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Friday, 12 July 2024
(9.45 am)
MRBEER: Good morning, sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, I can, thank you.
MR BEER: Thank you very much, may I call Richard Callard,
please.
SIR WYN WILLIAMS: Yes.
RICHARD JOHN CALLARD (sworn)
Questioned by MR BEER
MR BEER: Good morning, Mr Callard. My name is Jason Beer,
as you know, and I ask on behalf of the Inquiry. Can
you tell us your full name, please?
Richard John Callard.
You've made a long statement, 163 pages, excluding the
exhibit sheets, dated 14 June 2024. The URN for that is
WITNO0140100. If we can have that up on the screen,
please, and look at the bottom of page 23. Right at the
bottom, thank you.
Do you see the last line on the page, going into the
next page? It currently reads:
"By this time, Jenny Willott MP had replaced Jo
Swinson MP whilst Jo Swinson MP was on maternity leave."
Is there a correction you'd like to make to that
sentence?
Yes, please. I realised, after I read Jo Swinson's
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You started to lead the ShEx Post Office Team in January
2014 and were appointed as the Shareholder Non-Exec
Director for the Post Office in March 2014?
That's correct.
So you had two roles: Head of the Shareholder Team
within ShEx and the Shareholder NED for the Post Office?
Yes, that's correct.
You held the Post Office Board role until March 2018,
and the Head of the Shareholder Team role for Post
Office until May 2018?
That's correct.
You remain an Executive Director of UKGI, the successor
organisation to ShEx?
That's correct.
Thank you. Can I start then by asking you some
questions about the role you performed as
a Non-Executive Director, as a NED?
Mm-hm.
These questions are based on what you say in
paragraphs 8, 13 and 14 of your witness statement.
There's no need to turn them up.
You say that when you started working at the Post
Office as a Non-Executive Director, you first had no
experience as a NED; is that right?
That's correct.
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witness statement, that she had returned from maternity
leave in June. So it should read that by this time Jo
Swinson had returned from maternity leave.
If you could just angle those microphones and just move
forward a little bit. Thank you very much.
So the sentence should read "By this time Jo Swinson
had returned from maternity leave"?
That's correct.
Thank you. If you can turn, please, to page 173; is
that your signature?
Itis.
With that correction brought into account, are the
contents of the witness statement true to the best of
your knowledge and belief?
Yes, they are.
Thank you. You can put that to one side, thank you.
Can I start with your background, please. In summary
terms is this right: you qualified as a chartered
accountant in 2001 and joined Arthur Andersen, as it
then was, in 2002?
That's correct.
You joined the Shareholder Executive, ShEx, as we're
going to call it, initially on secondment in March 2007
and then permanently from March 2009?
That's correct.
You, second, had little knowledge of the Post Office?
I suppose I'd had a two-month run-in as the other
Shareholder Team, noting that I'd been on paternity
leave as well, but yes.
Third, you say that you found your new role as Head of
the ShEx Team for the Post Office overwhelming, in
particular because that role had been split previously
between two people?
That's correct.
Did you ever raise your concerns about your capacity or
capability to undertake the role of a Non-Executive
Director on the Post Office Board?
No, because, to start with, I thought I'd see how it
went and if I could manage. I was doing 50 per cent --
theoretically, 50 per cent of my time on the Green
Investment Bank shareholding, 50 per cent of my time on
the Post Office shareholding and then the Non-Executive
role was a sort of -- I'm not sure whether it was
considered part of the 50 per cent of the Post Office.
But the way UKGI and ShEx works is that you tend to have
a -- everybody has quite full workload, so whilst I say
it was overwhelming, it was, but I think it was more
about the sheer number of issues that were on the
agenda, as opposed to the level of workload.
Having taken on the role for which you had no prior
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experience, did you receive any relevant training or
mentoring?
Not particularly. I went on a course with regard to
being a NED and, clearly, I'd picked up snippets and
experience from other people but there was nothing
particularly formal to start with.
Even though you were new to the role of a Non-Executive
Director --
Yeah.
-- at this early stage, did you at least know that the
core part of a role of a Board would be to provide
appropriate challenge to the thinking and strategic of
the executive of a company?
Yes.
Did you understand that the Non-Executive Director, the
NED's role, within that function, was in particular to
provide independent oversight --
Yes.
-- and a constructive challenge to the Executive
Directors?
Yes.
When you took up the role, did you have any
understanding or recognition of the risk inherent in
an organisation dealing with longstanding challenges
that they -- or the organisation -- may develop
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directly challenged the Executive?
Are you talking about Horizon specifically or generally?
Horizon specifically?
Well, I think I asked questions around whether people
had appealed because I couldn't understand why people --
if there'd been miscarriages of justice, why people
hadn't appealed.
Just stopping there, isn't that a request for
information rather than a challenge to the approach or
direction that the company was taking?
Yes, I suppose you're right. Yeah.
I'm thinking about challenging and saying "What you're
doing, in my view, is wrong, it's the wrong path to
take. I would vote for ... I suggest you do X"?
I suppose when I got there, I inherited a position which
was relatively -- I felt relatively established. There
had been -- you know, Second Sight had been appointed at
sometime in 2012, they had then produced a report in
July '13. I thought Post Office's response to the
findings of that report, in terms of setting up
a Business Improvement Programme, setting up a Mediation
Scheme, where individual cases would be looked at and
also looking at prosecutions, was a reasonable response
to the information that was being received at the time.
So I was relatively satisfied with what was going on
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entrenched views, sometimes called groupthink?
Well, I'd certainly heard of groupthink, and clearly
there's always a bit of history, but I don't think I had
any specific worries about that in that sense. There
was -- when I joined, although Post Office is, I don't
know, 300-odd years old, it had only just come out from
under Royal Mail and had a relatively new Board, which
it never had before, so everybody on that Board was
pretty new to Post Office.
Does it follow that you didn't regard it as a particular
function of your job as a Non-Executive Director to be
alive to that risk of ingrained thinking or groupthink,
and be the one that ought to identify it and challenge
it?
I don't recall thinking that way specifically. So --
but I was aware that that is what my role was and I did
ask questions about a whole range of topics as part of
my role.
You do mention in your witness statement that you asked
questions over the years that you fulfilled the function
of NED, but in your witness statement, you don't appear
to identify any point at which you provided any
significant challenge to the Executive; would you agree?
No, I wouldn't agree with that.
Which were the occasions when you significantly and
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at that point. And I also received -- the information
I was getting from the team I inherited was similar. So
I'm not sure I felt the need to directly challenge in
that way because there was quite a bit of work and
investigation already ongoing, in terms of individual
cases within the Mediation Scheme being investigated
and, periodically, we then -- you know, there was things
around Deloittes, there was Linklaters, et cetera, and
I also volunteered to join the Sparrow subcommittee
because I was quite clear that ministers would want to
understand what was going on.
So whilst I didn't -- I can't think of any examples
that were directly challenging, I felt that was
a reflection of the fact that, at the time I joined,
I didn't feel I particularly needed to.
So was that state of being relatively satisfied or being
in a state of relative satisfaction one that continued
for the entirety of your role as a NED?
No, I think if you -- we were continually worried about
the issue of Sparrow, as I'll probably call it
throughout today --
I'm looking -- sorry to speak over you, Mr Callard.
You've mentioned asking for information. You said you
were worried or concerned.
Yeah.
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I'm asking, was there any occasion when you actively
challenged the Executive?
There will have been but I can't remember specific
examples. But at the Sparrow subcommittee, that is
where the forum would be to ask specific questions of
the Executive. A lot of those were focused around
how -- or by the time I got there, because of what --
the information, I understood it to be around the system
itself, it was around how we deal with the problems at
the Mediation Scheme was happening. On reflection,
knowing what I know now, I probably should have asked
more probing questions about the specifics of the IT
itself but, as I say, the position I inherited felt
a relatively good position, even though the Mediation
Scheme itself was starting to somewhat go awry.
Did you see your role as the ShEx representative on the
Board to be to represent the interests of taxpayers?
Yes, I think so. It was to represent -- the role of
a Shareholder NED, to my mind, is one of -- aside from
being an independent NED in its own right, it also has
an overlay of bringing a Government perspective to the
Board and bringing the Board's perspective to the
Government, so that they can understand each other
better.
You tell us in your witness statement, it's
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ShEx or UKGI because there's something -- you know, they
can't quite be commercial. So in Post Office's case,
for example, they have to keep open 3,000 branches that
would otherwise be unviable but, otherwise, we want them
to operate like a commercial entity and, through ShEx,
that's the kind of the sort of culture we're trying to
bring.
So you could have been selling oil or making microchips,
it didn’t matter that this was public money being spent,
in the provision of a public service?
Well, of course it matters and you always have an eye to
the fact that you're ultimately responsible through to
Parliament that -- so you want to make sure it gives
an extra angle, as it were, when you're looking at
a business case about money, that you know that the
money you've got to get won't otherwise go into
a hospital or a school. So there is that angle.
So we do -- you do -- one does think of the taxpayer
and that is the added angle that you bring, I suppose,
as a Non-Exec, a Shareholder Non-Exec because you've got
to think about the wider position of the Department and
the wider priorities.
Can I turn to potential conflicts of interest. In
paragraphs 10, 16, 63, and 317 to 19 of your witness
statement, you discuss the potential conflict of
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paragraph 39, that you did not see the responsibilities
of the Board of Directors as being fundamentally
different in Post Office to those that would ordinarily
apply to the Board of a large company, simply by virtue
of the fact that the company was wholly owned by the
Government. Can I ask, given that the Post Office was
effectively spending public funds, did you not consider
that there was a greater accountability on Post Office
than in the case of a private commercial entity?
I suppose we view, almost in some respects, somewhat
neutral about who owns the business itself. But we do
feel accountable to taxpayers in terms of how money is
spent and what it goes on. That is not to say that we
don't want the money to be spent, it's more about value
for money. Are you getting what you are paying for? So
we do did have -- I did have in mind an eye to things
like costs but also --
That would apply in a -- sorry to speak over you again.
That would apply in a straightforward commercial
company?
Yes, and I don't really see there's a -- you know, it
wouldn't be that different to a commercial company. The
part -- the way ShEx works is to almost treat its
businesses to the extent it can as commercial entities
because that's what we want them to be. Now, they're in
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interest which the Post Office Board perceived to exist
between the Post Office, on the one hand, and the
Government, as Post Office's shareholder on the other,
and you give a specific example of Board discussions of
Government funding levels as posing a problem?
Yeah.
You indicate that you were conscious of the potential
for you personally to be placed in a position of
conflict of interest and, therefore, decided to absent
yourself from certain parts of certain Board meetings ~
Mm.
-- particularly when funding was discussed, agreed?
That's correct.
Can you explain what specifically the perceived conflict
was, please, in relation to the Post Office's funding?
So, as a Non-Executive Director, you are there to
promote the interests of the company and I suppose, in
a crude way, the more investment that you get, the
better it is for the company. With your Civil Service
hat on, clearly you're there to look after public funds.
You want to make sure that the right amount of money
goes to the Post Office, or any other business that you
look after, and you're also very conscious that there is
limits on the level of taxpayer funding that can go to
the Post Office, as I say.
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And so those two things somewhat conflict. Not all
the time but they do somewhat conflict when the Board is
making decisions about what it's applying to the
Government for and I remember, it was one particular
Board meeting, it was a strategy away day where they
proposed -- Post Office proposed a number which
I thought was just far too big, and I said so. And, as
a team, the Shareholder Team, a lot of our efforts over
the course of the next 12 to 18 months were around
pushing that figure down in one direction and yet, at
the same time when we went to the Department, explaining
to the Department why we needed -- why Post Office
needed that investment.
And so you're trying to bring down their
expectations and get comfortable with the level of
funding that, as a Shareholder Team, you think Post
Office needs for what it wants to do, whilst, at the
same time, going into bat with the Department to say "We
think you need to provide X hundred million to Post
Office to provide them" --
When you said that number is too high, which hat were
you wearing? Were you --
Well, I often, in Boards, would say which hat I was
wearing, I'd specifically say, and I think I --
So on that occasion --
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high", were you saying that as the Government's
representative?
Yes, and I would probably be saying it as well as
a Shareholder NED -- I suppose knowing -- understanding
the Government context. So whether I actually said,
"I'm putting my government hat on", specifically, but
I just felt that the -- I wanted to set expectations
that that figure felt quite high. Now --
So hold on --
-- I didn't see that was a conflict in saying that at
the time. There was lots of discussions about funding
within the Post Office Board. I only -- I think
I recused myself from two discussions. Now, the reason
why I recused myself in those particular discussions was
because I could tell -- (a) I could pick up the feeling
from the Board but the discussion that was going to
happen then was more about the tactics and -- of the
Board as to what they're going to do, given that
Government is not giving them the money that they
wanted, and I don't think they felt comfortable and
I didn't feel comfortable in discussions around "Okay,
so what's our next move with Government”.
You know, I didn't feel comfortable being in that
discussion and I don't think they felt me being
comfortable there because they weren't sure what I would
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So on that occasion I think I will have said, "Look,
this number is too high for Government". But no one is
countenancing that --
Why were you entitled to say that, if you thought that
there was a conflict of interest in representing
Government's views on funding issues within the Board?
Sorry, I don't quite understand the question.
Yes. You told us that there was a conflict of
interest --
Yes.
-- on occasions --
Yes.
-- in particular in relation to funding --
Yes.
-- because the Board's overall aim -- this is describing
things in very generic terms -- would be to secure from
Government the highest level of funding that was
possible?
Yes.
That would not --
Within reason.
Yes. That would not necessarily be Government's
number 1 choice or priority?
Yeah, yeah.
When you said in a Board meeting "That number is too
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take back to the Department. There was plenty of
discussions we did have when I was in the room, about
funding, about what is this money for, what is the
business case for, is this the right direction,
et cetera. So I apologise if I've given you the
impression that I was never in the room of the Board for
funding discussions. There were plenty of funding
discussions but there were some specific times that
I recused myself because I wasn't comfortable being
there and the Board wasn't comfortable with me being
there.
Can you give us any other examples of specific areas
where the Board considered there to be a conflict of
interest or potential conflict of interest in you acting
both as a Board member and also as a member of the
Shareholder Executive?
Not particularly to be honest. I mean, some members --
I was first Shareholder NED that was also part of the
Shareholder Team so my predecessor, Susannah Storey, had
been separate to ShEx. Although she was -- had been
a ShEx person she was ex-ShEx, so I remember there was
a bit of discomfort when I first joined and I think
there was a concern about the sharing of Board papers
and those sorts of procedural issues, which I suppose
you could say is some sort of conflict.
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I'm not sure they wanted -- Boards tend to be very
sensitive about --
Specifically, Mr Callard, did you or any other Board
members perceive any conflict or potential conflict in
relation to Horizon issues on any occasion?
No, I don't think so.
Did you feel constrained in any way in disclosing
information by reason of your signature of NDAs,
non-disclosure agreements?
No, because the NDA agreement was specifically, I think,
worded to allow me to share Board papers with my team
and others in Government, if I felt it appropriate.
So the NDAs did not inhibit your ability to relay any
matters of concern about Post Office to Government?
No.
You tell us in paragraph 42 of your witness statement
about circumstances in Board meetings where you spoke
with your "NED hat on” or your "Government/shareholder
hat on", as you described --
Yeah.
-- and you say you might, for example, state that you
agreed with the Board's course of action, given what you
knew from Board discussions and your responsibilities as
a NED to the company --
Mm-hm.
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Yeah.
-- funding, pension changes and Sparrow?
Yeah.
In what ways did you believe your duties as a Director
were not or may not have been aligned with the interests
of the Government, its sole shareholder, in relation to
Sparrow?
It's less about not being in line, it's just not really
understanding the ministerial position and going back
for clarification. So I'm thinking specifically around
some of the decisions at the Sparrow subcommittee were
looking at, say, towards the start of June and the end
of April, where there were worries and concerns about
the investigations into each case of mediation not
proceeding quick enough and sort of almost getting stuck
with Second Sight, because they were only two people
versus the investigatory team at Post Office that had
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And so the options that were put forward by the
Executive and discussed by the subcommittee, it was
acknowledged that, to the extent that the Board decided
to do something, you'd have to go back to ministers,
particularly given the Parliamentary undertakings they
had made about Second Sight, for example, to say "Well,
you know, we would need ministerial consent or whatever
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-- but would make it clear that ministers might not
necessarily agree?
Yeah.
What did you understand, in your words, your
responsibilities as a NED to the company to mean?
So you're there to promote the success of the company.
So if I can give an example that might demonstrate that.
So there were -- for example, there were redundancy
programmes periodically to be done in the Post Office to
make them more efficient, so, for example, in the cash
supply chain, which was felt to be over-manned, and so
as a NED, I was quite content, having looked at the
business case for it, for those redundancies to go
thorough. But, clearly, redundancies are a politically
sensitive matter, so I would say "Well, as a NED, using
my independent judgement, I would agree with this change
but what we do need to do is inform the Minister because
it could have political ramifications. It's not that
they'll say no but I need to warn them and we need to
just make sure there's no objection".
You give examples in your witness statement where you
might be wearing two hats --
Yeah.
-- and had to make clear that fact, as including issues
of executive remuneration, mutualisation --
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to take a course of action".
So whilst I could, as a NED, say, well, I think this
is perhaps the right way forward because clearly X and Y
is happening and this looks like the right course of
action, I don't know how a minister feels about that.
They may say yes, they may say no to it, so we've got to
be live to that sort of thinking, so that's what I meant
by that particular example.
You tell us in paragraph 61 to 62 of your witness
statement that you shared the vast majority of
information that you received in your capacity --
Yes.
-- as a Shareholder NED with the Shareholder Team,
without restriction. Correct?
Yes.
Did you take the same approach, ie sharing the vast
majority of information, in relation to ministers and
civil servants outside of ShEx?
No, not in that way because the stuff you get through
from -- Board packs would be 150 to 250 pages. You
wouldn't share those with the Minister. They have --
Did you consider there to be a restriction of
a different kind in sharing information that you learned
in your capacity as Shareholder NED outside of the ShEx
team?
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No, I never felt there was things that I couldn't tell
ministers if I felt it appropriate to do so.
So you were able, you thought, to show Board papers to
ministers and civil servants outside of ShEx, if the
occasion arose?
If - I mean, I very rarely shared Board papers outside
of ShEx because I never felt there was a need to. What
we would do, if there was something to be said, we would
put that into a some sort of submission or some sort of
email and circulate it, rather than actually sharing the
paper itself.
So never mind how the information was conveyed, you
considered yourself able to inform ministers and civil
servants outside of ShEx of the substance and detail of
Post Office Board decisions without restriction?
Yes, whether I did or not, it comes down to my judgement
at the time and what the matter is and what I think
people's views are, but, yes, I never felt I couldn't
share the gist of it and the content of it. I wouldn't
necessarily share the papers themselves.
You said that you shared the vast majority of
information you received --
Yeah.
-- in your capacity. Can you give us some examples of
information that didn't fall within the vast majority?
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servants?
Yeah. I would filter that but yes.
But the filter you applied was not because of any
restriction?
No, it's to do with my judgement and what I think people
know and what I felt was relevant.
You tell us in paragraph 69 of your witness statement
that you found it difficult to identify the correct
balance when it came to the appropriate level of
Government engagement on the Horizon issue. What did
you mean by that?
I think -- sorry, without seeing the paragraph, um,
I think the position I inherited --
We can look at the paragraph to help.
Oh, I can just look --
Page 35.
Page 35, thank you. I should have brought my --
It will come up on the screen, page 35.
I think I explain it in the paragraph.
Just wait for it.
Sorry.
It was the sentence which I just read in the first line:
“In general terms, I found it difficult to identify
the correct balance when it came to the appropriate
level of Government engagement on the Horizon issue."
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I was largely thinking there of pensions, the pensions
subcommittee. So when I first joined Post Office I was
asked to go on the pensions subcommittee, which was
looking specifically at closing the defined benefits
pension scheme, because a deficit was emerging. There
was no one on my team particularly at that point that
really understood pensions. I'd dealt with pensions
under Royal Mail, so I don't recall particularly
sharing -- until we got to the point where there was
going to be an announcement about it -- particularly
sharing any pensions subcommittee --
That wasn't because of a restriction though, that was
just because the --
Yes, the --
-- circumstances didn't warrant it?
Quite.
So information could be shared, in your view --
Yes.
-- that you learnt in your capacity as Shareholder NED
through attending meetings, through reading Board
papers --
Yeah.
-- and otherwise --
Yeah.
-- without restriction, with ministers and civil
22
Yeah, yeah, so not unlike other arm's-length bodies I've
dealt with prior to that and was dealing with at the
time, you know, there's a balance between operational
independence of that body, because it's a specialist
body, and the desire sometimes of ministers and of
Government to intervene and do things. And I think on
Sparrow that was a particularly difficult one because
you had some very difficult stories, it was in the news
a lot --
Sorry, what do you mean you had some very difficult
stories?
Oh, sorry, well, the position of subpostmasters as
articulated by the story, you know, the -- their
experiences that were in the news, were obviously very
distressing and there's a natural inclination, I think,
of Government and particularly of ministers to want to
do something. But on the flipside, there is a business
there which is operationally -- maybe operationally
independent but also specialist, it is -- it's business.
And the -- trying to think about what ministers or what
civil servants like me could actually do, given it was
quite a sort of technical topic, it’s quite a difficult
balance.
And, I think, throughout my time, it was a constant
balance between trying to keep at arm's length and --
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from it because, realistically, there was not much that
I didn't think there was much that the ministers could
realistically do, whilst at the same time trying to make
sure that the Post Office are doing the right thing and
understanding what's going on at their end. And I just
found that quite a difficult balance, I think in part
because we never quite -- you know, sadly, and I regret
it - we never quite got to the bottom of whether there
was a -- where the problem was.
There were lots of investigations and each time
there was an investigation, it came back that there
wasn't really an issue and there were investigations
throughout my time, there's the Mediation Scheme, there
was the Parker Review and then the litigation. And
throughout that, particularly to the litigation, we
weren't really getting any particular news that there
was a particularly identifiable issue with Horizon which
caused losses to subpostmasters and, without that link,
it's very difficult to then do something.
Do you think, Mr Callard, that's a result of not looking
hard enough because now you've looked at some of the
papers themselves, ie you've looked at all of the Second
Sight Reports, you've looked at the Parker Review
itself --
Yeah.
25
Quite possibly but I mean --
Does that fairly represent --
I'm not sure what you mean by fatalistic, in that sense,
sorry?
le this needs to be litigated by the parties and a truly
independent view taken by a member of the judiciary?
Well, it wasn't that it needed a truly independent view
because I thought we'd had -- we were getting
independent views through from the likes of Second Sight
and I'm sure we'll probably come on to their reports in
due course. It was more about how do you -- my thoughts
about going to court was more about how do you draw
a line under it because when you've got a very committed
set of people in the form of the JFSA, who are certain
that there is a problem, and yet the investigations done
by Post Office, Second Sight and others, and including
things around like the Cartwright King review,
et cetera, are saying there isn't a problem, you know,
you'll never be able to meet in the middle.
So the court -- my views about the court were less
about there being independent scrutiny; it was more
about, if the court says -- you know, says what it says,
then there's nowhere else for either party to go, it
kind of arbitrates, and I always felt that I couldn't
really arbitrate in my position.
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-- rather than a letter summarising it --
Yeah, yeah.
-- you've looked in detail at the Deloitte reports --
Yeah.
-- rather than summaries of them --
Yeah.
-- and you've discovered a whole host of information
that puts an entirely different complexion on things?
Yes, it does. So, clearly, I was not curious enough.
I think that's probably self-evident but, as I said,
there was always some form of investigation going on,
there'd been 18 months' of investigation before I got
there, and I think that the problem I'd sort of had in
some respects was that -- and you can see this in some
of the papers by the time we get to December '14/early
‘15, and that represents what, about two years' worth of
investigation, what we're getting back is that there
isn't an issue with the IT, and so you get to the point,
well, every time we do review it says there isn't
something there and you're almost in the zone of trying
to prove a negative, that there isn't a problem and
I never thought that was ever going to be very easy to
get to, which is why I thought we always need to -- it
needs to go to court because --
That view might be said to be fatalistic.
26
Can I ask you to slow down a little bit in your answers,
even though they're very long, the shorthand writer is
struggling to take down each of the words that you say.
Okay.
Do you consider, standing back, that you showed undue
deference to what Post Office was telling you?
I think on reflection, I think you probably do have to
draw that conclusion. I would say, though, that the
stuff that we got, the -- the information that we got
through from Post Office was often quite comprehensive
and full and analytical. So when I look at things like
the response to the Panorama programme, the response to
the debates, that they put out in public as well, the
response to the Second Sight Part Two report, the slide
shows -- the 30-page slide show they prepared for
Baroness Neville-Rolfe, for example -- it was always
quite comprehensive and analytical and I thought well
thought through.
So I may have shown too much deference but what
I perceived at the time was quite comprehensive answers
coming my way. It wasn't a sort of one-line brush-off.
You said earlier that you think that you, looking back,
are guilty of a lack of curiosity.
Well, yes, I think -- it's self-evident there was a lack
of curiosity because, obviously, there was a problem and
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I didn't get to it. So I accept that. But I think that
there were times where, you know, I -- I think we were
curious, clearly not curious enough but, as I say, we
were getting a lot of information from Post Office, and
it was pretty comprehensive and analytical and looked
well thought through.
So you draw a degree of assurance from that.
Can I take you to some documents that may help us to
understand the relationship between you and Post Office
in the provision of information to outside sources. Can
we start, please, by looking at POL00100581. Thank you.
If we look at the bottom of page 1, please, we'll see
an email from Peter Batten to Belinda Crowe, copied to
you. Peter Batten was a member of the Shareholder
Executive; is that right?
Right.
Was he somebody who reported to you?
Yes.
He emails you and Belinda Crowe on 23 April 2014 and
says:
“Hi Belinda
“Many thanks for your time. Please see attached two
draft letters, one that we are proposing to send to Alan
Bates, and one to Sir Anthony Hooper (on the assumption
that the JFSA is unable to provide a reason for us not
29
Bates, I think, on 16 April. Going back to my point in
my witness statement about feeling the points of tension
between intervening or not intervening, we were very
aware that the Mediation Scheme was independent, we
understood Sir Anthony Hooper to protect his
independence very closely. So I think Sir Alan Bates'
letter was, I think, encouraging us to intervene. We
didn't want intervene because we felt the Mediation
Scheme should play out and we wanted to tell Sir Anthony
Hooper.
The reason why we ask Belinda is because she was
administering and leading the Working Group's operation,
and knew, I think, knew Anthony Hooper best, so we
wanted her view as to how he would perceive the letter
and how best to handle it with him.
Did you ever do things the other way round, ie write
a draft letter to Sir Alan or to Sir Anthony or any of
the subpostmasters and say, "We're proposing to say this
to the Post Office, is it okay if we say it"?
No.
So the Post Office were the source of your information
and vetted your letters?
No. They didn't vet the letters. I think we were very
sensitive about the Mediation Scheme because this is,
what --
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to forward the letter).
"We've included the final paragraph on the letter to.
Sir Anthony as a means of giving Jenny a future hook
into the process (for example in the event that she
feels she needs to intervene). I would be grateful for
your views on the benefits of including this hook,
versus the risks of perceived in infringement on
Sir Anthony's independence."
If we go to the top of the page, we can see that
Ms Crowe of the Post Office replies:
"Grateful if we could have a word about handling.
(I have also left you a message).
"Having had a good opportunity to look at the letter
I think that it contains some very significant points
which have to be addressed by both Post Office and the
Chair of the Working Group."
Just on a point of process or understanding how ShEx
worked, is it right that it will be normal that ShEx
would run drafts of letters that it proposed to send out
through the Post Office?
Not always, no. So it depends on the -- very much
depends on the context.
So, looking at this exchange, why was ShEx saying "Is it
okay, essentially, if we say what we want to say"?
Because -- so we'd received a letter from Sir Alan
30
April.
-- April'14. You know it's starting -- well, it's
definitely started to unwind in the sense that we've got
this letter from Sir Alan Bates. But it feels to us the
only way to really, still, to resolve a lot of the
concerns, and everybody had agreed, I think -- this is
before my time -- the Government would just stay out of
the Mediation Scheme to the extent possible. So we saw
Belinda as a sort of route to test how the Working
Group, in particular Sir Anthony Hooper, would want to
deal with the situation.
Thank you can we look at some other examples,
UKGI00002467. Look at the foot of the page, which is
the start of the chain. Melanie Corfield sending within
the Post Office a letter, a Sparrow letter, to Mark
Davies. Then scrolling up, 9 September, Mark Davies
sending that letter to you:
"Here you go. Let me know what else you need
(indeed, does this do enough for you)?"
Then scroll up a little. You say:
"Sorry, is there also an example of the inaccuracies
etc I could use to illustrate the issue?
"Cheers, and sigh ..."
He replies:
“Report claims power loss can lead to data loss and
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thus real loss for [subpostmaster]. Strongly refute
that."
Yeah.
So is the context here that -- in fact, you tell us the
context?
So I think the context is that the Second Sight -- the
first draft of the Second Sight Part Two review is out,
and I think we were providing advice to Jo Swinson.
I think -- well, we asked Post Office -- I'm not sure
whether we'd asked Post Office to provide a letter to Jo
Swinson or whether they'd volunteered one. They would
share a draft with me, essentially to check whether it's
intelligible and the like, and I think it said at the
top of the letter, you know, there are various
inaccuracies in the letter -- sorry.
The letter was saying that there was inaccuracies in
Second Sight's Report and I thought "Well, if I just --
I need to have an answer as to what -- an example of
what those are because Jo Swinson will ask, so can you
give me an example to substantiate what you're saying,
please, Mark?"
So why would you go to the Head of Media and
Communications for this issue?
Well, because that team would write the letter because
it comes from Melanie Corfield, who was his -- one of
33
No.
-- in seeking to --
No.
-- put the company’s best case to the Minister?
No, I'd say this is -- I mean, clearly there's a Venn
diagram of it but I'd say I'm a Shareholder Team here,
looking at what sort of communications the Post Office
is sending to the Minister and sort of giving them a few
hints and tips that it might be beneficial if they could
make it a bit clearer before it goes or I think probably
what's going on here is that they've either possibly
sent it already and I'm trying to get ready to
anticipate the questions I'm inevitably going to get
from the Minister.
Can we move forwards, please, to December UKGI00002726.
This is an email from you to Belinda Crowe and Patrick
Bourke forwarding a draft speech, I think, of the
minister --
Yeah.
-- in readiness for the WHD, the Westminster Hall
Debate --
Yeah.
-- that I think was to take place on 17 December 2014.
You say:
".., thanks for your respective emails. I will take
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his team, and say —-
So this is about a draft letter from --
From --
-- from Post Office to the Minister --
To the minister, I think, yeah --
-- and you're intervening and saying it needs beefing
up?
Well, they're writing to us to say "This is what we're
going to send", and they would often do that and we
would often ask to do that because I think, sometimes,
going back to my role as interpreter, sometimes what
they thought was clear wouldn't necessarily be clear to
Government. So they sort of sent it through -- it was
customary for them to send something like that to us,
not always, to get my view on it and I -- you know,
where I'm saying there, you know, "Your letter is not
clear enough can you give an example, so that when Jo
inevitably asks me ‘What does Post Office mean by
inaccuracies in the report’, I can say 'Well, what they
mean is this".
So it's trying to pre-empt the question, as it were,
that I know I'm going to get from ministers because
their letter isn't sufficiently clear.
So are you here performing the role of a Post Office
NED ~
34
a look and amend Jo's speech accordingly but given that
I'm about to get in a car for a couple of hours to drive
back home I thought this might be expedient to get this
off to you now to do a sweep of things we shouldn't say.
I hope I haven't gone too far -- the problems is that
ideally we wouldn't be having these debate, but as we
are Jo has to be able to say something reasonably
concrete in response to the accusations.
“Thanks to both of you for your help ..."
So you're asking them to vet the Minister's speech
it, is that right, "to do a sweep of things we shouldn't
say"?
Yes. The context, I would say there, is that (a) when
it comes to Parliamentary debates, there was always very
close -- a close relationship between Post Office and
the ShEx Shareholder Team because the Post Office is at
the operational forefront. So to give a non-Sparrow
example, you know, a constituency matter around
a closure proposal -- excuse me, sorry.
A debate around a closure of a particular
constituency, Post Office, or redundancies in the supply
chain or industrial action, that kind of thing, Post
Office can't speak to Parliament, it has to be the
Minister. We would therefore verify things and share
information and get information from the Post Office to
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be able to facilitate that debate and I think what I'm
saying there is "Here's the speech, is there anything in
there that we are saying that is sort of either
factually wrong", or whatever. So it wasn't be
unusual --
So would you routinely seek advice or input from the
Post Office on letters to be sent by ShEx?
Well, this is -- this could -- this is about the speech?
I'm talking about —-
Letters --
- looking at the run of things --
Oh, I see so not necessarily. No. Most of the time our
letters wouldn't be run past Post Office, although that
said, we would have standard stock responses for things
like a Post Office closure --
Okay, I'm going to have to try and --
Speed me up?
No, definitely not speed you up!
Sorry.
Ask you to try to constrain your answers --
Okay.
-- more directly to the questions I'm asking.
I'm just -- sorry, yeah, fair enough. I'm just saying
it's not unusual, it was standard practice to share some
things with Post Office. Usually, they were standard
37
third level question, in response to what they've said,
to sort of try and understand the response. I mean,
there would be rarely sort of backing documentation to
this sort of stuff. It would be a view where you'd be
asking "Are you sure? You say this but how about that?”
Can we move forward, please, to January 2015 and look at
UKGI00002996. If we scroll to the bottom of the page,
please. An email from you to the "Swinson MPST", is
that a generic email address for Jo Swinson's office?
That's her office.
Private office, is it?
Yes, it goes to four or five people who are in her
office.
You say "Alysa", who presumably is someone in her
private office; is that right?
"... further to my updates on the Horizon scheme,
note it looks as if BISCom are inviting [subpostmasters]
and [Post Office] to sessions on 3 February. I suggest
that Jo stays clear of this if she can given that this
is an independent scheme, but I suppose she might
inevitably be drawn in.
"I haven't talked to [Post Office] about this yet so
will keep you posted. I would be grateful if you could
provide us with Jo's views following my email of
yesterday as clearly this may have handling implications
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texts which we wouldn't have to share with Post Office
because we already had a shared agreement as to what we
were saying.
On debates?
On debates we would usually share that sort of text and
indeed they would come in and talk to the Minister about
the debate. It was very close because they're at the
forefront of the operational side of things, which is,
generally speaking, what the debates are concerned with.
What steps did you take, if any, to verify the lines
given to you by Post Office?
I think it depends on the line. So we wouldn't just --
if they made a change, we wouldn't just accept it. The
lines and the speech would be our speech but we're
checking what their -- whether they've got any views on
it.
How would you seek to verify the lines that the Post
Office was giving to the Minister to take either in his
speech or in correspondence?
Well, we wouldn't always verify it because it depends on
what it was. If --
On the occasions on which you did seek to verify it, how
would you go about that?
I don't know, to be honest. I suppose a lot of it would
be just probing and asking a sort of second level or
38
for [Post Office], although instinctively it feels that
the more conciliatory we are on this, the more the JFSA
get to try and widen the scope of the scheme to find
a smoking gun which does not exist.”
Then you forward this up to the page to Laura
Thompson, what role did she perform?
She had just joined the team.
The ShEx team?
Yes, taking over from Peter Batten, who was the prior
person looking after Horizon for me.
Saying that she:
"Better get up to speed on Horizon!!! So far we
have not been sucked in, but it's probably only a matter
of time."
Is that how you viewed matters at the time?
Well, you could feel the pressure building. We'd spent
a year trying not to -- to keep this as an operational
matter for Post Office and the pressure was building
that we might be required to intervene.
What do you mean by the suggestion that the JFSA were
trying to find a smoking gun which does not exist?
By that time, a lot of the mediation investigations had
been done. We hadn't heard of any specific problem with
Horizon that caused losses to subpostmasters, and there
was a -- there was a-- Second Sight were expanding their
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scope of work, and I thought that might be because they
hadn't found the issues they were expecting to find with
the Horizon scheme and therefore they'd be widening
their scope because they hadn't found the smoking gun,
which is the bug that creates the losses.
The words that you use appear to suggest, would you
agree, that you had formed the view that there would be
no smoking gun found in relation to problems with
Horizon system?
I think by that time I probably had. At least on the
balance of -- strongly on the balance of probabilities
that that is the -- that's the view I'd taken.
Did that mindset pervade your thinking and affect your
actions --
I think -
-- not only has one not been found, one will not be
found?
Yeah, because over the ~- I think that's probably right.
Over the course of time, the longer -- you know, another
year had gone by of investigations. In particular,
investigations of people's cases that had said there is
a problem, been looked at by Post Office, looked at by
Second Sight, we hadn't heard of a particular bug
causing the loss. So my emerging conclusion was, yes,
there isn't an issue and it did colour my view, going
41
from Post Office and yet so disbelieving of what the
subpostmasters and the MPs were telling you?
Because I suppose it's from the point of view that I was.
looking for a bug in the Horizon system that created
losses, with a direct link, I thought that's what
everybody was looking for, rightly or wrongly. That's
what I was sort of looking for.
Just stop there. Why were you looking for that?
Right, because that's what I thought the case was about,
that there were -- and it's often even said now in the
media today, there are bugs in Horizon. I thought we
were looking for bugs in Horizon that, therefore -- that
were unknown to Post Office and that they were causing
losses to the subpostmasters. I was looking for
a causation of -- finding an unknown bug that hadn't
been previously known about that caused the loss at the
subpostmaster end.
And, by this stage here, in February ‘15, as I --
I'd understood that that sort of investigation had been
going on in one form or another for two and a bit years
if not two and a half. So over that time, that's what.
gave me -- I won't say confidence but it gave me the
feeling that there wasn't a smoking gun knocking around
and that's why, rather than the JFSA widening the scope,
that's why I felt that Second Sight really were seeking
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forward from around that point.
Why were you so sure that the smoking gun did not, in
fact, exist?
Well, as I say, there'd been, I think, by that point
almost two and a half years of investigation, including
by Second Sight, and they hadn't found -- and they'd
looked at --
"Including by Second Sight", who had been the other
investigation?
Well, by Post Office, so Post Office had looked, and --
How had they looked?
Well, sorry?
What investigation had they conducted?
Oh, well, so as part of the Mediation Scheme, Post
Office had a team of 20 people that would be looking at
the each individual case. That case was referred to
Second Sight to also investigate. So you'd had two sets
of investigations with the first --
Is that how you viewed it? There were two
investigations going on here?
Yeah, that's how I viewed it. There were two
investigations going on, one of which is independent,
the latter one, Second Sight. I, you know, trusted the
first one, the investigations done by Post Office and --
Why were you so credulous when it came to reassurances
42
to widen the scope because they hadn't found any
particular problems with the individual cases where they
were saying there was an issue.
Can we turn to the issue of obtaining information from
the Post Office and look at UKGI00002292, an email from
you to Peter Batten of 1 May 2014.
Yeah.
If we just scroll down a little bit, thank you. In the
last paragraph -- I'm going to skip over the substance
if I may -- you say:
"... [hope I haven't crossed a line by saying Tim
mentioned you were worried that I apportioned some blame
to the team for the press notice stuff.”
So I think this part is about a press notice. I'm
not sure exactly what it's about. You continue:
"I just want to be clear that I don't at all -- it
has however taught me a lesson that I need to push
harder on [Post Office] to get things done, I have been
too reliant on their promises to deliver, which has been
an error on my part. We do however need to be realistic
as well -- our view and their view will often be
different ..."
Yeah.
"[And we're going to have to] pick our battles."
Yeah.
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What's the context of this; can you remember?
I honestly can't remember. I think it's something to do
with number 1 about -- because it's a press notice: Mark
Davies and I think Becky Barrow was a journalist of some
description. But I honestly can't remember the --
You said that you had been too reliant on Post Office's
promises to deliver.
Yeah.
Other than in this context, was that a theme of your
work over the four years that we're looking at?
Um --
Did you feel that you were over-reliant on them?
That I was overreliant? Well, I was reliant on them,
I don't think I was overreliant on them. I mean, it
depended on what the issue was. But in terms of comms,
which I think this is about, it's about relying on them
to do it in a way that we felt appropriate, I think.
I can't really remember, I'm afraid.
Can we turn to POL00158108, please, and look at page 3,
please. Scroll down. Keep going.
Yes, we can see this is signed off by Neil
Hayward --
Yes.
-- Group People Director. Do you remember the function
that he performed?
45
Would that record of what you were said to have said
be accurate --
I can't really remember but --
-- ie the content?
Yeah, that's probably something I might well have said.
If we scroll up to page 1, please. Ms Vennells' reply:
"... see the note below."
She's forwarding this to Alice Perkins. Scroll down
to the direct reply, she says:
"Richard [that's you] asks the right questions.”
Then in the next paragraph:
"Richard has the job of making sure the Government
gets a return ... We are in the delivery phase and
(within BIS) he is accountable. We need to make him
comfortable and confident that we will deliver what we
set out to."
Then scroll on a little bit, please, three
paragraphs from the bottom there:
"Richard's scope has not yet picked up Sparrow or
Business Transformation. It will as he is attending
next week's Board meeting. But as this is the case,
I suggest we leave them off the ShEx review agenda as he
will be well briefed by then."
So looking at this exchange generally then, at the
time that you joined Post Office as a NED and took over
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Yes, he was People Director, like HR Director.
If we go up, please, and keep going. Thank you. Just
a little bit further. I think we can see from the reply
here that I think Mr Hayward's email went to, amongst
others, Paula Vennells?
Yes.
Okay, if we scroll back down to the beginning part of
his email. So February '14:
"[For your information] -- I recently met with
Richard [that's you] during his induction and mine to
the Post Office.
"He provided me with some insight on the things that
interest him ... I thought I should share what I learnt
Scroll down, please:
"The Post Office is hugely politically important.
Whilst it is probably the third biggest of the [around]
20 or so businesses being managed through Shareholder
Executive, it carries the highest profile. Everything
that we do has the potential to create issues for
ministers. This is partly why he/they will always ask
us detailed questions. He also explained that [the]
Treasury applies pressure to ensure that the investment
in the Post Office is doing what we/they said it would
do."
46
as the lead on the ShEx team, was it the case that Post
Office carried the highest profile amongst all of the
businesses managed by ShEx?
I think so, yes.
How did the political importance of the Post Office
impact on the nature and extent of ShEx's and
ministerial interest in Post Office?
Sorry, can you explain the question? Sorry.
Yes. How did the political importance of the Post
Office, which is explained or described in this exchange
here, impact on the nature and extent of ShEx's
involvement in or oversight of Post Office? Did make it
different from any of the other 19 businesses?
No, it's not a question of degree but there was always
interest, politically, both from ministers but because
of interest in Parliament and the media around what Post
Office was doing, whether it be its Network
Transformation, whether it be putting Crown Offices into
WHSmith. Anything and everything always seemed to
create a lot of media attention and Parliamentary
attention, which just meant there was a lot of scrutiny.
Mr Hayward said that you wanted to get underneath the
surface a bit, you'll remember, in that email?
Mm-hm.
What did you do to get under the surface a bit --
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Well --
- in practical terms?
In practical -- well, we were on the phone to Post
Office and emailing Post Office practically every day
about every different, you know, overwhelming number of
issues. So anything from tearing apart their funding
plan to understanding the latest they were having with
a particular issue. So it was a constant stream of
areas that we would discuss with them, from industrial
relations to closing the pension scheme, to particular
constituency -- sorry, particular Post Office closures
or changes.
There were very -- there was a mix of very macro and
micro issues constantly coming our way that we were
interested in and we would go and ask them questions, we
would go and visit them, we would get on the phone, we
would send them emails and we would try and get
satisfied with what they are telling us.
Was there a document which told businesses which ShEx
managed and oversaw what Government expects of it?
I'm not sure there was. I mean, there are framework
agreements and articles of association and those sorts
of constitutional structures, and there are Chairman's
letters or letters to the Chair and those sorts of
things. So it depends on the company.
49
Yes.
In order for this to be effective, presumably the
business would have had to have been given this?
I can see why you'd say that. I'm not sure if it ever
was and I think that would be more around the idea that
the Shareholder Team would -- this is what the
Shareholder Team should expect of its business in --
But you don't tell the business about it?
But I don't think you tell the business about it, no.
That seems slightly odd, if I may say so, Mr Callard?
Yes, but I think you're placing reliance on a single
internal document that was done in 2007, which by 2014
things had moved on. I mean --
Was this updated then?
I don't know, I don't think it was. For example, it
doesn't mention -- and it's on page 2, it doesn't
mention having a Shareholder NED because time had moved
‘on. So I think this -- I don't know what happened to
it, to be honest.
I've been looking for a document that emanated from
Government that would be passed to a business, telling
the business what it, Government, expected of it --
Yeah.
-- in terms of general principles --
Yes.
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Could we look, please, at UKGI00044314. This is part of
the ShEx handbook; do you remember that?
Only vaguely. I remember it being written when
I arrived in 2007.
Was it not a document which, being a handbook and
everything, that people might have recourse to?
Not particularly, no. I don't recall it really being --
out of the first few months of it being in existence, it
didn't really get, from memory, really get rolled out.
I mean, when I saw it, I was like "Oh, I remember what
that was", but I don't recall it particularly being
rolled out as something that everybody had as
a handbook.
Was it, even when limitedly rolled out, something which
businesses which ShEx managed were directed to or given
a copy of?
I don't think so. I think it was internal but I don't
know for sure. I mean, it may well have been at the
time.
Can we look at page 3 please. This is in the section of
"Corporate Governance". If we scroll down, please.
Just go back to page 2, please, and then page 3., and
scroll down, and over the page. Thank you.
The heading, "What Government expects of its
businesses".
50
-- of governance, and this is the closest I've been able
to find. You say that this would have been an internal
document, even though it set out expectations of
businesses managed by ShEx and may not have been passed
to them?
Well, I can't remember what happened to that document.
Clearly, times have moved on but I think the stuff
there, looking at it, is stuff that you would expect
a business that you are the shareholder of to be doing
anyway.
So:
“Businesses” --
Should be open -- honest, open -- sorry.
- "should seek -- an honest, open and ongoing dialogue
with the Government as shareholder. They should clearly
communicate the plans they are pursuing and the likely
financial and wider consequences of those plans.”
Principle 1.
"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."
Yeah.
Then:
"Principle 8. Businesses should have and continue
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to develop coherent strategies for each business unit.
The approach to reviewing strategy should be a dialogue
between the Board and the shareholder."
Yes.
You say that these are essentially -- have I got you
right -- so obvious that a business ought need to be
told about them? (sic)
Yes, I guess so. I mean, I don't - you know, I was --
at this time, when this came out, I was an assistant
director. So I don't know quite what happened and why
this sort of phased away and I've no idea what happened
to Principles 3, 4, et cetera. But yes, I think you'd
expect, and we would expect as a shareholder team,
business to -- businesses to operate that. That's kind
of the culture that we would expect a business would
have and that we would operate, and then -- on the
understanding of.
So when you joined in 2014, were you aware of any of the
following: that the Post Office had known about a whole
series of bugs, errors and defects in Horizon that had
existed right from its inception since 2000?
No.
That that included the Falkirk bug from 2006?
I think what I understood was the Second Sight advice,
which had two bugs, mentioned two bugs —
53
Yes.
By whom?
Anybody that was talking to me about Sparrow.
I mean, they were issues that were relevant to -- or
they were matters that were relevant to issues in the
Group Litigation --
Right.
-- would you agree?
Well, yes, they're certainly relevant.
Whether Horizon was robust and whether subpostmasters
had been liable under their contracts for alleged
shortfalls. To whom do you attribute responsibility for
the Government not being informed of such matters?
That's hard to say because those matters are quite
historical. So I don't know who would be -- whether it
would be the Legal Team that should have that on file
and should tell people about it.
Was ShEx ever made aware of the Simon Clarke Advice in
relation to the credibility of the Post Office's main
expert witness, Gareth Jenkins?
No, the first time I learnt about the Clarke Advice was
in the sort of fallout of the GLO, I think.
Sorry, you learnt about I in the context of the GLO?
Yes, when it got raised in the GLO, that there was
advice -- the Clarke Advice, that was --
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One of which was Falkirk --
Right, okay.
-- is that right?
I can't remember, I'm afraid. So I knew that there
was -- the position I understood, as I came into the
role, was that there was no systemic failures, given
there's probably a discussion about what that really
means, and then there were two known bugs. But my
understanding was that those -- that the losses caused
by those bugs had been corrected by Post Office and the
subpostmasters didn't lose out. So that was my
understanding of the extent of bugs.
Were you ever told that it, the Post Office, was in
possession of expert reports as a result of civil
litigation that it had engaged in, in 2004 and 2006,
which challenged the proposition that Horizon was
robust?
No.
Were you ever told about the previous acquittals of
subpostmasters, each of whom had raised the defective
operation of Horizon as part of their defence. The
names included: Suzanne Palmer, Maureen McKelvey and
Nichola Arch?
No.
Would you expect to be briefed about that kind of thing?
54
Can you tell us a bit more about that?
Oh, well, it was just -- I think --
Because, as far as we know, the outward-facing
disclosure of the Clarke Advice didn't occur until
November 2020, in the context of the criminal appeals?
Okay, so maybe when I say GLO, I mean the legal cases
that happened after me. Sorry, I don't mean
specifically -- well, I -- I don't understand the
nuances between the different cases but, as part of the
findings against Post Office, I heard about the Clarke
Advice, but that's the first time I'd heard about it.
You've seen it now?
It was in my bundle.
Yes. Is that the kind of, in the light of the questions
that you were asking and the things that the Post Office
was saying publicly, is that the kind of document that
you would have expected to have been provided with or
the contents summarised to you?
Yes, and I would expect the Board to have been
provided -- before I got there, the Board to have been
provided with it immediately, given the Board then was
looking at prosecutions and the safety thereof.
Of course, the duties set out here, or the expectations
set out here, cut both ways, don't they? There was
a duty on ShEx to exercise a degree of professional
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curiosity and scrutiny; is that right?
Yes.
You said that you accept personally that, on reflection,
you were insufficiently curious?
Yes, I think that's self-evident because I didn't get to
the bottom of it.
Is that the basis on which you say you were
insufficiently curious, ie that, in fact, there were
things that you did not discover, or is it a more
nuanced reflection on what you, in fact, did or didn't
do?
Well, I think that it's -- it's probably both. I mean,
clearly I'm one part of this but I -- it's difficult to
know what to ask, if you don't know about it. So you
can't go and ask "Well, is there any evidence that
you've got that prosecutions aren't safe?", when it's
been present to Board before you've got there that
prosecutions are safe and that was set out by
an independent firm and a KC.
You take -- you have to take assurance from the
independent advice that's been given to a Board before
you get there.
When you were first appointed as Shareholder NED, what
was your understanding of Post Office's investigatory
and prosecutorial functions?
57
a member and I was still getting to grips of all of the
things of Post Office. I wouldn't have thought too
deeply about that paper.
So is the comfort that you took, hearing the words that
a firm of solicitors and a QC have undertaken a review,
and the outcome of it was reassuring --
Well, I -
-- is that as far as it went?
Well, I took comfort from the Board. I mean, the Board
that I'd joined had had that advice, was broadly
comfortable with it and whenever -- you know, the focus
of the Board thereafter tended to be around the
Mediation Scheme, not past prosecutions. So I didn't
just take comfort from the paper that I read; I took
comfort from the fact that the rest of the Board -- it
didn't seem to be an issue that the rest of the Board
were vexed about, so I took my lead from that.
Did you ever receive any copies of legal advice that
Post Office obtained during your time either as
Shareholder NED or as ShEx?
I can't remember. I may have done but I can't think of
any instances.
So you can't recall any instances where you actually
read the advice, rather than what Post Office said was
in the advice?
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There'd been quite a comprehensive discussion in the
February Board about the new Prosecution Policy and that
paper contained a reasonable amount of detail about the
history, in addition to the forward look about the new
policy. So I was aware quite early on that Post Office
bought prosecutions, I don't think I understood the
nuances of that, of being prosecutor, victim,
investigator.
In your witness statement you say -- and for the note
it's paragraphs 273 and 329 -- that you understood that
there had been a review in 2013 by Cartwright King and
Brian Altman QC which had been reassuring, and:
"The comfort I took from what I understood to be
a thorough review by Cartwright King and Brian Altman QC
was Clearly misplaced. I had never heard directly from
any of the affected subpostmasters on the issue of past
prosecutions."
You say that you and the Board were not provided
with a copy of Mr Clarke's Advice of 15 July 2013.
At the time that you were told about the Cartwright
King review, did you understand that, to an extent, it
was marking its own homework, ie reviewing prosecutions
which it itself had brought?
I don't think that occurred to me. I mean, I learnt of
it in the first Board that I observed -- I wasn't
58
I can't think of any instances. Not saying there
weren't any, but --
Did you ever request any copies of the primary material
itself, ie what the actual lawyer actually said?
Well, I can't think of an instance that -- outside of
the Sparrow situation -- where there was legal advice.
Hold on, sorry. Wait a minute. I may have seen some in
relation to the procurement -- reprocurement of Fujitsu.
I guess the Linklaters advice of March ‘15 is legally
privileged. I mean -- so yes -- so I will have seen
some.
Was there a prohibition, to your understanding, on Board
members seeing the legal advice itself?
Not that I understood but I've since seen evidence from
others, such as Tim Parker, where that has happened.
I didn't understand there to be a prohibition.
Was that ever the subject of discussion, ie Board
members saying, "We actually want to see what is said by
our legal adviser, rather than what somebody says the
legal adviser has said"?
I don't recall that ever being discussed.
MR BEER: Thank you.
Sir, it’s just after 11.05, I wonder whether we can
take our first morning break until 11.20 past, please?
SIR WYN WILLIAMS: Yes, of course.
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MRBEER: Thank you very much, sir.
(11.08 am)
(A short break)
(11.20 am)
MR BEER: Good morning, sir, can you continue to see and
hear us?
SIR WYN WILLIAMS: Yes, thank you.
MR BEER: Mr Callard, can you move right forward and aim
both microphones at your mouth, please. I've been told
that those listening online have sometimes encountered
difficulty in hearing you.
A. Right.
Q. Thank you. Is it right that one of the key roles of
ShEx was to identify risks in relation to each of its
assets?
A. Yes.
Q. Is it right that ShEx maintained a monthly risk
register?
A. For each asset, yes.
Q. sit right that the completion of that risk register on
a monthly basis didn't simply entail recording the
business's own assessment of risk but was in fact ShEx's
own assessment of the risk?
A. That's right.
Q. As the person who led the Post Office Shareholder Team,
61
Q. If we go to title and guide, so bottom left.
A. Yeah. It's just the reason why I'm saying that is
because the person that's got the -- one of the risks
around the Post Office Card Account is Leonie Lambert,
who joined the team at the end of 2014.
Q. So what's the point that you're making --
A. Well, because you're saying that it's a February '14 and
I'm saying it's probably eight months beyond February
14.
Q. So
A. Or--
Q._ -- this is a document that UKGI sent us?
A. Yes.
Q. It's got on it, can you see, "Last updated 13 February
2014". Can you see that? Third box down, "Last
updated" --
A. Yes, I can. Yes, I can.
Q. Are you saying that's wrong?
A. 'mnot sure but I know there was a different person —-
if we're dealing with February '14 there was a different
person in charge of some of those risks at the time, so
I'm not entirely sure of the date. So the risks though
broadly are probably similar to what they were in
February ‘14.
Q. So if we go back to risk register, thank you, and can
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was it ultimately your responsibility to ensure that the
risks were (a) properly recorded --
Yes.
-- and (b) adequately assessed?
Yes.
Was it, therefore, your responsibility to ensure that
you and your team had sufficient information in order
properly to record and assess risk?
Yes.
Can we look at some examples across the years, please,
starting with 2014, by looking at UKGI00002515.
This is the risk register for 13 February 2014. So,
just for some context, that is seven or eight months
after the publication of the Second Sight Interim Report
and, as we now know, at a time when the Post Office was
aware of problems connected with Mr Jenkins’ evidence in
criminal prosecutions and at a time when advice was
being sought externally from the likes of Cartwright
King and Brian Altman KC.
Could you just scroll down? I was looking at this last
night, so -
To which line?
Well, where you are now. I'm not sure whether it --
because the date should be in the top right-hand corner,
where it says, "TBC".
62
you point to the person --
So Government digital transformation, that was Leonie
Lambert, and the Post Office Card Account, risk 6,
Leonie Lambert. She joined the team, I think, towards
the back end of 2014. It was, prior to that, Katrina
Lidbetter that would have looked after those things, she
was there as the Government Services person when
I joined the team.
So what does that mean for us then --
Well --
Hold on.
Sorry.
We shouldn't rely on the dates on the UKGI risk
registers as being true?
To be honest, I don't know, actually, what it means.
All I was saying was, because you were putting it in the
context of it's February and it's X number of months
after Second Sight. I'm saying it's not. I think it's
actually perhaps a little bit beyond that. So that's
all I'm saying. In case you --
Yes, I mean, I'm not challenging you.
Yes.
I'm seeking to understand what reliance this Inquiry can
place on UKGI's documents. I mean, if we look, for
example, at line 7, if we scroll down, there's an entry
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there with - and the third part of column B -- just one
to the left if you put the cursor one to the left,
that's it - can you see it says "13 February 2014,
terminated 1 October 2014", which tends to support the
point that you're making.
Yes, yes.
So --
I don't know --
-- how should we treat these documents?
Well, I don't know. I can only imagine that 13/02 in
each of those is the date that risk was created.
Going back to "Title and guide", page 1?
Yes, I noticed. Yeah, I get that.
That says, "Last updated".
I know.
Because, obviously, the risks changed sometimes?
Yes, no, I get that entirely but I'm just pointing out
that what date that document comes from. I think "last
updated" -- I don't recall us ever really updating the
first page because the interesting bits are on the
second page.
So where it says, "Last updated”, you don't recall that
ever being updated?
No, I don't -- in fact, I'm not sure whether they even
come around with that "Title and Guide" page on any
65
which have the top right date put on them and that's
what should have happened, I don't know why it wasn't --
why it happened. I mean, these risk registers came in
around about February, which is why all those entries
are created then, I think. So people were still getting
used to populating them and possibly didn't populate the
top right-hand ...
Was the purpose of the risk register to act as a tool to
provide a snapshot of known risks, to provide a tool to
ensure prompt oversight and discussion of risk
management on an ongoing basis and then to provoke
action as a result?
Yes, it provided an opportunity for the team to think
about risk and to communicate risk sort of into the
centre of ShEx.
Is that right, an opportunity to consider risk and to
communicate what the risk was, rather than do anything
about it?
Well, inherently, we were doing stuff about all of these
risks. I mean, we wouldn't write risk down and then not
deal with it (unclear) steps to deal with it.
So the act of assessing and then recording the risk was
a tool to ensure action was then taken?
Yes, because what you would tend to do on these sorts of
risk registers, the risk would stay the same. The
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more. They just come around as the risk register.
Just going back to the risk register, then, please?
Sorry, if I'm causing some confusion.
No, it's not. It's just the extent to which we can
place reliance on the documents that are given to us.
We shouldn't treat this as a document which accurately
records the risks as the ShEx saw them on 13 February
2014?
Yes.
Some of the text may have been inserted after that date?
And the ratings may have moved around a bit.
Given that this was done on a monthly basis, if we look
for the March one, oughtn't that to be the place to
update it, rather than updating the February one?
Well, I -- this is probably the -- you know, this is,
I would imagine it has been updated in March and April
and February and -- until we get to October, and then
this is the October view, as it turns out to be.
I see.
Yeah.
So we should search through the document and look for
the latest date that there's an entry on it and we could
say confidently that it has been amended at least at
that time?
I've seen plenty of risk registers that are in my bundle
66
mitigations would move around a little bit, but
generally speaking the change would be in the far
right-hand column of "Current status", which is
essentially saying this the latest and it would either
set out what we've done or what is happening.
Can we look at lines 55 to 57, please -- thank you --
and risk number 11, which is Project Sparrow.
Mr Batten's name underneath it, is that the lead on the
risk or the owner of the risk?
He's the -- essentially, the person leading the work on
it so if there was ever a Sparrow issue I would turn to
him and ask him to do the work, in the same way, if it
was the Mail's contract above, I'd ask Tim to do that.
If we look under Sparrow, it's quite difficult to read
because the words "Page 2" are printed over the top of
it, but just reading along all of lines 55 to 57, so the
entirety of the risk numbered 11, there doesn't appear
to be anything that addresses that one of the risks that
had arisen was that Post Office may have prosecuted
individuals wrongly on the basis of data which lacked
integrity, does there?
No, that's right. It doesn't.
If we look at the fourth column along, so -- I'm
sorry -- the fourth one with writing in it, which
I think is column K.
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I'm so sorry, I mean column F. Thank you. That's
the one.
Can you see that the type of risk is recorded?
Yes.
It's record as being a reputational risk, a finance risk
and a people risk. It doesn't record the existence of
a legal risk. Do you know why that would be?
I don't. Is legal an option?
I don't know.
Well, the dropdown box would tell you.
Well, ought it to be an option?
Well, if that was -- I suppose so, yes.
And --
Although -- sorry -- the risk register would often be
about the risk to ShEx, as much as the risk to the --
Well, I was going to come to that question ultimately,
in a moment --
(Unclear)
-- but you might as well address it now as you've
mentioned it. Which organisation did the risks recorded
‘on this document relate to?
The risks should relate to ShEx. What would often --
and UKGI. What would often happen is that inherently
the risk to the organisation would sort of creep in and
it would get conflated because, if something at the
69
Post Office in its relationship with Royal Mail, which
it was -- which it was very reliant on.
I think what's supposed to happen is each numbered risk
is then meant to be translated into a box or a circle --
Yeah.
-- that appears on the heatmap; is that right?
I think at that stage we used to summarise the top six,
so you'd only put the top six circles on.
I was about to say: is that why Project Sparrow doesn't
even make it on to the heatmap?
Yes, because there are six other risks perceived to be
higher.
So risk 11 doesn't make it on to our heatmap at the top
there?
That's correct.
Would you agree there appears to be no mention, either
in the text or otherwise, of the possibility that the
Post Office may have prosecuted individuals and those
prosecutions may have resulted in unsafe convictions?
Yeah, well, on reflection, yes, that should have been --
There's no risk mentioned that Horizon might lack data
integrity, which could undermine the functioning of the
business, is there?
No, and I think that that's -- well, I can speculate why
that is but, no, I agree.
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organisation goes wrong then, essentially, ShEx has to
deal with the fallout of that. So, in this case, it
might have reputational risks for both Post Office but
also for -- largely for ShEx, in terms of having to deal
with the issues that are involved with it.
If you just look at the next column along, sort of G, H,
land J, which is the RAG rating boxes; can you see
those?
Yes.
The probability of the risk eventuating, the impact of
the risk if it does happen, and therefore the rating of
the risk, can you see that this risk rating rates
Project Sparrow overall as having a risk rating of 9,
which I think is the lowest or one of the lowest risks
identified in this document?
I can see the -- a9, yes.
Did that reflect the contemporaneous assessment of the
risk to both ShEx and to the Post Office that Project
Sparrow was low risk?
I think that it reflects, yes, where we had got to in
terms of our thoughts around the investigations that had
happened by that point but it's also put in ~ it's
relative to other risks which we perceive to be higher.
So, for example, 10, above it, is perceived to be very
high because there were existential threats perceived to
70
In fact, Sparrow is perceived not to pose any legal risk
to the Post Office or ShEx. Such risk as it does pose
is reputational, financial and people. In column E, the
risk recorded is reputational and brand risk due to
a perception; is that how things were seen?
Well, because it's -- the impact of risk, it's talking
about the risk of the Working Group failing.
Do you think the things that I've mentioned counters
omissions?
On reflection, knowing what I know now, yes, I would
agree.
Do those omissions reflect a rather cursory and limited
nature of the assessment of risk being undertaken?
No, I disagree with that.
The Post Office had focused significant attention on
Horizon issues during the work of Second Sight, hadn't
it?
It's what, sorry? Say that again?
The Post Office had focused significant attention --
On the --
-- on Horizon, in the course of the work of Second
Sight --
That's correct.
-- and, at this time, was still undergoing a review of
past criminal convictions? As I've said, it had taken
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advice and was taking advice from Brian Altman and
Cartwright King.
A. I had understood that they were over by then, I think.
Q. I see. So do you think that's why they're not
mentioned?
A. Soyes. So think, on entering the business in around
about February, from my perspective there has been
a review by Second Sight with an Interim Report that
says there's no systemic failures in Horizon. Stemming
from that, the business has responded with a business
improvement programme, a review --
Q. Sorry, just stopping there, you framed the Second Sight
Interim Report of 8 July as a report which said there
are no systemic problems in Horizon --
A. Idid. I was --
-- is that how you saw it?
2
A. I saw the ~ yes, the position that I felt that
I inherited was that there had been a report which said
there was no systemic failures within Horizon, but the
business's response to that, nevertheless, was to review
the safety of prosecutions -- Cartwright King -- to set
up a business improvement programme to deal with some of
the issues around training, and also to set up
a Mediation Scheme to investigate the individual cases
that postmasters still had with Horizon.
73
A. Yeah, well -- yes, so you identify a risk.
SIR WYN WILLIAMS: Yes, so what, in terms of this risk
register, do you understand Project Sparrow to be?
A. I understand it to be the -- essentially, the progress
of the Mediation Scheme to bring resolution to both
subpostmasters and Post Office in the remaining 136 --
‘or not remaining, but the 136 cases where subpostmasters
came forward and had an issue with the working of
Horizon.
SIR WYN WILLIAMS: Right. So if we understand Project
Sparrow in the -- what I'll call for these purposes the
narrow sense of the Mediation Scheme, to my way of
thinking, at least, what follows kind of makes sense
because you're assessing the risks associated with that
scheme. What's lacking, I think, from this register, it
might be argued, is any recognition of any kind of any
‘other potential risk arising from the use of Horizon.
A. Yes, and I would agree with you, and the reason for that
is because we thought that, of the things we were
seeing, either the risk was so small, you know, it
didn't really warrant a -- either it wasn't there or it
didn't warrant an entry because the probability of it
occurring was below 1 out of 5. So if the --
SIR WYN WILLIAMS: Effectively, you're telling me that the
wider risks which are being put to you by Mr Beer, in
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But by, certainly this time, if this is around about
October '14, you know, there had been quite a lot of
investigation by Second Sight, and by Post Office, into
the safety and integrity of Horizon, and therefore --
and I -- as I said before, I hadn't seen any evidence
that directly linked bugs -- new bugs -- any bugs in
Horizon to losses that hadn't been compensated for --
Q. I see. So the fact that the possibility that the Post
Office may have wrongfully prosecuted individuals or
that Horizon lacked data integrity, was such a remote
possibility that it needn't even be recorded on a risk
register?
A. I think that's probably right. We felt that the bigger
risk was the blue blobs that are there, plus, in terms.
of Project Sparrow specifically, we were looking to --
for Post Office to sort this out via the Mediation
Scheme and the Mediation Scheme was not going very well,
and that felt to be the bigger risk. The other risks
that you've just cited there were felt to have been --
wrongly, as it turns out -- were felt to have been dealt
with, which is why they would be very low probability
and so probably not on there.
‘SIR WYN WILLIAMS: Sorry to interrupt but item 11 is the
identification of a topic which might give rise to
a risk, all right? Is that a fair way of starting that?
74
your mind or in ShEx's mind, or UKGI's mind, actually
didn't qualify as a risk sufficiently important to put
on this register?
A. I think that's right, given what we knew at the time and
the information we --
SIR WYN WILLIAMS: Yes, I follow that's your reason --
A. Yes.
‘SIR WYN WILLIAMS: I -- but I just wanted to understand in my
head --
A. Yeah, no, no --
SIR WYN WILLIAMS: I -- just before -- have I got it right?
A. Yes, I think so. Yes. So we were very much focused on
the Mediation Scheme and trying to get that to be
successful and for Post Office to make sure it runs --
MR BEER: Can we move forward, please, a year to February
2015, UKGI00003427. If we can just go to the
"Guidance", please, the "Guidance" tab.
A. It's different.
Q. Yes, it's changed in nature. If we go back to the risk
register?
The top right-hand date is now correct.
Yes, February '15, 28 February 2015. On this occasion
shall we treat that as being a true date?
Yeah, I think we probably should.
So just to put this in context, 28 February '15, this
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was couple of weeks after Paula Vennells and Angela van
den Bogerd had appeared before Parliament, the Select
Committee, on 3 February 2015. I think also by this
time, the relationship between Second Sight and Post
Office had deteriorated still further; is that fair?
Yes, that's fair.
If we go to -- thank you, we're there -- 55 to 57,
Project Sparrow described in the same way, "Owner has
changed". Should we understand, following the
Chairman's questions, the reference to Project Sparrow
in the same way as you described it in relation to the
previous spreadsheet, namely in the narrow sense of
referring to the conduct of the work arising from Second
Sight's Interim Report and the operation of the Working
Group?
No, I think I'm -- Sparrow, as you've seen me use today,
became a sort of catch-all term for anything to do with
Horizon. So I would imagine that might have -- the term
"Sparrow" might have widened out. It wasn't
specifically focused on the Mediation but that probably
was our focus still at the time.
Do we understand the identity of the risk differently,
in the use of the words "Project Sparrow" on this
spreadsheet?
I think it's an evolution of where we were from the
77
"JFSA are increasing the profile of this issue,
including them and Post Office going to BISCom in
February. We've managed to keep ministers distanced
from this at the moment but we are seeing increased
correspondence in this area, risk level remains the same
for now, given ministerial distance."
Who had managed to keep ministers distant from the
Horizon issues at the Post Office?
Well, by distant what I think we mean is it's
an operational matter for Post Office.
So in the arm's length sense, the arms had got longer?
Well, the arms had stayed the same length, I would say.
Well, I think over time you'll see sometimes the arms
get longer when it suits Government and then get shorter
when it doesn't?
I'm not -- well, you see ministers wanting to do that
and often our advice would be, no, it's an arm's
length -- it is an operational matter for the business,
they're best placed to deal with it, in our view,
rightly or wrongly, and that was the advice we gave.
So who had managed to keep ministers distanced?
Well, I suppose it's a combination of factors but yes,
it's our team in the sense that --
How are they --
Well, in the sense that where there was inbound
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prior spreadsheet. So
So does this refer Project Sparrow now to wider issues,
the bigger issues, as the Chairman described them?
Well, yes, in the context of having a Mediation Scheme
which is clearly not working very well and a situation
where there is more pressure on Post Office and the
Government because of that fact.
We'll see that the risk rating in columns G, H, I and J
has not changed at all.
Yes.
Can you see that?
Ican.
Again, I think it doesn't even make on it onto the
heatmap?
No.
Had the risk therefore really remained unchanged since
February 2014, or October 2014?
We're clearly saying that it has stayed the same.
I think by the time I arrived in -- and got to grips
with Sparrow in February and March, it was already the
case that the Mediation Scheme was in trouble and so
I would imagine the risk -- my perception of risk hadn't
really changed over that period of time, even though,
you know, the circumstances possibly had.
If we look at the final column, column Q:
78
correspondence we would say that's a matter for Post
Office and we would ask Post Office to deal with it
so --
You would roll out the "It's an arm's length -- an ALB
situation, it is an operational matter"?
Well, yes, because we felt that it was an operational
matter. We had obviously been involved -- or there'd
been due based I think in December '14 with Jo Swinson
so they had been involved a little bit more but,
generally speaking, our position was still that it was
an operational matter for the business and that was the
best place to sort it out.
If there was limited risk and the risk remained
unchanged, why was there a need to keep the issue away
from ministers?
Well, because the position of -- that I inherited hadn't
changed in that sense. There was still -- it was
an operational matter for the business, there was lots
of stakeholder correspondence and Parliamentary activity
about it but, you know, in essence, it wasn't all that
different to the position I'd started with.
That last column tends to suggest that a function or
a primary function of this risk register is about the
risk that the Post Office posed to Government, rather
than the risk that the Post Office posed either to
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itself or to the public.
Well, perhaps there's an element of that because, as
I said, it was a ShEx risk register, rather than a Post
Office risk register, but we were always mindful - my
job as a civil servant, with my civil servant hat, on is
to try and deal with and protect ministers from undue --
or even due, sometimes -- criticism. This was
an operational matter for the business, that was the
position that was established with ministers, even
before I joined, and that was what I was trying to do.
Was thought ever given to maintaining a risk register
that recorded the risks that the Post Office posed to
itself or to the public?
No, because we'd see that as being a thing for the Post
Office to do.
Did you ever ask to see Post Office risk registers?
I -- not specifically but I think they would have
been -- come out in part of the Board pack. When
I joined the ARC I would have seen but I'd taken
assurance that the ARC, that I didn't sit on initially,
would be dealing with that side of things.
Can we move forward, please, to 2016. UKGI00006622.
This top right is 29 February 2016, so a year further
‘on. If we look, please, at lines 40 to 42, we can see
Project Sparrow.
81
time.
Yes, and we -- when the new Government came in, in May
"15, we tested that position about whether it's
an operational matter with ministers, to which they
agreed.
So it was understood that the Chairman, Tim Parker, was
undertaking a review with an independent QC, the CCRC's
conclusion was imminent and mediations were completed.
In those circumstances, what had happened to increase
the risk assessment?
Well, the mediation had now completed but there was
still significant stakeholder issues. It hadn't put the
matter to bed and the Mediation Scheme clearly didn't
offer a way through.
So in what sense did that increase the risk to ShEx?
I suppose we'd hoped the Mediation Scheme would put the
matter to bed and it would be resolved. It clearly
wasn't. We had a minister who was very interested in
the topic and we had to find a way to provide
reassurance and continue to look at the issues to
understand why those issues, that JFSA were saying still
existed, still existed because it hadn't been dealt with
by the Mediation Scheme, so there was a higher risk.
Under column P, and if we just scroll up to the top,
we'll see that that is an additional column for
83,
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Yeah.
If we go across to columns G to J, we can see that the
risk has increased very substantially --
Yeah.
-- both in terms of probability and impact, to a risk
rating of 20. Highlighted in red, under column K:
“Responsibility rests with Post Office to manage
both the Mediation Scheme and the stakeholders
generally. Post Office Chair undertaking review with
independent QC."
That's a reference to the Parker or Swift Review:
“We are managing ministers’ involvement with the
intention of keeping the issue independent of
Government."
Then far right column, in Q:
"Post Office Chair wrote to Baroness Neville-Rolfe
with an update on his review, meeting scheduled for end
of April. Baroness Neville-Rolfe keen to update
Lord Arbuthnot, so need a public line. CCRC conclusion
is not imminent and no news about JFSA plans for class
action. All mediations now completed. CEDR due to
issue final summary shortly.”
This records that the intention was to keep the
issue independent of Government. Was that your
understanding of ShEx's -- your -- intention at the
82
mitigating actions. Back down, please.
It's recorded that further mitigating actions are
to:
"Ensure that the Post Office is proactively managing
interest and noise and is aware of ministers’
expectations. Manage interests and wobbles from
ministers or the centre, including preparing fallback
options if current arm's-length position becomes
untenable."
There's quite a lot in there.
Yeah.
Firstly, what is meant in your mind by the word "noise",
in this context?
I think it's shorthand for anything that is, you know,
inbound correspondence, Parliamentary questions,
potential debates, Select Committees --
Does it indicate things without substance?
No, it's just a shorthand word of saying -- well,
I suppose it means criticism. It means that everything
that was going on at the time, it's a very shorthand
word and I think it's one of those words that people
within Government would understand and would use.
“Manage interest and wobbles from ministers or the
centre ..."
Yes.
(21) Pages 81 - 84
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Were those emerging?
Well, Baroness Neville-Rolfe was very keen to -- was
very interested in the topic, and --
That's slightly different from a wobble?
Itis but it was about whether she felt comfortable or
not with what was taking place. So periodically I think
she did and periodically I think she didn't. So at the
time, I think, she'd commissioned Parker, she was sort
of happy with that approach, we were waiting for
Mr Parker's review. But then, you know, there was lots
of noise and she would respond to that, and there's
a temptation for her to want to get more involved. And,
of course, our position, as we agreed with ministers,
was that it was an operational matter for Post Office.
But a fallback was to be prepared if the current
arm's-length position became untenable?
Yes, I'm --
So that indicates, does it not, Mr Callard, that it's
a matter of choice for Government, whether
an arm's-length relationship was maintained with the
Post Office or not?
Yes, it is.
So the length of the arms can vary according to
Government's desire?
They can, yes. They can.
85
The risk has seemingly now dropped back down to 12.
Yeah.
Column kK:
"Post Office have external legal advisors employed
‘on the civil litigation including a QC. They continue
to update UKGI through the Board and directly on key
stages but this is a legal matter and distinct from
Government."
Then:
"UKGI have briefed minister Margot James and will
keep ministers and SpAds updated at this point. BEIS
Legal are also up to speed and contributing to any
advice to ministers, maintaining a position that the
Government will not comment on an ongoing legal issue.”
Then there's some detail as to court hearings.
"No timeline yet on when the CCRC review will be
complete."
So I think this now recognises, we can see from
column F, that there is a legal risk to presumably both
the Post Office and ShEx?
Yes.
But the risk --
Well, I'm not sure the risk is legal to ShEx but the
risk itself is legal in nature.
Okay. So this column, who does it -- who is the -- who.
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Why was it now being contemplated that the arms might
get shorter?
Well, I think, due to the passage of time and no one has
been satisfied -- nobody from the JFSA has been
satisfied with the results so far, I think we are
waiting for -- well, this implies we've already got
Mr Parker's letter but, anyway, you know, it -- you
know, the position is just sort of still evolving,
I suppose.
Can we move forward to 2017, please. UKGI00007578.
This is January 2017. Just click on the guidance tab,
please. Thank you.
Back to risk register, please. If we go to lines 85
to 87, thank you. Under column D:
"Civil litigation and/or Court of Appeal processes
judged that Post Office has acted inappropriately or
illegally. Even absent such a finding, ongoing risk
that they continue to be perceived to have acted in that
way.
“Potential for significant compensation claims, if
civil or criminal courts rule against Post Office. 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."
86
are the words relating to?
Well, this is it. It tends to get conflated, as I've
said in my witness statement, as to exactly who the risk
pertains to but the nature of the risk itself is legal,
and its reputational, and its financial.
The risk has reduced from 20 back down to 12.
Mm-hm.
Why was that, given litigation was afoot?
I think, in part, it goes to whose risk it is and
I think Government's position is that it is a matter for
Post Office and it's somewhat -- actually, as a team
leader, I felt it slightly more out of my hands then
because it's a court process and I always thought that
court was where this was supposed to be. So I perceived
the risk to be lower for the team and, therefore, for
ShEx because it was -- there was a separate process,
which I would hope brings resolution, and it also led to
less public correspondence and debate, because it was
with the courts. So everything had died down.
How much reliance, Mr Callard, should we really place on
these risk registers, given that the words "Project
Sparrow" can refer to different things, and that
depending on it seems, the attitude of the person
writing the document, the risk can relate to either the
Post Office or to ShEx, or a bit of both, but it doesn't
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say?
Yeah, well, I think these things are a guide to make the
team think -- to make -- to inform people who are
reviewing the team and to feed up to the centre. So I'm
not sure how much reliance you can place on an internal
risk register. This is just a -- to get a snapshot at
the time of how the team is feeling about the variety of
risks that are with it.
There's no, for example, record of the fact that Swift
had reported there were eight recommendations and the
extent to which those recommendations had been
implemented?
Well, I hadn't seen Swift at that point and I was unfair
of Swift's findings.
So that's why it's missing?
Well, I've got a letter from Tim Parker, which I'm not
sure if we're going to come to but the letter, I feel,
was different to the Swift Report.
Very much so.
So I'm relying on the letter here, which is why,
I suppose, the context is also -- with litigation,
I thought our -- the Parker letter essentially informs
my stance on litigation because I think Post Office is
in perhaps a better position than it actually is, which
might explain why the risk has gone down because we've
89
Yeah.
-- and you expected that the outcome of the litigation
would be an endorsement of the integrity of the Horizon
system. Correct?
Yes.
Can we look, please, at UKGI00007995. Scroll to the
top. We can see this is 10 April 2018. So around the
time of your handover to Mr Cooper; would that be right?
He would have been in place for about three months by
then, it was sort of parallel running, but yes.
So it was in the course of parallel working --
Yes.
-- and, therefore, handover to him. Can we see on the
heatmap that the top rated risk, I think, is risk 12.
Yes.
If we go to risk 12, please. It's Project Sparrow under
your name.
Mm-hm.
Had you taken over responsibility for this risk?
I think -- so Laura had gone and we were waiting for
a new colleague to come in and take over from her, so
the reason why it’s in red is because that's a change so
it's new text compared to the previous risk register.
So I was probably between team members.
We can see columns D and E are essentially the same as
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done Parker. Parker is essentially — well, it's not
done but it's given us some assurance and I think we are
approaching litigation in a relatively stronger position
than, of course, Post Office was.
Q. It records that BEIS Legal were involved and up to
speed.
A. Yeah.
Q. What were they up to speed with?
A. So when the Freeths litigation was launched we wrote
to -- emailed BIS Legal to notify them, I think --
I haven't got my timeline with me but we had meetings
with them, they were aware that it was going on. We
introduced them to Post Office and they met Post Office,
I think, at our offices. And so they were patched in
and they were generally copied into any submissions and
updates that we did. So they were aware of what was
going on.
Q. Did they review any of the legal advice that was given
to the Post Office?
A. I don't think so, no.
Q. Thank you can we move forward, lastly, then to 2018.
Before we look at that, you tell us in paragraph 325
of your witness statement that, by the time of your
departure from the Board in March 2018, you expected the
GLO claim to fail --
90
previously in the previous year; can you see that?
A. Yes.
Q. We can see in columns F to J that the legal risk and
reputational risk are 4 and 5, albeit the score hasn't
been uprated to presumably 20; can you see that?
A. Yes, it's -- yes, you have to widen the column but then
it would be a 20, yes.
Q. Oh; itis, yes.
‘SIR WYN WILLIAMS: I take it that the rating is simply 4
times 5?
A. Yes.
‘SIR WYN WILLIAMS: Is there any magic about that or --
A. No, it's just that you can't -- the column and the
spreadsheet in this particular instance is not wide
enough to put 20.0, if you widen the column, you'll see.
it.
‘SIR WYN WILLIAMS: Not that, I mean, in terms of achieving
A.
a rating, is it sort of commonplace to just multiple --
Yes.
SIR WYN WILLIAMS: I -- the probability with the impact?
A
I think so. I've seen other risk registers like that,
yes.
‘SIR WYN WILLIAMS: All right. Fine.
MR BEER: K, essentially the same, but:
"UKGI seeking to put a protocol in place" --
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Yes.
--"to ensure Permanent Secretary remains up to date.”
Column P:
"UKGI have briefed minister and will keep ministers
and SpAds updated at key points. BEIS Legal are up to
speed", et cetera.
Then, lastly:
"Post Office are preparing for a security of costs
hearing, which may trigger negative press but which
could lead to the case being dropped. Post Office
preparing for the first main hearing in November. UKGI
is sighting Permanent Secretary, BEIS, on the issue and
establishing disclosure protocol", et cetera.
So now project Sparrow is the top-rated risk within
the whole of ShEx, yes?
If you say so. But not for the whole of ShEx but for
the whole of the Post Office team --
Yes, for the Post Office team?
Yes -- well, if you tell me -- if you say so because
I can't see the rest of the scores but, yes, I take your
word for it.
So it's the top-rated risk --
Yes.
-- with the highest probable impact rating, yes?
Yes.
93,
dismissed, and --
Yeah.
-- integrity of Horizon upheld?
That's what I -- yes.
But now this seems to have switched back to be looking
at a different issue, namely the information management
protocol --
Yes.
-- and the risk that that created?
Mm-hm.
What about, using the Chairman's words of earlier, the
bigger issue, namely that the Horizon system may be
proved to lack integrity, which may have a consequence,
in fact, on criminal convictions?
Quite. But I hadn't really seen any -- so during that
two years’ worth of discussion about the litigation
case, over those two years we weren't getting any
information from the GC that the risk of the case itself
had gone up. There was no -- we were told there was
nothing new particularly in the claims and, of course,
we hadn't seen the Swift Report so I was unsighted on
some of those issues that were in that, which is why
I was of the view I stated in my witness statement about
the underlying status of Horizon.
The risk here, I think, represents increasing
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Even with all of the mitigations listed?
Yes.
How was that so, given that you say that you were
confident that you expected the claim to fail and the
outcome of the litigation would be a full endorsement of
the integrity of the Horizon system?
So I think it was due to the fact that we were having
problems around the information protocol -- sharing
protocol. So I think it's possibly -- I mean, I haven't
seen how this risk has evolved between the last risk
register you've shown me and this one but I think it's
partly two things: (1) difficulty with the information
sharing protocol by that point because we were still
waiting to get that agreed with Post Office and I think,
secondly, there's perhaps just a little bit of
suddenly -- for two years it's been all very procedural
and not much happening and, suddenly, I think there's
an email in my pack somewhere where I say to people --
well, actually it's just getting closer and this is why
we're focusing more on it.
So it's much more in our mind, it's much more
serious now than 18 months ago when there was lots of
procedural hearings -- or not procedural hearings but
procedural discussion.
But you thought the claim was going to be roundly
94
tension, as Board members transition, as we're trying to
get an information sharing protocol in place and Post
Office not being very cooperative, and the risk
ultimately getting nearer and people thinking "Ooh, hang
on", I think, probably. So I think that's what -- that
is what explains the change in risk rating.
So can I summarise your answer, and tell me if I'm
incorrect: the risk of the Post Office losing the claim
and that having an impact on the integrity of Horizon,
and the possibility of that having an impact on criminal
convictions, was such a low risk that it didn't even
deserve to be included on a risk register?
Well, clearly it should have been. But no, it wasn't.
We were very much focused on the litigation and
I suppose, inherently, the risk you've just set out is
kind of in that risk somewhere, even if it's not --
Where is it -
Well, it's not explicitly set in that risk, it's --
This seems to be about process issues —-
Yes.
-- satellite issues --
Yes.
-- that are bolt-ones to the main issue?
No, I'm ~
I'm asking: why do we never see, in any of these,
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an assessment of the big issue or the main issues?
A. Yes, it's a good question and I think, as I've said in
my witness statements, you know, on reflection we should
have got a merits opinion and all those sorts of things
and been more proactive and --
Q. But why didn't you?
A. I suppose -- why didn't 1? Because, generally speaking,
Government's position, up until -- well, not this point
but prior to late '17, had always been to be quite
hands-off and leave it as a matter for courts and the
arm's-length body. It wasn't until the Magnox study
that -- lessons learned that UKGI did, where they were
involved in another case where it was stated they should
be more proactive, so I think --
Q. But, Mr Callard, even if the Government's attitude is
that this is an arm's-length body, the matters concerned
are operational in nature and there's an element to
which we, Government, should not get involved because
there's either an independent Mediation Scheme or
litigation —
A. Yeah.
Q._ -- there's still a risk to the, perhaps, existence of
the Post Office or the proper functioning of the Post
Office, if things go badly in the course of those
mediations or --
97
register is a sort of -- it's not a formal -- to my
mind, anyway, it's not a formal record as such. You
know, it's -- although it obviously goes up to the -- to
ExCo and the Board, it was -- from my perspective, it
was more a sort of record -- or a way of encapsulating
the risks as we saw it as a team. And inherently in
those risks, there are lots of other issues behind them
that we may be working on and dealing with, which are
not set out specifically in that wording.
MR BEER: Thank you.
Sir, can we take the second morning break. It's
just coming up to 12.20 so 12.30, please?
SIR WYN WILLIAMS: Yes, certainly.
MR BEER: Thank you, sir.
(12.18 pm)
(A short break)
(12.30 pm)
MR BEER: Good afternoon, sir. Can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
MR BEER: Thank you.
Mr Callard, can we turn to reporting to ministers,
please, as a topic, and start by looking at POL00065473.
If we go to page 5, please.
If we scroll down, please. We'll see this is
an email there, if we stop there, from Jane MacLeod. If
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Yes, but -
-- litigation. Why do we see none of that recorded?
Because I don't -- I didn't see anything that changed
my -- the information that I was getting didn't change
my view that, essentially, there hadn't been an issue
with Horizon found which causes losses to
subpostmasters. So I hadn't seen any new information
and, when I asked about that and when Jane MacLeod gave
her updates at Board about those sorts of things, there
was never any discussion that, "Oh, by the way, we found
an issue about balancing transactions as set out in the
Swift Report”.
So my view on the technicalities and merits,
I suppose, of what I understood -- I mean, merits not in
a legal sense -- but my understanding of what had been
found, say, one to two years prior hadn't changed. So
I didn't think the risk -- the underlying point that
you're saying that there was an underlying problem with
the -- with Horizon, I didn't think that risk had
particularly changed --
Isn't there a --
-- which is wrong. I accepted that that's wrong.
Even if that was your view, ought it to have been
recorded?
On reflection, yes. But my point here is that the risk
98
we scrolled up we would see that it was to Paula
Vennells on 2 April 2015. You're not included on the
distribution list but there's a comment made about you
which is why I'm asking you. It says:
"We [Jane MacLeod] are meeting with Laura tomorrow
That's Laura of the ShEx, yes?
Yes.
"... SO we can review where we've got to. Laura and
Richard Callard are briefing [Lady Neville-Rolfe] on
Tuesday on another matter, and Laura is concerned that
Sparrow will come up."
Do you see that?
Yes.
So we're mid-2015, a prospective briefing of Baroness
Neville-Rolfe by you and Laura, and it's recorded by
Jane MacLeod that Laura was concerned that Sparrow would
come up. Why would ShEx be worried that Project Sparrow
would come up in a discussion with the Minister?
Can you just clarify what month this was?
August 2015.
August. I don't think we were. We saw Baroness
Neville-Rolfe almost weekly on other matters, usually
being the Investment Bank, and I don't think we were
particularly concerned if it came up.
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Was there any sense that you, ShEx, had to formulate
lines with Post Office before briefing ministers?
No, not necessarily but we would check with Post Office
whether they are factually accurate, for example, and we
would ask -- I mean, no doubt what Laure is meaning here
is "No doubt Baroness Neville-Rolfe may well ask about
Sparrow, what's the latest?", depending on what was
happening around that time. I think if it's August '15,
I think they were about to -- Jane MacLeod and Paula
Vennells were due to meet Baroness Neville-Rolfe on
6 August, I think, so it could have been in preparation
for that.
To what extent did you and ShEx adopt Post Office lines
when reporting to the minister?
We would report our own lines but they would be
sometimes similar to Post Office lines because they
would be based on what we understood the facts to be
from Post Office.
Would you sometimes, in agreement with the Post Office,
keep information from the Permanent Secretary or the
Minister?
No. Not on -- not with the express intent of
withholding it.
Would you decide when it was necessary to provide the
Minister with information in your own judgement?
104
Yes. You were part of a Board --
Yes.
- of a company --
Yes.
-- that might not always agree with what the Government
was doing --
Yes.
-- in relation to that company?
That's correct.
Where did your loyalty sit in that situation?
Well, that's when it gets quite difficult and you try
and make the case of Government to the Board. So, for
example, that happened quite a lot around mutualisation
and those sorts of issues back in 2014.
You continue:
"... and that's what I was referring to when I said
we had ‘kept a lid’ on things."
That's in an email that we're going to look at in
a moment.
Yes.
"As I explain further below, our overarching approach in
relation to Horizon was that this was an issue for [Post
Office] to address and there was no real role for
Government to play, particularly in the absence (as we
understood it) of any evidence of a fault with Horizon
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Yes. Yes, that's up to us to decide.
You would draw that as a distinction between keeping
information from the Minister?
Yes, because you don't want to go to a minister
half-cocked, if you don't understand the full facts, for
example.
In your witness statement at paragraph 67 -- maybe we
should turn it up, please. It's page 34 of your witness
statement, fourth line of paragraph 67. You say:
"As to Horizon I also felt I had been doing
a reasonably good job of preventing the Minister from
being criticised publicly in relation to Horizon, which
I saw as part of my role ..."
Just stopping there, do you mean part of your role
as a NED?
No, as part of my -- my role as a civil servant is to
deal with and protect ministers from undue, or sometimes
due, criticism.
How did that sit with your role as a NED where --
Well, no, that was my -- with my civil servant hat on.
What about if you needed to as part of the Board?
Needed to what, sorry?
Say that "We have suggested X or Y to the Government and
they have failed to deliver"?
Sorry, I don't quite understand.
102
that might have caused losses in branch accounts."
That overarching approach -- ie that Horizon was
an issue for Post Office and not for Government -- how
long did that overarching approach last?
I think it lasted throughout my tenure. I'd inherited
it, we'd reconfirmed it in 2015, when the new Government
came in, and it sort of continued through to when
left.
Knowing what you know now, do you consider that the
overarching approach was an appropriate one?
It's -- I sort of wrestle with this a little bit. I'm
not sure because I'm not quite sure what else Government
could do to insert itself into the situation and to have
essentially resolved the situation. I'm not sure what
Government could have done, so I'm not sure what I would
have suggested.
Can we go, please, to the email, UKGI00006454, an email
from you to Tim Parker of 18 January 2016, second
paragraph:
"The underprovisioning of subpostmasters
compensation issue has worried [Baroness Neville-Rolfe],
perhaps disproportionately so.”
Just stopping there, the underprovisioning of
compensation to subpostmasters, is that a recognition by
you that, in fact, subpostmasters had been
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underprovisioned in terms of compensation?
This is an entirely separate matter where the business
had misstated its accounts, it had made a mistake in its
accounts. The provisioning is about compensation to
subpostmasters as part of the Network Transformation
programme. They hadn't pulled up through the right
figure and the accounts were wrong and Baroness
Neville-Rolfe was very worried about that, naturally.
Is that established by the fact that the subject of this
is RemCo?
Possibly because it might be that look, there's been
a bit of a mess-up there, what are we doing about it?
But I'm not quite sure why it's about RemCo. Yeah, well
in the bottom of that second paragraph, "I would be
happy to share drafts" ...
So this isn't to do with Horizon?
No, this is about retrospective action, why has there
been an accounting problem? And it was -- we had to --
the business had to restate its annual accounts, which
is obviously wrong and embarrassing, because it pulled
the wrong figures through from its account -- from its
underlying source documentation from a spreadsheet.
Can we see also from the third paragraph from the bottom
that you deal separately with the issue of Sparrow?
Yeah.
105
So of the two errors that I reported to her around
that time, one was a real cash cost and one wasn't.
This one wasn't, hence my “disproportionately so"
comment.
So, so this is a reflection, albeit on a separate issue,
of you acting in a way that either gave or withheld
information from Baroness Neville-Rolfe; is that right?
Well, I didn't withhold the information from her, no.
This is saying I've given her a submission about what's
gone wrong. Of the two issues, she reacted to one of --
this issue rather more strongly than the other issue,
which surprised me, because the other issue was about
real money and real cost overrun. This was just
an accounting error that had no cash implications.
I think you do agree, however, that you, on occasion,
got the balance wrong in making decisions as to whether
or not ministers should or should not be provided with
information?
Probably.
I think it's in your witness statement --
I'm sure it is.
- at page 36. It reads to me as a bit of an admission?
Okay, well, I'm not saying --
Page 36 of your witness statement -- it'll come up on
the screen -- paragraph 70.
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Does that help to establish that the second paragraph is
about the issue that you've mentioned, rather than
compensation to subpostmasters for --
Yes.
-- Horizon issues?
Yes, I think so because I'm also saying that it's also
about Sparrow, in addition to what we've just talked
about in the second paragraph.
You say, in any event, that you have sought to keep
a lid on it, in the first line of the second paragraph.
In what way had you sought to keep a lid on that
issue
Um --
-- even though it's a separate issue?
I think that means just having dealt with it. So
I think Baroness Neville-Rolfe was very worried about
the mistake in the accounts, I thought perhaps
disproportionately so because the submission I'd put to
her about it consisted of two things: one was a cost
overrun on IT, which was real money, and this, which was
just an accounting error and it hadn't actually meant
subpostmasters hadn't received the compensation they
wanted, it was just that Post Office hadn't forecast
properly in their accounts what it was but underlying
that they knew what they would have to pay.
106
Ah yes.
Page 36, paragraph 70:
"Whilst I did my best to do so, my job is subjective
and I acknowledge there were times when I got the
balance wrong, and one example is provided by an email
exchange in March 2015 where I agree with other members
of the Shareholder Team that there were dangers in the
Minister, Jo Swinson, receiving a copy of the Second
Sight thematic report.”
Then you give the reference:
"In essence I agreed with the advice of Laura
Thompson that 'The Minister and Government should
maintain its independence here’, and I expressed that
view in an offhand reply that it would be ‘bonkers’ for
the Minister to compromise that independence, which we
had considered a key part of the scheme, by receiving
the report in circumstances where she might then be
required to express a view and potentially take a side.”
So this is you essentially saying that you
acknowledge that you got it wrong in trying to dissuade
the Minister from seeing the Second Sight report, the
thematic report?
Yes, I think my concerns were legitimate but, you know,
on reflection, yes, you probably should see it -- one
should see it.
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You explain it as an attempt to draw the right line by
letting the Post Office have the freedom to deal with
operational matters, essentially?
Basically because, if she receives that report -- we
spent quite a long time, and my predecessors as well, in
maintaining this operational independence line. Once
the report's received, she has to take a view on it and
that's going to be very difficult for her, potentially.
But, at this point, Second Sight had been sacked in
controversial circumstances?
1am not sure I'd agree with that particular
characterisation of it.
What had happened?
So the way -- the Mediation Scheme -- this is by March
2015 -- the Mediation Scheme was progressing and Post
Office had done all of its investigations into the
cases. Second Sight were retained to finish their
investigations into those cases and to report their
thematic -- to produce their thematic report. So
I guess it was controversial. It was received
controversially but, to my mind, it was the conclusion
of the Mediation Scheme and that was that, essentially.
Because I knew that it would create tension.
In what way would the Minister, having a copy of the
Second Sight Report, involve her in operational matters?
109
there, it was an extension of that position, or
a continuation of that position. I'm trying to flag to
her the risk that, if you, essentially, break that
position, then you're exposed to risk. And she -- and
sorry, to finish off, she basically overruled me, which
I'm saying, on reflection, was right.
Doesn't your approach show a fundamental conflict within
the ALB model between the wishing to be seen as
independent, on the one hand, and yet, if advice like
this is given and acted upon, oversight cannot be
exercised in any meaningful anyway?
Sorry, can you just repeat the two ...
Yes. Government wished to be independent --
Yeah.
-- and seen to be independent of the Post Office --
Yes.
-- and leave operational matters --
Yes.
-- to the Post Office.
Yes.
Did that approach mean that it could never, effectively,
exercise any oversight?
I don't think it means never but I think what we're
trying to get at here is that they are best placed to
deal with it because, as I said before, it's quite hard
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Well, if she had a copy of the report she'd have to read
it. If she reads it, she's then got to take a view and
she either has to decide --
Why does she have to take a view?
Well, I suppose she doesn't but if she's asked by ~~
No, no, that's a fundamental part of your answer: if she
reads a document, she has to take a view.
Well, there'd been a number of difficult Parliamentary
debates where she'd managed them very well. If she
reads the report, someone will say to her "Well what do
you think of this? Is there a case here to be dealt
with or is there not?" And the way -- this was a very
polarised topic -- whichever answer she gave, people
would find fault with it, which I thought, as a person
trying to keep her away from criticism and trying to
protect her, I thought --
So Mr Callard, if a document addresses a difficult issue
about which there is more than one view, that means the
Minister shouldn't see it because she might have to take
a view about it?
No, that's not what I'm saying. I'm saying that there
was a risk that that's what she ends up being asked to
do and that, because we'd agreed that this was
an operational matter and that was the agreed position,
which she had agreed as part of -- before I'd even got
110
to understand how Government would insert itself into
this situation to resolve it.
Had you not been overruled, Government would never have
seen the report?
Possibly not, no.
Can we look, please, at what another Minister says, Jo
Swinson says, about information that was not provided to
her, by looking at the document itself, to start with.
UKGI00002439. This is just a covering email to the
attachment because the attachment isn't dated, so I'm
using this to date the attachment. It's an email from
you, again to the Swinson generic address. Yes?
Yes.
It's -
Ah, right, yes, sorry.
-- addressed to Claire.
Yes.
Can you help us identify who that would have been
within --
She would have been --
- the private office?
-- a private office person. Yes.
"Thanks for the discussion today -- very helpful.
I have attached the note I mentioned -- Alice saw the
first iteration ..."
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Who would that be?
Alice Perkins.
Okay.
"... [have just sent this second iteration to her
and thought it might be expedient that you see it sooner
rather than later. I would be grateful if you could
flag any potential ‘red [flags] in here.
"... this is not a speaking note as such, it's too
long for that. It's something to get thoughts in some
sort of order and give you the general gist of our
arguments.
“If you do have a word with Jo prior to the meeting
I would be grateful for any readout ...”
Can you give us the context to this, please?
So we were preparing for a meeting with Jo Swinson --
"we" being, I think, Mark Russell, my CEO, and I. We
had provided advice to both Jo -- sorry, both Jenny
Willott and then Jo Swinson about the replacement of the
CFO. Ministers had rejected that replacement --
a replacement on the basis that they were happy with the
salary and sort of golden handshake but they'd objected
to the payment of notice for the exiting CFO. So --
That's Mr Day?
Mr Day, yes. So, on the basis that they rejected that,
Mark and I thought we should go and see Jo Swinson to
113
the concerns that the Board (and ShEx) has about the CEO
That's Paula Vennells, yes?
Yes.
"... which you need to be aware of, and which puts the
appointment of a new CFO in a wider context.
"The Board's concern over the performance of the CEO
has been growing for some time, and has only recently
got to the point where it feels it needs to act in due
course."
I'm going to ask you this afternoon about some
questions concerning Paula Vennells' position within the
company and what action you and others took about it.
Okay.
“But this leaves the Board in a difficult place --
removing a CEO without a confident CFO capable of
holding the fort is a big risk. This makes replacing
the CFO all the more important ...
"We need to obtain a strong CFO and give them time
to get their feet under the table before acting on the
CEO. Without replacing both of them, the plan is at
significant risk.
[It] is extremely sensitive and highly
confidential.”
Then you sort of ask yourself a question, the type
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try and change her mind because it was very important to
get a new CFO and that's obviously very difficult, going
to see a minister to ask them to change their mind when
they've already opined.
Thank you. Can we look at the attachment, please.
UKGI00002440. Just look at the top half of the page.
So you said in the covering email -- this isn't
a speaking note but it's the gist of your arguments,
your arguments being ShEx's arguments?
Well, it's my argument, it's my note but, essentially,
yes, what I was planning to say and it's a way of
getting my thoughts in order by writing it down.
"Opening gambit
"As you know ShEx and the Board are clear that the
current CFO [that's Chris Day] is not the right person
to take the company forward given the challenges it
faces."
Skipping over.
"You know all that and on reflection we should have
approached you earlier ... we want to explain to you why
we need to come and see you on this, and why Alice and
the chair of the RemCo want to meet you and Vince."
That's Vince Cable, yes?
Yes.
"The difficulties on the CFO front have brought forward
114
of which you would imagine a minister to ask you; is
that right?
Yes.
And give yourself the answers?
Mm-hm.
"Why haven't you told me about the CEO before? Why
didn't it form part of the CFO advice?"
Yeah.
Pregnant in those questions is the truth, is that right,
that you hadn't told the Minister about any concerns
involving the CEO before then?
No. She'd been -- I suppose the worries about Paula had
been growing since I joined in January/February. Jo
Swinson had been on maternity leave for most of that
time. Mostly I didn't have a conversation with her
replacement, Jenny Willott either but, no, as I say
here, somewhere, this has kind of grown over time and
it's kind of starting to crystallise now.
So you hadn't told the Minister, whether in the person
of Jo Swinson or her replacement about any concerns
about Paula Vennells before this point?
No, because as I say in the first bullet of that
section, it's a very dangerous and destabilising thing
to do because, in the second bullet, your relationship
with her is already irrevocably damaged and I think in
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the early times often my tenure I didn't have enough
evidence to substantiate any worries. And this is
double edged: if I tell ministers early irrevocably
damage and put doubt in their mind about their
relationship with their CEO, which, if I'm wrong, is
hard to unwind, so you have to be quite sure of your
ground.
In the third bullet point you say:
"The Board has been monitoring the situation for
some time but until recently we felt the balance of risk
pointed towards keeping Paula in place ...
"There are number of reasons why the balance has
changed:
"Efforts to improve her performance have failed.
"The Board is increasingly frustrated with the lack
of progress on various areas, primarily the lack of
‘grip and pace' applied to revenue growth, cost cutting,
specific business areas like Horizon, and the strategy
Can I ask you now, before we get to the questions
specifically about Ms Vennells this afternoon, what was
the Board's concern at this point specifically over her
approach in relation to business areas like Horizon?
I think it was a reflection of the fact that the
117
strategy when, actually, as an Executive leading, it's
her strategy too and she should be putting the case
forward.
If we go over the page, please.
"What is wrong with the CEO?
"It's about ‘grip’ and ‘pace’.
"[She] has many strengths, but given [Post Office
Limited's] increasingly competitive environment and
strategy it must implement, we need stronger leadership
and vision. We need a better grip on the detail, we
need more traction on the ground to deliver cost savings
and revenue growth at pace.
“A number of examples include ..."
Then the third bullet point:
"Issues like the Horizon Mediation Scheme and
financial services have required significantly more
oversight by the Board than one might expect as things
haven't been gripped (to the point where the Board have
set up subcommittees when it should be Paula or the
CFO)."
Is that a reference to a Litigation Subcommittee?
No, that's the Sparrow Subcommittee of 2014, which was
set up to essentially give the Board more bandwidth to
think about how to deal with the emerging problems with
the Mediation Scheme.
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business -- the response to the Second Sight Interim
Report seemed to be along the right lines, in terms of
a Mediation Scheme, et cetera, but it had been rather
badly managed, to the point where, a year on, you know,
it's actually a cause of great difficulty and, whilst
I don't think she was personally responsible for that,
it was a reflection of the lack of general grip that we
felt she might have on the business because things like
the terms of reference with Second Sight, I don't think,
had been agreed, I think the Mediation Scheme had been
announced hastily, and it was things like that that made
us doubt that --
You say:
"This crystallised ... at the June away day, where
Paula Vennells very much sat back and let her team
lead -- she acts more like a [Non-Executive Director]
than someone who leads from the front.”
Yes.
Was that your own view or the view of the entirety of
the Post Office Board?
I think most of us felt like that, particularly -- you
talk about, in here, you know, it started to
crystallise -- the Board's view crystallised during that
time because, during those discussions, she tended to
ask the questions of the people who were presenting the
118
Was it the Board's view that that ought to have been led
by the CEO and/or the CFO?
Well, I think the Board's view is that we shouldn't have
had to get to that point where we're setting up
a committee to deal with it.
Scrolling down:
"Would a new CEO require higher remuneration?"
Answer:
"Yes ...
"What have you done to put measures in place to
improve her performance?
"Alice has spent an enormous amount of time
coaching, mentoring and monitoring Paula.
Alice has significant NED experience ...
‘Paula responded to initial efforts ... but this has
levelled off and is ultimately about character and
aptitude.
"Why are we paying her big bucks if she is not
performing?
"Her base pay is in the bottom quartile of
a cross-section of CEOs."
Over the page. Again, a question that you thought
Jo Swinson might ask you:
"I remember Alice asking to increase Paula's pay?
“At that point she was doing well, responding to
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coaching Alice and the Board were giving ..."
Third bullet point:
“Since that point:
"Paula has proactively said to Alice she wants to
say to see transformation through ..."
Then a challenge:
"Don't see how this has anything to do with the
CFO?"
Scroll down please, some questions about the CFO.
Over the page. Lastly:
"Ministers have made their decision!
"This is of great concern to the Board, who are
personally responsible to you and the Secretary of State
for the successful running of the business, and it's
their view that a change is needed.
"You are effectively saying you don't have
confidence in their judgement on these matters, which is
a very difficult position for the non-executives and
Chair to be in."
So "The ministers have made their decision", what
does that refer to?
That refers to -- pretty sure it refers to they were not
prepared to pay Chris Day's exit payment, which meant we
couldn't, as a Board, move Chris on because he hadn't
performed so badly that he could be fired, so -- and we
121
By "NED-like stance", do you mean an outsider?
Well, kind of asking the same -- a Board asking similar
questions that a NED might ask when, actually, other
Chief Executive's that I've seen operate come in, and
they almost present their colleagues’ sort of individual
strategies and they take the lead and it's them telling
the Board what's going on, rather than asking questions
of her team.
Can we look at what Jo Swinson says about this,
WITN10190100, at page 21, please, paragraph 45 onwards.
I'm going to read between paragraphs 45 and 47 so you
get the complete context:
“I have been shown by the Inquiry an undated
briefing note [that's the document I've just shown you,
the one ending in 440]. It seems to have been attached
to an email of 20 August 2014 [the email I showed you].
I understand, seeing it now, that this appears to have
been written by [you] as points or prompts for Alice
Perkins in advance of a call schedule between her and
me, to help her try to convince me to ask the Treasury
for permission to recruit a new CFO, Alisdair Cameron,
‘ona very high salary to replace Chris Day ..."
Is that right? Was that the purpose of the
document?
My understanding of the document -- well, no, so my
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had Al Cameron waiting in the wings and we wanted to
bring him in. He wasn't going to wait forever but
ministers had made the decision they didn't want to pay
that exit payment and we were trying to persuade her to
change her mind at this point.
Did you present to Jo Swinson your case in accordance
with this non-speaking note?
I think I probably did so. I recall the meeting was
supposed to be for half an hour and it lasted 90
minutes, or something like that. It was quite a long
meeting and, given the volume of stuff in there about
the CFO, I think I probably would have done. We were
essentially in the position of where we were sort of
trying to throw the kitchen sink at this to get
ministers to change their mind because that's very hard
todo.
Is it fair to say that a part of ShEx's approach was
specifically, as the CEO, Paula Vennells' lack of grip
and pace over Horizon issues?
I don't think Horizon was the lead thing, that was
indicative. I think it was more around the strategy.
So it mentioned on the first page that strategy, the
sort of revenue growth, cost reduction, those sorts of
things, and the general kind of NED-like stance that she
would take.
122
understanding of the document is that it was speaking
note for me when I was accompanying Mark Russell to talk
to Jo Swinson about this, and that it wasn't to persuade
her to pay a high salary. That had been, I think, not
agreed but not objected to. What had been objected to
was the exit payment. I think it was "payment for
failure", she used the term of. It's the exit payment
that was objectionable to I think Jenny Willott and then
Jo, not the salary.
She continues:
"In the light of Government finances at the time and
the austerity measures in place, any appointment using
public money to a role above a certain level of
remuneration required Treasury approval. I did not see
this document at the time, indeed it was not something
ever designed for me to see, as the covering email and
the contents of the note made clear (eg the fact that
the note is structured as a series of responses to
questions I might ask). It seems that Richard Callard
was asking my private office for advice on how Alice
Perkins could make the points in the note to me in a way
that would be was persuasive, and he anticipated I would
not be happy (‘I would be grateful if you could flag any
potential "red [flags] in here’)."
Is that right: you were asking her private office on
124
(31) Pages 121 - 124
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how Alice Perkins could make points in a way that might
land?
No, I think I'm asking how -- I think I'm saying to the
private office "I'm going to say this stuff, is there
anything" -- clearly there probably will be red -- you
know, difficult pushback because Jo Swinson was very hot
‘on executive pay. I think what I'm saying in my message
to private office, was "This is broadly what I'm going
to say can you -- you know Jo better than I do, can you
flag?"
So it's about you speaking to the Minister rather than
Alice Perkins?
That's how I interpret it.
On to paragraph 46, please:
"I was shocked to read this note. It seems to show
Mr Callard, a ShEx official, who was one of the key
officials who was supposed to support me in my
Ministerial role with regard to Post Office matters,
instead using his Departmental position, access and
contacts to work on behalf of [Post Office] to seek to
persuade me to do what [Post Office] wanted, contrary to
wider Government policy on pay restraint. It also makes
clear that he had deliberately kept me in the dark about
the concerns that ShEx had about Paula Vennells'
performance."
125
until the June away day and it's damaging to put doubt
in Jo Swinson or many minister's mind about that before
you are sure, and also, frankly, she wasn't -- wasn't
around until the end of June, back to the end of June.
This was sent to her private office but wasn't ever
intended for her to see?
It wasn't intended for her but I wasn't hiding anything
because otherwise I wouldn't send it to her private
office. In fact, I say, I think, at the bottom of that
email "If you do talk to Jo about it, I mean, don't show
the note but you can share the sentiment of the note and
let me know if there's any red flags coming back".
So was this you attempting to pitch your argument in the
best way possible by testing the water with private
office before speaking face-to-face with the Minister?
Yes, because the private office understand what -- they
know their ministers pretty well and so will have
a sense of what they're going to react to and how
they're going to react. So I think there's other
instances in my timeline where I sort of share things
with private offices to say "How will this float? I'm
trying to get your approach on how do I pitch this,
given the objective I'm trying to achieve". I'm trying
to get their advice.
25 Q. Lastly, before the lunch break, can we look at second
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Just stop there, then. Firstly, were you using your
Departmental position, access and contacts to work on
behalf of Post Office in a way that was contrary to
Government policy on pay restraint?
I don't think so because we were -- many were very clear
in the submission to ministers about what that pay is
and they had already opined on it. Pay -- senior
executive remuneration is one of the most difficult bits
of the Shareholder Executive/UKGI job because our assets
have to fish in the private sector market and you want
to get the best CEO that you can do, and CFO, which is
what we're trying to do here. The Shareholder Executive
was aligned with the Board in terms of trying to get
anew CFO in, and it didn't seem to us value for money
that you wouldn't pay -- I can't remember what the exit
payment was -- but that you wouldn't pay something in
the very, you know, tens of thousands to remove Chris
Day, if you could bring in a CFO who may save multiples
of that money over the course of the next few years in
implementing Post Office's strategy.
Is it right that you deliberately kept from her --
ie kept her in the dark -- concerns that ShEx had about
Ms Vennells' performance?
I think I explained that in the note, that, basically,
you have to wait until you're sure. We weren't sure
126
passage in Ms Swinson's witness statement, page 52,
paragraph 128. Ms Swinson says:
"I do wish I had asked to meet with Second Sight,
though I am pretty certain if I had that ShEx would have
told me that this was not possible due to operational
independence. I feel let down by a failure of briefing
from ShEx. Richard Callard was on the Board and knew
what was going on for months with steps towards sacking
Second Sight and the closure of the Working Group, but
he did not tell me. I was repeatedly advised in
briefings that it was an operational matter, so not one
for me to be involved in, but looking back it was not
clear that the [Post Office] Board or anyone else was
conducting an adequate oversight function.”
Did you discuss with the Minister whether she should
meet with Second Sight?
I may have done but I can't recall.
Can you therefore not recall whether you gave advice to,
or not to, meet with Second Sight?
Yeah, correct. I can't remember.
Did you keep the Minister informed of what she describes
as the steps towards the sacking of Second Sight?
Well, I think she says elsewhere in her witness
statement that I showed her a Board paper, I think, and
there is -- I can't remember it now but there is stuff
128
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in my chain where you can see that this decision is
coming, and we appreciate it's a very difficult
decision. So I don't think the submission being put to
her on that -- I think it's 4 March 2015 -- it shouldn't
have come as a complete surprise because we were
essentially giving her some information that that was
what was going to be coming her way.
MR BEER: Thank you.
Sir, it's 1.10 now I wonder whether we might break
until 1.55.
SIR WYN WILLIAMS: Yes, fine.
MR BEER: Thank you very much, sir.
(1.14 pm)
(The Short Adjournment)
(1.55 pm)
MR BEER: Good afternoon, sir. Can you see and hear us?
SIR WYN WILLIAMS: Yes, I can, thank you.
MR BEER: Thank you, sir.
Mr Callard, good afternoon. I want to continue, if
I may, the topic of briefing or providing information to
ministers and whether there was any manoeuvring going on
within ShEx in the provision of information to
ministers. Can I start, please, with UKGI00002288. If
we look at the bottom email first, just to get the sense
of it, if we scroll up a little bit, please, thank you.
129
A. Oh, I'm sorry. I suppose I needed her to understand
that over the five months she's been away the Mediation
Scheme hasn't progressed very well and there are a lot
more problems, and I suppose I'm trying to explain to
her that that might require some difficult decisions
going forward.
Q. If that was your intention you would have said, "I want
to provide some information about what has gone on in
the last five months", whereas you say, "I want to get
her in the right place". That suggests you want to move
her to a position or position her in relation to
Sparrow; do you agree?
A. I can see why you think that and I quite possibly did
want to get her in the right place, I --
Q. What was that place?
A. I think that's getting her ready to understand that
there may be some difficult choices coming because the
Mediation Scheme that she left, I think, had been
running, you know -- there was optimism that it might
work by, you know, November/December. By the time we're
in the end of April, it's really not in the good place
at all. We've had a letter from Sir Alan Bates on
16 April, clearly expressing unhappiness with it. The
subcommittee of the -- the Sparrow Subcommittee, which
I've just joined, is already thinking about how to deal
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30 April 2014, from the private office of Jenny Willott,
with the subject "Jo Swinson transition from maternity
leave", and then there's an update that follows:
some plans in train to support Jo Swinson's
return from maternity leave."
Then if we go to the top email, please, you forward
that to some members, I think, of the ShEx team --
Right.
and say:
"Peter [Peter Batten]. See below, please can you
start putting some thought into this. Clearly we will
have our priorities to discuss, but you will have
a better idea of what her priorities might be than
I will, as we will have to address those as well. We
might also want to think about how many sessions we
might need -- eg I want to get her in the right place on
Sparrow!"
What place did you want to get the Minister in on
Sparrow?
I think that's a reference to the fact that I haven't
really, at that point, dealt with Jo Swinson at all;
I think I probably had one or two meetings with her, by
that point, before she left for maternity leave. And
I think -
What place did you want to get her to?
130
with the sort of Second Sight problem of this, you know,
capacity to get cases through to the Working Group.
She needs to understand that and she needs to
understand that there may be a difficult decision coming
up.
To what place did you want her to be in?
Well, I didn’t want her to be in a particular place,
I just wanted her to understand that things hadn't gone
very well and there may be difficult decisions to come
up.
Is that all we're to read into "getting the Minister
into the right place"?
Yes, I think so.
Did you ever try and manoeuvre ministers into
a position?
I'm not quite sure what you mean by "manoeuvre" but --
Persuade, cajole, by the provision or non-provision of
information?
As a civil servant, you are constantly tying to provide
advice, the best advice you think in your judgement, to
ministers and you provide information on that basis and
advice on that basis, whether that's manoeuvring or not,
manoeuvring makes it sound rather sinister. It's not,
you're just giving the best advice, as you see it, based
on the information that you're getting at the time.
132
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When you are getting the minister in the right place are
you acting as the Post Office NED?
No, I'm acting as --
Got a different hat on, on this occasion?
Yes, because I'm talking to my team and saying "Look,
can you put together some thoughts on the transition,
please, got to get priorities discussed. Peter knows
her better than I do because I've only met her once or
twice because she left on maternity leave. I'm asking
you to think about how many sessions we might need
across the Post Office portfolio, including there's
a tough, you know, there's now a tougher gig on Sparrow
than you left it".
Can we move forward to a different Minister and
a different time, UKGI00005261, and start with page 2,
please. Scroll up, and again please. Thank you.
4 August 2015, "Sparrow catch-up". You're emailing
Paula Vennells' Executive Assistant, Ms O'Farrell and
you copy in Laura Thompson, Tom Wechsler and Mark
Davies, and you say:
"Hi Avene -- we had a catch-up with Lady
Neville-Rolfe today about Sparrow. Paula is seeing her
Thursday morning first thing (ish) and I thought it
might be worthwhile me having a chat with Paula for five
minutes over the phone tomorrow if there is time --
133
make sure that it's a good use of everybody's time.
That's not unusual in Government.
Did you make the Minister aware that you intended to
forewarn Paula Vennells of her, the Minister's, mood and
position in advance of the meeting?
I'm not sure if I did but, as an experienced minister,
I would expect BNR to think that would be -- that
would --
le you would tip off the Post Office as to what the
Minister was thinking before she met the Post Office?
Well, "tipping off" is perhaps the wrong phrase but,
yes, I would make sure --
Tell them about her mood and position?
Yes, because I want them to address it. This is
an opportunity for -- it was quite a key meeting, if
I recall. It was a 30-page slide show, I think they
had, and this was a key -- and Baroness Neville-Rolfe is
pretty new in role, and this is a key opportunity for
both to meet each other and to understand one of the
issues that's really bothering the Minister, and the
best way to deal with that is to explain to Post Office
what it is that the Minister is worried about, not that
there is much that she's worried about, as I say down
there.
It's to make an effective use of time and it's not
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I appreciate it's her first day back but grateful if we
could find a slot, it's worth her being aware of
[Baroness Neville-Rolfe's] mood and position (not that
there's too much to worry about)", et cetera.
Then scroll up, please. Mark Davies emails three
minutes later saying he's added Jane MacLeod in:
"... it would be good to catch up on this: we are
meeting with Paula tomorrow to discuss the meeting so if
it isn't possible for you and Paula to speak before
then, can we (myself or Jane) grab a word?"
Your reply to Mark Davies:
"... Sure, happy to chat”, et cetera.
Why did you consider it appropriate to advise the
Post Office of the Minister's mood and position in
advance of them meeting with her?
Because ministers and the likes of Paula Vennells would
only see -- meet each other occasionally. So when that
happens, you want it to be as effective as possible on
both sides, so that what's discussed is what each party
wants to be discussed. It's a bit like a high-level
diplomatic meeting, almost. So you want both sides to
be relatively well briefed so that the -- that Paula and
Jane, who were taking Baroness Neville-Rolfe through
quite a detailed picture on Sparrow, answer the
questions that I understand BNR has at that point, to
134
dissimilar to approaches, I think, across Government,
otherwise you get meetings where people talk at cross
purposes and it's a waste of time.
Which hat were you wearing: the NED hat or the other
one?
I think I am wearing my shareholder hat here. This is
not dissimilar to what I've done on other assets and not
dissimilar to what my colleagues do on other assets.
Did you think you were in a conflicted position here at
all?
Not in this particular instance, no.
So did you speak with Mark Davies or Jane MacLeod or
Paula Vennells?
I can't remember. I may well have done.
So you didn't ask the Minister whether she was content
for you to share information about her position to the
Post Office senior executives before they met?
I doubt I did. I would expect her not to have worried
about that because she wants the answers to her
questions. If I'm ensuring that she gets those answers
from the people she is meeting, that is a good use of
everybody's time.
In fact, she says -- I'm not going to display it on
screen but it's paragraph 102 of her witness statement
at WITN10200100 -- this is email chain:
136
(34) Pages 133 - 136
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"... seems to me to be clear evidence that the ShEx,
whose role it was to provide me and other ministers with
the objective and impartial advice to scrutinise Post
Office's actions and hold it to account, was in fact
taking steps to provide advance warning to Post Office
about my concerns and intended direction of travel.
I cannot see any good reason for them to have done so
and am sadly driven to the conclusion that ShEx ..."
On this occasion, it's you.
Yeah.
"_. and Post Office, perhaps inadvertently, were
working together to try to deflect me and that ShEx were
not giving me the independent and impartial advice that
I needed."
Is there any substance in her criticisms of you?
I don't think so. I'm saying below that I don't think
there's much to worry about, at that point. All I'm
trying to do is do what other people do, and we've done
on other assets and my colleagues do, is to make sure
that it's the best use of time.
So Baroness Neville-Rolfe has got the wrong end of the
stick here when she says that it appears that ShEx were
working together to deflect her, and you were failing to
give her impartial and independent advice?
Well, in my view, in this meeting, she has got the wrong
137
Did you, therefore, in fact, know that Baroness
Neville-Rolfe wanted, I think, attendance from somebody
or advice from somebody out side of ShEx.
Yeah, I did know because I had that email.
Yes.
I don't think I would equate that with the last email
about briefing -- ensuring Post Office come armed with
the answers that Baroness Neville-Rolfe --
Do you know why Baroness Neville-Rolfe wanted somebody
from outside ShEx to help her?
I think this goes to the shareholder versus policy role,
where, at the time, we were both policy officials and
shareholder role officials, and I think quite sensibly
she's identified that sometimes those things can clash.
I think what we're saying here is she's expressed
a request for that, we've said well, we do both roles at
the moment.
Were you involved in formulating that pushback to the
Minister?
Er--
"No, you shouldn't get somebody from outside ShEx"?
No, I don't think so.
That's just Laura Thompson's view.
Yes, I don't know what the email down -- well, the email
below possibly is that's where the request comes and
139
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end of the stick because, actually, this meeting is
an opportunity for Post Office to directly, so it's
don't take my word for it, as it were, Minister, it's
a chance for Post Office to directly present to the
Minister for her to make an assessment. I'm just asking
Post Office to make sure that they address the very
things that she is worried about. Not that I think
she's got a great deal of worries because, as I said,
there's not much to worry about.
At the time, did you know or did you have any suspicion
that she may not have trust the advice she was getting
from you and other members of ShEx?
No, I didn't have a reason to believe that.
Can we look at UKGI00005195, please, an email to you
from Laura Thompson of the 3rd -- so in the run-up to
the meeting on the 6th -- 3 August 2015:
"Just spoke to Harriet.”
Can you recall who that would be?
I think she's another person in private office.
Private office. Okay:
"She thinks [Baroness Neville-Rolfe] wants a senior
Official outside of ShEx and not including whoever we
get from Legal but is going to go back with the proposal
that just three of us plus Legal and see what the
Minister says."
138
Laura is responding to that request by phoning private
office and then relating to me what that conversation
was. But I mean, asking us to recommend someone else,
well, we had legal coming and I'm not sure who else in
the Department would be able to give her the advice she
needs because we dealt with Post Office policies.
Is this kind of thing a concern where your Minister is
saying, "I want a senior official outside your
organisation"?
Yes, I suppose so but I guess I didn’t understand quite
the nature of her concerns and I wasn't sure what to do
about it, to be honest, because Legal --
Did she --
Sorry, Legal were coming, we were taking a -- we'd end
up taking a more senior person from the Shareholder
Executive along, in the form of Anthony Odgers, I think.
But also I knew that in that meeting, which is the
internal meeting on 4 August, I knew that Special
Advisors were coming as well as BIS Legal. So there
were a range of people that were they're. I probably
didn't think it was necessary because there were so many
‘other people there, it wasn't just ShEx.
Who wins today here, ShEx or the Minister?
Well, if the Minister has got issues on that front and
she isn't happy with Laura's proposal, because private
140
(35) Pages 137 - 140
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office are saying, "I'll take that back to the
Minister", then she's more than welcome to go to the
Permanent Secretary and say "I'm not happy".
Do you remember what happened: did ShEx in fact prevail
and she only got advice from ShEx?
I don't think it's a case of prevailing. I think we've
said "Well, we can't give you advice as to who else you
should have", we turned up at the meeting as planned.
I don't recall anybody who was --
Outside of ShEx?
Oh, no, well, there was BIS Legal, there was Special
Advisers, they're both outside of ShEx.
Does this happen often, that ministers indicate that
maybe they're not trusting the advice they're getting?
I think -- not that I'm particularly aware of, no.
Did it cause you any concern?
No, it perhaps should, on reflection, have caused me
more concern than it probably did.
Can I turn to a different type of concern, namely
concerns over Paula Vennells. Can that document come
down from the screen, please, and can we look at your
witness statement, please, paragraph 49, which is on
page 23. Paragraph 49, please. You say:
"I recall that, at the start of my tenure ... there
were some concerns about [Ms Vennells'] suitability as
144
Exactly.
Yeah.
To what extent were those concerns that you express in
this paragraph discussed and shared with Alice Perkins?
By this time, which relates to the meeting we were
preparing for with Jo Swinson, that had been discussed
with Alex -- definitely discussed with Alice Perkins,
because it was -- I think there's been growing rumblings
in the Board up until about a June away day, and then
the June away day happen and that kind of crystallised
everything, combined with the CFO issue, meant that
there was active discussions going on.
For how long had those concerns been held?
By me or by ~
Yes, by you.
Well, it's difficult to say, because I was -- I got
briefings from the team very early on but hadn't
obviously formed -- had the chance to form my own
judgement --
So the note is August '14, you began in early '14?
In January '14, yes. So I guess they built over time,
and then you take soundings from other NEDs and you get
a sense of it and you've seen -- one has seen by that
time performance in Board and that sort of thing, so it
sort of grows and then these things tend to have
143
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CEO. These were initially explained to me by my team
and, as far as I can remember, these concerns
crystallised during an away day in June 2014, at which
[she] was felt by many members of the Board [including
me] to be overly passive and acting more like a NED than
a CEO in the way she interacted with member of her team
who came to present an item on the agenda.”
That's essentially what you've told us a couple of
times already today.
Yeah.
"A contemporaneous summary of the Board's concerns is.
set out in a note that I prepared in August 2014, ahead
of a meeting with the Minister, which I shared with the
Minister's office and which Alice Perkins had also
reviewed."
We have looked at that one earlier, the one in the
informal --
Yes.
"By this time, Jenny Willott MP had replaced Jo Swinson
MP whilst Jo Swinson MP was on maternity leave. The
concerns were" --
And we corrected --
"summarised in the following terms", and then there's
a quotation from the document we've looked at.
Apologies, but we've corrected that line at the start —
142
an event that crystallises consensus at a Board, if you
see what I mean.
Was that a unanimous or majority view held on the Board,
in particular that Ms Vennells was "overly passive and
acting more like a NED than a CEO"?
I think so, yes.
Unanimous or majority?
To be honest, it's not one of those things that you hold
a vote on but I don't think there were any dissenting
voices in that sense.
Can we look, please, at UKGI00006547. Scroll down,
please. Thank you. We're now in spring 2016, and can
you see an email exchange concerning Post Office
Limited's IT renewal --
Yes.
-- including you or members of ShEx speaking?
Yes.
If we scroll up, please. Further exchange. This is
about a different issue, not Horizon, correct?
I think it concerns Horizon in the sense of a renewal of
the contract, yes, but not --
But with Fujitsu but not --
But it's not a Sparrow thing --
Right. Then scroll up. Mr Russell says to you that he
mentioned that issue with Howard:
144
(36) Pages 141 - 144
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“As I was doing so, Paula ambushed us."
You reply:
"Told you, there's something ‘Teflon’ about her."
Mm.
What did you mean by that?
As I tried to explain in my witness statement, I think
what I mean there is that the issue around the
reprocurement hadn't been handled very well, was going
to cost quite a bit of money and Mark's having the
conversation with Howard Orme, who was the CFO of BIS,
the Department at the time. And Paula obviously bumped
into them, because I think sometimes she was in the
building, and I'm not sure why I say "Teflon", I think
it's something to do with, well, perhaps she's almost
oblivious to the fact that there's a conversation going
‘on in the Department about a failed procurement that's
going to cost some money and --
Mr Callard, "Teflon" doesn't usually refer to somebody
who is oblivious. "Teflon" usually describes somebody
who manages to avoid criticism, to keep a good
reputation, even after they have done something wrong.
Yes, but --
They are impervious to blame or criticism and nothing
sticks?
Well, kind of, it's just -- I don't know how he -- how
145
business. As CEO, you know, she ultimately bears
responsibility for that but, at the same time, yes,
she's almost sort of oblivious to that in the way she's
approached Mark and Howard.
So you saying that you meant "Teflon", in the sense of
oblivious?
In the sense of it's sort of water off a duck's back,
I suppose.
I think it's right that, right from the early days of
your involvement in ShEx, ShEx's Risk and Assurance
Committee had expressed concerns about the continued
suitability of Ms Vennells as CEO, hadn't they?
Well, we'd taken that to the Committee to discuss but,
yes.
Can we look at the record of the Assurance and Risk
Committee, UKGI00042124. If we look at the title at the
top, this is a Risk and Assurance Committee of who, of
what?
Of ShEx. It's the ShEx Internal Risk and Assurance
Committee.
What was the purpose of the ShEx Risk and Assurance
Committee?
Well, it's to consider risks possibly in more depth.
I think the background to this was that we had done one
of our sort of -- some sort of portfolio review or
147
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she met them but, yes, she would come up and I guess
she's approached them and not necessarily acknowledged
that there's as much of an issue as she might need to
appreciate --
You're speaking more generally here that there's
something Teflon about her, ie criticism never sticks,
correct?
Possibly. That's possibly what I ~
Was that your view?
I think that's quite a harsh view, I think I'm just
speaking off the cuff here that --
Sometimes when we speak off the cuff it reveals our true
thoughts, doesn't it?
Yes, possibly it does.
So why had this situation been allowed to carry on, that
somebody who was "Teflon", ie criticism never stuck,
they were impervious to blame or criticism, they
maintained their good reputation, even though they had
done something wrong --
Well, I don't think she'd done something necessarily
wrong it's just that something hadn't -- she's the CEO
of an organisation that the procurement hadn't panned
out as it should have done and it ended up costing some
money. It's not necessarily her fault and I think the
person who was in charge of IT ended up leaving the
146
something in January where we'd raised this and they'd
asked us to do a deep dive on the options around the
Chief Executive and these are the notes of that
discussion.
How frequently did the ShEx Risk and Assurance Committee
meet?
I don't know. This was -- I think a sort of outcome of
an initial -- of a portfolio review, which is
a quarterly thing that we tend to do at ShEx or did at
ShEx.
Did the risk registers that we looked at earlier feed
into the Risk Committee?
Possibly, and the management and the quality of
management was on the risk register.
I meant did the risk registers get taken to the Risk and
Assurance Committees?
I don't know because I wasn't on the Risk and Assurance
Committee. I'd only appear when it was a specific -
specific to the -- a particular risk that I was.
managing --
You're the presenting team here?
Yes, I'm presenting to a committee who are considering
our position and whether we're dealing with it properly.
You were also an author or a signer-off of the risk
registers?
148
(37) Pages 145 - 148
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Yes.
Did you know whether or not the documents you were
writing or signing off got sent to the Risk Committee?
I can't remember whether I knew that or not but I knew
that they would go to a risk team who would consider it,
and then the summation of the -- all of the risk would
then go, most likely, to a Risk and Assurance Committee
but they'd go to ExCo, the Executive Committee.
If we scroll down, please. Paragraph 2:
"RC [you] set out that advice from the recent ShEx
Annual Review of [Post Office] was to consider the
continued suitability of the current CEO."
So there'd been a ShEx-wide annual review of Post
Office; is that right?
So yes, there'd be quarterly reviews and then there's
a one-off annual review, where the team presents to
a set of peers, who kind of review what we're doing, and
so risks across Post Office, and the issue of Post
Office would be presented to the -- risks and other
issues would be presented to the -- to a team of peers
at an annual review and a quarterly review.
"There has been a general consensus that there is
an issue with the leadership of Post Office, however
there has only been anecdotal evidence.
"3. As the new Executive Director in ShEx for [Post
149
What would an independent Board review of the CEO's
position consist of?
I would imagine -- I don't actually know, to be honest,
I think it's probably a specific conversation amongst
NEDs to say what is our position.
What steps in the absence of an independent Board review
-- and we've seen none -- did ShEx take to quantify or
evaluate whether there was any merit in the anecdotal
evidence that is mentioned in this note?
So I think that, after this meeting, the idea was to go
and talk to the NEDs in more detail, and I think it
ultimately culminates in a desktop study we asked
a recruitment firm to do, to see if there were any other
alternative candidates that would be better than Paula,
because it's one thing to say we're unhappy with the
performance or -- not necessarily unhappy with the
performance but we may think there may be someone better
out there, but the idea is to go and find out. So later
‘on, I think it crystallised around the June away day, by
July we're in a position where we're commissioning, or
seeking to commission, Egon Zehnder, who are recruitment
consultants, to do a desktop review who was out in the
market for slightly more remuneration than Paula.
The answer essentially, do I summarise correctly, came
back no one, for the allegedly low pay?
151
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Office] [you] would now like to investigate this further
and is carrying out initial discussions with the Chair
and other [Post Office] NEDs. The committee suggested
that [you] continue to have regular catch-up meetings
with the NEDs as a matter of course.
"4. [You] also highlighted that there have been
issues between the Minister and the [Post Office] CEO."
Then forward to 5:
"The leadership role is in question due to the lack
of delivery of the current [Post Office] transformation
plan. This is their first CEO role and [Post Office's]
objective of being commercially sustainable is currently
being achieved. That said, the Network Transformation
is slower than expected but this is not necessarily
a fault of the CEO, further investigation will confirm.
Then over the page to 8:
"The Board has been in place for 16 months now and
their view on the CEO performance is mixed. The Chair
(who is also in her first Chair role) [that's Alice
Perkins] is still making a view. It has been suggested
that an independent Board review takes place. The
committee agreed that this would be a good idea and
confirmed that this should be an independent review."
Did that happen?
I can't remember.
150
Correct. The -- it felt that the -- it would be quite
hard to persuade ministers to part with Paula in return
for the cohort of people that had come through -- more
expensive cohort of people had come through. It would
just be more of a risk than keeping Paula in place.
Essentially, did this issue continue to fester,
ie concern --
Yeah.
-- amongst the Board about Ms Vennells but no concrete
action taken?
Well, we took action in the sense of doing that summary
on behalf of the Board, and Alice, as I understood it,
continued to mentor her up until that point. So it's
‘one of those things with Non-Executives, there's sort of
rumblings and side conversations, and then it sort of
meets with a crescendo and then action is taken, which
is where we got to with Egon Zehnder. I mean, my
position at this point was -- look, my view is that the
CEO role of Post Office is very, very difficult. It's
not just a single business; it's a conglomerate of
different sorts of businesses, plus it's
a government-owned business as well, so it's highly
political. It's very hard to find anybody that would
run it really well, to be honest, in my view.
And, you know, as a new person to the job -- and
152
(38) Pages 149 - 152
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I can't remember what date this is -- I might not have
even seen her perform at a Board by that point. So
I was still early days forming a view and, really, a lot
of this was coming from my team, who I trusted and who
I'd worked next to for quite some time, so I knew that
they were good. But I was having to rely on the team
and wanting to take time to form my own judgement.
Thank you. Can we turn to a separate topic, namely your
perception of the extent of issues or problems with
Horizon.
Yeah.
Can we turn to paragraph 69 of your witness statement,
please, which is on page 35. You say:
"In general terms, I found it difficult to identify
the correct balance when it came to the appropriate
level of Government engagement on the Horizon issue. On
the one hand I thought it was clear Government should
not intervene directly in the Mediation Scheme or court
proceedings, but on the other this was clearly a matter
of public concern, often raised in Parliament and the
media, with which Ministers were required to engage.
There was also the general point that, from my
perspective, it was difficult to see what the Government
could realistically be expected to do in response to the
concerns that were being raised in the apparent absence
153
fault and I think when I asked the question about when
you plead guilty, I was told, rightly or wrongly, that
the evidential basis still needs to be there for the
court to accept that plea.
Is that right; who told you that?
I can't remember.
Was it a lawyer?
It might have been. I don't know. I can't remember.
Why were you asking whether there needed to be --
I think it was --
-- proper -- hold on -- whether there needed to be
a proper evidential basis for a court to approve of
a guilty plea, irrespective of the plea of the
defendant?
Because I think it was in response to the point around
people had been pressured to plead guilty. So I was
wanting to -- it was part of my trying to understand the
extent to which one can simply pressure someone to plead
guilty, regardless of the evidence that's there.
You continue:
"and the unequivocal assertions by [Post Office]
that the issue had been exhaustively investigated and no
evidence of any problem had been found. I thought the
Government was in a difficult position in relation to
this issue and it was part of my job as a civil servant
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of a problem with Horizon, the stated decisions of
numerous different criminal proceedings ..."
Just stopping there, what do you mean by the "stated
different decisions of numerous different criminal
proceedings".
I guess, rightly or wrongly, I took assurance from the
fact that the courts convicted people beyond reasonable
doubt. I assume that's quite a high bar and -- because
there had been prosecutions by POL but, at the same
time, there had been -- it's the court that convicts, so
I took a degree of assurance that the courts had looked
at the evidence being put forward and, nevertheless, had
seen to convict, either by a jury --
Did you know how many cases had been taken to trial,
rather than guilty pleas for false accounting in
exchange for dropping a theft charge?
No, I didn't. I knew there was around about 50
prosecutions a year.
Did you know the proportion of those where the court
had, in fact, tried the issues?
I didn't, but I knew that some people had pleaded
guilty, and —-
So did you take assurance from that?
Yes, I did in some respects but, also, I knew that not
everybody had pleaded guilty and the court still found
154
to help ministers steer a path through these competing
considerations."
What was your perception of the reliability of
Horizon based upon?
It was based upon the fact that, throughout my tenure,
there was some sort of investigation going on, be it the
Mediation Scheme, be it the Parker Review or under the
auspices of the litigation. The fact that there had
been the Second Sight interim report that preceded me by
six months and the Mediation Scheme was ongoing at that
point, there had also been the Cartwright King/Altman
Advice, which, although it's not necessarily about
Horizon per se, is in -- is about the safety of
convictions and the evidence presented, and so that gave
me -- that gave me reassurance.
And then also, I suppose it's -- the information we
continued to get from Post Office was in a similar vein
and when we probed, we would get, you know, quite
detailed information, as I've said, around things like
the response to the Part Two Second Sight Report, the
response to Panorama, responses to debate -- the points
raised in debates would be quite comprehensive, quite
well articulated and, ultimately, I suppose, no one
seemed to have come forward, given Second Sight had
looked at all this, I didn't feel that they had
156
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articulated a clear link between a fault with Horizon
that could explain the losses that subpostmasters were
suffering. That's kind of what I felt I needed to
understand and see.
I think you accept that the Deloitte Zebra Report was in
part to the contrary effect: it revealed some relatively
fundamental problems?
Yes, I agree entirely, and I --
Just stopping there, that's not a document you ever
read?
I read the first one from 30 April.
Yes.
I can't recall whether I read the Board Briefing from
4 June. If I did read it, I didn't understand the
significance of it but, reading it now, it feels like
I should have had understood the significance of it,
which leads me to believe I may not have read it either
way, I regret that, for some reason, that wasn't taken
to Board, it wasn't considered and it should have been,
because that is, I think, one of the key bits in my
timeline where we might have changed path.
The other key bit would presumably be, in your mind,
Jonathan Swift's advice?
Well, the Parker Review, yes.
Yes.
157
That's correct, I missed the Deloitte report but
I wasn't informed that the Swift Report even existed and
I had a letter that I found reassuring from Tim Parker,
which didn't point to the issues that were being raised
or at least not all of them, the important ones, in the
Swift Report.
Thank you. Can we look at UKGI00019720, please. Thank
you. If we scroll down, please, an email from Laura
Thompson to three members of ShEx, including you,
"Readout from [Jo Swinson's] office on Sparrow’:
"Just had a chat with Claire ..."
Would that be Claire --
In Swinsor's office, I think, probably.
Another --
Another --
Private office?
I suppose it's the same Claire as the Claire before.
Thank you.
"Apparently Jo wasn't overly happy with it - she
feels she wasn't fully aware that [Post Office] were
terminating Second Sight's contract, or that the
publication of the Second Sight Report was so imminent.
I explained ... that the original advice did say that
‘this means POL will be terminating their engagement
with [Second Sight]' and the Second Sight Report was
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I mean, I think --
Well, in particular the advice?
Well, if I'd seen the advice and known what the advice
said, then, yes, I think that would have led to
a different path as well.
So why is it that the two documents that would have led
to a different path are the two documents that you
didn't read or see?
Well, the Deloitte one remains a bit of a mystery.
I don't know why I didn't look at that or the rest of
the Board consider it, and that's one of my -- probably
my biggest regret on this whole thing. With Swift, it
sounds a bit daft but I never really -- I didn't really
think at the time that there was a Swift Report. What
I was interested in was the Parker Review, or the Parker
view. Swift contributed to that but, as I understood
it, Tim Parker was also talking to Second Sight, he
talked Lord Arbuthnot, he was talking internally, and so
what we wanted was the Chair's view, not a QC's -- not
the QC's view of it. We wanted it to be Mr Parker's
view.
So it's coincidental, but for different reasons, that
two revelatory documents, the second Deloitte Zebra
Report and Jonathan Swift's advice didn't operate on
your mind to potentially lead to a different outcome?
158
never due to be published and attempts to portray it as
such are misleading.
"We are probably going to have to go chat to on
Monday to cover off these points, before she'll sign the
letter ...
I think there might be merit in sending Arbuthnot
and Bates ..."
I think that's Mr James Arbuthnot --
Yes.
-- and Mr Bates:
"... a holding reply if we are not going to be able
to reply until next week. I'll talk to private office
about that when I hear back from Tara."
Then scroll up, your reply:
"Not sure I want to provide an interim reply to
Bates and Arbuthnot. It would imply we are thinking
about things (as opposed to just taking some time to
reply).
"Jo clearly didn't read the [submission]! Think we
need to stiffen resolve on Monday. Aside from giving Jo
Hamilton wads of cash [with a little bag of money] and
a full apology, which this doesn't warrant, then this
won't go away in the nice way Jo wants it to.”
Does this email exchange disclose your true views
about Horizon here, that you thought this was a case of
160
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subpostmasters unjustifiably after wads of cash.
Well, I address this in my witness submission where
I apologise to Ms Hamilton, and I'm very sorry --
Of course, everyone does --
Yes, I know --
When their emails are brought up, they always apologise.
Yes, of course they do. Yes, of course they do. As
I explain this, I wasn't singling Ms Hamilton out, I was
making the point around hers was the more high-profile
case. What I'm trying to get at here is that I was
referred to earlier about the tough decisions that
ministers will have to make. As far as I'm concerned by
March '15, we had still not -- I have still not seen
a clear link with a bug in Horizon that generates a loss
to a subpostmaster. I've just not picked that up from
the Mediation Scheme or anything from Second Sight and,
without that, I feel that it's very difficult to provide
compensation to subpostmasters without that level of
evidence.
And what I'm talking about, in terms of stiffening
resolve, is that we put up what I thought was a very
clear submission on 4 March about how the closure of the
Working Group but the continuation of the Mediation
Scheme would work, including the arrangements around
Second Sight, to which Jo Swinson's office is expressing
161
the Cartwright King review, the initial Second Sight
review, had done, and also, actually, Deloitte review,
where we'd listened to Gareth James, I think his name
was, who came to Board. And so all of that led me to
believe -- wrongly -- that there wasn't an issue, and
that -- and the steps taken by Post Office had been
reasonable.
Can I turn, lastly, to the Magnox report by looking at
UKGI00009275. You'll see this is a draft dated
25 October 2017 and, if we just scroll up to see the
badge and the title, it's described as an "Initial
review into UKGI's role in the competition, award and
challenge of the Magnox/RSRL decommissioning contract’.
Can you tell us what this document is? It's not the
Magnox report itself?
No, I think what this is is a sort of lessons learnt
document, commissioned by UKGI in response to
a procurement within the Nuclear Decommissioning
Authority that went wrong.
In brief, that procurement had gone wrong, and then the
litigation involving the --
Yes.
-- assessment of the procurement had gone wrong too?
Yes, so I think this was largely about the latter part,
I think, possibly.
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surprise at, when I thought it was very clear in the
submission what the arrangements were.
Does this disclose a dismissive attitude towards the
plight of individuals by you?
Possibly. I think it discloses my view that, from what
I'm hearing from Post Office, consistently, and what I'm
not hearing -- and I'm not hearing from Second Sight are
a particular clear link between the Horizon IT System
and losses being incurred by subpostmasters. There
doesn't seem to be a link and, therefore, I'm sceptical
of that position of the JFSA.
Do you think that you, like perhaps others within the
Post Office Executive themselves, had rather forgotten
that, behind the campaign, lay individuals whose lives
had been destroyed by the impact of their criminal
convictions?
I hadn't forgotten that but I wasn't really sure what to
do about it because I couldn't -- as I've explained
elsewhere, I wasn't sure how Government -- what
Government could do to intervene.
As the Shareholder NED, ought yours to have been the
role that retained an independent and enquiry mind?
Well, I -- what I was trying to do was make sure that
Post Office looked at the issues seriously and, as far
as I was concerned, that's what the Mediation Scheme,
162
You tell us in your witness statement -- it's
paragraph 307, no need to turn it up -- that you were
aware of the lessons learned from this review?
Well, belatedly, but -- well, I don't know when I learnt
of the lessons of the review. This is from October '17,
which is towards the end of my tenure and its draft.
I'm not quite sure how of the findings got to me more
formally. I remember some sort of seminar at UKGI,
where they were sort of unveiled, I think. But! don't
know when that was.
Can we look, please, at page 26 of UKGI's review and
under the heading "General lessons learned", if we can
scroll down, please, to 4.12:
"The general recommendations below are made ...”
Then, if we go over the page, please, the first
bullet point of substance on that page is the
recommendation that:
"Where large legal risks are involved, UKGI should
ensure that an asset's board has direct access to legal
advice and to the in-house Legal Team. Legal advice
should not be relayed to the board by the Executive
Team, as it was in this case. Misunderstanding/
misconstruing legal advice was a material factor which
explained why the [Nuclear Decommissioning Authority]
Board was slow to respond in both the litigation and the
164
(41) Pages 161 - 164
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consolidation. Ensuring that an asset's board is
provided with the opportunity to discuss and challenge
legal risk directly with a General Counsel would
mitigate this risk, as would ensuring that the General
Counsel reports directly to the CEO."
Then if we scroll down, please, two bullet points
from the bottom:
"In holding 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 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 the UKGI
in-house legal colleagues.”
If we go back, please, to page 25. Under "Lessons
learnt during litigation":
"Steps that UKGI can take to mitigate/address the
underlying failings which caused this issue going
forward:
"[1] Government should be made aware of and approve
key steps in substantial litigation. To ensure the
appropriate level of challenge and oversight of any
165
to be uncertain, even a small risk of a very significant
setback requires mitigation. UKGI should ensure a full
discussion of the legal strategy to ensure risk
mitigation has been fully considered."
To what extent were those recommendations carried
into effect from October 2017 by UKGI?
So I'm not sure whether, as I said, when I would have
learnt of those recommendations because this is a draft
document, and so I'm not sure when those were released
but, by January 2018, the Board is putting a Litigation
Subcommittee in place and we're in discussions with Post
Office about the information-sharing protocol.
When, to your knowledge, were any of the
recommendations, as a result of the Magnox Inquiry
carried into effect by UKGI?
To be honest, I don't know but it was -- by being on the
subcommittee -- that was -- I wasn't on the
subcommittee, Tom Cooper -- sorry, if I could step back.
Tom Cooper, by this time, at least not quite October but
by the end of 2017, had joined and I was working in
parallel with him. He was observing the Board so he was
going to -- we ended up nominating him to go on the
Litigation Subcommittee, rather than me, given that
I was stepping down in March.
So much of this would have been dealt with via the
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future large-scale litigation the NDA and other assets
face in the future, UKGI should recommend that framework
documents with assets require immediate notification of,
and Government approval for, litigation above
an identified threshold of ‘substantial liability by
reference to each asset's risk profile."
Then the last bullet point that we can see, as this
is displayed:
"Where a substantial legal challenge is mounted
against an asset, UKGI should assure itself of the
asset's internal legal capability.”
Then scrolling down, last bullet point:
"Where the stakes are high, source more than one
external legal opinion. UKGI should insist that the
asset consider more than one external legal opinion to
ensure that legal advice and identified risks are
thoroughly tested. Further, it should ensure that any
opinions and their authors appear before the asset's
board so that the board is able to take strategic
decisions with proper calibration of legal risk.”
Penultimately:
"Legal strategy and mitigation of risk must be
challenged. Throughout, the NDA Executive Team
portrayed the litigation as a 'try-on' and entirely
without merit... litigation is universally recognised
166
Litigation Subcommittee, and we were putting in place
the information-sharing protocol so that we could -- and
I remember there was exchanges in my timeline around
getting second opinions, et cetera, so we were in
discussions with Post Office on doing that sort of
thing.
So we did, towards the end of 2017, into early '18,
the shareholder team took steps to implement this and
the General Counsel at the time was also heavily
involved.
So all of these recommendations ought to have been acted
upon or either accepted or rejected and, if accepted,
carried into effect --
Yes.
~ by the time of the first hearings in the Group
Litigation?
Which were in November '18?
Slightly earlier than that.
Oh, okay, right. So yes, they may well have been but
I stepped down in March '18 date. The subcommittee --
the Litigation Subcommittee of the board was sort of
ramping up, as it were, and Tom was sat on that, not me.
We were getting updates. So they may well have been.
I was less sighted on that because Tom and I were sort
of transitioning over.
168
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Q. Thank you.
So is your essential answer on that: this is more
for Mr Cooper to answer for than you?
A. Yes, I think so. I was involved with sum of it, and --
but yes, it's probably more for Tom than me.
MRBEER: Thank you very much, they're the only questions
\ ask, Mr Callard.
Sir, there are some questions from Core
Participants.
‘SIR WYN WILLIAMS: Mm-hm.
MR BEER: I wonder whether we might take the break now for
ten minutes until 3.05 and then recommence then.
SIR WYN WILLIAMS: Yes. Sure.
MR BEER: Thank you very much.
(2.54 pm)
(A short break)
(3.05 pm)
MR BEER: Sir, can you still see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
MRBEER: Thank you. Sir, we've got three sets of questions
of about ten minutes each.
SIR WYN WILLIAMS: = Okay.
MR BEER: Starting with Ms Patrick, then Mr Jacobs and then
Mr Henry.
‘SIR WYN WILLIAMS: Very good.
169
Ms Thompson and Mr Bourke, and you say:
"Seriously though, do you know how many legal firms
they have had -- would be good to take the lines with
ministers that this is yet another sabre rattle, and
that once legal firms get into the evidence they pull
away."
A. Mm-hm.
Q. Was this another example of a frank conversation with
colleagues, Mr Callard?
A. This one actually is a "Seriously though, do you know
how many legal firms they've had?" Because I'm about to
provide advice to ministers and, if I'm a minister,
I would want to know -- I'd be concerned about
litigation and if there had been, you know, attempts
before that had failed, I might take a different view of
the litigation that's now in front of me than if that
hadn't have happened. I did -- I did bear in mind that
there'd been Shoosmiths, there'd been Edwin Coe and
others.
Q. Okay. "Another sabre rattle".
A. Yes.
Q._ Had you convinced yourself that all lawyers would think
that the subpostmasters simply had no case?
A. By "sabre rattle", I mean, it's another -- so by the
time the -- it's November '15, so the Mediation Scheme
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Questioned by MS PATRICK
MS PATRICK: Good afternoon, Mr Callard. My name is Angela
prpro
Patrick, I act for a number of subpostmasters who were
prosecuted and who have since had their convictions
overturned, including Mrs Hamilton.
I want to ask you about two things. First, one
document, and then a few questions about your role.
First, if we could look at POL00162786, I'd be
grateful. Thank you. Can you see that there now,
Mr Callard?
I can, yes.
If we could start by scrolling to halfway down page 2,
please. We can see here there's an email from Melanie
Corfield circulating a press announcement from the JFSA.
Can you see that?
Yes.
I don't want to look at the detail. You see there's
a big headline "JFSA prepares for Group Litigation
against Post Office", November 2015. The original email
isn't sent to you but if we can scroll up to the top of
page 1, we can see it eventually is forwarded to you,
and there's some exchanges.
Yes.
You are engaged earlier but I just want to look at this
top part. You're replying, at that time, to Mr Davies,
170
had come to an end and, essentially, I think, you know,
there was a -- the Post Office was essentially
disengaged, in that sense, because the Mediation Scheme
had completed.
Can you just pause there for a minute and look at this.
Look at the language you use.
Yes.
After “sabre rattle":
"... and that once legal firms get in to the
evidence they pull away.”
You were asking for essentially that view to be
confirmed, weren't you?
Well, I was asking to -- the reason why I was asking,
because it goes down to others before them, as it were,
I'm saying "Seriously though, Mark, please, can you tell
me how many times litigation had been attempted",
because it's relevant when briefing the minister to know
how many times that had been attempted because she may
draw the conclusion that once, you know, you get into
litigation, you know -- the Shoosmiths --
Mr Callard, can I ask you to stop there?
Okay.
“Would be good to take the line with ministers".
Mm-hm.
You're asking Mr Davies to confirm that's the case,
172
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aren't you?
Well, essentially, because I do think it's perhaps
another case where it might not come to anything because
the evidence I had seen to that point, no one has shown
me a causality between a bug in Horizon causing a loss
to subpostmasters. I hadn't seen anything like that and
so, therefore, I'm saying that's the sort of message
I might use to convey to ministers because it's
relevant.
That sounds perfectly reasonable, Mr Callard, but look
at this message:
"Do you know how many legal firms they have had ..."
Yes.
There's no question mark after that, is there?
Well --
It's a statement, isn't it?
Well, I can see why you think that but it's a very quick
email so I'm not putting a question mark at the end
because I then say it would be good to take the line
with ministers that --
Just pause there. Can I ask if the Document Manager for
today could scroll down so I can see the message that
I wasn't going to read but let's turn it up. Mark
Davies -- you can see there, I think, on your screen at
the bottom, your first reply to Mark Davies, which you
173
between Horizon faults and losses. I hadn't seen any
evidence of that, even though Second Sight had
researched it for two and had a half years and --
Okay --
I'm sorry -
We --
-- and my experience was that there had been failed
attempts at litigation.
Okay, well, let's move on. The second issue I wanted to
ask you about was some general questions about your role
and the factors that were operating at the time you were
in post. They're very basic questions, I think.
Horizon was a business-critical system for the Post
Office, wasn't it?
Yeah.
At the time you were in post, something the Government
wanted to explore was mutualisation for the Post Office.
You're nodding but, for the transcriber, you have to say
"yes" or "no".
Yes, sorry, I was looking -- up until about -- during
the Coalition Government, yes.
But yes. It was a goal for Government to reduce the
public subsidy which the Post Office relied upon?
Yes.
These were goals which the Board and the Executive at
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send on 20 November at 8.32. Richard Callard wrote:
"Oh joy, normal service resuming then!"
Yeah.
"This is not saying that they have launched a class
action though is it, they are just 'preparing’."
Mm-hm.
“And what happened to the other solicitors they signed
up ~- it wasn't Freeths.”
Yes.
This is a frank conversation between colleagues, isn't
it, Mr Callard?
Well, it is but I'm asking a -- sort of making a genuine
point there because the previous -- I think it was Edwin
Coe that had been mentioned the previous firm involved
and that had come to nothing and I'd read the article
that said they're preparing, they'd not actually
launched, right? That's correct, is it? You know, I'm
trying to remind myself of what the other legal firms
that had been involved, what they were called.
The first line was a statement, Mr Callard.
Yes, certainly, it is.
You were saying your view that all lawyers will see
they've got no case when they look at the evidence.
That was your view you'd taken, wasn't it?
It was because I hadn't seen any evidence of causality
174
the Post Office were working towards?
Yes.
They were shared goals which you would have understood
as important with both of your hats on?
Yes.
If Horizon could not be relied upon, that would that
have jeopardised the Government's financial goals for
the Post Office, wouldn't it?
Yes.
Is there a danger that you focused too much on financial
implications for the Government in your role as
Shareholder NED?
Not with regard to Horizon. No.
Those financial goals, weren't those what you were
primarily concerned with?
I was certainly concerned with financial performance and
financial goals, and reducing the subsidy that taxpayers
were putting in to the Post Office. But that doesn't
translate and wasn't a primary concern with regard to
Horizon.
While you were looking at that, did you simply fail to
see the Government interest, the public interest, in the
broader sense of making sure that the innocent people,
the innocent people that were involved here, were not
prosecuted or being prosecuted in our country?
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A. Prosecutions had -- you know, were obviously a concern,
that stopped before I got there. And I thought that --
Q. Can I stop you there for a moment, Mr Callard. I wasn't
asking you what -- I was simply saying prosecutions had
stopped but was there not a wider governmental or public
interest in understanding whether a body that was wholly
owned by the State had been responsible for the unlawful
and unfair prosecution of innocent people under its
charge?
A. Yes, and the measures that we were getting Post Office
to take, including the Second Sight reviews and other
reviews, including the Cartwright King/Altman review of
prosecutions I thought were proportionate responses to
the concerns being addressed.
Q. Mr Beer has asked you a series of questions today and
I think you've accepted that you could have been more
curious?
A. Yes, I have.
Q. I want to ask you: did the awful, potentially awful
financial implications for the Government of these
subpostmasters simply being right blind you to the
potential that all of these ordinary, decent people,
supported by politicians of real conviction, might just
be right, and what you were being told by the Post
Office could be wrong?
177
questions for you.
THE WITNESS: = Thank you.
‘SIR WYN WILLIAMS: = Mr Jacobs?
Questioned by MR JACOBS
MR JACOBS: Hello, good afternoon. Can you hear me?
A. Yes.
Q. Thank you. I act for a large number of subpostmasters
and postmistresses, represented by Howe+Co.
I want to ask you about something that arises from
paragraph 156 of your statement, which we don't need to
turn up for now and we will look at the underlying
document. So the document is POL00138251. This in
relation to your first attendance at a Sparrow
Subcommittee meeting on 9 April - waiting for it to
come up on the screen.
Can we scroll down, please, or pause before we do
that. We can see the attendees at that meeting are
Alice Perkins, the Chief Executive, and you attended as
well, with Angela van den Bogerd, Chris Aujard and
Belinda Crowe. Was your role there as the Shareholder
Non-Executive Director?
Yes.
Is that what you were doing at that meeting?
Yes.
Okay. Can we scroll down, please, to the body of the
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A. The -- my position was not informed by the financial
ramifications of us being wrong. I would have just
dealt with that, like every other financial ramification
that we had from failed procurements to incorrectly
stated accounts, to overruns in Network Transformation.
So the financial considerations, we were clearly worried
it
Q. Is it possible that the fact that the failure of Horizon
would mean that mutualisation would simply not be
possible, is it possible that might have made you
a little incurious?
A. No, not at all. The mutualisation agenda was clearly
‘one that would take quite some time and mutualisation
was recognised as only being able to happen once
financial sustainability had been achieved. So you
can't be a mutual unless you're making profits and
you're financially sustainable. So it was not
an immediate -- it wasn't an immediate term goal because
it was clear that it would take some time for
mutualisation to take place and no designs as to what
mutualisation really means or would look like had really
been thought through by that point. So there was
a complete disconnect in my mind between mutualisation
and the Horizon issue. It just wasn't relevant.
MS PATRICK: Thank you, Mr Callard. I have no further
178
document. Keep going further, please. This is the
document that was provided to you and in bold type at
the second paragraph it says:
"The scheme [and this is the Initial Complaint
Review and Mediation Scheme] was established in August
2013 to resolve complaints in respect of the Horizon
system, on the basis that [in bold type] there were no
systemic problems with Horizon."
Now, were you aware that that statement was not
true?
A. In what sense?
Q. That the scheme was not established to resolve
complaints on the basis that there were no systemic
problems with Horizon?
A. Sorry, is your question that -- was I aware that the
scheme was established on the basis that there were no
systemic faults?
Q. That that was actually false?
A. Oh, well, I wasn't aware at the time that that was
false; I had the Second Sight Interim Report in my mind
that said exactly that.
Q. Well, there was a document, and we don't need to call it
up, but it was a document entitled "Post Office overview
of the Initial Complaint, Review and Mediation Scheme",
for the record that's POL00022120. It makes no mention
180
(45) Pages 177 - 180
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of the fact that the scheme was established on the basis
that there were no systemic problems with Horizon and it
actually says that Second Sight will determine
individual cases and will seek to look at whether there
was a problem with Horizon or any associated issue that
had an impact on subpostmasters.
So it was very much the remit of Second Sight, at
all stages -- and lan Henderson gave evidence to this
effect -- to look for systemic problems with Horizon.
I mean, my interpretation of the Mediation Scheme and
the investigations involved with it was that the Interim
Report had found there were no systemic failures but
there were, nevertheless, subpostmasters who said there
is still a problem. So I thought a sensible reaction to
that, which pre-dates me, is that each individual case
should be investigated by Post Office, then Second Sight
and then go to the Working Group for potential
mediation. I wasn't really concerned about systemic
failures in that sense because I thought, well, a very
sensible way to look for problems with the system is
to -- rather than look top-down is to look at the things
that people are saying, and investigate those
individually.
And they may find problems with either are systemic
or aren't systemic, it doesn't really matter. They will
181
incorrectly, to be the interim findings of Second Sight
and translating that into the whole scheme, when the
whole scheme did not operate on that basis.
My question to you is: isn't that an example of the
sort of abuses that are inherent in a scheme where the
subject of an investigation is the paymaster? Do you
accept that --
I can see why --
-- that was an issue --
-- there might be a conflict in that sense but I got the
very strong impression that Second Sight were quite
independent and went about what they wanted to go about
without really worrying about what Post Office -- who
was doing the paying. And what I thought was happening
was that Post Office investigate, Second Sight
investigate, and that's exactly what was needed. I'm
not sure that I felt that the fact that the Post Office
were paying for Second Sight, though, was.
a consideration for the Non-Executive -- as a Board
member, it's clearly a consideration, just like the
internal costs for Post Office were a consideration.
But I don't recall taking decisions at the subcommittee
‘on the basis of cost and costs alone.
Mr Callard, as the Shareholder Non-Executive Director,
are you concerned that at your first Sparrow
183
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find -- if they find a problem, that's good because then
it will explain the loss.
Q. But that statement in bold type is not true and didn't
it strike you as odd that the Sparrow Subcommittee is
saying that a scheme, which is to include a Second Sight
investigation on the Horizon issue in individual cases,
wouldn't consider whether there was a problem with the
Horizon system?
A. Well, I didn't interpret it that -- in that way.
I think that -- I took the wording in bold just as
a re-assertion of the Executive's point of view, that
that's what Second Sight had found nine months prior,
and that was that. I didn't really -- I don't think
I would have read it that way or scrutinised it to that
extent.
Q. Can I just ask you to bring the microphone closer, we
have number of clients who are following remotely who
can't hear you. Thank you.
A. Sorry.
Q. So when Mr Warmington gave evidence in June, he
criticised the fact that the whole scheme was predicated
‘on the principal subject of the investigation of Second
Sight's investigation and the Post Office being the
paymasters, and what we see here in this document is the
Sparrow Subcommittee taking what is understood, probably
182
Subcommittee meeting, which you attended as the
Government representative, the representative of the
‘owner, you were told in a document something that was
plainly untrue; doesn't that worry you?
A. Well, I didn't see it as untrue at the time. If you're
talking about the paragraph -- the sentence with the
bold --
SIR WYN WILLIAMS: Well, I think I've got this point.
MR JACOBS: Yes, I was going to ask my final point about
curiosity and whether he asked about this at the time.
Perhaps if I could just conclude with that?
SIR WYN WILLIAMS: Well, I'm pretty sure he didn't,
Mr Jacobs.
MR JACOBS: Very well.
THE WITNESS: Yes, because I don't recognise that --
MR JACOBS: Very well.
I don't have any further questions. Thank you.
THE WITNESS: Thank you.
‘SIR WYN WILLIAMS: = Mr Henry?
Questioned by MR HENRY
MR HENRY: = Thank you, sir.
Pannell Kerr Forster, Arthur Andersen and Deloitte
specialised in government and infrastructure. What was
your knowledge of IT systems before you became
Shareholder NED?
184
(46) Pages 181 - 184
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Very limited.
Very limited. So it never occurred to you that
Horizon's failures did not have to be system-wide; they
could be intermittent, sporadic, random glitches. It
never occurred to you that those intermittent bugs could
be capable of causing losses for a small cohort of
subpostmasters?
It did occur to me, which is why I was reasonably
comforted by the investigations into each individual
case. So Interim Report says no systemic errors,
that's -- get that. But then, Post Office is still
looking at the individual cases where, as I said,
I wasn't really -- I didn't get hung up on the word
"systemic". If there's an error, what I hoped would be
found -- or not found, either way -- is a clear error in
Horizon that could be shown to cause a loss, whether
it's systemic or not or repeats or not.
You had a growing number of subpostmasters who were
complaining but bugs, errors and defects -- using their
‘own language -- but that they were getting losses?
Mm-hm.
You did not get a grip on that, did you?
I was looking for Post Office to get a grip on that and
what I understood the Mediation Scheme and the
investigations were about were about exactly that:
185
cent, which I should have benchmarked but it felt very
low because the Post Office is vast. And so there's --
well, you've heard the 68,000 users, et cetera,
et cetera. The way I had it in my mind with regard to
the Mediation Scheme was that there were 136
subpostmasters, which spread over 14 years’ worth of
Horizon's existence was 10 a year, versus 68,000 users.
And, in fact, there had been over almost 500,000 users
cover those 14 years. So that figure didn't seem high to
me.
But there were much more than 10 being prosecuted per
year.
Oh, sorry, I was talking about the -- yes, you're right.
There were 40/50 people being prosecuted --
40/50, yes, which is less than 0.1 per cent. So that
didn't strike me as being particularly high. In
retrospect, I should have benchmarked it.
Can I move on to the second point. Prior to becoming
the Head of the Shareholder Team and the Shareholder NED
for the Post Office, you were part of the Royal Mail
Shareholder Team. So you were aware of the background
of the conjoined asset, weren't you?
Yes.
Were you part of the Royal Mail Shareholder Team during
the flotation?
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understanding what had happened at that particular --
for that particular subpostmaster, which was
investigated by Post Office and then investigated by
Second Sight. So, to my mind, those instances where it
might be just single one-off were being investigated
and, if there was a problem, I hoped, with the
combination of Post Office and then Second Sight looking
at it, that that error would be found.
We've heard that, at the end of this sorry tale in 2019,
Tim Parker said that 959 people had been prosecuted on
Horizon evidence. Did you ever ask for data and
statistics to explore the percentage of subpostmasters
who were being prosecuted apparently on the basis of
dishonesty?
That figure was provided at the first Board I observed
in February 2014.
Did it not occur to you then that this is
extraordinarily high?
Well, I didn't consider it extraordinarily high.
I reflect, in hindsight, that I --
Why didn't you?
Well, hang on --
It's vastly over the normal norm of dishonesty in
a business.
Sorry, the percentage that I understand was 0.1 per
186
Yes. I had two specific roles in that.
Right. So what did you know, at that stage, about the
risk of wrongful prosecutions for which the Royal Mail
Group would have been held responsible and unjust civil
liabilities foisted on the subpostmasters; what did you
know, at that stage, in the run-up to the flotation?
I knew nothing about that because I was looking after
the State Aid application to relieve the pension fund
and I was dealing primarily with the set-up of the
Employee Share Scheme.
In your career, however -- you are capable of expressing
an opinion on this -- the risk surrounding or emanating
from the postmasters' legals actions, their complaints,
‘ought to have been unequivocally stated pre-flotation,
shouldn't they?
It depends, I suppose, where the liability for those --
for that action, where that lies, whether it was --
because there was a lot of work to be done around how
‘one separates Royal Mail and Post Office.
Take it from me that the liability would have lain with
Royal Mail Group. That is not in contention.
Okay.
Now, that ought to have been unequivocally stated
pre-flotation, shouldn't it?
I don't know the listing rules, I'm afraid. So I don't
188
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The Post Office Horizon IT Inquiry
know.
Well, can I ask you, please, about this. Mr O'Sullivan
was questioned about a document, the minutes of
a Shareholder Executive Board Meeting, from 13 March
2013, and various risks related to the RMG flotation
were discussed but nowhere at all did the ShEx Board
recognise the risk that Horizon prosecutions were, or
may have been, wrongful and presented a risk to the
flotation. Can you think of an explanation for that:
that the SPMs' wrongful prosecutions and unjust civil
liabilities escaped the ShEx Board's attention?
No, I suppose it depends on the -- it was before my time
‘on Post Office. It depends on what ExCo were being told
by the Shareholder Team at the time.
So it would have depended upon that?
Well, yes, because --
Right. Right.
Do you accept, having reflected on your evidence and
what has been put to you today, that in your twin roles
as head of the Shareholder Team and Shareholder NED for
the Post Office, you lost all objectivity?
I don't think I lost all objectivity. I think what
I was doing was looking at the evidence that was being
presented to me, which included that it had been looked
at by Second Sight and the likes of Deloitte, which
189
and that innocent subpostmasters were the victims.
Clearly this is wholly untrue in two respects, probably
untrue in a third."
Then:
"When Paula/Al were explaining things she jumped to
an understanding and it was difficult to bring her back
from that first impression/correct her."
Then I omit words but you can read for yourself the
remaining bullet points.
Mm-hm.
Can I go to your response at the top, please. What did
you mean by "Positively Wilcox-ian"?
If you look at the first bullet point below, "There's
clearly still some confusion about what is Royal Mail
and what is Post Office". Baroness Wilcox was our Lords
Minister, and we often had to -- well, we had to explain
the difference between Royal Mail and Post Office, as
indeed we do with most people, including myself, before
I joined Government. People aren't clear.
I see. So that's that they're both peas of the same
pod; Tweedledum and Tweedledee: they make the same
mistake?
No -- well, we're making the same mistake because,
before I joined ShEx, I didn't know the difference
between Royal Mail and Post Office, to be honest.
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I accept I missed, and making a judgement.
You say you don't agree that you lost all objectivity,
but do you believe that your objectivity was markedly
compromised?
I'm not sure that I do.
Well, let me put it to you that Sparrow was a cynical
containment strategy -- that's what it was -- and, in
fact, in internal documents by the Post Office, it has
even been referred to as a “containment strategy", and
you were part of that?
No, I wasn't, and the discussions I was party to at the
Board, it was very clear that the Non-Executive
Directors clearly wanted to understand whether their
Electronic Point of Sale System was safe or not.
Can I take you to UKGI00019859. You did not write the
email that I'm going to take you to initially, which is
from Tim Mcinnes.
Yes.
But he is writing about a meeting with Baroness
Neville-Rolfe and he states -- I'm not going to read out
the whole thing but, in general, there is a certain tone
of derision towards the Minister. But let's go to the
second bullet point:
"As she has mentioned before she thought that
Horizon was another example of a Government IT debacle
190
The Minister, however, got it right, didn't she --
She did.
- over that bullet point?
Yeah.
But the whole team was there. It was you, it was
James -- is it Baugh --
Baugh.
-- Michael Dollin, Laura Thompson -- who obviously had
very close contact. This reflected the groupthink,
didn't it, that Horizon is safe, these postmasters are
on the take, or attempting to be on the take?
This is by what, June '15? By that point, there had
been almost three years of investigation into Horizon
and I'm ~
I'm asking you about the groupthink.
Okay.
I'm asking you about whether this reflects a cynical,
close-minded approach to the postmasters.
I think it reflects the data points that we'd received,
and the consistent reassurances that we'd had from Post
Office, and our understanding of the things we'd read
from Second Sight and the things I'd seen from Deloitte
by that point.
So you were looking at it at a very high level as
befits, I suppose, your training as an accountant, that
192
(48) Pages 189 - 192
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it was the data; the humans who were expressing this
sorrow, they didn't count?
Well, they do count, of course they do. But I can only
see the -- I'm asking -- well, I can only judge it based
‘on the data that I'm seeing --
I see.
-- after three years of investigation.
Can I go to another document, please, which is
UKGI00019531. Could we scroll up, please. This is
"Sparrow Questions", and we can see that it's in
December '14:
"... Patrick [it must be a reference to Bourke] is
holding the pen on this ..."
Then can we scroll further up, please, from you,
yes. Do you see the pro-penultimate paragraph which
begins "I would be happy to discuss these”, and then it
says:
"Even if we don't speak publicly of some of the
questions needed in here, we still need the answers to
provide Jo privately with the confidence to rebut James
Arbuthnot's claims. Although we have kept her sighted
‘on the scheme, there has clearly been a limit to what we
could tell her given confidentiality reasons to date."
Yes.
Here, the Minister is being used as a cannon to fire
193
about, you know, that you were relying on Second Sight
and you were taking comfort from Second Sight,
et cetera, et cetera, et cetera. I suggest that that's
rank hypocrisy: you wanted to get rid of Second Sight,
didn't you, Mr Callard?
I felt that they were holding up the Mediation Scheme's
work because there were two of them versus 20-odd
investigators at Post Office. So that's why, in the
Sparrow Subcommittee, we were looking at those sorts of
things, because we were getting inbound letters from,
for example, Sir Alan Bates, saying it's not going quick
enough. Meanwhile, from our perspective, Second Sight
aren't getting through the cases.
In fact, actually, nobody could have been prouder than
you when the mediation was brought to an end and Second
Sight were terminated; isn't that right?
Well, mediation wasn't brought to an end.
Well --
Well, hang on. So it's always mischaracterised as the
Mediation Scheme was stopped. The Working Group, which
was there to triage cases into mediation, was disbanded
because there was the presumption of mediation, which
is, as I understood it, a position that James Arbuthnot
and Sir Alan Bates had been calling for.
Right. Well, let me rephrase it and, by the way, when
195
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12 July 2024
your cannonballs, isn't she, even though she isn't fully
in the picture?
No, what this is a reference to is the confidential
nature of each mediation. It was agreed that details of
each mediation would be kept confidential because they
related to very personal circumstances, and Government's
point of view was always "We didn't really want to go
into that".
So the reference here is "we [can't] speak
publicly”, is that where there are questions -- or where
there are points made by James Arbuthnot in the debate
forthcoming, we cannot rebut those or respond to those
using specific examples of specific cases because they
are confidential but it may be that in private we can
explain those to Jo, so she understands when she stands
up and has the confidence.
You wanted short and punchy rebuttal of James Arbuthnot.
That's what this email says, doesn't it:
"It would be helpful if answers are short and punchy
Of course because --
Well --
-- you have to have short and punchy responses in
a debate. But that's just the way lines are written.
You have constantly, throughout my questions, talked
194
you said that Second Sight, there were only two of them,
they had more people working on it, and you, of course,
as well, were short resourced and so, therefore, other
people had to be brought in.
But let me go to my last document and I will finish
on this. It's UKGI00003792. Second Sight have been
terminated. It's been managed well in the house. There
hasn't been too much fallout, if any at all, in the
media following Prime Minister's Questions.
We can go through the whole of this but I'm sure
you're familiar with this email chain, so I'm going to
take it going straight to the top, after Alice Perkins
saying that Alwen Lyons, Neil McCausland, et cetera,
et cetera, Alasdair Marnoch, Mark Davies, et cetera,
have all done a brilliant job, "Mark and Jane ...
brilliant job", so Mark Davies and Jane MacLeod,
et cetera, et cetera, you write to Laura Thompson, your
colleague, and say:
“Let's just say that we are the unsung heroes!"
Your smug satisfaction that you had got rid of
Second Sight and that you had managed it so well in
Parliament --
Well --
- isn't that right?
I'd say there's two points on that. The first one is
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what Post Office -- following the Cartwright King
review, where Altman had said it's anachronistic to
bring your own prosecutions, the Board that I was to
Second Sight were retained to finish investigating all 1 gentlemen. Alll right?
of the cases in the Mediation Scheme and they were also 2 Thank you very much, Mr Henry.
retained to finish off and publish their Part Two 3 Questioned by SIR WYN WILLIAMS
Report; so that's the first point. The second point is 4 SIR WYN WILLIAMS: I've got one question for you, or it may
this was an off-the-cuff remark to Laura about how Alice 5 be more than one.
was thanking Mark for all the work he was doing in 6 Did I hear you correctly tell Mr Henry that at
managing the media and Parliamentary scrutiny that this 7 either the first or one of the first Sparrow
was going to get and didn't thank or didn't consider the 8 Subcommittee meetings there were, you were actually
fact that Laura had been working long hours in the 9 provided with the information that there had been 950,
background at the Government end. And that was not 10 or thereabouts, prosecutions in reliance upon Horizon
a unusual occurrence where, you know, we'd be the first 1 data?
to get moaned at by Post Office but we wouldn't get 12 A. No, what I said was that there's a Board paper -- the
thanked. 13 Board -- the first Board I observed was in February '14.
I'm not concerned so much at Mrs Perkins’ lack of 14 The first item in that Board was a paper on the new
politeness or consideration towards either you or 15 prosecutions policy. In that paper there was some
Ms Thompson. It's reflecting, is it not, the fact that 16 history and I think the statistic in there was that
this was your agenda, the two of you, "Let's just say 17 there were 50 -- generally speaking, 50 prosecutions
that we are the unsung heroes"? 18 a year, which equated to 0.1% of the users of Horizon,
It's -- 19 or something like that.
That you were an integral part of the agenda to get rid 20 SIRWYN WILLIAMS: I just want to be clear because did that
of Second Sight? 21 paper acknowledge, either expressly or impliedly, that
A decision had been made to -- in an effort to speed up 22 the 50 prosecutions per year were in reliance upon
mediations that there be a presumption of mediation, 23 Horizon?
which -- 24 A. I don't know. I think it was --
‘SIR WYN WILLIAMS: _ I think I've got this point as well, 25 SIRWYN WILLIAMS: Right, okay.
197 198
I think it was just about prosecutions generally and INDEX
RICHARD JOHN CALLARD (sworn) ..
Questioned by MR BEER .
12 July 2024
join was reconsidering that polic Questioned by MS PATRICK .... 170
; 9 poly: Questioned by MR JACOBS 179
SIR WYN WILLIAMS: All right. That's fine. Thank you very
fh Questioned by MR HENRY 184
tue. Questioned by SIR WYN WILLIAMS .. 198
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I think that brings an end to the questioning, does
it not, Mr Beer?
MR BEER: Yes, it does, sir.
SIR WYN WILLIAMS: So thank you, Mr Callard, for your very
detailed witness statement and for answering questions
during the course of the day. The Inquiry and I are
very grateful that you have done that.
THE WITNESS: = Thank you.
MR BEER: Sir, I think it's 12 noon on Monday, with
Sir Stephen Lovegrove.
SIR WYN WILLIAMS: That's my understanding, too. So we'll
adjourn until then.
MR BEER: Thank you, sir.
(3.48 pm)
(The hearing adjourned until 12 noon
On Monday, 15 June 2024)
199
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T[A] 124/23
‘Il would [1] 124/23
"kept [1] 103/17
‘no [1] 52/19
"pace' [1] 119/6
"preparing' [1] 174/5
"red [1] 113/7
‘substantial’ [1]
166/5
‘Teflon’ [1] 145/3
"The [1] 108/12
‘this [1] 159/24
‘try [1] 166/24
‘Well [1] 34/19
‘What [1] 34/18
--just [1] 76/11
0
0.1 [2] 187/15 198/18
0.1 per [1] 186/25
02 [1] 65/10
4
14 May [1] 44/6
1 October [1] 65/4
1.10 [1] 129/9
1.11 [1] 129/13
1.55 [2] 129/10
129/15
10 [4] 11/24 70/24
187/7 187/11
10 April [1] 91/7
102 [1] 136/24
11 [4] 68/7 68/17
71/13 74/23
11.05 [1] 60/23
11.08 [4] 61/2
11.20 [2] 60/24 61/4
12 [7] 1/1 13/9 87/1
88/6 91/14 91/16
199/22
12 noon [1] 199/16
12.18 [1] 99/15
12.20 [1] 99/12
12.30 [2] 99/12 99/17
128 [1] 128/2
13 [1] 3/20
13 February [4]
62/12 63/14 65/3 66/7
13 March [1] 189/4
13/02 [1] 65/10
136 [3] 75/6 75/7
187/5
14 [3] 3/20 187/6
187/9
14 June [1] 1/15
15 [1] 199/23
15 July [1] 58/19
150 [1] 20/20
156 [1] 179/10
16 [2] 11/24 150/17
16 April [2] 31/1
131/23
163 pages [1] 1/14
17 December [1]
35/23
173 [1] 2/9
18 [4] 13/9 26/12
94/22 104/18
19 [2] 11/24 48/13
2
2 April [1] 100/2
2.54 [1] 169/15
20 [7] 19/18 42/15
46/18 82/6 88/6 92/5
92/7
20 August [1] 123/16
20 November [1]
174/1
20-odd [1] 195/7
20.0 [1] 92/15
2000 [1] 53/21
2001 [1] 2/19
2002 [1] 2/20
2004 [1] 54/15
2006 [2] 53/23 54/15
2007 [3] 2/23 50/4
51/12
2009 [1] 2/24
2012 [1] 7/18
2013 [4] 58/11 58/19
180/6 189/5
2014 [24] 3/2 3/3
29/19 35/23 44/6
51/12 53/18 62/11
62/12 63/5 63/15 64/5
65/3 65/4 66/8 78/17
78/17 103/14 119/22
123/16 130/1 142/3
142/12 186/16
2015 [14] 39/6 76/16
76/22 77/3 100/2
100/15 100/21 104/6
108/6 109/15 129/4
133/17 138/16 170/19!
2016 [4] 81/22 81/23
104/18 144/12
2017 [6] 86/10 86/11
163/10 167/6 167/20
168/7
2018 [6] 3/8 3/10
90/21 90/24 91/7
167/10
2019 [1] 186/9
2020 [1] 56/5
2024 [3] 1/1 1/15
199/23
21 [1] 123/10
23 [2] 1/17 141/23
23 April [1] 29/19
25 [1] 165/18
25 October [1]
163/10
250 pages [1] 20/20
26 [1] 164/11
273 [1] 58/10
28 February [2]
76/22 76/25
29 February [1]
81/23
3
3 August [1] 138/16
3 February [2] 39/18
77/3
3,000 [1] 11/3
3.05 [2] 169/12
169/17
3.48 [1] 199/21
30 April [2] 130/1
157/11
30-page [1] 28/15
300-odd [1] 6/6
307 [1] 164/2
317 [1] 11/24
325 [1] 90/22
329 [1] 58/10
34 [1] 102/8
35 [4] 23/16 23/17
23/18 153/13
36 [3] 107/22 107/24
108/2
39 [1] 10/4
3rd [1] 138/15
4
4 August [2] 133/17
140/18
4 June [4] 157/14
4 March [2] 129/4
161/22
4.12 [1] 164/13
40 [1] 81/24
40/50 [2] 187/14
187/15
42 [2] 17/16 81/24
440 [1] 123/15
45 [2] 123/10 123/11
46 [1] 125/14
47 [1] 123/11
49 [2] 141/22 141/23
5
50 [6] 154/17 187/14
187/15 198/17 198/17]
198/22
50 per cent [4] 4/14
4/15 4/16 4/19
500,000 [1] 187/8
52 [4] 128/1
55 [3] 68/6 68/16
7717
57 [3] 68/6 68/16
777
6
6 August [1] 101/11
61 [4] 20/9
62 [1] 20/9
63 [4] 11/24
67 [2] 102/7 102/9
68,000 [2] 187/3
187/7
69 [2] 23/7 153/12
6th [1] 138/16
7
70 [2] 107/25 108/2
8
8 July [1] 73/13
8.32 [1] 174/1
85 [1] 86/13
87 [1] 86/14
9
9 April [1] 179/14
9 September [1]
32/16
9.45 [1] 1/2
90 [1] 122/9
950 [1] 198/9
959 [1] 186/10
ability [1] 17/13
able [10] 21/3 21/13
27/19 36/7 37/1 52/1
140/5 160/11 166/19
178/14
about [212]
above [4] 68/13
70/24 124/13 166/4
absence [3] 103/24
151/6 153/25
absent [2] 12/9 86/17)
abuses [1] 183/5
accept [8] 29/1 38/13
57/3 155/4 157/5
183/7 189/18 190/1
accepted [4] 98/22
168/12 168/12 177/16)
access [3] 125/19
126/2 164/19
accompanying [1]
124/2
accordance [1]
122/16
according [1] 85/23
accordingly [1] 36/1
account [7] 2/12 63/4)
64/3 105/21 137/4
165/9 165/12
accountability [1]
10/8
accountable [2]
10/12 47/14
accountant [2] 2/19
192/25
accounting [4]
105/18 106/21 107/14)
154/15
accounts [8] 104/1
105/3 105/4 105/7
105/19 106/17 106/24)
178/5
accurate [2] 47/2
101/4
accurately [1] 66/6
accusations [1] 36/8
achieve [1] 127/23
achieved [2] 150/13
(51) MR BEER: - achieved
A
achieved... [1]
178/15
achieving [1] 92/17
acknowledge [3]
108/4 108/20 198/21
acknowledged [2]
19/21 146/2
acquittals [1] 54/19
across [5] 62/10 82/2)
133/11 136/1 149/18
act [5] 67/8 67/22
115/9 170/3 179/7
acted [4] 86/16 86/18
111/10 168/11
acting [7] 16/14
107/6 115/20 133/2
133/3 142/5 144/5
action [14] 17/22
20/1 20/5 36/22 67/12
67/23 82/21 105/17
115/13 152/10 152/11
152/16 174/5 188/17
actions [6] 41/14
84/1 84/2 86/25 137/4
188/13
active [1] 143/12
actively [1] 9/1
activity [1] 80/19
acts [1] 118/16
actual [1] 60/4
actually [25] 15/5
21/10 24/21 59/23
60/4 60/18 64/15
64/19 76/1 88/11
89/24 94/19 106/21
118/5 119/1 123/3
138/1 151/3 163/2
171/10 174/16 180/18}
181/3 195/14 198/8
added [2] 11/19
134/6
addition [2] 58/4
106/7
additional [1] 83/25
address [9] 39/9
69/19 103/23 112/12
130/14 135/14 138/6
161/2 165/20
addressed [3] 30/15
112/16 177/14
addresses [2] 68/18
110/17
adequate [1] 128/14
adequately [1] 62/4
adjourn [1] 199/19
adjourned [1] 199/22
Adjournment [1]
129/14
administering [1]
31/12
admission [1] 107/22
adopt [1] 101/13
advance [5] 52/21
123/19 134/15 135/5
137/5
advice [58] 33/8 37/6
53/24 55/18 55/21
55/25 55/25 56/4
56/11 57/21 58/19
59/10 59/18 59/24
59/25 60/6 60/9 60/13
62/17 73/1 73/1 79/17
79/20 87/13 90/18
108/11 111/9 113/17
116/7 124/20 127/24
128/18 132/20 132/20)
132/22 132/24 137/3
137/13 137/24 138/11
139/3 140/5 141/5
141/7 141/14 149/10
156/12 157/23 158/2
158/3 158/3 158/24
159/23 164/20 164/20)
164/23 166/16 171/12)
advise [1] 134/13
advised [1] 128/10
adviser [2] 60/19
60/20
Advisers [1] 141/12
advisors [2] 87/4
140/19
affect [1] 41/13
affected [1] 58/16
afoot [1] 88/8
afraid [3] 45/18 54/4
188/25
after [19] 1/25 12/20
12/23 40/10 56/7
60/23 62/14 64/6
64/18 66/10 77/1
145/21 151/10 161/1
172/8 173/14 188/7
193/7 196/12
afternoon [7] 99/18
115/11 117/22 129/16)
129/19 170/2 179/5
again [6] 10/18 72/18
78/13 112/12 120/22
133/16
against [4] 56/10
86/22 166/10 170/19
agenda [6] 4/24
47/22 142/7 178/12
197/17 197/20
ago [1] 94/22
agree [17] 6/23 6/24
18/2 18/16 41/7 55/8
71/16 71/25 72/11
75/18 103/5 107/15
108/6 109/11 131/12
157/8 190/2
agreed [14] 12/12
17/22 32/6 83/5 85/13
94/14 108/11 110/23
110/24 110/25 118/10)
124/5 150/22 194/4
agreement [3] 17/10
38/2 101/19
agreements [2] 17/9
49/22
Ah [2] 108/1 112/15
ahead [1] 142/12
Aid [1] 188/8
aim [2] 14/15 61/8
Al [2] 122/14 191/5
Al Cameron [1]
122/1
Alan [8] 29/23 30/25
31/6 31/17 32/4
131/22 195/11 195/24
Alasdair [1] 196/14
ALB [2] 80/4 111/8
albeit [2] 92/4 107/5
Alex [1] 143/7
Alice [21] 47/8
112/24 113/2 114/21
120/12 120/14 120/24
121/1 121/4 123/18
124/20 125/1 125/12
142/14 143/4 143/7
150/19 152/12 179/18
196/12 197/5
aligned [2] 19/5
126/13
Alisdair [1] 123/21
alive [1] 6/12
all [47] 13/1 25/22
44/16 48/2 59/1 64/16
64/20 67/4 67/19
68/16 74/25 77/17
78/9 80/20 82/21
92/23 94/1 94/16 97/4
109/16 114/19 115/18
130/21 131/22 132/11
136/10 137/17 149/6
156/25 159/5 163/4
168/11 171/22 174/22
177/22 178/12 181/8
189/6 189/21 189/22
190/2 196/8 196/15
197/1 197/6 198/1
199/6
alleged [1] 55/11
allegedly [1] 151/25
allow [1] 17/11
allowed [1] 146/15
almost [12] 10/10
10/23 19/15 26/20
42/5 100/23 123/5
134/21 145/14 147/3
187/8 192/13
alone [1] 183/23
along [5] 68/16 68/23}
70/6 118/2 140/16
already [10] 8/5
35/12 38/2 78/20 86/6
114/4 116/25 126/7
131/25 142/9
also [40] 7/23 8/1 8/9
9/20 10/17 12/23
16/15 16/18 24/19
30/12 32/21 42/17
46/22 70/4 70/22
73/23 77/3 87/12
88/17 89/21 102/10
105/23 106/6 106/6
125/22 127/3 130/15
140/17 142/14 148/24}
150/6 150/19 153/22
154/24 156/11 156/16}
158/17 163/2 168/9
197/2
alternative [1]
151/14
although [8] 6/5
16/20 37/13 40/1
69/14 99/3 156/12
193/21
Altman [7] 58/12
58/14 62/19 73/1
156/11 177/12 199/3
always [20] 6/3 11/11
26/11 26/23 27/24
28/16 30/21 34/15
36/14 38/20 46/21
48/14 48/19 81/4
88/13 97/9 103/5
161/6 194/7 195/19
Alwen [1] 196/13
Alysa [1] 39/14
am [7] 1/2 61/2 61/4
109/11 128/4 136/6
137/8
ambushed [1] 145/1
amend [1] 36/1
amended [1] 66/23
amongst [4] 46/4
48/2 151/4 152/9
amount [3] 12/21
58/3 120/12
anachronistic [1]
199/3
analytical [3] 28/11
28/17 29/5
Andersen [2] 2/19
184/22
anecdotal [2] 149/24
151/8
Angela [3] 77/1 170/2
179/19
angle [4] 2/4 11/14
11/17 11/19
announced [1]
118/11
announcement [2]
22/10 170/14
annual [5] 105/19
149/11 149/13 149/16}
149/21
another [15] 41/19
43/20 97/13 100/11
112/6 138/19 159/14
159/15 171/4 171/8
171/20 171/24 173/3
190/25 193/8
answer [9] 33/18
96/7 110/6 110/13
120/8 134/24 151/24
169/2 169/3
answering [1] 199/12!
answers [9] 28/1
28/20 37/20 116/4
136/19 136/20 139/8
193/19 194/19
Anthony [8] 29/24
30/3 31/5 31/9 31/13
31/17 32/10 140/16
Anthony's [1] 30/8
anticipate [1] 35/13
anticipated [1]
124/22
any [78] 5/1 5/22 6/4
6/22 6/22 8/12 9/1
12/22 16/12 17/3 17/4I
17/5 17/7 17/13 22/11
23/3 25/16 31/17
38/10 38/15 40/23
44/1 48/13 53/18
57/15 58/16 59/18
59/22 59/23 60/1 60/2
60/3 65/25 72/1 74/5
74/6 75/16 75/16
75/16 87/12 90/15
90/18 92/12 95/15
95/17 96/25 98/7
98/10 101/1 103/25
106/9 111/11 111/22
113/7 113/13 116/10
116/20 117/2 124/12
124/23 127/12 129/21
137/7 137/15 138/10
141/16 144/9 151/8
151/13 155/23 165/25)
166/17 167/13 174/25)
175/1 181/5 184/17
196/8
anybody [3] 55/3
141/9 152/23
anyone [1] 128/13
anything [15] 37/2
48/19 49/6 52/21
67/17 68/18 77/17
84/14 98/3 121/7
125/5 127/7 161/16
173/3 173/6
anyway [4] 52/10
86/7 99/2 111/11
apart [1] 49/6
Apologies [1] 142/25
apologise [3] 16/5
161/3 161/6
apology [1] 160/22
apparent [1] 153/25
apparently [2]
159/19 186/13
Appeal [1] 86/15
appealed [2] 7/5 7/7
appeals [1] 56/5
(62) achieved... - appeals
A
appear [5] 6/21 41/6
68/17 148/18 166/18
appeared [1] 77/2
appears [4] 71/6
71/16 123/17 137/22
application [1] 188/8
applied [2] 23/3
417/17
applies [1] 46/23
apply [3] 10/4 10/18
10/19
applying [1] 13/3
appointed [3] 3/2
7/17 57/23
appointment [2]
115/6 124/12
apportioned [1]
44/12
appreciate [3] 129/2
134/1 146/4
approach [14] 7/9
20/16 53/2 85/9
103/21 104/2 104/4
104/10 111/7 111/21
117/24 122/17 127/22)
192/18
approached [3]
114/20 146/2 147/4
approaches [1]
136/1
approaching [1] 90/3
appropriate [10] 5/12)
17/12 21/2 23/9 23/24
45/17 104/10 134/13
153/15 165/25
approval [2] 124/14
166/4
approve [2] 155/12
165/23
April [14] 19/13
29/19 31/1 32/1 32/2
66/16 82/18 91/7
100/2 130/1 131/21
131/23 157/11 179/14
April '14 [1] 32/2
aptitude [1] 120/17
arbitrate [1] 27/25
arbitrates [1] 27/24
Arbuthnot [8] 82/19
158/18 160/6 160/8
160/16 194/11 194/17)
195/23
Arbuthnot's [1]
193/21
ARC [2] 81/19 81/20
Arch [1] 54/23
are [118] 2/12 2/15
3/19 7/2 10/15 10/15
12/16 18/14 21/18
25/4 27/14 27/18
28/23 29/23 33/14
33/19 34/24 36/7 37/3
38/9 39/5 39/12 39/17
40/2 43/11 47/13
49/18 49/21 49/23
52/9 52/16 53/5 55/14
57/18 62/23 63/18
63/23 65/20 66/5
66/25 67/5 68/15 70/5)
71/11 73/14 74/14
75/25 79/1 79/4 79/24
82/12 84/2 86/5 87/12
88/1 89/2 89/3 89/8
90/2 91/25 92/4 93/5
93/8 96/23 97/17 99/7,
99/8 100/5 100/10
101/4 105/12 111/24
114/14 117/12 120/18)
121/12 121/16 127/3
131/3 132/19 133/1
133/1 134/7 141/1
145/23 148/3 148/22
151/21 158/7 160/2
160/3 160/11 160/16
161/6 162/7 164/14
164/18 166/13 166/16)
169/8 170/24 174/5
179/17 181/22 181/24)
182/17 183/5 183/25
188/11 192/10 194/10)
194/11 194/14 194/19)
194/24 196/19 197/18)
199/13
area [1] 79/5
areas [5] 16/12 49/9
117/16 117/18 117/24)
aren't [5] 57/16 173/1
181/25 191/19 195/13)
arena [1] 52/22
argued [1] 75/16
argument [2] 114/10
127/13
arguments [4]
113/11 114/8 114/9
114/9
arisen [1] 68/19
arises [1] 179/9
arising [2] 75/17
7T7MN3
arm's [10] 24/1 24/25
79/11 79/17 80/4 84/8
85/16 85/20 97/11
97/16
arm's-length [5] 24/1
84/8 85/16 97/11
97/16
armed [1] 139/7
arms [5] 79/11 79/12
79/13 85/23 86/1
arose [1] 21/5
around [44] 7/4 8/8
9/6 9/8 9/9 13/9 15/21
19/10 27/17 36/18
36/20 42/1 43/23
46/17 48/16 51/5
59/12 63/4 65/25 66/1
66/11 67/4 68/1 70/21
73/6 73/23 74/1 91/7
94/8 101/8 103/13
107/1 122/21 127/4
145/7 148/2 151/19
154/17 155/15 156/19}
161/9 161/24 168/3
188/18
arrangements [2]
161/24 162/2
arrived [2] 50/4
78/19
Arthur [2] 2/19
184/22
Arthur Andersen [1]
184/22
article [1] 174/15
articles [1] 49/22
articulated [3] 24/13
156/23 157/1
as [245]
aside [2] 9/19 160/20
ask [41] 1/11 6/17
9/5 10/6 28/1 31/11
33/19 34/10 37/20
46/21 49/15 57/14
57/15 68/12 68/13
80/2 81/16 101/5
101/6 114/3 115/11
115/25 116/1 117/21
118/25 120/23 123/3
123/20 124/19 136/15}
169/7 170/6 172/21
173/21 175/10 177/19]
179/9 182/16 184/9
186/11 189/2
asked [15] 6/19 7/4
9/11 22/3 33/9 33/10
98/8 110/5 110/22
128/3 148/2 151/12
155/1 177/15 184/10
asking [30] 3/15 8/23
9/1 36/10 37/22 38/25
39/5 56/15 96/25
100/4 120/24 123/2
123/2 123/7 124/20
124/25 125/3 133/9
138/5 140/3 155/9
172/11 172/13 172/13}
172/25 174/12 177/4
192/15 192/17 193/4
asks [2] 34/18 47/10
assertion [1] 182/11
assertions [1]
155/21
assess [1] 62/8
assessed [1] 62/4
assessing [2] 67/22
75/14
assessment [8]
61/22 61/23 70/17
72/13 83/10 97/1
138/5 163/23
asset [4] 61/19
166/10 166/15 187/22
asset's [6] 164/19
165/1 165/11 166/6
166/11 166/18
assets [8] 61/15
126/9 136/7 136/8
137/19 165/15 166/1
166/3
assist [1] 165/11
assistant [2] 53/9
133/18
associated [2] 75/14
181/5
association [1] 49/22)
assume [1] 154/8
assumption [1]
29/24
assurance [16] 29/7
57/20 81/20 90/2
147/10 147/15 147/17
147/19 147/21 148/5
148/16 148/17 149/7
154/6 154/11 154/23
assure [1] 166/10
at [233]
at page 21 [1] 123/10
at page 3 [1] 45/19
attached [3] 29/22
112/24 123/15
attachment [4]
112/10 112/10 112/11
114/5
attempt [1] 109/1
attempted [2] 172/16
172/18
attempting [2]
127/13 192/11
attempts [3] 160/1
171/14 175/8
attendance [2] 139/2
179/13
attended [2] 179/18
184/1
attendees [1] 179/17
attending [2] 22/20
47/20
attention [5] 48/20
48/21 72/15 72/19
189/11
attitude [3] 88/23
97/15 162/3
attribute [1] 55/12
August [11] 100/21
100/22 101/8 101/11
123/16 133/17 138/16}
140/18 142/12 143/20}
180/5
August '14 [1]
143/20
August '15 [1] 101/8
Aujard [1] 179/19
auspices [1] 156/8
austerity [1] 124/12
author [1] 148/24
Authority [3] 163/19
164/24 165/8
authors [1] 166/18
Avene [1] 133/21
avoid [1] 145/20
award [1] 163/12
aware [20] 6/16 31/4
53/18 55/18 58/5
62/16 84/5 90/12
90/16 115/5 134/2
135/3 141/15 159/20
164/3 165/23 180/9
180/15 180/19 187/21
away [14] 13/5 53/11
80/14 110/15 118/14
127/1 131/2 142/3
143/9 143/10 151/19
160/23 171/6 172/10
awful [2] 177/19
177/19
awry [1] 9/15
B
back [36] 16/1 19/9
19/22 25/11 26/17
28/5 28/22 31/1 34/11
36/3 46/7 50/22 63/25
64/5 65/12 66/2 76/19I
84/1 86/13 87/1 88/6
95/5 103/14 118/15
127/4 127/12 128/12
134/1 138/23 141/1
147/7 151/25 160/13
165/18 167/18 191/6
background [4] 2/17
147/24 187/21 197/10)
backing [1] 39/3
badge [1] 163/11
badly [3] 97/24 118/4
121/25
bag [1] 160/21
balance [13] 23/9
23/24 24/3 24/23
24/25 25/6 41/11
41/11 107/16 108/5
117/10 117/12 153/15)
balancing [1] 98/11
bandwidth [1]
119/23
Bank [2] 4/16 100/24
bar [1] 154/8
Baroness [22] 28/16
82/16 82/18 85/2
100/15 100/22 101/6
101/10 104/21 105/7
106/16 107/7 134/3
134/23 135/17 137/21
138/21 139/1 139/8
139/9 190/19 191/15
Barrow [1] 45/4
base [1] 120/20
based [7] 3/19 80/8
101/17 132/24 156/4
156/5 193/4
(53) appear - based
B
basic [1] 175/12
basically [3] 109/4
111/5 126/24
basis [18] 57/7 61/21
66/12 67/11 68/20
113/20 113/24 132/21
132/22 155/3 155/12
180/7 180/13 180/16
181/1 183/3 183/23
186/13
bat [1] 13/18
Bates [9] 29/24 31/1
32/4 131/22 160/7
160/10 160/16 195/11
195/24
Bates' [1] 31/6
Batten [5] 29/13
29/14 40/9 44/6
130/10
Batten's [1] 68/8
battles [1] 44/24
Baugh [2] 192/6
192/7
be [240]
bear [4] 171/17
bears [1] 147/1
became [3] 77/17
85/16 184/24
because [168] 4/7
4/13 7/5 8/4 8/10 9/7
10/25 11/1 11/20
14/15 15/15 15/25
16/9 17/10 18/17
19/16 20/3 20/19 21/7)
22/5 22/12 22/13 23/3
24/4 24/7 25/1 25/7
25/21 26/24 27/8
27/13 28/25 30/25
31/8 31/11 31/24
33/19 33/24 33/24
34/10 34/22 36/16
38/2 38/7 38/20 41/1
41/4 41/18 43/3 43/9
44/1 45/3 48/15 51/17)
55/14 56/3 57/5 62/24,
63/3 63/7 64/16 65/16
65/20 67/24 68/15
69/25 70/25 71/11
72/6 75/14 75/19
75/22 78/7 80/6 80/16)
81/2 81/14 83/22
88/13 88/16 88/18
89/23 89/25 91/22
93/19 94/13 97/7
97/18 98/3 101/16
102/4 104/12 105/11
105/20 106/6 106/18
107/12 109/4 109/23
110/19 110/23 111/25
112/10 114/1 116/22
116/24 118/8 118/24
121/24 122/15 125/6
126/5 126/9 127/8
127/16 129/5 131/17
133/5 133/8 133/9
134/16 135/14 136/19)
138/1 138/8 139/4
140/6 140/12 140/21
140/25 143/8 143/16
145/12 148/17 151/15)
154/8 155/15 157/20
162/18 167/8 168/24
171/11 172/3 172/14
172/17 172/18 173/2
173/3 173/8 173/19
174/13 174/25 178/18)
181/19 182/1 184/15
187/2 188/7 188/18
189/16 191/23 194/5
194/13 194/21 195/7
195/10 195/22 198/20)
Becky [1] 45/4
becomes [1] 84/8
becoming [1] 187/18
bed [2] 83/13 83/17
beefing [1] 34/6
been [153] 4/3 4/7
7/6 TINT 7/17 9/3 11/8)
16/20 16/20 19/5
26/12 40/13 40/23
41/16 41/22 42/4 42/8)
43/16 43/19 44/18
44/19 45/6 50/18 51/3
51/20 52/1 52/2 52/4
54/10 55/11 56/17
56/19 56/20 57/17
57/21 58/1 58/11
58/12 61/9 66/10
66/16 66/23 71/20
73/7 73/18 74/2 TAIT
74/19 74/20 80/7 80/8)
80/9 81/18 83/22 86/4
86/4 89/11 91/9 92/5
94/16 96/13 97/5 97/9
98/5 98/15 98/23
101/11 102/10 104/25)
105/11 105/18 109/9
110/8 112/3 112/18
112/20 115/8 116/12
116/13 116/14 117/9
118/3 118/10 118/10
119/18 120/1 123/13
123/15 123/18 124/4
124/5 131/2 131/18
143/6 143/8 143/13
145/8 146/15 149/13
149/22 149/24 150/6
150/17 150/20 154/9
154/10 154/14 155/8
155/16 155/22 155/23)
156/9 156/11 157/19
162/15 162/21 163/6
167/4 167/25 168/11
168/19 168/23 171/14)
171/18 171/18 172/16)
172/18 174/14 174/19)
175/7 177/7 177/16
187/8 188/4 188/14
188/23 189/8 189/19
189/24 190/9 192/13
193/22 195/14 195/24
196/6 196/7 196/8
197/9 197/22 198/9
BEER [6] 1/9 1/10
75/25 177/15 199/9
200/3
befits [1] 192/25
before [39] 6/8 26/12
32/7 35/10 56/20
57/17 57/21 74/5
76/11 77/2 81/10
90/22 101/2 110/25
111/25 115/20 116/6
116/11 116/21 117/21
127/2 127/15 127/25
130/23 134/9 135/10
136/17 159/17 160/4
166/18 171/15 172/14
177/2 179/16 184/24
189/12 190/24 191/18I
191/24
began [1] 143/20
beginning [1] 46/7
begins [1] 193/16
behalf [4] 1/11
125/20 126/3 152/12
behind [2] 99/7
162/14
being [64] 5/4 7/24
8/6 8/16 8/16 9/20
10/2 11/9 15/23 15/24
16/9 16/10 19/8 27/21
46/18 50/3 50/5 50/7
50/8 50/11 55/13 58/7
60/21 62/18 64/14
65/23 69/5 72/13
75/25 76/23 81/14
86/1 93/10 96/3
100/24 102/12 110/22
113/16 114/9 129/3
134/2 150/12 150/13
153/25 154/12 159/4
162/9 165/15 167/16
176/25 177/14 177/21
177/24 178/2 178/14
182/23 186/5 186/13
187/11 187/14 187/16
189/13 189/23 193/25)
BEIS [4] 87/11 90/5
93/5 93/12
belatedly [1] 164/4
belief [1] 2/14
believe [5] 19/4
138/13 157/17 163/5
190/3
Belinda [7] 29/13
29/19 29/21 31/11
32/9 35/16 179/20
below [8] 47/7 75/23
178/15 178/22 186/10
103/21 130/10 137/16
139/25 164/14 191/13}
benchmarked [2]
187/1 187/17
beneficial [1] 35/9
benefits [2] 22/4 30/6
56/20 56/21 57/17
57/21 58/2 58/18
58/25 59/9 59/9 59/12)
59/15 59/16 60/12
60/17 81/18 87/6
90/24 96/1 98/9 99/4
best [14] 2/13 31/13
31/15 35/4 79/19
80/12 108/3 111/24
102/21 103/1 103/12
114/14 1145/1 115/15
117/9 117/15 118/20
126/11 127/14 132/20)
132/24 135/21 137/20}
119/17 119/18 119/23)
better [10] 9/24
12/19 40/12 89/24
119/10 125/9 130/13
133/8 151/14 151/17
between [25] 4/8
12/2 24/3 24/25 29/9
31/3 36/15 53/3 56/9
77/4 91/24 94/10
102/2 111/8 123/11
123/19 150/7 157/1
162/8 173/5 174/10
175/1 178/23 191/17
191/25
beyond [3] 63/8
64/19 154/7
big [5] 13/7 97/1
115/17 120/18 170/18}
bigger [4] 74/13
74/18 78/3 95/12
biggest [2] 46/17
158/12
BIS [5] 47/14 90/10
140/19 141/11 145/10}
BISCom [2] 39/17
79/2
bit [28] 2/5 6/3 8/4
16/22 28/1 35/10
43/20 44/8 46/3 47/17
48/23 48/25 56/1
64/19 66/11 68/1 80/9
88/25 94/15 104/11
105/12 107/22 129/25}
134/20 145/9 157/22
158/9 158/13
bits [3] 65/20 126/8
157/20
blame [3] 44/12
145/23 146/17
blind [1] 177/21
blobs [1] 74/14
blue [1] 74/14
BNR [2] 134/25 135/7
board [117] 3/8 4/12
5/11 6/7 6/8 9/17 9/22,
10/2 10/4 12/1 12/4
12/10 13/2 13/5 14/6
14/25 15/12 15/16
15/18 16/6 16/10
16/13 16/15 16/23
17/3 17/11 17/17
17/23 19/21 20/20
21/3 21/6 21/15 22/20)
47/21 53/3 56/19
121/1 121/12 121/24
123/2 123/7 126/13
128/7 128/13 128/24
142/4 143/9 143/24
144/1 144/3 150/17
150/21 151/1 151/6
152/9 152/12 153/2
157/13 157/19 158/11
163/4 164/19 164/21
164/25 165/1 165/9
165/9 165/16 166/19
166/19 167/10 167/21
168/21 175/25 183/19
186/15 189/4 189/6
190/12 198/12 198/13)
198/13 198/14 199/4
Board's [10] 9/22
14/15 17/22 115/7
117/23 118/23 120/1
120/3 142/11 189/11
boards [3] 13/23
17/1 165/12
bodies [1] 24/1
body [6] 24/4 24/5
97/11 97/16 177/6
179/25
Bogerd [2] 77/2
179/19
bold [5] 180/2 180/7
182/3 182/10 184/7
bolt [1] 96/23
bolt-ones [1] 96/23
both [26] 16/15 30/15
36/9 48/15 56/24
57/12 61/9 70/3 70/18
75/5 82/5 82/8 87/19
88/25 113/17 113/17
115/21 134/19 134/21
135/19 139/12 139/16
141/12 164/25 176/4
191/20
bothering [1] 135/20
bottom [15] 1/17
1/18 25/8 29/12 39/7
47/18 57/6 63/1
105/14 105/23 120/20
127/9 129/24 165/7
173/25
bought [1] 58/6
Bourke [3] 35/17
171/1 193/12
box [3] 63/15 69/10
71/4
boxes [1] 70/7
(64) basic - boxes
B
branch [1] 104/1
branches [1] 11/3
brand [4] 72/4
break [9] 60/24 61/3
99/11 99/16 111/3
127/25 129/9 169/11
169/16
Brian [4] 58/12 58/14
62/19 73/1
brief [1] 163/20
briefed [5] 47/23
54/25 87/10 93/4
134/22
briefing [9] 100/10
100/15 101/2 123/14
128/6 129/20 139/7
157/13 172/17
briefings [2] 128/11
143/17
brilliant [2] 196/15
196/16
bring [9] 11/7 11/19
13/14 75/5 122/2
126/18 182/16 191/6
199/4
bringing [2] 9/21
9/22
brings [2] 88/17
199/8
broader [1] 176/23
broadly [3] 59/10
63/23 125/8
brought [8] 2/12
23/17 58/23 114/25
161/6 195/15 195/17
196/4
brush [1] 28/21
brush-off [1] 28/21
bucks [1] 120/18
bug [7] 41/5 41/23
43/4 43/15 53/23
161/14 173/5
bugs [13] 43/11
43/12 53/20 53/25
53/25 54/8 54/10
54/12 74/6 74/6 74/6
185/5 185/19
building [3] 40/16
40/18 145/13
built [1] 143/21
bullet [13] 116/22
116/24 117/8 119/14
121/2 164/16 165/6
166/7 166/12 190/23
191/9 191/13 192/3
bumped [1] 145/11
bundle [2] 56/13
66/25
business [42] 7/21
10/11 11/15 12/22
16/4 18/13 24/17
24/19 47/20 51/3 51/7,
51/8 51/9 51/21 51/22
52/9 53/1 53/6 53/14
53/15 71/23 73/6
73/10 73/10 73/22
79/18 80/11 80/18
81/8 86/25 105/2
105/19 117/18 117/24)
118/1 118/8 121/14
147/1 152/20 152/22
175/13 186/24
business's [2] 61/22
73/20
businesses [13]
10/24 46/18 48/3
48/13 49/19 50/15
50/25 52/4 52/12
52/19 52/25 53/14
152/21
but [223]
Cable [1] 114/23
cajole [1] 132/17
calibration [1]
166/20
call [6] 1/5 2/23 8/20
75/11 123/19 180/22
Callard [35] 1/5 1/8
1/10 1/13 8/22 17/3
25/20 51/10 61/8
85/18 88/20 97/15
99/21 100/10 110/17
124/19 125/16 128/7
129/19 145/18 169/7
170/2 170/10 171/9
172/21 173/10 174/1
174/11 174/20 177/3
178/25 183/24 195/5
199/11 200/2
called [2] 6/1 174/19
calling [1] 195/24
came [15] 23/9 23/24
25/11 42/25 53/9 54/5)
67/3 75/8 83/2 100/25
104/7 142/7 151/24
153/15 163/4
Cameron [2] 122/1
123/21
campaign [1] 162/14
can [167] 1/3 1/4
1/11 1/16 2/9 2/16
2/17 3/15 9/23 10/6
10/24 11/23 12/14
12/24 16/12 18/7
21/24 23/14 23/15
26/14 28/1 29/8 29/10
30/9 32/12 32/25
33/19 34/17 34/19
35/15 39/6 39/19 44/4
45/1 45/19 45/21 46/3
48/8 50/20 51/4 56/1
60/23 61/5 61/8 62/10
63/14 63/15 63/17
63/17 63/25 64/23
65/3 65/10 66/4 68/6
69/3 70/7 70/12 70/16
71/24 76/15 76/16
78/11 78/12 81/22
81/24 82/2 85/23
85/25 85/25 86/10
87/18 88/22 88/24
89/5 90/21 91/6 91/7
91/13 91/25 92/1 92/3
92/5 96/7 99/11 99/18
99/21 100/9 100/20
104/17 105/23 111/12
112/6 112/18 113/14
114/5 117/21 123/9
125/9 125/9 126/11
127/11 127/25 128/18}
129/1 129/16 129/17
129/23 130/10 131/13
133/6 133/14 134/10
138/14 138/18 139/14]
141/19 141/20 141/21
142/2 144/11 144/12
147/15 153/8 153/12
155/18 159/7 163/8
163/14 164/11 164/12
165/20 166/7 169/18
170/9 170/11 170/13
170/15 170/20 170/21
172/5 172/15 172/21
173/17 173/21 173/22
173/24 177/3 179/5
179/16 179/17 179/25)
182/16 183/8 187/18
189/2 189/9 190/15
191/8 191/11 193/3
193/4 193/8 193/10
193/14 194/14 196/10
can't [33] 8/12 9/3
11/2 36/23 45/2 45/5
45/18 47/3 52/6 54/4
57/15 59/21 59/21
59/23 60/1 60/5 92/13
93/20 126/15 128/17
128/20 128/25 136/14
141/7 149/4 150/25
153/1 155/6 155/8
157/13 178/16 182/18}
194/9
candidates [1]
151/14
cannon [1] 193/25
cannonballs [1]
194/1
cannot [3] 111/10
137/7 194/12
capability [2] 4/11
166/11
capable [3] 115/16
185/6 188/11
capacity [6] 4/10
20/11 20/24 21/24
22/19 132/2
car [1] 36/2
Card [2] 63/4 64/3
career [1] 188/11
carried [4] 48/2
167/5 167/15 168/13
carries [1] 46/19
carry [1] 146/15
carrying [1] 150/2
Cartwright [11]
27/17 58/11 58/14
58/20 62/18 73/2
73/21 156/11 163/1
177/12 199/2
case [33] 10/9 11/2
11/15 16/4 18/13
19/14 35/4 42/16
42/16 43/9 47/21 48/1
64/20 70/2 78/21
93/10 95/17 95/18
97/13 103/12 110/11
119/2 122/6 141/6
160/25 161/10 164/22,
171/23 172/25 173/3
174/23 181/15 185/10}
cases [19] 7/22 8/6
41/21 44/2 56/6 56/9
73/24 75/7 109/17
109/18 132/2 154/14
181/4 182/6 185/12
194/13 195/13 195/21
197/2
cash [5] 18/10 107/2
107/14 160/21 161/1
catch [5] 77/17
133/17 133/21 134/7
150/4
catch-all [1] 77/17
catch-up [3] 133/17
133/21 150/4
causality [2] 173/5
174/25
causation [1] 43/15
cause [3] 118/5
141/16 185/16
caused [7] 25/18
40/24 43/16 54/9
104/1 141/17 165/21
causes [1] 98/6
causing [5] 41/24
43/13 66/3 173/5
185/6
CCRC [2] 82/19
87/16
CCRC's [1] 83/7
CEDR [1] 82/21
cent [6] 4/14 4/15
4/16 4/19 187/1
187/15
centre [4] 67/15 84/7
84/24 89/4
CEO [26] 113/16
1415/1 115/7 115/16
115/21 116/6 116/11
117/5 119/5 120/2
120/7 122/18 126/11
142/1 142/6 144/5
146/21 147/1 147/12
149/12 150/7 150/11
150/15 150/18 152/19)
165/5
CEO's [1] 151/1
CEOs [1] 120/21
certain [6] 12/10
12/10 27/14 124/13
128/4 190/21
certainly [7] 6/2 55/9
74/1 86/23 99/13
174/21 176/16
cetera [20] 8/8 16/5
27/18 53/12 93/6
93/13 118/3 134/4
134/12 168/4 187/3
187/4 195/3 195/3
195/3 196/13 196/14
196/14 196/17 196/17)
CFO [21] 113/19
113/22 114/2 114/15
114/25 115/6 115/16
115/18 115/19 116/7
119/20 120/2 121/8
121/9 122/12 123/21
126/11 126/14 126/18)
143/11 145/10
chain [6] 18/11 32/14
36/22 129/1 136/25
196/11
chair [9] 30/16 49/24
82/9 82/16 114/22
121/19 150/2 150/18
150/19
Chair's [1] 158/19
Chairman [2] 78/3
83/6
Chairman's [3] 49/23
77/10 95/11
challenge [11] 5/12
5/19 6/13 6/23 7/9 8/3
121/6 163/13 165/2
165/25 166/9
challenged [4] 7/1
9/2 54/16 166/23
challenges [2] 5/24
114/16
challenging [3] 7/12
8/13 64/21
chance [2] 138/4
143/18
change [11] 18/16
38/13 68/2 91/22 96/6
98/4 114/1 114/3
121/15 122/5 122/15
changed [11] 65/16
76/19 77/9 78/9 78/23
80/17 98/3 98/16
98/20 117/13 157/21
changes [2] 19/2
49/12
character [1] 120/16
characterisation [1]
109/12
(55)
branch - characterisation
Cc
charge [4] 63/21
146/25 154/16 177/9
chartered [1] 2/18
chat [4] 133/24
134/12 159/11 160/3
check [2] 33/12
101/3
checking [1] 38/15
Cheers [1] 32/23
Chief [3] 123/4 148/3
179/18
choice [2] 14/23
85/19
choices [1] 131/17
Chris [6] 114/15
121/23 121/24 123/22)
126/17 179/19
circle [1] 71/4
circles [1] 71/8
circulate [1] 21/10
circulating [1]
170/14
circumstances [7]
17/17 22/15 78/24
83/9 108/17 109/10
194/6
cited [4] 74/19
civil [18] 12/19 20/18
21/4 21/13 22/25
24/21 54/14 81/5 81/5
86/15 86/22 87/5
102/16 102/20 132/19
155/25 188/4 189/10
claim [4] 90/25 94/4
94/25 96/8
claims [4] 32/25
86/21 95/20 193/21
Claire [5] 112/16
159/11 159/12 159/17)
159/17
clarification [1]
19/10
clarify [1] 100/20
Clarke [5] 55/18
55/21 55/25 56/4
56/10
Clarke's [1] 58/19
clash [1] 139/14
class [2] 82/20 174/4
clear [26] 8/10 18/1
18/24 34/12 34/12
34/17 34/23 39/19
44/16 114/14 124/17
125/23 126/5 128/13
137/1 153/17 157/1
161/14 161/22 162/1
162/8 178/19 185/15
190/12 191/19 198/20
clearer [1] 35/10
clearly [30] 5/4 6/2
12/20 18/14 20/3 26/9)
29/3 35/5 39/25 52/7
52/15 57/13 58/15
78/5 78/18 83/13
83/17 96/13 125/5
130/11 131/23 153/19)
160/19 178/6 178/12
183/20 190/13 191/2
191/14 193/22
click [1] 86/11
clients [1] 182/17
close [5] 36/15 36/15
38/7 192/9 192/18
close-minded [1]
192/18
closely [1] 31/6
closer [2] 94/19
182/16
closest [1] 52/1
closing [2] 22/4
49/10
closure [5] 36/19
36/20 37/15 128/9
161/22
closures [1] 49/11
Co [1] 179/8
coaching [2] 120/13
121/1
Coalition [1] 175/21
cocked [1] 102/5
Coe [2] 171/18
174/14
coherent [1] 53/1
cohort [3] 152/3
152/4 185/6
coincidental [1]
158/22
colleague [2] 91/21
196/18
colleagues [5] 136/8
137/19 165/17 171/9
174/10
colleagues’ [1] 123/5
colour [1] 41/25
column [22] 65/1
68/3 68/23 68/25 69/1
70/6 72/3 78/25 78/25)
80/22 82/6 82/15
83/24 83/25 86/14
87/3 87/19 87/25 92/6
92/13 92/15 93/3
columns [4] 78/8
82/2 91/25 92/3
combination [2]
79/22 186/7
combined [1] 143/11
come [28] 6/6 23/18
27/10 38/6 65/25 66/1
69/16 81/18 89/17
91/21 100/12 100/18
100/19 107/24 114/21
123/4 129/5 132/9
139/7 141/20 146/1
152/3 152/4 156/24
172/1 173/3 174/15
179/15
comes [5] 21/16
33/25 36/14 65/18
139/25
comfort [6] 58/13
59/4 59/9 59/14 59/15
195/2
comfortable [10]
13/15 15/20 15/21
15/23 15/25 16/9
16/10 47/15 59/11
85/5
comforted [1] 185/9
coming [12] 28/21
49/14 99/12 127/12
129/2 129/7 131/17
132/4 140/4 140/14
140/19 153/4
comment [3] 87/14
100/3 107/4
commercial [6] 10/9
10/19 10/22 10/24
11/2 11/5
commercially [1]
150/12
commission [1]
151/21
commissioned [2]
85/8 163/17
commissioning [1]
151/20
committed [1] 27/13
committee [17] 77/3
120/5 147/11 147/13
147/16 147/17 147/20
147/22 148/5 148/12
148/18 148/22 149/3
149/7 149/8 150/3
150/22
Committees [2]
84/16 148/16
commonplace [1]
92/18
comms [1] 45/15
communicate [3]
52/16 67/14 67/17
communications [2]
33/23 35/7
company [16] 5/13
7/10 10/4 10/5 10/20
10/22 12/17 12/19
17/24 18/5 18/6 49/25
103/3 103/8 114/16
115/13
company's [1] 35/4
compared [1] 91/23
compensated [1]
TAIT
compensation [8]
86/21 104/21 104/24
105/1 105/4 106/3
106/22 161/18
competing [1] 156/1
competition [1]
163/12
competitive [1] 119/83)
complaining [1]
185/19
Complaint [2] 180/4
180/24
complaints [3] 180/6
180/13 188/13
complete [4] 87/17
123/12 129/5 178/23
completed [4] 82/21
83/8 83/11 172/4
completion [1] 61/20
complexion [1] 26/8
comprehensive [6]
28/10 28/17 28/20
29/5 58/1 156/22
compromise [1]
108/15
compromised [1]
190/4
concern [13] 16/23
17/14 115/7 117/23
121/12 140/7 141/16
141/18 141/19 152/7
153/20 176/19 177/1
concerned [14] 8/24
38/9 97/16 100/11
100/17 100/25 161/12}
162/25 171/13 176/15)
176/16 181/18 183/25
197/14
concerning [2]
115/12 144/13
concerns [22] 4/10
19/13 32/6 108/23
115/1 116/10 116/20
125/24 126/22 137/6
140/11 141/20 141/25)
142/2 142/11 142/21
143/3 143/13 144/20
147/11 153/25 177/14}
conciliatory [1] 40/2
conclude [1] 184/11
conclusion [7] 28/8
41/24 82/19 83/8
109/21 137/8 172/19
concrete [2] 36/8
152/9
conduct [1] 77/13
conducted [1] 42/13
conducting [1]
128/14
confidence [4] 43/22
121/17 193/20 194/16}
confident [3] 47/15
94/4 115/16
confidential [4]
115/24 194/3 194/5
194/14
confidentiality [1]
193/23
confidently [1] 66/23
confirm [2] 150/15
172/25
confirmed [2] 150/23
172/12
conflated [2] 69/25
88/2
conflict [15] 11/25
12/9 12/14 13/1 13/2
14/5 14/8 15/10 16/13)
16/14 16/25 17/4 17/4)
111/7 183/10
conflicted [1] 136/9
conflicts [1] 11/23
confusion [2] 66/3
191/14
conglomerate [1]
152/20
conjoined [1] 187/22
connected [1] 62/16
conscious [2] 12/7
12/23
consensus [2] 144/1
149/22
consent [1] 19/25
consequence [1]
95/13
consequences [1]
52/17
consider [14] 10/7
20/22 28/5 67/16
104/9 134/13 147/23
149/5 149/11 158/11
166/15 182/7 186/19
197/18
consideration [5]
165/10 183/19 183/20)
183/21 197/15
considerations [2]
156/2 178/6
considered [6] 4/19
16/13 21/13 108/16
157/19 167/4
considering [1]
148/22
consist [1] 151/2
consisted [1] 106/19
consistent [1]
192/20
consistently [1]
162/6
consolidation [1]
165/1
constant [2] 24/24
49/8
constantly [3] 49/14
132/19 194/25
constituency [3]
36/18 36/21 49/11
constitutional [1]
49/23
constrain [1] 37/20
constrained [1] 17/7
constructive [1] 5/19
consultants [1]
151/22
contact [1] 192/9
(56) charge - contact
Cc
contacts [2] 125/20
126/2
contained [1] 58/3
containment [2]
190/7 190/9
contains [1] 30/14
contemplated [1]
86/1
contemporaneous
[2] 70/17 142/11
content [4] 18/12
21/19 47/4 136/15
contention [1]
188/21
contentious [1]
52/22
contents [3] 2/13
56/18 124/17
context [19] 15/5
30/22 33/4 33/5 33/6
36/13 45/1 45/9 55/23
56/5 62/13 64/17
76/25 78/4 84/13
89/21 113/14 115/6
123/12
continually [1] 8/19
continuation [2]
111/2 161/23
continue [11] 44/15
52/25 61/5 83/20
86/18 87/5 103/15
129/19 150/4 152/6
155/20
continued [6] 8/17
104/7 147/11 149/12
152/13 156/17
continues [2] 86/24
124/10
contract [4] 68/13
144/21 159/21 163/13
contracts [1] 55/11
contrary [3] 125/21
126/3 157/6
contributed [1]
158/16
contributing [1]
87/12
controversial [2]
109/10 109/20
controversially [1]
109/21
conversation [7]
116/15 140/2 145/10
145/15 151/4 171/8
174/10
conversations [1]
152/15
convey [1] 173/8
conveyed [1] 21/12
convict [1] 154/13
convicted [1] 154/7
conviction [1] 177/23}
convictions [7] 71/19)
72/25 95/14 96/11
156/14 162/16 170/4
convicts [1] 154/10
convince [1] 123/20
convinced [1] 171/22
Cooper [4] 91/8
167/18 167/19 169/3
cooperative [1] 96/3
copied [2] 29/13
90/15
copies [2] 59/18 60/3
copy [6] 50/16 58/19
108/8 109/24 110/1
133/19
core [2] 5/11 169/8
Corfield [3] 32/14
33/25 170/14
corner [1] 62/24
Corporate [1] 50/21
correct [26] 2/8 2/21
2/25 3/4 3/7 3/11 3/14
3/25 4/9 12/13 20/14
23/8 23/24 71/15
72/23 76/21 91/4
103/9 128/20 144/19
146/7 152/1 153/15
159/1 174/17 191/7
corrected [3] 54/10
142/22 142/25
correction [2] 1/23
212
correctly [2] 151/24
198/6
correspondence [6]
38/19 79/5 80/1 80/19)
84/15 88/18
cost [10] 86/24
106/19 107/2 107/13
117/17 119/11 122/23)
145/9 145/17 183/23
costing [1] 146/23
costs [4] 10/17 93/8
183/21 183/23
could [52] 2/4 4/14
11/8 15/15 15/15
16/25 18/18 20/2
22/17 24/21 25/2
30/11 32/22 35/9 37/8
39/23 40/16 50/1
62/20 66/22 71/22
93/10 101/11 104/13
104/15 111/21 113/6
121/25 124/21 124/23)
125/1 126/18 134/2
153/24 157/2 162/20
165/12 167/18 168/2
170/8 170/12 173/22
176/6 177/16 177/25
184/11 185/4 185/5
185/16 193/9 193/23
195/14
couldn't [6] 7/5 21/1
21/18 27/24 121/24
162/18
Counsel [3] 165/3
165/5 168/9
count [2] 193/2 193/3I
countenancing [1]
14/3
counters [1] 72/8
country [1] 176/25
couple [3] 36/2 77/1
142/8
course [26] 5/3 11/11
13/9 17/22 20/1 20/4
27/11 41/19 56/23
60/25 72/21 85/13
90/4 91/11 95/20
97/24 115/10 126/19
150/5 161/4 161/7
161/7 193/3 194/21
196/2 199/13
court [15] 26/24
27/12 27/20 27/20
27/22 86/15 87/15
88/13 88/14 153/18
154/10 154/19 154/25)
155/4 155/12
courts [5] 86/22
88/19 97/10 154/7
154/11
cover [1] 160/4
covering [3] 112/9
114/7 124/16
create [3] 46/20
48/20 109/23
created [4] 43/4
65/11 67/5 95/9
creates [1] 41/5
credibility [1] 55/19
credulous [1] 42/25
creep [1] 69/24
crescendo [1]
152/16
criminal [9] 56/5
62/17 72/25 86/22
95/14 96/10 154/2
154/4 162/15
critical [1] 175/13
criticised [2] 102/12
182/21
criticism [9] 81/7
84/19 102/18 110/15
145/20 145/23 146/6
146/16 146/17
criticisms [1] 137/15
cross [2] 120/21
136/2
crossed [1] 44/11
Crowe [5] 29/13
29/19 30/10 35/16
179/20
Crown [1] 48/18
crude [1] 12/18
crystallise [2] 116/18
118/23
crystallised [5]
118/14 118/23 142/3
143/10 151/19
crystallises [1] 144/1
cuff [3] 146/11
146/12 197/5
culminates [1]
151/12
culture [2] 11/6
53/15
curiosity [4] 28/23
28/25 57/1 184/10
curious [6] 26/9 29/3
29/3 57/4 57/8 177/17,
current [6] 68/3 84/8
85/15 114/15 149/12
150/10
currently [2] 1/20
150/12
cursor [1] 65/2
cursory [1] 72/12
customary [1] 34/14
cut [1] 56/24
cutting [1] 117/17
cynical [2] 190/6
192/17
D
daft [1] 158/13
damage [1] 117/4
damaged [1] 116/25
damaging [1] 127/1
danger [1] 176/10
dangerous [1]
116/23
dangers [1] 108/7
dark [2] 125/23
126/22
data [9] 32/25 68/20
71/21 74/10 186/11
192/19 193/1 193/5
198/11
date [14] 62/24 63/22
65/11 65/18 66/10
66/22 67/1 76/21
76/23 93/2 112/11
153/1 168/20 193/23
dated [3] 1/15 112/10
163/9
dates [2] 64/13
181/15
Davies [13] 32/16
32/16 45/4 133/20
134/5 134/11 136/12
170/25 172/25 173/24}
173/25 196/14 196/16
day [15] 13/5 49/4
113/23 113/24 114/15}
118/14 123/22 126/18}
127/1 134/1 142/3
143/9 143/10 151/19
199/13
Day's [1] 121/23
days [2] 147/9 153/3
deal [19] 9/9 32/11
67/21 67/21 70/2 70/4
73/22 79/19 80/2 81/6I
102/17 105/24 109/2
111/25 119/24 120/5
131/25 135/21 138/8
dealing [7] 5/24 24/2
63/20 81/21 99/8
148/23 188/9
dealt [10] 22/7 24/2
74/20 83/22 106/15
110/11 130/21 140/6
167/25 178/3
debacle [1] 190/25
debate [10] 35/21
36/6 36/20 37/1 38/7
88/18 156/21 165/14
194/11 194/24
debates [8] 28/13
36/14 38/4 38/5 38/9
84/16 110/9 156/22
December [6] 26/15
35/15 35/23 80/8
131/20 193/11
December '14 [1]
80/8
decent [1] 177/22
decide [3] 101/24
102/1 110/3
decided [2] 12/9
19/21
decision [7] 121/11
121/20 122/3 129/1
129/3 132/4 197/22
decisions [11] 13/3
19/11 21/15 107/16
131/5 132/9 154/1
154/4 161/11 166/20
183/22
decommissioning [4]
163/13 163/18
164/24 165/8
deep [1] 148/2
deeply [1] 59/3
defective [1] 54/20
defects [2] 53/20
185/19
defence [1] 54/21
defend [1] 86/25
defendant [1] 155/14
deference [2] 28/6
28/19
deficit [1] 22/5
defined [1] 22/4
definitely [3] 32/3
37/18 143/7
deflect [2] 137/12
137/23
degree [4] 29/7 48/14I
56/25 154/11
deliberately [2]
125/23 126/21
deliver [5] 44/19 45/7
47/15 102/24 119/11
delivery [2] 47/13
(7) contacts - delivery
D
delivery... [1] 150/10
Deloitte [9] 26/3
157/5 158/9 158/23
159/1 163/2 184/22
189/25 192/22
Deloittes [1] 8/8
demonstrate [1] 18/7
den [2] 77/2 179/19
Department [8]
11/21 13/11 13/12
13/18 16/1 140/5
145/11 145/16
Departmental [2]
125/19 126/2
departure [1] 90/24
depended [2] 45/15
189/15
depending [2] 88/23
101/7
depends [8] 30/21
30/22 38/12 38/20
49/25 188/16 189/12
189/13
depth [1] 147/23
derision [1] 190/22
described [6] 17/19
48/10 77/8 77/11 78/3
163/11
describes [2] 128/21
145/19
describing [1] 14/15
description [1] 45/5
deserve [1] 96/12
designed [1] 124/16
designs [1] 178/20
desire [2] 24/5 85/24
desktop [2] 151/12
151/22
destabilising [1]
116/23
destroyed [1] 162/15
detail [7] 21/14 26/3
58/3 87/15 119/10
151/11 170/17
detailed [4] 46/22
134/24 156/19 199/12)
details [1] 194/4
deteriorated [1] 77/5
determine [1] 181/3
develop [3] 5/25 53/1
165/11
diagram [1] 35/6
dialogue [2] 52/14
53/2
did [113] 4/10 5/1
5/10 5/15 5/22 6/16
9/16 10/1 10/7 10/16
10/16 16/2 17/3 17/7
17/13 18/4 19/4 20/16
20/22 21/16 23/10
31/16 38/10 38/22
40/6 41/13 41/25 42/2
45/12 48/5 48/9 48/12
48/25 57/9 57/10
58/21 59/18 60/3
69/20 70/17 73/15
81/16 83/15 85/7
90/16 90/18 97/12
101/13 102/19 103/10)
104/4 108/3 111/21
122/6 122/8 124/14
128/10 128/15 128/21
130/18 130/25 131/13)
132/6 132/14 134/13
135/3 135/6 136/9
136/12 136/18 138/10)
138/10 139/1 139/4
140/13 141/4 141/16
141/18 145/5 148/5
148/9 148/11 148/15
149/2 150/24 151/7
152/6 154/14 154/19
154/23 154/24 157/14)
159/23 168/7 171/17
171/17 176/21 177/19)
183/3 185/3 185/8
185/22 185/22 186/11
186/17 188/2 188/5
189/6 190/15 191/11
192/2 198/6 198/20
didn't [75] 6/10 8/12
8/15 11/9 15/10 15/21
15/23 21/25 22/15
25/2 29/1 31/8 31/23
50/9 54/11 56/4 57/5
57/10 59/13 59/16
60/16 61/21 67/6
75/21 75/22 76/2
81/20 83/13 85/7
96/11 97/6 97/7 98/3
98/4 98/17 98/19
107/8 116/7 116/15
117/1 122/3 126/14
132/7 136/15 138/13
140/10 140/21 154/17)
154/21 156/25 157/14)
158/8 158/10 158/13
158/24 159/4 160/19
182/3 182/9 182/13
184/5 184/12 185/13
186/19 186/21 187/9
187/16 191/24 192/1
192/10 193/2 194/7
195/5 197/8 197/8
died [1] 88/19
difference [2] 191/17
191/24
different [30] 10/3
10/22 20/23 26/8
44/22 48/13 49/5 56/9
63/19 63/20 76/18
80/21 85/4 88/22
89/18 95/6 133/4
133/14 133/15 141/19)
144/19 152/21 154/2
154/4 154/4 158/5
158/7 158/22 158/25
171/15
ifferently [1] 77/22
difficult [31] 23/8
23/23 24/7 24/8 24/10
24/22 25/6 25/19
57/13 68/14 103/11
109/8 110/8 110/17
114/2 115/15 121/18
125/6 126/8 129/2
131/5 131/17 132/4
132/9 143/16 152/19
153/14 153/23 155/24
161/17 191/6
difficulties [1] 114/25]
iculty [3] 61/11
94/12 118/5
digital [1] 64/2
lomatic [1] 134/21
direct [3] 43/5 47/9
164/19
directed [1] 50/15
direction [4] 7/10
13/10 16/4 137/6
directly [12] 7/1 8/3
8/13 37/22 58/15 74/6
87/6 138/2 138/4
153/18 165/3 165/5
director [18] 3/3 3/12
3/17 3/23 4/12 5/8
5/15 6/11 12/16 19/4
45/24 46/1 46/1 53/10)
118/16 149/25 179/21
183/24
Directors [3] 5/20
10/2 190/13
disagree [1] 72/14
disbanded [1] 195/21
believing [1] 43/1
disclose [2] 160/24
162/3
discloses [1] 162/5
disclosing [1] 17/7
disclosure [3] 17/9
56/4 93/13
discomfort [1] 16/22
disconnect [1]
178/23
discover [1] 57/9
covered [1] 26/7
discuss [8] 11/25
49/9 128/15 130/12
134/8 147/13 165/2
193/16
discussed [10] 12/12
19/20 60/21 133/7
134/19 134/20 143/4
143/6 143/7 189/6
discussion [14]
15/16 15/24 54/7 58/1
60/17 67/10 94/24
95/16 98/10 100/19
112/23 148/4 165/13
167/3
discussions [15]
12/4 15/11 15/13
15/14 15/21 16/2 16/7}
16/8 17/23 118/24
143/12 150/2 167/11
168/5 190/11
disengaged [1] 172/3)
dishonesty [2]
186/14 186/23
dismissed [1] 95/1
dismissive [1] 162/3
isplay [1] 136/23
displayed [1] 166/8
disproportionately
[3] 104/22 106/18
107/3
dissenting [1] 144/9
dissimilar [3] 136/1
136/7 136/8
dissuade [1] 108/20
distance [1] 79/6
distanced [2] 79/3
79/21
distant [2] 79/7 79/9
distinct [4] 87/7
inction [1] 102/2
distraction [1] 86/24
distressing [1] 24/15
distribution [1] 100/3
dive [1] 148/2
do [120] 1/19 6/19
7/14 10/11 10/16
11/18 11/18 13/2
13/17 15/18 18/17
18/17 19/22 21/2 21/8
23/5 24/6 24/10 24/17,
24/21 25/3 25/19
25/20 26/19 27/11
27/12 28/5 28/7 31/16)
32/19 34/9 34/10 36/4,
36/11 40/20 44/20
45/2 45/17 45/24
46/20 46/25 48/25
50/2 55/12 57/11
67/17 67/24 68/12
68/13 69/7 72/8 72/12
73/4 75/3 77/17 77/22,
79/16 81/10 81/15
96/25 98/2 100/13
102/14 104/9 104/13
105/16 107/15 108/3
110/10 110/23 113/12}
116/24 121/7 122/16
123/1 125/9 125/21
126/11 126/12 127/10}
127/22 128/3 131/12
133/8 136/8 137/18
137/18 137/18 137/19}
139/9 139/16 140/11
141/4 145/14 148/2
148/9 151/13 151/22
151/24 153/24 154/3
161/7 161/7 162/12
162/18 162/20 162/23
171/2 171/10 173/2
173/12 179/16 183/6
189/18 190/3 190/5
191/18 193/3 193/3
193/15
document [41] 49/19
50/5 51/12 51/20 52/3}
52/6 56/16 63/12
65/18 66/6 66/21
69/21 70/15 88/24
110/7 110/17 112/8
123/14 123/24 123/25)
124/1 124/15 141/20
142/24 157/9 163/14
163/17 167/9 170/7
173/21 179/12 179/12
180/1 180/2 180/22
180/23 182/24 184/3
189/3 193/8 196/5
documentation [2]
39/3 105/22
documents [10] 29/8
64/24 65/9 66/5 149/2
158/6 158/7 158/23
166/3 190/8
does [26] 6/10 11/18
26/9 27/2 32/19 34/18
40/4 40/21 64/9 68/21
70/11 72/2 78/2 84/17)
85/18 87/25 106/1
110/4 121/21 141/13
146/14 160/24 161/4
162/3 199/8 199/10
doesn't [20] 51/16
51/16 68/17 68/22
69/6 71/9 71/13 78/13}
79/15 88/25 110/5
111/7 145/18 146/13
160/22 162/10 176/18)
181/25 184/4 194/18
doing [19] 4/14 7/13
25/4 46/24 48/17 52/9
67/19 102/10 103/6
105/12 120/25 145/1
149/17 152/11 168/5
179/23 183/14 189/23}
197/6
Dollin [1] 192/8
don't [91] 6/3 6/5
6/15 6/21 10/14 10/21
14/7 15/20 15/24 17/6)
20/5 22/8 38/24 44/16)
45/14 50/7 50/11
50/17 50/17 51/8 51/9I
51/15 51/15 51/18
53/8 53/10 55/15 56/7
56/8 56/24 57/14 58/6
58/24 60/21 64/15
65/8 65/10 65/19
65/22 65/24 67/2 69/8
69/9 90/20 98/3
100/22 100/24 102/4
102/5 102/25 111/23
118/6 118/9 121/7
(58) delivery... - don't
D
don't... [37] 121/16
122/20 126/5 127/10
129/3 137/16 137/16
138/3 139/6 139/22
139/24 141/6 141/9
144/9 145/25 146/20
148/7 148/17 151/3
155/8 158/10 164/4
164/9 167/16 170/17
179/10 180/22 182/13
183/22 184/15 184/17
188/25 188/25 189/22)
190/2 193/18 198/24
done [29] 18/9 27/15
40/23 42/24 44/18
51/12 59/21 66/12
68/5 90/1 90/2 104/15
109/16 120/10 122/12
128/17 136/7 136/14
137/7 137/18 145/21
146/19 146/20 146/23
147/24 163/2 188/18
196/15 199/14
double [1] 117/3
doubt [7] 101/5 101/6
117/4 118/12 127/1
136/18 154/8
down [43] 13/10
13/14 21/16 28/1 28/3
44/8 45/20 46/7 46/15
47/8 50/21 50/23
62/20 63/15 64/25
67/20 84/1 87/1 88/6
88/19 89/25 99/24
114/12 120/6 121/9
128/6 135/23 139/24
141/21 144/11 149/9
159/8 164/13 165/6
166/12 167/24 168/20)
170/12 172/14 173/22
179/16 179/25 181/21
draft [9] 29/23 31/17
33/7 33/12 34/2 35/17
163/9 164/6 167/8
drafts [2] 30/19
105/15
draw [6] 27/12 28/8
29/7 102/2 109/1
172/19
drawing [1] 165/16
drawn [1] 39/21
drive [1] 36/2
driven [1] 137/8
dropdown [1] 69/10
dropped [2] 87/1
93/10
dropping [1] 154/16
duck's [1] 147/7
due [13] 27/11 72/4
80/8 81/7 82/21 86/3
94/7 101/10 102/18
115/9 128/5 150/9
160/1
during [11] 46/10
59/19 72/16 95/15
118/23 118/24 142/3
165/19 175/20 187/24)
199/13
duties [2] 19/4 56/23
duty [1] 56/25
E
each [20] 9/23 19/14
25/10 28/3 42/16 53/1
54/20 61/14 61/19
65/11 71/3 134/17
134/19 135/19 166/6
169/21 181/15 185/9
194/4 194/5
earlier [8] 28/22
95/11 114/20 142/16
148/11 161/11 168/18)
170/24
early [10] 5/10 26/15
58/5 117/1 117/3
143/17 143/20 147/9
153/3 168/7
easy [1] 26/22
edged [1] 117/3
Edwin [2] 171/18
174/13
Edwin Coe [1]
171/18
effect [5] 157/6 167/6
167/15 168/13 181/9
effective [3] 51/2
134/18 135/25
effectively [4] 10/7
75/24 111/21 121/16
efficient [1] 18/10
effort [1] 197/22
efforts [3] 13/8
117/14 120/15
eg [2] 124/17 130/16
eg the [1] 124/17
Egon [2] 151/21
152/17
eight [3] 62/13 63/8
89/10
either [23] 27/23
35/11 37/3 38/18
59/19 68/4 71/16
75/20 75/21 80/25
88/24 97/19 107/6
110/3 116/16 154/13
157/17 168/12 181/24)
185/15 197/15 198/7
198/21
Electronic [1] 190/14
element [2] 81/2
97/17
else [7] 27/23 32/18
104/12 128/13 140/3
140/4 141/7
elsewhere [2] 128/23
162/19
email [40] 21/10
29/13 35/16 39/8 39/9
39/24 44/5 46/4 46/8
48/23 94/18 99/25
103/18 104/17 104/17I
108/5 112/9 112/11
114/7 123/16 123/16
124/16 127/10 129/24
130/6 136/25 138/14
139/4 139/6 139/24
139/24 144/13 159/8
160/24 170/13 170/19}
173/18 190/16 194/18}
196/11
emailed [1] 90/10
emailing [2] 49/4
133/17
emails [5] 29/19
35/25 49/17 134/5
161/6
emanated [1] 51/20
emanating [1]
188/12
embarrassing [1]
105/20
emerging [4] 22/5
41/24 85/1 119/24
employed [1] 87/4
Employee [1] 188/10
empt [1] 34/21
encapsulating [1]
99/5
encountered [1]
61/10
encourage [1]
165/13
encouraging [1] 31/7
end [22] 19/12 25/5
43/17 63/5 64/5 82/17,
127/4 127/4 131/21
137/21 138/1 140/14
164/6 167/20 168/7
172/1 173/18 186/9
195/15 195/17 197/10
199/8
ended [3] 146/23
146/25 167/22
ending [1] 123/15
endorsement [2]
91/3 94/5
ends [1] 110/22
engage [1] 153/21
engaged [2] 54/15
170/24
engagement [4]
23/10 23/25 153/16
159/24
enormous [1] 120/12
enough [10] 19/15
25/21 26/9 29/3 32/19
34/17 37/23 92/15
117/1 195/12
enquiry [1] 162/22
ensure [13] 46/23
62/1 62/6 67/10 67/23
84/4 93/2 164/19
165/24 166/16 166/17}
167/2 167/3
ensuring [5] 52/20
136/20 139/7 165/1
165/4
entail [4] 61/21
entering [1] 73/6
entirely [6] 26/8
63/22 65/17 105/2
157/8 166/24
entirety [3] 8/18
68/17 118/19
entities [1] 10/24
entitled [2] 14/4
180/23
entity [2] 10/9 11/5
entrenched [1] 6/1
entries [1] 67/4
entry [3] 64/25 66/22
75/22
environment [1]
119/8
equate [1] 139/6
equated [1] 198/18
Er [1] 139/20
error [6] 44/20
106/21 107/14 185/14}
185/15 186/8
errors [4] 53/20
107/1 185/10 185/19
escaped [1] 189/11
especially [1] 165/15
essence [2] 80/20
108/11
essential [1] 169/2
essentially [28]
30/24 33/12 53/5 68/4I
68/10 70/1 75/4 89/22,
90/1 91/25 92/24 98/5
104/14 108/19 109/3
109/22 111/3 114/10
119/23 122/13 129/6
142/8 151/24 152/6
172/14 172/2 172/11
173/2
establish [1] 106/1
established [7] 7/16
81/9 105/9 180/5
180/12 180/16 181/1
establishing [1]
93/13
et [20] 8/8 16/5 27/18
53/12 93/6 93/13
118/3 134/4 134/12
168/4 187/3 187/4
195/3 195/3 195/3
196/13 196/14 196/14}
196/17 196/17
et cetera [19] 8/8
16/5 27/18 53/12 93/6}
93/13 118/3 134/4
134/12 168/4 187/3
187/4 195/3 195/3
196/13 196/14 196/14)
196/17 196/17
ete [1] 32/22
evaluate [1] 151/8
even [30] 5/7 9/14
28/2 43/10 50/14 52/3}
65/24 71/10 74/11
78/13 78/23 81/7 81/9
86/17 94/1 96/11
96/16 97/15 98/23
106/14 110/25 145/21
146/18 153/2 159/2
167/1 175/2 190/9
193/18 194/1
event [3] 30/4 106/9
144/1
eventually [1] 170/21
eventuating [1]
70/10
ever [21] 4/10 26/22
31/16 51/4 54/13
54/19 55/18 59/18
60/3 60/17 60/21
65/19 65/23 68/11
81/11 81/16 124/16
127/5 132/14 157/9
186/11
every [4] 26/19 49/4
49/5 178/3
everybody [6] 4/21
6/8 32/6 43/6 50/12
154/25
everybody's [2]
135/1 136/22
everyone [1] 161/4
everything [6] 46/19
48/19 50/6 84/19
88/19 143/11
evidence [25] 57/15
60/14 62/16 74/5
103/25 117/2 137/1
149/24 151/9 154/12
155/19 155/23 156/14)
161/19 171/5 172/10
173/4 174/23 174/25
175/2 181/8 182/20
186/11 189/18 189/23}
evident [3] 26/10
28/24 57/5
evidential [2] 155/3
155/12
evolution [1] 77/25
evolved [1] 94/10
evolving [1] 86/8
ex [1] 16/21
ex-ShEx [1] 16/21
exactly [6] 44/15
88/3 143/1 180/21
183/16 185/25
example [27] 11/3
12/4 17/21 18/7 18/8
18/10 19/24 20/8
28/16 30/4 32/21
(69) don't... - example
E
example... [16] 33/18
33/20 34/17 36/18
51/15 64/25 70/24
89/9 101/4 102/6
103/13 108/5 171/8
183/4 190/25 195/11
examples [9] 8/12
9/4 16/12 18/21 21/24
32/12 62/10 119/13
194/13
exchange [8] 30/23
47/24 48/10 108/6
144/13 144/18 154/16)
160/24
exchanges [2] 168/3
170/22
excluding [1] 1/14
ExCo [3] 99/4 149/8
189/13
excuse [1] 36/19
Exec [3] 3/2 11/20
11/20
executive [42] 2/22
3/12 3/17 3/23 4/11
4/17 5/7 5/13 5/15
5/19 6/11 6/23 7/1 9/2
9/6 12/16 16/16 18/25
19/20 29/15 46/19
118/16 119/1 125/7
126/8 126/9 126/12
133/18 140/16 148/3
149/8 149/25 162/13
164/21 166/23 175/25
179/18 179/21 183/19}
183/24 189/4 190/12
Executive's [2] 123/4
182/11
Executive/UKGI [1]
126/9
executives [3]
121/18 136/17 152/14}
exercise [2] 56/25
111/22
exercised [1] 111/11
exhaustively [1]
155/22
exhibit [1] 1/15
exist [4] 12/1 40/4
40/21 42/3
existed [4] 53/21
83/22 83/22 159/2
existence [4] 50/8
69/6 97/22 187/7
existential [1] 70/25
exit [5] 121/23 122/4
124/6 124/7 126/15
exiting [1] 113/22
expanding [1] 40/25
expect [10] 51/7 52/8
53/13 53/13 53/15
54/25 56/19 119/17
135/7 136/18
expectations [5]
13/15 15/7 52/3 56/23
84/6
expected [7] 51/22
56/17 90/24 91/2 94/4
150/14 153/24
expecting [1] 41/2
expects [2] 49/20
50/24
expedient [2] 36/3
113/5,
expensive [1] 152/4
experience [5] 3/24
5/1 5/5 120/14 175/7
experienced [1]
135/6
experiences [1]
24/14
expert [2] 54/14
55/20
expertise [1] 165/16
explain [15] 12/14
23/19 48/8 89/25
103/21 109/1 114/20
131/4 135/21 145/6
157/2 161/8 182/2
191/16 194/15
explained [7] 46/22
48/10 126/24 142/1
159/23 162/18 164/24)
explaining [2] 13/11
191/5
explains [1] 96/6
explanation [1] 189/9I
explicitly [1] 96/18
explore [2] 175/17
186/12
exposed [1] 111/4
express [3] 101/22
108/18 143/3
expressed [3] 108/13)
139/15 147/11
expressing [4]
131/23 161/25 188/11
193/1
expressly [1] 198/21
extension [1] 111/1
extent [15] 10/24
19/21 32/8 48/6 48/11
54/12 58/21 66/4
89/11 101/13 143/3
153/9 155/18 167/5
182/15
external [3] 87/4
166/14 166/15
externally [1] 62/18
extra [1] 11/14
extraordinarily [2]
186/18 186/19
extremely [1] 115/23
eye [2] 10/16 11/11
a
face [3] 127/15
127/15 166/2
faced [1] 165/15
faces [1] 114/17
facilitate [1] 37/1
facing [1] 56/3
fact [41] 8/14 10/5
11/12 18/24 33/4 42/3
57/8 57/10 59/15
61/22 65/24 72/1 74/8
78/7 89/9 94/7 95/14
104/25 105/9 117/25
124/17 127/9 130/20
136/23 137/4 139/1
141/4 145/15 154/7
154/20 156/5 156/8
178/8 181/1 182/21
183/17 187/8 190/8
195/14 197/9 197/16
factor [1] 164/23
factors [2] 79/22
175/11
facts [2] 101/17
102/5
factually [2] 37/4
101/4
fail [3] 90/25 94/4
176/21
failed [6] 102/24
117/14 145/16 171/15}
175/7 178/4
failing [2] 72/7
137/23
failings [1] 165/21
failure [3] 124/7
128/6 178/8
failures [6] 54/6 73/9
73/19 181/12 181/19
185/3
fair [5] 37/23 74/25
77/5 77/6 122/17
fairly [1] 27/2
Falkirk [2] 53/23 54/1
fall [1] 21/25
fallback [2] 84/7
85/15
fallout [3] 55/22 70/2
196/8
false [3] 154/15
180/18 180/20
familiar [1] 196/11
far [11] 13/7 36/5
40/12 56/3 59/8 68/2
82/15 86/5 142/2
161/12 162/24
fatalistic [2] 26/25
27/3
fault [6] 103/25
110/14 146/24 150/15}
155/1 157/1
faults [2] 175/1
180/17
February [29] 39/18
43/18 46/8 58/2 62/12
63/7 63/8 63/14 63/20
63/24 64/17 65/3 66/7
66/14 66/17 67/4 73/7,
76/15 76/22 76/22
76/25 77/3 78/17
78/20 79/3 81/23
116/13 186/16 198/13}
February '14 [1]
63/20
February '15 [1]
76/22
feed [2] 89/4 148/11
feel [11] 8/15 10/12
15/21 15/23 17/7
40/16 45/12 89/17
128/6 156/25 161/17
feeling [4] 15/15 31/2
43/23 89/7
feels [7] 20/5 30/5
32/4 40/1 115/9
157/15 159/20
feet [1] 115/20
felt [37] 7/16 8/3 8/13
9/13 15/7 15/8 15/20
15/24 17/12 18/11
21/1 21/2 21/7 21/18
23/6 27/24 31/8 43/25
45/17 73/17 74/13
74/18 74/19 74/20
80/6 85/5 88/12
102/10 117/10 118/8
118/21 142/4 152/1
157/3 183/17 187/1
195/6
fester [1] 152/6
few [4] 35/8 50/8
126/19 170/7
figure [5] 13/10 15/8
105/7 186/15 187/9
figures [1] 105/21
file [1] 55/16
filter [2] 23/2 23/3
final [4] 30/2 78/25
82/22 184/9
finance [1] 69/5
finances [1] 124/11
financial [14] 52/17
72/3 88/5 119/16
176/7 176/10 176/14
176/16 176/17 177/20
178/1 178/3 178/6
178/15
financially [1] 178/17
find [12] 40/3 40/21
41/2 52/2 83/19
110/14 134/2 151/18
152/23 181/24 182/1
182/1
finding [2] 43/15
86/17
findings [5] 7/20
56/10 89/14 164/7
183/1
fine [3] 92/23 129/11
199/6
finish [5] 109/17
111/5 196/5 197/1
197/3
fire [1] 193/25
fired [1] 121/25
firm [4] 57/19 59/5
151/13 174/14
firms [6] 171/2 171/5
171/11 172/9 173/12
174/18
first [44] 3/23 16/18
16/22 22/2 23/22 33/7)
42/18 42/24 50/8
55/21 56/11 57/23
58/25 60/24 65/20
93/11 106/10 112/25
116/22 122/22 129/24)
133/23 134/1 150/11
150/19 157/11 164/15)
168/15 170/6 170/8
173/25 174/20 179/13}
183/25 186/15 191/7
191/13 196/25 197/4
197/11 198/7 198/7
198/13 198/14
Firstly [2] 84/12
126/1
fish [1] 126/10
five [4] 39/12 131/2
131/9 133/24
flag [4] 1114/2 113/7
124/23 125/10
flags [3] 113/7
124/24 127/12
flipside [1] 24/17
float [1] 127/21
flotation [6] 187/25
188/6 188/14 188/24
189/5 189/9
focus [2] 59/11 77/21
focused [7] 9/6 72/15]
72/19 76/12 77/20
96/14 176/10
focusing [1] 94/20
foisted [1] 188/5
follow [2] 6/10 76/6
following [7] 39/24
53/19 77/9 142/23
182/17 196/9 199/2
follows [2] 75/13
130/3
foot [1] 32/13
forecast [1] 106/23
forefront [2] 36/17
38/8
forever [1] 122/2
forewarn [1] 135/4
forgotten [2] 162/13
162/17
form [7] 26/11 27/14
43/20 116/7 140/16
143/18 153/7
formal [3] 5/6 99/1
99/2
(60) example... - formal
F
formally [1] 164/8
formed [2] 41/7
143/18
forming [1] 153/3
formulate [1] 101/1
formulating [1]
139/18
Forster [1] 184/22
fort [1] 115/17
forthcoming [1]
194/12
forum [1] 9/5
forward [24] 2/5
19/19 20/3 30/1 39/6
40/5 42/1 58/4 61/8
75/8 76/15 81/22
86/10 90/21 114/16
114/25 119/3 130/6
131/6 133/14 150/8
154/12 156/24 165/22)
forwarded [1] 170/21
forwarding [2] 35/17
47/8
forwards [1] 35/15
found [23] 4/5 23/8
23/23 25/6 41/2 41/4
41/8 41/16 41/17 42/6
44/1 98/6 98/10 98/16)
153/14 154/25 155/23
159/3 181/12 182/12
185/15 185/15 186/8
four [2] 39/12 45/10
fourth [3] 68/23
68/24 102/9
framed [1] 73/12
framework [2] 49/21
166/2
frank [2] 171/8
174/10
frankly [1] 127/3
freedom [1] 109/2
Freeths [2] 90/9
174/8
frequently [1] 148/5
Friday [1] 1/1
front [4] 114/25
118/17 140/24 171/16}
frustrated [1] 117/15
Fujitsu [2] 60/8
144/22
fulfilled [4] 6/20
full [7] 1/12 4/21
28/11 94/5 102/5
160/22 167/2
fully [3] 159/20 167/4
194/1
function [8] 5/16
6/11 6/20 45/24 80/22
80/23 128/14 165/10
functioning [2] 71/22
97/23
functions [1] 57/25
fund [1] 188/8
fundamental [3]
110/6 111/7 157/7
fundamentally [1]
10/2
funding [14] 12/5
12/12 12/15 12/24
13/16 14/6 14/13
16/7 19/2 49/6
funds [2] 10/7 12/20
further [14] 39/16
46/3 77/5 81/23 84/2
103/21 144/18 150/1
180/1 184/17 193/14
future [3] 30/3 166/1
166/2
G
gambit [1] 114/13
Gareth [2] 55/20
163/3
gave [11] 43/22
43/22 79/20 98/8
107/6 110/13 128/18
156/14 156/15 181/8
182/20
GC [1] 95/18
general [16] 23/23
51/24 113/10 117/19
118/7 122/24 149/22
153/14 153/22 164/12)
164/14 165/3 165/4
168/9 175/10 190/21
generally [11] 7/2
38/9 47/24 68/2 80/10
82/9 90/15 97/7 146/5)
198/17 199/1
generates [1] 161/14
generic [3] 14/16
39/9 112/12
gentlemen [1] 198/1
genuine [1] 174/12
get [80] 11/16 12/18
13/15 20/19 26/15
26/18 26/23 29/1
34/15 34/22 35/12
35/13 36/2 36/3 36/25)
40/3 40/12 44/18
48/22 48/25 49/16
49/17 50/9 50/9 57/5
57/22 65/13 65/17
66/17 69/25 76/13
79/14 79/14 85/12
86/2 88/2 89/6 94/14
96/2 97/18 111/24
113/9 114/2 115/20
117/21 120/4 122/14
123/12 126/11 126/13)
127/22 127/24 129/24)
130/16 130/18 130/25)
1341/9 131/14 132/2
133/7 136/2 138/23
14/17 15/11 16/3 16/7,
150/15 166/17 178/25)
171/5 172/9 172/19
185/23 195/4 197/8
gets [3] 47/13 103/11
136/20
19/15 25/16 26/17
27/8 29/4 59/1 67/5
114/12 131/16 132/11
132/25 133/1 138/11
141/14 168/4 168/23
195/13
gig [1] 133/12
gist [3] 21/19 113/10
114/8
give [18] 12/4 16/12
18/7 18/21 21/24
33/20 34/17 36/17
74/24 108/10 113/10
113/14 115/19 116/4
119/23 137/24 140/5
141/7
given [33] 10/6 15/18
16/5 17/22 19/23
24/21 36/1 38/11
39/19 50/15 51/3 54/6
56/21 57/21 66/5
66/12 76/4 79/6 81/11
88/8 88/21 90/2 90/18
94/3 107/9 111/10
114/16 119/7 122/11
127/23 156/24 167/23
193/23
gives [1] 11/13
giving [9] 15/19 30/3
35/8 38/18 121/1
129/6 132/24 137/13
160/20
glitches [1] 185/4
GLO [5] 55/22 55/23
55/24 56/6 90/25
go [52] 9/15 11/16
12/24 18/13 19/22
22/3 26/24 27/23 30/9
32/18 33/22 38/23
46/2 49/15 49/16
50/22 57/15 63/1
63/25 76/16 76/19
77/7 82/2 86/13 91/16
97/24 99/23 102/4
104/17 113/25 119/4
130/6 138/23 141/2
149/5 149/7 149/8
151/10 151/18 160/3
160/23 164/15 165/18}
167/22 181/17 183/12
190/22 191/11 193/8
194/7 196/5 196/10
goal [2] 175/22
139/21 143/22 148/15
156/17 156/18 161/10
185/11 185/13 185/22
197/12 197/12 197/20
getting [26] 8/2 10/15]
94/19 95/17 96/4 98/4
177/10 185/20 195/10
178/18
goals [5] 175/25
176/3 176/7 176/14
176/17
goes [9] 10/13 12/22
99/3 139/11 172/14
going [73] 1/19 2/23
26/11 26/22 27/12
35/11 35/13 37/16
41/25 42/20 42/22
43/20 44/9 44/24
69/16 74/17 79/2
84/20 89/17 90/12
90/17 94/25 103/18
109/8 114/2 115/11
122/2 123/7 123/11
125/4 125/8 127/18
127/19 128/8 129/7
129/21 131/6 136/23
138/23 143/12 145/8
145/15 145/17 156/6
160/3 160/11 165/21
167/22 173/23 180/1
184/9 190/16 190/20
195/11 196/11 196/12)
197/8
golden [1] 113/21
gone [10] 36/5 41/20
89/25 91/20 95/19
107/10 131/8 132/8
163/20 163/23
good [26] 1/3 1/10
9/14 30/13 61/5 97/2
99/18 102/11 129/16
129/19 131/21 134/7
135/1 136/21 137/7
145/20 146/18 150/22,
153/6 169/25 170/2
171/3 172/23 173/19
179/5 182/1
got [55] 7/15 9/7
11/16 11/20 20/6 22/9}
25/8 26/12 27/13 28/9
28/9 32/3 38/15 53/5
55/24 56/20 57/16
57/17 63/3 63/14
70/20 76/11 78/19
79/11 86/6 89/16
90/11 97/4 100/9
107/16 108/4 108/20
110/2 110/25 115/9
133/4 133/7 137/21
137/25 138/8 140/24
141/5 143/16 149/3
152/17 164/7 169/20
174/23 177/2 183/10
184/8 192/1 196/20
197/25 198/4
governance [2]
35/10 39/12 70/1 88/9)
7/25 8/11 13/18 15/16
15/18 19/9 22/10 25/5)
31/1 34/9 34/11 34/22,
45/20 46/2 65/12 66/2
50/21 52/1
government [80]
9/21 9/23 10/6 12/3
12/5 13/4 14/2 14/17
15/5 15/6 15/19 15/22I
17/12 17/14 17/18
19/6 23/10 23/25 24/6)
24/16 32/7 34/13
47/12 49/20 50/24
51/21 51/22 52/15
52/20 55/13 64/2 64/7I
78/7 79/14 80/24
82/14 82/24 83/2
84/22 85/19 87/8
87/14 97/18 102/23
103/5 103/12 103/24
104/3 104/6 104/12
104/15 108/12 111/13)
112/1 112/3 124/11
125/22 126/4 135/2
136/1 152/22 153/16
153/17 153/23 155/24)
162/19 162/20 165/23
166/4 175/16 175/21
175/22 176/11 176/22)
177/20 184/2 184/23
190/25 191/19 197/10}
Government's [9]
14/6 14/22 15/1 85/24)
88/10 97/8 97/15
176/7 194/6
Government/sharehoI
Ider [1] 17/18
governmental [1]
177/15
grab [1] 134/10
grateful [9] 30/5
30/11 39/23 113/6
113/13 124/23 134/1
170/9 199/14
great [3] 118/5
121/12 138/8
greater [1] 10/8
Green [1] 4/15
grip [5] 118/7 119/10
122/18 185/22 185/23}
gripped [1] 119/18
grips [2] 59/1 78/19
ground [2] 117/7
119/11
Group [15] 30/16
32/10 45/24 55/6 72/7I
77/15 128/9 132/2
161/23 168/15 170/18)
181/17 188/4 188/21
195/20
Group's [1] 31/12
groupthink [5] 6/1
6/2 6/12 192/9 192/15]
growing [4] 115/8
116/13 143/8 185/18
grown [1] 116/17
grows [1] 143/25
growth [3] 117/17
(61) formally - growth
G
growth... [2] 119/12
122/23
guess [7] 53/8 60/9
109/20 140/10 143/21
146/1 154/6
guidance [3] 76/17
76/17 86/11
guide [4] 63/1 65/12
65/25 89/2
guilty [8] 28/23
154/15 154/22 154/25
155/2 155/13 155/16
155/19
gun [6] 40/4 40/21
41/4 41/8 42/2 43/23
H
had [226]
hadn't [39] 7/7 40/23
41/2 41/4 41/23 42/6
43/15 44/1 72/16 74/5)
TAIT 78/22 80/16
83/12 83/22 89/13
95/15 95/21 98/5 98/7
98/16 105/6 106/21
106/22 106/23 116/10)
116/19 121/24 132/8
143/17 145/8 146/21
146/22 147/12 162/17)
171/17 173/6 174/25
175/1
half [6] 42/5 43/21
102/5 114/6 122/9
175/3
half-cocked [1]
102/5
halfway [1] 170/12
Hall [1] 35/20
Hamilton [4] 160/21
161/3 161/8 170/5
hand [7] 12/2 62/24
67/7 68/3 76/21 111/9)
153/17
handbook [3] 50/2
50/5 50/13
handle [1] 31/15
handled [1] 145/8
handling [2] 30/11
39/25
handover [2] 91/8
91/13
hands [2] 88/12
97/10
hands-off [1] 97/10
handshake [1]
113/21
hang [3] 96/4 186/22
195/19
happen [8] 15/17
69/23 70/11 71/3
141/13 143/10 150/24
178/14
happened [16] 51/18
52/6 53/10 53/11 56/7,
60/15 67/2 67/3 70/22
83/9 103/13 109/13
141/4 171/17 174/7
186/1
happening [6] 9/10
20/4 68/5 94/17 101/8
183/14
happens [1] 134/18
happy [9] 85/9
105/15 113/20 124/23)
134/12 140/25 141/3
159/19 193/16
hard [7] 25/21 55/14
111/25 117/6 122/15
152/2 152/23
harder [1] 44/18
Harriet [1] 138/17
harsh [1] 146/10
has [64] 4/21 9/20
36/7 36/23 41/16
44/17 44/19 46/20
47/12 47/19 60/15
60/20 66/16 66/23
70/1 73/7 73/10 77/8
78/9 78/18 82/3 86/3
86/4 86/16 87/1 88/6
89/25 94/10 104/21
105/17 109/7 110/3
1410/7 115/1 115/8
115/8 116/17 117/9
117/12 119/7 120/12
120/14 120/15 121/4
121/7 131/8 134/25
137/21 137/25 140/24)
143/23 149/22 149/24)
150/17 150/20 164/19)
167/4 173/4 177/15
189/19 190/8 190/24
193/22 194/16
hasn't [3] 92/4 131/3
196/8
hastily [1] 118/11
hat [12] 12/20 13/21
13/23 15/6 17/18
17/19 81/5 102/20
133/4 136/4 136/4
136/6
hats [2] 18/22 176/4
have [196] 1/16 4/20
5/22 9/3 9/11 10/16
10/16 11/3 11/8 11/11
14/1 16/2 18/18 19/5
19/22 20/21 23/17
28/7 28/19 30/11
30/12 30/15 33/18
37/14 37/16 38/1
39/25 40/13 44/18
44/24 47/1 47/5 50/6
50/18 51/3 51/3 52/2
52/4 52/7 52/25 53/5
53/16 55/16 56/17
56/17 56/19 56/20
57/20 59/2 59/5 59/21
60/7 60/10 61/10 64/6
66/10 66/11 67/1 67/2
68/19 70/3 71/18
71/19 71/20 74/9
74/19 74/20 76/11
77/18 77/19 81/17
81/19 86/18 87/4
87/10 91/9 92/6 93/4
95/5 95/13 96/13 97/4
98/23 101/11 102/23
102/24 104/1 104/13
104/15 104/16 106/9
106/25 109/2 110/1
110/4 110/19 112/3
112/18 112/20 112/24]
113/4 113/12 114/19
114/25 116/15 117/1
117/6 117/14 118/8
119/16 119/18 120/1
120/3 120/10 121/11
121/16 121/20 122/12
123/13 123/15 123/17]
126/10 126/25 127/17]
128/4 128/17 129/5
130/12 130/12 130/14
131/7 136/14 136/18
137/7 138/10 138/11
138/13 141/8 141/17
142/16 143/25 145/21
146/23 150/4 150/6
153/1 155/8 156/24
157/16 157/17 157/19!
157/21 158/4 158/6
160/3 161/12 161/13
162/21 167/7 167/25
168/11 168/19 168/23}
170/4 171/3 171/17
173/12 174/4 175/18
176/3 176/7 177/16
177/18 178/2 178/10
178/25 182/14 182/17
184/17 185/3 187/1
187/17 188/4 188/14
188/20 188/23 189/8
189/15 193/21 194/23}
194/23 194/25 195/14
196/6 196/15 199/14
haven't [8] 36/5
39/22 44/11 90/11
94/9 116/6 119/18
130/20
having [18] 4/25
18/12 30/13 36/6 49/7
51/17 70/4 70/13 78/4
94/7 96/9 96/10
106/15 109/24 133/24]
145/9 153/6 189/18
Hayward [2] 45/22
48/22
Hayward's [1] 46/4
he [31] 29/17 29/19
31/14 32/24 45/25
46/1 46/12 46/21
46/22 47/14 47/20
47/22 91/9 121/24
121/25 122/2 124/22
125/23 128/10 144/24}
145/25 158/17 158/18
167/21 167/21 182/20}
184/10 184/12 190/19}
190/20 197/6
he's [2] 68/10 134/6
helthey [1] 46/21
head [7] 3/5 3/9 4/5
33/22 76/9 187/19
189/20
heading [2] 50/24
164/12
headline [1] 170/18
hear [9] 1/3 61/6
99/18 129/16 160/13
169/18 179/5 182/18
198/6
heard [8] 6/2 40/23
41/23 56/10 56/11
58/15 186/9 187/3
hearing [8] 59/4
61/11 93/9 93/11
162/6 162/7 162/7
199/22
hearings [4] 87/15
94/23 94/23 168/15
heatmap [5] 71/6
71/10 71/13 78/14
91/14
heavily [1] 168/9
held [4] 3/8 143/13
144/3 188/4
Hello [1] 179/5
help [8] 23/14 29/8
36/9 106/1 112/18
123/20 139/10 156/1
helpful [2] 112/23
194/19
hence [1] 107/3
Henderson [1] 181/8
Henry [6] 169/24
184/19 184/20 198/2
198/6 200/6
her [92] 31/14 39/10
39/12 39/14 85/12
91/21 98/9 106/19
107/1 107/8 107/9
109/8 109/25 110/10
110/15 110/16 111/3
112/8 113/4 114/1
116/15 116/20 116/25}
117/14 117/23 118/15)
119/2 120/11 120/18
120/20 122/4 122/5
123/8 123/19 123/20
124/4 124/25 126/21
126/22 127/5 127/6
127/7 127/8 128/23
128/24 129/4 129/6
129/7 130/13 130/16
130/22 130/25 131/1
1341/5 131/10 131/11
131/11 131/14 131/16)
132/6 132/7 132/8
133/8 133/8 133/22
134/1 134/2 134/15
135/4 135/13 136/16
136/18 136/19 136/24)
137/15 137/23 137/24)
138/5 139/10 140/5
140/11 142/6 145/3
146/6 146/24 150/19
152/13 153/2 191/6
191/7 193/21 193/23
here [37] 32/18 33/4
34/24 35/6 35/11
42/20 43/18 46/4
48/11 56/23 56/24
89/20 95/25 98/25
101/5 110/11 111/24
113/7 116/17 118/22
126/12 136/6 136/9
137/22 139/15 140/23)
146/5 146/11 148/21
160/25 161/10 170/13)
176/24 182/24 193/19)
193/25 194/9
here’ [2] 108/13
124/24
Here's [1] 37/2
heroes [2] 196/19
197/18
hers [1] 161/9
Hi [2] 29/21 133/21
hiding [1] 127/7
high [16] 13/21 14/2
15/1 15/8 70/25
123/22 124/4 134/20
154/8 161/9 166/13
186/18 186/19 187/9
187/16 192/24
high-profile [1] 161/9
higher [4] 70/23
71/12 83/23 120/7
highest [4] 14/17
46/19 48/2 93/24
highlighted [2] 82/6
150/6
highly [2] 115/23
152/22
him [9] 31/15 46/13
47/14 68/12 68/12
91/13 122/2 167/21
167/22
hindsight [1] 186/20
hints [1] 35/9
his [9] 31/5 33/25
34/1 38/18 46/8 46/10
82/17 125/19 163/3
historical [1] 55/15
history [3] 6/3 58/4
198/16
hm [13] 3/18 17/25
48/24 88/7 91/18
95/10 116/5 169/10
(62) growth...- hm
H
hm... [5] 171/7
172/24 174/6 185/21
191/10
hold [6] 15/9 60/7
64/11 137/4 144/8
155/11
holding [6] 115/17
160/11 165/8 165/11
193/13 195/6
home [1] 36/3
homework [1] 58/22
honest [12] 16/17
38/24 51/19 52/13
52/14 64/15 140/12
144/8 151/3 152/24
167/16 191/25
honestly [2] 45/2
45/5
hook [2] 30/3 30/6
Hooper [5] 29/24
31/5 31/10 31/13
32/10
hope [3] 36/5 44/11
88/17
hoped [3] 83/16
185/14 186/6
horizon [90] 7/2 7/3
17/5 23/10 23/25
25/17 39/16 40/10
40/12 40/24 41/3 41/9
43/4 43/11 43/12
53/20 54/16 54/21
55/10 71/21 72/16
72/21 73/9 73/14
73/19 73/25 74/4 74/7,
74/10 75/9 75/17
77/18 79/8 91/3 94/6
95/3 95/12 95/24 96/9
98/6 98/19 102/10
102/12 103/22 103/25
104/2 105/16 106/5
117/18 117/24 119/15)
122/19 122/20 144/19}
144/20 153/10 153/16
154/1 156/4 156/13
157/1 160/25 161/14
162/8 165/14 173/5
175/1 175/13 176/6
176/13 176/20 178/8
178/24 180/6 180/8
180/14 181/2 181/5
181/9 182/6 182/8
185/16 186/11 189/7
190/25 192/10 192/13
198/10 198/18 198/23
Horizon's [2] 185/3
187/7
hospital [1] 11/17
host [1] 26/7
hot [1] 125/6
hour [1] 122/9
hours [2] 36/2 197/9
house [4] 164/20
165/10 165/17 196/7
how [60] 4/13 9/7 9/9
10/12 20/5 21/12
27/11 27/12 30/17
31/14 31/15 32/9
38/17 38/22 39/5
40/15 42/11 42/19
42/21 48/5 48/9 65/9
72/5 73/16 79/24
88/20 89/5 89/7 94/3
94/10 102/19 104/3
112/1 119/24 121/7
124/20 125/1 125/3
125/13 127/18 127/21
127/22 130/15 131/25)
133/10 143/13 145/25)
145/25 148/5 154/14
161/22 162/19 164/7
171/2 171/11 172/16
172/18 173/12 188/18)
197/5
Howard [3] 144/25
145/10 147/4
Howe [1] 179/8
however [7] 44/17
44/20 86/23 107/15
149/23 188/11 192/1
HR [1] 46/1
hugely [1] 46/16
humans [1] 193/1
hundred [1] 13/19
hung [1] 185/13
hypocrisy [1] 195/4
l accept [2] 29/1
190/1
l accepted [1] 98/22
I acknowledge [1]
108/4
lact [2] 170/3 179/7
I actually [1] 15/5
l address [1] 161/2
lagree [3] 71/25
108/6 157/8
l agreed [1] 108/11
lalso [3] 8/1 8/9
102/10
l always [2] 27/24
88/13
lam [3] 109/11 128/4
136/6
I apologise [2] 16/5
161/3
l appreciate [1]
134/1
lare [1] 199/13
l arrived [2] 50/4
78/19
lask [8] 1/11 10/6
28/1 117/21 169/7
172/21 173/21 189/2
l asked [3] 7/4 98/8
155/1
lassume [1] 154/8
I aware [1] 180/15
leall [1] 1/5
I came [1] 54/5
lcan [20] 1/4 18/7
23/15 34/19 51/4
63/17 63/17 65/10
70/16 71/24 78/12
129/17 131/13 142/2
170/11 173/17 173/22
183/8 193/3 193/4
l can't [22] 8/12 9/3
45/18 47/3 52/6 54/4
59/21 59/21 60/1 60/5
93/20 126/15 128/17
128/20 128/25 136/14
149/4 150/25 153/1
155/6 155/8 157/13
I cannot [1] 137/7
I could [7] 4/14 15/15
15/15 20/2 32/22
167/18 184/11
I couldn't [5] 7/5 21/1
21/18 27/24 162/18
I did [12] 6/16 10/16
21/16 108/3 124/14
135/6 136/18 139/4
154/24 157/14 171/17
171/17
I didn't [32] 8/12 8/15
15/10 15/21 15/23
25/2 29/1 57/5 59/13
60/16 81/20 98/3
98/17 98/19 107/8
116/15 117/1 132/7
138/13 140/10 154/17)
154/21 156/25 157/14]
158/10 158/13 182/9
182/13 184/5 185/13
186/19 191/24
I disagree [1] 72/14
I do [5] 125/9 128/3
133/8 173/2 190/5
I don't [70] 6/3 6/5
6/15 10/21 14/7 15/20
15/24 17/6 20/5 22/8
38/24 44/16 45/14
50/7 50/17 50/17
51/15 51/15 51/18
53/8 55/15 56/7 56/8
58/6 58/24 60/21
64/15 65/8 65/10
65/24 67/2 69/8 90/20
98/3 100/22 100/24
102/25 111/23 118/6
118/9 122/20 126/5
129/3 137/16 137/16
139/6 139/22 139/24
141/6 141/9 144/9
145/25 146/20 148/7
148/17 151/3 155/8
158/10 164/4 164/9
167/16 170/17 182/13}
198/24
I doubt [4] 136/18
l explain [3] 23/19
103/21 161/8
I explained [2]
126/24 159/23
l expressed [1]
108/13
I feel [3] 89/17 128/6
161/17
I felt [12] 7/16 8/3
8/13 17/12 21/2 23/6
43/25 73/17 88/12
157/3 183/17 195/6
I first [2] 16/22 22/2
I follow [1] 76/6
I found [2] 23/23
153/14
I get [2] 65/13 65/17
I go [2] 191/11 193/8
I got [10] 7/15 9/7
26/12 53/5 56/20
76/11 108/4 143/16
177/2 183/10
I guess [7] 53/8 60/9
109/20 140/10 143/21
146/1 154/6
Ihad [12] 6/3 58/15
73/3 102/10 128/3
128/4 139/4 159/3
173/4 180/20 187/4
188/1
I hadn't [8] 74/5
89/13 95/15 98/7
162/17 173/6 174/25
175/1
Ihave [7] 30/12
44/18 112/24 113/4
123/13 177/18 178/25}
I haven't [6] 36/5
39/22 44/11 90/11
94/9 130/20
I hear [2] 160/13
198/6
I heard [1] 56/10
I honestly [2] 45/2
45/5
I hope [2] 36/5 44/11
I hoped [2] 185/14
186/6
lin [4] 55/23
linherited [6] 7/15
8/2 9/13 23/13 73/18
80/16
linterpret [1] 125/13
I joined [8] 6/5 8/14
64/8 81/10 81/19
116/13 191/19 191/24)
Ijust [10] 15/7 23/22
25/5 33/17 44/16 76/8)
132/8 170/24 182/16
198/20
183/22 184/15 184/17)
188/25 188/25 189/22)
I knew [11] 54/4
109/23 140/17 140/18)
149/4 149/4 153/5
154/17 154/21 154/24)
188/7
I know [6] 9/11 34/22
63/19 65/15 72/10
161/5
Iearnt [4] 46/13
55/21 58/24 164/4
Ileft [1] 104/8
Hook [1] 28/11
Host [1] 189/22
I may [9] 28/19 44/10
51/10 59/21 60/7
128/17 129/20 136/14I
157/17
I mean [32] 16/17
21/6 27/1 35/5 39/2
45/14 49/21 50/10
50/18 51/13 53/8 55/4I
56/6 57/12 58/24 59/9I
60/10 64/24 67/3
67/20 69/1 92/17 94/9I
98/14 127/10 140/3
144/2 145/7 152/17
158/1 171/24 181/10
I meant [2] 20/7
148/15
I mentioned [1]
112/24
I might [5] 47/5
124/19 153/1 171/15
173/8
I missed [2] 159/1
190/1
I move [1] 187/18
I need [3] 18/19
33/18 44/17
I needed [3] 131/1
137/14 157/3
I never [5] 21/1 21/7
21/18 26/22 158/13
I noticed [1] 65/13
l observed [3] 58/25
186/15 198/13
l often [1] 13/23
lomit [1] 191/8
lonly [1] 15/12
I particularly [1] 8/15
I perceived [2] 28/20
88/14
I pitch [4] 127/22
I prepared [1] 142/12
I probably [6] 9/11
41/10 122/8 122/12
130/22 140/20
I quite [1] 131/13
lread [4] 1/25 59/14
157/11 157/13
I realised [1] 1/25
recall [3] 122/8
135/16 141/24
I recently [1] 46/9
(63) hm... - recently
l recused [3] 15/13
15/14 16/9
reflect [1] 186/20
I regret [2] 25/7
157/18
I remember [7] 13/4
16/21 50/3 50/10
120/24 164/8 168/3
I reported [1] 107/1
I said [10] 13/7 26/10
74/5 81/3 103/16
111/25 138/8 167/7
185/12 198/12
I saw [3] 50/10 73/17
102/13
I say [12] 4/21 9/13
12/25 29/3 42/4 56/6
94/18 116/16 116/22
127/9 135/23 145/13
I see [6] 37/12 66/19
73/4 74/8 191/20
193/6
I shared [1] 142/13
I should [5] 23/17
46/13 157/16 187/1
187/17
I showed [2] 123/16
128/24
I sort [2] 104/11
127/20
I start [3] 2/17 3/15
129/23
I stated [1] 95/23
I stepped [1] 168/20
I stop [4] 177/3
I suggest [4] 7/14
39/18 47/22 195/3
I summarise [2] 96/7
151/24
I suppose [32] 4/2
7/11 7/15 10/10 11/19
12/17 15/4 16/24
38/24 39/20 43/3
69/12 79/22 83/16
84/19 86/9 89/21
96/15 97/7 98/14
110/5 116/12 131/1
131/4 140/10 147/8
156/16 156/23 159/17)
188/16 189/12 192/25)
I take [4] 29/8 92/9
93/20 190/15
Itell [4] 117/3
I then [4] 173/19
I think [218]
I thought [28] 4/13
7/19 13/7 26/23 27/8
28/17 33/17 36/3 41/1
43/5 43/9 43/11 46/13)
89/22 106/17 110/14
110/16 113/25 133/23)
153/17 155/23 161/21
162/1 177/2 177/13
181/14 181/19 183/14}
I took [7] 58/13 59/9
59/14 59/17 154/6
154/11 182/10
I tried [1] 145/6
I trusted [1] 153/4
I turn [3] 11/23
141/19 163/8
l understand [4] 75/4
123/17 134/25 186/25)
I understood [11] 9/8)
53/24 54/5 58/6 58/13)
60/14 98/14 152/12
158/16 185/24 195/23)
I very [1] 21/6
I viewed [1] 42/21
want [10] 129/19
130/16 131/7 131/9
135/14 140/8 160/15
170/6 177/19 179/9
I wanted [2] 15/7
175/9
Iwas [69] 4/14 6/16
7/25 8/2 8/10 13/23
16/2 16/6 16/18 18/12
22/1 22/2 26/9 43/3
43/7 43/14 45/13
45/13 45/14 50/10
53/8 53/9 58/5 59/1
62/20 64/16 69/16
71/9 73/15 81/10
89/13 91/24 95/21
95/23 98/4 103/16
114/11 124/2 125/15
128/10 143/16 145/1
148/19 153/3 153/6
155/2 155/16 158/15
161/8 161/10 162/23
162/25 167/20 167/24)
168/24 169/4 172/13
172/13 175/20 176/16)
177/4 184/9 185/8
185/23 188/7 188/9
189/23 190/11 199/4
I wasn't [16] 16/9
58/25 127/7 140/11
148/17 159/2 161/8
162/17 162/19 167/17,
173/23 177/3 180/19
181/18 185/13 190/11
I went [1] 5/3
I were [1] 168/24
Iwill [5] 14/1 35/25
60/10 130/14 196/5
I won't [1] 43/22
I wonder [3] 60/23
129/9 169/11
I would [35] 7/14
15/3 15/25 18/15
18/16 23/2 28/8 30/5
36/13 39/23 56/19
66/16 68/11 72/10
75/18 77/18 78/22
79/12 81/19 88/17
104/15 105/14 113/6
113/13 124/22 135/7
135/12 136/18 139/6
151/3 167/7 171/13
178/2 182/14 193/16
I wouldn't [3] 6/24
21/19 127/8
I'd [29] 4/2 4/3 4/13
5/4 6/2 13/24 22/7
26/13 35/5 35/6 41/12,
43/19 56/11 59/10
68/13 80/21 81/19
104/5 106/18 109/11
110/25 148/18 153/5
158/3 170/8 171/13
174/15 192/22 196/25)
Vl [4] 8/20 75/11
141/1 160/12
I'm [130] 4/18 7/12
8/3 8/22 9/1 15/6 17/1
19/10 27/3 27/10 33/9
34/16 34/22 35/6
35/12 35/13 36/2 37/1
37/9 37/16 37/22
37/23 37/23 44/9
44/14 45/18 49/21
51/4 54/4 57/13 62/23
63/2 63/8 63/19 63/22
64/18 64/20 64/21
64/23 65/17 65/24
66/3 68/23 69/1 77/16
79/16 85/17 87/23
89/4 89/16 89/20 96/7
96/24 96/25 100/4
104/11 104/12 104/14
104/15 105/13 106/6
107/21 107/23 110/21
110/21 111/2 111/6
112/10 115/11 117/5
123/11 125/3 125/3
125/4 125/7 125/8
127/21 127/23 127/23
131/1 131/4 132/16
133/3 133/5 133/9
135/6 136/20 136/23
137/16 137/17 138/5
140/4 141/3 141/15
145/13 146/10 148/22)
161/3 161/10 161/12
161/20 162/6 162/6
162/7 162/10 164/7
167/7 167/9 171/11
171/12 172/15 173/7
173/18 174/12 174/17
175/5 183/16 184/12
188/25 190/5 190/16
190/20 192/14 192/15}
192/17 193/4 193/5
196/10 196/11 197/14]
I've [26] 16/5 24/1
51/20 52/1 53/11
60/14 61/9 66/25 72/8
72/25 88/2 89/16
92/21 97/2 107/9
123/4 123/14 131/25
133/8 136/7 156/19
161/15 162/18 184/8
197/25 198/4
ian [2] 181/8 191/12
idea [6] 51/5 53/11
130/13 150/22 151/10
151/18
ideally [1] 36/6
identifiable [1] 25/17
identification [1]
74124
identified [5] 70/15
139/14 165/14 166/5
166/16
identify [8] 6/13 6/22
23/8 23/23 61/14 75/1
112/18 153/14
identity [1] 77/22
ie [15] 20/16 25/22
27/5 31/16 47/4 57/8
58/22 60/4 60/17
104/2 126/22 135/9
146/6 146/16 152/7
ie Board [1] 60/17
ie concern [1] 152/7
ie criticism [2] 146/6
146/16
ie kept [1] 126/22
ie reviewing [1]
58/22
ie sharing [1] 20/16
ie that [2] 57/8 104/2
le this [1] 27/5
ie what [1] 60/4
ie write [1] 31/16
le you [1] 135/9
ie you've [1] 25/22
if [154] 1/16 2/4 2/9
4/14 7/6 8/19 14/4
16/5 17/12 18/7 21/2
21/4 21/6 21/8 27/22
29/12 30/9 30/11
30/24 31/19 33/17
35/9 38/10 38/13
38/21 39/7 39/17
39/19 39/23 43/21
44/8 44/10 46/2 46/7
47/6 50/21 51/4 51/10
57/14 63/1 63/20
63/25 64/24 64/25
65/2 66/3 66/12 68/11
68/12 68/14 68/23
69/12 69/25 70/6
70/11 74/1 75/10
75/23 76/16 76/19
77/7 78/25 80/13
81/24 82/2 83/24 84/8)
85/15 86/13 86/21
89/17 91/16 92/15
93/16 93/19 93/19
96/7 96/16 97/15
97/24 98/23 99/23
99/24 99/25 99/25
100/25 101/8 102/5
102/21 109/4 110/1
110/2 110/5 110/6
1410/9 110/17 111/3
111/9 113/6 113/12
117/3 117/5 119/4
120/18 124/23 126/18)
127/10 127/12 128/4
129/19 129/23 129/25)
130/6 131/7 133/25
134/1 134/8 135/6
135/15 136/20 140/24}
144/1 144/18 147/16
149/9 151/13 157/14
158/3 159/8 160/11
163/10 164/12 164/15)
165/6 165/18 167/18
168/12 170/8 170/12
170/20 171/12 171/14I
171/16 173/21 176/6
182/1 184/5 184/11
185/14 186/6 191/13
193/18 194/19 196/8
illegally [1] 86/17
illustrate [1] 32/22
imagine [6] 65/10
66/16 77/18 78/22
116/1 151/3
immediate [3] 166/3
178/18 178/18
immediately [1]
56/21
imminent [3] 82/20
83/8 159/22
impact [11] 48/6
48/11 70/10 72/6 82/5
92/20 93/24 96/9
96/10 162/15 181/6
impartial [3] 137/3
137/13 137/24
impervious [2]
145/23 146/17
implement [2] 119/9
168/8
implemented [1]
89/12
implementing [1]
126/20
implications [4]
39/25 107/14 176/11
177/20
impliedly [1] 198/21
implies [1] 86/6
imply [1] 160/16
importance [2] 48/5
48/9
important [6] 46/16
76/2 114/1 115/18
159/5 176/4
impression [3] 16/6
183/11 191/7
impression/correct
[1] 191/7
(64) I recused - impression/correct
I
improve [2] 117/14
120/11
improvement [3]
7/21 73/11 73/22
inaccuracies [4]
32/21 33/15 33/16
34/19
inadvertently [1]
137/11
inappropriately [1]
86/16
inbound [3] 79/25
84/15 195/10
inception [1] 53/21
inclination [1] 24/15
include [2] 119/13
182/5
included [6] 30/2
53/23 54/22 96/12
100/2 189/24
including [18] 18/24
27/16 30/6 42/5 42/8
79/2 84/7 87/5 133/11
138/22 142/4 144/16
159/9 161/24 170/5
177/11 177/12 191/18
incorrect [1] 96/8
incorrectly [2] 178/4
183/1
increase [3] 83/9
83/15 120/24
increased [2] 79/4
82/3
increasing [2] 79/1
95/25
increasingly [2]
117/15 119/8
incurious [1] 178/11
incurred [1] 162/9
indeed [4] 32/19 38/6
124/15 191/18
independence [7]
24/4 30/8 31/6 108/13
108/15 109/6 128/6
independent [29]
5/17 9/20 18/16 24/19
27/6 27/7 27/9 27/21
31/4 39/20 42/22
57/19 57/21 82/10
82/13 82/24 83/7
97/19 111/9 111/13
111/15 137/13 137/24}
150/21 150/23 151/1
151/6 162/22 183/12
indicate [3] 12/7
84/17 141/13
indicates [1] 85/18
indicative [1] 122/21
individual [11] 7/22
8/5 42/16 44/2 73/24
123/5 181/4 181/15
182/6 185/9 185/12
individually [1]
181/23
individuals [5] 68/20
71/18 74/9 162/4
162/14
induction [1] 46/10
industrial [2] 36/22
49/9
inevitably [3] 34/18
35/13 39/21
inform [3] 18/17
21/13 89/3
informal [1] 142/17
information [51] 7/9
7/24 8/1 8/23 9/8 17/8
20/11 20/17 20/23
21/12 21/22 21/25
22/17 26/7 28/9 29/4
29/10 31/21 36/25
36/25 44/4 46/9 62/7
76/5 94/8 94/12 95/6
95/18 96/2 98/4 98/7
101/20 101/25 102/3
107/7 107/8 107/18
112/7 129/6 129/20
129/22 131/8 132/18
132/21 132/25 136/16)
156/16 156/19 167/12)
168/2 198/9
information-sharing
[2] 167/12 168/2
informed [5] 52/21
55/13 128/21 159/2
178/1
informs [1] 89/22
infrastructure [1]
184/23
infringement [1] 30/7
ingrained [1] 6/12
inherent [2] 5/23
183/5
inherently [4] 67/19
69/23 96/15 99/6
inherited [7] 7/15 8/2
9/13 23/13 73/18
80/16 104/5
inhibit [1] 17/13
initial [7] 120/15
148/8 150/2 163/1
163/11 180/4 180/24
initially [4] 2/23
81/20 142/1 190/16
innocent [4] 176/23
176/24 177/8 191/1
input [1] 37/6
Inquiry [5] 1/11 64/23)
123/13 167/14 199/13}
insert [2] 104/13
112/1
inserted [1] 66/10
insight [1] 46/12
insist [1] 166/14
instance [3] 60/5
92/14 136/11
instances [5] 59/22
59/23 60/1 127/20
186/4
instead [1] 125/19
instinctively [1] 40/1
insufficiently [2]
57/4 57/8
integral [1] 197/20
integrity [9] 68/21
71/22 74/4 74/10 91/3
94/6 95/3 95/13 96/9
intelligible [1] 33/13
intended [4] 127/6
127/7 135/3 137/6
intent [1] 101/22
intention [4] 82/13
82/23 82/25 131/7
interacted [1] 142/6
interest [16] 11/23
12/1 12/9 14/5 14/9
16/14 16/14 46/13
48/7 48/15 48/16 84/5
84/23 176/22 176/22
17716
interested [4] 49/15
83/18 85/3 158/15
interesting [1] 65/20
interests [4] 9/17
12/17 19/5 84/6
interim [11] 62/14
73/8 73/13 77/14
118/1 156/9 160/15
180/20 181/11 183/1
185/10
intermittent [2] 185/4
185/5
internal [10] 50/17
51/12 52/2 89/5
140/18 147/19 165/13
166/11 183/21 190/8
internally [1] 158/18
interpret [2] 125/13
182/9
interpretation [1]
181/10
interpreter [1] 34/11
interrupt [1] 74/23
intervene [7] 24/6
30/5 31/7 31/8 40/19
153/18 162/20
intervening [3] 31/3
31/3 34/6
into [35] 1/19 2/12
11/16 13/18 19/14
21/9 30/4 48/18 54/5
67/14 71/4 74/3 90/15)
104/13 109/16 109/18}
112/1 130/11 132/11
132/12 132/14 145/12
148/12 163/12 167/6
167/15 168/7 168/13
171/5 172/19 183/2
185/9 192/13 194/8
195/21
introduced [1] 90/13
investigate [6] 42/17
73/24 150/1 181/22
183/15 183/16
investigated [6] 8/6
155/22 181/16 186/3
186/3 186/5
investigating [1]
197/1
investigation [18]
8/5 25/11 26/11 26/12,
26/17 42/5 42/9 42/13)
43/19 74/3 150/15
156/6 182/6 182/22
182/23 183/6 192/13
193/7
investigations [17]
19/14 25/10 25/12
27/15 40/22 41/20
41/21 42/18 42/20
42/22 42/24 70/21
109/16 109/18 181/11
185/9 185/25
investigator [1] 58/8
investigators [1]
195/8
investigatory [2]
19/17 57/24
investment [5] 4/16
12/18 13/13 46/23
100/24
inviting [1] 39/17
involve [1] 109/25
involved [16] 70/5
80/7 80/9 85/12 90/5
97/13 97/18 128/12
139/18 164/18 168/10
169/4 174/14 174/19
176/24 181/11
involvement [3]
48/12 82/12 147/10
involving [2] 116/11
163/21
irrespective [1]
155/13
irrevocably [2]
116/25 117/3
is [414]
ish [1] 133/23
isn't [21] 7/8 26/18
26/19 26/21 27/18
34/23 41/25 98/21
105/16 112/10 114/7
134/9 140/25 170/20
173/16 174/10 183/4
194/1 194/1 195/16
196/24
issue [60] 8/20 23/10
23/25 25/12 25/17
26/18 32/22 33/23
41/25 44/3 44/4 45/15
49/8 58/16 59/16
68/11 75/8 79/1 80/14
82/13 82/22 82/24
87/14 93/12 95/6
95/12 96/23 97/1 98/5I
98/11 103/22 104/3
104/21 105/24 106/2
106/12 106/14 107/5
107/11 107/11 107/12)
110/17 143/11 144/19)
144/25 145/7 146/3
149/18 149/23 152/6
153/16 155/22 155/25)
163/5 165/21 175/9
178/24 181/5 182/6
183/9
issues [38] 4/23 14/6
16/24 17/5 18/24 41/2)
46/20 49/6 49/14 55/4)
55/5 70/5 72/16 73/23}
78/2 78/3 79/8 83/12
83/20 83/21 95/22
96/19 96/21 97/1 99/7
103/14 106/5 107/10
119/15 122/19 135/20)
140/24 149/20 150/7
153/9 154/20 159/4
162/24
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it'll [1] 107/24
it's [183] 7/13 9/25
10/14 13/3 18/18 19/8)
19/8 23/5 24/4 24/19
24/22 25/19 28/24
32/2 32/2 33/12 34/21
37/24 40/13 43/3
43/10 44/15 45/2 45/3
45/16 48/14 51/16
57/12 57/12 57/13
57/16 58/10 60/23
63/2 63/7 63/8 63/14
64/17 64/17 64/18
64/18 66/4 66/4 68/14)
69/5 70/22 70/22 72/6I
72/6 72/18 76/18
76/19 77/25 79/9
79/17 79/22 79/23
80/4 83/3 84/2 84/14
84/18 84/20 84/21
85/18 88/11 88/13
89/15 90/1 90/2 91/16
91/22 91/23 92/6
92/13 93/22 94/9
94/11 94/16 94/19
94/21 94/21 96/16
96/18 96/18 97/2 99/1
99/2 99/3 99/11
100/16 101/8 102/8
104/11 105/13 106/6
106/14 107/20 111/25}
112/11 112/14 113/8
113/9 114/8 114/10
114/10 114/11 116/18}
116/23 118/5 119/1
119/6 121/14 123/6
124/7 125/11 127/1
129/2 129/4 129/9
(65) improve - it's
I
it's... [63] 131/21
132/23 134/1 134/2
134/20 135/1 135/25
135/25 136/3 136/24
137/9 137/20 138/2
138/3 141/6 143/16
144/8 144/23 145/14
145/25 146/21 146/24)
147/7 147/9 147/19
147/23 151/4 151/15
152/13 152/19 152/20)
152/21 152/22 152/23)
154/10 156/12 156/16)
158/22 159/17 161/17)
163/11 163/14 164/1
169/5 171/24 171/25
172/17 173/2 173/8
173/16 173/17 183/20}
185/17 186/23 193/10}
195/11 195/19 196/6
196/7 197/16 197/19
199/3 199/16
item [3] 74/23 142/7
198/14
item 11 [4] 74/23
iteration [2] 112/25
113/4
its [24] 9/20 10/23
19/6 48/17 50/24 51/7)
53/21 58/22 61/14
71/1 88/5 88/5 105/3
105/3 105/19 105/21
105/21 108/13 109/16}
164/6 165/9 165/10
165/11 177/8
itself [19] 9/9 9/13
9/15 10/11 21/11
25/24 58/23 60/4
60/13 81/1 81/13
87/24 88/4 95/18
104/13 112/1 112/8
163/15 166/10
J
Jacobs [5] 169/23
179/3 179/4 184/13
200/5
James [8] 87/10
160/8 163/3 192/6
193/20 194/11 194/17
195/23
Jane [11] 98/8 99/25
100/5 100/17 101/9
134/6 134/10 134/23
136/12 196/15 196/16}
January [8] 3/1 39/6
86/11 104/18 116/13
143/21 148/1 167/10
January '14 [1]
143/21
January/February [1]
116/13
Jason [1] 1/10
Jenkins [1] 55/20
Jenkins' [1] 62/16
Jenny [7] 1/21 30/3
113/17 116/16 124/8
130/1 142/19
jeopardised [1]
176/7
JFSA [12] 27/14
29/25 40/2 40/20
43/24 79/1 82/20
83/21 86/4 162/11
170/14 170/18
Jo [45] 1/21 1/22
1/25 2/2 2/6 33/8
33/10 33/19 34/17
36/7 39/9 39/19 80/8
108/8 112/6 113/12
113/15 113/17 113/18)
113/25 116/13 116/20}
120/23 122/6 123/9
124/3 124/9 125/6
125/9 127/2 127/10
130/2 130/4 130/21
142/19 142/20 143/6
159/10 159/19 160/19)
160/20 160/23 161/25)
193/20 194/15
Jo Swinson [1]
122/6
Jo Swinson's [3]
1/25 130/4 161/25
Jo's [2] 36/1 39/24
job [10] 6/11 47/12
81/5 102/11 108/3
126/9 152/25 155/25
196/15 196/16
JOHN [3] 1/8 1/13
200/2
join [2] 8/9 199/5
joined [20] 2/19 2/22
6/5 8/14 16/22 22/2
40/7 47/25 53/18
59/10 63/5 64/4 64/8
81/10 81/19 116/13
131/25 167/20 191/19)
191/24
Jonathan [2] 157/23
158/24
journalist [1] 45/4
joy [1] 174/2
judge [1] 193/4
judged [1] 86/16
judgement [9] 18/16
21/16 23/5 101/25
121/17 132/20 143/19)
153/7 190/1
judiciary [1] 27/6
July [5] 1/1 7/19
58/19 73/13 151/20
July 2024 [1] 1/1
jumped [1] 191/5
June [15] 1/15 2/2
19/12 118/14 127/1
127/4 127/4 142/3
143/9 143/10 151/19
157/14 182/20 192/12
199/23
jury [1] 154/13
just [109] 2/4 2/4 6/6
7/8 13/7 15/7 18/20
19/8 22/13 23/15
23/20 23/22 25/5
30/17 32/7 33/17
37/23 37/23 38/12
38/13 38/25 40/7 43/8
44/8 44/16 46/2 48/21
50/22 56/2 59/14
60/23 62/13 62/20
63/2 65/1 65/17 66/1
66/2 66/4 68/16 70/6
73/12 74/19 76/8
76/11 76/16 76/25
83/24 84/18 86/8
86/11 89/6 92/13
92/18 94/15 94/19
96/15 99/12 100/20
102/14 104/23 106/7
106/15 106/21 106/23
107/13 111/12 112/9
113/4 114/6 123/14
126/1 129/24 131/25
132/8 132/24 138/5
138/17 138/24 139/23
140/22 145/25 146/10}
146/21 152/5 152/20
154/3 157/9 159/11
160/17 161/15 163/10
170/24 172/5 173/21
174/5 177/23 178/2
178/24 182/10 182/16
183/20 184/11 186/5
194/24 196/19 197/17]
198/20 199/1
justice [1] 7/6
K
Katrina [1] 64/5
KC [2] 57/19 62/19
keen [2] 82/18 85/2
keep [20] 11/3 24/25
39/23 40/17 45/20
46/2 79/3 79/7 79/21
80/14 82/23 87/11
93/4 101/20 106/9
106/11 110/15 128/21
145/20 180/1
keeping [4] 82/13
102/2 117/11 152/5
kept [5] 125/23
126/21 126/22 193/21
194/5
Kerr [1] 184/22
key [11] 61/13 87/6
93/5 108/16 125/16
135/15 135/17 135/18}
157/20 157/22 165/24)
kind [20] 11/6 20/23
27/24 36/22 53/14
54/25 56/14 56/16
75/13 75/16 96/16
116/17 116/18 122/24}
123/2 140/7 143/10
145/25 149/17 157/3
King [11] 27/17
58/11 58/14 58/21
62/19 73/2 73/21
156/11 163/1 177/12
199/2
King/Altman [2]
156/11 177/12
kitchen [1] 122/14
knew [17] 17/23
31/13 31/13 54/4 76/4
106/25 109/23 128/7
140/17 140/18 149/4
149/4 153/5 154/17
154/21 154/24 188/7
knocking [1] 43/23
know [116] 1/11 5/10
6/6 7/17 8/7 9/11
10/21 11/1 11/15
15/23 19/25 20/5 23/6}
24/3 24/13 25/7 27/18
27/22 29/2 32/2 32/18
33/14 34/15 34/16
34/22 36/18 38/24
41/19 42/23 49/5
50/18 51/15 51/18
53/8 53/10 55/15 56/3)
57/14 57/14 59/11
62/15 63/19 64/15
65/8 65/10 65/15
66/15 67/2 69/7 69/9
72/10 74/2 75/20
78/24 80/20 84/14
85/10 86/7 86/8 97/3
99/3 104/9 108/23
114/14 114/19 118/4
118/22 125/6 125/9
126/17 127/12 127/17
131/19 131/20 132/1
133/12 138/10 139/1
139/4 139/9 139/24
145/25 147/1 148/7
148/17 149/2 151/3
152/25 154/14 154/19
155/8 156/18 158/10
161/5 164/4 164/10
167/16 171/2 171/10
171/13 171/14 172/1
172/17 172/19 172/20}
173/12 174/17 177/1
188/2 188/6 188/25
189/1 191/24 195/1
197/11 198/24
knowing [4] 9/11
15/4 72/10 104/9
knowledge [4] 2/14
4/1 167/13 184/24
known [5] 43/16
53/19 54/8 67/9 158/3
knows [1] 133/7
L
lack [10] 28/23 28/24
71/21 95/13 117/15
117/16 118/7 122/18
150/9 197/14
lacked [2] 68/20
74/10
lacking [1] 75/15
Lady [2] 100/10
133/21
lain [4] 188/20
Lambert [3] 63/4
64/3 64/4
land [1] 125/2
language [2] 172/6
185/20
large [4] 10/4 164/18
166/1 179/7
large-scale [1] 166/1
largely [3] 22/1 70/4
163/24
last [16] 1/19 44/9
62/20 63/14 63/15
65/14 65/18 65/22
80/22 94/10 104/4
131/9 139/6 166/7
166/12 196/5
lasted [2] 104/5
122/9
lastly [5] 90/21 93/7
121/10 127/25 163/8
late [1] 97/9
later [3] 113/6 134/6
151/18
latest [4] 49/7 66/22
68/4 101/7
latter [2] 42/23
163/24
launched [3] 90/9
174/4 174/17
Laura [18] 40/5 91/20)
100/5 100/7 100/9
100/11 100/16 100/17I
108/11 133/19 138/15)
139/23 140/1 159/8
192/8 196/17 197/5
197/9
Laura's [1] 140/25
Laure [1] 101/5
lawyer [2] 60/4 155/7
lawyers [2] 171/22
174/22
lay [1] 162/14
lead [10] 3/1 32/25
48/1 59/17 68/8 93/10
118/16 122/20 123/6
158/25
leader [1] 88/12
leadership [3] 119/9
149/23 150/9
leading [3] 31/12
68/10 119/1
(66) it's... - leading
L
157/17
learned [4] 20/23
97/12 164/3 164/12
55/21 55/23 58/24
163/16 164/4 165/19
167/8
least [6] 5/10 41/10
66/23 75/13 159/5
167/19
leave [14] 1/22 2/2
2/3 2/7 4/4 47/22
97/10 111/17 116/14
130/3 130/5 130/23
133/9 142/20
leaves [1] 115/15
leaving [1] 146/25
led [6] 61/25 88/17
120/1 158/4 158/6
163/4
left [9] 30/12 63/1
65/2 65/2 104/8
130/23 131/18 133/9
133/13
legal [53] 55/16 56/6
59/18 60/6 60/13
72/1 87/4 87/7 87/12
87/14 87/19 87/23
138/23 138/24 140/4
165/3 165/10 165/17
166/9 166/11 166/14
166/15 166/16 166/20)
166/22 167/3 171/2
171/5 171/11 172/9
173/12 174/18
legally [1] 60/9
legals [1] 188/13
legitimate [1] 108/23
length [12] 24/1
24/25 79/11 79/12
79/18 80/4 84/8 85/16
85/20 85/23 97/11
97/16
Leonie [3] 63/4 64/2
64/4
less [5] 19/8 27/20
88/18 168/24 187/15
lesson [1] 44/17
lessons [6] 97/12
163/16 164/3 164/5
164/12 165/18
let [7] 32/18 118/15
127/12 128/6 190/6
195/25 196/5
let's [5] 173/23 175/9
leads [2] 118/17
learnt [9] 22/19 46/13}
60/19 60/20 69/7 69/8
87/24 88/4 90/5 90/10
90/18 92/3 93/5 98/15)
140/12 140/14 140/19)
141/11 164/18 164/19}
164/20 164/20 164/23}
letter [28] 26/1 30/1
31/14 31/17 32/4
32/15 32/15 32/17
33/10 33/14 33/15
33/16 33/24 34/2
34/16 34/23 86/7
89/16 89/17 89/20
89/22 131/22 159/3
160/5
letters [10] 29/23
30/19 31/22 31/23
37/7 37/10 37/13
49/24 49/24 195/10
letting [1] 109/2
level [15] 4/24 12/24
13/15 14/17 23/9
levelled [1] 120/16
levels [1] 12/5
liabilities [2] 188/5
189/11
liability [3] 166/5
188/16 188/20
liable [1] 55/11
lid [2] 106/10 106/11
lid’ [1] 103/17
Lidbetter [1] 64/6
lies [1] 188/17
light [2] 56/14 124/11
like [36] 1/23 10/17
11/5 20/4 24/21 27/17)
28/11 33/13 34/14
37/15 46/1 50/10
92/21 111/9 117/18
117/24 118/8 118/11
118/16 118/21 119/15)
122/10 122/24 123/1
134/20 142/5 144/5
150/1 156/19 157/15
162/12 173/6 178/3
178/21 183/20 198/19)
likely [3] 52/16 86/23
149/7
likes [4] 27/9 62/18
134/16 189/25
limit [1] 193/22
limited [4] 72/12
80/13 185/1 185/2
Limited's [2] 119/8
144/14
limitedly [1] 50/14
its [1] 12/24
line [18] 1/19 19/8
23/22 27/13 28/21
38/12 44/11 62/22
64/25 82/19 102/9
106/10 109/1 109/6
142/25 172/23 173/19)
174/20
line 7 [4] 64/25
190/22 196/19 197/17,
30/2 30/13 30/25 31/7
23/25 38/25 39/1 79/5
124/13 134/20 153/16)
161/18 165/25 192/24,
lines [14] 38/10
38/14 38/17 68/6
68/16 81/24 86/13
101/2 101/13 101/15
101/16 118/2 171/3
194/24
link [6] 25/18 43/5
157/1 161/14 162/8
162/10
linked [1] 74/6
Linklaters [2] 8/8
60/9
list [1] 100/3
listed [1] 94/1
listened [1] 163/3
listening [1] 61/10
listing [1] 188/25
litigated [1] 27/5
litigation [38] 25/14
25/15 54/15 55/6
86/15 87/5 88/8 89/21
89/23 90/3 90/9 91/2
94/5 95/16 96/14
97/20 98/2 119/21
156/8 163/21 164/25
165/19 165/24 166/1
166/4 166/24 166/25
167/10 167/23 168/1
171/14 171/16 172/16
172/20 175/8
little [15] 2/5 4/1 28/1
32/20 44/8 46/3 47/17
64/19 68/1 80/9 94/15
104/11 129/25 160/21
178/11
live [1] 20/7
lives [1] 162/14
long [8] 1/14 28/2
104/4 109/5 113/9
122/10 143/13 197/9
longer [3] 41/19
79/11 79/14
longstanding [1]
5/24
look [64] 1/17 12/20
12/23 14/1 23/14
23/15 28/11 29/12
30/13 32/12 32/13
36/1 39/6 44/5 45/19
50/1 50/20 58/4 62/10)
64/24 66/12 66/21
68/6 68/14 68/23 70/6
78/25 81/24 83/20
90/22 91/6 103/18
105/11 112/6 114/5
114/6 123/9 127/25
129/24 133/5 138/14
141/21 144/11 147/15]
147/16 152/18 158/10}
159/7 164/11 170/8
170/17 170/24 172/5
172/6 173/10 174/23
178/21 179/11 181/4
168/16 168/21 170/18)
181/9 181/20 181/21
181/21 191/13
looked [20] 7/22
18/12 25/21 25/22
41/22 42/7 42/10
42/11 64/6 142/16
looking [41] 7/23
25/20 28/22 29/11
30/23 35/7 37/11
45/10 47/24 51/20
52/8 56/22 62/11
62/20 74/15 95/5
99/22 112/8 128/12
163/8 175/20 176/21
185/12 185/23 186/7
188/7 189/23 192/24
195/9
looks [2] 20/4 39/17
Lord [2] 82/19
158/18
Lord Arbuthnot [2]
82/19 158/18
Lords [1] 191/15
lose [1] 54/11
losing [1] 96/8
loss [9] 32/25 32/25
33/1 41/24 43/16
161/14 173/5 182/2
185/16
losses [14] 25/18
54/9 74/7 98/6 104/1
157/2 162/9 175/1
185/6 185/20
lost [3] 189/21
189/22 190/2
lot [15] 9/6 13/8 24/9
29/4 32/5 38/24 40/22,
48/20 48/21 74/2
84/10 103/13 131/3
153/3 188/18
lots [6] 15/11 25/10
80/18 85/10 94/22
99/7
Lovegrove [1]
199/17
low [5] 70/19 74/21
96/11 151/25 187/2
lower [1] 88/15
lowest [2] 70/14
70/14
loyalty [1] 103/10
lunch [1] 127/25
Lyons [1] 196/13
MacLeod [8] 98/8
99/25 100/5 100/17
25/23 26/3 29/5 41/22,
142/24 148/11 154/11
156/25 162/24 189/24)
8/22 11/14 19/12 22/4,
40/10 42/15 43/4 43/6
43/7 43/8 43/12 43/14
40/24 41/5 43/5 43/14
101/9 134/6 136/12
196/16
macro [1] 49/13
made [16] 1/14 19/24
38/13 55/18 100/3
105/3 118/11 121/11
121/20 122/3 124/17
164/14 165/23 178/10)
194/11 197/22
magic [1] 92/12
Magnox [5] 97/11
163/8 163/13 163/15
167/14
Magnox/RSRL [1]
163/13
Mail [14] 6/7 22/8
71/1 187/20 187/24
188/3 188/19 188/21
191/14 191/17 191/25)
Mail's [4] 68/13
main [4] 55/19 93/11
96/23 97/1
maintain [1] 108/13
maintained [3] 61/17
85/20 146/18
maintaining [3]
81/11 87/13 109/6
major [1] 165/14
majority [6] 20/10
20/17 21/21 21/25
144/3 144/7
make [31] 1/23 11/13
12/21 18/1 18/10
18/20 18/24 25/3
35/10 47/14 48/12
71/10 71/13 76/14
78/13 89/2 89/3
103/12 124/21 125/1
135/1 135/3 135/12
135/25 137/19 138/5
138/6 161/12 162/23
165/12 191/21
makes [5] 75/13
115/17 125/22 132/23)
180/25
making [13] 11/8
13/3 47/12 63/6 65/5
107/16 150/20 161/9
174/12 176/23 178/16
190/1 191/23
manage [4] 4/14 82/7
84/6 84/23
managed [12] 46/18
48/3 49/20 50/15 52/4
79/3 79/7 79/21 110/9I
118/4 196/7 196/21
management [5]
67/11 95/6 148/13
148/14 165/13
Manager [1] 173/21
manages [2] 145/20
165/15
managing [4] 82/12
84/4 148/20 197/7
(67) leads - managing
manned [1] 18/11
manoeuvre [2]
132/14 132/16
manoeuvring [3]
many [14] 29/22
119/7 126/5 127/2
130/15 133/10 140/21
142/4 154/14 171/2
171/11 172/16 172/18}
173/12
March [17] 2/23 2/24
3/3 3/8 60/9 66/13
66/16 78/20 90/24
108/6 109/14 129/4
161/13 161/22 167/24}
168/20 189/4
Margot [1] 87/10
mark [21] 32/15
32/16 33/21 45/3
113/16 113/25 124/2
133/19 134/5 134/11
136/12 147/4 172/15
173/14 173/18 173/23)
173/25 196/14 196/15
196/16 197/6
Mark's [1] 145/9
markedly [1] 190/3
market [2] 126/10
151/23
marking [1] 58/22
Marnoch [1] 196/14
material [2] 60/3
164/23
maternity [10] 1/22
2/1 2/3 2/7 116/14
130/2 130/5 130/23
133/9 142/20
matter [29] 11/9
18/15 21/17 36/18
40/13 40/18 79/10
79/18 80/1 80/5 80/7
80/11 80/18 81/8 83/4
83/13 83/17 85/14
85/19 87/7 88/10
97/10 100/11 105/2
110/24 128/11 150/5
153/19 181/25
matters [13] 11/11
17/14 40/15 55/5
55/13 55/14 97/16
100/23 109/3 109/25
111/17 121/17 125/18)
Maureen [1] 54/22
may [46] 1/5 3/10
5/25 19/5 20/6 20/6
28/19 29/8 39/25 44/6
44/10 50/18 51/10
52/4 59/21 60/7 66/10
66/11 68/19 71/18
71/19 74/9 83/2 93/9
95/12 95/13 99/8
129/21 132/22 132/23}
101/6 126/18 128/17
129/20 131/17 132/4
132/9 136/14 138/11
181/24 189/8 194/14
198/4
102/7 141/14
McCausland [1]
196/13
McInnes [1] 190/17
McKelvey [1] 54/22
me [72] 15/24 16/10
17/11 24/21 32/18
33/12 33/20 34/18
36/19 37/17 40/10
43/22 43/22 44/17
75/24 77/16 90/11
93/19 94/11 96/7
107/12 107/22 111/5
116/6 123/20 123/20
124/2 124/16 124/21
127/12 128/5 128/10
128/12 133/24 137/1
137/2 137/12 137/13
140/2 141/17 142/1
142/5 143/14 156/9
163/4 164/7 167/23
168/22 169/5 171/16
172/16 173/5 179/5
181/15 185/8 187/10
190/6 195/25 196/5
mean [52] 16/17 18/5
21/6 23/11 24/10 27/1
39/2 40/20 45/14
49/21 50/10 50/18
51/13 53/8 55/4 56/6
56/7 57/12 58/24 59/9)
60/10 64/9 64/21
64/24 67/3 67/20 69/1
79/9 92/17 94/9 98/14
101/5 102/14 111/21
123/1 127/10 132/16
140/3 144/2 145/5
145/7 152/17 154/3
158/1 171/24 178/9
181/10 191/12
meaning [1] 101/5
meaningful [1]
111/11
means [10] 30/3 54/8
64/15 84/19 84/19
106/15 110/18 111/23)
159/24 178/21
meant [9] 20/7 48/21
71/4 84/12 106/21
121/23 143/11 147/5
148/15
151/17 151/17 157/17)
168/19 168/23 172/18
maybe [4] 24/18 56/6
46/12 55/3 56/7 58/24
125/17 125/21 125/23)
156/15 156/15 157/17,
187/16 188/20 189/24)
27/3 34/18 34/20 35/5
Meanwhile [1]
195/12
measures [3] 120/10
124/12 177/10
media [7] 33/22
43/11 48/16 48/20
153/21 196/9 197/7
mediation [61] 7/21
8/6 9/10 9/14 19/14
32/8 40/22 42/14
59/13 73/24 74/16
7AI17 75/5 75/12
76/13 77/20 78/4
78/21 82/8 83/11
83/13 83/16 83/23
97/19 109/14 109/15
109/22 118/3 118/10
119/15 119/25 131/2
131/18 153/18 156/7
156/10 161/16 161/23
162/25 171/25 172/3
180/5 180/24 181/10
181/18 185/24 187/5
194/4 194/5 195/6
195/15 195/17 195/20}
195/21 195/22 197/2
197/23
mediations [4] 82/21
83/8 97/25 197/23
meet [9] 27/19
101/10 114/22 128/3
128/16 128/19 134/17
135/19 148/6
meeting [31] 13/5
14/25 47/21 82/17
100/5 113/12 113/15
122/8 122/11 134/8
134/8 134/15 134/21
135/5 135/15 136/21
137/25 138/1 138/16
140/17 140/18 141/8
142/13 143/5 151/10
179/14 179/17 179/23
184/1 189/4 190/19
meetings [8] 12/10
17/17 22/20 90/11
130/22 136/2 150/4
198/8
meets [1] 152/16
Melanie [3] 32/14
33/25 170/13
member [7] 16/15
16/15 27/6 29/14 59/1
142/6 183/20
members [12] 16/17
17/4 60/13 60/18
91/24 96/1 108/6
130/7 138/12 142/4
144/16 159/9
memory [1] 50/9
mention [5] 6/19
51/16 51/17 71/16
180/25
25/13 31/4 31/8 31/24
mentioned [14] 8/23
44/12 53/25 69/20
151/9 174/14 190/24
mentor [1] 152/13
mentoring [2] 5/2
120/13
166/25
98/14
mess [1] 105/12
message [5] 30/12
125/7 173/7 173/11
173/22
met [6] 46/9 90/13
133/8 135/10 136/17
146/1
Michael [1] 192/8
micro [1] 49/14
microchips [1] 11/8
microphone [1]
182/16
microphones [2] 2/4
61/9
mid [4] 100/15
mid-2015 [1] 100/15
middle [1] 27/19
might [54] 17/21 18/1
36/3 39/20 40/19 41/1
47/5 50/6 69/19 70/3
71/21 74/24 75/16
77/18 77/19 86/1
89/25 103/5 104/1
113/5 118/8 119/17
120/23 123/3 124/19
125/1 129/9 130/13
130/15 130/16 131/5
131/19 133/10 133/24I
146/3 153/1 155/8
157/21 160/6 169/11
171/15 173/3 173/8
177/23 178/10 183/10
186/5
million [4] 13/19
mind [24] 9/19 10/16
21/12 76/1 76/1 76/1
84/12 94/21 99/2
109/21 114/1 114/3
117/4 122/5 122/15
127/2 157/22 158/25
162/22 171/17 178/23}
180/20 186/4 187/4
minded [1] 192/18
mindful [1] 81/4
mindset [1] 41/13
mine [1] 46/10
minister [63] 18/17
20/5 20/21 34/4 34/5
35/4 35/8 35/14 35/18
36/24 38/6 38/18
71/21 72/8 73/5 106/2
112/24 122/22 144/25}
merit [3] 151/8 160/6
merits [3] 97/4 98/13
18/7 18/22 26/25 35/9)
105/11 108/17 110/19}
83/18 87/10 93/4
100/19 101/14 101/21
101/25 102/3 102/4
102/11 108/8 108/12
108/15 108/21 109/24I
110/19 112/6 114/3
116/1 116/10 116/19
125/11 127/15 128/15)
128/21 130/18 132/11
133/1 133/14 135/3
135/6 135/10 135/20
135/22 136/15 138/3
138/5 138/25 139/19
140/7 140/23 140/24
141/2 142/13 150/7
171/12 172/17 190/22!
191/16 192/1 193/25
minister's [6] 36/10
127/2 134/14 135/4
142/14 196/9
ministerial [5] 19/9
19/25 48/7 79/6
125/18
ministers [57] 8/10
18/1 19/22 20/17 21/2)
21/4 21/13 22/25 24/5I
24/16 24/20 25/2
34/22 46/21 48/15
79/3 79/7 79/16 79/21
80/15 81/6 81/9 83/4
84/7 84/23 85/13
87/11 87/13 93/4
99/21 101/2 102/17
107/17 113/19 117/3
121/11 121/20 122/3
122/15 126/6 127/17
129/21 129/23 132/14)
132/21 134/16 137/2
141/13 152/2 153/21
156/1 161/12 171/4
171/12 172/23 173/8
173/20
ministers’ [2] 82/12
84/5
minute [2] 60/7 172/5I
minutes [6] 122/10
133/25 134/6 169/12
169/21 189/3
miscarriages [1] 7/6
mischaracterised [1]
195/19
misconstruing [1]
164/23
misleading [1] 160/2
misplaced [1] 58/15
missed [2] 159/1
190/1
missing [1] 89/15
misstated [1] 105/3
mistake [4] 105/3
106/17 191/22 191/23)
Misunderstanding [1]
164/22
mitigate [2] 165/4
(68) manned - mitigate
mitigate... [1] 165/20
mitigate/address [1]
165/20
mitigating [2] 84/1
84/2
mitigation [3] 166/22
167/2 167/4
mitigations [2] 68/1
94/1
mix [4] 49/13
mixed [1] 150/18
Mm [15] 3/18 12/11
17/25 48/24 88/7
91/18 95/10 116/5
145/4 169/10 171/7
172/24 174/6 185/21
191/10
Mm-hm [13] 3/18
17/25 48/24 88/7
91/18 95/10 116/5
169/10 171/7 172/24
174/6 185/21 191/10
moaned [1] 197/12
model [1] 111/8
moment [5] 69/17
79/4 103/19 139/17
177/13
Monday [4] 160/4
160/20 199/16 199/23
money [18] 10/12
10/14 10/15 11/9
11/15 11/16 12/21
15/19 16/3 106/20
107/13 124/13 126/14}
126/19 145/9 145/17
146/24 160/21
monitoring [2] 117/9
120/13
month [2] 4/2 100/20
monthly [3] 61/17
61/21 66/12
months [13] 13/9
50/8 62/13 63/8 64/17
91/9 94/22 128/8
131/2 131/9 150/17
156/10 182/12
months’ [1] 26/12
mood [4] 134/3
134/14 135/4 135/13
more [58] 4/22 9/12
10/14 12/18 15/17
18/10 27/11 27/12
27/21 37/22 40/2 40/2
51/5 56/1 57/9 66/1
78/6 80/9 85/12 86/22
88/12 94/20 94/21
94/21 97/5 97/14 99/5
107/11 110/18 115/18}
118/16 119/11 119/16
119/23 122/21 131/4
140/15 141/2 141/18
142/5 144/5 146/5
152/3 152/5 161/9
164/7 165/12 166/13
166/15 169/2 169/5
177/16 187/11 196/2
198/5,
morning [6] 1/3 1/10
60/24 61/5 99/11
133/23
most [6] 37/12
116/14 118/21 126/8
149/7 191/18
Mostly [4] 116/15
mounted [1] 166/9
mouth [1] 61/9
move [15] 2/4 15/22
35/15 39/6 61/8 68/1
76/15 81/22 86/10
90/21 121/24 131/10
133/14 175/9 187/18
moved [4] 51/13
51/17 52/7 66/11
MP [6] 1/21 1/22 1/22
142/19 142/20 142/20)
MPs [1] 43/2
MPST [1] 39/8
MR [63] 1/9 1/10 8/22
17/3 25/20 46/4 48/22
51/10 58/19 61/8
62/16 68/8 75/25
85/10 85/18 86/7
88/20 91/8 97/15
99/21 110/17 113/23
113/24 125/16 129/19)
144/24 145/18 158/20)
160/8 160/10 169/3
169/7 169/23 169/24
170/2 170/10 170/25
171/1 171/9 172/21
172/25 173/10 174/11
174/20 177/3 177/15
178/25 179/3 179/4
182/20 183/24 184/13)
184/19 184/20 189/2
195/5 198/2 198/6
199/9 199/11 200/3
200/5 200/6
Mr Bates [1] 160/10
Mr Batten's [1] 68/8
MR BEER [5] 1/9
75/25 177/15 199/9
200/3
Mr Bourke [1] 1714/1
Mr Callard [27] 1/10
8/22 17/3 25/20 51/10
61/8 85/18 88/20
97/15 99/21 110/17
125/16 129/19 145/18)
169/7 170/2 170/10
171/9 172/21 173/10
174/11 174/20 177/3
178/25 183/24 195/5
199/11
Mr Clarke's [1] 58/19
147/23 151/11 151/23)
Mr Cooper [2] 91/8
169/3
Mr Davies [2] 170/25
172/25
Mr Day [2] 113/23
113/24
Mr Hayward [1]
48/22
Mr Hayward's [1]
46/4
Mr Henry [6] 169/24
184/19 184/20 198/2
198/6 200/6
179/3 184/13
Mr James [1] 160/8
Mr Jenkins' [1] 62/16
Mr O'Sullivan [1]
189/2
Mr Parker's [3] 85/10
86/7 158/20
Mr Russell [1]
144/24
Mr Warmington [1]
182/20
Mrs [2] 170/5 197/14
Mrs Hamilton [1]
170/5
Mrs Perkins’ [1]
197/14
Ms [18] 30/10 47/6
117/22 126/23 128/1
128/2 133/18 141/25
144/4 147/12 152/9
161/3 161/8 169/23
170/1 171/1 197/16
200/4
Ms Crowe [1] 30/10
Ms Hamilton [1]
161/8
Ms O'Farrell [1]
133/18
Ms Patrick [1]
169/23
Ms Swinson [1]
128/2
Ms Swinson's [1]
128/1
Ms Thompson [2]
171/1 197/16
Ms Vennells [4]
117/22 144/4 147/12
152/9
Ms Vennells' [3] 47/6
126/23 141/25
much [33] 1/5 2/5
25/1 25/2 28/19 30/21
61/1 69/15 76/12
88/20 89/5 89/19
94/17 94/21 94/21
96/14 118/15 129/12
134/4 135/23 137/17
138/9 146/3 167/25
169/6 169/14 176/10
Mr Jacobs [3] 169/23
181/7 187/11 196/8
197/14 198/2 199/7
multiple [1] 92/18
multiples [1] 126/18
must [3] 119/9
166/22 193/12
mutual [1] 178/16
mutualisation [9]
18/25 103/13 175/17
178/9 178/12 178/13
178/20 178/21 178/23}
my [121] 1/10 4/15
4/16 6/16 6/18 7/13
9/19 15/6 16/19 17/11
18/16 21/16 22/6 23/5
23/17 24/24 25/13
27/11 27/20 27/25
28/21 31/1 31/2 32/7
34/11 34/15 39/16
39/24 41/24 41/25
44/20 54/8 54/11
56/13 59/17 66/25
73/7 75/12 76/8 78/22,
81/4 81/5 88/3 88/12
89/23 90/11 94/18
95/23 97/3 98/4 98/5
98/13 98/15 98/25
99/1 99/4 102/13
102/16 102/16 102/20}
102/20 104/5 107/3
108/3 108/3 108/23
109/5 109/21 113/16
114/10 114/10 114/12)
117/1 123/25 123/25
124/20 125/7 125/17
127/20 129/1 133/5
136/6 136/8 137/6
137/19 137/25 138/3
141/24 142/1 143/18
145/6 152/17 152/18
152/24 153/4 153/7
153/22 155/17 155/25]
156/5 157/20 158/11
158/12 161/2 162/5
164/6 168/3 170/2
175/7 178/1 178/23
180/20 181/10 183/4
184/9 186/4 187/4
189/12 194/25 196/5
199/18
myself [6] 15/13
15/14 16/9 134/10
174/18 191/18
mystery [1] 158/9
N
name [6] 1/10 1/12
68/8 91/17 163/3
170/2
namely [5] 77/12
95/6 95/12 141/19
153/8
names [1] 54/22
narrow [2] 75/12
772
natural [1] 24/15
naturally [1] 105/8
nature [9] 48/6 48/11
72/13 76/19 87/24
88/4 97/17 140/11
194/4
NDA [3] 17/10 166/41
166/23
NDAs [2] 17/8 17/13
nearer [1] 96/4
necessarily [12]
14/22 18/2 21/20
34/12 37/12 101/3
146/2 146/20 146/24
150/14 151/16 156/12!
necessary [2] 101/24)
140/21
NED [39] 3/6 3/17
3/24 5/4 6/21 8/18
9/19 9/20 15/4 16/18
17/18 17/24 18/5
18/12 18/15 20/2
20/13 20/24 22/19
34/25 47/25 51/17
57/23 59/20 102/15
102/19 120/14 122/24I
123/1 123/3 133/2
136/4 142/5 144/5
162/21 176/12 184/25)
187/19 189/20
NED's [1] 5/16
NED-like [2] 122/24
123/1
NEDs [5] 143/22
150/3 150/5 151/5
151/11
need [31] 3/21 8/3
13/19 18/17 18/19
18/19 19/25 21/7
26/23 32/18 33/18
44/17 44/20 47/14
53/6 80/14 82/19
114/21 115/5 115/19
119/9 119/10 119/11
130/16 133/10 146/3
160/20 164/2 179/10
180/22 193/19
needed [14] 8/15
13/12 13/13 27/7
102/21 102/22 121/15)
131/1 137/14 155/9
155/11 157/3 183/16
193/19
needn't [1] 74/11
needs [10] 13/17
26/24 27/5 30/5 34/6
115/9 132/3 132/3
140/6 155/3
negative [2] 26/21
93/9
Neil [2] 45/21 196/13
Network [4] 48/17
105/5 150/13 178/5
(69) mitigate... - Network
N
neutral [1] 10/11
never [22] 6/8 16/6
21/1 21/7 21/12 21/18
25/7 25/8 26/22 27/19
58/15 96/25 98/10
111/21 111/23 112/3
146/6 146/16 158/13
160/1 185/2 185/5
nevertheless [3]
73/20 154/12 181/13
Neville [23] 28/16
82/16 82/18 85/2
100/10 100/16 100/23}
101/6 101/10 104/21
105/8 106/16 107/7
133/22 134/3 134/23
135/17 137/21 138/21
139/2 139/8 139/9
190/20
Neville-Rolfe [22]
28/16 82/16 82/18
85/2 100/10 100/16
100/23 101/6 101/10
104/21 105/8 106/16
107/7 133/22 134/23
135/17 137/21 138/21
139/2 139/8 139/9
190/20
Neville-Rolfe's [1]
134/3
new [22] 4/5 5/7 6/7
6/9 58/2 58/4 74/6
83/2 91/21 91/23
95/20 98/7 104/6
114/2 115/6 120/7
123/21 126/14 135/18}
149/25 152/25 198/14
news [4] 24/8 24/14
25/16 82/20
next [9] 1/20 13/9
15/22 47/11 47/21
70/6 126/19 153/5
160/12
nice [1] 160/23
Nichola [1] 54/23
night [1] 62/21
nine [1] 182/12
no [119] 3/21 3/23
4/13 4/25 6/24 8/19
14/2 17/6 17/10 17/15)
18/19 18/20 20/6
20/19 21/1 22/6 23/5
30/21 31/20 31/23
35/1 35/3 35/5 37/12
37/18 41/8 48/14 50/7
51/9 53/11 53/22 54/6
54/18 54/24 55/21
65/17 65/24 66/4
68/22 71/16 71/21
71/24 71/25 72/14
73/9 73/14 73/19
76/10 76/10 77/16
78/15 79/17 81/14
82/20 84/18 86/3
87/16 89/9 90/20
92/13 95/19 96/13
96/24 101/3 101/5
101/6 101/22 102/16
107/8 107/14 110/6
110/6 110/21 112/5
119/22 123/25 125/3
133/3 136/11 138/13
139/21 139/22 141/11
152/9 154/17 155/22
156/23 163/16 164/2
171/23 173/4 173/14
180/7 180/13 180/16
180/25 181/2 181/12
185/10 189/12 190/11
191/23 194/3 198/12
nobody [2] 86/4
195/14
nodding [1] 175/18
noise [3] 84/5 84/12
85/11
nominating [1]
167/22
non [22] 3/2 3/17
3/23 4/11 4/17 5/7
5/15 6/11 11/20 11/20
12/16 17/9 36/17
118/16 121/18 122/7
132/17 152/14 179/21
183/19 183/24 190/12,
non-disclosure [1]
17/19
Non-Exec [2] 3/2
11/20
Non-Executive [7]
4I17 5/15 118/16
179/21 183/19 183/24)
190/12
non-executives [2]
121/18 152/14
non-provision [1]
132/17
non-speaking [1]
122/7
none [2] 98/2 151/7
noon [2] 199/16
199/22
norm [1] 186/23
normal [3] 30/18
174/2 186/23
not [229]
note [20] 39/17 47/7
58/9 112/24 113/8
114/8 114/10 122/7
123/14 124/2 124/17
124/18 124/21 125/15)
126/24 127/11 127/11
102/20 103/23 105/17)
116/12 116/16 116/22
141/15 141/17 151/25)
174/23 175/19 176/13)
178/12 178/20 178/25)
142/12 143/20 151/9
notes [1] 148/3
nothing [5] 5/5 95/20
145/23 174/15 188/7
notice [4] 44/13
44/14 45/3 113/22
noticed [1] 65/13
n
notify [1] 90/10
noting [1] 4/3
November [7] 56/5
93/11 131/20 168/17
170/19 171/25 174/1
[1] 131/20
now [40] 9/11 10/25
43/10 56/12 62/15
62/23 69/19 72/10
76/21 78/2 79/6 82/21
93/14 94/22 95/5
104/9 116/18 117/21
123/17 128/25 129/9
133/12 144/12 150/1
150/17 157/15 169/11
170/9 171/16 179/11
180/9 188/23
nowhere [2] 27/23
189/6
nuanced [1] 57/10
nuances [2] 56/9
58/7
Nuclear [3] 163/18
164/24 165/8
number [17] 4/23
13/6 13/21 14/2 14/23
14/25 45/3 49/5 64/17I
68/7 110/8 117/12
119/13 170/3 179/7
182/17 185/18
number 1 [2] 14/23
45/3
number 11 [1] 68/7
numbered [2] 68/17
7113
numerous [2] 154/2
154/4
(e)
O'Farrell [1] 133/18
O'Sullivan [1] 189/2
objected [3] 113/21
124/15 124/5
objection [1] 18/20
objectionable [1]
124/8
objective [3] 127/23
137/3 150/12
objectivity [4] 189/21
189/22 190/2 190/3
oblivious [4] 145/15
145/19 147/3 147/6
observed [3] 58/25
ication [1] 166/3
November/December
15/8 15/13 25/21 36/4
83/11 86/1 87/1 87/18
186/15 198/13
observing [1] 167/21
obtain [1] 115/19
obtained [1] 59/19
obtaining [1] 44/4
obvious [1] 53/6
obviously [11] 24/14
105/20 114/2 143/18
145/11 177/1 192/8
occasion [9] 9/1
13/25 14/1 17/5 21/5
76/22 107/15 133/4
137/9
occasionally [1]
134/17
occasions [3] 6/25
14/11 38/22
occur [3] 56/4 185/8
186/17
occurred [3] 58/24
185/2 185/5
occurrence [1]
197/11
occurring [1] 75/23
October [9] 65/4
66/17 66/18 74/2
78/17 163/10 164/5
167/6 167/19
odd [4] 6/6 51/10
182/4 195/7
Odgers [1] 140/16
off [19] 28/21 36/4
45/21 47/22 97/10
111/5 120/16 135/9
135/11 146/11 146/12)
147/7 148/24 149/3
149/16 160/4 186/5
197/3 197/5
offer [1] 83/14
offhand [1] 108/14
office [265]
Office's [10] 7/19
11/2 12/3 12/15 45/6
55/19 57/24 126/20
137/4 150/11
offices [3] 48/18
90/14 127/21
official [3] 125/16
138/22 140/8
officials [3] 125/17
139/12 139/13
often [14] 13/23
28/10 34/9 34/10
43/10 44/21 69/14
69/22 69/23 79/17
117/1 141/13 153/20
191/16
Oh [14] 23/15 24/12
37/12 42/14 50/10
56/2 92/8 98/10 131/1
141/11 168/19 174/2
180/19 187/13
oil [1] 11/8
28/25 65/16 80/7 99/3,
okay [24] 15/21 28/4
30/24 31/19 37/16
37/21 46/7 54/2 56/6
87/25 107/23 113/3
115/14 138/20 168/19}
169/22 171/20 172/22)
175/4 175/9 179/25
188/22 192/16 198/25]
old [1] 6/6
omissions [2] 72/9
7212
omit [1] 191/8
on [333]
on’ [1] 166/24
once [6] 109/6 133/8
1714/5 172/9 172/19
178/14
one [84] 2/16 6/13
8/17 9/19 11/18 12/2
13/4 13/10 14/2 22/6
24/7 28/21 29/23
29/24 33/11 33/25
41/16 41/16 42/22
42/23 42/24 43/20
54/1 57/13 61/13 63/3I
65/1 65/2 66/13 66/14
68/18 68/24 69/2
70/14 84/21 86/3
94/11 98/16 104/10
106/19 107/2 107/2
107/3 107/10 108/5
108/24 110/18 111/9
119/17 123/15 125/16)
126/8 128/11 130/22
135/19 136/5 142/16
142/16 143/23 144/8
147/24 149/16 151/15)
151/25 152/14 153/17I
155/18 156/23 157/11
157/20 158/9 158/11
166/13 166/15 170/6
171/10 173/4 178/13
186/5 188/19 196/25
198/4 198/5 198/7
one-line [1] 28/21
one-off [1] 186/5
ones [2] 96/23 159/5
ongoing [6] 8/5
52/14 67/11 86/17
87/14 156/10
online [1] 61/10
only [20] 6/6 15/12
19/16 32/5 40/13
41/16 50/3 65/10 71/8
115/8 133/8 134/17
141/5 148/18 149/24
169/6 178/14 193/3
193/4 196/1
onto [1] 78/13
onwards [1] 123/10
Ooh [1] 96/4
open [4] 11/3 52/13
52/13 52/14
Opening [1] 114/13
(70) neutral - Opening
[e)
operate [7] 11/5
52/19 53/14 53/16
123/4 158/24 183/3
operating [1] 175/11
operation [3] 31/12
54/21 77/14
operational [21] 24/3
36/17 38/8 40/17
79/10 79/18 80/5 80/6
80/11 80/18 81/8 83/4
85/14 97/17 109/3
109/6 109/25 110/24
111/17 128/5 128/11
operationally [2]
24/18 24/18
opined [2] 114/4
126/7
opinion [4] 97/4
166/14 166/15 188/12)
opinions [2] 166/18
168/4
opportunity [7] 30/13}
67/13 67/16 135/15
135/18 138/2 165/2
opposed [2] 4/24
160/17
optimism [1] 131/19
option [2] 69/8 69/11
options [3] 19/19
84/8 148/2
or [173] 4/10 5/1 5/23
5/25 6/12 7/2 7/9 8/16
8/24 9/7 11/1 11/8
11/17 12/22 14/23
16/14 17/3 17/4 17/18)
19/5 19/25 21/9 21/16
24/20 30/17 31/3
31/17 31/17 33/11
35/10 36/21 36/22
37/4 37/6 38/19 38/25
39/12 43/6 43/20
46/18 47/19 48/10
48/12 49/12 49/24
50/15 55/4 56/17
56/23 57/9 57/10
59/20 62/13 63/11
68/5 68/9 70/14 71/4
TAI17 72/2 74/9 75/7
75/21 76/1 76/1 78/17,
79/20 80/7 80/22 81/1
81/7 81/13 82/11 84/7
84/23 85/5 85/21
86/15 86/16 86/22
88/25 88/25 92/12
94/23 97/1 97/19
97/23 97/25 99/5
101/20 102/17 102/23)
107/6 107/17 107/17
110/12 111/1 116/20
118/19 119/19 120/2
122/10 123/18 127/2
128/13 128/19 129/20
130/22 131/11 132/17,
132/22 133/8 134/10
136/4 136/12 136/12
138/10 139/3 140/23
143/14 144/3 144/7
144/16 145/23 146/17)
147/25 148/9 148/24
149/2 149/3 149/4
151/7 151/16 151/20
153/9 153/18 154/6
155/2 156/7 158/8
158/10 158/15 159/5
159/21 161/16 168/12)
168/12 175/19 176/25)
177/5 178/21 179/16
181/5 181/25 182/14
185/15 185/17 185/17)
185/17 188/12 189/7
190/14 192/11 194/10)
194/12 197/8 197/15
197/15 198/4 198/7
198/10 198/19 198/21
order [4] 51/2 62/7
113/10 114/12
ordinarily [1] 10/3
ordinary [1] 177/22
organisation [8] 3/13
5/24 5/25 69/20 69/24
70/1 140/9 146/22
original [2] 159/23
170/19
Orme [1] 145/10
other [47] 4/2 5/5
9/23 12/3 12/22 16/12
17/3 24/1 31/16 32/12
42/8 45/9 48/13 70/23
71/11 74/18 75/17
92/21 99/7 100/23
107/11 107/12 108/6
123/3 127/19 134/17
135/19 136/4 136/7
136/8 137/2 137/18
137/19 138/12 140/22)
143/22 149/19 150/3
151/13 153/19 157/22)
166/1 174/7 174/18
177/11 178/3 196/3
others [8] 17/12
27/16 46/5 60/15
115/13 162/12 171/19)
172/14
otherwise [7] 11/4
11/4 11/16 22/23
71/17 127/8 136/2
ought [9] 6/13 53/6
69/11 98/23 120/1
162/21 168/11 188/14)
188/23
oughtn't [1] 66/13
our [33] 13/8 15/22
37/12 38/14 44/21
44/24 49/14 60/19
60/24 70/21 71/13
77/21 79/17 79/19
79/23 80/10 85/13
89/22 90/14 94/21
101/15 103/21 113/10
126/9 130/12 146/12
147/25 148/23 151/5
176/25 191/15 192/21
195/12
out [41] 6/6 28/13
30/19 31/9 32/7 33/7
47/16 50/8 50/9 50/12
50/14 52/3 53/9 54/11
56/23 56/24 57/18
65/17 66/18 68/5
74/16 74/20 75/23
77/19 80/4 80/12
81/18 88/12 96/15
98/11 99/9 139/3
142/12 146/23 149/10
150/2 151/18 151/18
151/22 161/8 190/20
outcome [5] 59/6
91/2 94/5 148/7
158/25
outside [13] 20/18
20/24 21/4 21/6 21/14
29/10 60/5 138/22
139/10 139/21 140/8
141/10 141/12
outsider [1] 123/1
outward [1] 56/3
outward-facing [1]
56/3
over [42] 6/20 8/22
10/18 13/8 18/11 40/9
41/18 41/19 43/21
44/9 45/10 45/12
47/25 50/23 68/15
73/3 78/23 79/13
91/19 91/21 95/17
114/18 115/7 116/17
117/23 119/4 120/22
121/10 122/19 126/19}
131/2 133/25 141/20
143/21 150/16 164/15}
168/25 186/23 187/6
187/8 187/9 192/3
over-manned [1]
18/11
over-reliant [1] 45/12
overall [2] 14/15
70/13
overarching [4]
103/21 104/2 104/4
104/10
overlay [1] 9/21
overly [3] 142/5
144/4 159/19
overreliant [2] 45/13
45/14
overruled [2] 111/5
112/3
overrun [2] 106/20
107/13
overruns [1] 178/5
oversaw [1] 49/20
oversight [8] 5/17
48/12 67/10 111/10
111/22 119/17 128/14}
165/25
overturned [1] 170/5
overview [1] 180/23
overwhelming [3]
4/6 4/22 49/5
own [12] 9/20 58/22
61/22 61/23 101/15
101/25 118/19 143/18
153/7 165/9 185/20
199/4
owned [3] 10/5
152/22 177/7
owner [3] 68/9 77/8
184/3
owns [1] 10/11
Po
pace [2] 119/12
122/19
pace’ [1] 117/17
pack [2] 81/18 94/18
packs [1] 20/20
page [48] 1/17 1/19
1/20 2/9 23/16 23/17
23/18 28/15 29/12
30/9 32/13 39/7 40/5
45/19 47/6 50/20
50/22 50/22 50/23
51/16 65/12 65/20
65/21 65/25 68/15
99/23 102/8 107/22
107/24 108/2 114/6
119/4 120/22 121/10
122/22 123/10 128/1
133/15 135/16 141/23}
150/16 153/13 164/11
164/15 164/16 165/18
170/12 170/21
page 1 [4] 29/12 47/6
65/12 170/21
page 173 [1] 2/9
page 2 [4] 50/22
68/15 133/15 170/12
page 23 [2] 1/17
141/23
page 25 [1] 165/18
page 26 [1] 164/11
page 3 [2] 50/20
50/22
page 34 [1] 102/8
page 35 [4] 23/16
23/17 23/18 153/13
page 36 [3] 107/22
107/24 108/2
page 5 [1] 99/23
page 52 [1] 128/1
pages [2] 1/14 20/20
Palmer [1] 54/22
panned [1] 146/22
Pannell [1] 184/22
Panorama [2] 28/12
156/21
paper [9] 21/11 58/3
59/3 59/14 128/24
198/12 198/14 198/15}
198/21
papers [8] 16/23
17/11 21/3 21/6 21/20
22/21 25/22 26/15
paragraph [35] 10/1
17/16 20/9 23/7 23/12
23/14 23/19 30/2 44/9
47/11 90/22 102/7
102/9 104/19 105/14
105/23 106/1 106/8
106/10 107/25 108/2
123/10 125/14 128/2
136/24 141/22 141/23)
143/4 149/9 153/12
164/2 179/10 180/3
184/6 193/15
paragraph 102 [1]
136/24
paragraph 128 [1]
128/2
paragraph 156 [1]
179/10
Paragraph 2 [1]
149/9
paragraph 307 [1]
164/2
paragraph 325 [1]
90/22
paragraph 39 [1]
10/1
paragraph 42 [1]
17/16
paragraph 45 [1]
123/10
paragraph 46 [1]
125/14
paragraph 49 [2]
141/22 141/23
paragraph 67 [2]
102/7 102/9
paragraph 69 [2]
23/7 153/12
paragraph 70 [2]
107/25 108/2
paragraphs [5] 3/20
11/24 47/18 58/10
123/11
paragraphs 10 [1]
11/24
paragraphs 273 [1]
58/10
paragraphs 45 [1]
123/11
paragraphs 8 [1]
3/20
parallel [3] 91/10
91/11 167/21
Parker [18] 25/14
25/23 60/15 82/11
(71) operate - Parker
Pp
90/1 104/18 156/7
158/17 159/3 186/10
Parker's [3] 85/10
86/7 158/20
Parliament [6] 11/13
36/23 48/16 77/2
153/20 196/22
Parliamentary [7]
19/23 36/14 48/20
80/19 84/15 110/8
197/7
part [42] 4/19 5/11
28/14 33/7 42/14
81/18 88/9 102/13
103/1 105/5 108/16
110/6 110/25 116/7
122/17 152/2 155/17
155/25 156/20 157/6
187/24 190/10 197/3
197/20
Part Two [1] 156/20
Participants [1]
169/9
particular [26] 4/7
5/16 6/10 13/4 14/13
15/14 20/8 25/16
32/10 36/20 41/20
49/11 92/14 109/11
132/7 136/11 144/4
148/19 158/2 162/8
186/1 186/2
particularly [22] 5/3
5/6 8/15 12/12 16/17
19/23 22/6 22/8 22/10}
24/7 24/16 25/15
25/17 50/7 50/11
95/20 98/20 100/25
103/24 118/21 141/15)
187/16
parties [1] 27/5
partly [2] 46/21 94/12
parts [1] 12/10
party [3] 27/23
134/19 190/11
passage [2] 86/3
128/1
passed [2] 51/21
52/4
passive [2] 142/5
144/4
past [5] 37/13 58/16
59/13 60/24 72/25
patched [1] 90/14
Parker... [14] 83/6
85/8 89/16 89/22 90/1
157/24 158/15 158/15)
6/17 10/23 16/18 25/6
44/14 44/20 46/7 50/1
54/21 56/9 57/13 65/1
102/14 102/16 102/21
163/24 170/25 187/20)
41/23 44/2 49/8 49/10
paternity [1] 4/3
path [5] 7/13 156/1
157/21 158/5 158/7
Patrick [6] 35/16
169/23 170/1 170/3
193/12 200/4
Paula [33] 46/5 77/1
100/1 101/9 115/3
120/13 120/15 121/4
133/22 133/24 134/8
134/9 134/16 134/22
135/4 136/13 141/20
145/1 145/11 151/14
151/23 152/2 152/5
191/5
Paula's [1] 120/24
Paula/Al [1] 191/5
pause [3] 172/5
173/21 179/16
pay [14] 106/25
122/3 124/4 125/7
125/22 126/4 126/6
126/7 126/15 126/16
151/25
paying [4] 10/15
paymaster [1] 183/6
paymasters [1]
182/24
payment [7] 113/22
121/23 122/4 124/6
124/6 124/7 126/16
peas [1] 191/20
peers [2] 149/17
149/20
pen [1] 193/13
49/10 188/8
pensions [6] 22/1
22/1 22/3 22/7 22/7
22/11
penultimate [1]
193/15
Penultimately [1]
166/21
people [44] 4/8 5/5
7/4 7/5 7/6 19/16 23/5
27/14 39/12 42/15
45/24 46/1 50/6 55/17
67/5 69/6 72/3 84/21
89/3 94/18 96/4
110/13 118/25 136/2
136/21 137/18 140/20)
140/22 152/3 152/4
154/7 154/21 155/16
176/23 176/24 177/8
177/22 181/22 186/10)
187/14 191/18 191/19)
196/2 196/4
people's [2] 21/18
115/12 116/12 116/21
117/11 118/15 119/19)
122/18 125/24 133/18)
120/20 120/24 121/23)
120/18 183/14 183/18)
pension [4] 19/2 22/5)
41/21
4/19 156/13 186/25
per se [1] 156/13
perceive [3] 17/4
31/14 70/23
perceived [10] 12/1
12/14 28/20 30/7
70/24 70/25 71/11
72/1 86/18 88/14
percentage [2]
186/12 186/25
perception [4] 72/5
78/22 153/9 156/3
perfectly [1] 173/10
perform [2] 40/6
153/2
performance [10]
115/7 117/14 120/11
176/16
performed [3] 3/16
45/25 121/25
performing [2] 34/24
120/19
perhaps [15] 20/3
64/19 81/2 89/24
94/15 97/22 104/22
106/17 135/11 137/11
173/2 184/11
period [1] 78/23
periodically [4] 8/7
18/9 85/6 85/7
Perkins [12] 47/8
113/2 123/19 124/21
125/1 125/12 142/14
143/4 143/7 150/20
179/18 196/12
Perkins’ [1] 197/14
Permanent [4] 93/2
93/12 101/20 141/3
permanently [1] 2/24
permission [1]
123/21
person [18] 16/21
40/10 61/25 63/3
63/19 63/21 64/1 64/7
68/10 88/23 110/14
112/22 114/15 116/19]
138/19 140/15 146/25}
152/25
personal [1] 194/6
personally [4] 12/8
57/3 118/6 121/13
perspective [6] 9/21
9/22 73/7 99/4 153/23)
195/12
persuade [5] 122/4
124/3 125/21 132/17
152/2
persuasive [1]
per [9] 4/14 4/15 4/16I
187/11 187/15 198/22
125/25 126/23 143/24
150/18 151/16 151/17
141/17 145/14 162/12
124/22
pertains [1] 88/4
pervade [1] 41/13
40/9 44/6 130/10
130/10 133/7
phase [1] 47/13
phased [1] 53/11
133/25
phoning [1] 140/1
phrase [1] 135/11
pick [2] 15/15 44/24
picked [3] 5/4 47/19
161/15
picture [2] 134/24
194/2
pitch [2] 127/13
127/22
place [32] 35/23
64/24 66/5 66/13
91/9 92/25 96/2
131/15 131/21 132/6
132/7 132/12 133/1
150/17 150/21 152/5
167/11 168/1 178/20
111/24
placing [1] 51/11
plainly [1] 184/4
plan [3] 49/7 115/21
150/11
planned [1] 141/8
planning [1] 114/11
plans [4] 52/16 52/17
82/20 130/4
play [2] 31/9 103/24
plea [3] 155/4 155/13
155/13
plead [3] 155/2
155/16 155/18
pleaded [2] 154/21
154/25
pleas [1] 154/15
please [86] 1/6 1/12
1/17 1/25 2/9 2/17
12/15 29/11 29/12
29/22 33/21 35/15
39/6 39/8 45/19 45/20
46/2 46/15 47/6 47/17
50/1 50/20 50/21
50/22 60/24 61/9
62/10 66/2 68/6 76/15
76/17 81/22 81/24
84/1 86/10 86/12
86/13 91/6 91/16
99/12 99/22 99/23
99/24 102/8 104/17
112/6 113/14 114/5
119/4 121/9 123/10
Peter [7] 29/13 29/14
phone [3] 49/3 49/16
80/12 85/6 88/20 89/5)
115/15 117/11 120/10)
124/12 130/16 130/18}
130/25 131/10 131/14}
placed [3] 12/8 79/19
125/14 129/23 129/25]
130/6 130/10 133/7
133/16 133/16 134/5
138/14 141/21 141/22)
141/23 144/11 144/12!
144/18 149/9 153/13
159/7 159/8 164/11
164/13 164/15 165/6
165/18 170/13 172/15}
179/16 179/25 180/1
189/2 191/11 193/8
193/9 193/14
plenty [3] 16/1 16/7
66/25
plight [1] 162/4
plus [3] 74/14 138/24
152/21
pm [7] 99/15 99/17
129/13 129/15 169/15}
169/17 199/21
pod [1] 191/21
point [65] 6/22 8/1
22/6 22/9 26/18 30/17
31/1 42/1 42/4 43/3
63/6 64/1 65/5 70/22
87/11 89/13 94/13
97/8 98/17 98/25
109/9 115/9 116/21
117/8 117/23 118/4
119/14 119/18 120/4
120/25 121/2 121/3
122/5 130/21 130/23
134/25 137/17 152/13)
152/18 153/2 153/22
155/15 156/11 159/4
161/9 164/16 166/7
166/12 173/4 174/13
178/22 182/11 184/8
184/9 187/18 190/14
190/23 191/13 192/3
192/12 192/23 194/7
197/4 197/4 197/25
pointed [1] 117/11
pointing [1] 65/17
points [13] 30/14
31/2 93/5 123/18
124/21 125/1 156/21
160/4 165/6 191/9
192/19 194/11 196/25]
POL [2] 154/9 159/24
POL00022120 [1]
180/25
POL00065473 [1]
99/22
POL00100581 [1]
29/11
POL00138251 [1]
179/12
POL00158108 [1]
45/19
POL00162786 [1]
170/8
polarised [1] 110/13
policies [1] 140/6
(72) Parker... - policies
P
58/5 125/22 126/4
199/5
political [4] 18/18
48/5 48/9 152/23
politically [3] 18/14
46/16 48/15
populate [1] 67/6
populating [1] 67/6
portfolio [3] 133/11
147/25 148/8
portray [1] 160/1
portrayed [1] 166/24
pose [2] 72/1 72/2
posed [3] 80/24
80/25 81/12
posing [1] 12/5
position [52] 7/15
9/13 9/14 11/21 12/8
19/9 23/13 24/12
27/25 54/5 73/17
80/10 80/16 80/21
81/9 83/3 84/8 85/13
85/16 86/8 87/13
88/10 89/24 90/3 97/8
110/24 111/1 111/2
111/4 115/12 121/18
122/13 125/19 126/2
131/11 131/11 132/15}
134/3 134/14 135/5
135/13 136/9 136/16
148/23 151/2 151/5
151/20 152/18 155/24
162/11 178/1 195/23
Positively [1] 191/12
possession [1] 54/14
possibility [4] 71/17
74/8 74/11 96/10
possible [9] 14/18
32/8 127/14 128/5
134/9 134/18 178/8
178/10 178/10
possibly [16] 27/1
35/11 67/6 78/24 94/9
105/11 112/5 131/13
139/25 146/8 146/8
146/14 147/23 148/13)
162/5 163/25
post [251]
posted [1] 39/23
postmasters [3]
73/25 192/10 192/18
postmasters' [1]
188/13
postmistresses [1]
179/8
potential [13] 11/23
11/25 12/7 16/14 17/4)
46/20 75/17 84/16
policy [9] 52/20 58/2
139/11 139/12 198/15]
politeness [1] 197/15)
politicians [1] 177/23
86/21 113/7 124/24
177/22 181/17
potentially [5] 52/22
108/18 109/8 158/25
177/19
power [1] 32/25
practical [2] 49/2
49/3
practically [1] 49/4
practice [1] 37/24
pre [4] 34/21 181/15
188/14 188/24
pre-dates [1] 181/15
pre-empt [1] 34/21
pre-flotation [2]
188/14 188/24
preceded [1] 156/9
predecessor [1]
16/19
predecessors [1]
109/5
predicated [1]
182/21
Pregnant [1] 116/9
preparation [1]
101/11
prepared [4] 28/15
85/15 121/23 142/12
prepares [1] 170/18
preparing [6] 84/7
93/8 93/11 113/15
143/6 174/16
present [5] 57/17
122/6 123/5 138/4
142/7
presented [5] 149/19
149/20 156/14 189/8
189/24
presenting [3]
118/25 148/21 148/22)
presents [1] 149/16
press [5] 44/13 44/14
45/3 93/9 170/14
pressure [5] 40/16
40/18 46/23 78/6
155/18
pressured [1] 155/16
presumably [5]
39/14 51/2 87/19 92/5
157/22
presumption [2]
195/22 197/23
pretty [7] 6/9 29/5
121/22 127/17 128/4
135/18 184/12
prevail [1] 141/4
prevailing [1] 141/6
preventing [1]
102/11
previous [6] 54/19
77/12 91/23 92/1
174/13 174/14
previously [3] 4/7
43/16 92/1
primarily [3] 117/16
176/15 188/9
primary [3] 60/3
80/23 176/19
Prime [1] 196/9
principal [1] 182/22
Principle [3] 52/18
52/19 52/25
principles [2] 51/24
53/12
printed [1] 68/15
prior [10] 4/25 24/2
40/9 64/5 78/1 97/9
98/16 113/12 182/12
187/18
priorities [4] 11/22
130/12 130/13 133/7
priority [1] 14/23
private [23] 10/9
39/11 39/15 112/21
125/4 125/8 126/10
127/5 127/8 127/14
127/16 127/21 130/1
138/19 138/20 140/1
140/25 159/16 160/12
194/14
privately [1] 193/20
privileged [1] 60/10
pro [1] 193/15
pro-penultimate [1]
193/15
proactive [2] 97/5
97/14
proactively [2] 84/4
12114
probabilities [1]
41/11
probability [5] 70/10
74/21 75/22 82/5
92/20
probable [1] 93/24
probably [38] 8/20
9/11 15/3 26/10 27/10
28/7 35/10 40/13
41/10 41/18 46/17
47/5 54/7 57/12 63/8
63/23 66/15 74/13
74/22 76/24 77/20
91/24 96/5 107/19
108/24 122/8 122/12
125/5 130/22 140/20
141/18 151/4 158/11
159/13 160/3 169/5
182/25 191/2
probed [1] 156/18
probing [2] 9/12
38/25
problem [19] 12/5
25/9 26/13 26/21
27/15 27/18 28/25
40/23 41/22 98/18
105/18 132/1 154/1
155/23 181/5 181/14
112/22 124/20 124/25)
182/1 182/7 186/6
problems [17] 9/9
36/5 41/8 44/2 62/16
73/14 94/8 119/24
131/4 153/9 157/7
180/8 180/14 181/2
181/9 181/20 181/24
procedural [5] 16/24
94/16 94/23 94/23
94/24
proceeding [1] 19/15
proceedings [3]
153/19 154/2 154/5
process [6] 30/4
30/17 88/13 88/16
96/19 165/13
processes [1] 86/15
procurement [6]
60/8 145/16 146/22
163/18 163/20 163/23
procurements [1]
178/4
produce [1] 109/19
produced [1] 7/18
professional [1]
56/25
profile [5] 46/19 48/2
79/1 161/9 166/6
profits [1] 178/16
programme [5] 7/21
28/12 73/11 73/22
105/6
programmes [1] 18/9
progress [2] 75/4
117/16
progressed [1] 131/3)
progressing [1]
109/15
prohibition [2] 60/12
60/16
project [16] 68/7
70/13 70/18 71/9
74/15 75/3 75/10 77/8
77/10 77/23 78/2
81/25 88/21 91/16
93/14 100/18
promises [2] 44/19
45/7
promote [2] 12/17
18/6
prompt [1] 67/10
prompts [1] 123/18
proper [4] 97/23
155/11 155/12 166/20}
properly [4] 62/2
62/8 106/24 148/23
proportion [1]
154/19
proportionate [1]
177/13
proposal [3] 36/19
138/23 140/25
proposed [3] 13/6
13/6 30/19
proposing [2] 29/23
31/18
proposition [1] 54/16
prosecuted [10]
68/19 71/18 74/9
170/4 176/25 176/25
186/10 186/13 187/11
187/14
prosecution [2] 58/2
177/18
prosecutions [25]
7/23 56/22 57/16
57/18 58/6 58/17
58/22 59/13 62/17
71/19 73/21 154/9
154/18 177/14 177/4
177/13 188/3 189/7
189/10 198/10 198/15)
198/17 198/22 199/1
199/4
prosecutor [1] 58/7
prosecutorial [1]
57/25
prospective [1]
100/15
protect [4] 31/5 81/6
102/17 110/16
protocol [9] 92/25
93/13 94/8 94/9 94/13}
95/7 96/2 167/12
168/2
prouder [1] 195/14
prove [1] 26/21
proved [1] 95/13
provide [20] 5/11
5/17 13/19 13/20
29/25 33/10 39/24
67/9 67/9 83/19
101/24 131/8 132/19
132/21 137/2 137/5
160/15 161/17 171/12)
193/20
provided [15] 6/22
46/12 56/17 56/20
56/21 58/18 67/13
107/17 108/5 112/7
113/17 165/2 180/2
186/15 198/9
providing [2] 33/8
129/20
provision [5] 11/10
29/10 129/22 132/17
132/17
provisioning [1]
105/4
provoke [1] 67/11
public [15] 10/7 11/9
11/10 12/20 28/13
52/22 81/1 81/13
82/19 88/18 124/13
153/20 175/23 176/22)
177/15
publication [2] 62/14
159/22
(73) policy - publication
Po
publicly [4] 56/16
publish [1] 197/3
published [1] 160/1
pull [2] 171/5 172/10
pulled [2] 105/6
105/20
punchy [3] 194/17
194/19 194/23
purpose [3] 67/8
123/23 147/21
purposes [2] 75/11
136/3
pursuing [1] 52/16
push [1] 44/17
pushback [2] 125/6
139/18
pushing [1] 13/10
put [26] 2/16 19/19
21/9 28/13 35/4 65/2
67/1 70/22 71/8 75/25
76/2 76/25 83/12
83/16 92/15 92/25
106/18 117/4 120/10
127/1 129/3 133/6
154/12 161/21 189/19
190/6
puts [2] 26/8 115/5
putting [9] 15/6
48/18 64/16 119/2
130/11 167/10 168/1
173/18 176/18
Q
QC [6] 58/12 58/14
59/5 82/10 83/7 87/5
QC's [2] 158/19
158/20
qualified [1] 2/18
qualify [1] 76/2
quality [1] 148/13
quantify [1] 151/7
quarterly [3] 148/9
149/15 149/21
quartile [1] 120/20
question [16] 14/7
34/21 39/1 48/8 48/14
69/16 97/2 115/25
120/22 150/9 155/1
173/14 173/18 180/15
183/4 198/4
questioned [11] 1/9
170/1 179/4 184/20
189/3 198/3 200/3
200/4 200/5 200/6
200/7
questioning [1]
199/8
questions [40] 3/16
3/19 6/17 6/20 7/4 9/5)
9/12 35/13 37/22
46/22 47/10 49/15
102/12 193/18 194/10}
56/14 77/10 84/15
115/12 116/9 117/21
118/25 121/9 123/3
123/7 124/19 134/25
136/20 169/6 169/8
169/20 170/7 175/10
175/12 177/15 179/1
194/10 194/25 196/9
199/12
quick [3] 19/15
173/17 195/11
quite [53] 4/21 8/4
8/10 11/2 14/7 15/8
18/12 22/16 24/22
24/22 25/6 25/7 25/8
27/1 28/10 28/17
28/20 53/10 55/14
58/1 58/5 68/14 74/2
84/10 95/15 97/9
104/12 105/13 109/5
111/25 117/6 122/10
145/9 146/10 152/1
153/5 154/8 156/18
156/22 156/22 164/7
167/19 178/13 183/11
quotation [1] 142/24
Ro
RAG [1] 70/7
raise [1] 4/10
raised [7] 54/20
55/24 148/1 153/20
153/25 156/22 159/4
ramification [1]
178/3
ramifications [2]
18/18 178/2
ramping [1] 168/22
random [1] 185/4
range [2] 6/17 140/20)
rank [1] 195/4
rarely [2] 21/6 39/3
rated [3] 91/14 93/14
93/22
rates [1] 70/12
rather [23] 7/9 21/10
26/1 26/5 43/24 59/24
60/19 66/14 67/17
72/12 80/24 81/3
106/2 107/11 113/6
118/3 123/7 125/11
132/23 154/15 162/13}
167/23 181/21
rating [10] 70/7
70/11 70/12 70/13
78/8 82/6 92/9 92/18
93/24 96/6
ratings [1] 66/11
rattle [4] 171/4
171/20 171/24 172/8
184/17 193/10 193/19)
102/25 103/11 103/13)
131/13 132/16 134/24,
135/15 139/13 140/10)
RC [1] 149/10
re [4] 182/11
react [2] 127/18
127/19
reacted [1] 107/10
reaction [1] 181/14
read [24] 1/25 2/2 2/6
23/22 59/14 59/24
68/14 110/1 123/11
125/15 132/11 157/10
157/11 157/13 157/14
157/17 158/8 160/19
173/23 174/15 182/14
190/20 191/8 192/21
readiness [1] 35/20
reading [3] 22/20
68/16 157/15
readout [2] 113/13
159/10
reads [5] 1/20 107/22
110/2 110/7 110/10
ready [2] 35/12
131/16
real [7] 33/1 103/23
106/20 107/2 107/13
107/13 177/23
realised [1] 1/25
realistic [1] 44/20
realistically [3] 25/1
25/3 153/24
really [36] 10/21 19/8
22/7 25/12 25/16
27/25 32/5 43/25
45/18 47/3 50/7 50/9
50/9 54/7 65/19 75/21
78/16 78/23 88/20
95/15 130/21 131/21
135/20 152/24 153/3
158/13 158/13 162/17]
178/21 178/21 181/18I
181/25 182/13 183/13
185/13 194/7
reason [13] 14/21
15/13 17/8 29/25
31/11 63/2 75/18 76/6
91/22 137/7 138/13
157/18 172/13
reasonable [5] 7/23
58/3 154/7 163/7
173/10
reasonably [3] 36/7
102/11 185/8
reasons [3] 117/12
158/22 193/23
reassurance [2]
83/20 156/15
reassurances [2]
42/25 192/20
reassuring [3] 58/12
59/6 159/3
rebut [2] 193/20
194/12
rebuttal [1] 194/17
recall [17] 6/15 22/8
50/7 50/11 59/23
60/21 65/19 65/22
122/8 128/17 128/18
135/16 138/18 141/9
141/24 157/13 183/22,
receive [2] 5/1 59/18
received [9] 7/24 8/1
20/11 21/22 30/25
106/22 109/7 109/20
192/19
receives [1] 109/4
receiving [2] 108/8
108/16
recent [1] 149/10
recently [3] 46/9
115/8 117/10
recognise [2] 184/15
189/7
recognised [2]
166/25 178/14
recognises [1] 87/18
recognition [3] 5/23
75/16 104/24
recommence [1]
169/12
recommend [2]
140/3 166/2
recommendation [1]
164/17
recommendations
[7] 89/10 89/11
164/14 167/5 167/8
167/14 168/11
reconfirmed [1]
104/6
reconsidering [1]
199/5
record [9] 47/1 62/8
69/5 69/6 89/9 99/2
99/5 147/15 180/25
recorded [10] 62/2
69/3 69/20 72/4 74/11
81/12 84/2 98/2 98/24,
100/16
recording [2] 61/21
67/22
records [3] 66/7
82/23 90/5
recourse [1] 50/6
recruit [1] 123/21
recruitment [2]
151/13 151/21
recused [3] 15/13
15/14 16/9
red [5] 82/6 91/22
124/24 125/5 127/12
reduce [1] 175/22
reduced [1] 88/6
reducing [1] 176/17
reduction [1] 122/23
redundancies [3]
18/13 18/14 36/21
redundancy [1] 18/8
refer [4] 78/2 88/22
121/21 145/18
reference [10] 77/10
82/11 108/10 118/9
119/21 130/20 166/6
193/12 194/3 194/9
referred [3] 42/16
161/11 190/9
referring [2] 77/13
103/16
refers [2] 121/22
121/22
reflect [3] 70/17
72/12 186/20
reflected [2] 189/18
192/9
reflecting [1] 197/16
reflection [16] 8/14
9/10 28/7 57/3 57/10
71/20 72/10 97/3
98/25 107/5 108/24
111/6 114/19 117/25
118/7 141/17
reflects [3] 70/20
192/17 192/19
refute [1] 33/1
regard [6] 5/3 6/10
125/18 176/13 176/19}
187/4
regardless [1]
155/19
register [24] 61/18
61/20 62/12 63/25
66/1 66/2 67/8 69/14
74/12 75/3 75/15 76/3}
76/20 80/23 81/3 81/4
81/11 86/13 89/6
91/23 94/11 96/12
99/1 148/14
registers [10] 64/14
66/25 67/3 67/25
81/16 88/21 92/21
148/11 148/15 148/25]
regret [3] 25/7
157/18 158/12
regular [1] 150/4
rejected [3] 113/19
113/24 168/12
relate [3] 69/21 69/22
88/24
related [2] 189/5
194/6
relates [1] 143/5
relating [2] 88/1
140/2
relation [17] 12/15
14/13 17/5 19/6 20/17
41/8 55/19 60/8 61/14)
77/11 102/12 103/8
103/22 117/24 131/11
155/24 179/13
relations [1] 49/10
relationship [7] 29/9
36/15 71/1 77/4 85/20
116/24 117/5
(74) publicly - relationship
R
relative [2] 8/17
70/23
relatively [9] 6/7 7/16
7/16 7/25 8/16 9/14
90/3 134/22 157/6
relay [1] 17/13
relayed [1] 164/21
released [1] 167/9
relevant [8] 5/1 23/6
55/4 55/5 55/9 172/17
173/9 178/24
reliability [1] 156/3
reliance [7] 51/11
64/23 66/5 88/20 89/5
198/10 198/22
reliant [5] 44/19 45/6
45/12 45/13 71/2
relied [2] 175/23
176/6
relieve [1] 188/8
rely [2] 64/13 153/6
relying [3] 45/16
89/20 195/1
remain [1] 3/12
remained [2] 78/16
80/13
remaining [3] 75/6
75/7 191/9
remains [3] 79/5 93/2
158/9
remark [1] 197/5
RemCo [3] 105/10
105/13 114/22
remember [30] 9/3
13/4 16/21 45/1 45/2
45/5 45/18 45/24 47/3)
48/23 50/2 50/3 50/10)
52/6 54/4 59/21
120/24 126/15 128/20)
128/25 136/14 141/4
142/2 149/4 150/25
153/1 155/6 155/8
164/8 168/3
remind [1] 174/18
remit [1] 181/7
remote [1] 74/10
remotely [1] 182/17
remove [1] 126/17
removing [1] 115/16
remuneration [5]
18/25 120/7 124/14
126/8 151/23
renewal [2] 144/14
144/20
repeat [1] 111/12
repeatedly [1] 128/10
repeats [1] 185/17
rephrase [1] 195/25
replace [1] 123/22
replaced [2] 1/21
142/19
replacement [5]
113/18 113/19 113/20}
116/16 116/20
replacing [2] 115/17
115/21
replies [2] 30/10
32/24
reply [12] 46/3 47/6
47/9 108/14 134/11
145/2 160/11 160/12
160/14 160/15 160/18)
173/25
replying [1] 170/25
report [43] 7/18 7/20
28/14 32/25 33/17
62/14 73/8 73/13
73/13 73/18 7/14
89/18 95/21 98/12
101/15 108/9 108/17
108/21 108/22 109/4
109/18 109/19 109/25)
110/1 110/10 112/4
118/2 156/9 156/20
157/5 158/14 158/24
159/1 159/2 159/6
159/22 159/25 163/8
163/15 180/20 181/12,
185/10 197/4
report’ [1] 34/19
report's [1] 109/7
reported [3] 29/17
89/10 107/1
reporting [2] 99/21
101/14
reports [5] 25/23
26/3 27/10 54/14
165/5
represent [3] 9/17
9/18 27/2
representative [4]
9/16 15/2 184/2 184/2
represented [1]
179/8
representing [1] 14/5
represents [2] 26/16
95/25
reprocurement [2]
60/8 145/8
reputation [2] 145/21
146/18
reputational [6] 69/5
70/3 72/3 72/4 88/5
92/4
request [5] 7/8 60/3
139/16 139/25 140/1
require [3] 120/7
131/5 166/3
required [5] 40/19
108/18 119/16 124/14)
153/21
requires [1] 167/2
researched [1] 175/3
resolution [2] 75/5
88/17
resolve [6] 32/5
112/2 160/20 161/21
180/6 180/12
resolved [2] 83/17
104/14
resourced [1] 196/3
respect [1] 180/6
respective [1] 35/25
respects [4] 10/10
26/14 154/24 191/2
respond [3] 85/11
164/25 194/12
responded [2] 73/10
120/15
responding [2]
120/25 140/1
response [16] 7/19
7/23 28/12 28/12
28/14 36/8 39/1 39/2
73/20 118/1 153/24
155/15 156/20 156/21
163/17 191/11
responses [5] 37/14
124/18 156/21 177/13
194/23
responsibilities [3]
10/1 17/23 18/5
responsibility [6]
55/12 62/1 62/6 82/7
91/19 147/2
responsible [5]
11/12 118/6 121/13
177/7 188/4
rest [4] 59/15 59/16
93/20 158/10
restate [1] 105/19
restraint [2] 125/22
126/4
restriction [6] 20/14
20/22 21/15 22/12
22/25 23/4
rests [1] 82/7
result [4] 25/20 54/14
67/12 167/14
resulted [1] 71/19
results [1] 86/5
resuming [1] 174/2
retained [4] 109/17
162/22 197/1 197/3
retrospect [1] 187/17
retrospective [1]
105/17
return [3] 47/13
130/5 152/2
returned [3] 2/1 2/3
2/7
revealed [1] 157/6
reveals [1] 146/12
revelatory [1] 158/23
revenue [3] 117/17
119/12 122/23
review [49] 25/14
25/23 26/19 27/17
33/7 47/22 58/11
58/14 58/21 59/5
72/24 73/8 73/11
73/20 82/9 82/11
82/17 83/7 85/10
87/16 90/18 100/9
147/25 148/8 149/11
149/13 149/16 149/17]
149/21 149/21 150/21
150/23 151/1 151/6
151/22 156/7 157/24
158/15 163/1 163/2
163/2 163/12 164/3
164/5 164/11 177/12
180/5 180/24 199/3
reviewed [1] 142/15
reviewing [3] 53/2
58/22 89/4
reviews [3] 149/15
177/11 177/12
Richard [11] 1/5 1/8
1/13 46/10 47/10
47/12 100/10 124/19
128/7 174/1 200/2
Richard's [1] 47/19
rid [3] 195/4 196/20
197/20
right [85] 1/17 2/18
3/24 7/11 9/20 12/21
16/4 20/3 20/4 25/4
29/15 29/16 30/18
36/11 39/15 41/18
43/9 47/10 53/6 53/21
54/2 54/3 55/7 57/1
61/8 61/12 61/13
61/17 61/20 61/24
62/24 67/1 67/7 67/16
68/3 68/22 71/6 74/13,
74/25 75/10 76/4
76/11 76/21 81/23
82/15 91/8 92/23
105/6 107/7 109/1
111/6 112/15 114/15
116/2 116/9 118/2
123/23 124/25 126/21
130/8 130/16 131/10
131/14 132/12 133/1
144/24 147/9 147/9
149/14 155/5 168/19
174/17 177/21 177/24}
187/13 188/2 189/17
189/17 192/1 195/16
195/25 196/24 198/1
198/25 199/6
right-hand [4] 62/24
67/7 68/3 76/21
rightly [4] 43/6 79/20
154/6 155/2
rise [1] 74/24
risk [166] 5/23 6/12
61/17 61/20 61/22
61/23 62/8 62/12
63/25 64/3 64/13
65/11 66/1 66/2 66/25)
67/3 67/8 67/10 67/14
67/14 67/16 67/17
67/20 67/22 67/25
67/25 68/7 68/9 68/9
68/17 69/3 69/5 69/5
69/6 69/7 69/14 69/15
69/15 69/24 70/10
70/11 70/12 70/12
70/13 70/18 70/19
71/3 71/13 71/21 72/1
72/2 72/4 72/4 72/6
72/7 72/13 74/11
74/14 74/18 74/25
75/1 75/2 75/17 75/20)
76/2 76/19 77/22 78/8)
78/16 78/22 78/22
79/5 80/13 80/13
80/23 80/24 80/25
81/3 81/4 81/11 81/16I
82/3 82/5 83/10 83/15]
83/23 86/13 86/17
87/1 87/19 87/22
87/23 87/24 88/3 88/4I
88/6 88/9 88/15 88/21
88/24 89/6 89/25
91/14 91/14 91/16
91/19 91/23 92/3 92/4I
92/21 93/14 93/22
94/10 94/10 95/9
95/18 95/25 96/3 96/6I
96/8 96/11 96/12
96/15 96/16 96/18
97/22 98/17 98/19
98/25 110/22 111/3
111/4 115/17 115/22
117/10 147/10 147/15)
147/17 147/19 147/21
148/5 148/11 148/12
148/14 148/15 148/15)
148/17 148/19 148/24I
149/3 149/5 149/6
149/7 152/5 165/3
165/4 165/13 166/6
166/20 166/22 167/1
167/3 188/3 188/12
189/7 189/8
risks [32] 30/7 61/14
62/2 63/3 63/21 63/22
65/16 66/7 67/9 67/20}
68/18 69/20 69/22
70/3 70/14 70/23
71/11 74/18 75/14
75/25 81/12 89/8 99/6I
99/7 147/23 149/18
149/19 164/18 165/10)
165/14 166/16 189/5
RMG [1] 189/5
robust [2] 54/17
55/10
role [43] 3/8 3/9 3/16
4/5 4/7 4/11 4/18 4/25)
5/7 5/11 5/16 5/22
6/16 6/18 8/18 9/16
9/18 34/11 34/24 40/6I
54/6 102/13 102/14
102/16 102/19 103/23}
(75) relative - role
R
role... [17] 124/13
125/18 135/18 137/2
139/11 139/13 150/9
150/11 150/19 152/19
162/22 163/12 165/11
170/7 175/10 176/11
179/20
roles [5] 3/5 61/13
139/16 188/1 189/19
Rolfe [22] 28/16
82/16 82/18 85/2
100/10 100/16 100/23}
101/6 101/10 104/21
105/8 106/16 107/7
133/22 134/23 135/17
137/21 138/21 139/2
139/8 139/9 190/20
Rolfe's [1] 134/3
roll [1] 80/4
rolled [3] 50/9 50/12
50/14
room [2] 16/2 16/6
round [1] 31/16
roundly [1] 94/25
route [1] 32/9
routinely [1] 37/6
Royal [11] 6/7 22/8
71/1 187/20 187/24
188/3 188/19 188/21
191/14 191/17 191/25}
RSRL [1] 163/13
rule [1] 86/22
rules [1] 188/25
rumblings [2] 143/8
152/15
run [7] 4/2 30/19
37/11 37/13 138/15
152/24 188/6
run-in [1] 4/2
run-up [2] 138/15
188/6
running [3] 91/10
121/14 131/19
runs [1] 76/14
Russell [3] 113/16
124/2 144/24
Ss
sabre [4] 171/4
171/20 171/24 172/8
sacked [1] 109/9
sacking [2] 128/8
128/22
sadly [2] 25/7 137/8
safe [4] 57/16 57/18
190/14 192/10
safety [4] 56/22
73/21 74/4 156/13
said [54] 8/23 13/7
13/21 14/1 14/25 15/5)
21/8 21/21 26/10
26/25 28/22 33/13
37/14 39/1 41/21
43/10 45/6 46/24 47/1
47/1 47/5 48/22 57/3
59/24 60/4 60/18
60/20 72/25 73/13
73/18 74/5 81/3 88/3
97/2 103/16 111/25
114/7 1211/4 131/7
138/8 139/16 141/7
150/13 156/19 158/4
167/7 174/16 180/21
181/13 185/12 186/10
196/1 198/12 199/3
salary [4] 113/21
123/22 124/4 124/9
Sale [1] 190/14
same [20] 13/11
13/18 20/16 25/3
67/25 68/12 77/8
77/11 78/18 79/5
79/12 91/25 92/24
123/2 147/2 154/9
159/17 191/20 191/21
191/23
sat [2] 118/15 168/22
satellite [1] 96/21
satisfaction [2] 8/17
196/20
satisfied [5] 7/25
8/16 49/18 86/4 86/5
save [1] 126/18
savings [1] 119/11
saw [9] 32/8 50/10
66/7 73/16 73/17 99/6
100/22 102/13 112/24)
say [99] 3/19 3/22 4/5)
4/21 9/13 10/13 12/25
13/18 13/23 13/24
14/4 16/25 17/21
18/15 18/19 19/12
19/24 20/2 20/6 20/6
28/3 28/8 29/3 30/24
30/24 31/18 31/18
31/19 32/20 34/1 34/8)
34/19 35/5 35/6 35/24
36/4 36/7 36/12 36/13
39/5 39/14 42/4 43/22
44/10 51/4 51/10 52/2
53/5 55/14 56/6 57/7
58/9 58/18 66/23 71/9)
72/18 79/12 80/1 89/1
93/16 93/19 94/3
94/18 98/16 102/9
102/23 106/9 110/10
114/11 116/16 116/22)
117/8 118/13 121/5
122/17 125/4 125/9
127/9 127/21 130/9
131/9 133/20 135/23
141/3 141/23 143/16
145/13 151/5 151/15
153/13 159/23 171/1
173/19 175/18 190/2
196/18 196/19 196/25)
197/17
saying [58] 7/12 15/1
15/3 15/10 27/18
30/23 33/16 33/20
34/6 34/16 37/2 37/3
44/11 56/16 60/1
60/18 63/2 63/7 63/8
63/18 64/16 64/18
64/20 68/4 78/18
83/21 84/18 98/18
106/6 107/9 107/23
108/19 110/21 110/21
111/6 121/16 125/3
125/7 133/5 134/6
137/16 139/15 140/8
141/1 147/5 172/15
173/7 174/4 174/22
177/4 181/22 182/5
195/11 196/13
says [27] 26/19
27/22 27/22 27/22
29/20 47/9 60/19
62/25 65/3 65/14
65/22 73/9 100/4
112/6 112/7 123/9
128/2 128/23 136/23
137/22 138/25 144/24
180/3 181/3 185/10
193/17 194/18
scale [1] 166/1
sceptical [1] 162/10
schedule [1] 123/19
scheduled [1] 82/17
scheme [67] 7/22 8/6
9/10 9/15 22/5 25/13
31/4 31/9 31/24 32/8
39/16 39/20 40/3 41/3
42/14 49/10 59/13
73/24 74/17 74/17
75/5 75/12 75/15
76/13 78/4 78/21 82/8
83/13 83/16 83/23
97/19 108/16 109/14
109/15 109/22 118/3
118/10 119/15 119/25
131/3 131/18 153/18
156/7 156/10 161/16
161/24 162/25 171/25
172/3 180/4 180/5
180/12 180/16 180/24
181/1 181/10 182/5
182/21 183/2 183/3
183/5 185/24 187/5
188/10 193/22 195/20
197/2
Scheme's [1] 195/6
school [1] 11/17
scope [6] 40/3 41/1
41/4 43/24 44/1 47/19
score [1] 92/4
scores [1] 93/20
screen [7] 1/16 23/18}
107/25 136/24 141/21
37/23 38/3 40/11 44/3
173/24 179/15
scroll [35] 32/20 39/7
44/8 45/20 46/7 46/15)
47/6 47/8 47/17 50/21
50/23 62/20 64/25
83/24 91/6 99/24
121/9 129/25 133/16
134/5 144/11 144/18
144/24 149/9 159/8
160/14 163/10 164/13}
165/6 170/20 173/22
179/16 179/25 193/9
193/14
scrolled [1] 100/1
scrolling [4] 32/16
120/6 166/12 170/12
scrutinise [1] 137/3
scrutinised [1]
182/14
scrutiny [4] 27/21
48/21 57/1 197/7
se [4] 156/13
search [1] 66/21
second [98] 4/1 7/17
19/16 19/24 25/22
27/9 27/16 28/14 33/6)
33/7 33/17 38/25
40/25 41/23 42/6 42/8
42/17 42/23 43/25
53/24 62/14 64/18
65/21 72/16 72/21
73/8 73/12 74/3 77/4
77/13 99/11 104/18
105/14 106/1 106/8
106/10 108/8 108/21
109/9 109/17 109/25
113/4 116/24 118/1
118/9 127/25 128/3
128/9 128/16 128/19
128/22 132/1 156/9
156/20 156/24 158/17
158/23 159/21 159/22!
159/25 159/25 161/16}
161/25 162/7 163/1
168/4 175/2 175/9
177/11 180/3 180/20
181/3 181/7 181/16
182/5 182/12 182/22
183/1 183/11 183/15
183/18 186/4 186/7
187/18 189/25 190/23}
192/22 195/1 195/2
195/4 195/12 195/15
196/1 196/6 196/21
197/1 197/4 197/21
secondly [1] 94/15
secondment [1] 2/23
Secretary [5] 93/2
93/12 101/20 121/13
141/13
section [3] 50/20
116/23 120/21
sector [1] 126/10
secure [1] 14/16
security [1] 93/8
see [103] 1/3 1/19
4/13 9/16 10/1 10/21
15/10 26/14 29/12
29/22 30/9 37/12
45/21 46/3 47/7 51/4
60/18 61/5 63/14
63/15 65/3 66/19 69/3}
70/7 70/12 70/16 73/4I
74/8 78/8 78/11 79/13}
79/16 81/14 81/16
81/24 82/2 83/25
87/18 91/7 91/13
91/25 92/1 92/3 92/5
92/15 93/20 96/25
98/2 98/3 99/18 99/24I
100/1 100/13 105/23
108/24 108/25 110/19)
113/5 113/25 114/3
114/21 121/5 121/7
124/14 124/16 127/6
129/1 129/16 130/10
131/13 132/24 134/17
137/7 138/24 144/2
144/13 151/13 153/23)
157/4 158/8 163/9
163/10 166/7 169/18
170/9 170/13 170/15
170/17 170/21 173/17)
173/22 173/24 174/22)
176/22 179/17 182/24)
183/8 184/5 191/20
193/4 193/6 193/10
193/15
seeing [8] 23/12
60/13 75/20 79/4
108/21 123/17 133/22)
193/5
seek [6] 37/6 38/17
38/22 52/14 125/20
181/4
seeking [5] 35/2
43/25 64/23 92/25
151/21
seem [4] 59/16
126/14 162/10 187/9
seemed [3] 48/19
118/2 156/24
seemingly [1] 87/1
seems [8] 51/10
88/23 95/5 96/19
123/15 124/19 125/15)
137/1
seen [31] 56/12 60/7
60/10 60/14 66/25
72/5 74/5 77/16 81/19}
89/13 92/21 94/10
95/15 95/21 98/7
111/8 111/15 112/4
123/4 143/23 143/23
151/7 153/2 154/13
158/3 161/13 173/4
173/6 174/25 175/1
192/22
(76) role... - seen
Ss
self [3] 26/10 28/24
57/5
28/24 57/5
selling [1] 11/8
seminar [1] 164/8
send [7] 29/23 30/19
34/9 34/14 49/17
127/8 174/1
sending [4] 32/14
32/17 35/8 160/6
senior [5] 126/7
136/17 138/21 140/8
140/15
sense [26] 6/4 27/3
32/3 75/12 75/13
77/12 79/11 79/23
79/25 80/17 83/15
98/15 101/1 127/18
129/24 143/23 144/10}
144/20 147/5 147/7
152/11 172/3 176/23
180/11 181/19 183/10)
sensible [2] 181/14
181/20
sensibly [1] 139/13
sensitive [4] 17/2
18/15 31/24 115/23
sent [8] 34/13 35/12
37/7 63/12 113/4
127/15 149/3 170/20
sentence [4] 1/24 2/6
23/22 184/6
sentiment [1] 127/11
separate [6] 16/20
88/16 105/2 106/14
107/5 153/8
separately [1] 105/24)
separates [1] 188/19
September [1] 32/16
series [3] 53/20
124/18 177/15
serious [1] 94/22
seriously [4] 162/24
171/2 171/10 172/15
servant [6] 81/5 81/5
102/16 102/20 132/19
155/25
servants [5] 20/18
21/4 21/14 23/1 24/21
service [3] 11/10
12/19 174/2
services [2] 64/7
119/16
sessions [3] 39/18
130/15 133/10
set [20] 15/7 27/14
47/16 52/3 56/23
56/24 57/18 68/5
73/21 73/23 96/15
96/18 98/11 99/9
Select [2] 77/2 84/16
self-evident [3] 26/10
149/10 149/17 188/9
set-up [1] 188/9
setback [1] 167/2
setting [3] 7/20 7/21
120/4
seven [1] 62/13
shall [1] 76/23
share [15] 17/11
20/21 21/19 21/20
33/12 36/24 37/24
38/1 38/5 46/13
136/16 188/10
21/21 22/17 38/2
142/13 143/4 176/3
shareholder [57]
2/22 3/2 3/5 3/6 3/9
4/3 9/19 11/20 12/3
16/18 16/19 17/18
19/6 20/13 20/13
20/24 22/19 29/14
35/6 36/16 46/18 51/6)
52/21 53/3 53/13
57/23 59/20 61/25
108/7 126/9 126/12
136/6 139/11 139/13
140/15 162/21 168/8
176/12 179/20 183/24)
184/25 187/19 187/19)
187/21 187/24 189/4
189/14 189/20 189/20;
shareholding [2]
4/16 4/17
sharing [11] 16/23
20/16 20/23 21/10
22/9 22/11 94/8 94/13
96/2 167/12 168/2
she [94] 2/1 16/20
16/21 30/4 30/5 31/11
39/19 39/20 40/6 40/7
40/11 47/9 64/4 64/6
85/5 85/7 85/7 85/8
85/11 107/10 108/17
109/4 109/7 110/1
110/2 110/3 110/4
110/5 110/6 110/7
110/9 110/13 110/19
110/22 110/25 111/4
111/5 112/20 118/6
118/8 118/16 118/24
119/2 119/7 120/18
120/25 121/4 122/24
124/7 124/10 127/3
128/15 128/21 128/23)
130/23 131/18 132/3
132/3 133/9 135/10
136/15 136/19 136/20)
136/21 136/23 137/22)
137/25 138/7 138/11
119/19 119/23 142/12
sets [2] 42/17 169/20
105/15 127/11 127/20)
shared [8] 20/10 21/6
13/8 13/16 15/4 16/16
51/7 51/17 52/9 52/15)
138/11 138/21 140/5
140/13 140/25 141/5
142/4 142/6 145/12
146/1 146/1 146/3
147/1 159/19 159/20
191/5 192/1 192/2
194/1 194/1 194/15
194/15
she'd [5] 85/8 110/1
110/9 116/12 146/20
she'll [1] 160/4
she's [15] 47/8 110/2
110/5 131/2 135/23
138/8 138/19 139/14
139/15 141/2 145/14
146/2 146/21 147/3
147/3
sheer [1] 4/23
sheets [1] 1/15
ShEx [96] 2/22 3/1
3/6 3/13 4/6 4/20 9/16)
10/23 11/1 11/5 16/20
16/21 16/21 20/18
20/24 21/4 21/7 21/14
30/17 30/18 30/23
36/16 37/7 40/8 47/22
48/1 48/3 49/19 50/2
50/15 52/4 55/18
56/25 59/20 61/14
61/17 66/7 67/15
69/15 69/22 70/1 70/4
70/18 72/2 81/3 83/15)
87/20 87/23 88/16
88/25 93/15 93/16
100/7 100/18 101/1
101/13 114/14 115/1
125/16 125/24 126/22)
128/4 128/7 129/22
130/7 137/1 137/8
137/12 137/22 138/12
138/22 139/3 139/10
139/21 140/22 140/23
141/4 141/5 141/10
141/12 144/16 147/10
147/19 147/19 147/21
148/5 148/9 148/10
149/10 149/13 149/25)
151/7 159/9 189/6
189/11 191/24
ShEx's [8] 48/6 48/11
61/22 76/1 82/25
114/9 122/17 147/10
shocked [1] 125/15
Shoosmiths [2]
171/18 172/20
short [9] 61/3 86/23
99/16 129/14 169/16
194/17 194/19 194/23
196/3
short-term [1] 86/23
shorter [2] 79/14
86/2
shortfalls [1] 55/12
172/18 190/24 190/24
shorthand [4] 28/2
84/14 84/18 84/20
shortly [1] 82/22
should [58] 2/2 2/6
51/7 52/13 52/14
52/15 52/19 52/25
53/2 55/16 55/17
69/22 71/20 76/24
97/13 97/18 102/8
114/19 119/2 119/19
128/15 141/8 141/17
164/21 165/9 165/23
166/2 166/10 166/14
166/17 167/2 181/16
187/1 187/17
shouldn't [10] 36/4
36/11 64/13 66/6
110/19 120/3 129/4
show [6] 21/3 28/15
111/7 125/15 127/10
135/16
showed [3] 28/5
123/16 128/24
shown [6] 28/19
94/11 123/13 123/14
173/4 185/16
shows [1] 28/15
sic [1] 53/7
side [6] 2/16 38/8
81/21 108/18 139/3
152/15
sides [2] 134/19
134/21
sigh [1] 32/23
Sight [75] 7/17 19/16
19/24 25/23 27/9
27/16 28/14 33/6 33/7
40/25 41/23 42/6 42/8)
42/17 42/23 43/25
53/24 62/14 64/18
72/16 72/22 73/8
73/12 74/3 77/4 108/9)
108/21 109/9 109/17
109/25 118/1 118/9
128/3 128/9 128/16
128/19 128/22 132/1
156/9 156/20 156/24
158/17 159/22 159/25]
159/25 161/16 161/25
162/7 163/1 175/2
177/11 180/20 181/3
181/7 181/16 182/5
182/12 183/1 183/11
183/15 183/18 186/4
186/7 189/25 192/22
195/1 195/2 195/4
9/11 23/17 31/9 46/13)
62/24 65/9 66/21 67/2
77/9 88/20 96/13 97/3}
107/17 107/17 108/12)
108/24 108/25 113/25}
146/23 150/23 153/17)
157/16 157/19 164/18}
139/21 188/15 188/24)
195/12 195/16 196/1
196/6 196/21 197/1
197/21
Sight's [4] 33/17
77/14 159/21 182/23
sighted [2] 168/24
193/21
sighting [1] 93/12
sign [1] 160/4
signature [2] 2/10
17/8
signed [2] 45/21
174/7
signer [1] 148/24
significance [2]
157/15 157/16
significant [10] 6/23
30/14 72/15 72/19
83/12 86/21 86/24
115/22 120/14 167/1
significantly [2] 6/25
119/16
signing [1] 149/3
similar [5] 8/2 63/23
101/16 123/2 156/17
Simon [1] 55/18
simply [9] 10/4 61/21
92/9 155/18 171/23
176/21 177/4 177/21
178/9
since [6] 53/21 60/14
78/16 116/13 121/3
170/4
single [3] 51/11
152/20 186/5
singling [1] 161/8
sinister [1] 132/23
sink [1] 122/14
sir [35] 1/3 29/24
30/3 30/8 30/25 31/5
31/6 31/9 31/17 31/17
32/4 32/10 60/23 61/1
61/5 99/11 99/14
99/18 129/9 129/12
129/16 129/18 131/22)
169/8 169/18 169/20
184/21 195/11 195/24)
198/3 199/10 199/16
199/17 199/20 200/7
Sir Alan [7] 30/25
31/6 31/17 32/4
131/22 195/11 195/24)
Sir Anthony [6]
29/24 30/3 31/5 31/9
31/17 32/10
Sir Anthony's [1]
30/8
Sir Stephen [1]
199/17
sit [3] 81/20 102/19
103/10
situation [10] 32/11
60/6 78/5 80/5 103/10
104/13 104/14 112/2
(77) Select - situation
Ss
146/15
six [4] 71/7 71/8
71/11 156/10
skip [1] 44/9
Skipping [1] 114/18
slide [3] 28/14 28/15
135/16
slightly [5] 51/10
85/4 88/12 151/23
168/18
slot [1] 134/2
slow [2] 28/1 164/25
slower [1] 150/14
small [3] 75/20 167/1
185/6
smoking [6] 40/4
40/21 41/4 41/8 42/2
43/23
smug [1] 196/20
snapshot [2] 67/9
89/6
snippets [1] 5/4
so [342]
sole [1] 19/6
solicitors [2] 59/5
174/7
some [66] 3/15 10/10
16/8 16/17 16/25
24/8 24/10 25/21
26/11 26/14 26/14
29/8 30/14 32/12
37/24 44/12 45/4
46/12 60/7 60/11
62/10 62/13 63/21
66/3 66/10 73/22
87/15 90/2 95/22
113/9 115/8 115/11
117/10 121/9 129/6
130/4 130/7 130/11
131/5 131/8 131/17
133/6 141/25 145/17
146/23 147/25 153/5
154/21 154/24 156/6
157/6 157/18 160/17
164/8 169/8 170/22
175/10 178/13 178/19
191/14 193/18 198/15}
somebody [9] 29/17
60/19 139/2 139/3
139/9 139/21 145/18
145/19 146/16
someone [6] 39/14
110/10 118/17 140/3
151/17 155/18
something [29] 11/1
19/22 21/8 24/17
25/19 26/20 34/14
36/7 45/2 47/5 50/12
50/14 69/25 113/9
122/10 124/15 126/16}
situation... [2] 117/9
19/11 21/9 21/9 21/24)
145/3 145/14 145/21
146/6 146/19 146/20
146/21 148/1 175/16
179/9 184/3 198/19
sometime [1] 7/18
sometimes [14] 6/1
24/5 34/10 34/11
61/10 65/16 79/13
81/7 101/16 101/19
146/12
somewhat [5] 9/15
10/10 13/1 13/2 88/11
96/16 116/17
sooner [1] 113/5
sorrow [1] 193/2
sorry [46] 8/22 10/18
14/7 23/12 23/21
24/10 24/12 27/4
32/21 33/15 36/19
37/19 37/23 42/12
66/3 68/24 69/1 69/14
72/18 73/12 74/23
102/22 102/25 111/5
131/1 140/14 161/3
167/18 175/5 175/20
180/15 182/19 186/9
186/25 187/13
sort [65] 4/18 11/6
16/25 19/15 20/7 21/9)
21/9 24/22 26/13
28/21 32/9 34/13 35/7
35/8 37/3 38/5 38/25
39/2 39/3 39/4 43/7
43/19 53/11 55/22
67/14 69/24 70/6
74/16 77/17 80/12
85/8 86/8 91/10 92/18)
99/1 99/5 104/7
104/11 113/10 113/21
115/25 122/13 122/23)
123/5 127/20 132/1
143/24 143/25 147/3
147/7 147/25 147/25
148/7 152/14 152/15
156/6 163/16 164/8
164/9 168/5 168/21
168/24 173/7 174/12
183/5
sorts [10] 16/24
49/22 49/24 67/24
97/4 98/9 103/14
122/23 152/21 195/9
sought [3] 62/18
106/9 106/11
sound [1] 132/23
soundings [1]
143/22
sounds [2] 158/13
173/10
102/17 139/14 145/12,
somewhere [3] 94/18}
48/8 48/8 49/11 52/13
55/23 56/7 60/7 64/12
111/12 112/15 113/17)
source [3] 31/21
105/22 166/13
sources [1] 29/10
Sparrow [58] 8/9
8/20 9/4 19/2 19/7
19/11 24/7 32/15
68/7 68/11 68/14
70/13 70/19 71/9 72/1
77/10 77/16 77/19
77/23 78/2 78/20
81/25 88/22 91/16
93/14 100/12 100/17
100/18 101/7 105/24
106/7 119/22 130/17
179/13 182/4 182/25
183/25 190/6 193/10
195/9 198/7
speak [8] 8/22 10/18
36/23 134/9 136/12
146/12 193/18 194/9
speaking [14] 38/9
68/2 80/10 97/7 113/8
114/8 122/7 124/1
125/11 127/15 144/16
146/5 146/11 198/17
Special [2] 140/18
141/11
specialised [1]
184/23
specialist [2] 24/4
24/19
specific [14] 6/4 9/3
9/5 12/4 16/8 16/12
40/23 117/18 148/18
148/19 151/4 188/1
194/13 194/13
specifically [18] 6/15
7/2 713 12/14 13/24
15/6 17/3 17/10 19/10
22/4 56/8 74/15 77/20
81/17 99/9 117/22
117/23 122/18
specifics [1] 9/12
speculate [1] 71/24
speech [8] 35/17
36/1 36/10 37/2 37/8
38/14 38/14 38/19
speed [8] 37/17
37/18 40/12 87/12
90/6 90/8 93/6 197/22
spending [1] 10/7
spent [6] 10/13 10/14
11/9 40/16 109/5
120/12
split [1] 4/7
SPMs' [1] 189/10
spoke [2] 17/17
138/17
SpAds [2] 87/11 93/5
36/17 47/19 55/3 60/6}
74/15 75/3 75/11 77/8
130/19 131/12 131/24
133/12 133/17 133/22
134/24 144/23 159/10
sporadic [1] 185/4
spread [1] 187/6
spreadsheet [5]
77/12 77/24 78/1
92/14 105/22
spring [1] 144/12
stage [5] 5/10 43/18
71/7 188/2 188/6
stakeholder [2]
80/19 83/12
stakeholders [1]
82/8
stakes [1] 166/13
stance [3] 89/23
122/24 123/1
standard [3] 37/14
37/24 37/25
standing [1] 28/5
stands [1] 194/15
start [15] 2/17 3/15
4/13 5/6 19/12 29/11
32/14 99/22 112/8
141/24 142/25 170/12)
started [5] 3/1 3/22
32/3 80/21 118/22
starting [6] 9/15 32/2
62/11 74/25 116/18
169/23
state [6] 8/16 8/17
17/21 121/13 177/7
188/8
stated [7] 95/23
97/13 154/1 154/3
178/5 188/14 188/23
statement [34] 1/14
2/1 2/13 3/20 6/19
6/21 9/25 11/25 17/16
18/21 20/10 23/7 31/2)
58/9 88/3 90/23 95/23
102/7 102/9 107/20
107/24 128/1 128/24
136/24 141/22 145/6
153/12 164/1 173/16
174/20 179/10 180/9
182/3 199/12
statements [1] 97/3
states [1] 190/20
statistic [1] 198/16
statistics [1] 186/12
status [2] 68/3 95/24
stay [2] 32/7 67/25
stayed [2] 78/18
79/12
stays [1] 39/19
steer [1] 156/1
Stemming [1] 73/9
step [1] 167/18
Stephen [1] 199/17
stepped [1] 168/20
stepping [1] 167/24
steps [10] 38/10
67/21 128/8 128/22
stages [2] 87/7 181/8
129/23 130/11 133/15)
137/5 151/6 163/6
165/20 165/24 168/8
stick [2] 137/22
138/1
sticks [2] 145/24
146/6
stiffen [1] 160/20
stiffening [1] 161/20
still [26] 32/5 59/1
67/5 72/24 73/25 77/5I
77/21 80/10 80/17
83/12 83/21 83/22
86/8 94/13 97/22
150/20 153/3 154/25
155/3 161/13 161/13
169/18 181/14 185/11
191/14 193/19
stock [1] 37/14
stop [5] 43/8 99/25
126/1 172/21 177/3
stopped [3] 177/2
177/5 195/20
stopping [6] 7/8
73/12 102/14 104/23
154/3 157/9
Storey [1] 16/19
stories [2] 24/8 24/11
story [1] 24/13
straight [1] 196/12
straightforward [1]
10/19
strategic [2] 5/12
166/19
strategies [2] 53/1
123/6
strategy [13] 13/5
53/2 117/18 119/1
119/2 119/9 122/21
122/22 126/20 166/22)
167/3 190/7 190/9
stream [1] 49/8
strengths [1] 119/7
strike [2] 182/4
187/16
strong [2] 115/19
183/11
stronger [2] 90/3
119/9
strongly [3] 33/1
41/11 107/11
structured [1] 124/18)
structures [1] 49/23
struggling [1] 28/3
stuck [2] 19/15
146/16
study [2] 97/11
151/12
stuff [10] 20/19 28/9
39/4 44/13 52/7 52/8
67/19 122/11 125/4
128/25
subcommittee [25]
8/9 9/4 19/11 19/20
22/2 22/3 22/11
(78) si
ituation... - subcommittee
s
subcommittee... [18]
167/18 167/23 168/1
182/4 182/25 183/22
184/1 195/9 198/8
subcommittees [1]
119/19
subject [5] 60/17
105/9 130/2 182/22
183/6
subjective [1] 108/3
submission [9] 21/9
106/18 107/9 126/6
129/3 160/19 161/2
161/22 162/2
submissions [1]
90/15
subpostmaster [4]
33/1 43/17 161/15
186/2
subpostmasters [37]
24/12 25/18 31/18
39/17 40/24 43/2
43/14 54/11 54/20
55/10 58/16 75/6 75/7,
98/7 104/20 104/24
104/25 105/5 106/3
106/22 157/2 161/1
161/18 162/9 170/3
171/23 173/6 177/21
179/7 181/6 181/13
185/7 185/18 186/12
187/6 188/5 191/1
subsidy [2] 175/23
176/17
substance [5] 21/14
44/9 84/17 137/15
164/16
substantial [2]
165/24 166/9
substantially [1] 82/3}
substantiate [2]
33/20 117/2
success [1] 18/6
successful [2] 76/14
121/14
successor [1] 3/12
such [9] 55/13 60/15
72/2 74/10 86/17
96/11 99/2 113/8
160/2
sucked [1] 40/13
suddenly [2] 94/16
94/17
suffering [1] 157/3
sufficient [1] 62/7
sufficiently [2] 34/23
76/2
suggest [6] 7/14
39/18 41/6 47/22
119/21 119/22 131/24}
131/24 167/11 167/17)
168/20 168/21 179/14}
80/22 195/3
suggested [4]
102/23 104/16 150/3
150/20
suggestion [1] 40/20
suggests [1] 131/10
suitability [3] 141/25
147/12 149/12
suits [1] 79/14
sum [1] 169/4
summaries [1] 26/5
summarise [3] 71/7
96/7 151/24
summarised [2]
56/18 142/23
summarising [1]
26/1
summary [4] 2/17
82/22 142/11 152/11
summation [1] 149/6
supply [2] 18/11
36/21
support [3] 65/4
125/17 130/4
supported [1] 177/23
suppose [32] 4/2
7/11 7/15 10/10 11/19
12/17 15/4 16/24
38/24 39/20 43/3
69/12 79/22 83/16
84/19 86/9 89/21
96/15 97/7 98/14
110/5 116/12 131/1
131/4 140/10 147/8
156/16 156/23 159/17,
188/16 189/12 192/25)
supposed [4] 71/3
88/14 122/9 125/17
sure [61] 4/18 8/3
11/13 12/21 15/25
17/1 18/20 25/4 27/3
27/10 33/9 39/5 42/2
44/15 47/12 49/21
50/18 51/4 62/23
63/19 63/22 65/24
76/14 87/23 89/5
89/17 104/12 104/12
104/14 104/15 105/13)
107/21 109/11 117/6
121/22 126/25 126/25)
127/3 132/16 134/12
135/1 135/6 135/12
137/19 138/6 140/4
140/11 145/13 160/15)
162/17 162/19 162/23)
164/7 167/7 167/9
169/13 176/23 183/17,
184/12 190/5 196/10
surface [2] 48/23
48/25
surprise [2] 129/5
162/1
surprised [1] 107/12
surprises’ [1] 52/20
surrounding [1]
188/12
Susannah [1] 16/19
suspicion [1] 138/10
sustainability [1]
178/15
sustainable [2]
150/12 178/17
Suzanne [1] 54/22
sweep [2] 36/4 36/11
Swift [11] 82/11 89/9
89/13 89/18 95/21
98/12 158/12 158/14
158/16 159/2 159/6
Swift's [3] 89/14
157/23 158/24
Swinson [29] 1/22
1/22 2/3 2/6 33/8
33/11 33/19 39/8 80/8
108/8 112/7 112/12
113/15 113/18 113/25)
116/14 116/20 120/23
122/6 123/9 124/3
125/6 127/2 128/2
130/2 130/21 142/19
142/20 143/6
Swinson's [7] 1/25
39/9 128/1 130/4
159/10 159/13 161/25]
switched [1] 95/5
sworn [2] 1/8 200/2
system [13] 9/8 41/9
43/4 91/4 94/6 95/12
162/8 175/13 180/7
181/20 182/8 185/3
190/14
system-wide [1]
185/3
systemic [16] 54/6
73/9 73/14 73/19
180/8 180/13 180/17
181/2 181/9 181/12
181/18 181/24 181/25)
185/10 185/14 185/17
systems [1] 184/24
T
tab [2] 76/17 86/11
table [1] 115/20
tactics [1] 15/17
take [50] 7/14 16/1
20/1 20/16 28/3 29/8
35/23 35/25 38/10
38/18 57/20 57/20
59/14 60/24 91/21
92/9 93/20 99/11
108/18 109/7 110/2
110/4 110/7 110/19
114/16 122/25 123/6
138/3 141/1 143/22
151/7 153/7 154/23
165/20 166/19 169/11
171/3 171/15 172/23
173/19 177/11 178/13
190/15 190/16 192/11
192/11 196/12
taken [15] 4/25 27/6
41/12 67/23 72/25
81/19 91/19 147/13
154/14 157/18 163/6
174/24
takes [1] 150/21
taking [12] 7/10 40/9
73/1 85/6 134/23
137/5 140/14 140/15
195/2
tale [1] 186/9
talk [7] 38/6 118/22
124/2 127/10 136/2
151/11 160/12
talked [4] 39/22
106/7 158/18 194/25
talking [10] 7/2 37/9
55/3 72/6 133/5
158/17 158/18 161/20}
184/6 187/13
Tara [1] 160/13
taught [1] 44/17
taxpayer [2] 11/18
12/24
taxpayers [3] 9/17
10/12 176/17
TBC [1] 62/25
team [68] 3/1 3/5 3/9
4/3 4/6 8/2 13/8 13/8
13/16 16/19 17/11
19/17 20/13 20/25
22/6 33/24 34/1 35/6
36/16 40/7 40/8 42/15
44/13 48/1 51/6 51/7
53/13 55/16 61/25
62/7 63/5 64/4 64/8
67/13 79/23 88/11
88/15 89/3 89/4 89/7
91/24 93/17 93/18
99/6 108/7 118/15
123/8 130/7 133/5
142/1 142/6 143/17
148/21 149/5 149/16
149/20 153/4 153/6
164/20 164/22 166/23}
168/8 187/19 187/21
187/24 189/14 189/20
192/5
tearing [1] 49/6
technical [1] 24/22
technicalities [1]
98/13
Teflon [6] 145/13
145/18 145/19 146/6
146/16 147/5
tell [25] 1/12 9/25
15/15 17/16 20/9 21/1
23/7 31/9 33/4 51/8
51/9 55/17 56/1 69/10
178/19 178/20 188/20)
148/15 152/10 152/16}
160/17 182/25 183/22}
90/22 93/19 96/7
117/3 128/10 135/13
163/14 164/1 172/15
193/23 198/6
telling [6] 28/6 43/2
49/18 51/21 75/24
123/6
temptation [1] 85/12
ten [2] 169/12 169/21
tend [5] 4/20 17/1
67/24 143/25 148/9
tended [2] 59/12
118/24
tends [3] 65/4 80/22
88/2
tens [1] 126/17
tension [3] 31/2 96/1
109/23
tenure [5] 104/5
1417/1 141/24 156/5
164/6
term [5] 77/17 77/18
86/23 124/7 178/18
terminated [3] 65/4
195/16 196/7
terminating [2]
159/21 159/24
terms [22] 2/18 7/20
8/5 10/12 14/16 23/23}
45/15 49/2 51/24 70/4
70/21 74/14 75/2 82/5
92/17 105/1 118/2
118/9 126/13 142/23
153/14 161/20
test [1] 32/9
tested [2] 83/3
166/17
testing [1] 127/14
text [4] 38/5 66/10
7117 91/23
texts [1] 38/1
than [49] 7/9 10/9
21/10 26/1 26/5 43/24)
45/9 59/24 60/19
66/14 67/17 80/25
81/3 89/24 90/4 94/22
106/2 107/11 110/18
113/6 118/17 119/17
123/7 125/9 125/11
130/13 133/8 133/13
141/2 141/18 142/5
144/5 150/14 151/14
151/23 152/5 154/15
166/13 166/15 167/23)
168/18 169/3 169/5
171/16 181/21 187/11
187/15 195/14 198/5
thank [60] 1/4 1/5
1/18 2/5 2/9 2/16 2/16
3/15 23/17 29/11
32/12 44/8 46/2 50/23}
60/22 61/1 61/7 61/13)
63/25 68/6 69/1 77/7
86/12 86/14 90/21
(79) subcommittee... - thank
T
thank... [35] 99/10
99/14 99/19 99/20
114/5 129/8 129/12
129/17 129/18 129/25
133/16 144/12 153/8
159/7 159/7 159/18
169/1 169/6 169/14
169/19 169/20 170/9
178/25 179/2 179/7
182/18 184/17 184/18)
184/21 197/8 198/2
199/6 199/11 199/15
199/20
thanked [1] 197/13
thanking [1] 197/6
thanks [4] 29/22
35/25 36/9 112/23
that [1153]
that I [2] 44/12 159/3
that's [114] 2/8 2/21
2/25 3/4 3/7 3/11 3/14
3/25 4/9 10/25 11/6
12/13 20/7 25/20
26/10 39/10 41/12
41/18 42/21 43/5 43/6
43/9 43/21 43/24
43/25 46/10 47/5
47/10 53/14 55/14
56/11 57/5 57/21
61/24 63/3 63/18
64/19 65/3 67/1 68/22
69/1 71/15 71/24
72/23 73/4 74/13 76/4
76/6 77/6 80/1 82/11
85/4 89/15 91/22 95/4,
96/5 98/22 100/7
102/1 103/9 103/11
103/16 103/18 109/8
110/6 110/21 110/22
113/23 114/2 114/15
114/23 115/3 119/22
122/15 123/14 125/13)
130/20 131/16 132/22)
135/2 135/20 139/23
139/25 142/8 145/16
146/8 146/10 150/19
154/8 155/19 157/3
157/9 158/11 159/1
160/8 162/25 171/16
172/25 173/7 174/17
180/25 182/1 182/12
183/16 185/11 190/7
191/20 194/18 194/24}
195/3 195/8 197/4
199/6 199/18
theft [1] 154/16
their [43] 13/14 24/13}
25/5 27/10 34/23
38/15 40/25 41/4
44/19 44/21 49/6
54/21 55/11 86/25
106/24 109/17 109/18
109/19 114/3 115/20
117/4 117/4 117/5
121/11 121/15 121/17)
121/20 122/15 123/5
127/17 127/24 146/18)
150/11 150/18 159/24}
161/6 162/15 166/18
170/4 185/19 188/13
190/13 197/3
them [47] 3/21 10/25
11/4 13/20 15/19
18/10 18/19 26/5
34/14 35/8 36/10
45/12 45/13 45/14
45/16 47/22 49/9
49/15 49/16 49/17
52/5 53/7 66/7 67/1
67/6 78/3 79/2 90/10
90/12 90/13 99/7
110/9 114/3 115/19
115/21 123/6 134/15
135/13 135/14 137/7
145/12 146/1 146/2
159/5 172/14 195/7
196/1
thematic [4] 108/9
108/22 109/19 109/19)
theme [1] 45/9
themselves [3] 21/20
25/22 162/13
then [101] 2/20 2/24
3/15 4/17 7/18 8/7
15/17 25/14 25/19
27/23 32/16 32/20
40/5 47/11 47/17
47/23 47/24 50/22
51/14 52/24 53/16
54/8 56/21 64/9 66/2
66/17 67/5 67/11
67/20 67/22 67/23
70/1 71/4 73/3 79/14
82/15 85/10 87/9
87/15 88/12 90/21
91/10 92/6 93/7
108/10 108/17 110/2
111/4 113/18 115/25
116/11 119/14 121/6
124/8 126/1 130/3
130/6 134/5 134/10
140/2 141/2 142/23
143/9 143/22 143/25
144/24 149/6 149/7
149/15 150/8 150/16
152/15 152/16 156/16)
158/4 160/14 160/22
163/20 164/15 165/6
166/7 166/12 169/12
169/12 169/23 169/23)
170/7 173/19 174/2
181/16 181/17 182/41
185/11 186/3 186/7
186/17 191/4 191/8
193/14 193/16 199/19)
theoretically [1] 4/15
there [273]
there'd [10] 7/6 26/12
42/4 58/1 80/7 110/8
149/13 149/15 171/18
171/18
there's [52] 3/21 6/3
10/21 11/1 18/20 24/3
24/15 25/13 27/23
35/5 54/7 64/25 66/22
71/21 73/9 81/2 84/10
85/11 87/15 89/9
94/15 94/17 97/17
97/19 97/22 100/3
105/11 127/12 127/19]
130/3 133/11 133/12
134/4 137/17 138/9
142/23 143/8 145/3
145/15 146/3 146/5
149/15 152/14 170/13
170/17 170/22 173/14]
185/14 187/2 191/13
196/25 198/12
thereabouts [1]
198/10
thereafter [1] 59/12
therefore [15] 12/9
36/24 41/3 43/12 62/6
70/11 74/4 78/16
88/15 91/13 128/18
139/1 162/10 173/7
196/3
thereof [1] 56/22
these [24] 3/19 36/6
53/5 65/9 67/3 67/19
67/24 75/11 88/21
89/2 96/25 121/17
142/1 142/2 143/25
148/3 156/1 160/4
168/11 175/25 177/20
177/22 192/10 193/16
they [134] 2/15 5/25
7/18 9/23 11/1 11/3
13/2 13/5 15/19 15/20
15/24 15/25 17/1
19/16 19/23 20/6 20/6}
20/21 28/13 28/15
31/23 33/11 34/9
34/12 34/13 34/19
35/9 37/25 38/6 38/13
41/1 41/2 41/4 42/6
42/11 42/13 43/13
44/1 44/2 46/21 46/24
49/7 49/18 52/15
52/16 55/4 55/5 56/24
63/23 65/24 66/1 73/3)
74/21 79/24 80/9
81/17 83/4 85/25
85/25 86/18 86/25
87/5 90/8 90/12 90/13)
90/14 90/15 90/16
90/18 97/12 97/13
101/4 101/9 101/15
101/16 102/24 105/6
106/22 106/25 106/25}
111/24 113/20 113/24)
121/22 122/3 123/5
123/6 126/7 127/16
135/16 136/17 138/6
143/21 145/21 145/23
146/17 146/17 146/18}
147/12 149/5 153/6
156/25 161/6 161/7
161/7 164/9 168/19
168/23 171/3 171/5
172/10 173/12 174/4
174/5 174/7 174/19
174/23 176/3 181/24
181/25 182/1 183/12
185/3 185/20 188/15
191/21 193/2 193/3
193/3 194/5 194/13
195/6 196/2 197/2
they'd [7] 33/11 41/3
42/6 113/21 148/1
149/8 174/16
they'll [1] 18/19
they're [18] 10/25
15/18 28/2 34/8 38/7
55/9 73/4 79/19
127/18 127/19 140/20}
141/12 141/14 141/14
169/6 174/16 175/12
191/20
they've [6] 35/11
38/15 39/1 114/4
171/11 174/23
thing [15] 25/4 36/22
54/25 81/14 116/23
122/20 133/23 140/7
143/24 144/23 148/9
151/15 158/12 168/6
190/21
things [57] 8/7 10/16
13/1 14/16 21/1 24/6
26/8 27/17 28/11
31/16 36/4 36/11
36/24 37/11 37/14
37/25 38/8 44/18
46/12 49/25 51/13
56/15 57/9 59/2 64/6
72/5 72/8 75/19 81/21
84/17 88/22 89/2
94/12 97/4 97/24 98/9
103/17 106/19 118/8
118/11 119/17 122/24}
127/20 132/8 138/7
139/14 143/25 144/8
152/14 156/19 160/17}
170/6 181/21 191/5
192/21 192/22 195/10}
think [283]
thinking [13] 5/12
6/12 6/15 7/12 19/10
20/7 22/1 41/13 75/13
96/4 131/25 135/10
160/16
thinks [1] 138/21
third [10] 4/5 39/1
46/17 63/15 65/1
105/23 117/8 119/14
121/2 191/3
this [275]
this' [1] 34/20
Thompson [9] 40/6
108/12 133/19 138/15)
159/9 171/1 192/8
196/17 197/16
Thompson's [1]
139/23
thorough [2] 18/14
58/14
thoroughly [1]
166/17
those [61] 2/4 9/6
10/3 13/1 15/14 16/24}
18/13 20/21 33/19
49/22 49/24 52/17
54/9 54/10 55/14
61/10 63/21 64/6
65/11 67/4 70/8 71/18)
72/12 83/9 83/21
84/21 85/1 89/11
95/17 95/22 97/4
97/24 98/9 99/7
103/14 109/18 116/9
118/24 122/23 130/14}
136/20 139/14 143/3
143/13 144/8 152/14
154/19 167/5 167/8
167/9 176/14 176/14
181/22 185/5 186/4
187/9 188/16 194/12
194/12 194/15 195/9
though [18] 5/7 9/14
22/12 28/2 28/8 52/3
63/22 78/23 106/14
128/4 146/18 171/2
171/10 172/15 174/5
175/2 183/18 194/1
thought [45] 4/13
7/19 13/7 14/4 21/3
26/22 26/23 27/8
28/17 28/18 29/6
33/17 34/12 36/3 41/1
43/5 43/9 43/11 46/13
59/2 75/19 81/11
88/13 89/22 94/25
106/17 110/14 110/16)
113/5 113/25 120/22
130/11 133/23 153/17
155/23 160/25 161/21
162/1 177/2 177/13
178/22 181/14 181/19)
183/14 190/24
thoughts [6] 27/11
70/21 113/9 114/12
133/6 146/13
thousands [1]
126/17
threats [1] 70/25
three [8] 47/17 91/9
134/5 138/24 159/9
(80) thank... - three
T
three... [3] 169/20
192/13 193/7
threshold [1] 166/5
through [27] 11/5
11/12 20/19 22/20
22/20 27/9 28/10
28/18 29/6 30/20
34/13 46/18 66/21
83/14 87/6 104/7
105/6 105/21 121/5
132/2 134/23 152/3
152/4 156/1 178/22
195/13 196/10
throughout [8] 8/21
24/24 25/13 25/15
104/5 156/5 166/23
194/25
throw [1] 122/14
Thursday [1] 133/23
thus [1] 33/1
Tim [10] 44/11 60/15
68/13 83/6 89/16
104/18 158/17 159/3
186/10 190/17
time [105] 1/21 2/2
2/6 4/15 4/16 7/24
8/14 9/7 13/2 13/11
13/18 15/11 21/17
24/3 24/24 25/3 25/10
25/13 26/15 26/19
28/20 29/22 32/7
37/12 40/14 40/15
40/22 41/10 41/19
43/21 47/25 50/19
51/17 53/9 55/21
56/11 58/20 59/19
62/15 62/17 63/21
66/24 72/24 74/1 76/4
77/4 77/21 78/19
78/23 79/13 83/1
84/20 85/8 86/3 89/7
90/23 91/8 101/8
107/2 109/5 115/8
115/19 116/15 116/17
117/10 118/24 120/12)
124/11 124/15 131/20)
132/25 133/15 133/25
135/1 135/25 136/3
136/22 137/20 138/10}
139/12 142/19 143/5
143/21 143/24 145/11
147/2 153/5 153/7
154/10 158/14 160/17)
167/19 168/9 168/15
170/25 171/25 175/11
175/16 178/13 178/19}
180/19 184/5 184/10
189/12 189/14
timeline [5] 87/16
90/11 127/20 157/21
168/3
times [9] 16/8 29/2
52/7 92/10 108/4
117/1 142/9 172/16
172/18
tip [1] 135/9
tipping [1] 135/11
tips [1] 35/9
title [5] 63/1 65/12
65/25 147/16 163/11
today [10] 8/21 43/11
77/16 112/23 133/22
140/23 142/9 173/22
177/15 189/19
together [3] 133/6
137/12 137/23
told [19] 14/8 49/19
53/7 54/13 54/19
58/20 61/9 95/19
116/6 116/10 116/19
128/5 142/8 145/3
155/2 155/5 177/24
184/3 189/13
Tom [6] 133/19
167/18 167/19 168/22)
168/24 169/5
tomorrow [3] 100/5
133/25 134/8
tone [1] 190/21
too [16] 13/7 13/21
14/2 14/25 28/19 36/5)
44/19 45/6 59/2 113/8
119/2 134/4 163/23
176/10 196/8 199/18
took [13] 5/22 47/25
58/13 59/4 59/9 59/14
59/17 115/13 152/11
154/6 154/11 168/8
182/10
tool [3] 67/8 67/9
67/23
top [24] 30/9 33/14
62/24 67/1 67/7 68/15
71/7 7118 71/13 76/21
81/23 83/24 91/7
91/14 93/14 93/22
114/6 130/6 147/17
170/20 170/25 181/21
191/11 196/12
top-down [1] 181/21
top-rated [2] 93/14
93/22
topic [8] 24/22 74/24
83/19 85/3 99/22
110/13 129/20 153/8
topics [1] 6/17
tough [2] 133/12
161/11
tougher [1] 133/12
towards [11] 19/12
64/4 117/11 128/8
128/22 162/3 164/6
168/7 176/1 190/22
197/15
traction [1] 119/11
train [1] 130/4
training [3] 5/1 73/23
192/25
transactions [1]
98/11
transcriber [1]
175/18
transformation [8]
47/20 48/18 64/2
105/5 121/5 150/10
150/13 178/5
transition [3] 96/1
130/2 133/6
transitioning [1]
168/25
translate [1] 176/19
translated [1] 71/4
translating [1] 183/2
travel [1] 137/6
Treasury [3] 46/23
123/20 124/14
treat [4] 10/23 65/9
66/6 76/23
triage [1] 195/21
trial [1] 154/14
tried [2] 145/6 154/20)
trigger [1] 93/9
trouble [1] 78/21
true [7] 2/13 64/14
76/23 146/12 160/24
180/10 182/3
truly [2] 27/5 27/7
trust [1] 138/11
trusted [2] 42/23
153/4
trusting [1] 141/14
truth [1] 116/9
try [11] 37/16 37/20
39/2 40/3 49/17 81/6
103/11 114/1 123/20
132/14 137/12
trying [31] 11/6 13/14]
24/20 24/25 25/3
26/20 34/21 35/12
40/17 40/21 76/13
81/10 96/1 108/20
110/15 110/15 111/2
111/24 122/4 122/14
126/12 126/13 127/22
127/23 127/23 131/4
137/18 155/17 161/10
162/23 174/18
Tuesday [1] 100/11
turn [15] 2/9 3/21
11/23 44/4 45/19
68/11 99/21 102/8
141/19 153/8 153/12
163/8 164/2 173/23
179/11
turned [1] 141/8
turns [2] 66/18 74/20
Tweedledee [1]
191/21
Tweediedum [1]
191/21
twice [1] 133/9
twin [1] 189/19
two [44] 3/5 4/2 4/8
13/1 15/13 18/22
19/16 26/16 28/14
29/22 33/7 42/5 42/17,
42/19 42/21 43/20
43/21 53/25 53/25
54/8 94/12 94/16
95/16 95/17 98/16
106/19 107/1 107/10
111/12 130/22 156/20}
158/6 158/7 158/23
165/6 170/6 175/3
188/1 191/2 195/7
196/1 196/25 197/3
197/17
tying [1] 132/19
type [6] 69/3 115/25
141/19 180/2 180/7
182/3
U
UKGI [28] 3/12 4/20
11/1 63/12 64/13
69/23 87/6 87/10
92/25 93/4 93/11
97/12 126/9 163/17
164/8 164/18 165/9
165/12 165/12 165/16
165/16 165/20 166/2
166/10 166/14 167/2
167/6 167/15
UKGI's [4] 64/24 76/1
163/12 164/11
UKG100002288 [1]
129/23
UKG100002292 [1]
44/5
UKG100002439 [1]
112/9
UKG100002440 [1]
114/6
UKG100002467 [1]
32/13
UKG100002515 [1]
62/11
UKG100002726 [1]
35/15
UKG100002996 [1]
39/7
UKG100003427 [1]
76/16
UKG100003792 [1]
196/6
UKG100005195 [1]
138/14
UKG100005261 [1]
133/15
UKG100006454 [1]
104/17
UKG100006547 [1]
144/11
UKG100006622 [1]
81/22
UKGI00007578 [1]
86/10
UKGI00007995 [1]
91/6
UKGI00009275 [1]
163/9
UKGI00019531 [1]
193/9
UKGI00019720 [1]
159/7
UKGI00019859 [1]
190/15
UKGI00042124 [1]
147/16
UKG100044314 [1]
50/1
ultimately [8] 11/12
62/1 69/16 96/4
120/16 147/1 151/12
156/23
um [3] 23/12 45/11
106/13
unable [1] 29/25
unanimous [2] 144/3
144/7
uncertain [1] 167/1
unchanged [2] 78/16
80/14
unclear [2] 67/21
69/18
undated [1] 123/13
under [15] 6/7 22/8
27/13 48/25 55/11
68/14 82/6 83/24
86/14 91/16 115/20
156/7 164/12 165/18
17718
undergoing [1] 72/24I
underlying [7] 95/24
98/17 98/18 105/22
106/24 165/21 179/11
undermine [1] 71/22
underneath [2] 48/22)
68/8
underprovisioned [1]
105/1
underprovisioning
[2] 104/20 104/23
understand [38] 5/15)
7/5 8/11 9/23 14/7
18/4 29/9 39/2 56/8
58/21 60/16 64/23
75/3 75/4 75/10 76/8
77/9 77/22 83/21
84/22 102/5 102/25
1412/1 123/17 127/16
131/1 131/16 132/3
132/4 132/8 134/25
135/19 140/10 155/17I
157/4 157/14 186/25
190/13
understanding [20]
5/23 15/4 19/9 25/5
(81) three... - understanding
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54/12 57/24 60/12
82/25 98/15 123/25
124/1 177/6 186/1
191/6 192/21 199/18
understands [1]
194/15
understood [22] 9/8
157/16 158/16 176/3
undertake [1] 4/11
undertaken [2] 59/5
72/13
undertaking [2] 82/9
83/7
undertakings [1]
19/23
undue [3] 28/5 81/6
102/17
unequivocal [1]
155/21
unequivocally [2]
188/14 188/23
unfair [2] 89/13
177/18
unhappiness [1]
131/23
unhappy [2] 151/15
151/16
unit [1] 53/1
universally [1]
166/25
unjust [2] 188/4
189/10
unjustifiably [1]
161/1
unknown [2] 43/13
43/15
unlawful [1] 177/7
unless [1] 178/16
unlike [1] 24/1
unsafe [1] 71/19
unsighted [1] 95/21
unsung [2] 196/19
197/18
untenable [2] 84/9
85/16
until [20] 3/8 3/10
22/9 56/4 60/24 66/17
97/8 97/11 117/10
126/25 127/1 127/4
129/10 143/9 152/13
160/12 169/12 175/20
199/19 199/22
untrue [4] 184/4
184/5 191/2 191/3
unusual [4] 37/5
understanding... [16]
30/17 49/7 53/17 54/9
22/7 31/5 43/19 53/24
54/5 58/6 58/10 58/13
60/14 73/3 83/6 98/14
101/17 103/25 152/12)
182/25 185/24 195/23)
37/24 135/2 197/11
unveiled [1] 164/9
unviable [1] 11/4
unwind [2] 32/3
117/16
up [87] 1/16 3/21 5/4
5/22 7/20 7/21 15/15
23/18 32/16 32/20
40/12 46/2 47/6 47/19
73/22 73/23 83/24
87/12 89/4 90/5 90/8
93/2 93/5 95/19 97/8
99/3 99/12 100/1
100/25 102/1 102/8
105/6 105/12 107/24
120/4 129/25 132/5
132/10 133/16 133/17,
133/21 134/5 134/7
138/15 140/15 141/8
143/9 144/18 144/24
146/1 146/23 146/25
150/4 152/13 160/14
161/6 161/15 161/21
163/10 164/2 167/22
168/22 170/20 173/23)
174/8 175/20 179/11
179/15 180/23 185/13}
188/6 188/9 193/9
193/14 194/16 195/6
197/22
update [5] 66/14
82/17 82/18 87/6
130/3
updated [10] 51/14
63/14 63/16 65/14
65/19 65/22 65/23
66/16 87/11 93/5
updates [4] 39/16
90/16 98/9 168/23
updating [2] 65/19
66/14
upheld [1] 95/3
upon [9] 111/10
156/4 156/5 168/12
175/23 176/6 189/15
198/10 198/22
uprated [1] 92/5
URN [1] 1/15
us [44] 1/3 1/12 9/25
14/8 16/12 17/16 20/9)
21/24 23/7 29/8 29/25
31/7 32/4 33/4 34/8
34/14 39/24 46/22
49/18 56/1 61/6 63/12
64/9 65/19 66/5 90/2
90/22 99/18 102/1
112/18 113/14 118/12)
118/21 126/14 129/16)
138/24 140/3 142/8
145/1 148/2 163/14
164/1 169/18 178/2
34/7 37/17 37/18 40/5)
100/12 100/18 100/19)
110/22 119/19 119/23)
use [13] 32/22 41/6
75/17 77/16 7/23
84/22 135/1 135/25
172/6 173/8
used [4] 67/6 71/7
124/7 193/25
187/8 198/18
using [8] 18/15 95/11
126/1 185/19 194/13
usually [5] 37/25
38/5 100/23 145/18
145/19
utilise [1] 165/9
Vv
vaguely [1] 50/3
value [2] 10/14
126/14
van [2] 77/1 179/19
variety [1] 89/7
various [3] 33/14
117/16 189/5
vary [1] 85/23
vast [5] 20/10 20/16
21/21 21/25 187/2
vastly [1] 186/23
vein [1] 156/17
Venn [1] 35/5
Vennells [15] 46/5
77/1 100/2 101/10
115/3 116/21 117/22
118/15 134/16 135/4
136/13 141/20 144/4
147/12 152/9
Vennells' [7] 47/6
115/12 122/18 125/24
126/23 133/18 141/25)
verify [5] 36/24 38/10
38/17 38/20 38/22
versus [5] 19/17 30/7I
139/11 187/7 195/7
very [90] 1/5 2/5
12/23 14/16 17/1 21/6
24/8 24/10 24/14
25/19 26/22 27/13
28/2 30/14 30/21 31/3
31/6 31/23 36/14 38/7
49/13 49/13 61/1
70/24 71/2 74/17
74/21 76/12 78/5 82/3
83/18 84/20 85/2 85/3)
89/19 94/16 96/3
96/14 105/8 106/16
109/8 110/9 110/12
112/23 114/1 114/2
116/23 118/15 121/18}
122/15 123/22 125/6
126/5 126/17 129/2
129/12 131/3 132/9
138/6 143/17 145/8
152/19 152/19 152/23
136/21 137/20 165/12
users [4] 187/3 187/7
112/11 124/12 125/19)
161/3 161/17 161/21
162/1 167/1 169/6
175/12 1814/7 181/19
185/1 185/2 187/1
190/12 192/9 192/24
194/6 198/2 199/6
199/11 199/14
vet [2] 31/23 36/10
vetted [1] 31/22
vexed [1] 59/17
via [2] 74/16 167/25
victim [1] 58/7
victims [1] 191/1
view [56] 7/13 10/10
41/12 41/25 43/3
44/21 44/21 66/18
79/19 95/23 98/5
98/13 98/23 108/14
108/18 109/7 110/2
110/4 110/7 110/18
110/20 118/19 118/19}
118/23 120/1 120/3
121/15 137/25 139/23
144/3 146/9 146/10
150/18 150/20 152/18}
152/24 153/3 158/16
158/19 158/20 158/21
162/5 171/15 172/11
174/22 174/24 182/11
194/7
viewed [3] 40/15
42/19 42/21
views [9] 6/1 14/6
21/18 27/9 27/20 30/6
38/15 39/24 160/24
Vince [2] 114/22
114/23
virtue [1] 10/4
vision [1] 119/10
visit [1] 49/16
voices [1] 144/10
volume [1] 122/11
volunteered [2] 8/9
33/11
vote [2] 7/14 144/9
122/2 126/25
waiting [6] 85/9 86/6
91/20 94/14 122/1
179/14
want [42] 8/10 10/14
10/25 11/4 11/13
12/21 24/16 30/24
31/8 32/10 44/16
60/18 85/12 102/4
114/20 114/22 122/3
169/14 169/25 173/17
183/11 184/14 184/16)
22/17 26/25 27/6 27/7
31/14 34/15 39/4 41/7,
Wot way [46] 4/20 6/15
wads [2] 160/21 8/4 10/23 12/18 17/7
4161/1 20/3 20/19 28/21
wait [4] 23/20 60/7 I 31/16 32/5 45/17
126/10 129/19 130/15}
130/16 130/18 130/25)
131/7 131/9 131/10
131/14 132/6 132/7
134/18 134/21 135/14I
140/8 160/15 170/6
170/17 170/24 171/13)
177/19 179/9 194/7
198/20
wanted [21] 15/7
15/20 17/1 31/9 31/14
48/22 76/8 106/23
122/1 125/21 132/8
139/2 139/9 158/19
158/20 175/9 175/17
183/12 190/13 194/17
195/4
wanting [3] 79/16
153/7 155/17
wants [6] 13/17
121/4 134/20 136/19
138/21 160/23
Warmington [1]
182/20
warn [1] 18/19
warning [1] 137/5
warrant [4] 22/15
75/21 75/22 160/22
was [593]
wasn't [51] 16/9
16/10 22/12 25/12
27/7 28/21 37/4 43/23}
58/25 67/2 75/21
77/19 80/20 83/18
96/13 97/11 107/2
107/3 122/2 124/3
127/3 127/3 127/5
1427/7 127/7 140/11
140/22 148/17 157/18)
157/19 159/2 159/19
159/20 161/8 162/17
162/19 163/5 167/17
173/23 174/8 174/24
175/14 176/19 177/3
178/18 178/24 180/19)
181/18 185/13 190/11
195/17
waste [1] 136/3
water [2] 127/14
147/7
49/14 68/12 74/25
75/12 77/8 77/11
83/14 83/19 86/19
98/10 99/5 106/11
107/6 109/14 109/24
110/12 114/11 124/21
125/1 126/3 127/14
129/7 135/21 142/6
147/3 157/18 160/23
181/20 182/9 182/14
(82) understanding... - way
Ww
way... [4] 185/15
187/4 194/24 195/25
ways [2] 19/4 56/24
we [370]
we'd [16] 27/8 30/25
33/10 40/16 81/14
83/16 104/6 110/23
140/14 147/13 148/1
163/3 192/19 192/20
192/21 197/11
we'll [6] 27/10 29/12
78/8 83/25 99/24
199/18
we're [30] 2/22 11/6
26/17 31/18 34/8
38/14 44/24 45/10
63/20 77/7 78/18
89/17 94/20 96/1
100/15 103/18 111/23}
120/4 126/12 131/20
132/11 139/15 144/12)
148/23 149/17 151/15
151/20 151/20 167/11
191/23
we've [18] 20/6 30/2
32/3 68/5 79/3 86/6
89/25 100/9 106/7
131/22 137/18 139/16
141/6 142/24 142/25
151/7 169/20 186/9
welthey [1] 46/24
wearing [5] 13/22
13/24 18/22 136/4
136/6
Wechsler [1] 133/19
week [1] 160/12
week's [1] 47/21
weekly [1] 100/23
weeks [1] 77/1
welcome [1] 141/2
well [180] 4/4 6/2 7/4
11/11 13/23 15/3
18/15 19/24 20/2
24/12 26/19 27/7
28/13 28/17 28/24
29/6 32/2 33/9 33/17
33/24 34/8 37/8 38/20
40/16 42/4 42/10
42/12 42/14 44/21
45/13 47/5 47/23 49/1
49/3 50/18 52/6 52/21
55/9 56/2 56/8 57/12
57/15 59/7 59/9 60/5
62/23 63/7 64/10
65/10 66/15 67/19
69/10 69/11 69/12
69/16 69/19 71/20
71/24 72/6 74/17 75/1
78/4 78/5 79/9 79/12
79/13 79/16 79/22
79/25 80/6 80/16 81/2
83/11 84/18 85/2 86/3
86/6 87/23 88/2 89/2
89/13 89/16 90/1
93/19 94/19 96/13
96/18 97/8 101/6
102/20 103/11 105/13}
107/8 107/23 109/5
110/1 110/5 110/8
110/9 110/10 114/10
120/3 120/25 123/2
123/25 127/17 128/23)
130/14 131/3 132/7
132/9 134/22 135/11
136/14 137/25 139/16)
139/24 140/4 140/19
140/24 141/7 141/11
143/16 145/8 145/14
145/25 146/20 147/13)
147/23 152/11 152/22)
152/24 156/23 157/24)
158/2 158/3 158/5
158/9 161/2 162/23
164/4 164/4 168/19
168/23 172/13 173/2
173/15 173/17 174/12)
175/9 179/19 180/19
180/22 181/19 182/9
184/5 184/8 184/12
184/14 184/16 186/19)
186/22 187/3 189/2
189/16 190/6 191/16
191/23 193/3 193/4
194/22 195/17 195/18)
195/19 195/25 196/3
196/7 196/21 196/23
197/25
went [7] 4/14 5/3
13/11 46/4 59/8
163/19 183/12
were [251]
weren't [8] 15/25
25/16 60/2 95/17
126/25 172/12 176/14,
187/22
Westminster [1]
35/20
what [253]
what's [14] 15/22
25/5 35/11 45/1 63/6
71/3 75/15 101/7
107/9 123/7 134/19
whatever [2] 19/25
37/4
WHD [1] 35/20
when [80] 3/22 5/22
6/5 6/25 7/15 9/1
11/14 12/12 13/2
13/11 13/21 14/25
16/2 16/22 22/2 23/9
23/24 27/13 28/11
34/17 36/13 42/25
50/3 50/10 50/14 53/9)
53/18 55/24 56/6
57/16 57/23 62/15
62/17 64/7 79/14
79/15 81/18 83/2
87/16 90/9 94/22 98/8
98/8 101/14 101/24
103/11 103/16 104/6
104/7 108/4 114/3
119/1 119/19 123/3
124/2 133/1 134/17
137/22 146/12 148/18
153/15 155/1 155/1
156/18 160/13 161/6
162/1 164/4 164/10
167/7 167/9 167/13
172/17 174/23 182/20
183/2 191/5 194/15
195/15 195/25
whenever [1] 59/11
where [70] 7/22 9/5
13/5 16/13 17/17
18/21 19/13 22/9 25/9}
29/2 34/16 39/4 44/2
59/23 60/6 60/15
62/23 62/25 65/22
70/20 75/7 77/25 78/6
79/25 88/14 94/18
96/17 97/12 97/13
100/9 102/19 103/10
105/2 108/6 108/17
110/9 115/9 118/4
118/14 119/18 120/4
122/13 127/20 129/1
136/2 139/12 139/25
140/7 148/1 149/16
151/20 152/17 154/19!
157/21 161/2 163/3
164/9 164/18 166/9
166/13 173/3 183/5
185/12 186/4 188/16
188/17 194/10 194/10}
197/11 199/3
whereas [1] 131/9
whether [46] 4/18 7/4I
15/5 21/16 25/8 33/10}
33/11 33/12 38/15
48/17 48/18 55/10
55/10 55/15 60/23
62/23 65/24 83/3 85/5
85/19 101/4 107/16
116/19 128/15 128/18
129/9 129/21 132/22
136/15 148/23 149/2
149/4 151/8 155/9
155/11 157/13 167/7
169/11 177/6 181/4
182/7 184/10 185/16
188/17 190/13 192/17
which [142] 4/25 6/7
6/22 6/25 7/15 12/1
13/6 13/21 13/23
16/24 18/11 22/3
23/22 24/18 25/17
26/23 30/15 32/13
38/1 38/8 38/22 40/4
40/21 41/5 42/22
44/19 45/16 48/10
48/21 49/19 49/19
50/5 50/14 50/15
51/12 53/25 54/1
54/16 57/7 58/12
58/23 62/22 65/4 66/4
66/6 67/1 67/4 68/3
68/7 68/20 68/24
69/20 70/7 70/14
70/23 71/1 71/2 71/22
73/13 73/18 74/21
74/24 75/25 78/5 83/4,
88/17 89/11 89/16
89/20 89/24 93/9 93/9)
95/13 95/22 97/18
98/6 98/22 99/8 100/4
102/12 105/19 106/20)
106/20 107/12 108/15}
110/14 110/18 110/25)
111/5 115/5 115/5
116/1 117/5 119/22
121/17 121/23 126/11
131/24 136/4 140/17
141/22 142/3 142/13
142/14 143/5 148/8
152/16 153/13 153/21
155/18 156/12 157/17)
159/4 160/22 161/25
164/6 164/23 165/21
168/17 173/25 175/23}
175/25 176/3 179/10
181/15 182/5 184/1
185/8 186/2 187/1
187/6 187/15 188/3
189/24 189/25 190/16
193/8 193/15 195/20
195/22 197/24 198/18}
whichever [1] 110/13}
While [4] 176/21
whilst [10] 1/22 4/21
8/12 13/17 20/2 25/3
46/17 108/3 118/5
142/20
who [60] 10/11 27/14
29/17 33/25 39/12
39/14 40/9 42/8 55/15
61/25 63/5 79/7 79/21
83/18 87/25 87/25
87/25 88/3 89/3
112/18 113/1 118/17
118/25 121/12 125/16}
125/17 126/18 134/23}
138/18 140/4 140/23
141/7 141/9 142/7
145/10 145/19 145/20}
146/16 146/25 147/17)
148/22 149/5 149/17
150/19 151/21 151/22,
153/4 153/4 155/5
163/4 170/3 170/4
181/13 182/17 182/17
183/13 185/18 186/13}
192/8 193/1
whoever [1] 138/22
whole [13] 6/17 26/7
53/19 93/15 93/16
93/17 158/12 182/21
183/2 183/3 190/21
192/5 196/10
wholly [3] 10/5 177/6
191/2
whom [3] 54/20 55/2
55/12
whose [3] 88/9 137/2
162/14
WHSmith [1] 48/19
why [67] 7/5 7/6
13/12 13/12 14/4
15/14 26/23 30/23
31/11 33/22 42/2
42/25 43/8 43/24
43/25 46/21 51/4
53/10 63/2 67/2 67/3
67/4 69/7 71/9 71/24
73/4 74/21 80/14
83/21 86/1 88/8 89/15]
89/20 89/25 91/22
94/19 95/22 96/25
97/6 97/7 98/2 100/4
100/18 105/13 105/17)
110/4 114/20 114/21
116/6 116/6 117/12
120/18 131/13 134/13)
139/9 145/13 146/15
155/9 158/6 158/10
164/24 172/13 173/17
183/8 185/8 186/21
195/8
wide [3] 92/14
149/13 185/3
widen [4] 40/3 44/1
92/6 92/15
widened [1] 77/19
widening [2] 41/3
43/24
wider [8] 11/21 11/22
52/17 75/25 78/2
115/6 125/22 177/5
Wilcox [2] 191/12
191/15
Wilcox-ian [1] 191/12
will [37] 9/3 14/1
23/18 30/18 33/19
35/25 39/23 41/16
44/21 46/21 47/15
47/20 47/23 60/10
87/10 87/14 87/16
93/4 100/12 110/10
125/5 127/17 127/21
130/11 130/12 130/14)
130/14 150/15 159/24I
161/12 174/22 179/11
181/3 181/4 181/25
182/2 196/5
WILLIAMS [2] 198/3
200/7
Willott [6] 1/21
113/18 116/16 124/8
130/1 142/19
(83) way... - Willott
Ww
wings [1] 122/1
wins [1] 140/23
wish [1] 128/3
wished [1] 111/13
wishing [1] 111/8
withheld [1] 107/6
withhold [4] 107/8
withholding [1]
101/23
within [18] 3/6 5/16
8/6 14/6 14/21 15/12
21/25 32/14 47/14
73/19 84/22 93/14
4111/7 112/19 115/12
129/22 162/12 163/18
without [12] 20/14
21/15 22/25 23/12
25/18 84/17 115/16
115/21 161/17 161/18}
166/25 183/13
WITN00140100 [1]
1/16
WITN10190100 [1]
123/10
WITN10200100 [1]
136/25
witness [31] 2/1 2/13
3/20 6/19 6/21 9/25
11/24 17/16 18/21
20/9 23/7 31/2 55/20
58/9 88/3 90/23 95/23,
97/3 102/7 102/8
107/20 107/24 128/1
128/23 136/24 141/22)
145/6 153/12 161/2
164/1 199/12
wobble [1] 85/4
wobbles [2] 84/6
84/23
won't [3] 11/16 43/22
160/23
wonder [3] 60/23
129/9 169/11
word [9] 30/11 84/12
84/18 84/21 93/21
113/12 134/10 138/3
185/13
worded [1] 17/11
wording [2] 99/9
182/10
words [11] 18/4 28/3
41/6 59/4 68/15 77/23
84/21 88/1 88/21
95/11 191/8
work [15] 8/4 41/1
45/10 68/10 68/12
72/16 72/21 77/13
125/20 126/2 131/20
161/24 188/18 195/7
197/6
worked [2] 30/18
153/5
working [21] 3/22
30/16 31/12 32/9 72/7,
75/8 77/14 78/5 91/11
99/8 128/9 132/2
137/12 137/23 161/23}
167/20 176/1 181/17
195/20 196/2 197/9
workload [2] 4/21
4/24
works [2] 4/20 10/23
worried [12] 8/19
8/24 44/12 100/18
104/21 105/8 106/16
135/22 135/23 136/18)
138/7 178/6
worries [5] 6/4 19/13
116/12 117/2 138/8
worry [4] 134/4
137/17 138/9 184/4
worrying [1] 183/13
worth [4] 26/16 95/16I
134/2 187/6
worthwhile [1]
133/24
would [209]
wouldn't [19] 6/24
10/22 20/21 21/19
34/12 36/6 37/13 38/1
38/12 38/13 38/20
59/2 67/20 126/15
126/16 127/8 176/8
182/7 197/12
wrestle [1] 104/11
write [5] 31/16 33/24
67/20 190/15 196/17
writer [1] 28/2
writing [6] 34/8 68/24,
88/24 114/12 149/3
190/19
written [3] 50/3
123/18 194/24
wrong [27] 7/13 7/13
37/4 63/18 70/1 98/22
98/22 105/7 105/20
105/21 107/10 107/16)
108/5 108/20 117/5
119/5 135/11 137/21
137/25 145/21 146/19)
146/21 163/19 163/20)
163/23 177/25 178/2
wrongful [3] 188/3
189/8 189/10
wrongfully [1] 74/9
wrongly [7] 43/6
68/20 74/20 79/20
154/6 155/2 163/5
wrote [3] 82/16 90/9
174/1
WYN [2] 198/3 200/7
Y
yeah [68] 5/9 7/11
8/25 12/6 14/24 14/24
17/20 18/3 18/23 19/4
19/3 21/23 22/22
22/24 23/2 24/1 24/1
25/25 26/2 26/2 26/4
26/6 33/3 34/5 35/19
35/22 37/23 41/18
42/21 44/7 44/23
44/25 45/8 47/5 51/23)
52/23 63/2 65/13
66/20 71/5 71/20 75/1
76/10 76/24 82/1 82/4
84/11 87/2 89/2 90/7
91/1 95/2 97/21
105/13 105/25 111/14
116/8 117/20 128/20
137/10 139/4 142/10
143/2 152/8 153/11
174/3 175/15 192/4
year [11] 40/17 41/20
76/15 81/23 92/1
118/4 154/18 187/7
187/12 198/18 198/22
years [14] 6/6 6/20
42/5 43/20 45/10
62/10 94/16 95/17
98/16 126/19 175/3
187/9 192/13 193/7
years' [3] 26/16
95/16 187/6
yes [242]
yesterday [1] 39/25
yet [8] 13/10 27/15
39/22 43/1 47/19
87/16 111/9 171/4
you [731]
you'd [8] 1/23 19/22
39/4 42/17 51/4 53/12
71/8 174/24
you'll [5] 27/19 48/23
79/13 92/15 163/9
you're [35] 7/11 7/12
11/12 11/14 12/20
12/23 13/14 18/6
26/20 33/20 34/6
36/10 51/11 63/6 63/7
65/5 75/14 75/24
98/18 100/2 111/4
126/25 132/24 132/25)
133/17 146/5 148/21
170/25 172/25 175/18}
178/16 178/17 184/5
187/13 196/11
you've [23] 1/14 8/23
11/16 11/20 25/21
25/22 25/23 26/3 26/7
27/13 56/12 57/16
57/17 69/19 74/19
77/16 94/11 96/15
106/2 142/8 143/23
177/16 187/3
your [129] 1/12 2/10
2/14 2/17 3/20 4/5
4/10 4/10 6/11 6/19
6/21 8/18 9/16 9/25
11/24 12/19 17/8
17/13 17/16 17/18
17/18 17/23 18/4 18/4}
18/21 19/4 20/9 20/11
20/24 21/24 22/17
22/19 23/7 28/1 29/22
30/6 31/21 31/22
34/16 35/25 36/9
37/20 41/13 41/13
45/9 46/9 57/24 58/9
59/19 60/12 61/9 62/1
62/6 62/7 76/1 76/6
82/24 82/25 84/12
90/23 90/23 91/8
91/17 93/20 96/7
98/23 101/25 102/7
102/8 102/14 102/19
103/10 107/20 107/24}
110/6 111/7 114/8
114/9 116/24 117/6
118/19 122/6 126/1
127/13 127/22 131/7
132/20 134/11 140/7
140/8 141/21 146/9
147/10 153/8 153/12
156/3 157/22 158/25
160/14 160/24 164/1
167/13 169/2 170/7
173/24 173/25 174/22}
174/24 175/10 176/4
176/11 179/10 179/13}
179/20 180/15 183/25]
184/24 188/11 189/18}
189/19 190/3 191/11
192/25 194/1 196/17
196/20 197/17 199/4
199/11
yours [1] 162/21
yourself [6] 12/10
21/13 115/25 116/4
171/22 191/8
Zz
Zebra [2] 157/5
158/23
Zehnder [2] 151/21
152/17
zone [1] 26/20
(84) wings - zone