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The Post Office Horizon IT Inquiry
Wednesday, 17 July 2024
(10.05 am)
MR STEVENS: Good morning, sir. Hopefully you can see and
hear us?
SIR WYN WILLIAMS: Yes, I can, thank you.
MR STEVENS: Thank you. You will be hearing from Mr McCall
this morning.
KENNETH MCCALL (sworn)
Questioned by MR STEVENS
MR STEVENS: Please could you state your full name?
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Kenneth McCall.
Mr McCall, in front of you there should be a witness
statement; do you have that?
I do, thank you.
Firstly, can I thank you for providing that written
statement and for attending the Inquiry today to answer
questions about it.
Before I ask you to turn to your signature,
I understand there's one small correction to be made.
Please could we have on the screen page 30, paragraph 65
of the statement. In that paragraph, you say, at the
start, that you received Mr Cooper's call at around
8.00, and we'll come to this section in the course of
your questions. Just for the purposes of the
correction, midway down the paragraph it says, "Shortly
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your career at TNT; is that right?
That's correct.
You became the CEO for Asia and then CEO for China at
TNT?
\ did.
You joined DHL in 2007?
Correct.
You then joined the Europcar group becoming Deputy CEO
in 2016?
That's correct.
Was that an executive position at Europcar?
Europcar was an executive position.
What was the time commitment for that role?
I was a full-time executive at Europcar on a normal
basis, five days a week, or as required.
In practice, was it a five day a week job or did it
involve weekend work as well?
It involved weekend work as well.
You had been a Non-Executive Director of Superdry; is
that right?
That's correct.
When did you begin that role?
From my witness statement, it would be six years prior
to then, I recall, so I served two terms at Superdry and
joined the Post Office in 2016, so it would be 2010.
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17 July 2024
after the call with Mr Parker I rang Ms Stent", and
I understand you wish to change that to "Shortly after
the call with Mr Cooper"; is that correct?
Yes.
Thank you. That can come down from the screen. Thank
you. Mr McCall, can I ask you, please, to turn to
page 35 of your statement; do you see a signature?
Ido.
Is that your signature?
Itis.
Subject to the one correction we've just made, are the
contents of that statement true to the best of your
knowledge and belief?
They are.
Thank you. That stands as your evidence in the Inquiry.
It will be published on the website shortly and, for the
purpose of the record, the Unique Reference Number is
WITN10020100. I'm going to ask you some questions about
I but not all aspects of it. I'll start with your
background or, actually, your role at Post Office
Limited. You were the Senior Independent Director of
Post Office Limited from January 2016 to January 2022;
is that right?
That's correct.
Looking at your background, you spent the first part of
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Was there any overlap between your Superdry appointment
and your appointment as Senior Independent Director at
Post Office?
No, I don't recall there being so.
Did you have any other non-executive roles whilst you
were at the Post Office?
I did not.
I understand that your contractual time commitment as
Senior Independent Director was two days per month
whilst at Post Office?
That's correct.
Did you have sufficient time to meet your commitment to
the Post Office, given your executive commitments to
Europcar?
Yes, I did.
You say in your statement at paragraph 9 -- we don't
need to bring it up on the screen -- that Tim Parker
thought you would be a good fit at Post Office and you
refer to your experience in parcels and mails, yes?
Yes.
Later in your statement, you also refer to having some
experience of dealing with IT issues at an executive
level; is that right?
Yes.
Could you briefly just summarise what that IT experience
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was?
My IT experience, I was responsible at Europcar Group
for the business priorities of the IT function, which
was headquartered in Paris. So I would decide exactly
what the business required of the IT Department and
liaise with them.
Did you find that experience assisted you in your role
as a Senior Independent Director at the Post Office?
From a business perspective, yes; from a technical
perspective, not necessarily.
Why not from a technical perspective?
I'm sorry, I beg your pardon?
Why not, from a technical perspective?
Because my role at Europcar wasn't a technical role. It
wasn't deciding systems or otherwise, it was purely:
what does the business require; what do our customers
want?
When you were a Senior Independent Director at Post
Office, do you think its Board had sufficient technical
IT experience to handle the issues before it?
Yes, I do. We had an excellent ClO, Mr Houghton. We
had -- I had two fellow non-executive Board colleagues
who came from the IT and technology sectors, and
therefore, at least two of the Board, to my knowledge,
were very IT savvy and knowledgeable.
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The details of what?
The details of the options we had.
I'll ask it in another way. Are you referring to legal
issues to which this Inquiry relates, such as
compensation and criminal appeals?
Yes.
Do you think it would have assisted the Post Office
Board, then, to have experience such as that on the
Board when you were dealing with the Group Litigation?
At the time when I joined the Post Office Board, I did
not know anything about the Group Litigation, so
therefore, in joining, I wouldn't have had an opinion
that said we would benefit from having legal expertise.
Having then gone through the Group Litigation, I would
say, yes, it would have benefited the Board.
I want to look at your role as Senior Non-Executive
Director. The Inquiry has heard evidence, and is well
aware, that both the Shareholder Executive and then UKGI
appointed a Shareholder Non-Executive Director to
represent its shareholding interest at the Board.
Correct?
Yes.
As a Non-Executive Director, in whose interests did you
act?
In the interests of the shareholder.
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You say in your statement that, to the best of your
knowledge, the companies you had worked for prior to the
Post Office did not pursue private prosecutions?
That's correct.
Was there anyone on the Board with legal experience or
qualifications?
Latterly, I believe, if I recall correctly, a year
before the end of my second term, we had a Non-Executive
Director join, who's still there, I believe, at the
present time, who is from the legal profession.
Can you name that person, if you can remember the name?
I don't immediately recall -- yes, I do now:
Mr Tidswell.
Do you think the Post Office Board would have been
assisted by having a member of the Board who had legal
experience or qualifications, considering the matters
you were dealing with during your time there?
I believe that, latterly, the assistance of Mr Tidswell
was extremely helpful in guiding the Board through some
of the processes. So, yes, I -
Let me pause you there. When you say some of the
processes, what processes are you referring --
I think understanding what decisions we're required to
make and why, and how to maybe understand a bit better
the details.
How did you determine what those interests were?
In a company that's either a listed company or certainly
multi-shareholding, you're acting on behalf of that as
a shareholder. In this case, in the Government company,
I was acting on behalf of the Government Shareholder to
bring my expertise and experience to bear on a Post
Office Board.
The Government shareholding interest in Post Office
Limited wasn't simply to see Post Office making
a profit; would you agree with that?
That statement was never something that was in my terms.
of reference or was never made to me specifically. My
view was that my role was to try and ensure
a sustainable business model for Post Office looking
forward.
Can you summarise, in your view, what distinguished your
role as Senior Independent Director from that of the
other Non-Executive Directors?
I was responsible for reviewing the performance of the
chairman. I was the conduit for the other Non-Executive
Directors, if they needed any help or advice. In some
ways, I was the go-between also to the Chairman, where
I would advise the Chairman if there were any concerns
of the Non-Executive Directors. So, in simple terms,
I would say at a high level I was eyes and ears.
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The responsibility you referred to of evaluating the
Chair's performance, in one way, that was carried out
through yearly evaluations; is that right?
That's correct.
Would you see your responsibility for evaluating the
Chair's performance as an ongoing matter, though: you
that to keep on top of the Chair's conduct and
effectiveness?
Yes, in principle. I think through the Covid period,
where we were meeting remotely, I don't recall exactly
the process we went through but through the Covid period
it was extremely difficult. It was about survival and
it was about trying to keep a business together, so
I don't recall specifically the Chairman's performance
review. When it was done face-to-face, I recall it
quite specifically.
In your role as Non-Executive Director and protecting or
acting in the interests of the shareholder, to what
extent did you have meetings with the Minister with
responsibility for Post Office in your role as Senior
Independent Director?
I don't recall how many meetings I had with the Postal
Minister. Possibly one or two, nothing more. And,
again, please bear in mind that, through the period we
had three years of Covid as a part of that exercise, so
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a lack of robustness in Horizon or the Group Litigation?
No, I did not.
Do you recall what you discussed?
Frankly, I can't remember the date, I can't recall the
date, so I think I would just be hypothesising so no,
I don't remember.
Please can we bring up your statement at page 5,
paragraph 14. You're referring to your roles and
responsibilities as Non-Executive Director and, at the
end of paragraph 14, you say:
"At a high level, my role as a [Non-Executive
Director] was to be part of a board developing [Post
Office's] strategy to achieve financial
self-sustainability and to work with the management team
to deliver that.”
Then over the page at paragraph 16, just go down,
please. Towards the bottom half of that paragraph you
say:
"Our role as non-executives on the Board is to help
determine the company’s future direction and strategy.
In other words, we are focused on what the company might
look like in several years' time and how we can create
a sustainable and future-proof business."
So strategy is forward looking. Would you accept
that, to be able to advise on strategy, a non-executive
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therefore, no one was meeting anyone face to face.
I met the Chairman of BEIS at that time, I think --
I believe now BIS, and I met the possibly one other
minister as a part of that exercise. So I didn't
regularly meet a Postal Minister.
Before the hand-down of the Common Issues judgment in
March 2019, had you had any conversation with the Postal
Minister or indeed the Secretary of State about the
allegations concerning the robustness of the Horizon IT
System or the Group Litigation?
No, I don't recall I did.
To what extent would you meet representatives of the
Shareholder Executive -- sorry, UKGI -- outside of
meeting Tom Cooper in Board meetings?
I would meet possibly Richard Callard, who first -- was
the prior to Tom Cooper. Tom Cooper, afterwards, either
for a coffee beforehand or after a Board meeting.
I don't recall any formal meetings at their offices, as
a part of that. I had a conference call once with the
Permanent Secretary but, other than those, I don't
recall any.
The conference call with the Permanent Secretary, do you
recall when that was?
I don't recall the specific date.
Did you discuss issues relating to the allegations of
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has to consider risk to the business arising from past
liabilities or current operations?
From a strategic point of view, the focus of the
non-exec will be looking at the marketplace that the
business operates in, the business model that it's using
in that marketplace and how we might improve that
business model to ensure that, in this case, the Post
Office remained a leading player in the mails, parcels
and logistics market, and that was the focus of
sustainability as a business.
Do you think that, following the hand-down of Common
Issues, the Post Office's future strategy and its
sustainability changed as a result of that judgment?
After the Common Issues judgment there was, I believe,
about eight or nine workstreams that were started as
a result of the Common Issues judgment, looking at the
remarks and comments made by Justice Fraser and
requirement for the Post Office to substantially change
its way of operating and its relationship with the
subpostmasters.
I think you're agreeing with me that things changed
significantly during the Common Issues trial.
There had to be significant change.
The Common Issues judgment considered and made findings
on matters that happened in the past; would you agree?
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Predominantly, yes.
So was it not the role of the Board, including the
non-executives, to look at the past as well, to
determine what risks in future, or assess what risk in
future, may be on the Horizon?
As a non-executive I'm always looking forward, not
looking back, and looking at our business model, and in
this case, after the Common Issues judgment, we were
looking at what changes required to be made that was the
result of the judgment. And so that was really the
focus, as opposed to looking historically.
Do you think the Executive Team had a role in
identifying, analysing and mitigating risks for things
that happened in the past?
The Executive Team from the outcome of the Common Issues
judgment was --
No, I'll stop you there, sorry. I'm not talking about
from the Common Issues judgment here. As a matter of
generality, when you joined the Post Office in 2016, did
the Executive Team have a responsible to identify,
analyse and mitigate risks that the Post Office Limited
faced?
Yes, as a general principle, yes.
Did the Non-Executive Directors have a role in
overseeing that aspect of risk management?
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we have up page 6, paragraph 17 of the statement. Thank
you.
You say at the bottom there that:
“The Board will not consider the specifics of
individual bugs or defects, which is generally the
responsibility of the specialists in the IT Team, save
to the extent that those bugs or defects have a material
impact on the day-to-day running of the company.”
Then at paragraph 18, you say:
"Typically a non-executive board would have
high-level oversight of the conduct of any civil
litigation brought by or against the company but only if
and when it became material. Each company will have its
own materiality threshold and unless a civil claim met
that threshold, I would not necessarily expect the Board
to be made aware of it or updated on its progress."
How was the threshold of materiality determined at
the Post Office Board in 2016 to 2019?
In my witness statement comments, I refer to materiality
as if it would be determined by the auditors. So the
statement would be based on normally, if I recall
correctly, a percentage of turnover. So in this case,
my use of the term "materiality" would be a percentage
of turnover of the Post Office, and that's the reference
that I make by "materiality". So in the case, if
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Yes, mainly through the Audit and Risk Committee.
What did you see as the Non-Executive Director's role in
challenging the Executive Team's delivery of its
operations?
The robustness of the strategy, the business operating
model, the product evaluation, the Customer Service
requirements. The detailed operating requirements of
running a business and what we had to change and what
the Executive Team were focused on day to day.
So did the Non-Executive Directors, including yourself,
from 2016 onwards, have a role in overseeing the
Executive Team's analysis of the risk posed by the
Horizon allegations?
When I joined the Board in January 2016, I was
completely unaware of the Horizon issues, bugs and
historical problems and, therefore, in my mind, when
I joined in 2016, my focus was on building a sustainable
business model and future. It wasn't focused on looking
back. I was completely unawares of the history and what
had recently happened. I then became aware, in April
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Thank you. Well, I'm going to cover that shortly so.
we'll come back to that topic but, before I do, I want
to ask you a couple of questions on materiality which
appears in your statement at a few places. Please could
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I recall correctly, then it would be many millions. But
that's the use of the word "materiality".
We've heard this before in the Inquiry, exactly the
definition you describe, and would you accept that the
materiality, from the perspective of the Post Office
Limited Board, would be different from materiality to
an individual subpostmaster?
Yes, I would.
In terms of the allegations that --
Sorry, before I ask that question: did the Board,
when you were there, ever consider the subpostmasters'
perspective of materiality?
The comment on materiality was driven by the auditor
definition or from an annual accounts perspective. We
didn't look at it, as I recall, from a subpostmaster
perspective.
In terms of the allegations that were made that Post
Office had secured unsafe convictions using data
generated by the Horizon IT System, so the allegation of
an unsafe conviction, is that a matter that should be
considered at Board level or is there a test of
materiality for unsafe convictions?
When I joined the Board in January 2016, to the best of
my knowledge, there was no convictions and none of the
existing Board members at that time had sat on the Board
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previously and so, therefore, I find it hard to comment
‘on your question.
Can I just clarify with you what you mean by “no
convictions" there. Do you mean that when you were
a Senior Independent Director, you believe Post Office
didn't pursue prosecutions that led to convictions in
that time?
That is my understanding.
Let's look at your appointment letter, please. It's
POL00362996. So we see it's dated 2 December 2015. If
we could turn to page 8, please. It refers to
an induction, saying:
"After the commencement of your appointment, the
Company will provide a comprehensive, formal and
tailored induction. We will arrange for site visits and
meetings with senior and middle management.”
What induction did you actually receive by Post
Office?
I met most of the Senior Executive Team face to face at
Post Office offices.
Just so we can be clear, when you say the Senior
Executive Team, most of, who are you referring to?
I'm referring to the person that was in charge of the
banking business or the person that was in charge of the
mails business, so the people that were leading the
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on our limited background knowledge."
What, in particular, left you feeling as though you
were holding the baby?
Not having a non-executive on the Board who understand
(sic) what had happened in the previous one, two, three,
four years, and not having that knowledge.
When did you get this feeling?
My comments were quite general when I started to find
out about the Horizon issues, which was between April
and September 2016, that there was no one, when I looked
at my colleagues, who was in position prior to that.
So reading this, you say in the first sentence "When
I joined Post Office Limited", the second statement --
I say a sentence, sorry -- "I can recall feeling as
though we had been left holding the baby”, your evidence
is that that happened later in April 2016 onwards,
rather than when you joined Post Office Limited?
That's correct.
That document can come down, thank you. You refer, we
don't need to turn it up but in your witness statement
you refer to having an interview with Baroness
Neville-Rolfe, prior to your appointment as Senior
Independent Director.
Yes, that's correct.
Your evidence is that she didn't discuss with you
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various business units of Post Office. I met the Chief
Financial Officer. I -- in addition to that, I met the
Chief Executive. So, I mean, the sort of top-line
Executive Team. I don't recall how many of the people
I met, but I met number of the top-line team.
After that, I then did some external site visits and
I visited some sub post offices in the network: if
I recall correctly, probably four or five subpostmaster
network offices.
Did you meet anyone from the Legal Department as part of
your induction?
No, I did not.
So, for example, Jane MacLeod, you didn't meet her as
part of your injunction?
No.
Please can we bring up your statement, page 33,
paragraph 73. You're giving your reflections here and
you say:
"When I joined [Post Office], the Board was still
relatively new and, to my knowledge, none of the
[Non-Executive Directors] had been in post at the time
when the ‘Legacy’ Horizon system was in operation and
the private criminal prosecutions were still ongoing.
I can recall feeling as though we had been left holding
the baby and we had to decide what to do with it based
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matters such as the allegations regarding Horizon or Tim
Parker's review?
That's correct.
How confident are you now, looking back, that she made
no reference to the Parker Review in that interview?
Very confident.
Why?
Because I would have remembered something as
significant, if there was a major issue that had been
identified to me at the time before I was likely to join
anew Board. So I'm as confident as I can be, bear in
mind I'm talking eight years ago, that I recall that
nothing was mentioned about the historical issues.
Do you remember what briefing material, written
material, was provided to you as part of your induction?
No, I don't.
As part of your Rule 9 Request, the Inquiry sent you
number of documents and asked you when you first had
knowledge of them. Can we turn, please, to page 18 of
your statement, paragraph 41. You say, towards the
bottom of that paragraph:
"I now realise that, by this time [and you're
referring to 30 October 2018, we see, at the top],
several reports had been commissioned by [Post Office]
into possible issues with Horizon and I have been
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provided with copies of certain reports dating back to
2013. Except as set out in this statement, I had no
knowledge of any of those reports until they were
provided by the Inquiry.”
In that sentence, are you referring to documents
such as the Second Sight Interim Report in 2013, which
commented on the Horizon system itself?
Yes, the first that I've seen of any reports on the
Horizon system were in documentation provided by the
Inquiry.
Please can we turn to POL00006357. This document very
well known to the Inquiry, it's Simon Clarke's Advice of
15 July 2013, it was sent with the Rule 9 Request to you
and was one of the documents that the Inquiry asked you
about. Did you read it when preparing for this
statement?
No, I did not, because I wasn't in position in 2013.
So are you aware of what this document says?
No, I'm not.
Firstly, before I ask what it says, when did you first
see this document?
Only when it was presented to me as part of the papers
from the Inquiry.
Why did you not refer to it in your witness statement?
I didn't believe that it was relevant to me on the basis
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recollection in my mind.
Do you recall when you found out about the allegation
that Mr Jenkins had failed to comply with his duties as
an expert?
I don't know about duties as an expert but, in terms of
ability to access the system, I believe that was in
November/December 2019.
When you say “ability to access the system", do you mean
what we now refer to as remote access?
Yes, I believe so, yes.
Can you assist us with whether you were aware of
concerns about Mr Jenkins before, say, the Common Issues
judgment?
No, I was absolutely not.
Again, I'll phrase it slightly wider: do you recall when
the first time you became aware of concerns with
Mr Jenkins within Post Office?
I don't recall an exact date.
Can you give us a brief time, a time period?
Only when -- I go back to my November/December 2019,
when I heard the system could be remotely accessed.
That's probably the first time. I don't remember
anything prior to that.
Did you discuss concerns about Mr Jenkins with anyone
else on the Board?
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that I wasn't in position and didn't know anything about
it and so, therefore, I'd struggle to comment on it.
If we turn, please, to page 13, we see, under
"Conclusions", it says:
"What does this all mean? In short, it means that
It says "Dr Jennings", which refers to Gareth
Jenkins. Presumably now you know who Gareth Jenkins is?
Yes, I do.
".., [Gareth Jenkins] has not complied with his duties
to the court, the prosecution or the defence."
If we go down, at 38, we don't need to go through it
all, but it says:
"Dr Jenkins failed to disclose material known to him
but which undermines his expert opinion. This failure
is in plain breach of his duty as an expert witness",
and continues.
Were you provided any information regarding Gareth
Jenkins when you joined the Post Office?
I was not.
When was the first time you heard of Gareth Jenkins?
The first time I'd heard about Horizon issues was
between April and September 2016, after I joined in
January 2016. I don't recall exactly when I found out
about Gareth Jenkins. I don't have a date of
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No, I did not.
Could we look at the monitoring, please, of the Group
Litigation. We don't need to -- actually, no, let's
bring it up, please, your statement, page 16,
paragraph 37. You say:
"Initially, Ms MacLeod delivered updates to the full
Board on the status of the G proceedings, which soon
became a standing agenda item. These updates were
necessarily limited to high-level news and ‘headlines’:
how many claimants had joined the claim; whether there
was going to be a class action; and similar key issues
and milestones. From a very early stage there was
a huge amount of detail in the GLO proceedings that the
Board would not have time to review, and it was not the
Board's role to do so. Looking at the Board minutes
I have been provided with by the Inquiry, the notes of
Ms MacLeod's updates appear quite light. It's not clear
to me now why the Chairman did not request more detail
in the minutes."
You refer to Ms MacLeod's preoccupation with
preserving privilege.
So just clarifying this, is your evidence that,
actually, as a matter of fact, Ms MacLeod provided more
substantial briefings to the Board orally than is
reflected in the minutes?
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Mrs MacLeod provided updates to the Board that were
almost, almost verbal, that I recall.
Yes, and when she provided those verbal updates is your
evidence that what she actually said to you when you
were in the Board room was more substantive or provided
more information than is reflected in the Board minutes?
No, I don't recall specifically because everything was
verbal. I find it harder to recall whether it was more
detailed or less detailed, I just recall it was a verbal
update and the minutes reflected that update being quite
light. I don't know why but Mrs MacLeod wouldn't
present for one hour or otherwise, it was a short
session that I recall verbally updated on the high-level
points of the litigation.
What did you mean then by "It is not clear to me now why
the Chairman did not request more detail in the
minutes"? Are you saying that the Chairman should have
requested there to be more detail written down as to
what Ms MacLeod actually said or that the Chairman
should have requested that Ms MacLeod provide more
detail to the Board?
I'm saying that the Chairman should have requested more
detail in the minutes.
From saying that, what do you think is missing: what
sort of information is missing from the minutes that has
25
duty of the Company Secretary or Legal Team, Jane
MacLeod, and the Executive.
Then, after that, if there was anything required to
be escalated, then that would be escalated to the
subcommittee.
That can come down for the time being. Thank you.
Leaving aside what the formal terms of reference
said, as a matter of practice, what did you see your
role to be on the subcommittee?
The Group Litigation, as I first found out about in
between April and September 2016, started to snowball
very quickly. There was approximately 90 claims, and
that snowballed very quickly into 550 or 560 claimants,
so things were moving very fast.
And the role of the subcommittee was to be able to
try and quickly react, if there was any decisions or any
advice that was required, because it was happening so
fast. Decisions had to be made and so, therefore, the
purpose, as much as anything, of the subcommittee, was
to try and assist the Board in understanding what was
happening and to be available if the Executive or
Mrs MacLeod had to escalate anything that required
further discussion.
Can you give us a summary of what types of things were
escalated to the subcommittee?
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led you to make that statement?
The basis of my comments relate to receiving information
from the Inquiry. If I was able to read it now, it
would give me a better understanding of what was said
and what happened during those meetings, if the minutes
were more detailed. So my comments are really driven by
recollection of memory, as opposed to anything else.
Why didn't you raise any concerns about the minutes at
the time?
In hindsight, I should have done.
Please can we bring up POL00024270. So we know and have
heard evidence that there was initially a steering group
for the GLO and then the Board created a subcommittee in
early 2018. In fact, we see at paragraph 2.1, it says
it's following the meeting of 29 January 2018. In your
witness statement, you refer to one of the purposes of
the committee to be to receive legal advice. Was it
also to provide oversight for how the litigation was
being conducted?
If I recall correctly, there is terms of reference --
there were a terms of reference of the subcommittee in
documents. I haven't seen it as part of my papers but,
if I recall, there was terms of reference, and the
day-to-day management of the subcommittee and working
with the legal officers representing Post Office was the
26
I don't recall specific documents or items at the moment
and, in my papers provided by the Inquiry, there wasn't
any documents that I can give as an example but it was.
more about the frequency and the feed of information
that was coming very quickly.
I want to look at a different topic, please, and that's
what we now call the Swift Review or Tim Parker's
review. When did you first become aware of Tim Parker's
review as commissioned by Baroness Neville-Rolfe?
I never was aware of the Swift Review until the papers
and I saw the documents provided by the Inquiry.
So I want to try to delineate two things here. Firstly,
when were you aware that Tim Parker was carrying out
a review at the request of Baroness Neville-Rolfe?
I wasn't aware at all and I was never informed of that
at all.
The second question I was going to ask was: when did you
become aware of Sir Jonathan Swift's involvement? Your
evidence is you didn't see the report, the advice, until
it was sent to you by the Inquiry?
That's correct.
Apologies if I misheard you but just so I can be clear,
that's when you saw the advice produced by Sir Jonathan
‘Swift; when did you become aware of his actual
involvement?
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"His" being? Can you just clarify?
I'm very sorry, yes. Sir Jonathan Swift's involvement?
The name Swift, I was not aware of. It's not a name
that I was aware of. I believe when I looked through
the papers provided by the Inquiry, there's a comment
from Tom Cooper which says "I attach" -- and I don't
believe he names anything but he attaches a document.
I don't recall ever receiving that or seeing that
document but I've read the papers provided by the
Inquiry but, to the best of my recollection, it doesn't
mention a name, and I don't remember seeing it. So
physically seeing what was the Swift Report and the
letter to Baroness Neville-Rolfe, I didn't see it until
it was provided by the Inquiry.
I want to bring up, please, Jane MacLeod's witness
statement. It's WITN10010100. This is a witness
statement provided to the Inquiry by Jane MacLeod dated
30 April 2024, which has been read into the record.
Can we please turn to page 101, and if we could go
down, please. Sorry, it should be starting at page 100,
paragraph 184. So we see at the top there, it's
referring to -- 183 -- Sir Jonathan, that's Sir Jonathan
Swift, providing a draft version of his findings to
Mr Parker.
At 184, Jane MacLeod says that:
29
So, in your evidence, where we saw you refer to feeling
being left holding the baby, you weren't referring to
learning of the Chairman's review?
I have not seen that document nor have I questioned it,
nor have I said I have a totally different recollection,
otherwise I would have -- not have made the comments in
my witness Statement.
I'm just going to continue with what she says, in
fairness to you, so it's put to you:
"I believe that, as a result of that question [this
is Jane MacLeod speaking], I provided an oral briefing
to the Board (although I do not recall if this was at
the same meeting or subsequently), as to the scope and
findings of the Chairman's review as well as a summary
of the further work being undertaken following the
Chairman's review."
Again, I'll put it to you: do you disagree, then,
with Ms MacLeod's recollection?
I have absolutely an alternative view on that, I have
never -- and I stress again -- I have never seen that
report nor do I recall in any way that I made those
statements or that word.
Finally, she says:
“Although I have not seen any documents which
indicate the full report was circulated to the Board, my
31
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"I have not been provided with the minutes of any
Board meetings or Group Executive meetings in which the
Chairman's Review or the findings from it were
discussed, although it is clear that the Board were
aware that it had been commissioned as the CEO informed
the Board its meeting on 22 September 2015 ..."
Pausing there, that's before you joined the Post
Office:
that 'the Minister had asked the Chairman for
his independent review of Sparrow."
It then goes on, if you see further down, it refers
to Mr Parker's comments in open source material. She
says:
"My recollection is different to Mr Parker's,
although I agree that I discussed privilege and
confidentiality with him when I met him. My
recollection is that the Senior Independent Director,
Mr McCall, asked a question at a Board meeting as to
whether the Board would be briefed on the findings of
the Chairman's review, although I do not now recall the
exact timing, but it was after the further work
recommended by the Chairman's Review had commenced.
Pausing there, do you recall asking such a question,
as indicated by Ms MacLeod here?
No, I don't.
30
recollection is that I advised the Board that the full
report was available on request."
Do you agree with that?
No, I do not.
That can come down. Thank you. Can we please bring up
POL00024913. It's a letter from Tim Parker to Baroness
Neville-Rolfe regarding his review. It's dated 4 March
2016. I think you've already referred to it but for
clarity I will ask: did you see this at the time?
No, I did not.
When was the first time you became aware of this letter?
In the papers provide to me by the Inquiry.
Could we turn, please, to page 2, and if we go down to
the "Criminal Prosecutions" section -- we don't need to
read it all -- it sets out some information on the
review, and the criminal prosecutions element of it, and
above (1) minute it says:
“As a result of the review I have decided to take
the following steps.”
It says:
"I will take advice from specialist criminal counsel
as to whether the decision to charge theft and false
accounting could undermine the safety of any conviction
for false accounting if (a) the conviction was on the
basis of a guilty plea following which, and/or in return
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for which, the theft charge was dropped, and (b) there
had not been sufficient evidential basis to bring the
theft charge."
Were you aware of that work described there having
been commissioned?
No, I was not.
Do you think you should have been made aware of that?
My first Board meeting was in February '16 and I notice,
from seeing the letter again, it's March. But yes,
naturally in the course of events, I believe I should
have been aware of it but I was not aware of the letter,
at all.
If we turn the page, please, page 3, there's information
on Horizon and it refers to, firstly, various bugs,
errors and defects. We don't need to go to that. It's
the second two paragraphs I want to refer to:
"Nevertheless, the ... report suggested that
consideration should be given to whether it would be
possible, by analysis of the transaction logs of
subpostmasters who made complaints, to determine more
comprehensively whether or not the matters complained of
by each subpostmaster could show the existence of some
other generic bug within the system. Work is now
underway to assess if such testing is possible and, if
so, to scope the work that would need to be done."
33
a consequence the follow-up work, should not be shared
with the Board."
Does that fairly summarise any work you carried out
following your discovery of the Chairman's review?
The Chairman's review, and you're talking of the
Chairman's -- just for clarity, you're talking of the
Chairman's review of performance?
Initially, I'm saying: once you were asked to conduct
a -- no, let's pause here.
This says that "he does not think it appropriate to
take any action in relation to Tim Parker's
decision-making around the QC's review in 2015 of [Post
Office Limited's] handling of the Horizon complaints",
and then it goes on to say that you believe that he made
a significant error of judgement in accepting legal
advice that the QC's report, namely Jonathan Swift's
report -- and, as a consequence, the follow-up work --
should not be shared with the Board.
Well, this suggests that by September 2020 you were
aware of the Swift Review?
No, because by name, I wasn't aware of what anything was
called. Just for clarity, I don't recall the term
"Swift" and I don't see it in this document, and I've
not seen it in anything that's been provided to me that
would indicate, better than my recollection, that I have
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Then it goes on to say:
“Further work is also under way to address
suggestions that branch accounts might have been
remotely altered without complainants’ knowledge.”
Were you aware of one or either of those
recommendations or work being carried out further to
them?
No, I was not.
That can come down, thank you. Can we bring up
UKGI00012703. It's an email from Tom Cooper on
16 November 2020. We see in the distribution list and
the cc list there are various senior figures at UKGI and
then what was BEIS, the Permanent Secretary included.
It says:
"Ahead of our call this afternoon, this is just to
update you that Ken McCall, the [Senior Independent
Director], has confirmed that, having spoken to other
members of the Board as he deemed appropriate, he does
not think it appropriate to take any action in relation
to Tim Parker's decision making around the QC's review
in 2015 [referring to the Swift Review] of [Post
Office's] handling of the Horizon complaints.
“His rationale is the same as reported previously.
Ken believes Tim made a significant error of judgement
in accepting legal advice that the QC's report and, as
34
seen. And this refers to the Swift Report, so I was --
my understanding is that the Chairman conducted
areview. I did not know what it was called or what it
was and it wasn't shared with the Board but the name of
Swift was not known to me.
Were you aware that he had instructed a barrister to
assist with the review?
No, I was not.
So is your evidence that Tom Cooper here, when saying,
"Ken believes Tim made a significant error of judgement
in accepting legal advice that the QC's report and, as
a consequence, the follow-up work, should not be shared
with the Board", your evidence is that's inaccurate?
My evidence is that if there was something as serious as
that, having taken place, then I believe the Chairman
should have shared it with the Board.
That's a separate question. I'm asking, on this email
from Tom Cooper, the suggestion is that you had
evaluated Mr Parker's performance and determined he'd
made a significant error of judgement in failing to
share legal advice in the form of what's described as
the QC's report, and failing to share that with the
Board; is that wrong?
My conversation with Tom Cooper, to the best of my
recollection, there wasn't a reference in our
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conversation to "QC", so, therefore, I just recall Tom
saying "Tim Parker has carried out a review, it's not
been shared by the Board". I don't recall there being
a name given to that document, or QC's document, and the
email here is much more direct than the conversation
that we had. So my conversation with Tom Cooper was,
“Apparently there's been a document that Tim has
commissioned and it's not been shared by the Board”. It
was as general a recollection as that I have.
So here it's very specific. It says, "In this
email", which obviously I'm not a party to and didn't
see. Then, you know, it's a much more strongly worded
than the phone conversation with Tom Cooper with me was.
Did you say to Tom Cooper that you thought, on the
information you had, that Tim Parker had made
a significant error of judgement?
If there's a major report, that the Chairman should have
shared with the Board, then that's why I would refer to
it as a significant error of judgement.
So in saying you would have referred to it as
a significant error of judgement, you said “if there was
a major report". What were you told for you to believe
there was a major report that he'd failed to share with
the Board?
Verbally from Tom Cooper.
37
MR STEVENS: Please can we bring up UKGI00012155. I think
this is a document you were referring to earlier. We
see it says, "From: Tom Cooper" at the top, "To"
includes Tim Parker, and then you're there as well, Ken
McCall. "Subject: Chairman's review report".
Attachment, "QC Post Office review", 7 February 2016,
and then also the letter to Baroness Neville-Rolfe,
dated 4 March 2016:
"As promised yesterday, please finding attached
a copy of the QC's report prepared for Tim in 2016. The
recommendations are at the back.
"Also attaching a copy of Tim's letter to the
Minister."
Do you accept you did receive this Swift Review?
No, I do not. I accept I saw in the documents provided
to me that this is exactly what it says but I have no
recollection of actually having seen that report.
Is it not the case that you, on 30 July 2020, received
the Swift Review and then later, in the email we just
went to, gave Tom Cooper your views on it, namely having
read the report, you thought that it should have been
disclosed to the Board?
I don't believe so. To the best of my recollection,
I would -- I believe I would remember or have remembered
if I saw a document such as this.
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What did he say specifically about the report?
I mean we're talking four years ago or thereabouts.
I don't specifically recall the exact conversation, but
the Chairman had commissioned a report, and it's not
been shared with the Board. That is the essence of the
po
conversation. There was no reference to "Swift", there
was no reference to "QC". So I don't understand how Tom
knows those factors or QC's report. I certainly didn't
know those factors.
SIR WYN WILLIAMS: = Have I got this right, Mr McCall: that
you accept that there was a conversation with Mr Cooper
either shortly before or on the date of this email. In
that conversation, he told you that Mr Parker had
received a report which had not been shared with the
Board. You were told enough to consider that that was
a significant error of judgement on the part of
Mr Parker but, given his overall record, you did not
think that any action should be taken against him in
respect of that error of judgement.
You, however, dispute the fact that you were aware
either of the name "Swift" or that the report was
carried out by a barrister. Now, is that a fair summary
of what you've been debating with Mr Stevens?
A. Yes, sir. That's correct, sir.
SIR WYN WILLIAMS: Fine. Thank you.
38
MR STEVENS: Sir, that's probably a good time to take our
break and I wonder if we could come back at 11.25.
SIR WYN WILLIAMS: Yes, that's fine, Mr Stevens. I was just
checking the time.
MR STEVENS: Thank you, sir.
(11.15 am)
(A short break)
(11.26 am)
MR STEVENS: Sir, can you still see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
MR STEVENS: Please could we bring up POL00104107.
We see this is an email from you to Veronica Branton
and others on the Board on 22 April 2020. We'll come to
it in a moment. You say:
"I would appreciate seeing a redraft of the minutes
to include the points raised by Tom."
That's an email from Tom Cooper to which we'll turn
in a moment. Before we do, you say:
"I must say at this stage I do not feel comfortable
that the minutes truly reflect the complete unawareness
of the Board to the existence of a Deloitte report, whom
it was commissioned by and the contents therein, and
that the minutes reflect the complete shock at finding
out that Fujitsu had remote access."
Pausing there, the Inquiry has set you several
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reports from Deloitte but in two sets, broadly one
Project Zebra from 2014 and one Project Bramble from
2016 onwards. When you say "the existence of a Deloitte
report”, to what are you referring?
I wasn't aware, if I recall correctly, that there was
more than one, so I don't have a name or a badge that
I can give to that report. I didn't know that there was
multiple Deloitte reports, only in the papers that were
sent to me by the Inquiry was I aware that there was
multiple Deloitte documents.
So is your evidence, at this point, you were aware of no
Deloitte reports regarding remote access?
That's correct.
When you say things like "complete shock" and "complete
unawareness", do we take from that that you think the
Deloitte report should have been before the Board?
That was my perception, that someone had commissioned
a report and the Board hasn't seen it.
Did you think it was an important report?
That was my perception at the time, that there was
a report, and that the Board should have seen it, and so
my words used then are complete unawareness by the Board
and I believe myself and my fellow colleagues on the
Board -- specifically I refer to the non-executives --
would have felt the same way.
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accept that?
I accept it when I see it here in email, but day to day,
I don't have any recollection of that specific email and
I don't have a recollection of the name, but there is
an email here which I read the title and I see it and
I accept. But it's not something that I had any
retention for.
Well, looking back now then, would you accept that,
firstly, you knew Jonathan Swift had commissioned
a report, it was later sent to you, and you told Tom
Cooper that Tim Parker should have disclosed it to the
Board?
I see the paper trail and the email trail. I have no
recollection of receiving the Jonathan Swift Report.
I have none at all.
So there are two options, really: one is your
recollection is inaccurate and you did receive it and
read it; or, secondly, an obvious important report that
you were sent, you didn’t open?
The former, in that I have no recollection of receiving
the Swift Report.
Actually, the former thing I said is that your
recollection is incorrect.
Yes.
Are you accepting your recollection is incorrect?
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So if you'd known earlier that there was a report by
Deloitte that dealt with remote access, would you have
wanted to know more about it?
Yes, I would.
Could we go, before we move on to look at that in more
detail, I want to look at Tom Cooper's email, which you
refer to there. As I say, you say:
"I would appreciate seeing a redraft of the minutes
to include the points raised by Tom."
If we go to the bottom of the page, you see that is
the email from Tom Cooper, you are sent it, we see, on
the right side. Then if we go to see the meeting, it
says:
"Veronica
"I've got a few points on the minutes from the last
meeting.”
‘Something at paragraph 7 about the Deloitte report.
He says:
"I'd like to clarify that the 'who knew about’
question should apply to the various pieces of work
commissioned ..."
You see the third one is "following the Jonathan
Swift QC report”.
So you were aware that it was Jonathan Swift QC who
prepared a report by at least 22 April 2020; would you
42
When I see the paper trail, you would have to say yes,
that's potentially the case.
That document can come down, please. Could we please
look at your statement, page 29, paragraph 63. You say:
"At some point during the Board's review of CCRC
cases ... I received a telephone call from Mr Cooper
regarding a Deloitte report that Mr Parker appeared to
have commissioned but had not shared with the Board."
You go on in that paragraph to say you believe now
that he was referring to Project Bramble, which, as
I said earlier, was the post-2016 work.
If you can turn the page, please, to paragraph 66,
you say:
"During the CCRC review meeting, which Mr Parker
attended, the Board raised the subject of the Deloitte
[review] and why it had not been shared. The tone of
the meeting was not one of anger but definitely
puzzlement. Mr Parker's explanation was that he had
been advised that the report was legally privileged and
should not be shared with the Board ..."
So your evidence appears to be you were told of the
Deloitte review, the report, and you attended a Board
meeting at which you asked Mr Parker why he didn't
provide that information earlier?
Yes, that's correct.
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Please could we look at POL00006753. These are minutes
of the Group Litigation subcommittee of Post Office, on
21 February 2019. We see Tim Parker attends by phone
and then, third down, you attend by phone as well. Yes?
Yes.
We also see that Anthony de Garr Robinson QC, as he then
was, gave -- if we go down please -- at the upcoming
Horizon trial, gave a briefing or advice in conference
on his views. If we turn the page, please, number 4
says:
"Remote access risk. The claimants have posited the
theory that Fujitsu had interfered with branch data in
secret. [Post Office] Limited and Fujitsu's case on
remote access had changed over time. Initially Fujitsu
had said that remote access was not possible. The
Deloitte audit had found that it was. The claimants’
expert was arguing that the scope for remote access was
even greater than now stated", and goes on to say what
the court would do.
So let's take it in stages. Firstly, you were aware
at this stage, weren't you, that remote access by
Fujitsu was possible?
My recollection was some time between November and
December 2019 --
That's your recollection but this is a minute from
45
in the Horizon system because of the way that data was
captured. We could not distinguish easily between
maintenance access and making changes to branch data.
However, Fujitsu had been clear that branch data had
only been changed on very rare occasions.”
Then we see it goes on to say about a line between
bugs and systemic system errors and appeals.
So from these minutes, it firstly doesn't appear
that any surprise was raised at this information that
Fujitsu could remotely access data; do you accept that?
Ido.
Secondly, there's no question raised, such as what is
the Deloitte audit? Would you agree with that?
I don't see anything of that in the minutes.
From that, can we infer that members of this committee
were aware of the Deloitte audit before this meeting?
According to the minutes, I would have to agree with you
but, as I say, the dates were not my recollection. But
I'm obviously incorrect.
So you can't assist us, then -- you've said in your
evidence it's November 2019 or maybe December 2019.
Looking at this document, you can't assist with when,
before February 2019, you may have found out about this
information?
It's -- in my witness statement, I've honestly, to the
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February 2019, at which remote access is discussed. So
do you accept that you were aware of remote access by at
least this date in February 2019?
From the minute that's in here, I have to accept that
that's the case and my recollection is wrong.
Secondly, it refers to the Deloitte audit. So you were
aware of Deloitte's involvement in an issue relating to
remote access; would you accept that?
Yes, I do.
If we look further down, please, we see "Questions", and
the first one is about optimism on the claim; the second
a note about “limit of planning that we could do before
we had the judgment in the Common Issues trial";
a discussion there about risk mitigation.
If we turn the page, please, it says there, in this
paragraph:
"Whether an accusation was being made that [Post
Office Limited] had been involved in instructing Fujitsu
to change transactions? It was noted that only Fujitsu
could change data and there was no suggestion that [Post
Office] had operated a policy to get Fujitsu to
manipulate the branch data. The claim was that we had
lied about Fujitsu's ability to change branch data. It
was noted that it was hard to capture the number of
instances in which the data had been changed, especially
46
best of my recollection, said this is the date
I believed I found out about remote access, and that's
what's in my statement. That's what I believe. But
you've obviously shown me something that -- where my
recollection is incorrect.
Do you recall reading any of the reports into the
Bramble Deloitte reports?
No.
Given what we said earlier about the significance of
this and you would have asked about the Deloitte
reports, if you were aware of the Deloitte reports at
this time, would you have asked to read them?
Yes. I believe it was an error, certainly on my behalf.
Sorry, you say you believe it was an error. What are
you referring to there?
I believe, if I had been aware of the Deloitte reports,
I should have asked to see them.
Can we look, please, at a different topic. It's your
approach to litigation. POLO0006380, please. Now, this
is a paper for the steering group on the 11 September
2017, the Group Litigation steering group. You weren't
a member of that steering group, were you?
I was not.
You only became involved when it was the Board
subcommittee?
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That's correct.
We see the title is "Does Post Office support the
general strategy set out below?" Do you recall whether
you saw this document as part of your role as a Senior
Independent Director at the time?
No, I have not seen the document.
If we turn, please, to page 2, paragraph 4.3, we see the
heading is "Overall Post Office Strategy", and there's
some discussion on that, and then we get to 4.3, which
says:
"We believe the better solution is to try to force
the claimants into a collective position where they will
either abandon the claims or seek a reasonable
settlement."
It goes on to refer to the litigation funder, and at
the end says:
“Our target audience is therefore Freeths, the
funder and the insurers who will adopt a cold, logical
assessment of whether they will get a payout, rather
than the claimants who may wish to fight on principle
regardless of merit."
It says:
"To try to force the claimants into a position where
they give up or settle, we recommend a three-pronged,
approach", which we don't need to turn to.
49
"However in deciding the application, the Managing
Judge was very critical of our conduct of the case
intimating that we were not acting cooperatively and
constructively in trying to resolve this litigation
(which criticism was levelled equally between the
parties); and that we had impugned the court and its
processes by making the application for improper
purposes. This response is extremely disappointing as
this has not been our intention, and his challenge as to
the purpose for which we had applied for strikeout is at
odds with comments he had made during various procedural
hearings over the past year."
If we go up, please, to page 2 to see Mr McCall's
response. You say:
"Jane
"Many thanks for your note.
"Disappointing indeed.
“I would like to suggest we have a full update the
next time we are all together."
You say you'll leave it to Tim for thoughts on the
discussion.
What, if any, action did you take in response to
learning about Mr Justice Fraser's criticisms of the way
the Post Office had handled the litigation?
I believe, if my recollection is correct, that that's
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Were you aware of that broad strategy of trying to
force the claimants into a position where they give up
or settle, and focusing on the solicitors, funders and
insurers?
No, I was not.
In your witness statement at paragraph 36 -- we don't
need to bring it up -- you say that you recall the Board
being advised that the claim was funded by a litigation
funder and that their model would be to move quickly to
get other claimants involved?
Yes, that's correct.
Can you recall the context in which you were told that
there was a litigation funder involved and the purpose
for why you were told that?
It was just a matter of fact when the discussion came
forward about who was representing the claimants. So it
was only used as a matter of fact, a matter of
information.
Can we look, please, at POL00258369. Please can we go
to page 2, and further down, please, to Jane MacLeod's
email. Thank you. It refers to the "Case Management
Conference last week", and the decision of then
Mr Justice Fraser on the strikeout application, striking
out parts of the witness evidence that the claimants had
filed. At the bottom we see it says:
50
when we changed QCs -- now KC --
No, this is before the Common Issues trial.
Oh, I see. Then my view would be the tone and the
approach that we took.
What did you do to address the tone and the approach?
I personally don't recall, you know, I don't recall
specific conversations, other than I've said, "Look,
I think we need to discuss this, and I think we need the
Chairman to lead a discussion on what actions we should
take". That was the purpose of my note.
That can come down. Thank you.
I want to go to a different topic, please, on
contingency planning in the run-up to the Common Issues
trial. Please can we bring up page 20 of your
statement, paragraph 43. You say:
"I can recall being shocked at losing so badly when
the advice from [Post Office's] barristers had
consistently been that we had the better of the
arguments on most of the 23 separate issues under
consideration. Against that very clear and confident
advice, it was almost inconceivable that we had lost on
all material points. I also did not appreciate and I do
not believe the Board as a whole appreciated, how great
an impact the [Common Issues Trial] could have on [Post
Office's] day-to-day operations."
52
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The words you use there, "better of the arguments",
is taken from, or at least it's in, minutes recording
legal advice was given. When you hear the words "better
of the arguments", how much confidence do you think the
legal professionals had in the case, if using the term
"better of the arguments"?
It's very difficult for me to comment on the legal
professionals. My perception on the receiving end of
those comments would be that we were in a strong
position.
When you say a strong position, if you were to put
a percentage on it, what were you thinking of your
chance of success?
Better than 50 per cent.
As in anywhere from 51 per cent upwards, or?
I think it's quite subjective to put a figure on it but
I would say consistently our legal advice had been our
arguments were strong and that, based on those
arguments, my perception, and hence the use of my words
that I was shocked, I was shocked. I completely didn't
expect what had happened and so, on that basis, I said
“Well, how can we have got it so wrong? How can that be
so wrong? How could this have happened, based on our
legal advice?", and that's what I depended upon.
But from what you're saying, is it fair to say that you
53
the older ones."
I say "what king", it should be "what kind",
I think:
"Idea of good fait into contracts, [especially]
relational contracts ..."
I assume that's "especially long-term arrangements":
"New law. Unclear what a general duty of good faith
would mean."
It's there on the screen, sorry:
"Overall view is that the [Post Office] has the
better of [the arguments] in most 23 [arguments]. Don't
think it likely that the good faith claim will be upheld
but is material there for him to do so (bit of
a one-sided contract, etc) but in that case would advise
[Post Office] to appeal.”
Then, if we go to page 4, please. It says:
"Any view on how many of the 23 claims they're
likely to win? 5 or 6 significant issues where it's not
straightforward (go away and provide a summary?). Need
to manage the comms angle and work out the implications.
"Do a piece of work on impact of losing any of the
23 terms. Aiming to bring this back in July. Looking
at mitigations and what we could do now in addition to
wait ['what', I think] we do if we did lose.
Interesting to hear QCs' views on most contentious of
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hadn't considered this to be a certain victory or had
you considered it to be a certain victory?
No, I don't think you can ever say anything is a certain
victory but I certainly believed that there would be
a better outcome than there ended up being.
Can we look, please, at POL00006754. So this is
a minute of the meeting of the Subpostmaster Litigation
Subcommittee, we see it's on 15 May 2018. At the
bottom, we see you've given your apologies. Would you
have read the minutes of the meeting that were prepared
when you were -- in readiness for the next meeting?
I think you would have to assume normally, yes. But
it's difficult to recall, back in 2018.
We see Anthony de Garr Robinson QC and David Cavender QC
are listed as in attendance and, page 1, if we go down,
please, it gives an overview of the litigation. It
says, "Work out in Common Issues ['trial’, it should be
trial] what the contract means. Phase 2 work out how
the computer [it should be 'system'] worked."
The next paragraph down:
"Cl trial [Common Issues trial] -- what king of
relationship those documents in the round constitute.
We say business to business but could be interpreted
differently. Not straightforward because of the
drafting [it should be ‘of]] the contracts [especially]
54
the 23 issues."
Do you recall discussing the advice with anyone at
who attended this meeting afterwards?
No, I do not.
Would you accept that it appears that the barristers
were advising that some of the issues were not
straightforward?
When I read this document, even though the quality of
the English is extremely poor, I'd have to say yes,
there are obviously issues that are not straightforward.
And that the Post Office may lose some of them?
Yes.
It appears that the committee asked for more work to be
done to analyse the impact of a negative outcome?
Yes.
Can we look, please, at POL00006763. This is the
meeting of the Litigation Subcommittee on 10 July 2018.
We see that you're in attendance on the third line. If
you go to page 2, please, towards the bottom, we've got
"Contingency Planning":
"It was noted that the QCs had presented their
opinion on the merits of the case at the last meeting,
and had concluded that, based on the information
available to them at the time, on balance Post Office
had the better arguments.
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"In order to understand the potential impact of
an adverse outcome, the various terms sought by the
claimants to be implied into the postmaster contract had
been assessed from both a legal (likelihood) and
an operational (impact) perspective, and had been
prioritised using a simple 'RAG' approach. These were
discussed with the Committee and it was noted that, in
general, those terms which had been assessed as the most
likely, in fact had a low operational impact; and
conversely, those with the greatest potential impact
were less likely to be successful.”
It goes on to say, over the page, that:
"The Committee noted that the assessment was very
helpful."
If we look at that assessment now, it's POL00025908,
please. We can see it says "DRAFT Contingency Planning:
Risk Assessment Table", and do you see the date is
9 July 2018, at the bottom left? Do you remember
reviewing this document?
No, I don't recall seeing the document.
Do you accept would likely have been the document that
was before the Committee?
It's very hard to say, I don't recall seeing the
document and my solicitors, actually, asked from my
feedback of reading the document, could we please have
57
an implied term with a high likelihood 5 because it's
been admitted, but low operational impact of 2 for
cooperation.
Over the page, please. Similar on exercise of
powers. But, if we go, please, to page 7, we see there
at 11 there's an implied term about the relationship
and, for example, Post Office would not take steps which
would undermine the relationship of trust and confidence
between it and the subpostmasters, and the operational
impact has been listed as 4.
Over the page, shortfalls, implied term:
"Post Office would:
"A) produce, keep and maintain accurate records of
all transactions carried out using Horizon;
"B) be able to explain all relevant transactions;
"and
"C) use the records to explain any shortfalls."
It's an example of 5 on the operational impact.
Looking at that table again, do you agree you were
made aware, as a member of the Postmaster Litigation
Board subcommittee, that there were a number of
substantial adverse impacts on Post Office's day-to-day
business operations, in the event that the court
disagreed with Post Office's interpretation of the
contractual clauses?
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some more information on the document: when, who sent
it, what was it produced for, who was it from, who was
it to, who was it circulated to? And, without that,
it's very hard for me to understand, but reading it now,
I don't recall seeing the document.
Well, I'm going to ask you some questions on it and just
assist us as best as you can. We see at the top, it
says:
"This document summarises in Counsel's Opinion on
the Common Issues. By its very nature, it is simplistic
and should not be relied upon in /ieu of a careful
reading of Counsel's Opinion.
"Where we have offered a view on the impact on Post
Office, this is an initial view based on our current
knowledge and we have not sought to set out
an exhaustive list of impacts.”
Then we see below that there's a RAG analysis or
a grading table. We see on the left it’s likelihood,
Red 5 being "very likely to lose", right through to 1,
"Post Office is very likely to win the issue". On
Impact, 5, “A significant adverse impact on the
business", right through to "There will be negligible
impact on the business".
If we just go through that, for example, page 3 --
if we go further down, please, thank you ~- we see there
58
In reading the document, yes, I understand that but my
response to you would be that I hadn't seen and I don't
recall having seen the document, because I've seen no
information that I've seen it or circulated to me, and
I have no recollection of it.
I want to then move to your reaction to the judgment in
Common Issues, please. It's POL00392634. This is
an email from you to Tim Parker on 13 March 2019, so
shortly after the judgment in Common Issues. It says:
"Tim
"Apologies I was not able to stay on the call longer
“Anyway I understand we have a further call week of
18th to be scheduled.
"Outside of the call I [I assume that's ‘would’]
appreciate a private conversation on you on this topic
Pausing there, we see the subject is "GLO Call":
and it would be great if you could let me know
what might suit."
Firstly, can you recall if you had a private
conversation with Tim Parker following this email?
I don't recall specifically, no.
Well, do you recall what type of things you discussed
with Tim Parker in private conversations following the
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GLO judgment in Common Issues?
I have no recollection. I mean, we're talking March
‘19. I think to remember a conversation is extremely
hard. So I don't have a recollection of it.
This was a pretty significant moment, wasn't it, for the
Post Office?
Yes, indeed.
Is it fair to say you can remember your reaction to
learning of the decision in Common Issues?
Yes.
So is your evidence you can't remember discussions you
had in private with Tim Parker about that very issue?
I don't remember having a discussion in private with Tim
Parker.
I want to briefly touch on the recusal application,
please. Can we bring up your statement, page 24,
paragraph 50. You refer to a debate and the Board
unanimously supported the recusal application, including
Tim Franklin. You say no one on the Board, to your
knowledge, had been in that situation before. The final
sentence is:
"Given the rock-solid advice given Lord Neuberger
and Lord Grabiner that [Post Office] had ‘no
alternative’ other than applying to recuse Judge Fraser,
recusal appeared to be the only logical way forward.”
61
different question is the reasons given for why there
was no alternative to make the application?
I don't specifically remember a discussion taking place
that pointed out “Here are three alternatives" or "Here
is an approach". I don't believe there was that
discussion. I believe there was a discussion about the
rationale, as I've just explained but, other than that,
there wasn't presented a case that said "There's
option A, option B, option C"; we weren't given that.
Presumably, you knew there was option A, make the
application; option B, don't make the application?
That's correct.
So in those circumstances, can you recall what was said
or the reasons Lord Grabiner gave for saying there was
no alternative but to go for option A, to make the
application?
I can't remember his specific words but, as a layman,
it's very difficult when we've got some of the strongest
possible legal advice, when we have some of the most
senior people in the legal profession giving us that
advice and none of the Board had the experience of
having been through this before, then it was our opinion
that we had to follow our legal advice. In hindsight,
maybe we should have been far more questioning and said,
"What are our alternatives?" but I don't remember being
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Can you explain what you mean when you say “no
alternative"? Why did you think there was no
alternative?
Those were -- because this was such a dramatic
situation, I personally, and I believe my colleagues,
had never been in a situation like this before, and the
reason I remember those words is because those were the
specific words that Lord Grabiner used and that's why
I remember it. I remember those words specifically. If
there's anything I remember, it's those words: we had no
alternative but to ask to recuse Justice Fraser.
When saying there was no alternative, can you recall
what Lord Grabiner said as to the reasons why there was
no alternative?
There was a number of reasons in the discussion. There
wasn't any alternative put forward but there were
a number of reasons: reliability/credibility of Post
Office witnesses; the accusation of inadmissible
evidence; small issues being spread across the whole of
Post Office, et cetera. There was number of reasons and
rationale why, apparently, according to our legal
advice, amounted to apparent bias and, on that basis,
that was the legal advice we were given.
So those are reasons why the application may or may not
be strong or may or may not have merit. Slightly
62
presented with any at the time.
In your statement, you refer to Tom Cooper recusing
himself from the vote on the recusal application. Now,
in the Board meetings can you remember Tom Cooper
expressing a view on the application?
I remember that, in speaking -- I remember first of all
the Chairman recused himself because of an existing
accountability and then, I don't remember the exact
time, either just before or the day before, Tom Cooper
recused himself. But it was my clear understanding that
there was a unanimous opinion that we should proceed
with recusal. I don't recalll in any way any -- I have
no recollection of any dissenting word that said no.
Did you have a view on Mr Cooper's decision not to
participate in the vote?
I had to respect his opinion.
You can respect someone's opinion and agree or disagree
with it; did you have a view on whether you agreed or
disagreed with his decision to recuse himself?
I understood his position but I was a little bit
surprised.
Why?
I understood our Chairman had a conflict, which was very
evident, but I wasn't sure what the conflict was in the
case of Mr Cooper.
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Can we look at your statement, please, page 25,
paragraph 52. Turning now to the preparation for the
Horizon Issues trial.
Sorry, I'm not sure what I said, but it's page 25,
please. Speaking, actually, post-Horizon Issues trial,
you say:
"I do not recall that losing the [Horizon Issues
trial] came as a surprise to myself or the Board. In
contrast to the [Common Issues trial] judgment the,
legal advice we received before the [Horizon Issues
trial] judgment was much more pessimistic given that we
had lost the recusal application. It was clear Judge
Fraser had a strong view and, for the same reasons we
applied to recuse him, such as his criticism of POL's
witnesses, we did not expect his findings in the
[Horizon Issues trial] to be favourable to us."
So I think what you're saying is the legal advice
changed after the recusal application failed on Horizon
issues; is that right?
I would say the legal advice we were given became far
more balanced, as opposed to convincing, that Post
Office had a strong case.
So you refer to losing the recusal application and you
say about Judge Fraser's strong view. Are you saying
that before Horizon issues but after the recusal
65
of the grounds I understand, you took into account when
deciding to issue an application to recuse Mr Justice
Fraser, yes?
Yes.
So you presumably believed that the strong view
Mr Justice Fraser had taken on some of the witnesses was
a ground for arguing that he was apparently biased
against the Post Office?
That was our legal advice.
Well, did you believe it?
I believed the legal advice.
Did you believe or did you agree with the underlying
proposition?
I believed -- I believed that that was a factor but it
was based on the legal advice that we had been given.
So when you're now thinking about the Horizon Issues
trial and saying, "Well, we think our prospects of
success are low because of the strong views Mr Justice
Fraser had taken", what did you think of the fairness of
that?
I find it very hard to comment on the fairness. What
I feel more comfortable commenting on was our legal
advice gave a number of reasons which amounted to --
according to our barristers was apparent bias. So —-
Yes, but -- sorry, I interrupted you --
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judgment you thought that Mr Justice Fraser would find
against Post Office because you believed he'd developed
strongly critical views of the Post Office?
One of the key points put forward in our advice on
recusal was his strong criticism of Post Office's
witnesses and, on that basis, if those same witnesses
were the witnesses in the Horizon trial, there was
a strong belief that the arguments of Post Office would
not be favourable to securing a judgment.
At this point, did you think that you were predicting
losing the Horizon Issues trial because of the judge's
approach to the Post Office witnesses, rather than the
substance of the matters themselves?
I think it's very difficult to talk about the substance
of the matters itself because, obviously, myself and
none of my non-executive colleagues were employed by
Post Office at the time, the historical or the Legacy
Horizon systems were in place. So my knowledge of those
Legacy systems is very limited indeed. My position here
is that I said our inability to have Judge Fraser recuse
himself was, in simple terms, due to three or four
factors which would not stand us in good stead in the
Horizon judgment.
Well, let's take one of those factors. You said the
views he took of the Post Office witnesses, that was one
66
Sorry. And, on that basis, given a collection of
issues, as opposed to just one issue on its own, we
voted unanimously to proceed with the recusal
application.
Mr McCall, the point I'm trying to get at is whether
you, as the Senior Independent Director and your view of
the outcome of the Horizon Issues trial, whether you
thought or believed that it was there was a lack of
robustness with Legacy Horizon, as a matter of fact, or
whether it was because you thought that the judge had
taken strongly against your witnesses and it was just
the outcome of the trial?
I think my knowledge, as I said earlier -- my knowledge
of the robustness of a Legacy Horizon system was very
limited. I wasn't at Post Office. I had no knowledge
of that system whatsoever. But the judgment that you're
asking me on, I would -- I believed that the judgment
was given on the basis of that the Legacy Horizon system
was not robust.
I want to look at, now, some of the issues after the
judgment and the steps that Post Office took in
response. Could we look at, please, POL00021586. It's
a Post Office Board meeting on 30 June 2020, and we see
you're there on the third line down.
Can we please turn to page 5. We have "Postmaster
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Engagement/Representation". It says:
"Nick Read explained that we were trying to
rebalance the relationship between [Post Office] and
postmasters recognising the historical position and the
GLO. The partnership during the Covid-19 situation had
been very positive and built up trust. We wanted to
forge a proper partnership and make running a Post
Office an attractive proposition."
It goes on to describe some roadshows. The second
paragraph says:
“Amanda Jones noted that the position had been
moving quickly and the conversations with the
Non-Executive Directors and UKGI had been very helpful.
We had taken on the suggestion to extend the
consultation period", et cetera.
Do you remember the conversations you had with
Amanda Jones at this stage, regarding postmaster
engagement?
Not the specific conversations. I remember that -- Nick
Read carrying out roadshows to try and rebuild trust, to
listen to subpostmasters, to try and connect exactly
with those people that were part of our network and that
were running the most important part of our Nationwide.
And so I remember the roadshows, I remember that the
attendance was very good. I don't remember specific
69
Office choosing two people; it was actually the
postmasters themselves choosing who the representatives
would be. I remember that that was the principle of
independence and the subpostmasters should have the
ability to do that. That's my recollection.
Were you involved in establishing or advising on
establishing how the appointees would be selected?
I don't recall that I was.
That can come down. Thank you.
I want to ask you some broader questions, which
touch on the next phase that the Inquiry is going into,
Phase 7. Aside from what we've just referred to there,
the subpostmasters on the Board, what other steps had
the Post Office Board taken, following Horizon Issues,
to try to address the culture of the organisation and
the criticisms made by Mr Justice Fraser?
There were a number of workstreams instituted to try and
improve the relationship; there was technology, such as
the branch hub system, which was to try and address the
speed, the feedback, the ability of subpostmasters to go
online and address any challenges or queries they had
themselves; the ability of Post Office, through that
branch hub network, to be able to communicate far faster
and far more quickly to subpostmasters; there was
a strong push to try and improve the communication, in
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details. I think there was four or five, or maybe half
a dozen roadshows, and the information that came back
was that they were welcome, they were very positive and
they provided good feedback.
If we look at the bottom of the page, please. There's
a bullet point that says:
“Tom Cooper noted that it was important to establish
that the ... Board was comfortable with the proposals to
include one or more postmasters on the Board. All of
the Directors confirmed that they were comfortable with
the proposal and would prefer that two postmasters were
appointed to the Board."
It goes on to say they should be Non-Executive
Directors and remunerated as such.
Then at the bottom, it says:
“As noted, we would need to think carefully about
the selection process and also the credibility of the
appointees with their constituency."
Can you recall the discussion on the selection
process and credibility of appointees at this Board
meeting?
Not that -- I can't recall the specific discussion.
What I do recall is that we were very keen to ensure
that the subpostmasters joining the Board were recruited
and independent. So, therefore, it wasn't the Post
70
addition to having two subpostmasters on the Board to
help advise, guide and give the Board confidence that
the subpostmasters were being represented in terms of
strategy, communication and support.
So there was a much stronger push to get a lot
closer to the network and the people through some of
these initiatives.
As at the time you left, which was January 2022, what
did you think of the adequacy of those measures in
practice?
My recollection is that we had high 80s, maybe
90 per cent of the branch network connected and working
with branch hub. The two subpostmasters were
an excellent addition to the Board and gave really good,
strong at times and honest communication and feedback,
and I thought they were doing an exceptionally good job
in representing the subpostmasters.
And I felt Nick Read was really strongly trying to
get as close as possible to the subpostmasters and
improve the relationship between Post Office Executive
and the network. So I felt that the moves that were
made were very positive.
What was the culture of the Board like at the time you
left?
left in January '22. The -- myself and my colleagues
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who were there tried our hardest to address the
historical issues and to, in some small ways, try to put
right what had gone wrong, as we were -- none of us had
been in position at the time. And so the culture was
one of trying to help, trying to assist, trying to
address the historical issues and trying to work hard to
build the credibility. And there were some very
talented non-executives that were still on the Board of
the Post Office, and so I would say the Board culture
was very positive indeed, and Mr Parker was a good
Chairman that was very inclusive in trying to make sure
the Board was very focused indeed.
You've mentioned already Nick Read. What was your view
of him as Chief Executive in dealing with the issues
that arose from the GLO judgments?
He was a strong communicator. He tried to get round the
network as much as possible. He would welcome feedback.
His style was open and engaging and he was also
detailed, and so, therefore, I was very positive about
his approach to rebuilding trust between the Post Office
and the subpostmasters.
What about the relationship between Nick Read and
Alisdair Cameron; did you have any views on that?
In what terms?
Well, 'm just asking if you had any comments to make on
73
changes or proposals you would make to corporate
governance or the role of the Non-Execs to avoid
something like this happening again?
I think I'd have to reflect on that and take a bit more
time to answer the question in any sort of level of
detail. It's very hard, when you are attending as
a non-executive one or two days per month, to get --
other than the agenda and what is on a Board or
a subcommittee agenda, it's very hard to get a much
stronger feeling throughout the organisation on the
culture or the effectiveness. I certainly feel that the
induction could be strengthened, both in Post Office and
on the Government's expectation of a non-executive in
that company.
But I viewed Post Office as a trusted institution
that had been around for hundreds of years and I felt no
requirement to do strong investigations or due diligence
before joining. It's something I regret now and
I should have paid more attention to. But I think the
training and induction and the expectation of the major
shareholder -- and I think also the complication of the
business because, at the time, you know, this was
a Financial Services banking joint venture. It was
a broking business, it was a payments business, it was
a mails business, it's a parcels business. It is -- it
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if it was an effective working relationship?
A. I never saw that it wasn't an effective working
relationship.
Q. Do you have any other views on that matter?
A. No, sir.
Q. What are your views on the composition of the Board when
it left, in terms of did it have sufficient expertise to
deal with the matters before it?
A. As Isaid earlier, I believe it was the year before
I finished my second term and stepped down, and Ben
Tidswell, who joined the Board from a legal professional
background, was a great addition to the Board and I felt
that was very positive indeed.
The Chair of the Audit Committee was extremely
competent and an experienced Executive, and as was one
or two of the others. A replacement had started for me,
but that was his first Board meeting, so it's impossible
for me to comment.
But I was certainly very positive, although it was
going through a period of change with me leaving and
with the Chairman going to leave later in '22.
Q. The Inquiry will be considering issues of corporate
governance and the role of Non-Executive Directors when
it considers matters. Do you have any thoughts or
recommendations, having reflected on matters, for any
74
was a complex business and I think making sure that any
induction in process takes account of all those
businesses would be more preferential.
Q. Finally, just picking up on one thing you said earlier,
do you think that two days per month for a non-executive
at Post Office is insufficient time to carry out the
role effectively?
A. I think two days per month under normal circumstances,
and I caveat that because most of the non-executive
appointments, leaving aside Post Office itself, most of
the non-executive appointments are two to three days per
month. That's a common figure and should be sufficient.
In the case of what has happened here, patently it would
have been, and we ended up spending a lot more and
allocating a lot more time to Post Office, but normally
it should be sufficient.
MR STEVENS: Thank you, those are all the questions I ask.
Sir, I'm just going to check if there are any Core
Participant questions and if there are or if there
aren't, then we can take a view on whether it's an early
lunch or a break.
SIR WYN WILLIAMS: Yes.
MR STEVENS: It's just Ms Patrick who would seek five or ten
minutes. I am just looking at the transcriber --
The transcriber is happy to continue and then we can
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take an early lunch.
SIR WYN WILLIAMS: Yes, by all means. Over to you,
Ms Patrick.
Questioned by MS PATRICK
MS PATRICK: = Thank you, sir.
Mr McCall, my name is Angela Patrick and I ask
questions on behalf of number of subpostmasters, who
were prosecuted and convicted and have since had their
convictions overturned, and you see two of my clients
are sitting next to me: Ms Hamilton, on the left, and
Ms Hall, on my right.
You'll be glad to hear I've got one issue and one
document I want to go to and ask you about.
But before we go back to that, I just want to set
the scene. You can recall, I think, Mr Stevens took you
this morning to a minute from February 2019, where the
issue of the Deloitte reports were discussed. He asked
you.
"So your evidence appears to be that you were told
of the Deloitte review, the report, you attended a Board
meeting at which you asked Mr Parker why he didn't
provide the information earlier."
Then you replied:
"Yes, that's correct", having seen the minute.
He also took you to a minute of 21 February and
77
"To what extent can the court protect POL against
journalists overstating the evidence re Horizon? If
a journalist writes that there's evidence of systematic
problems with Horizon when in fact no evidence exists,
will the court help us [at all]?
"Seems to me it's extremely important to have
a press strategy that seeks to stop misrepresentation by
journalists and seeks to protect POL's business today
against the implication that the current system doesn't
work properly.”
That's to Jane MacLeod, I think. There's no other
Jane on the message.
Now, this is after the meeting, where there's
a discussion with Mr de Garr Robinson and there's
a conversation about the Deloitte report and remote
access. Now, here Mr Cooper is asking about how to
protect the position of the Post Office and in press
reporting during the GLO, isn't he?
A. Yes, that's what's written there.
Q. Was that a concern that was shared more widely on the
Board or on the Subcommittee?
A. Not particularly.
Q. But the subcommittee we see here, could be involved in
strategy for the Post Office during the GLO, including,
on communications and interaction with the press; is
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I think, if you can recall, that's the one where you and
Mr Parker attended by phone and, again, Deloitte and
remote access were discussed. Can you recall that
exchange with Mr Stevens this morning?
Yes, I do.
Of course. That just sets the scene for the document.
Can we look at POL00111699, please. If we can
scroll to the last page, which is page 3, I'd be very
grateful. If we can scroll a little way further down,
please. Do you see there at the bottom, you can see
there's a dial-in detail for that meeting, GLO
subcommittee, 21 February 2019, you see the meeting was
to be 11.00 to 12.00, and the various dial-in details,
including your name there; do you see that, Mr McCall?
Yes, I do, thank you.
Can we scroll up a little and we can see where this
email goes. If you scroll a bit further, I can see that
first message. You see there's a message there from Tom
Cooper, and it isn't copied to you but, just to set the
scene, he says:
“Jane
"One follow-up from the call.”
Presumably that was the meeting earlier that morning
because the timing on this is 12.47. If we read it
together, he is asking:
78
that right?
No, I think the subcommittee was involved in the -- in
items that were escalated by the day-to-day executive
who was managing the litigation.
It would be open to you, as a member of the
subcommittee, in the way that Mr Cooper is here, to ask
questions about anything around the strategy on the
litigation; is that fair?
That's fair but, as you can see from this email, I'm not
copied on the email, so -
I'll stop you there, Mr McCall. If we can scroll up so
we can see the next message in the thread. Stop there.
We see Ms Vennells replies, very shortly thereafter at
1.21, and she does copy you in; can you see that there,
Mr McCall?
Yes, I can.
So you're copied in, and you see Mr Cooper's question to
the other members -- to the members of staff but also
copied to his fellow subcommittee members. So you did
receive that message, didn't you?
It says there's an email, and I'm sure I then received
it.
Okay. I just want to have a quick look at what
Ms Vennells is telling you about the strategy in
response to Mr Cooper's enquiry. She says:
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"Yes we defend robustly but we avoid adding extra
coverage."
If you recall, this is after the meeting where we
know that you've had a conversation about remote access
and Deloitte:
"As before we hold the ground: the system is robust.
And not comment any further during the trial. So
‘aggressive’ no, robust -- absolutely no question.”
If we scroll down a little bit further we see she's
talking a little bit about the strategy and how it's
gone so far:
"The strategy has worked well so far, which is to
minimise coverage in mainstream media. Therefore, we
don't engage in any public debates, we have strong lines
but we add no oxygen by commenting or engaging. This is
not new news despite how the claimants will present it
as that; our approach is to curtail interest as much as
possible."
Then she goes down to sort of talk about the
question about legal options that Mr Cooper has raised:
"Your questions re how far we can go ‘legally’ are
important. We have used injunctions and demanded
apologies in the past. They are both to be used but
with caution. They gain more coverage, which is not
always balanced. But there are tools in the box
81
we should see Mr Davies' response to Ms Vennells'
outlining of the strategy and, again, copies you in.
We'll take this very briefly because it's, essentially,
repeating the message but with some greater detail:
"Our external communications strategy is to minimise
negative coverage by holding the robust line we have
deployed throughout. In doing so we have succeeded in
minimising coverage in the mainstream media.”
I want to cover this in great detail because he goes
over how different approaches have been taken in the
press, But he says:
"There is a group of journalists who have staked
their professional representations on campaigning on
behalf of those who have now taken us to court. They --
and one in particular -- drive most of the periodic
increases in external coverage. We have sought to
engage with this group but there is an unwillingness to
engage with our side of the story."
If we skip down a little further:
"Private Eye has also featured the issue regularly,
claiming Post Office has knowingly covered up evidence
of what it calls the ‘deeply dodgy’ Horizon system. We
believe the content in Private Eye is almost certainly
provided to it by one of the ‘campaigning’ journalists
who have staked their reputation on proving that Post
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(Portland are very experienced about this too ...)"
Portland, was that an external PR agency that the
Board was consulting?
That would be the responsibility of the Executive.
I don't know the name Portland specifically, and I never
met anyone from Portland. So I'm presuming, in the
circumstances of what I see written, it would be managed
by the Executive and that's who they are.
So here, Ms Vennells is writing to the whole
subcommittee, updating you on the approach they're
planning to take to the strategy around the GLO. She's
saying, "Maintain the position that the system is
robust", strategy is to be "aggressive, no, robust --
absolutely no question".
Was this the strategy towards press engagement on
which the subcommittee was essentially agreed?
Well, the subcommittee weren't responsible for the press
engagement. There was a communications director working
with the CEO, and the General Counsel, and they were
responsible for all the day-to-day strategy around
communication and what was said by the company in
addition to shareholder inputs or the subcommittee
wasn't on a day-to-day basis involved in this.
Okay. Can we just scroll up a little to see the last in
the line of communications. On the first page, I think
82
Office has conspired to see otherwise innocent people
jailed or penalised."
Now, first, Mr McCall, can I ask you: how closely
did Mr Davies work with the subcommittee at this time
during the development of strategy on the GLO?
As I said -- and let me repeat again -- Mr Davies, the
General Counsel and the Chief Executive were responsible
for the communications strategy and anything that was
responded to by Post Office. The subcommittee wasn't
day-to-day responsible at all.
I'll just stop you there, I've got one last question for
you, Mr McCall. This is February 2019. This message
which goes to the whole subcommittee talks about the
campaign. There's been a campaign by this stage for
a very long time, in which my clients, including
Mrs Hamilton and others, were deeply engaged. They've
managed to get their case into court, there was
a subcommittee of the Board set up to lead the strategy
on that litigation.
You are the Senior Independent Non-Executive
Director, you've agreed today that part of your role was
to represent the interests of the shareholder, who is
the taxpayer, the Government. Are you really suggesting
at this point -- and if I can remind you, you've
accepted the Board would have been aware that the
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picture on remote access was very different from that
which may have been presented at an earlier stage -- are
you really suggesting that, if you thought that the
strategy that was being presented by the Executive Team
was out of step or might be causing some risk to the
business, that you could not step in and say something?
A. I'm suggesting to you and I'm answering to you quite
firmly: the subcommittee is not responsible for the
communications strategy. There was a document produced
earlier today talking about the strategy of the
litigation. I didn't sit on the subcommittee of that.
I had never seen that document before and I'm copied in
here on an email, but I'm not responsible for the
communications strategy. I was the Senior Independent
Director, and I accept that, and I received the email,
I'm absolutely certain. But I wasn't responsible for
the strategy.
MS PATRICK: Thank you very much, Mr McCall. I don't have
any other questions for you.
‘SIR WYN WILLIAMS: I Is that it, Mr Stevens?
MR STEVENS: That's it, sir. Yes, that's all the questions.
SIR WYN WILLIAMS: Fine.
Well, thank you, Mr McCall, for making a witness
statement, as the Inquiry requested of you, and thank
you too for giving evidence this morning before me. I'm
85
you; do you have that?
A. Ido.
Itis dated 19 June 2024. If you could turn to page 73
of that, please. Do you have a copy with a visible
signature?
Ido, yes.
Is that your signature?
Itis.
2
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For the purposes of the transcript the reference for
Ms Tolhurst's statement is WITN10930100. Ms Tolhurst,
your witness statement is now in evidence and will be
published on the Inquiry's website in due course. As
such, I will not be asking you about every part of your
statement, just certain specific issues which are
addressed in it?
A. Okay.
Q. I'd like to start, please, with an overview of your
professional background and career in Government to date
you explain in your statement that you, before taking up
an elected role, ran a marine business for 17 years --
A. That's right.
Q._ --training as a marine surveyor during this time?
A. Correct.
Q. You were elected to Medway Council in 2011, representing
the Rochester West ward?
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very grateful to you.
THE WITNESS: Thank you, sir.
‘SIR WYN WILLIAMS: So what time shall we resume, Mr Stevens?
MR STEVENS: I wonder if we could resume at 1.35 and then,
because it will be a longer session, take two breaks but
that should give us sufficient time, I think, to cover
the evidence.
SIR WYN WILLIAMS: All right. 1.35.
MR STEVENS: Thank you, sir.
(12.44 pm)
(The Short Adjournment)
(1.35 pm)
MS PRICE: Good afternoon, sir, can you see and hear us?
SIR WYN WILLIAMS: I can indeed, thank you.
MS PRICE: May we please call Kelly Tolhurst.
THE RIGHT HONOURABLE KELLY JANE TOLHURST (sworn)
Questioned by MS PRICE
MS PRICE: Can you confirm your full name, please,
Ms Tolhurst?
A. Yes, Kelly Jane Tolhurst.
Q. As you know, my name is Emma Price and I will be asking
you questions on behalf of the Inquiry. Thank you for
coming to the Inquiry to assist it in its work and for
providing the statement which you have. You should have
a hard copy of that statement on the desk in front of
86
Correct.
You were elected as an MP in May 2015.
Yes, correct.
You served as Assistant Whip to the Treasury from
9 January 2018 to 19 July 2018?
Correct.
prop
oP
Following that, you served as Parliamentary
Under-Secretary of State for the Department for
Business, Energy and Industrial Strategy from 19 July
2018 to 13 February 2020, where you were responsible for
small businesses, consumers and corporate
responsibility?
Correct.
This was your first ministerial appointment?
Yes.
Was it in this role that you became involved in some of
the matters which the Inquiry is concerned with?
That's correct.
prop
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You went on to serve for a little over six months as
Parliamentary Under-Secretary in the Department of
Transport?
A. That's right.
Q. Followed by serving as Parliamentary Under-Secretary at
the Ministry of Housing, Communities and Local
Government between September 2020 and January 2021?
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Correct.
You were Deputy Chief Whip in the Commons from July 2020
to September 2022?
(No audible answer)
You then served as Minister of State at the Department
for Education for a short time, before serving at the
backbenches until the recent election?
Correct.
Is it right that the only time you have had involvement
in matters relevant to this Inquiry was when you were
Parliamentary Under-Secretary of State for the
Department for Business, Energy and Industrial Strategy?
Yes, that's right.
Moving then, please, to the civil servants who assisted
you when you were Parliamentary Under-Secretary at BEIS,
if I have understood your evidence in your statement
correctly, there were, broadly speaking, three pools of
civil servants who provided you with assistance on Post
Office matters. First, Private Secretaries from the
Department's private office?
Yes.
Second, officials who were subject matter experts in
particular policy areas --
(The witness nodded)
-- who, for the part of your role which related to the
89
a Minister, as potentially an amateur in the space in
which you're operating -- for example, in this
particular instance I didn't have any particular
experience within the Post Office or that kind of
structure -- so for example, the objectivity would be
important because, obviously, you would want to be given
advice where you feel that they weighed up both sides of
things, so you would be confident in the fact that you
were taking a decision or had information that was sound
and also had been looked at from a number of different
points of view.
So I think, when they're giving you that advice,
it's important that you have that range of the
‘objectivity, so that you can make decent judgements
based on what's put in front of you.
Turning, then, to the information you were given about
the Post Office, in the early period when you took up
your role as Parliamentary Under-Secretary at BEIS, you
explain at paragraph 9 of your statement that you had
a broad policy portfolio covering a range of sectors and
it was just a busy portfolio that it was, in fact, split
into two after you left BEIS; is that right?
That's correct, yes.
So there was a lot to get on top of?
Yeah.
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Post Office, worked for UK Government Investments?
Yes, that's correct.
The third category, from August 2018, when it was
established, were officials from the Post Office Policy
Team within BEIS; is that right?
That's right.
So far as your Private Secretaries were concerned, is it
right that they dealt mainly with managing your diary,
preparing paperwork for your ministerial box and
managing correspondence?
Correct.
In terms of advice you received from officials, you
addressed this at paragraph 12 of your statement. Could
we have that on screen, please it's page 4. Towards the
bottom of page 4, please. You say here at paragraph 12:
"The breadth of a Minister's portfolio is such that
they have to, to a greater or lesser extent, rely on the
advice of officials and make decisions on the basis of
it. Ministers expect the advice given to be competent,
accurate and reliable, honestly given and on the basis
that objectivity has been applied in the analysis of the
facts."
Why was the application of objectivity in the
analysis of the facts important?
In my ~ so, in my view, when you're coming in as
90
You were given an entire portfolio briefing to start
when you arrived in post; is that right?
Yes, sorry. Yeah.
You also received a briefing on postal affairs,
specifically?
Yes. For the whole of the brief, it's quite common for
new ministers to be given sort of a day 1 briefing on
all of the different elements that are included within
the brief because, within the brief of a minister, there
may be things that you would have more sight of than
others.
If we could have paragraph 13 of Ms Tolhurst's statement
‘on screen, please. That's page 5. In referring to that
briefing on postal affairs specifically, you say in the
last line:
"I was provided with some outline information
regarding the Horizon IT system issues."
At paragraph 14, is that your assessment of what you
understood those issues to be at the time, at
paragraph 14, there.
Yes. It was my assessment of what -- you know, the
information that I had at the time, yes.
You say:
"I understood at that time that a civil claim was
being brought by a number of SPMs in relation to
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accounting losses suffered in branch as a result of the
Horizon IT System. I understood that SPMs were alleging
that there were widespread problems with the system and
that [Post Office Limited] denied this. I knew that
several SPMs had been convicted for accounting losses."
You refer at paragraph 15 of your statement to
briefing documents which you received on 16 August 2018.
Yeah.
Looking first, please, at how these briefing documents
came to you, could we have on screen, please,
UKGI00008342. Starting, please, with the original email
dated 10 August 2018, which starts about two-thirds of
the way down the page. This is from Stephen Clarke,
from the Post Office Shareholder Team at UK Government
Investments. Going over the page, please, Mr Clarke
says:
“Please find attached" --
Actually, apologies, if we can just go back, please,
to who this was sent to. This was initially from
Mr Clarke to the Permanent Secretary's private office:
is that right?
Yes.
Going back over the page:
"Please find attached an update submission (with
5 annexes) on the Post Office Horizon litigation case.
93
it?
Yes.
Just scrolling down a bit, please. It says:
"Hi Sam..."
Was Sam your Private Secretary?
Yes, she was. One of them.
One of them?
Yeah, one of them.
“As discussed, here is the info submission that went to
the Perm Sec on the Post Office Horizon Litigation. I'm
sending this now for information as we won't be getting
any comments back from Alex before the Minister goes
away again.
"The recipients list in Annex 2 has been updated
There's a reference to getting the new SpAd on
board.
We can see from the list of attachments with the
updates submission, just looking there under "Subject",
the first attachment is the submission itself, and then
we have five annexes listed. So it appears from this,
doesn't it, that both the submission itself and all five
annexes were sent to your private office on 16 August?
(The witness nodded) Yes, sorry, yes.
The transcriber has to get your words.
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This is an info sub to (i) bring Alex up to speed on the
case ..."
Was that Alex Chisholm who was the Permanent
Secretary?
Correct.
(ii) brief Alex on safeguards for handling [Post
Office Limited's] legally privileged information under
the Disclosure Protocol and (iii) focus on plans for the
oral briefing on 10 September by [Post Office Limited's]
Legal Counsel. Please note that [Post Office Limited]
have password-protected their background briefing
(Annex 3) as an extra safeguard; the password will
follow ...
"For the benefit of copy addressees who saw this sub
in draft a few weeks back, I should explain that the sub
was put on hold while we collected the required
signatures for recipients on the disclosed description
list.”
Then there is a request not to share the submission
beyond the closed distribution list.
This email was then forwarded to your private
office, going back to the first page, please, on the
16 August 2018. So if we scroll from the top, we can
see from Stephen Clarke to -- we can't see the full
email address but that is to your private office, isn't
94
Apologies.
Thank you. It appears from your statement that you read
the submission dated 10 August 2018, which was the first
attachment to this email, because you refer, at
paragraph 23, to background information which you
derived from the documents provided to you on 16 August,
making specific reference to a paragraph of that
submission. Is that right, that you read the submission
itself at the time?
In regards -- I believe I did read the submission at the
time. Being a new minister, I had quite a lot to get
through and I would have read it because I did try and
read everything that was put in front of me, which
sometimes was a frustration to some.
Was this the first briefing that you had received
specific to the Group Litigation since becoming
Parliamentary Under-Secretary?
I believe so.
I'd like to explore, please, whether you read any of the
annexes which were sent to you, which were discussed in
the submission.
If I can stop you there, in your statement it's not
entirely clear which of the annexes you think you would
have read at the time. So if we can just take that in
stages. But, forgive me, you wanted to say something?
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No, apologies, I was sort of pre-empting what you were
going to say. In relation to the annexes, I remember
obviously reading the briefing. The protocol was
something that I obviously remembered -- remember,
obviously, being put in front of me because obviously it
was subject to me being given further information. And,
yeah, I don't remember what I was feeling at the time in
August when I would have read those, and I may have read
them sort of later than -- it might not have been on the
10 August, it might have been sort of later on when I --
when the documents may have been shared with me.
They were sent to your private office on 16 August?
16th, sorry, yeah.
I think it would have been after that date, if you did.
Yeah.
But let's just take it in stages. If we can have on
screen, please, paragraph 20 of Ms Tolhurst's statement,
that's page 7. So you say here:
"As to the other annexes, Annex 1 was the
Information Sharing Protocol [which you'd referred to
just now] and Annex 2 was the On-Boarding Protocol.
I do recall receiving those documents at the time, but
I do not remember reflecting on them."
Did you read those two annexes?
I believe I did.
97
it -- well, as I've said in the statement. But I don't
remember being given the QC's views on the merits of the
case. So that's all I can sort of, you know, genuinely
sort of -- with what I can remember from the time and
sort of looking back now.
Looking, please, to the 10 August submission itself,
could we have that on screen, please. The reference is
UKGI00018266. We can see there at the top the date, and
the submission title, "Post Office Limited -- Horizon
Litigation Update". Towards the bottom of page 2,
please, there is a heading "Litigation background
briefing and updates", and paragraph 8, underneath that,
contains this:
"Following the agreement of the Protocol, [Post
Office Limited's] Legal Counsel provided an initial
background briefing on the litigation (Annex 3)
including their QC's view on the merits of the case, and
has since provided a further update (Annex 4) following
discussion of the case at [Post Office Limited's] last
Board meeting on 31 July. For ease of reference, in
Annex 4, UKGI has highlighted in yellow any information
that is new and worthy of note.”
So this was in the submission itself flagging the
existence of both Annex 3, which contained the QC's view
‘on the merits, and a further update from Post Office
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You would have been aware, from those documents and in
fact from the submission, that Post Office Limited, BEIS
and UKGI had by this time established a disclosure
protocol which governed the flow of legallly privileged
and confidential information in respect of the Horizon
litigation from Post Office Limited to UKGI and BEIS; do
you recall that?
Yes, I do recall that.
Can we have on screen, please, paragraph 17 of
Ms Tolhurst's statement. That's page 6. You say this
of Annex 3:
“At paragraph 8 of that submission, it is recorded
that ‘following the agreement of the protocol, [Post
Office Limited's] Legal Counsel provided an initial
background briefing on the litigation (Annex 3),
including their QC's view on the merits of the case’."
You say here:
"I did not receive this Annex 3 at the time and have
not seen it since."
Just to clarify, Annex 3 was sent to your office
under cover of the email of 16 August. We've seen that
from the email. Albeit that it appears in the original
email sent, it was password protected. Can you help
with why you say here that you did not receive it?
Well, I don't remember receiving it and I hadn't seen
98
Limited's Legal Counsel at Annex 4, with anything that
was new and worthy of note highlighted. Did you ask to
see either of those documents when you read this
submission?
I genuinely don't remember. All I would say is that at
the time it would have been over the recess period, so
I don't remember specifically asking for that. So
I would be wrong to say anything else other than that,
really. But it would have been a period where we
weren't -- I wasn't necessarily in the Department, so
I may have been in the constituency, so it might have
been something that I maybe didn't request.
Looking, please, to paragraph 11 of the submission,
a little further down the page. This explains the
purpose of the oral briefing from Post Office Limited's
legal counsel, which was scheduled and which you were
going to be attending, for 10 September. Is it right
that you think this, in fact, occurred on 17 October?
Yes. I believe it did. I've sort of checked my diary,
and I actually had -- I think I had another what they
call a statutory instrument debate at the time it was
originally proposed. So I think that may have been the
reason why it didn't take place.
This is the explanation given of the meeting:
"The briefing is confirmed in your diary and the
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Minister's diary for 10 September. A proposed agenda
and list of attendees drawn up between UKGI and [Post
Office Limited] is attached [at Annex 5]. [Post Office
Limited's] Legal Counsel, Jane MacLeod, Chair Tim
Parker, and CEO Paula Vennells (via telephone/video
link) will brief you on the key issues at stake, as well
as on the financial, reputational and operational
implications (which could be considerable) of an adverse
ruling at November's ‘Common Issues trial’ and/or at the
‘Horizon trial’ in March 2019 and [Post Office
Limited's] contingency plans for dealing with these
risks. This will be an excellent opportunity for you
and the Minister to exercise Shareholder scrutiny and
seek reassurance on any issues of concern."
So this was flagging up, was it not, that there were
financial, reputational and operational implications,
potentially considerable ones, if there were adverse
findings for Post Office Limited at either Common Issues
or the Horizon Issues trials --
Yes.
-- and that contingency plans for dealing with these
risks were in train?
Yes.
It was also flagging what was expected of the Permanent
Secretary and you at the meeting, which was an exercise
101
‘over and above the inherent risk of any legal dispute?
Well, in relation to -- I'm just looking at -- I mean,
ultimately, I think, at that particular time, all the
informal -- the briefing that I'd been given, sort of
didn't suggest at that particular time that there was
anything particularly that I should be aware of or that
would mean that there would be sort of more -- well, as
big as it obviously -- what we now know the risks and
the troubles relating to the litigation.
So I hadn't been given the impression new into the
post that there was anything particularly to worry about
and, obviously, that sort of -- that was my
understanding sort of going into that meeting. At the
time, I suppose I was more concerned with actually any
kind of litigation, what that would mean for the Post
Office, what it would mean for the Government. But that
was sort of the limits of my sort of thinking at that
time.
You say in the paragraph above, paragraph 23, that:
"The only background information [you] derived from
the documents ... was that ‘the independent
investigations by Second Sight ... found no evidence of
flaws in the Horizon IT System’."
That is taken from paragraph 12 of the submission
itself.
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of shareholder scrutiny —-
Mm-hm.
-- as well as it being an opportunity to seek
reassurance on issues of concern. When you read this,
did it make you think to ask for Annex 3 or Annex 4: the
QC's views and the new and noteworthy information?
Genuinely, I can't say if it did or not at that
particular time. So I can't honestly tell you whether
or not -- what I thought about in relation to those
annexes you've outlined.
Could we have on screen, please, paragraph 24 of
Ms Tolhurst's statement, that's page 8. Your comments
in this paragraph are made in the context of the
documents sent to your office on 16 August, including
the submission itself, and in the first half of the
paragraph you say this:
"I do not recall any advice being given at the time
regarding the risks of the litigation. I was not given
the impression that [Post Office Limited] were anxious
about the litigation, or that there was any particular
risk involved with the litigation over and above the
inherent risk associated with any legal dispute."
Can you help, please, with why you took from the
submission -- and paragraph 11 in particular -- that
there was no particular risk involved in the litigation,
102
Given that this was background information which you
derived from documents at the time, did you ask to see
Second Sight's Report?
No, I didn't ask to see Second Sight's Report.
At paragraph 25 of your statement, you say that it was
obvious, notwithstanding your comments at paragraph 24
about what you appreciated in terms of risk, that the
litigation was going to be an important part of the
postal affairs brief, and you say that you did not think
that the information provided in August 2018 had given
you the information necessary to provide effective
leadership from within BEIS in respect of the
litigation.
You go on at paragraph 26 to say that you are
someone who is interested in the detail and concerned to
have all of the relevant information before taking
a decision.
Over again, please, at 27, you say this:
"For that reason, I requested further information,
and I was provided with the short further document
entitled ‘Briefing for Kelly Tolhurst MP, Postmaster
Litigation’. The document itself is undated. I do not
recall exactly when I received it but I am sure it was
provided after 16 August 2018 and before the meeting
with [Post Office Limited] took place on 17 October
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2018. Itis a top-level summary document drafted by
UKGI. I return to it below."
That document was a one-page high-level briefing, as
you say, but you were provided with two further
briefings between August 2018 and the meeting which was.
discussed in the August submission, that of 17 October
2018. The first of these was a briefing ahead of
a meeting you had with Paula Vennells on 3 September
2018 and you address that briefing at paragraph 28 of
your statement, and you quote the section which raises
concerns -- well, there were concerns which were raised
by UKGI that Post Office Limited had not done enough to
prepare for potential business, reputational and
financial implications of losing the litigation.
Do you recall discussing this with Paula Vennells at
your meeting with her?
I remember -- obviously I remember meeting with Paula
Vennells. I remember touching on it but I would say
that it was a touching on the litigation. It was very
much an intro meeting and, obviously, one of the things
that -- there were other sort of postal or Post Office
issues that were relevant as well, and my interest was
obviously, as a minister, how could I affect and be
helpful to the Post Office in relation to some of those
other duties and responsibilities? So I do remember
105
Paula Vennells, on which you comment in your statement,
at paragraphs 30 and 31. At paragraph 30, you say this:
"I do agree with Mr Aldred's note that I ‘emphasised
the need to provide plenty of detail and [Paula
Vennells] said [Post Office Limited] would be in a much
better position to do so after further briefings from
their QCs and hopefully more information on the claims’.
This fits with my memory of dealings with [Post Office
Limited] during my time at BEIS. [Post Office Limited]
always seemed willing to answer questions when asked,
but I did find that they were sometimes difficult about
what information they would volunteer. There was never
a refusal to provide information if it was requested,
but I did feel that details were not always forthcoming
in a proactive way."
Even at this early stage, your first meeting with
Paula Vennells, was this the impression you formed or
did that impression come later?
I think it -- the impression would have come later, as
I say, as I said in my statement, I was new to the brief
I wanted to understand as much as I possibly could. It
would be usual for me to ask for further information or
as much detail as I could, so it would have been normal
for me to have said to Paula, you know, "Provide me with
as much information as possible". But, as I sort of
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speaking with her. I remember the meeting, but
I remembered it only being sort of touched on, as
opposed gone into in any great depth at that particular
time.
Indeed in your statement you indicate that only five
minutes of the meeting was allocated to the litigation,
as opposed to those other issues; is that right?
Yes, approximately.
But this was, again, flagging up that there were
business, reputational and financial implications of
looking the litigation, this briefing, ahead of your
Paula Vennells meeting, wasn't it?
Yes.
At paragraph 29 of your statement, starting five lines
down, you say this:
"I note Mr Aldred recorded that Ms Vennells had
passed on the advice of [Post Office Limited's] leading
counsel that, in summary, ‘[Post Office Limited] will
likely lose on some contract clauses but not on the
highest impact ones’. Whilst I do not now recall the
detail of the point made, that fits with my
understanding at the time. I remember having the
general impression that the [Post Office Limited] had
confidence in its overall defence to the claim."
There are two parts of the note of the meeting with
106
said in the statement, there was never any -- I never
ever detected any sort of resistance to giving me that
information directly from Post Office but, obviously,
I felt, and when I reflect back, looking at obviously
the documents and reflect back on that time, you know,
I was -- I did feel that I was asking for information
all the time, or wanting further information. So
obviously that's what's sort of formulated my view on
this.
Was this is an impression you formed when you were
Parliamentary Under-Secretary at BEIS or is this what
you formed on reflection?
No, it was what was happening when I was actually in the
Department but, obviously, at this particular time -- so
that meeting with Paula was on 3 September, I'd only
just recently been appointed and, at that particular
time, there were a number of -- just to sort of set the
context, there were a number of big areas within my
portfolio at BEIS that required me to sort of get up to
speed on pretty quickly, and so it was -- and, actually,
this was the sort of first intro meeting.
So that's why I was pleased, actually, when she
suggested that, you know, sharing information, you know,
wasn't going to be a problem but, obviously, as time
went on, it was me asking for that information.
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At paragraph 31 you say this:
"I also note what Nick Parker writes international
first paragraph, ‘Paula frequently confirmed that
challenge from [Her Majesty's Government] is good but
also asks that HMG ensures the positive developments in
Post Office are made clear and that HMG continues to
stress the important role that Post Office plays in
communities up and down the country’. Reading this
comment now, I do feel that [Post Office Limited] was
more interested in the Department challenging [Post
Office] for the ‘appearance’ of challenge rather than
sincerely listening and changing course in response.
I got the impression that [Post Office Limited] expected
the Department to be positive about [Post Office
Limited] regardless of the scrutiny that the Minister or
Department wished to apply.”
Again, is this an impression you formed at this
point in September 2018 or one which came later?
It would have -- it came later. Yeah.
As far as you are aware, was this approach and attitude
from Post Office Limited ever challenged by BEIS or
raised with the Post Office Limited Board members at the
time?
Sorry, at the time? At the time of the further
September ~
109
think what would have -- what I may have done sort of
looking at it now, rather than sort of giving you any
solid -- you know, solid sort of factual -- or answer to
what actually would have happened at the time.
But I think that, you know, it was understood that
I was -- you know, I felt frustrated at that
particular -- you know, after that period of time.
I sort of -- the reactions and information that was
coming through or that sort of appearance. So, yeah.
The second written briefing you received further to the
August submission and ahead of the 17 October 2018
meeting, was the detailed paper you address at
paragraph 35 of your statement. Going over the page to
that, please -- and again, please -- here you say:
"On 11 October 2018 I received a briefing authored
by [Post Office Limited] for the 17 October meeting.
The briefing was extensive, although section 2 setting
out the background to the litigation was relatively
short. I did not understand this to be a meeting about
litigation strategy or the merits of the claim. It was
really just a meeting about what was happening in the
litigation.”
Just picking up there on your understanding of the
purpose of the 17 October 2018 meeting, this was, you
think, the adjourned meeting, which was addressed in the
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At the time that you had that impression and you had
that concern?
Sorry, yes, yeah.
Was that approach and attitude that you describe there
ever challenged by the Department with Post Office Board
members?
So, I'm not sure -- I don't know if it was challenged by
anyone within the Department. I know that I had
expressed frustrations over that period, particularly on
this point of not feeling that maybe I was getting the
information that I needed or that should be coming my
way. I can't say that I -- you know, it would be wrong
for me to say that I directly challenged Post Office
Limited on that particular point. But I think that my
feelings and frustration of that was understood by the
team at BEIS and the UKGI members that I spoke to and
interacted with.
In general, did you feel restricted in your ability to
change this attitude or approach or to ensure that Post
Office Limited acted upon suggestions made by BEIS?
I would say that -- you know, I'm generally somebody who
would -- if I have an opinion and I'm not happy with
something, I would generally make that clear, and
I would, you know, I would have thought that -- I mean,
I'm just sort of making, you know, I'm just trying to
110
10 August submission and, in that submission, the
meeting was described in paragraph 11, which we looked
at, as an excellent opportunity for you and the Minister
to exercise shareholder scrutiny and seek reassurance on
any issues of concern.
It was also envisaged that there would be some
scrutiny of Post Office Limited's contingency planning
at the meeting, wasn't it, because that was why you were
briefed ahead of the Paula Vennells meeting, to request
sight of the contingency plan in advance of the meeting;
do you recall that, from the documents?
Yes, I do recall it from the documents.
Can you help, therefore, with why you viewed the meeting
as really just a meeting about what was happening in the
litigation?
Yes. So, again, this would have been the first sort of
major meeting that I would have had around the
litigation in relation to the Post Office and it was
an -- and whilst the contingency plan was an element,
this was an opportunity for them to brief me about what
was happening with the litigation, and an opportunity
for me to discuss and ask questions. So for me, I felt
that it was very much about the whole litigation, not
just about the contingency planning.
And, obviously, I had limited knowledge. I'd only
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had what I'd read prior to that or, you know, informal
conversations. So it was an opportunity for me to meet
with all of the people involved and ask questions, and
listen to what they had to say.
But you're saying by "it was just about what was.
happening in the litigation", that you didn't have the
opportunity to apply that shareholder scrutiny at that
meeting, because that was the stated intention, wasn't
it, in the submission from August?
Yeah, I mean I -- at that particular meeting, I was
concerned about the -- you know, to have more
information about the litigation. I remember being able
to ask questions. I asked questions about the, you
know, I did ask questions of the merit. I asked
questions about the liability, what it would mean, what
the Post Office felt about the outcome or potential
outcomes of the litigation. So I think, from my
perspective, I wanted to use the meeting as a better
understanding of what was -- what the current state of
play was.
I was very much aware that this had been going on
for a long period of time and, you know, I wanted to be
able to perform correctly as a minister, in the best way
I could, and the only way I would, you know, I believe,
is to understand what's going on and the detail.
113
those postmasters and that as a result, they suffered
financial and reputational harm. A theme of these
campaigns is that flaws in Horizon (the in-branch point
of sale system) were the cause of these losses."
Going over the page again, please, at 1.8, the
number of claimants is identified there, as the group of
561 claimants. Then going to page 6, please, this is
the second section, the background to the litigation.
At 2.2 there is this:
"In 2012 a small number of (mostly former)
postmasters, under the banner of ‘Justice for
Subpostmasters Alliance’ and with support from some MPs
led by then MP (now Lord) James Arbuthnot, claimed Post
Office's Horizon IT System had caused losses (shortfalls
in physical cash against cash holdings recorded on
Horizon) which they had had to make good. In some cases
they had been prosecuted for these losses) usually for
false accounting, theft or both) while, in other cases,
they claim that it led to their contracts with Post
Office being terminated causing them financial loss and
‘other personal harm including bankruptcy, divorce and
emotional distress including suicide."
So this briefing was informing you that
subpostmasters had alleged that the IT system had caused
losses which they'd had to make good, yes?
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So whilst contingency planning was a part of it,
I think, from my perspective, you know, it was very
important that, you know, it was an opportunity for me
to ask questions.
Can we have on screen, please, POL00022976. This is the
briefing paper for the 17 October 2018 meeting.
Starting, please, with page 2, we can see a table of
contents and there were sections listed as 1 to 7, the
"Executive Summary"; "Background to the Litigation";
"Key Issues at Trial in November"; "Operational
Improvements already Underway”; "Contingency Planning":
“Communications Strategy"; and "Settlement Options".
You've said in your statement that you were
interested in the detail as a general rule.
Mm.
Did you read all of the sections of this briefing when
it was provided to you?
Yes, I would have done, ahead of that meeting.
Going to the executive summary over the page please, at
paragraph 1.2, under the heading "What is the case
about?", it says:
"The case represents the culmination of a series of
campaigns by disaffected postmasters and others
(including a number of MPs on both sides) who believe
that Post Office wrongly attributed branch losses to
114
Yes.
This had led to some people being prosecuted for false
accounting, theft or both?
Yes.
Others having their contracts terminated with the
consequences we see there?
Yes.
And they had had support from some MPs, led by Lord
Arbuthnot?
Yes.
Did the nature of the allegations being described here
cause you any alarm by their very nature?
Yes, of course. Anyone sort of being accused of
breaking the law or doing something regarded as illegal
and the consequences of that, of course, you know -- and
for me, absolutely, that's why, you know, I was keen to
understand more about what had gone on and what the
current situation was with the Post Office.
Did this paragraph cause you to ask yourself whether you
needed to test what you were being told by the Post
Office about its position on the allegations?
At this particular time, at this particular meeting, no.
And the answer to that is, again, this was the first big
meeting that I had had with the Post Office to talk
about the litigation in any kind of detail, and I was
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just formulating my views. I didn't have any developed
views, really, prior to taking on the role as
a minister.
So, you know, of course, reading it, it's really
concerning but it didn't sort of -- that particular
paragraph in that briefing didn't -- you know,
I didn't -- as you say, I didn't make any further
decisions based on that.
Did you understand, when you read this briefing, that it
was the Post Office which had been doing the
prosecuting?
Yes.
Did that aspect of it cause you any concern, taken with
the information here in paragraph 2.2?
Yes. Of course, any kind of private prosecution is of
a concern, and especially when it's being done by
an organisation. This, I think -- I think I mention
further in my statement, but this is where I sort of
asked the question about, you know, what the Post Office
really, you know, what the situation was with regards to
the litigation because I did feel that this was
a situation where you had a very large organisation
taking private prosecutions against, you know -- excuse
the phrase -- small businesses or individuals, in some
cases and so, for a large organisation to take that kind
117
that was in front of me. I would have expected the
briefing to have given me sort of factual and
relatively, you know, truthful information, but I didn't
ask to see that, and I would have taken what I was given
here on face value.
Could we have on screen, please, paragraph 36 of
Ms Tolhurst's statement. That's page 12. You refer,
here, to paragraph 2.3 of the briefing document. So
that's the paragraph we've just looked at, referencing
Second Sight, and you say in the last two sentences:
"I remember being reassured by this. I understood
‘no evidence of system-wide (systemic) problems’ to mean
that there were no fundamental flaws in the system that
could SPMs more widely, although there may have been
‘one-off issues arising from user error or occasional
bugs."
Going back a page to paragraph 33, please. You say:
"In my general impression at this point in time was
that [Post Office Limited] did not consider there was
a serious problem with the Horizon system, albeit there
may have been occasional bugs or errors in the system
affecting individual SPMs. I understood [Post Office
Limited] thought there was a possibility that the court
may find against them on various contractual points or
in respect of those occasional bugs or errors, but did
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of action against, you know, relatively small players --
excuse the expression-- you know, they must have been
pretty sure or confident in their position to move that
forward.
So obviously, you know, that was how I was feeling
at the time and obviously I was getting to know what was
going on and developing my views and thoughts and trying
to suck up as much information as was being given to me.
At paragraph 2.3 there was this:
"In response to these assertions, Post Office
appointed independent forensic accountants Second Sight
to perform a ‘top-down’ examination of Horizon. Second
Sight issued a report in July 2013 which concluded there
was no evidence of system-wide (systemic) problems with
the Horizon software but identified some areas where
Post Office could have done more to support individual
postmasters."
This was the second reference to Second Sight that
you'd had. When you read this, did you ask to see
Second Sight's Report?
No, I didn't ask to see Second Sight's Report.
Why not?
It wasn't -- at the time, I can't really give you
an answer as to why I didn't ask to see their report.
I was taking the -- making a judgement on the advice
118
not think they would lose on anything significant."
So the reference here to occasional bugs or errors
in the system affecting individual SPMs, did you at the
time question whether this system, which you understood
to have bugs or errors affecting individual SPMs, even
occasional ones, could be described as robust? The
language which was being used by Post Office.
So at that particular meeting, you know, the sort of
terms "occasional bugs or errors", I'm not a -- you
know, I'm not a technical expert, particularly with
computers and computer systems. So I wouldn't have --
you know, I wouldn't have sort of -- wouldn't sort of
maybe have asked that question. But I think, for me, it
was very much about I was sort of at that particular
meeting given assurances that, you know, the
representatives themselves and people in the room were
telling me that there was no systematic issue, it was
played down in the sense that it was only very minor.
So, again, I took what I was told on face value at
that early meeting, without sort of probing further what
bugs or errors could potentially be.
However, I'm not an expert in tech or computers, so
even if I had of, I'm not sure what information they
would have given me to maybe lead me to take different
views or ask for something further, if that sort of
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makes sense.
Q. Taking it fairly simply, did you understand these
occasional bugs or errors to be material, that is they
were affecting SPMs in the way they claimed, causing
accounting difficulties?
A. Yes, yes, I would say so.
Q. Did you question whether these occasional bugs or errors
were visible to subpostmasters when they occurred or
whether illusory losses caused by bugs could be told
apart from genuine losses by the Post Office?
A. So in relation to the bugs or errors in the system, you
know, I didn't ask and I didn't have information about
those specific bugs or errors and, potentially, how they
were affecting postmasters. I definitely was looking at
it from more of a global level, more of a top level
issue, rather than the individual specific points, which
is a -- you know, that's an honest sort of position of
what I was thinking at the time.
Q. Do you recognise now that, absent bugs or errors being
visible to SPMs or distinguishable from genuine losses,
wrongful action might be taken against someone, whether
a subpostmaster, their staff or a Post Office employee,
on the basis of unreliable data, without anyone knowing?
A. Yes, and it's terrible.
Q._ Did you recognise that at the time?
121
short afternoon break?
SIR WYN WILLIAMS: Yes.
MS PRICE: So ten minutes, please, sir, which I think brings
us back at just after 2.45.
SIR WYN WILLIAMS: I make it 2.38, so shall we give
ourselves 2.50? Yes, fine.
MS PRICE: Yes, sir, thank you.
(2.38 pm)
(A short break)
(2.50 pm)
MS PRICE: Hello, sir.
SIR WYN WILLIAMS: Yes.
MS PRICE: Could we have back on screen, please, the
briefing document for the 17 October meeting, the
reference is POL00022976. There is just one last
section of this briefing I'd like to go to, please, and
that is the contingency planning appendices towards the
end of the document, starting at page 32. If we can
zoom in a little more, please, so we can see the table
on page 32. That's the page above. We can see here
what is colour-coding -- albeit that this is black and
white -- of five different numbers in the left-hand
column for likelihood of Post Office losing a common
issue or an implied term being found against the Post
Office.
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A. No, I-- you know, I can -- my -- as I say, at that
particular time, I wasn't particularly -- I wasn't
thinking about the particular bugs and the errors and
the specific impacts that that might have had. But
absolutely, I mean, having been led to believe that --
or been told by Post Office that there were no
systematical errors with Horizon, I suppose in some
respects gave me some confidence and some comfort that
the only errors were incredibly minor and maybe didn't
have the impact that I now know had on the postmasters.
That's the best I can, you know -- yeah, that's my view
on that. Yeah.
Q. Do you think you should have recognised this risk at the
time?
A. Um, you know, do you think I should have recognised?
Absolutely. I mean, I'm sure there's things that, you
know, in hindsight, that I may have been able to
recognise at the time -- at the time I was -- yeah, it,
you know, I honestly didn't recognise that those -- that
issue or those issues were, you know, problematic in
that sense.
Yes, I mean, there's lots of things I would wish
I had done or said, or done differently. I can't make
any sort of excuses for that.
MS PRICE: Sir, is that a convenient moment for our first
122
Just scrolling down a little, please, so we can see.
In the right-hand column, there is a 1 to 5 assessment
mechanism for impact, so impact on the Post Office if
a common issue is decided in favour of the claimants,
and that is defined as a significant adverse impact on
the business that could threaten existence, as a 5, so
the top level in the right-hand column.
On the left-hand column, on likelihood of 5 is "Post
Office is very likely to lose the case, the proposed
term is very likely to be implied”.
Scrolling up, please, just to the top introduction
section there, this is the bit of the document relating
to high likelihood areas so that's the likelihood column
on the left and, beneath that, is a table detailing the
four Common Issues assessed as having a high likelihood
of Post Office losing the issue or having the implied
term found against them.
Going to page 37. This is the start of the table
relating to high impact areas, so those things in the
right-hand column, and the introductory section explains
that the table details the three Common Issues assessed
as having a significant adverse impact on the business,
if the issue or implied term were to go against the Post
Office. So it's saying there were three of the issues
that would have that impact.
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Did you read these appendices at the time? They're
not part of the main sections, in fairness to you.
I expect I would have read them at the time. I don't
recall -- to be absolutely straightforward, I don't
recall but I expect I would have.
Seeing the issues which were assessed as being 5s or
likely to lose on points, and the three in having a high
impact, were they to be lost, albeit that the likelihood
on those was lower, did that cause you any concern in
terms of the risks of the litigation?
I think that the -- you know, I was concerned about all
of the risks in relation to litigation. Going back to
the point that I made around the fact -- you know, I was
concerned of the large corporation against the small
individual. I was concerned that -- you know, I was
concerned that actually looking at the information that
I'd had, I was being given all these assurances. So
I think that, for me, that's definitely, in that
17 October meeting, I felt that the people briefing me
were relatively confident of their position, and -- but
that worries me just because of my sort of concern over
the length of time this had been going on and some of
the issues, obviously in greater detail.
So I think, in general, I was concerned, without
being able to draw out sort of specific, you know,
125
and had been working on this for a long period of time
gave me reassurance, and I didn't have any evidence or
any particular information in order to challenge what
was being put in front of me at that particular time.
So that's the sort of best way I can articulate it.
Could we go, please, to paragraph 38 of Ms Tolhurst's
statement, that's page 13. At paragraph 38, you say
this:
"My overwhelming concern at that time [this is at
the point of the October 2018 meeting] was that
a judgment against [Post Office Limited] or settlement
of the claim would not cause [Post Office Limited]
a financial crisis. I was very focused on keeping Post
Office going as a valued service. This is why it was so
important to me that I was provided with information on
[Post Office Limited's] financial position so that
proper planning could take place."
At 39, you go on to say this:
"Frustratingly, [Post Office Limited] were not
willing or perhaps not able to provide any concrete
advice on their liability at the meeting. I was
informed by way of a post-meeting note that for ‘for any
settlement up to around £50 million the cost could be
borne by the company. Above that they would need to
consider whether it could be funded by [Post Office
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particular parts on different particular clauses.
I think I had a genuine, overall concern, which I think
would have been -- it would have been right for any kind
of minister to have an overall concern about any
litigation that any sort of Government subsidiary would
have been -- would be. So I think I had concern but
obviously none on those particular points, if that makes
sense.
That document can come down now. At paragraph 34 of
your statement, you refer to this concern, the general
concern you had, and you say that you remember at this
early stage being concerned that Post Office Limited
were perhaps over-confident.
Mm.
Can you explain what in particular let you to form the
view that they were over-confident?
Well, I think at that particular meeting, you know,
I don't remember at any time there was any sort of
suggestion or acceptance that there was a potential for
losing any kind of litigation, and I suppose, in some
respects, that's what also concerned me, because the
objective approach would be obviously to look at the
worst-case scenario, if you were looking at it. But
I -- at all these stages, I suppose, these individuals
in the room who had obviously spent a lot of time on it
126
Limited] or request additional support from HMG',
I wanted more information about the arrangements that
would be put in place for [Post Office Limited's]
financial liability, and this is something that
I followed up the following month. My understanding was
that [Post Office Limited] were not giving me
an estimate of its potential liability because then it
would become a known liability disclosable to [Post
Office Limited's] auditors which may expose it to a risk
of trading when potentially insolvent. Whilst
I understood that, I would expect [Post Office Limited]
to be able to give me some clear information, even if it
was not an official figure.”
Yeah.
You also refer at paragraph 126 of your statement to
being told, in a June 2019 submission, that Post Office
Limited's auditors had previously had concerns that no
figures were included in the accounts on Post Office
Limited's potential liability. From whom did you gain
the understanding that the reason Post Office Limited
was unwilling to be open about the likely quantum in the
claims related to the need to declare the risk to the
auditor which could, in turn, endanger Post Office
Limited's position as a going concern?
Well, I believe, actually, this was discussed in the
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meeting of 17 October because I do believe, asking the
question directly, you know, give -- I mean, my question
to the Post Office was, you know, what do you think the
liable, potentially, could be to the Post Office?
I needed -- I wanted to understand what that looked
like, and they couldn't give me a figure and that was
a major frustration to me, because -- and, I have to
say, one of the things that frustrated me about it was
that, you know, I was questioning senior executives of
the Post Office about what the potential liability was
and, you know, okay, I hadn't been a senior director of
a large organisation like the Post Office but I couldn't
understand why nobody could articulate that to me as the
Minister.
And I thought, at this point in the process, they
would have had a better understanding of what that
figure was but, actually, they couldn't give me a --
they couldn't even give me an informal figure.
So until after that meeting, I had no idea what
their potential -- what the potential liability could
be.
We do actually have a draft note of that meeting, if we
can have that up on the screen, it's UKGI00008554. It's
page 2 of that document, towards the bottom. There's
a comment halfway down the page, which is the first one
129
potentially 561 postmasters could potentially have had
a claim on the Post Office, I was concerned that that
could equate to more than, obviously, the £50 million.
So I understood that any negative judgment against the
Post Office would have had a massive impact on the
finances and the taxpayer, and I was trying to be
diligent into trying to push the Post Office into giving
me some idea of what potentially that figure could be
and if it would have an impact on the Post Office -- the
functioning of the Post Office.
Because one of the things that, you know, it seems
sort of reflecting now, looking back, you know, I was
actually really pleased to have the Post Office as part
of my portfolio because I thought it was a great
business and I thought it was an interesting part of
Government. So it was something that obviously, as
an individual, I very much wanted to make sure that the
Post Office could continue with its function of public
service. You know, obviously separate to the litigation
and obviously what I now know.
Could we have on screen, please, UKGI00021096. This is
a Shareholder Executive Risk Register, dated 29 June
2018. It's a little difficult to see because we need to
click into the cells in order to see the text, so when
I ask the lady to click in a box, the text will appear
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from you. You say, "Kelly Tolhurst (KT)", and then
a little further down we have "KT":
“Additional funding requirements?
"Would [Post Office] have enough to cover?
Important that [department] is aware as could be
significant?
“Potential liability."
Is that what you're referring to in terms of what
you asked?
Yes, I mean, this note obviously was a note that
I hadn't seen but that's what I -- you know, I do
remember that particular conversation at that meeting.
So it characterises, in some form, my question.
That document can come down now. Did the lack of
figures being provided at that stage mean that no
account was being taken by the Government of the overall
value of the claims for the purposes of assessing
litigation risk?
Well, at that particular time, my understanding was that
Post Office had an ability to make financial
transactions up to £50 million. Anything over that
would need Government Minister sign-off.
My -- again, I'm not a legal expert. I have no idea
what sort of quantums of claims there could potentially
be but when I was told and when I understood that
130
in full, in the bar across the top.
Oh, okay. Yeah.
If we are looking at this first tab "Guidance" and cell
C6, please, we can see the text here explains that:
"This will be used as a graphical representation of
TOP RISKS [in capitals] each team faces and also allows
for different assets'/projects’ risks, to be compared
easily.”
In big capital letters towards the end:
"PLEASE ONLY INCLUDE YOUR TOP RISKS."
Then if we go to tab 2 of this please, which relates
to the Post Office, so this was a Shareholder Executive
Risk Register, which had that guidance and had this
specific risk register relating to Post Office. Have
you ever seen a Shareholder Executive Risk Register like
this before?
So I don't believe I had until obviously the documents
were shared with me, I think, a few days previous.
So these weren't shared with you at the time you were
Parliamentary Under-Secretary?
I don't believe they were.
If we go to row 38, which is item 11. We can see here
possible civil litigation against Post Office Limited,
and then in column D, which is "Risk overview", we have:
"Civil litigation and/or Court of Appeal processes
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judge that [Post Office] has acted inappropriately, or
illegally. Even in the absence of such a finding,
ongoing risk that they are perceived to have acted in
Then if we look at column E, "Impact of risk", on
that same line:
“Potential for significant compensation claims if
civil or criminal courts rule against Post Office
Limited. More likely, however, and certainly in the
short-term, is that this continues to be a significant
distraction (and cost) to the business as they defend
their actions."
Then column H. We can see that the civil litigation
has been given an impact rating of 4 out of 5 --
a probability rating of 4 out of 5, and then we can see
an impact rating there.
Forgive me, if we can just scroll up so we can see
the column heading. It seems to be current and
previous, so referring to two different times of that
being assessed.
Scrolling down, please. So probability at 4 out of
5 and impact at 5 out of 5.
Pausing there, was the scale of the risk ever
articulated to you in those terms?
I don't believe that was.
133
page 4 of that document, please, the email towards the
bottom of the page. You explain at paragraph 48 of your
statement that you met with Tosin Adegun and Tom Cooper
of UKGI on 19 November 2018. This email is sent next
day on 20 November and it's from Oluwatosin Adegun to
Sam White, who was one of your Private Secretaries, and
it says this:
"Hi Sam,
“Thanks to the Minister for her time yesterday,
detailed below are the follow-on actions (both Sams,
please let me know if I have missed anything)."
That first bullet point:
"Weekly briefings as the litigation case progresses
(verbal and written updates) (UKGI to action).”
Did you request those briefings?
Yes, I believe I did ask to be briefed. That was sort
of normal for me to -- I would rather have more
information than I needed. So, you know, you're better
off having more information. So weekly briefings,
I would have requested that at the meeting or as
a consequence of the meeting. However, I can't
guarantee that they -- I did receive weekly briefings or
verbal updates.
Did you request those because, as a matter of your
general practice, you liked to have regular updates or
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If we look at column K, mitigation overview, it states:
[Post Office Limited] have external legal advisers
employed on the civil litigation including a QC. They
continue to update UKGI through the Board where UKGI's
NED sits and directly to UKGI's Legal Counsel under
a Disclosure Protocol that protects legally privileged
information."
Then at column P "Further mitigating actions":
"UKGI have briefed Minister (Andrew Griffiths) and
will keep ministers, SpAds and [Permanent Secretary]
update at key points through the new Disclosure
Protocol, with POL's Legal Counsel to provide an oral
briefing on 10 September."
So that's the meeting which was adjourned to
17 October:
"BEIS Legal are also up to speed and contributing to
any advice to ministers. Maintaining a position that
Government will not comment on an ongoing legal issue.”
Were you aware that UKGI considered the civil
litigation against Post Office Limited to be one of
POL's top rated risk on its asset register?
No, I can't say that I knew that.
That document can come down now. In terms of your
experience of information flow from Post Office Limited,
could we have on screen, please, UKGI00021771. Going to
134
was there a particular concern --
No, I think it was more to do with my general practice.
I knew obviously it was a big issue. It was something
that was -- that it was important that I did have access
to any new information or information as quickly as
possible. So it would have been normal for me to have
asked for regular updates.
Some emails follow above about how frequently the
updates should be sent to your Private Secretary and
then, towards the bottom of the page, I think the bottom
of the first page, there is an email dated 23 November
2018, from Stephen Clarke to Richard Watson and Tom
Aldred, which says this:
"Richard,
"To see further clarification below from the
Minister's office on the Minister's request for trial
updates.”
"... we'll submit once a week ..."
Then that included a round-up of the week's news
coverage and also at the second bullet point an update
from Post Office Limited's Legal Team on trial
developments over the past week.
So the second bullet point here was referring to the
fact that you wished to have updates from Post Office
Limited's Legal Team in particular; is that right?
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So that would have been something that would have been
formulated via the team or with my private office.
I don't remember being specific about what I was
requesting. I would have just asked for weekly updates
and, you know, relevant information, not sort of giving
me information that had no consequence or was
irrelevant. So these would have been ideas that would
have been put forward by -- yeah, as I say, I'm unsure
of who would have sort of made those three particular
requests.
Okay. Then the reply from Richard Watson is above. It
says:
"Stephen
"Thanks. I have had no reply from [Post Office
Limited] Legal. I will chase them about it. I have not
said to them that the Minister wants the update, partly
because I rather feared that would cause the update to
be less useful or perhaps even be met with a refusal to
provide one."
Then Stephen Clarke's email above:
“Thanks Richard, I hadn't thought of that risk but
probably very wise based on past dealings!"
Were you aware that this was what was expected by
UKGI: that a request for an update having come from
a Minister might result in a less useful update or
137
had a good chat with Kelly after Tim had to leave, where
I was able to make a few points to her. I also walked
over to the meeting with Carl, the new BEIS director,
who seemed very nice.”
Then under “Litigation and recusal", the second
bullet point reads:
"Kelly complained that she wasn't seeing enough
information flow about the trial. We discussed as
Officials afterwards and it seems the block is somewhere
between her private office and her. Regardless, we
should make sure that we are providing updates to her as
soon as they are relevant."
At this point in April 2019, what information about
the trial were you expecting but not receiving; can you
recall?
I can't say -- I don't know what I was expecting.
I just wanted to have good information, you know,
regular information and, obviously, rather than getting
confused on the months again, I was -- I know we haven't
spoken yet about the recusal but, obviously, I was
frustrated and angry about that. So I was expecting to
get more timely and better information because,
ultimately, you know, I -- as the -- as the Minister who
that the responsibility to answer the House of Commons
or anyone that asked the questions, it was right that
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a refusal to provide one?
No, I wasn't and, actually, you know, I would have -- if
I had have been, I would have been rather annoyed by it
because, quite frankly, you know, they would have -- you
know, I would have -- yeah. A refusal to give an update
to the Minister, I would have thought would have been
absolutely outrageous. So if I'd known about that at
the time or that there was concern that that might not
be the case, I probably would have raised that directly
with them, if they were actually refusing to give me
updates.
It may follow from your answer but was this something
you ever experienced directly at any point?
A refusal to give me information? No, I can't say that
they refused to give me information. As far as I am
aware, should I say, because actually, that was just
from my direct contact with the Post Office. For what
may or may not have been said to UKGI or officials
within the team that I am not aware of, that may have
‘occurred, but with my direct communication, no.
Could we have on screen, please, UKGI00009455. This is
an email from Tom Aldred of UKGI to others from UKGI
dated 5 April 2019. The first paragraph of the email
says this:
"On Wednesday, Kelly met with Tim Parker. We also
138
the information flow should be there and -- but I don't
quite know what I was expecting to see because obviously
I didn't know what I didn't know. But I just wanted
that -- you know, if I was getting a regular flow,
hopefully there'd be information in there that would be
useful to me in my role as the Minister.
SIR WYN WILLIAMS: Can I just ask you in general, so that
perhaps we can shortcut some of this, in November 2018,
that was when the Common Issues trial started. Are you
telling me that, during the course of that trial, so
that in the weeks, effectively, of November and
December, you felt that you didn't get enough
information of how that trial was progressing? That's
point 1.
Then coming to this point in time, which is April
2019, we've now got the judgment in the Common Issues
trial. Everybody knows that the Post Office lost, and
so we're talking about the information you want to get
in the Horizon Issues trial.
So with those two staging posts in mind, so to
speak, first of all, going back to question number 1,
did you feel you were properly kept up to date with what
was happening in the Common Issues trial?
Thank you, Sir Wyn. I felt that I was getting some
information and, at the time, I would say that --
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I couldn't -- at the time, I couldn't make a judgement
on the reliability or the level of information I thought
that I was getting. I suppose my big issue was,
‘obviously after the judgment was made, it absolutely was
clear that I wasn't getting the updates or the
information that I felt I needed to know, if that makes
sense. If it answers your question.
SIR WYN WILLIAMS: Well, it answers my question about the
Common Issues trial and then, once you knew that the
Post Office had lost that trial, to what extent, if at
all, were you demanding greater discipline, if I can put
it in that way, in keeping you up-to-date with what was
happening in the Horizon Issues trial? We'll leave
recusal as a separate topic for Ms Price to deal with
but, so far as the Horizon Issues trial is concerned,
were you kept up to date in a more disciplined
fashion -- I can't think of putting it in any other
way -- during the course of that trial?
A. I'm not -- I was given more information from --
‘obviously, we had the policy team within BEIS and my
private office and we were all sort of trying to keep
abreast of what was happening, but I don't think that
I was kept updated in a more disciplined way, hence why
I was -- you know, I felt like I was continuously sort
of asking for more info, more info, more detail, more
141
with April 2019, your private office saying that Tom
Cooper wanted to meet you to update you on the
litigation, and you saying you'd rather the updates were
formalised. Then just going over the page, please, at
89, you say:
"I suspected by this time that Tom Cooper had gone
native. My feeling was that he had lost his
independence from [Post Office Limited] and was not
providing effective challenge or scrutiny."
What did you mean when you said Mr Cooper had "gone
native"?
A. Well, I meant that his objectivity had been lost,
I suppose, in regards to -- you know, whether that's
a fair characterisation or not of his approach, but that
was my feeling at the time. That's all I can sort of
say, and I think that had been borne out -- well, as
I think I've said in my statement, actually, that, you
know -- and I know we want to come on to it, so -- but
what happened around that recusal obviously gave me
cause for concern, and the reason I made a fuss about
not wanting to meet the people informally is that, you
know, this was very -- you know, I wasn't ignorant
enough to know -- not to know how serious the whole
litigation was, and because I had become frustrated with
the information flow, I didn't want informal
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detail. Because, clearly, the judgment, there were
issues. You know, I -- there were clearly issues with
what the Post Office was saying and what was happening,
based on that judgment.
So I didn't want to be blindsided, as well, if that
makes sense. So my determination to keep asking for
information, asking for more detail, meant that, you
know, in my view, I thought that I wouldn't -- you know,
I would know what's coming, if that makes sense.
SIR WYN WILLIAMS: All right. Then one last question before
I hand back to Ms Price. When you were saying more
info, more info, were you directing your requests to
Officials in UKGI or officials in the Department or to
both?
A. To both, to both.
SIR WYN WILLIAMS: All right. Fine.
Ms Price.
MR BEER: Not at all, sir.
Ms Tolhurst -- that document can come down now --
a number of times in your statement you touch on the
relationship and engagement you had with UKGI
specifically, to follow up on the point made by the
Chair as to who you were encountering difficulties with.
If we could have on screen, please, paragraph 88 of
Ms Tolhurst's statement. That's page 31. You deal here
142
information. I wanted information that was recorded and
on the record, hence why I didn't want to have a random
communication, as I characterised it.
Q._Inrelation to Mr Cooper's request for a meeting,
Mr Cooper's evidence to the Inquiry was that he would
have benefited from a lot more in-person contact with
the Department but, in particular, you, and his evidence
was that the Department had received briefings but no
questions came back. How would you respond to that?
A. Well, so, even as a junior Minister, I had a wide
portfolio and I had lots of responsibilities. At this
particular time, we had a number of other challenges
within my portfolio, not just the Horizon litigation.
Absolutely, I want to meet with all stakeholders but, as
‘one individual, there is a limit on some of the personal
contact that you can have with those stakeholders.
However, he had open and unfettered access to the
BEIS team. He also had the ability to speak with the
Permanent Secretary and any kind of severe concerns, in
my view, shouldn't have been just purely reliant on
having a face-to-face meeting with me.
If he had had those serious concerns or he had
something that was important to the Department, you
know, I would have imagined and I would have hoped that
anyone working in that environment would have raised it
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with a number of other people, rather than only speaking
to me, unless it, you know, it was something like a --
I don't know, a whistleblowing or something like that.
So I would say that, yeah, absolutely, as
a minister, I was always willing to meet with whoever
I could, within reason, particularly where it affected
by portfolio. But, you know, I recognise as well, it
wasn't possible with just the other pressures at that
particular time, to meet with -- you know, I wouldn't
have been able to meet with him on a weekly basis. But
that's a rather long answer, but I just wanted to give
you the context of that.
So I would say that's slightly unfair to suggest
that, because he didn't have as many face-to-face
meetings with me, that there was no sort of feedback
from my office, so to speak.
Coming, then, to your reaction to the Common Issues
judgment and the recusal application. Can we have on
screen, please, paragraph 58 of the statement, that's
page 21, this you being made aware of the judgment and
at 59, your immediate reaction was one of embarrassment.
Mm.
You were appalled that the judge had found Post Office
Limited to have behaved so reprehensibly and you felt
usher shame on behalf of Post Office Limited in respect
145
You provide your reflections on this at
paragraph 69, over the page, please, and you say:
"Looking back now this is probably one of the areas
where I should have pushed back and insisted on the
original wording."
Why do you consider that the original wording should
have been kept?
Because I believe that, actually, it was the true
characterisation of how, you know, I felt as the
Minister at the time. But, you know, looking -- you
know, looking back, I wish I had pushed harder on that
wording.
Coming, then, to the recusal decision, you say you were,
at this stage -- the drafting on the "Dear Colleagues
letter" stage -- unaware of any suggestion that Post
Office Limited might seek for the judge to recuse
himself, and that you became so aware on the 19 March
2019, when UKGI informed your office of this; is that
right?
Yes.
You say at paragraph 71 that your view and your
officials' view was that the application should not be
made and that you had very grave concerns about it.
Three lines down you say this:
"I believe that the Permanent Secretary, Alex
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of what the SPMs had been through.
You say you had a call with UKGI the next day about
the judgment and then, going over the page, please,
a call with Tim Parker, Alisdair Cameron and Jane
MacLeod, and you set out some of the speaking points for
that call which reflects your immediate concerns.
Then over the page, please. At the next paragraph,
you describe the handing down of the Common Issues
judgment as a lightbulb moment for you. And you also
say that your concern was what was going to change, in
terms of how the litigation was approached.
A "Dear colleagues" letter was sent to all members
of the House of Commons after this judgment, wasn't it?
Yes.
You explain at paragraph 65 to 68 that you had
originally recommended that some wording be included
which was subject to some amendments after comment from
UKGI but this wording was removed after input from Post
Office Limited; is that right?
Yes.
The wording you originally proposed is set out at
paragraph 66. That wording was that:
".., the judgment ‘represents a significant step
forward, delivering justice for those postmasters who
have been wronged’.
146
Chisholm, took this forward and tried to discourage
[Post Office Limited] from making the application. At
no time was anyone at POL given reassurance that
Government would be happy with POL making this
application; quite the contrary."
By "quite the contrary", is it your evidence that
you told Post Office Limited not to make the recusal
application, or not?
So I did not have any discussions with Post Office
Limited directly about the recusal. But, as far as
I can remember, I don't remember having that direct
conversation with them. However, what I do remember is
that, you know, my reaction and that of the others --
you know, other people within the Department, that this
was something that, you know, was not something that
I -- you know, I wouldn't support it and I thought it
was rather -- you know, madness, really, but that,
I don't believe was directly articulated directly to
Post Office Limited.
You deal at paragraph 73 with what you were told about
whether Government could or should be involved in the
decision, and you say:
“It was apparently not, however, within the
Department's gift to stop [Post Office Limited] from
making the application."
148
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If it had been within your gift, would you have
stopped the application, despite the legal advice to the
contrary?
Well, I believe I would have, because I -- and again,
it's easy to say -- it's easy for me to say that in
hindsight, with what we know now. But my view, as
a complete layperson in this area, my feeling at the
time was you've had a judge that's made this incredibly
damning position about the Post Office, so I was very
surprised how the Post Office's first thought was to try
and then recuse that judge. I, as a layperson,
I thought it was, you know, something that was madness.
Even what, you know, depending on what that legal advice
had been and, actually, you know, I think that we wanted
to, you know, we wanted to make sure that this came to
arresolution, and that it was moved forward, and, you
know, we were -- I was definitely concerned that
anything like this could delay any further, you know,
the progression of the case to draw a line under it for
the individuals involved.
Could we have on screen, please, WBON0001756. This is
an email from Jane MacLeod to Tom Beezer and Andrew
Parsons, copied to others, dated 16 March 2019, and it
says:
“Many thanks -- I have a call at 12.15 with our
149
So therefore, I couldn't understand how that would
help in any way the Post Office -- Post Office's case
going forward, with any future judgments.
So whilst that may have been the Department's view,
which I don't disagree with, I'm just saying that my
thoughts at the time were very much in that place, as
‘opposed to particularly concerned with what the
judiciary may or may not have thought.
Having seen the documents which have been sent to you
more recently, are you aware that BEIS Legal and the
Permanent Secretary had taken the view that the
Department should not involve itself directly in the
recusal decision?
Yes.
We needn't turn it up unless you'd like to see it but
there was an advice from BEIS Legal to Mr Cooper that he
should not take part in the decision on recusal, on
15 March 2019. Were you aware of that at the time?
So I don't think I was -- no, I wasn't aware that he --
that the advice he had been given was to not take part
in that discussion, as far as I think I am correct in
saying. However, I think this represents one of the
concerns and one of the issues for me because, having
the shareholder representative on the Board not taking
part in a significant decision that had the impact on
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Chairman, Al Cameron and Minister Kelly Tolhurst (and
others), although I don't believe recusal will be part
of the discussion. I have been advised by the UKGI GC
that ‘government will not express an opinion on recusal
as they will not want the ‘executive’ to be seen to be
criticising the’ judiciary’."
Was recusal discussed on the call on 16 March? That
was three days prior to the date you give in your
statement, you saying you were aware of it?
I genuinely -- I can't remember the exact details of the
call.
The suggestion that the reason Government would not
opine on the recusal application was said that it did
not want the Executive to be seen as criticising the
judiciary. Did you personally receive advice to that
effect?
I don't remember receiving -- you know, I don't remember
receiving advice to that effect and, actually, that's
not how I was thinking. So my objection to the recusal
was not worrying about whether or not the Government
would be seen to be criticising the judiciary. You
know, from my layperson's point of view, was that
I thought it was absolutely the wrong thing for the Post
Office to be doing, just because they had had a judge
who had made a scathing judgment against them.
150
the organisation of which we were the shareholder, and
on a position that, you know, I didn't agree with,
I suppose was a concern -- you know, is a concern, and
is a concern, you know, how were we able to -- you know,
we -- I mean, I -- whether the -- the advice was correct
or not, you know, I'm disappointed, and I disagree with
it.
You know, because I believe that, if you are
a shareholder, if you are a Board member, unless you
have a very clear conflict, you should be taking part of
those decisions and, you know, it's a frustration to me.
Could we have on screen, please, UKGI00009321. Going to
page 2 of that document, please, about halfway down
there's an email from your Private Secretary, or one of
them, it seems, to Tom Cooper, which refers to brief
discussion of this with Kelly over the phone and "as
expected she has concerns" and this relates to the
recusal application being considered:
"Immediately she said she would raise with
[Secretary of State] ..."
This is 19 March at 17.15:
have flagged this to his office and I believe
she has already contacted him.
"She has agreed that they shouldn't do anything
until after the decision has been made at the board
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meeting/call tomorrow ..."
That's the Post Office Limited Board meeting to
decide whether the application should be made; is that
right?
I think so.
"... and it is likely she will want another call with
Tim Parker and Al Cameron after this to ask them to
explain their reasoning behind their change of mind."
So it would appear from this that there was a plan
for you to have a discussion with the Secretary of State
but you had decided not to contact Post Office Limited
to intervene in the decision before it was made; is that
right?
I don't believe I made a decision not to intervene and
speak with the Post Office to -- I don't believe that
that correctly articulates -- articulated what that note
meant at the time because I was very clear on my --
I was very clear on my position, hence whilst I had
spoken to Secretary of State -- it may have been --
I can't -- I don't -- I wouldn't have seen this message,
I don't remember refusing or not agreeing to speak with
the Post Office Limited on this issue.
Well, did you make any attempt to speak to Post Office
Limited on this issue before the Board meeting decision?
So my belief was that my ~ my understanding -- if
153
The potential options which were available to you are
set out on page 4 of this document. Can we go to that,
please, and it refers you to a table at Annex A with a
range of options and they were said to range from
challenging the existing Post Office Limited Board to
change their litigation strategy, to more fundamental
changes, such as replacing the Post Office Limited Board
or BEIS assuming control of the litigation strategy.
Then the risks are explained at 18, of more rigorous
action and those included:
"Forcing further changes to the leadership team risk
disrupting the progress POL have been making in other
areas of operation of the business ... Making public
statements or directing POL to take certain action could
weaken their negotiating position in relation to
settlement and make it harder to stick to the existing
BEIS line that this was an operational matter for POL."
Then the recommendation was that you choose from
options 1 to 7, and options 1 to 7 were the less
fundamental changes of the options; is that right?
Correct, yeah.
I won't go to them for the sake of time but they're the
‘ones that you set out at paragraph 125 of your
statement?
Mm.
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I correct correctly, that Alex Chisholm, who was the
then Permanent Secretary, was going to speak with the
Board -- or not necessarily speak with the Board, but it
was left with him. But I -- but I think, you know, very
clear, that I definitely didn't try and avoid or refuse
to speak to Post Office Limited on this because, if
I had felt that I had had an opportunity to influence
it, I would have taken it.
That document can come down now. You received
a submission on 11 June 2019 about the Post Office
litigation. Can we have that on screen, please, it's
BEISO000075. If it helps, you address this submission
at paragraphs 124 to 128 of your statement if you want
to refer to them. So this submission, you are one of
the recipients?
Mm-hm.
Under "Summary":
"At the industry meeting on 4 June you ([Secretary
of State]) [so being the top recipient] asked for advice
‘on how the ongoing Post Office Limited litigation could
be brought to a swift and satisfactory conclusion,
ensuring postmasters who had been treated unfairly were
appropriately compensated.”
Does that reflect your wishes at the time as well?
Yeah, absolutely.
154
Looking at the points made in paragraph 18, was there
pressure to maintain POL's financial success as
a priority over the concerns and interests of
subpostmasters?
I don't believe so. That was definitely not something
that was my approach. I would say it was never about
protecting the Post Office over subpostmasters; it was
about making sure that, you know, as the people -- as
a taxpayer responsible body, we had confidence in the
leadership and the processes and that the right
decisions were being taken.
In respect of the line referred to here, that the
litigation is an operational matter for Post Office
Limited, did you agree with that?
I did agree with it because -- at that particular time
because obviously we -- there was an Executive Team
running the Post Office and they were responsible for
the operations and delivery of the Post Office as
an organisation and, you know, as far as I was aware,
none of the officials within BEIS, notwithstanding
whatever the officials in UKGI had been informed of,
that it was something that they were leading on and that
it was their responsibility to resolve, as well.
Wasn't this a classic example of an operation -- or
operational or contractual matter, which was concerning
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ministers at a policy level, such that simply leaving
matters to Post Office Limited, on the basis that they
were operational, was not a defensible position?
I think, in -- you know, looking at it from hindsight,
yeah, we could say that, absolutely, you know,
actually -- I mean, I think -- you know, we can go on --
I'm sure you'll pick up with me about the -- you know,
the future and, you know, potentially what is wrong but
I think that, at the time, all I can talk about is at
the time and when I was involved, and, you know, I did
think it was an operational matter. Yes, I was
concerned in relation to policy and how that would
affect policy, how that would affect future decision
making. But I didn't believe that we could take
operational responsibility for it because, obviously, we
weren't appraised or, you know, we weren't -- well,
I definitely wasn't directing the legal advice or, you
know, have -- you know, I don't even know what the
questions were asked of the legal representatives, when
this legal advice was given to the Post Office.
So I think that, absolutely, it's -- what we know
now and it absolutely -- you know, it was a mistake that
it -- it shouldn't have been, you know -- Government
should have had better oversight of what was going on at
that time.
157
please.
SIR WYN WILLIAMS: Before you do that, Ms Price, could
I just check with you, are we having a sort of second
break or are we going to the end now?
break, after which there will be some questions from
Core Participants. I will only be a couple of minutes
further with my questions at which point I was going to
suggest at 3.55 we take a break until 4.05.
1
2
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5 MSPRICE: Sir, I think we are going to have another short
6
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10 SIRWYN WILLIAMS: Fine; okay.
11. MSPRICE: So page 70 of the statement, please. In the
24 A.
25 Q.
interests of time, I won't read out all of paragraph 194
but that is the paragraph that essentially deals with
what you think was inadequate information being provided
to you.
Then on 71, we have 198 and 199, where you make some
observations in respect of the governance structure in
this instance.
In sum, is it correct that your position is that,
first, the Government was not given sufficient
information to act appropriately; and, second, the
structures in place tied the Government's hands as it
had no directing power?
Mm.
Is that a fair summary?
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Why, ultimately, did you choose not to make radical
changes to the left and right of the Board, so the
harder options that were in the submission?
So I've thought about this obviously since writing the
statement and I don't remember exactly, other than --
I don't remember exactly why I went from being very
determined in my views to move on the Chairman and
change the board, that we didn't end up doing that other
than that, I would imagine, that, you know, there was no
appetite for that within the Department or the advice
that I was being given by the Permanent Secretary and,
you know, the team at the time.
You know, it would have been seen as a very sort
of -- you know, I think I described it in my statement
as a nuclear option and, you know, as this was my first
ministerial role, I was really keen to make sure that
I acted appropriately, and obviously I was -- I did take
note of advice and -- that I was given.
However, I will caveat that in the sense that,
whilst I take note of the advice, if I thought that
I had an opportunity to do it, I would have taken it.
So I -- but I can't explain exactly why I didn't go for
the -- for that particular option.
I'd like to come finally to your reflections, and
starting with paragraph 194 on page 70 of the statement,
158
Yes, itis.
Is it right though, that, in terms of access to
information, the Government had a representative on the
Post Office Limited Board and you were in a different
position, in terms of knowledge of matters after the
Common Issues judgment, as compared with before?
Yeah.
The Government also had that nuclear option of removing
the Chair --
Yeah.
-- in extremis. Was there any conversation about the
responsibility of Government and collective Cabinet
responsibility in the context of litigation being
defended in a way which it appears you believed was
increasingly indefensible?
I can't speak for -- I don't know whether that was
discussed, and I definitely, you know, I genuinely can't
answer the question about the Cabinet's involvement or
whether that was discussed at that particular point.
I think for -- you know, I remain concerned about -- at
the time, I would have loved to have had -- I would have
loved to have had powers of direction over the Post
Office, actually, because, you know, if I am furnished
-- you know, I was, you know, more than happy to take
decisions, so I think that, fundamentally, the structure
160
(40) Pages 157 - 160
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of the Post Office and the way it's been set up, and
also even that connection between UKGI and the
Department, so for example, you know, the UKGI
shareholder representative wasn't a member of the
Department so it wasn't someone that was directly blank
to me, for example, or the Secretary of State.
I think I was operating within the system that was
there and, whilst I accept that, you know, the structure
of the organisation, I had to work on those boundaries,
yes, it was a frustration and, you know, that's
something that I believe that maybe, if it hadn't have
been set up in that way, we would have -- well,
I hope -- I would like to think that this may have been
resolved early on, because ministers would have had that
ability to direct and take further decision.
I mean, I think even -- sorry to sort of labour the
point, but just going back even to the point where the
Minister had to sign a protocol for information sharing.
I mean, even me coming in as a layperson, I thought:
well, hang on a second, if I am the Minister
responsible, why do I have to sign a document to say
that I'm not going to share -- you know, so that I can
be given that information, when, actually, we are the
shareholder, we own the organisation?
So I think that -- and, you know, I - yeah, I would
161
MR STEIN: I Sir, I'm grateful, I'll start my 12 minutes now.
Ms Tolhurst, my name is Sam Stein, I appear on
behalf of a very large group of subpostmasters,
subpostmasters' partners, mistresses and employees in
branch offices.
You said towards the end of your evidence when you
were being asked questions by Ms Price that you are
looking forward and you're very keen to see the outcome
of the Inquiry in relation to the recommendations that
are made. Okay?
Mm-hm.
Now, if you like, the lens through which I'm going to
ask you a number of questions is that one --
Okay.
-- the recommendations: how can we improve, what is
going to be better in terms of Government, the way
Government operates? Alll right.
Okay, thank you.
Now, to help with that and as a starting point, can
I take you, please, to paragraph 35 of your statement.
You'll see there at paragraph 35, that's page 12 of
Ms Tolhurst's statement, that you're referring there to
a briefing organised by POL for 17 October meeting:
"The briefing was extensive although section 2
setting out the background to litigation was relatively
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like -- yeah. I am also very keen to see the outcomes
of the Inquiry in relation to the recommendations that
are made because, obviously, it's something that, you
know, has caused me, you know, concern and a lot of
reflection since the process, since I was a Minister in
the Department.
MS PRICE: Sir, those are all my questions for Ms Tolhurst.
It is between 3.55 and 4.00. But I wonder if we could
come back between 4.05 and 4.10, if we're going to get
through the questions.
SIR WYN WILLIAMS: Yes, by all means. I'm prepared to
stretch 4.30 a little but, just so everybody knows, my
absolute limit today is 4.45. So either questions have
to be asked within that time frame or some other
arrangement has to be made, all right?
MS PRICE: Thank you, sir. Understood.
(3.57 pm)
(A short break)
(4.07 pm)
MS PRICE: Good afternoon, sir.
SIR WYN WILLIAMS: Good afternoon.
MS PRICE: We have questions from Mr Stein and Ms Patrick
I'm told they will be 12 minutes each.
SIR WYN WILLIAMS: The precision grows. All right.
Questioned by MR STEIN
162
short."
You go on to say:
"I did not understand this to be a meeting about
litigation strategy or the merits of the claim."
So I'm going to take you now to that briefing.
A. Okay.
Q. If we can go to that, that briefing is to be found at
POL00022976. If we look at page 1, and have that on the
screen, that would help. So this briefing paper, as
you'll see, and you had this in your pack, it's
a meeting on 17 October 2018, and it has a reference to
yourself, Ms Tolhurst, Parliamentary Under-Secretary for
the Department of BEIS, et cetera, okay?
A. Okay, so you'd joined and taken on this ministerial
post, I think, in July 2018, so you'd had some time to
get familiar with the role but not very much time. All
right?
So the particular paragraphs that I'd like to ask
you questions about at page 10, paragraph 3.3, please.
Thank you. Right. So 3.3:
"The most important common issues concern the
liability of agents for 'losses’."
Then it goes on to say this:
"The claimants argue that Post Office needs to show
that a postmaster's actions have caused Post Office to
164
(41) Pages 161 - 164
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suffer a net economic detriment, not just that the
branch's accounts ostensibly show a shortfall. Post
Office's position is that if a shortfall is shown in the
branch's accounts then, absent any cogent evidence to
the contrary, the postmaster is liable for that
shortfall, given that they are responsible for
conducting the transactions recorded in those accounts,
and for the Post Office cash and other assets used."
Paragraph 3.6, please, so over the page to page 11.
"Post Office's external Counsel believe that Post
Office has the stronger arguments on most of the Common
Issues."
Okay, so you're being given a pointer here within
the briefing document to what are strengths and
weaknesses, all right?
"However they also caution that areas likely to be
most problematic for Post Office are the clauses dealing
with suspending and terminating postmaster contracts
(including length of notice ...), withholding
remuneration during the periods of suspension, and
imposing liable for branch losses."
Okay?
So you're being given a steer as to areas of real
concern for the litigation and one of the steers that
you're getting, and an area of real weakness that's
165
look, there's a real issue about this question of how we
impose liability on those small businesses. Do you
agree that's what it says?
Well, I agree with -- that that's what it says, because
obviously that was the nature of the litigation, and the
dispute, and it was obviously an update of the
litigation, hence the first sort of big brief I'd been
given since taking on the role.
One of the things about this brief -- we've flicked
through it and we can see that it's something like
50 pages, it's quite dense stuff. So we can see that,
by being given this amount of material, without it
necessarily identifying "Look, Ms Tolhurst, this is the
hot topic, if we lose this then this could be curtains
for the Post Office", because the very identification of
who is responsible for paying these shortfalls is pretty
much an essential foundation of the litigation.
Mm.
Now, that doesn't seem to have happened. It doesn't
seem to have got on to your operational radar as being
"Look at this, watch out for this problem"; do you
agree?
So yeah, I would agree. So for example -- I mean, one
of the ways I work anyway, and I had it number of times
in that portfolio, I had to get to grips with very large
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being identified, is regarding this question of how
shortfalls are accounted for within branches.
So if we add up the pieces we've got so far: you've
been in post for a few months. One of the jobs that you
had to do is, essentially, look after areas that are
relating to the Post Office. Yes?
Mm-hm.
You need to say, yes, or no.
Sorry, sorry, yeah.
Thank you very much. You understood that the Horizon
system was essentially the working operating system for
branches, and that it was an accounting system, run by
the Post Office. Yes?
Yes, yes.
You've lived -- I think you've lived and worked in Kent
for -- you were an MP in Kent. You're as familiar, as
we all are, with small branches of post offices up and
down the country.
Yes.
You've said already in your evidence that you were aware
that these branches were small businesses, as against
a much larger corporation.
(The witness nodded)
Okay. So what we've got here, it seems, in the
briefing, do you accept this, is you're being warned:
166
documents, or points within Government that I had no
experience of before. So I'm absolutely fine with
reading documents, taking it in, obviously there may or
may not be some questions that I may or may not arrive
‘out of reading what's put in front of me, but you're
quite right.
So I don't remember or recall anyone, when I first
looked at this brief, saying, "This is going to be
a problem, this is something that the Post Office, you
know, will have such a bad judgment on", and the reason
I say that is because, obviously, I had this, going into
that meeting, and then having those assurances that
there was confidence from the Post Office that they were
right. And, obviously, whilst, you know -- and, you
know, I'm not a lawyer, I don't have any legal
experience, and I wouldn't -- and I'm sure the civil
servants wouldn't have liked it for a minister to have,
you know, to -- they would always caution against going
against sort of legal advice.
But here, Ms Tolhurst, the legal advice actually is
“Look, we may well lose on these issues". So here's
an area whereby the owner of the Post Office could have
said, "Hang on, what does it mean if we lose on these
issues? How bad is that?"
Yeah.
168
(42) Pages 165 - 168
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Now you say in your statement -- I don't want to go to
it because of time limitations -- paragraph 57, it was
probably -- this is March 2019:
"Probably at this time I was first told of the core
issues in the Horizon Issues trial."
Well, actually, when we go back to this briefing,
you are being told about these core issues quite a lot
earlier than that. Now, where has this gone wrong?
Should somebody and, if so, who, have said to you "Look,
if we lose this, this really is significant for the
entirety of the litigation. The company that we own."
Who should have pointed out to you, do you think?
Well, actually -- sorry, so I think that it was -- so
actually, there's not one person that is, you know, sort
of -- it's a failure of the whole system because,
actually, I think, as I said earlier in the evidence on
the answer to --
I said who. You may want to say role or position.
Yeah, sorry.
No. My fault.
So in answer to Emma Price's questioning and I said,
actually, that, you know, severe -- I shouldn't have
been the first or the last person to -- or could have
been -- I shouldn't have been the only person to have
had that message. So that -- you know, if there was
169
"This did not feel enough for me as a first time
junior minister to go against the advice. In my mind
also was that, in taking that sort of action ..."
Then you go on to talk about other issues that
you're saying are on your mind.
Mm.
But it's not just in recent history that there's been
a churn of ministers. It is -- there is a frequency of
churn of ministers across our system.
Yeah.
Indeed, you have occupied various --
A number --
Various posts, quite short periods of time, so you're
quite a good person to ask about this. It's frankly
quite difficult to get a sense of Government from
ministers that are constantly changing, who are
constantly having to be briefed, worked up in terms of
knowledge and then start making decisions.
Mm.
Because you end up in challenges like this, by being
told by senior legal people, X or Y. What do we do to
change that? How do we make sure that somebody actually
gets a grip on these things?
Well, I think specifically around the Post Office,
because I do agree with your point, you know, in regards
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a severe issue, I would have expected it to come through
the shareholder -- the Government Shareholder
representative on the Board because, ultimately, that's
their role but I would have -- but that should have been
something that had been discussed widely, it would have
been something that you would that have expected UKGI to
be over, a Permanent Secretary to be over.
It should be -- you know, you shouldn't have had
a junior Minister chasing around or sort of, you know,
working out what to -- what information or what not to
believe, and I think that's the fundamental issue.
Okay. Can I tackle that?
Sorry.
No, that's fine. Can I tackle that, paragraph 78 of
your statement, page 28. You're talking there, at the
beginning of that paragraph, about the arm's-length
model. You're talking there I think, if I recall
correctly, about recusal application and legal advice,
which I will, if I have time, just quickly go to in
a moment.
Mm-hm.
But this point about a junior minister point that you've
just gone to, you say this at paragraph 78, the
situation at that time, arm's length, senior counsel
legal advice, and so on:
170
to churn of ministers, getting up to speed, being given
that information in order to make proper decisions, but
I think where the Post Office concern is slightly
different, because -- and this is where -- and it
goes -- I think I've said it in my statement but, excuse
me, I can't remember the paragraph without looking it
up.
And my only sadness is that Post Office Limited
wasn't what I would call a true arm's-length body of
Government, where, actually, as the junior minister,
I would have had powers of direction and absolutely the
position to be able to ask and demand information or
make a judgement. And, for me, as -- even though it was
my first time ministerial appointment, you know, I've
spent my whole life taking, you know, living with the
consequences of the decisions that I make in my work
life, so if I had been in a position where I could make
decisions, I would have -- and it's a phrase I've
used -- I live or die by my sword. And if I made the
wrong decision, I'll take responsible for that. If
I made the right decision, all very good.
And that's one of the things that this is -- and,
for me, this is the problem. The fact that it was
a limited company, not a true arm's-length body of the
Government and, therefore, I personally, if I can say,
172
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you know, whatever -- you know, I -- I hope that the --
‘one of the outcomes of this Inquiry is actually the Post
Office structure is completely changed.
Q. Let me briefly, and we'll finish on this, legal advice,
paragraph 73 of your statement. Now, paragraph 73, it's
an example of legal advice that's been given but you
refer generally in your statement, as you have in your
evidence, to strong legal advice that you've been given.
Effectively strong legal advice to stay out of it,
to not interfere with this particular body.
Now, for the people that I represent, that feels mad
because there you are, you own essentially, as the
Government --
A. Yeah.
Q. -- you own the Post Office. Now, the legal advice that
you're being given if you look at what you have there at
paragraph 73, which is reasonably good as a reference to
the type of legal advice, it not legal advice that is
saying that there's legislation that says you've got to
keep out of this. It's not cases that say you've got to
keep out of it. This is more kind of we think it might
not be a bad idea if Government sort of keeps away from
it because we don't want to get burnt type legal advice.
This is barely legal advice if it's a legal advice
at all. Why did you feel that you had to follow stuff
173
Q. Do you agree that ministers in the future need to look
at the question, which is: is this actual legal advice?
Is this about the law saying something that can or can't
be done because that's a legal principle, or is this
other types of advice, which isn't necessarily from
anything other than coming from lawyers?
A. lagree, you know, I --
MR STEIN: No further questions. Thank you, Ms Tolhurst.
SIR WYN WILLIAMS: All right. Thank you.
Just one follow-up on that before Ms Patrick.
It seems to me that your core complaint when you
talk about what frustrated you was your inability, in
effect, to direct the Post Office what to do in certain
circumstances. So I take it you want me to look at
powers of direction, if any, which currently exist and
whether they should be greater?
A. Thank you, Sir Wyn, yes --
SIR WYN WILLIAMS: I've got the point. That's fine.
Yes, Ms Patrick?
Questioned by MS PATRICK
MS PATRICK: Thank you, sir.
Ms Tolhurst, my name is Angela Patrick, I represent
a number of subpostmasters who have been convicted but
since have had their convictions overturned. You see
Mrs Hamilton to my right and Ms Hall and Mrs Henderson,
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that isn't actually rooted in law?
Well, because as someone who is not an expert and
particularly in regards to legal matters, and I -- you
know, I can't profess to be so -- when you are given --
if you are given advice from trusted, experienced,
qualified -- or people that you perceive to be
qualified, you know, I had nothing to -- you know,
what -- you know, at that particular time, or especially
in short time, you've then got to rely on being able to
have other advice in order to challenge that, and
actually -- and one of the challenges, going back to
your earlier question, around, you know, the
responsible -- I'm not making excuses, please don't
think that that's the case.
But, you know, there is so much going on, there are
so many demands on your time. You only have a certain
amount of bandwidth. So you do have to rely or put some
trust in some of the information that you are given by
your advisers and that's not a get-out -- you know, I'm
not trying to negate any responsibility for not
challenging because, absolutely, that's the role of
a Minister: to challenge.
And, you know, others will judge, you know, whether
I was right or wrong. I just try to act in the best --
the best that I could at that time.
174
to my right.
I have two matters and I think I'll only take you to
one document, if I need to. The first I think I can
take quite quickly. Ms Price has asked you questions
about your concern that you had around the time of the
recusal, so spring 2019, that Mr Cooper had "gone
native", and that you're having problems getting
information through UKGI. She has also asked you
a general question about cabinet collective
responsibility.
Did you raise your concerns about Mr Cooper having
gone native or your concerns about blockages of
information coming through UKGI with any more senior
ministerial colleagues: your Secretary of State or
anybody at the Treasury?
So, yes, and absolutely, that's why we ended up with the
paper which gave us a number of options to -- on how
potentially we could move forward. One of the things
that I think I referred to in my statement is that, you
know, I was concerned about -- I was concerned about
what was happening at the Board for the shareholder
representative, and I was very annoyed about the
recusal. And, you know, my initial reaction was, you
know -- I know we didn't end up in that place but my
initial reaction was I wanted to change the Board and
176
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I wanted -- and I did -- I wanted advice on how I could
remove the Chair.
So -- and do you know, if I look back, if I had
taken that decision or enforced -- or got that decision
made, what would have, you know, would that have
affected things? I don't know because I don't -- we
don't know, in hindsight. But that's -- I do believe
I raised concerns, and hence whilst I also mentioned in
my statement that I didn't want informal meetings,
I wanted it on record, you know, the information that
I was being given, because it wasn't until -- sorry.
Can I stop you there. We've got your witness statement.
I just want to say you did escalate it.
Yeah.
Now, we're going to hear from other ministers.
Mm-hm.
That kind of communication, where you have concerns
about what briefings are happening, how they are,
whether the role is being performed properly, that's
something that any minister can do, they can share
concerns with other ministerial colleagues, they can
raise it, they can escalate it if they've got particular
concems at any time. That's fair?
Mm-hm, yeah.
Secondly, I just want to return, again in that general
177
Government would have had that nuclear option that all
shareholders have. They could have got rid of the
Chair, they could have got rid of the Board at any time.
Mm.
You're nodding, I think you have to say yes.
Sorry, apologies yes, yes, yes.
You've said repeatedly, like others have, that you would
have been deeply conscious about the important role the
Post Office played in the community?
Mm-hm.
You would have known that the Post Office was a business
with public commitments that had to be discharged --
Yes.
-- commitments that the Government was very conscious
of. Now, you knew the Government had passed the 2011
Act and was working with a goal towards mutualisation
for the Post Office. You would have known that in your
role, wouldn't you?
Yes.
Now, the Inquiry has seen repeated correspondence,
appointing repeated Post Office chairs, where ministers
write to those chairs and set the goals they see for the
business?
Mm-hm, yes.
You would have known as Minister that Government was
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sense, to what you say about the powers and
responsibilities of Government in respect of POL and
I won't take you to a document I was going to take you
to, just to save time. I will give the reference,
POL00259978.
It will have been very familiar to you. It's a long
also in list of PQs with your name on, where you
state -- most of them have answers which start with "POL
is wholly owned ... but POL is an independent commercial
business". That's a line that would have been very
familiar to you --
Mm-hm.
-- from the start of your role and it's reflected in the
evidence you've given to the Inquiry today about your
concerns about the arm's length role of the Post Office
and the limitations and responsibilities and the ability
of Government to direct.
Again, you've said about operational issues with
Ms Price and you've raised that with Mr Stein.
I just want to go back to taking hindsight out of
the picture, what you and other ministers would have
known at the time you were in post. You'd have known
that the Post Office was wholly publicly owned.
Correct.
You, of course, have addressed the fact that the
178
essentially setting strategic goals for the business
that they were essentially working through the Chair to
achieve?
Yes.
You knew that the Post Office continued to lie on
a really important public subsidy --
Yes.
-- and one of the goals was to reduce that public
subsidy?
Yes.
This was no ordinary, independent commercial business,
was it?
No.
No. So, was repeating that line, as Government often
did, including in PQs, really just a convenient way to
avoid the true picture, that the Government didn't want
to face up to the fact that the Post Office was
a state-owned body which had, or at least potentially
may have, unlawfully prosecuted hundreds of innocent men
and women for years?
So I -- so my response would be that I don't believe
that, you know, I definitely wasn't using it as
a convenient excuse not to get involved.
I fundamentally believed that I was unable to and hence
why I made the comment about what I believe that
180
(45) Pages 177 - 180
ONOaARWN
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The Post Office Horizon IT Inquiry
really -- you know, if we're in a -- if the Government
are ever in a position where they own a -- you know, it
doesn't work, you know. Government can't be
a shareholder of an organisation without having fully
operational responsibility, as far as I'm concerned.
Q. Can! stop you there, I'm very conscious about time and
I just want to go back to that notion of the nuclear
option: that the only option the Government had was that
nuclear option to get rid of the Chair. That nuclear
option, whether its owned by the Government or any other
majority shareholder, that nuclear option gives you
leverage, doesn't it?
A. Yeah.
Q. You had serious concerns about the direction of
litigation, you had serious concerns about Tom Cooper
and about UKGI, and you say you did something about it.
Now, we'll look at that. But if you or any other
minister really wanted to do something about what the
Post Office was doing, whether in the litigation or in
its other conduct, you really did have options short of
the nuclear, didn't you?
A. Yes, I mean, it's highlighted. I've -- I have
absolutely been clear about that and, you know, I -- if
I had, you know, I don't -- I said in -- earlier on in
evidence that, you know, I don't know why -- I, you
181
was leverage, you know, I asked questions.
Q. You did.
A. But it wasn't enough.
MS PATRICK: Thank you. That's all the questions I have,
Ms Tolhurst.
SIR WYN WILLIAMS: Ms Tolhurst, just so that I'm clear about
this, the so-called nuclear option, was that something
which you personally could have done, if you'd thought
that to be the appropriate course of action, or was that
for the Secretary of State?
A. Well, I think the -- it would have been for -- it would
have been under a direction of the Secretary of State,
Sir Wyn.
SIR WYN WILLIAMS: Ultimately, he or she would have had to
agree with that option?
A. Yeah, absolutely, and they were the options that were
presented to us. I mean, it's my characterisation of
nuclear option.
SIR WYN WILLIAMS: No, no, I follow that --
A. That's my words --
‘SIR WYN WILLIAMS:
process.
A. Yes, sorry, it was --
‘SIR WYN WILLIAMS: All right. Thank you very much.
Is that it, Ms Price?
183
I just used the phrase to identify the
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know, I know there wasn't an appetite for it. However,
actually, I was someone who, you know, I -- you know,
I would have -- I would have fronted -- even if it had
been the wrong decision, I would have fronted that out.
And, you know, that's one of the -- I don't know what
would have happened if I had taken that decision and if
it had -- hadn't have sort of been discouraged not to.
I don't know if it would have had any -- an impact for
the postmasters and subsequent -- you know, subsequent
operations.
And that's something, you know, I can't answer.
I can only explain what I was thinking and where I was
at the time. But you're right. But, I mean, I can only
speak for myself. I can't speak for other ministers,
you know. I -- for me, it was definitely not an -- it
wasn't an excuse not to get involved because if I had --
if I felt that I had justification and evidence to back
up a decision, I would have taken it.
Q. Just to bring it back to the very simple question, you
focused, in what you've said to Mr Stein and to the
Chair and in your witness statement, about the
Government being limited to that nuclear option. It
wasn't the only option Government had was it; there was
leverage?
A. Well, I think I've sort to explained that, you know, it
182
MS PRICE: I Itis, sir.
SIR WYN WILLIAMS: Well, thank you, Ms Tolhurst, for making
a very detailed witness statement and for answering
a good many questions this afternoon. I'm very grateful
to you on behalf of the Inquiry.
THE WITNESS: = Thank you.
SIR WYN WILLIAMS: So we'll resume again at 9.45, I take it,
tomorrow, with Mr McFadden; is that right?
MS PRICE: That's right, sir.
SIR WYN WILLIAMS: All right. Fine.
MS PRICE: Thank you.
(4.35 pm)
(The hearing adjourned until 9.45 am the following day)
184
(46) Pages 181 - 184
The Post Office Horizon IT Inquiry 17 July 2024
INDEX
KENNETH MCCALL (sworn) ...
Questioned by MR STEVENS ....
Questioned by MS PATRICK . 7
THE RIGHT HONOURABLE KELLY JANE 86
TOLHURST (sworn)
Questioned by MS PRICE ... 86
Questioned by MR STEIN .... 162
Questioned by MS PATRICK . 175
185
(47) Pages 185 - 185
MR BEER: [1]
142/18
MR STEIN: [2] 163/1
175/8
MR STEVENS: [13]
113 116 1/10 39/1 40/1
40/5 40/9 40/11 76/17
76/23 85/21 86/4 86/9
MS PATRICK: [4]
7715 85/18 175/21
183/4
MS PRICE: [17]
86/13 86/15 86/18
122/25 123/3 123/7
123/11 123/13 159/5
159/11 162/7 162/16
162/20 162/22 184/1
184/9 184/11
SIR WYN WILLIAMS:
[34] 1/5 38/10 38/25
40/3 40/10 76/22 77/2!
85/20 85/22 86/3 86/8
86/14 123/2 123/5
123/12 140/7 141/8
142/10 142/16 159/2
159/10 162/11 162/21
162/24 175/9 175/18
183/6 183/14 183/19
183/21 183/24 184/2
184/7 184/10
THE WITNESS: [2]
86/2 184/6
"16 [2] 14/21 33/8
49 [1] 61/3
"22 [2] 72/25 74/21
‘aggressive’ [1] 81/8
‘appearance’ [1]
109/11
"Briefing [1] 104/21
‘campaigning’ [1]
83/24
‘Common [1] 101/9
‘deeply [1] 83/22
‘emphasised [1]
107/3
"executive' [1] 150/5
‘following [1] 98/13
“for [1] 127/22
"government' [1]
150/4
"headlines' [1] 24/9
"Horizon [1] 101/10
"Justice [1] 115/11
"Legacy' [1] 18/22
‘legally’ [1] 81/21
‘losses’ [1] 164/22
"no [2] 61/23 119/12
‘of [1] 54/25
‘Paula [1] 109/3
"RAG' [1] 57/6
‘represents [1]
146/23
"system' [1] 54/19
‘the [2] 30/9 103/21
‘top [1] 118/12
‘trial’ [1] 54/17
‘what’ [1] 55/24
‘who [1] 42/19
‘would’ [1] 60/15
1
1.2 [1] 114/20
1.21 [1] 80/14
1.35 [3] 86/4 86/8
86/12
1.8 [1] 115/5
10 [1] 164/19
10 August [5] 93/12
96/3 97/10 99/6 112/1
10 July [1] 56/17
10 September [4]
94/9 100/17 101/1
134/13
10.05 [1] 1/2
100 [1] 29/20
101 [4] 29/19
14 [6] 59/6 100/13
102/24 112/2 132/22
165/9
11 June [1] 154/10
11 October [1]
111/15
11 September [1]
48/20
11.00 [1] 78/13
11.15 [1] 40/6
11.25 [4] 40/2
11.26 [1] 40/8
12 [5] 90/13 90/15
103/24 119/7 163/21
12 minutes [2]
162/23 163/1
12.00 [1] 78/13
12.15 [1] 149/25
12.44 [1] 86/10
12.47 [1] 78/24
124 [1] 154/13
125 [4] 155/23
126 [1] 128/15
128 [1] 154/13
13 [3] 22/3 92/12
12717
13 February [1]
88/10
13 March [1] 60/8
14 [4] 11/8 11/10
92/18 92/20
15 [1] 93/6
15 July [1] 21/13
15 March [1] 151/18
15 May [1] 54/8
16 [4] 11/16 24/4
98/21 150/7
16 August [7] 93/7
94/23 95/23 96/6
97/12 102/14 104/24
16 March [1] 149/23
16 November [1]
34/11
16th [1] 97/13
17 [3] 15/1 98/9
123/14
17 July 2024 [1] 1/1
17 October [12]
100/18 104/25 105/6
111/11 111/16 111/24
114/6 125/19 129/1
134/15 163/23 164/11
17 years [1] 87/20
17.15 [1] 152/21
18 [4] 15/9 20/19
155/9 156/1
183 [1] 29/22
184 [2] 29/21 29/25
18th [1] 60/14
19 [1] 69/5
19 July [2] 88/5 88/9
19 June [1] 87/3
19 March [2] 147/17
152/21
19 November [1]
135/4
194 [2] 158/25
159/12
198 [1] 159/16
199 [1] 159/16
2
2 December [1]
17/10
2.1 [1] 26/14
2.2 [2] 115/9 117/14
2.3 [2] 118/9 119/8
2.38 [2] 123/5 123/8
2.45 [1] 123/4
2.50 [2] 123/6 123/10
20 [2] 52/14 97/17
20 November [1]
135/5
2007 [1] 3/6
2010 [1] 3/25
2041 [2] 87/24
179/15
2012 [1] 115/10
2013 [5] 21/2 21/6
21/13 21/17 118/13
2014 [1] 41/2
2015 [5] 17/10 30/6
34/21 35/12 88/2
2016 [20] 2/22 3/9
3/25 13/19 14/11
14/14 14/17 15/18
16/23 19/10 19/16
22/23 22/24 27/11
32/8 39/6 39/8 39/10
41/3 44/11
2017 [4] 48/21
2018 [33] 20/23
26/14 26/15 54/8
54/13 56/17 57/18
88/5 88/5 88/10 90/3
93/7 93/12 94/23 96/3
104/10 104/24 105/1
105/5 105/7 105/9
109/18 111/11 111/15)
111/24 114/6 127/10
131/23 135/4 136/12
140/8 164/11 164/15
2019 [27] 10/7 15/18
23/7 23/20 45/3 45/24
46/1 46/3 47/21 47/21
47/23 60/8 77/16
78/12 84/12 101/10
128/16 138/23 139/13
140/16 143/1 147/18
149/23 151/18 154/10}
169/3 176/6
2020 [9] 34/11 35/19
39/18 40/13 42/25
68/23 88/10 88/25
89/2
2021 [1] 88/25
2022 [3] 2/22 72/8
89/3
2024 [3] 1/1 29/18
87/3
21 [4] 145/20
21 February [3] 45/3
77/25 78/12
22 April [2] 40/13
42/25
22 September [1]
30/6
23 [7] 52/19 55/11
55/17 55/22 56/1 96/5
103/19
23 November [1]
136/11
24 [3] 61/16 102/11
104/6
25 [3] 65/1 65/4
104/5
26 [4] 104/14
27 [1] 104/18
28 [2] 105/9 170/15
29 [2] 44/4 106/14
29 January [1] 26/15
29 June [1] 131/22
3 September [2]
105/8 108/15
3.3 [2] 164/19 164/20
3.55 [2] 159/9 162/8
3.57 [1] 162/17
3.6 [1] 165/9
30 [3] 1/20 107/2
107/2
30 April [1] 29/18
30 July [1] 39/18
30 June [1] 68/23
30 October [1] 20/23
31 [3] 107/2 109/1
142/25
31 July [1] 99/20
32 [2] 123/18 123/20
33 [2] 18/16 119/17
34 [1] 126/9
35 [4] 2/7 111/13
163/20 163/21
36 [2] 50/6 119/6
37 [2] 24/5 124/18
38 [4] 22/12 127/6
4127/7 132/22
39 [1] 127/18
4
4 June [1] 154/18
4 March [2] 32/7 39/8
4.00 [1] 162/8
4.05 [2] 159/9 162/9
4.07 [1] 162/19
4.10 [1] 162/9
4.3 [2] 49/7 49/9
4.30 [1] 162/12
4.35 [1] 184/12
4.45 [1] 162/13
41 [1] 20/20
43 [1] 52/15
48 [1] 135/2
5
5 annexes [1] 93/25
5 April [1] 138/23
50 [1] 61/17
50 million [3] 127/23
130/21 131/3
50 pages [1] 167/11
50 per cent [1] 53/14
51 per cent [1] 53/15
52 [4] 65/2
550 [1] 27/13
560 [4] 27/13
561 [2] 115/7 131/1
57 [1] 169/2
58 [1] 145/19
59 [4] 145/21
5s [1] 125/6
6
63 [1] 44/4
65 [2] 1/20 146/15
66 [2] 44/12 146/22
68 [1] 146/15
69 [1] 147/2
7
70 [2] 158/25 159/11
71 [2] 147/21 159/16
73 [6] 18/17 87/3
148/20 173/5 173/5
173/47
78 [2] 170/14 170/23
8.00 [1] 1/23
(48) MR BEER: - 8.00
8
80s [1] 72/11
88 [1] 142/24
89 [1] 143/5
9
9 January [1] 88/5
9 July [1] 57/18
9.45 [1] 184/7
9.45 am [1] 184/13
90 [1] 27/12
90 per cent [1] 72/12
A
abandon [1] 49/13
ability [11] 23/6 23/8
46/23 71/5 71/20
71/22 110/18 130/20
144/18 161/15 178/16)
able [17] 11/25 26/3
27/15 59/15 60/11
71/23 113/12 113/23
122/17 125/25 127/20)
128/12 139/2 145/10
152/4 172/12 174/9
about [153] 1/17 2/18
7/11 9/12 9/13 10/8
12/15 13/17 19/9
20/13 21/15 22/1
22/22 22/25 23/2 23/5
23/12 23/24 26/8
27/10 28/4 38/1 42/3
42/17 46/11 46/12
46/14 46/23 47/6
47/23 48/2 48/9 48/10
50/16 51/23 59/6
61/12 63/6 65/24
66/14 67/16 70/16
73/19 73/22 77/13
79/15 79/16 80/7
80/24 81/4 81/10
81/19 81/20 82/1
84/13 85/10 87/13
91/16 93/12 102/9
102/20 103/11 104/7
107/11 109/14 111/19}
111/21 112/14 112/20
112/23 112/24 113/5
113/11 113/12 113/13}
113/15 113/16 114/21
116/17 116/21 116/25}
117/19 120/14 121/12)
122/3 125/11 126/4
128/2 128/21 129/8
129/10 136/8 137/3
137/15 138/7 139/8
139/13 139/20 139/21
140/18 141/8 143/20
146/2 147/23 148/10
148/20 149/9 150/20
152/13 154/10 156/6
156/8 157/7 157/9
158/4 160/11 160/18
160/20 164/3 164/19
167/1 167/9 169/7
170/16 170/18 170/22)
171/4 171/14 175/3
175/12 176/5 176/9
176/11 176/12 176/20)
176/20 176/22 177/18)
178/1 178/14 178/15
178/18 179/8 180/25
181/6 181/14 181/15
181/16 181/16 181/18)
181/23 182/21 183/6
about' [1] 42/19
above [9] 32/17
102/21 103/1 103/19
123/20 127/24 136/8
137/11 137/20
abreast [1] 141/22
absence [1] 133/2
absent [2] 121/19
165/4
absolute [1] 162/13
absolutely [24] 23/14)
31/19 81/8 82/14
85/16 116/16 122/5
122/16 125/4 138/7
141/4 144/14 145/4
150/23 154/25 157/5
157/21 157/22 168/2
172/11 174/21 176/16)
181/23 183/16
accept [18] 11/24
16/4 38/11 39/14
39/15 43/1 43/2 43/6
43/8 46/2 46/4 46/8
47/10 56/5 57/21
85/15 161/8 166/25
acceptance [1]
126/19
accepted [1] 84/25
accepting [4] 34/25
35/15 36/11 43/25
access [24] 23/6
23/8 23/9 40/24 41/12
42/2 45/11 45/14
45/15 45/17 45/21
46/1 46/2 46/8 47/3
47/10 48/2 78/3 79/16
81/4 85/1 136/4
144/17 160/2
accessed [1] 23/21
according [3] 47/17
62/21 67/24
account [3] 67/1 76/2
130/16
accountability [1]
64/8
accountants [1]
118/11
accounted [1] 166/2
accounting [8] 32/23
32/24 93/1 93/5
115/18 116/3 121/5
166/12
accounts [6] 16/14
34/3 128/18 165/2
165/4 165/7
accurate [2] 59/13
90/20
accusation [2] 46/17
62/18
accused [1] 116/13
achieve [2] 11/13
180/3
across [3] 62/19
132/1 171/9
act [4] 7/24 159/21
174/24 179/16
acted [4] 110/20
133/1 133/3 158/17
acting [4] 8/3 8/5
9/18 51/3
action [12] 24/11
34/19 35/11 38/18
51/22 118/1 121/21
135/14 155/10 155/14
171/3 183/9
actions [5] 52/9
133/12 134/8 135/10
164/25
actual [2] 28/24
175/2
actually [45] 2/20
17/17 24/3 24/23 25/4
25/19 39/17 43/22
57/24 65/5 71/1 93/18
100/20 103/14 108/13
108/20 108/22 111/4
125/16 128/25 129/17
129/22 131/13 138/2
138/10 138/16 143/17]
147/8 149/14 150/18
157/6 160/23 161/23
168/20 169/6 169/13
169/14 169/16 169/22)
171/22 172/10 173/2
174/1 174/11 182/2
add [2] 81/15 166/3
adding [1] 81/1
addition [6] 18/2
55/23 72/1 72/14
74/12 82/22
additional [2] 128/1
130/3
address [11] 34/2
52/5 71/15 71/19
71/21 73/1 73/6 94/25
105/9 111/12 154/12
addressed [4] 87/15
90/13 111/25 178/25
addressees [1] 94/14)
Adegun [2] 135/3
135/5
adequacy [1] 72/9
adjourned [3] 111/25
134/14 184/13
Adjournment [1]
86/11
admitted [1] 59/2
adopt [1] 49/18
advance [1] 112/10
adverse [7] 57/2
58/21 59/22 101/8
101/17 124/5 124/22
advice [75] 8/21
21/12 26/17 27/17
28/19 28/23 32/21
34/25 35/16 36/11
36/21 45/8 52/17
52/21 53/3 53/17
53/24 56/2 61/22
62/22 62/23 63/19
63/21 63/23 65/10
65/17 65/20 66/4 67/9
67/11 67/15 67/23
90/12 90/18 90/19
91/7 91/12 102/17
106/17 118/25 127/21
134/17 149/2 149/13
150/15 150/18 151/16}
151/20 152/5 154/19
157/17 157/20 158/10}
158/18 158/20 168/19)
168/20 170/18 170/25
171/2 173/4 173/6
173/8 173/9 173/15
173/18 173/18 173/23}
173/24 173/24 174/5
174/10 175/2 175/5
4177/1
advise [4] 8/23 11/25
55/14 72/2
advised [4] 32/1
44/19 50/8 150/3
advisers [2] 134/2
174/19
advising [2] 56/6
7116
affairs [3] 92/4 92/14
104/9
affect [3] 105/23
157/13 157/13
affected [2] 145/6
17716
affecting [5] 119/22
120/3 120/5 121/4
121/14
after [33] 2/1 2/2
10/17 12/14 13/8
17/13 18/6 22/23 27/3}
30/21 60/9 65/18
65/25 68/20 79/13
81/3 91/22 97/14
104/24 107/6 111/7
123/4 129/19 139/1
141/4 146/13 146/17
146/18 152/25 153/7
159/6 160/5 166/5
afternoon [6] 34/15
86/13 123/1 162/20
162/21 184/4
afterwards [3] 10/16
56/3 139/9
again [25] 9/24 23/15
31/17 31/20 33/9
59/19 75/3 78/2 83/2
84/6 95/13 104/18
106/9 109/17 111/14
112/16 115/5 116/23
120/19 130/23 139/19}
149/4 177/25 178/18
184/7
against [27] 15/12
38/18 52/20 66/2 67/8
68/11 79/1 79/9
115/15 117/23 118/1
119/24 121/21 123/24I
124/17 124/23 125/14I
127/11 131/4 132/23
133/8 134/20 150/25
166/21 168/18 168/19}
17112
agency [1] 82/2
agenda [4] 24/8 75/8
75/9 101/1
agents [1] 164/22
aggressive [1] 82/13
ago [2] 20/12 38/2
agree [21] 8/10 12/25)
30/15 32/3 47/13
47/17 59/19 64/17
67/12 107/3 152/2
156/14 156/15 167/3
167/4 167/22 167/23
171/25 175/1 175/7
183/15
agreed [4] 64/18
82/16 84/21 152/24
agreeing [2] 12/21
153/21
agreement [2] 98/13
99/14
ahead [6] 34/15
105/7 106/11 111/14
112/9 114/18
Aiming [1] 55/22
Al [2] 150/1 153/7
Al Cameron [2]
150/1 153/7
alarm [1] 116/12
albeit [4] 98/22
119/20 123/21 125/8
Aldred [3] 106/16
136/13 138/22
Aldred's [1] 107/3
Alex [6] 94/1 94/3
94/6 95/12 147/25
154/1
Alisdair [2] 73/23
146/4
all [60] 2/19 22/5
22/13 28/15 28/16
32/15 33/12 43/15
51/19 52/22 59/14
59/15 64/6 70/9 76/2
76/17 77/2 79/5 82/20
(49) 80s - all
A
all... [41] 84/10 85/21
86/8 92/8 95/22 99/3
100/5 103/3 104/16
108/7 113/3 114/16
125/11 125/17 126/24}
140/21 141/11 141/21
142/10 142/16 142/18
143/15 144/14 146/12)
157/9 159/12 162/7
162/11 162/15 162/24}
163/17 164/16 165/15
166/17 172/21 173/25}
175/9 179/1 183/4
183/24 184/10
allegation [2] 16/19
23/2
allegations [8] 10/9
10/25 14/13 16/9
16/17 20/1 116/11
116/21
alleged [1] 115/24
alleging [1] 93/2
Alliance’ [1] 115/12
allocated [1] 106/6
allocating [1] 76/15
allows [1] 132/6
almost [4] 25/2 25/2
52/21 83/23
already [5] 32/8
73/13 114/11 152/23
166/20
also [37] 4/21 8/22
26/18 34/2 39/7 39/12
45/6 52/22 70/17
73/18 75/21 77/25
80/18 83/20 91/10
92/4 101/24 109/2
109/5 112/6 126/21
128/15 132/6 134/16
136/20 138/25 139/2
144/18 146/9 160/8
161/2 162/1 165/16
171/3 176/8 177/8
178/7
altered [1] 34/4
alternative [9] 31/19
62/2 62/3 62/11 62/12
62/14 62/16 63/2
63/15
alternative’ [1] 61/24
alternatives [2] 63/4
63/25
although [10] 30/4
30/15 30/20 31/12
31/24 74/19 111/17
119/14 150/2 163/24
always [6] 13/6 81/25)
107/10 107/14 145/5
168/18
am [12] 1/2 40/6 40/8
76/24 104/23 138/15
138/19 151/21 160/23
161/20 162/1 184/13
Amanda [2] 69/11
69/17
amateur [1] 91/1
amendments [1]
146/17
amount [3] 24/13
167/12 174/17
amounted [2] 62/22
67/23
analyse [2] 13/21
56/14
analysing [1] 13/13
analysis [5] 14/12
33/19 58/17 90/21
90/24
Andrew [2] 134/9
149/22
Angela [2] 77/6
175/22
anger [1] 44/17
angle [1] 55/20
angry [1] 139/21
Annex [17] 94/12
95/14 97/19 97/21
98/11 98/15 98/18
98/20 99/16 99/18
99/21 99/24 100/1
101/3 102/5 102/5
155/3
Annex 3 [1] 94/12
annexes [9] 93/25
95/21 95/23 96/20
96/23 97/2 97/19
97/24 102/10
annoyed [2] 138/3
176/22
annual [1] 16/14
another [4] 7/3
100/20 153/6 159/5
answer [14] 1/16
75/5 89/4 107/10
111/3 116/23 118/24
182/11
answering [2] 85/7
184/3
answers [3] 141/7
141/8 178/8
Anthony [2] 45/6
54/14
anxious [1] 102/19
any [105] 4/1 4/5
8/21 8/23 10/7 10/18
22/18 26/8 27/16
31/24 32/23 34/19
43/6 47/9 48/6 51/22
55/17 55/21 59/17
62/16 64/1 64/12
64/12 64/13 71/21
138/12 139/24 145/11
160/18 169/17 169/21
10/21 15/11 21/3 21/8
27/16 28/3 30/1 31/21
35/3 35/11 38/18 43/3
73/23 73/25 74/4
74/24 74/25 75/5 76/1
76/18 81/7 81/14
85/19 91/3 95/12
96/19 99/21 101/14
102/17 102/20 102/22
103/1 103/14 106/3
108/1 108/2 111/2
112/5 116/12 116/25
117/14 117/7 117/13
117/15 122/24 125/9
126/3 126/4 126/5
126/18 126/18 126/20
127/2 127/3 127/20
127/22 131/4 134/17
136/5 138/13 141/17
144/19 147/15 148/9
149/18 151/2 151/3
153/23 160/11 165/4
168/15 174/20 175/15}
176/13 177/20 177/23
179/3 181/10 181/17
182/8
anybody [1] 176/15
anyone [13] 6/5 10/1
18/10 23/24 56/2 82/6
110/8 116/13 121/23
139/25 144/25 148/3
168/7
anything [25] 7/11
22/1 23/23 26/7 27/3
27/19 27/22 29/7
35/21 35/24 47/14
54/3 62/10 80/7 84/8
100/1 100/8 103/6
103/11 120/1 130/21
135/11 149/18 152/24
175/16
anyway [2] 60/13
167/24
anywhere [1] 53/15
apart [1] 121/10
apologies [8] 28/22
54/9 60/11 81/23
93/18 96/1 97/1 179/6I
appalled [1] 145/23
apparent [2] 62/22
67/24
apparently [4] 37/7
62/21 67/7 148/23
appeal [2] 55/15
132/25
appeals [2] 7/5 47/7
appear [5] 24/17 47/8)
131/25 153/9 163/2
appearance [1]
111/9
appeared [2] 44/7
61/25
appears [9] 14/25
44/21 56/5 56/13
77/19 95/21 96/2
98/22 160/14
appendices [2]
123/17 125/1
appetite [2] 158/10
182/1
application [29]
50/23 51/1 51/7 61/15
61/18 62/24 63/2
63/11 63/11 63/16
64/3 64/5 65/12 65/18
65/23 67/2 68/4 90/23
145/18 147/22 148/2
148/5 148/8 148/25
149/2 150/13 152/18
153/3 170/18
applied [3] 51/10
65/14 90/21
apply [3] 42/20
109/16 113/7
applying [1] 61/24
appointed [4] 7/19
70/12 108/16 118/11
appointees [3] 70/18
70/20 71/7
appointing [1]
179/21
appointment [7] 4/1
4/2 17/9 17/13 19/22
88/14 172/14
appointments [2]
76/10 76/11
appraised [1] 157/16
appreciate [4] 40/15
42/8 52/22 60/16
appreciated [2]
52/23 104/7
approach [16] 48/19
49/25 52/4 52/5 57/6
63/5 66/12 73/20
81/17 82/10 109/20
110/4 110/19 126/22
143/14 156/6
approached [1]
146/11
approaches [1]
83/10
appropriate [4] 34/18}
34/19 35/10 183/9
appropriately [3]
154/23 158/17 159/21
approximately [2]
27/12 106/8
April [12] 14/20 19/9
19/16 22/23 27/11
29/18 40/13 42/25
138/23 139/13 140/15}
143/1
Arbuthnot [2] 115/13
116/9
are [90] 2/11 2/14
6/22 7/3 11/21 17/22
20/4 21/5 21/18 25/17
26/6 34/12 39/11 41/4
41/22 42/11 43/16
43/25 45/1 48/14
51/19 54/15 56/10
56/10 62/24 63/4
63/25 65/24 67/18
74/6 75/6 76/11 76/17
76/18 76/19 77/10
81/21 81/23 81/25
82/1 82/8 84/20 84/23}
85/2 87/14 92/8
102/13 104/14 106/25)
109/6 109/20 132/3
133/3 134/16 135/10
139/11 139/12 140/9
151/10 152/8 152/9
154/14 155/1 155/9
159/3 159/4 159/5
161/23 162/3 162/7
163/7 163/10 165/6
165/14 165/17 166/2
166/5 166/17 169/7
171/5 171/16 171/16
173/12 174/4 174/5
174/15 174/18 177/18)
177/18 181/2
area [3] 149/7 165/25
168/22
areas [10] 89/23
108/18 118/15 124/13)
124/19 147/3 155/13
165/16 165/23 166/5
aren't [1] 76/20
argue [1] 164/24
arguing [2] 45/17
67/7
arguments [11]
52/19 53/1 53/4 53/6
53/18 53/19 55/11
55/11 56/25 66/8
165/11
arising [2] 12/1
119/15
arm's [5] 170/16
170/24 172/9 172/24
178/15
arm's-length [3]
170/16 172/9 172/24
arose [1] 73/15
around [15] 1/22
34/20 35/12 75/16
80/7 82/11 82/20
112/17 125/13 127/23}
143/19 170/9 171/24
174/12 176/5
arrange [1] 17/15
arrangement [1]
162/15
arrangements [2]
55/6 128/2
arrive [1] 168/4
arrived [1] 92/2
articulate [2] 127/5
129/13
articulated [3]
133/24 148/18 153/16)
articulates [1]
153/16
(60) all... - articulates
A
as [280]
as Assistant [1] 88/4
Asia [1] 3/3
aside [3] 27/7 71/12
76/10
ask [42] 1/18 2/6
2/18 7/3 14/24 16/10
21/20 28/17 32/9 58/6
62/11 71/10 76/17
77/6 77/13 80/6 84/3
100/2 102/5 104/2
104/4 107/22 112/22
113/3 113/13 113/14
114/4 116/19 118/19
118/21 118/24 119/4
120/25 121/12 131/25}
135/16 140/7 153/7
163/13 164/18 171/14
172/12
asked [29] 20/18
21/14 30/9 30/18 35/8
44/23 48/10 48/12
48/17 56/13 57/24
T7IN7 77/21 107/10
113/13 113/14 117/19}
120/13 130/9 136/7
137/4 139/25 154/19
157/19 162/14 163/7
176/4 176/8 183/1
asking [15] 30/23
36/17 68/17 73/25
78/25 79/16 86/21
87/13 100/7 108/6
108/25 129/1 141/25
142/6 142/7
asks [1] 109/5
aspect [2] 13/25
117/13
aspects [1] 2/19
assertions [1]
118/10
assess [2] 13/4
33/24
assessed [6] 57/4
57/8 124/15 124/21
125/6 133/20
assessing [1] 130/17
assessment [7]
49/19 57/13 57/15
57/17 92/18 92/21
124/2
asset [1] 134/21
assets [1] 165/8
assets' [1] 132/7
assets'/projects' [1]
132/7
assist [8] 23/11
27/20 36/7 47/20
47/22 58/7 73/5 86/23)
assistance [2] 6/18
89/18
Assistant [1] 88/4
assisted [4] 5/7 6/15
TIT 89/14
associated [1]
102/22
assume [3] 54/12
55/6 60/15
assuming [1] 155/8
assurances [3]
120/15 125/17 168/12)
at [347]
attach [1] 29/6
attached [4] 39/9
93/17 93/24 101/3
attaches [1] 29/7
attaching [1] 39/12
attachment [3] 39/6
95/20 96/4
attachments [1]
95/18
attempt [1] 153/23
attend [1] 45/4
attendance [3] 54/15
56/18 69/25
attended [5] 44/15
44/22 56/3 77/20 78/2
attendees [1] 101/2
attending [3] 1/16
75/6 100/17
attends [1] 45/3
attention [1] 75/19
attitude [3] 109/20
110/4 110/19
attractive [1] 69/8
attributed [1] 114/25
audible [1] 89/4
audience [1] 49/17
audit [6] 14/1 45/16
46/6 47/13 47/16
74/14
auditor [2] 16/13
128/23
auditors [3] 15/20
128/9 128/17
August [20] 90/3
93/7 93/12 94/23
95/23 96/3 96/6 97/8
97/10 97/12 98/21
99/6 102/14 104/10
104/24 105/5 105/6
111/11 112/1 113/9
authored [1] 111/15
available [4] 27/21
32/2 56/24 155/1
avoid [4] 75/2 81/1
154/5 180/16
aware [55] 7/18
14/20 15/16 21/18
23/11 23/16 28/8
28/10 28/13 28/15
28/18 28/24 29/3 29/4
30/5 32/11 33/4 33/7
33/11 33/11 34/5
35/20 35/21 36/6
38/20 41/5 41/9 41/11
42/24 45/20 46/2 46/7
47/16 48/11 48/16
50/1 59/20 84/25 98/1
103/6 109/20 113/21
130/5 134/19 137/23
138/16 138/19 145/20
147/17 150/9 151/10
151/18 151/19 156/19I
166/20
away [3] 55/19 95/13
173/22
baby [4] 18/25 19/3
19/15 31/2
back [41] 13/7 14/19
14/23 20/4 21/1 23/20
39/11 40/2 43/8 54/13
55/22 70/2 77/14
93/18 93/23 94/15
94/22 95/12 99/5
108/4 108/5 119/17
123/4 123/13 125/12
131/12 140/21 142/11
144/19 147/3 147/4
147/11 161/17 162/9
169/6 174/11 177/3
178/20 181/7 182/17
182/19
backbenches [1]
89/7
background [16]
2/20 2/25 19/1 74/12
87/18 94/11 96/5
98/15 99/11 99/16
103/20 104/1 111/18
114/9 115/8 163/25
bad [3] 168/10
168/24 173/22
badge [1] 41/6
badly [1] 52/16
balance [1] 56/24
balanced [2] 65/21
81/25
bandwidth [1]
174/17
banking [2] 17/24
75/23
bankruptcy [1]
115/21
banner [1] 115/11
bar [1] 132/1
barely [1] 173/24
Baroness [6] 19/21
28/9 28/14 29/13 32/6}
39/7
barrister [2] 36/6
38/22
barristers [3] 52/17
56/5 67/24
based [11] 15/21
18/25 53/18 53/23
56/23 58/14 67/15
91/15 117/8 137/22
142/4
basis [16] 3/15 21/25
26/2 32/25 33/2 53/21
62/22 66/6 68/1 68/18
82/23 90/18 90/20
121/23 145/10 157/2
be [196]
bear [3] 8/6 9/24
20/11
became [10] 3/3
14/20 15/13 23/16
24/8 32/11 48/24
65/20 88/16 147/17
because [79] 5/14
20/8 21/17 25/7 27/17,
35/21 47/1 54/24 59/1
60/3 62/4 62/7 64/7
66/2 66/11 66/15
67/18 68/10 75/22
76/9 78/24 83/3 83/9
86/5 91/6 92/9 96/4
96/12 97/5 112/8
113/8 117/21 125/21
126/21 128/7 129/1
129/7 131/11 131/14
131/23 135/24 137/17]
138/4 138/16 139/22
140/2 142/1 143/24
145/14 147/8 149/4
150/24 151/23 152/8
153/17 154/6 156/15
156/16 157/15 160/23}
161/14 162/3 167/4
167/15 168/11 169/2
169/15 170/3 171/20
171/25 172/4 173/12
173/23 174/2 174/21
175/4 177/16 177/11
182/16
become [5] 28/8
28/18 28/24 128/8
143/24
becoming [2] 3/8
96/16
been [145] 3/19 6/14
18/21 18/24 19/15
20/9 20/24 20/25
24/16 29/18 30/1 30/5
33/2 33/5 33/7 33/11
34/3 35/24 37/3 37/7
37/8 38/5 38/14 38/23)
39/21 41/16 44/16
44/19 46/18 46/25
47/4 47/5 48/16 51/9
52/18 53/17 57/4 57/5)
57/8 57/21 59/2 59/10
61/20 62/6 63/22
63/24 67/15 69/6
69/11 69/13 73/4
75/16 76/14 83/10
84/14 84/25 85/2
90/21 91/10 93/5
95/14 97/9 97/10
97/11 97/14 98/1
100/6 100/9 100/11
100/12 100/22 103/4
103/10 107/23 108/16)
112/16 113/21 115/17)
117/10 118/2 119/14
119/21 122/5 122/6
122/17 125/22 126/3
126/3 126/6 127/1
129/11 133/14 136/6
137/1 137/1 137/7
137/8 138/3 138/3
138/6 138/18 143/12
143/16 144/20 145/10)
146/1 146/25 147/7
149/1 149/14 150/3
151/4 151/9 151/20
152/25 153/19 154/22)
155/12 156/21 157/23)
158/13 161/1 161/12
161/13 166/4 167/7
169/23 169/24 169/24)
170/4 170/5 170/6
171/7 172/17 173/6
173/8 175/23 178/6
178/10 179/8 181/23
182/4 182/7 183/11
183/12
Beezer [1] 149/22
before [47] 1/18 5/20
6/8 10/6 14/23 16/3
16/10 20/10 21/20
23/12 30/7 38/12
40/18 41/16 42/5
46/12 47/16 47/23
52/2 57/22 61/20 62/6I
63/22 64/9 64/9 65/10)
65/25 74/8 74/9 75/18}
77/14 81/6 85/12
85/25 87/19 89/6
95/12 104/16 104/24
132/16 142/10 153/12)
153/24 159/2 160/6
168/2 175/10
beforehand [1] 10/17)
beg [1] 5/12
begin [1] 3/22
beginning [1] 170/16
behalf [9] 8/3 8/5
48/13 77/7 83/14
86/22 145/25 163/3
184/5
behaved [1] 145/24
behind [1] 153/8
being [71] 4/4 25/10
26/19 27/6 29/1 31/2
31/15 34/6 37/3 46/17
50/8 52/16 54/5 58/19)
62/19 63/25 72/3 85/4I
92/25 96/11 97/5 97/6I
99/2 102/3 102/17
106/2 113/12 115/20
116/2 116/11 116/13
116/20 117/16 118/8
119/11 120/7 121/19
(61) as - being
B
being... [34] 123/24
125/6 125/17 125/25
126/12 127/4 128/16
130/15 130/16 133/20
137/3 145/20 152/18
154/19 156/11 158/6
158/11 159/14 160/13
163/7 165/13 165/23
166/1 166/25 167/12
167/20 169/7 171/20
172/1 173/16 174/9
177/11 177/19 182/22)
BEIS [25] 10/2 34/13
89/15 90/5 91/18
91/22 98/2 98/6
104/12 107/9 108/11
108/19 109/21 110/16
110/20 134/16 139/3
141/20 144/18 151/10}
151/16 155/8 155/17
156/20 164/13
BEIS0000075 [1]
154/12
belief [3] 2/13 66/8
153/25
believe [64] 6/7 6/9
6/18 10/3 12/14 17/5
21/25 23/6 23/10 29/4
29/7 31/10 33/10
35/14 36/15 37/22
39/23 39/24 41/23
44/9 48/3 48/13 48/14)
48/16 49/11 51/25
52/23 62/5 63/5 63/6
67/10 67/12 74/9
83/23 96/10 96/18
97/25 100/19 113/24
114/24 122/5 128/25
129/1 132/17 132/21
133/25 135/16 147/8
147/25 148/18 149/4
150/2 152/8 152/22
153/14 153/15 156/5
157/14 161/11 165/10
170/11 177/7 180/21
180/25
believed [11] 48/2
54/4 66/2 67/5 67/11
67/14 67/14 68/8
68/17 160/14 180/24
believes [2] 34/24
36/10
below [5] 49/3 58/17
105/2 135/10 136/15
Ben [1] 74/10
beneath [1] 124/14
benefit [2] 7/13 94/14
benefited [2] 7/15
144/6
best [13] 2/12 6/1
16/23 29/10 36/24
39/23 48/1 58/7
113/23 122/11 127/5
174/24 174/25
better [19] 6/24 26/4
35/25 49/11 52/18
53/1 53/3 53/6 53/14
54/5 55/11 56/25
107/6 113/18 129/16
135/18 139/22 157/24)
163/16
between [21] 4/1
8/22 19/9 22/23 27/11
45/23 47/2 47/6 51/5
59/9 69/3 72/20 73/20)
73/22 88/25 101/2
105/5 139/10 161/2
162/8 162/9
beyond [1] 94/20
bias [2] 62/22 67/24
biased [1] 67/7
big [7] 103/8 108/18
116/23 132/9 136/3
141/3 167/7
BIS [1] 10/3
bit [9] 6/24 55/13
64/20 75/4 78/17 81/9)
81/10 95/3 124/12
black [1] 123/21
blank [1] 161/5
blindsided [1] 142/5
block [1] 139/9
blockages [1] 176/12
board [133] 5/19
5/22 5/24 6/5 6/14
6/15 6/19 7/8 7/9 7/10
7/15 7/20 8/7 10/14
10/17 11/12 11/19
13/2 14/14 15/4 15/10
15/15 15/18 16/6
16/10 16/21 16/23
16/25 16/25 18/19
19/4 20/11 23/25 24/7)
24/14 24/15 24/24
25/1 25/5 25/6 25/21
26/13 27/20 30/2 30/4
30/6 30/18 30/19
31/12 31/25 32/1 33/8)
34/18 35/2 35/18 36/4
36/13 36/16 36/23
37/3 37/8 37/18 37/24
38/5 38/15 39/22
40/13 40/21 41/16
41/18 41/21 41/22
41/24 43/12 44/8
44/15 44/20 44/22
48/24 50/7 52/23
59/21 61/17 61/19
63/21 64/4 65/8 68/23
70/8 70/9 70/12 70/20)
70/24 71/13 71/14
72/1 72/2 72/14 72/23)
73/8 73/9 73/12 74/6
74/11 74/12 74/17
75/8 77/20 79/21 82/3)
84/18 84/25 95/17
99/20 109/22 110/5
134/4 151/24 152/9
152/25 153/2 153/24
154/3 154/3 155/5
155/7 158/2 158/8
160/4 170/3 176/21
176/25 179/3
Board's [2] 24/15
44/5
Boarding [1] 97/21
body [5] 156/9 172/9
172/24 173/10 180/18
borne [2] 127/24
143/16
both [14] 7/18 57/4
75/12 81/23 91/7
95/22 99/24 114/24
115/18 116/3 135/10
142/14 142/15 142/15
bottom [17] 11/17
15/3 20/21 42/10
50/25 54/9 56/19
57/18 70/5 70/15
78/10 90/15 99/10
129/24 135/2 136/10
136/10
boundaries [1] 161/9
box [3] 81/25 90/9
131/25
Bramble [3] 41/2
44/10 48/7
branch [15] 34/3
45/12 46/22 46/23
47/3 47/4 71/19 71/23
72/12 72/13 93/1
114/25 115/3 163/5
165/21
branch's [2] 165/2
165/4
branches [4] 166/2
166/12 166/17 166/21
Branton [1] 40/12
breach [1] 22/16
breadth [1] 90/16
break [9] 40/2 40/7
76/21 123/1 123/9
159/4 159/6 159/9
162/18
breaking [1] 116/14
breaks [1] 86/5
brief [13] 23/19 92/6
92/9 92/9 94/6 101/6
104/9 107/20 112/20
152/15 167/7 167/9
168/8
briefed [5] 30/19
112/9 134/9 135/16
171/17
briefing [45] 20/14
31/11 45/8 92/1 92/4
92/7 92/14 93/7 93/9
94/9 94/11 96/15 97/3
98/15 99/12 99/16
100/15 100/25 103/4
105/3 105/7 105/9
106/11 111/10 111/15}
111/17 114/6 114/16
115/23 117/6 117/9
119/2 119/8 123/14
123/16 125/19 134/13}
163/23 163/24 164/5
164/7 164/9 165/14
166/25 169/6
briefings [9] 24/24
105/5 107/6 135/13
135/15 135/19 135/22
144/8 177/18
briefly [4] 4/25 61/15
83/3 173/4
bring [18] 4/17 8/6
11/7 18/16 24/4 26/11
29/15 32/5 33/2 34/9
39/1 40/11 50/7 52/14
55/22 61/16 94/1
182/19
brings [1] 123/3
broad [2] 50/1 91/20
broader [1] 71/10
broadly [2] 41/1
89/17
broking [1] 75/24
brought [3] 15/12
92/25 154/21
bug [1] 33/23
bugs [19] 14/15 15/5
15/7 33/14 47/7
119/16 119/21 119/25)
120/2 120/5 120/9
120/21 121/3 121/7
121/9 121/11 121/13
121/19 122/3
build [1] 73/7
building [4] 14/17
built [1] 69/6
bullet [5] 70/6 135/12
136/20 136/23 139/6
burnt [1] 173/23
business [47] 5/3 5/5)
5/9 5/16 8/14 9/13
11/23 12/1 12/5 12/5
12/7 12/10 13/7 14/5
14/8 14/18 17/24
17/25 18/1 54/23
54/23 58/22 58/23
59/23 75/22 75/24
75/24 75/25 75/25
76/1 79/8 85/6 87/20
88/9 89/12 105/13
106/10 124/6 124/22
131/15 133/11 155/13}
178/10 179/11 179/23
180/1 180/11
businesses [5] 76/3
88/11 117/24 166/21
167/2
busy [1] 91/21
but [173] 2/19 9/11
10/20 14/23 15/12
16/1 18/5 19/20 22/13)
22/15 23/5 25/11
26/22 28/3 28/22 29/7I
29/9 29/10 30/21 32/8I
33/9 33/11 36/4 38/3
38/17 39/16 41/1 43/2I
43/4 43/6 44/8 44/17
45/25 47/18 47/18
48/3 53/16 53/25 54/4
54/12 54/23 55/13
55/14 58/4 59/2 59/5
60/1 62/11 62/16 63/7I
63/15 63/17 63/25
64/10 64/20 64/24
65/4 65/25 67/14
67/25 68/16 74/17
74/19 75/15 75/19
76/15 77/14 78/19
79/23 80/9 80/18 81/1
81/15 81/23 81/25
83/4 83/11 83/17
85/13 85/16 86/5
94/25 96/25 97/16
97/22 99/1 100/9
103/16 104/23 105/4
105/18 106/1 106/9
106/19 107/11 107/14)
107/25 108/3 108/14
108/24 109/4 110/14
111/5 113/5 117/5
117/18 118/15 119/3
119/25 120/13 122/4
125/5 125/20 126/6
126/23 129/12 129/17)
130/11 130/25 137/21
138/12 138/20 139/14)
139/20 140/1 140/3
141/15 141/22 143/14)
143/18 144/7 144/8
144/14 145/7 145/10
145/11 146/18 147/10)
148/10 148/17 149/6
151/15 153/11 154/3
154/4 154/4 155/22
157/8 157/14 158/22
159/13 161/17 162/8
162/12 164/16 168/5
168/20 170/4 170/4
170/22 171/7 172/2
172/5 173/6 174/15
175/23 176/24 177/7
178/9 181/17 182/13
182/13 183/3
c
C6 [1] 132/4
cabinet [2] 160/12
176/9
Cabinet's [1] 160/18
call [24] 1/22 2/4 2/3
10/19 10/22 28/7
34/15 44/6 60/11
60/13 60/15 60/18
78/22 86/15 100/21
(62) being... - call
Cc
call... [9] 146/2 146/4
146/6 149/25 150/7
150/11 153/1 153/6
17219
Callard [1] 10/15
called [3] 35/22 36/3
183/7
calls [1] 83/22
came [9] 5/23 50/15
65/8 70/2 93/10
109/18 109/19 144/9
149/15
Cameron [4] 73/23
146/4 150/1 153/7
campaign [2] 84/14
84/14
campaigning [1]
83/13
campaigns [2]
114/23 115/3
can [156] 1/3 1/5
1/15 2/5 2/6 6/11 6/11
8/16 11/7 11/22 17/3
17/21 18/16 18/24
19/14 19/19 20/11
20/19 21/11 23/11
23/19 26/11 27/6
27/24 28/3 28/22 29/1
29/19 32/5 32/5 34/9
34/9 39/1 40/9 41/7
44/3 44/12 47/15
48/18 50/12 50/19
50/19 52/11 52/14
52/16 53/22 53/22
54/3 54/6 56/16 57/16
58/7 60/21 61/8 61/16
62/1 62/12 63/13 64/4
64/17 65/1 68/25
70/19 71/9 76/20
76/25 77/15 78/1 78/3
78/7 78/7 78/9 78/10
78/16 78/16 78/17
79/1 80/9 80/11 80/12
80/14 80/16 81/21
82/24 84/3 84/24
86/13 86/14 86/18
91/14 93/18 94/23
95/18 96/22 96/24
97/16 98/9 98/23 99/3,
99/4 99/8 102/23
112/13 114/5 114/7
122/1 122/11 123/18
123/19 123/20 124/1
126/9 126/15 127/5
129/23 130/14 132/4
132/22 133/13 133/15}
133/17 133/17 134/23)
139/14 140/7 140/8
141/11 142/19 143/15
144/16 145/18 148/11
154/9 154/11 155/2
157/6 157/9 161/22
163/15 163/19 164/7
167/10 167/11 170/12)
170/14 172/25 175/3
176/3 177/12 177/20
177/20 177/21 177/22!
181/6 182/12 182/13
can't [29] 11/4 11/4
47/20 47/22 61/11
63/17 70/22 94/24
102/7 102/8 110/12
118/23 122/23 134/22)
135/21 138/14 139/16)
141/17 150/10 153/20)
158/22 160/16 160/17)
1721/6 174/4 175/3
1841/3 182/11 182/14
capital [1] 132/9
capitals [1] 132/6
capture [1] 46/24
captured [1] 47/2
career [2] 3/1 87/18
careful [1] 58/11
carefully [1] 70/16
Carl [1] 139/3
carried [6] 9/2 34/6
35/3 37/2 38/22 59/14
carry [1] 76/6
carrying [2] 28/13
69/20
case [33] 8/4 12/7
13/8 15/22 15/25
39/18 44/2 45/13 46/5)
50/21 51/2 53/5 55/14)
56/22 63/8 64/25
65/22 76/13 84/17
93/25 94/2 99/3 99/17
99/19 114/20 114/22
124/9 126/23 135/13
138/9 149/19 151/2
174/14
case’ [1] 98/16
cases [5] 44/6
115/16 115/18 117/25)
173/20
cash [3] 115/15
115/15 165/8
category [1] 90/3
cause [8] 115/4
116/12 116/19 117/13}
125/9 127/12 137/17
143/20
caused [5] 115/14
115/24 121/9 162/4
164/25
causing [3] 85/5
115/20 121/4
caution [3] 81/24
165/16 168/18
caveat [2] 76/9
158/19
Cavender [1] 54/14
cc [1] 34/12
CCRC [2] 44/5 44/14
cell [1] 132/3
cells [1] 131/24
cent [3] 53/14 53/15
72/12
CEO [6] 3/3 3/3 3/8
30/5 82/19 101/5
certain [9] 21/1 54/1
54/2 54/3 85/16 87/14
155/14 174/16 175/13
certainly [8] 8/2 38/8
48/13 54/4 74/19
75/11 83/23 133/9
cetera [3] 62/20
69/15 164/13
Chair [9] 74/14 101/4
142/23 160/9 177/2
179/3 180/2 181/9
182/21
Chair's [3] 9/2 9/6
9/7
chairman [21] 8/20
8/22 8/23 10/2 24/18
25/16 25/17 25/19
25/22 30/9 36/2 36/15
37/17 38/4 52/9 64/7
64/23 73/11 74/21
150/1 158/7
Chairman's [12] 9/14
30/3 30/20 30/22 31/3
31/14 31/16 35/4 35/5)
35/6 35/7 39/5
chairs [2] 179/21
179/22
challenge [7] 51/9
109/4 109/11 127/3
143/9 174/10 174/22
challenged [4]
109/21 110/5 110/7
110/13
challenges [4] 71/21
144/12 171/20 174/11
challenging [4] 14/3
109/10 155/5 174/21
chance [1] 53/13
change [15] 2/2
12/18 12/23 14/8
46/19 46/20 46/23
74/20 110/19 146/10
153/8 155/6 158/8
171/22 176/25
changed [8] 12/13
12/21 45/14 46/25
47/5 52/1 65/18 173/3
changes [7] 13/9
47/3 75/1 155/7
155/11 155/20 158/2
changing [2] 109/12
171/16
characterisation [3]
143/14 147/9 183/17
characterised [1]
144/3
characterises [1]
130/13
charge [5] 17/23
17/24 32/22 33/1 33/3
chase [1] 137/15
chasing [1] 170/9
chat [1] 139/1
check [2] 76/18
159/3
checked [1] 100/19
checking [1] 40/4
Chief [5] 18/1 18/3
73/14 84/7 89/2
China [1] 3/3
Chisholm [3] 94/3
148/1 154/1
choose [2] 155/18
158/1
choosing [2] 71/1
71/2
churn [3] 171/8
171/9 172/1
CI [1] 54/21
ClO [1] 5/21
circulated [3] 31/25
58/3 60/4
circumstances [4]
63/13 76/8 82/7
175/14
civil [12] 15/11 15/14
89/14 89/18 92/24
132/23 132/25 133/8
133/13 134/3 134/19
168/16
claim [13] 15/14
24/10 46/11 46/22
50/8 55/12 92/24
106/24 111/20 115/19
127/12 131/2 164/4
claimants [16] 24/10
27/13 45/11 49/12
49/20 49/23 50/2
50/10 50/16 50/24
57/3 81/16 115/6
115/7 124/4 164/24
claimants’ [1] 45/16
claimed [2] 115/13
121/4
claiming [1] 83/21
claims [7] 27/12
49/13 55/17 128/22
130/17 130/24 133/7
claims’ [1] 107/7
clarification [1]
136/15
clarify [4] 17/3 29/1
42/19 98/20
clarifying [1] 24/22
clarity [3] 32/9 35/6
35/22
Clarke [5] 93/13
93/15 93/20 94/24
136/12
Clarke's [2] 21/12
137/20
class [1] 24/11
classic [1] 156/24
clauses [4] 59/25
106/19 126/1 165/17
clear [20] 17/21
24/17 25/15 28/22
30/4 47/4 52/20 64/10
65/12 96/23 109/6
110/23 128/12 141/5
152/10 153/17 153/18
154/5 181/23 183/6
clearly [2] 142/1
142/2
click [2] 131/24
131/25
clients [2] 77/9 84/15
close [1] 72/19
closed [1] 94/20
closely [1] 84/3
closer [1] 72/6
coding [1] 123/21
coffee [1] 10/17
cogent [1] 165/4
cold [4] 49/18
colleagues [10] 5/22
19/11 41/23 62/5
66/16 72/25 146/12
147/14 176/14 177/21
collected [1] 94/16
collection [1] 68/1
collective [3] 49/12
160/12 176/9
colour [1] 123/21
colour-coding [1]
123/21
column [12] 123/23
124/2 124/7 124/8
124/13 124/20 132/24I
133/5 133/13 133/18
134/1 134/8
come [24] 1/23 2/5
14/23 19/19 27/6 32/5)
34/9 40/2 40/13 44/3
52/11 71/9 107/18
107/19 126/9 130/14
134/23 137/24 142/19)
143/18 154/9 158/24
162/9 170/1
comfort [1] 122/8
comfortable [4]
40/19 67/22 70/8
70/10
coming [12] 28/5
86/23 90/25 110/11
111/9 140/15 142/9
145/17 147/13 161/19)
175/6 176/13
commenced [1]
30/22
commencement [1]
17/13
comment [14] 16/13
17/1 22/2 29/5 53/7
67/21 74/18 81/7
107/1 109/9 129/25
134/18 146/17 180/25]
(53) call... - comment
Cc
commented [1] 21/7
commenting [2]
67/22 81/15
comments [13]
12/17 15/19 19/8 26/2)
26/6 30/12 31/6 51/11
53/9 73/25 95/12
102/12 104/6
commercial [2]
178/9 180/11
commissioned [11]
20/24 28/9 30/5 33/5
37/8 38/4 40/22 41/17
42/21 43/9 44/8
commitment [3] 3/13
418 4/12
commitments [3]
4/13 179/12 179/14
committee [8] 14/1
26/17 47/15 56/13
57/7 57/13 57/22
74/14
common [38] 10/6
12/11 12/14 12/16
12/22 12/24 13/8
13/15 13/18 23/12
46/13 52/2 52/13
52/24 54/17 54/21
58/10 60/7 60/9 61/1
61/9 65/9 76/12 92/6
101/18 123/23 124/4
124/15 124/21 140/9
140/16 140/23 141/9
145/17 146/8 160/6
164/21 165/11
Commons [3] 89/2
139/24 146/13
comms [1] 55/20
communicate [1]
71123
communication [7]
71/25 72/4 72/15
82/21 138/20 144/3
ATTNT
communications [8]
79/25 82/18 82/25
83/5 84/8 85/9 85/14
114/12
communicator [1]
73/16
communities [2]
88/24 109/8
community [1] 179/9
companies [1] 6/2
company [14] 8/2 8/2
8/4 11/21 15/8 15/12
15/13 17/14 27/1
75/14 82/21 127/24
169/11 172/24
company's [1] 11/20
compared [2] 132/7
160/6
compensated [1]
154/23
compensation [2]
7/5 133/7
competent [2] 74/15
90/19
complainants’ [1]
34/4
complained [2] 33/21
139/7
complaint [1] 175/11
complaints [3] 33/20
34/22 35/13
complete [6] 40/20
40/23 41/14 41/14
41/22 149/7
completely [4] 14/15
14/19 53/20 173/3
complex [1] 76/1
complication [1]
75/21
complied [1] 22/10
comply [1] 23/3
composition [1] 74/6
comprehensive [1]
17/14
comprehensively [1]
33/21
computer [2] 54/19
120/11
computers [2]
120/11 120/22
concern [28] 79/20
101/14 102/4 110/2
1412/5 117/13 117/16
125/9 125/21 126/2
126/4 126/6 126/10
126/11 127/9 128/24
136/1 138/8 143/20
146/10 152/3 152/3
152/4 162/4 164/21
165/24 172/3 176/5
concerned [21]
88/17 90/7 103/14
104/15 113/11 125/11
125/14 125/15 125/16)
125/24 126/12 126/21
131/2 141/15 149/17
151/7 157/12 160/20
176/20 176/20 181/5
concerning [3] 10/9
117/5 156/25
concerns [24] 8/23
23/12 23/16 23/24
26/8 105/11 105/11
128/17 144/19 144/22)
146/6 147/23 151/23
152/17 156/3 176/11
176/12 177/8 177/17
177/21 177/23 178/15)
181/14 181/15
concluded [2] 56/23
118/13
conclusion [1]
154/21
Conclusions [1] 22/4
concrete [1] 127/20
conduct [5] 9/7 15/11
35/8 51/2 181/20
conducted [2] 26/19
36/2
conducting [1] 165/7
conduit [1] 8/20
conference [4] 10/19
10/22 45/8 50/22
confidence [7] 53/4
59/8 72/2 106/24
122/8 156/9 168/13
confident [9] 20/4
20/6 20/11 52/20 91/8
118/3 125/20 126/13
126/16
confidential [1] 98/5
confidentiality [1]
30/16
confirm [1] 86/18
confirmed [4] 34/17
70/10 100/25 109/3
conflict [3] 64/23
64/24 152/10
confused [1] 139/19
connect [1] 69/21
connected [1] 72/12
connection [1] 161/2
conscious [3] 179/8
179/14 181/6
consequence [5]
35/1 35/17 36/12
135/21 137/6
consequences [3]
116/6 116/15 172/16
consider [7] 12/1
15/4 16/11 38/15
119/19 127/25 147/6
considerable [2]
101/8 101/17
consideration [2]
33/18 52/20
considered [6] 12/24
16/21 54/1 54/2
134/19 152/18
considering [2] 6/16
74/22
considers [1] 74/24
consistently [2]
52/18 53/17
conspired [1] 84/1
constantly [2] 171/16
171/17
constituency [2]
70/18 100/11
constitute [1] 54/22
constructively [1]
51/4
consultation [1]
69/15
consulting [1] 82/3
consumers [1] 88/11
contact [4] 138/17
144/6 144/16 153/11
contacted [1] 152/23
contained [1] 99/24
contains [1] 99/13
content [1] 83/23
contentious [1]
55/25
contents [3] 2/12
40/22 114/8
context [5] 50/12
102/13 108/18 145/12)
160/13
contingency [12]
52/13 56/20 57/16
101/11 101/21 112/7
112/10 112/19 112/24}
114/1 114/11 123/17
continue [4] 31/8
76/25 131/18 134/4
continued [1] 180/5
continues [3] 22/17
109/6 133/10
continuously [1]
141/24
contract [4] 54/18
55/14 57/3 106/19
contracts [6] 54/25
55/4 55/5 115/19
116/5 165/18
contractual [4] 4/8
59/25 119/24 156/25
contrary [4] 148/5
148/6 149/3 165/5
contrast [1] 65/9
contributing [1]
134/16
control [1] 155/8
convenient [3]
122/25 180/15 180/23}
conversation [18]
10/7 36/24 37/1 37/5
37/6 37/13 38/3 38/6
38/11 38/13 60/16
60/22 61/3 79/15 81/4
130/12 148/12 160/11
conversations [6]
52/7 60/25 69/12
69/16 69/19 113/2
conversely [1] 57/10
convicted [3] 77/8
93/5 175/23
conviction [3] 16/20
32/23 32/24
convictions [7] 16/18}
16/22 16/24 17/4 17/6}
77/9 175/24
convincing [1] 65/21
Cooper [38] 2/3
10/14 10/16 10/16
29/6 34/10 36/9 36/18
36/24 37/6 37/13
37/14 37/25 38/11
39/3 39/20 40/17
42/11 43/11 44/6 64/2
64/4 64/9 64/25 70/7
78/19 79/16 80/6
81/20 135/3 143/2
143/6 143/10 151/16
152/15 176/6 176/11
181/15
Cooper's [7] 1/22
42/6 64/14 80/17
80/25 144/4 144/5
cooperation [1] 59/3
cooperatively [1]
51/3
copied [6] 78/19
80/10 80/17 80/19
85/12 149/23
copies [2] 21/1 83/2
copy [6] 39/10 39/12
80/14 86/25 87/4
94/14
core [5] 76/18 159/7
169/4 169/7 175/11
corporate [3] 74/22
75/1 88/11
corporation [2]
125/14 166/22
correct [40] 2/3 2/24
3/2 3/7 3/10 3/21 4/11
6/4 7/21 9/4 19/18
19/24 20/3 28/21
38/24 41/13 44/25
49/1 50/11 51/25
63/12 77/24 87/23
88/1 88/3 88/6 88/13
88/18 89/1 89/8 90/2
90/11 91/23 94/5
151/21 152/5 154/1
155/21 159/19 178/24I
correction [3] 1/19
1/25 2/11
correctly [11] 6/7
15/22 16/1 18/8 26/20)
41/5 89/17 113/23
153/16 154/1 170/18
correspondence [2]
90/10 179/20
cost [2] 127/23
133/11
could [89] 1/10 1/20
4/25 14/25 17/11
23/21 24/2 29/19
32/13 32/23 33/22
40/2 40/11 42/5 44/3
45/1 46/12 46/20 47/2
47/10 52/24 53/23
54/23 55/23 57/25
60/19 68/22 75/12
79/23 85/6 86/4 87/3
90/13 92/12 93/10
99/7 101/8 102/11
105/23 107/21 107/23)
113/24 118/16 119/6
119/14 120/6 120/21
121/9 123/13 124/6
(64) commented - could
Cc
could... [39] 127/6
127/17 127/23 127/25)
128/23 129/4 129/13
129/20 130/5 130/24
131/1 131/3 131/8
131/18 131/21 134/25}
138/21 142/24 145/6
148/21 149/18 149/21
152/12 154/20 155/14}
157/5 157/14 159/2
162/8 167/14 168/22
169/23 172/17 174/25}
176/18 177/1 179/2
179/3 183/8
couldn't [7] 129/6
129/12 129/17 129/18}
141/1 141/1 151/1
Council [1] 87/24
counsel [14] 32/21
82/19 84/7 94/10
98/14 99/15 100/1
100/16 101/4 106/18
134/5 134/12 165/10
170/24
Counsel's [2] 58/9
58/12
country [1] 166/18
country’ [1] 109/8
couple [2] 14/24
159/7
course [13] 1/23
33/10 78/6 87/12
109/12 116/13 116/15
117/4 117/15 140/10
141/18 178/25 183/9
court [10] 22/11
45/19 51/6 59/23 79/1
79/5 83/14 84/17
119/23 132/25
courts [1] 133/8
cover [5] 14/22 83/9
86/6 98/21 130/4
coverage [7] 81/2
81/13 81/24 83/6 83/8
83/16 136/20
covered [1] 83/21
covering [1] 91/20
Covid [4] 9/9 9/11
9/25 69/5
Covid-19 [1] 69/5
create [1] 11/22
created [1] 26/13
credibility [4] 62/17
70/17 70/20 73/7
criminal [6] 7/5 18/23
32/14 32/16 32/21
133/8
crisis [1] 127/13
critical [2] 51/2 66/3
criticising [3] 150/6
150/14 150/21
criticism [3] 51/5
65/14 66/5
criticisms [2] 51/23
71/16
culmination [1]
114/22
culture [5] 71/15
72/23 73/4 73/9 75/11
current [6] 12/2
58/14 79/9 113/19
116/18 133/18
currently [1] 175/15
curtail [1] 81/17
curtains [1] 167/14
Customer [1] 14/6
customers [1] 5/16
D
damning [1] 149/9
data [11] 16/18 45/12
46/20 46/22 46/23
46/25 47/1 47/3 47/4
47/10 121/23
date [16] 10/24 11/4
11/5 22/25 23/18
38/12 46/3 48/1 57/17
87/18 97/14 99/8
140/22 141/12 141/16)
150/8
dated [11] 17/10
29/17 32/7 39/8 87/3
93/12 96/3 131/22
136/11 138/23 149/23)
dates [1] 47/18
dating [1] 21/1
David [1] 54/14
Davies [2] 84/4 84/6
Davies’ [1] 83/1
day [26] 3/16 14/9
14/9 15/8 15/8 26/24
26/24 43/2 43/2 52/25
52/25 59/22 59/22
64/9 80/3 80/3 82/20
82/20 82/23 82/23
84/10 84/10 92/7
135/5 146/2 184/13
days [8] 3/15 4/9
75/7 76/5 76/8 76/11
132/18 150/8
de [3] 45/6 54/14
79/14
de Garr [2] 45/6
54/14
deal [4] 74/8 141/14
142/25 148/20
dealing [7] 4/22 6/17
7/9 73/14 101/11
101/21 165/17
dealings [2] 107/8
137/22
deals [1] 159/13
dealt [2] 42/2 90/8
Dear [2] 146/12
147/14
debate [2] 61/17
100/21
debates [1] 81/14
debating [1] 38/23
December [6] 17/10
23/7 23/20 45/24
47/21 140/12
decent [1] 91/14
decide [3] 5/4 18/25
153/3
decided [3] 32/18
124/4 153/11
deciding [3] 5/15
51/1 67/2
decision [27] 32/22
34/20 35/12 50/22
61/9 64/14 64/19 91/9
104/17 147/13 148/22
151/13 151/17 151/25}
152/25 153/12 153/14
153/24 157/13 161/15}
172/20 172/21 177/4
177/4 182/4 182/6
182/18
decision-making [1]
35/12
decisions [12] 6/23
27/16 27/18 90/18
117/8 152/11 156/11
160/25 171/18 172/2
172/16 172/18
declare [1] 128/22
deemed [1] 34/18
deeply [2] 84/16
179/8
defects [3] 15/5 15/7
33/15
defence [2] 22/11
106/24
defend [2] 81/1
133/11
defended [1] 160/14
defensible [1] 157/3
defined [1] 124/5
definitely [10] 44/17
121/14 125/18 149/17]
154/5 156/5 157/17
160/17 180/22 182/15}
definition [2] 16/4
16/14
delay [1] 149/18
delineate [1] 28/12
deliver [1] 11/15
delivered [1] 24/6
delivering [1] 146/24
delivery [2] 14/3
156/18
Deloitte [25] 40/21
41/1 41/3 41/8 41/10
41/12 41/16 42/2
42/17 44/7 44/15
44/22 45/16 46/6
47/13 47/16 48/7
48/10 48/11 48/16
TTIAT 77120 78/2
79/15 81/5
Deloitte's [1] 46/7
demand [1] 172/12
demanded [1] 81/22
demanding [1]
141/11
demands [1] 174/16
denied [1] 93/4
dense [1] 167/11
department [25] 5/5
18/10 88/8 88/20 89/5)
89/12 100/10 108/14
109/10 109/14 109/16}
110/5 110/8 130/5
142/13 144/7 144/8
144/23 148/14 151/12
158/10 161/3 161/5
162/6 164/13
Department's [3]
89/20 148/24 151/4
depended [1] 53/24
depending [1]
149/13
deployed [1] 83/7
depth [1] 106/3
Deputy [2] 3/8 89/2
derived [3] 96/6
103/20 104/2
describe [4] 16/4
69/9 110/4 146/8
described [6] 33/4
36/21 112/2 116/11
120/6 158/14
description [1] 94/17
desk [1] 86/25
despite [2] 81/16
149/2
detail [22] 24/13
24/18 25/16 25/18
25/21 25/23 42/6 75/6)
78/11 83/4 83/9
104/15 106/21 107/4
107/23 113/25 114/14}
116/25 125/23 141/25}
142/1 142/7
detailed [8] 14/7 25/9)
25/9 26/6 73/19
111/12 135/10 184/3
detailing [1] 124/14
details [8] 6/25 7/1
7/2 70/1 78/13 107/14,
124/21 150/10
detected [1] 108/2
determination [1]
142/6
determine [4] 8/1
11/20 13/4 33/20
determined [4] 15/17
15/20 36/19 158/7
detriment [1] 165/1
developed [2] 66/2
4117/1
developing [2] 11/12
118/7
development [1]
84/5
developments [2]
109/5 136/22
DHL [1] 3/6
dial [2] 78/11 78/13
dial-in [1] 78/13
diary [4] 90/8 100/19
100/25 101/41
did [129] 3/5 3/16
3/22 4/5 4/7 4/12 4/15]
5/7 6/3 7/10 7/23 8/1
9/19 10/11 10/25 11/2!
13/19 13/24 14/2
14/10 16/10 17/17
18/6 18/10 18/12 19/7I
21/15 21/17 21/20
21/24 23/24 24/1
24/18 25/15 25/16
27/8 28/8 28/17 28/24
32/9 32/10 36/3 37/14I
38/1 38/17 39/14
41/19 43/17 51/22
52/5 52/22 55/24 62/2I
64/14 64/18 65/15
66/10 67/10 67/12
67/12 67/19 72/9
73/23 74/7 80/19 84/4I
96/10 96/12 97/14
97/24 97/25 98/18
98/24 100/2 100/19
102/5 102/7 104/2
104/9 107/11 107/14
107/18 108/6 110/18
111/19 113/14 114/16
116/11 116/19 117/9
117/13 117/21 118/19)
119/19 119/25 120/3
121/2 121/7 121/25
125/1 125/9 128/19
130/14 135/15 135/16
135/22 135/24 136/4
140/22 143/10 148/9
150/13 150/15 153/23)
156/14 156/15 157/10}
158/1 158/17 164/3
171/1 173/25 176/11
177/1 177/13 180/15
181/16 181/20 183/2
didn't [54] 10/4 16/15
17/6 18/13 19/25
21/25 22/1 26/8 28/19
29/13 37/11 38/8 41/7
43/19 44/23 53/20
77/21 80/20 85/11
91/3 100/12 100/23
103/5 104/4 113/6
4117/1 117/5 117/6
4117/7 117/7 118/21
118/24 119/3 121/12
121/12 122/9 122/19
127/2 140/3 140/3
140/12 142/5 143/25
144/2 145/14 152/2
(85) could... - didn't
D
didn't... [8] 154/5
157/14 158/8 158/22
176/24 177/9 180/16
181/21
die [1] 172/19
different [18] 16/6
28/6 30/14 31/5 48/18
52/12 63/1 83/10 85/1
91/10 92/8 120/24
123/22 126/1 132/7
133/19 160/4 172/4
differently [2] 54/24
122/23
difficult [8] 9/12 53/7
54/13 63/18 66/14
107/11 131/23 171/15}
difficulties [2] 121/5
142/23
diligence [1] 75/17
diligent [4] 131/7
direct [7] 37/5 138/17I
138/20 148/11 161/15
175/13 178/17
directing [4] 142/12
155/14 157/17 159/23
direction [6] 11/20
160/22 172/11 175/15}
181/14 183/12
directly [11] 108/3
110/13 129/2 134/5
138/9 138/13 148/10
148/18 148/18 151/12)
161/5
director [26] 2/21
3/19 4/2 4/9 5/8 5/18
6/9 7/17 7/19 7/23
8/17 9/17 9/21 11/9
11/12 17/5 19/23
30/17 34/17 49/5 68/6
82/18 84/21 85/15
129/11 139/3
Director's [1] 14/2
Directors [10] 8/18
8/21 8/24 13/24 14/10
18/21 69/13 70/10
70/14 74/23
disaffected [1]
114/23
disagree [4] 31/17
64/17 151/5 152/6
disagreed [2] 59/24
64/19
disappointed [1]
152/6
disappointing [2]
51/8 51/17
discharged [1]
179/12
discipline [1] 141/11
disciplined [2]
141/16 141/23
disclosable [1] 128/8
disclose [1] 22/14
disclosed [3] 39/22
43/11 94/17
disclosure [4] 94/8
98/3 134/6 134/11
discourage [1] 148/1
discouraged [1]
182/7
discovery [1] 35/4
discuss [5] 10/25
19/25 23/24 52/8
112/22
discussed [17] 11/3
30/4 30/15 46/1 57/7
60/24 77/17 78/3 95/9)
96/20 105/6 128/25
139/8 150/7 160/17
160/19 170/5
discussing [2] 56/2
105/15
discussion [19]
27/23 46/14 49/9
50/15 51/21 52/9
61/13 62/15 63/3 63/6
63/6 70/19 70/22
79/14 99/19 150/3
151/21 152/16 153/10)
discussions [2]
61/11 148/9
dispute [4] 38/20
102/22 103/1 167/6
disrupting [1] 155/12
dissenting [1] 64/13
distinguish [1] 47/2
distinguishable [1]
121/20
distinguished [1]
8/16
distraction [1]
133/11
distress [1] 115/22
distribution [2] 34/11
94/20
divorce [1] 115/21
do [119] 1/13 1/14
2/7 2/8 5/16 5/19 5/21
6/12 6/14 7/7 10/22
11/3 12/11 13/12
14/23 17/4 18/25
20/14 22/9 23/2 23/8
23/15 24/15 25/24
30/20 30/23 31/12
31/17 31/21 32/3 32/4
33/7 39/14 39/15
40/18 40/19 41/15
45/19 46/2 46/9 46/12
47/10 47/11 48/6 49/3
52/5 52/22 53/4 55/13)
55/21 55/23 55/24
56/2 56/4 57/17 57/18
57/21 59/19 60/24
65/7 69/16 70/23 71/5)
74/4 74/24 75/17 76/5)
78/5 78/10 78/14
78/15 87/1 87/2 87/4
87/6 97/22 97/23 98/6
98/8 102/17 104/22
105/15 105/25 106/20}
107/3 107/6 109/9
112/11 112/12 121/19]
122/13 122/15 129/1
129/3 129/22 130/11
136/2 147/6 148/12
152/24 158/21 159/2
161/21 166/5 166/25
167/2 167/21 169/12
171/21 171/21 171/22
171/25 174/17 175/1
175/13 177/3 177/7
177/20 181/18
document [53] 19/19
21/11 21/18 21/21
29/7 29/9 31/4 35/23
37/4 37/4 37/7 39/2
39/25 44/3 47/22 49/4
49/6 56/8 57/19 57/20
57/21 57/24 57/25
58/1 58/5 58/9 60/1
60/3 77/13 78/6 85/9
85/12 104/20 104/22
105/1 105/3 119/8
123/14 123/18 124/12
126/9 129/24 130/14
134/23 135/1 142/19
152/13 154/9 155/2
161/21 165/14 176/3
178/3
documentation [1]
21/9
documents [28]
20/18 21/5 21/14
26/22 28/1 28/3 28/11
31/24 39/15 41/10
54/22 93/7 93/9 96/6
97/11 97/22 98/1
100/3 102/14 103/21
104/2 108/5 112/11
112/12 132/17 151/9
168/1 168/3
dodgy' [1] 83/22
does [9] 5/16 22/5
34/18 35/3 35/10 49/2
80/14 154/24 168/23
doesn't [8] 29/10
47/8 79/9 95/22
167/19 167/19 181/3
181/12
doing [7] 72/16 83/7
116/14 117/10 150/24
158/8 181/19
don't [110] 4/4 4/16
6/12 9/10 9/14 9/22
10/11 10/18 10/20
10/24 11/6 18/4 19/20}
20/16 22/12 22/24
22/25 23/5 23/18
23/22 24/3 25/7 25/11
28/1 29/6 29/8 29/11
30/25 32/14 33/15
35/22 35/23 37/3 38/3)
38/7 39/23 41/6 43/3
43/4 47/14 49/25 50/6)
52/6 52/6 54/3 55/11
57/20 57/23 58/5 60/2,
60/23 61/4 61/13 63/3)
63/5 63/11 63/25 64/8
64/12 69/25 71/8
81/14 82/5 85/18 97/7,
98/25 99/1 100/5
100/7 110/7 125/3
125/4 126/18 132/17
132/21 133/25 137/3
139/16 140/1 141/22
145/3 148/11 148/18
150/2 150/17 150/17
151/5 151/19 153/14
153/15 153/20 153/21
156/5 157/18 158/5
158/6 160/16 168/7
168/15 169/1 173/23
174/13 177/6 177/6
177/7 180/21 181/24
181/25 182/5 182/8
done [13] 9/15 26/10
33/25 56/14 105/12
4111/1 114/18 117/16
118/16 122/23 122/23}
175/4 183/8
down [49] 1/25 2/5
10/6 11/16 12/11
19/19 22/12 25/18
27/6 29/20 30/11 32/5
32/13 34/9 44/3 45/4
45/7 46/10 50/20
52/11 54/15 54/20
58/25 68/24 71/9
74/10 78/9 81/9 81/19)
83/19 93/13 95/3
100/14 106/15 109/8
120/18 124/1 126/9
129/25 130/2 130/14
133/21 134/23 142/19}
146/8 147/24 152/13
154/9 166/18
down’ [1] 118/12
dozen [1] 70/2
Dr [2] 22/7 22/14
Dr Jenkins [1] 22/14
Dr Jennings [1] 22/7
draft [4] 29/23 57/16
94/15 129/22
drafted [1] 105/1
drafting [2] 54/25
147/14
dramatic [1] 62/4
draw [2] 125/25
149/19
drawn [1] 101/2
drive [1] 83/15
driven [2] 16/13 26/6
dropped [1] 33/1
due [3] 66/21 75/17
87/12
during [16] 6/17
12/22 26/5 44/5 44/14
51/11 69/5 79/18
79/24 81/7 84/5 87/22)
107/9 140/10 141/18
165/20
duties [4] 22/10 23/3
23/5 105/25
duty [3] 22/16 27/1
55/7
E
each [4] 15/13 33/22
132/6 162/23
earlier [16] 39/2 42/1
44/11 44/24 48/9
68/13 74/9 76/4 77/22
78/23 85/2 85/10
169/8 169/16 174/12
181/24
early [9] 24/12 26/14
76/20 77/1 91/17
107/16 120/20 126/12)
161/14
ears [1] 8/25
ease [1] 99/20
easily [2] 47/2 132/8
easy [2] 149/5 149/5
economic [1] 165/1
Education [1] 89/6
effect [3] 150/16
150/18 175/13
effective [4] 74/1
74/2 104/11 143/9
effectively [3] 76/7
140/11 173/9
effectiveness [2] 9/8
75/11
eight [2] 12/15 20/12
either [10] 8/2 10/16
34/5 38/12 38/21
49/13 64/9 100/3
101/18 162/13
elected [3] 87/20
87/24 88/2
election [1] 89/7
element [2] 32/16
112/19
elements [1] 92/8
else [3] 23/25 26/7
100/8
email [38] 34/10
36/17 37/5 37/11
38/12 39/19 40/12
40/17 42/6 42/11 43/2
43/3 43/5 43/13 50/21
60/8 60/22 78/17 80/9)
80/10 80/21 85/13
85/15 93/11 94/21
94/25 96/4 98/21
98/22 98/23 135/1
135/4 136/11 137/20
138/22 138/23 149/22)
(56) didn't... - email
E
email... [1] 152/14
emails [1] 136/8
embarrassment [1]
145/21
Emma [2] 86/21
169/21
emotional [1] 115/22
employed [2] 66/16
134/3
employee [1] 121/22
employees [1] 163/4
empting [1] 97/1
encountering [1]
142/23
end [11] 6/8 11/10
49/16 53/8 123/18
132/9 158/8 159/4
163/6 171/20 176/24
endanger [1] 128/23
ended [3] 54/5 76/14
176/16
Energy [2] 88/9
89/12
enforced [1] 177/4
engage [3] 81/14
83/17 83/18
engaged [1] 84/16
engagement [5] 69/1
69/18 82/15 82/18
142/21
Engagement/Repres
entation [1] 69/1
engaging [2] 73/18
81/15
English [4] 56/9
enough [8] 38/15
105/12 130/4 139/7
140/12 143/23 171/1
183/3
enquiry [1] 80/25
ensure [4] 8/13 12/7
70/23 110/19
ensures [1] 109/5
ensuring [1] 154/22
entire [1] 92/1
entirely [1] 96/23
entirety [1] 169/11
entitled [1] 104/21
environment [1]
144/25
envisaged [1] 112/6
equally [1] 51/5
equate [1] 131/3
error [12] 34/24
35/15 36/10 36/20
37/16 37/19 37/21
38/16 38/19 48/13
48/14 119/15
errors [16] 33/15
A7I7 119/21 119/25
120/2 120/5 120/9
120/21 121/3 121/7
121/11 121/13 121/19)
122/3 122/7 122/9
escalate [3] 27/22
177/13 177/22
escalated [4] 27/4
27/4 27/25 80/3
especially [6] 46/25
54/25 55/4 55/6
117/16 174/8
essence [1] 38/5
essential [1] 167/17
essentially [8] 82/16
83/3 159/13 166/5
166/11 173/12 180/1
180/2
establish [1] 70/7
established [2] 90/4
98/3
establishing [2] 71/6
717
estimate [1] 128/7
et [3] 62/20 69/15
164/13
et cetera [3] 62/20
69/15 164/13
etc [1] 55/14
Europcar [7] 3/8 3/11
3/12 3/14 4/14 5/2
5/14
evaluated [1] 36/19
evaluating [2] 9/1 9/5
evaluation [1] 14/6
evaluations [1] 9/3
even [18] 45/18 56/8
107/16 120/5 120/23
128/12 129/18 133/2
137/18 144/10 149/13)
157/18 161/2 161/16
161/17 161/19 172/13)
182/3
event [1] 59/23
events [1] 33/10
ever [10] 16/11 29/8
54/3 108/2 109/21
110/5 132/15 133/23
138/13 181/2
every [1] 87/13
everybody [2] 140/17)
162/12
everything [2] 25/7
96/13
evidence [42] 2/15
TINT 19/15 19/25
24/22 25/4 26/12
28/19 31/1 36/9 36/13
36/14 41/11 44/21
47/21 50/24 61/11
62/19 77/19 79/2 79/3
79/4 83/21 85/25 86/7
87/11 89/16 103/22
118/14 119/12 127/2
144/5 144/7 148/6
163/6 165/4 166/20
169/16 173/8 178/14
181/25 182/17
evident [1] 64/24
evidential [1] 33/2
exact [5] 23/18 30/21
38/3 64/8 150/10
exactly [10] 5/4 9/10
16/3 22/24 39/16
69/21 104/23 158/5
158/6 158/22
examination [1]
118/12
example [12] 18/13
28/3 58/24 59/7 59/18
91/2 91/5 156/24
161/3 161/6 167/23
173/16
excellent [4] 5/21
72/14 101/12 112/3
Except [1] 21/2
exceptionally [1]
72/16
exchange [1] 78/4
excuse [5] 117/23
118/2 172/5 180/23
182/16
excuses [2] 122/24
174/13
exec [1] 12/4
Execs [1] 75/2
executive [66] 3/11
3/12 3/14 3/19 4/5
4/13 4/22 5/22 6/8
7/16 7/18 7/19 7/23
8/18 8/20 8/24 9/17
10/13 11/9 11/11
11/25 13/6 13/12
13/15 13/20 13/24
14/2 14/3 14/9 14/10
14/12 15/10 17/19
17/22 18/3 18/4 18/21
19/4 27/2 27/21 30/2
66/16 69/13 70/13
72/20 73/14 74/15
74/23 75/7 75/13 76/5)
76/9 76/11 80/3 82/4
82/8 84/7 84/20 85/4
114/9 114/19 131/22
132/12 132/15 150/14
156/16
executives [5] 11/19
13/3 41/24 73/8 129/9
exercise [6] 9/25
10/4 59/4 101/13
101/25 112/4
exhaustive [1] 58/16
exist [1] 175/15
existence [5] 33/22
40/21 41/3 99/24
124/6
existing [4] 16/25
64/7 155/5 155/16
exists [1] 79/4
expect [7] 15/15
53/21 65/15 90/19
125/3 125/5 128/11
expectation [2]
75/13 75/20
expected [7] 101/24
109/13 119/1 137/23
152/17 170/1 170/6
expecting [4] 139/14
139/16 139/21 140/2
experience [15] 4/19
4/22 4/25 5/2 5/7 5/20
6/5 6/16 7/8 8/6 63/21
91/4 134/24 168/2
168/16
experienced [4]
74/15 82/1 138/13
174/15
expert [9] 22/15
22/16 23/4 23/5 45/17)
120/10 120/22 130/23}
174/2
expertise [3] 7/13 8/6
TAIT
experts [1] 89/22
explain [12] 59/15
59/17 62/1 87/19
91/19 94/15 126/15
135/2 146/15 153/8
158/22 182/12
explained [4] 63/7
69/2 155/9 182/25
explains [3] 100/14
124/20 132/4
explanation [2] 44/18)
100/24
explore [1] 96/19
expose [1] 128/9
express [1] 150/4
expressed [1] 110/9
expressing [1] 64/5
expression [1] 118/2
extend [1] 69/14
extensive [2] 111/17
163/24
extent [6] 9/19 10/12
15/7 79/1 90/17
141/10
external [6] 18/6 82/2!
83/5 83/16 134/2
165/10
extra [2] 81/1 94/12
extremely [7] 6/19
9/12 51/8 56/9 61/3
74/14 79/6
extremis [1] 160/11
Eye [2] 83/20 83/23
eyes [1] 8/25
Fo
face [13] 9/15 9/15
10/1 10/1 17/19 17/19}
119/5 120/19 144/21
144/21 145/14 145/14}
180/17
faced [1] 13/22
faces [1] 132/6
fact [17] 24/23 26/14
38/20 50/15 50/17
57/9 68/9 79/4 91/8
91/21 98/2 100/18
125/13 136/24 172/23)
178/25 180/17
factor [1] 67/14
factors [4] 38/8 38/9
66/22 66/24
facts [2] 90/22 90/24
factual [2] 111/3
119/2
failed [4] 22/14 23/3
37/23 65/18
failing [2] 36/20
36/22
failure [2] 22/15
169/15
fair [8] 38/22 53/25
61/8 80/8 80/9 143/14)
159/25 177/23
fairly [2] 35/3 12/2
fairness [4] 31/9
67/19 67/21 125/2
fait [1] 55/4
faith [2] 55/7 55/12
false [4] 32/22 32/24
115/18 116/2
familiar [4] 164/16
166/16 178/6 178/11
far [16] 63/24 65/20
71/23 71/24 81/11
81/12 81/21 90/7
109/20 138/15 141/15}
148/10 151/21 156/19)
166/3 181/5
fashion [1] 141/17
fast [2] 27/14 27/18
faster [1] 71/23
fault [1] 169/20
favour [1] 124/4
favourable [2] 65/16
66/9
feared [1] 137/17
featured [1] 83/20
February [11] 33/8
39/6 45/3 46/1 46/3
47/23 77/16 77/25
78/12 84/12 88/10
February 2019 [1]
84/12
feed [1] 28/4
feedback [6] 57/25
70/4 71/20 72/15
73/17 145/15
feel [12] 40/19 67/22
75/11 91/7 107/14
108/6 109/9 110/18
417/21 140/22 171/1
173/25
feeling [12] 18/24
19/2 19/7 19/14 31/1
75/10 97/7 110/10
(67) email... - feeling
F
feeling... [4] 118/5
143/7 143/15 149/7
feelings [1] 110/15
feels [1] 173/11
fellow [3] 5/22 41/23
80/19
felt [18] 41/25 72/18
72/21 74/12 75/16
108/4 111/6 112/22
113/16 125/19 140/12)
140/24 141/6 141/24
145/24 147/9 154/7
182/17
few [6] 14/25 42/15
94/15 132/18 139/2
166/4
fight [1] 49/20
figure [7] 53/16
76/12 128/13 129/6
129/17 129/18 131/8
figures [3] 34/12
128/18 130/15
filed [1] 50/25
final [4] 61/20
finally [3] 31/23 76/4
158/24
finances [1] 131/6
financial [14] 11/13
18/2 75/23 101/7
101/16 105/14 106/10}
115/2 115/20 127/13
127/16 128/4 130/20
156/2
find [10] 5/7 17/1
19/8 25/8 66/1 67/21
93/17 93/24 107/11
119/24
finding [3] 39/9 40/23)
133/2
findings [7] 12/24
29/23 30/3 30/19
31/14 65/15 101/18
fine [10] 38/25 40/3
85/22 123/6 142/16
159/10 168/2 170/14
175/18 184/10
finish [1] 173/4
finished [4] 74/10
mly [1] 85/8
first [51] 2/25 10/15
19/12 20/18 21/8
21/20 22/21 22/22
23/16 23/22 27/10
28/8 32/11 33/8 46/11
64/6 74/17 78/18
82/25 84/3 88/14
89/19 93/9 94/22
95/20 96/3 96/15
102/15 105/7 107/16
108/21 109/3 112/16
116/23 122/25 129/25)
132/3 135/12 136/11
138/23 140/21 149/10)
158/15 159/20 167/7
168/7 169/4 169/23
171/1 172/14 176/3
firstly [8] 1/15 21/20
28/12 33/14 43/9
45/20 47/8 60/21
fit [1] 4/18
fits [2] 106/21 107/8
five [10] 3/15 3/16
18/8 70/1 76/23 95/21
95/22 106/5 106/14
123/22
flagged [1] 152/22
flagging [4] 99/23
101/15 101/24 106/9
flaws [3] 103/23
115/3 119/13
flicked [1] 167/9
flow [6] 98/4 134/24
139/8 140/1 140/4
143/25
focus [5] 12/3 12/9
13/11 14/17 94/8
focused [6] 11/21
14/9 14/18 73/12
127/13 182/20
focusing [1] 50/3
follow [13] 35/1
35/17 36/12 63/23
78/22 94/13 135/10
136/8 138/12 142/22
173/25 175/10 183/19)
follow-on [1] 135/10
follow-up [5] 35/1
35/17 36/12 78/22
175/10
followed [2] 88/23
128/5
following [15] 12/11
26/15 31/15 32/19
32/25 35/4 42/22
60/22 60/25 71/14
88/7 99/14 99/18
128/5 184/13
force [3] 49/11 49/23
50/2
Forcing [1] 155/11
forensic [1] 118/11
forge [1] 69/7
forgive [2] 96/25
133/17
form [3] 36/21
126/15 130/13
formal [3] 10/18
17/14 27/7
formalised [1] 143/4
formed [4] 107/17
108/10 108/12 109/17)
former [3] 43/20
43/22 115/10
formulated [2] 108/8
137/2
formulating [1] 117/1
forthcoming [1]
107/14
forward [15] 8/15
11/24 13/6 50/16
61/25 62/16 66/4
118/4 137/8 146/24
148/1 149/16 151/3
163/8 176/18
forwarded [1] 94/21
found [11] 22/24 23/2]
27/10 45/16 47/23
48/2 103/22 123/24
124/17 145/23 164/7
foundation [1]
167/17
four [6] 18/8 19/6
38/2 66/21 70/1
124/15
frame [1] 162/14
Franklin [1] 61/19
frankly [3] 11/4 138/4I
171/14
Fraser [11] 12/17
50/23 61/24 62/11
65/13 66/1 66/20 67/3,
67/6 67/19 71/16
Fraser's [2] 51/23
65/24
Freeths [1] 49/17
frequency [2] 28/4
171/8
frequently [2] 109/3
136/8
front [8] 1/12 86/25
91/15 96/13 97/5
119/1 127/4 168/5
fronted [2] 182/3
182/4
frustrated [5] 111/6
129/8 139/21 143/24
175/12
Frustratingly [1]
127/19
frustration [5] 96/14
110/15 129/7 152/11
161/10
frustrations [1]
110/9
Fujitsu [9] 40/24
45/12 45/14 45/22
46/18 46/19 46/21
47/4 47/10
Fujitsu's [2] 45/13
46/23
full [9] 1/10 3/14 24/6
31/25 32/1 51/18
86/18 94/24 132/1
fully [1] 181/4
function [2] 5/3
131/18
functioning [1]
131/10
fundamental [4]
119/13 155/6 155/20
170/11
fundamentally [2]
160/25 180/24
funded [2] 50/8
127/25
funder [4] 49/15
49/18 50/9 50/13
funders [1] 50/3
funding [1] 130/3
furnished [1] 160/23
further [39] 27/23
30/11 30/21 31/15
34/2 34/6 46/10 50/20)
58/25 60/13 78/9
78/17 81/7 81/9 83/19
97/6 99/18 99/25
100/14 104/19 104/20}
105/4 107/6 107/22
108/7 109/24 111/10
1417/7 117/18 120/20
120/25 130/2 134/8
136/15 149/18 155/11
159/8 161/15 175/8
fuss [4] 143/20
future [10] 11/20
11/23 12/12 13/4 13/5}
14/18 151/3 157/8
157/13 175/1
future-proof [1]
11/23
G
gain [2] 81/24 128/19
Gareth [6] 22/7 22/8
22/10 22/18 22/21
22/25
Garr [3] 45/6 54/14
79/14
gave [10] 39/20 45/7
45/8 63/14 67/23
72/14 122/8 127/2
143/19 176/17
GC [1] 150/3
general [19] 13/23
19/8 37/9 49/3 55/7
57/8 82/19 84/7
106/23 110/18 114/14}
119/18 125/24 126/10
135/25 136/2 140/7
176/9 177/25
generality [1] 13/19
generally [4] 15/5
110/21 110/23 173/7
generated [1] 16/19
generic [1] 33/23
genuine [3] 121/10
121/20 126/2
genuinely [5] 99/3
100/5 102/7 150/10
160/17
get [28] 19/7 46/21
49/9 49/19 50/10 68/5)
72/5 72/19 73/16 75/7
75/9 84/17 91/24
95/25 96/11 108/19
139/22 140/12 140/18)
162/9 164/16 167/25
171/15 173/23 174/19)
180/23 181/9 182/16
gets [1] 171/23
getting [12] 95/11
95/16 110/10 118/6
139/18 140/4 140/24
141/3 141/5 165/25
172/1 176/7
gift [2] 148/24 149/1
give [23] 23/19 26/4
27/24 28/3 41/7 49/24)
50/2 72/2 86/6 118/23
123/5 128/12 129/2
129/6 129/17 129/18
138/5 138/10 138/14
138/15 145/11 150/8
178/4
given [61] 4/13 33/18
37/4 38/17 48/9 53/3
54/9 61/22 61/22
62/23 63/1 63/9 65/11
65/20 67/15 68/1
68/18 90/19 90/20
91/6 91/16 92/1 92/7
97/6 99/2 100/24
102/17 102/18 103/4
103/10 104/1 104/10
118/8 119/2 119/4
120/15 120/24 125/17)
133/14 141/19 148/3
151/20 157/20 158/11
158/18 159/20 161/23}
165/6 165/13 165/23
167/8 167/12 172/1
173/6 173/8 173/16
174/4 174/5 174/18
177/11 178/14
gives [2] 54/16
181/11
giving [9] 18/17
63/20 85/25 91/12
108/2 111/2 128/6
1314/7 137/5
glad [1] 77/12
GLO [11] 24/13 26/13
60/18 61/1 69/5 73/15
78/11 79/18 79/24
82/11 84/5
global [1] 121/15
go [49] 8/22 11/16
22/12 22/12 23/20
29/19 32/13 33/15
4215 42/10 42/12 44/9)
45/7 50/19 51/13
52/12 54/15 55/16
55/19 56/19 58/24
58/25 59/5 63/15
71/20 77/13 77/14
81/21 93/18 104/14
123/16 124/23 127/6
127/18 132/11 132/22!
(68) feeling... - go
G
go... [13] 155/2
155/22 157/6 158/22
164/2 164/7 169/1
169/6 170/19 171/2
171/4 178/20 181/7
go-between [1] 8/22
goal [1] 179/16
goals [3] 179/22
180/1 180/8
goes [16] 30/11 34/1
35/14 45/18 47/6
49/15 57/12 69/9
70/13 78/17 81/19
83/9 84/13 95/12
164/23 172/5
going [56] 2/18 14/22
24/11 28/17 31/8 58/6
71/11 74/20 74/21
76/18 93/15 93/23
94/22 97/2 100/17
103/13 104/8 108/24
111/13 113/21 113/25
114/19 115/5 115/7
118/7 119/17 124/18
125/12 125/22 127/14}
128/24 134/25 140/21
143/4 146/3 146/10
151/3 152/12 154/2
157/24 159/4 159/5
159/8 161/17 161/22
162/9 163/12 163/16
164/5 168/8 168/11
168/18 174/11 174/15
177/15 178/3
gone [11] 7/14 73/3
81/11 106/3 116/17
143/6 143/10 169/8
170/23 176/6 176/12
good [24] 1/3 4/18
40/1 55/4 55/7 55/12
66/22 69/25 70/4
72/14 72/16 73/10
86/13 109/4 115/16
115/25 139/1 139/17
162/20 162/21 171/14}
172/21 173/17 184/4
got [21] 38/10 42/15
53/22 56/19 63/18
77/12 84/11 109/13
140/16 166/3 166/24
167/20 173/19 173/20
174/9 175/18 177/4
177/12 177/22 179/2
179/3
governance [3]
74/23 75/2 159/17
governed [1] 98/4
Government [47] 8/4
8/5 8/8 84/23 87/18
88/25 90/1 93/14
103/16 109/4 126/5
130/16 130/22 131/16
134/18 148/4 148/21
150/12 150/20 157/23)
159/20 160/3 160/8
160/12 163/16 163/17)
168/1 170/2 171/15
172/10 172/25 173/13}
173/22 178/2 178/17
179/1 179/14 179/15
179/25 180/14 180/16)
181/1 181/3 1841/8
181/10 182/22 182/23)
Government's [2]
75/13 159/22
Grabiner [4] 61/23
62/8 62/13 63/14
grading [1] 58/18
graphical [1] 132/5
grateful [4] 78/9 86/1
163/1 184/4
grave [1] 147/23
great [6] 52/23 60/19
74/12 83/9 106/3
131/14
greater [6] 45/18
83/4 90/17 125/23
141/11 175/16
greatest [1] 57/10
Griffiths [1] 134/9
grip [1] 171/23
grips [1] 167/25
ground [2] 67/7 81/6
grounds [1] 67/1
group [21] 3/8 5/2
7/9 7/11 7/14 10/10
11/1 24/2 26/12 27/10
30/2 45/2 48/20 48/21
48/21 48/22 83/12
83/17 96/16 115/6
163/3
grows [1] 162/24
guarantee [1] 135/22
guidance [2] 132/3
132/13
guide [1] 72/2
guiding [1] 6/19
guilty [1] 32/25
H
had [269]
hadn't [9] 54/1 60/2
98/25 103/10 129/11
130/11 137/21 161/11
182/7
half [3] 11/17 70/1
102/15
halfway [2] 129/25
152/13
Hall [2] 77/11 175/25
Hamilton [3] 77/10
84/16 175/25
hand [8] 10/6 12/11
123/22 124/2 124/7
124/8 124/20 142/11
hand-down [2] 10/6
12/11
handing [1] 146/8
handle [1] 5/20
handled [1] 51/24
handling [3] 34/22
35/13 94/6
hands [1] 159/22
hang [2] 161/20
168/23
happened [13] 12/25
13/14 14/20 19/5
19/16 26/5 53/21
53/23 76/13 111/4
143/19 167/19 182/6
happening [14]
27/17 27/21 75/3
108/13 111/21 112/14
112/21 113/6 140/23
141/13 141/22 142/3
176/21 177/18
happy [4] 76/25
110/22 148/4 160/24
hard [10] 17/1 46/24
57/23 58/4 61/4 67/21
73/6 75/6 75/9 86/25
harder [4] 25/8
147/11 155/16 158/3
hardest [1] 73/1
harm [2] 115/2
115/21
has [37] 7/17 12/1
22/10 25/25 29/18
34/17 37/2 37/7 40/25
51/9 55/10 59/10
76/13 81/12 81/20
83/20 83/21 84/1
90/21 95/14 95/25
99/18 99/21 133/1
133/14 152/17 152/23
152/24 152/25 162/4
162/15 164/11 165/11
169/8 176/4 176/8
179/20
hasn't [1] 41/18
have [361]
haven't [2] 26/22
139/19
having [37] 4/21 6/15
7/13 7/14 19/4 19/6
19/21 33/4 34/17
36/15 39/17 39/20
60/3 61/13 63/22 72/1
74/25 77/24 106/22
116/5 122/5 124/15
124/16 124/22 125/7
135/19 137/24 144/21
148/11 151/9 151/23
159/3 168/12 171/17
176/7 176/11 181/4
he [40] 29/7 29/7
34/18 34/18 35/10
35/14 36/6 38/1 38/13)
42/18 44/10 44/18
44/23 45/6 51/11
66/25 67/7 73/16
73/16 73/17 73/18
TINT 77/21 77/25
78/20 78/25 79/18
83/9 83/11 143/7
144/5 144/17 144/18
144/22 144/22 145/14}
151/16 151/19 151/20
183/14
he'd [3] 36/19 37/23
66/2
heading [4] 49/8
99/11 114/20 133/18
headquartered [1]
5/4
hear [7] 1/4 40/9 53/3)
55/25 77/12 86/13
177/15,
heard [6] 7/17 16/3
22/21 22/22 23/21
26/12
hearing [2] 1/6
184/13
hearings [1] 51/12
Hello [1] 123/11
help [11] 8/21 11/19
72/2 73/5 79/5 98/23
102/23 112/13 151/2
163/19 164/9
helpful [4] 6/19 57/14
69/13 105/24
helps [1] 154/12
hence [7] 53/19
141/23 144/2 153/18
167/7 177/8 180/24
Henderson [1]
175/25
her [9] 18/13 105/16
106/1 109/4 135/9
139/2 139/10 139/10
139/11
here [40] 13/18 18/17,
28/12 30/24 35/9 36/9)
37/5 37/10 43/2 43/5
46/4 63/4 63/4 66/19
76/13 79/16 79/23
80/6 82/9 85/13 90/15)
95/9 97/18 98/17
98/24 111/14 116/11
117/14 119/5 119/8
120/2 123/20 132/4
132/22 136/23 142/25}
156/12 165/13 166/24,
168/20
here's [1] 168/21
Hi [2] 95/4 135/8
high [12] 8/25 11/11
15/11 24/9 25/13 59/1
72/11 105/3 124/13
124/15 124/19 125/7
high-level [4] 15/11
24/9 25/13 105/3
highest [1] 106/20
highlighted [3] 99/21
100/2 181/22
him [10] 22/14 30/16
30/16 38/18 55/13
65/14 73/14 145/10
152/23 154/4
himself [6] 64/3 64/7
64/10 64/19 66/21
147/17
hindsight [7] 26/10
63/23 122/17 149/6
157/4 177/7 178/20
his [29] 22/10 22/15
22/16 23/3 28/24 29/1
29/23 30/10 32/7
34/23 38/17 45/9 51/9
63/17 64/16 64/19
64/20 65/14 65/15
66/5 73/18 73/20
74/17 80/19 143/7
143/12 143/14 144/7
152/22
historical [6] 14/16
20/13 66/17 69/4 73/2
73/6
historically [1] 13/11
history [2] 14/19
17117
hm [10] 102/2 154/16
163/11 166/7 170/21
177/16 177/24 178/12)
179/10 179/24
HMG [2] 109/5 109/6
HMG' [1] 128/1
hold [2] 81/6 94/16
holding [5] 18/24
19/3 19/15 31/2 83/6
holdings [1] 115/15
honest [2] 72/15
121/17
honestly [4] 47/25
90/20 102/8 122/19
HONOURABLE [2]
86/16 185/8
hope [2] 161/13
173/1
hoped [1] 144/24
hopefully [3] 1/3
107/7 140/5
Horizon [60] 10/9
11/1 13/5 14/13 14/15)
16/19 18/22 19/9 20/1
20/25 21/7 21/9 22/22I
33/14 34/22 35/13
45/8 47/1 59/14 65/3
65/5 65/7 65/10 65/16
65/18 65/25 66/7
66/11 66/18 66/23
67/16 68/7 68/9 68/14)
68/18 71/14 79/2 79/4I
83/22 92/17 93/2
93/25 95/10 98/5 99/9I
101/19 103/23 115/3
115/14 115/16 118/12)
118/15 119/20 122/7
(69) go... - Horizon
H
166/10 169/5
hot [1] 167/14
Houghton [1] 5/21
hour [1] 25/12
House [2] 139/24
146/13
Housing [1] 88/24
how [50] 6/24 8/1
53/22 53/23 54/18
55/17 71/7 79/16
81/10 81/16 81/21
83/10 84/3 93/9
105/23 118/5 121/13
136/8 140/13 143/23
144/9 146/11 147/9
149/10 150/19 151/1
152/4 154/20 157/12
157/13 163/15 166/1
167/1 168/24 171/22
176/17 177/1 177/18
however [13] 38/20
47/4 51/1 120/22
133/9 135/21 144/17
148/12 148/23 151/22
158/19 165/16 182/1
hub [3] 71/19 71/23
72/13
huge [1] 24/13
hundreds [2] 75/16
180/19
hypothesising [1]
11/5
l accept [5] 39/15
43/2 43/6 85/15 161/8)
lacted [1] 158/17
l actually [1] 100/20
l advised [1] 32/1
laffect [1] 105/23
l agree [3] 30/15
167/4 175/7
lalso [4] 52/22 109/2
139/2 177/8
lam [8] 76/24 104/23
138/15 138/19 151/21
160/23 161/20 162/1
l appear [1] 163/2
lask [8] 1/18 2/6
16/10 21/20 76/17
77/6 84/3 131/25
lasked [3] 113/13
113/14 183/1
lattach [1] 29/6
l aware [1] 41/9
I beg [1] 5/12
I believe [32] 6/7 6/9
Horizon... [6] 140/19
141/13 141/15 144/13)
9/22 11/22 12/6 15/17
18/4 20/4 24/10 26/18)
38/7 52/23 53/4 53/22
6/18 10/3 12/14 23/6
23/10 29/4 31/10
33/10 36/15 39/24
41/23 48/3 48/13
74/9 96/18 97/25
135/16 147/8 147/25
149/4 152/8 152/22
180/25
I believed [5] 48/2
67/11 67/14 67/14
68/17
I but [1] 2/19
lean [27] 1/5 18/24
19/14 20/11 28/3
28/22 41/7 52/16
78/17 80/16 84/24
4122/1 122/11 127/5
141/11 143/15 148/11
157/9 161/22 172/25
176/3 182/12 182/13
Ican't [22] 11/4 11/4
63/17 70/22 102/7
102/8 110/12 118/23
122/23 134/22 135/21
160/16 172/6 174/4
182/11 182/14
I caveat [1] 76/9
I certainly [3] 38/8
54/4 75/11
I characterised [1]
144/3
I completely [1]
53/20
I correct [1] 154/1
I could [6] 107/23
113/24 145/6 172/17
174/25 177/1
I couldn't [4] 129/12
141/1 141/1 151/1
I definitely [4] 121/14
157/17 160/17 180/22)
I depended [1] 53/24
I described [1]
158/14
I did [30] 3/5 4/7 4/15
7/10 10/11 11/2 18/12
21/17 24/1 32/10 36/3
96/10 96/12 97/25
98/18 107/11 107/14
108/6 111/19 113/14
117/21 135/16 135/22)
136/4 148/9 156/15
157/10 158/17 164/3
177/1
I didn't [25] 10/4
21/25 29/13 41/7
85/11 91/3 104/4
417/14 117/7 117/7
118/21 118/24 119/3
48/16 51/25 62/5 63/6
100/19 113/24 128/25)
86/14 96/22 99/3 99/4
138/14 139/16 141/17,
150/10 153/20 158/22)
121/12 121/12 127/2
140/3 140/3 142/5
143/25 144/2 152/2
157/14 158/22 177/9
I directly [1] 110/13
I disagree [1] 152/6
Ido [36] 1/14 2/8
5/21 6/12 14/23 22/9
30/20 31/12 32/4
39/15 40/19 46/9
106/20 107/3 109/9
112/12 129/1 130/11
148/12 171/25 177/7
I don't [91] 4/4 6/12
9/10 9/14 9/22 10/11
10/18 10/20 10/24
11/6 18/4 20/16 22/24
22/25 23/5 23/18
23/22 25/7 25/11 28/1
29/6 29/8 29/11 30/25)
35/22 35/23 37/3 38/3
38/7 39/23 41/6 43/3
43/4 47/14 52/6 54/3
57/20 57/23 60/2
60/23 61/13 63/3 63/5
63/25 64/8 64/12
69/25 71/8 82/5 97/7
98/25 99/1 100/7
110/7 125/3 125/4
126/18 132/17 132/21
133/25 137/3 139/16
140/1 141/22 145/3
148/11 148/18 150/2
150/17 150/17 151/5
151/19 153/14 153/15}
153/20 153/21 156/5
157/18 158/5 158/6
160/16 168/7 168/15
169/1 177/6 177/6
180/21 181/24 181/25)
182/5 182/8
l expect [2] 125/3
125/5
I feel [1] 67/22
I felt [13] 72/18 72/21
74/12 75/16 108/4
111/6 112/22 125/19
140/24 141/6 141/24
147/9 182/17
I find [3] 17/1 25/8
67/21
I finished [1] 74/10
I first [2] 27/10 168/7
I follow [1] 183/19
I followed [1] 128/5
I found [2] 22/24 48/2I
I fundamentally [1]
180/24
I genuinely [3] 100/5
I discussed [1] 30/15)
47/11 52/22 56/4 65/7
70/23 78/5 78/15 87/2
87/6 97/22 97/23 98/8
102/17 104/22 105/25)
150/10 160/17
I go [1] 23/20
I had [42] 5/22 9/22
64/16 68/15 85/12
92/22 96/11 100/20
110/8 112/25 116/24
120/23 122/23 126/2
126/6 129/19 132/17
138/3 143/24 144/10
154/7 154/7 158/21
161/9 167/24 167/25
168/1 168/11 172/17
1T7AIT 17713 181/24
182/6 182/16 182/17
I hadn't [6] 60/2
98/25 103/10 129/11
130/11 137/21
Ihand [1] 142/11
Ihave [36] 20/25
24/16 30/1 31/4 31/5
31/19 31/19 31/20
31/24 32/18 35/25
37/9 39/16 43/13
110/22 129/7 130/23
149/25 150/3 152/22
161/21 170/19 176/2
181/22 183/4
I haven't [1] 26/22
I heard [1] 23/21
I honestly [1] 122/19
I hope [2] 161/13
173/1
interrupted [1]
67/25
I joined [7] 7/10
14/14 14/17 16/23
18/19 19/13 22/23
I just [16] 17/3 25/9
37/1 77/14 80/23
139/17 140/3 140/7
145/11 159/3 174/24
177/13 177/25 178/20}
181/7 183/21
I knew [3] 93/4
134/22 136/3
I know [5] 110/8
139/19 143/18 176/24,
182/1
Ileft [1] 72/25
Ilive [1] 172/19
Hook [1] 177/3
I looked [2] 19/10
29/4
I made [7] 31/21
125/13 143/20 153/14}
172/19 172/21 180/25}
I make [3] 15/25
123/5 172/16
I got [2] 38/10 109/13)
10/19 21/2 43/6 48/16)
144/11 147/11 153/18}
43/15 43/20 46/4 49/6
60/5 61/2 64/12 89/16
135/11 137/14 137/15}
I may [4] 97/8 100/11
111/1 122/17
I maybe [1] 100/12
I mean [19] 18/3 38/2
61/2 103/2 110/24
113/10 122/5 122/16
122/22 129/2 130/10
152/5 157/6 161/16
161/19 167/23 181/22!
182/13 183/17
I meant [1] 143/12
I mention [1] 117/17
I met [8] 10/2 10/3
17/19 18/1 18/2 18/5
18/5 30/16
I misheard [1] 28/22
I must [4] 40/19
I need [1] 176/3
I needed [4] 110/11
129/5 135/18 141/6
I never [4] 28/10 74/2)
82/5 108/1
I note [1] 106/16
I notice [1] 33/8
I now [3] 20/22
122/10 131/20
I obviously [1] 97/4
I personally [3] 52/6
62/5 172/25
I possibly [1] 107/21
I probably [1] 138/9
I provided [1] 31/11
I questioned [1] 31/4
Iraised [1] 177/8
Trang [1] 2/1
rather [1] 137/17
I read [2] 43/5 56/8
I recall [15] 3/24 6/7
9/15 15/21 16/1 16/15}
18/8 20/12 25/2 25/13)
26/20 26/23 31/21
41/5 170/17
I received [4] 44/6
85/15 104/23 111/15
I recognise [1] 145/7
I refer [2] 15/19
41/24
l referred [1] 176/19
I reflect [1] 108/4
I regret [1] 75/18
I remain [1] 160/20
I remember [18] 62/7!
62/9 62/9 62/10 64/6
64/6 69/19 69/24
69/24 71/3 97/2
105/17 105/17 105/18}
106/1 106/22 113/12
119/11
I remembered [1]
106/2
I represent [2]
173/11 175/22
I requested [1]
104/19
(60) Horizon... -lrequested
return [1] 105/2
I said [14] 31/5 43/22
44/11 53/21 65/4
66/20 68/13 74/9 84/6
107/20 169/16 169/18)
169/21 181/24
I saw [3] 28/11 39/15
39/25
I say [7] 19/14 47/18
55/2 107/20 122/1
137/8 168/11
I see [6] 43/2 43/5
43/13 44/1 52/3 82/7
I served [1] 3/24
I should [8] 26/10
33/10 48/17 75/19
94/15 103/6 122/15
147/4
I shouldn't [2] 169/22!
169/24
I sort [3] 107/25
111/8 117/18
I spoke [1] 110/16
I started [1] 19/8
I stop [2] 177/12
181/6
I stress [1] 31/20
I suppose [6] 103/14
122/7 126/20 126/24
143/13 152/3
I tackle [2] 170/12
170/14
I take [4] 158/20
163/20 175/14 184/7
I thank [1] 1/15
I then [3] 14/20 18/6
80/21
I think [85] 6/23 9/9
10/2 11/5 12/21 32/8
39/1 52/8 52/8 53/16
54/12 55/3 55/24 61/3,
65/17 66/14 68/13
70/1 75/4 75/19 75/21
76/1 76/8 77/15 78/1
79/11 80/2 82/25
91/12 97/14 100/20
100/22 103/3 107/19
110/14 111/5 113/17
114/2 117/17 117/17
120/13 123/3 125/11
125/18 125/24 126/2
126/2 126/6 126/17
132/18 136/2 136/10
143/16 143/17 149/14}
151/21 151/22 153/5
154/4 157/4 157/6
157/9 157/21 158/14
159/5 160/20 160/25
161/7 161/16 161/25
164/15 166/15 169/13}
169/16 170/11 170/17)
171/24 172/3 172/5
176/2 176/3 176/19
179/5 182/25 183/11
I thought [12] 72/16
102/9 129/15 131/14
131/15 141/2 142/8
148/16 149/12 150/23)
158/20 161/19
I took [1] 120/19
l understand [6] 1/19
2/2 4/8 60/1 60/13
67/1
I understood [9]
64/20 64/23 92/24
93/2 119/11 119/22
128/11 130/25 131/4
I very [1] 131/17
I viewed [1] 75/15
I visited [1] 18/7
I want [15] 7/16
14/23 28/6 28/12
29/15 33/16 42/6
52/12 60/6 61/15
68/20 71/10 77/13
83/9 144/14
I wanted [9] 107/21
113/18 113/22 128/2
129/5 176/25 177/1
177/1 177/10
Iwas [113] 3/14 5/2
8/5 8/19 8/20 8/22
8/25 14/14 14/19
20/10 22/20 23/14
26/3 28/15 28/17 29/3
29/4 33/6 33/11 34/8
36/1 36/8 40/3 48/23
50/5 53/20 60/11
64/20 71/8 73/19
74/19 85/14 92/16
97/1 97/7 102/18
103/14 104/20 107/20;
108/6 108/6 108/13
108/22 110/10 111/6
113/10 113/21 116/16)
116/25 118/5 118/6
118/25 119/4 120/14
120/19 121/18 122/18)
125/11 125/13 125/15)
125/15 125/17 125/24}
127/13 127/21 129/9
130/25 131/2 131/6
131/12 137/3 139/2
139/16 139/19 139/20)
139/21 140/2 140/4
140/24 141/3 141/19
141/23 141/24 141/24)
145/5 149/9 149/17
150/19 151/19 153/17,
153/18 156/19 157/10)
157/11 158/11 158/16)
158/17 158/18 159/8
160/24 161/7 162/5
169/4 174/24 176/20
176/20 176/22 177/11
178/3 180/24 182/2
182/12 182/12
I wasn't [15] 21/17
22/1 28/15 35/21 41/5)
64/24 68/15 85/16
100/10 122/2 122/2
138/2 141/5 143/22
151/19
I went [1] 158/6
I will [9] 32/9 32/21
86/21 87/13 137/15
158/19 159/7 170/19
178/4
I wish [1] 147/11
I won't [3] 155/22
159/12 178/3
I wonder [3] 40/2
86/4 162/8
I work [4] 167/24
I would [70] 5/4 7/14
8/23 8/25 10/15 11/5
15/15 16/8 20/8 31/6
37/18 39/24 39/24
40/15 42/4 42/8 47/17
51/18 53/17 65/20
68/17 73/9 96/12 97/8
100/5 100/8 105/18
110/21 110/24 110/24]
112/17 113/24 114/18}
119/1 119/4 121/6
122/22 125/3 125/5
128/11 135/17 135/20}
137/4 138/2 138/3
138/5 138/6 140/25
142/9 144/24 144/24
145/4 149/4 154/8
156/6 158/9 158/21
160/21 160/21 161/13
161/25 167/23 170/1
170/4 172/9 172/11
182/3 182/3 182/4
182/18
I wouldn't [7] 7/12
120/11 120/12 145/9
148/16 153/20 168/16
I'd [18] 22/2 22/22
42/19 56/9 75/4 78/8
87/17 96/19 103/4
108/15 112/25 113/1
123/16 125/17 138/7
158/24 164/18 167/7
[10] 2/19 7/3 13/17
23/15 31/17 80/11
84/11 163/1 172/20
176/2
I'm [63] 2/18 5/12
13/6 13/17 14/22
17/23 20/11 20/12
21/19 25/22 29/2 31/8
35/8 36/17 37/11
47/19 58/6 65/4 68/5
73/25 76/18 80/9
80/21 82/6 85/7 85/7
85/12 85/13 85/16
85/25 95/10 103/2
110/7 110/21 110/22
110/25 110/25 120/9
120/10 120/22 120/23}
122/16 130/23 137/8
141/19 151/5 152/6
157/7 161/22 162/11
162/23 163/1 163/12
164/5 168/2 168/15
168/16 174/13 174/19}
181/5 181/6 183/6
184/4
I've [21] 21/8 29/9
35/23 42/15 47/25
52/7 60/3 60/4 63/7
77/12 84/11 99/1
100/19 143/17 158/4
172/5 172/14 172/18
175/18 181/22 182/25}
1, [1] 149/11
las [1] 149/11
idea [5] 55/4 129/19
130/23 131/8 173/22
ideas [1] 137/7
identification [1]
167/15
identified [4] 20/10
115/6 118/15 166/1
identify [2] 13/20
183/21
identifying [2] 13/13
167/13
if [175] 6/7 6/11 8/21
8/23 15/12 15/20
15/21 15/25 17/10
18/7 20/9 22/3 22/12
26/3 26/5 26/20 26/23)
27/3 27/16 27/21
28/22 29/19 30/11
31/12 32/13 32/24
33/13 33/24 33/24
36/14 37/17 37/21
39/25 40/2 41/5 42/1
42/10 42/12 44/12
45/7 45/9 46/10 46/15)
48/11 48/16 49/7
51/13 51/22 51/25
53/5 53/11 54/15
55/16 55/24 56/18
57/15 58/24 58/25
59/5 60/19 60/21 62/9)
66/6 70/5 73/25 74/1
76/18 76/19 76/19
78/1 78/7 78/9 78/17
78/24 79/2 80/11 81/3)
81/9 83/19 84/24 85/3)
86/4 87/3 89/16 92/12,
93/18 94/23 96/22
96/24 97/14 97/16
101/17 102/7 107/13
110/7 110/22 120/23
120/25 123/18 124/3
124/23 126/7 126/23
128/12 129/22 131/9
132/3 132/11 132/22
133/5 133/7 133/17
134/1 135/11 138/2
138/7 138/10 140/4
141/6 141/7 141/10
141/11 142/5 142/9
142/24 144/22 149/1
152/8 152/9 153/25
154/6 154/12 154/13
158/20 160/23 161/11
161/20 162/8 162/9
163/12 164/7 164/8
165/3 166/3 167/14
168/23 169/9 169/10
169/25 170/17 170/19)
172/17 172/19 172/20)
172/25 173/16 173/22I
173/24 174/5 175/15
176/3 177/3 177/3
177/22 181/1 1814/1
181/17 181/23 182/3
182/6 182/6 182/8
182/16 182/17 183/8
ignorant [1] 143/22
ii [1] 94/6
iii [1] 94/8
illegal [1] 116/14
illegally [1] 133/2
illusory [1] 121/9
imagine [1] 158/9
imagined [1] 144/24
immediate [2] 145/21
146/6
immediately [2] 6/12
152/19
impact [32] 15/8
52/24 55/21 56/14
57/1 57/5 57/9 57/10
58/13 58/21 58/21
58/23 59/2 59/10
59/18 106/20 122/10
124/3 124/3 124/5
124/19 124/22 124/25]
125/8 131/5 131/9
133/5 133/14 133/16
133/22 151/25 182/8
impacts [3] 58/16
59/22 122/4
implication [1] 79/9
implications [5]
55/20 101/8 101/16
105/14 106/10
implied [8] 57/3 59/1
59/6 59/11 123/24
124/10 124/16 124/23)
important [19] 41/19
43/18 69/23 70/7 79/6)
81/22 90/24 91/6
91/13 104/8 109/7
114/3 127/15 130/5
136/4 144/23 164/21
179/8 180/6
impose [1] 167/2
imposing [1] 165/21
impossible [1] 74/17
(61) I return - impossible
impression [11]
102/19 103/10 106/23)
107/17 107/18 107/19}
108/10 109/13 109/17)
110/1 119/18
improper [1] 51/7
improve [5] 12/6
71/18 71/25 72/20
163/15
Improvements [1]
114/11
impugned [1] 51/6
inability [2] 66/20
175/12
inaccurate [2] 36/13
43/17
inadequate [1]
159/14
inadmissible [1]
62/18
inappropriately [1]
133/1
include [4] 40/16
42/9 70/9 132/10
included [6] 34/13
92/8 128/18 136/19
146/16 155/10
includes [1] 39/4
including [15] 13/2
14/10 61/18 78/14
79/24 84/15 98/16
99/17 102/14 114/24
115/21 115/22 134/3
165/19 180/15
inclusive [1] 73/11
inconceivable [1]
52/21
incorrect [4] 43/23
43/25 47/19 48/5
increases [1] 83/16
increasingly [1]
160/15
incredibly [2] 122/9
149/8
indeed [10] 10/8
51/17 61/7 66/19
73/10 73/12 74/13
86/14 106/5 171/11
indefensible [1]
160/15
independence [2]
71/4 143/8
independent [21]
2/21 4/2 4/9 5/8 5/18
8/17 9/21 17/5 19/23
30/10 30/17 34/16
49/5 68/6 70/25 84/20)
85/14 103/21 118/11
178/9 180/11
indicate [3] 31/25
35/25 106/5
indicated [1] 30/24
individual [10] 15/5
16/7 118/16 119/22
120/3 120/5 121/16
individuals [3]
induction [8] 17/12
17/15 17/17 18/11
20/15 75/12 75/20
76/2
Industrial [2] 88/9
89/12
industry [1] 154/18
infer [1] 47/15
influence [1] 154/7
info [6] 94/1 95/9
142/12
informal [5] 103/4
113/1 129/18 143/25
177/19
informally [1] 143/21
information [97]
22/18 25/6 25/25 26/2
28/4 32/15 33/13
37/15 44/24 47/9
47/24 50/18 56/23
58/1 60/4 70/2 77/22
91/9 91/16 92/16
92/22 94/7 95/11 96/5
97/6 97/20 98/5 99/21
102/6 103/20 104/1
104/10 104/11 104/16)
104/19 107/7 107/12
107/13 107/22 107/25)
108/3 108/6 108/7
108/23 108/25 110/11
1411/8 113/12 117/14
118/8 119/3 120/23
121/12 125/16 127/3
127/15 128/2 128/12
134/7 134/24 135/18
135/19 136/5 136/5
137/5 137/6 138/14
138/15 139/8 139/13
139/17 139/18 139/22)
140/1 140/5 140/13
140/18 140/25 141/2
141/6 141/19 142/7
143/25 144/1 144/1
159/14 159/21 160/3
161/18 161/23 170/10)
172/2 172/12 174/18
176/8 176/13 177/10
informed [5] 28/15
30/5 127/22 147/18
156/21
informing [1] 115/23
inherent [2] 102/22
103/1
initial [5] 58/14 98/14
99/15 176/23 176/25
initially [5] 24/6
26/12 35/8 45/14
125/15 131/17 144/15)
117/24 126/24 149/20,
141/25 141/25 142/12
93/19
initiatives [1] 72/7
injunction [1] 18/14
injunctions [1] 81/22
innocent [2] 84/1
180/19
input [1] 146/18
inputs [1] 82/22
Inquiry [37] 1/16 2/15
7/4 7I17 16/3 20/17
21/4 21/10 21/12
21/14 21/23 24/16
26/3 28/2 28/11 28/20
29/5 29/10 29/14
29/17 32/12 40/25
41/9 71/11 74/22
85/24 86/22 86/23
88/17 89/10 144/5
162/2 163/9 173/2
178/14 179/20 184/5
Inquiry's [1] 87/12
insisted [1] 147/4
insolvent [1] 128/10
instance [2] 91/3
159/18
instances [1] 46/25
instituted [1] 71/17
institution [1] 75/15
instructed [1] 36/6
instructing [1] 46/18
instrument [1]
100/21
insufficient [1] 76/6
insurers [2] 49/18
50/4
intention [2] 51/9
113/8
interacted [1] 110/17
interaction [1] 79/25
interest [4] 7/20 8/8
81/17 105/22
interested [3] 104/15
109/10 114/14
interesting [2] 55/25
131/15
interests [7] 7/23
7/25 8/1 9/18 84/22
156/3 159/12
interfere [1] 173/10
interfered [1] 45/12
Interim [1] 21/6
international [1]
109/2
interpretation [1]
59/24
interpreted [1] 54/23
interrupted [1] 67/25
intervene [2] 153/12
153/14
interview [2] 19/21
20/5
intimating [1] 51/3
into [20] 20/25 27/13
29/18 48/6 49/12
49/23 50/2 55/4 57/3
67/1 71/11 84/17
91/22 103/10 103/13
106/3 131/7 131/7
131/24 168/11
intro [2] 105/20
108/21
introduction [1]
124/11
introductory [1]
124/20
investigations [2]
75/17 103/22
Investments [2] 90/1
93/15
involve [2] 3/17
151/12
involved [18] 3/18
46/18 48/24 50/10
50/13 71/6 79/23 80/2
82/23 88/16 102/21
102/25 113/3 148/21
149/20 157/10 180/23}
182/16
involvement [6]
28/18 28/25 29/2 46/7
89/9 160/18
irrelevant [1] 137/7
is [299]
isn't [5] 78/19 79/18
94/25 174/1 175/5
issue [24] 20/9 46/7
58/20 61/12 67/2 68/2
77/12 77/17 83/20
120/17 121/16 122/20
123/24 124/4 124/16
124/23 134/18 136/3
141/3 153/22 153/24
167/1 170/1 170/11
issued [1] 118/13
issues [97] 4/22 5/20
7/4 10/6 10/25 12/12
12/14 12/16 12/22
12/24 13/8 13/15
13/18 14/15 19/9
20/13 20/25 22/22
23/12 24/11 46/13
52/2 52/13 52/19
52/24 54/17 54/21
55/18 56/1 56/6 56/10)
58/10 60/7 60/9 61/1
61/9 62/19 65/3 65/5
65/7 65/9 65/10 65/16
65/19 65/25 66/11
67/16 68/2 68/7 68/20)
71/14 73/2 73/6 73/14,
74/22 87/14 92/17
92/19 101/6 101/9
101/14 101/18 101/19}
102/4 105/22 106/7
112/5 114/10 119/15
122/20 124/15 124/21
124/24 125/6 125/23
140/9 140/16 140/19
140/23 141/9 141/13
141/15 142/2 142/2
145/17 146/8 151/23
160/6 164/21 165/12
168/21 168/24 169/5
169/5 169/7 171/4
178/18
t [492]
t's [86] 12/5 17/9
17/10 21/12 24/17
26/15 29/3 29/16
29/21 31/9 32/6 32/7
33/9 33/15 34/10 37/2
37/8 37/10 37/12 38/4
43/6 47/21 47/25
48/18 53/2 53/7 53/16
54/8 54/13 55/9 55/18
57/15 57/23 58/4
58/18 59/1 59/18 60/7
62/10 63/18 65/4
66/14 68/22 74/17
75/6 75/9 75/18 75/25
76/20 76/23 79/6
81/10 83/3 90/14
91/13 92/6 96/22
117/4 117/16 121/24
124/24 129/23 129/23
131/23 135/5 149/5
149/5 152/11 154/11
157/21 161/1 162/3
164/10 167/10 167/11
169/15 1741/7 171/14
172/18 173/5 173/20
173/24 178/6 178/13
181/22 183/17
item [2] 24/8 132/22
item 11 [1] 132/22
items [2] 28/1 80/3
its [20] 5/19 7/20
12/12 12/19 12/19
14/3 15/13 15/16 30/6
51/6 58/10 68/2 86/23
106/24 116/21 128/7
131/18 134/21 181/10
181/20
itself [12] 21/7 66/15
76/10 95/20 95/22
96/9 99/6 99/23
102/15 103/25 104/22
151/12
qe
jailed [1] 84/2
James [1] 115/13
Jane [17] 18/13 27/1
29/15 29/17 29/25
31/11 50/20 51/15
78/21 79/11 79/12
86/16 86/20 101/4
146/4 149/22 185/8
January [10] 2/22
2/22 14/14 16/23
22/24 26/15 72/8
72/25 88/5 88/25
(62) impression - January
J
Jenkins [11] 22/8
22/8 22/10 22/14
22/19 22/21 22/25
23/3 23/12 23/17
23/24
Jennings [1] 22/7
job [2] 3/16 72/16
jobs [1] 166/4
join [2] 6/9 20/10
joined [17] 3/6 3/8
3/25 7/10 13/19 14/14
14/17 16/23 18/19
19/13 19/17 22/19
22/23 24/10 30/7
74/11 164/14
joining [3] 7/12 70/24
75/18
joint [4] 75/23
Jonathan [10] 28/18
28/23 29/2 29/22
29/22 35/16 42/22
42/24 43/9 43/14
Jones [2] 69/11
69/17
journalist [1] 79/3
journalists [4] 79/2
79/8 83/12 83/24
judge [13] 51/2 61/24
65/12 65/24 66/20
68/10 133/1 145/23
147/16 149/8 149/11
150/24 174/23
judge's [1] 66/11
judgement [12]
34/24 35/15 36/10
36/20 37/16 37/19
37/21 38/16 38/19
118/25 141/1 172/13
judgements [1]
91/14
judgment [37] 10/6
12/13 12/14 12/16
12/24 13/8 13/10
13/16 13/18 23/13
46/13 60/6 60/9 61/1
65/9 65/11 66/1 66/9
66/23 68/16 68/17
68/21 127/11 131/4
140/16 141/4 142/1
142/4 145/18 145/20
146/3 146/9 146/13
146/23 150/25 160/6
168/10
judgments [2] 73/15
151/3
judiciary [3] 150/15
150/21 151/8
judiciary’ [1] 150/6
July [12] 1/1 21/13
39/18 55/22 56/17
57/18 88/5 88/9 89/2
99/20 118/13 164/15
July 2018 [1] 164/15
June [6] 68/23 87/3
128/16 131/22 154/10)
154/18
junior [5] 144/10
170/9 170/22 171/2
172/10
just [94] 1/24 2/11
4/25 11/5 11/16 17/3
17/21 24/22 25/9
28/22 29/1 31/8 34/15
35/6 35/22 37/1 39/19)
40/3 50/15 58/6 58/24
63/7 64/9 68/2 68/11
71/12 73/25 76/4
76/18 76/23 76/24
77/14 78/6 78/19
80/23 82/24 84/11
87/14 91/21 93/18
95/3 95/19 96/24
97/16 97/21 98/20
103/2 108/16 108/17
110/25 110/25 111/21
111/23 112/14 112/24}
113/5 117/1 119/9
123/4 123/15 124/1
124/11 125/21 133/17,
137/4 138/16 139/17
140/3 140/7 143/4
144/13 144/20 145/8
145/11 150/24 151/5
159/3 161/17 162/12
165/1 170/19 170/23
171/7 174/24 175/10
177/13 177/25 178/4
178/20 180/15 181/7
182/19 183/6 183/21
justice [10] 12/17
50/23 51/23 62/11
66/1 67/2 67/6 67/18
71/16 146/24
Justice Fraser [2]
12/17 62/11
justification [1]
182/17
K
KC [1] 52/1
keen [5] 70/23
116/16 158/16 162/1
163/8
keep [8] 9/7 9/13
59/13 134/10 141/21
142/6 173/20 173/21
keeping [2] 127/13
141/12
keeps [1] 173/22
Kelly [11] 86/15
86/16 86/20 104/21
130/1 138/25 139/1
139/7 150/1 152/16
185/8
Ken [4] 34/16 34/24
36/10 39/4
KENNETH [3] 1/8
1/11 185/2
Kent [2] 166/15
166/16
kept [4] 140/22
141/16 141/23 147/7
key [5] 24/11 66/4
101/6 114/10 134/11
kind [41] 55/2 91/4
103/15 116/25 117/15}
117/25 126/3 126/20
144/19 173/21 177/17!
king [2] 54/21 55/2
knew [9] 42/19 43/9
63/10 93/4 134/22
136/3 141/9 179/15
180/5
know [223]
knowing [1] 121/23
knowingly [1] 83/21
knowledge [19] 2/13
5/24 6/2 16/24 18/20
19/1 19/6 20/19 21/3
34/4 58/15 61/20
66/18 68/13 68/13
68/15 112/25 160/5
171/18
knowledgeable [1]
5/25
known [11] 21/12
22/14 36/5 42/1 128/8
138/7 178/22 178/22
179/11 179/17 179/25}
knows [3] 38/8
140/17 162/12
KT [2] 130/1 130/2
L
labour [1] 161/16
lack [3] 11/1 68/8
130/14
lady [1] 131/25
language [1] 120/7
large [6] 117/22
117/25 125/14 129/12)
163/3 167/25
larger [1] 166/22
last [12] 42/15 50/22
56/22 78/8 82/24
84/11 92/15 99/19
119/10 123/15 142/10
169/23
later [11] 4/21 19/16
39/19 43/10 74/21
97/9 97/10 107/18
107/19 109/18 109/19}
latterly [2] 6/7 6/18
law [4] 55/7 116/14
174/1 175/3
lawyer [1] 168/15
lawyers [1] 175/6
layman [1] 63/17
layperson [3] 149/7
149/11 161/19
layperson's [1]
150/22
lead [3] 52/9 84/18
120/24
leadership [3]
104/12 155/11 156/10}
leading [4] 12/8
17/25 106/17 156/22
learning [3] 31/3
51/23 61/9
least [5] 5/24 42/25
46/3 53/2 180/18
leave [4] 51/20 74/21
139/1 141/13
leaving [4] 27/7
74/20 76/10 157/1
led [7] 17/6 26/1
115/13 115/19 116/2
116/8 122/5
left [17] 18/24 19/2
19/15 31/2 57/18
58/18 72/8 72/24
72/25 74/7 77/10
91/22 123/22 124/8
124/14 154/4 158/2
left-hand [2] 123/22
124/8
Legacy [5] 66/17
66/19 68/9 68/14
68/18
legal [76] 6/5 6/10
6/15 7/3 7/13 18/10
26/17 26/25 27/1
34/25 35/15 36/11
36/21 53/3 53/5 53/7
53/17 53/24 57/4
62/21 62/23 63/19
63/20 63/23 65/10
65/17 65/20 67/9
67/11 67/15 67/22
74/11 81/20 94/10
98/14 99/15 100/1
100/16 101/4 102/22
103/1 130/23 134/2
134/5 134/12 134/16
134/18 136/21 136/25
137/15 149/2 149/13
151/10 151/16 157/17}
157/19 157/20 168/15]
168/19 168/20 170/18}
170/25 171/21 173/4
173/6 173/8 173/9
173/15 173/18 173/18
173/23 173/24 173/24}
174/3 175/2 175/4
legally [4] 44/19 94/7
98/4 134/6
legislation [1] 173/19
length [7] 125/22
165/19 170/16 170/24I
172/9 172/24 178/15
lens [1] 163/12
less [5] 25/9 57/11
137/18 137/25 155/19}
lesser [1] 90/17
let [6] 6/21 60/19
84/6 126/15 135/11
173/4
let's [6] 17/9 24/3
35/9 45/20 66/24
97/16
letter [10] 17/9 29/13
32/6 32/11 33/9 33/11
39/7 39/12 146/12
147/15
letters [1] 132/9
level [15] 4/23 8/25
11/11 15/11 16/21
24/9 25/13 75/5 105/1
105/3 121/15 121/15
124/7 141/2 157/1
levelled [1] 51/5
leverage [3] 181/12
182/24 183/1
liabilities [1] 12/2
liability [11] 113/15
127/21 128/4 128/7
128/8 128/19 129/10
129/20 130/7 164/22
167/2
liable [3] 129/4 165/5
165/21
liaise [1] 5/6
lie [1] 180/5
lied [1] 46/23
lieu [1] 58/11
life [2] 172/15 172/17
light [2] 24/17 25/11
lightbulb [1] 146/9
like [26] 11/22 41/14
42/19 51/18 62/6
72/23 75/3 87/17
96/19 123/16 129/6
129/12 132/15 141/24)
145/2 145/3 149/18
151/15 158/24 161/13}
162/1 163/12 164/18
167/10 171/20 179/7
liked [2] 135/25
168/17
likelihood [9] 57/4
58/18 59/1 123/23
124/8 124/13 124/13
124/15 125/8
likely [16] 20/10
55/12 55/18 57/9
57/11 57/21 58/19
58/20 106/19 124/9
124/10 125/7 128/21
133/9 153/6 165/16
limit [3] 46/12 144/15
162/13
limitations [2] 169/2
178/16
limited [77] 2/21 2/22)
8/9 13/21 16/6 19/1
19/13 19/17 24/9
45/13 46/18 66/19
(63) Jenkins - limited
L
limited... [65] 68/15
93/4 94/10 98/2 98/6
99/9 101/3 101/18
102/19 104/25 105/12)
106/18 106/23 107/5
107/9 107/9 109/9
109/13 109/15 109/21
109/22 110/14 110/20)
111/16 112/25 119/19}
119/23 126/12 127/11
127/12 127/19 128/1
128/6 128/11 128/20
132/23 133/9 134/2
143/8 145/24 145/25
146/19 147/16 148/2
148/7 148/10 148/19
148/24 153/2 153/11
153/22 153/24 154/6
154/20 155/5 155/7
156/14 157/2 160/4
172/18 172/24 182/22
Limited's [20] 35/13
99/19 100/1 100/15
101/4 101/11 106/17
112/7 127/16 128/3
128/9 128/17 128/19
limits [1] 103/17
line [14] 18/3 18/5
47/6 56/18 68/24
82/25 83/6 92/15
133/6 149/19 155/17
lines [3] 81/14
106/14 147/24
link [1] 101/6
list [9] 34/11 34/12
58/16 94/18 94/20
95/14 95/18 101/2
178/7
listed [5] 8/2 54/15
59/10 95/21 114/8
listen [2] 69/21 113/4
listening [1] 109/12
litigation [92] 7/9
7/11 7/14 10/10 11/1
15/12 24/3 25/14
26/18 27/10 45/2
48/19 48/21 49/15
50/8 50/13 51/4 51/24
54/7 54/16 56/17
59/20 80/4 80/8 84/19
85/11 93/25 95/10
96/16 98/6 98/15
99/10 99/11 99/16
102/18 102/20 102/21
102/25 103/9 103/15
104/8 104/13 105/14
105/19 106/6 106/11
111/18 111/20 111/22)
134/20 134/24 137/15)
94/7 94/9 98/14 99/15)
128/24 136/21 136/25)
156/12 178/10 180/14}
112/15 112/18 112/21
112/23 113/6 113/12
113/17 114/9 115/8
116/25 117/21 125/10)
125/12 126/5 126/20
130/18 131/19 132/23)
132/25 133/13 134/3
134/20 135/13 139/5
143/3 143/24 144/13
146/11 154/11 154/20)
155/6 155/8 156/13
160/13 163/25 164/4
165/24 167/5 167/7
181/19
Litigation’ [1] 104/22
little [14] 64/20 78/9
78/16 81/9 81/10
82/24 83/19 88/19
100/14 123/19 124/1
130/2 131/23 162/12
live [1] 172/19
lived [2] 166/15
166/15
living [1] 172/15
Local [1] 88/24
logical [2] 49/18
61/25
logistics [1] 12/9
logs [1] 33/19
long [6] 55/6 84/15
113/22 127/1 145/11
178/6
long-term [1] 55/6
longer [2] 60/11 86/5
look [39] 7/16 11/22
13/3 16/15 17/9 24/2
28/6 42/5 42/6 44/4
45/1 46/10 48/18
50/19 52/7 54/6 56/16)
57/15 65/1 68/20
68/22 70/5 78/7 80/23
126/22 133/5 134/1
164/8 166/5 167/1
167/13 167/21 168/21
169/9 173/16 175/1
175/14 177/3 181/17
looked [7] 19/10 29/4
91/10 112/2 119/9
129/5 168/8
looking [39] 2/25
8/14 11/24 12/4 12/16)
13/6 13/7 13/7 13/9
13/11 14/18 20/4
24/15 43/8 47/22
55/22 59/19 76/24
93/9 95/19 99/5 99/6
100/13 103/2 106/11
108/4 111/2 121/14
125/16 126/23 131/12)
132/3 147/3 147/10
147/11 156/1 157/4
163/8 172/6
Lord [7] 61/22 61/23
167/17 169/11 181/15)
62/8 62/13 63/14
115/13 116/8
Lord Grabiner [4]
61/23 62/8 62/13
63/14
Lord Neuberger [1]
61/22
58/19 106/19 120/1
124/9 125/7 167/14
losing [9] 52/16
55/21 65/7 65/23
66/11 105/14 123/23
124/16 126/20
loss [1] 115/20
114/25 115/4 115/14
115/17 115/25 121/9
lost [7] 52/21 65/12
125/8 140/17 141/10
143/7 143/12
lot [9] 72/5 76/14
76/15 91/24 96/11
126/25 144/6 162/4
169/7
lots [2] 122/22
144/11
loved [2] 160/21
160/22
low [3] 57/9 59/2
67/18
lower [1] 125/9
MacLeod [17] 18/13
24/6 24/23 25/1 25/11
25/19 25/20 27/2
27/22 29/17 29/25
30/24 31/11 79/11
101/4 146/5 149/22
MacLeod's [5] 24/17
24/20 29/15 31/18
50/20
mad [1] 173/11
made [49] 1/19 2/11
8/12 12/17 12/24 13/9
15/16 16/17 20/4
27/18 31/6 31/21 33/7I
33/20 34/24 35/14
36/10 36/20 37/15
46/17 51/11 59/20
71/16 72/22 102/13
106/21 109/6 110/20
125/13 137/9 141/4
142/22 143/20 145/20
147/23 149/8 150/25
152/25 153/3 153/12
153/14 156/1 162/3
162/15 163/10 172/19}
172/21 177/5 180/25
madness [2] 148/17
lose [11] 55/24 56/11
168/21 168/23 169/10
losses [11] 93/1 93/5
121/10 121/20 165/21
lunch [2] 76/21 77/1
149/12
mails [4] 4/19 12/8
17/25 75/25
main [1] 125/2
mainly [2] 14/1 90/8
mainstream [2]
81/13 83/8
maintain [3] 59/13
82/12 156/2
Maintaining [1]
134/17
maintenance [1]
47/3
Majesty's [1] 109/4
major [7] 20/9 37/17
37/22 37/23 75/20
112/17 129/7
majority [1] 181/11
63/15 69/7 73/11
73/25 75/1 90/18
91/14 102/5 110/23
115/16 115/25 117/7
122/23 123/5 130/20
131/17 139/2 139/11
141/1 148/7 149/15
153/23 155/16 158/1
172/2 172/13 172/16
172/17
makes [5] 121/1
126/7 141/6 142/6
142/9
making [20] 8/9
76/1 85/23 96/7
110/25 118/25 148/2
148/4 148/25 155/12
155/13 156/8 157/14
171/18 174/13 184/2
manage [1] 55/20
managed [2] 82/7
84/17
management [5]
11/14 13/25 17/16
26/24 50/21
managing [4] 51/1
80/4 90/8 90/10
manipulate [1] 46/22
many [10] 9/22 16/1
18/4 24/10 51/16
55/17 145/14 149/25
174/16 184/4
March [13] 10/7 32/7
33/9 39/8 60/8 61/2
101/10 147/17 149/23
150/7 151/18 152/21
169/3
March 2019 [1] 169/3I
marine [2] 87/20
87/22
market [1] 12/9
marketplace [2] 12/4
make [37] 6/24 15/25
26/1 63/2 63/10 63/11
158/16 159/16 171/22}
34/20 35/12 47/3 51/7,
12/6
massive [1] 131/5
material [10] 15/7
15/13 20/14 20/15
22/14 30/12 52/22
55/13 121/3 167/12
materiality [12] 14/24I
15/14 15/17 15/19
15/23 15/25 16/2 16/5I
16/6 16/12 16/13
16/22
matter [16] 9/6 13/18
16/20 24/23 27/8
50/15 50/17 50/17
68/9 74/4 89/22
135/24 155/17 156/13}
156/25 157/11
matters [16] 6/16
12/25 20/1 33/21
66/13 66/15 74/8
74124 74/25 88/17
89/10 89/19 157/2
160/5 174/3 176/2
may [39] 13/5 47/23
49/20 54/8 56/11
62/24 62/24 62/25
62/25 85/2 86/15 88/2
92/10 97/8 97/11
100/11 100/22 111/1
119/14 119/21 119/24)
122/17 128/9 138/12
138/18 138/18 138/19)
151/4 151/8 151/8
153/19 161/13 168/3
168/4 168/4 168/4
168/21 169/18 180/19)
maybe [11] 6/24
47/21 63/24 70/1
72/11 100/12 110/10
120/13 120/24 122/9
161/11
McCall [19] 1/6 1/8
1/11 1/12 2/6 30/18
34/16 38/10 39/5 68/5
77/6 78/14 80/11
80/15 84/3 84/12
85/18 85/23 185/2
McCall's [1] 51/13
McFadden [1] 184/8
me [101] 6/21 8/12
12/21 20/10 21/22
21/25 24/18 25/15
26/4 32/12 35/24 36/5
37/13 39/16 41/9 48/4I
53/7 58/4 60/4 60/19
68/17 74/16 74/18
74/20 77/10 79/6 84/6
85/25 96/13 96/25
97/5 97/6 97/11
107/22 107/24 107/24I
108/2 108/19 108/25
110/13 112/20 112/22)
112/22 113/2 114/3
116/16 118/8 119/1
(64) limited... - me
me... [53] 119/2
120/13 120/17 120/24}
120/24 122/8 125/18
125/19 125/21 126/21
127/2 127/4 127/15
128/6 128/12 129/6
129/7 129/8 129/13
129/17 129/18 131/8
132/18 133/17 135/11
135/17 136/6 137/6
138/10 138/14 138/15
140/6 140/10 143/19
144/21 145/2 145/15
149/5 151/23 152/11
157/7 161/6 161/19
162/4 168/5 171/1
172/6 172/13 172/23
173/4 175/11 175/14
182/15
mean [34] 17/3 17/4
18/3 22/5 23/8 25/15
38/2 55/8 61/2 62/1
103/2 103/7 103/15
103/16 110/24 113/10)
113/15 119/12 122/5
122/16 122/22 129/2
130/10 130/15 143/10}
152/5 157/6 161/16
161/19 167/23 168/23
181/22 182/13 183/17)
means [4] 22/5 54/18
77/2 162/11
meant [3] 142/7
143/12 153/17
measures [1] 72/9
mechanism [1] 124/3)
media [2] 81/13 83/8
Medway [1] 87/24
meet [13] 4/12 10/5
10/12 10/15 18/10
18/13 113/2 143/2
143/21 144/14 145/5
145/9 145/10
meeting [94] 9/10
10/1 10/14 10/17
26/15 30/6 30/18
31/13 33/8 42/12
42/16 44/14 44/17
44/23 47/16 54/7
54/10 54/11 56/3
56/17 56/22 68/23
70/21 74/17 77/21
78/11 78/12 78/23
79/13 81/3 99/20
100/24 101/25 103/13
104/24 105/5 105/8
105/16 105/17 105/20)
106/1 106/6 106/12
106/25 107/16 108/15
108/21 111/12 111/16}
111/19 111/21 111/24}
111/25 112/2 112/8
112/9 112/10 112/13
112/14 112/17 113/8
113/10 113/18 114/6
114/18 116/22 116/24)
120/8 120/15 120/20
123/14 125/19 126/17)
127/10 127/21 127/22)
129/1 129/19 129/22
130/12 134/14 135/20)
135/21 139/3 144/4
144/21 153/1 153/2
153/24 154/18 163/23)
164/3 164/11 168/12
meeting/call [1]
153/1
meetings [11] 9/19
9/22 10/14 10/18
17/16 26/5 30/2 30/2
64/4 145/15 177/9
member [6] 6/15
48/22 59/20 80/5
152/9 161/4
members [10] 16/25
34/18 47/15 80/18
80/18 80/19 109/22
110/6 110/16 146/12
memory [2] 26/7
107/8
men [1] 180/19
mention [2] 29/11
117/17
mentioned [3] 20/13
73/13 177/8
merit [3] 49/21 62/25
113/14
merits [7] 56/22
98/16 99/2 99/17
99/25 111/20 164/4
message [9] 78/18
78/18 79/12 80/12
80/20 83/4 84/12
153/20 169/25
met [13] 10/2 10/3
15/14 17/19 18/1 18/2
18/5 18/5 30/16 82/6
135/3 137/18 138/25
middle [1] 17/16
midway [1] 1/25
might [14] 11/21 12/6
34/3 60/20 85/5 97/9
97/10 100/11 121/21
122/4 137/25 138/8
147/16 173/21
milestones [1] 24/12
million [3] 127/23
130/21 131/3
millions [1] 16/1
mind [8] 9/24 14/16
20/12 23/1 140/20
153/8 171/2 1741/5
minimise [2] 81/13
83/5
minimising [1] 83/8
minister [44] 9/19
9/23 10/4 10/5 10/8
30/9 39/13 89/5 91/1
92/9 95/12 96/11
101/13 105/23 109/15}
112/3 113/23 117/3
126/4 129/14 130/22
134/9 135/9 137/16
137/25 138/6 139/23
140/6 144/10 145/5
147/10 150/1 161/18
161/20 162/5 168/17
170/9 170/22 171/2
172/10 174/22 177/20
179/25 181/18
Minister's [4] 90/16
101/1 136/16 136/16
ministerial [7] 88/14
90/9 158/16 164/14
172/14 176/14 177/21
ministers [15] 90/19
92/7 134/10 134/17
157/1 161/14 171/8
171/9 171/16 172/1
175/1 177/15 178/21
179/21 182/14
Ministry [1] 88/24
minor [2] 120/18
122/9
minute [7] 32/17
45/25 46/4 54/7 77/16
77/24 77125
minutes [28] 24/15
24/19 24/25 25/6
25/10 25/17 25/23
25/25 26/5 26/8 30/1
40/15 40/20 40/23
42/8 42/15 45/1 47/8
47/14 47/17 53/2
54/10 76/24 106/6
123/3 159/7 162/23
163/1
misheard [1] 28/22
misrepresentation
[1] 79/7
missed [1] 135/11
missing [2] 25/24
25/25
mistake [1] 157/22
mistresses [1] 163/4
mitigate [1] 13/21
mitigating [2] 13/13
134/8
mitigation [2] 46/14
134/1
mitigations [1] 55/23
Mm [19] 102/2
114/15 126/14 145/22)
154/16 155/25 159/24
163/11 166/7 167/18
170/21 171/6 171/19
177/16 177/24 178/12
179/4 179/10 179/24
Mm-hm [10] 102/2
154/16 163/11 166/7
170/21 177/16 177/24
178/12 179/10 179/24}
model [8] 8/14 12/5
12/7 13/7 14/6 14/18
50/9 170/17
moment [7] 28/1
40/14 40/18 61/5
122/25 146/9 170/20
monitoring [1] 24/2
month [6] 4/9 75/7
76/5 76/8 76/12 128/5)
months [3] 88/19
139/19 166/4
more [69] 9/23 24/18
24/23 25/5 25/6 25/8
25/16 25/18 25/20
25/22 26/6 28/4 33/20)
37/5 37/12 41/6 42/3
42/5 56/13 58/1 63/24)
65/11 65/21 67/22
70/9 71/24 75/4 75/19)
76/3 76/14 76/15
79/20 81/24 92/10
103/7 103/14 107/7
109/10 113/11 116/17)
118/16 119/14 121/15}
121/15 123/19 128/2
131/3 133/9 135/17
135/19 136/2 139/22
141/16 141/19 141/23}
141/25 141/25 141/25)
141/25 142/7 142/11
142/12 144/6 151/10
155/6 155/9 160/24
173/21 176/13
morning [6] 1/3 1/7
77/16 78/4 78/23
85/25
most [15] 17/19
17/22 52/19 55/11
55/25 57/8 63/19
69/23 76/9 76/10
83/15 164/21 165/11
165/17 178/8
mostly [1] 115/10
move [6] 42/5 50/9
60/6 118/3 158/7
176/18
moved [1] 149/16
moves [1] 72/21
moving [3] 27/14
69/12 89/14
MP [4] 88/2 104/21
115/13 166/16
MPs [3] 114/24
115/12 116/8
Mr [82] 1/6 1/9 1/12
1/22 2/1 2/3 2/6 5/21
6/13 6/18 23/3 23/12
23/17 23/24 29/24
30/12 30/14 30/18
36/19 38/10 38/11
38/13 38/17 38/23
40/3 44/6 44/7 44/14
44/18 44/23 50/23
51/13 51/23 64/14
64/25 66/1 67/2 67/6
67/18 68/5 71/16
73/10 77/6 77/15
77/21 78/2 78/4 78/14)
79/14 79/16 80/6
80/11 80/15 80/17
80/25 81/20 83/1 84/3
84/4 84/6 84/12 85/18)
85/20 85/23 86/3
93/15 93/20 106/16
107/3 143/10 144/4
144/5 151/16 162/22
162/25 176/6 176/11
178/19 182/20 184/8
185/4 185/13
Mr Aldred [1] 106/16
Mr Aldred's [1] 107/3)
Mr Clarke [2] 93/15
93/20
Mr Cooper [11] 2/3
38/11 44/6 64/25
79/16 80/6 81/20
143/10 151/16 176/6
176/11
Mr Cooper's [6] 1/22
64/14 80/17 80/25
144/4 144/5
Mr Davies [2] 84/4
84/6
Mr Davies' [1] 83/1
Mr de Garr [1] 79/14
Mr Houghton [1]
5/21
Mr Jenkins [4] 23/3
23/12 23/17 23/24
Mr Justice [7] 50/23
51/23 66/1 67/2 67/6
67/18 71/16
Mr McCall [14] 1/6
1/12 2/6 30/18 38/10
68/5 77/6 78/14 80/11
80/15 84/3 84/12
85/18 85/23
Mr McCall's [1] 51/13
Mr McFadden [1]
184/8
Mr Parker [10] 2/1
29/24 38/13 38/17
44/7 44/14 44/23
73/10 77/21 78/2
Mr Parker's [4] 30/12)
30/14 36/19 44/18
Mr Stein [3] 162/22
178/19 182/20
MR STEVENS [8] 1/9
38/23 40/3 77/15 78/4I
85/20 86/3 185/4
Mr Tidswell [2] 6/13
6/18
Mrs [6] 25/1 25/11
27/22 84/16 175/25
175/25
(65) me... - Mrs
Mrs Hamilton [2]
84/16 175/25
Mrs Henderson [1]
175/25
Mrs MacLeod [3]
25/1 25/11 27/22
Ms [58] 2/1 24/6
24/17 24/20 24/23
25/19 25/20 30/24
31/18 76/23 77/3 77/4
77/10 77/11 80/13
80/24 82/9 83/1 86/17,
86/19 87/10 87/10
92/12 97/17 98/10
102/12 106/16 119/7
127/6 141/14 142/11
142/17 142/19 142/25)
159/2 162/7 162/22
163/2 163/7 163/22
164/12 167/13 168/20)
175/8 175/10 175/19
175/20 175/22 175/25
176/4 178/19 183/5
183/6 183/25 184/2
185/6 185/11 185/15
Ms Hall [2] 77/11
175/25
Ms Hamilton [1]
77/10
Ms MacLeod [5] 24/6
24/23 25/19 25/20
30/24
Ms MacLeod's [3]
24/17 24/20 31/18
Ms Patrick [5] 76/23
77/3 162/22 175/10
175/19
MS PRICE [10] 86/17
141/14 142/11 142/17)
159/2 163/7 176/4
178/19 183/25 185/11
Ms Stent [1] 2/1
Ms Tolhurst [12]
86/19 87/10 142/19
162/7 163/2 167/13
168/20 175/8 175/22
183/5 183/6 184/2
Ms Tolhurst's [9]
87/10 92/12 97/17
98/10 102/12 119/7
127/6 142/25 163/22
Ms Vennells [4]
80/13 80/24 82/9
106/16
Ms Vennells' [1] 83/1
much [27] 27/19 37/5
37/12 53/4 65/11 72/5)
73/17 75/9 81/17
85/18 105/20 107/5
107/21 107/23 107/25}
112/23 113/21 118/8
120/14 131/17 151/6
multi [1] 8/3
multi-shareholding
[1] 8/3
multiple [2] 41/8
41/10
must [2] 40/19 118/2
mutualisation [1]
179/16
my [160] 3/23 5/2
5/14 5/24 6/8 8/6 8/11
8/12 8/13 11/11 14/16)
14/17 15/19 15/23
16/24 17/8 18/20 19/8
19/11 23/1 23/20 26/2
26/6 26/22 28/2 29/10
30/14 30/16 31/7
31/25 33/8 35/25 36/2
36/14 36/24 36/24
37/6 39/23 41/17
41/20 41/22 41/23
45/23 46/5 47/18
47/25 48/1 48/3 48/4
48/13 51/25 52/3
52/10 53/8 53/19
53/19 57/24 57/24
60/1 62/5 64/10 66/16
66/18 66/19 68/13
68/13 71/5 72/11
72/25 74/10 77/6 77/9
77/11 84/15 86/21
90/25 90/25 92/21
100/19 103/12 103/17)
105/22 106/21 107/8
107/9 107/20 108/8
108/18 110/11 110/14)
113/17 114/2 117/1
117/18 118/7 119/18
122/1 122/11 125/21
127/9 128/5 129/2
130/13 130/19 130/23}
131/14 136/2 137/2
138/17 138/20 140/6
141/3 141/8 141/20
142/6 142/8 143/7
143/15 143/17 144/13)
144/20 145/16 148/13)
149/6 149/7 150/19
150/22 151/5 153/17
153/18 153/25 153/25)
153/25 156/6 158/7
158/14 158/15 159/8
162/7 162/12 163/1
163/2 169/20 171/2
172/5 172/8 172/14
172/15 172/16 172/19}
175/22 175/25 176/1
176/19 176/23 176/24)
177/9 180/21 183/17
183/20
myself [5] 41/23 65/8
66/15 72/25 182/14
164/16 166/10 166/22,
167/17 174/15 183/24;
N
name [20] 1/10 6/11
6/11 29/3 29/3 29/11
35/21 36/4 37/4 38/21
41/6 43/4 77/6 78/14
82/5 86/18 86/21
163/2 175/22 178/7
namely [2] 35/16
39/20
names [1] 29/7
Nationwide [1] 69/23
native [4] 143/7
143/11 176/7 176/12
naturally [1] 33/10
nature [4] 58/10
116/11 116/12 167/5
necessarily [7] 5/10
15/15 24/9 100/10
154/3 167/13 175/5
necessary [1] 104/11
NED [1] 134/5
need [21] 4/17 19/20
22/12 24/3 32/14
33/15 33/25 49/25
50/7 52/8 52/8 55/19
70/16 107/4 127/24
128/22 130/22 131/23}
166/8 175/1 176/3
needed [6] 8/21
110/11 116/20 129/5
135/18 141/6
needn't [1] 151/15
needs [1] 164/24
negate [1] 174/20
negative [3] 56/14
83/6 131/4
negligible [1] 58/22
negotiating [1]
155/15
net [1] 165/41
network [8] 18/7 18/9)
69/22 71/23 72/6
72/12 72/21 73/17
Neuberger [1] 61/22
never [14] 8/11 8/12
28/10 28/15 31/20
31/20 62/6 74/2 82/5
85/12 107/12 108/1
108/1 156/6
Nevertheless [1]
33/17
Neville [6] 19/22 28/9
28/14 29/13 32/7 39/7
Neville-Rolfe [6]
19/22 28/9 28/14
29/13 32/7 39/7
new [15] 18/20 20/11
55/7 81/16 92/7 95/16
96/11 99/22 100/2
102/6 103/10 107/20
134/11 136/5 139/3
news [3] 24/9 81/16
136/19
next [9] 51/19 54/11
54/20 71/11 77/10
80/12 135/4 146/2
146/7
nice [1] 139/4
Nick [6] 69/2 69/19
72/18 73/13 73/22
109/2
nine [1] 12/15
no [109] 4/4 10/1
10/11 11/2 11/5 13/17}
16/24 17/3 18/12
18/15 19/10 20/5
20/16 21/2 21/17
21/19 23/14 24/1 24/3)
25/7 30/25 32/4 32/10
33/6 34/8 35/9 35/21
36/8 38/6 38/7 39/15
39/16 41/11 43/13
43/20 46/20 47/12
48/8 49/6 50/5 52/2
54/3 56/4 57/20 60/3
60/5 60/23 61/2 61/19
62/1 62/2 62/10 62/12,
62/14 63/2 63/15
64/13 64/13 68/15
74/5 75/16 79/4 79/11
80/2 81/8 81/8 81/15
82/13 82/14 89/4 97/1
102/25 103/22 104/4
108/13 116/22 118/14
118/21 119/13 120/17]
122/1 122/6 128/17
129/19 130/15 130/23}
134/22 136/2 137/6
137/14 138/2 138/14
138/20 144/8 145/15
148/3 151/19 158/9
159/23 166/8 168/1
169/20 170/14 175/8
180/11 180/13 180/14)
183/19 183/19
nobody [1] 129/13
nodded [3] 89/24
95/24 166/23
nodding [1] 179/5
non [37] 3/19 4/5
5/22 6/8 7/16 7/19
7/23 8/18 8/20 8/24
9/17 11/9 11/11 11/19)
11/25 12/4 13/3 13/6
13/24 14/2 14/10
15/10 18/21 19/4
41/24 66/16 69/13
70/13 73/8 74/23 75/2,
75/7 75/13 76/5 76/9
76/11 84/20
non-exec [1] 12/4
Non-Execs [1] 75/2
non-executive [21]
4/5 5/22 7/16 7/19
8/18 8/20 8/24 9/17
11/9 11/11 13/24 14/2}
14/10 18/21 66/16
69/13 70/13 74/23
76/9 76/11 84/20
non-executives [4]
11/19 13/3 41/24 73/8)
none [8] 16/24 18/20
43/15 63/21 66/16
73/3 126/7 156/20
nor [3] 31/4 31/5
31/21
normal [5] 3/14 76/8
107/23 135/17 136/6
normally [3] 15/21
54/12 76/15
not [209]
note [17] 46/12 51/16
52/10 94/10 99/22
100/2 106/16 106/25
107/3 109/2 127/22
129/22 130/10 130/10}
153/16 158/18 158/20)
noted [8] 46/19 46/24I
56/21 57/7 57/13
69/11 70/7 70/16
notes [1] 24/16
noteworthy [1] 102/6
nothing [3] 9/23
20/13 174/7
notice [2] 33/8
165/19
notion [1] 181/7
notwithstanding [2]
104/6 156/20
November [11] 23/7
23/20 34/11 45/23
47/21 114/10 135/4
135/5 136/11 140/8
140/11
November's [1]
101/9
November/DecemberI
[2] 23/7 23/20
now [67] 6/12 10/3
20/4 20/22 22/8 23/9
24/18 25/15 26/3 28/7
30/20 33/23 38/22
43/8 44/9 45/18 48/19)
52/1 55/23 57/15 58/4I
64/3 65/2 67/16 68/20
75/18 79/13 79/16
83/14 84/3 87/11
95/11 97/21 99/5
103/8 106/20 109/9
1411/2 115/13 121/19
122/10 126/9 130/14
131/12 131/20 134/23)
140/16 142/19 147/3
149/6 154/9 157/22
159/4 163/1 163/12
163/19 164/5 167/19
169/1 169/8 173/5
173/11 173/15 177/15)
179/15 179/20 181/17
nuclear [11] 158/15
160/8 179/1 181/7
(66) Mrs Hamilton - nuclear
N
nuclear... [7] 181/9
181/9 181/11 181/21
182/22 183/7 183/18
number [28] 2/17
18/5 20/18 45/9 46/24}
59/21 62/15 62/17
62/20 67/23 71/17
77/7 91/10 92/25
108/17 108/18 114/24)
115/6 115/10 140/21
142/20 144/12 145/1
163/13 167/24 171/12)
175/23 176/17
number 1 [1] 140/21
number 4 [1] 45/9
numbers [1] 123/22
[e)
objection [1] 150/19
objective [1] 126/22
objectivity [5] 90/21
90/23 91/5 91/14
143/12
observations [1]
159/17
obvious [2] 43/18
104/6
obviously [50] 37/11
47/19 48/4 56/10
66/15 91/6 97/3 97/4
97/5 97/5 103/8
103/12 105/17 105/20
105/23 108/3 108/4
108/8 108/14 108/24
112/25 118/5 118/6
125/23 126/7 126/22
126/25 130/10 131/3
131/16 131/19 131/20
132/17 136/3 139/18
139/20 140/2 141/4
141/20 143/19 156/16)
157/15 158/4 158/17
162/3 167/5 167/6
168/3 168/11 168/14
occasional [8]
119/15 119/21 119/25}
120/2 120/6 120/9
121/3 121/7
occasions [1] 47/5
occupied [1] 171/11
occurred [3] 100/18
121/8 138/20
October [16] 20/23
100/18 104/25 105/6
111/11 111/15 111/16}
111/24 114/6 123/14
125/19 127/10 129/1
134/15 163/23 164/11
odds [1] 51/11
off [3] 119/15 130/22
135/19
offered [1] 58/13
office [279]
Office's [13] 11/13
12/12 34/22 52/17
52/25 59/22 59/24
66/5 115/14 149/10
151/2 165/3 165/10
Officer [1] 18/2
officers [1] 26/25
offices [6] 10/18
17/20 18/7 18/9 163/5)
166/17
official [1] 128/13
officials [10] 89/22
90/4 90/12 90/18
138/18 139/9 142/13
142/13 156/20 156/21
officials' [1] 147/22
often [1] 180/14
Oh [2] 52/3 132/2
okay [17] 80/23
82/24 87/16 129/11
132/2 137/11 159/10
163/10 163/14 163/18
164/6 164/13 164/14
165/13 165/22 166/24)
170/12
older [1] 55/1
Oluwatosin [1] 135/5
on [392]
On-Boarding [1]
97/21
once [4] 10/19 35/8
136/18 141/9
one [74] 1/19 2/11
9/2 9/23 10/1 10/3
19/5 19/10 21/14
25/12 26/16 34/5 41/1
41/2 41/6 42/22 43/16
44/17 46/11 55/14
61/19 66/4 66/24
66/25 68/2 70/9 73/5
74/15 75/7 76/4 77/12
77/12 78/1 78/22
83/15 83/24 84/11
95/6 95/7 95/8 105/3
105/20 109/18 119/15)
123/15 129/8 129/25
131/11 134/20 135/6
137/19 138/1 142/10
144/15 145/21 147/3
151/22 151/23 152/14)
154/14 163/13 165/24)
166/4 167/9 167/23
169/14 172/22 173/2
174/11 175/10 176/3
176/18 180/8 182/5
one-off [1] 119/15
ones [4] 55/1 101/17
120/6 155/23
ones’ [1] 106/20
ongoing [5] 9/6
18/23 133/3 134/18
154/20
online [1] 71/21
only [29] 15/12 21/22
48/24 50/17 61/25
89/9 103/20 106/2
106/5 108/15 112/25
113/24 120/18 122/9
132/10 145/1 159/7
169/24 172/8 174/16
176/2 181/8 182/12
182/13 182/23
onwards [3] 14/11
19/16 41/3
open [6] 30/12 43/19
73/18 80/5 128/21
144/17
operated [1] 46/21
operates [2] 12/5
163/17
operating [6] 12/19
14/5 14/7 91/2 161/7
166/11
operation [3] 18/22
155/13 156/24
operational [17] 57/5
57/9 59/2 59/9 59/18
101/7 101/16 114/10
155/17 156/13 156/25I
157/3 157/11 157/15
167/20 178/18 181/5
operations [6] 12/2
14/4 52/25 59/23
156/18 182/10
opine [1] 150/13
opinion [11] 7/12
22/15 56/22 58/9
58/12 63/22 64/11
64/16 64/17 110/22
150/4
opportunity [10]
101/12 102/3 112/3
112/20 112/21 113/2
113/7 114/3 154/7
158/21
opposed [7] 13/11
26/7 65/21 68/2 106/3
106/7 151/7
optimism [1] 46/11
option [20] 63/9 63/9
63/9 63/10 63/11
63/15 158/15 158/23
160/8 179/1 181/8
181/8 181/9 181/10
181/11 182/22 182/23}
183/7 183/15 183/18
option A [1] 63/9
options [13] 7/2
43/16 81/20 114/12
155/1 155/4 155/19
155/19 155/20 158/3
176/17 181/20 183/16}
or [237]
oral [4] 31/11 94/9
100/15 134/12
orally [1] 24/24
23/20 41/8 46/19 47/5
order [5] 57/1 127/3
131/24 172/2 174/10
ordinary [1] 180/11
organisation [11]
71/15 75/10 117/17
117/22 117/25 129/12}
152/1 156/19 161/9
161/24 181/4
organised [1] 163/23
original [4] 93/11
98/22 147/5 147/6
originally [3] 100/22
146/16 146/21
ostensibly [1] 165/2
other [46] 4/5 8/18
8/20 10/3 10/20 11/21
33/23 34/17 50/10
52/7 61/24 63/7 71/13)
74/4 75/8 79/11 80/18
85/19 97/19 100/8
105/21 105/25 106/7
115/18 115/21 141/17
144/12 145/1 145/8
148/14 155/12 158/5
158/8 162/14 165/8
171/4 174/10 175/5
175/6 177/15 177/21
178/21 181/10 181/17}
181/20 182/14
others [12] 40/13
74/16 84/16 92/11
114/23 116/5 138/22
148/13 149/23 150/2
174/23 179/7
otherwise [4] 5/15
25/12 31/6 84/1
our [34] 5/16 11/19
13/7 19/1 34/15 36/25]
40/1 49/17 51/2 51/9
53/17 53/17 53/23
58/14 62/21 63/22
63/23 63/25 64/23
66/4 66/20 67/9 67/17,
67/22 67/24 69/22
69/23 73/1 81/17 83/5
83/18 122/25 149/25
17119
ourselves [1] 123/6
out [49] 9/2 19/9 21/2
22/24 23/2 27/10
28/13 32/15 34/6 35/3)
37/2 38/22 40/24
47/23 48/2 49/3 50/24)
54/17 54/18 55/20
58/15 59/14 63/4
69/20 76/6 85/5
111/18 125/25 133/14I
133/15 133/21 133/22}
143/16 146/5 146/21
155/2 155/23 159/12
163/25 167/21 168/5
169/12 170/10 173/9
173/20 173/21 174/19}
178/20 182/4
outcome [8] 13/15
54/5 56/14 57/2 68/7
68/12 113/16 163/8
outcomes [3] 113/17
162/1 173/2
outline [1] 92/16
outlined [1] 102/10
outlining [1] 83/2
outrageous [1] 138/7
outside [2] 10/13
60/15
over [36] 11/16 45/14
51/12 57/12 59/4
59/11 77/2 83/10
88/19 93/15 93/23
100/6 102/21 103/1
104/18 110/9 111/13
114/19 115/5 125/21
126/13 126/16 130/21
136/22 139/3 143/4
146/3 146/7 147/2
152/16 156/3 156/7
160/22 165/9 170/7
170/7
over-confident [2]
126/13 126/16
overall [7] 38/17 49/8
55/10 106/24 126/2
126/4 130/16
overlap [1] 4/1
overseeing [2] 13/25
14/11
oversight [3] 15/11
26/18 157/24
overstating [1] 79/2
overturned [2] 77/9
175/24
overview [4] 54/16
87/17 132/24 134/1
overwhelming [1]
127/19
own [7] 15/14 68/2
161/24 169/11 173/12)
173/15 181/2
owned [4] 178/9
178/23 180/18 181/10}
owner [1] 168/22
oxygen [1] 81/15
Pp
pack [1] 164/10
page [88] 1/20 2/7
11/7 11/16 15/1 17/11
18/16 20/19 22/3 24/4)
29/19 29/20 32/13
33/13 33/13 42/10
44/4 44/12 45/9 46/15
49/7 50/20 51/13
52/14 54/15 55/16
56/19 57/12 58/24
59/4 59/5 59/11 61/16I
65/1 65/4 68/25 70/5
78/8 78/8 82/25 87/3
90/14 90/15 92/13
(67) nuclear... - page
Pp
page... [44] 93/13
93/15 93/23 94/22
97/18 98/10 99/10
100/14 102/12 105/3
111/13 114/7 114/19
115/5 115/7 119/7
119/17 123/18 123/20
123/20 124/18 127/7
129/24 129/25 135/1
135/2 136/10 136/11
142/25 143/4 145/20
146/3 146/7 147/2
152/13 155/2 158/25
159/11 163/21 164/8
164/19 165/9 165/9
170/15
page 1 [2] 54/15
164/8
page 10 [1] 164/19
page 100 [1] 29/20
page 101 [1] 29/19
page 11 [1] 165/9
page 12 [2] 119/7
163/21
page 13 [2] 22/3
12717
page 16 [1] 24/4
page 18 [1] 20/19
page 2 [9] 32/13 49/7
50/20 51/13 56/19
99/10 114/7 129/24
152/13
page 20 [1] 52/14
page 21 [1] 145/20
page 24 [1] 61/16
page 25 [2] 65/1 65/4
page 28 [1] 170/15
page 29 [1] 44/4
page 3 [3] 33/13
58/24 78/8
page 30 [1] 1/20
page 31 [1] 142/25
page 32 [2] 123/18
123/20
page 33 [1] 18/16
page 35 [1] 2/7
page 37 [1] 124/18
page 4 [5] 55/16
90/14 90/15 135/1
155/2
page 5 [3] 11/7 68/25
92/13
page 6 [3] 15/1 98/10
115/7
page 7 [2] 59/5 97/18
page 70 [2] 158/25
159/11
page 73 [1] 87/3
page 8 [2] 17/11
102/12
pages [1] 167/11
paid [1] 75/19
paper [7] 43/13 44/1
48/20 111/12 114/6
164/9 176/17
papers [8] 21/22
26/22 28/2 28/10 29/5)
29/9 32/12 41/8
paperwork [1] 90/9
paragraph [99] 1/20
1/21 1/25 4/16 11/8
11/10 11/16 11/17
15/1 15/9 18/17 20/20
20/21 24/5 26/14
29/21 42/17 44/4 44/9
44/12 46/16 49/7 50/6
52/15 54/20 61/17
65/2 69/10 90/13
90/15 91/19 92/12
92/18 92/20 93/6 96/5)
96/7 97/17 98/9 98/12
99/12 100/13 102/11
102/13 102/16 102/24}
103/19 103/19 103/24)
104/5 104/6 104/14
105/9 106/14 107/2
109/1 109/3 111/13
112/2 114/20 116/19
117/6 117/14 118/9
119/6 119/8 119/9
119/17 126/9 127/6
127/7 128/15 135/2
138/23 142/24 145/19)
146/7 146/15 146/22
147/2 147/21 148/20
155/23 156/1 158/25
159/12 159/13 163/20)
163/21 164/19 165/9
169/2 170/14 170/16
170/23 172/6 173/5
173/5 173/17
paragraph 1.2 [1]
114/20
paragraph 11 [3]
100/13 102/24 112/2
paragraph 12 [3]
90/13 90/15 103/24
paragraph 125 [1]
155/23
paragraph 126 [1]
128/15
paragraph 13 [1]
92/12
paragraph 14 [4]
11/8 11/10 92/18
92/20
paragraph 15 [1]
93/6
paragraph 16 [1]
11/16
paragraph 17 [1]
15/1
paragraph 18 [2]
15/9 156/1
paragraph 184 [1]
29/21
paragraph 194 [2]
158/25 159/12
paragraph 2.1 [1]
26/14
paragraph 2.2 [1]
117/14
paragraph 2.3 [2]
118/9 119/8
paragraph 20 [1]
97/17
paragraph 23 [2]
96/5 103/19
paragraph 24 [2]
102/11 104/6
paragraph 25 [1]
104/5
paragraph 26 [1]
104/14
paragraph 28 [1]
105/9
paragraph 29 [1]
106/14
paragraph 3.3 [1]
164/19
Paragraph 3.6 [1]
165/9
paragraph 30 [1]
107/2
paragraph 31 [1]
109/1
paragraph 33 [1]
119/17
paragraph 34 [1]
126/9
paragraph 35 [3]
111/13 163/20 163/21
paragraph 36 [2]
50/6 119/6
paragraph 37 [1]
24/5
paragraph 38 [2]
127/16 127/7
paragraph 4.3 [1]
49/7
paragraph 41 [1]
20/20
paragraph 43 [1]
52/15
paragraph 48 [4]
135/2
paragraph 50 [1]
61/17
paragraph 52 [1]
65/2
paragraph 57 [1]
169/2
paragraph 58 [1]
145/19
paragraph 63 [1]
44/4
paragraph 65 [2]
1/20 146/15
paragraph 66 [2]
44/12 146/22
paragraph 69 [1]
147/2
paragraph 7 [1]
42/17
paragraph 71 [1]
147/21
paragraph 73 [5]
18/17 148/20 173/5
173/5 173/17
paragraph 78 [2]
170/14 170/23
paragraph 8 [2]
98/12 99/12
paragraph 88 [1]
142/24
paragraph 9 [2] 4/16
91/19
paragraphs [4] 33/16
107/2 154/13 164/18
paragraphs 124 [1]
154/13
paragraphs 30 [1]
107/2
parcels [3] 4/19 12/8
75/25
pardon [1] 5/12
Paris [1] 5/4
Parker [29] 2/1 4/17
20/5 28/13 29/24 32/6)
37/2 37/15 38/13
38/17 39/4 43/11 44/7
44/14 44/23 45/3 60/8
60/22 60/25 61/12
61/14 73/10 77/21
78/2 101/5 109/2
138/25 146/4 153/7
Parker's [9] 20/2
28/7 28/8 30/12 30/14
34/20 35/11 36/19
44/18
Parliamentary [10]
88/7 88/20 88/23
89/11 89/15 91/18
96/17 108/11 132/20
164/12
Parsons [1] 149/23
part [28] 2/25 9/25
10/4 10/19 11/12
18/10 18/14 20/15
20/17 21/22 26/22
38/16 49/4 69/22
69/23 84/21 87/13
89/25 104/8 114/1
125/2 131/13 131/15
150/2 151/17 151/20
151/25 152/10
Participant [1] 76/19
Participants [1]
159/7
participate [1] 64/15
particular [46] 19/2
83/15 89/23 91/3 91/3)
102/8 102/20 102/24
102/25 103/3 103/5
106/3 108/14 108/16
110/14 111/7 113/10
116/22 116/22 117/5
120/8 120/14 122/2
122/3 126/1 126/1
126/7 126/15 126/17
127/3 127/4 130/12
130/19 136/1 136/25
137/9 144/7 144/12
145/9 156/15 158/23
160/19 164/18 173/10)
174/8 177/22
particularly [9] 79/22
103/6 103/11 110/9
120/10 122/2 145/6
151/7 174/3
parties [1] 51/6
partly [1] 137/16
partners [1] 163/4
partnership [2] 69/5
69/7
parts [3] 50/24
106/25 126/1
party [1] 37/11
passed [2] 106/17
179/15
password [3] 94/11
94/12 98/23
password-protected
[1] 94/11
past [8] 12/1 12/25
13/3 13/14 51/12
81/23 136/22 137/22
patently [1] 76/13
Patrick [11] 76/23
77/13 77/4 77/6 162/22)
175/10 175/19 175/20)
175/22 185/6 185/15
Paula [11] 101/5
105/8 105/15 105/17
106/12 107/1 107/4
107/17 107/24 108/15}
112/9
pause [2] 6/21 35/9
Pausing [5] 30/7
30/23 40/25 60/18
133/23
paying [1] 167/16
payments [1] 75/24
payout [1] 49/19
penalised [1] 84/2
people [18] 17/25
18/4 63/20 69/22 71/1
72/6 84/1 113/3 116/2I
120/16 125/19 143/21
145/1 148/14 156/8
171/21 173/11 174/6
per [8] 4/9 53/14
53/15 72/12 75/7 76/5I
76/8 76/11
perceive [1] 174/6
perceived [1] 133/3
percentage [3] 15/22
15/23 53/12
(68) page... - percentage
P
perception [4] 41/17
41/20 53/8 53/19
perform [2] 113/23
118/12
performance [6] 8/19)
9/2 9/6 9/14 35/7
36/19
performed [1] 177/19)
perhaps [4] 126/13
127/20 137/18 140/8
period [13] 9/9 9/11
9/24 23/19 69/15
74/20 91/17 100/6
100/9 110/9 111/7
113/22 127/1
periodic [1] 83/15
periods [2] 165/20
171/13
Perm [1] 95/10
Permanent [13]
10/20 10/22 34/13
93/20 94/3 101/24
134/10 144/19 147/25}
151/11 154/2 158/11
170/7
person [8] 6/11
17/23 17/24 144/6
169/14 169/23 169/24
171/14
personal [2] 115/21
144/15
personally [5] 52/6
62/5 150/15 172/25
183/8
perspective [11] 5/9
5/10 5/11 5/13 16/5
16/12 16/14 16/16
57/5 113/18 114/2
pessimistic [1] 65/11
phase [3] 54/18
71/11 71/12
Phase 2 [1] 54/18
Phase 7 [1] 71/12
phone [5] 37/13 45/3
45/4 78/2 152/16
phrase [4] 23/15
117/24 172/18 183/21
physical [1] 115/15
physically [1] 29/12
pick [1] 157/7
picking [2] 76/4
111/23
picture [3] 85/1
178/21 180/16
piece [1] 55/21
pieces [2] 42/20
166/3
place [10] 36/15 63/3
66/18 100/23 104/25
127/17 128/3 151/6
159/22 176/24
places [1] 14/25
plain [1] 22/16
plan [3] 112/10
112/19 153/9
planning [11] 46/12
52/13 56/20 57/16
82/11 112/7 112/24
114/14 114/11 123/17
127/17
plans [3] 94/8 101/11
101/21
play [1] 113/20
played [2] 120/18
179/9
player [1] 12/8
players [1] 118/1
plays [1] 109/7
plea [1] 32/25
please [132] 1/10
1/20 2/6 9/24 11/7
11/17 14/25 17/9
17/11 18/16 20/19
21/11 22/3 24/2 24/4
26/11 28/6 29/15
29/19 29/20 32/5
32/13 33/13 39/1 39/9)
40/11 44/3 44/3 44/12
45/1 45/7 45/9 46/10
46/15 48/18 48/19
49/7 50/19 50/19
50/20 51/13 52/12
52/14 54/6 54/16
55/16 56/16 56/19
57/16 57/25 58/25
59/4 59/5 60/7 61/16
65/1 65/5 68/22 68/25)
70/5 78/7 78/10 86/15)
86/18 87/4 87/17
89/14 90/14 90/15
92/13 93/9 93/10
93/11 93/15 93/17
93/18 93/24 94/10
94/22 95/3 96/19
97/17 98/9 99/6 99/7
99/11 100/13 102/11
102/23 104/18 111/14)
111/14 114/5 114/7
114/19 115/5 115/7
119/6 119/17 123/3
123/13 123/16 123/19)
124/1 124/11 127/6
131/21 132/4 132/10
132/11 133/21 134/25)
135/1 135/11 138/21
142/24 143/4 145/19
146/3 146/7 147/2
149/21 152/12 152/13)
154/11 155/3 159/1
159/11 163/20 164/19)
165/9 174/13
pleased [2] 108/22
131/13
plenty [1] 107/4
pm [7] 86/10 86/12
123/8 123/10 162/17
162/19 184/12
point [35] 12/3 41/11
44/5 66/10 68/5 70/6
84/24 106/21 109/18
110/10 110/14 115/3
119/18 125/13 127/10
129/15 135/12 136/20
136/23 138/13 139/6
139/13 140/14 140/15}
142/22 150/22 159/8
160/19 161/17 161/17
163/19 170/22 170/22
171/25 175/18
pointed [2] 63/4
169/12
pointer [1] 165/13
points [16] 25/14
40/16 42/9 42/15
52/22 66/4 91/11
119/24 121/16 125/7
126/7 134/11 139/2
146/5 156/1 168/1
POL [10] 79/1 148/3
148/4 155/12 155/14
155/17 163/23 178/2
178/8 178/9
POL's [5] 65/14 79/8
134/12 134/21 156/2
POL00006357 [1]
21/11
POL00006380 [1]
48/19
POL00006753 [1]
45/1
POL00006754 [1]
54/6
POL00006763 [1]
56/16
POL00021586 [1]
68/22
POL00022976 [3]
114/5 123/15 164/8
POL00024270 [1]
26/11
POL00024913 [1]
32/6
POL00025908 [1]
57/15
POL00104107 [1]
40/11
POL00111699 [1]
78/7
POL00258369 [1]
50/19
POL00259978 [1]
178/5
POL00362996 [1]
17/10
POL00392634 [1]
60/7
policy [8] 46/21
89/23 90/4 91/20
141/20 157/1 157/12
157/13
pools [1] 89/17
poor [1] 56/9
portfolio [10] 90/16
91/20 91/21 92/1
108/19 131/14 144/11
144/13 145/7 167/25
Portland [4] 82/1
82/2 82/5 82/6
posed [1] 14/12
posited [1] 45/11
position [37] 3/11
3/12 19/11 21/17 22/1
49/12 49/23 50/2
53/10 53/11 64/20
66/19 69/4 69/11 73/4)
79/17 82/12 107/6
116/21 118/3 121/17
125/20 127/16 128/24}
134/17 149/9 152/2
153/18 155/15 157/3
159/19 160/5 165/3
169/18 172/12 172/17}
181/2
positive [9] 69/6 70/3
72/22 73/10 73/19
74/13 74/19 109/5
109/14
possibility [1] 119/23]
possible [13] 20/25
33/19 33/24 45/15
45/22 63/19 72/19
73/17 81/18 107/25
132/23 136/6 145/8
possibly [4] 9/23
10/3 10/15 107/21
post [287]
post-2016 [1] 44/11
post-Horizon [1]
65/5
postal [7] 9/22 10/5
10/7 92/4 92/14 104/9}
105/21
postmaster [7] 57/3
59/20 68/25 69/17
104/21 165/5 165/18
postmaster's [1]
164/25
postmasters [14]
69/4 70/9 70/11 71/2
114/23 115/1 115/11
118/17 121/14 122/10}
131/1 146/24 154/22
182/9
posts [2] 140/20
171/13
potential [13] 57/1
57/10 105/13 113/16
126/19 128/7 128/19
129/10 129/20 129/20}
130/7 133/7 155/1
potentially [14] 44/2
91/1 101/17 120/21
121/13 128/10 129/4
130/24 131/1 1341/1
131/8 157/8 176/18
180/18
power [1] 159/23
powers [5] 59/5
160/22 172/11 175/15}
178/1
PQs [2] 178/7 180/15
PR [1] 82/2
practice [5] 3/16 27/8)
72/10 135/25 136/2
pre [1] 97/1
pre-empting [1] 97/1
precision [1] 162/24
predicting [1] 66/10
Predominantly [1]
13/1
prefer [1] 70/11
preferential [1] 76/3
preoccupation [1]
24/20
preparation [1] 65/2
prepare [1] 105/13
prepared [4] 39/10
42/25 54/10 162/11
preparing [2] 21/15
90/9
present [3] 6/10
25/12 81/16
presented [7] 21/22
56/21 63/8 64/1 85/2
85/4 183/17
preserving [1] 24/21
press [6] 79/7 79/17
79/25 82/15 82/17
83/11
pressure [1] 156/2
pressures [1] 145/8
presumably [4] 22/8
63/10 67/5 78/23
presuming [1] 82/6
pretty [4] 61/5 108/20
118/3 167/16
previous [3] 19/5
132/18 133/19
previously [3] 17/1
34/23 128/17
PRICE [11] 86/17
86/21 141/14 142/11
142/17 159/2 163/7
176/4 178/19 183/25
185/11
Price's [1] 169/21
principle [5] 9/9
13/23 49/20 71/3
175/4
prior [9] 3/23 6/2
10/16 19/11 19/22
23/23 113/1 117/2
150/8
priorities [1] 5/3
prioritised [1] 57/6
priority [1] 156/3
private [27] 6/3 18/23
60/16 60/21 60/25
(69) perception - private
P
private... [22] 61/12
61/13 83/20 83/23
89/19 89/20 90/7
93/20 94/21 94/25
95/5 95/23 97/12
117/15 117/23 135/6
136/9 137/2 139/10
141/21 143/1 152/14
privilege [2] 24/21
30/15
privileged [4] 44/19
94/7 98/4 134/6
proactive [1] 107/15
probability [2]
133/15 133/21
probably [8] 18/8
23/22 40/1 137/22
138/9 147/3 169/3
169/4
probing [1] 120/20
problem [5] 108/24
119/20 167/21 168/9
172/23
problematic [2]
122/20 165/17
problems [5] 14/16
79/4 93/3 118/14
176/7
problems’ [1] 119/12
procedural [1] 51/11
proceed [2] 64/11
68/3
proceedings [2] 24/7
24/13
process [7] 9/11
70/17 70/20 76/2
129/15 162/5 183/22
processes [6] 6/20
6/22 6/22 51/7 132/25
156/10
produce [1] 59/13
produced [3] 28/23
58/2 85/9
product [1] 14/6
profess [1] 174/4
profession [2] 6/10
63/20
professional [3]
74/11 83/13 87/18
professionals [2]
53/5 53/8
profit [1] 8/10
progress [2] 15/16
155/12
progresses [1]
135/13
progressing [1]
140/13
progression [1]
149/19
Project [3] 41/2 41/2
44/10
projects’ [1] 132/7
promised [1] 39/9
pronged [1] 49/24
proof [1] 11/23
proper [3] 69/7
127/17 172/2
properly [3] 79/10
140/22 177/19
proposal [1] 70/11
proposals [2] 70/8
75/1
proposed [4] 100/22
101/1 124/9 146/21
proposition [2] 67/13)
69/8
prosecuted [4] 77/8
115/17 116/2 180/19
prosecuting [1]
117/11
prosecution [2]
22/11 117/15
prosecutions [6] 6/3
17/6 18/23 32/14
32/16 117/23
prospects [1] 67/17
protect [3] 79/1 79/8
79/17
protected [2] 94/11
98/23
protecting [2] 9/17
156/7
protects [1] 134/6
protocol [10] 94/8
97/3 97/20 97/21 98/4
98/13 99/14 134/6
134/12 161/18
provide [16] 17/14
25/20 26/18 32/12
44/24 55/19 77/22
104/11 107/4 107/13
107/24 127/20 134/12)
137/19 138/1 147/1
provided [36] 20/15
21/1 21/4 21/9 22/18
24/16 24/23 25/1 25/3
25/5 28/2 28/11 29/5
29/9 29/14 29/17 30/1
31/11 35/24 39/15
70/4 83/24 89/18
92/16 96/6 98/14
99/15 99/18 104/10
104/20 104/24 105/4
114/17 127/15 130/15)
159/14
providing [5] 1/15
29/23 86/24 139/11
143/9
proving [1] 83/25
public [6] 81/14
131/18 155/13 179/12)
180/6 180/8
publicly [1] 178/23
published [2] 2/16
87/12
purely [2] 5/15
144/20
purpose [7] 2/17
27/19 50/13 51/10
52/10 100/15 111/24
purposes [5] 1/24
26/16 51/8 87/9
130/17
pursue [2] 6/3 17/6
push [3] 71/25 72/5
1341/7
pushed [2] 147/4
147/11
put [17] 31/9 31/17
53/11 53/16 62/16
66/4 73/2 91/15 94/16
96/13 97/5 127/4
128/3 137/8 141/11
168/5 174/17
putting [1] 141/17
puzzlement [1] 44/18
Q
QC [9] 37/1 38/7 39/6
42/23 42/24 45/6
54/14 54/14 134/3
QC's [14] 34/20
34/25 35/12 35/16
36/11 36/22 37/4 38/8
39/10 98/16 99/2
99/17 99/24 102/6
QCs [3] 52/1 56/21
107/7
QCs' [1] 55/25
qualifications [2] 6/6
6/16
qualified [2] 174/6
174/7
quality [1] 56/8
quantum [1] 128/21
quantums [1] 130/24
queries [1] 71/21
question [34] 16/10
17/2 28/17 30/18
30/23 31/10 36/17
42/20 47/12 63/1 75/5)
80/17 81/8 81/20
82/14 84/11 117/19
120/4 120/13 121/7
129/2 129/2 130/13
140/21 141/7 141/8
142/10 160/18 166/1
167/1 174/12 175/2
176/9 182/19
questioned [11] 1/9
31/4 77/4 86/17
162/25 175/20 185/4
185/6 185/11 185/13
185/15
questioning [3]
63/24 129/9 169/21
questions [41] 1/17
1/24 2/18 14/24 46/10}
58/6 71/10 76/17
76/19 77/7 80/7 81/21
85/19 85/21 86/22
107/10 112/22 113/3
113/13 113/13 113/14}
113/15 114/4 139/25
144/9 157/19 159/6
159/8 162/7 162/10
162/13 162/22 163/7
163/13 164/19 168/4
175/8 176/4 183/1
183/4 184/4
quick [1] 80/23
quickly [11] 27/12
27/13 27/16 28/5 50/9)
69/12 71/24 108/20
136/5 170/19 176/4
quite [19] 9/16 19/8
24/17 25/10 53/16
85/7 92/6 96/11 138/4
140/2 148/5 148/6
167/11 168/6 169/7
171/13 171/14 171/15)
176/4
quote [1] 105/10
R
radar [1] 167/20
radical [1] 158/1
RAG [1] 58/17
raise [4] 26/8 152/19
176/11 177/22
raised [12] 40/16
42/9 44/15 47/9 47/12
81/20 105/11 109/22
138/9 144/25 177/8
178/19
raises [1] 105/10
ran [1] 87/20
random [1] 144/2
rang [1] 2/1
range [4] 91/13 91/20
155/4 155/4
rare [1] 47/5
rated [1] 134/21
rather [14] 19/17
49/19 66/12 109/11
111/2 121/16 135/17
137/17 138/3 139/18
143/3 145/1 145/11
148/17
rating [3] 133/14
133/15 133/16
rationale [3] 34/23
62/21 63/7
re [2] 79/2 81/21
react [1] 27/16
reaction [7] 60/6
61/8 145/17 145/21
148/13 176/23 176/25
reactions [1] 111/8
read [36] 21/15 26/3
29/9 29/18 32/15
39/21 43/5 43/18
48/12 54/10 56/8 69/2
69/20 72/18 73/13
73/22 78/24 96/2 96/8I
96/10 96/12 96/13
96/19 96/24 97/8 97/8
97/24 100/3 102/4
113/1 114/16 117/9
118/19 125/1 125/3
159/12
readiness [1] 54/11
reading [11] 19/12
48/6 57/25 58/4 58/12)
60/1 97/3 109/8 117/4
168/3 168/5
reads [1] 139/6
real [3] 165/23
165/25 167/1
realise [1] 20/22
really [23] 13/10 26/6
43/16 72/14 72/18
84/23 85/3 100/9
111/21 112/14 117/2
117/4 117/20 118/23
131/13 148/17 158/16)
169/10 180/6 180/15
181/1 181/18 181/20
reason [8] 62/7
100/23 104/19 128/20)
143/20 145/6 150/12
168/10
reasonable [1] 49/13
reasonably [1]
173/17
reasoning [1] 153/8
reasons [9] 62/13
62/15 62/17 62/20
62/24 63/1 63/14
65/13 67/23
reassurance [5]
101/14 102/4 112/4
127/2 148/3
reassured [1] 119/11
rebalance [1] 69/3
rebuild [1] 69/20
rebuilding [1] 73/20
recall [87] 3/24 4/4
6/7 6/12 9/10 9/14
9/15 9/22 10/11 10/18}
10/21 10/23 10/24
11/3 11/4 15/21 16/1
16/15 18/4 18/8 18/24
19/14 20/12 22/24
23/2 23/15 23/18 25/2I
25/7 25/8 25/9 25/13
26/20 26/23 28/1 29/8I
30/20 30/23 31/12
31/21 35/22 37/1 37/3
38/3 41/5 48/6 49/3
50/7 50/12 52/6 52/6
52/16 54/13 56/2
57/20 57/23 58/5 60/3
60/21 60/23 60/24
62/12 63/13 64/12
65/7 70/19 70/22
70/23 71/8 77/15 78/1
(70) private... - recall
R
recall... [16] 78/3
81/3 97/22 98/7 98/8
102/17 104/23 105/15
106/20 112/11 112/12
125/4 125/5 139/15
168/7 170/17
receive [9] 17/17
26/17 39/14 43/17
80/20 98/18 98/24
135/22 150/15
received [16] 1/22
38/14 39/18 44/6
65/10 80/21 85/15
90/12 92/4 93/7 96/15
104/23 111/10 111/15
144/8 154/9
receiving [10] 26/2
29/8 43/14 43/20 53/8
97/22 98/25 139/14
150/17 150/18
recent [2] 89/7 171/7
recently [3] 14/20
108/16 151/10
recess [1] 100/6
recipient [1] 154/19
recipients [3] 94/17
95/14 154/15
recognise [5] 121/19
121/25 122/18 122/19
145/7
recognised [2]
122/13 122/15
recognising [1] 69/4
recollection [33]
23/1 26/7 29/10 30/14,
30/17 31/5 31/18 32/1
35/25 36/25 37/9
39/17 39/23 43/3 43/4
43/14 43/17 43/20
43/23 43/25 45/23
45/25 46/5 47/18 48/1
48/5 51/25 60/5 61/2
61/4 64/13 71/5 72/11
recommend [1]
49/24
recommendation [1]
155/18
recommendations
[6] 34/6 39/11 74/25
162/2 163/9 163/15
recommended [2]
30/22 146/16
record [5] 2/17 29/18
38/17 144/2 177/10
recorded [5] 98/12
106/16 115/15 144/1
165/7
recording [1] 53/2
records [2] 59/13
59/17
recruited [1] 70/24
recusal [30] 61/15
61/18 61/25 64/3
64/12 65/12 65/18
65/23 65/25 66/5 68/3
139/5 139/20 141/14
143/19 145/18 147/13}
148/7 148/10 150/2
150/4 150/7 150/13
150/19 151/13 151/17)
152/18 170/18 176/6
176/23
recuse [8] 61/24
62/11 64/19 65/14
66/20 67/2 147/16
149/11
recused [2] 64/7
64/10
recusing [1] 64/2
Red [1] 58/19
redraft [2] 40/15 42/8
reduce [1] 180/8
refer [25] 4/19 4/21
15/19 19/19 19/21
21/24 23/9 24/20
26/16 31/1 33/16
37/18 41/24 42/7
49/15 61/17 64/2
65/23 93/6 96/4 119/7)
126/10 128/15 154/14)
173/7
reference [22] 2/17
8/12 15/24 20/5 26/20
26/21 26/23 27/7
36/25 38/6 38/7 87/9
95/16 96/7 99/7 99/20
118/18 120/2 123/15
164/11 173/17 178/4
referencing [1] 119/9)
referred [7] 9/1 32/8
37/20 71/12 97/20
156/12 176/19
referring [19] 6/22
7/3. 11/8 17/22 17/23
20/23 21/5 29/22 31/2
34/21 39/2 41/4 44/10
48/15 92/13 130/8
133/19 136/23 163/22)
refers [9] 17/11 22/7
30/11 33/14 36/1 46/6
50/21 152/15 155/3
reflect [6] 40/20
40/23 75/4 108/4
108/5 154/24
reflected [5] 24/25
25/6 25/10 74/25
178/13
reflecting [2] 97/23
131/12
reflection [2] 108/12
162/5
reflections [3] 18/17
147/1 158/24
reflects [1] 146/6
refusal [5] 107/13
137/18 138/1 138/5
138/14
refuse [1] 154/5
refused [1] 138/15
refusing [2] 138/10
153/21
regarded [1] 116/14
regarding [9] 20/1
22/18 32/7 41/12 44/7
69/17 92/17 102/18
166/1
regardless [3] 49/21
109/15 139/10
regards [5] 96/10
117/20 143/13 171/25}
174/3
register [5] 131/22
132/13 132/14 132/15}
134/21
regret [1] 75/18
regular [4] 135/25
136/7 139/18 140/4
regularly [2] 10/5
83/20
relate [1] 26/2
related [2] 89/25
128/22
relates [3] 7/4 132/11
152/17
relating [7] 10/25
46/7 103/9 124/12
124/19 132/14 166/6
relation [15] 34/19
35/11 92/25 97/2
102/9 103/2 105/24
112/18 121/11 125/12)
144/4 155/15 157/12
162/2 163/9
relational [1] 55/5
relationship [11]
12/19 54/22 59/6 59/8
69/3 71/18 72/20
73/22 74/1 74/3
142/21
relatively [6] 18/20
111/18 118/1 119/3
125/20 163/25
relevant [7] 21/25
59/15 89/10 104/16
105/22 137/5 139/12
reliability [2] 62/17
141/2
reliability/credibility
[1] 62/17
reliable [1] 90/20
reliant [1] 144/20
relied [1] 58/11
rely [3] 90/17 174/9
174/17
remain [1] 160/20
remained [1] 12/8
remarks [1] 12/17
remember [61] 6/11
11/4 11/6 20/14 23/22
29/11 39/24 57/18
61/3 61/8 61/11 61/13
62/7 62/9 62/9 62/10
63/3 63/17 63/25 64/4)
64/6 64/6 64/8 69/16
69/19 69/24 69/24
69/25 71/3 97/2 97/4
97/7 97/23 98/25 99/2,
99/4 100/5 100/7
105/17 105/17 105/18
105/25 106/1 106/22
113/12 119/11 126/11
126/18 130/12 137/3
148/11 148/11 148/12)
150/10 150/17 150/17}
153/21 158/5 158/6
168/7 172/6
remembered [4] 20/8)
39/24 97/4 106/2
remind [1] 84/24
remote [17] 23/9
40/24 41/12 42/2
45/11 45/14 45/15
45/17 45/21 46/1 46/2
46/8 48/2 78/3 79/15
81/4 85/1
remotely [4] 9/10
23/21 34/4 47/10
remove [1] 177/2
removed [1] 146/18
removing [1] 160/8
remunerated [1]
70/14
remuneration [1]
165/20
repeat [1] 84/6
repeated [2] 179/20
179/21
repeatedly [1] 179/7
repeating [2] 83/4
180/14
replacement [1]
74/16
replacing [1] 155/7
replied [1] 77/23
replies [1] 80/13
reply [2] 137/11
137/14
report [51] 21/6
28/19 29/12 31/21
31/25 32/2 33/17
34/25 35/16 35/17
36/1 36/11 36/22
37/17 37/22 37/23
38/1 38/4 38/8 38/14
38/21 39/5 39/10
39/17 39/21 40/21
41/4 41/7 41/16 41/18)
41/19 41/21 42/1
42/17 42/23 42/25
43/10 43/14 43/18
43/21 44/7 44/19
44/22 77/20 79/15
104/3 104/4 118/13
118/20 118/21 118/24
reported [1] 34/23
reporting [1] 79/18
reports [13] 20/24
21/1 21/3 21/8 41/1
41/8 41/12 48/6 48/7
48/11 48/11 48/16
TINT
reprehensibly [1]
145/24
represent [4] 7/20
84/22 173/11 175/22
representation [2]
69/1 132/5
representations [1]
83/13
representative [5]
151/24 160/3 161/4
170/3 176/22
representatives [4]
10/12 71/2 120/16
157/19
represented [1] 72/3
representing [4]
26/25 50/16 72/17
87/24
represents [2]
114/22 151/22
reputation [1] 83/25
reputational [5]
101/7 101/16 105/13
106/10 115/2
request [15] 20/17
21/13 24/18 25/16
28/14 32/2 94/19
100/12 112/9 128/1
135/15 135/24 136/16)
137/24 144/4
requested [7] 25/18
25/20 25/22 85/24
104/19 107/13 135/20)
requesting [1] 137/4
requests [2] 137/10
142/12
require [1] 5/16
required [9] 3/15 5/5
6/23 13/9 27/3 27/17
27/22 94/16 108/19
requirement [2]
12/18 75/17
requirements [3]
14/7 14/7 130/3
resistance [1] 108/2
resolution [1] 149/16
resolve [2] 51/4
156/23
resolved [1] 161/14
respect [10] 38/19
64/16 64/17 98/5
104/12 119/25 145/25)
156/12 159/17 178/2
respects [2] 122/8
126/21
respond [1] 144/9
responded [1] 84/9
(71) recall... - responded
R
51/14 51/22 60/2
68/22 80/25 83/1
responsibilities [5]
11/9 105/25 144/11
178/2 178/16
responsibility [14]
88/12 139/24 156/23
174/20 176/10 1814/5
responsible [18] 5/2
8/19 13/20 82/17
85/13 85/16 88/10
156/9 156/17 161/21
165/6 167/16 172/20
174/13
restricted [1] 110/18
13/10 31/10 32/18
93/1 115/1 137/25
resume [3] 86/3 86/4
184/7
retention [1] 43/7
return [3] 32/25
105/2 177/25
review [38] 9/15 20/2
20/5 24/14 28/7 28/8
28/9 28/10 28/14 30/3,
30/10 30/20 30/22
31/3 31/14 31/16 32/7
32/16 32/18 34/20
34/21 35/4 35/5 35/7
35/12 35/20 36/3 36/7
37/2 39/5 39/6 39/14
39/19 44/5 44/14
44/16 44/22 77/20
reviewing [2] 8/19
57/19
Richard [5] 10/15
136/12 136/14 137/11
137/21
rid [3] 179/2 179/3
181/9
right [63] 2/23 3/1
3/20 4/23 9/3 38/10
42/12 58/19 58/22
65/19 73/3 77/11 80/1
86/8 86/16 87/21
88/22 89/9 89/13 90/5)
90/6 90/8 91/22 92/2
93/21 96/8 100/17
106/7 124/2 124/7
124/20 126/3 136/25
139/25 142/10 142/16)
146/19 147/19 153/4
153/13 155/20 156/10
158/2 160/2 162/15
162/24 163/17 164/17)
164/20 165/15 168/6
response [10] 51/8
109/12 118/10 180/21
9/1 9/5 9/20 15/6 82/4
157/15 160/12 160/13)
82/20 84/7 84/10 85/8
result [8] 12/13 12/16)
175/9 175/25 176/1
182/13 183/24 184/8
184/9 184/10 185/8
right-hand [3] 124/2
124/7 124/20
rigorous [1] 155/9
risk [29] 12/1 13/4
13/25 14/1 14/12
45/11 46/14 57/17
85/5 102/21 102/22
102/25 103/1 104/7
122/13 128/9 128/22
133/3 133/5 133/23
134/21 137/21 155/11
risks [13] 13/4 13/13
13/21 101/12 101/22
102/18 103/8 125/10
125/12 132/6 132/7
132/10 155/9
roadshows [4] 69/9
69/20 69/24 70/2
Robinson [3] 45/6
54/14 79/14
robust [7] 68/19 81/6
81/8 82/13 82/13 83/6)
120/6
robustly [1] 81/1
robustness [5] 10/9
11/1 14/5 68/9 68/14
Rochester [1] 87/25
rock [1] 61/22
rock-solid [1] 61/22
role [44] 2/20 3/13
3/22 5/7 5/14 5/14
7/16 8/13 8/17 9/17
9/20 11/11 11/19 13/2
13/12 13/24 14/2
14/11 24/15 27/9
27/15 49/4 74/23 75/2
76/7 84/21 87/20
88/16 89/25 91/18
109/7 117/2 140/6
158/16 164/16 167/8
169/18 170/4 174/21
177/19 178/13 178/15)
179/8 179/18
roles [2] 4/5 11/8
Rolfe [6] 19/22 28/9
28/14 29/13 32/7 39/7
room [3] 25/5 120/16
126/25
rooted [1] 174/1
round [3] 54/22
73/16 136/19
round-up [1] 136/19
row [1] 132/22
rule [4] 20/17 21/13
114/14 133/8
Rule 9 [2] 20/17
21/13
ruling [1] 101/9
168/14 172/21 174/24,
130/18 131/22 132/13)
132/14 132/15 132/24}
run [2] 52/13 166/12
run-up [1] 52/13
s
safeguard [1] 94/12
safeguards [1] 94/6
safety [1] 32/23
said [54] 7/13 25/4
25/19 26/4 27/8 31/5
37/21 43/22 44/11
63/13 63/24 64/13
65/4 66/20 66/24
68/13 74/9 76/4 82/21
84/6 99/1 107/5
107/20 107/24 108/1
150/13 152/19 155/4
163/6 166/20 168/23
169/9 169/16 169/18
169/21 172/5 178/18
179/7 181/24 182/20
sake [1] 155/22
sale [1] 115/4
Sam [5] 95/4 95/5
135/6 135/8 163/2
same [6] 31/13 34/23
41/25 65/13 66/6
133/6
Sams [1] 135/10
sat [1] 16/25
satisfactory [1]
154/21
save [2] 15/6 178/4
savvy [1] 5/25
saw [8] 28/11 28/23
31/1 39/15 39/25 49/4
74/2 94/14
say [133] 1/21 4/16
6/1 6/21 7/15 8/25
11/10 11/18 15/3 15/9
17/21 18/18 19/12
19/14 20/20 23/8
23/12 24/5 34/1 35/14
37/14 38/1 40/14
40/18 40/19 41/3
41/14 42/7 42/7 44/1
44/4 44/9 44/13 45/18
47/6 47/18 48/14 50/7
51/14 51/20 52/15
53/11 53/17 53/25
54/3 54/23 55/2 56/9
57/12 57/23 61/8
61/19 62/1 65/6 65/20
65/24 70/13 73/9 85/6
90/15 92/14 92/23
96/25 97/2 97/18
98/10 98/17 98/24
100/5 100/8 102/7
running [5] 14/8 15/8
69/7 69/23 156/17
sadness [1] 172/8
45/15 47/20 48/1 48/9
52/7 53/21 62/13 63/8
114/13 122/23 137/16
138/18 143/10 143/17]
102/16 103/19 104/5
104/9 104/14 104/18
105/4 105/18 106/15
107/2 107/20 109/1
110/12 110/13 110/21
111/14 113/4 117/7
119/10 119/17 121/6
122/1 126/11 127/7
127/18 129/8 130/1
134/22 137/8 138/14
143/5 143/16 145/4
145/13 146/2 146/10
147/2 147/13 147/21
147/24 148/22 149/5
149/5 156/6 157/5
161/21 164/2 164/23
166/8 168/11 169/1
173/20 177/13 178/1
179/5 181/16
saying [28] 17/12
25/17 25/22 25/24
35/8 36/9 37/2 37/20
53/25 62/12 63/14
65/17 65/24 67/17
82/12 113/5 124/24
142/3 142/11 143/1
143/3 150/9 151/5
151/22 168/8 171/5
173/19 175/3
says [51] 1/25 21/18
21/20 22/4 22/7 22/13)
26/14 29/6 29/25
30/13 31/8 31/23
32/17 32/20 34/14
35/10 37/10 39/3
39/16 42/13 42/18
45/10 46/15 49/10
49/16 49/22 50/25
54/17 55/16 57/16
58/8 60/9 69/1 69/10
70/6 70/15 78/20
80/21 80/25 83/11
93/16 95/3 114/21
135/7 136/13 137/12
138/24 149/24 167/3
167/4 173/19
scale [1] 133/23
scathing [1] 150/25
scenario [1] 126/23
scene [3] 77/15 78/6
78/20
scheduled [2] 60/14
100/16
scope [3] 31/13
33/25 45/17
screen [24] 1/20 2/5
4/17 55/9 90/14 92/13)
93/10 97/17 98/9 99/7
102/11 114/5 119/6
123/13 129/23 131/21
134/25 138/21 142/24}
145/19 149/21 152/12
138/16 139/16 140/25}
169/18 170/23 172/25}
154/11 164/9
scroll [9] 78/8 78/9
78/16 78/17 80/11
81/9 82/24 94/23
133/17
scrolling [4] 95/3
124/1 124/11 133/21
scrutiny [7] 101/13
102/1 109/15 112/4
112/7 113/7 143/9
Sec [1] 95/10
second [27] 6/8
19/13 21/6 28/17
33/16 46/11 69/9
74/10 89/22 103/22
104/3 104/4 111/10
115/8 118/11 118/12
118/18 118/18 118/20)
118/21 119/10 136/20)
136/23 139/5 159/3
159/21 161/20
secondly [4] 43/18
46/6 47/12 177/25
secret [1] 45/13
Secretaries [3] 89/19
90/7 135/6
Secretary [35] 10/8
10/20 10/22 27/1
34/13 88/8 88/20
88/23 89/11 89/15
91/18 94/4 95/5 96/17
101/25 108/11 132/20)
134/10 136/9 144/19
147/25 151/11 152/14)
152/20 153/10 153/19}
154/2 154/18 158/11
161/6 164/12 170/7
176/14 183/10 183/12!
Secretary's [1] 93/20
section [9] 1/23
32/14 105/10 111/17
115/8 123/16 124/12
124/20 163/24
section 2 [2] 111/17
163/24
sections [3] 114/8
114/16 125/2
sectors [2] 5/23
91/20
secured [1] 16/18
securing [1] 66/9
see [108] 1/3 2/7 8/9
9/5 14/2 17/10 20/23
21/21 22/3 26/14 27/8I
28/19 29/13 29/21
30/11 32/9 34/11
35/23 37/12 39/3 40/9
40/12 42/10 42/11
42/12 42/22 43/2 43/5)
43/13 44/1 45/3 45/6
46/10 47/6 47/14
48/17 49/2 49/7 50/25)
51/13 52/3 54/8 54/9
54/14 56/18 57/16
(72) response - see
Ss
58/17 58/18 58/25
78/10 78/10 78/12
78/14 78/16 78/17
78/18 79/23 80/9
80/12 80/13 80/14
94/24 95/18 99/8
100/3 104/2 104/4
114/7 116/6 118/19
118/21 118/24 119/4
123/19 123/20 124/1
131/23 131/24 132/4
133/17 136/15 140/2
151/15 162/1 163/8
seeing [11] 29/8
29/11 29/12 33/9
40/15 42/8 57/20
57/23 58/5 125/6
139/7
seek [6] 49/13 76/23
101/14 102/3 112/4
147/16
seeks [2] 79/7 79/8
seem [2] 167/19
167/20
seemed [2] 107/10
139/4
seems [7] 79/6
131/11 133/18 139/9
152/15 166/24 175/11
seen [29] 21/8 26/22
31/4 31/20 31/24
35/24 36/1 39/17
41/18 41/21 49/6 60/2)
60/3 60/3 60/4 77/24
85/12 98/19 98/21
98/25 130/11 132/15
150/5 150/14 150/21
151/9 153/20 158/13
179/20
selected [1] 71/7
selection [2] 70/17
70/19
self [1] 11/14
self-sustainability [1]
11/14
sending [1] 95/11
senior [26] 2/21 4/2
4/9 5/8 5/18 7/16 8/17)
9/20 17/5 17/16 17/19
17/21 19/22 30/17
34/12 34/16 49/4
63/20 68/6 84/20
85/14 129/9 129/11
170/24 171/21 176/13)
sense [10] 120/18
see... [62] 57/17 58/7
59/5 60/18 68/23 77/9
80/17 81/9 82/7 82/24
83/1 84/1 86/13 94/24
132/22 133/13 133/15)
163/21 164/10 167/10)
167/11 175/24 179/22)
121/1 122/21 126/8
141/7 142/6 142/9
158/19 171/15 178/1
sent [19] 20/17 21/13
28/20 41/9 42/11
43/10 43/19 58/1
93/19 95/23 96/20
97/12 98/20 98/23
102/14 135/4 136/9
146/12 151/9
sentence [4] 19/12
19/14 21/5 61/21
sentences [1] 119/10
separate [4] 36/17
52/19 131/19 141/14
September [16]
19/10 22/23 27/11
30/6 35/19 48/20
88/25 89/3 94/9
100/17 101/14 105/8
108/15 109/18 109/25)
134/13
September 2016 [1]
27/11
series [1] 114/22
serious [6] 36/14
119/20 143/23 144/22)
181/14 181/15
servants [3] 89/14
89/18 168/17
serve [1] 88/19
served [4] 3/24 88/4
88/7 89/5
service [3] 14/6
127/14 131/19
Services [1] 75/23
serving [2] 88/23
89/6
session [2] 25/13
86/5
set [15] 21/2 40/25
49/3 58/15 77/14
78/19 84/18 108/17
146/5 146/21 155/2
155/23 161/1 161/12
179/22
sets [3] 32/15 41/1
78/6
setting [3] 111/17
163/25 180/1
settle [2] 49/24 50/3
settlement [5] 49/14
114/12 127/11 127/23}
155/16
several [4] 11/22
20/24 40/25 93/5
severe [3] 144/19
169/22 170/1
shall [2] 86/3 123/5
shame [1] 145/25
share [6] 36/21 36/22
37/23 94/19 161/22
177/20
shared [17] 35/1
35/18 36/4 36/12
44/20 79/20 97/11
132/18 132/19
shareholder [28]
9/18 10/13 75/21
82/22 84/22 93/14
101/13 102/1 112/4
113/7 131/22 132/12
132/15 151/24 152/1
152/9 161/4 161/24
170/2 170/2 176/21
181/4 181/11
shareholders [1]
179/2
shareholding [3]
7/20 8/3 8/8
sharing [3] 97/20
108/23 161/18
she [21] 19/25 20/4
25/3 25/4 30/12 31/8
31/23 80/14 80/25
81/19 95/6 108/22
139/7 152/17 152/19
153/6 176/8 183/14
she's [2] 81/9 82/11
shock [2] 40/23
41/14
shocked [3] 52/16
53/20 53/20
short [16] 22/5 25/12
40/7 86/11 89/6
104/20 111/19 123/1
123/9 133/10 159/5
162/18 164/1 171/13
174/9 181/20
short-term [1]
133/10
shortcut [1] 140/8
shortfall [3] 165/2
165/3 165/6
shortfalls [5] 59/11
59/17 115/14 166/2
167/16
shortly [7] 1/25 2/2
2/16 14/22 38/12 60/9
80/13
should [62] 1/12
16/20 25/17 25/20
25/22 26/10 29/20
33/7 33/10 33/18 35/1
35/18 36/12 36/16
37/17 38/18 39/21
41/16 41/21 42/20
43/11 44/20 48/17
52/9 54/17 54/19
54/25 55/2 58/11
63/24 64/11 70/13
71/4 75/19 76/12
76/16 83/1 86/6 86/24
94/15 103/6 110/11
36/16 37/3 37/8 37/18
38/5 38/14 44/8 44/16
7/18 7/19 7/25 8/4 8/5)
152/19 152/23 152/24
122/13 122/15 136/9
138/16 139/11 140/1
147/4 147/6 147/22
148/21 151/12 151/17}
152/10 153/3 157/24
169/9 169/12 170/4
170/8 175/16
should I [1] 138/16
shouldn't [6] 144/20
152/24 157/23 169/22}
169/24 170/8
show [3] 33/22
164/24 165/2
shown [2] 48/4 165/3
sic [1] 19/5
side [2] 42/12 83/18
sided [1] 55/14
sides [2] 91/7 114/24
sight [8] 21/6 92/10
103/22 112/10 118/11
118/13 118/18 119/10}
Sight's [4] 104/3
104/4 118/20 118/21
sign [3] 130/22
161/18 161/21
sign-off [1] 130/22
signature [5] 1/18
2/7 2/9 87/5 87/7
signatures [1] 94/17
significance [1] 48/9
significant [22] 12/23)
20/9 34/24 35/15
36/10 36/20 37/16
37/19 37/21 38/16
55/18 58/21 61/5
120/1 124/5 124/22
130/6 133/7 133/10
146/23 151/25 169/10
significantly [1]
12/22
similar [2] 24/11 59/4
Simon [1] 21/12
simple [4] 8/24 57/6
66/21 182/19
simplistic [1] 58/10
simply [3] 8/9 121/2
157/1
since [9] 77/8 96/16
98/19 99/18 158/4
162/5 162/5 167/8
175/24
sincerely [1] 109/12
sir [34] 1/3 28/18
28/23 29/2 29/22
29/22 38/24 38/24
40/1 40/5 40/9 74/5
76/18 77/5 85/21 86/2
86/9 86/13 122/25
123/3 123/7 123/11
140/24 142/18 159/5
162/7 162/16 162/20
163/1 175/17 175/21
183/13 184/1 184/9
Sir Jonathan [5]
28/18 28/23 29/2
29/22 29/22
Sir Wyn [3] 140/24
175/17 183/13
sit [1] 85/11
site [2] 17/15 18/6
sits [1] 134/5
sitting [1] 77/10
situation [8] 61/20
62/5 62/6 69/5 116/18}
117/20 117/22 170/24}
six [2] 3/23 88/19
skip [1] 83/19
slightly [4] 23/15
62/25 145/13 172/3
small [11] 1/19 62/19
73/2 88/11 115/10
117/24 118/1 125/14
166/17 166/21 167/2
snowball [1] 27/11
snowballed [1] 27/13
so [266]
so-called [1] 183/7
software [1] 118/15
solicitors [2] 50/3
57/24
solid [3] 61/22 111/3
111/3
solution [1] 49/11
some [61] 2/18 4/21
6/19 6/21 8/21 18/6
18/7 32/15 33/22 44/5)
45/23 49/9 56/6 56/11
58/1 58/6 63/18 63/19
67/6 68/20 69/9 71/10
72/6 73/2 73/7 83/4
85/5 88/16 92/16
96/14 105/24 106/19
112/6 115/12 115/16
116/2 116/8 117/24
118/15 122/7 122/8
122/8 125/22 126/20
128/12 130/13 131/8
136/8 140/8 140/24
144/15 146/5 146/16
146/17 159/6 159/16
162/14 164/15 168/4
174/17 174/18
somebody [3] 110/21
169/9 171/22
someone [6] 41/17
104/15 121/21 161/5
174/2 182/2
someone's [1] 64/17
something [40] 8/11
20/8 36/14 42/17 43/6I
48/4 75/3 75/18 85/6
96/25 97/4 100/12
110/23 116/14 120/25)
128/4 131/16 136/3
137/1 138/12 144/23
145/2 145/3 148/15
148/15 149/12 156/5
156/22 161/11 162/3
(73) see... - something
Ss
something... [10]
167/10 168/9 170/5
170/6 175/3 177/20
181/16 181/18 182/11
183/7
sometimes [2] 96/14
107/11
somewhere [1] 139/9)
soon [2] 24/7 139/12
sorry [26] 5/12 10/13
13/17 16/10 19/14
29/2 29/20 48/14 55/9
65/4 67/25 68/1 92/3
95/24 97/13 109/24
110/3 161/16 166/9
166/9 169/13 169/19
170/13 177/11 179/6
183/23
sort [70] 18/3 25/25
75/5 81/19 92/7 97/1
97/9 97/10 99/3 99/4
99/5 100/19 103/4
103/7 103/12 103/13
103/17 103/17 105/21
106/2 107/25 108/2
108/8 108/17 108/19
108/21 110/25 111/1
111/2 111/3 111/8
111/9 112/16 116/13
117/5 117/18 119/2
120/8 120/12 120/12
120/14 120/20 120/25}
121/17 122/24 125/21
125/25 126/5 126/18
127/5 130/24 131/12
135/16 137/5 137/9
141/21 141/24 143/15
145/15 158/13 159/3
161/16 167/7 168/19
169/14 170/9 171/3
173/22 182/7 182/25
sought [3] 57/2 58/15)
83/16
sound [1] 91/9
source [1] 30/12
space [1] 91/1
SpAd [1] 95/16
SpAds [1] 134/10
Sparrow' [1] 30/10
speak [12] 140/21
144/18 145/16 153/15
153/21 153/23 154/2
154/3 154/6 160/16
182/14 182/14
speaking [7] 31/11
64/6 65/5 89/17 106/1
145/1 146/5
specialist [1] 32/21
specific [19] 10/24
28/1 37/10 43/3 52/7
62/8 63/17 69/19
69/25 70/22 87/14
96/7 96/16 121/13
121/16 122/4 125/25
132/14 137/3
specifically [16] 8/12
9/14 9/16 25/7 38/1
38/3 41/24 60/23 62/9)
63/3 82/5 92/5 92/14
100/7 142/22 171/24
specifics [1] 15/4
speed [5] 71/20 94/1
108/20 134/16 172/1
spending [1] 76/14
spent [3] 2/25 126/25
172/15
split [1] 91/21
SPMs [10] 92/25 93/2!
93/5 119/14 119/22
120/3 120/5 121/4
121/20 146/1
spoke [1] 110/16
spoken [3] 34/17
139/20 153/19
spread [1] 62/19
spring [1] 176/6
staff [2] 80/18 121/22
stage [11] 24/12
40/19 45/21 69/17
84/14 85/2 107/16
126/12 130/15 147/14)
147/15
stages [4] 45/20
96/25 97/16 126/24
staging [1] 140/20
stake [1] 101/6
staked [2] 83/12
83/25
stakeholders [2]
144/14 144/16
stand [1] 66/22
standing [1] 24/8
stands [1] 2/15
start [9] 1/22 2/19
87/17 92/1 124/18
163/1 171/18 178/8
178/13
started [5] 12/15
19/8 27/11 74/16
140/9
starting [7] 29/20
93/11 106/14 114/7
123/18 158/25 163/19
starts [1] 93/12
state [16] 1/10 10/8
88/8 89/5 89/11
113/19 152/20 153/10
153/19 154/19 161/6
176/14 178/8 180/18
183/10 183/12
stated [2] 45/18
113/8
statement [92] 1/13
1/16 1/21 2/7 2/12
3/23 4/16 4/21 6/1
8/11 11/7 14/25 15/1
15/19 15/21 18/16
19/13 19/20 20/20
21/2 21/16 21/24 24/4
26/1 26/16 29/16
29/17 31/7 44/4 47/25
48/3 50/6 52/15 61/16
64/2 65/1 85/24 86/24
86/25 87/10 87/11
87/14 87/19 89/16
90/13 91/19 92/12
93/6 96/2 96/22 97/17
98/10 99/1 102/12
104/5 105/10 106/5
106/14 107/1 107/20
108/1 111/13 114/13
117/18 119/7 126/10
127/7 128/15 135/3
142/20 142/25 143/17]
145/19 150/9 154/13
155/24 158/5 158/14
158/25 159/11 163/20
163/22 169/1 170/15
172/5 173/5 173/7
176/19 177/9 177/12
182/21 184/3
statements [2] 31/22
155/14
states [1] 134/1
status [1] 24/7
statutory [1] 100/21
stay [2] 60/11 173/9
stead [1] 66/22
steer [1] 165/23
steering [4] 26/12
48/20 48/21 48/22
steers [1] 165/24
Stein [6] 162/22
162/25 163/2 178/19
182/20 185/13
Stent [4] 2/4
step [3] 85/5 85/6
146/23
Stephen [5] 93/13
94/24 136/12 137/13
137/20
stepped [1] 74/10
steps [4] 32/19 59/7
68/21 71/13
STEVENS [8] 1/9
38/23 40/3 77/15 78/4
85/20 86/3 185/4
stick [4] 155/16
still [5] 6/9 18/19
18/23 40/9 73/8
stop [9] 13/17 79/7
80/11 80/12 84/11
96/22 148/24 177/12
181/6
stopped [1] 149/2
story [1] 83/18
straightforward [5]
54/24 55/19 56/7
56/10 125/4
strategic [2] 12/3
180/1
strategy [37] 11/13
11/20 11/24 11/25
12/12 14/5 49/3 49/8
50/1 72/4 79/7 79/24
80/7 80/24 81/10
81/12 82/11 82/13
82/15 82/20 83/2 83/5
84/5 84/8 84/18 85/4
85/9 85/10 85/14
85/17 88/9 89/12
111/20 114/12 155/6
155/8 164/4
strengthened [1]
75/12
strengths [1] 165/14
stress [2] 31/20
109/7
stretch [1] 162/12
strikeout [2] 50/23
51/10
striking [1] 50/23
strong [18] 53/9
53/11 53/18 62/25
65/13 65/22 65/24
66/5 66/8 67/5 67/18
71/25 72/15 73/16
75/17 81/14 173/8
173/9
stronger [3] 72/5
75/10 165/11
strongest [1] 63/18
strongly [4] 37/12
66/3 68/11 72/18
structure [5] 91/5
159/17 160/25 161/8
173/3
structures [1] 159/22
struggle [1] 22/2
stuff [2] 167/11
173/25
style [1] 73/18
sub [4] 18/7 94/1
94/14 94/15
subcommittee [30]
26/13 26/21 26/24
27/5 27/9 27/15 27/19)
27/25 45/2 48/25 54/8
56/17 59/21 75/9
78/12 79/21 79/23
80/2 80/6 80/19 82/10
82/16 82/17 82/22
84/4 84/9 84/13 84/18
85/8 85/11
subject [8] 2/11 39/5
44/15 60/18 89/22
95/19 97/6 146/17
subjective [1] 53/16
submission [31]
93/24 94/19 95/9
95/19 95/20 95/22
96/3 96/8 96/8 96/10
96/21 98/2 98/12 99/6
99/9 99/23 100/4
100/13 102/15 102/24}
103/24 105/6 111/11
112/1 112/1 113/9
128/16 154/10 154/12!
154/14 158/3
submit [1] 136/18
subpostmaster [6]
16/7 16/15 18/8 33/22I
54/7 121/22
subpostmasters [23]
12/20 33/20 59/9
69/21 70/24 71/4
71/13 71/20 71/24
72/1 72/3 72/13 72/17I
72/19 73/21 77/7
115/12 115/24 121/8
156/4 156/7 163/3
175/23
subpostmasters' [2]
16/11 163/4
subsequent [2]
182/9 182/9
subsequently [1]
31/13
subsidiary [1] 126/5
subsidy [2] 180/6
180/9
substance [2] 66/13
66/14
substantial [2] 24/24
59/22
substantially [1]
12/18
substantive [1] 25/5
succeeded [1] 83/7
success [3] 53/13
67/18 156/2
successful [1] 57/11
such [18] 7/4 7/8
20/1 21/6 30/23 33/24
39/25 47/12 62/4
65/14 70/14 71/18
87/13 90/16 133/2
155/7 157/1 168/10
suck [1] 118/8
suffer [1] 165/1
suffered [2] 93/1
1415/1
sufficient [8] 4/12
5/19 33/2 74/7 76/12
76/16 86/6 159/20
suggest [4] 51/18
103/5 145/13 159/9
suggested [2] 33/17
108/23
suggesting [3] 84/23
85/3 85/7
suggestion [6] 36/18
46/20 69/14 126/19
147/15 150/12
suggestions [2] 34/3
110/20
suggests [1] 35/19
(74) something... - suggests
Ss
suicide [1] 115/22
suit [1] 60/20
sum [1] 159/19
summarise [3] 4/25
8/16 35/3
summarises [1] 58/9
summary [10] 27/24
31/14 38/22 55/19
105/1 106/18 114/9
114/19 154/17 159/25)
Superdry [3] 3/19
3/24 4/1
support [7] 49/2 72/4
115/12 116/8 118/16
128/1 148/16
supported [1] 61/18
suppose [7] 103/14
122/7 126/20 126/24
141/3 143/13 152/3
sure [18] 64/24 65/4
73/11 76/1 80/21
104/23 110/7 118/3
120/23 122/16 131/17)
139/11 149/15 156/8
157/7 158/16 168/16
171/22
surprise [2] 47/9
65/8
surprised [2] 64/21
149/10
surveyor [1] 87/22
survival [1] 9/12
suspected [1] 143/6
suspending [1]
165/18
suspension [1]
165/20
sustainability [3]
11/14 12/10 12/13
sustainable [3] 8/14
11/23 14/17
swift [21] 28/7 28/10
28/24 29/3 29/12
29/23 34/21 35/20
35/23 36/1 36/5 38/6
38/21 39/14 39/19
42/23 42/24 43/9
43/14 43/21 154/21
Swift's [3] 28/18 29/2
35/16
sword [1] 172/19
sworn [4] 1/8 86/16
185/2 185/9
system [39] 10/10
16/19 18/22 21/7 21/9
23/6 23/8 23/21 33/23
47/1 47/7 68/14 68/16)
68/18 71/19 79/9 81/6
82/12 83/22 92/17
93/2 93/3 115/4
115/14 115/24 118/14)
119/12 119/13 119/20}
119/21 120/3 120/4
121/11 161/7 166/11
166/11 166/12 169/15)
171/9
System’ [1] 103/23
system-wide [2]
118/14 119/12
systematic [2] 79/3
120/17
systematical [1]
122/7
systemic [3] 47/7
118/14 119/12
systems [4] 5/15
66/18 66/19 120/11
T
tab [2] 132/3 132/11
tab 2 [1] 132/11
table [9] 57/17 58/18
59/19 114/7 123/19
124/14 124/18 124/21
155/3
tackle [2] 170/12
170/14
tailored [1] 17/15
take [41] 32/18 32/21
34/19 35/11 40/1
41/15 45/20 51/22
52/10 59/7 66/24 75/4
76/20 77/1 82/11 83/3)
86/5 96/24 97/16
100/23 117/25 120/24)
127/17 151/17 151/20)
155/14 157/14 158/17)
158/20 159/9 160/24
161/15 163/20 164/5
172/20 175/14 176/2
176/4 178/3 178/3
184/7
taken [23] 36/15
38/18 53/2 67/6 67/19)
68/11 69/14 71/14
83/10 83/14 103/24
117/13 119/4 121/21
130/16 151/11 154/8
156/11 158/21 164/14)
177/4 182/6 182/18
takes [1] 76/2
taking [15] 63/3
87/19 91/9 104/16
117/2 117/23 118/25
121/2 151/24 152/10
167/8 168/3 171/3
172/15 178/20
talented [1] 73/8
talk [6] 66/14 81/19
116/24 157/9 171/4
175/12
talking [11] 13/17
20/12 35/5 35/6 38/2
61/2 81/10 85/10
140/18 170/15 170/17)
talks [1] 84/13
target [1] 49/17
taxpayer [3] 84/23
131/6 156/9
team [25] 11/14
13/12 13/15 13/20
14/9 15/6 17/19 17/22
18/4 18/5 27/1 85/4
90/5 93/14 110/16
132/6 136/21 136/25
137/2 138/19 141/20
144/18 155/11 156/16
158/12
Team's [2] 14/3
14/12
tech [4] 120/22
technical [6] 5/9 5/11
5/13 5/14 5/19 120/10
technology [2] 5/23
71/18
telephone [2] 44/6
101/5
telephone/video [1]
101/5
tell [1] 102/8
telling [3] 80/24
120/17 140/10
ten [2] 76/23 123/3
term [14] 6/8 15/23
35/22 53/5 55/6 59/1
59/6 59/11 74/10
123/24 124/10 124/17
124/23 133/10
terminated [2]
115/20 116/5
terminating [1]
165/18
terms [29] 3/24 8/11
8/24 16/9 16/17 23/5
26/20 26/21 26/23
27/7 55/22 57/2 57/8
66/21 72/3 73/24 74/7
90/12 104/7 120/9
125/10 130/8 133/24
134/23 146/11 160/2
160/5 163/16 171/17
terrible [4] 121/24
test [2] 16/21 116/20
testing [1] 33/24
text [3] 131/24
131/25 132/4
than [32] 10/20 19/17
24/24 25/6 35/25 37/5
37/13 41/6 45/18
49/20 52/7 53/14 54/5
61/24 63/7 66/12 75/8
92/10 97/9 100/8
109/11 1114/2 121/16
131/3 135/18 139/18
145/1 158/5 158/9
160/24 169/8 175/6
thank [46] 1/5 1/6
1/14 1/15 2/5 2/5 2/15
14/22 15/1 19/19 27/6
32/5 34/9 38/25 40/5
40/10 50/21 52/11
58/25 71/9 76/17 77/5
78/15 85/18 85/23
85/24 86/2 86/9 86/14
86/22 96/2 123/7
140/24 162/16 163/18
164/20 166/10 175/8
175/9 175/17 175/21
183/4 183/24 184/2
184/6 184/11
thanks [5] 51/16
135/9 137/14 137/21
149/25
that [1130]
that [3] 127/15
154/5 161/11
that's [116] 2/24 3/2
3/10 3/21 4/11 6/4 8/2
9/4 15/24 16/2 19/18
19/24 20/3 23/22 28/6I
28/21 28/23 29/22
30/7 35/24 36/13
36/17 37/18 38/24
40/1 40/3 40/17 41/13
44/2 44/25 45/25 46/4
46/5 48/2 48/3 49/1
50/11 51/25 53/24
55/6 60/15 62/8 63/12
71/5 76/12 77/24 78/1
79/11 79/19 80/9 82/8
85/21 85/21 87/21
88/18 88/22 89/13
90/2 90/6 91/23 92/13
97/18 98/10 99/3
102/12 108/8 108/22
116/16 119/7 119/9
124/47 122/11 122/11
123/20 124/13 125/18
126/21 127/5 127/7
130/11 134/14 140/13}
142/25 143/13 143/15]
145/11 145/13 145/19}
149/8 150/18 153/2
161/10 163/21 165/25}
167/3 167/4 170/3
170/41 170/14 172/22}
173/6 174/14 174/19
174/21 175/4 175/18
176/16 17/7 177/19
177/23 178/10 182/5
182/11 183/4 183/20
184/9
the' [1] 150/6
theft [5] 32/22 33/1
33/3 115/18 116/3
their [29] 10/18 50/9
56/21 70/18 77/8
83/13 83/25 84/17
94/11 98/16 99/17
107/7 115/19 116/5
116/12 118/3 118/24
121/22 125/20 127/21
129/20 133/12 153/8
153/8 155/6 155/15
156/23 170/4 175/24
them [27] 5/6 20/19
34/7 48/12 48/17
56/11 56/24 95/6 95/7
95/8 97/9 97/23
112/20 115/20 119/24)
124/17 125/3 137/15
137/16 138/10 148/12)
150/25 152/15 153/7
154/14 155/22 178/8
theme [1] 115/2
themselves [4] 66/13)
71/2 71/22 120/16
then [89] 3/3 3/8 3/24
7/8 7/14 7/18 11/16
14/20 15/9 16/1 18/6
25/15 26/13 27/3 27/4I
30/11 31/17 34/1
34/13 35/14 36/15
37/12 37/18 39/4 39/7
39/19 41/22 42/12
43/8 45/4 45/6 47/6
47/20 49/9 50/22 52/3)
55/16 58/17 60/6
63/22 64/8 70/15
76/20 76/25 77/23
80/21 81/19 86/4 89/5
89/14 91/16 94/19
94/21 95/20 115/7
115/13 128/7 130/1
132/11 132/24 133/5
133/13 133/15 134/8
136/10 136/19 137/11
137/20 139/5 140/15
141/9 142/10 143/4
145/17 146/3 146/7
147/13 149/11 154/2
155/9 155/18 159/16
164/23 165/4 167/14
168/12 171/4 171/18
174/9
theory [1] 45/12
there [194]
there'd [1] 140/5
there's [29] 1/19 29/5I
33/13 37/7 37/17
47/12 49/8 58/17 59/6
62/10 63/8 70/5 78/11
78/18 79/3 79/11
79/13 79/14 80/21
84/14 95/16 122/16
122/22 129/24 152/14)
167/1 169/14 171/7
173/19
thereabouts [1] 38/2
thereafter [1] 80/13
therefore [15] 5/24
7/12 10/1 14/16 17/1
22/2 27/18 37/1 49/17
70/25 73/19 81/13
112/13 151/1 172/25
therein [1] 40/22
these [27] 24/8 45/1
47/8 57/6 72/7 93/9
(75) suicide - these
T
these... [21] 101/11
101/21 105/7 115/2
115/4 115/17 118/10
121/2 121/7 125/1
125/17 126/24 126/24}
132/19 137/7 166/21
167/16 168/21 168/23
169/7 171/23
they [78] 2/14 8/21
21/3 49/12 49/19
49/24 50/2 70/3 70/3
70/4 70/10 70/13
71/21 72/16 81/23
81/24 82/8 82/19
83/14 90/8 90/17 91/7
97/12 100/20 107/11
107/12 113/4 115/1
115/16 115/17 115/19
116/8 118/2 120/1
120/23 121/3 121/4
121/8 121/13 125/8
126/16 127/24 129/6
129/15 129/17 129/18}
132/21 133/3 133/11
134/3 135/22 138/4
138/10 138/15 139/12
150/5 150/24 152/24
155/4 156/17 156/22
157/2 162/23 165/6
165/16 168/13 168/18}
175/16 177/18 177/20)
177/21 177/22 179/2
179/3 179/22 180/2
181/2 183/16
they'd [4] 115/25
they're [5] 55/17
82/10 91/12 125/1
155/22
they've [2] 84/16
177/22
thing [3] 43/22 76/4
150/23
things [20] 12/21
13/13 27/14 27/24
28/12 41/14 60/24
91/8 92/10 105/20
122/16 122/22 124/19}
129/8 131/11 167/9
171/23 172/22 176/18}
177/16
think [127] 5/19 6/14
6/23 7/7 9/9 10/2 11/5)
12/11 12/21 13/12
25/24 32/8 33/7 34/19
35/10 38/18 39/1
41/15 41/19 52/8 52/8
53/4 53/16 54/3 54/12,
55/3 55/12 55/24 61/3
62/2 65/17 66/10
66/14 67/17 67/19
68/13 70/1 70/16 72/9
75/4 75/19 75/21 76/1
76/5 76/8 77/15 78/1
79/11 80/2 82/25 86/6)
91/12 96/23 97/14
100/18 100/20 100/22!
102/5 103/3 104/9
107/19 110/14 111/1
111/5 111/25 113/17
114/2 117/17 117/17
120/1 120/13 122/13
122/15 123/3 125/11
125/18 125/24 126/2
126/2 126/6 126/17
129/3 132/18 136/2
136/10 141/17 141/22)
143/16 143/17 149/14)
151/19 151/21 151/22)
153/5 154/4 157/4
157/6 157/9 157/11
157/21 158/14 159/5
159/14 160/20 160/25)
161/7 161/13 161/16
161/25 164/15 166/15)
169/12 169/13 169/16)
170/11 170/17 171/24}
172/3 172/5 173/21
174/14 176/2 176/3
176/19 179/5 182/25
183/11
thinking [7] 53/12
67/16 103/17 121/18
122/3 150/19 182/12
third [5] 42/22 45/4
56/18 68/24 90/3
thirds [1] 93/12
this [300]
those [63] 8/1 10/20
15/7 21/3 25/3 26/5
31/21 34/5 38/8 38/9
53/9 53/18 54/22 57/8)
57/10 62/4 62/7 62/7
62/9 62/10 62/24
63/13 66/6 66/18
66/24 69/22 72/9 76/2
76/17 83/14 92/19
97/8 97/22 97/24 98/1
100/3 102/9 105/24
106/7 115/1 119/25
121/13 122/19 122/20)
124/19 125/9 126/7
133/24 135/15 135/24}
137/9 140/20 144/16
144/22 146/24 152/11
155/10 161/9 162/7
165/7 167/2 168/12
179/22
though [7] 9/6 18/24
19/2 19/15 56/8 160/2
172/13
thought [27] 4/18
37/14 39/21 66/1 68/8
68/10 72/16 85/3
102/9 110/24 119/23
129/15 131/14 131/15)
137/21 138/6 141/2
142/8 148/16 149/10
149/12 150/23 151/8
158/4 158/20 161/19
183/8
thoughts [4] 51/20
74/24 118/7 151/6
thread [1] 80/12
threaten [1] 124/6
three [13] 9/25 19/5
49/24 63/4 66/21
76/11 89/17 124/21
124/24 125/7 137/9
147/24 150/8
threshold [3] 15/14
15/15 15/17
through [29] 6/19
7/14 9/3 9/9 9/11 9/11
9/24 14/1 22/12 29/4
58/19 58/22 58/24
63/22 71/22 72/6
74/20 96/12 111/9
134/4 134/11 146/1
162/10 163/12 167/10
170/1 176/8 176/13
180/2
throughout [2] 75/10
83/7
Tidswell [3] 6/13
6/18 74/11
tied [1] 159/22
Tim [30] 4/17 20/1
28/7 28/8 28/13 32/6
34/20 34/24 35/11
36/10 37/2 37/7 37/15
39/4 39/10 43/11 45/3
51/20 60/8 60/10
60/22 60/25 61/12
61/13 61/19 101/4
138/25 139/1 146/4
153/7
Tim's [1] 39/12
time [152] 3/13 3/14
4/8 4/12 6/10 6/17
7/10 10/2 11/22 16/25
17/7 18/21 20/10
20/22 22/21 22/22
23/16 23/19 23/19
23/22 24/14 26/9 27/6
32/9 32/11 40/1 40/4
41/20 45/14 45/23
48/12 49/5 51/19
56/24 64/1 64/9 66/17
72/8 72/23 73/4 75/5
75/22 76/6 76/15 84/4
84/15 86/3 86/6 87/22
89/6 89/9 92/19 92/22
92/24 96/9 96/11
96/24 97/7 97/22 98/3
98/18 99/4 100/6
100/21 102/8 102/17
103/3 103/5 103/14
103/18 104/2 106/4
106/22 107/9 108/5
108/7 108/14 108/17
108/24 109/23 109/24,
109/24 110/1 111/4
111/7 113/22 116/22
118/6 118/23 119/18
120/4 121/18 121/25
122/2 122/14 122/18
122/18 125/1 125/3
125/22 126/18 126/25}
127/1 127/4 127/9
130/19 132/19 135/9
138/8 140/15 140/25
141/1 143/6 143/15
144/12 145/9 147/10
148/3 149/8 151/6
151/18 153/17 154/24}
155/22 156/15 157/9
157/10 157/25 158/12}
159/12 160/21 162/14}
164/15 164/16 169/2
169/4 170/19 170/24
1714/1 171/13 172/14
174/8 174/9 174/16
174/25 176/5 177/23
178/4 178/22 179/3
181/6 182/13
timely [4] 139/22
times [4] 72/15
133/19 142/20 167/24}
timing [2] 30/21
78/24
title [3] 43/5 49/2
99/9
TNT [2] 3/1 3/4
today [6] 1/16 79/8
84/21 85/10 162/13
178/14
together [3] 9/13
51/19 78/25
told [20] 37/22 38/13
38/15 43/10 44/21
50/12 50/14 77/19
116/20 120/19 121/9
122/6 128/16 130/25
148/7 148/20 162/23
169/4 169/7 171/21
Tolhurst [20] 86/15
86/16 86/19 86/20
87/10 104/21 130/1
142/19 150/1 162/7
163/2 164/12 167/13
168/20 175/8 175/22
183/5 183/6 184/2
185/9
Tolhurst's [9] 87/10
92/12 97/17 98/10
102/12 119/7 127/6
142/25 163/22
Tom [35] 10/14 10/16
10/16 29/6 34/10 36/9}
36/18 36/24 37/1 37/6
37/13 37/14 37/25
38/7 39/3 39/20 40/16)
40/17 42/6 42/9 42/11
43/10 64/2 64/4 64/9
70/7 78/18 135/3
136/12 138/22 143/1
143/6 149/22 152/15
181/15
tomorrow [2] 153/1
184/8
tone [3] 44/16 52/3
52/5
too [2] 82/1 85/25
took [11] 52/4 66/25
67/1 68/21 77/15
77125 91/17 102/23
104/25 120/19 148/1
tools [1] 81/25
top [19] 9/7 18/3 18/5)
20/23 29/21 39/3 58/7
91/24 94/23 99/8
105/1 121/15 124/7
124/11 132/1 132/6
132/10 134/21 154/19)
top-line [2] 18/3 18/5
topic [7] 14/23 28/6
48/18 52/12 60/16
141/14 167/14
Tosin [1] 135/3
totally [1] 31/5
touch [3] 61/15 71/11
142/20
touched [1] 106/2
touching [2] 105/18
105/19
towards [13] 11/17
20/20 56/19 82/15
90/14 99/10 123/17
129/24 132/9 135/1
136/10 163/6 179/16
trading [1] 128/10
trail [3] 43/13 43/13
44/1
train [4] 101/22
training [2] 75/20
87/22
transaction [1] 33/19
transactions [5]
46/19 59/14 59/15
130/21 165/7
transcriber [3] 76/24
76/25 95/25
transcript [1] 87/9
Transport [1] 88/21
Treasury [2] 88/4
176/15
treated [1] 154/22
trial [38] 12/22 45/8
46/13 52/2 52/14
52/24 54/18 54/21
54/21 65/3 65/5 65/8
65/9 65/11 65/16 66/7
66/11 67/17 68/7
68/12 81/7 114/10
136/16 136/21 139/8
139/14 140/9 140/10
140/13 140/17 140/19)
140/23 141/9 141/10
(76) these... - trial
T
trial... [4] 141/13
141/15 141/18 169/5
trial’ [2] 101/9 101/10
trials [1] 101/19
tried [3] 73/1 73/16
148/1
troubles [1] 103/9
true [5] 2/12 147/8
172/9 172/24 180/16
truly [1] 40/20
trust [5] 59/8 69/6
69/20 73/20 174/18
trusted [2] 75/15
174/5
truthful [1] 119/3
try [17] 8/13 27/16
27/20 28/12 49/11
49/23 69/20 69/21
71/15 71/17 71/19
71/25 73/2 96/12
149/10 154/5 174/24
trying [17] 9/13 50/1
51/4 68/5 69/2 72/18
73/5 73/5 73/5 73/6
73/11 110/25 118/7
131/6 131/7 141/21
174/20
turn [20] 1/18 2/6
17/11 19/20 20/19
21/11 22/3 29/19
32/13 33/13 40/17
44/12 45/9 46/15 49/7
49/25 68/25 87/3
128/23 151/15
Turning [2] 65/2
91/16
turnover [2] 15/22
15/24
two [30] 3/24 4/9
5/22 5/24 9/23 19/5
28/12 33/16 41/1
43/16 70/11 71/1 72/1
72/13 74/16 75/7 76/5)
76/8 76/11 77/9 86/5
91/22 93/12 97/24
105/4 106/25 119/10
133/19 140/20 176/2
two-thirds [1] 93/12
type [3] 60/24 173/18
173/23
types [2] 27/24 175/5
Typically [1] 15/10
U
UK [2] 90/1 93/14
UKGI [33] 7/18 10/13
34/12 69/13 98/3 98/6
99/21 101/2 105/2
105/12 110/16 134/4
134/9 134/19 135/4
135/14 137/24 138/18
138/22 138/22 142/13}
142/21 146/2 146/18
147/18 150/3 156/21
161/2 161/3 170/6
176/8 176/13 181/16
UKGI's [2] 134/4
134/5,
UKGI00008342 [1]
93/11
UKGI00008554 [1]
129/23
UKGI00009321 [1]
152/12
UKGI00009455 [1]
138/21
UKGI00012155 [1]
39/1
UKGI00012703 [1]
34/10
UKGI00018266 [1]
99/8
UKGI00021096 [1]
131/21
UKGI00021771 [1]
134/25
ultimately [5] 103/3
139/23 158/1 170/3
183/14
Um [1] 122/15
unable [1] 180/24
unanimous [1] 64/11
unanimously [2]
61/18 68/3
unaware [2] 14/15
147/15
unawareness [3]
40/20 41/15 41/22
unawares [1] 14/19
Unclear [1] 55/7
undated [1] 104/22
under [24] 22/3 34/2
52/19 76/8 88/8 88/20
88/23 89/11 89/15
91/18 94/7 95/19
96/17 98/21 108/11
114/20 115/11 132/20)
134/5 139/5 149/19
154/17 164/12 183/12)
Under-Secretary [10]
88/8 88/20 88/23
89/11 89/15 91/18
96/17 108/11 132/20
164/12
underlying [1] 67/12
undermine [2] 32/23
59/8
undermines [1]
22/15
underneath [1] 99/12
understand [21] 1/19
2/2 4/8 6/24 19/4 38/7
57/1 58/4 60/1 60/13
67/1 107/21 111/19
113/25 116/17 117/9
121/2 129/5 129/13
151/1 164/3
understanding [15]
6/23 17/8 26/4 27/20
36/2 64/10 103/13
128/5 128/20 129/16
130/19 153/25
understood [16]
64/20 64/23 89/16
92/19 92/24 93/2
110/15 111/5 119/11
119/22 120/4 128/11
130/25 131/4 162/16
166/10
undertaken [1] 31/15
underway [2] 33/24
114/11
unfair [1] 145/13
unfairly [1] 154/22
unfettered [1] 144/17
Unique [1] 2/17
units [1] 18/4
unlawfully [1] 180/19
unless [4] 15/14
145/2 151/15 152/9
unreliable [1] 121/23
unsafe [3] 16/18
16/20 16/22
unsure [1] 137/8
until [11] 21/3 28/10
28/19 29/13 89/7
129/19 132/17 152/25)
159/9 177/11 184/13
unwilling [1] 128/21
unwillingness [1]
83/17
up [71] 4/17 11/7
15/1 18/16 19/20 24/4]
26/11 29/15 32/5 34/9
35/1 35/17 36/12 39/1
40/11 49/24 50/2 50/7
51/13 52/13 52/14
54/5 61/16 69/6 76/4
76/14 78/16 78/22
80/11 82/24 83/21
84/18 87/19 91/7
91/17 94/1 101/2
101/15 106/9 108/19
109/8 111/23 118/8
124/11 127/23 128/5
129/23 130/21 133/17
134/16 136/19 140/22
141/12 141/16 142/22)
151/15 157/7 158/8
161/1 161/12 166/3
166/17 171/17 171/20
172/1 172/7 175/10
176/16 176/24 180/17]
182/18
upcoming [1] 45/7
update [18] 25/10
25/10 34/16 51/18
93/24 99/10 99/18
99/25 134/4 134/11
106/22 111/23 113/19}
137/24 137/25 138/5
143/2 167/6
updated [4] 15/16
25/13 95/14 141/23
updates [19] 24/6
24/8 24/17 25/1 25/3
95/19 99/12 135/14
135/23 135/25 136/7
136/9 136/17 136/24
137/4 138/11 139/11
141/5 143/3
updating [1] 82/10
upheld [1] 55/12
upon [3] 53/24 58/11
110/20
upwards [1] 53/15
us [18] 1/4 23/11
23/19 27/24 40/9
47/20 58/7 63/20
83/14 86/6 86/13
123/4 176/17 183/17
use [6] 15/23 16/2
53/1 53/19 59/17
113/18
used [10] 41/22
50/17 62/8 81/22
81/23 120/7 132/5
165/8 172/19 183/21
useful [3] 137/18
137/25 140/6
user [1] 119/15
usher [1] 145/25
using [6] 12/5 16/18
53/5 57/6 59/14
180/22
usual [1] 107/22
usually [1] 115/17
Vv
value [3] 119/5
120/19 130/17
valued [1] 127/14
various [10] 18/1
33/14 34/12 42/20
51/11 57/2 78/13
Vennells [13] 80/13
80/24 82/9 101/5
105/8 105/15 105/18
106/12 106/16 107/1
107/5 107/17 112/9
Vennells' [1] 83/1
venture [1] 75/23
verbal [6] 25/2 25/3
25/8 25/9 135/14
135/23
verbally [2] 25/13
37/25
Veronica [2] 40/12
42/14
version [1] 29/23
very [91] 5/25 20/6
136/20 137/16 137/17)
65/16 66/22 73/3 79/5)
119/24 171/11 171/13)
21/11 24/12 27/12
27/13 27/14 28/5 29/2I
37/10 47/5 51/2 52/20)
53/7 57/13 57/23 58/4
58/10 58/19 58/20
61/12 63/18 64/23
66/14 66/19 67/21
68/14 69/6 69/13
69/25 70/3 70/23
72/22 73/7 73/10
73/11 73/12 73/19
74/13 74/19 75/6 75/9}
78/8 80/13 82/1 83/3
84/15 85/1 85/18 86/1
105/19 112/23 113/21
114/2 116/12 117/22
120/14 120/18 124/9
124/10 127/13 131/17)
137/22 139/4 143/22
147/23 149/9 151/6
152/10 153/17 153/18)
154/4 158/6 158/13
162/1 163/3 163/8
164/16 166/10 167/15)
167/25 172/21 176/22)
178/6 178/10 179/14
181/6 182/19 183/24
184/3 184/4
via [2] 101/5 137/2
victory [3] 54/1 54/2
54/4
video [1] 101/5
view [34] 8/13 8/16
12/3 31/19 52/3 55/10}
55/17 58/13 58/14
64/5 64/14 64/18
65/13 65/24 67/5 68/6
73/13 76/20 90/25
91/11 98/16 99/17
99/24 108/8 122/11
126/16 142/8 144/20
147/21 147/22 149/6
150/22 151/4 151/11
viewed [2] 75/15
112/13
views [16] 39/20 45/9)
55/25 66/3 66/25
67/18 73/23 74/4 74/6I
99/2 102/6 117/1
117/2 118/7 120/25
158/7
visible [3] 87/4 121/8
121/20
visited [1] 18/7
visits [2] 17/15 18/6
volunteer [1] 107/12
vote [2] 64/3 64/15
voted [1] 68/3
Wo
wait [1] 55/24
walked [1] 139/2
want [38] 5/17 7/16
14/23 28/6 28/12
(77) trial... - want
Wo
want... [33] 29/15
33/16 42/6 52/12 60/6
61/15 68/20 71/10
77/13 77/14 80/23
83/9 91/6 140/18
142/5 143/18 143/25
144/2 144/14 150/5
150/14 153/6 154/13
169/1 169/18 173/23
175/14 177/9 177/13
177/25 178/20 180/16
181/7
wanted [21] 42/3
69/6 96/25 107/21
113/18 113/22 128/2
129/5 131/17 139/17
140/3 143/2 144/1
145/11 149/14 149/15
176/25 177/1 177/1
177/10 181/18
wanting [2] 108/7
143/21
wants [1] 137/16
ward [1] 87/25
warned [1] 166/25
was [653]
wasn't [48] 5/14 5/15
8/9 14/18 21/17 22/1
28/2 28/15 35/21 36/4
36/25 41/5 61/5 62/16
63/8 64/24 68/15
70/25 74/2 82/23 84/9
85/16 100/10 106/12
108/24 112/8 113/8
118/23 122/2 122/2
138/2 139/7 141/5
143/22 145/8 146/13
151/19 156/24 157/17)
161/4 161/5 172/9
177/11 180/22 182/1
182/16 182/23 183/3
watch [1] 167/21
Watson [2] 136/12
137/11
way [30] 7/3 9/2
12/19 31/21 34/2
41/25 47/1 51/23
61/25 64/12 78/9 80/6
93/13 107/15 110/12
113/23 113/24 121/4
127/5 127/22 133/4
141/12 141/18 141/23}
151/2 160/14 161/1
161/12 163/16 180/15
ways [3] 8/22 73/2
167/24
WBON0001756 [1]
149/21
we [317]
we'll [10] 1/23 14/23
40/13 40/17 83/3
136/18 141/13 173/4
181/17 184/7
we're [7] 6/23 38/2
61/2 140/18 162/9
177/15 181/1
we've [12] 2/11 16/3
56/19 63/18 71/12
98/21 119/9 140/16
166/3 166/24 167/9
177/12
weaken [1] 155/15
weakness [1] 165/25
weaknesses [1]
165/15
website [2] 2/16
87/12
Wednesday [2] 1/1
138/25
week [6] 3/15 3/16
50/22 60/13 136/18
136/22
week's [1] 136/19
weekend [2] 3/17
3/18
weekly [5] 135/13
135/19 135/22 137/4
145/10
weeks [2] 94/15
140/11
weighed [1] 91/7
welcome [2] 70/3
73/17
well [54] 3/17 3/18
TINT 13/3 14/22 21/12
31/14 35/19 39/4 43/8
45/4 53/22 58/6 60/24
66/24 67/10 67/17
73/25 81/12 82/17
85/23 98/25 99/1
101/6 102/3 103/2
103/7 105/11 105/22
126/17 128/25 130/19)
141/8 142/5 143/12
143/16 144/10 145/7
149/4 153/23 154/24
156/23 157/16 161/12)
161/20 167/4 168/21
169/6 169/13 171/24
174/2 182/25 183/11
184/2
went [6] 9/11 39/20
88/19 95/9 108/25
158/6
were [213]
weren't [9] 31/2
45/21 48/21 63/9
82/17 100/10 132/19
157/16 157/16
West [1] 87/25
what [213]
what -- you [1] 174/8
what's [8] 36/21 48/3
79/19 91/15 108/8
113/25 142/9 168/5
whatever [2] 156/21
173/
when [108] 3/22 5/18
6/21 7/9 7/10 9/15
10/23 13/19 14/14
14/16 15/13 16/11
16/23 17/4 17/21
18/19 18/22 19/7 19/8}
19/10 19/12 19/17
20/18 21/15 21/20
21/22 22/19 22/21
22/24 23/2 23/8 23/15)
23/20 23/21 25/3 25/4
28/8 28/13 28/17
28/23 28/24 29/4
30/16 32/11 36/9 41/3
41/14 43/2 44/1 47/22
48/24 50/15 52/1
52/16 53/3 53/11
54/11 56/8 58/1 62/1
62/12 63/18 63/19
67/1 67/16 74/6 74/23,
75/6 79/4 89/10 89/15
90/3 90/25 91/12
91/17 92/2 97/8 97/10
97/11 100/3 102/4
104/23 107/10 108/4
108/10 108/13 108/22
114/16 117/9 117/16
118/19 121/8 128/10
130/25 130/25 131/24]
140/9 142/11 143/10
147/18 157/10 157/19!
161/23 163/6 168/7
169/6 174/4 175/11
where [36] 8/22 9/10
31/1 48/4 49/12 49/23
50/2 55/18 58/13
77/16 78/1 78/16
79/13 81/3 88/10 91/7,
100/9 117/18 117/22
118/15 134/4 139/1
145/6 147/4 159/16
161/17 169/8 172/3
172/4 172/10 172/17
177/17 178/7 179/21
181/2 182/12
whereby [1] 168/22
whether [35] 23/11
24/10 25/8 30/19
32/22 33/18 33/21
46/17 49/3 49/19
64/18 68/5 68/7 68/10
76/20 96/19 102/8
116/19 120/4 121/7
121/9 121/21 127/25
143/13 148/21 150/20}
152/5 153/3 160/16
160/19 174/23 175/16
177/19 181/10 181/19}
which [115] 5/3 7/4
14/24 15/5 19/9 21/6
22/7 22/15 24/7 29/6
29/18 30/2 31/24
whatsoever [1] 68/16
32/25 33/1 37/11
44/10 44/14 44/23
59/7 64/23 66/22
67/23 71/10 71/19
81/24 82/16 84/13
84/15 85/2 86/24
87/14 88/17 89/25
91/2 93/7 93/12 96/3
96/5 96/13 96/20
96/20 96/23 97/20
98/4 99/24 100/16
100/16 101/8 101/25
104/1 105/5 105/10
105/11 107/1 109/18
111/25 112/2 115/16
115/25 117/10 118/13
120/4 120/7 121/16
123/3 125/6 126/2
128/9 128/23 129/25
132/11 132/13 132/22}
132/24 134/14 136/13}
140/15 146/6 146/17
151/5 151/9 152/1
152/15 155/1 156/25
159/6 159/8 160/14
163/12 170/19 173/17]
175/2 175/5 175/15
176/17 178/8 180/18
183/8
while [2] 94/16
115/18
whilst [12] 4/5 4/10
106/20 112/19 114/1
128/10 151/4 153/18
158/20 161/8 168/14
177/18
Whip [2] 88/4 89/2
whistleblowing [1]
145/3
white [2] 123/22
135/6
who [57] 5/23 6/10
6/15 10/15 17/22 19/4)
19/11 22/8 33/20
42/24 49/18 49/20
50/16 56/3 58/1 58/2
58/2 58/3 71/2 73/1
74/11 76/23 77/7 80/4
82/8 83/12 83/14
83/25 84/22 89/14
89/18 89/22 89/25
93/19 94/3 94/14
104/15 110/21 114/24)
126/25 135/6 137/9
139/4 139/23 142/23
146/24 150/25 154/1
154/22 167/16 169/9
169/12 169/18 171/16}
174/2 175/23 182/2
who's [1] 6/9
38/14 40/17 42/6 43/5)
46/1 46/25 49/9 49/25
50/12 51/5 51/10 57/8)
72/8 77/21 78/8 81/12,
whoever [1] 145/5
whole [9] 52/23
62/19 82/9 84/13 92/6I
112/23 143/23 169/15)
172/15
wholly [2] 178/9
178/23
whom [2] 40/21
128/19
whose [1] 7/23
why [44] 5/11 5/13
6/24 20/7 21/24 24/18)
25/11 25/15 26/8
37/18 44/16 44/23
50/14 62/2 62/8 62/13
62/21 62/24 63/1
64/22 77/21 90/23
98/24 100/23 102/23
108/22 112/8 112/13
116/16 118/22 118/24I
127/14 129/13 141/23}
144/2 147/6 158/1
158/6 158/22 161/21
173/25 176/16 180/25)
181/25
wide [3] 118/14
119/12 144/10
widely [3] 79/20
119/14 170/5
wider [1] 23/15
widespread [1] 93/3
will [43] 1/6 2/16 12/4I
15/4 15/13 17/14
17/15 32/9 32/21
49/12 49/18 49/19
55/12 58/22 74/22
79/5 81/16 86/5 86/21
87/11 87/13 94/12
101/6 101/12 106/18
131/25 132/5 134/10
134/18 137/15 150/2
150/4 150/5 153/6
158/19 159/6 159/7
162/23 168/10 170/19)
174/23 178/4 178/6
willing [3] 107/10
127/20 145/5
win [2] 55/18 58/20
wise [1] 137/22
wish [4] 2/2 49/20
122/22 147/11
wished [2] 109/16
136/24
wishes [1] 154/24
withholding [1]
165/19
within [23] 23/17
33/23 90/5 91/4 92/8
92/9 104/12 108/18
110/8 138/19 141/20
144/13 145/6 148/14
148/23 149/1 156/20
158/10 161/7 162/14
165/13 166/2 168/1
(78) want... - within
Ww
without [8] 34/4 58/3
120/20 121/23 125/24}
167/12 172/6 181/4
WITN10010100 [1]
29/16
WITN10020100 [1]
2/18
WITN10930100 [1]
87/10
witness [21] 1/12
3/23 15/19 19/20
21/24 22/16 26/16
29/15 29/16 31/7
47/25 50/6 50/24
85/23 87/11 89/24
95/24 166/23 177/12
182/21 184/3
witnesses [9] 62/18
65/15 66/6 66/6 66/7
66/12 66/25 67/6
68/11
women [1] 180/20
won't [4] 95/11
155/22 159/12 178/3
wonder [3] 40/2 86/4
162/8
word [3] 16/2 31/22
64/13
worded [1] 37/12
wording [7] 146/16
146/18 146/21 146/22)
147/5 147/6 147/12
words [12] 11/21
41/22 53/1 53/3 53/19
62/7 62/8 62/9 62/10
63/17 95/25 183/20
work [29] 3/17 3/18
11/14 30/21 31/15
33/4 33/23 33/25 34/2
34/6 35/1 35/3 35/17
36/12 42/20 44/11
54/17 54/18 55/20
55/21 56/13 73/6
79/10 84/4 86/23
161/9 167/24 172/16
181/3
worked [6] 6/2 54/19
81/12 90/1 166/15
171/17
working [11] 26/24
72/12 74/1 74/2 82/18
127/1 144/25 166/11
170/10 179/16 180/2
workstreams [2]
12/15 71/17
worries [1] 125/21
worry [1] 103/11
worrying [1] 150/20
worst [1] 126/23
worst-case [1]
126/23
worthy [2] 99/22
100/2
would [229]
wouldn't [12] 7/12
25/11 120/11 120/12
120/12 142/8 145/9
148/16 153/20 168/16)
168/17 179/18
write [1] 179/22
writes [2] 79/3 109/2
writing [2] 82/9 158/4I
written [7] 1/15 20/14I
25/18 79/19 82/7
111/10 135/14
wrong [13] 36/23
46/5 53/22 53/23 73/3
100/8 110/12 150/23
157/8 169/8 172/20
174/24 182/4
wronged’ [1] 146/25
wrongful [1] 121/21
wrongly [1] 114/25
Wyn [3] 140/24
175/17 183/13
Y
yeah [36] 91/25 92/3
93/8 95/8 97/7 97/13
97/15 109/19 110/3
111/9 113/10 122/11
122/12 122/18 128/14)
132/2 137/8 138/5
145/4 154/25 155/21
157/5 160/7 160/10
161/25 162/1 166/9
167/23 168/25 169/19)
171/10 173/14 177/14)
177/24 181/13 183/16)
year [3] 6/7 51/12
74/9
yearly [1] 9/3
years [8] 3/23 9/25
19/6 20/12 38/2 75/16
87/20 180/20
years' [1] 11/22
yellow [1] 99/21
yes [132] 1/5 2/4 4/15
4/19 4/20 4/24 5/9
5/21 6/12 6/20 7/6
7/15 7/22 9/9 13/1
13/23 13/23 14/1 16/8)
19/24 21/8 22/9 23/10
23/10 25/3 29/2 33/9
38/24 40/3 40/10 42/4
43/24 44/1 44/25 45/4
45/5 46/9 48/13 50/11
54/12 56/9 56/12
56/15 60/1 61/7 61/10)
67/3 67/4 67/25 76/22
77/2 77124 78/5 78/15
79/19 80/16 81/1
85/21 86/20 87/6 88/3
88/15 89/13 89/21
90/2 91/23 92/3 92/6
92/21 92/22 93/22
95/2 95/6 95/24 95/24
98/8 100/19 101/20
101/23 106/8 106/13
110/3 112/12 112/16
114/18 115/25 116/1
116/4 116/7 116/10
116/13 117/12 117/15}
121/6 121/6 121/24
122/22 123/2 123/6
123/7 123/12 130/10
135/16 146/14 146/20
147/20 151/14 157/11
160/1 161/10 162/11
166/6 166/8 166/13
166/14 166/14 166/19)
175/17 175/19 176/16}
179/5 179/6 179/6
179/6 179/13 179/19
179/24 180/4 180/7
180/10 181/22 183/23
yesterday [2] 39/9
135/9
yet [1] 139/20
you [976]
you'd [9] 42/1 97/20
118/19 143/3 151/15
164/14 164/15 178/22
183/8
you'll [5] 51/20 77/12
157/7 163/21 164/10
you're [36] 8/3 11/8
12/21 18/17 20/22
35/5 35/6 39/4 53/25
56/18 65/17 67/16
68/16 68/24 80/17
90/25 91/2 113/5
130/8 135/18 163/8
163/22 165/13 165/23
165/25 166/16 166/25)
168/5 170/15 170/17
171/5 171/13 173/16
176/7 179/5 182/13
you've [26] 32/8
38/23 47/20 48/4 54/9
73/13 81/4 84/21
84/24 102/10 114/13
149/8 166/3 166/15
166/15 166/20 170/22
173/8 173/19 173/20
174/9 178/14 178/18
178/19 179/7 182/20
your [189]
yourself [3] 14/10
116/19 164/12
Zebra [1] 41/2
zoom [1] 123/19
(79) without - zoom