government's representative
on the Board of an arm's-length body, to be party to
a decision that sought to challenge the judiciary.”
You say:
“In essence, this was the ‘presentational’ concern
referred to in Richard Watson's email of 18 March."
Can we take a look at that email, please,
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decision swung towards recusal because of my vote, there
will be a clear -- you know, it would be clear that it
wouldn't have happened, had it not been for the
shareholder representative on the Board and,
effectively, the actions of the Department, and that
would create the opposite intent of what the -- what was
intended here, of me not participating.
What would be the problem with your vote: tipping the
balance the other way, namely in stopping the Post
Office from making the application?
Well, what this exchange is saying is that I shouldn't
cast -- the previous sentence, if I was casting the vote
either way -- I mean, to be honest, I didn't focus on
that bit. You know, I felt very strongly that this was
a very rash thing to do and I think everyone's instinct
here was to try to avoid it happening.
So the idea of me voting in favour of recusal, you
know, at this time, I think, was not in contemplation.
I have thought about -- I mean, we might come on to
that, you might ask me the question: what would I have
done as a Director if I had been in the meeting and
heard all the arguments? But I don't think that was
relevant to this, to this email exchange.
I mean, it was clear to me, and it's clear from this
email and the subsequent one, that the right course of
86
UKGI00009273.
By this stage you had canvassed the opinions of
Mr Chisholm, that's correct?
Yes.
It was your understanding that, like you, he was opposed
to application; is that right?
Yes. I think it was clear from his email that he had
reservations but I think he set out -- because I'd
forwarded to him Lord Neuberger’s note, which he read,
and I think it was -- he also knew, because I think I'd
told him that Lord Grabiner's view was even stronger at
that time. We hadn't heard his advice but it was
reported that his advice was even stronger than Lord
Neuberger's. So that was part of Alex's email.
So I think perhaps it's worth reading it but, you
know, he set out, I think, why the Board might
reluctantly come to a decision to support recusal but
then went on to say it was clear in his mind that the
Department should -- I think he used words like maintain
a distance from this, which clearly supported -- in my
view, was totally consistent with the views of the Legal
team that we've just looked at, that I shouldn't
participate.
So, obviously, there's a difference between, on the one
hand, the Department expressing a view, or becoming
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involved, and you as a member of the Board?
Correct.
Those are distinct. In terms of your involvement, you
received some further advice from Mr Watson on 18 March.
Can we look, please, at the top of page 2. This is in
response to a request from you for a script to explain
why it is that you're proposing not to participate in
the decision. He says this:
"I have discussed this with the BEIS Legal Director.
I should be clear that the [Secretary of State] does not
have the power to direct you not to participate in the
actual Board decision and I do not consider you have
a conflict of interest. So in fulfilling your role as
a Director you could properly reach the view that you
should participate in the actual decision. However, the
reason we are suggesting that you follow something along
the lines of the above script is because of the
presentational concerns that may arise if it transpired
that the shareholding appointed Director participated in
the actual Board decision."
So here, Mr Watson reiterating the advice that
there's no legal barrier to your participation in the
decision; do you agree?
Correct.
He states --
89
about how it's going to look, rather than the actual
decision that you need to make; is that fair?
Well, I think I've tried to explain what I think
“presentational” means in this context and I don't think
it's just a style point or a form over substance point.
I think it's a real concern about, you know, how the
decision would be interpreted and how my action on the
Board would be interpreted by the outside world in this
particular, very special, context.
Given the strength of feeling that you had about the
merits of the recusal application, and the feelings
articulated to you by BEIS, did you consider whether you
had a duty to vote against it in your capacity as
Shareholder Non-Executive Director?
I did but it seemed to me that I -- the proper thing to
do here was to take -- to follow the legal advice, and,
you know, if we could come back -- if we can find the
engineering and outcome email, I think I can -- that
would help.
Is that an email from Alex Chisholm to which you're
referring?
No, this is an exchange between Richard Watson and
Gareth Evans in the Department. It's between the
lawyers in the Department.
We'll see if we can find that.
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A. But! think the word "presentational" here actually
makes, you know, makes a lot of sense because what
I think he's communicating was that it would be very
hard, I think, for anyone in the outside world to
understand the distinction between my role as the
departmental representative on the Board and my own
personal view. This is the point I was making earlier.
I think the two would get conflated and, you know, if --
let's say I voted in favour of the recusal and that was
criticised, and the Department then had to say publicly,
"Well, you know, Tom was just expressing his personal
view". Nobody would believe that.
And I think this comes out quite clearly in a later
email which talks about engineering an outcome which is
where the decision effectively gets thrown back to the
Department. So I don't know if you've got that
available but I think it's worth looking at.
Q. We'll have a short break and I'll see if we can find
that one to which you're referring.
A. Yeah.
Q. Before we do, is it not right that what's being
expressed here is a concern about style over substance,
namely that you're being advised that Mr Watson from
UKGI, as UKGI General Counsel, and his colleagues in
BEIS, with whom he's consulted, they're really concerned
90
A. Thank you.
MS HODGE: Thank you, sir. This might be a convenient time
to take our second morning break.
SIR WYN WILLIAMS: Yes, certainly.
MS HODGE: Shall we --
SIR WYN WILLIAMS: = Yeah, what time, please?
MS HODGE: Shall we resume at 12.35?
SIR WYN WILLIAMS: Yes, fine.
(12.24 pm)
(A short break)
(12.35 pm)
MS HODGE: Hello, sir. Can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you. Yes.
MS HODGE: Thank you.
Mr Cooper, just before the break you mentioned
an email chain containing some further commentary about
the recusal application.
A. Yes.
Q. We've managed to locate that, that bears the reference
UKGI00009308. Now, this is an email chain, it
originates with an update from the Post Office's General
Counsel, and you explained earlier in your evidence that
you forwarded some legal advice to Alex Chisholm. So we
see his email at the start of the chain. We can go to
that if you wish but I think the part to which you were
92
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referring earlier in your evidence can be found at
page 2, please. It's at the middle of the page.
Would it be possible just to look at Alex's sort of
punchline at the end?
Yes, by all means.
That would just be helpful.
So at the middle of page 3, please, we can see Alex's
email to you of 19 March. So if we scroll down to
page 4, please, I think it's fair to say that you've
already summarised the gist of what he said. In the
final paragraph, please, nearer to the bottom of
page 4 -- thank you -- is this the one to which you were
referring:
"The Department should maintain its clearly distinct
and detached position, so that it is free and credible
for dealing with the consequences as they unfold.
Ministers may want to show appropriate concern about the
criticisms and may express a desire for [Post Office] to
act appropriately but should not comment substantively
in ongoing litigation in which the Department has
a clear interest but no direct involvement."
Yes. Can I just say, this email was very important for
me, and the key bit of this is the first sentence in
that paragraph that says, "maintain a clearly distinct
and detached position". And I do understand what you're
93
object ie some sort of conditional Board approval. As
shareholder I don't consider she has the legal power to
prevent this even if it was an appropriate thing for her
to express a view on, which I think we agree it isn't
but instead is properly a matter for the Board.
"It is of course proper for the Minister to
understand [Post Office's] decision and why their
position might have changed since her call with the
Chair on the weekend. I understand that might be the
subject of a call with the Minister later today."
Okay. So the key bit of this is "are we agreed that we
should not try to engineer a position today whereby",
et cetera, "ie some sort of conditional Board approval",
and I say "I have no intention of engineering such
an outcome”.
And what this is saying is that, if I had to express
comments here in the Board of saying I really don't
think we should be doing this or, in the opposite
direction, I really think we should be, there would have
been a very high chance -- whatever I'd said about this
being my personal opinion, nothing to do with the
Department, I think other members of the Board would
interpret it as informed by the views of the Department
and that would increase the risk that Board would say,
"Well, we've received legal advice that says we should
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going to say, you're going to say "Yes, but this doesn't
talk about you, Tom, it talks about the Department", and
I get that but I think -- and we'll come on to that with
this other email -- but I think this totally reinforced
the view I was getting from the Legal Team in UKGI and
BEIS, in other words from everything I knew, all the
bits of the Department were saying the same thing, which
was "Stay out of this thing", yeah?
In your mind, are you saying that you are unable to see
any material distinction between the Department's
position and your casting a vote as a shareholder
representative on the Board?
No, I'm not saying that. I understand that distinction
very well. What I'm saying is in this particular
situation, it would be impossible to separate the two
and this other email, I'm trying to -- I'm pointing you
to, is -- I think highlights that quite well.
If we scroll up, please -- sorry, to page 2, I think, is
the email from Richard Watson. Yes.
Yeah, okay.
Thank you. This is 20 March, two days later:
“All
"Are we agreed that we stood not try to engineer
a position today whereby if the Board decides to proceed
with the recusal the Minister is given a chance to
94
go for recusal, we think reluctantly that's what we
should do but we'll only do it if the Department agrees
that that's what we should do", and that's the
conditional approval, yeah?
And so my concern, which I believe is totally valid,
is that any view I expressed to the Board was likely to
increase the chance for the conditional approval or
rejection which was exactly what the Department didn't
want. The Department did not want this decision to come
back to them. That's, I think, very clear, from all the
emails and also the subsequent actions of the Minister
because you'll see, in the second paragraph of this, it
says it's proper for the Minister to understand and --
since her call at the weekend, and she might have a call
later today. She did want to have a call, there's
an email chain to that effect, but then decided against
it.
So I think everything in these exchanges was telling
me that I should not take any action that would increase
the chance of this decision coming back to the
Department.
What you appear to be saying, is it right, is that, so
far as you were concerned, the Department didn't want to
make this difficult decision?
Correct.
96
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You didn't want to make this difficult decision?
I don't think it was -- I think in this situation, my
personal views, I think, were overridden by my
principal, by the Department. I didn't feel -- I don't
feel I could have explained afterwards, if I -- let's
say I had spoken at the meeting and the result of that
would have been that it came back to the Department,
I think I would have had a very difficult job to explain
why I'd done what I'd done.
Are you saying, therefore, you felt constrained by the
position that the Department took, in expressing your
own personal views to the Board about the merits of the
application?
Absolutely. I felt I had very clear -- the sum of all
of this is I felt I had instructions not to participate.
I'd like to address one final topic with you, please,
Mr Cooper, before I hand over to the recognised legal
representatives of the Core Participants. This relates
to the Department's oversight of Post Office in the
litigation. Now we covered that a little earlier in
your evidence this morning when we discussed the policy
team, the late establishment of the policy team, and
communications between UKGI and BEIS. You said in your
evidence that you felt there was a lack of engagement on
the part of the Department and ministers. I think you
97
that I believe the recognised legal representatives
would like to use to ask questions to see if we're able
to upload them for Mr Cooper to consider them.
In terms of timings, sir, I think the indication is
that there may be about half an hour, possibly slightly
more, of questions, cumulatively from Core Participants.
If you're content for those questions to be placed now,
we can take a slightly later lunch break and hopefully
enable Mr Cooper to finish his evidence this morning --
SIR WYN WILLIAMS: By all means, yes.
MS HODGE: -- in this session.
SIR WYN WILLIAMS: Yes, let's do that.
MS HODGE: So! think we're hearing first from Hudgells.
Questioned by MR MOLONEY
MR MOLONEY: Thank you, sir, and thank you Ms Hodge.
Mr Cooper, in your witness statement -- and if we
could please go to it, it's page 112 and paragraph 242,
if possible. Just whilst that's coming up, you
addressed the late disclosure of KELs before judgment in
the Horizon Issues trial, at a time when POL was
considering settlement.
Yes.
You explain in paragraph 242 -- and it's magically there
now -- that:
"The Board was advised of the steps that were being
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explained that, so far as you were concerned, UKGI were
feeding information to the ministers but you weren't
getting much back. Is that a fair summary of your
evidence?
Correct, yeah.
Now, you also referred to a meeting you attended with
the Minister, Kelly Tolhurst, on 17 October 2018; that's
correct, isn't it?
Yes.
Do you recall, as part of the outputs of that meeting,
the Minister requesting access to more information and
the advice that the Post Office was receiving in
relation to the litigation?
I actually don't recall that. I think the first time
I recall that was in the immediate aftermath of the
Common Issues judgment, and there was a phone call on
16 March, in the afternoon, with Tim Parker and others
from the Post Office, which Kelly Tolhurst was on, and
I recall her asking for more information then. And it
may be in the record, I don't know, but I don't remember
it in the aftermath of the 17 October.
It might refresh your memory, if we could take a look at
UKGI00008608.
Sir, we unfortunately don't have those documents to
hand at the moment. It may be that we can take the time
98
taken to address the disclosure failure, including work
to assess the evidential significance of the new
material and whether the errors by Fujitsu might give
rise to a cause of action against Fujitsu in relation to
this specific incident."
Then you carry on to discuss about whether or not
there might be further evidence.
You return to the topic when dealing with
post-settlement events at paragraph 256, which is
page 117, if we may. So we can see there, it's under
"Post-settlement", and if we scroll down to
paragraph 256, it reads -- if we could just go perhaps
a few more lines so we can see the top of 118:
"The subcommittee had previously requested advice
about whether POL had an action against Fujitsu so that
it could recover at least part of the settlement cost
from Fujitsu. Ben Foat reported that initial advice had
been received but a final advice was awaited. My
recollection is that POL was ultimately advised that any
claim it wanted to make against Fujitsu would almost
certainly be time-barred."
So just, as it were, considering both of those
paragraphs together, at paragraph 242, you talk about,
as it were, the origins of the advice, or the request
for the advice and, in respect of that advice, on
100
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whether any errors by Fujitsu might give rise to a cause
of action. Was that advice sought following
encouragement by the Board and/or the subcommittee or
was it initially sought simply on the initiative of
POL's lawyers?
A. My recollection is that Ken McCall asked this question
in the subcommittee or in the Board, I'm not sure which.
Ken was, I think, rightly interested to know whether
Post Office could recover anything against Fujitsu. And
I think there were actually two -- twice it came up
during my tenure that the Board asked about this and
wanted it reconfirmed, and the answer basically came
back the same both times that -- and I am probably
expressing this in too simplistic a term for the
lawyers -- but, essentially, it's that Post Office knew
or should have known, more than six years before, that
there were problems with the system and that, therefore,
you know, any claim would be time-barred.
Q. Right, okay. Just to move away from the terms of the
advice but you sought the advice in order to see whether
POL, and ultimately the public purse, could recover at
least part of the settlement cost?
A. Correct.
Q. It would clearly be important because it would help in
working at what would be a reasonable settlement and
101
A. It was not -- I -- well, just a bit more context for
you. I think one of the things that hampered -- it was
HSF who were giving the advice here and I think one of
the things that hampered them -- and this issue also fed
into the whole discussion about malicious prosecution
that happened later, and Limb 2 abuse, is that their
visibility -- Post Office's visibility on events
pre-2010 particularly was very limited, and so the
advice they were giving here was very -- was hampered by
that or constrained by their lack of knowledge of the
history -- complete knowledge of the history.
So I think HSF's advice was always -- on this topic
of what could be recovered from Fujitsu was always
caveated by "Well, we don't have the whole story but
this is what we think you can't claim".
MR MOLONEY: All right. Thank you very much, Mr Cooper.
Questioned by MR HENRY
MR HENRY: Mr Cooper, I ask questions on behalf of number of
subpostmasters, including Mrs Seema Misra who sits
beside me.
Common Issues judgment, 15 March 2019. Obviously
a watershed for you personally.
A. Yes.
Q. By 15 November 2019, the Horizon Issues trial had been
and gone and you were awaiting a judgment, weren't you?
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10 July 2024
when to make the settlement during the negotiations?
Yes, and I don't think it -- yes, it wasn't totally
financially driven. I think there was a real sense of
culpability here, that both -- I mean, obviously, Post
Office itself was culpable but I think there was also
a very strong feeling that Fujitsu was culpable here and
that they should be, you know, part of the resolution
and remediation process.
There was initial advice reported by Ben Foat, you say,
at paragraph 256, and then you refer to, as it were, POL
being ultimately advised on any claim it wanted to make.
So two stages to this, as you've just outlined to the
Chair.
Yes.
The initial advice reported by Ben Foat, did you
actually see any documents relating to that advice or
was it just reported by Ben Foat?
I think there was a document that we were shown, that we
received, yes, but I can't pin -- I couldn't pin down
for you when or in what forum.
Then in terms of the final advice, did you, as a member
of the Board, then see that final advice?
It was probably in that context that we got the final
advice.
Yes.
102
15 November?
2019, you were awaiting a judgment?
‘Awaiting the Horizon Issues judgment?
Yes.
Yes.
By this time, again, you must have been thoroughly
disenchanted by the brief you'd been given? I mean, the
Common Issues judgment was a disaster and, so far as the
Horizon issues, the prospects looked grim, didn't they?
Well, the advice we were receiving then from Tony
de Garr Robinson had changed a lot. It had moved from
great confidence to gloom about the prospects. So
I think at that time the expectation was that the
Horizon Issues judgment would be negative as well, and
I think, yes, I think that's clear from the minutes too.
So I'm going to be probing how you personally responded
to that and I'm going to take you now to UKGI00010737.
Could we just scroll further down, it's from Joshua
Scott, "Hi Toms", that's to you and Tom Aldred:
"You both tasked me with doing some research on the
convicted claimants in the GLO so I have decided to lump.
them together in one document.
"Tom A in relation to how they were treated in the
last mediation and Tom C in how their stories are
portrayed in the public domain.
104
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"Please see attached an initial draft of what I've
done so far. Let me know if this ticks the boxes or
not.
"I've looked specifically at 5 of the convicted
claimants, 2 of whom (Jo Hamilton and Seema Misra)
feature quite prominently in multiple media releases and
the [Nick Wallis] blog."
That must be a reference to Nick Wallis, "NW":
"I have to say it has been a little harrowing
reading up on the stories but I think a useful exercise
to understand some of the convict claimants’ positions."
Now, Mr Cooper, I suggest there that Josh Scott is
going a little off piste, over emotional or seeking to
distance himself from what was your ulterior purpose,
because I suggest you wanted to know how, there, the
convicted claimants’ stories were portrayed in the
public domain, to see if you could undermine them,
didn't you?
Um, with respect, that is completely the opposite of
what I was trying to do. So if I could give you a bit
of background.
Of course.
You'll see from my witness statement that I spent quite
a lot of time talking about my attempts to get
an understanding of the lead cases and the
105
matters that refer to you within this note. We know
that this note was composed, because we can see from the
first line, on 24 January 2020 and, in the course of
this note you are reported, together with Tim Parker,
wanting to know if you can take pot shots at Seema
Misra, who sits beside me, whilst telling the lawyers
not to consider safety. So I want to go, please, to
page 3 of this document.
Now, do you see there:
"Horizon training -- [Rodric Williams] -- leave that
with me."
I'm going to assume, because there doesn't appear to
be any further initial before "CCRC agenda’, that it is
Rodric Williams speaking:
"CCRC agenda -- want to make sure got [documents],
got right people, bow around it to give to counsel.
Need to start reading CCRC files now. Feel from Board
that they will go with wide review. We have material
for 34 [applications] to CCRC [including] Misra/
Hamilton/Thomas/McDonald. Board's concern is that there
is a narrative and we're just letting it go. Board
desperate to decide whether to take pot shots at Misra.”
What do you say to that, Mr Cooper?
First of all, I'd like to say sorry to Mrs Misra that
she would have read this. I'm sure it's one of many
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understanding, a real -- a proper understanding of the
facts in the lead cases, and I was frustrated in that.
I actually tried to Google the lead cases in the Common
Issues judgment and found very little in the public
domain. I'd made at least two attempts to try and get
an understanding and the claimants’ perspective and Post
Office's response to individual cases, the lead cases,
in the Common Issues judgment, and didn't get
satisfactory -- I got fobbed off both times.
So by the time we reached this point, I was
expecting the same thing to happen again and what
I wanted -- what I was asking the team to do here was
to -- let's see what's in the public domain. I can't
trust the Post Office to give me a proper description of
what the claimants are saying because of the history
here, and so let's research what we can and if the Post
Office don't address them in the information we get, we
can cross-check against the two. And I think there's
an email I sent Josh Scott, actually, that says it in
pretty much those terms.
We'll come to that in due course but I want to go now to
POL00337435.
Now, this is a consultation with Mr Altman, Rodric
Williams, Nick Vamos of Peters & Peters, and others.
You are not present but want to ask you about some
106
things she'd have found very insulting in this whole
saga.
AllI can say to you is that I have no idea where
this came from. At this point in time, I was
actually -- as you'll see, my attempts to look at the
press coverage of Mrs Misra's case and others was to
actually challenge Post Office's description of events,
and I was -- I hadn't -- I was not in a position at this
point in time to decide -- I mean, if I was ever going
to take pot shots at anyone, whatever that means --
Well, you know what pot shots means?
Well, yes, but I mean the key meeting here was
28 February, which was our first meeting with Brian
Altman on the convictions. So my research on the
history of these cases was in the run-up to that. I had
no view about Mrs Misra's case at that point in time.
I'm going to put it to you straight. What do you say,
“Board is desperate to decide whether to take pot shots
at Misra"; are you saying that Williams just invented
that?
As far as I'm concerned, yes.
Let's go to the next immediate paragraph below. Brian
Altman, Queen's Counsel:
did Board suggest about whether we should
review safety or just disclosure? [Rodric Williams] —
108
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No just on disclosure. Not opining on safety."
Did the Board fetter the lawyers, "Don't advise on
safety, just advise on disclosure"?
No, absolutely not. I mean, the Board's perspective on
this was that, clearly, as far as the company could
possibly do so, this situation of the postmasters
concerned, who had been convicted/terminated/harmed in
any way, needed to be compensated/resolved/apologised
for in every way -- you know, in every way possible and
this was the opposite of what the Board was trying to
do.
Can we go to the last two lines on this page, please.
Here you are mentioned in the same breath as Tim Parker.
It's unattributed who is speaking. But it says:
"Tom Cooper/Tim Parker -- need to say ‘Misra has
been saying x in the press, what our actual review of
her case is x’."
Yeah.
Then Mr Altman says, "Know Misra well", in other words,
the case.
It suggests, doesn't it, that you wanted to impugn
the credibility of the claimants, including, amongst
them, Seema Misra, that you were asking Mr Scott to
trawl for inconsistencies in their account.
That is what it suggests. What I was trying to do was
109
a check against what POL will show us."
Yes. Yes, I wasn't trying to check what the claimants
were saying; I was trying to check what Post Office was
saying. I mean, you have to remember, I had -- Post
Office's record in providing me with accurate
information about individual cases was woeful and
I didn't trust what I was hearing.
Did you think that the Misra case was particularly
important?
Everything we'd been told by the Legal Team was, yes,
that her case in some -- many respects was a watershed
case.
It was the paradigm case of the Post Office's
misfeasance towards the convicted claimants, wasn't it?
Correct.
That is why, presumably -- and there's no need to get it
up - but it's UKG100038672, you're writing to somebody
called Tasila; do you remember?
Yes, Tasila Banda, yes.
You say:
"I think it would be worth asking HSF to take you
through some of the history of the prosecutions and
maybe some typical examples. There was a pattern to
many of these cases which might help the team understand
what the issues might be from a malicious prosecution
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the opposite, which was find inconsistencies in Post
Office's account. As I say, there's an email I sent
Josh Scott to that effect.
Well, let's go to that email because I apprehend we're
going to be thinking about 11 February 2020, and it's
UKGI00011190. But before it's put up on the screen, you
appear to be suggesting that you are saying, "Stop", but
Williams is saying, "Go". In other words, you are
saying, "Black" and he is saying, "White"; you were
saying "Night", he is saying "Day"; in other words, the
instructions that the Board are giving are, as it were,
totally reversed --
Correct.
Well, I suggest --
Does that surprise you?
I suggest that's not credible.
Well, I'm sorry, in that case but I am being entirely
truthful when I'm talking about this.
Let's go to this email and, if we could scroll up
a little bit, and this is from you:
"We have a meeting on [the] 28th with the lawyers to
go through some of the criminal cases in detail.
"Josh has a list of the cases that have been covered
publicly. I'd like to have a dossier of these cases
which includes the claimants’ side of the story as
110
perspective. Also the Misra case, because it's so
important."
Because it was a quintessential malicious
prosecution, was it?
Yes, I don't know if we knew that then. I can't
remember -- what's the timing of this -- if I knew?
That's 30 March 2021?
Oh yes, we knew by then.
Right. My final question to you arises out of your
answers to Ms Hodge earlier today, and could we go to
UKGI00027113.
Now, this is you writing to Mr Scott again, together
with Shanice Swales, Richard Watson, Carl Cresswell and
it's the debate pack. I want to concentrate on three
references: page 10, page 16 and page 24:
"[Page] 10 should refer to previous management as
well given that Horizon was introduced in [year] and the
claims in the GLO relate to events going back to the
late 1990s in some cases. The claims predate Paula
Vennells' involvement in the company -- we should not
mention her by name except in response to a specific
question. Should also mention that POL was part of the
[Royal Mail Group] when Horizon was introduced.”
Dealing with the last point first, of course that
was a reference, was it not, to the fact that the Royal
112
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Mail Group, before separation was responsible for
prosecutions, correct?
A. Correct. Well, sorry, correction. I don't think I knew
then that Royal Mail -- actually, their Legal Team did
the prosecutions at that stage. So I don't know if it
was exactly the point you're making lay behind what
Iwas saying.
Q. But we can agree that there was an insistence -- or not
an insistence but a suggestion by you -- that Paula
Vennells is not to be referred to unless there's no
alternative?
Well, no. Not unless there's no alternative.
Well, unless there is a specific question?
Correct.
Yes, which would leave no alternative. By that time,
I suppose, she was damaged goods?
Sorry, is that a question?
Yes. Why the insistence or the suggestion, rather,
don't mention her by name?
A. This isn't specific to Paula. I think my comment would
have been the same in respect of any individual that (1)
you don't need to mention people's names. I didn't feel
that it would be appropriate to mention anyone's name in
this context. If I actually had the draft, I could
probably explain it to you better.
113
prop,
oP
Your response to that is:
"Nothing wrong with it but it rather begs the
question about what happened before."
The answer to the question it begs is that,
effectively, you were supine, weren't you?
Me, personally?
ShEx oversight was essentially --
Oh, I see.
~ supine?
. Oh, you're talking about ShEx.
SIR WYN WILLIAMS: I think, Mr Henry, it's not realistic to
expect a meaningful answer about things before the
witness joined the organisation, which was 2017/18,
wasn't it?
MR HENRY: 2018, sir.
March, I think, was it?
A. Yes.
Q. Yes, March.
Well, then, if I rephrase it in this way.
rPoOoOPrPOoP,
Mr Swannell yesterday summed it up when he said "When in
curiosity meets a toxic culture bad things happen"; do
you agree with that diagnosis?
A. Ican understand why he said that. I wouldn't quote it
as a generalisation but I can understand why in the
context of the Post Office he said it.
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So be it.
But I haven't looked at that document but I think this
was a general point I would have made irrespective of
whether it was Paula Vennells or someone else.
It's now 2 March 2020, and you say:
"[Page] 16. References to change/culture
improvement are well under way is premature (couple of
similar references elsewhere). Better to use the
language about Nick Read being committed to
an overhaul."
So would that reflect, essentially, that the
culture, the toxic culture was deep rooted?
Yes.
Yes.
And I think what I didn't want anyone -- I felt it would
be wrong and misleading for the Minister to give the
impression that everything had been fixed. Absolutely,
the opposite was the case. It was still huge amounts of
work to do.
Then page 24, you say:
"Do we want to say this? ‘On the litigation,
following the critical Common Issues judgment, UKGI
challenged the Post Office Board's strategy and approach
and supported on activities to enable the successful
mediation to take place in December 2019'."
114
Were you reassured by the constant mantra and refrain,
"It's not systemic, it's not systemi
I took it at face value to start with. But I think over
time -- you know, it became very clear, over time, and
again, I can't pin down a date of when exactly, but this
case wasn't about systemic problems.
Exactly.
This was about the system causing problems for
individual postmasters --
Precisely.
-- and their balances and it was -- if you articulate it
in that way, which is, in my view, the correct way, it's
a very different question from systemic issues.
So the question was being phrased wrongly. Horizon's
failures did not have to be system-wide, the problems
could be sporadic, intermittent, random but capable of
causing losses as claimed by the victimised
subpostmasters?
Correct.
When did you get that?
Well, I've just said, I can't pin it down to a date.
But I think in the -- it was after the summer of 2018.
Probably before the Common Issues judgment.
Well, then, if so, why didn't you do something about it,
if you saw the questions so clearly that the question or
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The Post Office Horizon IT Inquiry
the mantra that they were espousing was wrong, why
didn't you do something about it?
A. Because I think, to the earlier question, the approach
I took to the Horizon issue was that that was a matter
for the experts. The experts who were far better
qualified than I to resolve this question were going to
do so in the Horizon Issues judgment. I am not
a lawyer, I'm certainly not an IT expert, and they were
the people who were best qualified to do it. And I felt
confident that we would get the answer to that question.
Q. But did you make your concern known, even if you felt
“It's not a matter for me but my concern at least should
be relayed to the lawyers so that it can then be
forwarded to the experts"?
A. I don't recall what I said, but my -- dealing with the
Legal Team at that point in time was dealing with
a brick wall. I might be exaggerating slightly but that
was how it felt. They were completely - you couldn't
get any traction with these people on anything.
MR HENRY: I I've nothing further to ask you, Mr Cooper.
Thank you.
SIR WYN WILLIAMS: Thank you. Are there any other
questions?
MR STEIN: Sir, yes, I have questions for Mr Cooper.
Sir, I will be five minutes, possibly six or seven
117
"I considered this to be a wholly unreasonable and
untenable position to maintain in general, but
particularly in the litigation.”
Okay? Right, so this is a matter that you in your
statement referred to very strongly; in your evidence
today you've repeated your strong concerns about this
particular issue.
Now, my questions are these: were you told that
before 2012, this liability clause had been differently
worded but, nevertheless, the Post Office had
consistently always imposed liability regardless of
fault, going right the way back to the beginning of the
Horizon time?
A. No, I hadn't. I'd been told that it had changed so, in
the July 2018 meeting, around about then, I had with
Jane MacLeod, both versions of the liability clause were
discussed. So -- but I was not told about how it was
applied in practice in the past.
Q. Right. So at the time we're looking at this -- we can
see the bottom of that particular paragraph there's
reference to a date in October 2018. So around this
sort of a time, quite close to when you joined as a NED
the POL Board, you're learning about this liability
clause which you really dislike?
A. Yeah.
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minutes.
SIR WYN WILLIAMS: On this occasion, I will hold you to
that, Mr Stein.
MR STEIN: Sir, given the timing, I'm not surprised.
Questioned by MR STEIN
MR STEIN: Mr Cooper, my name is Sam Stein. I represent
a large number of subpostmaster/mistresses, if you like,
and people who worked in branches. I'm instructed by
a firm of solicitors called Howe+Co, who have had a very
long engagement with these issues with the Post Office.
Can I take you straightaway, please, to your
statement, paragraph 118. That's page 57.
So paragraph 118, page 57, please. Now, here
Mr Cooper what you're referring to is a clause that you
felt particularly strongly about, that's the liability
clause. Now, you've given evidence about this in part
today and you've said to Ms Hodge, who was asking you
questions earlier today, that you felt this clause was
completely unfair. That's at 16.1 on the [draft]
transcript. What you're saying here is this:
“I understood that in 2012, the liability clause had
been changed by POL to say that [subpostmasters] were
liable for losses regardless of fault."
About seven lines down from there, same paragraph,
you say this:
118
Q. Right, okay. You don't know that before 2012 the same
interpretation had been placed upon it, going back for
12 years before that?
A. Correct.
Q. Right. At this point, though, you're learning that this
is the way that matters are dealt with, with
postmasters, postmistresses and people in branches.
What happened? Did you say, "Hang on are we still doing
this to people, right now? Forget about the litigation,
is this still going on"?
A. No, I think the message we received from the management
team at Post Office was any bad practices that existed
in the past, for example, investigations, you know,
asking for money that wasn't owed, that had been -- bad
training had all been remedied.
Q. Okay, so you were being reassured about that. Who told
you, as you say at the beginning of that paragraph,
“I understood that in 2012 the liability clause had been
changed"; who told you that?
A. Jane MacLeod.
Q._ Right, paragraph 119 over the page, please, to page 58.
Now, that says:
"However, POL was robust in its view that it should
continue to defend it, arguing that any other approach
to liability was not operationally possible."
120
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Mm-hm.
Then you talk about a feeling of a significant degree of
frustration. Wasn't that telling you that this was
still going on, that this is the way POL looked at its
world view regarding the Horizon system?
I didn't interpret it in that way. But I can
understand --
That's what you appear to be saying?
Perhaps, with hindsight, I should have interpreted it
that way but that wasn't what I was hearing from the
management team.
Okay. Right, now see what's happening from the POL
perspective, its response. Now, equally, you've got
an entire team working with you in relation to your
responsibilities as the NED for UKGI. Yes?
Yes.
What did you do about the other way, so going to the
owners, the shareholders that own POL, the Post Office,
what did you say to them? "This can't go on, we've got
a real problem with a liability clause I utterly
disagree with"; what happened woman that perspective?
POL's no good, they're batting you away. What did you
do about going back to Government and saying, "We've got
to stop this"?
Yeah, I think we talked about that earlier.
121
owner do about it?
Nothing, but I think, in fairness, I don't think -- to
them, there was no -- they didn't -- I hadn't
communicated to them how strongly I felt about it. Why?
Because where I felt I could make -- get the most out of
the Department at that time was on the contingency
planning.
Right. Well, you anticipated my next question, this is
therefore my very last question, you said the reason,
the why you didn't press this harder with, as I put it,
the owner is because you felt you could get more on
other issues.
Now my last question therefore is this: is that
something that you thought of at the time? Did you sit
there at your desk or at your laptop and go "Hang on,
whilst I'm really frustrated about this issue I don't
think I should raise it because it's like a seesaw, I'll
get better traction on something else", or is that
a post-event rationalisation as to what's happened,
Mr Cooper?
No, it's at the time. I'm not sure I thought about it
exactly the way you've described but I -- you know, you
have to prioritise what you can get out of senior people
and, to me, that was the one where I thought they would
engage the most.
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Abit but this is rather (unclear).
So my -- the point at which I raised this with -- you
know, my, if you like, most significant engagement,
because there was more than one -- with the Legal Team
and the Board was on 30 October. It's also important to
understand that I was actually on a journey of actually
understanding this stuff. I'd only got involved in
March. My first meeting on the 23 implied terms was in
July. So this was quite quick, I think, in -- I hope
you'd agree, in sort of legal time frame.
So I -- you know, my, if you like, point of maximum
exasperation on this was on the 30 October meeting,
which was only a few days before the hearing was due to
commence. And I think, in practice, the die was cast.
In terms of what -- the way Post Office were going to
deal with this in court, was, you know, were they going
to concede the liability clause --
‘SIR WYN WILLIAMS: I think, if I may say so, we all know
A
that they defended that clause in court.
Yes.
MR STEIN: The question, actually, Mr Cooper, is not about
that: it's about what the owner did when you were saying
to the owner, as part of that team, "Look, there's
areal problem here. They're getting this utterly
wrong. This is morally indefensible". What did the
122
SIR WYN WILLIAMS: Right, thank you very much.
MR STEIN: Thank you, Mr Cooper.
SIR WYN WILLIAMS: Now, then, Ms Hodge, is there anything
you want to ask in terms of having found a document or
not, so to speak?
MS HODGE: Sir, the NFSP would like five minutes to ask
questions. Obviously, 'm conscious we've run quite ~
‘SIR WYN WILLIAMS: I don't think I'm going to carry on
indefinitely. We are going to stop now. We just need
to decide when we start again.
MS HODGE: If we were to return at 2.15, the NFSP could put
their questions for five minutes and, if I needed to,
I could put any outstanding matters for five minutes.
That would take us to around 2.30. I think that would
leave sufficient time in the afternoon for Mr Stevens,
as I understand it, with our next witness.
‘SIR WYN WILLIAMS: Well, can I take it clear to everyone
that today is a day where I cannot sit beyond 4.30
because I've arranged a meeting relating to the next
phase of this Inquiry, which I need to have promptly
after 4.30. So I'm just warning people that that is the
cut-off point today. Alll right?
MS HODGE: Thank you, sir.
‘SIR WYN WILLIAMS: So we'll start again at 2.15.
MS HODGE: Thank you.
124
(31) Pages 121 - 124
25
The Post Office Horizon IT Inquiry
(1.29 pm)
(The Short Adjournment)
(2.15 pm)
MS HODGE: Good afternoon, sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
MS HODGE: Sir, there will be some short questions from the
NFSP.
SIR WYN WILLIAMS: Yes.
Questioned by MS SHAH
MS SHAH: Can you see and hear me now?
Good afternoon, Mr Cooper, my name is Rohini Shah
and I represent the National Federation of
SubPostmasters. I'm going to refer to some sections of
your witness statement. There is no need to turn it up
unless you wish to review them. At paragraphs 13 to 14
of your witness statement, you refer to your role on the
Nominations Committee and explain that this committee
dealt with senior appointments at the Post Office. As
a member of the nomination committee and given what
you've said today about the conduct of the litigation,
did you or anyone within UKGI suggest that any board
member or senior management members of the Post Office
resign following the judgment of Mr Justice Fraser?
A. Yes. Absolutely. Yes, I mean, Jane MacLeod was asked
to leave the company.
125
Common Issues judgment and so, effectively, Post Office
said unilaterally "We are going to interpret the
contract in a way that's compliant with the Common
Issues judgment”, and that avoided then the need for
subpostmasters to sign new contracts.
Q. Finally, in terms of finances in the future would you
accept that Post Office will likely never be able to
afford the costs involved of the Horizon scandal, in
terms of administration and redress without ongoing
financial support from the Government?
A. Well, never say never. But! think, certainly at the
time I left the Board, which was over a year ago now,
I think it's clear that Post Office would not be able
to -- it's abundantly clear it wouldn't be able to
afford the cost of the compensation and the ongoing
business model was unsustainable, financially. Yes.
MS SHAH: Thank you very much, those are my questions.
‘SIR WYN WILLIAMS: I'm very sorry that -- hang on, I seem to
have disappeared. No, here we are.
I'm very sorry that I asked you to wait for
45 minutes for delivering those. If I had thought that
you'd have been as short winded as that, I would
certainly have permitted you to ask the questions before
lunch. So my apologies.
MS HODGE: Thank you, sir, I have some very brief follow-up
127
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Qa
10 July 2024
Other than Jane MacLeod, was anybody else discussed?
No. I mean, the priority then was to change the Legal
Team, and get new advisers on board.
Okay. At paragraph 252 of your witness statement, you
refer to a Board meeting on 26 November 2019 at which it
was confirmed that the Common Issues appeal decision had
gone against POL and that it was now necessary to
implement the findings of the Common Issues judgment in
full, including asking subpostmasters to sign new
contracts.
However, postmasters were never asked to sign new
contracts and the NFSP were never informed that it was
considered that postmasters should sign new contracts.
Could you explain why that was?
Yes. can. So I think the initial advice that Post
Office got and the Board got was that postmasters would
need to be asked to sign new contracts. I think the
team led by Nick Read considered that and I think the
practical answer that they came up with was for the
company to restate all its policies in relation to how
the contract would -- the existing contract would be
interpreted.
So there were new policies issued around things like
terminations, suspension, investigation and disputes,
those kind of -- all those issues that came out of the
126
questions, please, if I may.
Further questioned by MS HODGE
MS HODGE: Mr Cooper, I would like to briefly revisit the
issue of the Department's level of engagement in the
Group Litigation. Could we look, please, at what you
say about that at paragraph 80 of your witness
statement. It's page 39, please. Thank you.
You explain in the preceding paragraph,
paragraph 79, that the Department had the same rights as
UKGI in relation to receiving information and reports
from the Post Office, concerning the litigation; is that
right?
That's what I believe the protocol said, yes.
You go on to say at paragraph 18:
"In practice, however, it was made clear by the
Department that it expected UKGI to take the lead on
monitoring the litigation and keeping the Department
informed. As I explain below, the Department was
provided with regular updates throughout the litigation.
My perception was that the Department was interested in
the progress of the litigation, and wished to be
updated, but did not envisage playing an active role in
the oversight of the proceedings. This is reflected in
the read out from the UKGI quarterly portfolio meeting
on 5 July in which it is record that whilst it was
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UKGI's view that the Department's Legal Team should be
involved at every stage of the litigation, securing such
a level of engagement ‘may be a challenge’.”
Do you consider that you were hampered in your
oversight of the Group Litigation by the Department's
refusal to engage more meaningfully, as you saw it?
Sorry, was my effectiveness hampered?
By your perception that the Department were not engaging
more meaningfully?
I think the Department could have been more effective on
areas where I had thought it would matter to them, yes,
had they been more involved. And, as I said earlier,
I think the absence of meetings to talk about this, the
litigation, was, you know, regrettable.
You go on to say in the same paragraph that:
"As I explain below, there was a step-change in the
active interest from the Department following the
handing down of the Common Issues judgment and the
subsequent progress towards settlement, but, with the
exception of the meeting between [Post Office] the
Minister, the Permanent Secretary and others in October
2018, prior to that point the model was largely one of
UKGI providing the Department with progress updates."
I just want to test with you briefly whether your
recollection in relation to the timing of the
129
in November. So I think that meshes, that's consistent.
But you're right, I had said earlier I had no
recollection of Kelly asking for more information until
March 2019, and you're right, there's evidence here that
she was asking for it earlier.
Thank you. Finally, I'd like to ask you some brief
questions about the Department's reactions to the Common
Issues judgment. You address these at paragraph 170 of
your statement on page 80. That reads:
"The Common Issues judgment was formally handed down
on 15 March 2019. On the same day there was a meeting
for [Post Office] to brief Departmental officials. The
ministerial briefing to which I referred in my email to
the Board took place on 16 March, the day after the
judgment was handed down. I recall the Department being
very concerned about the judgment and what could be said
publicly in response. During the course of the briefing
... [recall the Secretary of State, Greg Clarke MP,
making a comment to the effect that he had always
believed the [subpostmasters] were right and that it was
now important that these cases were resolved as quickly
as possible.”
You then go on to say:
"I had not previously heard those views previously
expressed by the Secretary of State (or anyone else in
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10 July 2024
Department's intervention is quite right. Can we look,
please, at UKGI00008656. This is a summary of a meeting
you attended with Kelly Tolhurst on 19 November 2018
produced by an official in UKGI. It reads:
"All,
"We had a meeting with Kelly Tolhurst this
morning -- Tom C [presumably a reference to you] dialled
in, whilst Sam W, Sam R and I were in attendance.
It goes on to say:
"Kelly had concerns over [Post Office's] potential
liabilities over the court case.
"She was sorry to hear Paula is leaving but
suspicious about the timing given the ongoing litigation
case and asked about the process for getting her
replacement."
It says:
“Keen to be properly briefed as the litigation case
progresses and would welcome both verbal and written
updates on a biweekly basis ...
"She would also welcome a face-to-face meeting with
Tom C..."
Thank you, yes, so I understand what you were saying
earlier now. So I think, firstly, my witness statement
is accurate because the period I was addressing in my
witness statement was up to October 2018, this email is
130
the Department)."
You appear to be suggesting at various points
throughout your statement that the handing down of the
Common Issues judgment marked a turning point in the
Department's engagement in the litigation; is that fair?
Yes.
Were you emboldened by the intervention of the Minister
to take more decisive action in your oversight of the
litigation?
Not reallly. I felt I was engaging with the litigation
in the way I thought it was appropriate for
a Non-Executive and a member of the Shareholder Team.
I don't think I was particularly -- I mean, the Common
Issues judgment was massive event, and it needed to be
fixed. I don't think I needed Greg Clarke's views about
the litigation to change how I approached that.
My point in relation to his views were that I think
they -- had I known, it possibly might have made
a difference before the Common Issues judgment and
I think it might have made me more challenging in terms
‘of what I was hearing from the postmasters. I mean, it
would be good to know why he thought the postmasters
were always right and, perhaps, you know, that would
have been good to get, to help me. So my point was in
relation to pre-Common Issues, rather than post.
132
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Q. His intervention coincided, did it not, with your
decision to initiate discussions with the Chair about
the replacement of the Post Office Legal team?
A. Yes, but they're not connected. I formed my own —-
I think I explained earlier the first Board meeting
after the Common Issues judgment was handed down, and
the interaction I'd had with Jane MacLeod at that
meeting, and I said earlier that I -- something to the
effect that at that point I'd lost all faith, whatever
faith I had left in the Legal Team, and it was off the
back of that that I felt it was imperative that the
Legal team was changed, and that prompted me to discuss
it with Tim Parker and we got on quickly with making
that change. So that would have happened independently
of whatever Greg Clarke had to say on the topic or not.
Q. Do you consider the Department was in any way
instrumental in bringing about a change in strategy
within the Post Office in respect of the litigation?
A. No, because I think everyone was completely aligned.
I mean, the Department was -- and the Board were in the
same place. You know, something had gone badly wrong,
it needed to be fixed as a matter of urgency.
Where I think -- had the Department said, "Hang on
a minute, we don't want you to settle with the claimants
or, you know, spin this out as long as you keep -- as
133
beginning of your role as a director or did that sort of
emerge as time went by, so to speak?
A. No, it was pretty early on, Sir Wyn, and, you know, the
kind of formal feedback I got through Tim Parker to Mark
Russell came, I think, in the summer of 2018, but it was
clear earlier on that some of the individuals we'd dealt
with in the company were not happy with the way -- with
what we were trying to do.
SIR WYN WILLIAMS: All right. Can you actually pinpoint any
individuals who made that clear to you?
A. I think, if I can say, the communication of it came more
through actions than words, or responses to requests,
and I think that the issues we had were with the --
predominantly the Legal team, with Jane MacLeod and Rod
Williams primarily, and, you know, there were specific
issues with the Finance Team, with Al Cameron.
‘SIR WYN WILLIAMS: All right, thank you very much.
Well, thank you, Mr Cooper, for your detailed
witness statement and for giving evidence interesting
the course of this morning and into this afternoon. I'm
grateful to you.
THE WITNESS: Thank you.
SIR WYN WILLIAMS: So, Ms Hodge, I won't disappear. I don't
think I need to disappear. I'll just wait for the
handover.
135
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long as you can", whatever, if they'd had a different
motive or agenda from the company, then the Department's
views would have made a difference but I think all of us
were completely aligned in what we wanted to happen
afterwards.
Q. Towhom, therefore, do you credit the significant change
in litigation strategy which resulted in a settlement of
the Group Litigation later in 2019?
A. Sorry, say that again?
Q. To whom do you credit the change in litigation strategy,
which resulted in the settlement in late 2019?
A. The Board. The Board. This had gone badly wrong, it
needed to be solved and the claimants were right, the
Post Office was wrong. It had to be settled and the
people affected had to be compensated.
MS HODGE: Thank you. I've got no further questions.
A. Thank you.
Questioned by SIR WYN WILLIAMS
SIR WYN WILLIAMS: Just before you finish, Mr Cooper, at
various points in your witness statement, you suggest
that Post Office Executives thought that your approach
to your role as a Non-Executive Director was a bit too
enquiring and a bit too interfering.
Can I just try and get some detail of that? First
of all, was that something you felt almost from the
134
MS HODGE: Thank you, sir.
SIR WYN WILLIAMS: I see Mr Stevens is in pole position next
do you so —-
MS HODGE: Ready to go. Thank you.
(Pause)
MR STEVENS: Good afternoon, sir. Can you hear and see me?
SIR WYN WILLIAMS: Yes, thank you very much.
MR STEVENS: Thank you, sir. We'll be hearing from
Mr O'Sullivan.
PATRICK HENRY PIERCE O'SULLIVAN (sworn)
Questioned by MR STEVENS
MR STEVENS: Thank you. Please can you state your full
name.
A. Patrick Henry O'Sullivan.
Q. Thank you, Mr O'Sullivan, for giving evidence to the
Inquiry and thank you to you for producing a written
witness statement, which should be in front of you. Is
that in front of you?
A. Yes.
Q. For the record that witness statement is reference
number WITN11000100. Before I take you to your
signature, I understand there's a correction to be made.
Please can we bring up page 2 of the statement,
paragraph 5. So in paragraph 5, there are two
corrections to your qualifications in the second
136
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sentence. I believe the first is that the words "arts
in" should be removed so it just says, "bachelor's of
business studies"; is that correct?
Correct.
Secondly, the words "master's of economics" should be
removed and in place it should read "MSC in accounting
and finance"?
Correct.
Thank you. That statement can come down now. Thank
you. Can I ask you, please, in your hard copy to turn
to page 23.
Yes.
There should be your signature or a Docusign version of
it; do you see that?
Ido.
Itis your signature, is it?
Yes.
Can you confirm, please, that the facts stated in that
witness statement, subject to the corrections you've
just made, are true to the best of your knowledge and
belief?
They are.
That now stands as your evidence to the Inquiry. The
statement will be published on the Inquiry's website
shortly. I am going to ask you some questions about it.
137
commitment for the role of Deputy Governor was one day
per week?
That expanded, depending on the need at the time. It
could have been --
You anticipated my next question. In practice, how
often did you, on an average week, spend working as
Deputy Governor?
Two days a week.
Two days a week. You were appointed as a Non-Executive
chair of Old Mutual Plc in 2010?
Correct.
In your witness statement, you say that the time
commitment for that was four days a week?
That is correct.
In practice, how much time did you need to spend on
that?
Three days a week.
So less time than -- okay. From 2013, you were Chair of
Lloyd's Syndicate 2187
Correct.
Do you remember roughly when in 2013 you started that
role?
I believe it was September.
September 2013?
(The witness nodded)
139
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'll start with your background. You trained as
a chartered accountant; is that right?
Correct.
During your career, you worked in a number of executive
positions at various financial institutions?
Correct.
You began to undertake Non-Executive roles in 2007?
Correct.
I think your last executive role was as Vice-Chairman of
Zurich Financial Services, which you resigned from in
2009?
Correct.
Since then you focusing on non-executive roles.
(The witness nodded)
Correct.
Thank you.
You became Non-Executive Chairman of the Audit
Committee of the Bank of Ireland in 2009?
Correct.
You became Deputy Governor of the same institution in
2011?
That's correct.
You stayed there until 2015?
Yes.
In your witness statement, you say that the time
138
What was the time commitment for the Lloyd's Syndicate
role?
One day a month.
Did that translate into how much time you actually spent
‘on it?
It did, except for the occasional phone call, et cetera.
So you were appointed to become the Chair of the
Shareholder Executive Board -- well, you were appointed
on October 2011 but you started that position in March
2012?
That's correct.
In your witness statement, if we could bring it up,
please, paragraph 6, page 2, so in the middle, we see it
says -- sorry, before there we see you refer to the
Deputy Governor role. Then you say:
"The Secretary of State appointed me as Chair of the
[Shareholder Executive] Board in October 2011, with
a start date of March 2012. The time commitment for
each of these roles was one day a week."
Pausing there, I think in practice you said that was
two days --
(The witness nodded)
-- and then two days a month respectively. So what
you're saying in the witness statement is the Chair role
took up two days a month; is that right?
140
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Excuse me, that's technically incorrect. It was one day
aweek.
One day a week. That statement can come down. Thank
you. Did you have sufficient time to commit to
Shareholder Executive, given your other commitments to
Old Mutual and the Bank of Ireland?
Yes, in -- I put in the extra time to the extent that it
was required, at weekends, evenings, or whatever.
At any point did you feel that you were in conflict, in
the sense that you had too many tasks for different
companies?
Well, jumping ahead, that was one of the major reasons
that I did not extend beyond September '14 because the
intensity of the work with Old Mutual was exceptional at
that point.
Did you feel you were able to honour your commitment and
the time required to the role as Chair of ShEx?
Yes.
Let's look, then, at the role of ShEx, please.
Actually, if we can bring back up the statement,
page 10, paragraph 26. It says that:
“lam asked to address matters that go to reporting
and risk structures within ShEx. These evolved over
time, and I understand the evolution of these matters
will be addressed fully by other UKGI witnesses to the
141
is that right?
That is correct.
We don't need to bring this up but, at paragraph 18.2 of
your statement, you say that you think this document
fairly reflects the role of the Board of ShEx?
That is correct.
In particular, you refer to paragraphs 6 and 7 of some
terms of reference which are appended to it. If we
could look further down the page, please, paragraph 7 is
quoted there, and it says:
"... of the existing Terms of Reference sets out the
Board's overall remit: ‘The Board has an advisory role
in relation to the work of the Shareholder Executive as
awhole. This will include setting strategic direction
in the 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."
It says:
"This holds true but, more specifically, the Board
should expect to ...”
Then if we turn the page, thank you, we see some
other points there. One of them is:
"Review the progress and status of big projects ...”
"Projects", is that referring or will it include
143
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Inquiry."
I think you may be referring to Mr Russell, who
appeared yesterday, and the witnesses next week; is that
right?
That's correct.
Would you agree that one of the core roles of the
Executive of any body or company or Government
department is to identify, analyse and mitigate risk?
Yes, it's among the important governance requirements of
any Executive Team.
In respect of ShEx, the Executive were required or
needed to take steps to identify, analyse and consider
mitigation for risks of its assets, such as Post Office
Limited; would you agree?
Ido.
Whose responsibility was it to carry out that risk
management?
That was the responsibility of the team specifically
within ShEx reporting to the CEO.
I want to look at the ShEx Board now, of which you were
the Chair and look at what its role was in respect of
risk management whilst you were there. Please could we
bring up UKGI00041953.
This is a paper on the ShEx Board's remit, which
I understand was prepared by your predecessor as Chair:
assets such as the Post Office?
Yes, but it's important to remember that the Post
Office, when this was written, of course, was such
a division of Royal Mail.
Yes. Until April 2012, when it became under direct ...
Correct.
We're going turn to that shortly, but do you agree with
the suggestion here that this also formed part of the
Board's responsibilities?
Absolutely.
That document can come down, thank you.
At the Board level, what role did you see the ShEx
Board as having in respect of risk management?
Well, as I think has been pointed out by Mark Russell
yesterday, it was an evolving process but it was very
clear that the experience level of the Shareholder
Executive at the time that I assumed my position did not
have, at that point, the benefit of current risk
management, as practised in most major corporations that
I was part of. And it became our objective to begin to
improve that process and, as you heard, a Risk Committee
was established under Fiona MacGregor, and then, later
‘on, the RAG or Red, Amber and Green analysis process was
commenced and then refined in 2014.
You say that it evolved. When you started in your role
144
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The Post Office Horizon IT Inquiry
as Chair, what steps did you take as chair, or did the
Board take, in respect of improving risk management?
We spent quite a bit of time discussing the process as
currently practised at that point in the corporations
that I happened to be involved with, with Mark, and he
duly took up the cudgel and went to work on applying
those standards, taking advice from some of the
corporations that I worked with.
In order for the Board to properly carry out its role,
did it need to satisfy itself that the executive had
identified the appropriate risks for each asset?
Well, as I indicated, it was an evolving process and
just the number and size and complexity of what was
being looked at and reviewed at that time was, by any
standards, very heavy. Particularly in the light of the
fact that Royal Mail was being floated and all of those
issues around the impact on the shareholder's investment
in Royal Mail, nuclear decommissioning, which was
costing hundreds of millions of pounds a year, the
establishment of the British Business Bank, the Green
Investment Bank, so in the context of looking and
reviewing the risks around those investments, it
depended on the size and scope of the particular
investment.
And at that point in time, at the beginning in 2012,
145
do you think it would have assisted the ShEx Board to
have someone with experience of the legal function of
a corporate body?
Well, in the context of the Board's knowledge or indeed
the Shareholder Executive's knowledge of what the
prosecutions were being -- what the impact of those
prosecutions were at the time, it was very, very
limited. In fact, I cannot remember a discussion at any
point in time in my tenure on the Post Office
prosecutions issues. There was a discussion which was
between myself and the Chairperson of the Post Office
around the key issues that were concerning her at the
time. This was the standard type of questioning that
I had for each Board member that I interacted with, and
her response was that it was just some challenges
dealing with the subpostmasters and their union.
We're going to come to that. I assume you're talking
about a meeting with Alice Perkins?
Correct.
We'll come to that shortly. Can we please bring up
UKGI00045855. This is a letter to you dated 4 October
2011, it's your letter of appointment. If we could turn
to page 3, please, to paragraph 3b. It says:
"As Chairman, your key role will be to provide high
level strategic direction to the Shareholder Executive."
147
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Post Office would have been well down the list in the
context of the perceived levels of risks.
I'm asking you questions generally there but we'll test
that as we go through the chronology. I'll stick with
a few other general questions first, though. The first
is: did anyone on the ShEx Board have expertise in the
legal function of a corporate body?
Not specifically.
Why not?
We were not a corporation that was constituted under the
Companies Act. We were an advisory board and, as
judged, I think, by my predecessor and subsequently
reinforced by me, the key was to get a skillset around
that board table of great experience, which would
complement and supplement some of the lack of experience
within the Shareholder Executive.
Two points, there. Firstly, in terms of identifying the
skills required at the ShEx Board meetings and who was
a member of the Board, was that your responsibility as
Chair?
linherited a Board from the outset and changes to that
Board were my responsibility.
When we consider that one of the assets that ShEx was
overseeing, Post Office Limited, we consider that it was
prosecuting subpostmasters, which was a legal function,
146
We don't need to go through all of them. One of
them is to:
"develop a constructive, frank and open relationship
with the Chief Executive, holding him/her accountable
for the effective implementation of decisions ..."
Did you consider that to be a personal
responsibility, to hold the Chief Executive to account,
in respect of his duties in relation to risk management?
Most certainly.
That can come down. Thank you. My last sort of general
topic on Post Office Limited as an arm's-length body.
Please could we bring up your witness statement at
page 3, paragraph 10. Thank you. You say at
paragraph 10:
"The Secretary of State for [the Department of
Business, Innovation and Skills], at the time, had
ultimate responsibility for the ... shareholdings in
Royal Mail Group and [Post Office Limited]. The
Secretary of State could not delegate his
responsibilities."
When you refer to the Secretary of State's
responsibilities here, what are you actually referring
to?
In respect of arm’s-length bodies.
Could you define precisely what the responsibilities
148
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are?
We did not, no, those were defined either in practice,
or
Sorry, what I mean is when you're here in your witness
statement saying "had ultimate responsibility", and
you're saying the Secretary of State could not delegate
his responsibilities, my question is: precisely what
responsibilities are you referring to when you write
these sentences?
I can't recall the distinction between whether they were
actually delineated in writing but, obviously, the rules
and the overview of how an arm's-length body, such as
the Post Office would have been run and managed would
have been set out either in emails or statutorily.
Let me ask it another way: when you were writing this
part of your statement, what did you think was required
of the Secretary of State when you said that the
Secretary of State could not delegate his
responsibilities?
Well, I believe that the Shareholder Executive was
acting as his agent, if you like, that may be the wrong
legal term, in ensuring that he was -- he or she, but it
was a he -- were aware of all of the key issues that
needed to be elevated to his level, so that issues that
were important, either politically or in the context of
149
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."
As an intelligent and informed shareholder, should
the Government have taken steps to satisfy itself that
the businesses it owned were following these principles?
Well, the Government was -- through Martin Donnelly, the
Permanent Secretary, was assured on an ongoing basis as
to where we might or might not have been performing
under these requirements, these principles.
Let's frame it in another way. If the Shareholder
Executive is, I think using your words, acting as an
agent of Government -- I think that's what you said
earlier?
Yes.
You're nodding. Yes. When it says, "What government
expects of its businesses", let's consider "business"
there to be Post Office?
The business to be?
The Post Office?
Yes, correct.
Do you think, as the Shareholder Executive in managing
the Government's shareholding function, that the
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funding, et cetera, were made very clear to him.
If we look, maybe, at UKG100044314, please. You refer
to this in your witness statement as the ShEx Handbook.
At page 2, please, right at the bottom, so "The
Shareholder Executive model of corporate governance":
"The Government intends to operate as an intelligent
and informed shareholder."
Then, if we go over the page, please. "How the
Government intends to operate as a shareholder’, it
says:
"The basic shareholder model as set out below
summarises the key actions of the shareholder ..."
Then in the box, we don't have to read it all but
you'll see it there, the final one is:
"The shareholder monitors the performance of the
business to satisfy itself that the strategic plan is on
track and ensure that any interventions required are
well informed and appropriate.”
Are these the responsibilities you were referring
to?
Yes, they certainly were among the key responsibilities.
If we can turn the page, please, we have what the
Government expects of its businesses:
"Principle 1. Businesses should seek an honest,
‘open and ongoing dialogue with the Government as
150
Shareholder Executive should have taken steps to see
that, for example, the Post Office was complying with
principles 1 and 2?
There was no reason to doubt that an honest, open and
‘ongoing dialogue was not taking place between Post
Office Executives and the Shareholder Executive.
That's a slightly different answer. That's to whether
or not what actually happened. I'm asking as a matter
of principle whether you accept that the Shareholder
Executive, as acting as an agent of government, as you
said, owed steps to satisfy itself that principles 1 and
2 were being complied with?
I agree completely.
That can come down. Thank you. Can we go back, please,
to your witness statement, page 3, paragraph 11. You
say that:
"The Secretary of State, in my view, cannot have
been expected to have taken any more of an active role
in overseeing the day-to-day operations of Royal Mail
Group and/or [Post Office]. This reflects usual
practice -- the role of a shareholder is not to manage
the operations of the company.”
There's a difference, isn’t there, between managing
the operations of a company on the one hand and
overseeing the management of a company's operation on
152
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another?
There is.
You go on. You say:
"Nor was it the function of [the Department for
Business, Innovation and Skills] (or ShEx, as
an organisation within [that Department!) to be
responsible for the operations of Royal Mail Group
and/or [Post Office Limited]. Responsibility for the
company's operations was with the [Post Office] Board,
comprised of senior management and independent
Non-Executive Directors, including a representative of
the Secretary of State, through ShEx, the Shareholder
NED."
Breaking that down, you say it wasn't the
Department's role to be responsible for the operations
of Royal Mail or Post Office. Is that your evidence?
Correct.
You then say that the responsibility for the company's
operation was with the Post Office Board?
Yes.
You say that the Post Office Board was comprised of
Executive Directors and independent Non-Executive
Directors --
Yes.
-- and the responsibility for the company's operation
153
I would.
I want to look at some of the specifics now in the
oversight of Horizon. Could we look at page 20 of your
witness statement, please, paragraph 45. Thank you. At
45, you say that you've been asked -- that's asked by
the Inquiry -- whether the ShEx Board was informed or
had knowledge of the following matters and in the
subparagraphs there's listed various matters, including
some documents that the Inquiry sent you. You see
there's the Second Sight Interim Report at 45.3; then
the Clarke Advices; and 45.7 there's Deloittes Project
Zebra Report.
If we turn over the page, please, and have
paragraphs 46 and 47 on screen, if we can. Thank you.
You say:
"The matters and documents referred to at paragraph
45 ... were not raised with the ShEx Board."
That's correct.
Now, in paragraph 47, you refer to a conversation with
Richard Callard about the instruction of Deloitte. I am
going to come to that later. Excluding that, were any
of the matters or documents referred to in paragraph 45
raised with you personally outside of the Board?
No, they were not.
At 46, if we can just go back up, please, you say:
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therefore lay with those Directors?
Yes.
One of those Directors was the Shareholder Non-Executive
Director, correct?
Correct.
That was a Shareholder Executive official, correct?
Correct.
You describe that person as the Secretary of State's
representative?
Yes, correct.
Why, then, do you say that ShEx and the Secretary of
State did not have responsibility for the day-to-day
running of the company?
Well, what I said was they don't get involved on
day-to-day decisions nor the normal requirements of
management in deciding on investment policy, et cetera.
This is an issue where the Secretary of State, through
the full time appointment of a ShEx representative of
the Board, ensured that adequate oversight and review
was happening.
Yesterday, the Inquiry heard evidence from both Mark
Russell and Robert Swannell. They agreed that, as
an arm's-length body, the Minister was ultimately
responsible and accountable for the operations of Post
Office; would you agree with that?
154
"What information is passed to the ShEx Board is
dependent on what ShEx Team and the ShEx CEO deem to be
an issue that required the attention or advice of the
ShEx Board. It is now clear that the documents referred
to raised serious issues in relation to the functioning
of the Horizon system, and the prosecution and treatment
of subpostmasters. I think that both ShEx and the Board
should have been made aware of these very significant
matters."
That can come down. Thank you.
It may seem an obvious question but can I ask you
why you believe that the ShEx Board should have been
made aware of those documents and matters?
It became clear, in hindsight, reading the documents
now, that there was a lot of -- there were many issues
happening in the context of that relationship with the
subpostmasters and, indeed, although not in absolute
volume terms, a huge number of issues being raised in
Parliament. Though we should have had a mechanism that
would have allowed us to be aware of just those factors.
Whether it would have led to a different advice is
something I couldn't comment on.
I mean, is it the fact that the matters raised go to the
heart of the operations of Post Office Limited?
They --
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The significant issues, for instance.
Yes, they do.
On that basis, they posed a significant risk to the
business?
Yes, and that's only evident on hindsight. For example,
the Linklaters report, which mentioned a risk of
100 million, 0 to 100 million in settlement risk, which
was a significant number in reference to the P&L of the
Post Office. That should have been flagged.
Can I ask you how often would you meet people from the
Post Office team within the Shareholder Executive?
My role was to meet with the Chairperson, which would
be, at most, twice a year.
Let me clarify the question, sorry. I'm talking about
within the Shareholder Executive those persons working
on the Post Office as an asset? How often did you --
Most of my time was spent with the Chief Executive,
Stephen Lovegrove, followed by Mark Russell, and the
individual team members only as issues arose. So the
leader of the team, Susannah Storey or, in later cases,
Roger, the -- it was more frequent but on, I should say,
an unplanned basis.
When you say “as issues arose", what issues are you
referring to?
Well, I'm referring in the main to Royal Mail issues at
157
No.
Let's look at your first Board meeting as Chair, please.
It's UKGI00045852. We see 7 March 2012, you're listed
as in the Chair. If you could go to the bottom, please,
of the document. There's an introductory paragraph, and
it says:
"Patrick informed the Board that he would step out
if there were any discussions on the Royal Mail side
relating to Bank of Ireland as he was Deputy Governor."
Did you ever have to do that: step away from
a discussion on Royal Mail because of your ongoing
relationship with the Bank of Ireland?
Yes, of course it should say Post Office, because the
relationship between Bank of Ireland on the Financial
Services side was with the Post Office, and I do recall
at least on one occasion recusing myself.
Do you recall what the issue was about?
The financial arrangements of the transaction.
When you say "the transaction”, is -
The agreement between Post Office Limited and Bank of
Ireland to supply certain Financial Services products.
If a person was raising with you an issue about Horizon,
which was the system that generated the data on which
Post Office put together its accounts and which it
provided information to its clients, would you have been
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the time.
So Royal Mail issues, so the company had separated in
April 2012 --
Correct.
- is that correct?
Correct.
The Secretary of State maintained a shareholding until
I think it was the next year; is that right?
Correct.
Is your evidence that the Post Office team were dealing
with Royal Mail issues still?
The -- no. I'm misleading you. The issue was that the
dominance of the Royal Mail issues in the context of
what the Shareholder Executive was reviewing and
following up with, it became a major exercise.
For example, you mentioned Susannah Storey earlier.
What issues did you discuss with Susannah Storey?
Well, things were discussed, really, through the Chief
Executive as to her experience on the Royal Mail Board
and the Post Office Board, and I believe Mark referred
to it yesterday, Mark Russell, when he said it was not
an easy relationship.
Can you recall any issues relating to the Post Office as.
a business, which you were aware of through Susannah
Storey?
158
able to deal with that or consider it without being in
conflict?
Yes, indeed. I don't think it would have been in
conflict at all.
Why do you think that?
Because the system -- the operation system through the
Post Office was not really related to the services
provided by Bank of Ireland.
Are you aware of there being any reluctance or reticence
within the team to discuss issues with you regarding
Post Office because of your relationship with the Bank
of Ireland?
None.
We mentioned earlier Susannah Storey and the appointment
of the Shareholder Non-Executive Director. Are you
aware how Susannah Storey was selected for that role?
That was the choice of the Chief Executive.
Are you aware of whether anyone -- well, let's say the
Chief Executive considered her suitability for the
appointment, or what consideration he applied?
It had already occurred by the time I started so
I didn't -- it didn't arise.
Could we look, please, at page 19 of your statement,
paragraph 43. You say:
"Following [Post Office Limited's] separation from
160
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Royal Mail its status was raised to priority level.
[Post Office Limited] had been a division of a major
asset, and now it was a major asset in its own right,
receiving substantial levels of funding from the
government and so it was wholly appropriate for ShEx to
take a more direct role in its governance."
When you say it was raised to priority level, what
did that mean in practical terms?
In practical terms, it probably meant that it was more
visible within the portfolio --
Visible to whom?
Visible to the Shareholder Executive management and, in
respect of peer reviews, for example, within the
Shareholder Executive, it would have been under much
greater scrutiny than it had been as a division of Royal
Mail. They're the points that strike me most of all,
I think.
Was it raised as a priority for the Board?
No.
Why not?
Because -- in the sense that it was reported on
occasionally in the time that I was in charge, it --
there was no change in intensity, in the sense that Post
Office was not perceived at that time to be an issue of
concer, of great concern,
161
Executive's visibility of the risk to Post Office
Limited were not clear, shall we say?
That would be absolutely a fair description.
If we turn to the page 2, please. If we go down to
Royal Mail, thank you, item 4, we see Royal Mail is
discussed. Over the page, please. It talks about State
Aid approval for Post Office funding. Then 4.2:
“Board members discussed a transaction, specifically
points around a trade sale [versus] IPO; employee shares
and the mutualisation consultation for the Post Office;
and union interest."
It doesn't appear that there was any discussion, or
a deep dive, as it were, into the risks of Post Office
Limited as an asset in itself --
Correct.
-- or in fact to the corporate governance of Post Office
now as an asset?
It would have been too early in the life of the Post
Office as an independent business to do that, at that
time.
Do you think, at some stage, that should have been done
by the Shareholder Executive --
Yes.
-- and by the Board?
Yes.
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MR STEVENS: Sir, that's probably a good time for the
afternoon break. If I could ask that we come back at
3.30, I'd be grateful. Thank you, sir.
(3.20 pm)
(A short break)
(3.30 pm)
MR STEVENS: Sir, can you see and hear me?
SIR WYN WILLIAMS: Yes, I can, thank you.
MR STEVENS: Please can we bring up UKGI00036711. It's
Po
minutes of a Board meeting on 8 May 2012. You say in
your witness statement that you're satisfied that these
minutes accurately record the discussions at the various
meetings.
Correct.
This is the first meeting after Post Office Limited
becomes independent of Royal Mail; is that right?
Correct.
So in terms of, as we discussed before, the governance
shifted in that, for the first time, the Shareholder
Executive and the Secretary of State were directly --
had a direct line, essentially, into Post Office
Limited?
Correct.
And is it fair to say that, previously, as Royal Mail
Group, as part of Royal Mail Group, the Shareholder
162
How long should it have waited until it --
Oh, only 18 months after establishment.
Why at this stage, when it was a business that had been
running for a while, in terms of the actual business of
the Post Office, why was then not the ideal time to
analyse what the risks were to the business?
The structure of the spin-off of the Post Office from
Royal Mail was one where it was business as usual for
the Post Office. There were no major changes in its
‘operating procedures.
Wasn't this a time when, after not having visibility of
the Post Office, ShEx now had visibility and could
understand the risks that that business had? Why didn't
it do that?
Well, as I said, I think some period of time after its
Official foundation would have been more appropriate.
Would you accept that the Board should have done risk or
a deep dive of a risk assessment of Post Office Limited
within the first six months, say, of separation?
There were no reasons at that point of time, visible to
the Board or to the ShEx Executive, that would suggest
that such a deep dive was required.
How could the Board satisfy itself that that was an
appropriate course of action without having done a deep
dive of what was effectively a new relationship with
164
(41) Pages 161 - 164
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an asset?
Well, you'll have seen the split of the categorisation
of the various parts of the portfolio and, at that point
in time, we had just appointed the first Shareholder
Executive representative to the Post Office Board. That
person and the whole organisation needed time to bed
down.
On that point, can we look, please, at UKGI00019348.
These are minutes of the Post Office Limited Board
meeting on 23 May 2012. Can we turn, please, to page 4.
If you can go down, thank you.
The Inquiry asked you to consider the entry at
POLB12/60 and your evidence was, or is, that you didn't
see these Board minutes at the time.
Correct.
If we look, it says Susannah Storey here is outlining
the reasons for representation of ShEx on the Board of
Post Office Limited and we see that she says at the end
of paragraph (a):
"She clarified that she would not be sharing the
Board papers with her colleagues at [Shareholder
Executive].”
Was that something you were aware of?
No.
Given the role of the Shareholder Non-Executive Director
165
She was highly regarded within the Shareholder
Executive. She was one of the most experienced members
of staff at that level and, of course, much of this too
would have been a learning experience for her, as well
as everybody else appointed to such positions.
Shortly after that meeting, Second Sight were instructed
to address concerns raised by Members of Parliament in
June/July 2012. Were you aware of that at the time?
No.
The MPs represented subpostmasters, some of whom had
been convicted on the basis of data generated by the
Horizon IT System; were you aware that there were such
convicted persons?
I was not.
Second Sight's terms of reference were to consider and
to advise on whether there are any systemic issues
and/or concerns with the Horizon system including
training and support processes, giving evidence and
reasons for the conclusions reached, so effectively
an investigation into Post Office's front-end accounting
system; do you agree?
Yes.
If Second Sight had found any issues with that, any
problems, that would have been significant to the Post
Office?
167
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was so important in oversight of Post Office Limited,
should the Board of ShEx have been aware of this
position?
It would have been perfectly reasonable for the
Chairperson to have requested that Board papers did not
go outside the Boardroom whether it was for the Post
Office or any other public company. However, there was
nothing to prevent Susannah from communicating the
essence of what the Board meeting and what the Board
Papers were saying.
But why wasn't you, as chair, and the Board aware of
what appears to be quite a significant self-imposed
restriction on sharing Board papers?
This is nothing unusual in the context of normal Board
practice.
So is it your evidence that the Board of ShEx didn't
need to know about this?
At that point, no.
So how could the Board understand the flow of
information from its assets, such as Post Office
Limited, to the Board?
Through Susannah as the representative.
What steps did you take to satisfy yourself that
Ms Storey was discharging her role as Shareholder NED
effectively?
166
It would.
Firstly, there would have been, or there could have
been, unsafe convictions if they'd found issues; do you
agree?
With the benefit of hindsight, absolutely.
Secondly, the data on which Post Office produced its
accounts would possibly be unreliable. Would you agree?
There's always a possibility. That depends on the
impact of what the judgment was in the context of the
financial impact on the balance sheet and P&L of the
Post Office.
At paragraph 31 of your statement you refer to meetings
of the Board on 11 July 2012 and the 12 September 2012
and you say there was no -- well, there was no reference
in those meeting minutes to the launch of the Second
Sight investigation. Why was such a significant issue
not raised with the Board; can you assist us with that?
Well, as I -- as I think -- again, with hindsight, it is
clear that these matters were believed to be business as
usual, and it was an internally sponsored inquiry.
It might be a surprise to some that the Chair of the
body of ShEx with responsibility for overseeing Post
Office wasn't aware of the Second Sight review. With
hindsight, where do you think the problem lay in this
not being raised to the Board?
168
(42) Pages 165 - 168
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I believe that the modus operandi of the Post Office
Management team was the assumption that the system was
adequate and did not have systemic issues. It may have
been a self-reinforcing view that they took and their
approach to any review of the system as a consequence.
Do you think you should have taken more interest in the
Post Office itself as an asset?
I think that interest grew significantly as time
progressed. But perhaps, with hindsight now, the answer
is probably yes.
When did it grow, your interest?
It grew over the two years that I was -- two and a half
years that I was Chairman.
What caused your interest to grow?
The size of the request for Government funding, the
nature of the political decisions around, sadly, not the
ones we're discussing here, but rather the issues of
Post Office representation around the country, the
ownership of last mile in delivery and postcodes. Those
issues became very important.
So as you gained more interest and became more involved
can you help us with how you, as you say, in your
statement, remained unaware of issues such as the
prosecution of subpostmasters?
Can you say the question again, please?
169
It never came up in that context.
Just to be clear, when you say concerns, is that
concerns in relation to the business or concerns in
relation to Post Office Limited or concerns in relation
to how ShEx was overseeing the business?
All of the above.
You say -- we don't need to bring it up -- that in one
of the meetings with Alice Perkins -- sorry, sir, it's
page 14 paragraph 31.2, if you want to review it -- you
say that you remember Alice Perkins mentioning, almost
as a passing comment, that there was a small segment of
difficult subpostmasters and ongoing difficulties with
the union?
That's correct.
Did you ask any questions about those difficulties?
I can't recall what the substance of the conversation
was but it was very much in the vein I've mentioned of
this is just business as usual, we're getting on with
it.
Did you discuss, though, those issues with anyone at
Shareholder Executive?
Mark Russell and I had some conversations about the
effectiveness of the Post Office Management, which
was -- some of my concerns were that they could have
been doing a better job.
171
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Yes, so as your interest grew and you took more of
an interest in Post Office Limited, can you assist us
with how, when you were discussing Post Office with
people, you apparently remained unaware of issues such
as prosecution of subpostmasters?
I think I said at the beginning that these issues were
regarded as business as usual, by Post Office
Management. In that sense, there was no evidence or
urgency around it, nor that indeed it might be severely
damaging.
You referred to, in your statement, biannual meetings
with the Chair of Post Office, yes?
Correct.
What was the purpose of those meetings?
My role in taking over the chairmanship was to bring
corporate experience to bear on the review of portfolio
companies. I'd had a lot of that experience in prior
roles as Chief Executive and subsequently Chief
Financial Officer of financial institutions.
We instituted what was called a fireside chat review
with the Chairpeople, where there was an attempt to
create an atmosphere that was non-threatening, so that
they could express, without fear of retribution, any
issue around their major concerns. The question
normally phrased was "What keeps you awake at night?"
170
Who within Post Office Management?
That's the chairperson and the CEO.
So you had a conversation with Mark Russell about
whether they could have been doing a better job?
We -- and that is normal. We did this with all the
portfolio management team.
What were your concerns with the Chair and the CEO?
I -- in particular in the context of the Chair,
an appointment which preceded my time in ShEx, I had
a concern that Alice's experience was not particularly
suitable to the role of chairing a business of this
nature.
What were the basis for those concerns?
My personal experience.
What about Paula Vennells? What were your concerns with
her?
No, those were more in the nature of the points raised
which led to a review of her performance later on.
What were they?
I can't recall.
When you were having meetings, these fireside chats, as
you described them, were you briefed by anyone at
Shareholder Executive prior to the chat?
Yes, by the portfolio responsible -- portfolio
individual responsible.
172
(43) Pages 169 - 172
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As part of that briefing, did no one raise with you the
Second Sight review?
No, they did not.
Let's move forward in the chronology. We have the
Second Sight Report that's published, the Interim Report
‘on 8 July 2013. My understanding of your evidence is
that this wasn't discussed at Board level?
That's correct.
Your evidence is that you weren't made aware of it?
Correct.
Were you made aware of the involvement of the CCRC in
investigating past convictions of subpostmasters?
I was not.
I want to look at one matter in particular where you say
you do have some knowledge. Can we bring up, please,
page 20, paragraph 45 of your statement -- sorry,
page 21, paragraph 47. So we've been to paragraph 46
already, that's where you discuss your knowledge of
various documents. Paragraph 47 says:
"... [should add that I recall a conversation with
Richard Callard in which he referred to Deloitte having
been instructed to conduct a review to give assurance in
respect of concerns raised in Parliament. I recall
saying to him that I had experience of Deloitte, and
would recommend them."
173
Would you consider to be business as usual for
a business to face concerns raised in Parliament about
its accounting software?
It's highly unusual and, looking back on it with
hindsight, there was a level at which the inquiry, the
inquiries, or rather the issues, being raised by MPs,
had risen to a volume that should have been brought to
the attention of the Shareholder Executive in the first
place, and possibly to the Board after that.
Well, if we bring up your witness statement, please, at
page 22, paragraph 50.
SIR WYN WILLIAMS: While that's being done, can you give me
some indication of the year in which you had the
conversation with Mr Callard, ie was it towards the end
of your period or some other time?
Yes, sir, it was towards the end of my period about
April time.
SIR WYN WILLIAMS: Yes, April 2014, yes.
A.
Yes.
SIR WYN WILLIAMS: Fine. Thank you.
MR STEVENS: In these paragraphs, you're saying, you're
commenting, on things you would have handled differently
and giving reflections. In paragraph 50 you say, as
a leader point, you say:
"I believe that it could have been helpful for ShEx
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In what context was that conversation with Richard
Callard?
He was the head of the team at the Shareholder Executive
with responsibility for Post Office and, in my normal
occasional conversation with those positions, those
people in those positions, I tried to impart some of my
knowledge of who would be the best people in the context
of an external review. It was at that point -- I had
never heard of Second Sight, never -- had no experience
of them. So I tried to press on him that the Deloitte
team would be best equipped to do the kind of deep dive
required to determine what the issues were. As it
turned out, they did a desktop review.
Did you ask what the issues were, that were to be
investigated?
He mentioned they were around the Horizon system at that
time, the "systems", quote/unquote.
Did he refer to the fact of subpostmasters being
prosecuted?
No, he did not, to my memory.
You say that he was -- he said it was to review to give
assurance in respect of concerns raised in Parliament.
Did you continue to believe that it was business as
usual at this stage?
Yes, I did.
174
board packs to have a schedule of significant issues
raised in Parliament relating to Government assets where
ShEx handled the shareholder role."
Well, the fact that Parliament was -- concerns had
been raised in Parliament was raised directly with you
by Richard Callard, why did that not set alarm bells
ringing as to the significance of this issue with Post
Office Limited?
Most probably because of the timing. In other words,
the reviews were just, in the case of Deloitte,
beginning, rather than at the end, and I had not had any
knowledge of the Second Sight Interim Report.
Do you think, at this stage, you should have asked more
questions on the background to the issue?
With perfect hindsight, absolutely.
Well, not with hindsight. If you're told that there are
concerns raised in Parliament about a business that the
Shareholder Executive is overseeing, do you think, with
the information you had at the time, you should have
asked more questions about it?
I think the level at which the number of questions being
raised -- it started in the single figures, and then
eventually rose to 47, I believe, by about this time; 47
is certainly a number that should have been raised.
47 what, sorry?
176
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47 specific questions in Parliament from different MPs
about the Horizon system.
That's a slightly different question. I'm asking: at
the time, with what you knew, should you have asked more
questions of Richard Callard or the Shareholder
Executive Team, once you'd been told that Deloitte were
involved and there were concerns raised in Parliament?
At the time, I felt I addressed the issue
satisfactorily.
Let's look at the Board Briefing, please. It's for the
Deloitte report. It's POL00028069. You've had a chance
to read this in preparing for your witness statement and
the Inquiry has seen it several times. I'll whistle
through the key points. Can we look at page 3, please,
and at the bottom, "Limitations and Assumptions". As
you said earlier, it's a desktop report. It says:
"... we have not validated whether Horizon has been
implemented or operated as described in the
documentation reviewed."
Second bullet point refers to "significant gaps
existing in the information available".
If we go over the page, please, you see it says that
the assumptions include that:
"The documents proffered are a complete and accurate
representation of the Horizon design."
177
Then over the page at 8, please. Down to Matter 5,
"Balancing transaction process", it says:
"an emergency process, accessible only to
restricted individuals in Fujitsu, which can create
transactions directly in Branch ledgers. This process
creates an identifiable transaction in the ledger,
verbally asserted by [Post Office Limited] staff to be
visible to subpostmasters in their branch reporting tool
but does not require positive acceptance or approval by
the subpostmaster. The use of the process has a full
audit trail, monitored by Fujitsu."
It goes on to say some various assertions. Then
finally, over the page, please, it refers again to the:
"Balancing transaction processes [that] are
controlled by Fujitsu via formal change control and
monitoring processes. An audit trail is retained over
the use of this process and, since 2008, when reporting
became easier, it is asserted by Fujitsu staff that the
audit trail is monitored by a Fujitsu department
independent of those with access to the function also in
Fujitsu. The degree of formality over this monitoring,
and its frequency, is unknown."
It goes on.
If this report had been put before the Board as, in
your evidence, you say it should do, what action do you
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Then, finally:
"Assertions made by [Post Office Limited] and
Fujitsu staff have been accepted as accurate without
corroboration or verification.”
Those are quite significant assumptions, aren't
they?
They are.
Can we turn to page 7, please. If we go down -- sorry,
stay there for the moment. Matter 3, the issue is:
"Baskets of transactions recorded to the Audit Store
are complete and ‘digitally sealed’, to protect their
integrity and make it evident if they have been tampered
with.”
We don't need to go through all the detail but, if
we see the third bullet point down, the final sentence:
"This could allow suitably authorised privileged
staff in Fujitsu to delete a sealed set of baskets and
replace them with properly sealed baskets, although they
would have to fake the digital signatures ...
"We have not identified any document controls
designed to:
“Prevent a person with authorised privileged access
from deleting a digitally sealed group of data and
replacing it with a ‘fake’ group within the Audit Store
178
think would have been taken by the ShEx Board?
We would have pointed out that a desktop review in the
context of everything that had been written warranted
a full blown analysis of what was going on with the
system.
When you say it warranted a full belong analysis, what
precisely do you mean?
It would mean going into a deep dive and audit of
transactions from start to finish, and the fallout or
implications of those actions, where there were, for
example, discrepancies.
If the report was before the Board, we've heard from
witnesses -- I think you listened to yesterday's
evidence about the degree by which oversight was
exercised by the Shareholder Executive, I think people
referred to arm's lengthening or shortening, would this
report have led to a shortening of the arms, in terms of
oversight of --
It most likely would have.
I'll move on and look at a matter in your statement
about Shareholder Executive, page 12, paragraph 30,
please. You set out, in paragraph 30, the various
structures that were in place to oversee Post Office
which we turn to. I don't need to read out.
You say:
180
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"... [believe that there was a governance structure
in place that provided an appropriate level of oversight
of [Post Office].
Does that remain your belief?
A. It does.
Q. How do you reconcile that with the fact that you say the
Board weren't aware of the significant issues referred
to, that you say it should have been aware of?
A. Because the oversight function is a two-way process,
it's both bottom-up and top-down. We were in the
top-down role as the Shareholder Executive. The
bottom-up process of understanding the risks, the
importance of those risks, the significance of them, and
bringing them appropriately to the Post Office Board,
failed.
Q. Could we look, please, at UKGI00016718. This a Board
meeting on 16 July 2014 of the Shareholder Executive.
You're in the Chair and Robert Swannell, who gave
evidence yesterday, who became Chair in September, was.
also in attendance, marked as RS, you're POS. If we go
down to "Risk Registers":
"The Board agreed that the revisions to the risk
register were a significant improvement."
It says at the end that:
[You] summarised that the key aim of the risk
181
burden on top of that process, if it was working
effectively. However, here we have a situation where
the Government is at arm's length from the shareholder,
in other words is arm's length from the business, but we
have a responsibility on behalf of the owners of that
business, who are the citizens of this country, and
their representatives in Parliament, who, when they
raise issues of significance -- and that's the key
difficult item to define, what is significant and what
is not -- that process should -- the full circle should
occur, which brings it back into the realm of the
Government bodies charged with looking after those
investments.
Q. Does there need to be better communication between the
Department and -- sorry, let me rephrase that.
When you were there, did you think there needed to
be better communication on issues like that between the
Department and ShEx?
A. I never that the impression that I wasn't -- didn't have
sufficient time, or not discussing the right issues with
both the Permanent Secretary and the ministers.
Q. At paragraph 51, you --
SIR WYN WILLIAMS: Before we get to 51, Mr Stevens, in terms
of the schedule of significant issues raised in
Parliament, I suppose the advantage of that is that it
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registers should be to provoke questions and cautioned
against further significant changes."
What significant changes were you cautioning
against?
A. I can't recall what was being proposed at the time but,
at this point, we had implemented the colour-coding and
the heatmap and that was best practice in industry at
the time.
Q. Were you satisfied with the process of risk management
in ShEx at this point?
A. Atthat point, yes. With hindsight, clearly there were
some shortcomings.
Q. Please can we bring up your witness statement at
paragraph 50. I want to look at some of the
recommendations that you suggest. It's page 22, sorry.
I should have said. We've been to paragraph 50 already.
This is where you say you believe it would be helpful
for the ShEx Board pack to have a schedule of
significant issues raised in Parliament. Do you think
that would add anything additional to a well-run risk
management process where risks were identified and
brought to board level?
A. It might. It may not. In the context of a risk
management system which cascaded the key issues to the
correct levels, it might have been an extra, additional
182
takes away judgment about risks, ie if something is
significant enough to be raised in Parliament, it's
significant enough for you to pay attention to it.
A. Well, sir, I would expect there would be a healthy
tension between the risk register in Parliament and the
risk function in the underlying businesses.
SIR WYN WILLIAMS: Exactly so. Yes. Sorry, Mr Stevens.
MR STEVENS: Notatall. Thank you, sir.
Paragraph 51, you say:
"In addition, I would like to have raised as a query
at ShEx board level the way in which ShEx Teams received
and challenged information received from Government
assets, as I believe it is now clear that there were
deficiencies in information flow within [Post Office
Limited] and up to ShEx."
What type of queries did you have in mind when you
were drafting this statement?
A. Well, I'm referring to the risks, the whole Horizon
issues, and whether these were being surfaced at the
right levels in the underlying asset, in this case Post
Office. So corporate practice, I might add, was in
constant change in the previous 10 years to this, where
a lot of risks were inadequately addressed in many
corporations. You only have to look at the failures,
but we won't go there, of public corporations. This was
184
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an ongoing exercise to improve how you raised the issues
and who signed off on raising those issues, so there was
accountability for raising the issue and being held
accountable that the issue was properly addressed in due
course.
So if you were thinking about what chairs of businesses
or bodies should do in future, what type of queries they
should be asking, what springs to mind?
Well, Boards are entirely dependent on management, and
the experience of the Board members. It becomes
a really critical issue, in the case of the Post Office
Board, whether they had the right mix of skills to
properly challenge internal audit, legal, risk
management, on the issues, and that is, of course, where
some of the weaknesses can appear.
The Inquiry will hear in the coming weeks from witnesses
who make other recommendations. One suggestion that
will be made is that there should be a change in the law
to empower a minister to become directly involved in the
decision making of the board of a company, such as Post
Office. What would your view of that be?
I think my view is that ministers have total authority
right now to investigate anything they wish to look at
and it might be superfluous.
MR STEVENS: Sir, that concludes my questions. I think
185
matter for POL."
Is that your understanding of where we were —-
That's correct.
-- at the time. So it follows then, doesn't it, that it
was your understanding that the ShEx team was informed
and instructed by POL, Post Office, in relation to
complaints that were escalated, or being attempted to be
escalated, to ministers through MPs?
I would not have had any sight of those issues.
Yes. But what you've said is that it was because of the
messaging from POL, which was being communicated to the
Minister via ShEx. So you were aware of the messaging
from POL, weren't you?
Yes, that was a normal -- this is, in effect, a sort of
dual mandate for the Shareholder Executive to
communicate back to the Minister and to help assist the
arm's-length business with that exercise.
What I want to ask you then is, in relation to
paragraph 37, Mr O'Sullivan you say:
"If the issues being raised by subpostmasters with
Horizon and the associated ministerial complaints had
been flagged as significant or as a significant issue by
the ShEx team, I would have expected to have had sight
of it.”
Is that your understanding?
187
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there are two sets of Core Participant questions, one
from -- how long?
Five minutes from Howe+Co and ten minutes from Hodge
Jones & Allen. That should bring us to a close within
time.
SIR WYN WILLIAMS: Good. So I shall look forward to the
discipline of the advocates in ensuring that,
Mr Stevens.
Questioned by MR JACOBS
MR JACOBS: We act for Alan Riddell, who is a subpostmaster
rPOoOPrO
from Sunderland, and he has travelled down here today
with Jean Smith. His wife Carol, who is watching,
I understand, remotely is unable to attend today. Now,
they were involved with the East Boldon Post Office, and
their member of Parliament, Stephen Hepburn, wrote to
Ed Davey as a minister in February 2012, and they say
they never received a proper reply beyond simple
acknowledgement.
Now, you say at paragraph 36 of your statement that
you had no involvement in this particular case. At
paragraph 38, you say:
"The messaging from Post Office through the ShEx
Team was that Horizon was robust, POL was addressing
matters including by way of the Second Sight Review and
the ShEx team considered that this was an operational
186
That's correct.
So what sort of complaint made by a subpostmaster or
subpostmistress communicated through a Member of
Parliament would have amounted to a sufficiently
significant issue for you to get involved,
Mr O'Sullivan; what would it have taken?
The reality in these situations is that it might have
been communicated on the basis of complaints about the
effectiveness or rather the usefulness of the IT system.
That would be a normal operating issue, not one for the
Board.
So that sort of complaint would get through to you?
It would not, normally.
What would get through to you, was my question?
Well, it's very clear now, with hindsight, that, as the
issues of complaints arose about the process used with
the subpostmasters to prosecute them and to prosecute
them as part of the Post Office's remit, which was
different than handing to it an external counsel to do
it, that sort of issue would have been -- should have
been raised.
Should have been. But what you said in your statement
is that complaints, ministerial complaints, if they were
flagged as a significant issue by ShEx, those are the
ones you would have expected to have sight of. I'm not
188
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talking about with hindsight; I'm talking about back in
2012 --
Yes.
-- and thereafter. What was a significant issue that
would have led to you having sight --
At that time, a threat to the financial performance of
the Post Office.
So there's nothing, really, it seems, that
a subpostmaster could have done to have gone over the
heads of the Post Office, to the owner of the company,
to the Minister, there's nothing that really would have
got to your attention; is that what you're saying?
It's difficult to see how that might have happened but
that's hence my recommendation that there would be
a risk register within Parliament to -- back to the
‘owner.
Do you accept, then, I think it follows, that when
subpostmasters such as my clients who sit behind me,
when they sought to escalate their cases to the
Minister, via their Members of Parliament, through the
democratic process, it was the Shareholder Executive who
blocked those attempts, wasn't it?
No, I would not agree with that.
Well, your statement says that these were considered to
be operational matters because of the messaging from
189
Contractual in the context of the day-to-day operations
of the business. As the significance of them grew,
based on the circumstances, independent judgement at
that time might have judged differently as to how
operational they were or how significant they were.
Isn't the reality of the matter that, if the Shareholder
Executive had said, "Our advice is these are probably
contractual matters, probably operational matters, but
these appears to be significant matters and the Minister
should look at them if the Minister feels that that
would be the right thing to do", that's the advice you
should have given, isn't it?
If we had had the information, absolutely.
You no doubt accept, then, that the Shareholder
Executive, in not giving that advice, failed
subpostmasters who tried to escalate their cases to the
Minister?
I respectfully disagree. I repeat that the issue is
what information the Shareholder Executive had to be
able to make those judgements as to complexity,
importance or significance from a Post Office
perspective.
MR JACOBS: = Thank you. I don't have any further questions
for you.
Questioned by MR HENRY
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POL. So they didn't get through.
But in the context of the Post Office Board, who had the
responsibility to determine the significance of these
issues, along with management, executive management. It
was not ShEx's role to second guess at that point what
the POL Board was doing.
You will no doubt have been following the evidence in
the Inquiry —
Correct.
-- and you will have heard perhaps the evidence in the
Human Impact hearings from subpostmasters?
Yes, and like everybody else, I regret them deeply.
These are all significant matters, aren't they, that
everybody has raised, all the subpostmasters?
They are indeed.
So these issues were in the public domain. Do you
accept that, when subpostmasters tried to use the
democratic process -- MP, Minister -- to escalate their
complaints, the Shareholder Executive should have let
them do that, should have let the Minister --
The Shareholder Executive did not stop the complaints
from Parliament reaching either the ministers or the
Post Office Board.
Well, they advised ministers that these were contractual
and operational matters?
190
MR HENRY: Mr O'Sullivan, you were appointed in 2011. Can
A
a
you help us when that was?
I believe it was October. It's on the appointment --
the appointment letter from my predecessor. Let me have
a look.
Let's take it as October, then, Mr O'Sullivan. So that
would be October 2011.
‘SIR WYN WILLIAMS: I think, Mr Henry, just to help, his
witness statement says appointed October 2011, started
March 2012.
MR HENRY: = Thank you very much, sir.
A
Qa
So October 2011, coincidentally, there was
an article in Computer Weekly which said 85
subpostmasters seek legal support in claims against the
Post Office computer system.
Throughout this Inquiry, we have seen, from inside
the Post Office -- and obviously not necessarily ShEx
because that was different -- but inside the Post
Office, an obsession with the media and how the plight
of the subpostmasters is being portrayed in the media.
Were you aware of that background?
No, I was not.
So it follows that, before your appointment, the six
stories in Computer Weekly -- I can go through them, if
you like -- the BBC News programmes, et cetera,
192
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et cetera, none of that permeated your consciousness?
Correct.
During your tenure, which was from March 2012 to
September 2014, we've got ten stories in Computer
Weekly; you were presumably not made aware of those
either?
That's correct.
Right, could we go to UKGI00016739, and while that is
being put up, you would accept, sir, would you not, that
the vital thing in any flotation is that the listing
particulars in the prospectus are completely accurate,
that you get a warts and all -- forgive that
expression -- but a warts and all picture of the
business so that anybody who wishes to subscribe or take
up shares is fully acquainted with proper risk?
lagree.
Right. So this is a ShEx Board meeting of 13 March 2013
and at page 17 of 39 we go to the proposed flotation of
RMG, and it's noted that:
"A number of critical transaction ‘enablers’ have
been confirmed in the last two months."
I omit words, and then further down we can see, if
we go to number 3:
"On the basis of this work we are now in a position
to recommend that:
193
completely?
I couldn't -- I couldn't necessarily agree with that
because --
Why not?
-- the analysis would and the counter -- the rebuttal
might have been sufficient to mitigate what was
perceived at that time as an unlikely event.
So, in other words, it would be compounded because there
would be, therefore, a false denial of accountability
and, down the line, there would be, when this all blew
up, there would no doubt be recriminations that it had
been wrongly priced?
If you -- the Board was entitled to look at the
Linklaters, I believe, review, which categorically
stated that the probability of loss from the
postmasters' actions was low, although it could be
100 million, was the number. That should have been
stated.
Categorically is somewhat overstated. It was a very,
very highly caveated report, was it not?
Well, in reading it post-the event, yes.
Yes. May I ask you, were you aware that people from
your Department, people from ShEx, were trying to remove
what were perceived to be adverse or critical remarks
about Horizon from the prospectus?
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"We should pursue a sale of shares.
"We should prepare for an IPO in autumn 2013."
Then over the page at page 18 we have "Key risks"
and we've got "Industrial relations", this is under
paragraph 5, "Financial performance"; "Investment
appetite"; "Market Economic Conditions"; "Regulation".
Then going over to page 19 internally but 18 on the
document itself, we've got at paragraph 6 at the top of
the page:
"These risks are significant and there remains
a strong possibility that one or more could materialise:
we are continuing to assess contingency options should
this be the case. However, at this stage we (and [the
Union Bank of Switzerland]) remain of the view that
a sale should be feasible from autumn 2013."
Now, the position, as you say, however -- if I may
be forgiven for making an observation -- improbable it
is, that you had no idea about the noise, as it has been
contemptuously described, generated by the
subpostmasters, but the position is that the risk of
historical prosecutions, of sending innocent people to
prison, appears nowhere in this document.
That's correct.
You would surely agree with me that, if that had been
a known risk, it would have killed the flotation
194
oP
>
I was not.
Q. So, therefore, it follows that you cannot have been
aware that the Chief Executive Officer of the Post
Office, when the officials at ShEx had failed,
intervened and actually had what was perceived to be
damaging and critical material of Horizon removed from
the prospectus?
I was not aware of that.
oP
That would be, on any view, given what we now know,
contrary to the whole principle of candour and
transparency so far as risk; do you agree?
A. You could reach that conclusion.
MR HENRY: I'm grateful. Thank you.
SIR WYN WILLIAMS: = Thank you, Mr Henry.
Thank you to everyone for bringing this afternoon's
proceedings to a timely close. I'm grateful to you.
I'm also grateful to you, Mr O'Sullivan, for making
your witness statement and for coming to answer
questions at the Inquiry this afternoon.
THE WITNESS: Thank you, sir.
‘SIR WYN WILLIAMS: Right. So we won't sit tomorrow and we
will resume on Friday --
MR STEVENS: That's correct, sir, yes.
SIR WYN WILLIAMS: I -- I take it, Mr Stevens?
MR STEVENS: Sorry, sir. Spoke over you, then.
196
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‘SIR WYN WILLIAMS: No, no. I take it at 9.45 on Friday?
MR STEVENS: Yes, 9.45, thank you.
SIR WYN WILLIAMS: Fine. Thank you all very much.
(4.27 pm)
(The hearing adjourned until 9.45 am
on Friday, 12 July 2024)
197
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INDEX
THOMAS KNUT GLENN COOPER (affirmed) ...... 1
Questioned by MS HODGE ...
Questioned by MR MOLONEY ... 99
Questioned by MR HENRY 103
Questioned by MR STEIN ..... 118
Questioned by MS SHAH . 125
Further questioned by MS HODGE .... 128
Questioned by SIR WYN WILLIAMS .. 134
PATRICK HENRY PIERCE O'SULLIVAN (sworn) 136
Questioned by MR STEVENS . 136
Questioned by MR JACOBS ..... 186
Questioned by MR HENRY ..... 191
198
(50) Pages 197 - 198
MR HENRY: [6]
103/18 115/15 117/20}
192/1 192/11 196/13
MR JACOBS: [2]
186/10 191/23
MR MOLONEY: [2]
99/15 103/16
MR STEIN: [5]
117/24 118/4 118/6
122/21 124/2
MR STEVENS: [12]
136/6 136/8 136/12
162/1 162/7 162/9
175/21 184/8 185/25
196/23 196/25 197/2
MS HODGE: [27] 1/3
115 118 1/12 43/13
45/16 47/12 47/17
47/19 92/2 92/5 92/7
92/12 92/14 99/11
99/13 124/6 124/11
124/23 124/25 125/4
125/6 127/25 128/3
134/16 136/1 136/4
MS SHAH: [2]
125/10 127/17
SIR WYN WILLIAMS:
[50] 1/4 1/7 41/17
42/15 43/7 43/12
45/19 46/8 46/11
46/13 47/8 47/13
47/18 92/4 92/6 92/8
92/13 99/10 99/12
115/11 117/22 118/2
122/18 124/1 124/3
124/8 124/17 124/24
125/5 125/8 127/18
134/19 135/9 135/17
135/23 136/2 136/7
162/8 175/12 175/18
175/20 183/23 184/7
186/6 192/8 196/14
196/21 196/24 197/1
197/3
THE WITNESS: [2]
135/22 196/20
44 [1] 141/13
48 [1] 10/23
‘an' [1] 35/7
‘at [1] 77/7
"bad [1] 64/8
"breached' [1] 19/11
‘considerable [1]
19/5
‘digitally [1] 178/11
‘enablers' [1] 193/20
‘extraordinarily [1]
71/1
‘fake’ [1] 178/24
‘may [1] 129/3
"Misra [1] 109/15
‘no [1] 151/2
‘On [4] 114/21
‘presentational’ [1]
87/23
‘risk [1] 77/17
‘settle [1] 72/14
‘The [1] 143/12
‘whether [1] 77/1
1
1.29 [1] 125/1
10 [5] 112/15 112/16
141/21 148/13 148/14)
10 December [1] 3/2
10 July 2024 [1] 1/1
10 October [1] 18/16
10 September [1]
54/25
10 years [1] 184/22
10.00 [1] 1/6
100 million [3] 157/7
157/7 195/17
11 [3] 49/12 49/21
152/15
11 February [1]
110/5
414 July [1] 168/13
11.00 [1] 47/14
11.15 [2] 47/12 47/16
112 [1] 99/17
117 [1] 100/10
118 [3] 100/13
118/12 118/13
119 [2] 16/17 120/21
12 [4] 53/10 120/3
180/21 197/6
12 February [1] 2/10
12 March [1] 73/20
12 September [1]
168/13
12.24 [1] 92/9
12.35 [2] 92/7 92/11
13 [1] 125/15
13 June [1] 1/19
13 March [1] 193/17
13 November [1]
65/8
14 [2] 125/15 171/9
15 [2] 85/8 104/1
15 March [6] 75/22
83/9 87/7 87/16
103/21 131/11
15 November [1]
103/24
150 pages [1] 1/22
16 [3] 112/15 114/6
131/14
16 July [1] 181/17
16 March [1] 98/17
16 October [2] 17/25
40/3
16.1 [1] 118/19
167 [2] 72/7 72/8
17 [2] 23/25 193/18
17 October [9] 20/21
24/1 24/18 25/1 25/6
62/23 64/18 98/7
98/21
17 September [1]
2/16
170 [1] 131/8
18 [5] 115/13 128/14
164/2 194/3 194/7
18 March [2] 87/24
89/4
18.2 [1] 143/3
185 [1] 87/12
19 [2] 160/23 194/7
19 March [1] 93/8
19 November [1]
130/3
1990s [1] 112/19
2
2 March [1] 114/5
2.15 [3] 124/11
124/24 125/3
2.30 [1] 124/14
20 [4] 60/15 60/18
155/3 173/16
20 March [1] 94/21
2007 [1] 138/7
2008 [1] 179/17
2009 [2] 138/11
138/18
2010 [2] 103/8
139/10
2011 [8] 138/21
140/9 140/17 147/22
192/1 192/7 192/9
192/12
2012 [19] 118/21
119/9 120/1 120/18
140/10 140/18 144/5
145/25 158/3 159/3
162/10 165/10 167/8
168/13 168/13 186/16I 3
3 January [1] 64/23
189/2 192/10 193/3
2013 [7] 139/18
139/21 139/24 173/6
193/17 194/2 194/15
2014 [4] 144/24
175/18 181/17 193/4
2015 [2] 65/4 138/23
2017 [3] 4/3 4/9
28/15
2017/18 [4] 115/13
2018 [32] 2/10 4/10
4/13 10/22 10/23 11/8
11/46 12/20 12/24
17/5 17/25 19/9 32/6
36/10 37/23 49/3 49/6
49/24 55/24 56/17
57/9 61/1 65/20 98/7
115/15 116/22 119/15I
119/21 129/22 130/3
130/25 135/5
2019 [18] 2/11 2/16
3/2 30/23 53/16 59/3
64/11 69/23 70/4
73/20 103/21 103/24
104/2 126/5 131/4
131/11 134/8 134/11
2019' [1] 114/25
2020 [6] 5/8 8/3
42/12 107/3 110/5
114/5
2021 [1] 112/7
2023 [1] 4/15
2024 [2] 1/1 197/6
20th [1] 83/10
21 [4] 173/17
21 years [1] 3/21
218 [1] 139/19
22 [2] 175/11 182/15
23 [5] 13/11 34/1
47/1 122/8 137/11
23 clauses [1] 15/8
23 May [1] 165/10
238 [4] 2/14
239 [1] 2/14
24 [2] 112/15 114/20
24 January [1] 107/3
242 [3] 99/17 99/23
100/23
25 October [1] 28/15
252 [1] 126/4
253 [1] 2/25
254 [1] 2/25
256 [3] 100/9 100/12
102/10
26 [2] 28/17 141/21
26 November [1]
126/5
27 [2] 28/18 28/25
28 February [1]
108/13
28th [4] 110/21
29 June [1] 49/3
3.00 [1] 79/3
3.20 [1] 162/4
3.30 [2] 162/3 162/6
30 [2] 180/21 180/22
30 March [1] 112/7
30 October [2] 122/5
122/12
31 [1] 168/12
31 December [1]
57/9
31.2 [1] 171/9
325 pages [1] 70/16
34 [4] 107/19
36 [1] 186/19
37 [4] 187/19
38 [4] 186/21
39 [2] 128/7 193/18
3b [1] 147/23
4
4 October [1] 147/21
4.2 [1] 163/7
4.27 [1] 197/4
4.28 pm [1] 70/8
4.30 [2] 124/18
124/21
43 [1] 160/24
45 [5] 155/4 155/5
155/17 155/22 173/16)
45 minutes [1]
127/21
45.3 [1] 155/10
45.7 [4] 155/11
46 [3] 155/14 155/25
173/17
47 [8] 155/14 155/19
173/17 173/19 176/23)
176/23 176/25 177/1
5
5 July [1] 128/25
50 [4] 175/11 175/23
182/14 182/16
51 [3] 183/22 183/23
184/9
57 [2] 118/12 118/13
58 [1] 120/21
6
6 November [1]
37/22
60 [4] 165/13
69 [1] 2/2
7 March [1] 159/3
75 [1] 2/8
750 [1] 44/17
79 [2] 72/8 128/9
8
8 July [1] 173/6
8 March [3] 69/23
70/4 70/8
8 May [1] 162/10
80 [2] 128/6 131/9
85 [1] 192/13
88 [1] 87/13
9
9.45 [3] 1/2 197/1
197/2
9.45 am [1] 197/5
950 [1] 44/18
A
able [12] 16/25 24/22
34/16 44/15 51/21
99/2 127/7 127/13
127/14 141/16 160/1
191/20
about [168] 3/16 5/21
6/20 9/4 9/14 10/4
(61) MR HENRY: - about
A
about... [162] 10/7
10/8 10/25 11/10 14/4)
14/16 15/22 16/13
16/23 17/5 17/14
21/17 21/25 22/3 22/8
23/18 24/2 24/13
24/20 25/8 26/16 27/1
29/15 30/13 30/25
33/22 35/18 35/20
35/21 35/23 36/20
37/10 37/14 38/6
38/15 39/12 39/13
39/20 42/2 42/18
44/12 45/9 47/21 49/3
51/16 51/25 54/15
56/18 57/9 58/18
58/20 58/22 61/20
62/8 63/13 64/1 65/22
67/8 67/14 67/20 69/1
69/2 74/6 75/8 75/14
78/1 78/10 79/19
81/17 86/19 87/6
87/12 90/14 90/22
91/1 91/6 91/10 92/16
93/17 94/2 94/2 95/20)
97/12 99/5 100/6
100/15 100/23 101/11
103/5 104/12 105/24
106/25 108/16 108/24
110/5 110/18 111/6
114/9 115/3 115/10
115/12 116/6 116/8
116/24 117/2 118/15
118/16 118/24 119/6
119/15 119/17 119/23)
120/9 120/16 121/2
121/17 121/23 121/25
122/21 122/22 123/1
123/4 123/16 123/21
125/20 128/6 129/13
130/13 130/14 131/7
131/16 132/15 133/2
133/17 137/25 147/18}
155/20 157/14 159/17
159/22 163/6 166/17
171/15 171/22 172/3
172/15 175/2 175/16
176/17 176/20 176/23
177/2 180/14 180/21
184/1 185/6 188/8
188/16 189/1 189/1
194/18 195/25
above [2] 89/17
171/16
absence [3] 40/18
50/18 129/13
absent [2] 40/7 59/5
absolute [1] 156/17
absolutely [14] 12/6
14/25 30/9 35/24 72/1
97/14 109/4 114/17
125/24 144/10 163/3
168/5 176/15 191/13
absorbed [1] 60/8
absorbing [1] 60/9
abundantly [1]
127/14
abuse [1] 103/6
accept [7] 127/7
152/9 164/17 189/17
190/17 191/14 193/9
acceptance [1] 179/9)
accepted [3] 14/21
61/17 178/3
accepts [1] 70/24
access [6] 9/18
27/13 32/8 98/11
178/22 179/20
accessible [1] 179/3
accompanying [1]
79/21
account [8] 35/4 35/8
71/3 71/6 71/8 109/24
110/2 148/7
accountability [2]
185/3 195/9
accountable [3]
148/4 154/24 185/4
accountancy [1] 3/18)
accountant [1] 138/2
accounting [4] 38/12
137/6 167/20 175/3
accounts [3] 9/17
159/24 168/7
accurate [7] 61/20
80/17 111/5 130/24
177/24 178/3 193/11
accurately [4] 52/16
58/14 73/9 162/12
acknowledge [1]
63/6
acknowledgement
[1] 186/18
acquainted [1]
193/15
Acquisitions [2] 3/24
4/2
act [4] 77/16 93/19
146/11 186/10
acted [4] 39/10 50/17
50/23 51/15
acting [5] 19/18 46/4
149/21 151/14 152/10)
action [17] 28/3 31/7
31/8 34/18 45/2 62/18
78/2 82/24 87/1 91/7
96/19 100/4 100/15
101/2 132/8 164/24
179/25
actions [10] 49/18
51/10 54/8 54/20 86/5)
96/11 135/12 150/12
180/10 195/16
activated [1] 71/14
active [3] 128/22
129/17 152/18
actively [1] 63/16
activities [1] 114/24
activity [1] 32/2
actual [8] 38/18
38/25 89/12 89/15
89/20 91/1 109/16
164/4
actually [44] 8/14
8/20 14/8 16/1 17/11
19/11 23/21 25/22
26/12 28/3 28/22 31/4
34/15 38/21 50/7 55/7
60/3 60/5 62/9 67/9
67/15 68/10 75/8
75/10 90/1 98/14
101/10 102/16 106/3
106/19 108/5 108/7
113/4 113/24 122/6
122/6 122/21 135/9
140/4 141/20 148/22
149/11 152/8 196/5
add [4] 37/13 173/20
182/20 184/21
addition [3] 32/23
87/14 184/10
additional [3] 59/19
182/20 182/25
address [7] 9/1 97/16I
100/1 106/17 131/8
141/22 167/7
addressed [9] 18/3
37/23 38/8 70/7 99/19)
141/25 177/8 184/23
185/4
addresses [1] 81/9
addressing [2]
130/24 186/23
adduced [1] 17/18
adequate [3] 69/11
154/19 169/3
adjourned [1] 197/5
Adjournment [1]
125/2
administration [1]
127/9
admissibility [1] 19/8
adopting [1] 19/25
advance [4] 1/18
25/6 55/13 151/4
advantage [2] 10/14
183/25
adverse [4] 40/18
42/25 79/3 195/24
advice [58] 17/6
23/15 43/14 46/3
54/16 62/3 63/1 63/8
63/9 74/1 74/24 75/23
76/9 76/12 76/13 77/5
78/5 78/9 80/10 80/12
82/17 84/3 84/23
85/11 88/12 88/13
89/4 89/21 91/16
92/23 95/25 98/12
100/14 100/17 100/18}
100/24 100/25 100/25)
101/2 101/20 101/20
102/9 102/15 102/16
102/21 102/22 102/24}
103/3 103/9 103/12
104/10 126/15 145/7
156/3 156/21 191/7
191/11 191/15
Advices [1] 155/11
advise [3] 109/2
109/3 167/16
advised [10] 21/15
73/25 74/15 74/15
78/13 90/23 99/25
100/19 102/11 190/24)
advisers [3] 54/11
60/20 126/3
advisory [2] 143/12
146/11
advocates [1] 186/7
affected [2] 68/8
134/15
affecting [1] 53/4
affirmed [2] 1/10
198/2
afford [2] 127/8
127/15
after [22] 13/4 21/23
32/3 37/15 42/17 44/8)
52/4 55/13 61/7 63/14
78/4 116/22 124/21
131/14 133/6 162/15
164/2 164/11 164/15
167/6 175/9 183/12
aftermath [2] 98/15
98/21
afternoon [8] 98/17
124/15 125/4 125/11
135/20 136/6 162/2
196/19
afternoon's [1]
196/15
afterwards [3] 34/10
97/5 134/5
again [23] 3/3 33/20
38/6 44/14 47/11
59/25 60/3 60/13 61/4,
62/14 68/2 83/8 83/8
104/6 106/11 112/12
116/5 124/10 124/24
134/9 168/18 169/25
179/13
against [17] 44/13
49/22 51/7 59/13
75/24 91/13 96/16
100/4 100/15 100/20
101/9 106/18 111/1
126/7 182/2 182/4
192/14
agency [1] 38/19
agenda [4] 28/5
107/13 107/15 134/2
agent [3] 149/21
151/15 152/10
agents [1] 13/17
ago [3] 6/6 87/10
127/12
agree [28] 15/9 15/12)
33/23 40/9 65/12
67/25 69/14 81/15
84/9 85/13 89/23 95/4I
113/8 115/22 122/10
142/6 142/14 144/7
152/13 154/25 167/21
168/4 168/7 189/23
193/16 194/24 195/2
196/11
agreed [13] 12/20
12/21 13/14 14/21
22/5 46/24 47/3 72/2
75/10 94/23 95/11
154/22 181/22
agreement [4] 12/16
12/24 13/4 159/20
agreements [1]
14/15
agrees [1] 96/2
ahead [2] 64/24
141/12
Aid [1] 163/7
aim [1] 181/25
airing [1] 59/24
Al [4] 135/16
Alan [1] 186/10
alarm [3] 1/6 11/1
176/6
Aldred [3] 33/17
37/25 104/19
alerted [1] 53/15
Alex [13] 31/16 31/17
78/5 78/25 79/1 79/17
80/2 85/15 85/15 87/7
87/16 91/20 92/23
Alex's [3] 88/14 93/3
93/7
Alice [3] 147/18
171/8 171/10
Alice's [1] 172/10
aligned [2] 133/19
134/4
alive [1] 9/20
all [63] 9/8 14/1 14/7
14/9 14/18 15/11
15/24 31/24 33/17
40/20 43/7 43/12 46/2)
47/8 68/17 68/20
68/22 69/1 69/8 69/8
69/18 70/9 70/14
70/18 70/20 73/18
86/22 93/5 94/6 94/22
96/10 97/14 99/10
103/16 107/24 108/3
120/15 122/18 124/22)
126/20 126/25 130/5
133/9 134/3 134/25
135/9 135/17 145/16
148/1 149/23 150/13
160/4 161/16 171/6
(62) about... - all
A
all... [9] 172/5 178/14
184/8 190/13 190/14
193/12 193/13 195/10
197/3
Allen [1] 186/4
allow [1] 178/16
allowed [2] 57/4
156/20
almost [3] 100/20
134/25 171/10
alone [1] 43/6
along [2] 89/16 190/4
already [7] 37/24
63/16 67/20 93/10
160/21 173/18 182/16
also [32] 5/17 7/5
7/10 12/12 13/9 13/20
21/10 24/6 25/14
26/11 37/24 39/2 58/6
60/6 62/25 72/2 72/10
72/23 73/2 88/10
96/11 98/6 102/5
103/4 112/1 112/22
122/5 130/20 144/8
179/20 181/20 196/17
alternative [7] 11/14
39/5 39/17 41/5
113/11 113/12 113/15}
alternatives [1] 10/8
although [6] 14/21
77/6 85/3 156/17
178/18 195/16
Altman [6] 42/11
43/15 106/23 108/14
108/23 109/19
always [9] 52/19
55/17 87/2 103/12
103/13 119/11 131/19}
132/23 168/8
am [14] 1/2 1/6 20/25
21/14 47/14 47/16
80/7 101/13 110/17
4117/7 137/25 141/22
155/20 197/5
Amber [1] 144/23
amend [1] 3/7
amendment [1] 2/21
amendments [1]
2/13
among [2] 142/9
150/21
amongst [2] 48/15
109/22
amount [1] 60/9
amounted [2] 9/12
188/4
amounts [1] 114/18
analogy [1] 51/23
analyse [3] 142/8
142/12 164/6
analysis [4] 144/23
180/4 180/6 195/5
analysis’ [1] 19/5
Andrew [3] 54/21
55/4 55/11
Angela [1] 73/3
another [14] 17/13
32/22 52/25 53/1
53/23 56/23 57/1
69/20 81/24 84/16
85/25 149/15 151/13
153/1
answer [11] 1/16
44/6 44/15 101/12
115/4 115/12 117/10
126/19 152/7 169/9
196/18
answering [1] 43/9
answers [1] 112/10
anticipated [2] 123/8
139/5
any [73] 5/23 7/15
7/18 9/25 10/11 10/13)
11/24 16/21 17/1 25/7
29/14 30/6 34/2 35/16
39/3 41/17 41/21
44/21 45/2 48/6 63/1
65/13 66/18 72/25
81/16 82/24 83/6
85/14 94/10 96/6
96/19 100/19 101/1
101/18 102/11 102/16)
107/13 109/8 113/21
117/19 117/22 120/12)
120/24 124/13 125/21
133/16 135/9 141/9
142/7 142/10 143/17
145/14 147/8 150/17
152/18 155/21 158/23}
159/8 160/9 163/12
166/7 167/16 167/23
167/23 169/5 170/23
171/15 176/11 178/20)
187/9 191/23 193/10
196/9
anybody [2] 126/1
193/14
anyone [9] 90/4
108/10 114/15 125/21
131/25 146/6 160/18
171/20 172/22
anyone's [1] 113/23
anything [10] 37/13
42/5 79/24 80/22
101/9 117/19 124/3
151/4 182/20 185/23
anywhere [2] 45/15
68/1
apart [2] 13/24 46/9
apologies [1] 127/24
apologised [1] 109/8
apparent [2] 11/18
25/5
apparently [1] 170/4
appeal [13] 15/17
50/16 64/9 71/12 74/1
74/21 74/25 75/8
75/14 75/24 76/17
77/14 126/6
appealed [1] 75/19
appeals [2] 44/9 76/9
appear [8] 40/4 96/22)
107/12 110/7 121/8
132/2 163/12 185/15
appeared [3] 59/18
68/5 142/3
appears [5] 63/6
63/15 166/12 191/9
194/22
appended [1] 143/8
appetite [1] 194/6
application [26]
17/16 18/18 18/21
18/22 19/16 19/22
21/1 21/9 21/15 24/3
37/16 77/19 79/20
80/5 80/20 81/17 82/2
83/6 85/14 86/10 87/7
87/18 88/6 91/11
92/17 97/13
applications [1]
107/19
applied [4] 20/1
76/19 119/18 160/20
apply [5] 19/7 51/20
76/24 78/11 87/3
applying [2] 18/25
145/6
appointed [12] 3/23
29/2 81/23 89/19
139/9 140/7 140/8
140/16 165/4 167/5
192/1 192/9
appointment [9] 29/6
147/22 154/18 160/14
160/20 172/9 192/3
192/4 192/23
appointments [1]
125/18
appraised [1] 55/19
apprehend [1] 110/4
approach [11] 5/11
13/11 16/21 19/25
23/7 33/25 114/23
117/3 120/24 134/21
169/5
approached [2]
27/18 132/16
approaching [1]
33/24
appropriate [12]
11/25 80/13 93/17
95/3 113/23 132/11
145/11 150/18 161/5
164/16 164/24 181/2
appropriately [2]
93/19 181/14
approval [6] 95/1
95/13 96/4 96/7 163/7
179/9
April [4] 144/5 158/3
175/17 175/18
are [90] 5/4 5/18 5/19
6/12 10/21 11/2 14/14,
14/17 20/3 21/16
21/20 32/10 33/10
36/15 38/23 49/13
51/21 53/10 56/25
57/1 58/4 58/11 58/12
58/24 61/1 62/25 63/7,
63/8 71/11 73/15
76/20 79/4 89/3 89/16
94/9 94/9 94/23 95/11
97/10 104/24 106/15
106/25 107/4 108/19
109/13 110/7 110/8
110/11 110/11 114/7
117/22 119/8 120/6
120/8 124/9 127/2
127/17 127/19 136/24,
137/20 137/22 143/8
148/22 149/1 149/8
150/17 150/19 157/23
160/9 160/15 160/18
165/9 167/16 176/16
177/24 178/5 178/7
178/11 179/14 183/6
185/9 186/1 188/24
190/13 190/15 191/7
193/11 193/24 194/10)
194/12
area [2] 24/9 34/21
areas [3] 47/5 58/5
129/11
aren't [3] 32/14 178/5
190/13
arena [1] 151/5
argue [4] 38/22 46/21
74/16 76/20
arguing [2] 16/20
120/24
argument [5] 39/6
39/25 62/16 74/7
7A4N3
arguments [3] 70/18
71124 86/22
arise [2] 89/18
160/22
arises [2] 3/4 112/9
arising [1] 30/14
arm's [9] 87/20
148/11 148/24 149/12)
154/23 180/16 183/3
183/4 187/17
arm's-length [4]
87/20 148/24 149/12
187/17
arms [1] 180/17
arose [3] 157/19
157/23 188/16
around [19] 13/13
28/21 32/21 82/7
107/16 119/15 119/21
124/14 126/23 145/17
145/22 146/13 147/12
163/9 169/16 169/18
170/9 170/24 174/16
arranged [1] 124/19
arrangements [2]
64/8 159/18
arrived [2] 55/6 61/8
article [2] 38/13
192/13
articulate [2] 56/22
116/11
articulated [3] 57/7
82/9 91/12
articulates [2] 82/1
82/16
arts [1] 137/1
as [308]
aside [1] 34/8
ask [24] 1/15 3/15
15/15 44/11 47/20
86/20 99/2 103/18
106/25 117/20 124/4
124/6 127/23 131/6
137/10 137/25 149/15)
156/11 157/10 162/2
171/15 174/14 187/18)
195/22
asked [19] 8/21 11/4
20/24 26/13 39/24
101/6 101/11 125/24
126/11 126/17 127/20)
130/14 141/22 155/5
155/5 165/12 176/13
176/20 177/4
asking [17] 9/4 31/16
56/24 79/5 98/19
106/12 109/23 111/21
118/17 120/14 126/9
131/3 131/5 146/3
152/8 177/3 185/8
aspect [1] 21/17
asserted [2] 179/7
179/18
assertions [2] 178/2
179/12
assess [2] 100/2
194/12
assessed [1] 4/25
assessment [1]
164/18
asset [13] 4/20 5/12
47/25 48/3 145/11
157/16 161/3 161/3
163/14 163/17 165/1
169/7 184/20
asset's [1] 35/8
assets [13] 4/23 5/5
5/10 5/20 27/9 35/11
48/25 142/13 144/1
146/23 166/20 176/2
184/13
assist [5] 35/6 80/7
168/17 170/2 187/16
assisted [2] 7/24
(53) all... - assisted
A
assisted... [1] 147/1
associated [1]
187/21
assume [3] 21/10
107/12 147/17
assumed [1] 144/17
assumption [2]
21/12 169/2
assumptions [3]
177/15 177/23 178/5
assurance [2] 173/22)
174/22
assured [4] 8/13 8/25]
22/18 151/10
astonishment [1]
77/21
at [316]
atmosphere [1]
170/22
attached [2] 77/5
105/1
attaching [1] 53/9
attempt [1] 170/21
attempted [1] 187/7
attempts [4] 105/24
106/5 108/5 189/22
attend [1] 186/13
attendance [2] 130/8
181/20
attended [3] 73/22
98/6 130/3
attention [6] 44/22
72/21 156/3 175/8
184/3 189/12
audit [10] 72/22 73/1
138/17 178/10 178/24}
179/11 179/16 179/19
180/8 185/13
August [1] 31/20
authorised [2]
178/16 178/22
authority [2] 35/4
185/22
autumn [2] 194/2
194/15
available [4] 25/21
71/16 90/17 177/21
average [1] 139/6
avoid [1] 86/16
avoided [1] 127/4
awaited [1] 100/18
awaiting [3] 103/25
104/2 104/3
awaits [1] 64/5
awake [1] 170/25
award [2] 26/24
28/13
aware [30] 26/22
27/23 35/22 58/12
72/17 83/5 149/23
156/8 156/13 156/20
158/24 160/9 160/16
160/18 165/23 166/2
166/11 167/8 167/12
168/23 173/9 173/11
181/7 181/8 187/12
192/21 193/5 195/22
196/3 196/8
away [11] 28/2 41/24
58/13 60/10 82/14
82/22 83/2 101/19
121/22 159/10 184/1
B
bachelor's [1] 137/2
back [36] 7/12 23/3
31/6 31/6 43/7 44/8
63/19 63/23 64/2
66/18 68/24 69/10
79/10 84/9 85/24
90/15 91/17 96/10
96/20 97/7 98/3
101/13 112/18 119/12)
120/2 121/23 133/11
141/20 152/14 155/25)
162/2 175/4 183/11
187/16 189/1 189/15
backdrop [1] 41/19
background [7] 3/16
27/2 31/5 105/21
138/1 176/14 192/21
bad [4] 87/3 115/21
120/12 120/14
badly [2] 133/21
134/12
balance [2] 86/9
168/10
balanced [1] 84/4
balances [1] 116/11
Balancing [2] 179/2
179/14
Banda [1] 111/19
bang [1] 34/22
bank [13] 3/20 4/2
138/18 141/6 145/20
145/21 159/9 159/12
159/14 159/20 160/8
160/11 194/14
barred [2] 100/21
101/18
barrier [1] 89/22
based [1] 191/3
basic [2] 6/3 150/11
basically [4] 5/7 5/11
8/12 101/12
basis [14] 16/2 32/16
39/1 43/4 71/23 75/11
130/19 151/10 157/3
157/22 167/11 172/13)
188/8 193/24
baskets [3] 178/10
178/17 178/18
batting [1] 121/22
BBC [1] 192/25
BBC News [1]
192/25
be [237]
bear [4] 22/22 25/14
65/24 170/16
bears [9] 16/17 28/11
49/4 54/19 57/10
57/17 70/1 78/22
92/19
became [14] 4/5 25/5
42/16 116/4 138/17
138/20 144/5 144/20
156/14 158/15 169/20
169/21 179/18 181/19}
because [65] 10/10
10/24 12/9 13/20 16/3
25/11 31/9 31/14
31/23 32/15 36/11
37/4 40/7 40/19 44/6
44/16 45/14 46/9
46/25 50/2 52/13
53/22 55/17 61/12
62/13 63/12 66/1
67/17 80/9 81/8 86/1
88/8 88/10 89/17 90/2
96/12 101/24 105/15
106/15 107/2 107/12
110/4 112/1 112/3
117/3 122/4 123/5
123/11 123/17 124/19}
130/24 133/19 141/13
159/11 159/13 160/6
160/11 161/21 176/9
181/9 187/10 189/25
192/18 195/3 195/8
become [3] 11/5
140/7 185/19
becomes [2] 162/16
185/10
becoming [1] 88/25
bed [1] 165/6
been [136] 2/18 3/5
5/23 7/1 7/5 7/8 8/4
9/6 11/17 12/21 12/24
15/4 19/25 21/17
24/20 24/22 26/22
26/23 32/7 32/18
33/21 38/24 39/2 40/9
41/6 41/15 41/17 42/1
44/13 44/15 46/16
47/1 47/3 51/13 57/20
61/13 61/13 63/10
64/25 67/14 67/15
68/2 69/5 70/9 72/16
72/20 72/24 73/3 73/5
76/21 77/24 86/3
86/21 95/20 97/7
100/18 103/24 104/6
104/7 105/9 109/7
109/16 110/23 111/10
113/21 114/17 118/22
119/9 119/14 120/2
120/14 120/15 120/18}
127/22 129/10 129/12
132/24 139/4 144/14
146/1 149/13 149/14
151/11 152/18 155/5
156/8 156/12 157/9
159/25 160/3 161/2
161/14 161/15 163/18
163/21 164/3 164/16
166/2 166/4 167/4
167/11 167/24 168/2
168/3 169/4 171/25
172/4 173/17 173/22
175/7 175/25 176/5
176/24 177/6 177/17
178/3 178/12 179/24
180/1 180/3 181/8
182/16 182/25 187/22)
188/8 188/20 188/21
188/22 190/7 193/21
194/18 194/24 195/6
195/12 195/17 196/2
before [44] 3/16 4/2
10/10 12/22 21/20
24/2 30/21 40/1 42/19)
54/7 54/17 54/18 61/7,
72/14 74/21 75/14
79/11 83/6 84/22
90/21 92/15 97/17
99/19 101/16 107/13
110/6 113/1 115/3
115/12 116/23 119/9
120/1 120/3 122/13
127/23 132/19 134/19}
136/21 140/14 162/18
179/24 180/12 183/23}
192/23
beforehand [1] 6/2
began [2] 54/14
138/7
begin [2] 10/11
144/20
beginning [7] 45/21
119/12 120/17 135/1
145/25 170/6 176/11
begs [3] 8/19 115/2
115/4
behalf [3] 1/15
103/18 183/5
behaviour [2] 39/3
39/14
behaviours [1] 70/23
behind [2] 113/6
189/18
being [48] 7/22 10/2
11/11 27/18 30/20
35/11 37/11 39/8
39/24 45/22 51/12
52/8 66/8 67/9 72/4
7717 77/21 87/18
90/21 90/23 95/21
99/25 102/11 110/17
114/9 116/14 120/16
131/15 145/14 145/16
147/6 152/12 156/18
160/1 160/9 168/25
174/18 175/6 175/12
176/21 182/5 184/19
185/3 187/7 187/11
187/20 192/20 193/9
BEIS [19] 31/21
36/13 36/13 56/7
62/25 63/3 63/7 64/13
64/22 78/6 79/7 79/18I
87/15 87/17 89/9
90/25 91/12 94/6
97/23
belief [3] 3/13 137/21
181/4
believe [22] 51/3
51/12 57/17 73/6
90/12 96/5 99/1
128/13 137/1 139/23
149/20 156/12 158/20)
169/1 174/23 175/25
176/23 181/1 182/17
184/13 192/3 195/14
believed [2] 131/20
168/19
bells [1] 176/6
belong [1] 180/6
below [5] 59/9
108/22 128/18 129/16)
150/11
Ben [4] 100/17 102/9
102/15 102/17
benefit [8] 10/17
21/11 36/5 36/9 37/8
57/6 144/18 168/5
benefited [2] 30/17
68/25
beside [3] 57/23
103/20 107/6
besides [1] 57/24
best [13] 3/12 10/19
23/6 34/13 41/12
65/25 70/6 85/16
117/9 137/20 174/7
174/11 182/7
better [13] 2/4 29/3
57/5 59/9 69/16
113/25 114/8 117/5
123/18 171/25 172/4
183/14 183/17
between [28] 13/17
16/2 19/20 37/17
38/15 38/17 40/14
53/24 56/3 65/19
83/11 83/25 88/24
90/5 91/22 91/23
94/10 97/23 129/20
147/11 149/10 152/5
152/23 159/14 159/20)
183/14 183/17 184/5
beyond [3] 124/18
141/13 186/17
biannual [1] 170/11
bias [4] 76/11 79/20
83/19 84/5
biased’ [1] 77/4
big [4] 32/2 35/21
67/17 143/24
(64) assisted... - big
B
bigger [1] 67/10
bit [15] 63/25 69/1
80/17 80/17 80/18
86/14 93/23 95/11
103/1 105/20 110/20
122/1 134/22 134/23
145/3
bits [2] 27/8 94/7
biweekly [1] 130/19
Black [1] 110/9
blanket [1] 52/5
blew [1] 195/10
blocked [1] 189/22
blog [1] 105/7
blown [1] 180/4
board [197] 2/4 2/16
3/2 4/15 4/19 5/15
5/15 11/11 11/16
12/22 25/18 26/2
27/21 29/8 29/8 29/17
31/7 35/4 35/5 35/12
35/17 36/1 36/6 36/11
36/13 36/19 36/23
37/2 37/3 37/4 37/6
41/2 41/22 42/12
44/22 45/6 48/21
48/22 48/24 49/1 49/1
53/14 53/20 53/25
53/25 54/6 59/3 60/22
65/15 66/16 68/6 68/6
68/12 68/20 68/25
70/11 72/23 73/7
73/19 73/25 76/8 80/6
80/8 80/21 80/22
80/24 81/16 82/4
82/25 83/22 84/2
84/25 85/1 86/4 87/20
88/16 89/1 89/12
89/20 90/6 91/8 94/12
94/24 95/1 95/5 95/13
95/17 95/22 95/24
96/6 97/12 99/25
101/3 101/7 101/11
102/22 107/17 107/21
108/18 108/24 109/2
109/10 110/11 119/23)
122/5 125/21 126/3
126/5 126/16 127/12
131/14 133/5 133/20
134/12 134/12 140/8
140/17 142/20 143/5
143/12 143/20 144/12)
144/13 145/2 145/9
146/6 146/11 146/14
146/18 146/19 146/21
146/22 147/1 147/14
153/9 153/19 153/21
154/19 155/6 155/17
155/23 156/1 156/4
156/7 156/12 158/19
158/20 159/2 159/7
161/18 162/10 163/8
163/24 164/17 164/21
164/23 165/5 165/9
165/14 165/17 165/21
166/2 166/5 166/9
166/9 166/11 166/13
166/14 166/16 166/19)
166/21 168/13 168/17)
168/25 173/7 175/9
176/1 177/10 179/24
180/1 180/12 181/7
181/14 181/16 181/22)
182/18 182/22 184/11
185/10 185/12 185/20)
188/11 190/2 190/6
190/23 193/17 195/13
Board's [7] 107/20
109/4 114/23 142/24
143/12 144/9 147/4
Boardroom [1] 166/6
boards [3] 35/8 36/8
185/9
bodies [3] 148/24
183/12 185/7
body [8] 87/20 142/7
146/7 147/3 148/11
149/12 154/23 168/22)
Bogerd [1] 73/3
Boldon [1] 186/14
both [22] 9/20 10/15
17/10 22/11 46/3
52/13 53/6 61/9 65/10
70/22 87/17 100/22
101/13 102/4 104/20
106/9 119/16 130/18
154/21 156/7 181/10
183/21
bottom [16] 2/3 5/11
10/20 18/1 18/2 28/24
35/2 70/2 78/23 93/11
119/20 150/4 159/4
177/15 181/10 181/12)
bottom-up [2] 181/10
181/12
bound [2] 74/10 81/4
bow [1] 107/16
box [1] 150/13
boxes [1] 105/2
branch [8] 9/17 71/4
72/15 74/11 82/22
85/24 179/5 179/8
branches [6] 34/6
34/17 71/7 83/13
118/8 120/7
break [10] 45/17 47/9
47/15 90/18 92/3
92/10 92/15 99/8
162/2 162/5
breaking [2] 12/6
153/14
breath [1] 109/13
Brian [4] 42/11 43/15
108/13 108/22
brick [1] 117/17
brief [6] 3/15 79/4
104/7 127/25 131/6
131/12
briefed [5] 54/21
64/17 65/7 130/17
172/22
briefing [21] 6/20
6/23 6/25 7/16 7/19
8/23 11/7 25/6 27/3
27/20 54/25 55/9
55/12 56/10 62/23
63/21 79/3 131/13
131/17 173/1 177/10
briefings [3] 31/4
31/4 55/9
briefly [3] 27/1 128/3
129/24
bring [17] 36/7 44/21
62/9 136/23 140/12
141/20 142/23 143/3
147/20 148/12 162/9
170/15 171/7 173/15
175/10 182/13 186/4
bringing [4] 75/24
133/17 181/14 196/15}
brings [2] 36/6
183/11
British [4] 145/20
broad [1] 83/1
broadly [1] 73/15
brought [7] 44/13
48/25 72/20 72/24
83/6 175/7 182/22
buck [1] 34/22
bullet [4] 28/25 35/1
177/20 178/15
burden [1] 183/1
burning [1] 52/2
business [38] 14/13
14/14 14/20 32/1
51/10 72/22 127/16
137/3 143/17 145/20
148/16 150/16 151/19}
151/21 153/5 157/4
158/24 163/19 164/3
164/4 164/6 164/8
164/13 168/19 170/7
171/3 171/5 171/18
172/11 174/23 175/1
175/2 176/17 183/4
183/6 187/17 191/2
193/14
businesses [7]
150/23 150/24 151/2
151/8 151/19 184/6
185/6
busy [1] 32/10
but [185] 6/2 7/8 9/3
9/4 9/8 9/11 12/11
13/19 14/2 14/6 15/2
21/2 21/8 21/10 21/12
22/19 23/5 23/8 24/6
24/23 24/24 26/18
30/15 32/1 33/10
33/15 34/10 35/18
36/10 37/6 38/6 39/20)
40/4 42/1 42/2 42/17
43/3 43/10 43/18 44/4)
45/13 45/24 46/8
46/14 46/21 46/25
48/9 48/19 49/12
51/18 52/6 53/1 53/10)
54/17 55/5 55/12
56/19 58/5 59/7 60/11
60/16 61/4 61/7 63/22,
64/1 65/23 66/3 66/21
66/25 67/19 67/25
68/5 68/9 68/17 68/21
69/4 69/16 70/25
72/20 77/14 79/17
80/10 81/2 81/12
82/13 83/19 84/16
84/25 85/9 85/17
86/22 87/18 88/8
88/12 88/15 88/17
90/1 90/17 91/15
92/25 93/19 93/21
94/1 94/3 94/4 95/5
96/2 96/16 98/2 98/20)
100/18 101/15 101/20}
102/5 102/19 103/14
105/10 106/21 106/25}
108/12 109/14 110/6
110/7 110/17 111/17
113/8 113/9 114/2
114/2 115/2 115/24
116/3 116/5 116/16
116/22 117/11 117/12)
117/15 117/17 119/2
119/10 119/17 121/6
121/10 122/1 123/2
123/22 127/11 128/22)
129/19 130/12 131/2
133/4 134/3 135/5
140/9 143/3 143/20
144/2 144/7 144/15
146/3 149/11 149/22
150/13 156/11 157/21
166/11 169/9 169/17
171/17 178/14 179/9
182/5 183/4 184/25
187/10 188/22 189/13}
190/2 191/8 192/18
193/13 194/7 194/20
buying [1] 52/5
c
cack [1] 17/22
cack-handed [1]
17/22
calculated [1] 51/22
call [10] 45/25 76/8
79/8 95/8 95/10 96/14
96/14 96/15 98/16
140/6
Callard [11] 4/12
4/13 6/21 8/24 9/4
155/20 173/21 174/2
175/14 176/6 177/5
called [3] 111/18
118/9 170/20
came [17] 6/11 14/9
31/5 31/6 40/22 41/8
42/12 43/10 97/7
101/10 101/12 108/4
126/19 126/25 135/5
135/11 171/41
Cameron [1] 135/16
can [115] 1/3 1/4 3/8
5/9 8/6 18/2 20/19
27/1 28/25 31/9 32/12I
34/15 38/22 43/4
45/19 45/21 46/13
A7I17 49/2 49/9 49/14
49/19 50/6 57/8 58/6
60/15 63/24 68/21
69/15 70/3 72/6 76/2
78/21 78/24 83/15
85/8 87/11 87/25 89/5
90/18 91/17 91/18
91/25 92/12 92/24
93/1 93/7 93/22 98/25
99/8 100/10 100/13
106/16 106/18 107/2
107/5 108/3 109/12
113/8 115/23 115/24
117/13 118/11 119/19)
121/6 123/23 124/17
125/4 125/10 126/15
130/1 134/1 134/24
135/9 135/11 136/6
136/12 136/23 137/9
137/10 137/18 141/3
141/20 144/11 147/20)
148/10 150/22 152/14)
152/14 155/14 155/25)
156/10 156/11 157/10}
158/23 162/7 162/8
162/9 165/8 165/10
165/11 168/17 169/22)
169/25 170/2 173/15
175/12 177/14 178/8
179/4 182/13 185/15
192/1 192/24 193/22
can't [21] 37/2 39/19
39/20 40/10 41/25
42/24 48/8 48/18
66/11 66/11 102/19
103/15 106/13 112/5
116/5 116/21 121/19
149/10 171/16 172/20)
182/5
candour [1] 196/10
cannot [5] 71/7
124/18 147/8 152/17
196/2
canvassed [1] 88/2
capable [1] 116/16
capacity [3] 29/16
81/1 91/13
career [2] 3/17 138/4
Carl [4] 112/13
Carol [1] 186/12
(65) bigger - Carol
Cc
carry [4] 100/6 124/8
142/16 145/9
carrying [1] 80/8
cascaded [1] 182/24
case [45] 18/22 19/4
19/6 19/17 21/5 22/4
22/9 28/9 36/12 38/11
52/4 52/6 52/14 56/14,
58/9 58/18 65/5 65/8
70/10 70/23 72/20
77/9 79/6 81/3 82/23
108/6 108/16 109/17
109/20 110/17 111/8
111/11 111/12 111/13)
112/1 114/18 116/6
130/11 130/14 130/17)
176/10 184/20 185/11
186/20 194/13
case’ [1] 77/11
cases [17] 52/13
105/25 106/2 106/3
106/7 106/7 108/15
110/22 110/23 110/24}
111/6 111/24 112/19
131/21 157/20 189/19
191/16
cash [6] 38/17 38/18
38/21 38/24 39/1 71/6
cast [3] 25/12 86/12
122/14
casting [4] 85/18
85/22 86/12 94/11
categorically [2]
195/14 195/19
categorisation [1]
165/2
cause [3] 22/2 100/4
101/1
caused [3] 9/16 9/17
169/14
causing [2] 116/8
116/17
cautioned [1] 182/1
cautioning [1] 182/3
caveated [2] 103/14
195/20
caveats [1] 46/13
Cavender [2] 13/6
73/23
Cavender's [1] 74/24
CCRC [5] 107/13
107/15 107/17 107/19}
173/11
central [1] 45/25
centrally’ [1] 72/14
centred [1] 58/5
CEO [8] 22/15 23/19
45/10 68/19 142/19
156/2 172/2 172/7
certain [3] 46/18
71/24 159/21
certainly [14] 14/25
41/15 48/22 51/8
58/23 82/13 92/4
100/21 117/8 127/11
127/23 148/9 150/21
176/24
cetera [6] 95/13
140/6 150/1 154/16
192/25 193/1
chain [10] 36/24
53/23 53/24 80/11
81/10 81/13 92/16
92/20 92/24 96/16
chains [1] 29/25
chair [30] 7/25 22/12
23/19 36/21 45/10
53/13 76/5 95/9
102/13 133/2 139/10
139/18 140/7 140/16
140/24 141/17 142/21
142/25 145/1 145/1
146/20 159/2 159/4
166/11 168/21 170/12)
172/7 172/8 181/18
181/19
chairing [1] 172/11
Chairman [6] 4/1
7/10 138/9 138/17
147/24 169/13
chairmanship [1]
170/15
Chairpeople [1]
170/21
chairperson [4]
147/11 157/12 166/5
172/2
chairs [1] 185/6
challenge [8] 19/25
24/7 28/13 83/19
84/10 87/21 108/7
185/13
challenge’ [1] 129/3
challenged [3] 74/14
114/23 184/12
challenges [1]
147/15
challenging [2] 74/5
132/20
chance [6] 52/2
94/25 95/20 96/7
96/20 177/11
change [28] 5/23
22/18 22/20 23/2 23/2
23/7 23/9 24/11 25/15)
25/20 59/15 67/13
67/15 68/7 68/11
68/14 114/6 126/2
129/16 132/16 133/14)
133/17 134/6 134/10
161/23 179/15 184/22)
185/18
change/culture [1]
114/6
changed [9] 55/8
62/10 65/18 95/8
104/11 118/22 119/14]
120/19 133/12
changes [4] 146/21
164/9 182/2 182/3
channel [4] 33/1
36/19 68/8 68/9
characterisation [1]
72/3
characterises [1]
71/1
charge [2] 43/21
161/22
charged [1] 183/12
chartered [1] 138/2
chat [2] 170/20
172/23
chats [1] 172/21
check [4] 106/18
1141/1 111/2 111/3
Chief [9] 148/4 148/7
157/17 158/18 160/17]
160/19 170/18 170/18
196/3
Chisholm [11] 31/16
78/5 78/8 78/25 79/14
85/15 87/7 87/16 88/3
91/20 92/23
choice [1] 160/17
chronology [2] 146/4
173/4
circle [1] 183/10
circulated [1] 48/15
circumstances [1]
191/3
cite [2] 2/17 3/2
izens [1] 183/6
civil [9] 49/11 49/22
50/16 51/7 54/12
59/13 61/21 62/1
69/12
claim [7] 40/11 43/2
43/2 100/20 101/18
102/11 103/15
claimants [13] 14/23
17/18 19/11 40/6
70/25 104/21 105/5
106/15 109/22 111/2
111/14 133/24 134/13
claimants' [6] 18/19
19/3 105/11 105/16
106/6 110/25
claimed [4] 116/17
claims [4] 51/6
112/18 112/19 192/14
clarified [2] 35/3
165/20
clarify [3] 30/3 45/19
157/14
clarity [1] 14/16
Clarke [5] 37/25
59/14 131/18 133/15
155/11
Clarke's [4] 132/15
clause [21] 15/1
15/21 15/22 16/9
16/20 25/23 37/18
46/19 47/2 67/21
118/14 118/16 118/18}
118/21 119/9 119/16
119/24 120/18 121/20}
122/17 122/19
clauses [1] 15/8
clear [33] 23/9 47/10
51/17 58/4 86/2 86/2
86/24 86/24 87/2
87/16 88/7 88/18
89/10 93/21 96/10
97/14 104/15 116/4
124/17 127/13 127/14}
128/15 135/6 135/10
144/16 150/1 156/4
156/14 163/2 168/19
171/2 184/13 188/15
clearly [12] 12/12
32/2 35/22 53/8 88/20)
90/13 93/14 93/24
101/24 109/5 116/25
182/11
clients [2] 159/25
189/18
close [3] 119/22
186/4 196/16
closely [2] 14/1 63/7
Co [3] 4/1 118/9
186/3
Co-Chairman [1] 4/1
coding [1] 182/6
coerced [1] 43/20
coercive [2] 39/3
39/14
coercively [1] 39/10
cognisant [1] 84/25
coincided [1] 133/1
coincidentally [1]
192/12
colleagues [9] 12/4
26/2 35/13 35/24
37/22 44/22 68/24
90/24 165/21
collectively [3] 48/10
58/12 73/18
colour [3] 61/11
66/11 182/6
colour-coding [1]
182/6
column [12] 49/14
50/14 51/4 52/1 54/9
54/19 55/22 59/17
59/20 60/19 62/17
64/3
columns [2] 49/13
51/24
come [25] 25/3 26/21
32/9 44/8 45/17 80/9
84/18 85/14 85/16
86/19 88/17 91/17
94/3 96/9 106/21
137/9 141/3 144/11
147/17 147/20 148/10}
152/14 155/21 156/10)
162/2
comes [3] 19/8 85/24
90/13
comfort [1] 12/18
comfortable [1]
36/21
coming [8] 1/16
26/12 63/20 64/2
96/20 99/18 185/16
196/18
command [1] 36/24
commence [1]
122/14
commenced [1]
144/24
commences [1]
28/16
comment [7] 32/13
63/2 93/19 113/20
131/19 156/22 171/11
commentary [3]
41/11 41/11 92/16
commenting [1]
175/22
comments [5] 17/19
20/2 21/25 49/18
95/17
commission [1] 7/25
commissioned [1]
7/11
commit [1] 141/4
commitment [5]
139/1 139/13 140/1
140/18 141/16
commitments [1]
14115
committed [1] 114/9
committee [7] 72/23
125/17 125/17 125/19}
138/18 143/18 144/21
common [45] 13/6
19/4 19/9 32/3 33/24
42/19 42/24 42/25
44/8 45/21 46/1 46/15)
46/22 47/6 63/14
66/24 67/1 67/8 67/14
67/22 69/21 69/24
70/15 71/24 72/17
73/10 98/16 103/21
104/8 106/3 106/8
114/22 116/23 126/6
126/8 127/1 127/3
129/18 131/7 131/10
132/4 132/13 132/19
132/25 133/6
comms [4] 59/22
63/4 64/23 64/24
communicate [2]
24/12 187/16
communicated [5]
28/1 123/4 187/11
188/3 188/8
(56) carry - communicated
Cc
communicating [5]
23/10 30/1 38/5 90/3
166/8
communication [8]
27/16 33/1 36/19
55/16 60/5 135/11
183/14 183/17
communications [4]
20/5 64/22 71/15
97/23
companies [4] 15/5
141/11 146/11 170/17)
company [46] 8/13
9/10 15/20 16/3 16/3
17/10 23/2 24/7 25/17
25/18 26/17 28/6
30/22 33/24 34/6
34/15 34/20 37/10
43/1 44/15 44/19 47/3
53/9 55/3 56/24 57/3
61/6 61/8 72/25 74/15}
75/10 81/17 109/5
112/20 125/25 126/20}
134/2 135/7 142/7
152/22 152/24 154/13}
158/2 166/7 185/20
189/10
company's [6] 45/6
78/1 152/25 153/9
153/18 153/25
comparing [1] 8/18
compensated [2]
109/8 134/15
compensated/resolv
ed/apologised [1]
109/8
compensation [3]
34/9 51/6 127/15
competition [1]
28/13
complainants [4]
38/22 39/24 40/5
59/23
complaint [2] 188/2
188/12
complaints [9] 37/10
187/7 187/21 188/8
188/16 188/23 188/23
190/19 190/21
complement [1]
146/15
complete [3] 103/11
177/24 178/11
completely [14]
15/19 15/23 16/5
25/24 70/17 74/19
105/19 117/18 118/19)
133/19 134/4 152/13
193/11 195/1
completes [1] 5/12
complexity [2]
145/13 191/20
compliant [1] 127/3
complicated [1] 32/1
complied [1] 152/12
complying [1] 152/2
composed [1] 107/2
compounded [1]
195/8
comprehensive [1]
28/1
comprehensively [3]
65/10 70/22 73/7
comprised [2]
153/10 153/21
compromise [4] 15/6
17/1 47/1 47/5
compromised [1]
46/16
computer [10] 15/9
15/10 17/4 38/13 47/4
65/2 192/13 192/15
192/24 193/4
concede [1] 122/17
conceded [1] 14/24
concentrate [1]
112/14
concern [24] 19/10
22/3 23/15 23/22
32/20 36/15 63/13
67/20 75/15 79/24
81/19 82/1 82/16
87/23 90/22 91/6
93/17 96/5 107/20
117/11 117/12 161/25)
161/25 172/10
concerned [15] 17/5
20/11 20/25 21/13
36/20 42/3 52/16
74/24 80/11 90/25
96/23 98/1 108/21
109/7 131/16
concerning [8] 7/3
26/4 31/12 69/20
75/22 78/16 128/11
147/12
concerns [42] 9/14
15/22 17/14 20/14
22/6 22/8 22/11 23/18
24/13 25/3 25/8 25/10
32/19 33/14 35/20
35/21 44/21 45/1 45/9)
54/15 55/22 62/8
89/18 119/6 130/10
167/7 167/17 170/24
171/2 171/3 171/3
171/4 171/24 172/7
172/13 172/15 173/23)
174/22 175/2 176/4
176/17 177/7
conclude [1] 77/3
concluded [1] 19/1
concludes [1] 185/25
conclusion [3] 11/17
46/20 196/12
conclusions [1]
167/19
conditional [4] 95/1
95/13 96/4 96/7
Conditions [1] 194/6
conduct [16] 11/20
16/14 17/14 19/17
26/5 30/8 37/18 39/11
69/2 70/23 125/20
173/22
conducting [1] 68/15
confidence [5] 61/2
61/9 62/5 74/19
104/12
confident [1] 117/10
confirm [5] 13/22
38/1 64/16 70/5
137/18
confirmed [5] 18/3
19/7 69/23 126/6
193/21
confirms [2] 54/20
7113
conflate [1] 61/5
conflated [2] 81/5
90/8
conflict [7] 81/18
82/2 82/5 89/13 141/9
160/2 160/4
connected [1] 133/4
connection [1] 41/13
connotations [1]
60/12
conscious [1] 124/7
consciousness [1]
193/1
consensual [1] 66/24)
consequence [1]
169/5
consequences [8]
32/4 40/17 52/9 57/1
58/22 58/25 69/4
93/16
consider [22] 11/13
30/6 69/10 80/4 80/18
83/19 89/12 91/12
95/2 99/3 107/7 129/4
133/16 142/12 146/23}
146/24 148/6 151/19
160/1 165/12 167/15
175/1
considerable [5]
18/23 22/2 22/8 59/22
65/1
consideration [4]
9/25 25/7 35/6 160/20
considered [11] 75/1
77/2 78/3 84/3 87/18
119/1 126/13 126/18
160/19 186/25 189/24
considering [4] 75/2
99/21 100/22 143/17
consistent [5] 9/3
concurrently [1] 56/4
21/6 23/19 24/13 25/8
29/11 43/14 88/21
131/1
consistently [3] 9/10
14/6 119/11
constant [2] 116/1
184/22
constituted [1]
146/10
constrained [2]
97/10 103/10
constructive [1]
148/3
constructively [1]
19/19
consultation [2]
106/23 163/10
consulted [1] 90/25
contact [1] 30/17
containing [1] 92/16
contains [3] 2/22
57/11 57/24
contemplation [1]
86/18
contemptuously [1]
194/19
content [2] 3/11 99/7
contentious [1]
151/5
contents [1] 48/6
context [28] 8/16
14/20 15/3 20/5 82/7
85/14 91/4 91/9
102/23 103/1 113/24
115/25 145/21 146/2
147/4 149/25 156/16
158/13 166/14 168/9
171/1 172/8 174/1
174/7 180/3 182/23
190/2 191/1
contingency [12]
24/8 28/4 34/5 40/21
56/11 56/23 57/3
58/24 64/7 71/14
123/6 194/12
continue [6] 16/20
34/16 54/13 60/22
120/24 174/23
continued [1] 50/22
continues [2] 51/9
64/18
continuing [1]
194/12
continuity [1] 55/17
contract [17] 13/17
14/4 16/6 26/24 28/14}
38/16 38/19 46/2 46/6
46/24 56/3 64/6 74/9
74/10 126/21 126/21
127/3
contracts [7] 14/14
74/8 126/10 126/12
126/13 126/17 127/5
contractual [10]
13/11 17/2 39/24
40/11 43/2 67/4 71/2
190/24 191/1 191/8
contractually [1]
38/23
contrary [1] 196/10
contributing [1]
62/25
contributions [1] 2/4
control [2] 25/19
179/15
controlled [3] 12/19
48/12 179/15
controls [1] 178/20
convened [1] 73/19
convenient [2] 45/16
92/2
conversation [7]
155/19 171/16 172/3
173/20 174/1 174/5
175/14
conversations [4]
17/8 26/15 40/21
171/22
convey [1] 61/15
conveyed [1] 69/19
conveying [1] 63/17
convict [1] 105/11
convicted [9] 41/20
42/2 104/21 105/4
105/16 109/7 111/14
167/11 167/13
convicted/terminated
/harmed [1] 109/7
conviction [2] 40/12
42/9
convictions [6] 40/7
40/22 51/12 108/14
168/3 173/12
convinced [1] 81/18
COOPER [29] 1/10
1/13 1/14 43/13 45/20)
47/20 62/13 92/15
97/17 99/3 99/9 99/16}
103/16 103/18 105/12)
107/23 109/15 117/20)
117/24 118/6 118/14
122/21 123/20 124/2
125/11 128/3 134/19
135/18 198/2
Cooper/Tim [1]
109/15
cooperative [1]
19/18
copied [6] 18/13
37/25 70/8 79/11
79/14 81/12
copy [9] 1/18 13/5
20/16 28/20 49/2 51/2I
57/8 71/19 137/10
copying [1] 79/18
core [5] 27/10 97/18
99/6 142/6 186/1
corner [1] 53/6
corporate [6] 146/7
(57) communicating - corporate
Cc
corporate... [5] 147/3
150/5 163/16 170/16
184/21
corporation [1]
146/10
corporations [5]
144/19 145/4 145/8
184/24 184/25
correct [92] 1/25 2/6
2/20 3/24 4/22 6/17
6/21 6/24 7/9 13/7
20/18 22/16 22/17
23/17 41/10 44/2 46/7,
46/10 48/1 48/14
49/25 65/16 73/20
75/25 78/7 78/12
78/18 82/5 85/6 88/3
89/2 89/24 96/25 98/5
98/8 101/23 110/13
111/15 113/2 113/3
113/14 116/12 116/19}
120/4 137/3 137/4
137/8 138/3 138/6
138/8 138/12 138/15
138/19 138/22 139/11
139/14 139/20 140/11
142/5 143/2 143/6
144/6 147/19 151/23
153/17 154/4 154/5
154/6 154/7 154/10
155/18 158/4 158/5
158/6 158/9 162/14
162/17 162/23 163/15
165/15 170/13 171/14}
173/8 173/10 182/25
187/3 188/1 190/9
193/2 193/7 194/23
196/23
correction [3] 2/7
113/3 136/22
corrections [4] 1/23
3/11 136/25 137/19
correctly [1] 76/18
correspondence [1]
39/7
corroboration [1]
178/4
cost [4] 51/9 100/16
101/22 127/15
costing [1] 145/19
costs [2] 21/9 127/8
could [104] 1/8 13/22
16/16 16/24 17/23
18/1 19/3 19/14 21/17)
23/6 24/7 24/10 25/9
27/18 28/10 28/17
28/24 32/22 33/21
34/6 34/9 34/21 34/24
35/8 37/21 37/25 39/5
39/25 43/24 46/8
46/21 46/24 47/1 47/7)
47/10 49/8 52/20
56/21 58/10 58/18
68/7 69/15 70/1 76/2
76/3 76/24 79/24
85/14 85/16 89/14
91/17 97/5 98/22
99/17 100/12 100/16
101/9 101/21 103/13
104/18 105/17 105/20
109/5 110/19 112/10
113/24 116/16 123/5
123/11 124/11 124/13)
126/14 128/5 129/10
131/16 139/4 140/12
142/22 143/9 147/22
148/12 148/19 148/25)
149/6 149/18 155/3
159/4 160/23 162/2
164/12 164/23 166/19)
168/2 170/23 171/24
172/4 175/25 178/16
181/16 189/9 193/8
194/11 195/16 196/12)
couldn't [8] 15/13
25/5 43/1 102/19
117/18 156/22 195/2
195/2
counsel [26] 13/10
13/23 16/8 17/24 18/4
20/15 27/4 45/2 54/24
56/10 60/24 62/22
64/17 64/19 65/7
69/23 71/18 73/17
TAIT 75/22 78/9 90/24
92/22 107/16 108/23
188/19
counter [1] 195/5
country [3] 14/14
169/18 183/6
counts [1] 69/18
couple [3] 12/7 79/4
114/7
course [18] 10/7
49/23 80/7 85/4 86/25
95/6 105/22 106/21
107/3 112/24 131/17
135/20 144/3 159/13
164/24 167/3 185/5
185/14
court [9] 19/21 20/12
21/1 50/16 73/5 76/15
122/16 122/19 130/11
courts [2] 51/7 51/16
cover [1] 56/11
coverage [4] 58/11
58/19 58/21 108/6
covered [4] 27/21
28/6 97/20 110/23
covering [2] 49/8
65/5
create [4] 14/17 86/6
170/22 179/4
creates [1] 179/6
credibility [1] 109/22
credible [2] 93/15
110/16
credit [2] 134/6
134/10
Cresswell [1] 112/13
crime [1] 43/25
criminal [6] 38/20
40/12 51/7 51/12
51/16 110/22
critical [9] 19/17 34/5
34/8 69/16 114/22
185/11 193/20 195/24
196/6
criticised [3] 70/21
73/4 90/10
criticism [2] 19/20
21/6
criticisms [2] 20/8
93/18
cross [1] 106/18
cross-check [1]
106/18
crowd [1] 65/4
Crucially [1] 85/18
crumbled [1] 74/18
cudgel [1] 145/6
culpability [1] 102/4
culpable [2] 102/5
102/6
culture [4] 114/6
114/12 114/12 115/21
cumulatively [1] 99/6
cupboard [1] 74/11
curiosity [1] 115/21
current [5] 34/14
49/18 55/22 64/3
144/18
currently [1] 145/4
cursorily [1] 77/7
curve [1] 31/25
cut [2] 42/15 124/22
cut-off [1] 124/22
DO
Daily [4] 65/1
damaged [1] 113/16
damaging [2] 170/10
196/6
data [6] 40/7 44/20
159/23 167/11 168/6
178/23
date [6] 41/25 55/23
116/5 116/21 119/21
140/18
dated [9] 1/19 2/10
2/11 28/15 37/22 49/3
57/9 85/8 147/21
Davey [1] 186/16
David [2] 13/5 73/23
day [28] 20/22 25/2
25/2 32/16 32/16
32/19 32/19 32/23
32/23 65/5 85/9
110/10 124/18 131/11
131/14 139/1 140/3
140/19 141/1 141/3
152/19 152/19 154/12}
154/12 154/15 154/15)
191/1 191/1
days [10] 75/22
94/21 122/13 139/8
139/9 139/13 139/17
140/21 140/23 140/25}
de [1] 104/11
de Garr [1] 104/11
deaf [1] 23/15
deal [3] 64/8 122/16
160/1
dealing [10] 2/13
36/3 54/8 93/16 100/8
112/24 117/15 117/16
147/16 158/10
deals [1] 58/8
dealt [6] 19/13 34/9
37/12 120/6 125/18
135/6
Dear [1] 76/7
debate [3] 35/10
83/10 112/14
December [7] 3/2
57/9 61/1 61/6 65/19
69/7 114/25
December 2019" [1]
114/25
deceptively [1] 45/22
decide [5] 21/8
107/22 108/9 108/18
124/10
decided [4] 18/22
37/1 96/16 104/21
decides [1] 94/24
deciding [2] 19/16
154/16
decision [38] 55/21
64/9 78/10 78/16 79/5)
79/6 80/5 80/15 80/19
81/16 81/24 82/18
82/25 83/10 84/9
84/12 85/1 85/5 85/20)
86/1 87/21 88/17 89/8
89/12 89/15 89/20
89/23 90/15 91/2 91/7,
95/7 96/9 96/20 96/24
97/1 126/6 133/2
185/20
decisions [5] 2/5
21/8 148/5 154/15
169/16
decisive [1] 132/8
decommissioning [4]
26/24 28/14 35/4
145/18
dedicated [2] 32/5
65/5
deem [1] 156/2
deeming [1] 40/1
deep [7] 114/12
163/13 164/18 164/22)
164/24 174/11 180/8
deeply [2] 87/17
190/12
defects [1] 72/18
defence [1] 56/9
defend [3] 16/20
51/10 120/24
defended [1] 122/19
defending [1] 16/9
deficiencies [1]
184/14
define [2] 148/25
183/9
defined [1] 149/2
definitive [1] 10/12
degree [4] 16/22
121/2 179/21 180/14
delaying [1] 47/9
delegate [3] 148/19
149/6 149/18
delete [1] 178/17
deleting [1] 178/23
delineated [1] 149/11
deliver [1] 85/16
delivered [1] 85/17
delivering [1] 127/21
delivery [3] 57/25
143/16 169/19
Deloitte [7] 155/20
173/21 173/24 174/10)
176/10 177/6 177/11
Deloittes [1] 155/11
democratic [2]
189/21 190/18
demonstrated [2]
76/17 76/24
den [1] 73/3
denial [1] 195/9
department [89]
12/12 12/19 23/22
24/5 24/10 24/12
24/15 25/9 25/16 26/7
27/11 27/13 27/17
29/20 29/21 30/2
30/13 30/19 30/20
30/24 31/3 31/12
31/15 32/5 33/4 33/6
34/4 34/19 38/6 58/23}
63/14 63/16 63/17
66/20 68/14 68/20
79/23 80/14 81/8
82/11 82/12 82/13
82/23 83/5 86/5 88/19
88/25 90/10 90/16
91/23 91/24 93/14
93/20 94/2 94/7 95/22)
95/23 96/2 96/8 96/9
96/21 96/23 97/4 97/7
97/11 97/25 123/6
128/9 128/16 128/17
128/18 128/20 129/8
129/10 129/17 129/23)
131/15 132/1 133/16
133/20 133/23 142/8
148/15 153/4 153/6
(58)
corporate... - department
D
department... [4]
179/19 183/15 183/18)
195/23
Department's [10]
94/10 97/19 128/4
129/1 129/5 130/1
131/7 132/5 134/2
153/15
departmental [3]
31/8 90/6 131/12
depended [1] 145/23
dependent [2] 156/2
185/9
depending [2] 63/4
139/3
depends [1] 168/8
Deputy [5] 138/20
139/1 139/7 140/15
159/9
describe [5] 6/19
20/7 71/22 77/20
154/8
described [7] 16/8
49/22 59/12 123/22
172/22 177/18 194/19}
description [4] 66/2
106/14 108/7 163/3
design [1] 177/25
designed [1] 178/21
desire [1] 93/18
desk [1] 123/15
desktop [3] 174/13
177/16 180/2
desperate [2] 107/22
108/18
detached [2] 93/15
93/25
detail [5] 21/2 59/11
110/22 134/24 178/14)
detailed [4] 1/17
70/16 71/15 135/18
determine [4] 56/3
64/5 174/12 190/3
Deutsche [1] 4/2
develop [2] 35/7
148/3
developed [1] 44/5
developments [1]
50/10
diagnosis [1] 115/22
dialled [1] 130/7
dialogue [2] 150/25
152/5
did [113] 4/8 7/15
7/18 8/11 8/24 8/25
9/13 9/25 10/3 10/8
14/22 15/15 23/18
24/12 25/7 25/22 26/3
26/13 27/22 29/14
30/6 30/10 31/21 33/7
33/12 33/13 36/8 36/9
37/6 37/17 44/1 44/16
44/21 45/2 45/8 48/6
48/17 52/16 53/20
54/15 60/14 65/13
71/19 72/24 82/19
82/19 83/6 85/21
91/12 91/15 96/9
96/15 102/15 102/21
108/24 109/2 111/8
113/4 116/15 116/20
117/11 120/8 121/17
121/19 121/22 122/22)
122/25 123/14 125/21
128/22 133/1 135/1
139/6 139/15 140/4
140/6 141/4 141/9
141/13 141/16 144/12)
144/17 145/1 145/1
145/10 146/6 148/6
149/2 149/16 154/12
157/16 158/17 159/10)
161/8 166/5 166/23
169/3 169/11 171/15
171/20 172/5 173/1
173/3 174/13 174/14
174/18 174/20 174/23)
174/25 176/6 183/16
184/16 190/21
didn't [54] 7/17 12/20
15/11 15/18 22/25
25/11 25/25 26/1
33/23 37/4 37/4 40/24
41/2 42/7 42/9 44/7
44/11 44/24 45/13
45/14 46/20 50/7 54/5
59/2 59/5 67/9 67/24
68/1 68/9 80/16 82/20
86/13 96/8 96/23 97/1
97/4 104/9 105/18
106/8 111/7 113/22
114/15 116/24 117/2
121/6 123/3 123/10
160/22 160/22 164/13}
165/13 166/16 183/19)
190/1
die [2] 25/12 122/14
difference [6] 34/2
69/7 88/24 132/19
134/3 152/23
different [11] 9/2
46/17 116/13 134/1
141/10 152/7 156/21
177/1 177/3 188/19
192/18
differently [3] 119/9
175/22 191/4
difficult [8] 81/22
82/18 96/24 97/1 97/8
171/12 183/9 189/13
difficulties [3] 83/24
171/12 171/15
digital [1] 178/19
digitally [1] 178/23
digress [1] 31/9
direct [6] 48/6 89/11
93/21 144/5 161/6
162/21
direction [4] 83/25
95/19 143/14 147/25
directly [7] 17/8 37/6
60/24 162/20 176/5
179/5 185/19
director [29] 4/14
12/8 29/2 29/6 30/11
38/3 60/23 62/8 64/22
66/15 80/7 81/1 81/15)
81/23 81/25 82/3
83/22 84/8 84/15
86/21 89/9 89/14
89/19 91/14 134/22
135/1 154/4 160/15
165/25
Directors [7] 36/7
36/22 153/11 153/22
153/23 154/1 154/3
disagree [2] 121/21
191/18
disagreed [2] 75/11
75/11
disappear [2] 135/23
135/24
disappeared [1]
127/19
disappointed [1]
25/22
disappointing [2]
19/24 25/25
disaster [1] 104/8
discharging [1]
166/24
discipline [1] 186/7
disclosure [10]
54/23 56/6 60/24
62/21 64/12 99/19
100/1 108/25 109/1
109/3
discovery [1] 10/17
discrepancies [2]
9/16 180/11
discrepancy [1]
38/17
discretion [4] 18/24
18/25 84/14 85/3
discuss [10] 63/24
64/24 69/15 73/20
100/6 133/12 158/17
160/10 171/20 173/18
discussed [17] 13/10
13/20 41/17 56/10
65/9 82/10 82/12
87/15 89/9 97/21
119/17 126/1 158/18
162/18 163/6 163/8
173/7
discussing [5] 44/9
145/3 169/17 170/3
183/20
discussion [12] 25/2
35/10 44/4 44/23
74/22 87/6 87/12
103/5 147/8 147/10
159/11 163/12
discussions [11] 2/5
16/7 23/4 29/8 32/10
41/21 41/22 87/14
133/2 159/8 162/12
disenchanted [1]
104/7
dislike [1] 119/24
dismissal [1] 37/15
ismissed [1] 17/16
dismissive [1] 39/8
dispute [7] 7/2 7/6
13/12 15/4 17/12 28/5}
72/13
disputed [1] 19/12
disputes [1] 126/24
disputing [2] 15/6
72/14
disregarding [1]
21/16
distance [2] 88/20
105/14
distinct [3] 89/3
93/14 93/24
distinction [4] 90/5
94/10 94/13 149/10
distinguish [1] 81/7
distinguishing [1]
83/24
distraction [3] 51/9
60/6 60/12
dive [6] 163/13
164/18 164/22 164/25
174/11 180/8
diverted [1] 60/10
division [3] 144/4
161/2 161/15
do [101] 6/7 7/23
8/20 11/13 16/4 16/6
27/20 28/4 28/20
31/17 32/4 40/11 50/1
50/11 53/1 53/19
55/19 56/24 58/14
58/15 59/3 59/15 60/2
68/24 69/10 79/6 79/8)
84/22 86/15 89/12
89/23 90/21 91/16
93/25 95/21 96/2 96/2,
96/3 98/10 99/12
105/20 106/12 107/9
107/23 108/17 109/6
109/11 109/25 111/18}
114/19 114/21 115/21
116/24 117/2 117/7
117/9 121/17 121/23
123/1 129/4 133/16
134/6 134/10 135/8
136/3 137/14 137/15
139/21 142/15 144/7
147/1 151/24 154/11
157/2 159/10 159/15
159/17 160/5 163/19
163/21 164/14 167/21
168/3 168/24 169/6
173/15 174/11 176/13)
176/18 179/25 179/25)
180/7 181/6 182/19
185/7 188/19 189/17
190/16 190/20 191/11
196/11
document [21] 2/14
2/16 2/18 3/2 8/3
12/20 48/12 53/24
71/5 78/24 102/18
104/22 107/8 114/2
124/4 143/4 144/11
159/5 178/20 194/8
194/22
documentation [1]
177/19
documents [14] 13/1
24/23 27/13 98/24
102/16 107/15 155/9
155/16 155/22 156/4
156/13 156/14 173/19}
177/24
Docusign [1] 137/13
does [12] 32/16 41/4
44/10 56/16 63/6 73/9)
89/10 110/15 179/9
181/4 181/5 183/14
doesn't [10] 34/14
34/15 52/14 52/14
61/11 94/1 107/12
109/21 163/12 187/4
doing [12] 5/19 16/4
23/3 23/10 60/6 60/10
95/18 104/20 120/8
171/25 172/4 190/6
domain [5] 104/25
105/17 106/5 106/13
190/16
dominance [1]
158/13
don't [77] 6/1 23/21
27/22 27/25 28/22
30/25 32/11 32/11
32/15 34/1 39/12 43/5
43/10 44/4 44/5 44/14
44/23 44/24 52/22
54/2 55/11 55/17
58/16 58/20 59/9
59/16 61/4 62/15
66/13 67/12 67/13
67/15 69/14 70/5 80/3
80/16 80/18 82/5
83/18 86/22 90/16
91/4 95/2 95/17 97/2
97/4 98/14 98/20
98/20 98/24 102/2
103/14 106/17 109/2
1412/5 113/3 113/5
113/19 113/22 117/15)
120/1 123/2 123/16
124/8 132/13 132/15
133/24 135/23 143/3
(69) department... - don't
D
don't... [8] 148/1
150/13 154/14 160/3
171/7 178/14 180/24
191/23
done [12] 58/24
74/17 84/8 86/21 97/9
97/9 105/2 163/21
164/17 164/24 175/12)
189/9
Donnelly [1] 151/9
dossier [1] 110/24
double [1] 80/3
doubt [5] 23/21 152/4)
190/7 191/14 195/11
down [44] 12/7 19/14
20/20 49/21 52/2
57/18 59/11 65/11
71/10 71/17 76/14
93/8 100/11 102/19
104/18 116/5 116/21
118/24 129/18 131/10}
131/15 132/3 133/6
137/9 141/3 143/9
144/11 146/1 148/10
152/14 153/14 156/10
163/4 165/7 165/11
178/8 178/15 179/1
181/10 181/11 181/21
186/11 193/22 195/10
draft [7] 14/16 28/14
71/19 76/16 105/1
113/24 118/19
drafted [1] 33/19
drafting [1] 184/17
drawing [1] 35/12
drawn [1] 84/6
driven [2] 65/12
102/3
drop [4] 32/12
dropped [1] 31/18
dropping [1] 43/21
dual [4] 187/15
due [5] 10/11 22/23
106/21 122/13 185/4
duly [1] 145/6
during [12] 5/24 10/7
10/23 10/24 20/2
36/10 77/16 101/11
102/1 131/17 138/4
193/3
duties [1] 148/8
duty [1] 91/13
E
each [9] 5/12 5/16
19/5 47/25 48/3 83/13)
140/19 145/11 147/14)
earlier [34] 8/22
11/12 23/4 47/22
48/21 51/2 51/11 59/1
60/4 62/19 63/12
63/19 64/1 68/1 84/16
90/7 92/22 93/1 97/20
112/10 117/3 118/18
121/25 129/12 130/23)
131/2 131/5 133/5
133/8 135/6 151/16
158/16 160/14 177/16)
early [11] 4/10 9/13
9/25 10/22 11/8 11/9
11/14 22/23 42/12
135/3 163/18
ears [1] 23/16
easier [1] 179/18
easily [1] 5/2
East [1] 186/14
easy [3] 21/11 61/5
158/22
Economic [1] 194/6
economics [1] 137/5
Ed [1] 186/16
Ed Davey [1] 186/16
edifice [1] 74/17
effect [14] 12/25 16/3
41/9 42/21 42/24
53/14 68/14 72/13
74/25 96/16 110/3
131/19 133/9 187/14
effective [5] 24/10
33/1 68/21 129/10
148/5
effectively [15] 14/11
15/7 29/24 42/7 48/23
66/3 72/12 86/5 90/15
115/5 127/1 164/25
166/25 167/19 183/2
effectiveness [3]
129/7 171/23 188/9
effort [1] 23/24
efforts [1] 7/5
either [11] 23/19
45/10 82/11 85/19
85/23 86/13 149/2
149/14 149/25 190/22)
193/6
element [3] 12/14
28/8 36/11
elements [2] 14/5
27/10
elevated [1] 149/24
Elizabeth [2] 27/3
28/1
else [7] 42/5 114/4
123/18 126/1 131/25
167/5 190/12
elsewhere [1] 114/8
email [56] 2/9 18/2
18/13 29/25 37/21
39/22 40/3 40/4 44/2
44/6 70/1 70/4 70/7
70/8 70/10 76/4 77/21
78/21 78/24 79/12
79/17 79/21 81/9
81/10 81/12 84/14
84/17 85/2 85/7 85/10
85/11 86/23 86/25
87/10 87/24 87/25
88/7 88/14 90/14
91/18 91/20 92/16
92/20 92/24 93/8
93/22 94/4 94/16
94/19 96/16 106/19
110/2 110/4 110/19
130/25 131/13
emails [5] 18/16 81/3
82/15 96/11 149/14
emboldened [1]
132/7
emerge [1] 135/2
emergency [1] 179/3
emotional [1] 105/13
employed [1] 54/11
employee [1] 163/9
empower [1] 185/19
enable [4] 11/24
29/10 99/9 114/24
enabled [3] 12/17
12/25 57/4
encourage [1] 35/9
encouraged [2] 41/5
45/5
encouragement [2]
68/4 101/3
encouraging [2] 39/4
39/16
end [11] 8/9 17/12
43/16 45/17 93/4
165/18 167/20 175/14
175/16 176/11 181/24
ended [1] 46/22
engage [2] 123/25
129/6
engaged [4] 6/15 7/2
63/16 79/22
engagement [9]
31/12 63/13 64/2
97/24 118/10 122/3
128/4 129/3 132/5
engaging [2] 129/8
132/10
engineer [2] 94/23
95/12
engineering [3]
90/14 91/18 95/14
enough [3] 27/15
184/2 184/3
enquiries [1] 83/7
enquiring [1] 134/23
ensure [2] 83/22
150/17
ensured [1] 154/19
ensuring [3] 149/22
151/3 186/7
entire [1] 121/14
entirely [4] 47/5
68/13 110/17 185/9
entirety [1] 75/19
entitled [2] 28/16
195/13
entrenched [1] 17/9
entry [4] 51/14 59/19
64/4 165/12
envisage [1] 128/22
equally [2] 19/20
121/13
equipped [1] 174/11
error [1] 2/2
errors [3] 9/6 100/3
101/41
escalate [4] 35/16
189/19 190/18 191/16}
escalated [2] 187/7
187/8
escalating [1] 36/15
especially [1] 35/12
espousing [1] 117/1
essence [2] 87/23
166/9
essentially [9] 5/13
12/17 27/5 41/11 52/7
101/15 114/11 115/7
162/21
establish [3] 40/11
40/11 43/2
established [4] 19/2
37/16 67/20 144/22
establishment [4]
7IT 97/22 145/20
164/2
et [6] 95/13 140/6
150/1 154/16 192/25
193/1
et cetera [6] 95/13
140/6 150/1 154/16
192/25 193/1
European [1] 3/23
evaluated [1] 75/8
Evans [3] 81/11
85/21 91/23
Evans' [3] 84/19 85/7
85/10
even [18] 11/16
12/21 12/21 27/13
30/16 38/22 42/19
43/5 43/22 50/18
59/21 67/13 74/8
77/24 88/11 88/13
95/3 117/11
evenings [1] 141/8
event [6] 52/12 52/15
123/19 132/14 195/7
195/21
events [4] 100/9
103/7 108/7 112/18
eventually [1] 176/23
ever [4] 82/5 83/5
108/9 159/10
every [6] 48/9 48/9
65/5 109/9 109/9
129/2
everybody [3] 167/5
190/12 190/14
everyone [4] 28/8
124/17 133/19 196/15)
everyone's [1] 86/15
everything [7] 15/6
15/17 94/6 96/18
111/10 114/17 180/3
evidence [47] 2/17
3/3 17/17 18/19 19/3
19/12 21/13 21/16
36/2 38/21 38/25 40/8
43/13 45/20 53/13
56/12 59/1 63/13
70/24 84/7 92/22 93/1
97/21 97/24 98/4 99/9
100/7 118/16 119/5
131/4 135/19 136/15
137/23 153/16 154/21
158/10 165/13 166/16
167/18 170/8 173/6
173/9 179/25 180/14
181/19 190/7 190/10
evident [2] 157/5
178/12
evidential [1] 100/2
evolution [1] 141/24
evolved [5] 6/4 11/9
50/9 141/23 144/25
evolving [3] 31/23
144/15 145/12
exactly [8] 44/25
82/19 96/8 113/6
116/5 116/7 123/22
184/7
exaggerating [1]
117/17
example [22] 6/9
15/2 15/8 29/25 30/20}
33/16 34/7 34/13
38/13 39/4 39/16
39/25 41/18 51/25
72/12 74/5 120/13
152/2 157/5 158/16
161/13 180/11
examples [1] 111/23
exasperation [1]
122/12
except [2] 112/21
140/6
exception [1] 129/20
exceptional [1]
141/14
exchange [4] 84/17
86/11 86/23 91/22
exchanges [1] 96/18
Excluding [1] 155/21
Excuse [1] 141/1
executive [84] 4/14
12/8 29/2 30/11 36/7
36/22 38/3 58/6 60/23
62/7 66/15 82/3 91/14I
132/12 134/22 138/4
138/7 138/9 138/13
138/17 139/9 140/8
140/17 141/5 142/7
142/10 142/11 143/13)
143/18 144/17 145/10}
(60) don't... - executive
E
executive... [53]
146/16 147/25 148/4
148/7 149/20 150/5
151/14 151/24 152/1
152/6 152/10 153/11
153/22 153/22 154/3
154/6 157/11 157/15
157/17 158/14 158/19}
160/15 160/17 160/19)
161/12 161/14 162/20)
163/22 164/21 165/5
165/22 165/25 167/2
170/18 171/21 172/23)
174/3 175/8 176/18
177/6 180/15 180/21
181/11 181/17 187/15}
189/21 190/4 190/19
190/21 191/7 191/15
191/19 196/3
Executive's [2] 147/5
163/1
Executives [2]
134/21 152/6
exercise [5] 75/13
105/10 158/15 185/1
187/17
exercised [1] 180/15
existed [1] 120/12
existing [3] 126/21
143/11 177/21
expanded [1] 139/3
expect [4] 45/2
115/12 143/21 184/4
expectation [1]
104/13
expected [7] 63/5
64/6 64/7 128/16
152/18 187/23 188/25}
expecting [1] 106/11
expects [2] 150/23
151/19
experience [15]
14/13 36/7 144/16
146/14 146/15 147/2
158/19 167/4 170/16
170/17 172/10 172/14}
173/24 174/9 185/10
experienced [1]
167/2
expert [5] 10/16
61/15 61/15 66/13
117/18
expertise [3] 35/12
36/6 146/6
experts [3] 117/5
4117/5 117/14
explain [17] 5/9 22/5
27/1 51/21 51/24 59/5
87/6 89/6 91/3 97/8
99/23 113/25 125/17
126/14 128/8 128/18
129/16
explained [7] 11/18
37/24 53/23 92/22
97/5 98/1 133/5
explanation [1] 59/9
explicitly [1] 84/13
explore [1] 11/14
express [6] 27/19
38/11 93/18 95/4
95/16 170/23
expressed [8] 9/2
16/12 22/6 63/12 84/7
90/22 96/6 131/25
expresses [1] 84/20
expressing [5] 61/9
88/25 90/11 97/11
101/14
expression [1]
193/13
extend [1] 141/13
extension [1] 14/11
extent [3] 24/12 39/3
141/7
external [8] 41/11
54/11 60/20 62/3 73/1
73/16 174/8 188/19
extinguisher [1] 52/5
extra [2] 141/7
182/25
extracted [1] 41/10
extreme [1] 78/2
extremely [1] 19/24
F
face [6] 7/22 77/10
116/3 130/20 130/20
175/2
faced [1] 35/11
fact [14] 2/10 33/22
43/5 50/5 55/1 67/7
112/25 145/16 147/8
156/23 163/16 174/18)
176/4 181/6
factors [1] 156/20
facts [4] 10/6 77/2
106/2 137/18
factual [1] 65/13
fail [1] 77/16
failed [4] 21/9 181/15
191/15 196/4
failure [1] 100/1
failures [2] 116/15
184/24
fair [15] 6/25 13/14
23/16 31/13 36/20
47/3 58/15 77/1 82/4
91/2 93/9 98/3 132/5
162/24 163/3
fair-minded [1] 77/1
fairly [2] 56/16 143/5
fairness [3] 41/13
84/19 123/2
faith [5] 14/4 14/14
14/17 133/9 133/10
fake [1] 178/19
falling [1] 23/15
fallout [2] 59/22
180/9
false [2] 38/12 195/9
far [16] 5/2 46/9
52/16 54/2 65/1 74/24
82/10 83/5 96/23 98/1
104/8 105/2 108/21
109/5 117/5 196/11
fastest [1] 11/5
fault [2] 118/23
119/12
favour [2] 86/17 90/9
fear [1] 170/23
feasible [1] 194/15
feature [2] 65/4
105/6
February [4] 2/10
108/13 110/5 186/16
February 2012 [1]
186/16
fed [4] 32/22 48/18
67/14 103/4
Federation [1]
125/12
feed [2] 39/25 54/5
feedback [2] 29/7
135/4
feeding [2] 63/9 98/2
feeds [2] 5/13 5/17
feel [8] 26/1 30/15
97/4 97/5 107/17
113/22 141/9 141/16
feeling [8] 9/23 16/22
20/7 21/23 71/22
91/10 102/6 121/2
feelings [1] 91/11
feels [3] 81/22 82/17
191/10
felt [29] 12/2 14/22
15/1 15/2 20/25 23/12}
24/8 24/9 30/15 36/21
66/6 86/14 97/10
97/14 97/15 97/24
114/15 117/9 117/11
117/18 118/15 118/18}
123/4 123/5 123/11
132/10 133/11 134/25)
177/8
fetter [1] 109/2
few [4] 55/4 100/13
122/13 146/5
field [1] 83/14
figured [1] 67/25
figures [2] 51/21
176/22
files [1] 107/17
final [13] 28/25 55/22
64/3 73/12 93/11
97/16 100/18 102/21
102/22 102/23 112/9
150/14 178/15
finally [8] 2/25 24/1
49/18 84/4 127/6
131/6 178/1 179/13
finance [2] 135/16
137/7
finances [1] 127/6
financial [13] 51/20
65/2 127/10 138/5
138/10 159/14 159/18}
159/21 168/10 170/19)
170/19 189/6 194/5
financially [2] 102/3
127/16
find [6] 3/8 26/13
90/18 91/17 91/25
110/1
finding [1] 50/18
findings [2] 76/21
126/8
fine [7] 8/17 9/10
43/7 47/13 92/8
175/20 197/3
finely [1] 84/4
finish [3] 99/9 134/19
180/9
finished [1] 11/2
Fiona [4] 144/22
fire [5] 1/6 11/1 52/1
52/5 52/5
fireside [2] 170/20
172/21
firm [1] 118/9
firmly [1] 28/5
first [48] 2/1 5/14 9/5
10/23 11/11 12/7
15/14 21/14 29/14
31/10 32/6 40/5 42/1
42/11 42/13 44/10
45/17 50/14 53/15
56/2 59/17 63/4 63/5
64/5 65/11 75/14 79/2
80/10 83/2 93/23
98/14 99/13 107/3
107/24 108/13 112/24)
122/8 133/5 134/24
137/1 146/5 146/5
159/2 162/15 162/19
164/19 165/4 175/8
firstly [3] 130/23
146/17 168/2
fit [1] 17/4
five [6] 6/5 117/25
124/6 124/12 124/13
186/3
fixed [3] 114/17
132/15 133/22
flag [1] 84/24
flagged [6] 51/13
57/20 76/8 157/9
187/22 188/24
flaws [2] 72/10 72/24
floated [1] 145/16
flotation [3] 193/10
193/18 194/25
flow [2] 166/19
184/14
flowed [1] 14/5
Flowing [1] 17/8
Foat [4] 100/17 102/9I
102/15 102/17
fobbed [1] 106/9
focus [5] 21/4 34/3
58/23 60/4 86/13
focused [4] 32/11
34/20 34/20 47/7
focusing [1] 138/13
follow [5] 41/4 44/10
89/16 91/16 127/25
follow-up [1] 127/25
followed [3] 45/4
68/2 157/18
following [14] 20/22
53/21 71/10 76/17
85/11 101/2 114/22
125/23 129/17 151/8
155/7 158/15 160/25
190/7
follows [4] 187/4
189/17 192/23 196/2
Forget [1] 120/9
forgive [4] 33/10
64/21 79/10 193/12
forgiven [1] 194/17
form [1] 91/5
formal [3] 85/1 135/4
179/15
formality [1] 179/21
formally [3] 32/24
7117 131/10
formed [3] 27/17
133/4 144/8
forms [2] 5/14 9/12
forth [1] 29/22
forthcoming [1] 29/6
fortuitously [1] 36/12I
forum [1] 102/20
forward [5] 62/2
64/19 74/8 173/4
186/6
forwarded [4] 81/12
88/9 92/23 117/14
forwards [2] 84/22
85/8
found [9] 9/7 15/20
76/3 93/1 106/4 108/1
124/4 167/23 168/3
foundation [1]
164/16
four [3] 8/10 8/12
139/13
fourth [1] 28/8
Fox [3] 2/10 18/6
37/24
frame [3] 25/21
122/10 151/13
frank [2] 73/5 148/3
Fraser [8] 17/15
18/17 23/10 34/13
73/4 75/5 76/23
125/23
(61) executive... - Fraser
F
39/17 41/5
free [1] 93/15
freelance [1] 65/3
frequency [1] 179/22
frequent [1] 157/21
frequently [2] 26/14
31/1
Friday [3] 196/22
197/1 197/6
front [4] 1/19 136/17
136/18 167/20
front-end [1] 167/20
frustrated [2] 106/2
123/16
frustration [3] 16/13
16/23 121/3
Fujitsu [17] 100/3
100/4 100/15 100/17
100/20 101/1 101/9
102/6 103/13 178/3
178/17 179/4 179/11
179/15 179/18 179/19}
179/21
fulfilling [1] 89/13
full [8] 1/12 126/9
136/12 154/18 179/10}
180/4 180/6 183/10
fuller [1] 29/7
fully [8] 29/10 35/25
47/8 70/17 72/16
83/22 141/25 193/15
fulsome [1] 31/4
function [10] 35/6
83/21 146/7 146/25
147/2 151/25 153/4
179/20 181/9 184/6
functioning [1] 156/5
fundamental [2]
15/10 43/22
fundamentally [2]
6/1 33/23
funded [1] 10/16
funding [5] 65/4
150/1 161/4 163/7
169/15
further [23] 3/1 18/16
19/14 34/25 49/17
54/20 62/17 75/23
76/9 77/12 89/4 92/16
100/7 104/18 107/13
117/20 128/2 134/16
143/9 182/2 191/23
193/22 198/14
future [2] 127/6
185/7
G
gained [1] 169/21
gaps [1] 177/20
Gareth [4] 79/18
81/14 83/17 91/23
fraud [4] 38/11 39/5
Garr [1] 104/11
gauge [1] 31/2
gave [4] 12/17 22/2
67/23 181/18
general [21] 5/9 13/9
20/15 27/4 28/16
35/19 45/1 69/22
71/18 75/21 78/9
90/24 92/21 114/3
119/2 146/5 148/10
generalisation [1]
115/24
generally [2] 39/14
146/3
generate [2] 58/10
58/19
generated [3] 159/23
167/11 194/19
get [51] 12/20 23/24
24/4 24/11 24/22
25/25 28/5 29/21
34/16 34/19 34/20
44/17 44/20 45/6
55/18 55/21 58/23
106/5 106/8 106/17
117/19 123/5 123/11
123/18 123/23 126/3
154/14 183/23 188/5
188/12 188/14 190/1
193/12
gets [1] 90/15
getting [12] 10/6
10/19 10/24 12/15
21/3 37/10 63/19 94/5
98/3 122/24 130/14
171/18
gist [1] 93/10
give [16] 1/12 9/25
25/7 39/16 56/10 82/2
85/13 100/3 101/1
105/20 106/14 107/16)
114/16 173/22 174/21
175/12
given [23] 6/23 8/15
19/4 19/24 25/15
30/20 53/18 56/21
57/15 59/7 81/19
91/10 94/25 104/7
112/17 118/4 118/16
125/19 130/13 141/5
165/25 191/12 196/9
giving [8] 103/3
103/9 110/11 135/19
136/15 167/18 175/23)
191/15
GLENN [3] 1/10 1/13
198/2
Gavin [2] 79/12 79/17
13/23 16/7 17/24 18/4
34/22 42/8 42/8 44/16)
63/22 77/15 79/3 81/3
81/4 90/8 94/3 105/24!
111/16 116/20 117/10;
132/24 134/24 146/13)
GLO [2] 104/21
112/18
Global [1] 4/1
gloom [1] 104/12
gloomy [1] 65/22
go [50] 25/9 37/4
45/14 48/17 49/8
60/14 68/1 75/13
92/24 96/1 99/17
100/12 106/21 107/7
109/12 110/4 110/8
129/15 131/23 136/4
141/22 146/4 148/1
150/8 152/14 153/3
155/25 156/23 159/4
163/4 165/11 166/6
177/22 178/8 178/14
193/8 193/18 193/23
goes [11] 19/12 23/3
39/22 51/4 61/12
62/24 64/16 71/9
130/9 179/12 179/23
24/16 25/12 25/20
25/21 26/13 27/12
55/19 56/25 59/10
66/2 66/9 67/7 67/11
68/11 91/1 94/1 94/1
107/12 108/9 108/17
110/5 112/18 117/6
119/12 120/2 120/10
121/4 121/17 121/23
122/15 122/16 124/8
124/9 125/13 127/2
137/25 144/7 147/17
155/21 180/4 180/8
194/7
gone [8] 43/3 54/4
74/4 103/25 126/7
133/21 134/12 189/9
good [20] 1/3 10/6
14/4 14/14 14/17
26/12 27/3 36/8 36/14
47/17 55/21 57/3
121/22 125/4 125/11
132/22 132/24 136/6
162/1 186/6
goods [1] 113/16
Google [1] 106/3
got [34] 26/1 30/5
31/19 32/24 37/8
39/19 41/12 41/25
54/18 62/14 68/3
68/19 68/19 68/20
74/21 80/3 90/16
102/23 106/9 107/15
107/16 121/13 121/19}
107/18 107/21 108/22
110/19 110/22 112/10
121/19 123/15 128/14
181/20 184/25 192/24
going [55] 3/15 10/19
12/13 15/4 15/16 24/6
27/16 33/18 44/7 53/3
104/16 104/17 105/13
121/23 122/7 126/16
135/4 189/12 193/4
194/4 194/8
governance [6]
142/9 150/5 161/6
162/18 163/16 181/1
government [37]
3/17 4/20 29/3 34/4
78/15 79/23 79/25
81/20 82/8 82/23
83/13 83/18 85/13
85/24 121/23 127/10
142/7 150/6 150/9
150/23 150/25 151/3
151/7 151/9 151/15
151/18 152/10 161/5
169/15 176/2 183/3
183/12 184/12
Government's [2]
87/19 151/25
Governor [5] 138/20
139/1 139/7 140/15
159/9
Grabiner's [1] 88/11
grateful [6] 49/11
135/21 162/3 196/13
196/16 196/17
great [4] 61/9 104/12
146/14 161/25
greater [1] 161/15
greatest [3] 4/25 5/2
53/18
Green [2] 144/23
145/20
Greg [3] 131/18
132/15 133/15
grew [4] 169/8
169/12 170/1 191/2
grey [1] 51/24
grievances [1] 59/24
Griffiths [3] 54/21
55/4 55/11
grim [1] 104/9
ground [1] 77/13
grounds [10] 18/23
71/12 74/1 74/25
76/10 76/11 76/17
76/20 76/24 79/20
group [22] 6/16 7/2
11/21 30/8 35/17 40/6
53/15 64/22 65/18
69/3 112/23 113/1
128/5 129/5 134/8
148/18 152/20 153/7
162/25 162/25 178/23
178/24
grow [2] 169/11
169/14
guard [1] 59/15
guess [2] 41/12
190/5
guidance [2] 29/9
126/16 133/13 134/16)
34/23 36/15 63/2 64/8
29/14
guilty [10] 39/4 39/16
41/5 42/3 42/4 42/6
42/6 43/15 43/20
43/25
gun [2] 9/7 9/8
Guyett's [1] 36/10
H
had [211]
had a [1] 130/6
hadn't [11] 40/16
41/14 41/15 43/22
7417 75/8 77/24
88/12 108/8 119/14
123/3
half [4] 10/23 32/6
99/5 169/12
halfway [1] 20/20
Hamilton [2] 105/5
107/20
Hamilton/Thomas/McI
Donald [1] 107/20
hampered [6] 12/3
103/2 103/4 103/9
129/4 129/7
hand [7] 49/14 52/1
53/5 88/25 97/17
98/25 152/24
Handbook [1] 150/3
handed [7] 17/22
65/11 71/9 71/17
131/10 131/15 133/6
handing [3] 129/18
132/3 188/19
handled [6] 23/8 66/8
67/9 67/15 175/22
176/3
handling [9] 17/20
17/21 22/4 22/9 25/2
32/21 39/15 65/22
79/6
handover [1] 135/25
hang [4] 120/8
123/15 127/18 133/23}
happen [9] 25/13
25/20 25/21 27/15
34/6 68/11 106/11
115/21 134/4
happened [16] 6/3
10/20 24/1 31/1 42/8
69/8 86/3 103/6 115/3
120/8 121/21 123/19
133/14 145/5 152/8
189/13
happening [6] 68/22
69/8 86/16 121/12
154/20 156/16
happens [1] 34/15
happy [2] 80/7 135/7
hard [6] 31/2 32/9
53/22 69/5 90/4
137/10
harder [1] 123/10
(62) fraud - harder
H
harrowing [1] 105/9
has [42] 2/18 5/23
18/17 18/23 21/8
50/17 53/13 56/6
60/12 61/24 64/12
64/22 64/25 69/9
69/19 70/21 71/4
77/11 77/14 84/8
85/13 93/20 95/2
105/9 109/15 110/23
A77IN7 179/10 186/11
190/14 194/18
hats [1] 80/24
have [260]
haven't [3] 24/22
82/11 114/2
having [21] 7/23
20/19 25/1 26/16
28/19 32/5 37/9 39/2
45/1 72/14 77/2 78/2
85/17 87/15 124/4
172/21 173/21 189/5
he [72] 9/4 9/7 13/24
13/25 17/15 18/4 18/7I
18/7 18/9 19/7 19/7
20/2 21/8 21/18 21/20
21/23 22/2 29/24
31/19 38/2 55/5 70/25
71/2 71/4 73/25 75/2
77/6 77/7 77/12 79/15
82/16 82/16 83/16
84/9 84/20 84/23
85/17 85/19 85/21
88/5 88/7 88/8 88/9
88/10 88/16 88/19
89/8 89/25 93/10
110/9 110/10 115/20
115/23 115/25 131/19}
132/22 145/5 149/22
149/22 149/23 158/21
159/7 159/9 160/20
173/21 174/3 174/16
174/18 174/20 174/21
174/21 186/11
he'd [1] 45/4
he's [5] 18/10 79/14
82/9 90/3 90/25
head [4] 3/23 39/21
47/10 174/3
heading [2] 54/20
76/12
heads [1] 189/10
healthy [1] 184/4
hear [9] 1/3 47/17
92/12 125/4 125/10
130/12 136/6 162/7
185/16
harmed [1] 109/7
21/20 35/20 41/4 43/2
71/14 76/18 77/7 77/9
143/12 144/14 177/13}
144/13 164/11 164/24)
88/12 131/24 144/21
154/21 174/9 180/12
190/10
hearing [20] 25/1
56/5 61/6 61/7 66/24
99/13 111/7 121/10
122/13 132/21 136/8
197/5
hearings [9] 10/11
10/15 20/3 22/23
22/25 23/8 25/13
61/10 190/11
heart [1] 156/24
heatmap [6] 52/21
52/22 57/11 57/24
59/6 182/7
heavily [4] 9/9 33/17
38/4 73/4
heavy [1] 145/15
held [4] 13/9 48/12
TINT 185/3
Hello [1] 92/12
help [9] 40/18 91/19
169/22 187/16 192/2
192/8
helpful [6] 8/5 53/2
55/21 93/6 175/25
182/17
helpfully [1] 43/10
hence [1] 189/14
HENRY [10] 103/17
191/25 192/8 196/14
198/8 198/18 198/24
Hepburn [1] 186/15
her [24] 15/15 30/24
65/7 79/25 81/20 95/3
95/8 96/14 98/19
109/17 111/11 112/21
113/19 130/14 147/12)
147/15 148/4 158/19
160/19 165/21 166/24)
167/4 172/16 172/18
here [52] 23/7 25/15
39/13 43/10 43/18
49/12 50/6 54/4 57/20
60/4 60/6 60/8 60/11
61/14 66/4 67/14 68/5)
79/24 80/12 80/18
82/1 82/9 82/16 83/9
83/12 86/7 86/16
89/21 90/1 90/22
91/16 95/17 102/4
102/6 103/3 103/9
106/12 106/16 108/12)
109/13 118/13 118/20)
122/24 127/19 131/4
144/8 148/22 149/4
165/16 169/17 183/2
heard [9] 53/13 86/22
33/25 41/16 47/6 56/2
69/9 72/18 74/23 84/7
heightened [1] 17/15
101/24 111/24 132/24,
115/11 136/10 136/14)
186/11
Hi [1] 104/19
high [14] 6/19 19/1
52/9 52/12 52/13
56/22 58/2 58/10
58/19 70/18 79/6
79/22 95/20 147/24
highest [1] 76/15
highlights [1] 94/17
highly [3] 167/41
175/4 195/20
him [12] 22/2 31/17
42/13 45/2 76/24
82/19 88/9 88/11
148/4 150/1 173/24
174/10
him/her [1] 148/4
himself [6] 22/13
76/10 76/25 77/15
84/20 105/14
hindsight [22] 8/4
10/4 21/11 24/17
33/20 40/20 44/14
51/18 57/6 121/9
156/14 157/5 168/5
168/18 168/24 169/9
175/5 176/15 176/16
182/11 188/15 189/1
his [35] 9/5 13/22
14/2 14/2 17/19 18/6
19/25 20/11 20/19
76/16 84/14 85/7
85/25 88/7 88/12
88/13 88/18 90/11
90/24 92/24 99/9
132/17 133/1 148/8
148/19 149/7 149/18
192/8
historic [1] 70/22
historical [1] 194/21
‘orically [1] 6/9
history [5] 103/11
111/22
hm [9] 18/5 35/14
55/25 57/12 61/25
62/4 66/17 71/21
121/1
HODGE [14] 1/11
1/14 42/17 43/8 47/9
99/15 112/10 118/17
124/3 128/2 135/23
186/3 198/4 198/14
hold [2] 118/2 148/7
holding [3] 35/3 35/7
148/4
holds [1] 143/20
honest [6] 23/21 31/2
82/20 86/13 150/24
152/4
honestly [1] 39/19
highlighted [1] 46/19
20/22 21/6 21/20 22/8
149/21 149/24 186/12
103/11 106/15 108/15}
honour [1] 141/16
hook [1] 16/4
hope [3] 23/6 81/3
122/9
hopefully [2] 81/9
99/8
hoping [1] 57/15
34/14 34/14 35/11
38/18 40/8 47/7 56/5
64/12 67/1 67/2 67/7
67/11 67/17 77/17
84/2 99/20 103/24
104/3 104/9 104/14
117/4 117/7 119/13
121/5 127/8 155/3
156/6 159/22 167/12
167/17 174/16 177/2
196/6
Horizon's [1] 116/14
horrified [1] 74/6
hour [1] 99/5
house [5] 35/5 35/13
51/25 52/1 52/2
how [54] 5/9 5/21
5/22 8/20 26/13 27/17,
28/4 29/24 31/2 31/21
37/11 40/11 42/20
43/4 43/24 51/21 66/7
78/19 82/10 82/12
83/12 91/1 91/6 91/7
104/16 104/23 104/24}
105/15 117/18 119/17]
123/4 126/20 132/16
139/5 139/15 140/4
149/12 150/8 157/10
157/16 160/16 164/1
164/23 166/19 169/22,
170/3 171/5 181/6
185/1 186/2 189/13
191/4 191/5 192/19
Howe [2] 118/9 186/3
however [13] 2/18
19/7 51/8 70/18 77/12}
89/15 120/23 126/11
128/15 166/7 183/2
194/13 194/16
HSF [3] 14/7 103/3
111/21
HSF's [1] 103/12
Hudgells [1] 99/13
huge [2] 114/18
156/18
hugely [2] 8/5 36/9
Human [1] 190/11
hundreds [1] 145/19
l actually [6] 28/22
50/7 62/9 98/14 106/3I
Horizon [48] 7/3 9/14
10/2 10/3 10/14 19/10)
107/10 112/17 112/23)
ATTIT 177/25 184/18)
186/23 187/21 195/25}
113/24
l addressed [1]
177/18
l agree [4] 67/25
85/13 152/13 193/16
lalso [4] 26/11 39/2
60/6 72/23
lam [9] 20/25 21/14
80/7 101/13 110/17
117/7 137/25 141/22
155/20
l apprehend [1]
110/4
l approached [1]
132/16
lask [6] 1/15 103/18
137/10 156/11 157/10)
195/22
lasked [1] 127/20
lassume [2] 21/10
147/17
l assumed [1] 144/17)
I believe [16] 51/3
57/17 73/6 96/5 99/1
128/13 137/1 139/23
149/20 158/20 175/25}
176/23 181/1 184/13
192/3 195/14
Ican [10] 1/4 91/18
108/3 115/23 115/24
121/6 126/15 135/11
162/8 192/24
I can't [14] 37/2
39/20 41/25 48/8
48/18 102/19 106/13
112/5 116/5 116/21
149/10 171/16 172/20)
182/5
I cannot [2] 124/18
147/18
I challenged [1]
7414
I considered [1]
119/1
I could [10] 16/24
33/21 34/21 47/10
97/5 105/20 113/24
123/5 124/13 162/2
I couldn't [5] 15/13
102/19 156/22 195/2
195/2
I did [10] 8/11 10/3
10/8 15/15 25/22 36/8}
36/9 91/15 141/13
174/25
I didn't [20] 7/17
25/11 25/25 26/1
33/23 37/4 37/4 44/7
45/13 46/20 50/7
80/16 82/20 86/13
97/4 111/7 113/22
114/15 121/6 160/22
Ido [5] 89/12 93/25
137/15 142/15 159/15}
(63) harmed - 1 do
I don't [51] 6/1 23/21
27/22 27/25 30/25
39/12 43/10 44/4 44/5
44/14 44/23 44/24
52/22 54/2 55/11
58/16 58/20 59/9
59/16 61/4 62/15
66/13 67/12 67/13
67/15 69/14 80/16
82/5 83/18 86/22
90/16 91/4 95/2 97/2
97/4 98/20 98/20
102/2 112/5 113/3
113/5 117/15 123/2
123/16 124/8 132/13
132/15 135/23 160/3
180/24 191/23
I doubt [1] 23/21
l explain [2] 128/18
129/16
l explained [1] 133/5
l expressed [1] 96/6
I feel [1] 30/15
I felt [15] 15/1 15/2
24/8 24/9 30/15 36/21
86/14 97/14 97/15
114/15 117/9 123/4
123/5 132/10 133/11
Il formed [1] 133/4
I get [1] 94/3
I got [7] 26/1 37/8
39/19 41/12 41/25
106/9 135/4
I had [29] 8/22 9/22
13/25 23/23 27/3
27/25 67/5 67/8 67/25
86/21 87/15 95/16
97/6 97/14 97/15
108/15 111/4 119/15
127/21 129/11 131/2
131/2 131/24 133/10
147/14 171/22 172/9
174/8 176/11
I hadn't [4] 40/16
108/8 119/14 123/3
Ihand [1] 97/17
Ihave [14] 20/24
26/14 42/10 45/24
79/19 86/19 86/20
89/9 95/14 104/21
105/9 108/3 117/24
127/25
I haven't [3] 24/22
82/11 114/2
I honestly [1] 39/19
I hope [2] 81/3 122/9
lindicated [1] 145/12
linfer [1] 21/3
linherited [1] 146/21
interacted [1]
147/14
I joined [2] 11/16
12/22
I just [4] 45/19 93/22
129/24 134/24
I knew [3] 94/6 112/6
113/3
I know [2] 9/3 54/2
I known [1] 132/18
led [1] 12/14
Heft [4] 127/12
I looked [1] 48/9
I may [3] 122/18
128/1 194/16
I mean [54] 6/1 9/11
9/22 10/23 11/10
15/23 24/15 24/16
25/11 26/10 33/20
34/7 35/18 35/25 36/5)
36/6 40/10 40/12
40/15 43/10 43/22
46/20 51/15 53/10
54/17 55/20 58/20
60/7 63/10 65/23
67/12 69/7 69/10 74/6
75/4 80/23 83/8 83/9
86/13 86/19 86/24
102/4 104/7 108/9
108/12 109/4 111/4
125/24 126/2 132/13
132/21 133/20 149/4
156/23
I mentioned [2] 38/2
84/16
I might [3] 61/13
61/13 184/21
I moved [1] 44/6
Ineed [3] 79/4
124/20 135/24
I needed [5] 12/10
28/2 28/2 124/12
132/15
I never [1] 183/19
lomit [1] 193/22
lor [1] 58/20
I put [2] 123/10 141/7
I raised [2] 31/16
122/2
read [2] 8/3 8/11
Ireally [4] 34/1 54/18
95/17 95/19
recall [9] 13/13
16/22 74/3 98/15
98/19 131/15 131/18
173/20 173/23
received [1] 28/23
Ireferred [1] 131/13
I regret [1] 190/12
I remain [1] 24/21
I remember [4] 9/23
31/16 42/11 74/5
l repeat [2] 60/3
191/18
I rephrase [1] 115/19
I represent [2] 118/6
125/12
I respectfully [1]
191/18
I said [13] 29/18
48/21 55/3 60/3 68/1
77/24 80/22 117/15
129/12 133/8 154/14
164/15 170/6
I saw [2] 16/25 25/15
I say [6] 30/15 42/23
44/23 45/14 95/14
110/2
I see [3] 39/18 115/8
136/2
I seem [1] 127/18
I sent [2] 106/19
110/2
I shall [1] 186/6
I shared [1] 79/20
I should [8] 35/3
89/10 96/19 121/9
123/17 157/21 173/20
182/16
I shouldn't [2] 86/11
88/22
I spent [1] 105/23
I started [1] 160/21
I suggest [4] 105/12
105/15 110/14 110/16
I suppose [2] 113/16
183/25
I take [5] 118/11
124/17 136/21 196/24
197/1
I talk [1] 31/17
I think [219]
I thought [13] 15/23
25/23 27/25 28/1
33/22 72/16 74/12
74/18 75/6 75/7
123/21 123/24 132/11
Ito [1] 117/6
I took [10] 5/7 7/22
13/19 41/24 82/14
82/22 82/24 83/2
116/3 117/4
I tried [3] 30/23 174/6
174/10
I understand [11]
1/22 2/1 47/8 94/13
95/9 124/16 130/22
136/22 141/24 142/25
186/13
I understood [3]
29/19 118/21 120/18
lutterly [1] 121/20
I voted [1] 90/9
I want [7] 106/21
107/7 112/14 142/20
155/2 173/14 187/18
I wanted [1] 106/12
Iwas [62] 7/20 7/22
10/24 11/10 12/9 17/8
25/22 25/24 26/16
27/6 27/25 29/23
34/19 37/9 37/10
37/11 39/12 39/13
40/13 46/23 50/2 53/3)
63/18 64/1 65/21 66/3
66/3 66/5 72/10 80/21
83/12 86/12 90/7 94/5)
105/20 106/2 106/10
106/12 108/4 108/8
108/8 108/9 109/25
111/3 1141/7 113/7
119/17 121/10 122/6
130/24 132/10 132/13)
132/21 144/20 161/22}
167/14 169/12 169/13}
173/13 192/22 196/1
196/8
I wasn't [4] 6/2 36/22
111/2 183/19
Iwill [2] 117/25 118/2
I won't [1] 135/23
I wonder [1] 16/16
I worked [2] 14/1
145/8
I would [17] 8/21
16/25 45/5 58/16
83/18 83/21 84/8 97/8
114/3 127/22 128/3
155/1 184/4 184/10
187/9 187/23 189/23
I'd [29] 11/4 17/9
23/4 39/19 41/10
47/20 62/10 66/21
66/22 68/3 68/6 69/20)
74/19 88/8 88/10
95/20 97/9 97/9 97/16
106/5 107/24 110/24
119/14 122/7 131/6
133/7 133/9 162/3
170/17
Mil [11] 1/7 45/25
52/25 84/18 90/18
123/17 135/24 138/1
146/4 177/13 180/20
I'm [61] 3/15 5/21 6/9
9/11 24/24 38/15
38/21 39/12 39/18
42/15 43/9 43/9 45/22
49/10 50/13 57/15
65/23 66/1 68/9 68/10
69/14 81/18 82/9
83/11 94/13 94/14
94/16 94/16 101/7
104/16 104/17 107/12
107/25 108/17 108/21
110/17 110/18 117/8
118/4 118/8 123/16
123/21 124/7 124/8
124/21 125/13 127/18}
127/20 135/20 146/3
152/8 157/14 157/25
158/12 177/3 184/18
188/25 189/1 196/13
196/16 196/17
I've [17] 28/22 30/20
36/16 45/17 50/13
52/4 53/22 57/15
58/22 91/3 105/1
105/4 116/21 117/20
124/19 134/16 171/17
idea [9] 39/10 42/2
50/13 82/20 86/17
87/3 87/15 108/3
194/18
ideal [1] 164/5
identifiable [1] 179/6
identified [22] 26/4
26/8 30/7 35/10 35/16I
40/4 40/23 44/10 45/3)
45/12 46/15 49/16
53/4 53/8 61/24 66/18
66/22 66/22 69/17
145/11 178/20 182/21
identifies [1] 54/10
identify [6] 11/24
40/24 56/24 59/10
142/8 142/12
identifying [1]
146/17
ie [8] 38/25 43/2
82/23 84/24 95/1
95/13 175/14 184/1
ie flag [1] 84/24
ie if [1] 184/1
[1] 82/23
ie it [1] 38/25
ie the [1] 43/2
ie was [1] 175/14
if [173] 6/13 12/10
13/13 15/15 16/16
16/23 18/1 19/14
25/20 26/9 29/25
31/17 34/6 34/10
34/12 34/13 34/22
36/14 40/10 40/25
42/4 42/6 42/18 42/24
42/24 43/19 43/22
43/23 43/23 44/1 45/2
45/4 45/4 45/22 46/13)
49/8 49/10 49/12
49/21 50/14 51/6
51/24 52/7 52/19 53/1
54/17 54/19 56/22
57/17 57/23 59/11
60/14 61/15 66/9
67/13 68/3 68/10 70/2I
70/10 72/21 74/3 74/9I
74/16 76/3 77/12
77/16 78/23 79/13
81/10 82/6 83/1 83/15]
84/8 85/18 85/22
85/25 86/12 86/21
89/18 90/8 90/16
90/18 91/17 91/17
91/25 92/25 93/8
94/18 94/24 95/3
95/16 96/2 97/5 98/22)
99/2 99/7 99/16 99/18
100/10 100/11 100/12!
(64) I don't - if
if... [72] 105/2 105/17
105/20 106/16 107/5
108/9 110/19 112/5
112/6 113/5 113/24
115/19 116/11 116/24}
116/25 117/11 118/7
122/3 122/11 122/18
124/11 124/12 127/21
128/1 134/1 135/11
140/12 141/20 143/8
143/22 147/22 149/21
150/2 150/8 150/22
151/13 155/13 155/14}
155/25 159/4 159/8
159/22 162/2 163/4
163/4 165/11 165/16
167/23 168/3 171/9
175/10 176/16 177/22
178/8 178/12 178/14
179/24 180/12 181/20)
183/1 184/1 185/6
187/20 188/23 191/6
191/10 191/13 192/24}
193/22 194/16 194/24}
195/13
illegally [2] 50/17
51/15
immediate [2] 98/15
108/22
immediately [1] 4/8
impact [17] 9/23
49/15 51/5 52/3 52/12)
52/15 52/17 53/7
59/19 60/17 67/9
83/23 145/17 147/6
168/9 168/10 190/11
impacts [1] 34/11
impart [1] 174/6
imperative [1]
133/11
implement [1] 126/8
implementation [1]
148/5
implemented [4]
22/19 35/24 177/18
182/6
implementing [1]
27/8
implication [1] 60/11
implications [3]
14/11 79/7 180/10
implied [4] 39/23
39/25 47/1 122/8
importance [2]
181/13 191/21
important [24] 11/19
13/15 14/3 14/22
30/12 53/1 56/20
61/10 61/14 63/23
67/3 74/4 75/13 93/22
101/24 111/9 112/2
122/5 131/21 142/9
144/2 149/25 166/1
169/20
importantly [1] 68/5
imposed [2] 119/11
166/12
impossible [2] 81/6
94/15
impression [4] 45/24
45/24 114/17 183/19
impressions [1]
41/25
improbable [1]
194/17
improper [2] 19/22
21/2
improve [2] 144/21
185/1
improvement [2]
114/7 181/23
improving [1] 145/2
impugn [1] 109/21
impugned [2] 19/21
21/1
impugning [1] 20/11
inability [1] 72/12
inaccurate [1] 62/6
inadequacies [1]
72/15
inadequate [1] 24/9
inadequately [1]
184/23
inadmissible [1]
18/18
inappropriate [4]
15/19 60/7 78/14
87/19
inappropriately [1]
50/17
incident [1] 100/5
include [3] 143/14
143/25 177/23
included [1] 7/6
includes [1] 110/25
including [20] 14/7
19/17 20/4 43/14 48/3
54/12 60/20 72/11
73/1 79/17 83/23
100/1 103/19 107/19
109/22 126/9 153/11
155/8 167/17 186/24
inconsistencies [2]
109/24 110/1
incorrect [1] 141/1
increase [4] 56/14
95/24 96/7 96/19
indeed [6] 69/1 147/4
156/17 160/3 170/9
190/15
indefensible [2] 16/9
122/25
indefinitely [1] 124/9
independence [2]
80/1 81/21
independent [7]
73/17 153/10 153/22
162/16 163/19 179/20
191/3
independently [1]
133/14
indicated [1] 145/12
indicates [1] 70/19
indication [2] 99/4
175/13
individual [7] 48/25
106/7 111/6 113/21
116/9 157/19 172/25
individuals [5] 48/19
70/7 135/6 135/10
179/4
induction [1] 7/21
Industrial [1] 194/4
industry [1] 182/7
infer [1] 21/3
inferences [1] 84/6
influence [1] 21/7
inform [3] 12/12
29/10 48/21
information [35] 12/5I
12/16 12/18 12/25
29/4 29/15 29/19
30/13 44/12 44/16
50/5 50/5 50/7 55/23
56/21 61/20 63/18
63/20 64/15 98/2
98/11 98/19 106/17
111/6 128/10 131/3
156/1 159/25 166/20
176/19 177/21 184/12
184/14 191/13 191/19}
informed [22] 2/4
6/15 8/4 12/13 25/10
27/11 48/19 57/4 64/1
65/25 77/2 80/2 95/23,
126/12 128/18 150/7
150/18 151/4 151/6
155/6 159/7 187/5
inherent [1] 56/14
inherited [3] 50/8
51/1 146/21
initial [10] 15/14
20/22 21/20 28/12
100/17 102/9 102/15
105/1 107/13 126/15
initially [3] 12/2
62/18 101/4
initiate [1] 133/2
initiative [1] 101/4
innocent [1] 194/21
Innovation [2]
148/16 153/5
inns [1] 83/19
input [7] 13/25 36/9
36/10 48/6 50/7 63/8
83/12
inputted [2] 33/11
50/5
inquiries [1] 175/6
inquiry [24] 1/15 1/16
26/23 27/2 27/7 27/24
28/23 35/1 53/13
124/20 136/16 137/23}
142/1 154/21 155/6
155/9 165/12 168/20
175/5 177/13 185/16
190/8 192/16 196/19
Inquiry's [1] 137/24
inside [2] 192/16
192/18
insight [1] 65/13
insistence [3] 113/8
113/9 113/18
instance [1] 157/1
instead [2] 62/11
95/5
instinct [1] 86/15
instituted [1] 170/20
institution [1] 138/20
institutions [2] 138/5
170/19
instructed [4] 118/8
167/6 173/22 187/6
instruction [1]
155/20
instructions [2]
97/15 110/11
instrumental [1]
133/17
insufficient [1] 31/11
insulting [1] 108/1
integral [1] 56/9
integrated [1] 6/8
integrity [5] 56/5
64/11 80/1 81/21
178/12
intelligent [2] 150/6
151/6
intended [3] 43/6
73/14 86/7
intends [2] 150/6
150/9
intensity [2] 141/14
161/23
intent [2] 38/20 86/6
intention [1] 95/14
interact [2] 31/21
83/13
interacted [1] 147/14
interaction [1] 133/7
interactions [5]
25/16 26/11 32/14
32/17 32/23
interest [16] 32/3
59/25 65/1 81/19 82/3)
89/13 93/21 129/17
163/11 169/6 169/8
169/11 169/14 169/21
170/1 170/2
interested [3] 31/2
101/8 128/20
interesting [2] 63/24
135/19
interfering [1] 134/23
Interim [3] 155/10
173/5 176/12
intermittent [1]
116/16
internal [3] 35/9 73/1
185/13
internally [5] 26/6
26/7 45/8 168/20
194/7
interpret [3] 95/23
121/6 127/2
interpretation [1]
120/2
interpreted [6] 76/18
80/23 91/7 91/8 121/9
126/22
intervened [1] 196/5
intervention [3]
130/1 132/7 133/1
interventions [1]
150/17
intimating [1] 19/18
into [30] 5/13 5/17
7/21 12/7 24/25 25/9
26/24 27/24 28/3
28/12 33/11 36/25
43/20 48/6 48/18
48/25 49/3 54/18 59/3
61/12 65/14 81/12
103/5 135/20 140/4
162/21 163/13 167/20}
180/8 183/11
intractable [1] 7/2
introduced [2]
112/17 112/23
introduction [1] 10/7
introductory [1]
159/5
intrusive [1] 37/11
invented [1] 108/19
investigate [1]
185/23
investigated [2] 40/1
174/15
investigating [1]
173/12
investigation [4] 7/6
126/24 167/20 168/16)
investigations [1]
120/13
investment [6] 3/20
145/17 145/21 145/24)
154/16 194/5
investments [3] 3/17
145/22 183/13
invited [1] 22/11
involved [34] 5/2
5/12 14/7 14/18 24/5
26/23 27/9 33/18
35/25 38/4 50/3 54/2
54/3 63/7 80/4 80/14
80/19 81/16 81/23
81/25 82/18 83/4 89/1
122/7 127/8 129/2
(65) if... - involved
involved... [8] 129/12
145/5 154/14 169/21
177/7 185/19 186/14
188/5
involvement [7]
78/10 80/11 89/3
93/21 112/20 173/11
186/20
involving [1] 35/24
IPO [2] 163/9 194/2
Ireland [8] 138/18
141/6 159/9 159/12
159/14 159/21 160/8
160/12
irregularity [1] 76/22
irrelevant [1] 21/16
irrespective [1]
114/3
is [386]
isn't [7] 55/21 95/4
98/8 113/20 152/23
191/6 191/12
issue [50] 16/23
22/15 24/7 24/20
25/23 35/21 36/1 37/8
45/14 53/12 55/15
55/17 63/2 67/10
67/17 67/19 69/19
69/19 79/19 79/22
82/6 82/6 82/12 103/4
117/4 119/7 123/16
128/4 154/17 156/3
158/12 159/17 159/22
161/24 168/16 170/24}
176/7 176/14 177/8
178/9 185/3 185/4
185/11 187/22 188/5
188/10 188/20 188/24}
189/4 191/18
issued [1] 126/23
issues [138] 7/3 9/20
10/1 10/4 10/15 11/6
13/6 13/12 17/2 19/4
19/6 19/9 21/8 21/14
26/16 28/6 32/3 32/21
33/24 34/1 34/9 36/15)
37/9 42/16 42/19
42/25 43/1 44/8 45/21
46/1 46/1 46/14 46/15
46/22 47/6 47/7 58/7
63/14 66/24 67/1 67/2
67/2 67/4 67/7 67/8
67/11 67/14 67/22
69/21 69/24 70/16
71/24 72/17 72/20
73/10 77/7 98/16
99/20 103/21 103/24
104/3 104/8 104/9
104/14 106/4 106/8
111/25 114/22 116/13}
116/23 117/7 118/10
123/12 126/6 126/8
126/25 127/1 127/4
129/18 131/8 131/10
132/4 132/14 132/19
132/25 133/6 135/13
135/16 143/17 145/17]
147/10 147/12 149/23
149/24 156/5 156/15
156/18 157/1 157/19
157/23 157/23 157/25I
158/2 158/11 158/13
158/17 158/23 160/10)
167/16 167/23 168/3
169/3 169/17 169/20
169/23 170/4 170/6
171/20 174/12 174/14)
175/6 176/1 181/7
182/19 182/24 183/8
183/17 183/20 183/24)
184/19 185/1 185/2
185/14 187/9 187/20
188/16 190/4 190/16
it [595]
it's [111] 1/13 2/2
5/11 6/3 6/4 6/4 6/4
6/8 6/12 10/25 12/6
28/14 28/22 31/15
31/17 31/25 35/1
35/19 36/14 37/23
37/24 38/8 43/3 50/21
51/16 51/18 52/3
52/13 53/1 53/22
54/17 55/17 55/20
56/19 57/1 57/20 59/8
59/8 59/9 59/14 61/2
61/4 61/10 61/10
65/17 66/14 68/17
68/17 69/5 69/5 69/8
69/8 69/14 70/10
70/16 72I7 79/5 84/14
86/24 87/12 88/15
90/17 91/1 91/5 91/6
91/23 93/2 93/9 96/13
99/17 99/23 100/10
101/15 104/18 107/25]
109/14 110/5 110/6
114/47 1121 112/14
114/5 115/11 116/2
116/2 116/12 117/12
122/5 122/22 123/17
123/21 127/13 127/14)
128/7 142/9 144/2
147/22 159/3 162/9
1741/8 175/4 177/10
177/11 177/16 181/10)
182/15 184/2 188/15
189/13 192/3 193/19
item [3] 72/14 163/5
183/9
items [2] 53/10 72/13
its [43] 5/5 5/10
13/17 16/8 16/19
19/11 19/21 27/17
28/12 33/25 33/25
35/5 35/5 35/7 39/10
39/13 39/14 46/20
55/16 67/21 68/15
75/19 93/14 120/23
121/4 121/13 126/20
142/13 142/21 145/9
150/23 151/19 159/24
159/25 161/1 161/3
161/6 164/9 164/15
166/20 168/6 175/3
179/22
itself [19] 8/13 8/25
15/20 22/4 28/23
67/22 74/23 75/9
77/25 83/10 102/5
145/10 150/16 151/7
152/11 163/14 164/23
169/7 194/8
qa
JACOBS [2] 186/9
198/22
Jane [18] 13/10
15/13 17/9 17/24 18/2
23/4 36/10 70/4 74/5
74/14 76/5 78/4
119/16 120/20 125/24)
126/1 133/7 135/14
Jane's [2] 13/19
79/21
January [7] 53/16
53/21 59/3 63/5 64/7
64/23 107/3
Jean [1] 186/12
jerk [1] 75/16
Jo [1] 105/5
job [3] 97/8 171/25
172/4
joined [10] 3/16 4/11
11/16 12/22 28/21
29/15 31/11 35/15
115/13 119/22
joining [4] 4/2 4/5
6/14 26/22
Jones [1] 186/4
Josh [6] 18/15 33/16
105/12 106/19 110/3
110/23
Joshua [4] 2/10 18/6
37/23 104/18
journalist [1] 65/3
journey [1] 122/6
judge [19] 10/17
18/17 18/23 18/25
19/16 20/25 21/3 39/6
50/17 70/21 70/24
72/11 76/10 76/15
76/18 77/4 77/15
78/11 87/4
judge's [4] 20/6 20/8
38/10 72/2
judged [2] 146/12
191/4
judgement [1] 191/3
judgements [1]
191/20
Judges [1] 21/15
judgment [62] 18/19
20/16 20/19 20/24
21/21 21/23 22/13
32/3 42/25 43/1 44/8
58/25 61/8 63/5 64/5
64/10 64/24 65/11
67/11 69/21 70/15
71/9 71/17 71/19
73/10 73/20 75/1 75/2,
75/9 75/18 75/24
76/16 77/25 79/2
98/16 99/19 103/21
103/25 104/2 104/3
104/8 104/14 106/4
106/8 114/22 116/23
117/7 125/23 126/8
127/1 127/4 129/18
131/8 131/10 131/15
131/16 132/4 132/14
132/19 133/6 168/9
184/1
judgment' [1] 64/9
judgments [1] 40/18
judiciary [5] 78/17
80/1 81/22 82/24
87/21
July [11] 1/1 13/13
55/7 119/15 122/9
128/25 167/8 168/13
173/6 181/17 197/6
jumping [1] 141/12
June [16] 1/19 12/20
12/24 49/3 49/5 49/6
49/24 54/14 54/17
55/24 56/17 59/19
60/15 62/19 65/19
167/8
June 2018 [1] 12/24
June/July [1] 167/8
junior [1] 38/3
just [63] 1/5 1/7
13/19 13/22 14/6 15/6}
16/5 23/11 24/2 28/19)
30/3 39/9 43/11 43/13
45/19 47/7 49/12
51/23 54/7 54/8 65/24
70/5 77/24 80/9 85/11
88/22 90/11 91/5
92/15 93/3 93/6 93/22,
99/18 100/12 100/22
101/19 102/12 102/17,
103/1 104/18 107/21
108/19 108/25 109/1
109/3 116/21 124/9
124/21 129/24 134/19
134/24 135/24 137/2
137/20 145/13 147/15)
155/25 156/20 165/4
171/2 171/18 176/10
192/8
justice [11] 17/15
18/17 23/10 34/13
44/3 45/10 67/22 73/4
75/5 76/23 125/23
K
Keen [1] 130/17
keep [6] 12/12 54/22
56/7 64/13 64/25
133/25
keeping [2] 62/20
128/17
keeps [1] 170/25
Kelly [8] 55/6 55/12
98/7 98/18 130/3
130/6 130/10 131/3
KELs [1] 99/19
Ken [2] 101/6 101/8
kept [1] 24/16
key [29] 8/3 8/8 12/14
36/11 48/24 54/23
56/8 62/21 64/14
69/17 69/19 69/19
71/2 71/5 82/21 93/23}
95/11 108/12 146/13
147/12 147/24 149/23)
150/12 150/21 177/14)
181/25 182/24 183/8
194/3
Kilgarriff [6] 81/11
83/16 84/11 84/23
85/10 85/12
Kilgarriff's [1] 85/2
killed [1] 194/25
kind [5] 34/17 68/1
126/25 135/4 174/11
knee [1] 75/16
knew [10] 24/2 33/18
88/10 94/6 101/15
112/5 112/6 112/8
113/3 177/4
know [139] 1/14 7/22
8/15 8/17 8/20 9/2 9/3}
9/11 10/3 10/14 10/17
12/21 14/2 14/13 15/2)
15/15 15/19 15/25
24/8 24/21 24/24 25/3I
25/22 25/24 26/11
26/19 28/2 29/22
29/23 30/22 30/25
31/3 31/6 31/17 32/1
32/7 32/19 33/5 33/19I
33/21 34/6 34/8 34/18}
35/19 36/12 36/16
36/23 37/1 37/10
37/11 40/16 40/19
42/7 42/11 43/23
45/12 47/3 48/10
48/20 50/1 50/12
51/16 53/7 53/8 53/11
54/2 55/18 55/20 57/5I
59/7 59/15 60/2 61/8
61/10 61/12 61/15
62/10 62/12 62/13
62/15 63/23 65/23
66/3 66/4 66/7 66/9
(66) involved... - know
K
67/17 68/7 68/17
68/22 69/8 74/19
82/10 82/22 86/2
86/14 86/18 88/16
91/6 91/17 98/20
101/8 101/18 102/7
105/2 105/15 107/1
107/5 108/11 109/9
109/19 112/5 113/5
116/4 120/1 120/13
122/3 122/11 122/16
132/22 132/23 133/21
133/25 135/3 135/15
166/17 196/9
knowing [1] 69/1
knowledge [14] 3/12
33/7 33/11 70/6
103/10 103/11 137/20
147/4 147/5 155/7
173/15 173/18 174/7
176/12
known [4] 101/16
117/11 132/18 194/25}
KNUT [3] 1/10 1/13
198/2
L
lack [5] 30/21 63/13
97/24 103/10 146/15
Lambert [2] 79/12
79/15
language [5] 9/12
40/13 51/17 84/8
114/9
laptop [1] 123/15
large [1] 118/7
largely [1] 129/22
last [13] 18/19 39/6
76/14 83/3 104/24
109/12 112/24 123/9
123/13 138/9 148/10
169/19 193/21
late [12] 5/8 17/5
18/19 23/6 25/11
54/14 56/17 64/7
97/22 99/19 112/19
134/11
later [26] 7/17 11/12
19/13 26/21 55/13
56/19 57/8 57/10
71/10 75/22 79/8 81/9
81/13 82/17 84/18
90/13 94/21 95/10
96/15 99/8 103/6
134/8 144/22 155/21
157/20 172/18
launch [2] 71/16
168/15
know... [53] 66/25
74/22 78/1 80/20 81/2
90/2 90/8 90/11 90/16
122/18 123/22 129/14)
law [6] 14/12 19/8
38/16 38/20 76/19
185/18
18/11 18/13 38/7
65/23 66/1 117/8
lawyers [17] 8/16
16/8 30/1 46/4 46/5
62/14 91/24 101/5
101/15 107/6 109/2
110/21 117/13
lay [3] 113/6 154/1
168/24
lead [7] 17/18 70/24
105/25 106/2 106/3
106/7 128/16
leader [2] 157/20
175/24
leadership [1] 4/8
leading [1] 4/11
leap [1] 59/10
learn [1] 73/2
learned [3] 27/24
28/16 71/23
11/10 31/25 35/23
119/23 120/5 167/4
learnings [1] 27/7
least [13] 7/13 45/13
66/6 67/2 77/8 77/10
77/18 82/8 100/16
101/22 106/5 117/12
159/16
leave [4] 107/10
leaving [2] 33/6
130/12
led [7] 12/14 36/25
180/17 189/5
ledger [1] 179/6
ledgers [1] 179/5
left [7] 5/8 49/14 52/1
55/5 74/11 127/12
133/10
left-hand [2] 49/14
52/1
legal [68] 12/5 13/25
17/6 19/5 21/7 23/8
35/5 35/13 35/24 45/7
46/3 51/20 54/11
54/16 54/24 56/8
59/21 60/20 60/24
61/3 62/3 62/22 62/25)
63/2 63/8 64/17 64/19
65/7 72/16 73/7 73/13
73/15 74/19 75/18
78/1 79/18 79/23
82/13 83/12 84/3
87/15 88/21 89/9
89/22 91/16 92/23
94/5 95/2 95/25 97/17)
99/1 111/10 113/4
lawyer [8] 18/8 18/10
13/24 14/6 14/7 14/15
learning [8] 7/20 10/7I
113/15 124/15 125/25)
126/18 156/21 172/18)
117/16 122/4 122/10
126/2 129/1 133/3
146/7 146/25 147/2
legally [1] 64/15
length [8] 87/20
148/11 148/24 149/12
154/23 183/3 183/4
187/17
lengthening [1]
180/16
lengthier [1] 64/4
less [1] 139/18
lessons [2] 27/24
28/16
let [9] 16/3 43/5
105/2 149/15 157/14
183/15 190/19 190/20}
192/4
let's [16] 90/9 97/5
99/12 106/13 106/16
108/22 110/4 110/19
141/19 151/13 151/19}
159/2 160/18 173/4
177/10 192/6
letter [3] 147/21
147/22 192/4
letting [1] 107/21
level [27] 6/19 25/17
31/7 31/8 31/11 32/9
56/22 58/10 58/14
58/19 70/18 79/23
128/4 129/3 144/12
144/16 147/25 149/24]
161/1 161/7 167/3
173/7 175/5 176/21
181/2 182/22 184/11
levelled [1] 19/20
levels [4] 146/2
161/4 182/25 184/20
lever [1] 34/19
levers [1] 25/14
liabilities [1] 130/11
liability [21] 15/4
15/21 16/9 16/20
16/21 25/23 37/17
38/16 46/19 47/2
67/21 118/15 118/21
119/9 119/11 119/16
119/23 120/18 120/25}
121/20 122/17
liable [2] 40/2 118/23
life [1] 163/18
light [3] 72/24 143/15
145/15
like [46] 1/23 2/7
2/21 3/7 6/12 6/13
6/13 12/11 26/10
30/18 31/24 32/14
32/20 34/9 34/22
36/14 42/4 42/18
44/23 47/20 51/17
59/4 61/15 69/20
133/10 133/12 135/14
149/22 185/13 192/14
74/16 82/6 83/1 88/5
88/19 97/16 99/2
107/24 110/24 118/7
122/3 122/11 123/17
124/6 126/23 128/3
131/6 149/21 183/17
likelihood [1] 46/5
likely [7] 22/20 51/7
59/21 80/22 96/6
127/7 180/19
Limb [1] 103/6
Limitations [1]
177/15,
limited [26] 58/13
103/8 142/14 146/24
147/8 148/11 148/18
153/8 156/24 159/20
161/2 162/15 162/22
163/2 163/14 164/18
165/9 165/18 166/1
166/21 170/2 171/4
176/8 178/2 179/7
184/15
Limited's [1] 160/25
line [5] 2/3 45/18
107/3 162/21 195/10
lines [4] 89/17
100/13 109/12 118/24}
link [5] 37/16 42/23
53/23 53/24 67/21
linked [1] 58/6
Linklaters [2] 157/6
195/14
list [3] 38/7 110/23
146/1
listed [3] 53/10 155/8
159/3
listened [1] 180/13
listing [4] 193/10
litigation [111] 6/16
6/20 8/5 8/16 10/2
10/5 10/8 11/5 11/10
11/15 11/21 11/23
12/9 13/2 13/12 13/16}
14/1 15/3 16/14 17/15)
17/20 17/21 19/19
21/4 21/7 22/3 22/8
23/19 23/23 24/14
25/9 25/18 26/5 26/9
26/18 27/8 27/12
27/18 30/8 30/11
30/14 31/5 32/21 33/8
33/18 34/12 35/17
35/18 38/6 40/6 40/17)
40/25 41/17 42/16
46/4 46/9 49/11 49/22)
49/24 50/3 50/10
50/16 52/9 52/14
52/18 53/15 54/12
57/16 58/8 58/9 58/18)
59/2 59/13 60/1 61/21
62/1 65/18 66/7 67/1
68/16 69/3 69/13 72/4
184/10 190/12 192/25}
73/8 73/13 84/2 93/20
97/20 98/13 114/21
119/3 120/9 125/20
128/5 128/11 128/17
128/19 128/21 129/2
129/5 129/14 130/13
130/17 132/5 132/9
132/10 132/16 133/18}
134/7 134/8 134/10
little [14] 8/6 19/14
21/3 21/14 26/21
41/21 77/14 83/9
84/18 97/20 105/9
105/13 106/4 110/20
Lloyd's [2] 139/19
140/1
locate [1] 92/19
logical [2] 42/22
46/20
long [7] 15/4 42/10
118/10 133/25 134/1
164/1 186/2
longer [1] 59/14
look [52] 16/16 17/23
28/10 28/17 29/25
34/24 37/21 49/2
50/14 53/2 54/19 57/8
57/23 70/1 72/6 76/2
78/21 79/11 84/19
87/11 87/25 89/5 91/1
93/3 98/22 108/5
122/23 128/5 130/1
141/19 142/20 142/21
143/9 150/2 155/2
155/3 159/2 160/23
165/8 165/16 173/14
177/10 177/14 180/20)
181/16 182/14 184/24I
185/23 186/6 191/10
192/5 195/13
looked [8] 48/9 77/7
88/22 104/9 105/4
114/2 121/4 145/14
looking [8] 15/5
68/24 69/10 90/17
119/19 145/21 175/4
183/12
Lord [6] 76/13 77/5
79/21 88/9 88/11
88/13
Lord Grabiner's [1]
88/11
Lord Neuberger [1]
76/13
Lord Neuberger's [2]
77/5 88/9
lose [2] 40/25 67/7
loses [1] 15/16
losing [1] 62/12
loss [1] 195/15
losses [5] 9/17 15/24
40/1 116/17 118/23
lost [7] 34/6 34/12
61/2 62/5 70/20 74/19
(67) know... - lost
L
lot [14] 15/5 23/24
25/13 25/25 30/17
50/8 63/19 75/5 90/2
170/17 184/23
lots [1] 68/18
Lovegrove [1]
157/18
low [1] 195/16
lump [1] 104/21
144/22
MacLeod [15] 13/10
17/9 17/24 18/3 19/15}
70/4 74/5 76/5 78/4
119/16 120/20 125/24}
126/1 133/7 135/14
MacLeod's [1] 15/13
made [34] 7/5 20/2
21/1 21/17 21/25
26/22 34/1 34/25
38/24 41/14 41/15
60/8 69/6 75/6 76/21
87/18 106/5 114/3
134/3 135/10 136/22
137/20 150/1 156/8
156/13 173/9 173/11
178/2 185/18 188/2
193/5
magically [1] 99/23
Magnox [6] 26/24
27/7 27/24 28/13
29/14 34/25
Magnox/RSRL [1]
28/13
Mail [26] 65/1 112/23
113/1 113/4 144/4
145/16 145/18 148/18
152/19 153/7 153/16
157/25 158/2 158/11
158/13 158/19 159/8
159/11 161/1 161/16
162/16 162/24 162/25}
163/5 163/5 164/8
main [10] 8/8 9/5
23/22 26/19 29/18
48/20 50/2 56/2 56/4
157/25
mainly [1] 58/5
maintain [4] 88/19
93/14 93/24 119/2
maintained [4] 47/21
48/3 61/23 158/7
maintaining [1] 63/1
Majesty's [3] 65/8
79/25 81/20
major [13] 27/8 35/10
lost... [1] 133/9
104/11 105/24 156/15)
lunch [2] 99/8 127/24
MacGregor [1]
128/15 132/18 132/20)
35/16 36/4 36/20
72/18 141/12 144/19
158/15 161/2 161/3
164/9 170/24
make [25] 1/23 2/7
15/18 21/15 27/10
28/6 35/8 53/3 73/12
80/5 80/20 83/6 87/2
91/2 96/24 97/1
100/20 102/1 102/11
107/15 117/11 123/5
makes [2] 90/2 90/2
making [14] 2/4
19/22 41/13 55/21
64/1 64/7 86/10 90/7
113/6 131/19 133/13
185/20 194/17 196/17)
malicious [3] 103/5
111/25 112/3
manage [3] 45/3
58/13 152/21
managed [2] 92/19
149/13
management [35]
8/15 9/9 18/22 35/9
36/25 41/23 48/18
58/6 60/9 112/16
120/11 121/11 125/22)
142/17 142/22 144/13}
144/19 145/2 148/8
152/25 153/10 154/16)
161/12 169/2 170/8
171/23 172/1 172/16
182/9 182/21 182/24
185/9 185/14 190/4
190/4
manages [1] 35/11
managing [7] 18/17
18/23 18/25 19/16
34/24 151/24 152/23
mandate [1] 187/15
mantra [2] 116/1
4117/1
many [10] 9/2 41/14
53/9 63/20 107/25
111/11 111/24 141/10)
156/15 184/23
map [1] 57/21
March [32] 4/13
11/16 64/11 69/23
70/4 70/8 73/20 75/22
83/9 85/8 87/7 87/16
87/24 89/4 93/8 94/21
98/17 103/21 112/7
114/5 115/16 115/18
122/8 131/4 131/11
131/14 140/9 140/18
159/3 192/10 193/3
193/17
Mark [15] 5/7 26/11
26/12 33/22 36/25
79/12 135/4 144/14
majority [2] 42/1 42/3)
178/12 185/17 191/20)
145/5 154/21 157/18
172/3
marked [2] 132/4
181/20
Market [1] 194/6
Martin [1] 151/9
massive [1] 132/14
master's [1] 137/5
material [12] 5/23
7/15 7/17 7/18 7/23
27/14 29/21 70/20
94/10 100/3 107/18
196/6
materialise [1]
194/11
matter [20] 10/10
42/9 43/16 56/12 68/9
80/6 84/14 95/5 117/4
117/12 119/4 129/11
133/22 152/8 173/14
178/9 179/1 180/20
187/1 191/6
Matter 3 [1] 178/9
matters [25] 19/10
19/12 31/12 80/18
83/25 107/1 120/6
124/13 141/22 141/24
155/7 155/8 155/16
155/22 156/9 156/13
156/23 168/19 186/24]
189/25 190/13 190/25
191/8 191/8 191/9
mature [2] 6/5 6/7
maximum [1] 122/11
may [26] 4/15 14/8
21/8 45/16 46/14
50/21 54/4 84/9 89/18
93/17 93/18 98/20
98/25 99/5 100/10
122/18 128/1 142/2
149/21 156/11 162/10}
165/10 169/3 182/23
194/16 195/22
maybe [2] 111/23
150/2
McCall [1] 101/6
McDonald [1] 107/20
me [72] 8/8 8/15 9/23
10/4 10/9 10/15 10/18
14/3 15/12 15/18
17/11 23/1 25/25
26/13 26/13 28/2
33/10 34/4 34/21
40/16 40/20 42/22
42/23 45/5 46/21 47/5
53/22 64/21 67/6 70/9
74/6 75/4 75/6 75/13
79/10 81/6 82/21 86/7
86/17 86/20 86/24
87/19 91/15 93/23
96/19 103/20 104/20
105/2 106/14 107/6
107/11 111/5 115/6
158/20 158/21 171/22
136/6 140/16 141/1
161/16 162/7 175/12
183/15 189/18 192/4
194/24
mean [63] 6/1 6/7
15/23 24/15 24/16
25/11 26/10 33/20
40/15 43/10 43/22
46/20 50/4 51/15
53/10 54/17 55/20
58/20 60/7 63/10
65/23 66/13 67/12
69/7 69/10 74/6 75/4
85/21 86/13 86/19
86/24 102/4 104/7
108/9 108/12 109/4
111/4 125/24 126/2
149/4 156/23 161/8
180/7 180/8
meaningful [1]
115/12
meaningfully [2]
129/6 129/9
means [8] 10/2 29/3
108/10 108/11
meant [2] 74/10
161/9
meantime [1] 71/11
156/19
media [6] 59/24 65/1
84/1 105/6 192/19
192/20
mediation [3] 7/7
104/24 114/25
meet [3] 64/24
157/10 157/12
meeting [57] 2/15
2/17 2/23 3/1 3/3 3/5
13/9 15/14 23/24
24/18 24/18 24/22
25/1 25/1 25/6 25/10
30/21 30/21 30/22
55/2 55/3 55/14 63/24)
73/19 73/22 74/14
80/22 86/21 97/6 98/6)
98/10 108/12 108/13
110/21 119/15 122/8
122/12 124/19 126/5
128/24 129/20 130/2
130/6 130/20 131/11
133/5 133/8 147/18
159/2 162/10 162/15
165/10 166/9 167/6
168/15 181/17 193/17]
117/12 123/24 125/10)
132/20 132/24 133/12)
146/13 149/15 157/14}
9/11 9/22 10/23 11/10)
34/7 35/18 35/25 36/5)
36/6 40/6 40/10 40/12
80/23 82/19 83/8 83/9
132/13 132/21 133/20}
52/10 91/4 93/5 99/10)
mechanism [2] 25/20]
meetings [10] 37/5
42/13 129/13 146/18
162/13 168/12 170/11
170/14 171/8 172/21
meets [1] 115/21
member [15] 4/5
18/7 30/11 38/4 78/16)
80/24 89/1 102/21
125/19 125/22 132/12
146/19 147/14 186/15)
188/3
members [14] 29/9
33/15 37/7 48/15
70/11 73/6 95/22
125/22 157/19 163/8
167/2 167/7 185/10
189/20
memory [6] 24/21
24/23 26/15 44/5
98/22 174/20
mention [6] 22/4
112/21 112/22 113/19)
113/22 113/23
mentioned [11]
15/21 38/2 39/7 84/16
92/15 109/13 157/6
158/16 160/14 171/17
174/16
mentioning [1]
171/10
Mergers [2] 3/23 4/1
merits [11] 13/5
13/21 14/3 22/4 22/9
28/7 28/9 29/21 84/4
91/11 97/12
meshes [1] 131/1
message [4] 9/3 83/2
83/3 120/11
messaging [4]
186/22 187/11 187/12)
189/25
met [1] 64/22
method [1] 47/23
mid [2] 22/23 64/7
mid-October [1]
22/23
middle [4] 85/9 93/2
93/7 140/13
midnight [1] 22/24
might [40] 10/9 36/3
40/7 43/19 44/3 51/17)
53/2 59/5 61/13 61/13
68/4 83/22 86/19
86/20 88/16 92/2 95/8I
95/9 96/14 98/22
100/3 100/7 101/1
111/24 111/25 117/17
132/18 132/20 151/11
151/11 168/21 170/9
182/23 182/25 184/21
185/24 188/7 189/13
191/4 195/6
mile [1] 169/19
million [3] 157/7
(68) lost... - million
million... [2] 157/7
195/17
millions [1] 145/19
mind [10] 9/1 22/22
25/14 52/20 60/13
65/24 88/18 94/9
184/16 185/8
minded [1] 77/1
minister [35] 7/12
23/25 24/19 24/25
30/24 33/4 54/21 55/5
55/7 56/8 64/14 64/17,
64/20 94/25 95/6
95/10 96/11 96/13
98/7 98/11 114/16
129/21 132/7 154/23
185/19 186/16 187/12
187/16 189/11 189/20
190/18 190/20 191/9
191/10 191/17
ministerial [4]
131/13 143/15 187/21
188/23
ministers [15] 32/8
32/15 54/22 55/15
62/20 63/1 63/9 93/17
97/25 98/2 183/21
185/22 187/8 190/22
190/24
minor [1] 1/23
minority [1] 66/4
minute [2] 22/24
133/24
minutes [19] 2/15
2/23 3/1 3/5 3/9
104/15 117/25 118/1
124/6 124/12 124/13
127/21 162/10 162/12)
165/9 165/14 168/15
186/3 186/3
miscarriage [3] 44/3
45/9 67/21
misfeasance [1]
111/14
mislead [1] 73/5
misleading [3] 62/6
114/16 158/12
mismanaged [1]
73/8
mismanagement [1]
73/13
Misra [11] 103/19
105/5 107/6 107/19
107/22 107/24 108/19}
109/19 109/23 111/8
112/1
Misra's [2] 108/6
108/16
missed [1] 66/23
missing [9] 24/17
38/17 38/23 39/1 43/4,
43/5 43/24 50/20
63/25
mistresses [1] 118/7
mitigate [5] 11/25
mitigation [13] 49/16
52/11 52/13 54/10
54/20 60/19 62/2
62/17 142/13
mitigations [1] 65/11
mix [1] 185/12
Mm [14] 16/15 18/5
18/12 21/22 23/14
35/14 53/17 55/25
57/12 61/25 62/4
66/17 71/21 121/1
Mm-hm [9] 18/5
35/14 55/25 57/12
61/25 62/4 66/17
71/21 121/1
model [4] 127/16
129/22 150/5 150/11
modus [1] 169/1
MOLONEY [2] 99/14
198/6
moment [2] 98/25
178/9
money [7] 34/16 40/9
43/2 43/5 43/23 43/24
120/14
monitor [2] 11/20
12/11
monitored [2] 179/11
179/19
monitoring [4] 11/23
128/17 179/16 179/21
monitors [1] 150/15
month [3] 140/3
140/23 140/25
months [12] 10/10
11/11 44/16 44/19
44/19 44/19 49/3 55/8)
57/9 164/2 164/19
193/21
morally [1] 122/25
more [56] 6/4 6/4 6/7
6/8 8/6 10/13 21/10
30/16 30/17 32/18
33/1 33/22 35/8 38/3
42/16 42/16 43/21
50/10 51/7 67/3 68/5
68/8 69/1 72/16 73/15)
98/11 98/19 99/6
100/13 101/16 103/1
122/4 123/11 129/6
129/9 129/10 129/12
1314/3 132/8 132/20
135/11 143/20 152/18)
157/21 161/6 161/9
164/16 169/6 169/21
169/21 170/1 172/17
176/13 176/20 177/4
194/11
morning [13] 1/3
45/3 54/9 142/8 195/6
49/17 49/17 52/4 52/8
1/16 45/17 47/17
47/23 51/11 56/13
130/7 135/20
mortem [2] 74/22
77125
most [19] 19/12
24/10 26/15 34/22
53/11 55/23 57/21
76/23 122/3 123/5
123/25 144/19 148/9
167/2 176/9 180/19
motive [1] 134/2
move [5] 54/7 69/20
101/19 173/4 180/20
moved [2] 44/6
104/11
Moving [1] 3/20
MP [2] 131/18 190/18
MPs [4] 167/10 175/6
177/1 187/8
Mr [95] 1/14 8/24 9/4
17/15 18/17 22/6
43/13 45/1 45/20
47/20 74/24 76/23
78/8 78/13 79/14
79/15 81/11 81/11
81/11 82/1 83/16
84/11 84/19 84/22
84/23 85/2 85/2 85/7
85/8 85/10 85/10
85/10 85/12 85/21
88/3 89/4 89/21 90/23
92/15 97/17 99/3 99/9
99/14 99/16 103/16
103/17 103/18 105/12
106/23 107/23 109/19}
109/23 112/12 115/11
115/20 117/20 117/24
118/3 118/5 118/6
118/14 122/21 123/20}
124/2 124/15 125/11
125/23 128/3 134/19
135/18 136/2 136/9
136/11 136/15 142/2
175/14 183/23 184/7
186/8 186/9 187/19
188/6 191/25 192/1
192/6 192/8 196/14
196/17 196/24 198/6
198/8 198/10 198/20
198/22 198/24
Mr Altman [2] 106/23
109/19
Mr Callard [3] 8/24
9/4 175/14
Mr Cavender's [1]
74/24
Mr Chisholm [3] 78/8
79/14 88/3
Mr Cooper [24] 1/14
43/13 45/20 47/20
92/15 97/17 99/3 99/9
70/15 92/3 97/21 99/9
157/13 157/17 161/16
99/16 103/16 103/18
105/12 107/23 117/20}
117/24 118/6 118/14
122/21 123/20 124/2
125/11 128/3 134/19
135/18
Mr Evans [2] 81/11
85/21
Mr Evans' [3] 84/19
85/7 85/10
MR HENRY [5]
103/17 115/11 192/8
196/14 198/8
Mr Justice [3] 17/15
18/17 125/23
Mr Justice Fraser [1]
76/23
Mr Kilgarriff [5]
81/11 84/11 84/23
85/10 85/12
Mr Kilgarriff's [1]
85/2
Mr Lambert [1] 79/15
Mr O'Sullivan [7]
136/9 136/15 187/19
188/6 192/1 192/6
196/17
Mr Russell [1] 142/2
Mr Scott [2] 109/23
112/12
Mr Stein [1] 118/3
Mr Stevens [8]
124/15 136/2 136/11
183/23 184/7 186/8
196/24 198/20
Mr Swannell [1]
115/20
Mr Watson [13] 22/6
45/1 78/13 81/11 82/1
83/16 84/22 85/2 85/8)
85/10 89/4 89/21
90/23
Mrs [4] 103/19
107/24 108/6 108/16
Mrs Misra [1] 107/24
Mrs Misra's [2] 108/6I
108/16
Mrs Seema [1]
103/19
MS [19] 1/11 1/14
19/15 22/18 27/20
42/17 43/8 47/9 99/15
112/10 118/17 124/3
125/9 128/2 135/23
166/24 198/4 198/12
198/14
MS HODGE [13] 1/11
1/14 42/17 43/8 47/9
99/15 112/10 118/17
124/3 128/2 135/23
198/4 198/14
Ms MacLeod [1]
19/15
Ms O'Neill [1] 27/20
Ms Storey [1] 166/24
Ms Vennells [1]
22/18
MSC [1] 137/6
much [27] 8/2 26/1
32/2 36/18 40/13
40/16 57/5 59/8 59/9
60/4 61/12 64/2 66/11
98/3 103/16 106/20
124/1 127/17 135/17
136/7 139/15 140/4
161/14 167/3 171/17
192/11 197/3
multiple [4] 105/6
must [3] 84/12 104/6
105/8
Mutual [3] 139/10
141/6 141/14
mutualisation [1]
163/10
my [105] 1/14 5/3
5/23 7/21 10/7 12/9
14/13 14/18 23/21
24/4 24/20 24/21
24/23 26/1 26/15
29/23 31/6 33/17
34/22 38/2 39/20
41/12 41/16 41/22
42/12 43/11 45/20
47/10 52/2 52/5 54/1
61/5 65/24 67/2 67/13
73/5 78/2 81/7 83/14
86/1 88/20 90/5 90/6
91/7 95/21 96/5 97/2
97/3 100/18 101/6
101/11 105/23 105/24)
108/5 108/14 112/9
113/20 116/12 117/12
117/15 118/6 119/8
122/2 122/3 122/8
122/11 123/8 123/9
123/13 125/11 127/17
127/24 128/20 129/7
130/23 130/24 131/13)
132/17 132/24 133/4
139/5 144/17 146/12
146/22 147/9 148/10
149/7 152/17 157/12
157/17 170/15 171/24I
172/9 172/14 173/6
174/4 174/6 174/20
175/16 185/22 185/25}
188/14 189/14 189/18)
192/4
myself [3] 36/23
147/11 159/16
N
name [9] 1/12 1/14
50/1 112/21 113/19
113/23 118/6 125/11
136/13
named [2] 59/14
59/15
(69) million... - named
N
46/1 86/9 90/23
names [1] 113/22
narrative [1] 107/21
narrow [1] 73/14
National [1] 125/12
naturally [4] 55/18
15/22 25/10 169/16
172/12 172/17
NDA [4] 29/7 29/8
29/12 35/3
nearer [1] 93/11
59/5 61/11 192/17
195/2
necessary [4] 19/2
36/3 46/25 126/7
NED [8] 4/19 29/7
29/16 61/18 119/22
NEDs [1] 29/10
need [30] 12/12 17/1
21/2 22/22 25/14
65/24 68/18 79/4
84/25 91/2 107/17
124/9 124/20 125/14
126/17 127/4 135/24
139/3 139/15 143/3
145/10 148/1 166/17
171/7 178/14 180/24
183/14
needed [17] 12/10
23/2 23/9 28/2 28/2
47/6 75/18 109/8
149/24 165/6 183/16
needs [1] 38/20
negative [6] 52/15
58/11 58/19 58/25
80/3 104/14
negotiations [1]
102/1
Network [1] 58/4
Neuberger [2] 76/13
79/22
Neuberger's [3] 77/5
88/9 88/14
never [17] 8/13 19/3
40/22 65/25 83/18
83/19 83/20 126/11
126/12 127/7 127/11
127/11 171/1 174/9
174/9 183/19 186/17
nevertheless [2]
20/3 119/10
new [10] 54/23 100/2
126/3 126/9 126/11
126/13 126/17 126/23)
127/5 164/25
namely [4] 13/16
nature [7] 9/14 13/16
necessarily [5] 26/17
121/15 153/13 166/24}
109/15 111/16 113/22)
124/12 132/14 132/15)
133/22 134/13 142/12
News [1] 192/25
next [13] 5/23 49/15
51/4 54/7 81/10
108/22 123/8 124/16
124/19 136/2 139/5
142/3 158/8
NFSP [4] 124/6
124/11 125/7 126/12
Nick [6] 65/3 105/7
105/8 106/24 114/9
126/18
night [3] 18/20
110/10 170/25
no [88] 4/10 6/1 7/17
8/18 9/6 9/7 11/9
30/9 30/9 31/5 39/12
40/8 41/8 42/2 44/14
50/7 50/13 56/14
58/16 59/13 63/21
67/5 67/5 67/5 69/14
80/16 82/20 83/8
84/13 89/22 91/22
93/21 94/13 95/14
108/3 108/16 109/1
109/4 111/16 113/10
123/3 123/21 125/14
126/2 127/19 131/2
133/19 134/16 135/3
149/2 152/4 155/24
158/12 159/1 161/19
161/23 164/9 164/20
165/24 166/18 167/9
168/14 168/14 170/8
172/17 173/1 173/3
174/9 174/20 186/20
189/23 190/7 191/14
192/22 194/18 195/11
197/1 197/1
Nobody [1] 90/12
nodded [3] 138/14
139/25 140/22
nodding [1] 151/18
noise [1] 194/18
nomination [1]
125/19
Nominations [1]
125/17
non [24] 4/14 12/8
26/23 29/2 30/11 36/7)
36/22 60/23 62/7
66/15 82/3 91/14
132/12 134/22 138/7
138/13 138/17 139/9
153/11 153/22 154/3
160/15 165/25 170/22)
non-executive [17]
4/14 29/2 30/11 36/7
36/22 60/23 62/7
66/15 91/14 138/7
138/13 138/17 153/11
153/22 154/3 160/15
11/16 27/22 30/5 30/5)
113/12 113/12 113/15)
119/14 120/11 121/22
165/25
non-threatening [1]
170/22
none [3] 72/20
160/13 193/1
nor [4] 72/21 153/4
154/15 170/9
normal [6] 154/15
166/14 172/5 174/4
187/14 188/10
normally [2] 170/25
188/13
not [215]
note [5] 79/21 88/9
107/1 107/2 107/4
noted [2] 63/22
193/19
nothing [9] 31/6
95/21 115/2 117/20
123/2 166/8 166/14
189/8 189/11
notice [1] 21/18
November [12] 4/3
4/9 19/9 22/24 37/22
56/3 65/8 103/24
104/1 126/5 130/3
1314/1
now [69] 6/12 7/23
11/2 18/17 21/20
23/11 30/16 35/15
43/13 47/20 51/11
53/13 54/13 59/12
61/1 61/1 69/7 77/24
78/13 80/9 82/11 85/7
92/20 97/20 98/6 99/7
99/24 104/17 105/12
106/21 106/23 107/9
107/17 112/12 114/5
118/13 118/16 119/8
120/9 120/22 121/12
121/13 123/13 124/3
124/9 125/10 126/7
127/12 130/23 131/21
137/9 137/23 142/20
155/2 155/19 156/4
156/15 161/3 163/17
164/12 169/9 184/13
185/23 186/13 186/19}
188/15 193/24 194/16}
196/9
nowhere [1] 194/22
nuclear [2] 35/4
145/18
number [24] 19/4
33/17 38/2 44/12
44/17 44/17 49/12
49/21 57/15 58/4 59/8
59/12 103/18 118/7
136/21 138/4 145/13
156/18 157/8 176/21
176/24 193/20 193/23
195/17
number 11 [2] 49/12
49/21
number 2 [2] 33/17
38/2
number 3 [1] 193/23
number 9 [3] 57/15
59/8 59/12
numbered [1] 49/13
numbers [1] 42/2
nutshell [1] 75/15
NW [1] 105/8
[e)
O'Neill [2] 27/4 27/20
O'Sullivan [10] 136/9
187/19 188/6 192/1
192/6 196/17 198/18
object [1] 95/1
objective [5] 66/2
66/10 66/12 66/13
144/20
objectively [1] 75/3
objectives [3] 58/5
143/15 143/16
obligations [3] 14/17
19/11 29/12
obliquely [1] 45/12
observation [1]
194/17
observer [1] 77/2
obsession [1] 192/19]
obstacles [1] 30/6
obtain [4] 12/25
obtained [3] 13/5
29/16 39/9
obtaining [1] 29/3
obvious [7] 8/19 8/21
17/19 25/24 35/19
42/23 156/11
obviously [23] 6/1
7/20 12/8 14/2 26/11
29/13 34/9 35/23 36/6
36/25 54/1 54/14 55/5)
60/10 61/7 79/11
80/24 88/24 102/4
103/21 124/7 149/11
192/17
occasion [3] 37/6
118/2 159/16
occasional [2] 140/6
174/5
occasionally [1]
161/22
occur [2] 44/1 183/11
occurred [3] 44/3
55/1 160/21
October [30] 17/25
18/16 20/21 22/23
24/1 24/18 25/1 25/6
28/15 30/22 40/3 55/1
55/13 62/23 64/18
98/7 98/21 119/21
122/5 122/12 129/21
130/25 140/9 140/17
147/21 192/3 192/6
136/10 136/14 136/15)
192/7 192/9 192/12
odds [3] 16/5 17/11
20/2
off [9] 16/3 39/20
42/15 105/13 106/9
124/22 133/10 164/7
185/2
offence [1] 42/3
offer [1] 65/13
Office [218]
Office's [45] 13/9
13/11 13/24 14/6 16/7)
16/13 17/16 17/24
21/6 21/19 21/24 22/3}
23/18 24/13 26/5 30/7
37/15 37/18 46/4 56/9
56/10 61/3 69/22 72/3I
72/11 72/19 72/19
72/22 73/2 73/15
73/16 74/7 75/21
81/16 92/21 95/7
103/7 106/7 108/7
110/2 1114/5 111/13
130/10 167/20 188/18)
Officer [2] 170/19
196/3
official [3] 130/4
154/6 164/16
officials [3] 33/4
131/12 196/4
often [3] 139/6
157/10 157/16
Oh [11] 5/2 13/23
15/17 32/13 39/18
52/24 73/18 112/8
115/8 115/10 164/2
okay [13] 11/3 49/7
52/24 80/2 94/20
95/11 101/19 119/4
120/1 120/16 121/12
126/4 139/18
Old [3] 139/10 141/6
141/14
Old Mutual [4]
141/14
omit [1] 193/22
on [330]
once [2] 65/11 177/6
one [65] 15/8 17/12
22/24 23/6 24/17
30/20 32/21 33/6 40/4I
40/23 45/25 46/18
48/20 51/14 53/18
58/17 61/11 66/4
66/12 67/1 67/5 67/5
74/6 77/21 80/25
82/22 84/18 84/18
84/24 85/24 86/25
88/24 90/19 93/12
97/16 103/2 103/3
104/22 107/25 122/4
123/24 129/22 139/1
140/3 140/19 141/1
141/3 141/12 142/6
(70) namely - one
[e)
one... [16] 143/23
146/23 148/1 150/14
152/24 154/3 159/16
164/8 167/2 171/7
173/1 173/14 185/17
186/1 188/10 194/11
ones [2] 169/17
188/25
ongoing [17] 6/15
50/18 58/8 58/9 58/18
63/2 72/21 93/20
127/9 127/15 130/13
150/25 151/10 152/5
159/11 171/12 185/1
online [1] 1/7
only [18] 4/20 10/10
13/25 14/25 21/9 38/6
46/8 56/21 66/5 77/7
96/2 122/7 122/13
157/5 157/19 164/2
179/3 184/24
open [6] 34/7 36/18
47/5 148/3 150/25
152/4
operandi [1] 169/1
operate [4] 34/16
150/6 150/9 151/2
operated [2] 29/24
177/18
operating [2] 164/10
188/10
operation [4] 152/25
153/19 153/25 160/6
operational [6] 83/25
186/25 189/25 190/25)
191/5 191/8
operationally [2]
16/21 120/25
operations [10]
70/22 152/19 152/22
152/24 153/7 153/9
153/15 154/24 156/24}
191/1
opining [1] 109/1
opinion [7] 13/5
13/21 14/3 20/14 28/7)
29/22 95/21
opinions [2] 66/11
88/2
opportunity [6] 11/13}
24/20 27/16 29/7
32/18 66/23
opposed [1] 88/5
opposite [6] 86/6
95/18 105/19 109/10
110/1 114/18
oppressive [1] 72/13
optimise [1] 29/9
option [2] 11/14
77/14
options [1] 194/12
or [137] 4/24 5/12
8/15 8/25 10/6 12/17
14/21 15/25 17/13
38/11 41/22 42/25
58/20 63/22 63/23
63/24 66/12 67/18
69/1 70/17 73/15
77/18 79/8 79/14
79/17 80/5 80/14
80/20 82/11 84/5
84/10 85/15 88/25
100/24 101/3 101/3
101/7 101/16 102/16
102/20 103/10 105/2
105/13 108/25 113/8
113/18 114/4 116/25
124/4 125/21 125/22
134/2 135/1 135/12
137/13 141/8 142/7
142/7 142/11 143/25
144/23 145/1 147/4
149/3 149/14 149/22
149/25 151/11 152/8
152/20 153/5 153/8
153/16 155/6 155/22
156/3 157/20 160/1
160/9 160/20 163/12
163/16 164/17 164/21
165/13 166/7 167/17
168/2 170/8 171/3
171/4 175/6 175/15
17715 177/18 178/4
179/9 180/9 180/16
183/20 185/7 187/7
187/22 188/2 188/9
190/22 191/5 191/21
oral [2] 54/24 62/22
orally [1] 6/23
order [4] 24/5 71/15
101/20 145/9
organisation [3]
115/13 153/6 165/6
original [1] 78/24
originates [1] 92/21
origins [1] 100/24
other [37] 10/2 10/11
13/25 14/7 16/21 17/2
32/14 36/10 40/23
44/7 60/10 67/1 73/6
83/13 86/9 94/4 94/6
94/16 95/22 109/19
110/8 110/10 117/22
120/24 121/17 123/12)
126/1 141/5 141/25
143/23 146/5 166/7
175/15 176/9 183/4
185/17 195/8
19/10 23/7 23/7 23/19
26/1 32/13 32/22 36/2
45/3 45/10 50/5 50/16
50/17 51/7 52/5 58/17)
91/5 95/18 96/7 100/6
117/25 123/15 123/18)
131/25 133/15 133/25)
193/14 194/11 195/24)
others [5] 41/14
98/17 106/24 108/6
129/21
our [24] 5/17 5/19
19/17 20/4 20/4 27/4
27/9 45/16 60/13
70/22 70/23 70/25
777 77/18 92/3
108/13 109/16 124/16
144/20 191/7
out [41] 17/8 17/17
18/18 25/3 30/23
34/17 34/22 36/21
37/6 48/25 62/9 63/20
67/25 71/2 72/10 75/9
79/2 80/8 83/14 88/8
88/16 90/13 94/8
112/9 123/5 123/23
126/25 128/24 133/25)
142/16 143/11 143/16
144/14 145/9 149/14
150/11 159/7 174/13
180/2 180/22 180/24
outcome [8] 10/12
59/21 61/9 63/4 69/24
90/14 91/18 95/15
outlined [1] 102/12
outlining [1] 165/16
outputs [1] 98/10
outset [2] 11/19
146/21
outside [4] 90/4 91/8
155/23 166/6
outstanding [1]
124/13
over [31] 5/7 11/9
11/10 20/3 50/9 79/8
90/22 91/5 97/17
105/13 116/3 116/4
120/21 127/12 130/10}
130/11 141/23 150/8
155/13 163/6 169/12
170/15 177/22 179/1
179/13 179/16 179/21
189/9 194/3 194/7
196/25
overall [5] 57/25
60/17 67/16 82/7
143/12
overhaul [1] 114/10
overridden [1] 97/3
oversee [1] 180/23
overseeing [7] 10/18
146/24 152/19 152/25)
168/22 171/5 176/18
oversight [15] 5/19
12/8 66/16 97/19
115/7 128/23 129/5
132/8 154/19 155/3
166/1 180/14 180/18
181/2 181/9
overstated [1]
ought [2] 14/24 46/16
5/19 15/14 18/17 19/6
195/19
overturned [1] 51/13
overview [7] 49/15
49/17 50/15 54/10
57/25 60/19 149/12
owed [2] 120/14
152/11
own [14] 14/13 14/18
27/17 35/5 54/11
55/19 63/8 65/14
65/24 90/6 97/12
121/18 133/4 161/3
owned [1] 151/8
owner [6] 122/22
122/23 123/1 123/11
189/10 189/16
owners [2] 121/18
183/5
ownership [1]
169/19
Pp
pack [2] 112/14
182/18
packs [1] 176/1
page [69] 18/1 20/20
28/17 28/18 28/25
49/8 59/11 70/3 72/8
76/4 85/9 87/13 89/5
93/2 93/2 93/7 93/9
93/12 94/18 99/17
100/10 107/8 109/12
112/15 112/15 112/15}
112/16 114/6 114/20
118/12 118/13 120/21
120/21 128/7 131/9
136/23 137/11 140/13
141/21 143/9 143/22
147/23 148/13 150/4
150/8 150/22 152/15
155/3 155/13 160/23
163/4 163/6 165/10
171/9 173/16 173/17
175/11 177/14 177/22}
178/8 179/1 179/13
180/21 182/15 193/18}
194/3 194/3 194/7
194/9
page 1 [1] 70/3
page 10 [2] 112/15
141/21
page 112 [1] 99/17
page 117 [1] 100/10
page 12 [1] 180/21
page 14 [1] 171/9
page 16 [1] 112/15
page 17 [1] 193/18
page 18 [1] 194/3
page 19 [2] 160/23
194/7
page 2 [7] 89/5 93/2
94/18 136/23 140/13
150/4 163/4
page 20 [2] 155/3
173/16
page 21 [1] 173/17
page 22 [2] 175/11
182/15
page 23 [1] 137/11
page 24 [2] 112/15
114/20
page 26 [1] 28/17
page 27 [2] 28/18
28/25
page 3 [6] 93/7 107/8
147/23 148/13 152/15)
177/14
page 39 [1] 128/7
page 4 [4] 59/11 93/9
93/12 165/10
page 57 [2] 118/12
118/13
page 58 [1] 120/21
page 7 [1] 178/8
page 79 [1] 72/8
page 80 [1] 131/9
page 88 [1] 87/13
pages [2] 1/22 70/16
painful [3] 84/6 85/18)
85/22
Panorama [2] 9/22
65/4
paper [2] 54/6 142/24]
papers [7] 6/11 37/3
55/12 165/21 166/5
166/10 166/13
paradigm [1] 111/13
paragraph [69] 2/2
2/3 2/8 5/4 16/17 72/7
72/8 72/8 77/6 87/12
93/11 93/24 96/12
99/17 99/23 100/9
100/12 100/23 102/10)
108/22 118/12 118/13)
118/24 119/20 120/17)
120/21 126/4 128/6
128/8 128/9 128/14
129/15 131/8 136/24
136/24 140/13 141/21
143/3 143/9 147/23
148/13 148/14 152/15)
155/4 155/16 155/19
155/22 159/5 160/24
165/19 168/12 171/9
173/16 173/17 173/17)
173/19 175/11 175/23)
180/21 180/22 182/14I
182/16 183/22 184/9
186/19 186/21 187/19)
194/5 194/8
paragraph 10 [2]
148/13 148/14
paragraph 11 [1]
152/15
paragraph 118 [2]
118/12 118/13
paragraph 119 [2]
16/17 120/21
¢
71) one... - paragraph 119
P
paragraph 167 [2]
72/7 72/8
paragraph 170 [1]
131/18
paragraph 18 [1]
128/14
paragraph 18.2 [1]
143/3
paragraph 185 [1]
87/12
paragraph 242 [3]
99/17 99/23 100/23
paragraph 252 [1]
126/4
paragraph 256 [3]
100/9 100/12 102/10
paragraph 26 [1]
141/21
paragraph 30 [2]
180/21 180/22
paragraph 31 [1]
168/12
paragraph 31.2 [1]
171/9
paragraph 36 [1]
186/19
paragraph 37 [1]
187/19
paragraph 38 [1]
186/21
paragraph 3b [1]
147/23
paragraph 43 [4]
160/24
paragraph 45 [3]
155/4 155/22 173/16
paragraph 46 [4]
173/17
paragraph 47 [3]
155/19 173/17 173/19
paragraph 5 [4] 77/6
136/24 136/24 194/5
paragraph 50 [4]
175/11 175/23 182/14
182/16
paragraph 51 [2]
183/22 184/9
paragraph 6 [2]
140/13 194/8
paragraph 69 [1] 2/2
paragraph 7 [2] 5/4
143/9
paragraph 75 [1] 2/8
paragraph 79 [1]
128/9
paragraph 80 [1]
128/6
paragraphs [7] 2/14
2/25 100/23 125/15
143/7 155/14 175/21
paragraphs 13 [1]
125/15
paragraphs 238 [1]
2114
paragraphs 46 [1]
155/14
paraphrasing [1]
9/11
Parker [9] 7/11 22/12
76/5 98/17 107/4
109/13 109/15 133/13}
135/4
Parliament [22] 84/1
156/19 167/7 173/23
174/22 175/2 176/2
176/4 176/5 176/17
177/1 177/7 182/19
183/7 183/25 184/2
184/5 186/15 188/4
189/15 189/20 190/22)
part [31] 2/18 5/3
5/14 5/18 6/10 6/11
11/19 12/9 14/8 33/5
63/14 74/21 84/12
85/1 85/4 88/14 92/25
97/25 98/10 100/16
101/22 102/7 112/22
118/16 122/23 144/8
144/20 149/16 162/25)
173/1 188/18
Participant [1] 186/1
Participants [2]
97/18 99/6
participate [8] 78/15
85/20 87/1 88/23 89/7
89/11 89/15 97/15
participated [1]
89/19
participating [1] 86/7
participation [1]
89/22
particular [16] 8/2
37/8 45/14 45/18
57/13 65/3 79/24 91/9
94/14 119/7 119/20
143/7 145/23 172/8
173/14 186/20
particularly [18] 10/3
10/4 10/5 15/3 30/24
40/20 56/11 57/6 67/9)
68/3 73/3 103/8 111/8)
118/15 119/3 132/13
145/15 172/10
particulars [1]
193/11
parties [6] 14/16
14/18 19/21 21/4 46/9)
46/23
partisan’ [1] 71/1
partly [2] 24/5 31/14
partnership [1] 16/2
parts [8] 3/4 12/7
17/17 18/18 66/25
75/9 75/10 165/3
party [1] 87/20
passed [2] 30/2
156/1
passing [1] 171/11
past [8] 20/3 37/18
39/11 39/13 72/25
119/18 120/13 173/12]
Patrick [7] 79/18
81/14 83/16 136/10
136/14 159/7 198/18
Patrick's [1] 84/24
pattern [1] 111/23
Paula [7] 22/15
112/19 113/9 113/20
114/4 130/12 172/15
pause [3] 11/1 49/12
136/5
pausing [4] 28/19
39/9 80/9 140/20
pay [2] 21/10 184/3
peer [1] 161/13
penetrate [1] 59/3
penny [1] 31/18
people [22] 25/2
32/10 34/16 42/1
68/18 107/16 117/9
117/19 118/8 120/7
120/9 123/23 124/21
134/15 157/10 170/4
174/6 174/7 180/15
194/21 195/22 195/23
people's [1] 113/22
per [1] 139/2
perceived [8] 50/22
52/17 52/19 146/2
161/24 195/7 195/24
196/5
perception [5] 11/5
11/7 22/19 128/20
129/8
perceptive [1] 42/21
perceptiveness [1]
42/18
perfect [1] 176/15
perfectly [1] 166/4
performance [5] 29/8
150/15 172/18 189/6
194/5
performing [1]
151/11
perhaps [10] 32/20
51/17 52/20 56/18
88/15 100/12 121/9
132/23 169/9 190/10
period [8] 10/24
11/12 55/8 65/19
130/24 164/15 175/15}
175/16
periodically [1]
143/15
Perkins [3] 147/18
171/8 171/10
Permanent [19]
23/25 24/19 24/25
32/8 32/15 36/13
54/22 55/10 56/7
62/20 64/13 64/18
65/7 78/5 80/13 85/15)
129/21 151/10 183/21
permeated [1] 193/1
permitted [1] 127/23
persisted [1] 42/10
person [8] 30/17
50/2 66/5 66/12 154/8
159/22 165/6 178/22
person's [1] 61/11
personal [12] 61/5
65/21 65/25 81/1 81/7
90/7 90/11 95/21 97/3,
97/12 148/6 172/14
personally [5] 75/7
103/22 104/16 115/6
155/23
persons [2] 157/15
167/13
perspective [13]
12/11 21/24 31/7 53/8}
61/11 65/21 83/1
106/6 109/4 112/1
121/13 121/21 191/22}
persuade [6] 16/24
17/1 68/18 68/19
68/19 68/20
Peters [2] 106/24
106/24
phase [2] 11/14
124/20
phone [2] 98/16
140/6
phrased [2] 116/14
170/25
picking [1] 59/25
picture [4] 31/23
67/12 67/16 193/13
pieces [1] 80/10
PIERCE [2] 136/10
198/18
pin [4] 102/19 102/19
116/5 116/21
inpoint [1] 135/9
piste [1] 105/13
pitch [2] 14/9 66/6
pithy [2] 59/4 84/7
place [18] 12/15
31/19 42/9 42/20 56/6
64/12 68/7 68/11 73/1
73/22 114/25 131/14
133/21 137/6 152/5
175/9 180/23 181/2
placed [2] 99/7 120/2
plan [3] 20/5 143/17
150/16
planning [10] 24/8
28/4 34/5 40/21 56/11
56/23 57/3 58/24
71/15 123/7
plans [1] 71/16
playing [1] 128/22
plea [6] 39/4 39/16
41/5 42/4 43/15 43/20)
pleaded [2] 42/3 42/6)
please [102] 1/8 1/12
5/9 13/22 16/16 17/23}
18/1 18/6 19/14 20/20)
27/1 28/10 28/17
28/24 34/25 37/21
38/1 45/23 49/2 49/9
49/10 49/21 50/11
51/19 56/24 57/8
57/18 57/24 59/11
63/24 69/20 70/1 70/3I
72/6 72/7 76/2 76/4
78/21 78/24 79/13
81/10 83/15 87/11
87/25 89/5 92/6 93/2
93/7 93/9 93/11 94/18)
97/16 99/17 105/1
107/7 109/12 118/11
118/13 120/21 128/1
128/5 128/7 130/2
136/12 136/23 137/10)
137/18 140/13 141/19)
142/22 143/9 147/20
147/23 148/12 150/2
150/4 150/8 150/22
152/14 155/4 155/13
155/25 159/2 159/4
160/23 162/9 163/4
163/6 165/8 165/10
169/25 173/15 175/10)
177/10 177/14 177/22)
178/8 179/1 179/13
180/22 181/16 182/13)
plight [1] 192/19
pm [9] 70/8 79/3 92/9
92/11 125/1 125/3
162/4 162/6 197/4
point [69] 10/9 10/14
10/18 10/21 13/15
14/3 14/10 14/22
16/25 23/5 25/12
28/25 31/18 34/2 35/1
35/19 43/22 45/16
53/3 55/10 57/13
57/25 57/25 58/1
58/21 60/7 64/1 71/16)
74/18 74/20 85/25
90/7 91/5 91/5 106/10}
108/4 108/9 108/16
112/24 113/6 114/3
117/16 120/5 122/2
122/11 124/22 129/22)
132/4 132/17 132/24
133/9 141/9 141/15
144/18 145/4 145/25
147/9 164/20 165/3
165/8 166/18 174/8
175/24 177/20 178/15)
182/6 182/10 182/11
190/5
pointed [3] 72/10
144/14 180/2
pointing [2] 38/14
94/16
7)
paragraph 167 - pointing
P
points [20] 14/23
15/16 44/1 46/18
54/23 55/4 62/21
70/20 72/17 77/8
77/10 82/22 132/2
134/20 143/23 146/17)
161/16 163/9 172/17
177/14
POL [32] 4/6 39/3
50/17 51/7 56/2 63/3
64/5 64/10 64/13 79/3
79/5 99/20 100/15
100/19 101/21 102/10)
111/1 112/22 118/22
119/23 120/23 121/4
121/12 121/18 126/7
186/23 187/1 187/6
187/11 187/13 190/1
190/6
POL's [9] 39/7 54/24
62/22 64/17 64/19
64/22 72/16 101/5
121/22
POL00028069 [1]
177/11
POL00103411 [1]
70/2
POL00103438 [1]
76/3
POL00103667 [1]
2/22
POL00104327 [1]
217
POL00290368 [1] 3/8
POL00337435 [1]
106/22
POLB12 [1] 165/13
POLB12/60 [1]
165/13
pole [1] 136/2
policies [2] 126/20
126/23
policy [17] 31/15
31/19 31/21 32/5
32/16 32/22 32/25
58/4 63/4 64/23 82/6
83/1 83/1 97/21 97/22
151/3 154/16
Policy/Comms [1]
63/4
political [2] 58/3
169/16
politically [1] 149/25
portfolio [9] 5/17
6/10 128/24 161/10
165/3 170/16 172/6
172/24 172/24
portrayed [3] 104/25
105/16 192/20
POS [1] 181/20
pose [1] 4/25
posed [2] 4/24 157/3
position [22] 16/8
17/9 21/19 63/1 72/3
77/18 93/15 93/25
94/11 94/24 95/8
95/12 97/11 108/8
119/2 136/2 140/9
144/17 166/3 193/24
194/16 194/20
positions [5] 105/11
138/5 167/5 174/5
174/6
positive [4] 7/12
59/21 62/2 179/9
possibility [5] 10/1
43/18 77/3 168/8
194/11
possible [13] 16/22
21/5 37/16 40/5 45/9
49/22 62/15 79/19
93/3 99/18 109/9
120/25 131/22
possibly [12] 43/9
55/11 59/7 59/7 69/4
71/10 99/5 109/6
117/25 132/18 168/7
175/9
post [270]
post-mortem [1]
77/25
post-settlement [2]
100/9 100/11
post-the [1] 195/21
postcodes [1]
169/19
postmaster [2] 42/6
43/23
postmaster's [1]
43/3
postmasters [19]
9/17 15/24 16/2 38/16
38/23 39/15 40/2
41/20 56/4 71/3 71/6
109/6 116/9 120/7
126/11 126/13 126/16)
132/21 132/22
postmasters' [1]
195/16
postmistresses [1]
120/7
pot [5] 107/5 107/22
108/10 108/11 108/18)
potential [4] 51/6
53/11 67/21 130/10
potentially [5] 34/11
58/10 58/19 67/23
151/5
pounds [1] 145/19
power [3] 68/14
89/11 95/2
practical [4] 32/4
126/19 161/8 161/9
practice [12] 59/4
119/18 122/14 128/15)
139/5 139/15 140/20
149/2 152/21 166/15
182/7 184/21
practices [1] 120/12
practised [2] 144/19
145/4
pre [8] 24/18 24/22
25/1 25/6 30/21 30/21
103/8 132/25
pre-2010 [1] 103/8
pre-Common [1]
132/25
pre-meeting [1]
30/21
preamble [2] 74/3
74/4
preceded [1] 172/9
preceding [1] 128/8
precisely [4] 116/10
148/25 149/7 180/7
predate [1] 112/19
predecessor [6] 6/20
27/5 74/12 142/25
146/12 192/4
predominantly [1]
135/14
preferable [1] 81/24
preliminary [1] 77/5
premature [2] 75/7
114/7
preparation [2] 20/4
24/18
prepare [1] 194/2
prepared [2] 7/24
142/25
preparing [4] 54/3
56/2 64/10 177/12
present [1] 106/25
presentational [3]
89/18 90/1 91/4
presentationally [3]
81/22 82/17 82/21
President [1] 76/14
press [6] 38/12 59/25
108/6 109/16 123/10
174/10
pressing [1] 42/17
pressures [1] 58/12
presumably [7]
11/23 55/24 64/24
80/3 111/16 130/7
193/5
pretty [3] 77/11
106/20 135/3
prevent [3] 95/3
166/8 178/22
previous [6] 39/7
50/9 60/16 86/12
112/16 184/22
previously [6] 5/22
64/6 100/14 131/24
131/24 162/24
priced [1] 195/12
primarily [3] 33/9
33/15 135/15
primary [3] 50/4
58/23 61/18
principal [3] 47/23
67/19 97/4
principle [7] 13/15
14/22 38/19 150/24
151/2 152/9 196/10
principles [4] 151/8
151/12 152/3 152/11
prior [3] 129/22
170/17 172/23
priorities [1] 55/20
prioritise [1] 123/23
priority [5] 24/4
126/2 161/1 161/7
161/18
prison [1] 194/22
privilege [2] 12/5
56/9
privileged [5] 27/14
29/21 64/15 178/16
178/22
probability [8] 52/6
52/8 52/10 53/6 60/17,
62/10 62/12 195/15
probably [15] 6/5
50/2 62/9 62/11 80/6
101/13 102/23 113/25}
116/23 161/9 162/1
169/10 176/9 191/7
191/8
probing [1] 104/16
problem [7] 3/4 8/18
42/19 86/8 121/20
122/24 168/24
problems [5] 101/17
116/6 116/8 116/15
167/24
procedural [3] 20/2
76/22 77/13
procedures [1]
164/10
proceed [1] 94/24
proceedings [2]
128/23 196/16
process [29] 6/3 10/5]
10/11 35/9 43/11 54/5)
65/9 65/12 102/8
130/14 144/15 144/21
144/23 145/3 145/12
179/2 179/3 179/5
179/10 179/17 181/9
181/12 182/9 182/21
183/1 183/10 188/16
189/21 190/18
processes [11] 5/14
5/18 6/11 19/22 50/16
65/14 72/11 72/19
167/18 179/14 179/16}
produce [2] 10/12
57/4
produced [5] 13/5
27/23 28/11 130/4
168/6
producing [2] 48/10
136/16
products [1] 159/21
professional [2] 3/16
12/5
proffered [1] 177/24
profile [2] 41/21 79/6
programme [1] 9/22
programmes [1]
192/25
progress [6] 11/20
44/24 128/21 129/19
129/23 143/24
progressed [1] 169/9I
progresses [1]
130/18
project [4] 5/12 5/18
6/10 155/11
projects [4] 5/6 5/20
143/24 143/25
prominent [1] 42/16
prominently [1]
105/6
prompted [3] 78/8
87/10 133/12
promptly [2] 77/16
124/20
proof [1] 39/2
proper [8] 77/25
91/15 95/6 96/13
106/1 106/14 186/17
193/15
properly [17] 8/13
8/25 19/7 24/5 27/11
54/6 78/3 84/3 84/5
84/6 89/14 95/5
130/17 145/9 178/18
185/4 185/13
proposed [3] 83/23
182/5 193/18
proposing [1] 89/7
prosecute [4] 39/1
43/4 188/17 188/17
prosecuted [1]
174/19
prosecuting [1]
146/25
prosecution [6]
103/5 111/25 112/4
156/6 169/24 170/5
prosecutions [15]
37/19 38/11 38/24
39/11 39/13 41/1
44/12 44/18 111/22
113/2 113/5 147/6
147/7 147/10 194/21
prospects [2] 104/9
104/12
prospectus [3]
193/11 195/25 196/7
protect [1] 178/11
protecting [2] 56/8
64/14
protocol [13] 12/15
(73) points - protocol
Pp
protocol... [12] 12/16
12/23 13/4 27/15 28/3)
33/16 54/24 56/6
60/25 62/22 64/13
128/13
protocols [1] 29/20
provide [8] 12/18
15/9 15/13 47/4 54/24}
63/21 66/16 147/24
provided [10] 1/18
29/10 49/15 55/9 55/9
62/22 128/19 159/25
160/8 181/2
providing [4] 17/3
29/19 111/5 129/23
provision [1] 34/11
provisions [1] 71/2
provoke [1] 182/1
public [10] 34/12
101/21 104/25 105/17)
106/4 106/13 151/5
166/7 184/25 190/16
publicly [3] 90/10
110/24 131/17
published [2] 137/24
173/5
punchline [1] 93/4
purpose [7] 11/23
17/4 20/1 48/20 66/14
105/14 170/14
purposes [3] 19/23
21/2 48/20
purse [1] 101/21
pursue [1] 194/1
pursued [1] 71/23
put [17] 28/3 46/13
56/6 62/13 64/12 66/9
74/8 81/24 108/17
110/6 123/10 124/11
124/13 141/7 159/24
179/24 193/9
puts [1] 62/1
putting [1] 25/7
Q
QC [3] 13/6 43/15
73/23
qualifications [1]
136/25
qualified [2] 117/6
117/9
quality [3] 17/6 29/3
54/15
quarterly [1] 128/24
Queen's [1] 108/23
queries [2] 184/16
185/7
query [1] 184/10
question [38] 5/23
8/19 8/21 9/1 9/18
11/4 40/15 40/16
42/22 42/23 43/9
44/15 86/20 101/6
112/9 112/22 113/13
113/17 115/3 115/4
116/13 116/14 116/25)
1417/3 117/6 117/10
122/21 123/8 123/9
123/13 139/5 149/7
156/11 157/14 169/25)
170/24 177/3 188/14
questioned [21] 1/11
74/1 99/14 103/17
118/5 125/9 128/2
134/18 136/11 186/9
191/25 198/4 198/6
198/8 198/10 198/12
198/14 198/16 198/20)
198/22 198/24
questioning [3] 66/7
81/21 147/13
questions [42] 1/15
417 3/15 10/1 31/5
34/8 34/21 45/18
47/20 63/20 63/22
99/2 99/6 99/7 103/18)
116/25 117/23 117/24)
118/18 119/8 124/7
124/12 125/6 127/17
127/23 128/1 131/7
134/16 137/25 146/3
146/5 171/15 176/14
176/20 176/21 177/1
177/5 182/1 185/25
186/1 191/23 196/19
quick [2] 79/5 122/9
quickly [6] 10/13
31/19 55/6 68/8
131/21 133/13
quintessential [1]
112/3
quite [28] 23/23 31/2
31/4 31/19 31/25
33/17 34/7 38/4 54/14
55/5 56/22 63/7 63/16)
65/12 65/18 65/21
77/8 90/13 94/17
105/6 105/23 119/22
122/9 124/7 130/1
145/3 166/12 178/5
quote [2] 115/23
174/17
quote/unquote [1]
174/17
quoted [1] 143/10
RAG [4] 49/16 51/19
60/14 144/23
raise [8] 25/23 41/2
45/13 57/13 77/8
123/17 173/1 183/8
raised [41] 14/23
22/15 31/9 31/16 45/1
45/5 56/12 68/6 79/19)
122/2 155/17 155/23
156/5 156/18 156/23
161/1 161/7 161/18
167/7 168/17 168/25
172/17 173/23 174/22
175/2 175/6 176/2
176/5 176/5 176/17
176/22 176/24 177/7
182/19 183/24 184/2
184/10 185/1 187/20
188/21 190/14
raising [5] 43/18 44/2
159/22 185/2 185/3
random [1] 116/16
rash [1] 86/15
rather [15] 5/21
11/12 15/6 22/20
26/17 60/1 91/1
113/18 115/2 122/1
132/25 169/17 175/6
176/11 188/9
rating [6] 49/16
49/17 51/19 60/14
60/15 60/18
rationalisation [1]
123/19
reach [6] 17/11 30/23
37/6 53/20 89/14
196/12
reached [4] 12/24
47/2 106/10 167/19
reaching [3] 36/21
46/23 190/22
reaction [4] 20/22
69/21 75/16 77/20
reactions [1] 131/7
reactive [1] 20/5
read [22] 2/5 7/23
7/24 8/3 8/9 8/11 8/11
21/21 22/12 39/22
70/17 80/16 85/2 88/9
107/25 114/9 126/18
128/24 137/6 150/13
177/12 180/24
reading [9] 21/23
73/10 75/5 77/21
88/15 105/10 107/17
156/14 195/21
reads [19] 2/4 18/14
29/1 35/2 38/8 50/15
56/1 58/2 59/20 64/4
70/5 72/9 76/6 76/12
81/13 87/13 100/12
130/4 131/9
ready [2] 71/16 136/4
real [10] 9/24 25/14
34/10 65/13 77/3 91/6
102/3 106/1 121/20
122/24
real-world [1] 34/10
realised [1] 83/22
realising [1] 42/18
realistic [2] 23/1
115/11
realistically [2] 23/5
32/8
reality [2] 188/7
191/6
really [32] 10/23
13/24 15/18 23/12
25/19 26/16 29/23
34/1 34/20 37/2 42/9
43/15 44/7 45/6 45/14
54/18 55/20 57/20
59/10 75/10 82/20
90/25 95/17 95/19
119/24 123/16 132/10}
158/18 160/7 185/11
189/8 189/11
realm [1] 183/11
reason [4] 14/15
89/16 123/9 152/4
reasonable [4] 14/24
77/9 101/25 166/4
reasonably [2] 56/16
66/10
reasons [4] 141/12
164/20 165/17 167/19
reassured [2] 116/1
120/16
reassuring [1] 7/14
rebuttal [1] 195/5
recall [24] 13/13
16/22 23/21 27/20
28/20 55/11 74/3
78/19 98/10 98/14
98/15 98/19 117/15
131/15 131/18 149/10}
158/23 159/15 159/17,
171/16 172/20 173/20
173/23 182/5
receive [3] 7/17
29/14 79/10
received [24] 8/23
11/7 17/23 18/19
28/23 31/3 43/14 46/3
48/22 55/12 63/22
69/22 70/15 75/21
80/10 83/16 89/4
95/25 100/18 102/19
120/11 184/11 184/12
186/17
receives [1] 5/15
receiving [13] 6/19
17/7 44/5 54/16 63/8
63/18 71/18 78/4
80/12 98/12 104/10
128/10 161/4
recently [1] 26/23
recipients [1] 70/6
recognise [1] 30/10
recognised [4] 36/3
53/18 97/17 99/1
recollect [1] 44/25
recollection [4]
100/19 101/6 129/25
131/3
recommend [2]
173/25 193/25
recommendation [5]
29/5 29/13 34/25
35/23 189/14
recommendations
[6] 8/9 8/10 8/19
28/18 182/15 185/17
reconcile [1] 1841/6
reconfirmed [1]
101/12
record [6] 59/23
98/20 111/5 128/25
136/20 162/12
recorded [3] 47/24
62/18 178/10
recording [1] 69/11
records [1] 5/9
recover [3] 100/16
101/9 101/21
recovered [1] 103/13
recriminations [1]
195/11
recusal [18] 77/1
77/18 78/16 79/19
80/5 80/20 81/17 83/6I
86/1 86/17 87/7 87/15]
88/17 90/9 91/11
92/17 94/25 96/1
recuse [5] 76/10
76/25 77/15 78/11
87/4
recusing [1] 159/16
red [4] 50/11 53/6
69/18 144/23
redacted [2] 2/19 3/5
redress [1] 127/9
reduce [1] 52/15
reduced [1] 52/6
reduces [1] 52/10
refer [17] 2/8 2/15
3/1 78/22 102/10
107/1 112/16 125/13
125/16 126/5 140/14
143/7 148/21 150/2
155/19 168/12 174/18)
reference [23] 2/21
3/7 16/18 20/11 28/11
49/4 57/10 57/17 70/2
73/12 73/14 78/22
92/19 105/8 112/25
119/21 130/7 136/20
143/8 143/11 157/8
167/15 168/14
references [4] 2/14
112/15 114/6 114/8
referred [16] 57/11
59/18 87/24 98/6
113/10 119/5 131/13
143/18 155/16 155/22)
156/4 158/20 170/11
173/21 180/16 181/7
referring [16] 10/21
51/14 73/15 90/19
91/21 93/1 93/13
118/14 142/2 143/25
(74) protocol... - referring
R
149/8 150/19 157/24
157/25 184/18
refers [2] 177/20
179/13
refined [1] 144/24
refining [1] 20/4
reflect [3] 52/17 73/9
114/11
reflected [4] 58/14
72/23 84/5 128/23
reflecting [1] 62/7
reflections [1]
175/23
reflects [2] 143/5
152/20
refrain [1] 116/1
refresh [1] 98/22
refusal [1] 129/6
regarded [2] 167/1
170/7
regarding [2] 121/5
160/10
regardless [2]
118/23 119/11
register [30] 5/13
26/8 26/20 33/9 33/11
33/19 47/21 47/23
48/2 48/7 48/11 49/2
56/20 57/2 57/5 57/9
57/11 57/23 59/5
59/18 61/23 62/19
69/11 181/23 184/5
189/15
registered [1] 58/2
registers [7] 5/16 6/9
45/13 48/23 54/1
181/21 182/1
regret [1] 190/12
regrettable [1]
129/14
regular [4] 32/11
64/25 65/6 128/19
regularly [1] 6/10
Regulation [1] 194/6
reinforced [3] 9/9
94/4 146/13
reinforcing [1] 169/4
reiterating [1] 89/21
rejection [1] 96/8
relate [2] 8/10 112/18
related [1] 160/7
relates [3] 2/1 62/17
97/18
relating [13] 5/10
13/1 33/8 53/19 59/2
61/21 65/18 69/12
102/16 124/19 158/23}
159/9 176/2
relation [39] 5/19 9/8
referring... [6] 148/22
Refinements [1] 6/13
51/2 51/13 52/23 54/8
45/25 47/22 47/25
48/3 51/19 52/17
55/16 57/14 59/12
62/1 66/5 74/8 98/13
100/4 104/23 121/14
148/8 156/5 171/3
171/4 171/4 187/6
187/18
relational [4] 14/4
46/2 46/6 46/24
relations [1] 194/4
relationship [13]
38/15 40/14 148/3
relationships [1]
82/7
relative [1] 60/5
relatively [1] 26/14
relayed [1] 117/13
releases [1] 105/6
relevant [8] 2/18 3/4
19/3 21/8 21/13 39/5
81/13 86/23
reliable [1] 61/20
reliant [2] 29/23
83/12
relied [1] 71/7
relies [1] 71/5
reluctance [2] 12/3
160/9
reluctantly [2] 88/17
96/1
rely [1] 77/13
remain [4] 1/7 24/21
181/4 194/14
remained [3] 4/15
169/23 170/4
remains [3] 29/11
60/14 194/10
remarks [2] 20/6
195/24
remediation [1]
102/8
remedied [1] 120/15
remember [19] 9/23
31/16 39/19 39/20
42/11 44/5 44/23
48/19 69/7 74/5 83/8
98/20 111/4 111/18
112/6 139/21 144/2
147/8 171/10
remind [1] 1/5
remit [4] 38/10
142/24 143/12 188/18)
remote [1] 9/18
remotely [1] 186/13
remove [1] 195/23
removed [3] 137/2
11/4 13/6 13/11 13/16
22/25 27/8 34/3 39/14
126/20 128/10 129/25)
132/17 132/25 143/13)
15/11 16/5 26/16 37/9)
156/16 158/22 159/12)
159/14 160/11 164/25,
137/6 196/6
remuneration [1]
58/7
repeat [2] 60/3
191/18
repeated [1] 119/6
repeats [2] 60/19
62/18
rephrase [2] 115/19
183/15
replace [1] 178/18
replaced [1] 4/13
replacement [2]
130/15 133/3
replacing [1] 178/24
reply [2] 70/9 186/17
report [28] 9/6 23/18
27/23 28/10 28/15
28/18 28/20 28/22
28/23 33/7 33/13 35/1
36/2 45/9 48/21 66/18
155/10 155/12 157/6
173/5 173/5 176/12
177/11 177/16 179/24
180/12 180/17 195/20
reported [11] 7/12
19/15 37/2 47/24
88/13 100/17 102/9
102/15 102/17 107/4
161/21
reporting [18] 5/5
5/15 26/4 26/19 27/21
30/7 33/6 36/1 36/23
45/8 49/1 55/16 60/1
69/12 141/22 142/19
179/8 179/17
reports [6] 5/10 5/24
7/24 21/23 48/24
128/10
represent [2] 118/6
125/12
representation [3]
165/17 169/18 177/25)
representative [12]
78/15 80/21 80/25
86/4 87/19 90/6 94/12
153/11 154/9 154/18
165/5 166/22
representatives [3]
97/18 99/1 183/7
represented [1]
167/10
reputational [2]
51/20 58/1
request [8] 7/15 7/18
65/6 76/10 78/8 89/6
100/24 169/15
requested [4] 20/16
71/19 100/14 166/5
requesting [1] 98/11
requests [1] 135/12
require [3] 19/5 71/3
179/9
required [10] 65/10
141/8 141/17 142/11
156/3 164/22 174/12
requirements [3]
142/9 151/12 154/15
requiring [1] 40/1
research [3] 104/20
106/16 108/14
reservations [1] 88/8
resign [1] 125/23
resignation [1] 23/12
resigned [1] 138/10
resolution [4] 17/12
21/5 46/15 102/7
resolve [5] 7/6 11/6
19/19 28/4 117/6
resolved [4] 10/2
46/8 109/8 131/21
resolving [1] 10/6
respect [14] 14/25
100/25 105/19 113/21
133/18 142/11 142/21
144/13 145/2 148/8
148/24 161/13 173/23}
174/22
respectfully [1]
191/18
respectively [1]
140/23
respects [1] 111/11
responded [1]
104/16
response [19] 15/14
15/16 19/24 20/19
45/6 45/7 73/9 79/10
79/13 83/15 84/20
85/7 89/6 106/7
112/21 115/1 121/13
131/17 147/15
responses [1]
135/12
responsibilities [11]
26/3 121/15 144/9
148/20 148/22 148/25)
149/7 149/8 149/19
150/19 150/21
responsibility [18]
4/23 26/10 43/3
142/16 142/18 146/19
146/22 148/7 148/17
149/5 153/8 153/18
153/25 154/12 168/22)
174/4 183/5 190/3
responsible [17]
4/21 5/5 6/2 15/24
15/25 36/22 38/23
43/24 48/8 48/10 65/4)
113/1 153/7 153/15
154/24 172/24 172/25)
restate [1] 126/20
restricted [1] 179/4
restriction [1] 166/13
result [7] 20/14 22/11
22/20 52/11 70/17
146/18 149/16 150/17)
76/21 97/6
resulted [2] 134/7
134/11
resume [2] 92/7
196/22
retained [1] 179/16
reticence [1] 160/9
retribution [1] 170/23)
return [4] 43/21
47/12 100/8 124/11
returns [1] 82/16
reversed [1] 110/12
review [33] 5/18 5/18
6/10 6/11 7/11 7/25
8/2 8/19 8/22 28/12
63/4 65/10 70/19
107/18 108/25 109/16)
125/15 143/24 154/19)
168/23 169/5 170/16
170/20 171/9 172/18
173/2 173/22 174/8
174/13 174/21 180/2
186/24 195/14
reviewed [3] 20/19
145/14 177/19
reviewing [3] 143/16
145/22 158/14
reviews [2] 161/13
176/10
revisions [1] 181/22
revisit [1] 128/3
rewrite [1] 58/17
rewritten [1] 58/17
Richard [40] 2/9 4/12
4/13 6/21 13/20 13/23)
18/3 18/15 20/15
20/21 29/22 29/23
30/2 30/3 30/4 33/15
35/25 37/23 38/5 38/7I
38/8 38/9 40/3 68/3
68/4 78/8 79/12 79/14
82/8 83/17 87/14
87/24 91/22 94/19
112/13 155/20 173/21
174/1 176/6 177/5
Richard's [1] 27/5
Richards [1] 30/5
Riddell [1] 186/10
right [103] 1/20 1/24
2/19 2/23 3/5 3/18 4/3}
4/6 4/16 4/18 4/24 5/6
6/23 9/21 11/21 11/25]
12/2 13/2 13/12 16/10}
17/14 20/9 20/17
21/25 22/6 22/13
22/21 24/1 32/25 37/7I
43/7 43/12 43/19 47/8)
47/25 48/2 48/13
49/23 52/3 53/5 55/1
57/16 59/8 61/2 61/13
65/17 66/14 66/21
68/13 68/13 69/18
69/24 71/25 72/4
73/23 74/2 75/3 78/6
(75) referring... - right
R
right... [45] 86/25
87/8 88/6 90/21 96/22
101/19 103/16 107/16
112/9 119/4 119/12
119/19 120/1 120/5
120/9 120/21 121/12
123/8 124/1 124/22
128/12 130/1 131/2
131/4 131/20 132/23
134/13 135/9 135/17
138/2 140/25 142/4
143/1 150/4 158/8
161/3 162/16 183/20
184/20 185/12 185/23
191/11 193/8 193/17
196/21
right-hand [1] 53/5
rightly [3] 42/17
81/19 101/8
rights [3] 17/21
77/18 128/9
ringing [1] 176/7
rise [4] 67/23 82/2
100/4 101/1
risen [1] 175/7
ible [1] 74/12
risk [96] 4/25 5/5
5/13 5/16 5/24 6/9
26/4 26/8 26/9 26/18
26/19 27/21 30/7 33/9
33/11 33/19 34/24
35/9 36/4 36/20 39/23
40/24 41/9 44/11 45/3)
45/13 47/21 47/23
48/11 48/23 49/11
49/15 49/16 50/14
50/18 51/5 51/12
51/25 52/23 53/4 53/4
53/21 54/1 54/9 55/16)
56/14 56/20 57/1 57/5
57/21 58/1 58/2 58/3
58/5 58/15 59/6 59/12
59/18 62/19 65/10
66/21 66/22 69/11
69/17 69/17 72/22
95/24 141/23 142/8
142/16 142/22 144/13}
144/18 144/21 145/2
148/8 157/3 157/6
157/7 163/1 164/17
164/18 181/21 181/22)
181/25 182/9 182/20
182/23 184/5 184/6
185/13 189/15 193/15
194/20 194/25 196/11
risks [44] 5/10 11/24
30/14 33/8 35/6 35/11
35/16 40/5 40/23
40/24 47/24 48/25
49/13 51/20 52/17
53/9 53/15 53/19
56/22 56/24 56/25
58/13 59/2 61/20
61/23 65/18 66/18
67/23 69/12 142/13
145/11 145/22 146/2
163/13 164/6 164/13
181/12 181/13 182/21
184/1 184/18 184/23
194/3 194/10
RMG [1] 193/19
Robert [4] 36/9 53/14
154/22 181/18
Robinson [1] 104/11
robust [4] 16/19 84/7
120/23 186/23
Rod [1] 135/14
Rod's [1] 18/16
Rodric [6] 2/9 18/13
106/23 107/10 107/14)
108/25
Roger [1] 157/21
Rohini [1] 125/11
role [46] 4/15 11/20
12/3 12/7 12/9 13/22
18/6 28/12 30/10 35/7)
66/15 80/8 89/13 90/5)
125/16 128/22 134/22)
135/1 138/9 139/1
139/22 140/2 140/15
140/24 141/17 141/19)
142/21 143/5 143/12
144/12 144/25 145/9
147/24 152/18 152/21
153/15 157/12 160/16)
161/6 165/25 166/24
170/15 172/11 176/3
181/11 190/5
roles [7] 37/24 38/1
138/7 138/13 140/19
142/6 170/18
rooted [1] 114/12
rose [1] 176/23
roughly [2] 44/18
139/21
Royal [25] 112/23
112/25 113/4 144/4
145/16 145/18 148/18)
152/19 153/7 153/16
157/25 158/2 158/11
158/13 158/19 159/8
159/11 161/1 161/15
162/16 162/24 162/25)
163/5 163/5 164/8
RS [1] 181/20
RSRL [1] 28/13
rule [2] 19/9 51/7
ruled [1] 18/17
rules [1] 149/11
ruling [2] 39/6 74/7
run [5] 72/17 108/15
124/7 149/13 182/20
run-up [2] 72/17
108/15
running [3] 25/18
154/13 164/4
runs [1] 1/22
Russell [13] 5/8
26/12 33/22 37/1
79/12 135/5 142/2
144/14 154/22 157/18}
158/21 171/22 172/3
Ss
s/he [1] 84/9
sadly [1] 169/16
safeguards [1] 72/25
safety [4] 107/7
108/25 109/1 109/3
saga [1] 108/2
said [60] 9/4 9/10
14/10 15/17 22/2
23/11 23/11 29/18
34/13 43/13 47/22
48/21 49/5 51/11
51/19 55/3 57/15
58/22 59/1 60/3 68/1
73/4 74/15 74/16
77/24 80/22 85/22
93/10 95/20 97/23
115/20 115/23 115/25)
116/21 117/15 118/17
123/9 125/20 127/2
128/13 129/12 131/2
131/16 133/8 133/23
140/20 149/17 151/15}
152/11 154/14 158/21
164/15 170/6 174/21
177/16 182/16 187/10
188/22 191/7 192/13
sake [1] 15/7
sale [3] 163/9 194/1
194/15
Sam [3] 118/6 130/8
130/8
same [24] 2/23 3/4
3/9 6/4 11/17 57/17
59/17 60/14 60/17
64/10 70/7 85/9 94/7
101/13 106/11 109/13}
113/21 118/24 120/1
128/9 129/15 131/11
133/21 138/20
satellite [1] 21/4
satisfactorily [1]
177/19
satisfactory [1]
106/9
satisfied [2] 162/11
182/9
satisfy [6] 145/10
150/16 151/7 152/11
164/23 166/23
saw [8] 16/25 25/15
32/25 36/18 82/8
87/10 116/25 129/6
say [124] 4/24 5/4
6/25 8/6 10/21 12/2
13/14 15/15 16/16
16/18 26/14 30/15
32/13 32/25 41/2
42/10 42/23 44/23
45/14 45/23 48/9 51/5)
53/22 62/24 63/18
63/23 68/10 69/5 69/6
71/9 72/6 75/1 78/13
78/25 83/18 83/19
87/11 87/22 88/18
90/9 90/10 93/9 93/22
94/1 94/1 95/14 95/24)
97/6 102/9 105/9
107/23 107/24 108/3
108/17 109/15 110/2
111/20 114/5 114/20
114/21 118/22 118/25}
120/8 120/17 121/19
122/18 127/11 128/6
128/14 129/15 130/9
131/23 133/15 134/9
135/11 138/25 139/12
140/15 143/4 144/25
148/13 152/16 153/3
153/14 153/18 153/21
154/11 155/5 155/15
155/25 157/21 157/23}
159/13 159/19 160/18
160/24 161/7 162/10
162/24 163/2 164/19
168/14 169/22 169/25)
171/2 1714/7 171/10
173/14 174/21 175/23
175/24 179/12 179/25}
180/6 180/25 181/6
181/8 182/17 184/9
186/16 186/19 186/21
187/19 194/16
saying [43] 8/12 8/16
9/6 33/10 52/1 52/4
52/7 57/20 68/9 75/6
86/11 94/7 94/9 94/13)
94/14 95/16 95/17
96/22 97/10 106/15
108/19 109/16 110/7
110/8 110/9 110/9
110/10 110/10 111/3
111/4 113/7 118/20
121/8 121/23 122/22
130/22 140/24 149/5
149/6 166/10 173/24
175/21 189/12
says [34] 51/15
70/13 79/15 80/18
83/16 84/23 85/12
89/8 93/24 95/25
96/13 106/19 109/14
109/19 120/22 130/16
137/2 140/14 141/21
143/10 143/19 147/23}
150/10 151/18 159/6
165/16 165/18 173/19
177/16 177/22 179/2
181/24 189/24 192/9
scandal [1] 127/8
scenario [1] 46/23
sceptical [1] 70/25
schedule [3] 176/1
182/18 183/24
Scheme [1] 7/8
scope [4] 38/10 56/3
64/6 145/23
scoring [1] 67/13
Scott [7] 33/16
104/19 105/12 106/19}
109/23 110/3 112/12
screen [2] 110/6
155/14
script [2] 89/6 89/17
scroll [19] 18/1 19/14
28/24 49/10 49/21
52/20 57/17 59/11
70/2 76/3 78/23 79/13}
81/10 83/15 93/8
94/18 100/11 104/18
110/19
scrolling [1] 52/21
scrutiny [1] 161/15
sealed [3] 178/17
178/18 178/23
sealed’ [1] 178/11
second [25] 2/7 7/7
7/25 9/5 35/1 56/4
64/11 76/4 83/2 92/3
96/12 136/25 155/10
167/6 167/15 167/23
168/15 168/23 173/2
173/5 174/9 176/12
177/20 186/24 190/5
secondly [5] 42/4
46/11 76/20 137/5
168/6
Secretary [36] 23/25
24/19 24/25 32/9
32/16 36/14 54/22
55/10 56/7 62/21
64/13 64/18 65/7 78/6
80/14 85/15 89/10
129/21 131/18 131/25)
140/16 148/15 148/19)
148/21 149/6 149/17
149/18 151/10 152/17
153/12 154/8 154/11
154/17 158/7 162/20
183/21
section [1] 28/15
sections [1] 125/13
securing [1] 129/2
see [72] 1/3 7/15
7/18 18/2 20/24 20/24I
28/25 32/15 37/4
39/18 47/17 49/9
49/14 49/19 50/6
59/11 60/15 70/3 70/7I
71/19 76/4 77/6 78/24)
79/13 81/2 81/8 83/15
85/8 90/18 91/25
92/12 92/24 93/7 94/9I
96/12 99/2 100/10
100/13 101/20 102/16
(76) right... - see
Ss
see... [32] 102/22
105/1 105/17 105/23
106/13 107/2 107/9
108/5 115/8 119/20
121/12 125/4 125/10
136/2 136/6 137/14
140/13 140/14 143/22
144/12 150/14 152/1
155/9 159/3 162/7
163/5 165/14 165/18
177/22 178/15 189/13
193/22
seek [3] 77/15
150/24 192/14
seeking [1] 105/13
seeks [1] 66/10
seem [7] 15/11 22/25
38/13 43/18 72/24
127/18 156/11
Seema [4] 103/19
105/5 107/5 109/23
seemed [15] 10/9
10/15 10/18 15/18
15/25 16/5 17/10
17/19 34/21 46/21
47/4 75/6 75/13 82/14)
91/15
seems [3] 81/24 85/2
189/8
seen [17] 20/19
28/19 28/22 32/13
32/13 36/2 53/10
79/25 81/20 82/5 82/6
82/11 82/12 85/11
165/2 177/13 192/16
sees [2] 53/25 53/25
seesaw [1] 123/17
segment [1] 171/11
selected [1] 160/16
self [2] 166/12 169/4
self-imposed [1]
166/12
send [1] 78/9
sending [1] 194/21
senior [6] 33/4 68/24
123/23 125/18 125/22)
153/10
seniors [1] 35/21
sense [15] 15/18
16/12 23/12 41/23
46/16 63/7 67/16 75/6
83/19 90/2 102/3
141/10 161/21 161/23)
170/8
sensible [2] 84/24
85/4
sent [3] 106/19 110/2
155/9
sentence [7] 58/16
73/12 83/3 86/12
93/23 137/1 178/15
sentences [1] 149/9
separate [3] 5/14
64/21 94/15
separated [1] 158/2
separation [3] 113/1
160/25 164/19
September [8] 2/16
54/25 139/23 139/24
193/4
September 2013 [1]
139/24
serious [8] 25/8
43/21 44/3 52/8 57/21
59/6 76/21 156/5
seriousness [1]
83/23
services [5] 34/11
138/10 159/15 159/21
160/7
serving [1] 4/18
session [1] 99/11
set [10] 18/25 32/1
88/8 88/16 143/16
149/14 150/11 176/6
178/17 180/22
set-up [1] 32/1
sets [3] 51/24 143/11
186/1
setting [2] 34/8
143/14
settle [1] 133/24
settled [1] 134/14
settlement [12] 65/9
99/21 100/9 100/11
100/16 101/22 101/25)
102/1 129/19 134/7
134/11 157/7
seven [2] 117/25
118/24
several [7] 7/1 11/11
30/5 37/22 49/13
80/10 177/13
severely [1] 170/9
SHAH [3] 125/9
125/11 198/12
shall [7] 47/10 47/12
51/23 92/5 92/7 163/2
186/6
shall I [1] 51/23
Shanice [1] 112/13
share [2] 12/4 82/14
shared [2] 73/6 79/20)
shareholder [89] 4/6
4/14 4/19 5/1 6/14
12/14 18/7 29/11
29/16 30/10 31/22
35/20 38/1 48/13
61/18 62/7 65/14
66/15 80/4 80/19
80/21 80/25 81/23
83/24 86/4 91/14
94/11 95/2 132/12
140/8 140/17 141/5
143/13 144/16 146/16)
141/13 168/13 181/19)
147/5 147/25 149/20
150/5 150/7 150/9
151/1 151/4 151/6
151/13 151/24 152/1
152/6 152/9 152/21
153/12 154/3 154/6
157/11 157/15 158/14
160/15 161/12 161/14)
162/19 162/25 163/22
165/4 165/21 165/25
166/24 167/1 171/21
172/23 174/3 175/8
176/3 176/18 177/5
180/15 180/21 181/11
181/17 183/3 187/15
189/21 190/19 190/21
191/6 191/14 191/19
shareholder's [2]
80/23 145/17
shareholders [1]
121/18
shareholding [3]
89/19 151/25 158/7
shareholdings [1]
148/17
shares [3] 163/9
193/15 194/1
sharing [4] 12/16
29/15 165/20 166/13
she [22] 15/17 27/4
55/7 69/23 71/9 71/13
73/4 74/16 95/2 96/14,
96/15 107/25 113/16
130/12 130/20 131/5
149/22 165/18 165/20
165/20 167/1 167/2
she'd [1] 108/1
sheet [1] 168/10
ShEx [56] 115/7
115/10 141/17 141/19}
141/23 142/11 142/19}
142/20 142/24 143/5
144/12 146/6 146/18
146/23 147/1 150/3
153/5 153/12 154/11
154/18 155/6 155/17
156/1 156/2 156/2
156/4 156/7 156/12
161/5 164/12 164/21
165/17 166/2 166/16
168/22 171/5 172/9
175/25 176/3 180/1
182/10 182/18 183/18}
184/11 184/11 184/15}
186/22 186/25 187/5
187/12 187/23 188/24I
192/17 193/17 195/23
196/4
ShEx's [4] 190/5
shifted [1] 162/19
shocked [2] 71/22
72/10
shocking [1] 73/2
150/11 150/12 150/15}
short [12] 47/15 51/8
68/22 68/23 74/22
87/10 90/18 92/10
125/2 125/6 127/22
162/5
short-term [1] 51/8
shortcomings [1]
182/12
shortening [2]
180/16 180/17
shortly [7] 13/4 37/15]
78/4 137/25 144/7
147/20 167/6
shots [5] 107/5
107/22 108/10 108/11
108/18
should [108] 1/18 2/5)
2/10 2/12 15/5 15/9
15/12 15/24 16/4 16/6}
16/19 21/7 23/2 23/22,
29/9 31/1 35/3 35/5
35/7 35/16 37/1 38/24)
46/17 46/22 58/17
62/12 65/9 78/11 80/4,
80/19 81/16 81/20
82/23 84/19 85/17
85/19 88/19 89/10
89/15 93/14 93/19
95/12 95/18 95/19
95/25 96/2 96/3 96/19
101/16 102/7 108/24
112/16 112/20 112/22}
117/12 120/23 121/9
123/17 126/13 129/1
136/17 137/2 137/5
137/6 137/13 143/21
150/24 151/2 151/6
152/1 156/8 156/12
156/19 157/9 157/21
159/13 163/21 164/1
164/17 166/2 169/6
173/20 175/7 176/13
176/19 176/24 177/4
179/25 181/8 182/1
182/16 183/10 183/10
185/7 185/8 185/18
186/4 188/20 188/22
190/19 190/20 191/10)
191/12 194/1 194/2
194/12 194/15 195/17
shouldn't [4] 37/2
83/3 86/11 88/22
show [2] 93/17 111/1
shown [4] 28/20 50/1
51/21 102/18
side [7] 33/6 34/4
34/23 36/16 110/25
159/8 159/15
sides [1] 10/15
sight [17] 7/7 7/25
9/6 155/10 167/6
167/23 168/16 168/23}
173/2 173/5 174/9
176/12 186/24 187/9
187/23 188/25 189/5
Sight's [1] 167/15
sighted [2] 23/22
28/8
sign [5] 126/9 126/11
126/13 126/17 127/5
signalling [1] 23/1
signature [3] 136/22
137/13 137/16
signatures [1]
178/19
signed [3] 33/16 74/9
185/2
significance [9]
50/11 81/8 100/2
176/7 181/13 183/8
190/3 191/2 191/21
significant [47] 11/24I
14/11 16/22 27/6
47/24 51/6 51/9 53/12
53/21 54/15 58/3 60/9I
67/23 75/4 77/8 79/7
121/2 122/3 134/6
156/8 157/1 157/3
157/8 166/12 167/24
168/16 176/1 177/20
178/5 181/7 181/23
182/2 182/3 182/19
183/9 183/24 184/2
184/3 187/22 187/22
188/5 188/24 189/4
190/13 191/5 191/9
194/10
significantly [2]
65/19 169/8
silk [3] 54/12 60/21
62/3
similar [1] 114/8
simple [5] 40/10
40/12 45/22 45/23
186/17
simpler [1] 40/13
simplistic [1] 101/14
simply [2] 39/1 101/4
since [4] 95/8 96/14
138/13 179/17
single [1] 176/22
sir [40] 1/3 1/5 1/8
41/19 45/16 47/17
47/19 92/2 92/12
98/24 99/4 99/15
115/15 117/24 117/25)
118/4 124/6 124/23
125/4 125/6 127/25
134/18 135/3 136/1
136/6 136/8 162/1
162/3 162/7 171/8
175/16 184/4 184/8
185/25 192/11 193/9
196/20 196/23 196/25]
198/16
Sir Wyn [2] 41/19
135/3
sit [5] 60/23 123/14
(77) see... - sit
Ss
189/18 196/21
sits [2] 103/19 107/6
situation [6] 15/19
183/2
situations [1] 188/7
six [6] 49/3 57/9
192/23
size [3] 145/13
145/23 169/15
skills [4] 146/18
148/16 153/5 185/12
skillset [1] 146/13
Slaughter [1] 14/8
slightly [7] 64/4
84/20 99/5 99/8
417/17 152/7 177/3
slower [1] 68/17
small [2] 31/23
171/11
Smith [1] 186/12
smoking [2] 9/7 9/8
so [256]
software [1] 175/3
solicitors [2] 73/16
118/9
solve [1] 66/24
solved [2] 17/13
134/13
some [66] 1/23 2/13
3/4 3/15 14/23 15/1
21/13 27/6 28/17
32/20 38/12 39/1
39/23 46/14 47/20
50/8 50/20 54/14 55/8
63/10 72/10 73/2 77/8
77/10 78/9 89/4 92/16)
92/23 95/1 95/13
104/20 105/11 106/25)
110/22 111/11 111/22)
111/23 112/19 125/6
125/13 127/25 131/6
134/24 135/6 137/25
143/7 143/22 145/7
146/15 147/15 155/2
155/9 163/21 164/15
167/10 168/21 171/22)
171/24 173/15 174/6
175/13 175/15 179/12)
182/12 182/14 185/15}
somebody [1] 111/17I
somehow [1] 74/10
someone [2] 114/4
147/2
something [19] 5/7
9/24 31/16 41/6 41/10
42/7 66/10 74/16
89/16 116/24 117/2
123/14 123/18 133/8
133/21 134/25 156/22)
sit... [3] 124/18
81/6 94/15 97/2 109/6
101/16 117/25 164/19}
165/23 184/1
somewhat [2] 62/6
195/19
somewhere [1] 74/11
sophisticated [2] 6/5
6/7
sorry [37] 13/22 18/9
30/3 30/4 33/13 39/18
39/18 42/15 43/9
46/12 50/13 57/24
64/23 66/12 69/14
84/22 94/18 107/24
110/17 113/3 113/17
127/18 127/20 129/7
130/12 134/9 140/14
149/4 157/14 171/8
173/16 176/25 178/8
182/15 183/15 184/7
196/25
sort [18] 10/24 12/6
22/24 24/5 42/9 44/24
55/23 93/3 95/1 95/13)
119/22 122/10 135/1
148/10 187/14 188/2
188/12 188/20
sought [12] 20/14
73/5 75/23 76/9 76/13
76/16 78/5 87/21
101/2 101/4 101/20
189/19
sounding [1] 36/8
source [5] 9/5 13/25
30/12 50/4 61/18
SpAds [2] 54/22
62/20
speak [3] 37/3 124/5
135/2
speaking [4] 5/21
80/12 107/14 109/14
special [1] 91/9
specific [14] 8/6 29/9
29/13 35/18 36/5
46/18 48/2 100/5
112/21 113/13 113/20)
135/15 143/17 177/1
specifically [5] 105/4
142/18 143/20 146/8
163/8
specifics [1] 155/2
speculative [1] 69/6
speed [2] 10/25
62/25
spend [2] 139/6
139/15
spent [5] 23/23
105/23 140/4 145/3
157/17
spin [2] 133/25 164/7
spin-off [1] 164/7
split [4] 165/2
Spoke [1] 196/25
spoken [1] 97/6
sponsored [1]
168/20
sporadic [1] 116/16
springs [1] 185/8
staff [5] 167/3 178/3
178/17 179/7 179/18
stage [26] 7/20 9/1
23/13 24/10 24/14
37/13 49/23 56/15
56/21 61/1 62/5 63/7
129/2 163/21 164/3
stage’ [1] 77/15
stages [3] 56/8 64/14
102/12
stake [1] 13/15
stand [2] 24/22 84/9
standard [2] 19/2
147/13
standards [2] 145/7
145/15
standout [1] 15/2
stands [1] 137/23
start [15] 7/21 21/18
22/23 31/24 47/10
68/18 70/4 92/24
107/17 116/3 124/10
124/24 138/1 140/18
180/9
started [10] 3/17
61/7 69/9 75/14
139/21 140/9 144/25
160/21 176/22 192/9
starting [1] 61/17
state [18] 72/2 89/10
131/18 131/25 136/12
140/16 148/15 148/19}
149/6 149/17 149/18
152/17 153/12 154/12
154/17 158/7 162/20
163/6
State's [2] 148/21
154/8
stated [6] 28/14
51/16 71/4 137/18
195/15 195/18
statement [78] 1/17
1/19 1/22 1/23 2/8
2/15 2/25 3/12 5/4
6/19 11/18 16/12
16/17 20/7 22/5 23/11
31/10 37/12 71/4 71/7I
71/22 72/7 72/15 75/1
77/20 78/13 78/22
87/2 87/11 99/16
105/23 118/12 119/5
125/14 125/16 126/4
128/7 130/23 130/25
131/9 132/3 134/20
135/19 136/17 136/20}
136/23 137/9 137/19
137/24 138/25 139/12
140/12 140/24 141/3
141/20 143/4 148/12
9/13 9/25 13/14 16/13
63/11 67/6 88/2 113/5
174/24 176/13 194/13
149/5 149/16 150/3
152/15 155/4 160/23
189/24 192/9 196/18
states [2] 77/6 89/25
status [5] 49/18
55/22 64/3 143/24
161/1
statutory [1] 26/23
stay [4] 34/7 62/11
94/8 178/9
stayed [1] 138/23
steal [1] 43/6
Stein [4] 118/3 118/5
118/6 198/10
step [5] 32/2 84/3
129/16 159/7 159/10
step-up [1] 32/2
Stephen [6] 37/25
38/3 38/4 59/14
157/18 186/15
stepped [1] 76/14
steps [9] 11/25 44/21
99/25 142/12 145/1
151/7 152/1 152/11
166/23
Stevens [8] 124/15
136/2 136/11 183/23
184/7 186/8 196/24
198/20
stick [1] 146/4
still [9] 10/24 24/24
61/6 61/8 114/18
120/8 120/10 121/4
158/11
stock [1] 71/6
stolen [3] 38/21 39/2
40/9
stood [1] 94/23
stop [4] 110/7 121/24
124/9 190/21
stopped [1] 44/24
stopping [1] 86/9
Store [2] 178/10
178/24
Storey [8] 157/20
158/16 158/17 158/25)
160/14 160/16 165/16
166/24
stories [5] 104/24
105/10 105/16 192/24}
193/4
story [2] 103/14
110/25
straight [1] 108/17
straightaway [1]
118/11
straightforward [1]
16/25
strategic [4] 83/25
162/11 168/12 169/23}
170/11 173/16 175/10}
177/12 180/20 182/13)
184/17 186/19 188/22)
statutorily [1] 149/14
143/14 147/25 150/16
strategy [7] 27/12
44/9 84/2 114/23
133/17 134/7 134/10
strength [1] 91/10
strictly [1] 80/12
strike [3] 17/17 18/18
161/16
strikeout [5] 19/1
20/1 24/2 24/3 37/16
strong [12] 16/12
41/23 42/14 45/24
67/8 69/2 74/1 74/25
77/11 102/6 119/6
194/11
stronger [3] 84/21
88/11 88/13
strongly [5] 67/10
86/14 118/15 119/5
123/4
struck [3] 40/20 71/2
75/4
structural [1] 31/14
structure [2] 164/7
181/1
structures [2] 141/23
180/23
studies [1] 137/3
stuff [2] 68/10 122/7
stupid [1] 51/23
style [3] 39/7 90/22
91/5
subcommittee [7]
12/10 30/12 41/18
72/21 100/14 101/3
101/7
subject [4] 3/11 12/5
95/10 137/19
subjective [1] 69/2
submissions [1]
21117
submitting [1] 43/20
subparagraphs [1]
155/8
subpostmaster [7]
43/20 74/9 118/7
179/10 186/10 188/2
189/9
subpostmaster/mistr
esses [1] 118/7
subpostmasters [34]
6/16 7/3 13/18 44/13
46/2 72/12 103/19
116/18 118/22 125/13}
126/9 127/5 131/20
146/25 147/16 156/7
156/17 167/10 169/24I
170/5 171/12 173/12
174/18 179/8 187/20
188/17 189/18 190/11
190/14 190/17 191/16)
192/14 192/20 194/20)
subpostmistress [1]
188/3
(78) sit... - subpostmistress
Ss
subscribe [1] 193/14
subsequent [4] 81/2
86/25 96/11 129/19
subsequently [4] 4/1
36/17 146/12 170/18
substance [7] 13/1
22/21 23/3 60/1 90/22
91/5 171/16
substantial [2] 17/17
161/4
substantially [1]
59/17
substantive [1] 67/16
substantively [1]
93/19
successful [3] 7/8
18/21 114/24
successfully [1]
59/23
such [20] 17/3 50/18
64/10 76/15 82/25
95/14 129/2 142/13
144/1 144/3 149/12
164/22 166/20 167/5
167/12 168/16 169/23
170/4 185/20 189/18
sufficient [5] 38/25
124/15 141/4 183/20
195/6
sufficiently [2] 75/2
188/4
suggest [11] 31/10
67/19 105/12 105/15
108/24 110/14 110/16)
125/21 134/20 164/21
182/15
suggested [2] 41/6
84/11
suggesting [5] 63/15
85/3 89/16 110/7
132/2
suggestion [5] 41/4
113/9 113/18 144/8
185/17
suggests [5] 77/12
84/14 85/19 109/21
109/25
suitability [1] 160/19
suitable [1] 172/11
suitably [1] 178/16
sum [4] 97/14
summaries [3] 45/21
54/3 59/4
summarise [1] 56/16
summarised [6] 5/16
48/24 49/14 53/25
93/10 181/25
summarises [1]
150/12
summarising [1]
54/5
summary [5] 57/23
58/1 58/15 98/3 130/2
summed [1] 115/20
summer [4] 17/5
23/5 116/22 135/5
Sunderland [1]
186/11
superfluous [1]
185/24
supine [2] 115/5
115/9
supplement [1]
146/15
supply [1] 159/21
support [7] 25/25
26/1 68/3 88/17
127/10 167/18 192/14)
supported [2] 88/20
114/24
supporting [2] 16/4
82/25
suppose [2] 113/16
183/25
Supreme [1] 76/14
sure [13] 6/9 27/10
28/6 39/12 41/16
42/15 59/2 82/9 83/11
101/7 107/15 107/25
123/21
surely [1] 194/24
surfaced [2] 68/6
184/19
surprise [2] 110/15
168/21
surprised [4] 20/7
21/14 24/24 118/4
surprises’ [1] 151/3
Susannah [9] 157/20
158/16 158/17 158/24)
160/14 160/16 165/16)
166/8 166/22
suspension [1]
126/24
suspicious [1]
130/13
Swales [1] 112/13
Swannell [4] 53/14
115/20 154/22 181/18)
Swannell's [1] 36/9
Swift [3] 8/2 8/18
8/22
Switzerland [1]
194/14
sworn [3] 1/9 136/10
198/18
swung [1] 86/1
Syndicate [2] 139/19
140/1
system [34] 8/11
8/14 8/17 8/25 9/8
9/10 9/16 15/9 15/10
17/4 38/18 40/8 47/4
56/5 64/12 101/17
116/8 116/15 121/5
156/6 159/23 160/6
160/6 167/12 167/17
167/21 169/2 169/5
174/16 177/2 180/5
182/24 188/9 192/15
system-wide [1]
116/15
systematic [1] 9/6
systemic [7] 8/18
116/2 116/2 116/6
116/13 167/16 169/3
systems [1] 174/17
T
tab [1] 49/9
table [1] 146/14
tack [2] 22/18 46/17
tactics [3] 21/7 22/3
22/9
take [53] 4/8 8/12
11/25 14/19 17/23
28/2 28/10 28/17
38/16 44/21 45/2
45/16 46/20 49/2
52/25 57/8 72/6 76/2
78/21 84/4 84/9 84/12
85/4 85/4 87/25 91/16
92/3 96/19 98/22
98/25 99/8 104/17
107/5 107/22 108/10
108/18 111/21 114/25}
118/11 124/14 124/17]
128/16 132/8 136/21
142/12 145/1 145/2
161/6 166/23 192/6
193/14 196/24 197/1
takeaway [1] 42/12
taken [13] 42/20
46/17 52/4 54/8 83/10
84/2 100/1 151/7
152/1 152/18 169/6
180/1 188/6
takes [3] 55/18 68/21
184/1
taking [6] 17/10 64/9
78/1 145/7 152/5
170/15
talk [11] 24/20 26/14
30/24 31/17 32/18
56/18 75/7 94/2
100/23 121/2 129/13
talked [2] 33/21
121/25
talking [11] 39/12
39/13 75/14 78/1
105/24 110/18 115/10
147/17 157/14 189/1
189/1
talks [4] 51/15 90/14
94/2 163/6
tampered [1] 178/12
Tasila [2] 111/18
111/19
tasked [1] 104/20
tasks [1] 141/10
team [96] 4/6 4/8
4/11 5/12 6/14 7/13
8/15 9/9 12/14 14/8
18/7 23/8 23/23 26/10}
31/15 31/19 31/21
31/22 31/23 32/5
32/16 32/20 32/22
32/25 33/12 33/12
33/13 33/15 33/19
35/20 36/24 38/1 38/4)
41/23 48/8 48/13
48/15 50/2 50/9 54/1
54/3 58/11 58/20 60/5)
61/3 62/3 63/8 72/16
73/7 73/13 73/15
73/16 74/20 75/18
78/1 82/13 88/22 94/5)
97/22 97/22 106/12
111/10 111/24 113/4
117/16 120/12 121/11
121/14 122/4 122/23
126/3 126/18 129/1
132/12 133/3 133/10
133/12 135/14 135/16}
142/10 142/18 156/2
157/11 157/19 157/20}
158/10 160/10 169/2
172/6 174/3 174/11
177/6 186/23 186/25
187/5 187/23
team's [2] 45/7 53/7
teams [3] 5/17 5/19
184/11
technically [1] 141/1
Telegraph [1] 65/2
telephone [1] 73/22
tell [1] 56/25
telling [4] 67/6 96/18
107/6 121/3
ten [2] 186/3 193/4
tension [1] 184/5
tenure [5] 9/13 49/4
101/11 147/9 193/3
term [5] 9/7 39/25
51/8 101/14 149/22
terminated [1] 109/7
terminations [1]
126/24
terms [41] 5/9 7/12
7/14 14/17 24/15
25/12 26/18 34/24
35/18 39/24 40/10
41/19 45/8 47/1 51/4
53/6 66/4 82/10 84/21
89/3 99/4 101/19
102/21 106/20 122/8
122/15 124/4 127/6
127/9 132/20 143/8
143/11 146/17 156/18)
161/8 161/9 162/18
164/4 167/15 180/17
183/23
test [5] 1/6 11/1 77/4
129/24 146/3
text [3] 50/11 50/20
51/1
than [24] 5/21 6/5 6/8
10/2 11/12 15/6 22/21
26/17 40/13 60/1 67/3
68/8 88/13 91/1
101/16 117/6 122/4
126/1 132/25 135/12
139/18 161/15 176/11
188/19
thank [85] 1/4 1/5 1/8
1/14 1/15 2/7 2/13
3/11 3/15 6/14 26/21
28/24 37/12 38/8 47/9
47/18 47/19 49/8 49/9
50/24 54/7 64/21 70/3
70/10 72/8 76/4 92/1
92/2 92/13 92/14
93/12 94/21 99/15
99/15 103/16 117/21
117/22 124/1 124/2
124/23 124/25 125/5
127/17 127/25 128/7
130/22 131/6 134/16
134/17 135/17 135/18
135/22 136/1 136/4
136/7 136/8 136/12
136/15 136/16 137/9
137/9 138/16 141/3
143/22 144/11 148/10]
148/13 152/14 155/4
155/14 156/10 162/3
162/8 163/5 165/11
175/20 184/8 191/23
192/11 196/13 196/14
196/15 196/20 197/2
197/3
that [1106]
that I [4] 173/24
that's [65] 1/25 2/20
4/22 23/10 29/5 33/5
35/22 40/3 41/16 49/8
49/23 52/9 52/12
56/12 58/2 62/15
66/10 66/21 70/10
80/16 82/14 88/3 96/1
96/3 96/3 96/10 98/7
99/18 104/15 104/19
110/16 112/7 118/12
118/15 118/19 121/8
127/3 128/13 131/1
138/22 140/11 1414/1
142/5 151/15 152/7
152/7 155/5 155/18
157/5 162/14 171/14
172/2 173/5 173/8
173/18 175/12 177/3
183/8 187/3 188/1
189/14 191/11 193/7
194/23 196/23
theft [1] 38/25
their [37] 5/20 21/7
24/7 29/11 32/23 36/7I
37/8 37/24 38/1 40/7
(79) subscribe - their
T
their... [27] 51/10
54/11 55/19 59/24
63/8 63/9 74/9 74/11
95/7 103/6 103/10
104/24 109/24 113/4
116/11 124/12 147/16)
169/4 170/24 178/11
179/8 183/7 186/15
189/19 189/20 190/18)
191/16
them [48] 11/25
12/17 14/9 14/16 15/1
17/1 27/19 29/10
31/25 32/10 32/12
37/4 43/4 55/18 60/10)
73/18 75/12 77/8
79/20 96/10 99/3 99/3,
103/4 104/22 105/17
106/17 109/23 121/19}
123/3 123/4 125/15
129/11 143/23 148/1
148/2 172/22 173/25
174/10 178/18 181/13}
181/14 188/17 188/18)
190/12 190/20 191/2
191/10 192/24
themselves [1] 23/8
then [86] 2/13 3/20
5/13 5/17 9/18 12/11
17/16 25/4 28/7 30/2
32/22 33/6 43/24
46/11 46/13 47/5
48/18 48/19 48/23
49/15 49/21 50/9
50/14 51/4 52/3 54/7
54/8 54/19 55/6 55/8
58/8 61/16 77/14
80/25 82/11 88/18
90/10 96/16 98/19
100/6 102/10 102/21
102/22 104/10 109/19}
112/5 112/8 113/4
114/20 115/19 116/24}
117/13 119/15 121/2
124/3 126/2 127/4
131/23 134/2 138/13
140/15 140/23 141/19}
143/22 144/22 144/24)
150/8 150/13 153/18
154/11 155/10 163/7
164/5 176/22 178/1
179/1 179/12 187/4
187/18 189/17 191/14}
192/6 193/22 194/3
194/7 196/25
there [182] 1/5 5/23
5/25 9/7 9/11 9/18
9/24 9/24 10/9 11/13
12/11 12/22 13/15
18/2 20/20 26/8 27/6
27/15 27/16 28/19
30/6 30/22 31/11
31/14 31/20 31/25
32/2 33/5 33/20 34/10)
36/18 38/17 38/20
39/9 39/23 40/8 40/25
41/9 41/23 42/8 44/7
48/2 48/17 49/10
49/11 49/14 50/1 50/9)
50/20 50/21 51/18
51/21 52/7 52/8 53/9
53/10 57/13 58/3 58/4
58/9 58/18 59/12
59/15 60/15 63/19
63/21 64/2 64/25
66/10 66/25 70/3 70/6
72/18 74/3 74/22
74/25 75/4 75/15
76/20 77/3 77/24 79/4
80/4 80/9 81/1 81/4
81/18 83/8 83/11 84/5
84/16 85/9 86/1 95/19
97/24 98/16 99/5
99/23 100/7 100/10
101/10 101/17 102/3
102/5 102/9 102/18
105/12 105/15 107/9
107/12 107/20 111/23)
113/8 113/13 117/22
118/24 122/4 123/3
123/15 124/3 125/6
125/14 126/23 129/16)
131/11 135/15 136/24)
137/13 138/23 140/14}
140/20 142/22 143/10)
143/23 146/3 146/17
147/10 150/14 151/20)
152/4 152/23 153/2
156/15 156/15 159/8
160/9 161/23 163/12
164/9 164/20 166/7
167/12 167/16 168/2
168/2 168/14 168/14
170/8 170/21 171/11
175/5 176/16 177/7
178/9 180/10 181/1
182/11 183/14 183/16)
183/16 184/4 184/13
184/25 185/2 185/18
186/1 189/14 192/12
194/10 195/8 195/10
195/11
there's [31] 8/17
37/13 49/12 50/20
51/5 53/23 59/8 59/19
60/4 64/21 84/18
88/24 89/22 96/15
106/18 110/2 111/16
113/10 113/12 119/20}
122/23 131/4 136/22
152/23 155/8 155/10
155/11 159/5 168/8
189/8 189/11
thereafter [1] 189/4
therefore [13] 2/21
3/7 44/11 48/15 72/19
97/10 101/17 123/9
123/13 134/6 154/1
195/9 196/2
these [53] 7/8 11/6
15/5 15/16 25/3 34/7
41/19 41/25 41/25
42/15 54/1 54/5 58/5
61/12 72/17 72/20
72/23 82/15 96/18
108/15 110/24 111/24
117/19 118/10 119/8
131/8 131/21 140/19
141/23 141/24 149/9
150/19 151/8 151/12
151/12 156/8 162/11
165/9 165/14 168/19
170/6 172/21 175/21
184/19 188/7 189/24
190/3 190/13 190/16
190/24 191/7 191/9
194/10
they [94] 6/12 10/16
10/16 14/7 14/9 15/25)
21/10 23/9 23/9 24/6
24/6 27/18 27/19
30/25 30/25 31/1
31/20 32/24 33/18
33/23 37/1 40/23
40/24 40/24 41/2 42/6
43/6 43/22 43/24
50/19 50/22 51/10
54/12 55/19 60/22
63/25 72/21 74/9
75/10 75/11 79/22
82/13 93/16 102/7
103/9 104/9 104/23
107/18 117/1 117/8
117/18 122/16 122/19}
123/3 123/24 126/19
129/12 132/18 137/22
149/10 150/21 154/14
154/22 155/24 156/25}
157/2 157/3 169/4
170/23 171/24 172/4
172/19 173/3 174/13
174/16 178/6 178/7
178/12 178/18 183/7
185/7 185/12 185/23
186/14 186/16 186/17
188/23 189/19 190/1
190/13 190/15 190/24
191/5 191/5
they'd [3] 31/3 134/1
168/3
they're [9] 32/9 33/5
36/8 63/9 90/25
121/22 122/24 133/4
161/16
thing [13] 8/8 14/19
34/5 61/14 69/16
86/15 91/15 94/7 94/8
95/3 106/11 191/11
193/10
things [25] 6/12
24/17 26/13 28/5 30/2
30/17 32/19 34/17
40/15 41/24 44/7 54/5)
60/10 61/12 74/6 79/4
84/25 103/2 103/4
108/1 115/12 115/21
126/23 158/18 175/22)
think [290]
thinking [6] 16/23
58/20 58/22 67/3
110/5 185/6
thinks [1] 62/13
third [3] 2/3 55/7
178/15
this [343]
THOMAS [4] 1/10
1/13 107/20 198/2
thoroughly [1] 104/6
those [68] 1/16 2/1
3/5 3/11 6/12 8/12
9/20 10/1 10/1 17/10
19/6 21/20 24/15
26/15 28/5 28/6 32/17
34/17 34/18 34/20
40/14 47/2 47/5 49/19)
54/3 81/7 82/10 89/3
98/24 99/7 100/22
106/20 126/25 126/25}
127/17 127/21 131/24}
145/7 145/16 145/22
147/6 149/2 154/1
154/3 156/13 156/20
157/15 168/15 169/19}
170/14 171/15 171/20}
172/13 172/17 174/5
174/5 174/6 178/5
179/20 180/10 181/13
183/12 185/2 187/9
188/24 189/22 191/20}
193/5
though [6] 12/21
38/22 120/5 146/5
156/19 171/20
thought [24] 15/23
25/23 27/25 28/1
33/22 43/11 46/14
65/14 72/16 74/12
74/18 75/6 75/7 83/21
86/19 87/3 123/14
123/21 123/24 127/21
129/11 132/11 132/22)
134/21
thoughts [1] 21/20
threat [1] 189/6
threatening [1]
170/22
three [3] 75/22
112/14 139/17
threshold [1] 19/1
through [41] 12/13
14/2 25/19 29/20
32/18 32/23 33/1 33/9)
36/13 54/5 54/23
59/24 60/22 62/21
65/5 68/8 68/14 75/14I
110/22 111/22 135/4
135/12 146/4 148/1
151/9 153/12 154/17
158/18 158/24 160/6
166/22 177/14 178/14)
186/22 187/8 188/3
188/12 188/14 189/20)
190/1 192/24
throughout [3]
128/19 132/3 192/16
thrown [1] 90/15
ticks [4] 105/2
till [1] 38/18
Tim [10] 7/11 22/12
76/5 76/7 98/17 107/4I
109/13 109/15 133/13}
135/4
time [127] 4/11 5/3
5/24 8/1 8/23 9/20
10/19 10/21 11/9
23/20 25/21 26/17
27/4 28/21 30/15
31/15 36/18 37/3
40/22 41/14 41/22
42/11 44/1 45/11
45/15 47/10 48/9 50/9
53/5 55/5 55/18 58/15}
58/17 60/9 60/13
63/10 64/4 64/10
68/21 73/10 79/8 83/9I
86/18 87/10 88/12
92/2 92/6 98/14 98/25]
99/20 100/21 101/18
104/6 104/13 105/24
106/10 108/4 108/9
108/16 113/15 116/4
116/4 117/16 119/13
119/19 119/22 122/10)
123/6 123/14 123/21
124/15 127/12 135/2
138/25 139/3 139/12
139/15 139/18 140/1
140/4 140/18 141/4
141/7 141/17 141/24
144/17 145/3 145/14
145/25 147/7 147/9
147/13 148/16 154/18)
157/17 158/1 160/21
161/22 161/24 162/1
162/19 163/20 164/5
164/11 164/15 164/20)
165/4 165/6 165/14
167/8 169/8 172/9
174/17 175/15 175/17)
176/19 176/23 177/4
177/8 182/5 182/8
183/20 186/5 187/4
189/6 191/4 195/7
time-barred [2]
100/21 101/18
timely [1] 196/16
times [5] 30/23 65/2
101/13 106/9 177/13
(80) their... - times
timing [5] 112/6
118/4 129/25 130/13
176/9
timings [1] 99/4
tipping [1] 86/8
d [1] 21/3
title [2] 28/12 28/19
today [17] 1/6 5/21
48/22 79/8 94/24
95/10 95/12 96/15
119/6 124/18 124/22
together [8] 8/12
13/21 14/1 100/23
104/22 107/4 112/12
159/24
told [14] 7/10 7/22
27/1 27/6 35/15 88/11
111/10 119/8 119/14
176/16 177/6
Tolhurst [6] 55/6
55/12 98/7 98/18
130/3 130/6
Tom [18] 20/23 33/16
37/25 38/2 62/13 76/7
79/16 85/16 85/16
85/18 90/11 94/2
104/19 104/23 104/24}
109/15 130/7 130/21
tomorrow [1] 196/21
Toms [1] 104/19
tone [2] 22/20 23/7
Tony [1] 104/10
too [12] 23/6 45/22
60/4 61/12 66/11
101/14 104/15 134/22)
134/23 141/10 163/18
167/3
took [20] 5/7 7/13
7/22 13/19 41/24
44/16 44/19 73/22
82/14 82/22 82/24
83/2 97/11 116/3
117/4 131/14 140/25
145/6 169/4 170/1
tool [2] 69/11 179/8
top [20] 20/20 24/1
26/9 39/20 49/10
49/19 50/21 52/21
53/4 53/4 53/5 57/16
59/8 69/18 89/5
100/13 181/10 181/11
183/1 194/8
top-down [2] 181/10
181/11
topic [9] 31/9 54/18
68/2 69/20 97/16
100/8 103/12 133/15
148/11
escale [1] 68/23
112/10 118/17 118/18)
125/20 186/11 186/13}
119/17 120/16 120/19)
total [3] 44/18 75/6
185/22
totally [5] 88/21 94/4
96/5 102/2 110/12
touch [1] 64/25
touchpoints [1]
32/12
towards [6] 46/18
86/1 111/14 129/19
175/14 175/16
toxic [2] 114/12
115/21
track [2] 59/23
150/17
traction [2] 117/19
123/18
trade [1] 163/9
trading [2] 71/4
72/115
trail [3] 179/11
179/16 179/19
trained [1] 138/1
training [4] 17/3
107/10 120/15 167/18)
transaction [7]
159/18 159/19 163/8
179/2 179/6 179/14
193/20
transactions [3]
178/10 179/5 180/9
transcript [1] 118/20
translate [1] 140/4
transparency [1]
196/11
transpired [1] 89/18
travelled [1] 186/11
trawl [1] 109/24
Treasury [2] 36/12
65/8
treated [1] 104/23
treatment [1] 156/6
trial [25] 19/8 19/9
20/4 21/5 21/14 21/18
39/5 39/17 41/6 42/19)
45/21 46/1 46/16 63/5)
63/15 64/5 64/11
67/22 69/24 70/16
71/24 77/17 79/2
99/20 103/24
trials [1] 19/13
tried [10] 24/21 30/23
45/6 62/11 91/3 106/3
174/6 174/10 190/17
191/16
true [6] 3/12 35/22
48/23 63/10 137/20
143/20
trump [1] 42/5
trust [2] 106/14
1114/7
truthful [1] 110/18
try [7] 55/21 61/14
86/16 94/23 95/12
106/5 134/24
trying [19] 16/6 17/11
19/19 23/24 24/11
34/19 40/14 40/17
60/8 63/18 66/1 94/16
105/20 109/10 109/25
111/2 111/3 135/8
195/23
Tuesday [1] 76/8
turn [11] 125/14
137/10 143/22 144/7
147/22 150/22 155/13
163/4 165/10 178/8
180/24
turned [1] 174/13
turning [1] 132/4
turnover [1] 55/15
Tweets [1] 65/6
twice [2] 101/10
157/13
two [29] 5/14 40/4
40/14 41/24 51/24
64/21 66/25 80/24
81/4 90/8 94/15 94/21
101/10 102/12 106/5
106/18 109/12 136/24
139/8 139/9 140/21
140/23 140/25 146/17
169/12 169/12 181/9
186/1 193/21
two years [1] 169/12
tying [1] 68/10
type [4] 49/16 147/13
184/16 185/7
typical [1] 111/23
typographical [1] 2/2
U
UBS [2] 3/20 3/23
UK [2] 3/16 76/15
UKGI [92] 4/2 4/5 5/8
5/9 5/24 12/4 12/25
13/23 18/4 18/7 20/15I
23/20 26/6 26/8 26/22
27/7 27121 27/23
28/11 28/21 29/6
29/15 30/5 30/13
31/11 31/22 32/11
33/7 34/24 35/5 35/8
35/9 35/12 35/13
35/15 36/1 36/5 36/11
36/19 36/25 37/22
45/8 45/10 46/4 47/21
47/24 48/18 48/22
49/1 53/14 53/20
54/13 54/21 55/15
56/5 58/11 59/3 59/22
60/22 61/23 62/20
64/12 64/18 64/23
65/10 66/20 68/8 68/9
68/13 68/25 68/25
78/9 81/15 81/25
83/21 84/8 84/15
87/16 90/24 90/24
94/5 97/23 98/1
114/22 121/15 125/21
128/10 128/16 128/24}
129/23 130/4 141/25
UKGI's [6] 5/5 28/12
60/23 60/24 65/7
129/1
UKG1I00008532 [1]
17/25
UKGI00008608 [1]
98/23
UKGI00008614 [1]
37/21
UKGI00008656 [1]
130/2
UKGI00009208 [1]
78/23
UKGI00009211 [1]
85/7
UKGI00009273 [1]
88/1
UKGI00009275 [1]
28/11
UKGI00009308 [1]
92/20
UKGI00010737 [1]
104/17
UKGI00011190 [1]
110/6
UKG1I00015921 [1]
57/10
UKGI00016718 [1]
181/16
UKGI00016739 [1]
193/8
UKGI00019332 [1]
3/3
UKGI00019348 [1]
165/8
UKGI00021096 [1]
49/4
UKGI00027113 [1]
112/11
UKGI00036711 [1]
162/9
UKGI00038672 [1]
411/17
UKGI00041953 [1]
142/23
UKG100044314 [4]
150/2
UKG1I00045852 [1]
159/3
UKGI00045855 [1]
147/21
ulterior [1] 105/14
ultimate [2] 148/17
149/5
ultimately [5] 84/6
100/19 101/21 102/11
154/23
Um [1] 105/19
unable [2] 94/9
186/13
unattributed [1]
109/14
unaware [2] 169/23
170/4
unbending [1] 33/25
uncertainty [1] 14/17
unclear [1] 122/1
uncomfortable [2]
21/24 87/17
under [16] 15/13
50/14 59/19 60/19
60/24 62/17 64/3
76/12 100/10 114/7
144/5 144/22 146/10
151/12 161/14 194/4
underlying [2] 184/6
184/20
undermine [1]
105/17
undermined [1] 16/1
undermining [2]
82/24 85/25
underneath [1] 59/14!
underpinned [1] 7/16
underpinning [1]
79
understand [35] 1/22)
2/1 8/24 9/14 12/10
21/2 26/3 40/14 40/17
47/8 56/20 74/4 82/19)
82/21 85/21 90/5
93/25 94/13 95/7 95/9
96/13 105/11 111/24
115/23 115/24 121/7
122/6 124/16 130/22
136/22 141/24 142/25]
164/13 166/19 186/13)
understanding [14]
45/20 51/1 65/17 88/5)
105/25 106/1 106/1
106/6 122/7 173/6
181/12 187/2 187/5
187/25
understood [7] 7/1
7/5 24/6 29/19 70/18
118/21 120/18
undertake [1] 138/7
underway [1] 49/24
unethical [1] 16/1
unfair [3] 15/23 16/1
118/19
unfairness [3] 37/17
72/13 77/13
unfold [4] 93/16
unfolded [1] 42/17
unfortunately [1]
98/24
unilaterally [1] 127/2
union [4] 147/16
163/11 171/13 194/14)
unknown [1] 179/22
unless [5] 37/13
113/10 113/12 113/13)
125/15
unlikely [1] 195/7
(81) timescale - unlikely
U
unplanned [1]
157/22
unquote [1] 174/17
unrealistic [1] 72/4
unreasonable [2]
15/12 119/1
unredacted [2] 2/22
3/8
unreliable [1] 168/7
unsafe [4] 38/12 40/7
40/25 168/3
unsustainable [1]
127/16
untenable [1] 119/2
until [15] 4/10 4/15
7/17 12/20 28/23 44/8
53/21 59/3 63/14
131/3 138/23 144/5
158/7 164/1 197/5
unusual [5] 14/10
14/19 46/25 166/14
175/4
unwilling [1] 33/25
up [60] 4/8 5/11 5/13
10/25 24/22 32/1 32/2)
32/22 40/22 45/20
46/22 48/18 52/20
52/21 55/23 59/3
59/25 62/25 63/9 68/2
72/17 79/13 81/10
83/15 94/18 99/18
101/10 105/10 108/15
110/6 110/19 111/17
115/20 125/14 126/19}
127/25 130/25 136/23)
140/12 140/25 141/20)
142/23 143/3 145/6
147/20 148/12 155/25)
158/15 162/9 171/1
1714/7 173/15 175/10
181/10 181/12 182/13}
184/15 193/9 193/15
195/11
update [11] 17/23
54/13 54/23 60/22
65/13 69/22 71/18
75/21 76/2 78/4 92/21
updated [5] 24/16
56/8 62/21 64/14
128/22
updates [4] 64/19
128/19 129/23 130/19}
upholding [1] 79/25
upload [1] 99/3
upon [2] 4/5 120/2
urgency [2] 133/22
170/9
urgently [1] 76/23
us [20] 1/3 31/24
32/18 32/20 47/17
56/25 57/4 57/4 74/15)
92/12 111/1 124/14
125/4 134/3 156/20
168/17 169/22 170/2
186/4 192/2
use [8] 29/2 35/8
36/8 99/2 114/8
179/10 179/17 190/17)
used [5] 9/7 21/16
36/16 88/19 188/16
useful [1] 105/10
usefulness [1] 188/9
using [2] 51/23
151/14
usual [8] 1/7 152/20
164/8 168/20 170/7
171/18 174/24 175/1
usually [3] 29/25
38/20 48/16
utilise [1] 35/5
utterly [2] 121/20
122/24
Vv
valid [1] 96/5
validated [1] 177/17
value [2] 7/22 116/3
Vamos [1] 106/24
van [1] 73/3
various [12] 4/23
9/12 20/2 132/2
134/20 138/5 155/8
162/12 165/3 173/19
179/12 180/22
vehicle [5] 26/19
27/14 29/18 36/14
36/16
vein [1] 171/17
Vennells [5] 22/15
22/18 113/10 114/4
172/15
Vennells' [1] 112/20
verbal [1] 130/18
verbally [1] 179/7
verification [1] 178/4
version [11] 2/22 3/8
5/16 34/14 52/22
52/25 53/2 54/1 57/1
60/16 137/13
versions [2] 56/19
119/16
versus [1] 163/9
very [92] 7/21 8/2 8/3
9/9 14/1 14/19 17/9
17/22 19/1 21/16
21/24 22/2 22/8 24/8
26/12 27/3 27/6 27/25
30/12 32/9 32/9 36/8
36/14 36/18 40/10
40/12 40/15 41/20
41/23 42/10 42/14
43/9 44/2 52/12 52/13
53/22 59/6 66/14
67/23 67/23 68/21
69/1 69/5 69/6 70/3
70/16 77/7 78/2 78/23)
83/8 86/14 86/15 90/3
91/9 93/22 94/14
95/20 96/10 97/8
97/14 102/6 103/8
103/9 103/16 106/4
108/1 116/4 116/13
118/9 119/5 123/9
124/1 127/17 127/18
127/20 127/25 131/16}
135/17 136/7 144/15
145/15 147/7 147/7
150/1 156/8 169/20
171/17 188/15 192/11
195/19 195/20 197/3
via [3] 179/15 187/12
189/20
Vice [1] 138/9
Vice-Chairman [1]
138/9
victimised [1] 116/17
view [34] 13/19 16/19]
38/11 42/10 42/14
58/21 61/16 67/5 73/6
78/2 80/23 82/14
84/24 85/17 88/11
88/21 88/25 89/14
90/7 90/12 94/5 95/4
96/6 108/16 116/12
120/23 121/5 129/1
152/17 169/4 185/21
185/22 194/14 196/9
viewed [1] 14/5
views [19] 14/2 27/17
27/19 61/5 62/7 65/25
67/8 67/13 69/2 76/16
81/7 88/21 95/23 97/3
97/12 131/24 132/15
132/17 134/3
visibility [5] 103/7
103/7 163/1 164/11
164/12
visible [6] 60/16
161/10 161/11 161/12
164/20 179/8
vital [1] 193/10
volume [2] 156/18
175/7
vote [7] 85/19 85/22
86/1 86/8 86/12 91/13
94/11
voted [1] 90/9
voting [1] 86/17
vulnerable [1] 17/3
Ww
wait [2] 127/20
135/24
waited [1] 164/1
waived [1] 77/17
wall [4] 117/17
Wallis [3] 65/3 105/7
105/8
want [26] 14/16
35/21 68/10 83/18
93/17 96/9 96/9 96/15
96/23 97/1 106/21
106/25 107/7 107/15
112/14 114/15 114/21
124/4 129/24 133/24
142/20 155/2 171/9
173/14 182/14 187/18}
wanted [7] 100/20
101/12 102/11 105/15)
106/12 109/21 134/4
wanting [1] 107/5
wants [1] 21/4
warning [1] 124/21
warranted [2] 180/3
180/6
warts [2] 193/12
193/13
was [709]
wasn't [28] 6/2 13/19
18/7 31/8 31/14 36/22,
43/23 46/24 46/25
52/7 54/2 60/16 64/2
102/2 111/2 111/14
115/14 116/6 120/14
121/3 121/10 153/14
164/11 166/11 168/23
173/7 183/19 189/22
watched [1] 9/22
watching [2] 9/23
186/12
watershed [2] 103/22!
111/11
Watson [30] 2/9
13/20 13/23 18/3
20/15 20/21 22/6 30/3
30/4 37/23 38/9 45/1
78/9 78/13 79/12
79/14 81/11 82/1
83/16 84/22 85/2 85/8)
85/10 87/14 89/4
89/21 90/23 91/22
94/19 112/13
Watson's [1] 87/24
way [57] 5/24 8/11
10/6 10/19 11/6 12/19}
14/2 17/12 17/22 23/7
29/11 32/22 33/24
38/14 50/23 50/24
65/22 66/6 66/24 67/2
67/3 67/8 67/14 67/16
68/15 80/16 81/24
82/8 83/13 85/19
85/23 86/9 86/13
109/8 109/9 109/9
114/7 115/19 116/12
116/12 119/12 120/6
121/4 121/6 121/10
121/17 122/15 123/22}
127/3 132/11 133/16
135/7 149/15 151/13
181/9 184/11 186/24
ways [1] 9/2
we [297]
we'd [8] 25/16 45/4
55/7 55/9 55/9 63/21
111/10 135/6
we'll [13] 15/17 56/18)
80/9 81/3 90/18 91/25
94/3 96/2 106/21
124/24 136/8 146/3
147/20
we're [10] 49/24 99/2
99/13 107/21 110/4
119/19 144/7 147/17
169/17 171/18
we've [18] 30/5 56/10)
62/13 70/17 80/3
85/11 88/22 92/19
95/25 121/19 121/23
124/7 173/17 180/12
182/16 193/4 194/4
194/8
weakened [1] 77/18
weaknesses [1]
185/15
website [2] 65/6
137/24
Wednesday [1] 1/1
week [12] 71/10
71/10 139/2 139/6
139/8 139/9 139/13
139/17 140/19 141/2
141/3 142/3
weekend [4] 79/9
83/11 95/9 96/14
weekends [1] 141/8
Weekly [5] 38/13
65/2 192/13 192/24
193/5
weeks [1] 185/16
welcome [2] 130/18
130/20
well [94] 8/8 8/17
8/20 9/16 9/19 12/13
14/25 15/10 15/23
28/7 29/18 32/7 33/15
36/16 39/6 39/16
41/15 42/22 43/7
43/22 45/4 49/24
51/23 55/3 55/11 57/6
60/7 61/17 68/4 74/3
74/16 77/24 84/1
84/20 84/22 85/24
86/11 90/11 91/3
94/14 94/17 95/25
103/1 103/14 104/10
104/14 108/11 108/12!
109/19 110/4 110/14
110/17 112/17 113/3
113/12 113/13 114/7
115/19 116/21 116/24I
123/8 124/17 127/11
135/18 140/8 141/12
144/14 145/12 146/1
147/4 149/20 150/18
151/4 151/9 154/14
157/25 158/18 160/18}
164/15 165/2 167/4
(82) unplanned - well
Ww
well... [13] 168/14
168/18 175/10 176/4
176/16 182/20 184/4
184/18 185/9 188/15
189/24 190/24 195/21
went [4] 24/25 88/18
135/2 145/6
were [250]
weren't [9] 60/13
63/19 63/20 98/2
103/25 115/5 173/9
1814/7 187/13
what [218]
what's [12] 6/3 15/16
52/2 52/2 55/19 59/10
67/10 90/21 106/13
112/6 121/12 123/19
whatever [8] 17/20
32/24 95/20 108/10
133/9 133/15 134/1
141/18
when [79] 4/11 5/7
5/7 8/9 8/11 8/11 8/15)
10/21 11/7 11/16 14/7)
14/9 15/14 17/15 19/8
25/5 25/22 29/14
30/23 31/10 32/12
35/15 36/3 41/25
41/25 42/11 44/9
44/10 44/16 71/22
73/25 75/8 85/21
97/21 99/20 100/8
102/1 102/20 110/18
112/23 115/20 115/20}
116/5 116/20 119/22
122/22 124/10 139/21
144/3 144/5 144/25
146/23 148/21 149/4
149/8 149/15 149/17
151/18 157/23 158/21
159/19 161/7 164/3
164/11 169/11 170/3
171/2 172/21 179/17
180/6 183/7 183/16
184/16 189/17 189/19}
190/17 192/2 195/10
196/4
where [47] 2/3 3/8
3/20 24/9 27/9 27/19
28/25 34/21 35/20
36/19 38/16 38/17
38/20 39/9 39/18
41/12 46/21 46/21
46/23 48/17 56/16
59/20 60/23 68/7 81/4
90/15 108/3 123/5
123/24 124/18 129/11
133/23 151/11 154/17)
164/8 168/24 170/21
173/14 173/18 176/2
180/10 182/17 182/21
183/2 184/22 185/14
187/2
whereas [1] 35/20
whereby [2] 94/24
95/12
whether [46] 11/6
15/25 19/10 27/20
28/20 36/2 38/22 43/6
46/1 64/9 67/17 69/15
76/9 76/16 76/18
76/20 76/23 78/10
80/5 80/19 82/9 84/5
91/12 100/3 100/6
100/15 101/1 101/8
101/20 107/22 108/18)
108/24 114/4 129/24
149/10 152/7 152/9
155/6 156/21 160/18
166/6 167/16 172/4
177/17 184/19 185/12)
which [151] 1/17
2/22 4/20 4/23 5/8
5/18 5/24 5/25 7/6
7/15 8/3 9/17 9/22
12/14 13/10 16/17
17/2 17/6 17/12 18/23
19/10 19/12 19/13
19/20 20/1 21/9 22/6
23/25 24/8 25/23 26/4
27/14 28/15 28/25
29/15 35/2 35/16 40/5)
41/6 41/14 42/24
44/12 46/14 47/21
47/24 51/14 54/10
54/19 57/11 57/15
58/10 58/18 59/18
60/9 60/12 61/6 64/3
64/6 65/13 67/10 68/7)
68/15 68/21 69/16
69/23 70/1 71/2 71/5
71/5 71/23 73/6 75/9
75/10 75/23 76/2
76/24 77/9 77/10
78/21 79/5 82/1 82/16)
83/3 88/9 88/20 90/14
90/14 90/19 91/20
92/25 93/12 93/20
94/7 95/4 96/5 96/8
98/18 100/9 101/7
108/13 110/14 110/25
111/24 113/15 115/13)
116/12 119/24 122/2
122/13 124/20 126/5
127/12 128/25 131/13}
134/7 134/11 136/17
138/10 142/20 142/24)
143/8 145/18 146/14
146/25 147/10 157/6
157/7 157/12 158/24
159/23 159/23 159/24)
168/6 171/23 172/9
172/18 173/21 175/5
175/13 176/21 179/4
180/14 180/24 182/24)
183/11 184/11 187/11
188/18 192/13 193/3
195/14
while [7] 56/8 65/3
80/2 81/18 164/4
175/12 193/8
whilst [8] 4/18 64/14
99/18 107/6 123/16
128/25 130/8 142/22
whistle [1] 177/13
White [4] 110/9
who [45] 4/11 9/10
14/16 20/15 27/4 30/2I
31/17 33/17 66/6 66/6
70/25 74/15 74/15
76/13 85/12 103/3
103/19 107/6 109/7
109/14 117/5 117/9
118/8 118/9 118/17
120/16 120/19 135/10
142/2 146/18 172/1
174/7 181/18 181/19
183/6 183/7 185/2
185/17 186/10 186/12)
189/18 189/21 190/2
191/16 193/14
who'd [4] 42/1
who's [2] 59/14
66/12
whole [9] 15/11
74/17 103/5 103/14
108/1 143/14 165/6
184/18 196/10
wholly [2] 119/4
161/5
whom [11] 33/7
33/10 33/13 62/5
79/18 90/25 105/5
134/6 134/10 161/11
167/10
Whose [1] 142/16
why [37] 7/18 8/6
44/25 50/1 51/25
53/19 59/2 59/5 59/15)
60/2 77/23 88/16 89/7
95/7 97/9 111/16
113/18 115/23 115/24]
116/24 117/1 123/4
123/10 126/14 132/22
146/9 154/11 156/12
160/5 161/20 164/3
164/5 164/13 166/11
168/16 176/6 195/4
wide [2] 107/18
116/15
widely [1] 21/10
wider [3] 73/16 84/1
85/14
wife [1] 186/12
will [35] 1/5 19/5 19/7I
19/9 19/13 20/24
21/10 26/21 34/16
40/25 54/22 63/2 63/3
64/23 64/25 65/10
71/9 77/6 86/2 107/18
4111/1 117/25 118/2
125/6 127/7 137/24
141/25 143/14 143/25)
147/24 185/16 185/18
190/7 190/10 196/22
Williams [11] 2/9
18/13 106/24 107/10
107/14 108/19 108/25
110/8 134/18 135/15
198/16
winded [1] 127/22
wisdom [1] 37/9
wise [1] 21/11
wish [6] 37/13 57/13
77/12 92/25 125/15
185/23
wished [1] 128/21
wishes [1] 193/14
withdraw [1] 85/17
within [28] 26/6 26/8
33/7 34/24 38/1 38/10)
41/16 45/8 82/7 107/1
125/21 133/18 141/23}
142/19 146/16 153/6
157/11 157/15 160/10}
161/10 161/13 164/19}
167/1 172/1 178/24
184/14 186/4 189/15
without [9] 25/1
38/24 39/2 78/2 127/9
160/1 164/24 170/23
178/3
WITN00200100 [1]
16/18
WITN11000100 [1]
136/21
witness [38] 1/8 1/17
A7N7 21/13 72/7
99/16 105/23 115/13
124/16 125/14 125/16}
126/4 128/6 130/23
130/25 134/20 135/19)
136/17 136/20 137/19}
138/14 138/25 139/12)
139/25 140/12 140/22)
140/24 148/12 149/4
150/3 152/15 155/4
162/11 175/10 177/12}
182/13 192/9 196/18
witnesses [7] 10/16
70/25 73/3 141/25
142/3 180/13 185/16
woeful [1] 111/6
woman [1] 121/21
won't [3] 135/23
184/25 196/21
wonder [2] 16/16
39/3
wondering [3] 38/15
38/21 42/20
word [6] 48/9 56/23
60/6 60/11 82/21 90/1
worded [2] 69/16
119/10
wording [2] 50/8
69/15
words [14] 40/23
88/19 94/6 109/19
110/8 110/10 135/12
137/1 137/5 151/14
176/9 183/4 193/22
195/8
work [10] 14/9 34/14
34/15 63/3 100/1
114/19 141/14 143/13)
145/6 193/24
worked [14] 3/20 4/1
5/22 5/25 8/14 8/25
14/1 15/10 47/4 67/18)
75/9 118/8 138/4
145/8
working [9] 15/10
38/5 58/12 71/11
101/25 121/14 139/6
157/15 183/1
works [2] 5/21 8/17
world [4] 34/10 90/4
91/8 121/5
worth [5] 12/6 51/23
88/15 90/17 111/21
would [201]
wouldn't [8] 10/12
47/6 63/22 63/23
80/13 86/3 115/23
127/14
write [1] 149/8
writing [5] 25/7
111/17 112/12 149/11
149/15
written [5] 27/23
130/18 136/16 144/3
180/3
wrong [14] 54/4
56/25 61/13 62/14
74/4 82/25 114/16
1415/2 117/1 122/25
133/21 134/12 134/14)
149/21
wrongly [2] 116/14
195/12
wrongs [1] 17/21
wrote [1] 186/15
Wyn [4] 41/19 134/18)
135/3 198/16
Xo
x' [4] 109/17
Y
yeah [26] 1/21 38/2
40/10 41/3 43/17 48/8
49/20 50/25 52/3
54/17 57/19 57/22
61/22 65/16 68/17
70/9 70/12 90/20 92/6I
94/8 94/20 96/4 98/5
109/18 119/25 121/25I
year [10] 1/19 20/3
(83) well... - year
Y
year... [8] 53/21
76/14 112/17 127/12
145/19 157/13 158/8
175/13
years [8] 3/21 6/5 7/1
101/16 120/3 169/12
169/13 184/22
yes [192] 1/4 1/7 2/12
2/24 3/6 3/10 3/19
3/22 3/25 4/4 4/7 4/17
5/2 5/7 5/11 6/18 6/22
7/4 7/13 9/22 10/23
11/3 11/22 12/1 12/6
13/3 13/8 13/13 13/19}
14/25 16/11 17/8
17/19 20/10 20/13
22/1 22/7 22/10 22/14,
22/22 26/25 27/3 30/4
30/15 31/14 33/3 33/5)
36/5 36/5 37/8 37/12
37/20 39/18 39/18
41/10 45/19 46/20
47/8 47/18 47/18 48/5
48/16 51/15 52/19
60/3 61/4 61/4 61/19
62/15 63/10 63/25
65/21 65/21 66/19
66/21 69/4 69/25
71/21 72/1 72/5 72/5
73/11 73/21 73/24
75/4 75/17 75/20 76/1
77/22 78/20 84/16
87/5 87/9 88/4 88/7
92/4 92/8 92/13 92/13,
92/18 93/5 93/22 94/1
94/19 98/9 99/10
99/12 99/22 102/2
102/2 102/14 102/19
102/25 103/23 104/4
104/5 104/15 108/12
108/21 111/2 111/2
111/10 111/19 111/19)
112/5 112/8 113/15
113/18 114/13 114/14}
115/17 115/18 117/24}
121/15 121/16 122/20)
125/5 125/8 125/24
125/24 126/15 127/16)
128/13 129/11 130/22)
132/6 133/4 136/7
136/19 137/12 137/17)
138/24 141/7 141/18
142/9 144/2 144/5
150/21 151/17 151/18}
151/23 153/20 153/24}
154/2 154/10 157/2
157/5 159/13 160/3
162/8 163/23 163/25
167/22 169/10 170/1
170/12 172/24 174/25}
175/16 175/18 175/18)
175/19 182/11 184/7
187/10 187/14 189/3
190/12 195/21 195/22)
196/23 197/2
yesterday [6] 115/20
142/3 144/15 154/21
158/21 181/19
yesterday's [1]
180/13
yet [2] 41/14 70/17
you [938]
you'd [9] 1/22 2/7
30/7 36/2 45/3 104/7
122/10 127/22 177/6
you'll [8] 79/3 81/2
81/8 96/12 105/23
108/5 150/14 165/2
you're [38] 9/3 41/13
57/20 59/1 59/13 66/9)
80/12 81/1 81/11 89/7,
90/19 90/23 91/20
93/25 94/1 99/7
111/17 113/6 115/10
118/14 118/20 119/23)
120/5 131/2 131/4
140/24 147/17 149/4
149/6 151/18 159/3
162/11 175/21 175/21
176/16 181/18 181/20)
189/12
you've [31] 5/25
11/18 15/21 18/3
23/11 31/9 37/24
47/22 51/11 53/10
56/12 59/1 61/17
68/18 68/19 68/20
79/11 80/10 90/16
93/9 102/12 118/16
118/17 119/6 121/13
123/22 125/20 137/19)
155/5 177/11 187/10
your [205]
yourself [1] 166/23
z
Zebra [1] 155/12
Zurich [1] 138/10
(84) year... - Zurich