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The Post Office Horizon IT Inquiry 15 July 2024
Monday, 15 July 2024
(12.00 noon)
Announcement re Phase 7
MS PRICE: Good morning sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, I can. Before we start hearing
evidence, Ms Price, I have an announcement to make about
evidence gathering relating to the final phase of this
Inquiry, so I propose to make this announcement now, all
right?
MS PRICE: Yes, sir.
SIR WYN WILLIAMS: As Core Participants and members of the
public will be aware, the final phase of the Inquiry,
Phase 7, is concerned essentially with the here and now.
I will be enquiring into such questions as:
How does the Post Office treat its subpostmasters?
What is the culture of the Post Office like now?
How does that culture compare with the culture
prevailing before the Group Litigation?
How do those who are entitled to compensation view
their experiences of making claims?
Has the Post Office and Government delivered on its
promise to provide compensation which is full and fair?
In order to help me answer these questions, I have
commissioned YouGov, an independent research and data
analytics firm, to conduct two surveys. One survey is
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when responding to the surveys without fear of
repercussions.
I want to make public too that Post Office, at the
Inquiry's request, will shortly be writing to all
applicants to the Historic Shortfall Scheme inviting
them to may have their legal privilege in respect of
certain information about the scheme.
The Post Office is taking that step so as to enable
it to answer requests for information which the Inquiry
has requested it should provide. I urge all applicants
to the scheme to respond positively to this letter so
the Inquiry is given as much information as possible on
how the scheme is running.
The answers which are provided to the surveys will
be treated as formal evidence to the Inquiry and they
will be analysed by YouGov in a report. Such a report
will, I have no doubt, help to make sure valuable
lessons can be learnt.
From this week, some 16,000 people will be contacted
directly via email. The surveys can be completed online
or over the telephone for those who need reasonable
adjustments. If you are both a current subpostmaster
and you applied for compensation understanding the
Horizon Shortfall Scheme, you will receive two separate
survey links, one for each survey.
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aimed at current subpostmasters, the second survey is
for those who have applied for compensation under the
Horizon Shortfall Scheme.
I want to hear from all of those persons to whom
these surveys will be sent. As people with direct
experience of the topics covered by the surveys, they
are best placed to provide me with invaluable
information about key issues relating to current
practices within the Post Office and how the largest
compensation scheme has operated in practice.
To current subpostmasters, let me make one thing
clear: I know full well it can be difficult to speak
about the challenges you have faced, or still face at
work, or in your claims for compensation. Let me assure
you that these surveys are in no way connected to the
Post Office; they are anonymous and no individual will
be identified when the findings are published.
Some of the applicants to the Horizon Shortfall
Scheme will have negotiated compensation payments with
Post Office on a without-prejudice basis. I am pleased
to be able to report that Post Office has agreed to
waive the legal privilege which attaches to such
negotiations, specifically for these surveys. This
means that those applicants who conducted negotiations
on a without-prejudice basis can share their experiences
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Let me conclude by saying this: human stories are at
the heart of this Inquiry. As will be obvious by now
and as I have said from time to time, I have been deeply
affected by the accounts of hardship and suffering
endured by many. I urge all those who are contacted to
complete the surveys and I offer my heartfelt thanks now
to all those who take the time and trouble to do so.
Now, Ms Price, we can now resume with the evidence
on Phases 5 and 6.
MS PRICE: Thank you, sir.
Please may we call Sir Stephen Lovegrove.
SIR WYN WILLIAMS: Yes, of course.
SIR STEPHEN AUGUSTUS LOVEGROVE (affirmed)
Questioned by MS PRICE
MS PRICE: Could you confirm your full name, please,
Sir Stephen?
A. Stephen Augustus Lovegrove.
Q. As you know, my name is Emma Price and I will be asking
questions on behalf of the Inquiry.
Thank you for coming to the Inquiry today to assist
it with its work, and for providing the detailed witness
statement which you have in advance of today. You
should have a hard copy of that witness statement on the
desk in front of you; do you have that?
A. Ido.
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The Post Office Horizon IT Inquiry
Itis dated 14 June 2024. If you could turn to page 56
of that document, please.
Yes.
Do you have a copy with a visible signature?
Ido.
Is that signature yours?
Itis.
Are the contents of that statement true to the best of
your knowledge and belief?
They are.
For the purposes of the transcript, the reference for
Sir Stephen's statement is WITN11010100.
Sir Stephen, your witness statement is now in
evidence and will be published on the Inquiry's website
in due course. As such, I will not be asking you about
respect of that statement, just certain specific issues
which are addressed within it. Okay?
Understood.
I'd like to start, please, with your professional
background and the roles you have held which are
relevant to the matters being explored by the Inquiry.
You explain in your statement that, upon graduation, you
worked as a small management consultancy specialising in
the media sector, where you remained for around three
years; is that right?
prominence and extremely severe commercial problems?
That's correct.
In particular, you say you helped to establish the
Hooper Review in 2007, which ultimately recommended the
separation of Post Office Limited from its parent
company, Royal Mail Group, in 2008?
Yes.
You remained Chief Executive of the Shareholder
Executive until the end of January 2013; is that right?
That's right.
In February 2013, you were appointed the Permanent
Secretary of the Department of Energy and Climate
Change --
Yes.
-- a role you performed until April 2016 --
Yes.
-- when you were appointed Permanent Secretary of the
Ministry of Defence?
Yeah -- yes.
You continued in that role until January -- let me just
check my dates on that -- until January 2021, when you
were appointed as a National Security Adviser?
The National Security Adviser, yes.
You stepped down that role in September 20227
Yes.
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That's correct.
Then from 1993 to 2003 you worked in investment banking
at the bank Morgan Grenfell, working in its media team?
That's correct.
In early 2004 you joined the Shareholder Executive,
working under the then Chief Executive Richard
Gillingwater; is that right?
That's correct.
Given your media experience, you say you initially
worked almost entirely with the Department for Media,
Culture and Sport; is that right?
That's correct.
Then in around 2005, you were asked to become the
director responsible for Royal Mail Group and, by
extension, its subsidiary, Post Office Limited?
That's correct.
Was this the first time you were involved in Royal Mail
Group matters?
It was.
In June 2007, you became the Chief Executive of the
Shareholder Executive?
Yes.
But you say at paragraph 7 of your statement that you
stayed closely involved with the Government's strategy
for Royal Mail Group, given you describe as its scale,
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You were then the Prime Minister's Adviser on Defence
Industrial Strategy until December 2022?
Correct.
Since leaving Government, you have held number of roles
including being Chair of Rolls-Royce SMR?
Yes.
Governor of the Wellcome Trust?
Yes.
Visiting Fellow at Colombia University's School of
International and Public Affairs?
Yes.
And a Senior Adviser at an investment bank?
Yes.
I'd like to turn, please, to the Shareholder Executive's
responsibility for Royal Mail Group and Post Office
Limited. Could we have on screen, please, paragraph 17
of Sir Stephen's statement, which is on page 7, towards
the bottom. You explain the Shareholder Executive's
principal purpose, starting in the penultimate line on
this page, and you say:
"ShEx's principal purpose was to ensure that
Government was an effective and intelligent
shareholding, working with the boards and management
teams of HMG-owned businesses to ensure that they were
being run in a way that was commercially effective but
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that was also within the clear confines of the
Government's policy objectives."
In your view, what was required to ensure that the
Government was an effective and intelligent shareholder?
In the first place, there needed to be a clear and well
articulated set of policy objectives for the companies
in question. In the second place, there needed to be
clear and well articulated set of commercial objectives
also and, to the extent where -- that we possibly could,
we wanted to ensure that the corporate apparatus and the
corporate governance of the assets for which we were
responsible as nearly approximated best practice in the
private sector as we could as well.
And in that regard, a lot of the focus was making
sure that the Board was properly constituted, it had the
right kind of skills on it, that the Chair was
responsive to the shareholder and that we kept
a constant dialogue with the management of the asset and
the directors of the asset, such that we would know what
was going on and whether or not Government's objectives
were being fulfilled.
In the context of government-owned assets, did this
require a balance between ensuring commercial
effectiveness and ensuring that the asset operated
within the parameters of Government policy objectives?
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some very specialised businesses in there where the
skills to run them and to recruit the right people to
perform the assets’ business would simply not have been
able to have been done within central Whitehall, so we
would set up a - or typically there would be
an organisation set up at arm's length from Government,
in order to be able to recruit the right people to do
that and often to have certain types of pay freedoms,
which would allow for private sector executives to be
attracted to work for these assets in the national
interest.
Could we go, please, to paragraph 23 of the statement,
that is page 10 and, in this paragraph, you describe
Post Office Limited's social role. You say this:
"POL was an unusual organisation in that it clearly
had its own status and identity as an ALB but was
a wholly-owned subsidiary of another ALB: RMG. As
an ALB, POL had a vital social role in maintaining
branches in remote and rural locations, providing
Government services as well as postal services, and
playing an important role in financial inclusiveness.
The network would always require significant subsidy if
it were to be maintained at the size Government policy
dictated. However, significant elements of POL were
commercial, including the financial services that it
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Yes, it did. If there were no policy objectives at all,
typically what would happen is that the Government would
seek to privatise the business. That would often come
with a degree of regulation because, clearly, that's
important in many businesses but, if there were no
policy objectives that the Government had for the
business, we didn't think that it was a very -- or the
Government at the time did not think that it was
a particularly sensible thing to hold.
A good example of that would have been the Tote,
which was a betting business, which, for a variety of
historical reasons, the Government held. There was no
reasonable policy objective in the Government owning
a string of betting shops and, as a result of that, it
was sold.
You go on at paragraph 18 to say that, "In pursuit of
that objective the model necessarily adopted by
Government was that of ALBs", arm's-length bodies. Why
do you say "necessarily" there?
Because the assets and the companies that fell into the
Shareholder Executive portfolio were typically very
complicated and often quite large, and the idea that
they would be capable of being managed and -- or managed
mainly, actually, within central Whitehall would have
led to very, very inefficient practices. There were
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offered and the retail element of most post offices. As
a company it was best run by professional executives
with relevant commercial experience, allied to a clear
understanding of the social role the Post Office was
expected to play.”
Was the maintenance of Post Office Limited's social
role a Government policy objective?
Yes, it was.
Put simply, was it the case that, even if it did not
make financial sense to keep Post Office branches open
in rural areas, the social value of doing so justified
that?
That is definitely the case and there were -- well,
there was at least one very wide public consultation on
the size of the Post Office Network, which happened
while I was at the Shareholder Executive, to ascertain
the exact size of that network. And I should say it
required a Government subsidy to keep the network at the
size that Government policy dictated.
Would it be fair to say that subpostmasters running
branches in rural areas, as well as their staff and Post
Office employees employed in such branches, played
an integral part in delivery of Post Office Limited's
social role?
Yes, it certainly would.
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In other words, the social role was not possible without
people willing to run and staff Post Office branches
across the country?
Correct.
Would you agree, therefore, that how those people were
treated by Post Office Limited was directly relevant to
a key Government policy objective for Post Office
Limited?
Yes, I would.
Post Office Limited was a 100 per cent owned subsidiary
of Royal Mail Group pre-separation, and you observe in
your statement that, in normal circumstances, there
would not have been any supplementary Government
oversight of a subsidiary of a government-owned company.
Do I summarise your evidence at paragraph 24 of your
statement correctly in this way: the fact that there
was, unusually, direct oversight of Post Office Limited
pre-separation was a consequence of the social function
that Post Office Limited Network was expected to
perform?
Yes, you would be correct in saying that. I should say
that the oversight of the Post Office was a mixture.
Because of the nature of its -- its subsidiary nature,
it was a mixture of oversight of POL directly, and
conversations with POL Management and Board directly,
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much of the management information that the executives
and the board of the asset were using to run the
company, to assist us in our own oversight of the asset.
Would you agree that the reason for this -- and that is
the fact that there is monitoring of operational
performance and there isn't a clear-cut distinction
between operational and policy -- is that there may be
times when the way in which an ALB conducts itself at
an operational or contractual level can cause concern
for ministers at a policy level?
Yes.
Particularly where, as a matter of policy, there is
a social role performed by a Government-owned asset, or
in this case a subsidiary of a Government-owned asset,
would you agree that it is vital that there is effective
oversight of key operational and contractual matters?
Yes.
Would you also agree that, in order for oversight to be
effective, the Government must have access to adequate
information about key operational and contractual
matters?
Yes.
In particular, it was important, wasn't it, that
operational or contractual matters which gave rise to
risk were identified and monitored at every level of the
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and conversations with the Royal Mail Group's management
and Board members as well because, of course, as the
parent -- as the corporate parent -- they had
responsibility for the Post Office.
Indeed, you say in your statement that Royal Mail Group
was expected to discharge its ownership responsibilities
towards Post Office Limited in a manner consistent with
the Government's policy objectives?
That's correct.
You observe at paragraph 31 of your statement that the
types of decisions that were for ALBs to take, rather
than ShEx or the Government, would include matters which
are sometimes described as "operational" or
“contractual” but you say that, in your view, this
terminology does not always help to distinguish between
those matters in which Government became involved and
those in which it did not; is that right?
That is correct.
You also make clear that the Government had a role in
establishing policy goals and monitoring operational
performance, so, in short, it would not just set the
strategy for an asset and leave it to it?
That is correct. I mean, the strategy for an asset
would be set in cooperation with the executives and
board of the asset, in most instances, and we would use
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governance structure?
Yes.
So those levels being: the Post Office Limited Executive
level; the Post Office Limited Board level; the ShEx
level; and the Government Departmental level?
All of those, although you miss out the Royal Mail Group
in that. You would have expected risks and operational
performance measures for POL to have been included in
the Royal Mail and risk registers and, you know,
management packs as well.
Indeed. Can you help at all with what, if any, training
was given to ShEx employees about the circumstances in
which operational or contractual matters might be
relevant to wider policy or strategic considerations?
I'm not sure that, in the precise terms in which you
talk about it, we had specific training like that.
There would certainly be an induction period when
a civil servant would find themselves being assigned to
a particular asset, they would learn about it, they
would learn about the policy objectives, they would
learn about the commercial objectives, they would learn
about the asset in general and, clearly, there were
plenty of people in Shareholder Executive, certainly
towards the end, who had experience of helping people
through.
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So it was more of a conversation, really, than
a specific programme.
Do you believe that ShEx's employees understood that the
distinction between operations and strategy or policy
was not always clear-cut?
Yes. I mean, there was a very fuzzy line between these
things sometimes and there continues to be in every
organisation I've ever been involved in.
Before we come to the information sharing and risk
identification and management mechanisms, which were in
place for Post Office Limited, I'd like to deal, please,
with the question of who held the shareholder role
relating to Post Office Limited and who held the policy
role relating to Post Office Limited. Could we have on
screen, please, paragraph 26 of Sir Stephen's statement,
that is page 11. At the start of paragraph 26, you say
this:
"In general, ShEx would oversee the shareholder
function and usually the Department (or another
department if that was where the policy objectives sat)
would oversee the policy function, though in some cases
this would sit with ShEx instead."
Why was the general position as you describe it?
The Shareholder Executive was aiming to bring
a distinctive capability to Government which did not
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Is it right that, for the whole time you were at the
Shareholder Executive, ShEx held both the shareholder
and policy roles relating to Post Office Limited?
Yes, it is.
\s it right that this was in contrast, as you refer to
at paragraph 26 a little further down, to other assets
where the policy role may have been with ShEx in the
early days but it transferred to the relevant Government
Department thereafter?
That's correct and, in the Royal Mail's case, we
inherited -- when there was a lift and shift,
effectively, of the whole of the Royal Mail and postal
services team into Shareholder Executive, along with
that came the team that looked after the things such as
the requirement for a six-day universal service in the
Royal Mail. We felt that gave rise to complications
that were difficult to reconcile within Shareholder
Executive, so we moved that back into the main part of
the Department.
As far as you're aware, why did the policy role for Post
Office Limited stay within the Shareholder Executive?
I'm afraid I don't really recall, at this time, and
I wouldn't like to speculate, actually. I don't quite
recall. Clearly, we were thinking that there, in
an ideal world, should be a separation between policy
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exist before 2003/2004, which was that there was a level
of commercial, professional expertise overseeing these
assets. So, on the whole, what we would try to do would
be to look at both the policy function and the
commercial function, in a way that had not happened
before, where civil servants, policy civil servants,
would typically really just look at the policy function.
That gave quite a lot of latitude to the boards of
the ALBs who were then effectively allowed to run the
commercial functions as they saw fit, and it was
attempting to redress that kind of balance that -- for
which the Shareholder Executive would be -- was set up.
I mean, on the whole, we wanted policy objectives,
though, to be set and discussed with ministers, who.
ultimately set those policy objectives, by policy
officials because it was not for us to decide, for
instance, whether or not the purposes of Channel 4 were
going to be met by Shareholder Executive oversight or,
indeed, the purposes of the Post Office, size of the
Network, were going to be discharged by a purely
commercial approach's. So we wanted, on the whole,
where we could, to get the policy objectives out of
Shareholder Executive. We weren't always successful
with that and we weren't wholly successful on Royal Mail
and Post Office.
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and commercial, otherwise we wouldn't have done what we
did with Royal Mail. Why we didn't do that with the
Post Office at the time I'm not sure.
Could we have on screen, please, UKGI00001339. These
are the minutes of a Shareholder Executive Board
meeting, which took place on 15 September 2010. This is
a meeting at which you were present and you comment on
these minutes, if you wish to refer to it, at
paragraph 28 of your statement.
Looking, please, to the second page to
paragraph 2.1, this paragraph comes under a heading
which was at the bottom of the previous page "ShEx Board
Governance", and the minutes at 2.1 say this:
"Philip went through his paper on the ShEx Board's
remit, particularly alerting members to the following
considerations ..."
The first bullet point there:
“Policy restraints -- the Board will give advice on
the operational implications and effectiveness of policy
proposals ..."
Then at 2.2, there is this:
"Board members went on to discuss the Board's role,
effectiveness and accountability. The Board saw itself
as an advisory group to help ShEx fulfil its role in
Government and escalate issues when necessary, with
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accountability to ShEx. Members commented that there
may be situations where the Board disagrees with policy
decisions, and therefore ShEx's involvement in some
cases which could compromise ShEx's capability or affect
its reputation. Stephen
Was that you?
That was.
"Stephen stated that ShEx would always start from
a commercial position but would overlay policy
priorities in order to get a settled and agreed
position.”
The concern raised here was that there may be
‘occasions when the ShEx Board disagrees with the policy
position in relation to an asset. With this concern in
mind, where ShEx holds both the shareholder and the
policy role in relation to an arm’s-length body, is
there a risk of a conflict between the two roles?
There could be the risk of a conflict between the two
roles, yes. I mean, I should say here -- I mean it
wouldn't have found its way into these minutes because
they wouldn't have been written like that, but the
statement where -- situations where the Board disagrees
with policy decisions is a peculiar one because we're
talking there about the Board of Shareholder Executive
and it's not really in ~ not really the Board's role or
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sort of, afterwards, and it was an iterative process.
Could we have on screen, please, paragraph 29 of
Sir Stephen's statement. That's page 12, towards the
bottom of page 12, please. You say here:
"I discuss the role of the ShEx Board further below.
Part of that role was to ensure that ShEx maintained
a commercial outlook in its dealings with both ALBs and
Government departments, and to guard against a danger
that the balance of ShEx's activities would tilt too far
away from the interests of the taxpayer. To put it in
other terms, the Board here was seeking to ensure that
priority given to the shareholder function and the
policy function remained in the correct proportion,
a concern that was particularly prevalent at the time of
the meeting with the new Coalition Government's emphasis
on efficiencies."
So you're referring back there, aren't you, to the
minutes we've just looked at -- and do look at the
paragraph above if you need to, for context, in terms of
the timing of the meeting --
lam, yes.
-- and that coinciding with the new Coalition
Government's emphasis on efficiencies?
Yes.
Did ShEx ever feel under pressure in light of the new
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place to disagree with policy decisions which have been
signed off by ministers. So that is a slightly strange
formulation, which I think is -- in hindsight, doesn't
look right to me.
I mean the point that I was trying to make in the.
rest of this paragraph was that in most situations, the
size of the Post Office Network being a very good
example, there was going to inevitably some form of
compromise between a policy objective and a commercial
objective and it was our role to try and bring out where
the trade-offs were likely to be and then to end up with
a settled and -- I think I say settled and --
Settled and agreed.
-- a settled and agreed position. And that was really
about getting an agreed position between the policy
imperatives and the commercial imperatives. I mean,
clearly, for instance, if you wanted -- if the policy
imperative had been that we need a Post Office Network
of 20,000 branches, rather than 11,500, which I think
was the position at the time, that would have required
a very much greater Government subsidiary and, clearly,
the trade-offs there had to be discussed and analysed
properly.
And it was often, I should say, easier to start from
a commercial position and then work with the policy,
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Coalition Government's emphasis on efficiencies, to give
greater priority to the shareholder role than the policy
role?
No, I don't think we ever felt we were under a new type
of pressure, there was -- I mean, managing public money,
for instance, which was one of the core documents that
civil servants have to abide by, and accounting officers
in particular have to abide by, talks about
affordability, for instance. So affordability is always
something that civil servants have to think about when
they are assessing policy proposals. A new
Government -- new ministers and a new Government are
perfectly entitled to shift the balance of policy in one
direction, and if that brings affordability kind of
issues along with it, then so be it. You do what you
can to make sure that this new policy would be workable.
It may have been the case at the time -- I mean,
I think it probably was the case at the time -- that the
Coalition Government's emphasis on efficiencies did mean
that affordability constraints were tighter but they
were maybe slightly different in degree than in kind
from a normal conversation that you would have.
The Inquiry has heard evidence from Mark Russell, who
became the CEO of the Shareholder Executive in 2013,
that an advantage of the shareholder and policy roles
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being held separately for an asset is that it provides
another set of eyes on key issues. Would you agree with
that?
Yes, I would.
In your view, is it better practice to keep the
shareholder and policy roles separate?
Yes, I do agree with that.
Are there any other reasons, apart from the reason given
by Mark Russell, which I've just referred to, for that?
As I said, the -- reaching a settled and agreed position
for a particular asset or a particular policy is going
to be a function of negotiation between the various
differing, completely legitimate, agendas that people
bring to bear on it. And, in some ways, I think the
clarity that is brought to those potentially differing
perspectives is enhanced if the teams who are looking at
the policy issues, as opposed to the commercial issues,
are separate.
I'd like to move, please, to information sharing within
the governance structure for Post Office Limited. You
say at paragraph 35 of your statement that the Board is
entitled to expect accurate and full information to be
provided to it by the Executive Team in order to
discharge its functions. You are referring to the Post
Office Limited Board here, is that right?
25
and Nominations Committee and appointments of Executives
are made by the Board.
Now, we would, as Shareholder Executive, have wanted
to have, if at all possible, participated in the
discussions around the Executive's appointments, and we
would have given our views if we felt that there were
any particular names that we didn't think were
especially suitable or were suitable, but we wouldn't
try and interpose ourselves into what would be standard
corporate governance.
In terms of information, which is a slightly
different matter, the principal responsibility of how
the information comes up to the Board is that of the
Board, and you expect to have experienced Non-Executive
Directors and chairs who would know whether or not the
kind of information that they were getting was the right
kind of information, whether or not anything was being
elided or missed out, and this a panoply of different
types of things that would assist them in that, most
notably internal audit, and the company secretary, and
the other risk functions, effectively, in the board.
As I say, for us, in Shareholder Executive, we
would, by and large, work through that type of
mechanism, rather than trying to interpose a sort of
totally different information regime on companies
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I'm referring, actually, to the board of any company,
whether or not it's privately owned, publicly owned, or
a publicly listed company. The board has the principal
responsibility for the proper running of the company
and, if it is not getting the right kind of information
from the Executive, then that is a very serious matter.
You explain at paragraph 39 of your statement that Her
Majesty's Government would usually be involved in the
appointment of the chairs of assets operating as
arm's-length bodies and might hold approval rights over
other board members but, in general, it would not
appoint key executives; is that right?
That is correct.
In these circumstances, how did ShEx satisfied itself
that the Executive was up to the task of, and was in
fact providing, accurate and full information to the
Post Office Limited Board?
The principal role of -- well, no, that's not -- let me
rephrase that.
One of the principal roles of the Board is to ensure
that the Executive of the company is properly
constituted to be able to effectively run the company.
There are lots of bits of corporate governance around
that which have evolved over the years and continue to
evolve but, basically, they go through the Remuneration
26
because that would have been duplicative and unhelpful.
Can we have on screen, please, paragraph 40 of
Sir Stephen's statement. That's page 19. About four
lines down, at paragraph 40, you say this:
"ShEx and the responsible department had to sustain
and manage a close working relationship with the Chairs,
Boards and executive teams of its assets. This was not
always easy. At the time when I was Chief Executive,
many senior executive teams were used to a culture in
which they had a high degree of autonomy in how they ran
the companies, as they had become used to a formerly
very hands-off approach adopted by policy officials.
They saw the relationship with Government as being akin
to that between a publicly listed company and
an institutional shareholder, not that between a company
and its 100 per cent owner, or sometimes seemed to feel
that they had been appointed by a Secretary of State to
do a job and should be left alone to get on with it. As
is discussed below, there was considerable resistance in
some ALBs to greater involve from ShEx, including [Royal
Mail Group] and [Post Office Limited], in particular
with regard to the appointment of Shareholder NEDs
[Non-Executive Directors].”
Starting with the senior Executive Team at Post
Office Limited, when you were the Chief Executive of
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ShEx, did you see or were you aware of, this resistance
to greater involvement from ShEx, leading to the
Executive Team at Post Office Limited being resistant to
sharing information about operational and contractual
matters with ShEx?
I did not. I was aware of that kind of dynamic at the
parent, with the Royal Mail Group but -- because that
was where my focus primarily was. That's not to say
that it didn't exist at POL but I was not aware of it.
Now, in relation to the Post Office Limited Board, did
you see or were you aware of this resistance to greater
involvement from ShEx leading to the Post Office Limited
Board being resistant to sharing information about
operational and contractual matters with ShEx?
Again, I think my answer to that is similar to my answer
from the previous one. From the papers that I have seen
and have been reminded about, clearly there was a degree
of reluctance towards the end of my time at ShEx for
Susannah Storey to go onto the Board as a Government
Non-Executive Director, and that may have been
indicative of the kind of thing that you are talking
about.
You refer at paragraph 76 of your statement a submission
that you made to the Secretary of State in December
2006. Could we have that on screen, please. It is
29
providing information; threats of resignations and
insolvency; and the playing out of issues in the media.
There has been no shared vision of the ideal profile of
members of the Board, with difficulties arising over the
appointment of Baroness Prosser and the need for at
least one Board member to have regulatory experience.
There has also been poor consultation over key executive
appointments in letters, POL and the finance function.
In a word, ‘trust’ is missing from the relationship."
Focusing first on the reference to the company
indulging in gaming and trying to apply pressure on the
shareholder, what did you mean by "gaming" in this
context?
Well, I give a couple of examples later on, possibly
being slow to provide information, using the media to
get a particular point of view across which would have
been better shared privately. Generally not -- not
having the kind of trusting and straightforward
relationship that we aspired to have.
What was done to ensure that the Board was no longer
inclined to game the shareholder?
Well, we had a number of, probably at the time -- I mean
I can't remember, it was a long time ago -- rather
difficult conversations with members of the Board.
I mean, as I say in my evidence, I'm not -- I wouldn't
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UKGI00045962. The title of this submission is "Royal
Mail Board Composition: Non-Executive Directors".
Appended to this submission as annex B is an earlier
submission. So the date of this one is 6 December 2006
and it's from you to the Secretary of State; the earlier
submission, which is appended to it, is dated 21 June.
Could we go to that, please, it's page 5 of this
document. We can see there, tucked underneath, your
name and role, 21 June 2006, to the Secretary of State.
Going over two more pages, please, to page 7.
Paragraph 9 of the submission deals with "Our
relationship with the Board", this was the Royal Mail
Holdings Board; is that right?
That's correct.
You say here at paragraph 9:
"The shareholder/Board relationship has been far
from ideal. It is expected that there will always be
some elements of tension between the two parties but at
various times over the last three years the company has
indulged in gaming and has tried to apply pressure on
the shareholder without taking due consideration of the
fact the shareholder is the Government and has to work
within certain constraints (albeit that we strive to act
as a commercial shareholder). This has manifested
itseff in the company refusing or being slow in
30
want to say that this was a sort of broken relationship
because everybody was at each others throats for no
particularly good reason. That wasn't the case. This
was a business which was in extremely challenging
circumstances indeed, and we were on the verge of having
to make a very significant investment in the business to
keep it solvent and modernise its operations. It had
a very, very large pension fund deficit.
There were different visions of how the ownership of
the company that is Royal Mail Group should develop. On
the one hand, the management wanted there to be very
significant employee share ownership. Ultimately that
wasn't the Government's policy.
So the context at the time, was that this was quite
a fraught environment. We -- I think I say, later on in
the document, or possibly in some of the other documents.
later on, that the relationships became better but it
was -- there was no question, it was a fraught
relationship at the time and we had to work pretty hard
to make sure that ministers’ objectives were fulfilled.
I mean, what made things better -- I mean there's
been a suggestion, I think, at some points that
ministers didn't have that much agency in the running of
the businesses. I don't really agree with that. One of
the things that made it better, for instance, was the
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appointment of Baroness Prosser, so that de facto, there
was a board member who was more capable of reflecting
what would have been the Government's objectives in --
around the Board table.
Thinking in particular of the reference in this
paragraph to resentment manifesting itself in the
company refusing or being slow in providing information,
do you consider that there was a cultural resistance in
Royal Mail Group to the shareholder having access to
potentially sensitive commercial information?
I think that would be a fair characterisation, yes,
although I should say here this the Royal Mail I'm
referring to here, rather than Post Office.
Indeed. That document can come down now. Thank you.
You say at paragraph 69 of your statement that Royal
Mail Group's culture of independence carried over into
Post Office Limited, and you cite the example of
resistance of the Chair of Post Office Board to the
appointment of a Shareholder Non-Executive Director.
You say that that continued well into 2011, when
plans for separation were being finalised. To what do
you attribute Post Office Limited's resistance to the
appointment of a Shareholder Non-Executive Director?
I think that Alice Perkins was pretty clear about her
objections to having a Shareholder Non-Executive
33
"It had, in fact, long been my view that the
Government (through ShEx) should be taking seats on the
Boards of its main assets and I thought I anomalous that
it had often not done so when it was the sole owner of
these companies. However, there was resistance to this
proposition both within the Government and the assets in
the early years of ShEx's existence. From the
Government's side, this was due to concerns that
a Government board member might be associated with
politically controversial decisions. From the asset's
side, a Shareholder NED was often seen as an unwelcome
innovation that risked political or inexpert
interference in commercial decisions."
Then at paragraph 69, you say:
"In my initial years in ShEx, my view that we should
have been taking Board seats did not prevail. For
a company such as [Royal Mail Group] in which management
that a deeply engrained culture of independence from
Government, it would have been extremely difficult to
even raise the issue."
Just as a matter of clarification, did you or anyone
else at ShEx ever take practical steps to explore with
Royal Mail Group whether ShEx could or should have a NED
‘on the Royal Mail Group's Board at any time prior to
Post Office Limited's separation from Royal Mail Group?
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Director on the Board, and I think she gave three
reasons: one of them was that there were -- there was
another non-executive who didn't want to serve; one was
that they thought that there would be a potential for
conflict; and there was another reason as well.
We will come on to that --
Okay.
-- correspondence in due course. But from your
perspective -- forgive me for interjecting -- quite
apart from the reasons given, what did you think the
reason behind Post Office Limited's resistance to the
appointment of a Shareholder NED was?
A desire for independence from Government --
Was a --
-- to the extent that it was manageable.
Was a cultural resistance to information sharing
something which also carried over from Royal Mail Group
into Post Office Limited?
I'm afraid I don't know the answer to that. I wasn't
closely enough associated with the information coming
out of Post Office to know.
While we are on the topic of the Shareholder Executive
taking seats on the Boards of its main assets, could we
have page 33 of Sir Stephen's statement on screen,
please, and at paragraph 68 you say this:
34
We didn't take practical steps to try and put somebody
onto the Board. If we had done that, there would have
been evidence in submissions to ministers that that was
a position that we wanted them to endorse and follow
through. I'm entirely sure that we would have had
conversations with Executives, with the Chair, where
we -- I would have said something like "It is odd that
Government doesn't take board seats". But we never
actually did anything about it.
Do you recall that actively being discussed with the
Royal Mail Group Board?
No, I don't, to be honest. So that would have been --
that is speculation on my part.
Were any of the reasons you have cited in the remainder
of paragraph 69 -- so, namely, strong pushback which
might become public; destabilisation commercially and
politically; and the potential resignation of the Chair
of the Royal Mail Group Board -- given to you at the
time as reasons for ShEx not to have a NED on the Royal
Mail Group's Board?
I'm not sure that the conversation would have been had
with the degree of precision that you're talking about.
I think it was so much the case that the policy was not
to have non-executives on the boards, that these issues
would have been kind of internalised in support of that,
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that position, rather than a conversation as "We ought
to have a Shareholder Executive Non-Executive Director
on this particular Board. Well, we can't because we're
going through all these things".
I mean, these things are all referenced, I think, in
my submission that you put up a few minutes ago, which
I sent to the then Secretary of State. So they were in
the air and, as I think I say here, I think the idea of
even raising it would have been wasted breath, to be
honest.
So just seeking to understand, these were in your
consideration that they weren't necessarily reasons
given to you by the Royal Mail Group Board for why this
couldn't happen?
That is correct, though I don't rule out that there was
a conversation where I might have mentioned this to one
of the Board, but I don't remember it specifically.
MS PRICE: Sir, we are approaching 1.00, I wonder if we
could keep going until 1.15, if that's all right by you,
and have a 45-minute lunch given that we only started at
12.00 today.
SIR WYN WILLIAMS: Yes, certainly, yes.
MS PRICE: Thank you, sir.
Could we have on screen, please, UKGI00017395. This
is the April 2008 ShEx quarterly report; is that right?
37
we can just click in the box, please, we can't see the
context in the box but if we look at the formula bar, if
I'm using the right terminology, we see:
"Annual plus frequest ad hoc. New programme of
meetings now commencing."
Now we have the second question:
"Do we have regular and informative contact with the
Chair and senior execs?"
The answer is "Yes", and there's “Quarterly and
frequent ad hoc".
The third question:
"Does the Chair respond to shareholder concerns?"
The answer is: "No" and the comment is:
"Yes and no. Often extreme. Recently some
improvement. Chairman's response to [Secretary of
State] Chairman's letter acknowledges importance of
monitoring and reporting the company's performance."
Then we have at 1.4:
"Does the company operate a ‘no surprises’ approach
to communication (includes media)?"
The answer is "No" and the comment is:
"Inconsistent: some off record, briefing of media;
no pre-warning of high profile press releases. Getting
much better, however."
It says:
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Yes.
I'm taking that from a description where you've dealt
with it in your statement, as I think that is accurate.
Yes.
If we could go to the Royal Mail tab in this.
spreadsheet, please. It's tab 27, if that assists with
finding it. That's it. So this is April 2008, and it
is two years on from your submission to the Secretary of
State, which we've looked at, containing concerns about
the relationship with the Royal Mail Group Board. This
was the state of play by this point, and we can see,
just to put it in some context, the heading "Shareholder
Executive: Traffic Light". Under the first section
"Shareholder Relationship", there are questions posed
and then we have columns, a "Yes" column and a "No"
column, and there is a code for what type of issue the
"Yes" or "No" relates to. So number 1 is in the summary
above as the shareholder relationship. So all of those
items in that first table, section 1, relate to
shareholder relationship.
Just looking at some of the questions and answers
that we have here, the first one is:
"Do we have regular and informative contact with
non-execs?"
The answer to that is "Yes" and, on the comment, if
38
"Is the overall relationship satisfactory?"
The answer is "Yes", but the comment is
"Satisfactory. Just".
At the next box down, we have as "Red", we have:
"Relationship with Chair can be mixed. Other issues
consensus can be reached. Board refresh now being
undertaken -- New MD letters now appointed; and new
settlement with the Board being slowly established.
Some friction experienced over bonuses which have still
not been agreed for the (now previous) financial year of
07/08."
Just looking down, please, to section 3, which is
"Quality of Management Team & Board", and under "Do we
have a suitable and strong Chair?", the answer is "Yes",
and we have some comments there:
"Chair re-appointed for further year to oversee
review and POL ..."
The answer is also "Yes" for whether we have
a suitable and strong CEO:
"Relationship with CEO has been strained but is
improving. He is looking to move on in 12-24 months’
time."
"Suitable and strong FD", is that Finance Director?
Itis, yeah.
"Yes. [Finance Director] now in post for 18 months ...
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performance ... okay but not great. New initiatives to
improved reporting are often met with resistance
initially, but then gradually overcome."
Then looking at some of the Nos:
"Do we have a suitable and strong line management
(including other executive directors, heads of business
units?"
The answer is "No":
"[Royal Mail] undertaking 'refresh’ programme.
Major concerns about bench strength of team.
"Is there a strong NED team?", two down.
"No. Strategy for reappointment/recruitment being
implemented, interviews for NEDs have been undertaken
recently.
"Is the Board compliant with the Combined Code ...
"Yes", but with the comment:
“But seeking to reduce Board size."
Then we have this:
"Do we have appropriate Board dynamics?
"No. Need to ensure that future NED appointments
are truly independent and expect to do so through NED
recruitment."
The last one:
"Has there been a Board performance review
recently?"
a
non-executives on the Royal Mail Group.
So there was quite a tight group of non-executives
who would have been making improvements probably
a little bit more difficult than we would have ideally
liked.
Were there, at this point, still concerns that
insufficient information was being shared with ShEx?
I would imagine that there probably was. I mean, bear
in mind that the reporting packs, the requests for
information, the formality and length of the meetings
that we were having were changing all the time,
admittedly possibly from a relatively low base, but I am
guessing that we would probably have still wanted to see
more types of information than occasionally we got.
What were the concerns about the strength of the
Executive Team which were referred to in this review?
Well, we clearly felt that we had a strong CEO, although
these "Yes/No" binary judgements are indeed just that:
rather binary. And the Finance Director, I think, gets
a tick in that box as well. I can't remember at this
distance --
If I can help you, with 3.4, "Do we have a suitable and
strong line management, including other executive
directors/heads of business units?", and then in the
comment, "Major concerns about bench strength of team";
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"No. Last Review in 2005. Since then there have
been changes to the Executive Team and NED refresh under
way. Do not expect full Board Review until new chair
appointed March 2009."
So looking at all of those answers taken together,
would you agree that it appears from this document that
the relationship with the Board was still poor at this
point, two years on?
It's certainly problematic. I wouldn't remotely want to
deny that. I think it shows some signs of improvement
from my earlier submission where I described the general
atmospherics around this relationship, but it is
absolutely clear from this that we had not been
completely successful in resetting the relationship.
What was preventing improvement or at least making it
slow?
It is difficult to make these kinds of improvements if
the Chair and the Board are -- have set their face
against some of them. If, for instance, as I think
I said in the earlier submission, the Chair does not
want to do a Board review, then it is very difficult to
do a Board review and, if I remember rightly, although
this was before my time in Shareholder Executive,
I think that the Chair here had brought in many of
his -- many people he knew personally to be
42
it was that specifically that I was referring to.
Okay. So I don't remember in any great detail but,
clearly, this was a comment which was recognised by the
Chief Executive in the main, who was obviously
undertaking an exercise to improve the quality of his
Executive Team.
There were stated to be concerns about the independence
of the Non-Executive Directors on the Board. Is that
linked to what you have just told us about who had been
selected and how or the --
Yes, I think it was, and I think it goes to the point
here about needing to ensure the future Non-Executive
Director appointments are properly independent, as
opposed to anything else.
MS PRICE: That document can come down now. Thank you.
Sir, I have reached the end of one topic and, before
turing to the next, I wonder if that might be
a convenient moment to break for lunch?
SIR WYN WILLIAMS: Yes, certainly. So we'll resume at 2.00,
yes?
MS PRICE: Yes, please, sir.
SIR WYN WILLIAMS: Right, see you all then.
MS PRICE: Thank you.
(1.10 pm)
(The Short Adjournment)
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(2.00 pm)
MS PRICE: Good afternoon, sir.
SIR WYN WILLIAMS: Good afternoon.
MS PRICE: Sir Stephen, would you agree that information
sharing is an integral part of risk identification,
monitoring and management?
Yes, I would agree with that.
You deal directly with the link between the two at
paragraph 52 of your statement. Could we have that on
screen, please. It is page 26. Three lines down, you
say:
“As the 20 June 2007 Departmental Risk Register
shows, it was the job of the Post Office Network Team to
compile the POL Risk Register within ShEx, relying on
their analysis of the information that was provided to
them by POL, informed by further data from RMG, its
parent company, and officials' own appreciate of the
risks being run. The effectiveness of the risk register
is therefore largely dependent on the flow of
information from the asset in question."
You go on at paragraph 53, a little further down the
page, please, to say this:
"Looking back now, with the benefit of hindsight and
acknowledging that I have not seen all of the evidence,
it seems to me that the failure of identify and
45
oP
I don't think, however, that is quite the full
picture because, clearly, there were people in
Shareholder Executive who were aware of the complaints
of the subpostmasters. They had received letters from
the JFSA, there had been meetings, there had been
subsequent meetings where they had quizzed the Post
Office on what all this was about. So it was not the
case that there was absolutely no knowledge of this
issue within Shareholder Executive but it didn't come
through the normal ascension of the risk through the
various risk registers, and that was wrong.
Q. You refer in paragraph 53 to Post Office Limited's power
to prosecute subpostmasters using Horizon data and you
do so again at paragraph 83 of your statement. Could we
go to that, please, it's page 40. You say:
"Neither this team nor anybody else in ShEx was in
any way in charge of the conduct of prosecutions by RMG
prior to separation, or POL after at. It seems from the
documentary evidence that knowledge of the prosecutions
was very limited. I was not personally aware that
RMG/POL had the power to conduct prosecutions, nor was
it a power that I would in any way have expected
a company to have."
In fact, Royal Mail Group and later Post Office
Limited did not have any special statutory power to
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socialise the risk posed by, first, errors in the
Horizon system and, second, POL's power to prosecute
subpostmasters using Horizon data, was central to what
followed. This is so both in terms of the initial
wrongful prosecutions and the subsequent delay in
acknowledgement and rectification. Those two risks
should have appeared on the Risk Registers of, in
ascending order, POL, Royal Mail, ShEx and the
Department.”
The implication here, by reference to "ascending
order" and taken with your comments in the previous
paragraph, is that you attribute the failure to identify
and socialise those two risks primarily to inadequate
information flow from Post Office Limited; is that
right?
I think it is right. I think it's difficult for
officials to identify, with sufficient gravity, the
types of risks that we're talking about here, if the
organisations that are actually responsible for them --
Post Office and then subsequently Royal Mail -- haven't
identified them as risks themselves, which is why I say
at 54 the order is important. And it's certainly the
case that this kind of issue should certainly have been
identified by internal auditors and quite possibly
external auditors as well.
46
bring prosecutions. It brought private prosecutions
against individuals, something which any ordinary
individual or company can do. Were you aware that such
private prosecutions were taking place when you were at
ShEx?
Like any large company, there were going to be instances
of crime committed by employees. I mean, I can remember
that there was a moment at which, in the Royal Mail,
there was considerable concern about post going
missing/being stolen, and I would have expected, in
anormal -- in the normal course of events, that people
would have been prosecuted for theft. I mean, it
wouldn't have surprised me that, on occasion, Post
Office prosecuted subpostmasters because they felt that
there had been and -- and could prove and had
evidence -- that there had been some kind of theft. But
I wasn't -- it wasn't something that I thought about
very much at all, to be honest.
So the distinction I'm drawing is between the
implication in your statement that there is a special,
perhaps statutory, power for the Post Office, in
particular, to bring such prosecutions, as opposed to
private prosecutions which are not brought by the CPS
but can be brought by anyone. Do you see that
distinction?
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I do. I am -- my knowledge of the law is limited here.
So if a private prosecution can be bought by anybody,
can that private prosecution mean that the person who is.
found guilty, as it were, can they end up in prison?
The question at the moment is simply whether you,
drawing that distinction, were aware that it was the
Post Office, or before that Royal Mail Group, as opposed
to the CPS, bring prosecutions?
lam sorry, I misunderstood. I certainly was not
under -- I did not know that it was not the CPS.
Okay. The Inquiry has received evidence that there were
over 800 prosecutions brought by Royal Mail Group and
Post Office Limited between 2000 and 2015. How can it
be that the Shareholder Executive and Departmental
knowledge of these prosecutions was so limited in the
period you were at ShEx; can you help with that?
I haven't seen any evidence that we were told that that
was the volume of prosecutions and, indeed, I think
I remember seeing some evidence from other witnesses who
were much more closely associated with it, such as
Chairs of Post Office themselves, that they weren't
aware of it, either. So I think it was one of those
facts that was not widely -- was not widely known and
was not widely noised.
Were you aware that criminal enforcement proceedings
49
endemic flaws in Post Office Limited's Horizon system
had resulted in wrongful termination of subpostmaster
contracts and prosecutions for false accounting. But,
in general terms, can you help with how it came to pass
that the Chief Executive of ShEx was unaware of
allegations being made by subpostmasters about the
integrity of Horizon?
This is speculation, to a certain extent, so I'd like
that caveat to be noted. But I was clearly not made
aware of these -- of this situation, and I don't see my
name on any of these submissions and I wasn't copied
into many of the documents or emails about it.
I would imagine that the team in charge, and I think
the documentation does prove this out, would have taken
account of what were forceful and repeated and detailed
denials that there was anything wrong coming from the --
from Post Office, that those -- those denials were
supported in full by the Post Office trade union.
There had been meetings with the Minister and,
indeed, subsequent ministers as well. There had been
further questions which had been asked by Shareholder
Executive officials, detailed questions, which largely
went to the matters being raised by the wronged
postmasters and, ultimately, the Board of the Post
Office had appointed Second Sight to do an inquiry.
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were also being used by the Post Office to obtain
confiscation orders against some of those it prosecuted?
No, I wasn't.
In terms of your own knowledge of the Horizon system,
you address this at paragraph 60 of your statement.
Could we have that on screen, please, it's page 29.
Here you say this:
"My knowledge of Horizon during the time in which
I was involved with [Post Office Limited] and [Royal
Mail Group] related matters in ShEx was extremely
limited: I understood that it was the Post Office's
point of sale system and that it had been a complicated
procurement some years before, but I knew little beyond
this. I do not recall the May 2009 Computer Weekly
article being brought to my attention during my time at
ShEx. Nor do I remember being made aware of complaints
made by subpostmasters as to the integrity of the
Horizon IT System."
Just picking up, first of all, on the complicated
procurement some years before, what did you understand
was complicated about the procurement?
The negotiations with Fujitsu had been lengthy and
fraught. Little more than that.
We will come shortly to the submission to Edward Davey
from ShEx in October 2010, which addressed claims that
50
Now, in those circumstances, I would -- in that
context I can see that the officials in question would
have thought, "Well, what else is there that can be done
in this kind of situation? Is it something that we need
to bring to the Chief Executive's mind -- to Stephen's
attention? Do we want him to intervene? Will he change
anything?" And I would have asked questions which would
have gone to the issues I've just mentioned.
And if all of those things were in place I would
have probably said, "Okay, well, crack on. You know,
I'd like to know about the progress of this". But
clearly that was not the view that was taken at the time
and it had been through the ministerial channel as well,
but I can't -- that is speculation, and I'd just like to
make that clear.
You refer to the ShEx handbook at paragraph 34(a) of
your statement. Could we have that on screen, please.
The reference is UKGI00044314. This document is from
2007; is that correct?
Yes, I think so.
That's the date that you give it in your statement.
Yeah.
Going to page 4 of that document, please, section 2
deals with "What Government expects of its businesses",
and the first sentence there says:
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"Government set out nine key principles which the
government expects to govern the behaviour of businesses
in government ownership.”
The principles set out below include:
"Principle 1. Businesses 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. Ideally, goals, overall
plan and progress should also be made public and
discussed in the annual report and accounts.
“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.
"Principle 8. Businesses should have and continue
to develop coherent strategies for each business unit.
The approach to reviewing strategy should be a dialogue
between the Board and the shareholder."
With those principles in mind, it appears from the
evidence the Inquiry has received so far that, at least
during the time when you were at ShEx, ShEx was unaware
of a number of important matters. To take some
examples:
First, Post Office Limited's knowledge of a bug
53
context, is that, by and large, the shareholder, the
Shareholder Executive, was engaging less with the
executives who were close to the kinds of issues that
you are talking about, and more with the Board and the
senior executives, and it's not clear to me whether or
not the senior executives and the Board were aware of
those issues either.
In fact, actually, from what I have seen of the
previous evidence, there is a surprising lack of
knowledge of some of those kinds of issues at the
executive of the Post Office and I think, in those
circumstances, where the communication breakdown
actually occurs is an interesting question.
That document can come down now. Thank you.
Is it right that the IT risk, that is the risk of
errors in Horizon, and the prosecution risk, were two
distinct risks, neither of which were identified or
socialised in the relevant risk registers from the Post
Office Limited level upwards.
Yes. From what I have seen.
As a matter of principle, should all risks on the Post
Office Limited risk register also be identified as risks
‘on the ShEx risk register?
Not as a matter of principle, no. I think the matter of
principle should be that all risks on the Post Office
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called the Falkirk bug, since 2006, and the receipts and
payments mismatch bug since 2010:
Second, that a joint expert report prepared for the
civil action brought by the Post Office against Julie
Wolstenholme in 2004 had challenged the proposition that
Horizon was robust, and the case was, as a result,
settled by the Post Office;
Third, that there had been acquittals of
subpostmasters in prosecutions brought against them
after the operation of the Horizon system had been
raised by them; and
Fourth, that Fujitsu had the capability to access
subpostmasters' terminals without their knowledge or
consent.
Taking those examples and combined with the failure
as you see it, for the Post Office to identify and
socialise risks of errors in the Horizon system and
relating to prosecutions, do you consider that Post
Office Limited complied with the principles we are
looking at here, namely open and honest dialogue,
operating a "no surprises” policy and engaging in
strategy dialogue?
The way that you have just described that would
certainly indicate that there were serious failings in
that area. The thing I would say, though, by way of
54
risk register should be looked at and considered, and
a decision -- a conscious decision should be taken by
sufficiently senior people as to whether or not they
should go on to the Shareholder Executive risk register.
Itis possible, isn't it, that something might be
identified as a risk by ShEx which is not on the POL
risk register?
Itis, yes.
Could we have on screen, please, UKGI00000062.
This is the submission I referred to earlier
prepared by Mike Whitehead in advance of Edward Davey's
meeting with the Alan Bates. It is dated 5 October
2010, and you address this at paragraph 87 of your
statement, if you wish to refer to it.
Mike Whitehead was a member of the ShEx POL
shareholding team; is that right?
That's correct, he came from the policy side.
That POL team, you say in your statement, had five to
six members and was headed up by a Director. That was
your description at paragraph 57.
Yes. The Royal Mail and Post Office team was headed up
by a Director. Underneath that Director there was --
there were two Deputy Directors, one for the Royal Mail
and one for the Post Office.
I see. The Deputy Director headed up the five to six
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individuals in the team?
Correct.
Accepting that you do not think you saw this submission
at the time, I'd like to look, please, at some of the
issues that were being raised in it. First, under the
heading "Purpose" there is this:
"(Rescheduled) meeting with Alan Bates (JFSA) on
Thursday, 7 October at his request to discuss the JFSA's
claims that endemic flaws in [Post Office Limited's]
Horizon system have resulted in a number of
subpostmasters having their contracts wrongly terminated
by [Post Office Limited] and in many cases prosecuted
for false accounting."
Then under "Background to the meeting":
"Mr Bates has written twice requesting a meeting
with you. In response to his first letter of 20 May,
the request was declined on the grounds that the issues
raised were operational and contractual matters for
[Post Office Limited]. His second (more
confrontational) letter of 8 July was followed by
reports that Channel 4 were planning to run a news item
on the JFSA campaign. We then recommended offering
a meeting in response to this 2nd request for
presentational reasons against the background of
potential publicity ({Channel 4] News item) playing
57
process to decide on the JFSA case and that the issues
are effectively sub judice."
Over the page, please, two more bullet points:
“Demonstrate that you're prepared to hear the JFSA's
side of the story ... but make clear that you are not in
a position to offer substantive comment.
"Avoid committing to set up an independent
external/review of Horizon.
The "JFSA objectives" are summarised below there,
and they include:
"To press for an independent investigation into the
reliability and integrity of the Horizon system ..."
At the last point:
"To press for the establishment of a new
representative body for subpostmasters as an alternative
to the cosy relationship between [Post Office Limited]
and NFSP."
Then starting about halfway down under the bold font
there are some what seem to be key points:
“Avoid any commitment to adopting any of the JFSA's
objectives in the terms these are set.
"Substantial changes to subpostmasters' contracts
and the branch operating model are a key element of
POL's 2011-16 business strategy.
"An independent review/audit of the integrity of
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heavily on Government Minister, ‘refusing to meet
victims of [Government] owned Post Office Horizon IT
system which has systemic faults resulting in wrongful
accusations of theft/false accounting’. The JFSA has
also mounted a substantial lobbying campaign with MPs
and several [named individuals written there] have
written to you or tabled PQs on behalf of constituents
who are members of the JFSA."
"Our objectives" underneath:
"Tactically we would advise that you seek to
establish at a very early stage whether legal action
against POL is imminent/planned. If so, it would be
prudent to adopt a ‘sub judice' approach in the comments
you make."
Then bullet points:
“Emphasise that the issues raised by the JFSA are
operational and contractual matters for [Post Office
Limited].
"Make clear that, as the shareholder, Government has
an arm's-length relationship with the company and does
[not] have any role in its day-to-day operations.
“Establish whether, as reported, the JFSA is
committed/planning to initiate legal action against
[Post Office Limited].
"If so, note that it will be for the relevant legal
58
Horizon would be expensive (and time consuming). POL's
view is that if there were systematic integrity issues
as claimed by JFSA, there would have been a higher
incidence than is claimed, there would have been
instances of Crown Offices being affected as well as sub
post offices as identical system is used."
And:
“Subpostmasters are contractually entitled to be
accompanied at appeal hearings by an NFSP representative
or friend.”
Over the page, please, is a more detailed document.
I don't intend to take you through it all because I'm
aware you have read this before but, just scrolling
down, please, to see what is here. It sets out the Post
Office Limited position in relation to the integrity of
the Horizon system. Then, over the page, please, the
Post Office position, scrolling further down, in
relation to action taken with subpostmasters for
accounting irregularities.
In relation to the second of these headings, it is
explained at the second paragraph under the heading
that:
“In certain cases, following consultation with legal
advisors, a decision may be made by [Post Office
Limited] to pursue a criminal case. Since 2005 there
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have been 230 criminal cases that have proceeded to
Court. Of these 169 have been found guilty and 18
defendants cautioned. Of the remaining 43, 1 was found
not guilty but this was nothing to do with any Horizon
challenge. 42 cases were not carried forward for
a variety of reasons (but there are no suggestions that
any of these reasons were related to concerns about
Horizon)."
Setting aside for a moment the question of advice
that was given to Edward Davey by Mike Whitehead, would
you agree that this document shows that, by at least
document 2010, ShEx and the Minister were aware of
allegations that there were endemic flaws and systemic
faults in Horizon and that hundreds of people had been
prosecuted based on Horizon data?
That's undeniable.
You say at paragraph 89 of your statement that you
believe concerns about the Horizon system were not
escalated on to the ShEx risk register entry for Post
Office Limited prior to separation, or during your
tenure as Chief Executive. At paragraph 106, you
acknowledge that it would clearly have been vastly
preferable if Horizon and POL's prosecutorial function
had appeared on internal risk registers in ShEx.
Looking at this document, which was from Mike
61
union. There had been a meeting with the Minister,
questions had been asked later by Mike Whitehead
specifically of the Post Office, about a month after
this, I think, again going very much to the concerns
that Mr Bates was raising. I mean, I think in those
circumstances, clearly the decision was taken that it
did not warrant escalation, and that is -- that is --
that was wrong. But I speculate here because I didn't
write this submission and I didn't see it.
Indeed. But these were officials who were at ShEx when
you were Chief Executive, so in terms of --
They certainly were.
-- how you would expect those operating under you to
behave, would you not have expected both a recognition
of the risks, an escalation of those risks?
I very much wish that it had been escalated. I am not
resiling from that position at all. The point I'm
trying to make is that, in the context of the time,
I can just about see how a decision might have been
taken not to escalate and, to be clear, it was escalated
to the Minister --
Yes.
-- and consequent ministers, all of whom met Mr Bates.
There is in place, though, as you set out in some detail
in your statement and we have heard some information
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Whitehead, shouldn't the ShEx officials involved in the
production of this submission have immediately
identified: first, the risk of there being endemic flaws
and systemic faults in Horizon; and, second, the risk of
there being unsafe convictions and other wrongful action
taken against individuals based on unreliable Horizon
data?
I think it is absolutely undeniable that this whole
situation should have been on Shareholder Executive's
risk register, just as it should have been on the Post
Office's risk register, just as it should have been on
the Royal Mail's risk register, and I should say that
I think if it had been on those two companies' risk
registers, that would have made it vastly more likely
that it would have appeared on the Shareholder
Executive's risk register as well.
I can't answer for colleagues’ state of mind or
exact thinking from this period of time. I wasn't
copied in on this particular document. I fear
I probably have to repeat what I said earlier on, which
is that I would speculate that, in the face of the very
forceful and detailed denials from the Post Office,
supported by the subpostmasters' trade union, although
I accept that the JFSA don't -- made it clear in this
document that they didn't particularly trust their trade
62
about from others, of identification and management of
risk, which relies on things being recorded so that they
can be considered by, for example, the ShEx Executive
Committee or the ShEx Board?
Yes.
So it is important, isn't it, notwithstanding that
things that should be considered by the Executive
Committee and the Board are raised, notwithstanding that
there might be a separate line of reporting to the
Department?
Yes, indeed, and I am very clear in my witness statement
that I - they should have been put on the risk
register. But I'll repeat, they should have been on the
Post Office risk register and they should have been on
the Royal Mail risk register as well.
That document can come down now. Thank you.
At paragraphs 57 to 59 of your statement, you
explain that separate teams at ShEx dealt with Post
Office Limited and Royal Mail Group policy issues,
respectively. Do you think that this may have inhibited
effective flows of information and oversight of Post
Office Limited?
I've given this matter some thought and reflect on it at
the end of my statement. I think, honestly, the answer
is -- well, it's clearly unknowable. Honestly, I think
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no, though. The fact that there were policy officials
in the Post Office team as well as, as it were,
commercial officials in the Post Office team. Once the
information had come into Shareholder Executive, I don't
think that the fact that they were in the same team sort
of inhibited a flow of information. I think the issue
about separating those two functions is more about being
clear where the perspectives are.
Were there any checks in place within ShEx to control or
govern the flow of information coming through from
assets and throughout ShEx?
Yes. I mean, each quarterly review and then annual
review had a set -- and they weren't exactly the same,
there wasn't complete commonality but there were a set
of expectations about the kinds of -- the bits of
information that the companies and the assets were meant
to provide, and there would be questions asked if that
information was not being provided. I mean, I think
we've seen from earlier evidence that, certainly in the
early days of Shareholder Executive, sometimes it was
difficult to get that kind of information from the
assets in question but we knew, in large part and
certainly as we went, you know, as time went on, what we
wanted to know, and we were perfectly happy to ask for
it.
65
Executive, that the JFSA considered that the National
Federation of SubPostmasters had a “cosy relationshi
with Post Office Limited? That was the -- one of the
bullet points that we just looked at.
No, I wasn't.
Should that fact, that the JFSA considered there to be
a cosy relationship between the NFSP and Post Office
Limited, not have made Mr Whitehead and the POL
shareholder team more wary of reliance upon the NFSP
position?
I'm not sure that you can infer that they were reliant
‘on the NFSP position. I think that it's much more
relevant that, on -- I think it's 10 November -- this
was in the Rule 10 material -- sorry, 4th November 2010,
which was subsequent to the JFSA meeting with Edward
Davey, Mike had a clearly a long conversation with the
Post Office covering matters such as whether or not the
contract had changed, the lack of audit trail, whether
or not POL can access the system remotely, frequency of
software updates, and it goes on.
I mean, these are all of the issues which Mr Bates
had raised a few weeks before and had received answers
which he was entitled -- detailed answers and forceful
answers -- which he was entitled to rely on. I think
that the fact that the National Federation of
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Q. You say at paragraph 87 of your statement that you are
confident that Mr Whitehead would have presented the
Minister with an accurate representation of the facts as
he understood them, and that's a reference back to his
submission to Mr Davey. You address this further at
paragraph 88 of your statement. Could we have that on
screen, please. It's page 42. Here you say this:
"I do not know what steps Mike took to obtain and
interrogate information provided by [Post Office
Limited] to him, though he seems to have asked the main
subpostmasters' trade union, the National Federation of
SubPostmasters about it, and been told that their view
that there should be no lack of confidence in the
Horizon system. Mike was in regular contact with the
NFSP and so it would not surprise me if he had spoken to
them about Horizon. He was not, nor could he have been
expected to be, an expert on [Post Office Limited's] IT
system. Any official in his position would have been
entitled to expect [Post Office Limited] to provide
a truthful answer to the questions posed about Horizon.
There had to be a degree of trust between ShEx and those
who had been appointed to the job of running an ALB."
Dealing first with the reliance placed on the
National Federation of SubPostmasters' position on the
issues, were you aware at the time that you were Chief
66
SubPostmasters were, as it were, rowing in behind that
position would have been a factor, but it would have not
been as much of a factor as the very long conversation,
by the sounds of things, that he had in November with
the Post Office itself.
I see. I'm simply taking from your statement the
suggestion that this was another source of information
that Mr Whitehead might have used to probe the POL
position and --
That is perfect - I don't know. It is perfectly
possible that he did, and maybe he did have in mind the
fact that -- I mean, it was him who wrote that there was
a cosy relationship. So I don't know exactly the cast
of mind that he brought to that conversation, I'm
afraid.
My question is whether, given that he's recorded the
NFSP position in his submission and recorded that there
is a view that there is this cosy relationship, that
should in some way have made Mr Whitehead slightly more
wary of finding that reassuring?
Indeed. That is a perfectly reasonable position to take
and, as far as I know, that may well have been the
position that Mike did take. I don't know.
In general terms, did ShEx seek assurances, before
placing reliance on information provided to it by
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assets?
No, we didn't, because that would have been an admission
that we didn't really -- if we asked a question, we
weren't necessarily expecting an honest, truthful and
full answer. And we did not operate along those lines.
The Shareholder Executive handbook, the Shareholder
Executive annual guidance, the framework agreements, the
chairman's letters, all made it absolutely clear that we
expected full and frank, honest, well-founded, detailed
responses to questions that we might be asking. If we
had had to go through that process every single time
that we had communication with an asset, that would have
been very, very wearing indeed, as well as wasting a lot
of time.
That was not the kind of relationship that we sought
to develop.
That document can come down now. Thank you.
It may follow from your last answer, but was it part
of the role of ShEx officials to interrogate information
provided by the Post Office to ShEx or query any gaps in
information provided before conveying it to ministers?
Certainly. If there was a sense that either information
had been unhelpfully presented or misleadingly
presented, or incompletely presented, then I would
certainly have expected Shareholder Executive colleagues
69
implication for prosecutions and other action taken
against subpostmasters, wasn't there a requirement, in
those circumstances, to be more probing? Where there is
an increasing body of accounts that there is something
wrong with the system?
I think there is evidence that officials were more
probing, as time went on. Now, I think it's difficult
to say that they shouldn't have probed even further but
I think the evidence does show that, increasingly,
questions were being asked and that went alongside,
increasingly clearly, questions being asked at the POL
Board, as well, ultimately culminating, at least in my
tenure, in the appointment of Second Sight to do
an independent review.
So, clearly, the questions were becoming more
pointed and acute and, clearly, there was a response to
that. I think it is perfectly open for anybody to say
it should have happened quicker.
Do you agree that the risks posed by errors in the
Horizon system and action against subpostmasters,
including prosecutions, were not simply operational
issues that should have been left to Post Office
Limited?
By the time that the volume of those prosecutions and
cases had reached a very high level, yes, I do agree
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to have pressed and challenged on that. I mean, I used
to do that kind of thing all the time myself.
So you draw a distinction between seeking assurances
when, on the face of it, there's nothing to question,
and where there is, on the face of it, something that
needs explaining?
I think the --
~ exploring?
-- distinction that I would draw is that we expected, as
a matter of course, and made explicit at the beginning
of a relationship, that we expected a full and frank and
‘open, honest, straightforward relationship with
appropriate responses. That does not mean to say that
we would always necessarily get that, nor does it mean
to say that if we didn't get that, that was necessarily
always -- we didn't get it because there was a lack of
good faith.
It might have been just that people misunderstood.
So I would have expected a constant dialogue,
challenging dialogue, rather in the same way as a Board
is meant to have a challenging dialogue with the
Executive, to take place. I hope that's clear.
In a situation like this, where a submission is
summarising an increasing number of people challenging
the integrity of the Horizon system, with the
70
with that. But this is not -- again, it's not
a completely binary issue. If this had been kind of one
‘or two cases in a five-year period then I think
I probably would have said yes, well, this is
an operational matter. It's catching this when it
became clear that there was a systemic problem should
have been done earlier.
We've seen in the submission these issues being
described as operational and contractual issues, and the
first position being that the Minister wouldn't meet
with Alan Bates for that reason. Given what you've just
said, do you consider that the issues were incorrectly
presented to the Minister as being for Post Office
Limited, as operational and contractual?
I find that a difficult question to answer because
I don't know what -- going back to the point about the
volume, I don't know what was the understanding of the
volume of those cases known to the officials at the
time.
Well, we saw the numbers, didn't we, of prosecutions
that were relevant to the question of challenges to the
integrity of Horizon --
Yeah.
-- in the several hundreds.
Yes, and you're saying that, as a result of that, that
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becomes sort of kind of more than merely operational?
Well, my question is, in circumstances where, if they
were right -- if those challenging the integrity of the
Horizon system were right -- that there were systemic
and endemic problems with the system, that was the
number of prosecutions which might have been affect by
it, brought in reliance on --
Yes.
-- Horizon data.
Yeah.
So just looking at the information in the submission
alone, wasn't that enough to take it out of the
territory of operational and contractual purely for Post
Office Limited?
I don't know, is the honest answer. I don't know
whether or how those numbers compared against the
historical record of prosecutions by the Post Office or
Royal Mail. I would guess that officials at the time
might have taken some degree of comfort from the fact
that there had been a process which had been gone
through sort of British courts and there had been
a particular answer.
So I find it difficult to answer the question very
clearly for you because I can't put myself in their
shoes. I can imagine some of the things that they might
73
very, very considerable industrial unrest so it wasn't
so much achieving profitability, it was more about
ensuring that the Royal Mail Group continued to survive.
Did that mean that we were focused on those kinds of
metrics at that time? Yes, it did mean that. And we
wouldn't have had, as you pointed out in this bit of the
evidence, we wouldn't have had, as it were, an organic
sense of the operations of some of these things because
we weren't so close to the business, by sitting on the
Board or whatever, that it would have -- we would have
picked that up in the normal course of events.
I mean, this is a very, very stressed period indeed,
in the history of Royal Mail Group, which is why the
Hooper Review had to be written and all of the very
significant changes that flowed from that were
ultimately taken.
The statement can come down now. Thank you.
Your time as Chief Executive of ShEx finished not
long after the separation of Post Office Limited and the
privatisation of Royal Mail Group. Do you agree that
separation and privatisation was a top policy priority
for the Department of Business, Innovation and Skills?
It was an important -- it was an important priority.
I mean, there were a number of key conclusions that the
Hooper Review came to, of which that was one. There
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have been thinking but I can't give you a very
definitive answer, I'm afraid.
Q. Could we have on screen, please, paragraph 61 of
Sir Stephen's statement. It's page 30, please.
Starting three lines down, you say:
"It was also the case that, particularly in respect
of the period before separation, reporting on [Royal
Mail Group] and [Post Office Limited] was heavily
focused on financial performance (as reflected in ShEx's
reporting for this period, including traffic light
analyses and Quarterly/Annual Reviews) and ShEx did not
have a representative on the Board of [Royal Mail Group]
or [Post Office Limited], meaning that risks arising
from operational matters were less likely to appear in
ShEx's reporting for this period."
Was achieving financial profitability the foremost
aim of ShEx for Royal Mail Group and, by extension, Post
Office Limited in this period to which you refer?
A. I think it would be fair to say that that we were very
heavily focused on not so much achieving profitability
but whether or not the Royal Mail itself was sustainable
at all as a business. We had, as I mentioned before,
an enormous pension fund deficit, which could have sunk
the company. There was huge industrial change
associated with e-substitution going on. There was
74
were others. He recommended that the existing regulator
was abolished and the duties were taken on by Ofcom. He
recommended that the pension fund was absorbed into the
public finances and he recommended that the Royal Mail,
in that situation -- separated from the Post Office --
was privatised and that required a change in the law and
we had to take primary legislation through.
We did all of those things. They were all extremely
difficult, as it turns out, but we did all of those
things. One of them was certainly the separation of the
Royal Mail Group from the Post Office.
‘SIR WYN WILLIAMS: Ms Price, can you hear me?
MS PRICE: Yes, sir.
SIR WYN WILLIAMS: I have lost the screen. I can't see
what's going on at the moment.
MS PRICE: Sir, we'll investigate that, if you just give us
a moment.
‘SIR WYN WILLIAMS: I can hear perfectly, but I can't see.
(Pause)
MS PRICE: I Sir, I'm being told it might be an idea to have
a 10-minute break so this can be resolved at this point.
‘SIR WYN WILLIAMS: All right that's fine. I'll remain near
the screen so that you can let me know what's happening
if necessary, all right?
MS PRICE: Yes, sir. Thank you.
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(2.54 pm)
(A short break)
(3.01 pm)
MS PRICE: Hello, sir. Can you see us now?
SIR WYN WILLIAMS: Yes, I can, thank you.
(Pause)
MS PRICE: Hello, sir.
‘SIR WYN WILLIAMS: Hello.
MS PRICE: Can you still he and hear us?
SIR WYN WILLIAMS: Yes, I can, very much.
MS PRICE: Is my microphone working now?
Yes, okay. I think we really are now ready to
continue.
SIR WYN WILLIAMS: Right. Very good.
MS PRICE: Sir Stephen, we were just talking about the plans
for separation and privatisation and I had asked you
first of all about the priority of that for the
Department. In terms of ShEx's priorities, were
readying Post Office Limited for separation and readying
Royal Mail Group for privatisation important priorities
for ShEx?
A. Yes, they were.
Q. Was that something that the Directors of both Royal Mail
Group and Post Office Limited would have known?
A. Yes, itis something they would have known.
77
ultimately in the hands of, for these kinds of things,
in the -- in the hands of the Board. So our role, in
order to make an influence on or have an influence on
the culture of the Post Office, would have been to make
sure that it had the right kind of Board that would be
able to drive that through the -- and Executive that
would be able to drive that through the organisation in
time. We wouldn't have sought or been able to influence
the culture of an organisation of that size ourselves in
any other way.
Q. Were concerns about culture, ethics and conduct in
relation to Post Office Limited ever raised with you
when you were at ShEx?
A. No, they weren't. I don't recall them anyway.
Q. I'd like to come, please, to the pushback that you say
there was by Post Office Limited to having a Shareholder
Non-Executive Director on the Post Office Limited Board.
Could we have on screen, please, paragraph 94 of
Sir Stephen's statement. It's page 46. You say here:
"The appointment of a Shareholder NED was met with
resistance from the new Chair, despite what Anthony
understood to be RMG's agreement."
So the new Chair, is that Alice Perkins?
A. Yes.
Q. And Anthony, that was Anthony Odgers?
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Did you ever get any sense that this influenced the
willingness of Royal Mail Group or Post Office Limited
to share information with ShEx and the relevant
Department?
I did not get that feeling at all, no. In fact, in some
ways, quite the opposite because readying a company --
I'm talking about Royal Mail now, rather than the Post
Office, readying a company for a major listing on the
London Stock Exchange is an extremely exhaustive process
where enormous quantities of data have to be provided to
satisfy the lawyers, the accountants, the bankers, you
name it. It's an extremely complicated and exhaustive
undertaking.
Did you ever get any sense that the plan for separation
and privatisation, and the importance of that, affected
the appetite of ShEx to challenge the Post Office
Limited position on Horizon?
No, I never encountered that at all.
The Inquiry has heard evidence relating to Post Office
Limited's culture, ethics and conduct. What mechanisms
were in place, if any, when you were at ShEx to enable
oversight of those things?
The principal mechanism for that was through our
engagement with the Chair and the Board of the Post
Office, you know, British UK corporate governance is
78
Odgers, yes.
Odgers, forgive me:
"A submission from the ShEx Post Office Network team
to Ed Davey dated 24 October 2011 that I have seen while
preparing this statement indicate that Ed Davey and
Vince Cable decided in spring 2011 that a Shareholder
NED would be appointed. However, when Alice Perkins met
the Permanent Secretary in September 2011 in the first
of a series of meetings she undertook with senior
figures in the Department, she indicated that she had
some concerns. These were ..."
These are the ones you were referring to earlier,
I think?
Yes.
"... first, that ShEx joining the board was inconsistent
with the policy of future mutualisation, where the
relationship between [Post Office Limited] and
Government would be purely contractual; second, that it
would ‘in some way prevent Government insulation from
the impact of operational decisions’; and third, that
‘one Board member had indicated that they would be
reluctant to serve on a Board where a ShEx appointee was.
also a director’.”
At paragraph 95, you explain that Vince Cable and
Edward Davey decided to impose a Shareholder NED on Post
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Office Limited, despite the pushback and, it seems,
a threat from one NED to quit the Board if it happened.
Is it right that, to your mind, the most important
reason for having Shareholder NEDs that a Board seat or
at least the ability to attend Board meetings was likely
to be important to understand the business in detail?
A. I think there are a few reasons, actually. One is
certainly to understand the business in more detail and
to feel -- have a better sense of the business as a sort
of living organism, as it were, and to be inevitably
exposed to different types of information and
perspectives than you would if you had not had a Board
seat.
Another crucial element of it -- and this goes to
the slightly dual-hatted nature of a Shareholder
Non-Executive representative -- is to make sure that the
Board, in a very immediate way and a sort of very formal
way, is aware of the 100 per cent shareholder's views
and objectives for the business.
A third, less important to my mind, but a reason, is
improve and deepen the relationships between the Board
and executives and the shareholder. As I've said at
various stages in this statement and as has come up on
a number of occasions, these relationships do need to --
they require a degree of trust to work properly and
81
A. I don't think it's helpful and I note that that
particular prohibition was lifted in due course, and
I think it's right that it was lifted. Whether or not,
in practice, at the time when the prohibition was in
place, it prevented proper conversations between the
shareholder team and Susannah about the Board
discussions, I rather doubt and my understanding is that
Susannah arranged specific meetings so that she could
inform the team as to the basic substance of the
discussions.
I think that's unfortunate that she had to do that.
I think it would have been easier if the Board papers
had been made -- capable of being made available to the
team, but it was what it was. And I think clearly
people were feeling their way. This is one of the very
first Board seats that Shareholder Executive had taken,
which is now pretty common practice, frankly, and
I think people were feeling their way and maybe this was
a compromise that it was felt needed to be made.
SIR WYN WILLIAMS: I was going to ask you, Sir Stephen, was
the attitude taken by the Post Office Board, to having
a Non-Executive Director who is a member of ShEx,
unusual but I think you've answered it by saying that
this was one of the first boards in which that situation
arose. Have I got that correctly?
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15 July 2024
greater familiarisation with each other enabled that.
I should have referred to the other reasons you include
at paragraph 67, that, in paragraph 67, you describe
that first reason, that is it was likely to be important
to understand the business in detail, as being the most
important. So in the context of there being other
reasons as well, do you still consider it to have been,
to your mind, the most important?
Yes, those the others are -- this is a matter of degree.
In particular, the transmission of Government objectives
in a clear and straightforward fashion is, you know,
very nearly as important.
Looking to paragraph 96, please, over the page about
five lines down, you say:
"Susannah Storey was subsequently appointed but, as
I understand it, following discussion with the Board,
she did not share Board papers with the ShEx POL team
out of concern that this would create a conflict of
interest or otherwise undermine the independence of
Board discussions. I do not recall being aware of this
arrangement at the time when I was Chief Executive."
Do you agree that an inability to share Board papers
undermines a key purpose of the Shareholder NED role,
ie the transmission of potentially important information
back to Government?
82
You have absolutely got that correct, Sir Wyn.
the decision not to share papers?
Would I have been expected? I would have liked to have
been consulted. "Expected" is probably putting it too
strongly.
Would you have agreed with the prohibition, had you been
aware of it?
I would have wanted to have had a conversation about it.
If I had been told, "Look, this is new territory for us,
they're very, very unhappy about it, it's not going to
make a massive practical difference, let's go with it in
the interests of making sure that we get off on the
right foot, rather than the wrong foot", I would have
probably gone along with that. There would have been
other conversations that -- in different circumstances
but, if that was the situation, I would have probably
gone along with that.
Had you been aware, would you have considered that
ministers should have been informed of that?
That, I think, would have been a function of the
judgement that I would have made as to whether or not
the arrangements were capable of being effective and if
they -- if I'd thought that they were effective, then
I wouldn't have probably felt that that raised them to
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the level of needing to seek guidance from a minister.
If I thought that this was actually genuinely really
unhelpful, obstructive behaviour -- and it's difficult
for me to see from these documents where that line
was -- if I'd thought it was really genuinely
obstructive behaviour, then I may well have taken that
to a minister.
Do you find any strength in the argument that sharing
Board papers with the ShEx POL team and/or the
shareholder may have created a conflict of interest?
No, I don't, actually. The Shareholder Executive NED
was a part of the Shareholder Executive, by virtue of
the fact that he or she was going to have seen those,
that conflict, if it was likely to have arisen, would
have arisen. Widening the circle of knowledge wouldn't
have fundamentally altered that particular principle.
The only issue, really, would have been whether or not
there was a concern about the confidentiality of the
papers, which I would have hoped nobody would have
really taken very seriously because I take that kind of
thing very seriously myself.
Do you find any strength in the argument that sharing
Board papers with the ShEx POL team and/or the
shareholder may have undermined the independence of
Board discussions?
85
Typically, I would try and stay in the conversation
as long as I possibly could because it was important to
do so but there's a moment when it's clear that the
interests diverge and then you would recuse yourself,
you would ask not to see the papers relating to it that
other Board members would see, and you would not attend
that discussion, and these are very well trodden paths.
I mean, most of the time conflicts of interest don't
raise themselves to that level of materiality and it is
the job of the Chair to make sure that they don't and
that the conversations can happen in a sensible way.
But, as I say, these are not complex mechanisms, they're
not uncommon mechanisms, and I remain very much of the
view that it is much better for the Government to have
shareholder representatives on the Boards of companies
like this that they own.
Moving, please, to the mechanisms which were in place to
ensure that adequate information about Post Office
Limited was provided to ministers, you explain in your
statement that one method for keeping ministers informed
about Post Office Limited was submissions and meetings.
What other mechanisms were there and, in particular,
when you were Chief Executive of ShEx, what went to
ministers by way of risk registers and quarterly or
annual reviews relating to Post Office Limited?
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No, I don't. That leads you on to a series of
questions, which you may be about to ask, about how one
handles conflict in a Board and, if it does, then I will
stop there but, otherwise, I will carry on.
No, if you can simply explain why you don't find
strength in that argument, that would be helpful.
It is very, very common practice for shareholders to sit
on Boards. In fact, it is almost always the case that
they do. When I sat on the Board of the Olympics,
LOCOG, for the Government, I was the Government's
representative -- effectively the shareholders of the
Olympics were the Government, who was paying all the
money, the Mayor, in whose town it was happening, and
the British Olympic Association. Each one of those
entities had the right to put a Board member on LOCOG's
Board and I was the Government's representative.
It is certainly the case that, on occasion, you will
find that, in those kinds of situations, there are
conversations or discussions which could potentially
represent a conflict of interest. In the case of the
Olympics, the budgets were going up quite a lot and the
only place where the budget was going to be met from was
going to be Government and, at that point, I would have
to take a view as to whether or not I could participate
in a discussion or not participate in a discussion.
86
Well, the two principal mechanisms for communicating
with ministers certainly were submissions and meetings,
and the job of a civil servant is quite often to hang
around the door of the relevant minister and try and
apprise him or her of a particular situation and what
kind of line they would like to take with it and maybe
doesn't rise to the level of importance that it needs
a submission, or possibly it might say, well -- the
minister might say "Send me a submission on that,
please", and then you would do so.
Obviously, conversations on the telephone, not
texts, because that kind of thing didn't really exist
back in the day, but there were lots and lots of
conversations, both formal and informal, by which
information could be distributed and socialised.
Sorry, the second part of your question was?
In addition to those submissions and meetings, the Chair
would like to understand what in the relevant documents
assessing risk and the annual reviews and quarterly
reviews, what would have made its way to ministers from
those documents and how?
I don't remember precisely. It would have been
unlikely, I think, that the quarterly traffic lights
reviews or general reviews would have made their way to
ministers. The annual reviews, I think, did. The
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ministers had to sign off annual report and, of course,
I can't remember exactly when it was but there was
a minister ultimately specifically given responsibility
for Shareholder Executive itself, and that minister
would have spent a good deal of time thinking about not
the assets within Shareholder Executive, but the running
of Shareholder Executive and the information that we
were using to organise the business.
So there would have been a range of things, but
exactly which of the various risk registers, traffic
light reviews, and so on, I'm afraid I don't fully
recall.
Do you think that the mechanisms that there were were
adequate to keep the Department appraised of key
operational and contractual matters which might be
relevant at policy level?
I think it's impossible to say, against the background
of this disaster, that they were fully adequate. They
were certainly better than they were when the
Shareholder Executive was established and they are no
doubt better today than they were when I was running it.
But I think it's impossible to say that they were fully
adequate because, if they had been fully adequate, this
dreadful situation would have been raised much, much
more quickly and, I hope, would have been dealt with
89
governance are fit for purpose and should drive proper
and honest company behaviours when implemented."
You go on at 112 to say that:
“Evolving a more effective Government ownership
lies, therefore, not in a complete redesign of
governance arrangements or ownership structures, but in
a more effective implementation of the highest standards
of existing corporate governance, with systems and
practices that promulgate and enforce those standards
right through the organisation. Its operations need to
be fully understood by the Board and executive, its
risks need to be identified accurately and honestly, its
issues and problems need to be escalated appropriately,
and the shareholder needs to be properly apprised of the
most significant issues and developments in the company.
This is particularly the case where there are complex
policy issues at play as well as commercial ones. The
evidence that this Inquiry has heard of the devastating
effects on the lives of so many blameless people is, at
least in part, witness to the human cost of governance
failure."
Can you explain, please, what you mean at the end of
paragraph 111 -- and if we can just scroll up a little
so Sir Stephen can see it - by "fully implemented"; so
"the modern codes of corporate governance should drive
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with much greater expedition.
After April 2012, when Susannah Storey started as the
first Shareholder NED on the Post Office Limited Board,
was there any mechanism for matters being fed back to
the Department directly via the Shareholder NED?
Yes, I think Susannah -- I mean, this was very much
towards the end my time at Shareholder Executive, so my
knowledge is perhaps less reliable than others’ would be
but I know that Susannah met with the Shareholder Team
very regularly to make sure that the information that
she thought was important was being fed back into the
Shareholder Team.
Coming, finally, please, to your reflections provided
towards the end of your statement to the Inquiry, could
we have on screen, please, paragraph 111 of
Sir Stephen's statement. That's page 55. You say here:
“Notwithstanding the multiple failures of
governance, starting at ground level in [Post Office
Limited], that have been a major contributory factor in
the perpetuation of the Horizon scandal, I do not
believe that an inference should be drawn that the
models of corporate governance employed by ShEx or UKGI
on behalf of the Secretary of State as owner of the
Royal Mail and, after 2012, [Post Office Limited] were
flawed in conception. Modern codes of corporate
90
proper and honest company behaviours when fully
implemented"?
Um, corporate governance evolves all the time. There
had been multiple codes of best practice over my career,
and improvements made at various stages, and there was
a very, very big change in the way in which corporate
governance was approached after the great financial
crisis of 2008 and 2009, when the concepts, for
instance, of first, second and third lines of risk
management were rolled out very widely in the corporate
world, in a way that they hadn't been before, precisely
because there were corporate failures: the wrong things
appeared on risk registers; management and Boards were
not told about things that needed to happen, or were
happening; the risks were not properly analysed and then
were not properly calibrated afterwards; remediation was
not put in place; risk owners were -- all of this kind
of stuff it's not perfect now, nothing is ever going to
be perfect, but it gets better.
I mean, I think, looking at the evidence here and
looking at the papers that I have seen, it seems to me
that, at various points, working up from the Post Office
through Royal Mail, through Shareholder Executive, there
were moments at which this could have been caught.
Principally, I think this is around internal audit, this
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around Audit and Risk Committees, this around the
Boards, particularly of POL, because I think it starts
there and then it comes up. Now, as I say, some of this
information came in from the side, as it were, into
Shareholder Executive and that arguably should have been
picked up in a different way than it was. But it really
start witnesses implementing fully the best practice of
corporate governance as it has evolved and I think, if
that had been done in this case, we would have hopefully
had a different outcome.
Do you consider that the governance framework of Post
Office Limited was fit for purpose and drove proper and
honest company behaviours?
On the surface, it looked -- certainly, at the time of
the separation, there was a specific attempt to bring
the Board and the governance of Post Office up to the
standards of an independent, large organisation with
proper corporate governance, the appropriate number of
independent Non-Executives, the appropriate number of
NEDs, the right balance of experience on the Board, the
apparatus of Board committees, all of those things were
improved at the time of separation.
I think by inference you can say that those things
were not in place before separation, and I'm afraid
I don't know the details of whether or not they had
93,
I mean, there's an example, for instance, earlier in
this evidence where Patricia Hewitt felt that it was
important to have some form of trade union
representative on the Board of the Royal Mail and,
obviously, they didn't like that but, ultimately,
Baroness Prosser was put on the Board of the Royal Mail.
It doesn't have to be the nuclear option of, you know,
firing the Board and getting a new Chair, and all the
rest of it. There is considerable authority just
invested in being the minister in charge.
The lines of communication and accountability in between
Post Office Limited itself and the Government
Shareholder at the top were, it might be said, complex
and multi-layered. Did those arrangements run the risk
that responsible people -- so across Government, civil
servants, RMG, POL Boards and the POL senior team --
would act on the basis that someone else would or should
or could grip problems?
There's an argument that the fact that there was
an intervening parent in the form of the Royal Mail
Group, between the Post Office and Government, did
complicate matters. We, as I say in my statement, there
was another actually bigger subsidiary, certainly in
financial terms bigger subsidiary, where we didn't have
any kind of direct relationship with it at all because
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a Risk Committee which looked at things in the
appropriate detail. I'm not sure about the nature of
that or the effectiveness of their internal audit
process. All of these things, however, go to, and
should have picked up on, on the problems that we have
here. So I suspect that there are things to look at.
You refer in paragraph 112 to "systems and practices
implementing the highest standards of existing corporate
governance". How do you suggest those systems and
practices should be enforced?
The enforcement mechanisms for these -- for systems and
practices of this type lie in the first place with the
Board and the Chair of the Board and the Chair of the
Audit and Risk Committee, the Chair of the Remuneration
Committee and any other Chairs that happen to -- any
other committees that happen to pop up.
Now, if it is the case that it is those -- that that
corporate apparatus is not in place, or is in place and
not doing their jobs properly -- its job properly, then
the Chair needs to, in the first place, make sure that
that is in fact happening properly. If that doesn't
happen, the Chair and other senior members of the Board
don't force that through, then I think the shareholder
needs to take action to ensure that that is the case,
and it can do.
94
we worked entirely through the Royal Mail Group.
I think that there was a good degree of oversight of
the Post Office, given that it was a subsidiary but
whether or not the complications that you allude to made
it more difficult to pick up this problem is
a possibility. I think it is a possibility. Certainly
I think it became easier when the Post Office had been
separated and there was a very -- there was a singular,
solo direct line from Post Office to Government.
Scrolling down, please, just to the bottom of 112, "the
devastating effects of governance failures". Are these
due to the inadequacies of individuals or is it the
governance systems which don't make sufficient demands
of individuals to ensure appropriate behaviour?
I find that a difficult question to answer, except to
repeat what I said before, really, which is that the
full implementation of proper governance systems would
have picked these things up and picking these things up
would have made their resolution quicker and more
equitable.
Whether or not that is specifically because people
decided not to put in place governance systems that were
state-of-the-art and up to the task, or whether or
not -- I mean, I guess, at the end of the day, those are
personal decisions.
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MS PRICE: Sir, those are all the questions that I have for
Sir Stephen. There are some from Core Participants.
I'm just looking around the room.
I think two sets of Core Participants have
questions. Is it Mr Henry asking on behalf of the HJA
team and then I think we have Ms Patrick.
SIR WYN WILLIAMS: All right. Thank you.
MS PRICE: Thank you, sir.
Questioned by MR HENRY
MR HENRY: Sir Stephen, do you think it would have been
helpful to have more prescriptive guidance for NEDs who
were Government appointed, so that there wasn't a danger
of them losing objectivity and becoming, as it were,
cheerleaders or interlocutors for the business but
rather, actually, being an objective, critical and
discerning eye for Government?
A. Well, I think a distinction needs to be drawn between
a Shareholder Non-Executive and an Independent
Non-Executive. The Independent Non-Executive -- as you
know, all directors of all companies have fiduciary
duties and they have duties towards the shareholders,
the employees, the creditors, the regulators, if that is
appropriate, and all directors have that. Clearly, if
you're a Shareholder Non-Executive, you have a -- there
is going to be a greater weight, inevitably, on the
97
the time knew about this risk themselves.
Q. That risk, of course, involved their historic legacy of
prosecutions?
A. Yes.
Q. Now, your background, of course, in strategic
communications and media, the destructive repercussions
of it becoming known that hundreds of subpostmasters had
been wrongly prosecuted would have been enormous, that
must be obvious?
A. Well, I don't have a background in strategic
communications and media. I was an investment banker
before I became a civil servant. I happened to do a lot
of deals in the media industry but I --
Q. Forgive me, I thought --
A. That's fine. That's neither here nor there. Clearly,
the reputational implications of a disaster like this
are terrible. I mean, they're not as terrible as the
impact on personal lives and livelihoods but, yes, they
are very bad.
Q. Ofcourse, compounding that atrocious injustice, if it
had also been known that, as opposed to hundreds,
thousands of subpostmasters had been wrongly milked for
cash, in respect of fictitious Horizon created debts,
that, would also have been a scandal, wouldn't it?
A. Certainly, that was a scandal. I mean, that's why we're
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shareholder interest for sort of kind of obvious
reasons.
I would have expected that the Non-Executive
Directors of any of the companies that we were involved
in would have had the fully rounded sense of what
a Non-Executive Director ought to be doing, and I think
that it is arguable that we could have, at the very
beginning of this process, back in 2005 or so, when
I started getting involved, have reiterated what the
fullest duties of the Non-Executive Directors were,
because there was a degree of tension which I think was
unhelpful.
That tension sometimes being resolved in, paradoxically,
a relaxation of actually looking after the shareholder,
it appears, that the shareholder and particularly
Government ministers, were not properly sighted on
significant risks?
I don't know whether or not you can jump from the one to
the other. The risks that were being run that we're
talk about here should have come up through any number
of different routes but, in the main, through the
executive information, which was going into Board
papers, which was going into papers that were being sent
over by the Shareholder Executive. It's not clear to me
whether or not the Royal Mail Non-Executive Directs of
98
here.
Yes, exactly. Now, your focus throughout your tenure
from 2007 to the end of January 2013, was very, very
much on the Royal Mail Group, among other considerable
responsibilities you had, because, of course, your
portfolio was getting bigger and bigger?
That's correct. My focus was much more on the Royal
Mail Group than it was on POL.
Yes, and presumably that is because of the Bill, the
Act, the Postal Services Act of 13 June 2011. Once that
passed, it made the roadmap to separation and RMG
privatisation clear, did it not?
It did. It was the enabling act that allowed for the
recommendations of the Hooper Review to be enacted, yes.
Now we're all agreed that, without going into the detail
of it, but you unreservedly accept that the risk posed
by wrongful prosecutions and the risk posed by the
unlawful civil pursuit of debt that did not exist,
serious reputational repercussions and it ought to have
appeared on the ShEx risk register, not preferable,
really, but mandatory?
It certainly should have appeared on the ShEx risk
register, yes --
Now --
-- for POL.
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Yes. For POL definitely but also because, by extension,
it would have been a considerable risk to your assets,
so, therefore, it ought to have appeared on your risk
register as well?
Yes, I -- during my time, we didn't have a risk register
for Shareholder Executive, per se. I think that did
come into account after but we didn't have one at that
time. It would have appeared -- it should have appeared
‘on the specific risk registers for Post Office and,
while Post Office was owned by Royal Mail, it should
have appeared on the Royal Mail risk register as well.
Yes. Now, I want to return to the fact about your focus
and we all accept that you would have been looking
principally at the Royal Mail Group because that was
your immediate priority, together with, of course,
number of other complicated and complex enterprises that
fell under your control.
But just probing paragraph 60 of your witness
statement, you say you were not aware of the complaints
made by subpostmasters in respect of the integrity of
the Horizon system --
That's correct.
-- and that you're not aware of the Computer Weekly
article being shown to you. I just want to explore with
you - and, forgive me, I'm not trying to be
101
accounts shortfall".
November 2009, "Post Office theft case deferred over
IT questions". That was Mrs Misra's case.
May 2010, "A pilot of the new Horizon Online system
at the Royal Mail has been scaled back after
connectivity problems and outages."
February 2011, “post Office faces legal action over
alleged accounting system failures.”
October 2011, "85 subpostmasters seek legal support
in claims against Post Office computer system.”
That was obviously another one. So October 2011.
One in June 2012, "Post Office launches external
review of system at centre of legal disputes".
Then three in January 2013, "Post Office admits
Horizon system needs more investigation"; "Post Office
announces amnesty for Horizon evidence" and "Post Office
wants to get to the bottom of IT system allegations".
So Sir Stephen, I mean none of these impacted you.
I'm afraid I have no knowledge of any of those at all.
By the same token I, you know, don't read publications
which are to do with the nuclear decommissioning
industry or, you know, the data industry. I'm afraid
the Computer Weekly articles completely passed me by and
they were not drawn to my attention.
But what about the media? I mean, for example,
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facetious -- but were you, as it were, in a bubble of
unknowing, in other words genuine ignorance about this
or is it a case of, "I don't recall, I may have been
made aware of this but I don't remember now"?
I have absolutely no memory of reading -- I've never
heard an article in Computer Weekly, and I have no
memory of reading this one or having it being brought to
my attention.
Now, that, of course, is perhaps entirely correct but,
of course, it was replicated in Private Eye and also, in
Government, you do have services where media is
distilled and relayed to ministers and so, therefore, it
would go through your hands as well, don't you; you have
services where media is looked at and digested?
There are services such as that. I didn't use them
particularly at all.
I see. So, again -- and this is probably inadvertence,
but I have a list in front of me of the articles in
Computer Weekly that occurred during your watch. There
were ten of them:
The May 2009 one entitled "Bankruptcy, prosecution
and disrupted livelihoods: Postmasters tell their
story", the one that you've actually specifically
referred into paragraph 60.
September 2009, "Postmasters form action group after
102
Channel 4 and also the fact that the MPs were beginning
to agitate for affected subpostmasters in their
constituencies? All of this was going on in tandem or
in parallel. Was none of this permeating your office?
It wasn't permeating my office. It clearly did permeate
the Shareholder Executive and there is plenty of
evidence in the bundles that everybody has seen that
people are referring to the Computer Weekly articles,
the BBC programmes, the Channel 4 programmes, and so on.
But it was being dealt with in the way in which it was
being dealt with. It didn't come to me.
Right. I mean, leaving your position aside and now
concentrating -- and you did refer to this in passing
during your evidence -- the Inquiry has heard from
Sir Mike Hodgkinson, Allan Leighton, Alan Cook, Adam
Crozier and, to a greater or lesser degree, all have
claimed ignorance of the wrongful prosecutions and
wrongful convictions being secured by Royal Mail Group
lawyers.
You've said that you don't wish to speak on behalf
of other people's knowledge but that is an extraordinary
state of affairs, is it not?
Well, I -- when responding to the Counsel for the
Inquiry's final questions, I -- she asked me about my
final observations and I am clear that there are
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multiple failures of corporate governance, which have --
I mean, there may be other reasons for this as well and
it will be for the Inquiry to decide what those are, but
certainly corporate governance is part of the question
here.
Yes. I mean the question that arises is that: was the
Government, the shareholder, in other words, unable to
appoint directors capable of gripping the issues, or is
it conceivable that those appointed by Government chose
to disregard the marginalised SPMs as being unworthy of
interest because they didn't fit the narrative; do you
see the distinction there?
First, the Non-Executive Directors were not appointed by
Government. Certainly at the beginning of my tenure,
the Royal Mail Non-Executive Directors were appointed
effectively by the Chair and the Chair was appointed by
Government.
I would be -- I think any right-thinking person
would be horrified by the types of stories that have
come to light in the last few years and I would hope
that that would be the case for those individuals as
well. But what was going through their mind at the
time, I'm afraid, I'm just not in a position to be able
to answer --
Well, returning to you, sir, and I don't need to take
105
So I suspect the answer is that they were still not
recognising that there was a big problem, but even if
they had recognised there was a big problem, I do not
think it bites on the success or otherwise of the IPO of
Royal Mail Group.
So two parts to your answer. Are you saying, therefore,
that the legacy of prosecutions had, as it were, been
hived off and POL had been -- the Post Office had been
saddled with them? In other words, RMG's historic
liability for prosecutions had been hived off and left
with the Post Office?
I think -- I was not involved in the drafting of the
prospectus. I had left the organisation by that point.
But I think it is very difficult to believe that, in
a flotation of that magnitude and of that profile, which
was very, very high profile indeed, as we will all
remember, that the legal advice -- and I'm fairly
certain it was Slaughter and May -- would have
recommended anything other than leaving reference to the
prosecutions in there, if there was a potential
liability. It must have been moved across to POL by
then.
So that's your supposition?
That is my supposition but I have done a lot of IPOs in
my life and I know what it is like to write a prospectus
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you to the document, but Mr Patrick O'Sullivan was
questioned about UKGI00016739, the minutes of
a Shareholder Executive Board meeting from 13 March
2013, and various risks relating 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 to that flotation. There's a complete
absence, it just appeared not to have occurred to them
at all.
I think -- if I may, I think there are two parts in
response to that. One is clearly that knowledge of the
problems was partial, incomplete, and not sufficiently
escalated, and I think we spent a lot of time talking
about that this afternoon and I have no problem in
admitting that.
I mean, if it had been, however, I would have been
surprised if the plight of the subpostmasters would have
had any affect whatsoever on the IPO of the Royal Mail.
By then, the liabilities would have been resting with
the Post Office and the prospectus for the Royal Mail
flotation would have been crawled over in unbelievable
detail by Slaughter and May and various other corporate
lawyers, and if they had felt that there was a liability
there, contingent or otherwise, it would have had to
have been put into the risk factors.
106
of this type, and I've not heard any evidence to suggest
so far that it should have been in the prospectus.
If your supposition is incorrect -- and let's just go on
this is angle, are you saying -- and it is, to
an extent, a thought experiment -- but let us suppose
that, between March and the actual flotation, which
I think was October?
I think you may be right, yeah.
Let us suppose that something exploded, that surely --
I mean, it hadn't been priced in -- that surely would
have dampened market confidence and there was a risk
that the IPO would become a damp squib?
I think that's -- my experience of doing these kinds of
things is that's very unlikely. Unless investigators
genuinely believed that there is a financial liability
associated with a situation like that, they would look
through it and assume that it had been dealt with in
POL.
Well, financial liability undoubtedly exists, and it's
going to be the subject of Phase 7 of this Inquiry.
But not for the Royal Mail Group.
No, not for the Royal Mail Group but, nevertheless --
nevertheless -- the idea that the Royal Mail Group had
been --
SIR WYN WILLIAMS: Can I interrupt you, please --
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MR HENRY: Of course, sir.
SIR WYN WILLIAMS: = -- because I've been thinking about this
and I may be seeing it too simplistically but my
understanding is that the prosecutions were brought by
Post Office Limited. The involvement of Royal Mail was
simply, in inverted commas, "to provide the legal
expertise to do that". Bult, if it is right, and
I stress if, because I will obviously need to go back
over a lot of evidence, if it is right that a limited
company, Post Office Limited, prior to separation, so
there's no doubt about it, brought the prosecution,
maybe assisted by Royal Mail lawyers, then it's not
difficult to suppose that the liability would be Post
Office Limited and, obviously, after separation, there's
no doubt about that.
MR HENRY: No, on reflection, sir, you're right and I think
it follows that the liability in those circumstances
would lie with the Post Office.
SIR WYN WILLIAMS: Yes, well at least there's an argument to
be had about it, so debating it with Sir Stephen is
probably not going to get us anywhere. That's the
point.
MR HENRY: No, I'm not going to debate it further with
Sir Stephen, sir. Thank you very much.
‘SIR WYN WILLIAMS: Ms Patrick?
109
a contract like that. That's exactly the kinds of thing
that it does but I'm -- I don't recall it.
Q. But you don't recall but, if it had been part of that
limited knowledge you had, would it have been relevant
to the knowledge that would have informed your -- or
anybody else's -- performance of a role that involved
‘oversight of that contract?
A. I find it difficult to answer that question because
I don't know what the NAO said in its report, if it did
do a report. If it had said something along the lines
of "This is a hopelessly negotiated contract and the
Government has been taken for a ride", that's one thing.
If it had said, "This is a dreadful contract for a whole
host of reasons, not least of which technical due
diligence has not been done properly", that would be
another one. And I don't know what it said, so I am,
\'m afraid I find it a bit difficult to answer the
question.
Q. Okay. Take a slightly different tack. Last week the
Inquiry saw an email indicating that, by February 2015,
one minister, Baroness Neville-Rolfe, seemed to be
questioning whether Horizon might be another example of
a Government IT debacle. I'm not going to turn it up,
but for anybody listening the reference was
UKGI00019859.
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Questioned by MS PATRICK
MS PATRICK: Sir Stephen, my name is Angela Patrick. I act
with Mr Moloney and Hudgells Solicitors for a number of
subpostmasters who were prosecuted and have since had
their convictions overturned. You might be glad to know
I only want to return to one topic that Ms Price covered
this morning -- sorry, this afternoon, in fact.
Earlier this afternoon just after lunch she asked
you about your state of knowledge of the history of the
Horizon contract with Fujitsu, and I just want to turn
back to that. I think you said your knowledge was
little more than that the negotiations with Fujitsu had
been fraught; is that a fair reflection?
A. I think that's what I said, yes. Long, complicated and
fraught, I suspect.
Q. Long, complicated and fraught, and I don't have to turn
up for the transcript but for the record and those
listening it's today's [draft] transcript at page 51,
lines 1 to 7.
Were you aware at the time you were responsible for
oversight of Royal Mail Group and Post Office, that
there had been critical scrutiny during the development
of the contract, including by the National Audit Office?
A. I genuinely don't recall. It would not have surprised
me that the National Audit Office would have looked at
110
Would reporting on repeated problems in IT
contracting by Government and public agencies have been
a well-known part of the public discourse by the time
you were in post in 2005 through 2013?
A. Yes, it would have been, though the nature of the
criticisms are normally -- were normally, and continue
to be, actually, that they were too expensive and not --
and too slow. They weren't typically that they were
subject to third-party remote access that -- I mean, it
wasn't that kind of criticism that typically you saw in
these Government IT problems.
Q. Okay. But if there had been a sort of general dialogue
or debate about complexity and failure and risk in the
contract management, would that be reason for
particularly close scrutiny when you were facing
particular allegations about a third-party IT system,
which was business critical to a public asset?
A. Well, again, I think I would go back to -- there weren't
IT specialists of any sort of kind of sophistication
within the Shareholder Executive. We didn't carry that
kind of expertise in-house. We would have relied, in
large part, on technical scrutiny, which would have been
undertaken by the Post Office themselves and, clearly,
we did ask a lot of questions about the Horizon system
and took the answers at face value.
112
(28) Pages 109 - 112
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The Post Office Horizon IT Inquiry 15 July 2024
Now, I think the argument is more about whether or
not we should have taken the answers at face value,
rather than whether or not we should have gone in and
tried to understand specifically what was going on with
Horizon ourselves because we didn't carry that kind of
expertise, I'm afraid.
Indeed. Simply taking it again in the general, if you
had a set of circumstances where you have a complex
history in IT contracting, a particular history of
problems in the development of a particular contract,
would that be reason to ask for particular due diligence
in scrutinising the technical information that you were
being given by a particular Government asset?
I think that's a very fair question and I think the
answer to that is, in due course yes, and of course that
is what happened in the end with Second Sight and the
subsequent investigations. I think the question is
whether or not those happened fast enough because it
did -- those did happen in the end.
I think it may be a question for the Inquiry in due
course as to whether, looking at Second Sight and those
inquiries, whether particularly the questions asked by
shareholders and others were themselves particularly
probing. But I think you address that in your own
witness statement about the role and the questions that
113
Clearly, that information was unreliable.
One final point, simply picking up on something you said
about there being no particular specific technical
expertise within ShEx and relying on the technical
information being fed up through the asset, is that kind
of technical expertise something that you expect is
available now to ShEx?
I would be surprised if the technical expertise is
available to Shareholder Executive -- or UKGI now. It
would be very expensive to maintain in-house, and it
wouldn't be used probably that much. But what I would
hope is that there would have been -- there would be now
access to independent firms who can -- if the need
arises to look into a situation like this, there is sort
of a roster of independent firms that UKGI could go to
very quickly and get the drains up to look at the
problem. I think it would be difficult to maintain it
in-house but I would hope that there is more capability
that they could draw on from outside.
When you were in post, was that a thing that you could
have asked to have happened yourself, or somebody under
you in your team, could you have said to RMG, "Hang on,
I'm not really sure that that is really bottoms out" --
or to POL -- "I think we independently will get our own
independent eyes and we will pay for that to look and
115
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‘ought to have been asked.
But, looking at Horizon, there had been a difficult
history in IT, an area that was known to be problematic.
There was an increasing body of complaints, where the
potential for failure in this case was not just about
an IT problem making business more difficult but that
a state-owned asset had potentially relied on faulty IT
to prosecute innocent men and women. Can you accept
what a sceptical, or at least a very cautious, approach
have been adopted by everyone involved, including
Government, to the scrutiny and oversight of Horizon
from the outset?
A. Sol hope I have answered that earlier on. Officials in
Shareholder Executive did ask lots of questions, we did
meet with Mr Bates and his organisation, we did then go
and ask lots of questions of the Post Office and,
ultimately, as I say, Second Sight was appointed.
Throughout that period, we got very, very forceful,
very -- and repeated and detailed answers from the Post
Office about the integrity of Horizon.
And on the whole, I would have expected officials to
have taken the view that they were entitled to rely on
answers like ~- rely on answers provided by POL,
particularly as you point out, when it goes to the
livelihoods and indeed liberty of sort of individuals.
114
see how this is working"; was that something you could
have done?
A. We could have done it. The information and the context
at the time didn't look from the documentation to sort
of kind of quite justify that, but clearly it got to the
stage where Second Sight were appointed. I don't think,
as it happens, that -- this is a small point -- I would
have expected the Shareholder Executive to have paid for
it. I would have expected POL to have paid for it and
the firm in question to have reported directly and to be
completely accountable to Shareholder Executive, but
I would have expected the company to pay for it, and
that is standard practice in this kind of situation.
MS PATRICK: Thank you, Sir Stephen. We have no further
questions.
Questioned by SIR WYN WILLIAMS
SIR WYN WILLIAMS: Sir Stephen, just one or two from me.
First of all, just to be clear about an answer you
gave to Mr Henry, was there a risk register in being
when you first became the Chief Executive of ShEx?
A. To the best of my knowledge, there was not a risk
register for Shareholder Executive itself.
‘SIR WYN WILLIAMS: Right. Can you tell me approximately,
obviously, when such a register was created for ShEx?
A. I'm afraid I can't, off the top of my head, Sir Wyn.
116
(29) Pages 113 - 116
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‘SIR WYN WILLIAMS: = That's all right. Fine. I am sure I can
find out from another source, so don't worry.
Then, finally, back to paragraphs 111 and 112 of
your witness statement: although ALBs are not mentioned
specifically in those paragraphs, do I take it that they
are an endorsement of the concept of ALBs?
A. You do take it as that, Sir Wyn, and indeed at 109 --
SIR WYN WILLIAMS: 109 makes that clear, yes?
A. I hope makes that clear. It is very difficult to
imagine a situation, a world where we don't have ALBs of
some type.
SIR WYN WILLIAMS: Right. So I don't mean this in any
disparaging sense, so please don't take it like that:
have you actually been engaged in work since 2013 which
involves ALBs?
A. Yes.
‘SIR WYN WILLIAMS: Right, fine.
A. Many times.
SIR WYN WILLIAMS: Fine. So it's not just based upon your
experience with the Shareholder Executive but on the
work you've done subsequently as a civil servant since
2013?
A. Yes.
SIR WYN WILLIAMS: That would be --
A. That is correct, both at Energy and in Defence, there
117
INDEX
Announcement re Phase 7 ....
SIR STEPHEN AUGUSTUS LOVEGROVE . 4
(affirmed)
Questioned by MS PRICE .... 4
Questioned by MR HENRY ... 97
Questioned by MS PATRICK ... 110
Questioned by SIR WYN WILLIAMS .. 116
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15 July 2024
are many ALBs that we used to do specialist, important
tasks where we needed to be able to get certain types of
jobs done.
‘SIR WYN WILLIAMS: = Thank you very much.
So I take it, Ms Price, that there are no further
questions?
MS PRICE: That's correct, sir.
SIR WYN WILLIAMS: So thank you very much, Sir Stephen, for
making your witness statement and for coming to give
evidence before the Inquiry. I am very grateful to you.
THE WITNESS: = Thank you very much.
‘SIR WYN WILLIAMS: So it's Mr Dunks tomorrow morning at
9.45. Is that correct, Ms Price?
MS PRICE: Yes, sir, itis.
SIR WYN WILLIAMS: All right. See you all then.
MS PRICE: Thank you.
(4.11 pm)
(The hearing adjourned until 9.45 am the following day)
118
(30) Pages 117 - 119
MR HENRY: [4]
97/10 109/1 109/16
109/23
MS PATRICK: [2]
110/2 116/14
MS PRICE: [26] 1/4
1/10 4/10 4/15 37/18
37/23 44/15 44/21
44/23 45/2 45/4 76/13
76/16 76/20 76/25
77/4 77/7 7719 77/11
77/15 84/2 97/1 97/8
118/7 118/14 118/16
SIR WYN WILLIAMS:
[33] 1/5 1/11 4/12
37/22 44/19 44/22
45/3 76/12 76/14
76/18 76/22 77/5 7/8
77/10 77/14 83/20
97/7 108/25 109/2
109/19 109/25 116/17
116/23 117/1 117/8
117/42 117/17 117/19}
117/24 118/4 118/8
118/12 118/15
THE WITNESS: [1]
118/11
‘in [1] 80/19
‘no [2] 39/19 53/12
‘one [1] 80/21
‘refresh’ [1] 41/9
‘refusing [1] 58/1
"sub [1] 58/13
‘trust’ [1] 31/9
0
07/08 [1] 40/11
08 [4] 40/11
1
1.00 [1] 37/18
4.10 [1] 44/24
1.15 [1] 37/19
1.4 [1] 39/18
10 [2] 11/13 67/14
10 November [1]
67/13
100 [1] 28/16
100 per cent [1]
81/18
106 [1] 61/21
109 [2] 117/7 117/8
44 [1] 17/16
11,500 [1] 22/19
111 [3] 90/15 91/23
117/3
112 [4] 91/3 94/7
96/10 117/3
12 [2] 23/3 23/4
12-24 [1] 40/21
12.00 [2] 1/2 37/21
13 June [1] 100/10
13 March [1] 106/3
14 June [1] 5/1
15 July 2024 [1] 1/1
15 September [1]
20/6
16 [1] 59/24
16,000 [1] 3/19
169 [1] 61/2
17 [1] 8/16
18 [3] 10/16 40/25
61/2
19 [1] 28/3
1993 [1] 6/2
2
2.00 [2] 44/19 45/1
2.1 [2] 20/11 20/13
2.2 [1] 20/21
2.54 [1] 77/1
20 June [1] 45/12
20 May [1] 57/16
20,000 [1] 22/19
2000 [1] 49/13
2003 [1] 6/2
2003/2004 [1] 18/1
2004 [3] 6/5 18/1
54/5
2005 [5] 6/13 42/1
60/25 98/8 112/4
2006 [4] 29/25 30/4
30/9 54/1
2007 [5] 6/20 7/4
45/12 52/19 100/3
2008 [4] 7/6 37/25
38/7 92/8
2009 [6] 42/4 50/14
92/8 102/21 102/25
103/2
2010 [7] 20/6 50/25
54/2 56/13 61/12
67/14 103/4
2011 [8] 33/20 80/4
80/6 80/8 100/10
103/7 103/9 103/11
2011-16 [1] 59/24
2012 [3] 90/2 90/24
103/12
2013 [9] 7/9 7/11
24/24 100/3 103/14
106/4 112/4 117/14
117/22
2015 [2] 49/13
111/20
2016 [1] 7/15
2024 [1] 7/21
2022 [2] 7/24 8/2
2024 [2] 1/1 5/1
21 June [1] 30/6
21 June 2006 [1]
30/9
23 [4] 11/12
230 [1] 61/1
24 [2] 13/15 40/21
24 October [1] 80/4
26 [4] 17/15 17/16
19/6 45/10
27 [1] 38/6
28 [1] 20/9
29 [2] 23/2 50/6
2nd [1] 57/23
9
9.45 [2] 118/13
118/18
94 [1] 79/18
95 [1] 80/24
96 [1] 82/13
A
3
3.04 [4] 77/3
3.4 [1] 43/22
30 [1] 74/4
31 [4] 14/40
33 [1] 34/24
34 [1] 52/16
35 [1] 25/21
39 [1] 26/7
4
4.11 [1] 118/17
40 [3] 28/2 28/4
47/15
42 [2] 61/5 66/7
43 [1] 61/3
46 [1] 79/19
4th November 2010
[1] 67/14
5
5 October [1] 56/12
51 [4] 110/18
52 [1] 45/9
53 [2] 45/21 47/12
54 [1] 46/22
55 [1] 90/16
56 [1] 5/1
57 [2] 56/20 64/17
59 [1] 64/17
6
6 December [1] 30/4
60 [3] 50/5 101/18
102/24
61 [1] 74/3
67 [2] 82/3 82/3
68 [1] 34/25
69 [3] 33/15 35/14
36/15
7
7 October [1] 57/8
76 [1] 29/23
8
8 July [4] 57/20
800 [1] 49/12
83 [1] 47/14
85 [1] 103/9
87 [2] 56/13 66/1
88 [1] 66/6
89 [1] 61/17
abide [2] 24/7 24/8
ability [1] 81/5
able [9] 2/21 11/4
11/7 26/22 79/6 79/7
79/8 105/23 118/2
abolished [1] 76/2
about [92] 1/6 2/8
2/13 3/7 5/15 15/20
16/12 16/16 16/19
16/20 16/21 16/22
21/24 22/15 24/8
24/10 28/3 29/4 29/13)
29/17 29/22 33/24
36/9 36/22 38/9 41/10
43/15 43/25 44/7 44/9
44/12 46/18 47/7 48/9)
48/17 50/21 51/6
51/12 52/11 55/4
59/18 61/7 61/18 63/3)
63/19 64/1 65/7 65/7
65/15 66/12 66/16
66/20 72/16 75/2
77/15 77/17 78/7
79/11 82/13 83/6 84/9
84/11 85/18 86/2 86/2
87/18 87/21 89/5
92/14 94/2 98/20 99/1
101/12 102/2 103/25
104/24 106/2 106/14
109/2 109/11 109/15
109/20 110/9 112/13
112/16 112/24 113/1
113/25 114/5 114/20
115/3 116/18
above [2] 23/19
38/18
absence [1] 106/8
absolutely [6] 42/13
47/8 62/8 69/8 84/1
102/5
absorbed [1] 76/3
accept [4] 62/24
100/16 101/13 114/8
Accepting [1] 57/3
access [6] 15/19
33/9 54/12 67/19
112/9 115/13
accompanied [1]
60/9
account [2] 51/15
101/7
accountability [3]
20/23 21/1 95/11
accountable [1]
116/11
accountants [1]
78/11
accounting [5] 24/7
51/3 57/13 60/19
103/8
accounting’ [1] 58/4
accounts [4] 4/4
53/11 71/4 103/1
accurate [4] 25/22
26/16 38/3 66/3
accurately [1] 91/12
accusations [1] 58/4
achieving [3] 74/16
74/20 75/2
acknowledge [1]
61/22
acknowledgement
[1] 46/6
acknowledges [1]
39/16
acknowledging [1]
45/24
acquittals [1] 54/8
across [4] 13/3 31/16
95/15 107/21
act [6] 30/23 95/17
100/10 100/10 100/13}
110/2
action [10] 54/4
58/11 58/23 60/18
62/5 71/1 71/20 94/24
102/25 103/7
actively [1] 36/10
activities [1] 23/9
actual [1] 108/6
actually [16] 10/24
19/23 26/1 36/9 46/19}
55/8 55/13 81/7 85/2
85/11 95/23 97/15
98/14 102/23 112/7
117/14
acute [1] 71/16
ad [2] 39/4 39/10
ad hoc [1] 39/10
Adam [1] 104/15
addition [1] 88/17
address [4] 50/5
56/13 66/5 113/24
addressed [2] 5/17
50/25
adequate [6] 15/19
87/18 89/14 89/18
89/23 89/23
adjourned [1] 118/18
Adjournment [1]
44/25
adjustments [1] 3/22
admission [1] 69/2
admits [1] 103/14
admittedly [1] 43/12
admitting [1] 106/15
adopt [1] 58/13
adopted [3] 10/17
28/12 114/10
(31) MR HENRY: - adopted
A
adopting [1] 59/20
advance [3] 4/22
53/14 56/11
advantage [1] 24/25
advice [3] 20/18 61/9
107/17
advise [1] 58/10
Adviser [4] 7/22 7/23
8/1 8/12
advisors [1] 60/24
advisory [1] 20/24
affairs [2] 8/10
104/22
affect [3] 21/4 73/6
106/18
affected [4] 4/4 60/5
78/15 104/2
affirmed [2] 4/13
119/5
affordability [4] 24/9
24/9 24/14 24/20
afraid [12] 19/22
34/19 68/15 74/2
89/11 93/24 103/19
103/22 105/23 111/17)
113/6 116/25
after [14] 19/14 47/18)
54/10 63/3 75/19 90/2
90/24 92/7 98/14
101/7 102/25 103/5
109/14 110/8
afternoon [5] 45/2
45/3 106/14 110/7
110/8
afterwards [2] 23/1
92/16
again [7] 29/15 47/14
63/4 72/1 102/17
112/18 113/7
against [15] 23/8
42/19 48/2 50/2 54/4
54/9 57/24 58/12
58/23 62/6 71/2 71/20}
73/16 89/17 103/10
agencies [1] 112/2
agency [1] 32/23
agendas [1] 25/13
agitate [1] 104/2
ago [2] 31/23 37/6
agree [15] 13/5 15/4
15/15 15/18 25/2 25/7
32/24 42/6 45/4 45/7
61/11 71/19 71/25
75/20 82/22
agreed [9] 2/21 21/10)
22/13 22/14 22/15
25/10 40/10 84/7
100/15
agreement [1] 79/22
agreements [1] 69/7
aim [1] 74/17
aimed [1] 2/1
aiming [1] 17/24
air [1] 37/8
akin [1] 28/13
Alan [4] 56/12 57/7
72/11 104/15
ALB [5] 11/16 11/17
11/18 15/8 66/22
albeit [1] 30/23
ALBs [10] 10/18
14/11 18/9 23/7 28/20
117/4 117/6 117/10
117/15 118/1
alerting [1] 20/15
Alice [3] 33/24 79/23
80/7
all [65] 1/8 2/4 3/4
3/10 4/5 4/7 10/1 16/6)
16/11 27/4 37/4 37/5
37/19 38/18 42/5
43/11 44/22 45/24
47IT 48/18 50/19 52/9
55/21 55/25 60/12
63/17 63/23 67/21
69/8 70/2 74/22 75/14
76/8 76/8 76/9 76/22
76/24 77/17 78/5
78/18 86/12 92/3
92/17 93/21 94/4 95/8)
95/25 97/1 97/7 97/20
97/20 97/23 100/15
101/13 102/16 103/19)
104/3 104/16 106/5
106/9 107/16 116/18
117/1 118/15 118/15
Allan [4] 104/15
allegations [4] 51/6
61/13 103/17 112/16
alleged [1] 103/8
allied [1] 12/3
allow [1] 11/9
allowed [2] 18/9
100/13
allude [1] 96/4
almost [2] 6/10 86/8
alone [2] 28/18 73/12
along [6] 19/13 24/15
69/5 84/15 84/18
111/10
alongside [1] 71/10
also [18] 9/1 9/9
14/19 15/18 31/7
34/17 40/18 50/1
53/10 55/22 58/5 74/6
80/23 99/21 99/24
101/1 102/10 104/1
altered [1] 85/16
alternative [1] 59/15
although [6] 16/6
33/12 42/22 43/17
62/23 117/4
always [11] 11/22
14/15 17/5 18/23 21/8)
24/9 28/8 30/17 70/14
70/16 86/8
am [12] 2/20 23/21
43/12 49/1 49/9 63/16
64/11 104/25 111/16
117/1 118/10 118/18
amnesty [1] 103/16
among [1] 100/4
analysed [3] 3/16
22/22 92/15
analyses [1] 74/11
analysis [1] 45/15
analytics [1] 1/25
Angela [1] 110/2
angle [1] 108/4
annex [1] 30/3
announcement [4]
1/3 1/6 1/8 119/2
announces [1]
103/16
annual [9] 39/4 53/11
65/12 69/7 74/11
87/25 88/19 88/25
89/1
anomalous [1] 35/3
anonymous [1] 2/16
another [12] 11/17
17/19 25/2 34/3 34/5
68/7 81/14 95/23
103/11 111/16 111/22
117/2
answer [31] 1/23 3/9
29/15 29/15 34/19
38/25 39/9 39/13
39/21 40/2 40/14
40/18 41/8 62/17
64/24 66/20 69/5
69/18 72/15 73/15
73/22 73/23 74/2
96/15 105/24 107/1
107/6 111/8 111/17
113/15 116/18
answered [2] 83/23
114/13
answers [11] 3/14
38/21 42/5 67/22
67/23 67/24 112/25
113/2 114/19 114/23
114/23
Anthony [3] 79/21
79/25 79/25
any [41] 13/13 16/11
25/8 26/1 27/7 35/24
36/14 44/2 47/17
47/22 47/25 48/2 48/6
49/17 51/11 58/21
59/20 59/20 61/4 61/7
65/9 66/18 69/20 78/1
78/14 78/21 79/10
85/8 85/22 90/4 94/15
94/15 95/25 98/4
98/20 103/19 105/18
106/18 108/1 112/19
117/12
anybody [5] 47/16
49/2 71/17 111/6
111/24
anyone [2] 35/21
48/24
anything [7] 27/17
36/9 44/14 51/16 52/7
53/14 107/19
anyway [1] 79/14
anywhere [1] 109/21
apart [2] 25/8 34/10
apparatus [3] 9/10
93/21 94/18
appeal [1] 60/9
appear [1] 74/14
appeared [11] 46/7
61/24 62/15 92/13
100/20 100/22 101/3
101/8 101/8 101/11
106/8
appears [3] 42/6
53/20 98/15
appended [2] 30/3
30/6
appetite [1] 78/16
applicants [4] 2/18
2/24 3/5 3/10
applied [2] 2/2 3/23
apply [2] 30/20 31/11
appoint [2] 26/12
105/8
appointed [18] 7/11
TIN7 7/22 28/17 40/7
40/16 42/4 51/25
66/22 80/7 82/15
97/12 105/9 105/13
105/15 105/16 114/17,
116/6
appointee [1] 80/22
appointment [9] 26/9
28/22 31/5 33/1 33/19)
33/23 34/12 71/13
79/20
appointments [5]
27/1 27/5 31/8 41/20
44/13
appraised [1] 89/14
appreciate [1] 45/17
apprise [1] 88/5
apprised [1] 91/14
approach [5] 28/12
39/19 53/18 58/13
114/9
approach's [1] 18/21
approached [1] 92/7
approaching [1]
37/18
appropriate [7] 41/19]
70/13 93/18 93/19
94/2 96/14 97/23
appropriately [1]
91/13
approval [1] 26/10
approximated [1]
9/12
approximately [1]
116/23
April [4] 7/15 37/25
38/7 90/2
April 2008 [1] 38/7
are [82] 1/19 2/7 2/15
2/16 2/17 3/14 3/22
4/1 4/5 5/8 5/10 5/17
5/20 14/13 20/5 24/11
24/12 25/8 25/16
25/18 25/24 26/23
27/2 29/21 34/22 37/5I
37/18 38/14 41/2
41/21 42/18 43/18
44/13 46/19 48/23
53/8 54/19 55/4 58/8
58/16 59/2 59/5 59/9
59/19 59/21 59/23
60/8 61/6 64/8 65/8
66/1 67/21 77/12
80/12 81/7 82/9 86/18
87/7 87/12 89/20 91/1
91/16 94/6 96/11
96/24 97/1 97/2 99/17
99/19 102/15 103/21
104/8 104/25 105/3
106/10 107/6 108/4
112/6 117/4 117/6
118/1 118/5
area [2] 54/25 114/3
areas [2] 12/11 12/21
aren't [1] 23/17
arena [1] 53/15
arguable [1] 98/7
arguably [1] 93/5
argument [6] 85/8
85/22 86/6 95/19
109/19 113/1
arisen [2] 85/14
85/15
arises [2] 105/6
115/14
arising [2] 31/4 74/13
arm's [5] 10/18 11/6
21/16 26/10 58/20
arm's-length [2]
10/18 26/10
arose [1] 83/25
around [11] 5/24
6/13 26/23 27/5 33/4
42/12 88/4 92/25 93/1
93/1 97/3
arranged [1] 83/8
arrangement [1]
82/21
arrangements [3]
84/23 91/6 95/14
art [1] 96/23
article [3] 50/15
101/24 102/6
articles [3] 102/18
103/23 104/8
articulated [2] 9/6
9/8
as [167]
(32) adopting - as
A
as annex [1] 30/3
ascending [2] 46/8
46/10
ascension [1] 47/10
ascertain [1] 12/16
aside [2] 61/9 104/12
ask [8] 65/24 83/20
86/2 87/5 112/24
113/11 114/14 114/16)
asked [15] 6/13
51/21 52/7 63/2 65/17
66/10 69/3 71/10
71/11 77/16 104/24
110/8 113/22 114/1
115/21
asking [4] 4/18 5/15
69/10 97/5
aspired [1] 31/19
assessing [2] 24/11
88/19
asset [21] 9/18 9/19
9/24 14/22 14/23
14/25 15/2 15/3 15/13}
15/14 16/19 16/22
21/14 25/1 25/11
45/20 69/12 112/17
113/13 114/7 115/5
asset's [1] 35/10
assets [17] 9/11 9/22
10/20 11/10 18/3 19/6}
26/9 28/7 34/23 35/3
35/6 65/11 65/16
65/22 69/1 89/6 101/2
assets' [1] 11/3
assigned [1] 16/18
assist [3] 4/20 15/3
27119
assisted [1] 109/12
assists [1] 38/6
associated [5] 34/20
35/9 49/20 74/25
108/16
Association [1]
86/14
assume [1] 108/17
assurances [2] 68/24I
70/3
assure [1] 2/14
at [186]
atmospherics [1]
42/12
atrocious [1] 99/20
attaches [1] 2/22
attempt [1] 93/15
attempting [1] 18/11
attend [2] 81/5 87/6
attention [4] 50/15
52/6 102/8 103/24
attitude [1] 83/21
attracted [1] 11/10
attribute [2] 33/22
46/12
audit [9] 27/20 59/25
67/18 92/25 93/1 94/3
94/14 110/23 110/25
auditors [2] 46/24
46/25
AUGUSTUS [3] 4/13
4/17 119/4
authority [1] 95/9
autonomy [1] 28/10
available [3] 83/13
115/7 115/9
Avoid [2] 59/7 59/20
aware [26] 1/12
19/20 29/1 29/6 29/9
29/11 47/3 47/20 48/3
49/6 49/22 49/25
50/16 51/10 55/6
60/13 61/12 66/25
81/18 82/20 84/8
84/19 101/19 101/23
102/4 110/20
away [1] 23/10
B
back [15] 19/18
23/17 45/23 66/4
72/16 82/25 88/13
90/4 90/11 98/8 103/5)
109/8 110/11 112/18
1417/3
background [6] 5/20
57/14 57/24 89/17
99/5 99/10
bad [1] 99/19
balance [5] 9/23
18/11 23/9 24/13
93/20
bank [2] 6/3 8/12
banker [1] 99/11
bankers [1] 78/11
banking [1] 6/2
Bankruptcy [1]
102/21
bar [4] 39/2
Baroness [4] 31/5
33/1 95/6 111/21
base [1] 43/12
based [3] 61/15 62/6
117/19
basic [1] 83/9
basically [1] 26/25
basis [3] 2/20 2/25
95/17
Bates [8] 56/12 57/7
57/15 63/5 63/23
67/21 72/11 114/15
BBC [1] 104/9
be [160]
bear [2] 25/14 43/8
became [8] 6/20
14/16 24/24 32/17
72/6 96/7 99/12
116/20
because [40] 10/4
10/20 13/23 14/2
18/16 21/20 21/23
28/1 29/7 32/2 37/3
47/2 48/14 60/12 63/8
69/2 70/16 72/15
73/24 75/8 78/6 85/20
87/2 88/12 89/23
92/12 93/2 95/25
96/21 98/11 100/5
100/9 101/1 101/14
105/11 109/2 109/8
111/8 113/5 113/18
become [4] 6/13
28/11 36/16 108/12
becomes [1] 73/1
becoming [3] 71/15
97/13 99/7
been [156]
before [21] 1/5 1/18
17/9 18/1 18/6 42/23
44/16 49/7 50/13
50/20 60/13 67/22
68/24 69/21 74/7
74/22 92/11 93/24
96/16 99/12 118/10
beginning [4] 70/10
98/8 104/1 105/14
behalf [5] 4/19 58/7
90/23 97/5 104/20
behave [1] 63/14
behaviour [4] 53/2
85/3 85/6 96/14
behaviours [3] 91/2
92/1 93/13
behind [2] 34/11 68/1
being [64] 5/21 8/5
8/25 9/21 10/23 16/3
16/18 22/7 25/1 27/17I
28/13 29/3 29/13
30/25 31/15 33/7
33/21 36/10 40/6 40/8
41/12 43/7 45/18
48/10 50/1 50/15
50/16 51/6 51/23 57/5)
60/5 62/3 62/5 64/2
65/7 65/18 71/10
71/11 72/8 72/10
72/13 76/20 82/5 82/6
82/20 83/13 84/23
90/4 90/11 95/10
97/15 98/13 98/19
98/23 101/24 102/7
104/10 104/11 104/18)
105/10 113/13 115/3
115/5 116/19
belief [1] 5/9
believe [4] 17/3
61/18 90/21 107/14
believed [1] 108/15
below [4] 23/5 28/19
53/4 59/9
bench [2] 41/10
43/25
benefit [1] 45/23
best [7] 2/7 5/8 9/12
12/2 92/4 93/7 116/21
better [11] 25/5
31/17 32/17 32/21
32/25 39/24 81/9
87/14 89/19 89/21
92/19
betting [2] 10/11
10/14
between [29] 9/23
14/15 15/7 17/4 17/6
19/25 21/17 21/18
22/9 22/15 25/12
28/14 28/15 30/18
45/8 48/19 49/13
53/19 59/16 66/21
67/7 70/3 80/17 81/21
83/5 95/11 95/21
97/17 108/6
beyond [1] 50/13
big [3] 92/6 107/2
107/3
bigger [4] 95/23
95/24 100/6 100/6
Bill [1] 100/9
binary [3] 43/18
43/19 72/2
bit [3] 43/4 75/6
111/17
bites [1] 107/4
bits [2] 26/23 65/15
blameless [1] 91/19
board [121]
Board's [3] 20/14
20/22 21/25
boards [12] 8/23
18/8 28/7 34/23 35/3
36/24 83/24 86/8
87/15 92/13 93/2
95/16
bodies [2] 10/18
26/10
body [4] 21/16 59/15
71/4 114/4
bold [1] 59/18
bonuses [1] 40/9
both [11] 3/22 18/4
19/2 21/15 23/7 35/6
46/4 63/14 77/23
88/14 117/25
bottom [5] 8/18
20/12 23/4 96/10
103/17
bottoms [1] 115/23
bought [1] 49/2
box [4] 39/1 39/2
40/4 43/20
branch [1] 59/23
branches [6] 11/19
12/10 12/21 12/22
13/2 22/19
break [3] 44/18 76/21
77/2
breakdown [1] 55/12
breath [1] 37/9
briefing [1] 39/22
bring [8] 17/24 22/10
25/14 48/1 48/22 49/8)
52/5 93/15
brings [1] 24/14
British [3] 73/21
78/25 86/14
broken [1] 32/1
brought [14] 25/15
42/24 48/1 48/23
48/24 49/12 50/15
54/4 54/9 68/14 73/7
102/7 109/4 109/11
bubble [1] 102/1
budget [1] 86/22
budgets [1] 86/21
bug [3] 53/25 54/1
54/2
bullet [4] 20/17 58/15
59/3 67/4
bundles [1] 104/7
business [22] 10/3
10/7 10/11 11/3 32/4
32/6 41/6 43/24 53/17I
59/24 74/22 75/9
75/22 81/6 81/8 81/9
81/19 82/5 89/8 97/14)
112/17 114/6
businesses [9] 8/24
10/5 11/1 32/24 52/24I
53/2 53/5 53/12 53/16I
but [115] 6/23 8/25
10/5 11/16 14/14 19/8)
21/9 21/21 24/20
26/11 26/25 27/8 29/7I
29/9 30/18 32/17 34/8
36/8 37/17 39/2 40/2
40/20 41/1 41/3 41/16
41/17 42/12 43/12
44/2 47/9 48/16 48/24
50/13 51/3 51/9 52/11
52/14 59/5 60/13 61/4I
61/6 63/8 63/10 64/13}
65/14 65/22 68/2
69/18 71/8 72/1 74/1
74/21 76/9 76/18
81/20 82/15 83/14
83/23 84/17 86/4 87/3
87/12 88/13 89/2 89/6I
89/9 89/22 90/9 91/6
92/19 93/6 95/5 96/3
97/14 98/21 99/13
99/18 100/16 100/21
101/1 101/7 101/18
102/1 102/4 102/9
102/18 103/25 104/10}
104/21 105/3 105/22
106/1 106/5 107/2
107/14 107/24 108/5
108/21 108/22 109/3
109/7 110/17 111/2
111/3 111/3 111/24
112/12 113/24 114/2
(33) as annex - but
B
but... [6] 114/6
115/11 115/18 116/5
116/11 117/20
Cc
Cable [2] 80/6 80/24
calibrated [1] 92/16
call [4] 4/11
called [1] 54/1
came [5] 19/14 51/4
56/17 75/25 93/4
campaign [2] 57/22
58/5
can [60] 1/4 1/5 2/12
2/25 3/18 3/20 4/8
15/9 16/11 24/16 28/2
30/8 33/14 38/11 39/1
40/5 40/6 43/22 44/15
48/3 48/7 48/24 49/2
49/3 49/4 49/13 49/16
51/4 52/2 52/3 55/14
63/19 64/3 64/16
67/11 67/19 69/17
73/25 75/17 76/12
76/18 76/21 76/23
77/4 77/5 77/9 77/10
86/5 87/11 91/22
91/23 91/24 93/23
94/25 98/18 108/25
114/8 115/13 116/23
1417/1
can't [12] 31/23 37/3
39/1 43/20 52/14
62/17 73/24 74/1
76/14 76/18 89/2
116/25
capability [4] 17/25
21/4 54/12 115/18
capable [5] 10/23
33/2 83/13 84/23
105/8
career [1] 92/4
carried [3] 33/16
34/17 61/5
carry [3] 86/4 112/20
113/5
case [26] 12/9 12/13
15/14 19/10 24/17
24/18 32/3 36/23
46/23 47/8 54/6 59/1
60/25 74/6 86/8 86/17,
86/20 91/16 93/9
94/17 94/24 102/3
103/2 103/3 105/21
114/5
cases [9] 17/21 21/4
57/12 60/23 61/1 61/5}
71/25 72/3 72/18
cash [1] 99/23
cast [1] 68/13
catching [1] 72/5
caught [1] 92/24
cause [1] 15/9
cautioned [1] 61/3
cautious [1] 114/9
caveat [1] 51/9
cent [3] 13/10 28/16
81/18
central [3] 10/24 11/4
46/3
centre [1] 103/13
CEO [4] 24/24 40/19
40/20 43/17
certain [8] 3/7 5/16
11/8 30/23 51/8 60/23
107/18 118/2
certainly [27] 12/25
16/17 16/23 37/22
42/9 44/19 46/22
46/23 49/9 54/24
63/12 65/19 65/23
69/22 69/25 76/10
81/8 86/17 88/2 89/19)
93/14 95/23 96/6
99/25 100/22 105/4
105/14
chair [27] 8/5 9/16
33/18 36/6 36/17 39/8
39/12 40/5 40/14
40/16 42/3 42/18
42/20 42/24 78/24
79/21 79/23 87/10
88/17 94/13 94/13
94/14 94/20 94/22
95/8 105/16 105/16
chairman's [3] 39/15
39/16 69/8
chairs [5] 26/9 27/15
28/6 49/21 94/15
challenge [2] 61/5
78/16
challenged [2] 54/5
70/1
challenges [2] 2/13
72/21
challenging [5] 32/4
70/20 70/21 70/24
73/3
change [5] 7/13 52/6
74/24 76/6 92/6
changed [1] 67/18
changes [3] 42/2
59/22 75/15
changing [1] 43/11
channel [6] 18/17
52/13 57/21 57/25
104/1 104/9
Channel 4 [5] 18/17
57/21 57/25 104/1
104/9
characterisation [1]
33/11
charge [3] 47/17
51/13 95/10
check [1] 7/21
checks [1] 65/9
cheerleaders [1]
97/14
Chief [15] 6/6 6/20
7/8 28/8 28/25 44/4
51/5 52/5 61/21 63/11
66/25 75/18 82/21
87/23 116/20
chose [1] 105/9
circle [1] 85/15
circumstances [12]
13/12 16/12 26/14
32/5 52/1 55/12 63/6
71/3 73/2 84/16
109/17 113/8
cite [1] 33/17
id [1] 36/14
civil [14] 16/18 18/6
18/6 24/7 24/10 54/4
88/3 95/15 99/12
100/18 117/21
claimed [3] 60/3 60/4
104/17
claims [5] 1/20 2/14
50/25 57/9 103/10
clarification [1]
35/21
clarity [1] 25/15
clear [29] 2/12 9/1
9/5 9/8 12/3 14/19
15/6 17/5 33/24 42/13}
52/15 55/5 58/19 59/5
62/24 63/20 64/11
65/8 69/8 70/22 72/6
82/11 87/3 98/24
100/12 104/25 116/18}
117/8 117/9
clear-cut [1] 17/5
clearly [29] 10/4
11/15 16/22 19/24
22/17 22/21 29/17
43/17 44/3 47/2 51/9
52/12 53/7 61/22 63/6
64/25 67/16 71/11
71/15 71/16 73/24
83/14 97/23 99/15
104/5 106/11 112/23
115/1 116/5
click [4] 39/4
Climate [1] 7/12
close [4] 28/6 55/3
75/9 112/15
closely [3] 6/24
34/20 49/20
Coalition [4] 23/15
23/22 24/1 24/19
code [2] 38/16 41/15
codes [3] 90/25
91/25 92/4
coherent [1] 53/17
coinciding [1] 23/22
colleagues [1] 69/25
colleagues' [1] 62/17
Colombia [1] 8/9
column [2] 38/15
38/16
columns [1] 38/15
combined [2] 41/15
54/15
come [18] 10/3 17/9
33/14 34/6 44/15 47/9)
50/24 55/14 64/16
65/4 69/17 75/17
79/15 81/23 98/20
101/7 104/11 105/20
comes [3] 20/11
27/13 93/3
comfort [1] 73/19
coming [6] 4/20
34/20 51/16 65/10
90/13 118/9
commas [1] 109/6
commencing [1]
39/5
comment [9] 20/7
38/25 39/13 39/21
40/2 41/16 43/25 44/3)
59/6
commented [1] 21/1
comments [3] 40/15
46/11 58/13
commercial [22] 7/1
9/8 9/23 11/25 12/3
16/21 18/2 18/5 18/10}
18/21 20/1 21/9 22/9
22/16 22/25 23/7
25/17 30/24 33/10
35/13 65/3 91/17
commercially [2]
8/25 36/16
commissioned [1]
1124
commitment [1]
59/20
committed [2] 48/7
58/23
committed/planning
[1] 58/23
Committee [6] 27/1
64/4 64/8 94/1 94/14
94/15
committees [3] 93/1
93/21 94/16
committing [1] 59/7
common [2] 83/17
86/7
commonality [1]
65/14
communicate [1]
53/7
communicating [1]
88/1
communication [4]
39/20 55/12 69/12
95/11
communications [2]
99/6 99/11
companies [9] 9/6
10/20 27/25 28/11
35/5 65/16 87/15
97/20 98/4
companies’ [1] 62/13
company [33] 7/6
12/2 13/14 15/3 26/1
26/3 26/4 26/21 26/22I
27/20 28/14 28/15
30/19 30/25 31/10
32/10 33/7 35/17
39/19 45/17 47/23
48/3 48/6 58/20 74/24)
78/6 78/8 91/2 91/15
92/1 93/13 109/10
116/12
company's [1] 39/17
compare [1] 1/17
compared [1] 73/16
compensation [7]
1/19 1/22 2/2 2/10
2/14 2/19 3/23
compile [1] 45/14
complaints [4] 47/3
50/16 101/19 114/4
complete [4] 4/6
65/14 91/5 106/7
completed [1] 3/20
completely [5] 25/13
42/14 72/2 103/23
116/11
complex [5] 87/12
91/16 95/13 101/16
113/8
complexity [1]
112/13
compliant [1] 41/15
complicate [1] 95/22
complicated [8]
10/22 50/12 50/19
50/21 78/12 101/16
110/14 110/16
complications [2]
19/16 96/4
complied [1] 54/19
Composition [1] 30/2!
compounding [1]
99/20
compromise [3] 21/4
22/9 83/19
computer [7] 50/14
101/23 102/6 102/19
103/10 103/23 104/8
conceivable [1]
105/9
concentrating [1]
104/13
concept [1] 117/6
conception [1] 90/25
concepts [1] 92/8
concern [7] 15/9
21/12 21/14 23/14
48/9 82/18 85/18
concerned [1] 1/13
concerns [13] 35/8
38/9 39/12 41/10 43/6
(34) but... - concerns
Cc
concerns... [8] 43/15
43/25 44/7 61/7 61/18)
63/4 79/11 80/11
conclude [1] 4/1
conclusions [1]
75/24
conduct [5] 1/25
A7IN7 47/21 78/20
79/11
conducted [1] 2/24
conducts [1] 15/8
confidence [2] 66/13
108/11
confident [1] 66/2
confidentiality [1]
85/18
confines [1] 9/1
confirm [1] 4/15
confiscation [1] 50/2
conflict [8] 21/17
21/18 34/5 82/18
85/10 85/14 86/3
86/20
conflicts [1] 87/8
confrontational [1]
57/20
connected [1] 2/15
connectivity [1]
103/6
conscious [1] 56/2
consensus [1] 40/6
consent [1] 54/14
consequence [1]
13/18
consequences [1]
53/9
consequent [1]
63/23
consider [5] 33/8
54/18 72/12 82/7
93/11
considerable [6]
28/19 48/9 75/1 95/9
100/4 101/2
consideration [2]
30/21 37/12
considerations [2]
16/14 20/16
considered [6] 56/1
64/3 64/7 67/1 67/6
84/19
consistent [1] 14/7
constant [2] 9/18
70/19
constituencies [1]
104/3
constituents [1] 58/7
constituted [2] 9/15
26/22
constraints [2] 24/20
30/23
consultancy [1] 5/23
consultation [3]
12/14 31/7 60/23
consulted [2] 84/2
84/5
consuming [1] 60/1
contact [3] 38/23
39/7 66/14
contacted [2] 3/19
4/5
containing [1] 38/9
contentious [1]
53/15
contents [1] 5/8
context [11] 9/22
23/19 31/13 32/14
38/12 39/2 52/2 55/1
63/18 82/6 116/3
contingent [1]
106/24
continue [4] 26/24
53/16 77/13 112/6
continued [3] 7/20
33/20 75/3
continues [1] 17/7
contract [9] 67/18
110/10 110/23 111/1
1414/7 111/11 111/13
112/14 113/10
contracting [2] 112/2
113/9
contracts [3] 51/3
57/11 59/22
contractual [15]
14/14 15/9 15/16
15/20 15/24 16/13
29/4 29/14 57/18
58/17 72/9 72/14
73/13 80/18 89/15
contractually [1]
60/8
contrast [1] 19/5
contributory [1]
90/19
control [2] 65/9
101/17
controversial [1]
35/10
convenient [1] 44/18
conversation [10]
17/1 24/22 36/21 37/1
37/16 67/16 68/3
68/14 84/9 87/1
conversations [10]
13/25 14/1 31/24 36/6
83/5 84/16 86/19
87/11 88/11 88/14
conveying [1] 69/21
convictions [3] 62/5
104/18 110/5
Cook [1] 104/15
cooperation [1]
14/24
copied [2] 51/11
62/19
copy [2] 4/23 5/4
core [4] 1/11 24/6
97/2 97/4
corporate [21] 9/10
9/11 14/3 26/23 27/10
78/25 90/22 90/25
91/8 91/25 92/3 92/6
92/10 92/12 93/8
93/18 94/8 94/18
105/1 105/4 106/22
correct [27] 6/1 6/4
6/8 6/12 6/16 7/2 8/3
13/4 13/21 14/9 14/18
14/23 19/10 23/13
26/13 30/14 37/15
52/19 56/17 57/2 84/1
100/7 101/22 102/9
117/25 118/7 118/13
correctly [2] 13/16
83/25
correspondence [1]
34/8
cost [1] 91/20
cosy [5] 59/16 67/2
67/7 68/13 68/18
could [45] 4/15 5/1
8/16 9/9 9/13 11/12
17/14 18/22 20/4 21/4
21/18 23/2 29/25 30/7
34/23 35/23 37/19
37/24 38/5 45/9 47/14
48/15 50/6 52/17 56/9
66/6 66/16 74/3 74/23,
79/18 83/8 86/19
86/24 87/2 88/15
90/14 92/24 95/18
98/7 115/15 115/19
115/20 115/22 116/1
116/3
couldn't [1] 37/14
Counsel [1] 104/23
country [1] 13/3
couple [1] 31/14
course [20] 4/12 5/15]
14/2 34/8 48/11 70/10}
75/11 83/2 89/1 99/2
99/5 99/20 100/5
101/15 102/9 102/10
109/1 113/15 113/15
113/21
Court [1] 61/2
courts [1] 73/21
covered [2] 2/6 110/6
covering [1] 67/17
CPS [3] 48/23 49/8
49/10
crack [1] 52/10
crawled [1] 106/21
create [1] 82/18
created [3] 85/10
99/23 116/24
creditors [1] 97/22
crime [1] 48/7
criminal [3] 49/25
60/25 61/1
crisis [1] 92/8
critical [3] 97/15
110/22 112/17
criticism [1] 112/10
criticisms [1] 112/6
Crown [1] 60/5
Crozier [1] 104/16
crucial [1] 81/14
culminating [1]
7112
cultural [2] 33/8
34/16
culture [11] 1/16
4/17 1/17 6/11 28/9
33/16 35/18 78/20
79/4 79/9 79/11
current [4] 2/1 2/8
2/11 3/22
cut [2] 15/6 17/5
D
damp [1] 108/12
dampened [1]
108/11
danger [2] 23/8
97/12
data [9] 1/24 45/16
46/3 47/13 61/15 62/7)
73/9 78/10 103/22
date [2] 30/4 52/21
dated [4] 5/1 30/6
56/12 80/4
dates [1] 7/21
Davey [7] 50/24
61/10 66/5 67/16 80/4
80/5 80/25
Davey's [1] 56/11
day [6] 19/15 58/21
58/21 88/13 96/24
118/18
days [2] 19/8 65/20
de [1] 33/1
de facto [1] 33/1
deal [3] 17/11 45/8
89/5
Dealing [1] 66/23
dealings [1] 23/7
deals [3] 30/11 52/24
99/13
dealt [6] 38/2 64/18
89/25 104/10 104/11
108/17
debacle [1] 111/23
debate [2] 109/23
112/13
debating [1] 109/20
debt [1] 100/18
debts [1] 99/23
December [3] 8/2
29/24 30/4
decide [3] 18/16 59/1
105/3
decided [3] 80/6
80/25 96/22
decision [6] 56/2
56/2 60/24 63/6 63/19]
84/3
decisions [7] 14/11
21/3 21/23 22/1 35/10)
35/13 96/25
decisions' [1] 80/20
declined [1] 57/17
decommissioning [1]
103/21
deepen [1] 81/21
deeply [2] 4/3 35/18
Defence [3] 7/18 8/1
117/25
defendants [1] 61/3
deferred [1] 103/2
deficit [2] 32/8 74/23
definitely [2] 12/13
101/1
definitive [1] 74/2
degree [12] 10/4
24/21 28/10 29/17
36/22 66/21 73/19
81/25 82/9 96/2 98/11
104/16
delay [1] 46/5
delivered [1] 1/21
delivery [1] 12/23
demands [1] 96/13
Demonstrate [1]
59/4
denials [3] 51/16
51/17 62/22
deny [1] 42/10
department [15] 6/10
7/12 17/19 17/20 19/9)
19/19 28/5 46/9 64/10)
75/22 77/18 78/4
80/10 89/14 90/5
Departmental [3]
16/5 45/12 49/14
departments [1] 23/8
dependent [1] 45/19
Deputy [2] 56/23
56/25
describe [4] 6/25
11/13 17/23 82/3
described [4] 14/13
42/11 54/23 72/9
description [2] 38/2
56/20
desire [1] 34/13
desk [1] 4/24
despite [2] 79/21
81/1
destabilisation [1]
36/16
destructive [1] 99/6
detail [8] 44/2 63/24
81/6 81/8 82/5 94/2
100/15 106/22
detailed [8] 4/21
51/15 51/22 60/11
(35) concerns... - detailed
D
detailed... [4] 62/22
67/23 69/9 114/19
details [1] 93/25
devastating [2] 91/18)
96/11
develop [3] 32/10
53/17 69/16
development [2]
110/22 113/10
developments [1]
91/15
dialogue [9] 9/18
53/6 53/18 54/20
54/22 70/19 70/20
70/21 112/12
dictated [2] 11/24
12/19
did [54] 9/22 10/1
10/8 12/9 14/17 17/25}
19/20 20/2 23/25
24/19 26/14 29/1 29/6
29/10 31/12 34/10
35/16 35/21 36/9
47/25 49/10 50/20
63/7 68/11 68/11
68/23 68/24 69/5
74/11 75/4 75/5 76/8
76/9 78/1 78/5 78/14
82/17 88/25 95/14
95/21 100/12 100/13
100/18 101/6 104/5
104/13 106/5 111/9
112/24 113/19 113/19
114/14 114/14 114/15}
didn't [27] 10/7 20/2
27/7 29/9 32/23 34/3
36/1 47/9 62/25 63/8
63/9 69/2 69/3 70/15
70/16 72/20 88/12
95/5 95/24 101/5
101/7 102/15 104/11
105/11 112/20 113/5
116/4
difference [1] 84/12
different [11] 24/21
27/12 27/18 27/25
32/9 81/11 84/16 93/6
93/10 98/21 111/19
differing [2] 25/13
25/15
difficult [24] 2/12
19/17 31/24 35/19
42/17 42/21 43/4
46/16 65/21 71/7
72/15 73/23 76/9 85/3
96/5 96/15 107/14
109/13 111/8 111/17
114/2 114/6 115/17
1417/9
difficulties [1] 31/4
digested [1] 102/14
diligence [2] 111/15
113/11
direct [4] 2/5 13/17
95/25 96/9
direction [1] 24/14
directly [7] 3/20 13/6
13/24 13/25 45/8 90/5)
116/10
director [17] 6/14
29/20 33/19 33/23
34/1 37/2 40/23 40/25)
43/19 44/13 56/19
56/22 56/22 56/25
79/17 83/22 98/6
director’ [1] 80/23
directors [16] 9/19
27/15 28/23 30/2 41/6
43/24 44/8 56/23
77/23 97/20 97/23
98/4 98/10 105/8
105/13 105/15
directors/heads [1]
43/24
Directs [1] 98/25
disagree [1] 22/1
disagrees [3] 21/2
21/13 21/22
disaster [2] 89/18
99/16
discerning [1] 97/16
discharge [2] 14/6
25/24
discharged [1] 18/20
discourse [1] 112/3
discuss [3] 20/22
23/5 57/8
discussed [6] 18/14
22/22 28/19 36/10
53/11 106/5
discussion [4] 82/16
86/25 86/25 87/7
discussions [6] 27/5
82/20 83/7 83/10
85/25 86/19
disparaging [1]
117/13
disputes [1] 103/13
disregard [1] 105/10
disrupted [1] 102/22
distance [1] 43/21
distilled [1] 102/12
distinct [1] 55/17
distinction [9] 15/6
17/4 48/19 48/25 49/6
70/3 70/9 97/17
105/12
distinctive [1] 17/25
distinguish [1] 14/15
distributed [1] 88/15
diverge [1] 87/4
do [74] 1/19 4/7 4/24
4/25 5/4 5/5 10/19
11/7 13/15 17/3 18/3
20/2 23/18 24/15 25/7
28/18 33/8 33/21
36/10 38/23 39/7
40/13 41/5 41/19
41/21 42/3 42/21
42/22 43/22 47/14
48/3 48/24 49/1 50/14
50/16 51/25 52/6
54/18 57/3 61/4 64/20
66/8 70/2 71/13 71/19
71/25 72/12 75/20
81/24 82/7 82/20
82/22 83/11 85/8
85/22 86/9 87/3 88/10
89/13 90/20 93/11
94/9 94/25 97/10
99/12 102/11 103/21
105/11 107/3 109/7
111/10 117/5 117/7
118/1
document [18] 5/2
30/8 32/16 33/14 42/6
44/15 52/18 52/23
55/14 60/11 61/11
61/12 61/25 62/19
62/25 64/16 69/17
106/1
documentary [1]
47/119
documentation [2]
51/14 116/4
documents [6] 24/6
32/16 51/12 85/4
88/18 88/21
does [13] 1/15 1/17
14/15 39/12 39/19
42/20 51/14 58/20
70/13 70/14 71/9 86/3,
111/2
doesn't [5] 22/3 36/8
88/7 94/21 95/7
doing [4] 12/11 94/19
98/6 108/13
don't [52] 19/22
19/23 24/4 32/24
34/19 36/12 37/15
37/17 44/2 47/1 51/10}
60/12 62/24 65/4
68/10 68/13 68/23
72/16 72/17 73/15
73/15 79/14 83/1
85/11 86/1 86/5 87/8
87/10 88/22 89/11
93/25 94/23 96/13
98/18 99/10 102/3
102/4 102/13 103/20
104/20 105/25 110/16
110/24 111/2 111/3
111/9 111/16 116/6
117/2 117/10 117/12
117/13
done [14] 11/4 20/1
31/20 35/4 36/2 52/3
72/7 93/9 107/24
111/15 116/2 116/3
117/21 118/3
door [1] 88/4
doubt [5] 3/17 83/7
89/21 109/11 109/15
down [20] 7/24 19/6
28/4 33/14 40/4 40/12
41/11 44/15 45/10
45/21 55/14 59/18
60/14 60/17 64/16
69/17 74/5 75/17
82/14 96/10
draft [1] 110/18
drafting [1] 107/12
drains [1] 115/16
draw [3] 70/3 70/9
115/19
drawing [2] 48/19
49/6
drawn [3] 90/21
97/17 103/24
dreadful [2] 89/24
111/13
drive [4] 79/6 79/7
91/1 91/25
drove [1] 93/12
dual [1] 81/15
dual-hatted [1] 81/15
due [10] 5/15 30/21
34/8 35/8 83/2 96/12
111/14 113/11 113/15)
113/20
Dunks [1] 118/12
duplicative [1] 28/1
during [8] 50/8 50/15
53/22 61/20 101/5
102/19 104/14 110/22,
duties [4] 76/2 97/21
97/21 98/10
dynamic [1] 29/6
dynamics [1] 41/19
E
e-substitution [1]
74/25
each [6] 3/25 32/2
53/17 65/12 82/1
86/14
earlier [12] 30/3 30/5
42/11 42/20 56/10
62/20 65/19 72/7
80/12 95/1 110/8
114/13
early [5] 6/5 19/8
35/7 58/11 65/20
easier [3] 22/24
83/12 96/7
easy [1] 28/8
Ed [2] 80/4 80/5
Edward [5] 50/24
56/11 61/10 67/15
80/25
effective [10] 8/22
8/25 9/4 15/15 15/19
64/21 84/23 84/24
91/4 91/7
effectively [7] 18/9
19/12 26/22 27/21
59/2 86/11 105/16
effectiveness [5]
9/24 20/19 20/23
45/18 94/3
effects [2] 91/19
96/11
efficiencies [4] 23/16
23/23 24/1 24/19
either [3] 49/22 55/7
69/22
element [3] 12/1
59/23 81/14
elements [2] 11/24
30/18
elided [1] 27/18
else [5] 35/22 44/14
47/16 52/3 95/17
else's [1] 111/6
email [2] 3/20 111/20
emails [1] 51/12
Emma [1] 4/18
emphasis [4] 23/15
23/23 24/1 24/19
Emphasise [1] 58/16
employed [2] 12/22
90/22
employee [1] 32/12
employees [5] 12/22
16/12 17/3 48/7 97/22)
enable [2] 3/8 78/21
enabled [1] 82/1
enabling [1] 100/13
enacted [1] 100/14
encountered [1]
78/18
end [14] 7/9 16/24
22/11 29/18 44/16
49/4 64/24 90/7 90/14)
91/22 96/24 100/3
113/16 113/19
endemic [5] 51/1
57/9 61/13 62/3 73/5
endorse [1] 36/4
endorsement [1]
117/6
endured [1] 4/5
Energy [2] 7/12
117/25
enforce [1] 91/9
enforced [1] 94/10
enforcement [2]
49/25 94/11
engaged [1] 117/14
engagement [1]
78/24
engaging [2] 54/21
55/2
engrained [1] 35/18
enhanced [1] 25/16
enormous [3] 74/23
78/10 99/8
enough [3] 34/20
(36) detailed... - enough
E
enough... [2] 73/12
113/18
enquiring [1] 1/14
ensure [13] 8/21 8/24I
9/3 9/10 23/6 23/11
26/20 31/20 41/20
44/12 87/18 94/24
96/14
ensuring [4] 9/23
9/24 53/13 75/3
enterprises [1]
101/16
entirely [4] 6/10 36/5
96/1 102/9
entities [1] 86/15
entitled [9] 1/19
24/13 25/22 60/8
66/19 67/23 67/24
102/21 114/22
entry [1] 61/19
environment [1]
32/15
equitable [1] 96/20
errors [4] 46/1 54/17
55/16 71/19
escalate [2] 20/25
63/20
escalated [5] 61/19
63/16 63/20 91/13
106/13
escalation [2] 63/7
63/15
especially [1] 27/8
essentially [1] 1/13
establish [3] 7/3
58/11 58/22
established [2] 40/8
89/20
establishing [1]
14/20
establishment [1]
59/14
ethics [2] 78/20
79/11
even [5] 12/9 35/20
37/9 71/8 107/2
events [2] 48/11
75/11
ever [8] 17/8 23/25
24/4 35/22 78/1 78/14,
79/12 92/18
every [3] 15/25 17/7
69/11
everybody [2] 32/2
104/7
everyone [1] 114/10
evidence [31] 1/6 1/7
3/15 4/8 5/14 13/15
24/23 31/25 36/3
45/24 47/19 48/16
49/11 49/17 49/19
53/21 55/9 65/19 71/6
71/9 75/7 78/19 91/18
92/20 95/2 103/16
104/7 104/14 108/1
109/9 118/10
evolve [1] 26/25
evolved [2] 26/24
93/8
evolves [1] 92/3
Evolving [1] 91/4
exact [2] 12/17 62/18
exactly [6] 65/13
68/13 89/2 89/10
100/2 111/1
example [7] 10/10
22/8 33/17 64/3 95/1
103/25 111/22
examples [3] 31/14
53/24 54/15
except [1] 96/15
Exchange [1] 78/9
execs [2] 38/24 39/8
executive [115] 6/5
6/6 6/20 6/21 7/8 7/9
10/21 12/16 16/3
16/23 17/24 18/12
18/18 18/23 19/2
19/13 19/18 19/21
20/5 21/24 24/24
25/23 26/6 26/15
26/21 27/3 27/14
27/22 28/7 28/8 28/9
28/23 28/24 28/25
29/3 29/20 30/2 31/7
33/19 33/23 33/25
34/3 34/22 37/2 37/2
38/13 41/6 42/2 42/23
43/16 43/23 44/4 44/6
44/8 44/12 47/3 47/9
49/14 51/5 51/22 55/2
55/11 56/4 61/21
63/11 64/3 64/7 65/4
65/20 67/1 69/6 69/7
69/25 70/22 75/18
79/6 79/17 81/16
82/21 83/16 83/22
85/11 85/12 87/23
89/4 89/6 89/7 89/20
90/7 91/11 92/23 93/5
97/18 97/19 97/19
97/24 98/3 98/6 98/10)
98/22 98/24 98/25
101/6 104/6 105/13
105/15 106/3 112/20
114/14 115/9 116/8
116/11 116/20 116/22)
117/20
Executive's [6] 8/14
8/18 27/5 52/5 62/9
62/16
executives [15] 11/9
12/2 14/24 15/1 26/12
27/1 36/6 36/24 43/1
43/2 55/3 55/5 55/6
81/22 93/19
exercise [1] 44/5
exhaustive [2] 78/9
78/12
exist [4] 18/1 29/9
88/12 100/18
existence [1] 35/7
existing [3] 76/1 91/8
94/8
exists [1] 108/19
expect [7] 25/22
27/14 41/21 42/3
63/13 66/19 115/6
expectations [1]
65/15
expected [22] 12/5
13/19 14/6 16/7 30/17I
47/22 48/10 63/14
66/17 69/9 69/25 70/9
70/11 70/19 84/2 84/4
84/5 98/3 114/21
116/8 116/9 116/12
expecting [1] 69/4
expects [2] 52/24
53/2
expedition [1] 90/1
expensive [3] 60/1
112/7 115/10
experience [8] 2/6
6/9 12/3 16/24 31/6
93/20 108/13 117/20
experienced [2]
27/14 40/9
experiences [2] 1/20
2/25
experiment [1] 108/5
expert [2] 54/3 66/17
expertise [7] 18/2
109/7 112/21 113/6
115/4 115/6 115/8
explain [8] 5/22 8/18
26/7 64/18 80/24 86/5
87/19 91/22
explained [1] 60/21
explaining [1] 70/6
explicit [1] 70/10
exploded [1] 108/9
explore [2] 35/22
101/24
explored [1] 5/21
exploring [1] 70/8
exposed [1] 81/11
extension [3] 6/15
74/17 101/1
extent [4] 9/9 34/15
51/8 108/5
external [3] 46/25
59/8 103/12
external/review [1]
59/8
extraordinary [1]
104/21
extreme [1] 39/14
extremely [7] 7/1
32/4 35/19 50/10 76/8
78/9 78/12
eye [2] 97/16 102/10
eyes [2] 25/2 115/25
F
face [7] 2/13 42/18
62/21 70/4 70/5
112/25 113/2
faced [1] 2/13
faces [1] 103/7
facetious [1] 102/1
facing [1] 112/15
fact [21] 13/16 15/5
26/16 30/22 35/1
47/24 55/8 65/1 65/5
67/6 67/25 68/12
73/19 78/5 85/13 86/8)
94/21 95/19 101/12
104/1 110/7
facto [1] 33/1
factor [3] 68/2 68/3
90/19
factors [1] 106/25
facts [2] 49/23 66/3
failings [1] 54/24
failure [6] 45/25
46/12 54/15 91/21
112/13 114/5
failures [5] 90/17
92/12 96/11 103/8
105/1
fair [6] 1/22 12/20
33/11 74/19 110/13
113/14
fairly [1] 107/17
faith [1] 70/17
Falkirk [1] 54/1
false [3] 51/3 57/13
58/4
familiarisation [1]
82/1
far [6] 19/20 23/9
30/16 53/21 68/22
108/2
fashion [1] 82/11
fast [1] 113/18
faults [3] 58/3 61/14
62/4
faulty [1] 114/7
FD [1] 40/23
fear [2] 3/1 62/19
February [3] 7/11
103/7 111/20
February 2011 [1]
103/7
February 2015 [1]
111/20
fed [3] 90/4 90/11
1415/5
Federation [4] 66/11
66/24 67/2 67/25
feel [3] 23/25 28/16
81/9
feeling [3] 78/5 83/15
83/18
fell [2] 10/20 101/17
Fellow [1] 8/9
felt [9] 19/16 24/4
27/6 43/17 48/14
83/19 84/25 95/2
106/23
few [4] 37/6 67/22
81/7 105/20
fictitious [1] 99/23
fiduciary [1] 97/20
figures [1] 80/10
final [5] 1/7 1/12
104/24 104/25 115/2
finalised [1] 33/21
finally [2] 90/13
117/13
finance [4] 31/8
40/23 40/25 43/19
finances [1] 76/4
financial [11] 11/21
11/25 12/10 40/10
53/8 74/9 74/16 92/7
95/24 108/15 108/19
find [11] 16/18 72/15
73/23 85/8 85/22 86/5
86/18 96/15 111/8
111/17 117/2
finding [2] 38/7 68/20
findings [1] 2/17
fine [5] 76/22 99/15
4117/1 117/17 117/19
finished [1] 75/18
firing [1] 95/8
firm [2] 1/25 116/10
firms [2] 115/13
115/15
first [29] 6/17 9/5
20/17 31/10 38/13
38/19 38/22 46/1
50/19 52/25 53/25
57/5 57/16 62/3 66/23
72/10 77/17 80/8
80/15 82/4 83/16
83/24 90/3 92/9 94/12
94/20 105/13 116/18
116/20
fit [4] 18/10 91/1
93/12 105/11
five [4] 56/18 56/25,
72/3 82/14
flawed [1] 90/25
flaws [4] 51/1 57/9
61/13 62/3
flotation [5] 106/4
106/7 106/21 107/15
108/6
flow [4] 45/19 46/14
65/6 65/10
flowed [1] 75/15
flows [1] 64/21
focus [5] 9/14 29/8
100/2 100/7 101/12
focused [3] 74/9
(37) enough... - focused
F
focused... [2] 74/20
75/4
Focusing [1] 31/10
follow [2] 36/4 69/18
followed [2] 46/4
57/20
following [4] 20/15
60/23 82/16 118/18
follows [1] 109/17
font [1] 59/18
foot [2] 84/14 84/14
force [1] 94/23
forceful [4] 51/15
62/22 67/23 114/18
foremost [1] 74/16
forgive [4] 34/9 80/2
99/14 101/25
form [4] 22/8 95/3
95/20 102/25
formal [3] 3/15 81/17
88/14
formality [1] 43/10
formerly [1] 28/11
formula [1] 39/2
formulation [1] 22/3
forward [1] 61/5
found [4] 21/20 49/4
61/2 61/3
founded [1] 69/9
four [1] 28/3
Fourth [1] 54/12
framework [2] 69/7
93/11
frank [2] 69/9 70/11
frankly [1] 83/17
fraught [6] 32/15
32/18 50/23 110/13
110/15 110/16
freedoms [1] 11/8
frequency [1] 67/19
frequent [1] 39/10
frequest [1] 39/4
friction [1] 40/9
friend [1] 60/10
front [2] 4/24 102/18
Fujitsu [4] 50/22
54/12 110/10 110/12
fulfil [1] 20/24
fulfilled [2] 9/21
32/20
full [12] 1/22 2/12
4/15 25/22 26/16 42/3
47/1 51/18 69/5 69/9
70/11 96/17
fullest [1] 98/10
fully [9] 89/11 89/18
89/22 89/23 91/11
91/24 92/1 93/7 98/5
function [12] 13/18
17/19 17/21 18/4 18/5)
18/7 23/12 23/13
25/12 31/8 61/23
84/21
functions [4] 18/10
25/24 27/21 65/7
fund [3] 32/8 74/23
76/3
fundamentally [1]
85/16
further [12] 19/6 23/5)
40/16 45/16 45/21
51/21 60/17 66/5 71/8)
109/23 116/14 118/5
future [3] 41/20
44/12 80/16
fuzzy [1] 17/6
G
game [1] 31/21
gaming [3] 30/20
31/11 31/12
gaps [1] 69/20
gathering [1] 1/7
gave [5] 15/24 18/8
19/16 34/1 116/19
general [10] 16/22
17/18 17/23 26/11
42/11 51/4 68/24
88/24 112/12 113/7
Generally [1] 31/17
genuine [1] 102/2
genuinely [4] 85/2
85/5 108/15 110/24
get [17] 18/22 21/10
28/18 31/16 65/21
70/14 70/15 70/16
78/1 78/5 78/14 84/13
103/17 109/21 115/16)
115/24 118/2
gets [2] 43/19 92/19
getting [7] 22/15 26/5)
27/16 39/23 95/8 98/9)
100/6
Gillingwater [1] 6/7
give [7] 20/18 24/1
31/14 52/21 74/1
76/16 118/9
given [18] 3/12 6/9
6/25 16/12 23/12 25/8
27/6 34/10 36/18
37/13 37/20 61/10
64/23 68/16 72/11
89/3 96/3 113/13
glad [1] 110/5
go [19] 10/16 11/12
26/25 29/19 30/7 38/5)
45/21 47/15 56/4
69/11 84/12 91/3 94/4
102/13 108/3 109/8
112/18 114/15 115/15)
goals [2] 14/20 53/9
goes [4] 44/11 67/20
81/14 114/24
going [33] 9/20 18/18)
18/20 22/8 25/11
30/10 37/4 37/19 48/6)
48/9 52/23 63/4 72/16
74/25 76/15 83/20
84/11 85/13 86/21
86/22 86/23 92/18
97/25 98/22 98/23
100/15 104/3 105/22
108/20 109/21 109/23
111/23 113/4
gone [5] 52/8 73/20
84/15 84/18 113/3
good [10] 1/4 10/10
22/7 32/3 45/2 45/3
70/17 77/14 89/5 96/2
got [5] 43/14 83/25
84/1 114/18 116/5
govern [2] 53/2 65/10)
governance [27]
9/11 16/1 20/13 25/20
26/23 27/10 78/25
90/18 90/22 91/1 91/6
91/8 91/20 91/25 92/3
92/7 93/8 93/11 93/16
93/18 94/9 96/11
96/13 96/17 96/22
105/1 105/4
government [81]
1/21 8/4 8/22 9/4 9/22)
9/25 10/2 10/6 10/8
10/12 10/13 10/18
11/6 11/20 11/23 12/7
12/18 12/19 13/7
13/13 13/14 14/12
14/16 14/19 15/13
15/14 15/19 16/5
17/25 19/8 20/25
22/21 23/8 24/12
24/12 26/8 28/13
29/19 30/22 34/13
35/2 35/6 35/9 35/19
36/8 52/24 53/1 53/2
53/3 53/6 53/13 58/1
58/2 58/19 80/18
80/19 82/10 82/25
86/10 86/12 86/23
87/14 91/4 95/12
95/15 95/21 96/9
97/12 97/16 98/16
102/11 105/7 105/9
105/14 105/17 111/12]
111/23 112/2 112/11
113/13 114/11
Government's [13]
6/24 9/2 9/20 14/8
23/15 23/23 24/1
24/19 32/13 33/3 35/8
86/10 86/16
government-owned
[1] 9/22
Governor [1] 8/7
gradually [1] 41/3
graduation [1] 5/22
grateful [1] 118/10
gravity [1] 46/17
great [3] 41/1 44/2
92/7
greater [9] 22/21
24/2 28/20 29/2 29/11
82/1 90/1 97/25
104/16
Grenfell [1] 6/3
grip [4] 95/18
gripping [1] 105/8
ground [1] 90/18
grounds [1] 57/17
group [51] 1/18 6/14
6/18 6/25 7/6 8/15
13/11 14/5 16/6 20/24}
28/21 29/7 32/10 33/9)
34/17 35/17 35/23
35/25 36/11 36/18
37/13 38/10 43/1 43/2,
47/24 49/7 49/12
50/10 64/19 74/8
74/12 74/17 75/3
75/13 75/20 76/11
77/20 77/24 78/2
95/21 96/1 100/4
100/8 101/14 102/25
104/18 107/5 108/21
108/22 108/23 110/21
Group's [4] 14/1
33/16 35/24 36/20
guard [1] 23/8
guess [2] 73/18
96/24
guessing [1] 43/13
guidance [3] 69/7
85/1 97/11
guilty [3] 49/4 61/2
61/4
H
had [129]
hadn't [2] 92/11
108/10
halfway [1] 59/18
hand [1] 32/11
handbook [2] 52/16
69/6
handles [1] 86/3
hands [4] 28/12 79/1
79/2 102/13
hands-off [1] 28/12
hang [2] 88/3 115/22
happen [8] 10/2
37/14 87/11 92/14
94/15 94/16 94/22
113/19
happened [8] 12/15
18/5 71/18 81/2 99/12,
113/16 113/18 115/21
happening [4] 76/23
86/13 92/15 94/21
happens [1] 116/7
happy [1] 65/24
hard [2] 4/23 32/19
hardship [1] 4/4
has [30] 1/21 2/10
2/21 3/10 24/23 26/3
30/16 30/19 30/20
30/22 30/24 31/3 31/7I
40/20 41/24 49/11
53/21 57/15 58/3 58/4
58/19 78/19 81/23
91/18 93/8 103/5
104/7 104/14 111/12
111/15
hatted [1] 81/15
have [325]
haven't [2] 46/20
49/17
having [10] 31/18
32/5 33/9 33/25 43/11
57/11 79/16 81/4
83/21 102/7
he [20] 40/21 42/25
52/6 56/17 66/4 66/10
66/15 66/16 66/16
67/23 67/24 68/4
68/11 68/11 68/14
76/1 76/2 76/4 77/9
85/13
he's [1] 68/16
head [1] 116/25
headed [3] 56/19
56/21 56/25
heading [4] 20/11
38/12 57/6 60/21
headings [1] 60/20
heads [2] 41/6 43/24
hear [6] 1/4 2/4 59/4
76/12 76/18 77/9
heard [7] 24/23 63/25]
78/19 91/18 102/6
104/14 108/1
hearing [2] 1/5
118/18
hearings [1] 60/9
heart [1] 4/2
heartfelt [1] 4/6
heavily [3] 58/1 74/8
74/20
held [7] 5/20 8/4
10/12 17/12 17/13
19/2 25/1
Hello [3] 77/4 77/7
7718
help [8] 1/23 3/17
14/15 16/11 20/24
43/22 49/16 51/4
helped [1] 7/3
helpful [3] 83/1 86/6
97/11
helping [1] 16/24
Henry [4] 97/5 97/9
116/19 119/9
her [3] 26/7 33/24
88/5
here [29] 1/13 21/12
21/19 23/4 23/11
25/25 30/15 33/12
33/13 37/8 38/22
(38) focused... - here
H
44/12 46/10 46/18
92/20 94/6 98/20
99/15 100/1 105/5
Hewitt [1] 95/2
high [4] 28/10 39/23
71/25 107/16
higher [1] 60/3
highest [2] 91/7 94/8
him [4] 52/6 66/10
68/12 88/5
hindsight [2] 22/3
45/23
his [10] 20/14 42/25
66/4 66/18 68/17
114/15
historic [3] 3/5 99/2
107/9
historical [2] 10/12
73/17
history [5] 75/13
110/9 113/9 113/9
114/3
hived [2] 107/8
107/10
HJA [1] 97/5
HMG [1] 8/24
HMG-owned [1] 8/24
hoc [2] 39/4 39/10
Hodgkinson [1]
104/15
hold [2] 10/9 26/10
Holdings [1] 30/13
holds [1] 21/15
honest [12] 36/12
37/10 48/18 53/5
54/20 69/4 69/9 70/12
73/15 91/2 92/1 93/13,
honestly [3] 64/24
64/25 91/12
Hooper [4] 7/4 75/14
75/25 100/14
hope [7] 70/22 89/25
105/20 114/13 115/12)
115/18 117/9
hoped [1] 85/19
hopefully [1] 93/9
hopelessly [1]
111/11
Horizon [52] 2/3 2/18
3/24 46/2 46/3 47/13
50/4 50/8 50/18 51/1
51/7 54/6 54/10 54/17,
55/16 57/10 58/2 59/8)
59/12 60/1 60/16 61/4
61/8 61/14 61/15
61/18 61/23 62/4 62/6
66/14 66/16 66/20
70/25 71/20 72/22
here... [18] 42/24
49/1 50/7 54/20 60/14
63/8 66/7 79/19 90/16
44/5 57/8 57/16 57/19
99/23 101/21 103/4
103/15 103/16 106/6
113/5 114/2 114/11
114/20
horrified [1] 105/19
host [4] 111/14
house [3] 112/21
115/10 115/18
how [20] 1/15 1/17
1/19 2/9 3/13 13/5
26/14 27/12 28/10
32/9 44/10 49/13 51/4
63/13 63/19 73/16
86/2 88/21 94/9 116/1
however [7] 11/24
35/5 39/24 47/1 80/7
94/4 106/16
Hudgells [1] 110/3
huge [1] 74/24
human [2] 4/1 91/20
hundreds [4] 61/14
72/24 99/7 99/21
laccept [1] 62/24
Tact [1] 110/2
lam [14] 2/20 23/21
43/12 49/1 49/9 63/16
64/11 104/25 111/16
117/1 118/10
l anomalous [1] 35/3
I became [1] 99/12
Ican [10] 1/5 43/22
48/7 52/2 63/19 73/25
76/18 77/5 77/10
117/1
I can't [10] 31/23
43/20 52/14 62/17
73/24 74/1 76/14
76/18 89/2 116/25
I certainly [1] 49/9
I could [1] 86/24
I described [1] 42/11
I did [3] 29/6 49/10
78/5
I didn't [3] 63/8 63/9
102/15
I discuss [1] 23/5
Ido [10] 4/25 5/5
25/7 49/1 50/14 66/8
71/25 82/20 90/20
107/3
I don't [37] 19/22
19/23 24/4 32/24
34/19 36/12 37/15
37/17 44/2 47/1 51/10)
60/12 65/4 68/10
68/13 68/23 72/16
72/117 73/15 73/15
79/14 83/1 85/11 86/1
88/22 89/11 93/25
98/18 99/10 102/4
73/4 73/9 78/17 90/20
110/10 111/22 112/24)
105/25 110/16 111/2
111/9 111/16 116/6
117/12
I fear [1] 62/19
Ifind [5] 72/15 73/23
96/15 111/8 111/17
I genuinely [1]
110/24
I give [1] 31/14
I got [1] 83/25
I guess [1] 96/24
I had [3] 77/16 84/10
107/13
I happened [1] 99/12
Ihave [22] 1/6 1/23
3/17 4/3 4/3 29/16
44/16 45/24 55/8
92/21 97/1 102/5
102/6 102/18 103/19
106/14 107/24 114/13
I haven't [1] 49/17
I hope [4] 70/22
89/25 114/13 117/9
Ijust [2] 101/24
110/10
I knew [1] 50/13
I know [4] 2/12 68/22
90/9 107/25
I may [4] 85/6 102/3
106/10 109/3
I mean [39] 14/23
17/6 18/13 21/19
21/19 22/5 22/16 24/5
24/17 31/22 31/25
32/21 32/21 37/5 43/8
48/7 48/12 63/5 65/12
65/18 67/21 68/12
70/1 75/12 75/24 87/8
90/6 92/20 95/1 96/24
99/17 99/25 103/25
104/12 105/2 105/6
106/16 108/10 112/9
I mentioned [1]
74/22
I might [1] 37/16
I misunderstood [1]
49/9
I never [1] 78/18
I note [1] 83/1
l offer [1] 4/6
l only [1] 110/6
I possibly [1] 87/2
I probably [2] 62/20
72/4
I propose [1] 1/8
rather [1] 83/7
l referred [1] 56/10
I remain [1] 87/13
I remember [3] 42/22
49/19 50/16
I said [5] 25/10 42/20
62/20 96/16 110/14
Isat [1] 86/9
55/20 76/14 80/4 84/4
31/25 32/15 37/8
46/21 87/12 93/3
95/22 114/17
I see [3] 56/25 68/6
102/17
I sent [1] 37/7
I should [7] 12/17
13/21 21/19 22/24
33/12 62/12 82/2
I speculate [1] 63/8
I started [1] 98/9
I stress [1] 109/8
I summarise [1]
13/15
I suspect [3] 94/6
107/1 110/15
I take [3] 85/20 117/5
118/5
I think [98] 22/3
22/12 22/19 24/18
25/14 29/15 32/15
32/22 33/11 33/24
34/1 36/23 37/5 37/8
37/8 38/3 42/10 42/19)
42/24 43/19 44/11
44/11 46/16 46/16
49/18 49/22 51/13
52/20 55/11 55/24
62/8 62/13 63/4 63/5
64/24 64/25 65/6
65/18 67/12 67/13
67/24 70/7 71/6 71/7
71/9 71/17 72/3 74/19)
77/12 80/13 81/7 83/3
83/11 83/12 83/14
83/18 83/23 88/23
88/25 89/17 89/22
90/6 92/20 92/25 93/2,
93/8 93/23 94/23 96/2,
96/6 96/7 97/4 97/6
97/17 98/6 98/11
101/6 105/18 106/10
106/10 106/13 107/12)
107/14 108/7 108/8
108/13 109/16 110/11
110/14 112/18 113/1
113/14 113/14 113/17]
113/20 113/24 115/17,
115/24
I thought [4] 35/3
48/17 85/2 99/14
I understand [1]
82/16
I understood [1]
50/11
lurge [2] 3/10 4/5
lused [1] 70/1
I very [1] 63/16
I want [3] 2/4 3/3
101/12
Iwas [15] 12/16 22/5
28/8 29/6 29/9 47/20
50/9 51/9 82/21 83/20
Isay [10] 22/12 27/22]
86/10 86/16 89/21
99/11 107/12
I wasn't [6] 34/19
48/17 50/3 51/11
62/18 67/5
I will [6] 1/14 4/18
5/15 86/3 86/4 109/8
I wonder [2] 37/18
4417
I would [37] 13/9
25/4 36/7 43/8 45/7
47/22 48/10 51/13
52/1 52/7 52/9 54/25
62/21 69/24 70/9
70/19 73/18 84/4 84/9
84/14 84/17 84/22
85/19 86/23 87/1 98/3}
105/18 105/20 106/16)
112/18 114/21 115/8
115/11 115/18 116/7
116/9 116/12
I wouldn't [4] 19/23
31/25 42/9 84/25
I'd [11] 5/19 8/14
17/11 25/19 51/8
52/11 52/14 57/4
79/15 84/24 85/5
lll [2] 64/13 76/22
I'm [37] 16/15 19/22
20/3 26/1 31/25 33/12
34/19 36/5 36/21 38/2
39/3 48/19 60/12
63/17 67/11 68/6
68/14 74/2 76/20 78/7I
89/11 93/24 94/2 97/3
101/25 103/19 103/22)
105/23 105/23 107/17)
109/23 111/2 111/17
111/23 113/6 115/23
116/25
I've [8] 17/8 25/9 52/8)
64/23 81/22 102/5
108/1 109/2
idea [4] 10/22 37/8
76/20 108/23
ideal [3] 19/25 30/17
31/3
ideally [2] 43/4 53/9
identical [1] 60/6
identification [3]
17/10 45/5 64/1
identified [9] 2/17
15/25 46/21 46/24
55/17 55/22 56/6 62/3I
91/12
identify [4] 45/25
46/12 46/17 54/16
identity [1] 11/16
ie [1] 82/24
ie the [1] 82/24
if [89] 3/22 5/1 10/1
10/5 11/22 12/9 16/11
17/20 20/8 22/17
22/17 23/19 24/14
(39) here... - if
if... [76] 25/16 26/5
27/4 27/6 36/2 37/18
37/19 38/5 38/6 38/25
39/2 39/2 42/17 42/19
42/22 43/22 44/17
46/18 49/2 52/9 56/14)
58/12 58/25 60/2
61/23 62/13 65/17
66/15 69/3 69/10
69/22 70/15 72/2 73/2
73/3 76/16 76/24
78/21 81/2 81/12
83/12 84/10 84/17
84/23 84/24 85/2 85/5
85/14 86/3 86/5 89/23
91/23 93/8 94/17
94/21 97/22 97/23
99/20 106/10 106/16
106/17 106/23 107/2
107/20 108/3 109/7
109/8 109/9 111/3
111/9 111/10 111/13
112/12 113/7 115/8
115/13
ignorance [2] 102/2
104/17
imagine [4] 43/8
51/13 73/25 117/10
immediate [2] 81/17
101/15
immediately [1] 62/2
imminent [1] 58/12
imminent/planned [1]
58/12
impact [2] 80/20
99/18
impacted [1] 103/18
imperative [1] 22/18
imperatives [2]
22/16 22/16
implementation [2]
91/7 96/17
implemented [4]
41/13 91/2 91/24 92/2)
implementing [2]
93/7 94/8
implication [3] 46/10
48/20 71/1
implications [2]
20/19 99/16
importance [3] 39/16
78/15 88/7
important [21] 10/5
11/21 15/23 46/22
53/23 64/6 75/23
75/23 77/20 81/3 81/6
81/20 82/4 82/6 82/8
82/12 82/24 87/2
90/11 95/3 118/1
impose [1] 80/25
impossible [2] 89/17 i
89/22
improve [2] 44/5
81/21
improved [2] 41/2
93/22
improvement [3]
39/15 42/10 42/15
improvements [3]
42/17 43/3 92/5
improving [1] 40/21
inability [1] 82/22
inadequacies [1]
96/12
inadequate [1] 46/13
inadvertence [1]
102/17
incidence [1] 60/4
inclined [1] 31/21
include [4] 14/12
53/4 59/10 82/2
included [1] 16/8
includes [1] 39/20
including [9] 8/5
11/25 28/20 41/6
43/23 71/21 74/10
110/23 114/10
inclusiveness [1]
11/21
incomplete [1]
106/12
incompletely [1]
69/24
inconsistent [2]
39/22 80/15
incorrect [1] 108/3
incorrectly [1] 72/12
increasing [3] 70/24
71/4 114/4
increasingly [2] 71/9
71/11
indeed [17] 14/5
16/11 18/19 32/5
33/14 43/18 49/18
51/20 63/10 64/11
68/21 69/13 75/12
107/16 113/7 114/25
4117/7
independence [6]
33/16 34/13 35/18
44/7 82/19 85/24
independent [14]
59/11 59/25 71/14
93/17 93/19 97/18
97/19 115/13 115/15
115/25
independently [1]
115/24
indicate [2] 54/24
80/5
indicated [2] 80/10
80/21
individual [2] 2/16
1/24 41/21 44/13 59/7)ii
48/3
individuals [8] 48/2
57/1 58/6 62/6 96/12
96/14 105/21 114/25
induction [1] 16/17
indulged [1] 30/20
indulging [1] 31/11
industrial [3] 8/2
74/24 75/1
industry [3] 99/13
103/22 103/22
inefficient [1] 10/25
inevitably [3] 22/8
81/10 97/25
inexpert [1] 35/12
infer [1] 67/11
inference [2] 90/21
93/23
influence [3] 79/3
79/3 79/8
influenced [1] 78/1
inform [1] 83/9
informal [1] 88/14
information [59] 2/8
3/7 3/9 3/12 15/1
15/20 17/9 25/19
25/22 26/5 26/16
27/11 27/13 27/16
27/17 27/25 29/4
29/13 31/1 31/15 33/7
33/10 34/16 34/20
43/7 43/10 43/14 45/4
45/15 45/20 46/14
63/25 64/21 65/4 65/6
65/10 65/16 65/18
65/21 66/9 68/7 68/25)
69/19 69/21 69/22
73/11 78/3 81/11
82/24 87/18 88/15
89/7 90/10 93/4 98/22
113/12 115/1 115/5
116/3
informative [2] 38/23
39/7
informed [5] 45/16
53/14 84/20 87/20
111/5
inherited [1] 19/11
inhibited [2] 64/20
65/6
itial [2] 35/15 46/4
ly [2] 6/9 41/3
jate [1] 58/23
initiatives [1] 41/1
injustice [1] 99/20
innocent [1] 114/8
innovation [2] 35/12
75/22
inquiries [1] 113/22
inquiry [22] 1/8 1/12
3/9 3/12 3/15 4/2 4/19
4/20 5/21 24/23 49/11
51/25 53/21 78/19
90/14 91/18 104/14
105/3 108/20 111/20
113/20 118/10
Inquiry's [3] 3/4 5/14
104/24
insolvency [1] 31/2
instance [8] 18/17
22/17 24/6 24/9 32/25)
42/19 92/9 95/1
instances [3] 14/25
48/6 60/5
instead [1] 17/22
institutional [1]
28/15
insufficient [1] 43/7
insulation [1] 80/19
integral [2] 12/23
45/5
integrity [11] 50/17
51/7 59/12 59/25 60/2
60/15 70/25 72/22
73/3 101/20 114/20
intelligent [2] 8/22
9/4
intend [1] 60/12
interest [7] 11/11
82/19 85/10 86/20
87/8 98/1 105/11
interesting [1] 55/13
interests [3] 23/10
84/13 87/4
interference [1]
35/13
interjecting [1] 34/9
interlocutors [1]
97/14
internal [5] 27/20
46/24 61/24 92/25
94/3
internalised [1]
36/25
International [1] 8/10)
interpose [2] 27/9
27124
interrogate [2] 66/9
69/19
interrupt [1] 108/25
intervene [1] 52/6
intervening [1] 95/20
interviews [1] 41/13
into [22] 1/14 10/20
19/13 19/18 21/20
27/9 33/16 33/20
34/18 51/12 59/11
65/4 76/3 90/11 93/4
98/22 98/23 100/15
101/7 102/24 106/25
115/14
invaluable [1] 2/7
inverted [1] 109/6
invested [1] 95/10
investigate [1] 76/16
investigation [2]
59/11 103/15
investigations [1]
113/17
investigators [1]
108/14
investment [4] 6/2
8/12 32/6 99/11
inviting [1] 3/5
involve [1] 28/20
involved [13] 6/17
6/24 14/16 17/8 26/8
50/9 62/1 98/4 98/9
99/2 107/12 111/6
114/10
involvement [4] 21/3
29/2 29/12 109/5
involves [1] 117/15
IPO [3] 106/18 107/4
108/12
IPOs [1] 107/24
irregularities [1]
60/19
is [270]
isn't [3] 15/6 56/5
64/6
issue [7] 35/20 38/16
46/23 47/9 65/6 72/2
85/17
issues [30] 2/8 5/16
20/25 24/15 25/2
25/17 25/17 31/2
36/24 40/5 52/8 55/3
55/7 55/10 57/5 57/17
58/16 59/1 60/2 64/19I
66/25 67/21 71/22
72/8 72/9 72/12 91/13}
91/15 91/17 105/8
it [357]
it's [35] 21/25 26/2
30/5 30/7 38/6 42/9
46/16 46/22 47/15
50/6 55/5 64/25 66/7
67/12 67/13 71/7 72/1
72/5 74/4 78/12 79/19
83/1 83/3 84/11 85/3
87/3 89/17 89/22
92/18 98/24 108/19
109/12 110/18 117/19}
118/12
item [2] 57/21 57/25
items [1] 38/19
iterative [1] 23/1
its [30] 1/15 1/21
4/21 6/3 6/15 6/25 7/5)
11/16 13/23 13/23
14/6 20/24 21/5 21/20)
23/7 25/24 28/7 28/16I
32/7 34/23 35/3 45/16
52/24 58/21 88/20
91/10 91/11 91/12
94/19 111/9
itself [10] 15/8 20/23
26/14 30/25 33/6 68/5
74/21 89/4 95/12
116/22
(40) if... - January
J
JFSA [14] 47/5 57/7
57/22 58/4 58/8 58/16)
58/22 59/1 59/9 60/3
62/24 67/1 67/6 67/15
JFSA's [3] 57/8 59/4
59/20
job [6] 28/18 45/13
66/22 87/10 88/3
94/19
jobs [2] 94/19 118/3
joined [1] 6/5
joining [1] 80/15
joint [1] 54/3
judgement [1] 84/22
judgements [1]
43/18
judice [1] 59/2
judice' [1] 58/13
Julie [4] 54/4
July [2] 1/1 57/20
jump [1] 98/18
June [7] 5/1 6/20
30/6 30/9 45/12
100/10 103/12
June 2012 [1] 103/12
just [44] 5/16 7/20
14/21 18/7 23/18 25/9}
35/21 37/11 38/12
38/21 39/1 40/3 40/12
43/18 44/9 50/19 52/8
52/14 54/23 60/13
62/10 62/11 63/19
67/4 70/18 72/11
73/11 76/16 77/15
91/23 95/9 96/10 97/3
101/18 101/24 105/23
106/8 108/3 110/8
110/10 114/5 116/17
116/18 117/19
justified [1] 12/11
justify [1] 116/5
K
keep [6] 12/10 12/18
25/5 32/7 37/19 89/14,
keeping [1] 87/20
kept [1] 9/17
key [13] 2/8 13/7
15/16 15/20 25/2
26/12 31/7 53/1 59/19
59/23 75/24 82/23
89/14
kind [33] 9/16 18/11
24/14 24/21 26/5
27/16 27/17 29/6
29/21 31/18 36/25
46/23 48/16 52/4
65/21 69/15 70/2 72/2
73/1 79/5 85/20 88/6
88/12 92/17 95/25
98/1 112/10 112/19
112/21 113/5 115/5
116/5 116/13
kinds [9] 42/17 55/3
55/10 65/15 75/4 79/1
86/18 108/13 111/1
knew [4] 42/25 50/13
65/22 99/1
know [35] 2/12 4/18
9/19 16/9 27/15 34/19
34/21 49/10 52/10
52/11 65/23 65/24
66/8 68/10 68/13
68/22 68/23 72/16
72/17 73/15 73/15
76/23 78/25 82/11
90/9 93/25 95/7 97/20
98/18 103/20 103/22
107/25 110/5 111/9
111/16
knowledge [20] 5/9
47/8 47/19 49/1 49/15)
50/4 50/8 53/25 54/13)
55/10 85/15 90/8
103/19 104/21 106/11
110/9 110/11 111/4
111/5 116/21
known [8] 49/23
72/18 77/24 77/25
99/7 99/21 112/3
114/3
L
lack [4] 55/9 66/13
67/18 70/16
large [8] 10/22 27/23
32/8 48/6 55/1 65/22
93/17 112/22
largely [2] 45/19
51/22
largest [1] 2/9
last [7] 30/19 41/23
42/1 59/13 69/18
105/20 111/19
later [5] 31/14 32/15
32/17 47/24 63/2
latitude [1] 18/8
launches [1] 103/12
law [2] 49/1 76/6
lawyers [4] 78/11
104/19 106/23 109/12)
layered [1] 95/14
leading [2] 29/2
29/12
leads [1] 86/1
learn [4] 16/19 16/20
16/21 16/21
learnt [1] 3/18
least [11] 12/14 31/6
42/15 53/21 61/11
71/12 81/5 91/20
109/19 111/14 114/9
leave [1] 14/22
leaving [3] 8/4
104/12 107/19
led [1] 10/25
left [4] 28/18 71/22
107/10 107/13
legacy [2] 99/2 107/7
legal [11] 2/22 3/6
58/11 58/23 58/25
60/23 103/7 103/9
103/13 107/17 109/6
legislation [1] 76/7
legitimate [1] 25/13
Leighton [1] 104/15
length [6] 10/18 11/6
21/16 26/10 43/10
58/20
lengthy [1] 50/22
less [4] 55/2 74/14
81/20 90/8
lesser [1] 104/16
lessons [1] 3/18
let [8] 2/11 2/14 4/1
7/20 26/18 76/23
108/5 108/9
let's [2] 84/12 108/3
letter [4] 3/11 39/16
57/16 57/20
letters [4] 31/8 40/7
47/4 69/8
level [15] 15/9 15/10
15/25 16/4 16/4 16/5
16/5 18/1 55/19 71/25
85/1 87/9 88/7 89/16
90/18
levels [1] 16/3
liabilities [1] 106/19
liability [7] 106/23
107/10 107/21 108/15}
108/19 109/13 109/17
liberty [1] 114/25
lie [2] 94/12 109/18
lies [1] 91/5
life [1] 107/25
lift [1] 19/11
lifted [2] 83/2 83/3
light [5] 23/25 38/13
74/10 89/11 105/20
lights [1] 88/23
like [27] 1/16 5/19
8/14 16/16 17/11
19/23 21/21 25/19
36/7 48/6 51/8 52/11
52/14 57/4 70/23
79/15 87/16 88/6
88/18 95/5 99/16
107/25 108/16 111/1
114/23 115/14 117/13
liked [2] 43/5 84/4
likely [7] 22/11 53/8
62/14 74/14 81/5 82/4
85/14
limited [80] 6/15 7/5
8/16 13/6 13/8 13/10
13/17 13/19 14/7 16/3
16/4 17/11 17/13
17/14 19/3 19/21
25/20 25/25 26/17
28/21 28/25 29/3
29/10 29/12 33/17
34/18 46/14 47/20
47/25 49/1 49/13
49/15 50/9 50/11
54/19 55/19 55/22
57/12 57/19 58/18
58/24 59/16 60/15
60/25 61/20 64/19
64/22 66/10 66/19
67/3 67/8 71/23 72/14,
73/14 74/8 74/13
74/18 75/19 77/19
77/24 78/2 78/17
79/12 79/16 79/17
80/17 81/1 87/19
87/21 87/25 90/3
90/19 90/24 93/12
95/12 109/5 109/9
109/10 109/14 111/4
Limited's [12] 11/14
12/6 12/23 33/22
34/11 35/25 47/12
51/1 53/25 57/9 66/17,
78/20
line [8] 8/19 17/6
41/5 43/23 64/9 85/4
88/6 96/9
lines [9] 28/4 45/10
69/5 74/5 82/14 92/9
95/11 110/19 111/10
link [1] 45/8
linked [1] 44/9
links [1] 3/25
list [1] 102/18
listed [2] 26/3 28/14
listening [2] 110/18
111/24
listing [1] 78/8
Litigation [1] 1/18
little [7] 19/6 43/4
45/21 50/13 50/23
91/23 110/12
livelihoods [3] 99/18
102/22 114/25
lives [2] 91/19 99/18
living [1] 81/10
lobbying [1] 58/5
locations [1] 11/19
LOCOG [1] 86/10
LOCOG's [1] 86/15
London [1] 78/9
long [8] 31/23 35/1
67/16 68/3 75/19 87/2
110/14 110/16
longer [1] 31/20
look [13] 18/4 18/7
22/4 23/18 39/2 57/4
84/10 94/6 108/16
115/14 115/16 115/25]
116/4
looked [9] 19/14
23/18 38/9 56/1 67/4
93/14 94/1 102/14
110/25
looking [19] 20/10
25/16 38/21 40/12
40/21 41/4 42/5 45/23
54/20 61/25 73/11
82/13 92/20 92/21
97/3 98/14 101/13
113/21 114/2
losing [1] 97/13
lost [1] 76/14
lot [9] 9/14 18/8
69/13 86/21 99/12
106/13 107/24 109/9
112/24
lots [5] 26/23 88/13
88/13 114/14 114/16
Lovegrove [4] 4/11
4/13 4/17 119/4
low [1] 43/12
lunch [3] 37/20 44/18
110/8
made [28] 27/2 29/24
32/21 32/25 50/16
50/17 51/6 51/9 53/10
60/24 62/14 62/24
67/8 68/19 69/8 70/10}
83/13 83/13 83/19
84/22 88/20 88/24
92/5 96/4 96/19
100/11 101/20 102/4
magnitude [1]
107/15
Mail [84] 6/14 6/17
6/25 7/6 8/15 13/11
14/1 14/5 16/6 16/9
18/24 19/12 19/16
20/2 28/21 29/7 30/2
30/12 32/10 33/9
33/12 33/16 34/17
35/17 35/23 35/24
35/25 36/11 36/18
36/20 37/13 38/5
38/10 41/9 43/1 46/8
46/20 47/24 48/8 49/7
49/12 50/10 56/21
56/23 64/15 64/19
73/18 74/8 74/12
TAIT 74/21 75/3
75/13 75/20 76/4
76/11 77/20 77/23
78/2 78/7 90/24 92/23}
95/4 95/6 95/20 96/1
98/25 100/4 100/8
101/10 101/11 101/14I
103/5 104/18 105/15
106/18 106/20 107/5
108/21 108/22 108/23}
109/5 109/12 110/21
Mail's [2] 19/10 62/12
main [6] 19/18 34/23
35/3 44/4 66/10 98/21
mainly [1] 10/24
(41) JFSA - mainly
maintain [2] 115/10
115/17
maintained [2] 11/23
23/6
maintaining [1]
11/18
maintenance [1]
12/6
Majesty's [1] 26/8
major [4] 41/10 43/25)
78/8 90/19
make [25] 1/6 1/8
2/11 3/3 3/17 12/10
14/19 22/5 24/16 32/6)
32/20 42/17 52/15
58/14 58/19 59/5
63/18 79/3 79/4 81/16
84/12 87/10 90/10
94/20 96/13
makes [2] 117/8
117/9
making [7] 1/20 9/14
42/15 43/3 84/13
114/6 118/9
manage [1] 28/6
manageable [1]
34/15
managed [2] 10/23
10/23
management [18]
5/23 8/23 9/18 13/25
14/1 15/1 16/10 17/10}
32/11 35/17 40/13
41/5 43/23 45/6 64/1
92/10 92/13 112/14
managing [1] 24/5
mandatory [1]
100/21
manifested [1] 30/24
manifesting [1] 33/6
manner [1] 14/7
many [10] 4/5 10/5
28/9 42/24 42/25
51/12 57/12 91/19
117/18 118/1
March [3] 42/4 106/3
108/6
marginalised [1]
105/10
Mark [2] 24/23 25/9
market [1] 108/11
massive [1] 84/12
material [1] 67/14
materiality [1] 87/9
matter [11] 15/12
26/6 27/12 35/21
55/21 55/24 55/24
64/23 70/10 72/5 82/9
matters [20] 5/21
6/18 14/12 14/16
15/16 15/21 15/24
16/13 29/5 29/14
50/10 51/23 53/23
57/18 58/17 67/17
74/14 89/15 90/4
95/22
may [29] 3/6 4/11
15/7 19/7 21/2 21/12
24/17 29/20 50/14
57/16 60/24 64/20
68/22 69/18 85/6
85/10 85/24 86/2
102/3 102/21 103/4
105/2 106/6 106/10
106/22 107/18 108/8
109/3 113/20
May 2010 [1] 103/4
maybe [5] 24/21
68/11 83/18 88/6
109/12
Mayor [1] 86/13
MD [4] 40/7
me [29] 1/23 2/7 2/11
2/14 4/1 7/20 22/4
26/18 34/9 45/25
48/13 55/5 66/15
76/12 76/23 80/2 85/4
88/9 92/21 98/24
99/14 101/25 102/18
103/23 104/11 104/24)
110/25 116/17 116/23)
mean [49] 14/23 17/6
18/13 21/19 21/19
22/5 22/16 24/5 24/17
24/19 31/12 31/22
31/25 32/21 32/21
37/5 43/8 48/7 48/12
49/3 63/5 65/12 65/18)
67/21 68/12 70/1
70/13 70/14 75/4 75/5
75/12 75/24 87/8 90/6)
91/22 92/20 95/1
96/24 99/17 99/25
103/18 103/25 104/12!
105/2 105/6 106/16
108/10 112/9 117/12
meaning [1] 74/13
means [1] 2/24
meant [2] 65/16
70/21
measures [1] 16/8
mechanism [3] 27/24I
78/23 90/4
mechanisms [9]
17/10 78/20 87/12
87/13 87/17 87/22
88/1 89/13 94/11
media [14] 5/24 6/3
6/9 6/10 31/2 31/15
39/20 39/22 99/6
99/11 99/13 102/11
102/14 103/25
meet [3] 58/1 72/10
114/15
meeting [12] 20/6
20/7 23/15 23/20
56/12 57/7 57/14
57/15 57/23 63/1
67/15 106/3
meetings [11] 39/5
43/10 47/5 47/6 51/19
80/9 81/5 83/8 87/21
88/2 88/17
member [7] 31/6
33/2 35/9 56/15 80/21
83/22 86/15
members [12] 1/11
14/2 20/15 20/22 21/1
26/11 31/4 31/24
56/19 58/8 87/6 94/22
memory [2] 102/5
102/7
men [1] 114/8
mentioned [4] 37/16
52/8 74/22 117/4
merely [1] 73/1
met [7] 18/18 41/2
63/23 79/20 80/7
86/22 90/9
method [1] 87/20
metrics [1] 75/5
microphone [1]
77/11
might [22] 16/13
26/10 35/9 36/16
37/16 44/17 56/5
63/19 64/9 68/8 69/10
70/18 73/6 73/19
73/25 76/20 88/8 88/9
89/15 95/13 110/5
111/22
Mike [10] 56/11
56/15 61/10 61/25
63/2 66/8 66/14 67/16
68/23 104/15
milked [1] 99/22
mind [11] 21/15 43/9
52/5 53/20 62/17
68/11 68/14 81/3
81/20 82/8 105/22
minister [16] 51/19
58/1 61/12 63/1 63/21
66/3 72/10 72/13 85/1
85/7 88/4 88/9 89/3
89/4 95/10 111/21
Minister's [1] 8/1
ministerial [1] 52/13
ministers [19] 15/10
18/14 22/2 24/12
32/23 36/3 51/20
63/23 69/21 84/20
87/19 87/20 87/24
88/2 88/20 88/25 89/1
98/16 102/12
ministers’ [1] 32/20
Ministry [1] 7/18
minute [2] 37/20
76/21
minutes [7] 20/5 20/8}
20/13 21/20 23/18
37/6 106/2
misleadingly [1]
69/23
mismatch [1] 54/2
Misra's [1] 103/3
miss [1] 16/6
missed [1] 27/18
missing [2] 31/9
48/10
missing/being [1]
48/10
misunderstood [2]
49/9 70/18
mixed [1] 40/5
mixture [2] 13/22
13/24
model [2] 10/17
59/23
models [1] 90/22
modern [2] 90/25
91/25
modernise [1] 32/7
Moloney [1] 110/3
moment [7] 44/18
48/8 49/5 61/9 76/15
76/17 87/3
moments [1] 92/24
Monday [1] 1/1
money [2] 24/5 86/13)
monitored [1] 15/25
monitoring [4] 14/20
15/5 39/17 45/6
month [1] 63/3
months [1] 40/25
months’ [1] 40/21
more [34] 17/1 30/10
33/2 43/4 43/14 49/20
50/23 55/4 57/19 59/3
60/11 62/14 65/7 67/9)
67/12 68/19 71/3 71/6)
71/15 73/1 75/2 81/8
89/25 91/4 91/7 96/5
96/19 97/11 100/7
103/15 110/12 113/1
114/6 115/18
Morgan [1] 6/3
morning [3] 1/4
110/7 118/12
most [9] 12/1 14/25
22/6 27/19 81/3 82/5
82/8 87/8 91/15
mounted [1] 58/5
move [2] 25/19 40/21
moved [2] 19/18
107/21
Moving [1] 87/17
MPs [2] 58/5 104/1
Mr [17] 57/15 63/5
63/23 66/2 66/5 67/8
67/21 68/8 68/19 97/5
97/9 106/1 110/3
114/15 116/19 118/12)
119/9
Mr Bates [5] 57/15
63/5 63/23 67/21
114/15
Mr Davey [1] 66/5
Mr Dunks [1] 118/12
Mr Henry [4] 97/5
97/9 116/19 119/9
Mr Moloney [1] 110/3
Mr Patrick [1] 106/1
Mr Whitehead [4]
66/2 67/8 68/8 68/19
Mrs [1] 103/3
Mrs Misra's [1] 103/3
Ms [12] 1/6 4/8 4/14
76/12 97/6 109/25
110/1 110/6 118/5
118/13 119/7 119/11
Ms Patrick [4] 97/6
109/25 110/1 119/11
Ms Price [8] 1/6 4/8
4/14 76/12 110/6
118/5 118/13 119/7
much [28] 3/12 15/1
22/21 32/23 36/23
39/24 48/18 49/20
63/4 63/16 67/12 68/3I
74/20 75/2 77/10
87/13 87/14 89/24
89/24 90/1 90/6 100/4I
100/7 109/24 115/11
118/4 118/8 118/11
multi [1] 95/14
multi-layered [1]
95/14
multiple [3] 90/17
92/4 105/1
must [3] 15/19 99/9
107/21
mutualisation [1]
80/16
my [46] 4/6 4/18 7/21
29/8 29/15 29/15
29/18 31/25 35/1
35/15 35/15 36/13
37/6 42/11 42/23 49/1
50/8 50/15 50/15
51/10 64/11 64/24
68/16 71/12 73/2
77/11 81/20 83/7 90/7I
90/7 92/4 95/22 100/7
101/5 102/8 103/24
104/5 104/24 105/14
107/24 107/25 108/13)
109/3 110/2 116/21
116/25
myself [3] 70/2 73/24
85/21
N
name [6] 4/15 4/18
30/9 51/11 78/12
110/2
named [1] 58/6
namely [2] 36/15
54/20
(42) maintain - namely
N
names [1] 27/7
NAO [1] 111/9
narrative [1] 105/11
national [9] 7/22 7/23
11/10 66/11 66/24
67/1 67/25 110/23
110/25
nature [5] 13/23
13/23 81/15 94/2
112/5
near [1] 76/22
nearly [2] 9/12 82/12
necessarily [6] 10/17
10/19 37/12 69/4
70/14 70/15
necessary [2] 20/25
76/24
NED [16] 34/12 35/11
35/23 36/19 41/11
41/20 41/21 42/2
79/20 80/7 80/25 81/2
82/23 85/11 90/3 90/5
NEDs [5] 28/22 41/13
81/4 93/20 97/11
need [13] 3/21 22/18
23/19 31/5 41/20 52/4
81/24 91/10 91/12
91/13 105/25 109/8
115/13
needed [5] 9/5 9/7
83/19 92/14 118/2
needing [2] 44/12
85/1
needs [7] 70/6 88/7
91/14 94/20 94/24
97/17 103/15
negotiated [2] 2/19
111/11
negotiation [1] 25/12
negotiations [4] 2/23
2/24 50/22 110/12
neither [3] 47/16
55/17 99/15
network [10] 11/22
12/15 12/17 12/18
13/19 18/20 22/7
22/18 45/13 80/3
never [3] 36/8 78/18
102/5
nevertheless [2]
108/22 108/23
Neville [1] 111/21
Neville-Rolfe [1]
111/21
new [19] 23/15 23/22
23/25 24/4 24/11
24/12 24/12 24/16
39/4 40/7 40/7 41/1
42/3 59/14 79/21
79/23 84/10 95/8
103/4
news [2] 57/21 57/25
next [2] 40/4 44/17
NFSP [7] 59/17 60/9
66/15 67/7 67/9 67/12
68/17
nine [1] 53/1
no [52] 2/15 2/16
3/17 10/1 10/5 10/12
24/4 26/18 31/3 31/20
32/2 32/18 36/12
38/15 38/17 39/13
39/14 39/21 39/23
41/8 41/12 41/20 42/1
43/18 47/8 50/3 54/21
55/24 61/6 65/1 66/13)
67/5 69/2 78/5 78/18
79/14 85/11 86/1 86/5
89/20 102/5 102/6
103/19 106/14 108/22)
109/11 109/15 109/16)
109/23 115/3 116/14
118/5
nobody [1] 85/19
noised [1] 49/24
Nominations [1] 27/1
non [29] 27/14 28/23
29/20 30/2 33/19
33/23 33/25 34/3
36/24 37/2 38/24 43/1
43/2 44/8 44/12 79/17
81/16 83/22 93/19
97/18 97/19 97/19
97/24 98/3 98/6 98/10)
98/25 105/13 105/15
non-execs [1] 38/24
non-executive [22]
27/14 28/23 29/20
30/2 33/19 33/23
33/25 34/3 37/2 44/8
44/12 79/17 81/16
97/18 97/19 97/19
97/24 98/3 98/10
98/25 105/13 105/15
non-executives [4]
36/24 43/1 43/2 93/19)
none [2] 103/18
104/4
noon [1] 1/2
nor [6] 47/16 47/21
50/16 66/16 70/14
99/15
normal [6] 13/12
24/22 47/10 48/11
48/11 75/11
normally [2] 112/6
112/6
Nos [1] 41/4
not [163]
notably [1] 27/20
note [2] 58/25 83/1
noted [1] 51/9
nothing [3] 61/4 70/4
92/18
notwithstanding [3]
64/6 64/8 90/17
November [4] 67/13
67/14 68/4 103/2
November 2009 [1]
103/2
now [45] 1/8 1/13
1/16 4/2 4/6 4/8 4/8
5/13 27/3 29/10 33/14
39/5 39/6 40/6 40/7
40/10 40/25 44/15
45/23 52/1 55/14
64/16 69/17 71/7
75/17 77/4 77/11
77/12 78/7 83/17
92/18 93/3 94/17 99/5)
100/2 100/15 100/24
101/12 102/4 102/9
104/12 113/1 115/7
115/9 115/12
nowhere [1] 106/5
nuclear [2] 95/7
103/21
number [14] 8/4
31/22 38/17 53/23
57/10 70/24 73/6
75/24 81/24 93/18
93/19 98/20 101/16
110/3
number 1 [1] 38/17
numbers [2] 72/20
73/16
(e)
O'Sullivan [1] 106/1
objections [1] 33/25
objective [7] 10/13
10/17 12/7 13/7 22/9
22/10 97/15
objectives [21] 9/2
9/6 9/8 9/20 9/25 10/1
10/6 14/8 16/20 16/21
17/20 18/13 18/15
18/22 32/20 33/3 58/9
59/9 59/21 81/19
82/10
objectivity [1] 97/13
observations [1]
104/25
observe [2] 13/11
14/10
obstructive [2] 85/3
85/6
obtain [2] 50/1 66/8
obvious [3] 4/2 98/1
99/9
obviously [7] 44/4
88/11 95/5 103/11
109/8 109/14 116/24
occasion [2] 48/13
86/17
occasionally [1]
43/14
occasions [2] 21/13
81/24
occurred [2] 102/19
106/8
occurs [1] 55/13
October [7] 50/25
56/12 57/8 80/4 103/9)
103/11 108/7
October 2011 [2]
103/9 103/11
odd [1] 36/7
Odgers [3] 79/25
80/1 80/2
Ofcom [1] 76/2
off [8] 22/2 28/12
39/22 84/13 89/1
107/8 107/10 116/25
offer [2] 4/6 59/6
offered [1] 12/1
offering [1] 57/22
office [173]
Office's [2] 50/11
62/11
officers [1] 24/7
offices [3] 12/1 60/5
60/6
official [1] 66/18
officials [15] 18/16
28/12 46/17 51/22
52/2 62/1 63/10 65/1
65/3 69/19 71/6 72/18
73/18 114/13 114/21
officials’ [1] 45/17
offs [2] 22/11 22/22
often [9] 10/3 10/22
11/8 22/24 35/4 35/11
39/14 41/2 88/3
okay [9] 5/17 34/7
41/1 44/2 49/11 52/10)
77/12 111/19 112/12
Olympic [1] 86/14
Olympics [3] 86/9
86/12 86/21
on [196]
Once [2] 65/3 100/10
one [47] 1/25 2/11
3/25 12/14 21/23 24/6)
24/13 26/20 29/16
30/4 31/6 32/11 32/24
34/2 34/3 37/16 38/22,
41/23 44/16 49/22
56/23 56/24 67/3 72/2
75/25 76/10 81/2 81/7,
83/15 83/24 86/2
86/14 87/20 98/18
101/7 102/7 102/21
102/23 103/11 103/12}
106/11 110/6 111/12
111/16 111/21 115/2
116/17
ones [2] 80/12 91/17
ongoing [1] 53/6
online [2] 3/20 103/4
only [4] 37/20 85/17
86/22 110/6
onto [2] 29/19 36/2
open [5] 12/10 53/6
54/20 70/12 71/17
operate [3] 39/19
53/12 69/5
operated [2] 2/10
9/24
operating [4] 26/9
54/21 59/23 63/13
operation [1] 54/10
operational [24]
14/13 14/20 15/5 15/7)
15/9 15/16 15/20
15/24 16/7 16/13
20/19 29/4 29/14
57/18 58/17 71/21
72/5 72/9 72/14 73/1
73/13 74/14 80/20
89/15
operations [5] 17/4
32/7 58/21 75/8 91/10
opposed [5] 25/17
44/14 48/22 49/7
99/21
opposite [1] 78/6
option [1] 95/7
or [118] 2/13 2/14
3/21 9/20 10/7 10/23
11/5 14/12 14/13 15/9}
15/13 15/24 16/13
16/14 17/4 17/19
18/17 18/18 21/4
21/25 25/11 26/2 26/2
27/8 27/15 27/17
27/18 28/16 29/1
29/11 30/25 32/16
33/7 35/12 35/21
35/23 38/17 42/15
44/10 47/18 48/3 49/7
51/12 54/13 55/5
55/17 56/3 58/7 60/10}
61/20 62/17 64/4 65/9I
67/17 67/19 69/20
69/23 69/24 72/3
73/16 73/17 74/13
74/21 75/10 78/2 79/3I
79/8 81/4 82/19 83/3
84/22 85/9 85/13
85/17 85/23 86/19
86/24 86/25 87/24
88/5 88/8 88/24 90/22
91/6 92/14 93/25 94/3}
94/18 95/17 95/18
96/4 96/12 96/21
96/23 96/23 97/14
98/8 98/18 98/25
102/3 102/7 103/22
104/3 104/16 105/8
106/6 106/24 107/4
111/5 112/13 113/1
113/3 113/18 114/9
115/9 115/21 115/24
116/17
order [9] 1/23 11/7
15/18 21/10 25/23
46/8 46/11 46/22 79/3)
(43) names - order
[e)
orders [1] 50/2
ordinary [1] 48/2
organic [1] 75/7
organisation [9] 11/6
11/15 17/8 79/7 79/9
91/10 93/17 107/13
114/15
organisations [1]
46/19
organise [1] 89/8
organism [1] 81/10
other [33] 13/1 19/6
23/11 25/8 26/11
27/21 32/16 40/5 41/6
43/23 49/19 62/5 71/1
79/10 82/1 82/2 82/6
84/16 87/6 87/22
94/15 94/16 94/22
98/19 100/4 101/16
102/2 104/21 105/2
105/7 106/22 107/9
107/19
others [5] 32/2 64/1
76/1 82/9 113/23
others' [1] 90/8
otherwise [5] 20/1
82/19 86/4 106/24
107/4
ought [5] 37/1 98/6
100/19 101/3 114/1
our [8] 15/3 22/10
27/6 30/11 58/9 78/23
79/2 115/24
ourselves [3] 27/9
79/9 113/5
out [20] 16/6 18/22
22/10 27/18 31/2
34/21 37/15 51/14
53/1 53/4 60/14 63/24,
73/12 75/6 76/9 82/18
92/10 114/24 115/23
117/2
outages [1] 103/6
outcome [1] 93/10
outlook [1] 23/7
outset [1] 114/12
outside [1] 115/19
over [21] 3/21 26/10
26/24 30/10 30/19
31/4 31/7 33/16 34/17
40/9 49/12 59/3 60/11
60/16 82/13 92/4
98/24 103/2 103/7
106/21 109/9
overall [2] 40/1 53/9
overcome [1] 41/3
overlay [1] 21/9
oversee [3] 17/18
17/21 40/16
overseeing [1] 18/2
oversight [14] 13/14
13/17 13/22 13/24
15/3 15/16 15/18
18/18 64/21 78/22
96/2 110/21 111/7
114/11
overturned [1] 110/5
own [7] 11/16 15/3
45/17 50/4 87/16
113/24 115/24
owned [12] 8/24 9/22
11/17 13/10 13/14
15/13 15/14 26/2 26/2
58/2 101/10 114/7
owner [3] 28/16 35/4
90/23
owners [1] 92/17
ownership [6] 14/6
32/9 32/12 53/3 91/4
91/6
owning [1] 10/13
P
packs [2] 16/10 43/9
page [27] 5/1 8/17
8/20 11/13 17/16
20/10 20/12 23/3 23/4
28/3 30/7 30/10 34/24
45/10 45/22 47/15
50/6 52/23 59/3 60/11
60/16 66/7 74/4 79/19
82/13 90/16 110/18
page 10 [1] 11/13
page 11 [1] 17/16
page 12 [2] 23/3 23/4
page 19 [1] 28/3
page 26 [1] 45/10
page 29 [1] 50/6
page 30 [1] 74/4
page 33 [1] 34/24
page 4 [1] 52/23
page 40 [1] 47/15
page 42 [1] 66/7
page 46 [1] 79/19
page 5 [1] 30/7
page 51 [1] 110/18
page 55 [1] 90/16
page 56 [1] 5/1
page 7 [2] 8/17 30/10
pages [1] 30/10
paid [2] 116/8 116/9
panoply [1] 27/18
paper [1] 20/14
papers [12] 29/16
82/17 82/22 83/12
84/3 85/9 85/19 85/23
87/5 92/21 98/23
98/23
paradoxically [1]
98/13
paragraph [53] 6/23
8/16 10/16 11/12
11/13 13/15 14/10
17/15 17/16 19/6 20/9)
20/11 20/11 22/6 23/2
23/19 25/21 26/7 28/2
28/4 29/23 30/11
30/15 33/6 33/15
34/25 35/14 36/15
45/9 45/21 46/12
47/12 47/14 50/5
52/16 56/13 56/20
60/21 61/17 61/21
66/1 66/6 74/3 79/18
80/24 82/3 82/3 82/13
90/15 91/23 94/7
101/18 102/24
paragraph 106 [1]
61/21
paragraph 111 [2]
90/15 91/23
paragraph 112 [1]
94/7
paragraph 17 [1]
8/16
paragraph 18 [1]
10/16
paragraph 2.1 [1]
20/11
paragraph 23 [1]
11/12
paragraph 24 [1]
13/15
paragraph 26 [3]
17/15 17/16 19/6
paragraph 28 [1]
20/9
paragraph 29 [1]
23/2
paragraph 31 [1]
14/10
paragraph 34 [1]
52/16
paragraph 35 [1]
25/21
paragraph 39 [1]
26/7
paragraph 40 [2]
28/2 28/4
paragraph 52 [1]
45/9
paragraph 53 [2]
45/21 47/12
paragraph 57 [1]
56/20
paragraph 60 [3]
50/5 101/18 102/24
paragraph 61 [1]
74/3
paragraph 67 [2]
82/3 82/3
paragraph 68 [1]
34/25
paragraph 69 [3]
33/15 35/14 36/15
paragraph 7 [1] 6/23
paragraph 76 [1]
29/23
paragraph 83 [1]
47/14
paragraph 87 [2]
56/13 66/1
paragraph 88 [1]
66/6
paragraph 89 [1]
61/17
paragraph 9 [2]
30/11 30/15
paragraph 94 [4]
79/18
paragraph 95 [1]
80/24
paragraph 96 [1]
82/13
paragraphs [3] 64/17
117/3 117/5
paragraphs 111 [1]
117/3
paragraphs 57 [1]
64/17
parallel [1] 104/4
parameters [1] 9/25
parent [6] 7/5 14/3
14/3 29/7 45/17 95/20}
part [14] 12/23 19/18
23/6 36/13 45/5 65/22
69/18 85/12 88/16
91/20 105/4 111/3
112/3 112/22
partial [1] 106/12
Participants [3] 1/11
97/2 97/4
participate [2] 86/24
86/25
participated [1] 27/4
particular [25] 7/3
15/23 16/19 24/8
25/11 25/11 27/7
28/21 31/16 33/5 37/3,
48/22 62/19 73/22
82/10 83/2 85/16
87/22 88/5 112/16
113/9 113/10 113/11
113/13 115/3
particularly [15] 10/9
15/12 20/15 23/14
32/3 62/25 74/6 91/16
93/2 98/15 102/16
112/15 113/22 113/23
114/24
parties [1] 30/18
parts [2] 106/10
107/6
party [2] 112/9
112/16
pass [1] 51/4
passed [2] 100/11
103/23
passing [1] 104/13
paths [1] 87/7
Patricia [1] 95/2
Patrick [6] 97/6
106/1 109/25 110/1
110/2 119/11
Pause [2] 76/19 77/6
pay [3] 11/8 115/25
116/12
paying [1] 86/12
payments [2] 2/19
54/2
peculiar [1] 21/23
pension [3] 32/8
74/23 76/3
penultimate [1] 8/19
people [22] 2/5 3/19
11/2 11/7 13/2 13/5
16/23 16/24 25/13
42/25 47/2 48/11 56/3)
61/14 70/18 70/24
83/15 83/18 91/19
95/15 96/21 104/8
people's [1] 104/21
per [4] 13/10 28/16
81/18 101/6
per se [1] 101/6
perfect [3] 68/10
92/18 92/19
perfectly [6] 24/13
65/24 68/10 68/21
71/17 76/18
perform [2] 11/3
13/20
performance [8]
14/21 15/6 16/8 39/17
41/1 41/24 74/9 111/6)
performed [2] 7/15
15/13
perhaps [3] 48/21
90/8 102/9
period [10] 16/17
49/16 62/18 72/3 74/7
74/10 74/15 74/18
75/12 114/18
Perkins [3] 33/24
79/23 80/7
Permanent [3] 7/11
7/17 80/8
permeate [1] 104/5
permeating [2] 104/4
104/5
perpetuation [1]
90/20
person [2] 49/3
105/18
personal [2] 96/25
99/18
personally [2] 42/25
47/20
persons [1] 2/4
perspective [1] 34/9
perspectives [3]
25/16 65/8 81/12
phase [6] 1/3 1/7
4/12 1/13 108/20
119/2
Phase 7 [2] 1/13
108/20
Phases [1] 4/9
(44) orders - Phases
Pp
Phases 5 [1] 4/9
Philip [1] 20/14
pick [1] 96/5
picked [4] 75/11 93/6
94/5 96/18
picking [3] 50/19
96/18 115/2
picture [1] 47/2
pilot [1] 103/4
place [21] 9/5 9/7
17/11 20/6 22/1 48/4
52/9 63/24 65/9 70/22
78/21 83/5 86/22
87/17 92/17 93/24
94/12 94/18 94/18
94/20 96/22
placed [2] 2/7 66/23
placing [1] 68/25
plan [2] 53/10 78/14
planned [1] 58/12
planning [2] 57/21
58/23
plans [4] 33/21 53/7
53/9 77/15
play [3] 12/5 38/11
91/17
played [1] 12/22
playing [3] 11/21
31/2 57/25
please [50] 4/11 4/15
5/2 5/19 8/14 8/16
11/12 17/11 17/15
20/4 20/10 23/2 23/4
25/19 28/2 29/25 30/7
30/10 34/25 37/24
38/6 39/1 40/12 44/21
45/10 45/22 47/15
50/6 52/17 52/23 56/9
57/4 59/3 60/11 60/14,
60/16 66/7 74/3 74/4
79/15 79/18 82/13
87/17 88/10 90/13
90/15 91/22 96/10
108/25 117/13
pleased [1] 2/20
plenty [2] 16/23
104/6
plight [1] 106/17
plus [1] 39/4
pm [5] 44/24 45/1
77/1 77/3 118/17
point [18] 20/17 22/5
31/16 38/11 42/8 43/6
44/11 50/12 59/13
63/17 72/16 76/21
86/23 107/13 109/22
114/24 115/2 116/7
pointed [2] 71/16
75/6
points [6] 32/22
58/15 59/3 59/19 67/4,
92/22
POL [37] 11/15 11/18
11/24 13/24 13/25
16/8 29/9 31/8 40/17
45/14 45/16 46/8
47/18 47/21 56/6
56/15 56/18 58/12
67/8 67/19 68/8 71/11
82/17 85/9 85/23 93/2
95/16 95/16 100/8
100/25 101/1 107/8
107/21 108/18 114/23)
115/24 116/9
POL's [4] 46/2 59/24
60/1 61/23
policy [65] 9/2 9/6
9/25 10/1 10/6 10/13
11/23 12/7 12/19 13/7)
14/8 14/20 15/7 15/10
15/12 16/14 16/20
17/4 17/13 17/20
17/21 18/4 18/6 18/7
18/13 18/15 18/15
18/22 19/3 19/7 19/20
19/25 20/18 20/19
21/2 21/9 21/13 21/16
21/23 22/1 22/9 22/15
22/17 22/25 23/13
24/2 24/11 24/13
24/16 24/25 25/6
25/11 25/17 28/12
32/13 36/23 53/13
54/21 56/17 64/19
65/1 75/21 80/16
89/16 91/17
political [1] 35/12
politically [2] 35/10
36/17
poor [2] 31/7 42/7
pop [1] 94/16
portfolio [2] 10/21
100/6
posed [6] 38/14 46/1
66/20 71/19 100/16
100/17
position [28] 17/23
21/9 21/11 21/14
22/14 22/15 22/20
22/25 25/10 36/4 37/1
59/6 60/15 60/17
63/17 66/18 66/24
67/10 67/12 68/2 68/9)
68/17 68/21 68/23
72/10 78/17 104/12
105/23
positively [1] 3/11
possibility [2] 96/6
96/6
possible [5] 3/12
13/1 27/4 56/5 68/11
possibly [7] 9/9
31/14 32/16 43/12
46/24 87/2 88/8
post [177]
postal [3] 11/20
19/12 100/10
postmasters [3]
51/24 102/22 102/25
potential [5] 34/4
36/17 57/25 107/20
114/5
potentially [6] 25/15
33/10 53/15 82/24
86/19 114/7
power [6] 46/2 47/12
47/21 47/22 47/25
48/21
PQs [1] 58/7
practical [3] 35/22
36/1 84/12
practice [9] 2/10 9/12
25/5 83/4 83/17 86/7
92/4 93/7 116/13
practices [6] 2/9
10/25 91/9 94/7 94/10)
94/12
pre [3] 13/11 13/18
39/23
pre-separation [2]
13/11 13/18
pre-warning [1]
39/23
precise [1] 16/15
precisely [2] 88/22
92/11
precision [1] 36/22
preferable [2] 61/23
100/20
prejudice [2] 2/20
2/25
prepared [3] 54/3
56/11 59/4
preparing [1] 80/5
prescriptive [1]
97/11
present [1] 20/7
presentational [1]
57/24
presented [5] 66/2
69/23 69/24 69/24
72/13
press [3] 39/23 59/11
59/14
pressed [1] 70/1
pressure [4] 23/25
24/5 30/20 31/11
presumably [1]
100/9
pretty [3] 32/19 33/24]
83/17
prevail [1] 35/16
prevailing [1] 1/18
prevalent [1] 23/14
prevent [1] 80/19
prevented [1] 83/5
preventing [1] 42/15
previous [5] 20/12
29/16 40/10 46/11
55/9
Price [9] 1/6 4/8 4/14
4/18 76/12 110/6
118/5 118/13 119/7
priced [1] 108/10
primarily [2] 29/8
46/13
primary [1] 76/7
Prime [1] 8/1
principal [8] 8/19
8/21 26/3 26/18 26/20)
27/12 78/23 88/1
principally [2] 92/25
101/14
principle [7] 53/5
53/12 53/16 55/21
55/24 55/25 85/16
principles [4] 53/1
53/4 53/20 54/19
prior [4] 35/24 47/18
61/20 109/10
priorities [3] 21/10
77/18 77/20
priority [6] 23/12
24/2 75/21 75/23
T7717 101/15
prison [1] 49/4
private [8] 9/13 11/9
48/1 48/4 48/23 49/2
49/3 102/10
privately [2] 26/2
31/17
privatisation [6]
75/20 75/21 77/16
77/20 78/15 100/12
privatise [1] 10/3
privatised [1] 76/6
privilege [2] 2/22 3/6
probably [15] 24/18
31/22 43/3 43/8 43/13)
52/10 62/20 72/4 84/5)
84/15 84/17 84/25
102/17 109/21 115/11
probe [1] 68/8
probed [1] 71/8
probing [4] 71/3 71/7
101/18 113/24
problem [7] 72/6
96/5 106/14 107/2
107/3 114/6 115/17
problematic [2] 42/9
114/3
problems [10] 7/1
73/5 91/13 94/5 95/18
103/6 106/12 112/1
112/11 113/10
proceeded [1] 61/1
proceedings [1]
49/25
process [7] 23/1 59/1
69/11 73/20 78/9 94/4
98/8
procurement [3]
50/13 50/20 50/21
production [1] 62/2
professional [3] 5/19
12/2 18/2
profile [4] 31/3 39/23
107/15 107/16
profitability [3] 74/16
74/20 75/2
programme [3] 17/2
39/4 41/9
programmes [2]
104/9 104/9
progress [2] 52/11
53/10
prohibition [3] 83/2
83/4 84/7
prominence [1] 7/1
promise [1] 1/22
promulgate [1] 91/9
proper [7] 26/4 83/5
91/1 92/1 93/12 93/18
96/17
properly [13] 9/15
22/23 26/21 44/13
81/25 91/14 92/15
92/16 94/19 94/19
94/21 98/16 111/15
proportion [1] 23/13
proposals [2] 20/20
24/11
propose [1] 1/8
proposition [2] 35/6
54/5
prosecute [3] 46/2
47/13 114/8
prosecuted [7] 48/12
48/14 50/2 57/12
61/15 99/8 110/4
prosecution [5] 49/2
49/3 55/16 102/21
109/11
prosecutions [30]
46/5 47/17 47/19
47/21 48/1 48/1 48/4
48/22 48/23 49/8
49/12 49/15 49/18
51/3 54/9 54/18 71/1
71/21 71/24 72/20
73/6 73/17 99/3
100/17 104/17 106/6
107/7 107/10 107/20
109/4
prosecutorial [1]
61/23
prospectus [4]
106/20 107/13 107/25)
108/2
Prosser [3] 31/5 33/1
95/6
prove [2] 48/15 51/14)
provide [7] 1/22 2/7
3/10 31/15 65/17
66/19 109/6
provided [12] 3/14
25/23 45/15 65/18
66/9 68/25 69/20
(45) Phases 5 - provided
Pp
provided... [5] 69/21
78/10 87/19 90/13
114/23
provides [1] 25/1
providing [5] 4/21
11/19 26/16 31/1 33/7
prudent [1] 58/13
public [12] 1/12 3/3
8/10 12/14 24/5 36/16
53/10 53/15 76/4
112/2 112/3 112/17
publications [1]
103/20
publicity [1] 57/25
publicly [3] 26/2 26/3
28/14
published [2] 2/17
5/14
purely [3] 18/20
73/13 80/18
purpose [6] 8/19
8/21 57/6 82/23 91/1
93/12
purposes [3] 5/11
18/17 18/19
pursue [1] 60/25
pursuing [1] 53/8
pursuit [2] 10/16
100/18
pushback [3] 36/15
79/15 81/1
put [12] 12/9 23/10
36/1 37/6 38/12 64/12
73/24 86/15 92/17
95/6 96/22 106/25
putting [1] 84/5
Q
quality [2] 40/13 44/5
quantities [1] 78/10
quarterly [7] 37/25
39/9 65/12 74/11
87/24 88/19 88/23
Quarterly/Annual [1]
74/11
query [1] 69/20
question [28] 9/7
17/12 32/18 39/6
39/11 45/20 49/5 52/2
55/13 61/9 65/22
68/16 69/3 70/4 72/15)
72/21 73/2 73/23
88/16 96/15 105/4
105/6 111/8 111/18
113/14 113/17 113/20}
116/10
questioned [9] 4/14
97/9 106/2 110/1
116/16 119/7 119/9
119/11 119/13
questioning [1]
111/22
questions [27] 1/14
1/23 4/19 38/14 38/21
51/21 51/22 52/7 63/2
65/17 66/20 69/10
71/10 71/11 71/15
86/2 97/1 97/5 103/3
104/24 112/24 113/22)
113/25 114/14 114/16)
116/15 118/6
quicker [2] 71/18
96/19
quickly [2] 89/25
115/16
quit [1] 81/2
quite [12] 10/22 18/8
19/23 32/14 34/9 43/2
46/24 47/1 78/6 86/21
88/3 116/5
quizzed [1] 47/6
R
raise [2] 35/20 87/9
raised [11] 21/12
51/23 54/11 57/5
57/18 58/16 64/8
67/22 79/12 84/25
89/24
raising [2] 37/9 63/5
ran [1] 28/10
range [1] 89/9
rather [13] 14/11
22/19 27/24 31/23
33/13 37/1 43/19
70/20 78/7 83/7 84/14)
97/15 113/3
re [3] 1/3 40/16 119/2
re-appointed [1]
40/16
reached [3] 40/6
44/16 71/25
reaching [1] 25/10
read [2] 60/13 103/20
reading [2] 102/5
102/7
ready [1] 77/12
readying [4] 77/19
77/19 78/6 78/8
really [19] 17/1 18/7
19/22 21/25 21/25
22/14 32/24 69/3
77/12 85/2 85/5 85/17
85/20 88/12 93/6
96/16 100/21 115/23
115/23
reappointment [1]
41/12
reappointment/recrui
tment [4] 41/12
reason [11] 15/4 25/8)
32/3 34/5 34/11 72/11
81/4 81/20 82/4
112/14 113/11
reasonable [3] 3/21
10/13 68/21
reasons [16] 10/12
25/8 34/2 34/10 36/14
36/19 37/12 57/24
61/6 61/7 81/7 82/2
82/7 98/2 105/2
111/14
reassuring [1] 68/20
recall [11] 19/22
19/24 36/10 50/14
79/14 82/20 89/12
102/3 110/24 111/2
111/3
receipts [1] 54/1
receive [1] 3/24
received [4] 47/4
49/11 53/21 67/22
recently [3] 39/14
41/14 41/25
recognise [1] 106/6
recognised [2] 44/3
107/3
recognising [1]
107/2
recognition [1] 63/14
recommendations
[1] 100/14
recommended [6]
7/4 57/22 76/1 76/3
76/4 107/19
reconcile [1] 19/17
record [3] 39/22
73/17 110/17
recorded [3] 64/2
68/16 68/17
recruit [2] 11/2 11/7
recruitment [2] 41/12
41/22
rectification [1] 46/6
recuse [1] 87/4
Red [1] 40/4
redesign [1] 91/5
redress [1] 18/11
reduce [1] 41/17
refer [9] 19/5 20/8
29/23 47/12 52/16
56/14 74/18 94/7
104/13
reference [8] 5/11
31/10 33/5 46/10
52/18 66/4 107/19
111/24
referenced [1] 37/5
referred [5] 25/9
43/16 56/10 82/2
102/24
referring [7] 23/17
25/24 26/1 33/13 44/1
80/12 104/8
reflect [1] 64/23
reflected [1] 74/9
reflecting [1] 33/2
reflection [2] 109/16
110/13
reflections [1] 90/13
refresh [2] 40/6 42/2
refusing [2] 30/25
33/7
regard [2] 9/14 28/22
regime [1] 27/25
register [24] 45/12
45/14 45/18 55/22
55/23 56/1 56/4 56/7
61/19 62/10 62/11
62/12 62/16 64/13
64/14 64/15 100/20
100/23 101/4 101/5
101/11 116/19 116/22}
116/24
registers [10] 16/9
46/7 47/11 55/18
61/24 62/14 87/24
89/10 92/13 101/9
regular [3] 38/23
39/7 66/14
regularly [1] 90/10
regulation [1] 10/4
regulator [1] 76/1
regulators [1] 97/22
regulatory [1] 31/6
reiterated [1] 98/9
relate [1] 38/19
related [2] 50/10 61/7
relates [1] 38/17
relating [10] 1/7 2/8
17/13 17/14 19/3
54/18 78/19 87/5
87/25 106/4
relation [7] 21/14
21/16 29/10 60/15
60/18 60/20 79/12
relationship [29]
28/6 28/13 30/12
30/16 31/9 31/19 32/1
32/19 38/10 38/14
38/18 38/20 40/1 40/5
40/20 42/7 42/12
42/14 58/20 59/16
67/2 67/7 68/13 68/18)
69/15 70/11 70/12
80/17 95/25
relationships [3]
32/17 81/21 81/24
relatively [1] 43/12
relaxation [1] 98/14
relayed [1] 102/12
releases [1] 39/23
relevant [14] 5/21
12/3 13/6 16/14 19/8
55/18 58/25 67/13
72/21 78/3 88/4 88/18
89/16 111/4
reliability [1] 59/12
reliable [1] 90/8
reliance [4] 66/23
67/9 68/25 73/7
reliant [1] 67/11
relied [2] 112/21
114/7
relies [1] 64/2
reluctance [1] 29/18
reluctant [1] 80/22
rely [3] 67/24 114/22
114/23
relying [2] 45/14
115/4
remain [2] 76/22
87/13
remainder [1] 36/14
remained [3] 5/24
7/8 23/13
remaining [1] 61/3
remediation [1]
92/16
remember [12] 31/23)
37/17 42/22 43/20
44/2 48/7 49/19 50/16)
88/22 89/2 102/4
107/17
reminded [1] 29/17
remit [1] 20/15
remote [2] 11/19
112/9
remotely [2] 42/9
67/19
Remuneration [2]
26/25 94/14
repeat [3] 62/20
64/13 96/16
repeated [3] 51/15
112/1 114/19
repercussions [3]
3/2 99/6 100/19
rephrase [1] 26/19
replicated [1] 102/10
report [9] 2/21 3/16
3/16 37/25 53/11 54/3
89/1 111/9 111/10
reported [2] 58/22
116/10
reporting [8] 39/17
41/2 43/9 64/9 74/7
74/10 74/15 112/1
reports [1] 57/21
represent [1] 86/20
representation [1]
66/3
representative [7]
59/15 60/9 74/12
81/16 86/11 86/16
95/4
representatives [1]
87/15
reputation [1] 21/5
reputational [2]
99/16 100/19
request [4] 3/4 57/8
57/17 57/23
requested [1] 3/10
requesting [1] 57/15
requests [2] 3/9 43/9
require [3] 9/23
11/22 81/25
(46) provided... - require
R
required [4] 9/3
12/18 22/20 76/6
requirement [2]
19/15 71/2
Rescheduled [1]
57/7
research [1] 1/24
resentment [1] 33/6
resetting [1] 42/14
resignation [1] 36/17
resignations [1] 31/1
resiling [1] 63/17
resistance [11] 28/19
29/1 29/11 33/8 33/18
33/22 34/11 34/16
35/5 41/2 79/21
resistant [2] 29/3
29/13
resolution [1] 96/19
resolved [2] 76/21
98/13
respect [5] 3/6 5/16
74/6 99/23 101/20
respectively [1]
64/20
respond [2] 3/11
39/12
responding [2] 3/1
104/23
response [5] 39/15
57/16 57/23 71/16
106/11
responses [2] 69/10
70/13
responsibilities [2]
14/6 100/5
responsibility [5]
8/15 14/4 26/4 27/12
89/3
responsible [6] 6/14
9/12 28/5 46/19 95/15)
110/20
responsive [1] 9/17
rest [2] 22/6 95/9
resting [1] 106/19
restraints [1] 20/18
result [3] 10/14 54/6
72/25
resulted [2] 51/2
57/10
resulting [1] 58/3
resume [2] 4/8 44/19
retail [1] 12/1
return [2] 101/12
110/6
returning [1] 105/25
review [17] 7/4 40/17
41/24 42/1 42/3 42/21
42/22 43/16 59/8
59/25 65/12 65/13
71/14 75/14 75/25
100/14 103/13
review/audit [1]
59/25
reviewing [1] 53/18
reviews [8] 74/11
87/25 88/19 88/20
88/24 88/24 88/25
89/11
Richard [1] 6/6
ride [1] 111/12
right [50] 1/9 5/25 6/7I
6/11 7/9 7/10 9/16
11/2 11/7 14/17 19/1
19/5 22/4 25/25 26/5
26/12 27/16 30/13
37/19 37/25 39/3
44/22 46/15 46/16
55/15 56/16 73/3 73/4
76/22 76/24 77/14
79/5 81/3 83/3 84/14
86/15 91/10 93/20
97/7 104/12 105/18
108/8 109/7 109/9
109/16 116/23 117/1
117/12 117/17 118/15)
right-thinking [1]
105/18
rightly [1] 42/22
rights [1] 26/10
rise [3] 15/24 19/16
88/7
risk [64] 15/25 16/9
17/9 21/17 21/18
27/21 45/5 45/12
45/14 45/18 46/1 46/7
47/10 47/11 55/15
55/15 55/16 55/18
55/22 55/23 56/1 56/4
56/6 56/7 61/19 61/24
62/3 62/4 62/10 62/11
62/12 62/13 62/16
64/2 64/12 64/14
64/15 87/24 88/19
89/10 92/9 92/13
92/17 93/1 94/1 94/14)
95/14 99/1 99/2
100/16 100/17 100/20)
100/22 101/2 101/3
101/5 101/9 101/11
106/6 106/25 108/11
112/13 116/19 116/21
risked [1] 35/12
risks [20] 16/7 45/18
46/6 46/13 46/18
46/21 54/17 55/17
55/21 55/22 55/25
63/15 63/15 71/19
74/13 91/12 92/15
98/17 98/19 106/4
RMG [8] 11/17 45/16
A7IN7 47/21 95/16
100/11 106/4 115/22
RMG's [2] 79/22
107/9
RMG/POL [4] 47/21
roadmap [1] 100/11
robust [1] 54/6
role [33] 7/15 7/20
7/24 11/14 11/18
11/21 12/4 12/7 12/24]
13/1 14/19 15/13
17/12 17/14 19/7
19/20 20/22 20/24
21/16 21/25 22/10
23/5 23/6 24/2 24/3
26/18 30/9 58/21
69/19 79/2 82/23
111/6 113/25
roles [8] 5/20 8/4
19/3 21/17 21/19
24/25 25/6 26/20
Rolfe [1] 111/21
rolled [1] 92/10
Rolls [1] 8/5
Rolls-Royce [1] 8/5
room [1] 97/3
roster [1] 115/15
rounded [1] 98/5
routes [1] 98/21
rowing [1] 68/1
Royal [86] 6/14 6/17
6/25 7/6 8/15 13/11
14/1 14/5 16/6 16/9
18/24 19/10 19/12
19/16 20/2 28/20 29/7
30/1 30/12 32/10 33/9
33/12 33/15 34/17
35/17 35/23 35/24
35/25 36/11 36/18
36/19 37/13 38/5
38/10 41/9 43/1 46/8
46/20 47/24 48/8 49/7
49/12 50/9 56/21
56/23 62/12 64/15
64/19 73/18 74/7
74/12 74/17 74/21
75/3 75/13 75/20 76/4
76/11 77/20 77/23
78/2 78/7 90/24 92/23,
95/4 95/6 95/20 96/1
98/25 100/4 100/7
101/10 101/11 101/14
103/5 104/18 105/15
106/18 106/20 107/5
108/21 108/22 108/23
109/5 109/12 110/21
Royal Mail's [1]
19/10
Royce [1] 8/5
rule [2] 37/15 67/14
Rule 10 [1] 67/14
run [11] 8/25 11/2
12/2 13/2 15/2 18/9
26/22 45/18 57/21
95/14 98/19
running [7] 3/13
12/20 26/4 32/23
66/22 89/6 89/21
rural [3] 11/19 12/11
12/21
Russell [2] 24/23
25/9
Ss
saddled [1] 107/9
said [20] 4/3 25/10
36/7 42/20 52/10
62/20 72/4 72/12
81/22 95/13 96/16
104/20 110/11 110/14,
111/9 111/10 111/13
111/16 115/2 115/22
sale [1] 50/12
same [4] 65/5 65/13
70/20 103/20
sat [2] 17/20 86/9
satisfactory [2] 40/1
40/3
satisfied [1] 26/14
satisfy [1] 78/11
saw [7] 18/10 20/23
28/13 57/3 72/20
111/20 112/10
say [64] 6/9 6/23 7/3
8/20 10/16 10/19
11/14 12/17 12/20
13/21 14/5 14/14
17/16 20/13 21/19
22/12 22/24 23/4
25/21 27/22 28/4 29/8
30/15 31/25 32/1
32/15 33/12 33/15
33/20 34/25 35/14
37/8 45/11 45/22
46/21 47/15 SO/7
54/25 56/18 61/17
62/12 66/1 66/7 70/13)
70/15 71/8 71/17 74/5)
74/19 79/15 79/19
82/14 87/12 88/8 88/9
89/17 89/22 90/16
91/3 93/3 93/23 95/22,
101/19 114/17
saying [6] 4/1 13/21
72/25 83/23 107/6
108/4
says [2] 39/25 52/25
scale [1] 6/25
scaled [1] 103/5
scandal [3] 90/20
99/24 99/25
sceptical [1] 114/9
scheme [8] 2/3 2/10
2/19 3/5 3/7 3/11 3/13
3/24
School [1] 8/9
screen [18] 8/16
17/15 20/4 23/2 28/2
29/25 34/24 37/24
45/10 50/6 52/17 56/9)
66/7 74/3 76/14 76/23
79/18 90/15
scroll [1] 91/23
scrolling [3] 60/13
60/17 96/10
scrutinising [1]
113/12
scrutiny [4] 110/22
112/15 112/22 114/11
se [1] 101/6
seat [2] 81/4 81/13
seats [5] 34/23 35/2
35/16 36/8 83/16
second [19] 2/1 9/7
20/10 39/6 46/2 51/25
54/3 57/19 60/20
60/21 62/4 71/13
80/18 88/16 92/9
113/16 113/21 114/17
116/6
secretary [12] 7/12
7/17 27/20 28/17
29/24 30/5 30/9 37/7
38/8 39/15 80/8 90/23}
section [4] 38/13
38/19 40/12 52/23
section 1 [1] 38/19
section 2 [1] 52/23
section 3 [1] 40/12
sector [3] 5/24 9/13
11/9
secured [1] 104/18
Security [2] 7/22
7/23
see [29] 1/4 29/1
29/11 30/8 38/11 39/1
39/3 43/13 44/22
48/24 51/10 52/2
54/16 56/25 60/14
63/9 63/19 68/6 76/14
76/18 77/4 85/4 87/5
87/6 91/24 102/17
105/12 116/1 118/15
seeing [2] 49/19
109/3
seek [6] 10/3 53/5
58/10 68/24 85/1
103/9
seeking [4] 23/11
37/11 41/17 70/3
seem [1] 59/19
seemed [2] 28/16
111/21
seems [5] 45/25
47/18 66/10 81/1
92/21
seen [12] 29/16
35/11 45/24 49/17
55/8 55/20 65/19 72/8
80/4 85/13 92/21
104/7
selected [1] 44/10
Send [1] 88/9
senior [10] 8/12 28/9
28/24 39/8 55/5 55/6
56/3 80/9 94/22 95/16
sense [8] 12/10
(47) required - sense
Ss
sense... [7] 69/22
75/8 78/1 78/14 81/9
98/5 117/13
sensible [2] 10/9
87/11
sensitive [1] 33/10
sent [3] 2/5 37/7
98/23
sentence [1] 52/25
separate [5] 3/24
25/6 25/18 64/9 64/18
separated [2] 76/5
96/8
separately [1] 25/1
separating [1] 65/7
separation [21] 7/5
13/11 13/18 19/25
33/21 35/25 47/18
61/20 74/7 75/19
75/21 76/10 77/16
77/19 78/14 93/15
93/22 93/24 100/11
109/10 109/14
September [4] 7/24
20/6 80/8 102/25
September 2009 [1]
102/25
series [2] 80/9 86/1
serious [3] 26/6
54/24 100/19
seriously [2] 85/20
85/21
servant [4] 16/18
88/3 99/12 117/21
servants [5] 18/6
18/6 24/7 24/10 95/16
serve [2] 34/3 80/22
service [1] 19/15
services [8] 11/20
11/20 11/25 19/13
100/10 102/11 102/14}
102/15
set [19] 9/6 9/8 11/5
11/6 14/21 14/24
18/12 18/14 18/15
25/2 42/18 53/1 53/4
59/7 59/21 63/24
65/13 65/14 113/8
sets [2] 60/14 97/4
Setting [1] 61/9
settled [7] 21/10
22/12 22/12 22/13
22/14 25/10 54/7
settlement [1] 40/8
several [2] 58/6
72/24
severe [1] 7/1
share [6] 2/25 32/12
78/3 82/17 82/22 84/3
shared [3] 31/3 31/17I
43/7
shareholder [118]
6/5 6/21 7/8 8/14 8/18
9/4 9/17 10/21 12/16
16/23 17/12 17/18
17/24 18/12 18/18
18/23 19/2 19/2 19/13
19/17 19/21 20/5
21/15 21/24 23/12
24/2 24/24 24/25 25/6
27/3 27/22 28/15
28/22 30/16 30/21
30/22 30/24 31/12
31/21 33/9 33/19
33/23 33/25 34/12
34/22 35/11 37/2
38/12 38/14 38/18
38/20 39/12 42/23
47/13 47/9 49/14 51/21
53/7 53/14 53/19 55/1
55/2 56/4 58/19 62/9
62/15 65/4 65/20 67/9)
69/6 69/6 69/25 79/16
79/20 80/6 80/25 81/4
81/15 81/22 82/23
83/6 83/16 85/10
85/11 85/12 85/24
87/15 89/4 89/6 89/7
89/20 90/3 90/5 90/7
90/9 90/12 91/14
92/23 93/5 94/23
95/13 97/18 97/24
98/1 98/14 98/15
98/24 101/6 104/6
105/7 106/3 112/20
114/14 115/9 116/8
116/11 116/22 117/20}
shareholder's [1]
81/18
shareholder/Board
[1] 30/16
shareholders [4]
86/7 86/11 97/21
113/23
shareholding [2]
8/23 56/16
sharing [8] 17/9
25/19 29/4 29/13
34/16 45/5 85/8 85/22
she [11] 34/1 80/9
80/10 80/10 82/17
83/8 83/11 85/13
90/11 104/24 110/8
ShEx [86] 14/12 16/4
16/12 17/18 17/22
19/2 19/7 20/12 20/14
20/24 21/1 21/8 21/13
21/15 23/5 23/6 23/25
26/14 28/5 28/20 29/1
29/2 29/5 29/12 29/14
29/18 35/2 35/15
35/22 35/23 36/19
37/25 43/7 45/14 46/8)
47/16 48/5 49/16
50/10 50/16 50/25
51/5 52/16 53/22
53/22 55/23 56/6
56/15 61/12 61/19
61/24 62/1 63/10 64/3)
64/4 64/18 65/9 65/11
66/21 68/24 69/19
69/20 74/11 74/17
75/18 77/21 78/3
78/16 78/21 79/13
80/3 80/15 80/22
82/17 83/22 85/9
85/23 87/23 90/22
100/20 100/22 106/5
115/4 115/7 116/20
116/24
ShEx's [9] 8/21 17/3
21/3 21/4 23/9 35/7
74/9 74/15 77/18
shift [2] 19/11 24/13
shoes [1] 73/25
shops [1] 10/14
short [3] 14/21 44/25
77/2
shortfall [5] 2/3 2/18
3/5 3/24 103/1
shortly [2] 3/4 50/24
should [56] 3/10 4/23
12/17 13/21 19/25
21/19 22/24 28/18
32/10 33/12 35/2
35/15 35/23 46/7
46/23 53/5 53/7 53/10
53/12 53/16 53/18
55/21 55/25 56/1 56/2,
56/4 62/9 62/10 62/11
62/12 64/7 64/12
64/13 64/14 66/13
67/6 68/19 71/18
71/22 72/6 82/2 84/20
90/21 91/1 91/25 93/5
94/5 94/10 95/17
98/20 100/22 101/8
101/10 108/2 113/2
113/3
shouldn't [2] 62/1
71/8
show [1] 71/9
shown [1] 101/24
shows [3] 42/10
45/13 61/11
side [5] 35/8 35/11
56/17 59/5 93/4
Sight [6] 51/25 71/13
113/16 113/21 114/17I
116/6
sighted [1] 98/16
sign [1] 89/1
signature [2] 5/4 5/6
ined [1] 22/2
significant [7] 11/22
11/24 32/6 32/12
75/15 91/15 98/17
signs [1] 42/10
simplistically [1]
109/3
simply [9] 11/3 12/9
49/5 68/6 71/21 86/5
109/6 113/7 115/2
since [8] 8/4 42/1
54/1 54/2 60/25 110/4I
117/14 117/21
single [1] 69/11
singular [1] 96/8
sir [55] 1/4 1/10 4/10
4/11 4/13 4/16 5/12
5/13 8/17 17/15 23/3
28/3 34/24 37/18
37/23 44/16 44/21
45/2 45/4 74/4 76/13
76/16 76/20 76/25
77/4 77/7 77/15 79/19)
83/20 84/1 90/16
91/24 97/1 97/2 97/8
97/10 103/18 104/15
105/25 109/1 109/16
109/20 109/24 109/24}
110/2 116/14 116/16
116/17 116/25 117/7
118/7 118/8 118/14
119/4 119/13
Sir Mike [1] 104/15
Sir Stephen [18] 4/11
4/13 4/16 5/13 45/4
77/15 83/20 91/24
97/2 97/10 103/18
109/20 109/24 110/2
116/14 116/17 118/8
119/4
Sir Stephen's [9]
5/12 8/17 17/15 23/3
28/3 34/24 74/4 79/19
90/16
Sir Wyn [3] 84/1
116/25 117/7
sit [2] 17/22 86/7
sitting [1] 75/9
situation [13] 51/10
52/4 62/9 70/23 76/5
83/24 84/17 88/5
89/24 108/16 115/14
116/13 117/10
situations [4] 21/2
21/22 22/6 86/18
six [3] 19/15 56/19
56/25
size [8] 11/23 12/15
12/17 12/19 18/19
22/7 41/17 79/9
skills [3] 9/16 11/2
75/22
Slaughter [2] 106/22
107/18
slightly [6] 22/2
24/21 27/11 68/19
81/15 111/19
slow [5] 30/25 31/15
33/7 42/16 112/8
slowly [1] 40/8
small [2] 5/23 116/7
SMR [1] 8/5
so [98] 1/8 3/8 3/11
4IT 11/4 12/11 14/21
16/3 17/1 18/3 18/21
19/18 22/2 23/17 24/9)
24/15 30/4 32/14 33/1
35/4 36/12 36/15
36/23 37/7 37/11 38/7
38/17 38/18 41/21
42/5 43/2 44/2 44/19
46/4 47/7 47/14 48/19
49/2 49/15 49/22 51/8
52/20 53/21 58/12
58/25 63/11 64/2 64/6
66/15 68/13 70/3
70/19 71/15 73/11
73/23 74/20 75/1 75/2I
75/9 76/21 76/23 79/2I
79/23 82/6 83/8 87/3
88/10 89/9 89/11 90/7I
91/19 91/24 91/24
94/6 95/15 97/12 98/8
101/3 102/12 102/17
103/11 103/18 104/9
107/1 107/6 107/23
108/2 109/10 109/20
111/16 114/13 117/2
117/12 117/13 117/19}
118/5 118/8 118/12
social [9] 11/14
11/18 12/4 12/6 12/11
12/24 13/1 13/18
15/13
socialise [3] 46/1
46/13 54/17
socialised [2] 55/18
88/15
software [1] 67/20
sold [4] 10/15
sole [1] 35/4
Solicitors [1] 110/3
solo [1] 96/9
solvent [1] 32/7
some [43] 2/18 3/19
11/1 17/21 21/3 22/8
25/14 28/20 30/18
32/16 32/22 38/12
38/21 39/14 39/22
40/9 40/15 41/4 42/10
42/19 48/16 49/19
50/2 50/13 50/20
53/23 55/10 57/4
59/19 63/24 63/25
64/23 68/19 73/19
73/25 75/8 78/5 80/11
80/19 93/3 95/3 97/2
117/11
somebody [2] 36/1
115/21
someone [1] 95/17
something [16]
24/10 34/17 36/7 48/2I
48/17 52/4 56/5 70/5
(48) sense... - something
Ss
something... [8] 71/4
77/23 77/25 108/9
111/10 115/2 115/6
116/1
sometimes [5] 14/13
17/7 28/16 65/20
98/13
sophistication [1]
112/19
sorry [4] 49/9 67/14
88/16 110/7
sort [14] 23/1 27/24
32/1 65/5 73/1 73/21
81/9 81/17 98/1
112/12 112/19 114/25
115/14 116/4
sought [2] 69/15 79/8)
sounds [1] 68/4
source [2] 68/7 117/2I
speak [2] 2/12
104/20
special [2] 47/25
48/20
ialised [1] 11/1
ing [1] 5/23
t [1] 118/41
specialists [1]
112/19
specific [7] 5/16
16/16 17/2 83/8 93/15}
101/9 115/3
specifically [9] 2/23
37/17 44/1 63/3 89/3
96/21 102/23 113/4
117/5
speculate [3] 19/23
62/21 63/8
speculation [3] 36/13)
51/8 52/14
spent [2] 89/5 106/13
SPMs [1] 105/10
spoken [1] 66/15
Sport [1] 6/11
spreadsheet [1] 38/6
spring [1] 80/6
squib [1] 108/12
staff [2] 12/21 13/2
stage [2] 58/11 116/6
stages [2] 81/23 92/5
standard [2] 27/9
116/13
standards [4] 91/7
91/9 93/17 94/8
start [6] 1/5 5/19
17/16 21/8 22/24 93/7
started [3] 37/20
90/2 98/9
starting [5] 8/19
28/24 59/18 74/5
90/18
starts [1] 93/2
state [14] 28/17
29/24 30/5 30/9 37/7
38/9 38/11 39/16
62/17 90/23 96/23
104/22 110/9 114/7
stated [2] 21/8 44/7
statement [54] 4/22
4/23 5/8 5/12 5/13
5/16 5/22 6/23 8/17
11/12 13/12 13/16
14/5 14/10 17/15 20/9)
21/22 23/3 25/21 26/7
28/3 29/23 33/15
34/24 38/3 45/9 47/14)
48/20 50/5 52/17
52/21 56/14 56/18
61/17 63/25 64/11
64/17 64/24 66/1 66/6
68/6 74/4 75/17 79/19)
80/5 81/23 87/20
90/14 90/16 95/22
101/19 113/25 117/4
118/9
status [1] 11/16
statutory [2] 47/25
48/21
stay [2] 19/21 87/4
stayed [1] 6/24
step [1] 3/8
Stephen [21] 4/11
4113 4/16 4/17 5/13
21/5 21/8 45/4 77/15
83/20 91/24 97/2
97/10 103/18 109/20
109/24 110/2 116/14
116/17 118/8 119/4
Stephen's [10] 5/12
8/17 17/15 23/3 28/3
34/24 52/5 74/4 79/19
90/16
stepped [1] 7/24
steps [3] 35/22 36/1
66/8
still [8] 2/13 40/9
42/7 43/6 43/13 77/9
82/7 107/1
Stock [1] 78/9
stolen [1] 48/10
stop [1] 86/4
Storey [3] 29/19
82/15 90/2
stories [2] 4/1 105/19}
story [2] 59/5 102/23
straightforward [3]
31/18 70/12 82/11
strained [1] 40/20
strange [1] 22/2
strategic [3] 16/14
99/5 99/10
strategies [1] 53/17
strategy [9] 6/24 8/2
14/22 14/23 17/4
41/12 53/18 54/22
59/24
strength [6] 41/10
43/15 43/25 85/8
85/22 86/6
stress [1] 109/8
stressed [1] 75/12
string [1] 10/14
strive [1] 30/23
strong [8] 36/15
40/14 40/19 40/23
41/5 41/11 43/17
43/23
strongly [1] 84/6
structure [2] 16/1
25/20
structures [1] 91/6
stuff [1] 92/18
sub [2] 59/2 60/5
subject [2] 108/20
112/9
submission [23]
29/23 30/1 30/3 30/4
30/6 30/11 37/6 38/8
42/11 42/20 50/24
56/10 57/3 62/2 63/9
66/5 68/17 70/23 72/8
73/11 80/3 88/8 88/9
submissions [5] 36/3}
51/11 87/21 88/2
88/17
subpostmaster [2]
3/22 51/2
subpostmasters [27]
1/15 2/1 2/11 12/20
46/3 47/4 47/13 48/14
50/17 51/6 54/9 57/11
59/15 60/8 60/18
66/12 67/2 68/1 71/2
71/20 99/7 99/22
101/20 103/9 104/2
106/17 110/4
subpostmasters' [5]
54/13 59/22 62/23
66/11 66/24
subsequent [5] 46/5
47/6 51/20 67/15
113/17
subsequently [3]
46/20 82/15 117/21
subsidiary [10] 6/15
11/17 13/10 13/14
13/23 15/14 22/21
95/23 95/24 96/3
subsidy [2] 11/22
12/18
substance [1] 83/9
substantial [2] 58/5
59/22
substantive [1] 59/6
substitution [1]
74/25
success [1] 107/4
successful [3] 18/23
18/24 42/14
such [14] 1/14 2/22
3/16 5/15 9/19 12/22
19/14 35/17 48/3
48/22 49/20 67/17
102/15 116/24
suffering [1] 4/4
sufficient [2] 46/17
96/13
sufficiently [2] 56/3
106/12
suggest [2] 94/9
108/1
suggestion [2] 32/22
68/7
suggestions [1] 61/6
suitable [7] 27/8 27/8
40/14 40/19 40/23
41/5 43/22
summarise [1] 13/15
summarised [1] 59/9
summarising [1]
70/24
summary [1] 38/17
sunk [1] 74/23
supplementary [1]
13/13
support [2] 36/25
103/9
supported [2] 51/18
62/23
suppose [3] 108/5
108/9 109/13
supposition [3]
107/23 107/24 108/3
sure [18] 3/17 9/15
16/15 20/3 24/16
32/20 36/5 36/21
67/11 79/5 81/16
84/13 87/10 90/10
94/2 94/20 115/23
4117/1
surely [2] 108/9
108/10
surface [1] 93/14
surprise [1] 66/15
surprised [4] 48/13
106/17 110/24 115/8
surprises [1] 54/21
surprises' [2] 39/19
53/13
surprising [1] 55/9
survey [4] 1/25 2/1
3/25 3/25
surveys [9] 1/25 2/5
2/6 2/15 2/23 3/1 3/14
3/20 4/6
survive [1] 75/3
Susannah [7] 29/19
82/15 83/6 83/8 90/2
90/6 90/9
suspect [3] 94/6
107/14 110/15
sustain [1] 28/5
sustainable [1] 74/21
system [30] 46/2
50/4 50/12 50/18 51/1
54/10 54/17 57/10
58/3 59/12 60/6 60/16I
61/18 66/14 66/18
67/19 70/25 71/5
71/20 73/4 73/5
101/21 103/4 103/8
103/10 103/13 103/15)
103/17 112/16 112/24)
systematic [1] 60/2
systemic [5] 58/3
61/13 62/4 72/6 73/4
systems [7] 91/8
94/7 94/9 94/11 96/13}
96/17 96/22
T
tab [2] 38/5 38/6
tab 27 [1] 38/6
table [2] 33/4 38/19
tabled [1] 58/7
tack [4] 111/19
Tactically [1] 58/10
take [22] 4/7 14/11
35/22 36/1 36/8 53/23}
60/12 68/21 68/23
70/22 73/12 76/7
85/20 86/24 88/6
94/24 105/25 111/19
117/5 117/7 117/13
118/5
taken [20] 42/5 46/11
51/14 52/12 56/2
60/18 62/6 63/6 63/20
71/1 73/19 75/16 76/2I
83/16 83/21 85/6
85/20 111/12 113/2
114/22
taking [10] 3/8 30/21
34/23 35/2 35/16 38/2I
48/4 54/15 68/6 113/7)
talk [2] 16/16 98/20
talking [8] 21/24
29/21 36/22 46/18
55/4 77/15 78/7
106/13
talks [1] 24/8
tandem [1] 104/3
task [2] 26/15 96/23
tasks [1] 118/2
taxpayer [1] 23/10
team [36] 6/3 19/13
19/14 25/23 28/24
29/3 40/13 41/10
41/11 42/2 43/16
43/25 44/6 45/13
47/16 51/13 56/16
56/18 56/21 57/1 65/2I
65/3 65/5 67/9 80/3
82/17 83/6 83/9 83/14
85/9 85/23 90/9 90/12!
95/16 97/6 115/22
teams [5] 8/24 25/16
28/7 28/9 64/18
technical [7] 111/14
(49) something... - technical
T
technical... [6]
112/22 113/12 115/3
115/4 115/6 115/8
telephone [2] 3/21
88/11
tell [2] 102/22 116/23
ten [1] 102/20
tension [3] 30/18
98/11 98/13
tenure [4] 61/21
71/13 100/2 105/14
terminals [1] 54/13
terminated [1] 57/11
termination [1] 51/2
terminology [2]
14/15 39/3
terms [12] 16/15
23/11 23/19 27/11
46/4 50/4 51/4 59/21
63/11 68/24 77/18
95/24
terrible [2] 99/17
99/17
territory [2] 73/13
84/10
texts [1] 88/12
than [24] 14/12 17/1
22/19 24/2 24/21
27/24 33/13 37/1 43/4
43/14 50/23 60/4 73/1
78/7 81/12 84/14
89/19 89/21 90/8 93/6
100/8 107/19 110/12
113/3
thank [20] 4/10 4/20
33/14 37/23 44/15
44/23 55/14 64/16
69/17 75/17 76/25
77/5 97/7 97/8 109/24,
116/14 118/4 118/8
118/11 118/16
thanks [1] 4/6
that [779]
that's [40] 6/1 6/4 6/8
6/12 6/16 7/2 7/10
10/4 14/9 19/10 23/3
26/18 28/3 29/8 30/14
37/19 38/7 52/21
56/17 61/16 66/4
70/22 76/22 83/11
90/16 99/15 99/15
99/25 100/7 101/22
107/23 108/13 108/14}
109/21 110/14 111/1
111/12 113/14 117/1
118/7
theft [4] 48/12 48/16
58/4 103/2
theft/false [1] 58/4
their [22] 1/20 2/25
3/6 12/21 42/18 45/15)
54/13 57/11 62/25
66/12 73/24 83/15
83/18 88/24 94/3
94/19 96/19 99/2
102/22 104/2 105/22
110/5
them [21] 3/6 11/2
27/19 34/2 36/4 42/19
45/16 46/19 46/21
54/9 54/11 66/4 66/16
76/10 79/14 84/25
97/13 102/15 102/20
106/8 107/9
themselves [7] 16/18)
46/21 49/21 87/9 99/1
112/23 113/23
then [47] 6/2 6/6 6/13
8/1 18/9 20/21 22/11
22/25 24/15 26/6
35/14 37/7 38/15
39/18 41/3 41/4 41/18
42/1 42/21 43/24
44/22 46/20 57/14
57/22 58/15 59/18
60/16 65/12 69/24
72/3 84/24 85/6 86/3
87/4 88/10 92/15 93/3
94/19 94/23 97/6
103/14 106/19 107/22)
109/12 114/15 117/3
118/15
there [191]
there's [10] 32/21
39/9 70/4 87/3 95/1
95/19 106/7 109/11
109/14 109/19
thereafter [1] 19/9
therefore [7] 13/5
21/3 45/19 91/5 101/3
102/12 107/6
these [44] 1/23 2/5
2/15 2/23 11/10 17/6
18/2 20/4 20/8 21/20
26/14 35/5 36/24 37/4
37/5 37/11 42/17
43/18 49/15 51/10
51/11 59/21 60/20
61/2 61/7 63/10 67/21
72/8 75/8 79/1 80/11
80/12 81/24 85/4 87/7
87/12 94/4 94/11
96/11 96/18 96/18
103/18 108/13 112/11
they [82] 2/6 2/16
3/15 5/10 8/24 10/23
14/3 16/19 16/19
16/20 16/21 18/10
21/21 24/11 24/20
26/25 27/16 28/10
28/10 28/11 28/13
28/17 34/4 37/7 37/12
47/4 47/6 48/14 49/4
49/21 53/7 53/8 56/3
59/10 62/25 63/12
64/2 64/12 64/13
64/14 65/5 65/13
67/11 71/8 73/2 73/25
76/8 77/22 77/25
79/14 80/21 81/25
84/24 84/24 86/9
87/10 87/16 88/6
89/18 89/18 89/19
89/20 89/21 89/22
89/23 92/11 93/25
95/5 97/21 99/18
103/24 105/11 106/23
107/1 107/3 108/16
112/7 112/8 112/8
114/22 115/19 117/5
they're [3] 84/11
87/12 99/17
thing [10] 2/11 10/9
29/21 54/25 70/2
85/21 88/12 111/1
111/12 115/20
things [28] 17/7
19/14 27/19 32/21
32/25 37/4 37/5 52/9
64/2 64/7 68/4 73/25
75/8 76/8 76/10 78/22
79/1 89/9 92/12 92/14
93/21 93/23 94/1 94/4
94/6 96/18 96/18
108/14
think [114] 10/7 10/8
22/3 22/12 22/19 24/4
24/10 24/18 25/14
27/7 29/15 32/15
32/22 33/11 33/24
34/1 34/10 36/23 37/5
37/8 37/8 38/3 42/10
42/19 42/24 43/19
44/11 44/11 46/16
46/16 47/1 49/18
49/22 51/13 52/20
55/11 55/24 57/3 62/8
62/13 63/4 63/5 64/20
64/24 64/25 65/5 65/6
65/18 67/12 67/13
67/24 70/7 71/6 71/7
71/9 71/17 72/3 74/19
77/12 80/13 81/7 83/1
83/3 83/11 83/12
83/14 83/18 83/23
84/21 88/23 88/25
89/13 89/17 89/22
90/6 92/20 92/25 93/2
93/8 93/23 94/23 96/2
96/6 96/7 97/4 97/6
97/10 97/17 98/6
98/11 101/6 105/18
106/10 106/10 106/13}
107/4 107/12 107/14
108/7 108/8 108/13
109/16 110/11 110/14]
112/18 113/1 113/14
113/14 113/17 113/20
113/24 115/17 115/24
116/6
thinking [7] 19/24
33/5 62/18 74/1 89/5
105/18 109/2
third [7] 39/11 54/8
80/20 81/20 92/9
112/9 112/16
third-party [1] 112/9
this [170]
those [70] 1/19 2/2
2/4 2/24 3/21 4/5 4/7
13/5 14/16 14/17 16/3}
16/6 18/15 25/15
38/18 42/5 46/6 46/13,
49/22 50/2 51/17
51/17 52/1 52/9 53/9
53/20 54/15 55/7
55/10 55/11 62/13
63/5 63/13 63/15 65/7,
66/21 69/5 71/3 71/24
72/18 73/3 73/16 75/4
76/8 76/9 78/22 82/9
85/13 86/14 86/18
88/17 88/21 91/9
93/21 93/23 94/9
94/17 95/14 96/24
97/1 103/19 105/3
105/9 105/21 109/17
110/17 113/18 113/19}
113/21 117/5
though [8] 17/21
18/14 37/15 54/25
63/24 65/1 66/10
112/5
thought [11] 34/4
35/3 48/17 52/3 64/23
84/24 85/2 85/5 90/11
99/14 108/5
thousands [1] 99/22
threat [1] 81/2
threats [1] 31/1
three [6] 5/24 30/19
34/1 45/10 74/5
103/14
throats [1] 32/2
through [31] 16/25
20/14 26/25 27/23
35/2 36/5 37/4 41/21
47/10 47/10 52/13
60/12 65/10 69/11
73/21 76/7 78/23 79/6
79/7 91/10 92/23
92/23 94/23 96/1
98/20 98/21 102/13
105/22 108/17 112/4
115/5
throughout [3] 65/11
100/2 114/18
Thursday [1] 57/8
tick [1] 43/20
tight [1] 43/2
tighter [1] 24/20
tilt [1] 23/9
time [59] 4/3 4/3 4/7
6/17 10/8 19/1 19/22
20/3 22/20 23/14
24/17 24/18 28/8
29/18 31/22 31/23
32/14 32/19 35/24
36/19 40/22 42/23
43/11 50/8 50/15
52/12 53/22 57/4 60/1
62/18 63/18 65/23
66/25 69/11 69/14
70/2 71/7 71/24 72/19}
73/18 75/5 75/18 79/8I
82/21 83/4 87/8 89/5
90/7 92/3 93/14 93/22I
99/1 101/5 101/8
105/23 106/13 110/20)
112/3 116/4
times [3] 15/8 30/19
117/18
timing [1] 23/20
title [1] 30/1
today [4] 4/20 4/22
37/21 89/21
today's [1] 110/18
together [2] 42/5
101/15
token [1] 103/20
told [6] 44/9 49/17
66/12 76/20 84/10
92/14
tomorrow [1] 118/12
too [6] 3/3 23/9 84/5
109/3 112/7 112/8
took [3] 20/6 66/8
112/25
top [3] 75/21 95/13
116/25
topic [3] 34/22 44/16
110/6
topics [1] 2/6
totally [1] 27/25
Tote [1] 10/10
towards [8] 8/17 14/7
16/24 23/3 29/18 90/7)
90/14 97/21
town [1] 86/13
trade [7] 22/11 22/22
51/18 62/23 62/25
66/11 95/3
trade-offs [2] 22/11
22/22
traffic [4] 38/13
74/10 88/23 89/10
trail [4] 67/18
training [2] 16/11
16/16
transcript [3] 5/11
110/17 110/18
transferred [1] 19/8
transmission [2]
82/10 82/24
treat [1] 1/15
treated [2] 3/15 13/6
tried [2] 30/20 113/4
trodden [1] 87/7
(50) technical... - trodden
T
trouble [1] 4/7
true [1] 5/8
truly [1] 41/21
trust [4] 8/7 62/25
66/21 81/25
trusting [1] 31/18
truthful [2] 66/20
69/4
try [6] 18/3 22/10
27/9 36/1 87/1 88/4
trying [5] 22/5 27/24
31/11 63/18 101/25
tucked [1] 30/8
turn [5] 5/1 8/14
110/10 110/16 111/23
turning [1] 44/17
turns [1] 76/9
twice [1] 57/15
two [23] 1/25 3/24
21/17 21/18 30/10
30/18 38/8 41/11 42/8
45/8 46/6 46/13 55/16)
56/23 59/3 62/13 65/7,
72/3 88/1 97/4 106/10)
107/6 116/17
type [6] 24/4 27/23
38/16 94/12 108/1
117/11
types [8] 11/8 14/11
27/19 43/14 46/18
81/11 105/19 118/2
typically [7] 10/2
10/21 11/5 18/7 87/1
112/8 112/10
U
UK [1] 78/25
UKGI [3] 90/22 115/9
115/15
UKGI00000062 [1]
56/9
UKGI00001339 [1]
20/4
UKGI00016739 [1]
106/2
UKGI00017395 [1]
37/24
UKGI00019859 [1]
111/25
UKG100044314 [4]
52/18
UKG1I00045962 [1]
30/1
ultimately [10] 7/4
18/15 32/12 51/24
71/12 75/16 79/1 89/3,
95/5 114/17
Um [1] 92/3
unable [1] 105/7
unaware [2] 51/5
53/22
unbelievable [1]
106/21
uncommon [1] 87/13
undeniable [2] 61/16
62/8
under [16] 2/2 6/6
20/11 23/25 24/4
38/13 40/13 42/2
49/10 57/5 57/14
59/18 60/21 63/13
101/17 115/21
undermine [1] 82/19
undermined [1]
85/24
undermines [1]
82/23
underneath [3] 30/8
56/22 58/9
understand [8] 37/11
50/20 81/6 81/8 82/5
82/16 88/18 113/4
understanding [5]
3/23 12/4 72/17 83/7
109/4
understood [6] 5/18
17/3 50/11 66/4 79/22
91/11
undertaken [3] 40/7
41/13 112/23
undertaking [3] 41/9
44/5 78/13
undertook [1] 80/9
undoubtedly [1]
108/19
unfortunate [1] 83/11
unhappy [1] 84/11
unhelpful [3] 28/1
85/3 98/12
unhelpfully [1] 69/23
union [5] 51/18 62/23
63/1 66/11 95/3
unit [1] 53/17
units [2] 41/7 43/24
universal [1] 19/15
University's [1] 8/9
unknowable [1]
64/25
unknowing [1] 102/2
unlawful [1] 100/18
Unless [1] 108/14
unlikely [2] 88/23
108/14
unreliable [2] 62/6
115/1
unreservedly [1]
100/16
unrest [1] 75/1
unsafe [1] 62/5
until [8] 7/9 7/15 7/20
7/21 8/2 37/19 42/3
118/18
unusual [2] 11/15
83/23
unusually [1] 13/17
unwelcome [1] 35/11
unworthy [1] 105/10
up [33] 11/5 11/6
18/12 22/11 26/15
27/13 37/6 49/4 50/19}
56/19 56/21 56/25
59/7 75/11 81/23
86/21 91/23 92/22
93/3 93/6 93/16 94/5
94/16 96/5 96/18
96/18 96/23 98/20
110/17 111/23 115/2
115/5 115/16
updates [1] 67/20
upon [3] 5/22 67/9
117/19
upwards [1] 55/19
urge [2] 3/10 4/5
us [12] 1/4 15/3
18/16 27/22 44/9
76/16 77/4 77/9 84/10
108/5 108/9 109/21
use [2] 14/25 102/15
used [8] 28/9 28/11
50/1 60/6 68/8 70/1
115/11 118/1
using [6] 15/2 31/15
39/3 46/3 47/13 89/8
usually [2] 17/19
26/8
Vv
valuable [1] 3/17
value [3] 12/11
112/25 113/2
variety [2] 10/11 61/6
various [9] 25/12
30/19 47/11 81/23
89/10 92/5 92/22
106/4 106/22
vastly [2] 61/22
62/14
verge [1] 32/5
very [76] 10/7 10/21
10/25 10/25 11/1
12/14 17/6 22/7 22/21
26/6 28/12 32/6 32/8
32/8 32/11 42/21
47/20 48/18 58/11
62/21 63/4 63/16
64/11 68/3 69/13
69/13 71/25 73/23
74/1 74/19 75/1 75/1
75/12 75/12 75/14
77/10 77/14 81/17
81/17 82/12 83/15
84/11 84/11 85/20
85/21 86/7 86/7 87/7
87/13 90/6 90/10 92/6
92/6 92/10 96/8 98/7
99/19 100/3 100/3
107/14 107/16 107/16
108/14 109/24 113/14
114/9 114/18 114/18
114/19 115/10 115/16
117/9 118/4 118/8
118/10 118/11
via [2] 3/20 90/5
victims [1] 58/2
view [14] 1/19 9/3
14/14 25/5 31/16 35/1
35/15 52/12 60/2
66/12 68/18 86/24
87/14 114/22
views [2] 27/6 81/18
Vince [2] 80/6 80/24
virtue [1] 85/12
visible [1] 5/4
vision [1] 31/3
visions [1] 32/9
Visiting [1] 8/9
vital [2] 11/18 15/15
volume [4] 49/18
71/24 72/17 72/18
Wo
waive [1] 2/22
want [11] 2/4 3/3
32/1 34/3 42/9 42/21
52/6 101/12 101/24
110/6 110/10
wanted [10] 9/10
18/13 18/21 22/17
27/3 32/11 36/4 43/13
65/24 84/9
wants [1] 103/17
warning [1] 39/23
warrant [1] 63/7
wary [2] 67/9 68/20
was [324]
wasn't [17] 15/23
32/3 32/13 34/19
48/17 48/17 50/3
51/11 62/18 65/14
67/5 71/2 73/12 75/1
97/12 104/5 112/10
wasted [1] 37/9
wasting [1] 69/13
watch [1] 102/19
way [27] 2/15 8/25
13/16 15/8 18/5 21/20}
42/3 47117 47/22
54/23 54/25 68/19
70/20 79/10 80/19
81/17 81/18 83/15
83/18 87/11 87/24
88/20 88/24 92/6
92/11 93/6 104/10
ways [2] 25/14 78/6
we [179]
we'll [2] 44/19 76/16
we're [6] 21/23 37/3
46/18 98/19 99/25
100/15
we've [4] 23/18 38/9
65/19 72/8
wearing [1] 69/13
website [1] 5/14
week [2] 3/19 111/19
Weekly [6] 50/14
101/23 102/6 102/19
103/23 104/8
weeks [1] 67/22
weight [1] 97/25
well [54] 2/12 9/5 9/8
9/13 11/20 12/13
12/21 14/2 16/10
26/18 31/14 31/22
33/20 34/5 37/3 43/17
43/20 46/25 51/20
52/3 52/10 52/13
53/14 60/5 62/16
64/15 64/25 65/2
68/22 69/9 69/13
71/12 72/4 72/20 73/2
82/7 85/6 87/7 88/1
88/8 91/17 97/17
99/10 101/4 101/11
102/13 104/23 105/2
105/22 105/25 108/19)
109/19 112/3 112/18
well-founded [1]
69/9
Wellcome [1] 8/7
went [8] 20/14 20/22
51/23 65/23 65/23
71/7 71/10 87/23
were [198]
weren't [10] 18/23
18/24 37/12 49/21
65/13 69/4 75/9 79/14)
112/8 112/18
what [58] 1/16 9/3
9/19 10/2 16/11 18/3
20/1 24/15 27/9 31/12I
31/20 32/21 33/3
33/21 34/10 38/16
42/15 43/15 44/9 46/3
47/7 50/20 51/15 52/3)
52/24 55/8 55/20
59/19 60/14 62/20
65/23 66/8 72/11
72/16 72/17 78/20
79/21 83/14 87/22
87/23 88/5 88/18
88/20 91/22 96/16
98/5 98/9 103/25
105/3 105/22 107/25
110/14 111/9 111/16
113/4 113/16 114/9
115/11
what's [2] 76/15
76/23
whatever [1] 75/10
whatsoever [1]
106/18
when [42] 2/17 3/1
TINT 7/21 15/8 16/17
19/11 20/25 21/13
24/10 28/8 28/25
33/20 35/4 48/4 53/22)
63/10 70/4 72/5 78/21
79/13 80/7 82/21 83/4
(1) trouble - when
Wo
when... [18] 86/9
87/3 87/23 89/2 89/19
89/21 90/2 91/2 92/1
92/8 96/7 98/8 104/23
112/15 114/24 115/20)
116/20 116/24
where [40] 5/24 9/9
11/1 15/12 17/20 18/6}
18/22 19/7 21/2 21/15)
21/22 21/22 22/10
29/8 36/6 37/16 38/2
42/11 47/6 55/12 65/8
70/5 70/23 71/3 73/2
78/10 80/16 80/22
85/4 86/22 91/16 95/2
95/24 102/11 102/14
113/8 114/4 116/6
117/10 118/2
whether [33] 9/20
18/17 26/2 27/15
27/17 35/23 40/18
49/5 55/5 56/3 58/11
58/22 67/17 67/18
68/16 73/16 74/21
83/3 84/22 85/17
86/24 93/25 96/4
96/21 96/23 98/18
98/25 111/22 113/1
113/3 113/18 113/21
113/22
which [101] 1/22
2/22 3/9 3/14 4/22
5/17 5/20 7/4 8/17
9/11 10/11 10/11 11/9
12/15 14/12 14/16
14/17 15/8 15/24
16/13 16/15 17/10
17/25 18/1 18/12 20/6)
20/7 20/12 21/4 22/1
22/3 22/19 24/6 25/9
26/24 27/11 28/10
30/6 31/16 32/4 34/17
35/17 36/15 37/6 38/9
40/9 40/12 43/16 44/3)
46/21 48/2 48/8 48/23
50/8 50/25 51/21
51/22 52/7 53/1 55/17
56/6 58/3 61/25 62/20
64/2 67/15 67/21
67/23 67/24 73/6
73/20 74/18 74/23
75/13 75/25 83/17
83/24 85/19 86/2
86/19 87/17 88/14
89/10 89/15 92/6
92/24 94/1 96/13
96/16 98/11 98/22
98/23 103/21 104/10
105/1 107/15 108/6
111/14 112/17 112/22}
117/14
while [4] 12/16 34/22
80/4 101/10
Whitehall [2] 10/24
11/4
Whitehead [9] 56/11
56/15 61/10 62/1 63/2
66/2 67/8 68/8 68/19
who [32] 1/19 2/2
2/24 3/21 4/5 4/7
16/24 17/12 17/13
18/9 18/14 24/23
25/16 27/15 33/2 34/3
43/3 44/4 44/9 47/3
49/3 49/19 55/3 58/8
63/10 66/22 68/12
83/22 86/12 97/11
110/4 115/13
whole [8] 18/3 18/13
18/21 19/1 19/12 62/8)
111/13 114/21
wholly [2] 11/17
18/24
whom [2] 2/4 63/23
whose [1] 86/13
why [9] 10/18 17/23
19/20 20/2 37/13
46/21 75/13 86/5
99/25
wide [1] 12/14
widely [4] 49/23
49/23 49/24 92/10
Widening [1] 85/15
wider [2] 16/14 53/8
will [29] 1/12 1/14 2/5)
2/16 2/19 3/4 3/14
3/16 3/17 3/19 3/24
4/2 4/18 5/14 5/15
20/18 30/17 34/6
50/24 52/6 58/25 86/3
86/4 86/17 105/3
107/16 109/8 115/24
115/25
WILLIAMS [2] 116/16
119/13
willing [4] 13/2
willingness [1] 78/2
wish [4] 20/8 56/14
63/16 104/20
within [17] 2/9 5/17
9/1 9/25 10/24 11/4
19/17 19/21 25/19
30/23 35/6 45/14 47/9)
65/9 89/6 112/20
115/4
without [7] 2/20 2/25
3/1 13/1 30/21 54/13
100/15
WITN11010100 [1]
5/12
witness [9] 4/21 4/23
5/13 64/11 91/20
101/18 113/25 117/4
118/9
witnesses [2] 49/19
93/7
Wolstenholme [1]
54/5
women [1] 114/8
wonder [2] 37/18
44/17
word [1] 31/9
words [4] 13/1 102/2
105/7 107/9
work [10] 2/14 4/21
11/10 22/25 27/23
30/22 32/19 81/25
117/14 117/21
workable [1] 24/16
worked [4] 5/23 6/2
6/10 96/1
working [7] 6/3 6/6
8/23 28/6 77/11 92/22
116/1
world [3] 19/25 92/11
117/10
worry [1] 117/2
would [214]
wouldn't [16] 19/23
20/1 21/20 21/21 27/8
31/25 42/9 48/13
72/10 75/6 75/7 79/8
84/25 85/15 99/24
115/11
write [2] 63/9 107/25
writing [1] 3/4
written [5] 21/21
57/15 58/6 58/7 75/14
wrong [6] 47/11
51/16 63/8 71/5 84/14
92/12
wronged [1] 51/23
wrongful [7] 46/5
51/2 58/3 62/5 100/17
104/17 104/18
wrongly [3] 57/11
99/8 99/22
wrote [1] 68/12
Wyn [5] 84/1 116/16
116/25 117/7 119/13
Y
yeah [6] 7/19 40/24
52/22 72/23 73/10
108/8
year [3] 40/10 40/16
72/3
years [10] 5/25 26/24
30/19 35/7 35/15 38/8
42/8 50/13 50/20
105/20
yes [95] 1/5 1/10 4/12
5/3 6/22 7/7 7/14 7/16
7/19 7/23 7/25 8/6 8/8
8/11 8/13 10/1 12/8
12/25 13/9 13/21
15/11 15/17 15/22
16/2 17/6 19/4 21/19
23/21 23/24 25/4 25/7
33/11 37/22 37/22
38/1 38/4 38/15 38/17
38/25 39/9 39/14 40/2
40/14 40/18 40/25
41/16 43/18 44/11
44/19 44/20 44/21
45/7 52/20 55/20 56/8
56/21 63/22 64/5
64/11 65/12 71/25
72/4 72/25 73/8 75/5
76/13 76/25 77/5
77/10 77/12 77/22
77/25 79/24 80/1
80/14 82/9 90/6 99/4
99/18 100/2 100/9
100/14 100/23 101/1
101/5 101/12 105/6
109/19 110/14 112/5
113/15 117/8 117/16
117/23 118/14
Yes/No [1] 43/18
you [313]
you're [8] 19/20
23/17 36/22 59/4
72/25 97/24 101/23
109/16
you've [6] 38/2 72/11
83/23 102/23 104/20
117/21
YouGov [2] 1/24 3/16
your [78] 2/14 4/15
5/9 5/13 5/19 5/22 6/9
6/23 9/3 13/12 13/15
13/15 14/5 14/10
14/14 20/9 25/5 25/21
26/7 29/23 30/8 33/15
34/8 37/11 38/3 38/8
45/9 46/11 47/14
48/20 50/4 50/5 52/17)
52/21 56/13 56/18
56/20 61/17 61/20
63/25 64/17 66/1 66/6
68/6 69/18 75/18 81/3
82/8 87/19 88/16
90/13 90/14 99/5
100/2 100/2 100/5
101/2 101/3 101/12
101/15 101/17 101/18}
102/13 102/19 104/4
104/12 104/14 107/6
107/23 108/3 110/9
110/11 111/5 113/24
115/22 117/4 117/19
118/9
yours [1] 5/6
yourself [2] 87/4
115/21
(62) when... - yourself